Adelanto City Council
May 13, 2026

416
Geo-Monitor, Inc.

Project:

Client:

Reported:

Received:

Sampled:

Sampler:

Sub Project: Monthly - Distribution System
11780 Air Expressway
Adelanto CA, 92301
System:

Fax:

Phone:

Contact:
(620) 474-7310
Woodard & Curran - Adelanto Water
Adelanto Water
Chris Mcmahon
CA3610001
02/05/2026
Edward Rodriguez
02/05/2026 14:40
02/12/2026
Result Analyte Method Units Prepared Analyzed Batch
11099 Star St G26B110-10 (Water) Sample Date: 02/05/26 11:52 Sampler: Edward Rodriguez Rep. Limit Qualifier
Field Analyses
Cl Res Free (Field) Field 0.73 mg/L 02/06/26 02/06/26 2606048 General Physical Analyses
Apparent Color SM 2120BM <3.0 Color Units 3.0 02/05/26 02/05/26 2606049 Odor Threshold EPA 140.1-M 1 1 TON 02/05/26 02/05/26 2606049 Turbidity EPA 180.1 <0.1 NTU 0.10 02/05/26 02/05/26 2606049 P.O. Box 401428 Hesperia, CA 92340. 760-244-3481. ELAP Number 2691 Page 2 of 3 Kristal Escobar
Laboratory Supervisor

417

418
Geo-Monitor, Inc.

Project:

Client:

Reported:

Received:

Sampled:

Sampler:

Sub Project: Week 2 Distribution System
11780 Air Expressway
Adelanto CA, 92301
System:

Fax:

Phone:

Contact:
(620) 474-7310
Woodard & Curran - Adelanto Water
Adelanto Water
Chris Mcmahon
CA3610001
02/10/2026
Edward Rodriguez
02/10/2026 15:22
02/13/2026

RESULTS
Laboratory
ID
Sample
Location
Sample
Time
E. Coli
P/A
Total Coliform
P/A
Cl Res (Field)
mg/L
Plate Count
CFU/ml
G26B165-01 09:50 11815 Hardy Ave 1.11 A A <1
G26B165-02 10:23 10518 Chevron 1.20 A A 1
G26B165-03 10:21 10407 Vintage 1.31 A A <1
G26B165-04 11:20 9351 Industrial 0.43 A A <1
G26B165-05 11:36 15620 Joshua Road (High School) 0.46 A A <1 G26B165-06 11:45 10850 Rose Place 0.47 A A <1
G26B165-07 12:01 14283 Ivy St 0.42 A A <1
G26B165-08 12:25 14202 Sandy Ridge Ct 0.45 A A <1
G26B165-09 09:06 11688 Begonia Rd 0.43 A A <1
G26B165-10 08:36 11771 Dana Dr 0.40 A A <1
A - Absence of Bacteria
P - Presence of Bacteria
P.O. Box 401428 Hesperia, CA 92340. 760-244-3481. ELAP Number 2691 Page 1 of 3 Kristal Escobar
Laboratory Supervisor

419
Geo-Monitor, Inc.

Project:

Client:

Reported:

Received:

Sampled:

Sampler:

Sub Project: Week 2 Distribution System
11780 Air Expressway
Adelanto CA, 92301
System:

Fax:

Phone:

Contact:
(620) 474-7310
Woodard & Curran - Adelanto Water
Adelanto Water
Chris Mcmahon
CA3610001
02/10/2026
Edward Rodriguez
02/10/2026 15:22
02/13/2026
Result Analyte Method Units Prepared Analyzed Batch
10407 Vintage G26B165-03 (Water) Sample Date: 02/10/26 10:21 Sampler: Edward Rodriguez Rep. Limit Qualifier
Field Analyses
Cl Res Free (Field) Field 1.31 mg/L 02/10/26 02/10/26 2607026 General Physical Analyses
Apparent Color SM 2120BM <3.0 Color Units 3.0 02/11/26 02/11/26 2607049 Odor Threshold EPA 140.1-M 1 1 TON 02/11/26 02/11/26 2607049 Turbidity EPA 180.1 0.20 0.10 NTU 02/11/26 02/11/26 2607049 P.O. Box 401428 Hesperia, CA 92340. 760-244-3481. ELAP Number 2691 Page 2 of 3 Kristal Escobar
Laboratory Supervisor

420

421
Geo-Monitor, Inc.

Project:

Client:

Reported:

Received:

Sampled:

Sampler:

Sub Project: Week 3 Distribution System
11780 Air Expressway
Adelanto CA, 92301
System:

Fax:

Phone:

Contact:
(620) 474-7310
Woodard & Curran - Adelanto Water
Adelanto Water
Chris Mcmahon
CA3610001
02/17/2026
Salvador Ruiz
02/17/2026 15:17
02/20/2026

RESULTS
Laboratory
ID
Sample
Location
Sample
Time
E. Coli
P/A
Total Coliform
P/A
Cl Res (Field)
mg/L
Plate Count
CFU/ml
G26B253-01 10:25 12070 Chamberlain 0.80 A A <1
G26B253-02 10:38 17900 Jonathan 0.86 A A <1
G26B253-03 11:02 10176 Kemper 1.23 A A <1
G26B253-04 12:31 14277 Nicoles Way 0.41 A A <1
G26B253-05 12:09 11579 Villa St 0.35 A A <1
G26B253-06 11:36 14984 Huntington St 0.29 A A <1
G26B253-07 11:50 15083 Arcadian St 0.31 A A <1
G26B253-08 11:27 11747 Cloverlawn 0.38 A A <1
G26B253-09 09:51 16880 Sportsmen Center Dr 1.01 A A <1
G26B253-10 10:07 12191 Violet Rd 0.86 A A <1
A - Absence of Bacteria
P - Presence of Bacteria
P.O. Box 401428 Hesperia, CA 92340. 760-244-3481. ELAP Number 2691 Page 1 of 3 Kristal Escobar
Laboratory Supervisor

422
Geo-Monitor, Inc.

Project:

Client:

Reported:

Received:

Sampled:

Sampler:

Sub Project: Week 3 Distribution System
11780 Air Expressway
Adelanto CA, 92301
System:

Fax:

Phone:

Contact:
(620) 474-7310
Woodard & Curran - Adelanto Water
Adelanto Water
Chris Mcmahon
CA3610001
02/17/2026
Salvador Ruiz
02/17/2026 15:17
02/20/2026
Result Analyte Method Units Prepared Analyzed Batch
11579 Villa St G26B253-05 (DW) Sample Date: 02/17/26 12:09 Sampler: Salvador Ruiz Rep. Limit Qualifier
Field Analyses
Cl Res Free (Field) Field 0.35 mg/L 02/17/26 02/17/26 2608030 General Physical Analyses
Apparent Color SM 2120BM <3.0 Color Units 3.0 02/18/26 02/18/26 2608049 Odor Threshold EPA 140.1-M 1 1 TON 02/18/26 02/18/26 2608049 Turbidity EPA 180.1 <0.1 NTU 0.10 02/18/26 02/18/26 2608049 P.O. Box 401428 Hesperia, CA 92340. 760-244-3481. ELAP Number 2691 Page 2 of 3 Kristal Escobar
Laboratory Supervisor

423

424
Geo-Monitor, Inc.

Project:

Client:

Reported:

Received:

Sampled:

Sampler:

Sub Project: Week 4 Distribution System
11780 Air Expressway
Adelanto CA, 92301
System:

Fax:

Phone:

Contact:
(620) 474-7310
Woodard & Curran - Adelanto Water
Adelanto Water
Chris Mcmahon
CA3610001
02/26/2026
Edward Rodriguez
02/26/2026 13:12
03/03/2026

RESULTS
Laboratory
ID
Sample
Location
Sample
Time
E. Coli
P/A
Total Coliform
P/A
Cl Res (Field)
mg/L
Plate Count
CFU/ml
G26B391-01 07:51 11000 Cortez Ave 0.95 A A <1
G26B391-02 08:15 10518 Chevron 0.53 A A <1
G26B391-03 08:47 9957 Payne 0.51 A A <1
G26B391-04 09:05 17451-2 Raccoon Ave 0.52 A A <1
G26B391-05 09:30 9351 Industrial 0.47 A A <1
G26B391-06 10:00 10850 Rose Place 0.39 A A <1
G26B391-07 10:31 10814 Pemberton 0.43 A A 1
G26B391-08 11:01 10668 Thorndale 0.45 A A <1
G26B391-09 11:26 14283 Ivy St 0.48 A A <1
G26B391-10 11:48 10982 Wilson Ave 0.50 A A <1
A - Absence of Bacteria
P - Presence of Bacteria
P.O. Box 401428 Hesperia, CA 92340. 760-244-3481. ELAP Number 2691 Page 1 of 3 Kristal Escobar
Laboratory Supervisor

425
Geo-Monitor, Inc.

Project:

Client:

Reported:

Received:

Sampled:

Sampler:

Sub Project: Week 4 Distribution System
11780 Air Expressway
Adelanto CA, 92301
System:

Fax:

Phone:

Contact:
(620) 474-7310
Woodard & Curran - Adelanto Water
Adelanto Water
Chris Mcmahon
CA3610001
02/26/2026
Edward Rodriguez
02/26/2026 13:12
03/03/2026
Result Analyte Method Units Prepared Analyzed Batch
11000 Cortez Ave G26B391-01 (Water) Sample Date: 02/26/26 7:51 Sampler: Edward Rodriguez Rep. Limit Qualifier
Field Analyses
Cl Res Free (Field) Field 0.95 mg/L 02/26/26 02/26/26 2609039 General Physical Analyses
Apparent Color SM 2120BM <3.0 Color Units 3.0 02/26/26 02/26/26 2609041 Odor Threshold EPA 140.1-M 1 1 TON 02/26/26 02/26/26 2609041 Turbidity EPA 180.1 <0.1 NTU 0.10 02/26/26 02/26/26 2609041 P.O. Box 401428 Hesperia, CA 92340. 760-244-3481. ELAP Number 2691 Page 2 of 3 Kristal Escobar
Laboratory Supervisor

426

427
Woodard & Curran - Adelanto Water
Adelanto, CA 92301
11780 Air Expressway
Chris Mcmahon
13 February 2026
Sincerely,
Geo-Monitor Lab No.: G26B108
Enclosed are the results of the analyses for sample(s) received at the laboratory on 02/05/26 . These sample(s) were analyzed at a sub-contract laboratory, with the final reports indicating the analyzing/reporting laboratory.

If applicable, these final reports will also indicate any state EDT transfer that has occurred. Please call if any additional information and/or assistance are needed.

Thank you for choosing Geo-Monitor, Inc for your analytical needs.

Project Name: Adelanto Water
Kristal Escobar
Laboratory Supervisor
Geo-Monitor, Inc.

428
Geo-Monitor, Inc.

Project:

Client:

Reported:

Received:

Sampled:

Sampler:

Sub Project: Monthly - I&M Treatment Plant
11780 Air Expressway
Adelanto CA, 92301
System:

Fax:

Phone:

Contact:
(620) 474-7310
Woodard & Curran - Adelanto Water
Adelanto Water
Chris Mcmahon
CA3610001
02/05/2026
Salvador Ruiz
02/05/2026 14:15
02/13/2026

RESULTS
Laboratory
ID
Sample
Location
Sample
Time
E. Coli
P/A
Total Coliform
P/A
Cl Res (Field)
mg/L
Plate Count
CFU/ml
G26B108-01 08:09 Filter Effluent 1.40 A A <1
G26B108-02 07:33 Front Pump House 1.64 A A <1
A - Absence of Bacteria
P - Presence of Bacteria
P.O. Box 401428 Hesperia, CA 92340. 760-244-3481. ELAP Number 2691 Page 2 of 5 Kristal Escobar
Laboratory Supervisor

429
Geo-Monitor, Inc.

Project:

Client:

Reported:

Received:

Sampled:

Sampler:

Sub Project: Monthly - I&M Treatment Plant
11780 Air Expressway
Adelanto CA, 92301
System:

Fax:

Phone:

Contact:
(620) 474-7310
Woodard & Curran - Adelanto Water
Adelanto Water
Chris Mcmahon
CA3610001
02/05/2026
Salvador Ruiz
02/05/2026 14:15
02/13/2026
Result Analyte Method Units Prepared Analyzed Batch
Filter Effluent G26B108-01 (DW) Sample Date: 02/05/26 8:09 Sampler: Salvador Ruiz Rep. Limit Qualifier
Field Analyses
Cl Res Free (Field) Field 1.4 mg/L 02/05/26 02/05/26 2607006 General Chemical Analyses
Fluoride (F) EPA 300.0 0.39 0.10 mg/L 02/06/26 02/06/26 2606204 Metals
Manganese (Mn) EPA 200.7 ND ug/L 20 02/11/26 02/11/26 2607177 Iron (Fe) EPA 200.7 ND ug/L 100 02/11/26 02/11/26 2607177 Arsenic (As) EPA 200.8 ND ug/L 2.0 02/10/26 02/10/26 2607087 P.O. Box 401428 Hesperia, CA 92340. 760-244-3481. ELAP Number 2691 Page 3 of 5 Kristal Escobar
Laboratory Supervisor

430
Geo-Monitor, Inc.

Project:

Client:

Reported:

Received:

Sampled:

Sampler:

Sub Project: Monthly - I&M Treatment Plant
11780 Air Expressway
Adelanto CA, 92301
System:

Fax:

Phone:

Contact:
(620) 474-7310
Woodard & Curran - Adelanto Water
Adelanto Water
Chris Mcmahon
CA3610001
02/05/2026
Salvador Ruiz
02/05/2026 14:15
02/13/2026
Result Analyte Method Units Prepared Analyzed Batch
Front Pump House G26B108-02 (DW) Sample Date: 02/05/26 7:33 Sampler: Salvador Ruiz Rep. Limit Qualifier
Field Analyses
Cl Res Free (Field) Field 1.64 mg/L 02/05/26 02/05/26 2607006 General Chemical Analyses
Fluoride (F) EPA 300.0 0.38 0.10 mg/L 02/06/26 02/06/26 2606204 Metals
Manganese (Mn) EPA 200.7 ND ug/L 20 02/11/26 02/11/26 2607177 Iron (Fe) EPA 200.7 ND ug/L 100 02/11/26 02/11/26 2607177 Arsenic (As) EPA 200.8 ND ug/L 2.0 02/10/26 02/10/26 2607087 P.O. Box 401428 Hesperia, CA 92340. 760-244-3481. ELAP Number 2691 Page 4 of 5 Kristal Escobar
Laboratory Supervisor

431

432
Woodard & Curran - Adelanto Water
Adelanto, CA 92301
11780 Air Expressway
Chris Mcmahon
16 February 2026
Sincerely,
Geo-Monitor Lab No.: G26B109
Enclosed are the results of the analyses for sample(s) received at the laboratory on 02/05/26 . These sample(s) were analyzed at a sub-contract laboratory, with the final reports indicating the analyzing/reporting laboratory.

If applicable, these final reports will also indicate any state EDT transfer that has occurred. Please call if any additional information and/or assistance are needed.

Thank you for choosing Geo-Monitor, Inc for your analytical needs.

Project Name: Adelanto Water
Kristal Escobar
Laboratory Supervisor
Geo-Monitor, Inc.

433
Geo-Monitor, Inc.

Project:

Client:

Reported:

Received:

Sampled:

Sampler:

Sub Project: Monthly - Wells
11780 Air Expressway
Adelanto CA, 92301
System:

Fax:

Phone:

Contact:
(620) 474-7310
Woodard & Curran - Adelanto Water
Adelanto Water
Chris Mcmahon
CA3610001
02/05/2026
Salvador Ruiz
02/05/2026 13:50
02/16/2026

RESULTS
Laboratory
ID
Sample
Location
Sample
Time
E. Coli
P/A
Total Coliform
P/A
Cl Res (Field)
mg/L
Plate Count
CFU/ml
G26B109-01 08:26 Well 1G 0.02 A A <1
G26B109-02 08:59 Well 4G 0.03 A A <1
G26B109-03 09:31 Well 8G2 0.06 A A <1
G26B109-04 10:56 Well 15 0.02 A A <1
A - Absence of Bacteria
P - Presence of Bacteria
P.O. Box 401428 Hesperia, CA 92340. 760-244-3481. ELAP Number 2691 Page 2 of 7 Kristal Escobar
Laboratory Supervisor

434
Geo-Monitor, Inc.

Project:

Client:

Reported:

Received:

Sampled:

Sampler:

Sub Project: Monthly - Wells
11780 Air Expressway
Adelanto CA, 92301
System:

Fax:

Phone:

Contact:
(620) 474-7310
Woodard & Curran - Adelanto Water
Adelanto Water
Chris Mcmahon
CA3610001
02/05/2026
Salvador Ruiz
02/05/2026 13:50
02/16/2026
Result Analyte Method Units Prepared Analyzed Batch
Well 1G G26B109-01 (Water) Sample Date: 02/05/26 8:26 Sampler: Salvador Ruiz Rep. Limit Qualifier
Field Analyses
Cl Res Free (Field) Field 0.02 mg/L 02/06/26 02/06/26 2607018 General Chemical Analyses
Fluoride (F) EPA 300.0 0.42 0.10 mg/L 02/11/26 02/11/26 2607081 Metals
Manganese (Mn) EPA 200.7 34 20 ug/L 02/11/26 02/11/26 2607177 Iron (Fe) EPA 200.7 ND ug/L 100 02/11/26 02/11/26 2607177 Arsenic (As) EPA 200.8 ND ug/L 2.0 02/09/26 02/09/26 2607039 P.O. Box 401428 Hesperia, CA 92340. 760-244-3481. ELAP Number 2691 Page 3 of 7 Kristal Escobar
Laboratory Supervisor

435
Geo-Monitor, Inc.

Project:

Client:

Reported:

Received:

Sampled:

Sampler:

Sub Project: Monthly - Wells
11780 Air Expressway
Adelanto CA, 92301
System:

Fax:

Phone:

Contact:
(620) 474-7310
Woodard & Curran - Adelanto Water
Adelanto Water
Chris Mcmahon
CA3610001
02/05/2026
Salvador Ruiz
02/05/2026 13:50
02/16/2026
Result Analyte Method Units Prepared Analyzed Batch
Well 4G G26B109-02 (Water) Sample Date: 02/05/26 8:59 Sampler: Salvador Ruiz Rep. Limit Qualifier
Field Analyses
Cl Res Free (Field) Field 0.03 mg/L 02/06/26 02/06/26 2607018 General Chemical Analyses
Fluoride (F) EPA 300.0 0.33 0.10 mg/L 02/11/26 02/11/26 2607081 Metals
Manganese (Mn) EPA 200.7 35 20 ug/L 02/11/26 02/11/26 2607177 Iron (Fe) EPA 200.7 ND ug/L 100 02/11/26 02/11/26 2607177 Arsenic (As) EPA 200.8 ND ug/L 2.0 02/09/26 02/09/26 2607039 P.O. Box 401428 Hesperia, CA 92340. 760-244-3481. ELAP Number 2691 Page 4 of 7 Kristal Escobar
Laboratory Supervisor

436
Geo-Monitor, Inc.

Project:

Client:

Reported:

Received:

Sampled:

Sampler:

Sub Project: Monthly - Wells
11780 Air Expressway
Adelanto CA, 92301
System:

Fax:

Phone:

Contact:
(620) 474-7310
Woodard & Curran - Adelanto Water
Adelanto Water
Chris Mcmahon
CA3610001
02/05/2026
Salvador Ruiz
02/05/2026 13:50
02/16/2026
Result Analyte Method Units Prepared Analyzed Batch
Well 8G2 G26B109-03 (Water) Sample Date: 02/05/26 9:31 Sampler: Salvador Ruiz Rep. Limit Qualifier
Field Analyses
Cl Res Free (Field) Field 0.06 mg/L 02/06/26 02/06/26 2607018 General Chemical Analyses
Fluoride (F) EPA 300.0 0.26 0.10 mg/L 02/11/26 02/11/26 2607081 Metals
Manganese (Mn) EPA 200.7 660 ug/L 20 02/11/26 02/11/26 2607177 Iron (Fe) EPA 200.7 ND ug/L 100 02/11/26 02/11/26 2607177 Arsenic (As) EPA 200.8 ND ug/L 2.0 02/09/26 02/09/26 2607039 P.O. Box 401428 Hesperia, CA 92340. 760-244-3481. ELAP Number 2691 Page 5 of 7 Kristal Escobar
Laboratory Supervisor

437
Geo-Monitor, Inc.

Project:

Client:

Reported:

Received:

Sampled:

Sampler:

Sub Project: Monthly - Wells
11780 Air Expressway
Adelanto CA, 92301
System:

Fax:

Phone:

Contact:
(620) 474-7310
Woodard & Curran - Adelanto Water
Adelanto Water
Chris Mcmahon
CA3610001
02/05/2026
Salvador Ruiz
02/05/2026 13:50
02/16/2026
Result Analyte Method Units Prepared Analyzed Batch
Well 15 G26B109-04 (Water) Sample Date: 02/05/26 10:56 Sampler: Salvador Ruiz Rep. Limit Qualifier
Field Analyses
Cl Res Free (Field) Field 0.02 mg/L 02/05/26 02/05/26 2606169 Cl Res Free (Field) Field 0.02 mg/L 02/06/26 02/06/26 2607018 General Chemical Analyses
Fluoride (F) EPA 300.0 0.72 0.10 mg/L 02/11/26 02/11/26 2607081 Metals
Manganese (Mn) EPA 200.7 ND ug/L 20 02/11/26 02/11/26 2607177 Iron (Fe) EPA 200.7 ND ug/L 100 02/11/26 02/11/26 2607177 Arsenic (As) EPA 200.8 5.0 2.0 ug/L 02/09/26 02/09/26 2607039 P.O. Box 401428 Hesperia, CA 92340. 760-244-3481. ELAP Number 2691 Page 6 of 7 Kristal Escobar
Laboratory Supervisor

438

439
Woodard & Curran - Adelanto Water
Adelanto, CA 92301
11780 Air Expressway
Chris Mcmahon
17 February 2026
Sincerely,
Geo-Monitor Lab No.: G26B166
Enclosed are the results of the analyses for sample(s) received at the laboratory on 02/10/26 . These sample(s) were analyzed at a sub-contract laboratory, with the final reports indicating the analyzing/reporting laboratory.

If applicable, these final reports will also indicate any state EDT transfer that has occurred. Please call if any additional information and/or assistance are needed.

Thank you for choosing Geo-Monitor, Inc for your analytical needs.

Project Name: Adelanto Water
Kristal Escobar
Laboratory Supervisor
Geo-Monitor, Inc.

440
Geo-Monitor, Inc.

Project:

Client:

Reported:

Received:

Sampled:

Sampler:

Sub Project: Week 2 - I&M Treatment Plant
11780 Air Expressway
Adelanto CA, 92301
System:

Fax:

Phone:

Contact:
(620) 474-7310
Woodard & Curran - Adelanto Water
Adelanto Water
Chris Mcmahon
CA3610001
02/10/2026
Edward Rodriguez
02/10/2026 15:22
02/17/2026

RESULTS
Laboratory
ID
Sample
Location
Sample
Time
E. Coli
P/A
Total Coliform
P/A
Cl Res (Field)
mg/L
Plate Count
CFU/ml
G26B166-01 08:10 Filter Effluent 1.71 A A <1
G26B166-02 09:04 Front Pump House 1.00 A A <1
A - Absence of Bacteria
P - Presence of Bacteria
P.O. Box 401428 Hesperia, CA 92340. 760-244-3481. ELAP Number 2691 Page 2 of 4 Kristal Escobar
Laboratory Supervisor

441
Geo-Monitor, Inc.

Project:

Client:

Reported:

Received:

Sampled:

Sampler:

Sub Project: Week 2 - I&M Treatment Plant
11780 Air Expressway
Adelanto CA, 92301
System:

Fax:

Phone:

Contact:
(620) 474-7310
Woodard & Curran - Adelanto Water
Adelanto Water
Chris Mcmahon
CA3610001
02/10/2026
Edward Rodriguez
02/10/2026 15:22
02/17/2026
Result Analyte Method Units Prepared Analyzed Batch
Filter Effluent G26B166-01 (Water) Sample Date: 02/10/26 8:10 Sampler: Edward Rodriguez Rep. Limit Qualifier
Field Analyses
Cl Res Free (Field) Field 1.71 mg/L 02/10/26 02/10/26 2607027 Metals
Manganese (Mn) EPA 200.7 ND ug/L 20 02/12/26 02/12/26 2607231 Iron (Fe) EPA 200.7 ND ug/L 100 02/12/26 02/12/26 2607231 Result Analyte Method Units Prepared Analyzed Batch
Front Pump House G26B166-02 (Water) Sample Date: 02/10/26 9:04 Sampler: Edward Rodriguez Rep. Limit Qualifier
Field Analyses
Cl Res Free (Field) Field 1 mg/L 02/10/26 02/10/26 2607027 General Chemical Analyses
Fluoride (F) EPA 300.0 0.45 0.10 mg/L 02/12/26 02/12/26 2607124 Metals
Manganese (Mn) EPA 200.7 ND ug/L 20 02/12/26 02/12/26 2607231 Iron (Fe) EPA 200.7 ND ug/L 100 02/12/26 02/12/26 2607231 Arsenic (As) EPA 200.8 ND ug/L 2.0 02/16/26 02/16/26 2608064 P.O. Box 401428 Hesperia, CA 92340. 760-244-3481. ELAP Number 2691 Page 3 of 4 Kristal Escobar
Laboratory Supervisor

442

443
Woodard & Curran - Adelanto Water
Adelanto, CA 92301
11780 Air Expressway
Chris Mcmahon
26 February 2026
Sincerely,
Geo-Monitor Lab No.: G26B255
Enclosed are the results of the analyses for sample(s) received at the laboratory on 02/17/26 . These sample(s) were analyzed at a sub-contract laboratory, with the final reports indicating the analyzing/reporting laboratory.

If applicable, these final reports will also indicate any state EDT transfer that has occurred. Please call if any additional information and/or assistance are needed.

Thank you for choosing Geo-Monitor, Inc for your analytical needs.

Project Name: Adelanto Water
Kristal Escobar
Laboratory Supervisor
Geo-Monitor, Inc.

444
Geo-Monitor, Inc.

Project:

Client:

Reported:

Received:

Sampled:

Sampler:

Sub Project: Week 3 - I&M Treatment Plant
11780 Air Expressway
Adelanto CA, 92301
System:

Fax:

Phone:

Contact:
(620) 474-7310
Woodard & Curran - Adelanto Water
Adelanto Water
Chris Mcmahon
CA3610001
02/17/2026
Salvador Ruiz
02/17/2026 15:17
02/26/2026

RESULTS
Laboratory
ID
Sample
Location
Sample
Time
E. Coli
P/A
Total Coliform
P/A
Cl Res (Field)
mg/L
Plate Count
CFU/ml
G26B255-01 09:23 Filter Effluent 1.02 A A <1
G26B255-02 08:55 Front Pump House 1.40 A A <1
A - Absence of Bacteria
P - Presence of Bacteria
P.O. Box 401428 Hesperia, CA 92340. 760-244-3481. ELAP Number 2691 Page 2 of 4 Kristal Escobar
Laboratory Supervisor

445
Geo-Monitor, Inc.

Project:

Client:

Reported:

Received:

Sampled:

Sampler:

Sub Project: Week 3 - I&M Treatment Plant
11780 Air Expressway
Adelanto CA, 92301
System:

Fax:

Phone:

Contact:
(620) 474-7310
Woodard & Curran - Adelanto Water
Adelanto Water
Chris Mcmahon
CA3610001
02/17/2026
Salvador Ruiz
02/17/2026 15:17
02/26/2026
Result Analyte Method Units Prepared Analyzed Batch
Filter Effluent G26B255-01 (DW) Sample Date: 02/17/26 9:23 Sampler: Salvador Ruiz Rep. Limit Qualifier
Field Analyses
Cl Res Free (Field) Field 1.02 mg/L 02/17/26 02/17/26 2608032 Metals
Manganese (Mn) EPA 200.7 ND ug/L 20 02/19/26 02/19/26 2608194 Iron (Fe) EPA 200.7 ND ug/L 100 02/19/26 02/19/26 2608194 Result Analyte Method Units Prepared Analyzed Batch
Front Pump House G26B255-02 (DW) Sample Date: 02/17/26 8:55 Sampler: Salvador Ruiz Rep. Limit Qualifier
Field Analyses
Cl Res Free (Field) Field 1.4 mg/L 02/17/26 02/17/26 2608032 General Chemical Analyses
Fluoride (F) EPA 300.0 0.44 0.10 mg/L 02/20/26 02/20/26 2608234 Metals
Manganese (Mn) EPA 200.7 ND ug/L 20 02/19/26 02/19/26 2608194 Iron (Fe) EPA 200.7 ND ug/L 100 02/19/26 02/19/26 2608194 Arsenic (As) EPA 200.8 ND ug/L 2.0 02/23/26 02/23/26 2609041 P.O. Box 401428 Hesperia, CA 92340. 760-244-3481. ELAP Number 2691 Page 3 of 4 Kristal Escobar
Laboratory Supervisor

446

447

ADELANTO PUBLIC UTILITY AUTHORITY
A D E L A N T O G O V E R N M E N T A L C E N T E R | 1 1 6 0 0 A I R E X P R E S S W A Y | A D E L A N T O , C A L I F O R N I A 9 2 3 0 1
DATE: May 13, 2026
TO: Honorable Chairman, and Public Utility Authority Members FROM: Jessie Flores, Executive Director
BY: Chris McMahon, Woodard & Curran, Area Manager/ Senior Principal SUBJECT: RECEIVE AND FILE THE WASTERWATER DEPARTMENT MONTHYLY REPORT – FEBRUARY 2026
STAFF RECOMMENDATION:

Receive and File the Wastewater Department Monthly Report.

ATTACHMENTS:

1. Wastewater Department Monthly Report – February 2026 448
Table of Contents
Wastewater Department
Monthly Operating Report
February 2026
449
City of Adelanto 2 Woodard & Curran, Inc.

Adelanto Wastewater MOR 2026-02 February 2026
Section Page No.

1. Executive Summary ……………………………………………………… 3

2. Health & Safety ……………………………………………………… 4

3. Regulatory Compliance ……………………………………………………… 6

4. WWTP Operations ……………………………………………………… 7

4.1. Flow & Loading ……………………………………………………… 7

4.2. Bio-Solids Report ……………………………………………………… 8

5. Collection System management ……………………………………………………… 9

6. Industrial Pretreatment Program ……………………………………………………… 9

7. Maintenance & Repair ……………………………………………………… 9

8. Personnel ……………………………………………………… 10

9. Financial Overview ……………………………………………………… 11
Attachments:

1. Adelanto WWTP Summary Report

2. Monthly Laboratory Analysis
450
City of Adelanto 3 Woodard & Curran, Inc.

Adelanto Wastewater MOR 2026-02 February 2026

1. Executive Summary
The following operational overview highlights the successful operations of the City’s water system from February 1 – February 28, 2026.

February was an exciting month; Woodard & Curran transitioned operations and maintenance of the Adelanto Wastewater Plant and Collections System, completing the first 28 days of operations. The first period of transition focuses on onboarding employees while maintaining routine functionality of the facilities.

Health & Safety
The safety of our employees, City staff, contractors, and ratepayers remains Woodard & Curran’s highest priority. We are pleased to report that there were no OSHA-recordable or lost-time incidents during this reporting period, and we have now reached 28 days without a safety incident.

Regulatory Compliance
Woodard & Curran met regulatory compliance standards for the City’s wastewater system in accordance with regulations.

Capital Improvement Projects
Woodard & Curran has reviewed the previous O&M firm’s CIP recommendations and is engaged in discussions with the City’s Engineering Department. We will continue to partner with the City’s Engineering Department and position the city to implement necessary capital improvement projects.

Budget
Adelanto’s Wastewater budget execution through February reflects the ongoing transition process as employees are hired and trained to fulfill the responsibilities of managing the system.

451
City of Adelanto 4 Woodard & Curran, Inc.

Adelanto Wastewater MOR 2026-02 February 2026

2. Health & Safety
Initial Onsite Safety Training
As part of the transition of operations for the City of Adelanto’s wastewater facilities, initial onsite safety training was conducted to establish clear safety expectations and ensure staff were prepared to operate safely under Woodard & Curran’s Health & Safety program.

This initial training focused on site-specific hazards, emergency procedures, and safe work practices unique to the facilities. Topics included facility orientation, emergency action plans, chemical awareness, confined space considerations, lockout/tagout procedures, personal protective equipment (PPE) requirements, and general operational safety expectations. Emphasis was placed on identifying potential hazards early, understanding reporting protocols, and reinforcing stop-work authority if unsafe conditions are observed.

The training also served to align all staff with Woodard & Curran’s safety culture, reinforcing the importance of communication, documentation, and accountability from the outset of operations.

Completing this initial onsite safety training during the transition helped establish a strong safety foundation, support regulatory compliance, and promote consistent, safe operations moving forward.

Ongoing safety training, daily tailgate discussions, and periodic audits will continue as part of the broader Health & Safety program to reinforce safe behaviors and support continuous improvement.

SPARKS Program Overview
The SPARKS Program is an O&M safety initiative designed to recognize employees who demonstrate a strong personal commitment to safety and consistently work with their peers to maintain a safe and healthy work environment. Each year, staff are evaluated on established safety goals—such as maintaining zero OSHA-recordable incidents, completing required safety training, attending monthly safety meetings, and fulfilling all annual H&S tasks. When individuals and teams meet these expectations, they become eligible for an annual incentive, with increased rewards for consecutive years of achievement. The program reinforces daily safe-work habits, strengthens teamwork, and encourages proactive communication about safety, all of which contributes to our long-term safety performance.

Startup Safety Audit
As part of the transition of operations, a Startup Safety Audit was conducted to establish a clear baseline for health and safety conditions and to ensure safe, compliant operations from day one. The audit is a standard component of the transition process and is designed to verify that facilities, equipment, documentation, and work practices align with applicable safety regulations and Woodard & Curran’s Health & Safety standards.

The audit included a comprehensive review of facility conditions, safety programs, and operational practices, with particular attention to hazard identification, emergency preparedness, lockout/tagout procedures, confined space considerations, chemical storage and handling, electrical safety, and use of 452
City of Adelanto 5 Woodard & Curran, Inc.

Adelanto Wastewater MOR 2026-02 February 2026
personal protective equipment (PPE). Site documentation was reviewed alongside field observations to confirm alignment between written procedures and actual work practices.

Any items identified during the audit were documented and prioritized based on risk. Corrective actions focused on practical, preventative measures such as updating procedures, reinforcing training, improving signage or guarding, and ensuring appropriate safety equipment was in place. Where appropriate, findings were incorporated into the site’s training plan and standard operating procedures to prevent recurrence and strengthen overall safety awareness.

The completion of the Startup Safety Audit provided a strong foundation for ongoing operations and helped establish clear safety expectations for staff and contractors. Follow-up actions and periodic safety reviews will continue as part of the ongoing Health & Safety program to ensure continuous improvement, regulatory compliance, and protection of employees, the public, and the community. 167 actions items were identified in the audit and staff has already started to address the items. 453
City of Adelanto 6 Woodard & Curran, Inc.

Adelanto Wastewater MOR 2026-02 February 2026

3. Regulatory Compliance
During this reporting period, the City of Adelanto has maintained 100% regulatory compliance with all regulatory requirements. All required samples were collected and analyzed for required water quality constituents. Babcock Laboratories continues to be the preferred vendor for outside wastewater laboratory analysis. All process control analysis is performed in-house by Woodard & Curran staff, this analysis is crucial for making the adjustments at the facilities to ensure that treatment goals are achieved.

Table 3-1 – Monthly Mean
Constituents Units 30 day Mean Limit Measured Mean
Biochemical Oxygen Demand (BOD) mg/L 15 5.30
Methylene Blue Active Substances (MBAs) mg/L 1 0.03
Total Nitrogen (TN) mg/L 10 3.6
Table 3-2 – Daily Maximum
Constituents Units Daily Limit Measured
Biochemical Oxygen Demand (BOD) mg/L Maximum 30 8.9
Methylene Blue Active Substances (MBAS) mg/L Maximum 2 <0.08 Total Nitrogen (TN) mg/L NA 4.3
pH Su Between 6.0 to 9.0 6.36 – 6.74
Dissolved Oxygen (DO) mg/L Minimum 1 mg/L 1.87
454
City of Adelanto 7 Woodard & Curran, Inc.

Adelanto Wastewater MOR 2026-02 February 2026

4. WWTP Operations
Influent flow for the month of February totaled 92.093 MG with a peak flow of 3692.6 GPM on February 16th.

All pH and electrical conductivity monitoring equipment was calibrated weekly, monthly, or as needed by plant staff based on the manufacturer’s recommendations and operational needs.

Operational highlights for the reporting period:
 Polymer dosed to aid the clarifiers in settling solids.  Sampling performed on Percolation Pond #5.
 Effluent discharge was changed from Percolation Pond #5 to Percolation Pond #9.  The North Basin Dissolved Oxygen probe stopped working and staff is working with PACE to service the probe under warranty from the 2025 Optimization Project.

4.1 Flow & Loading
Table 4-1 – Monthly Influent Information
Parameter Units Measured Value
Total Flow MG 92.093
Average Daily Flow MGD 3.289
Maximum Daily Flow MG 3.636
Minimum Daily Flow MG 3.151
Maximum Daily Peak Flow GPM 3692.6
Minimum Daily Peak Flow GPM 2814.8
Average BOD mg/L 248
Average Total Suspended Solids (TSS) mg/L 270
Average pH su 6.85
Average Electrical Conductivity (EC) umho/cm 1229
Table 4-2 – Monthly Effluent Information
Parameter Units Measured Value
Average BOD mg/L 5.3
Average TSS mg/L 4
Average Total Nitrogen mg/L 3.6
Average Total Dissolved Solids (TDS) mg/L 523
Average MBAs mg/L 0.03
Average DO mg/L 1.97
Average pH Su 6.63
Average Electrical Conductivity (EC) umho/cm 960
455
City of Adelanto 8 Woodard & Curran, Inc.

Adelanto Wastewater MOR 2026-02 February 2026

4.1 Bio-Solids Report
Wet Tons Dry Tons Wet Tons Dry Tons
January 332.13 69.75 13 13 $5,297.47 $10,810.83 $16,108.31 $48.50 February 263.90 55.42 10 10 $4,209.21 $8,864.40 $13,073.61 $49.54 March 0.00 596.03 125.17 $0.00 $0.00 $0.00 #DIV/0!
April 0.00 $0.00 $0.00 $0.00 #DIV/0!
May 0.00 $0.00 $0.00 $0.00 #DIV/0!
June 0.00 0.00 0.00 $0.00 $0.00 $0.00 #DIV/0!
July 0.00 $0.00 $0.00 $0.00 #DIV/0!
August 0.00 $0.00 $0.00 $0.00 #DIV/0!
September 0.00 0.00 0.00 $0.00 $0.00 $0.00 #DIV/0!
October 0.00 $0.00 $0.00 $0.00 #DIV/0!
November 0.00 $0.00 $0.00 $0.00 #DIV/0!
December 0.00 0.00 0.00 $0.00 $0.00 $0.00 #DIV/0!
Total Tons 596.03 125.17 596.03 125.17 23 23 $9,506.68 $19,675.23 $29,181.91 #DIV/0! Metric Tons 540.60 113.53 540.60 113.53 total total total total total average 2026 BIO-SOLIDS HAULED
Adelanto production Quarter # of GIC
end
dump
Removed
# Synagro
loads
received
Total Hauling
Cost
Total Tipping
Fee Cost Total Cost Total Cost Per Ton

RECYCLE
# of Bins ft3
yards # of Bins
January 21 42 1
February 21 42 2
March 0
April 0
May 0
June 0
July 0
August 0
September 0
October 0
November 0
December 0
Total 42 84 3
2026 SCREENINGS/GRIT HAULED
456
City of Adelanto 9 Woodard & Curran, Inc.

Adelanto Wastewater MOR 2026-02 February 2026

5. Collection System Management
Zero sanitary sewer overflows occurred during the reporting period.

Woodard & Curran received a new Vactor combination sewer cleaner in early February and training was conducted by the manufacturer’s representative on February 17th.

Sewer Collection System team members will attend NASSCO Inspector Certification Training during the month of March to allow them to properly identify and label CCTV video to identify defects and concerns in the sewer system.

CCTV equipment is expected to be delivered from the factory and be onsite during the month of April.

6. Industrial Pretreatment Program
Woodard & Curran is in the process of reviewing the APUA Industrial Pretreatment Program and develop a plan for ensuring compliance with all regulatory requirements is maintained.

7. Maintenance & Repair
Woodard & Curran is in the process of implementing the Utility Cloud platform for maintenance management of all assets in the sewer collection system and wastewater treatment plant.

Adelanto Wastewater Treatment Plant staff continued to conduct routine weekly equipment inspections and perform maintenance while the Utility Cloud platform is implemented.

On February 19th a 3 inch water line east of the office building at the WWTP required repair. 457
City of Adelanto 10 Woodard & Curran, Inc.

Adelanto Wastewater MOR 2026-02 February 2026

8. Personnel
The City of Adelanto is supported by a dedicated team of six (5) full-time on-site personnel. In addition, both the City and the on-site team are backed by a broad network of technical and administrative experts from Woodard & Curran.

Onsite Staff
Chris McMahon – Interim Project Manager
Dutch Hause - Lead WWTP Operator
James Strang – Operator 2
Scott Heller – Operator 1
Art – Lead Collections Systems Operator
Armando – Collection Systems Operator 1
Additional Support Staff
Chris McMahon – Area Manager
Dave Kitzmiller – Operations Leader-Western U.S.

Marc Thomas – National Operations Leader
Anthony Naccarato – Client Services Manager
Adam Shapiro – O&M Technology Implementation Specialist Steve Lindemann – O&M Health & Safety Manager
Kyle McKee – Health & Safety Specialist
Ken Davis – Asset Management Services Manager

458
City of Adelanto 11 Woodard & Curran, Inc.

Adelanto Wastewater MOR 2026-02 February 2026

9. Financial Overview
Table 9-1 – Chemical Costs
Chemical Monthly Order Monthly Cost YTD Cost
Polymer 5 totes (1,375 gallons) $19,297 $72,174
Table 9-2 – Monthly Power Consumption
Power Source Total Consumption (KWH)
SCE 850
Solar 238
Table 9-3 – Bio-solids Costs
Hauling / Tipping Fee Monthly Cost YTD Cost
GIC (Hauling) $4,209.21 $79,342.60
Synagro (Tipping Fee) $8,864.40 $176,344.70
TOTAL COMBINED $13,073.61 $255,687.30
459
Managed by: Woodard Curran ADELANTO WWTP SUMMARY REPORT February 2026
Inf Flow Inst. Peak FlowEff. Q Ponds Pond #1Pond #2 & #3Pond #4 Pond #5 Pond #9 Basin N Basin S MGD GPM MGD Freeboard Ft Freeboard Ft Freeboard Ft Freeboard Ft Freeboard Ft Freeboard Ft Freeboard Ft 2/1/2025 3.227 3295.9 3.227 24.00 EMPTY EMPTY 16.00 9.25 2.18 2.08 2/2/2025 3.263 3295.1 3.263 24.00 EMPTY EMPTY 16.00 9.00 2.04 1.93 2/3/2025 3.231 3217.6 3.231 24.00 EMPTY EMPTY 16.00 9.00 2.77 2.14 2/4/2025 3.232 3296.1 3.232 24.00 EMPTY EMPTY 16.00 9.00 2.27 2.36 2/5/2025 3.240 3354.9 3.240 24.00 EMPTY EMPTY 16.00 9.00 3.01 2.91 2/6/2025 3.238 3071.9 3.238 24.00 EMPTY EMPTY 16.00 9.00 2.42 2.49 2/7/2025 3.205 2968.4 3.205 24.00 EMPTY EMPTY 16.00 8.75 2.89 2.76 2/8/2025 3.254 3012.4 3.254 24.00 EMPTY EMPTY 16.00 8.75 2.71 2.65 2/9/2025 3.369 3407.4 3.369 24.00 EMPTY EMPTY 16.00 8.50 3.14 3.03 2/10/2025 3.480 3365.5 3.480 24.00 EMPTY EMPTY 16.00 8.25 2.50 2.52 2/11/2025 3.420 3377 3.420 24.00 EMPTY EMPTY 16.00 8.00 2.08 2.29 2/12/2025 3.198 3185.4 3.198 24.00 EMPTY EMPTY 16.00 7.75 1.79 2.11 2/13/2025 3.198 3084.3 3.198 24.00 EMPTY EMPTY 16.00 7.50 3.00 2.92 2/14/2025 3.200 2946 3.200 24.00 EMPTY EMPTY 16.00 7.50 3.12 3.00 2/15/2025 3.296 3103.2 3.296 24.00 EMPTY EMPTY 16.00 7.25 3.28 3.15 2/16/2025 3.636 3692.6 3.636 24.00 EMPTY EMPTY 16.00 7.50 3.46 3.35 2/17/2025 3.450 3369.9 3.450 24.00 EMPTY EMPTY 16.00 7.25 2.58 2.64 2/18/2025 3.387 3380.8 3.387 24.00 EMPTY EMPTY 16.00 7.00 2.72 2.78 2/19/2025 3.372 3314.3 3.372 24.00 EMPTY EMPTY 16.00 7.00 2.86 2.87 2/20/2025 3.203 3051.3 3.203 24.00 EMPTY EMPTY 16.00 7.00 2.86 2.87 2/21/2025 3.151 2997.1 3.151 24.00 EMPTY EMPTY 16.00 9.00 1.97 2.22 2/22/2025 3.199 3288.8 3.199 24.00 EMPTY EMPTY 16.00 10.00 1.75 2.00 2/23/2025 3.249 3374.2 3.249 24.00 EMPTY EMPTY 16.00 14.00 2.69 2.66 2/24/2025 3.363 3447.2 3.363 24.00 EMPTY EMPTY 16.00 14.50 1.71 2.01 2/25/2025 3.345 3363.5 3.345 24.00 EMPTY EMPTY 16.00 15.50 1.89 2.17 2/26/2025 3.283 3278.8 3.283 24.00 EMPTY EMPTY 16.00 16.00 2.52 2.56 2/27/2025 3.209 2995.4 3.209 24.00 EMPTY EMPTY 16.00 16.00 1.78 2.71 2/28/2025 3.195 2814.8 3.195 24.00 EMPTY EMPTY 16.00 16.00 2.00 2.28 Total 92.093 92.093
Average 3.289 3226.779 3.289 24.000 EMPTY EMPTY 16.000 9.759 2.500 2.552 Maximum 3.636 3692.600 3.636 24.000 0.000 0.000 16.000 16.000 3.460 3.350 Minimum 3.151 2814.800 3.151 24.000 0.000 0.000 16.000 7.000 1.710 1.930 Biolac Basins
Date
Flow Data Percolation Ponds
460
Managed by: Woodard Curran ADELANTO WWTP SUMMARY REPORT February 2026
BOD5 TSS pH D.O. EC TN TDS MBAS BOD5 TSS pH EC
mg/L mg/L su mg/L umho/cm mg/L mg/L mg/L mg/L mg/L su umho/cm 2/1/2025
2/2/2025
2/3/2025
2/4/2025 <5.0 4 6.36 1.89 842 4.3 510 <0.08 230 220 7.83 1104 2/5/2025
2/6/2025
2/7/2025
2/8/2025
2/9/2025
2/10/2025
2/11/2025 8.9 6 6.73 1.84 845 3.1 520 0.02 250 270 7.23 1126 2/12/2025
2/13/2025
2/14/2025
2/15/2025
2/16/2025
2/17/2025
2/18/2025 3.8 4 6.74 2.27 1092 4.2 520 0.03 310 280 5.97 1334 2/19/2025
2/20/2025
2/21/2025
2/22/2025
2/23/2025
2/24/2025
2/25/2025 3.2 2 6.68 1.87 1062 2.9 540 <0.08 200 310 6.35 1353 2/26/2025
2/27/2025
2/28/2025
3/1/2025
3/2/2025
3/3/2025
Total
Average 5.30 4 6.63 1.97 960 3.6 523 0.03 248 270 6.85 1229 Maximum 8.90 6 6.74 2.27 1092 4.3 540 0.03 310 310 7.83 1353 Minimum 3.20 2 6.36 1.84 842 2.9 510 0.02 200 220 5.97 1104 Date
Effluent Weekly Influent
461
Managed by: Woodard Curran ADELANTO WWTP SUMMARY REPORT February 2026
TN D.O. EC Temp TN D.O. EC Temp TN D.O. EC Temp
mg/L mg/L umho/cm C mg/L mg/L umho/cm C mg/L mg/L umho/cm C 2/1/2025
2/2/2025
2/3/2025
2/4/2025
2/5/2025
2/6/2025
2/7/2025
2/8/2025
2/9/2025
2/10/2025
2/11/2025
2/12/2025
2/13/2025
2/14/2025
2/15/2025
2/16/2025
2/17/2025
2/18/2025
2/19/2025
2/20/2025
2/21/2025
2/22/2025
2/23/2025
2/24/2025
2/25/2025
2/26/2025
2/27/2025
2/28/2025
3/1/2025
3/2/2025
3/3/2025
Total
Average
Maximum 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 Minimum 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 Pond Monitoring #9 Annually
Date
Pond Monitoring #1 Annually Pond Monitoring #5 Annually 462
Adelanto - Weekly/BiWeekly
WW 2026
Adelanto WWTP - Adelanto
WWTP 19101 Jonathan St.

Project Name:

Analytical Report: Page 1 of 5
Project Number:

Address:

Contact:

Adelanto, CA 92301
Daniel Peralta
P.O. Box 506
Client Name: Woodard & Curran
Report Date: 13-Feb-2026 Work Order Number:

Received on Ice (Y/N): Yes Temp: 5 °C
C6B0463
Attached is the analytical report for the sample(s) received for your project. Below is a list of the individual sample descriptions with the corresponding laboratory number(s). Also, enclosed is a copy of the Chain of Custody document (if received with your sample(s)). Please note any unused portion of the sample(s) may be responsibly discarded after 30 days from the above report date, unless you have requested otherwise.

Thank you for the opportunity to serve your analytical needs. If you have any questions or concerns regarding this report please contact our client service department.

Lab Sample # Client Sample ID Matrix Date Sampled
Sample Identification
By Date Submitted By
C6B0463-01 Liquid 02/04/26 07:05 Scott Heller 02/04/26 11:45 Courier (Guillermo) -DE
Influent ---ROUTINE---
C6B0463-02 Liquid 02/04/26 06:45 Scott Heller 02/04/26 11:45 Courier (Guillermo) -DE
Effluent ---ROUTINE---
mailing
6235 River Crest Dr. Ste H
Riverside, CA 92507
CA ELAP No. 2698
EPA No. CA00102
NELAP No. OR4035
LACSD No. 10119
P (951) 653-3351
F (951) 653-1662
www.babcocklabs.com
Babcock Laboratories, Inc. - Riverside
6100 Quail Valley Court
Riverside, CA 92507-0704
463
Adelanto - Weekly/BiWeekly
WW 2026
Adelanto WWTP - Adelanto
WWTP 19101 Jonathan St.

Project Name:

Analytical Report: Page 2 of 5
Project Number:

Address:

Contact:

Adelanto, CA 92301
Daniel Peralta
P.O. Box 506
Client Name: Woodard & Curran
Report Date: 13-Feb-2026 Work Order Number:

Received on Ice (Y/N): Yes Temp: 5 °C
C6B0463
Laboratory Reference Number
Sample Description
02/04/26 07:05
Sampled Date/Time Received Date/Time
02/04/26 11:45
Matrix
Influent Liquid
C6B0463-01
Analyte(s) Result RDL MDL Units Method Analysis Date Analyst Flag Testing performed by: Babcock Laboratories, Inc. - Riverside CA ELAP No. 2698, EPA No. CA00102, NELAP No. OR4035
Solids
Total Dissolved Solids 580 10 mg/L SM 2540C 02/05/26 21:46 AAR Total Suspended Solids 220 10 mg/L SM 2540D 02/05/26 22:14 CXR Aggregate Organic Compounds
Biochemical Oxygen Demand 230 50 mg/L SM 5210B 02/05/26 14:00 JXM Nutrients
Ammonia-Nitrogen 37 5.1 3.3 mg/L SM 4500NH3 G 02/05/26 14:34 RUB mailing
6235 River Crest Dr. Ste H
Riverside, CA 92507
CA ELAP No. 2698
EPA No. CA00102
NELAP No. OR4035
LACSD No. 10119
P (951) 653-3351
F (951) 653-1662
www.babcocklabs.com
Babcock Laboratories, Inc. - Riverside
6100 Quail Valley Court
Riverside, CA 92507-0704
464
Adelanto - Weekly/BiWeekly
WW 2026
Adelanto WWTP - Adelanto
WWTP 19101 Jonathan St.

Project Name:

Analytical Report: Page 3 of 5
Project Number:

Address:

Contact:

Adelanto, CA 92301
Daniel Peralta
P.O. Box 506
Client Name: Woodard & Curran
Report Date: 13-Feb-2026 Work Order Number:

Received on Ice (Y/N): Yes Temp: 5 °C
C6B0463
Laboratory Reference Number
Sample Description
02/04/26 06:45
Sampled Date/Time Received Date/Time
02/04/26 11:45
Matrix
Effluent Liquid
C6B0463-02
Analyte(s) Result RDL MDL Units Method Analysis Date Analyst Flag Testing performed by: Babcock Laboratories, Inc. - Riverside CA ELAP No. 2698, EPA No. CA00102, NELAP No. OR4035
Anions
Nitrate as N 2.1 0.20 mg/L EPA 300.0 02/05/26 01:26 VMV Nitrite as N 0.2 0.1 mg/L EPA 300.0 02/05/26 01:26 VMV
Solids
Total Dissolved Solids 510 10 mg/L SM 2540C 02/05/26 21:46 AAR Nconf Total Suspended Solids 4 0.5 mg/L SM 2540D 02/05/26 22:14 CXR Aggregate Organic Compounds
Biochemical Oxygen Demand ND 5.0 mg/L SM 5210B 02/05/26 14:00 JXM Surfactants
MBAS ND 0.08 mg/L SM 5540C 02/04/26 19:22 RJB
Nutrients
Ammonia-Nitrogen 0.5 0.1 0.06 mg/L SM 4500NH3 G 02/05/26 14:36 RUB Kjeldahl Nitrogen 2.0 0.1 mg/L EPA 351.2 02/06/26 17:17 CXR Total Nitrogen 4.3 0.40 mg/L Calculation
mailing
6235 River Crest Dr. Ste H
Riverside, CA 92507
CA ELAP No. 2698
EPA No. CA00102
NELAP No. OR4035
LACSD No. 10119
P (951) 653-3351
F (951) 653-1662
www.babcocklabs.com
Babcock Laboratories, Inc. - Riverside
6100 Quail Valley Court
Riverside, CA 92507-0704
465
Adelanto - Weekly/BiWeekly
WW 2026
Adelanto WWTP - Adelanto
WWTP 19101 Jonathan St.

Project Name:

Analytical Report: Page 4 of 5
Project Number:

Address:

Contact:

Adelanto, CA 92301
Daniel Peralta
P.O. Box 506
Client Name: Woodard & Curran
Report Date: 13-Feb-2026 Work Order Number:

Received on Ice (Y/N): Yes Temp: 5 °C
C6B0463
Notes and Definitions
Nconf Result(s) confirmed by re-analysis.

NR Not Reported
ND Analyte NOT DETECTED at or above the Method Detection Limit (if MDL is reported), otherwise at or above the Reportable Detection Limit (RDL)
RDL Reportable Detection Limit
MDL Method Detection Limit
* / ''' NELAP does not offer accreditation for this analyte/method/matrix combination e-Short_No Alias.rpt
This report applies only to the sample(s) analyzed. As a mutual protection to clients, the public, and Babcock Laboratories, Inc., this report is submitted and accepted for the exclusive use of the Client to whom it is addressed. Interpretation and use of the information contained within this report are the sole responsibility of the Client. Babcock Laboratories, Inc. is not responsible for any misinformation or consequences that may result from misinterpretation or improper use of this report. This report is not to be modified or abbreviated in any way.

Additionally, this report is not to be used, in whole or in part, in any advertising or publicity matter without written authorization from Babcock Laboratories, Inc. The liability of Babcock Laboratories, Inc. is limited to the actual cost of the requested analyses, unless otherwise agreed upon in writing. There is no other warranty expressed or implied.

Enclosed are the analytical results for the submitted sample(s). Babcock Laboratories certify the data presented as part of this report meet the minimum quality standards in the referenced analytical methods. Any exceptions have been noted.

Approval
cc:

Cindy A. Waddell
mailing
6235 River Crest Dr. Ste H
Riverside, CA 92507
CA ELAP No. 2698
EPA No. CA00102
NELAP No. OR4035
LACSD No. 10119
P (951) 653-3351
F (951) 653-1662
www.babcocklabs.com
Babcock Laboratories, Inc. - Riverside
6100 Quail Valley Court
Riverside, CA 92507-0704
466
Adelanto - Weekly/BiWeekly
WW 2026
Adelanto WWTP - Adelanto
WWTP 19101 Jonathan St.

Project Name:

Analytical Report: Page 5 of 5
Project Number:

Address:

Contact:

Adelanto, CA 92301
Daniel Peralta
P.O. Box 506
Client Name: Woodard & Curran
Report Date: 13-Feb-2026 Work Order Number:

Received on Ice (Y/N): Yes Temp: 5 °C
C6B0463
mailing
6235 River Crest Dr. Ste H
Riverside, CA 92507
CA ELAP No. 2698
EPA No. CA00102
NELAP No. OR4035
LACSD No. 10119
P (951) 653-3351
F (951) 653-1662
www.babcocklabs.com
Babcock Laboratories, Inc. - Riverside
6100 Quail Valley Court
Riverside, CA 92507-0704
467
Client Name:

Report Date:

Woodard & Curran
P.O. Box 506
Daniel Peralta
Adelanto, CA 92301
Contact:

Address: Project Number:

Analytical Report: Page 1 of 11
Project Name:
26-Feb-2026
Work Order Number: C6B1333
Received on Ice (Y/N): Yes Temp: 5 °C
Adelanto Weekly WW 2026
Adelanto WWTP - Adelanto WWTP 19101 Jo
C6B1333
Attached is the analytical report for the sample(s) received for your project. Below is a list of the individual sample descriptions with the corresponding laboratory number(s). Also, enclosed is a copy of the Chain of Custody document (if received with your sample(s)). Please note any unused portion of the sample(s) may be responsibly discarded after 30 days from the above report date, unless you have requested otherwise.

Thank you for the opportunity to serve your analytical needs. If you have any questions or concerns regarding this report please contact our client service department.

Sample Identification
Lab Sample # Client Sample ID Matrix Date Sampled By Date Submitted By C6B1333-01 Liquid 02/11/26 6:40 Scott Heller Courier
(Guillermo)-DE
Influent ---ROUTINE--- 02/11/26 11:55
C6B1333-02 Liquid 02/11/26 7:00 Scott Heller Courier
(Guillermo)-DE
Effluent ---ROUTINE--- 02/11/26 11:55
mailing
6235 River Crest Dr. Ste H
Riverside, CA 92507
CA ELAP No. 2698
EPA No. CA00102
NELAP No. OR4035
LACSD No. 10119
P (951) 653-3351
F (951) 653-1662
www.babcocklabs.com
location
6100 Quail Valley Court
Riverside, CA 92507-0704
468
Client Name:

Report Date:

Woodard & Curran
P.O. Box 506
Daniel Peralta
Adelanto, CA 92301
Contact:

Address: Project Number:

Analytical Report: Page 2 of 11
Project Name:
26-Feb-2026
Work Order Number: C6B1333
Received on Ice (Y/N): Yes Temp: 5 °C
Adelanto Weekly WW 2026
Adelanto WWTP - Adelanto WWTP 19101 Jo
C6B1333
Laboratory Reference Number
Sample Description
02/11/26 06:40
Sampled Date/Time Received Date/Time
02/11/26 11:55
Matrix
Influent Liquid
C6B1333-01
Analyte(s) Result RDL MDL Units Method Analysis Date Analyst Flag Solids
Total Dissolved Solids 580 10 10 mg/L SM 2540C 02/12/26 18:15 AAR Total Suspended Solids 270 10 10 mg/L SM 2540D 02/17/26 18:35 CXR Aggregate Organic Compounds
Biochemical Oxygen Demand 250 50 50 mg/L SM 5210B 02/11/26 21:24 CXR Nutrients
Ammonia-Nitrogen 36 5.1 3.3 mg/L SM 4500NH3 G 02/20/26 10:12 GMB mailing
6235 River Crest Dr. Ste H
Riverside, CA 92507
CA ELAP No. 2698
EPA No. CA00102
NELAP No. OR4035
LACSD No. 10119
P (951) 653-3351
F (951) 653-1662
www.babcocklabs.com
location
6100 Quail Valley Court
Riverside, CA 92507-0704
469
Client Name:

Report Date:

Woodard & Curran
P.O. Box 506
Daniel Peralta
Adelanto, CA 92301
Contact:

Address: Project Number:

Analytical Report: Page 3 of 11
Project Name:
26-Feb-2026
Work Order Number: C6B1333
Received on Ice (Y/N): Yes Temp: 5 °C
Adelanto Weekly WW 2026
Adelanto WWTP - Adelanto WWTP 19101 Jo
C6B1333
Laboratory Reference Number
Sample Description
02/11/26 07:00
Sampled Date/Time Received Date/Time
02/11/26 11:55
Matrix
Effluent Liquid
C6B1333-02
Analyte(s) Result RDL MDL Units Method Analysis Date Analyst Flag Anions
Nitrate as N 1.2 0.20 0.12 mg/L EPA 300.0 02/12/26 00:01 JXM Nitrite as N 0.1 0.1 0.05 mg/L EPA 300.0 02/12/26 00:01 JXM Solids
Total Dissolved Solids 520 10 10 mg/L SM 2540C 02/12/26 18:15 AAR Nconf Total Suspended Solids 6 0.5 0.5 mg/L SM 2540D 02/17/26 16:57 SNB Aggregate Organic Compounds
Biochemical Oxygen Demand 8.9 5.0 5.0 mg/L SM 5210B 02/11/26 21:24 CXR N-BOD1 Surfactants
MBAS 0.02 0.08 0.02 mg/L SM 5540C 02/11/26 20:43 RJB J
Nutrients
Ammonia-Nitrogen 0.4 0.1 0.06 mg/L SM 4500NH3 G 02/20/26 10:14 GMB Kjeldahl Nitrogen 1.8 0.1 0.07 mg/L EPA 351.2 02/24/26 11:47 VMV Total Nitrogen 3.1 0.40 mg/L Calculation
mailing
6235 River Crest Dr. Ste H
Riverside, CA 92507
CA ELAP No. 2698
EPA No. CA00102
NELAP No. OR4035
LACSD No. 10119
P (951) 653-3351
F (951) 653-1662
www.babcocklabs.com
location
6100 Quail Valley Court
Riverside, CA 92507-0704
470
Client Name:

Report Date:

Woodard & Curran
P.O. Box 506
Daniel Peralta
Adelanto, CA 92301
Contact:

Address: Project Number:

Analytical Report: Page 4 of 11
Project Name:
26-Feb-2026
Work Order Number: C6B1333
Received on Ice (Y/N): Yes Temp: 5 °C
Adelanto Weekly WW 2026
Adelanto WWTP - Adelanto WWTP 19101 Jo
C6B1333
Result RDL Units Level
Spike
Result
Source
%REC
%REC
Limits RPD
RPD
Analyte(s) Limit Flag
Anions - Batch Quality Control
Batch 6B11130 - Analyzed as Received IC
Blank (6B11130-BLK1) Prepared & Analyzed: 02/11/26
Nitrite as N ND 0.1 0.05 mg/L
Nitrate as N ND 0.20 0.12 mg/L
LCS (6B11130-BS1) Prepared & Analyzed: 02/11/26
Nitrite as N 2.46 0.1 0.05 mg/L 2.50 98 90-110
Nitrate as N 5.67 0.20 0.12 mg/L 5.65 100 90-110
Matrix Spike (6B11130-MS1) Source: C6B1192-04RE1 Prepared & Analyzed: 02/12/26 Nitrite as N 50.3 2.1 1.0 mg/L 50.0 1.32 98 80-120
Nitrate as N 126 4.2 2.5 mg/L 113 9.40 104 75-131
Matrix Spike (6B11130-MS2) Source: C6B1192-06RE1 Prepared & Analyzed: 02/11/26 Nitrite as N 2.47 0.1 0.05 mg/L 2.50 0.408 83 80-120
Nitrate as N 34.3 0.20 0.12 mg/L 5.65 28.6 101 75-131
Matrix Spike Dup (6B11130-MSD1) Source: C6B1192-04RE1 Prepared & Analyzed: 02/12/26 Nitrite as N 51.1 2.1 1.0 mg/L 50.0 1.32 99 80-120 2 20 Nitrate as N 130 4.2 2.5 mg/L 113 9.40 107 75-131 3 20
mailing
6235 River Crest Dr. Ste H
Riverside, CA 92507
CA ELAP No. 2698
EPA No. CA00102
NELAP No. OR4035
LACSD No. 10119
P (951) 653-3351
F (951) 653-1662
www.babcocklabs.com
location
6100 Quail Valley Court
Riverside, CA 92507-0704
471
Client Name:

Report Date:

Woodard & Curran
P.O. Box 506
Daniel Peralta
Adelanto, CA 92301
Contact:

Address: Project Number:

Analytical Report: Page 5 of 11
Project Name:
26-Feb-2026
Work Order Number: C6B1333
Received on Ice (Y/N): Yes Temp: 5 °C
Adelanto Weekly WW 2026
Adelanto WWTP - Adelanto WWTP 19101 Jo
C6B1333
Result RDL Units Level
Spike
Result
Source
%REC
%REC
Limits RPD
RPD
Analyte(s) Limit Flag
Solids - Batch Quality Control
Batch 6B12142 - Analyzed as received
Blank (6B12142-BLK1) Prepared & Analyzed: 02/12/26
Total Dissolved Solids ND 10 10 mg/L
LCS (6B12142-BS1) Prepared & Analyzed: 02/12/26
Total Dissolved Solids 741 10 10 mg/L 746 99 90-110
Duplicate (6B12142-DUP1) Source: C6B1358-02 Prepared & Analyzed: 02/12/26 Total Dissolved Solids 628 10 10 mg/L 611 3 20
Duplicate (6B12142-DUP2) Source: C6B1461-01 Prepared & Analyzed: 02/12/26 Total Dissolved Solids 907 10 10 mg/L 869 4 20
Batch 6B17176 - Analyzed as received
Blank (6B17176-BLK1) Prepared & Analyzed: 02/17/26
Total Suspended Solids ND 0.5 0.5 mg/L
LCS (6B17176-BS1) Prepared & Analyzed: 02/17/26
Total Suspended Solids 512 5 5 mg/L 500 102 90-110
Duplicate (6B17176-DUP1) Source: C6B1280-01 Prepared & Analyzed: 02/17/26 Total Suspended Solids 260 10 10 mg/L 250 4 25
Duplicate (6B17176-DUP2) Source: C6B1768-01 Prepared & Analyzed: 02/17/26 Total Suspended Solids 1720 50 50 mg/L 1740 1 25
Batch 6B17177 - Analyzed as received
Blank (6B17177-BLK1) Prepared & Analyzed: 02/17/26
Total Suspended Solids ND 0.5 0.5 mg/L
mailing
6235 River Crest Dr. Ste H
Riverside, CA 92507
CA ELAP No. 2698
EPA No. CA00102
NELAP No. OR4035
LACSD No. 10119
P (951) 653-3351
F (951) 653-1662
www.babcocklabs.com
location
6100 Quail Valley Court
Riverside, CA 92507-0704
472
Client Name:

Report Date:

Woodard & Curran
P.O. Box 506
Daniel Peralta
Adelanto, CA 92301
Contact:

Address: Project Number:

Analytical Report: Page 6 of 11
Project Name:
26-Feb-2026
Work Order Number: C6B1333
Received on Ice (Y/N): Yes Temp: 5 °C
Adelanto Weekly WW 2026
Adelanto WWTP - Adelanto WWTP 19101 Jo
C6B1333
Result RDL Units Level
Spike
Result
Source
%REC
%REC
Limits RPD
RPD
Analyte(s) Limit Flag
Solids - Batch Quality Control
Batch 6B17177 - Analyzed as received
LCS (6B17177-BS1) Prepared & Analyzed: 02/17/26
Total Suspended Solids 489 5 5 mg/L 500 98 90-110
Duplicate (6B17177-DUP1) Source: C6B1260-01 Prepared & Analyzed: 02/17/26 Total Suspended Solids 456 10 10 mg/L 354 25 25
Duplicate (6B17177-DUP2) Source: C6B1328-02 Prepared & Analyzed: 02/17/26 Total Suspended Solids 492 20 20 mg/L 472 4 25
Batch 6B18113 - Analyzed as received
Blank (6B18113-BLK1) Prepared & Analyzed: 02/18/26
Total Dissolved Solids ND 10 10 mg/L
LCS (6B18113-BS1) Prepared & Analyzed: 02/18/26
Total Dissolved Solids 720 10 10 mg/L 746 97 90-110
Duplicate (6B18113-DUP1) Source: C6B2048-08 Prepared & Analyzed: 02/18/26 Total Dissolved Solids 161 10 128 20 QFpas,
QRPDo
10 mg/L 23
Duplicate (6B18113-DUP2) Source: C6B2138-01 Prepared & Analyzed: 02/18/26 Total Dissolved Solids 491 10 10 mg/L 479 2 20
mailing
6235 River Crest Dr. Ste H
Riverside, CA 92507
CA ELAP No. 2698
EPA No. CA00102
NELAP No. OR4035
LACSD No. 10119
P (951) 653-3351
F (951) 653-1662
www.babcocklabs.com
location
6100 Quail Valley Court
Riverside, CA 92507-0704
473
Client Name:

Report Date:

Woodard & Curran
P.O. Box 506
Daniel Peralta
Adelanto, CA 92301
Contact:

Address: Project Number:

Analytical Report: Page 7 of 11
Project Name:
26-Feb-2026
Work Order Number: C6B1333
Received on Ice (Y/N): Yes Temp: 5 °C
Adelanto Weekly WW 2026
Adelanto WWTP - Adelanto WWTP 19101 Jo
C6B1333
Result RDL Units Level
Spike
Result
Source
%REC
%REC
Limits RPD
RPD
Analyte(s) Limit Flag
Aggregate Organic Compounds - Batch Quality Control
Batch 6B11124 - Analyzed as received
Blank (6B11124-BLK1) Prepared & Analyzed: 02/11/26
Biochemical Oxygen
Demand
ND 1.0 1.0 mg/L
LCS (6B11124-BS1) Prepared & Analyzed: 02/11/26
Biochemical Oxygen
Demand
207 50 50 mg/L 198 105 85-115
Duplicate (6B11124-DUP1) Source: C6B1272-01 Prepared & Analyzed: 02/11/26 Biochemical Oxygen
Demand
176 50 50 mg/L 156 12 20
Batch 6B11129 - Analyzed as received
Blank (6B11129-BLK1) Prepared & Analyzed: 02/11/26
Biochemical Oxygen
Demand
ND 1.0 1.0 mg/L
LCS (6B11129-BS1) Prepared & Analyzed: 02/11/26
Biochemical Oxygen
Demand
203 50 50 mg/L 198 103 85-115
Duplicate (6B11129-DUP1) Source: C6B1260-01 Prepared & Analyzed: 02/11/26 Biochemical Oxygen
Demand
409 100 100 mg/L 442 8 20
mailing
6235 River Crest Dr. Ste H
Riverside, CA 92507
CA ELAP No. 2698
EPA No. CA00102
NELAP No. OR4035
LACSD No. 10119
P (951) 653-3351
F (951) 653-1662
www.babcocklabs.com
location
6100 Quail Valley Court
Riverside, CA 92507-0704
474
Client Name:

Report Date:

Woodard & Curran
P.O. Box 506
Daniel Peralta
Adelanto, CA 92301
Contact:

Address: Project Number:

Analytical Report: Page 8 of 11
Project Name:
26-Feb-2026
Work Order Number: C6B1333
Received on Ice (Y/N): Yes Temp: 5 °C
Adelanto Weekly WW 2026
Adelanto WWTP - Adelanto WWTP 19101 Jo
C6B1333
Result RDL Units Level
Spike
Result
Source
%REC
%REC
Limits RPD
RPD
Analyte(s) Limit Flag
Surfactants - Batch Quality Control
Batch 6B10208 - Solvent Extraction.

Blank (6B10208-BLK1) Prepared & Analyzed: 02/10/26
MBAS ND 0.08 0.02 mg/L
LCS (6B10208-BS1) Prepared & Analyzed: 02/10/26
MBAS 0.421 0.08 0.02 mg/L 0.400 105 90-110
Matrix Spike (6B10208-MS1) Source: C6B1057-01 Prepared & Analyzed: 02/10/26 MBAS 0.504 0.20 0.06 mg/L 0.500 ND 101 43-150
Matrix Spike Dup (6B10208-MSD1) Source: C6B1057-01 Prepared & Analyzed: 02/10/26 MBAS 0.482 0.20 0.06 mg/L 0.500 ND 96 43-150 4 30
mailing
6235 River Crest Dr. Ste H
Riverside, CA 92507
CA ELAP No. 2698
EPA No. CA00102
NELAP No. OR4035
LACSD No. 10119
P (951) 653-3351
F (951) 653-1662
www.babcocklabs.com
location
6100 Quail Valley Court
Riverside, CA 92507-0704
475
Client Name:

Report Date:

Woodard & Curran
P.O. Box 506
Daniel Peralta
Adelanto, CA 92301
Contact:

Address: Project Number:

Analytical Report: Page 9 of 11
Project Name:
26-Feb-2026
Work Order Number: C6B1333
Received on Ice (Y/N): Yes Temp: 5 °C
Adelanto Weekly WW 2026
Adelanto WWTP - Adelanto WWTP 19101 Jo
C6B1333
Result RDL Units Level
Spike
Result
Source
%REC
%REC
Limits RPD
RPD
Analyte(s) Limit Flag
Nutrients - Batch Quality Control
Batch 6B20010 - Analyzed as received
Blank (6B20010-BLK1) Prepared & Analyzed: 02/20/26
Ammonia-Nitrogen ND 0.1 0.06 mg/L
LCS (6B20010-BS1) Prepared & Analyzed: 02/20/26
Ammonia-Nitrogen 0.943 0.1 0.06 mg/L 1.00 94 90-110
Matrix Spike (6B20010-MS1) Source: C6B1436-02 Prepared & Analyzed: 02/20/26 Ammonia-Nitrogen 0.940 0.1 0.06 mg/L 1.00 ND 94 80-120
Matrix Spike Dup (6B20010-MSD1) Source: C6B1436-02 Prepared & Analyzed: 02/20/26 Ammonia-Nitrogen 0.876 0.1 0.06 mg/L 1.00 ND 88 80-120 7 20 Batch 6B20032 - Analyzed as received
Blank (6B20032-BLK1) Prepared: 02/20/26 Analyzed: 02/24/26 Kjeldahl Nitrogen ND 0.1 0.07 mg/L
LCS (6B20032-BS1) Prepared: 02/20/26 Analyzed: 02/24/26 Kjeldahl Nitrogen 1.11 0.1 0.07 mg/L 1.00 111 90-110
Matrix Spike (6B20032-MS1) Source: C6B1385-01 Prepared: 02/20/26 Analyzed: 02/24/26 Kjeldahl Nitrogen 1.87 0.1 0.07 mg/L 1.00 0.789 108 80-120 Matrix Spike Dup (6B20032-MSD1) Source: C6B1385-01 Prepared: 02/20/26 Analyzed: 02/24/26 Kjeldahl Nitrogen 1.87 0.1 0.07 mg/L 1.00 0.789 108 80-120 0 25 mailing
6235 River Crest Dr. Ste H
Riverside, CA 92507
CA ELAP No. 2698
EPA No. CA00102
NELAP No. OR4035
LACSD No. 10119
P (951) 653-3351
F (951) 653-1662
www.babcocklabs.com
location
6100 Quail Valley Court
Riverside, CA 92507-0704
476
Client Name:

Report Date:

Woodard & Curran
P.O. Box 506
Daniel Peralta
Adelanto, CA 92301
Contact:

Address: Project Number:

Analytical Report: Page 10 of 11
Project Name:
26-Feb-2026
Work Order Number: C6B1333
Received on Ice (Y/N): Yes Temp: 5 °C
Adelanto Weekly WW 2026
Adelanto WWTP - Adelanto WWTP 19101 Jo
C6B1333
Notes and Definitions
J Estimated value
N-BOD1 Dilution water blank exceeds 0.20 mg/L. As per method, data is reportable as qualified.

Nconf Result(s) confirmed by re-analysis.

QFpas Follow-up result within laboratory acceptance criteria.

QRPDo The RPD value for the sample duplicate or MS/MSD did not meet laboratory acceptance criteria.

NR Not Reported
ND Analyte NOT DETECTED at or above the Method Detection Limit (if MDL is reported), otherwise at or above the Reportable Detection Limit (RDL)
RDL Reportable Detection Limit
MDL Method Detection Limit
* / (Non-NELAP) NELAP does not offer accreditation for this analyte/method/matrix combination e-Standard_No Alias.rpt
This report applies only to the sample(s) analyzed. As a mutual protection to clients, the public, and Babcock Laboratories, Inc., this report is submitted and accepted for the exclusive use of the Client to whom it is addressed. Interpretation and use of the information contained within this report are the sole responsibility of the Client. Babcock Laboratories, Inc. is not responsible for any misinformation or consequences that may result from misinterpretation or improper use of this report. This report is not to be modified or abbreviated in any way.

Additionally, this report is not to be used, in whole or in part, in any advertising or publicity matter without written authorization from Babcock Laboratories, Inc. The liability of Babcock Laboratories, Inc. is limited to the actual cost of the requested analyses, unless otherwise agreed upon in writing. There is no other warranty expressed or implied.

Enclosed are the analytical results for the submitted sample(s). Babcock Laboratories certify the data presented as part of this report meet the minimum quality standards in the referenced analytical methods. Any exceptions have been noted.

Approval
cc:

Estrella Z Vargas For Cindy A. Waddell
mailing
6235 River Crest Dr. Ste H
Riverside, CA 92507
CA ELAP No. 2698
EPA No. CA00102
NELAP No. OR4035
LACSD No. 10119
P (951) 653-3351
F (951) 653-1662
www.babcocklabs.com
location
6100 Quail Valley Court
Riverside, CA 92507-0704
477
Client Name:

Report Date:

Woodard & Curran
P.O. Box 506
Daniel Peralta
Adelanto, CA 92301
Contact:

Address: Project Number:

Analytical Report: Page 11 of 11
Project Name:
26-Feb-2026
Work Order Number: C6B1333
Received on Ice (Y/N): Yes Temp: 5 °C
Adelanto Weekly WW 2026
Adelanto WWTP - Adelanto WWTP 19101 Jo
C6B1333
mailing
6235 River Crest Dr. Ste H
Riverside, CA 92507
CA ELAP No. 2698
EPA No. CA00102
NELAP No. OR4035
LACSD No. 10119
P (951) 653-3351
F (951) 653-1662
www.babcocklabs.com
location
6100 Quail Valley Court
Riverside, CA 92507-0704
478
Client Name:

Report Date:

Woodard & Curran
P.O. Box 506
Daniel Peralta
Adelanto, CA 92301
Contact:

Address: Project Number:

Analytical Report: Page 1 of 10
Project Name:
27-Feb-2026
Work Order Number: C6B2239
Received on Ice (Y/N): Yes Temp: 4 °C
Adelanto - Weekly/BiWeekly WW 2026
Adelanto WWTP - Adelanto WWTP 19101 Jo
C6B2239
Attached is the analytical report for the sample(s) received for your project. Below is a list of the individual sample descriptions with the corresponding laboratory number(s). Also, enclosed is a copy of the Chain of Custody document (if received with your sample(s)). Please note any unused portion of the sample(s) may be responsibly discarded after 30 days from the above report date, unless you have requested otherwise.

Thank you for the opportunity to serve your analytical needs. If you have any questions or concerns regarding this report please contact our client service department.

Sample Identification
Lab Sample # Client Sample ID Matrix Date Sampled By Date Submitted By C6B2239-01 Liquid 02/18/26 6:38 James Strong Courier
(Guillermo)-DE
Influent ---ROUTINE--- 02/18/26 12:41
C6B2239-02 Liquid 02/18/26 6:20 James Strong Courier
(Guillermo)-DE
Effluent ---ROUTINE--- 02/18/26 12:41
mailing
6235 River Crest Dr. Ste H
Riverside, CA 92507
CA ELAP No. 2698
EPA No. CA00102
NELAP No. OR4035
LACSD No. 10119
P (951) 653-3351
F (951) 653-1662
www.babcocklabs.com
location
6100 Quail Valley Court
Riverside, CA 92507-0704
479
Client Name:

Report Date:

Woodard & Curran
P.O. Box 506
Daniel Peralta
Adelanto, CA 92301
Contact:

Address: Project Number:

Analytical Report: Page 2 of 10
Project Name:
27-Feb-2026
Work Order Number: C6B2239
Received on Ice (Y/N): Yes Temp: 4 °C
Adelanto - Weekly/BiWeekly WW 2026
Adelanto WWTP - Adelanto WWTP 19101 Jo
C6B2239
Laboratory Reference Number
Sample Description
02/18/26 06:38
Sampled Date/Time Received Date/Time
02/18/26 12:41
Matrix
Influent Liquid
C6B2239-01
Analyte(s) Result RDL MDL Units Method Analysis Date Analyst Flag Solids
Total Dissolved Solids 600 20 20 mg/L SM 2540C 02/19/26 19:55 AAR Total Suspended Solids 280 10 10 mg/L SM 2540D 02/24/26 13:08 VMV Aggregate Organic Compounds
Biochemical Oxygen Demand 310 50 50 mg/L SM 5210B 02/18/26 22:51 CXR Nutrients
Ammonia-Nitrogen 37 5.1 3.3 mg/L SM 4500NH3 G 02/23/26 11:19 RUB mailing
6235 River Crest Dr. Ste H
Riverside, CA 92507
CA ELAP No. 2698
EPA No. CA00102
NELAP No. OR4035
LACSD No. 10119
P (951) 653-3351
F (951) 653-1662
www.babcocklabs.com
location
6100 Quail Valley Court
Riverside, CA 92507-0704
480
Client Name:

Report Date:

Woodard & Curran
P.O. Box 506
Daniel Peralta
Adelanto, CA 92301
Contact:

Address: Project Number:

Analytical Report: Page 3 of 10
Project Name:
27-Feb-2026
Work Order Number: C6B2239
Received on Ice (Y/N): Yes Temp: 4 °C
Adelanto - Weekly/BiWeekly WW 2026
Adelanto WWTP - Adelanto WWTP 19101 Jo
C6B2239
Laboratory Reference Number
Sample Description
02/18/26 06:20
Sampled Date/Time Received Date/Time
02/18/26 12:41
Matrix
Effluent Liquid
C6B2239-02
Analyte(s) Result RDL MDL Units Method Analysis Date Analyst Flag Anions
Nitrate as N 2.6 0.20 0.12 mg/L EPA 300.0 02/19/26 03:27 VMV Nitrite as N 0.1 0.1 0.05 mg/L EPA 300.0 02/19/26 03:27 VMV Solids
Total Dissolved Solids 520 10 10 mg/L SM 2540C 02/19/26 19:55 AAR Total Suspended Solids 4 0.6 0.6 mg/L SM 2540D 02/24/26 13:08 VMV Aggregate Organic Compounds
Biochemical Oxygen Demand 3.8 2.5 2.5 mg/L SM 5210B 02/18/26 22:51 CXR Surfactants
MBAS 0.03 0.08 0.02 mg/L SM 5540C 02/18/26 21:40 CLP J
Nutrients
Ammonia-Nitrogen 0.3 0.1 0.06 mg/L SM 4500NH3 G 02/23/26 11:21 RUB Kjeldahl Nitrogen 1.5 0.1 0.07 mg/L EPA 351.2 02/24/26 20:17 NR Total Nitrogen 4.2 0.40 mg/L Calculation
mailing
6235 River Crest Dr. Ste H
Riverside, CA 92507
CA ELAP No. 2698
EPA No. CA00102
NELAP No. OR4035
LACSD No. 10119
P (951) 653-3351
F (951) 653-1662
www.babcocklabs.com
location
6100 Quail Valley Court
Riverside, CA 92507-0704
481
Client Name:

Report Date:

Woodard & Curran
P.O. Box 506
Daniel Peralta
Adelanto, CA 92301
Contact:

Address: Project Number:

Analytical Report: Page 4 of 10
Project Name:
27-Feb-2026
Work Order Number: C6B2239
Received on Ice (Y/N): Yes Temp: 4 °C
Adelanto - Weekly/BiWeekly WW 2026
Adelanto WWTP - Adelanto WWTP 19101 Jo
C6B2239
Result RDL Units Level
Spike
Result
Source
%REC
%REC
Limits RPD
RPD
Analyte(s) Limit Flag
Anions - Batch Quality Control
Batch 6B18133 - Analyzed as Received IC
Blank (6B18133-BLK1) Prepared & Analyzed: 02/18/26
Nitrite as N ND 0.1 0.05 mg/L
Nitrate as N ND 0.20 0.12 mg/L
LCS (6B18133-BS1) Prepared & Analyzed: 02/18/26
Nitrite as N 2.35 0.1 0.05 mg/L 2.50 94 90-110
Nitrate as N 5.49 0.20 0.12 mg/L 5.65 97 90-110
Duplicate (6B18133-DUP1) Source: C6B2212-01 Prepared & Analyzed: 02/18/26 Nitrite as N ND 0.1 0.05 mg/L 0.200 20
Nitrate as N ND 0.20 0.12 mg/L ND 20
Matrix Spike (6B18133-MS1) Source: C6B2212-01 Prepared & Analyzed: 02/18/26 Nitrite as N 11.3 0.5 0.3 mg/L 12.5 ND 90 80-120
Nitrate as N 27.1 1.0 0.62 mg/L 28.2 ND 96 80-120
Matrix Spike (6B18133-MS2) Source: C6B2280-01 Prepared & Analyzed: 02/19/26 Nitrite as N 2.33 0.1 0.05 mg/L 2.50 ND 93 80-120
Nitrate as N 5.34 0.20 0.12 mg/L 5.65 ND 95 80-120
Matrix Spike Dup (6B18133-MSD1) Source: C6B2212-01 Prepared & Analyzed: 02/18/26 Nitrite as N 11.5 0.5 0.3 mg/L 12.5 ND 92 80-120 2 20
Nitrate as N 27.1 1.0 0.62 mg/L 28.2 ND 96 80-120 0.1 20 mailing
6235 River Crest Dr. Ste H
Riverside, CA 92507
CA ELAP No. 2698
EPA No. CA00102
NELAP No. OR4035
LACSD No. 10119
P (951) 653-3351
F (951) 653-1662
www.babcocklabs.com
location
6100 Quail Valley Court
Riverside, CA 92507-0704
482
Client Name:

Report Date:

Woodard & Curran
P.O. Box 506
Daniel Peralta
Adelanto, CA 92301
Contact:

Address: Project Number:

Analytical Report: Page 5 of 10
Project Name:
27-Feb-2026
Work Order Number: C6B2239
Received on Ice (Y/N): Yes Temp: 4 °C
Adelanto - Weekly/BiWeekly WW 2026
Adelanto WWTP - Adelanto WWTP 19101 Jo
C6B2239
Result RDL Units Level
Spike
Result
Source
%REC
%REC
Limits RPD
RPD
Analyte(s) Limit Flag
Solids - Batch Quality Control
Batch 6B19118 - Analyzed as received
Blank (6B19118-BLK1) Prepared & Analyzed: 02/19/26
Total Dissolved Solids ND 10 10 mg/L
LCS (6B19118-BS1) Prepared & Analyzed: 02/19/26
Total Dissolved Solids 731 10 10 mg/L 746 98 90-110
Duplicate (6B19118-DUP1) Source: C6B2038-02 Prepared & Analyzed: 02/19/26 Total Dissolved Solids 687 10 10 mg/L 689 0.3 20
Duplicate (6B19118-DUP2) Source: C6B2140-01 Prepared & Analyzed: 02/19/26 Total Dissolved Solids 574 10 10 mg/L 573 0.2 20
Batch 6B24144 - Analyzed as received
Blank (6B24144-BLK1) Prepared & Analyzed: 02/24/26
Total Suspended Solids ND 0.5 0.5 mg/L
LCS (6B24144-BS1) Prepared & Analyzed: 02/24/26
Total Suspended Solids 511 5 5 mg/L 500 102 90-110
Duplicate (6B24144-DUP1) Source: C6B2162-01 Prepared & Analyzed: 02/24/26 Total Suspended Solids 372 10 10 mg/L 372 0 25
Duplicate (6B24144-DUP2) Source: C6B2390-02 Prepared & Analyzed: 02/24/26 Total Suspended Solids 222 10 10 mg/L 224 0.9 25
mailing
6235 River Crest Dr. Ste H
Riverside, CA 92507
CA ELAP No. 2698
EPA No. CA00102
NELAP No. OR4035
LACSD No. 10119
P (951) 653-3351
F (951) 653-1662
www.babcocklabs.com
location
6100 Quail Valley Court
Riverside, CA 92507-0704
483
Client Name:

Report Date:

Woodard & Curran
P.O. Box 506
Daniel Peralta
Adelanto, CA 92301
Contact:

Address: Project Number:

Analytical Report: Page 6 of 10
Project Name:
27-Feb-2026
Work Order Number: C6B2239
Received on Ice (Y/N): Yes Temp: 4 °C
Adelanto - Weekly/BiWeekly WW 2026
Adelanto WWTP - Adelanto WWTP 19101 Jo
C6B2239
Result RDL Units Level
Spike
Result
Source
%REC
%REC
Limits RPD
RPD
Analyte(s) Limit Flag
Aggregate Organic Compounds - Batch Quality Control
Batch 6B18138 - Analyzed as received
Blank (6B18138-BLK1) Prepared & Analyzed: 02/18/26
Biochemical Oxygen
Demand
ND 1.0 1.0 mg/L
LCS (6B18138-BS1) Prepared & Analyzed: 02/18/26
Biochemical Oxygen
Demand
206 50 50 mg/L 198 104 85-115
Duplicate (6B18138-DUP1) Source: C6B2141-01 Prepared & Analyzed: 02/18/26 Biochemical Oxygen
Demand

43.5 20 20 mg/L 45.2 4 20
mailing
6235 River Crest Dr. Ste H
Riverside, CA 92507
CA ELAP No. 2698
EPA No. CA00102
NELAP No. OR4035
LACSD No. 10119
P (951) 653-3351
F (951) 653-1662
www.babcocklabs.com
location
6100 Quail Valley Court
Riverside, CA 92507-0704
484
Client Name:

Report Date:

Woodard & Curran
P.O. Box 506
Daniel Peralta
Adelanto, CA 92301
Contact:

Address: Project Number:

Analytical Report: Page 7 of 10
Project Name:
27-Feb-2026
Work Order Number: C6B2239
Received on Ice (Y/N): Yes Temp: 4 °C
Adelanto - Weekly/BiWeekly WW 2026
Adelanto WWTP - Adelanto WWTP 19101 Jo
C6B2239
Result RDL Units Level
Spike
Result
Source
%REC
%REC
Limits RPD
RPD
Analyte(s) Limit Flag
Surfactants - Batch Quality Control
Batch 6B17237 - Solvent Extraction.

Blank (6B17237-BLK1) Prepared & Analyzed: 02/17/26
MBAS ND 0.08 0.02 mg/L
LCS (6B17237-BS1) Prepared & Analyzed: 02/17/26
MBAS 0.440 0.08 0.02 mg/L 0.400 110 90-110
Matrix Spike (6B17237-MS1) Source: C6B1929-01 Prepared & Analyzed: 02/17/26 MBAS 0.495 0.20 0.06 mg/L 0.500 ND 99 80-120
Matrix Spike Dup (6B17237-MSD1) Source: C6B1929-01 Prepared & Analyzed: 02/17/26 MBAS 0.455 0.20 0.06 mg/L 0.500 ND 91 80-120 8 25
mailing
6235 River Crest Dr. Ste H
Riverside, CA 92507
CA ELAP No. 2698
EPA No. CA00102
NELAP No. OR4035
LACSD No. 10119
P (951) 653-3351
F (951) 653-1662
www.babcocklabs.com
location
6100 Quail Valley Court
Riverside, CA 92507-0704
485
Client Name:

Report Date:

Woodard & Curran
P.O. Box 506
Daniel Peralta
Adelanto, CA 92301
Contact:

Address: Project Number:

Analytical Report: Page 8 of 10
Project Name:
27-Feb-2026
Work Order Number: C6B2239
Received on Ice (Y/N): Yes Temp: 4 °C
Adelanto - Weekly/BiWeekly WW 2026
Adelanto WWTP - Adelanto WWTP 19101 Jo
C6B2239
Result RDL Units Level
Spike
Result
Source
%REC
%REC
Limits RPD
RPD
Analyte(s) Limit Flag
Nutrients - Batch Quality Control
Batch 6B23141 - Analyzed as received
Blank (6B23141-BLK1) Prepared & Analyzed: 02/23/26
Ammonia-Nitrogen ND 0.1 0.06 mg/L
LCS (6B23141-BS1) Prepared & Analyzed: 02/23/26
Ammonia-Nitrogen 0.981 0.1 0.06 mg/L 1.00 98 90-110
Matrix Spike (6B23141-MS1) Source: C6B1995-02 Prepared & Analyzed: 02/23/26 Ammonia-Nitrogen 0.916 0.1 0.06 mg/L 1.00 ND 92 80-120
Matrix Spike Dup (6B23141-MSD1) Source: C6B1995-02 Prepared & Analyzed: 02/23/26 Ammonia-Nitrogen 0.915 0.1 0.06 mg/L 1.00 ND 92 80-120 0.1 20 Batch 6B23158 - Acid Digest
Blank (6B23158-BLK1) Prepared & Analyzed: 02/24/26
Kjeldahl Nitrogen ND 0.1 0.07 mg/L
LCS (6B23158-BS1) Prepared & Analyzed: 02/24/26
Kjeldahl Nitrogen 0.922 0.1 0.07 mg/L 1.00 92 80-120
Matrix Spike (6B23158-MS1) Source: C6B1994-05 Prepared & Analyzed: 02/24/26 Kjeldahl Nitrogen 0.898 0.1 0.07 mg/L 1.00 ND 90 42-154 Matrix Spike Dup (6B23158-MSD1) Source: C6B1994-05 Prepared & Analyzed: 02/24/26 Kjeldahl Nitrogen 0.925 0.1 0.07 mg/L 1.00 ND 92 42-154 3 25 mailing
6235 River Crest Dr. Ste H
Riverside, CA 92507
CA ELAP No. 2698
EPA No. CA00102
NELAP No. OR4035
LACSD No. 10119
P (951) 653-3351
F (951) 653-1662
www.babcocklabs.com
location
6100 Quail Valley Court
Riverside, CA 92507-0704
486
Client Name:

Report Date:

Woodard & Curran
P.O. Box 506
Daniel Peralta
Adelanto, CA 92301
Contact:

Address: Project Number:

Analytical Report: Page 9 of 10
Project Name:
27-Feb-2026
Work Order Number: C6B2239
Received on Ice (Y/N): Yes Temp: 4 °C
Adelanto - Weekly/BiWeekly WW 2026
Adelanto WWTP - Adelanto WWTP 19101 Jo
C6B2239
Notes and Definitions
J Estimated value
NR Not Reported
ND Analyte NOT DETECTED at or above the Method Detection Limit (if MDL is reported), otherwise at or above the Reportable Detection Limit (RDL)
RDL Reportable Detection Limit
MDL Method Detection Limit
* / (Non-NELAP) NELAP does not offer accreditation for this analyte/method/matrix combination e-Standard_No Alias.rpt
This report applies only to the sample(s) analyzed. As a mutual protection to clients, the public, and Babcock Laboratories, Inc., this report is submitted and accepted for the exclusive use of the Client to whom it is addressed. Interpretation and use of the information contained within this report are the sole responsibility of the Client. Babcock Laboratories, Inc. is not responsible for any misinformation or consequences that may result from misinterpretation or improper use of this report. This report is not to be modified or abbreviated in any way.

Additionally, this report is not to be used, in whole or in part, in any advertising or publicity matter without written authorization from Babcock Laboratories, Inc. The liability of Babcock Laboratories, Inc. is limited to the actual cost of the requested analyses, unless otherwise agreed upon in writing. There is no other warranty expressed or implied.

Enclosed are the analytical results for the submitted sample(s). Babcock Laboratories certify the data presented as part of this report meet the minimum quality standards in the referenced analytical methods. Any exceptions have been noted.

Approval
cc:

Cindy A. Waddell
mailing
6235 River Crest Dr. Ste H
Riverside, CA 92507
CA ELAP No. 2698
EPA No. CA00102
NELAP No. OR4035
LACSD No. 10119
P (951) 653-3351
F (951) 653-1662
www.babcocklabs.com
location
6100 Quail Valley Court
Riverside, CA 92507-0704
487
Client Name:

Report Date:

Woodard & Curran
P.O. Box 506
Daniel Peralta
Adelanto, CA 92301
Contact:

Address: Project Number:

Analytical Report: Page 10 of 10
Project Name:
27-Feb-2026
Work Order Number: C6B2239
Received on Ice (Y/N): Yes Temp: 4 °C
Adelanto - Weekly/BiWeekly WW 2026
Adelanto WWTP - Adelanto WWTP 19101 Jo
C6B2239
mailing
6235 River Crest Dr. Ste H
Riverside, CA 92507
CA ELAP No. 2698
EPA No. CA00102
NELAP No. OR4035
LACSD No. 10119
P (951) 653-3351
F (951) 653-1662
www.babcocklabs.com
location
6100 Quail Valley Court
Riverside, CA 92507-0704
488
Adelanto - Weekly/BiWeekly
WW 2026
Adelanto WWTP - Adelanto
WWTP 19101 Jonathan St.

Project Name:

Analytical Report: Page 1 of 5
Project Number:

Address:

Contact:

Adelanto, CA 92301
Daniel Peralta
P.O. Box 506
Client Name: Woodard & Curran
Report Date: 11-Mar-2026 Work Order Number:

Received on Ice (Y/N): Yes Temp: 5 °C
C6B3019
Attached is the analytical report for the sample(s) received for your project. Below is a list of the individual sample descriptions with the corresponding laboratory number(s). Also, enclosed is a copy of the Chain of Custody document (if received with your sample(s)). Please note any unused portion of the sample(s) may be responsibly discarded after 30 days from the above report date, unless you have requested otherwise.

Thank you for the opportunity to serve your analytical needs. If you have any questions or concerns regarding this report please contact our client service department.

Lab Sample # Client Sample ID Matrix Date Sampled
Sample Identification
By Date Submitted By
C6B3019-01 Liquid 02/25/26 06:15 Scott Heller 02/25/26 12:19 Courier (Guillermo) -DE
Influent ---ROUTINE---
C6B3019-02 Liquid 02/25/26 06:30 Scott Heller 02/25/26 12:19 Courier (Guillermo) -DE
Effluent ---ROUTINE---
mailing
6235 River Crest Dr. Ste H
Riverside, CA 92507
CA ELAP No. 2698
EPA No. CA00102
NELAP No. OR4035
LACSD No. 10119
P (951) 653-3351
F (951) 653-1662
www.babcocklabs.com
Babcock Laboratories, Inc. - Riverside
6100 Quail Valley Court
Riverside, CA 92507-0704
489
Adelanto - Weekly/BiWeekly
WW 2026
Adelanto WWTP - Adelanto
WWTP 19101 Jonathan St.

Project Name:

Analytical Report: Page 2 of 5
Project Number:

Address:

Contact:

Adelanto, CA 92301
Daniel Peralta
P.O. Box 506
Client Name: Woodard & Curran
Report Date: 11-Mar-2026 Work Order Number:

Received on Ice (Y/N): Yes Temp: 5 °C
C6B3019
Laboratory Reference Number
Sample Description
02/25/26 06:15
Sampled Date/Time Received Date/Time
02/25/26 12:19
Matrix
Influent Liquid
C6B3019-01
Analyte(s) Result RDL MDL Units Method Analysis Date Analyst Flag Testing performed by: Babcock Laboratories, Inc. - Riverside CA ELAP No. 2698, EPA No. CA00102, NELAP No. OR4035
Solids
Total Dissolved Solids 620 20 mg/L SM 2540C 02/26/26 13:36 EZP Total Suspended Solids 310 10 mg/L SM 2540D 03/02/26 19:32 SXA Aggregate Organic Compounds
Biochemical Oxygen Demand 200 50 mg/L SM 5210B 02/25/26 21:26 CXR Nutrients
Ammonia-Nitrogen 37 5.0 3.2 mg/L SM 4500NH3 G 03/02/26 10:57 RUB mailing
6235 River Crest Dr. Ste H
Riverside, CA 92507
CA ELAP No. 2698
EPA No. CA00102
NELAP No. OR4035
LACSD No. 10119
P (951) 653-3351
F (951) 653-1662
www.babcocklabs.com
Babcock Laboratories, Inc. - Riverside
6100 Quail Valley Court
Riverside, CA 92507-0704
490
Adelanto - Weekly/BiWeekly
WW 2026
Adelanto WWTP - Adelanto
WWTP 19101 Jonathan St.

Project Name:

Analytical Report: Page 3 of 5
Project Number:

Address:

Contact:

Adelanto, CA 92301
Daniel Peralta
P.O. Box 506
Client Name: Woodard & Curran
Report Date: 11-Mar-2026 Work Order Number:

Received on Ice (Y/N): Yes Temp: 5 °C
C6B3019
Laboratory Reference Number
Sample Description
02/25/26 06:30
Sampled Date/Time Received Date/Time
02/25/26 12:19
Matrix
Effluent Liquid
C6B3019-02
Analyte(s) Result RDL MDL Units Method Analysis Date Analyst Flag Testing performed by: Babcock Laboratories, Inc. - Riverside CA ELAP No. 2698, EPA No. CA00102, NELAP No. OR4035
Anions
Nitrate as N 0.69 0.20 mg/L EPA 300.0 02/25/26 21:14 VMV Nitrite as N ND 0.1 mg/L EPA 300.0 02/25/26 21:14 VMV
Solids
Total Dissolved Solids 540 10 mg/L SM 2540C 02/26/26 13:36 EZP Total Suspended Solids 2 0.5 mg/L SM 2540D 03/02/26 19:32 SXA Aggregate Organic Compounds
Biochemical Oxygen Demand 3.2 2.5 mg/L SM 5210B 02/25/26 21:26 CXR N-BOD1 Surfactants
MBAS ND 0.08 mg/L SM 5540C 02/25/26 21:11 CLP
Nutrients
Ammonia-Nitrogen 1.2 0.1 0.06 mg/L SM 4500NH3 G 03/02/26 11:00 RUB Kjeldahl Nitrogen 2.2 0.2 mg/L EPA 351.2 03/10/26 14:54 AMB Total Nitrogen 2.9 0.50 mg/L Calculation
mailing
6235 River Crest Dr. Ste H
Riverside, CA 92507
CA ELAP No. 2698
EPA No. CA00102
NELAP No. OR4035
LACSD No. 10119
P (951) 653-3351
F (951) 653-1662
www.babcocklabs.com
Babcock Laboratories, Inc. - Riverside
6100 Quail Valley Court
Riverside, CA 92507-0704
491
Adelanto - Weekly/BiWeekly
WW 2026
Adelanto WWTP - Adelanto
WWTP 19101 Jonathan St.

Project Name:

Analytical Report: Page 4 of 5
Project Number:

Address:

Contact:

Adelanto, CA 92301
Daniel Peralta
P.O. Box 506
Client Name: Woodard & Curran
Report Date: 11-Mar-2026 Work Order Number:

Received on Ice (Y/N): Yes Temp: 5 °C
C6B3019
Notes and Definitions
N-BOD1 Dilution water blank exceeds 0.20 mg/L. As per method, data is reportable as qualified.

NR Not Reported
ND Analyte NOT DETECTED at or above the Method Detection Limit (if MDL is reported), otherwise at or above the Reportable Detection Limit (RDL)
RDL Reportable Detection Limit
MDL Method Detection Limit
* / ''' NELAP does not offer accreditation for this analyte/method/matrix combination e-Short_No Alias.rpt
This report applies only to the sample(s) analyzed. As a mutual protection to clients, the public, and Babcock Laboratories, Inc., this report is submitted and accepted for the exclusive use of the Client to whom it is addressed. Interpretation and use of the information contained within this report are the sole responsibility of the Client. Babcock Laboratories, Inc. is not responsible for any misinformation or consequences that may result from misinterpretation or improper use of this report. This report is not to be modified or abbreviated in any way.

Additionally, this report is not to be used, in whole or in part, in any advertising or publicity matter without written authorization from Babcock Laboratories, Inc. The liability of Babcock Laboratories, Inc. is limited to the actual cost of the requested analyses, unless otherwise agreed upon in writing. There is no other warranty expressed or implied.

Enclosed are the analytical results for the submitted sample(s). Babcock Laboratories certify the data presented as part of this report meet the minimum quality standards in the referenced analytical methods. Any exceptions have been noted.

Approval
cc:

Estrella Z Vargas For Cindy A. Waddell
mailing
6235 River Crest Dr. Ste H
Riverside, CA 92507
CA ELAP No. 2698
EPA No. CA00102
NELAP No. OR4035
LACSD No. 10119
P (951) 653-3351
F (951) 653-1662
www.babcocklabs.com
Babcock Laboratories, Inc. - Riverside
6100 Quail Valley Court
Riverside, CA 92507-0704
492
Adelanto - Weekly/BiWeekly
WW 2026
Adelanto WWTP - Adelanto
WWTP 19101 Jonathan St.

Project Name:

Analytical Report: Page 5 of 5
Project Number:

Address:

Contact:

Adelanto, CA 92301
Daniel Peralta
P.O. Box 506
Client Name: Woodard & Curran
Report Date: 11-Mar-2026 Work Order Number:

Received on Ice (Y/N): Yes Temp: 5 °C
C6B3019
mailing
6235 River Crest Dr. Ste H
Riverside, CA 92507
CA ELAP No. 2698
EPA No. CA00102
NELAP No. OR4035
LACSD No. 10119
P (951) 653-3351
F (951) 653-1662
www.babcocklabs.com
Babcock Laboratories, Inc. - Riverside
6100 Quail Valley Court
Riverside, CA 92507-0704
493

ADELANTO PUBLIC UTILITY AUTHORITY
A D E L A N T O G O V E R N M E N T A L C E N T E R | 1 1 6 0 0 A I R E X P R E S S W A Y | A D E L A N T O , C A L I F O R N I A 9 2 3 0 1
DATE: May 13, 2026
TO: Honorable Chairman, and Public Utility Authority Members FROM: Jessie Flores, Executive Director
BY: Virginia Velis, Deputy City Clerk, Executive Assistant SUBJECT: APPROVAL OF CONTRACT AMENDMENT NO.2 BETWEEN MARIA DEL CARMEN

ESQUIVEL, DBA C&C INTERPRETING SERVICES, THE CITY OF ADELANTO AND

ADELANTO PUBLIC UTILITY AUTHORITY
STAFF RECOMMENDATION:

It is recommended that the City Council and Adelanto Public Utility Authority approve Amendment No. 2 to the Professional Services Agreement with C&C Interpreting Services to ensure continued access to vital translation and interpreting services.

BACKGROUND:

The City of Adelanto contracted with C&C Interpreting Services on August 1, 2022, for translation services under the City Managers signing Authority. Amendment No. 1 was approved on September 25, 2024, during a City Council Meeting. The initial contract expired, and the City would like to extend it by 1 year. The contract needs to be Increased by $24,000 for a not to exceed amount of $64,000.

To continue fostering effective communication with our non-English speaking residents and to enhance community engagement, we propose the following amendments:
• Extension of Contract Term:

An extension of one additional year, allowing continued access to high-quality interpreting services.
• Compensation:

An increase to the contract in the amount of $24,000 for a not to exceed amount of $64,000.

These adjustments will enable us to maintain our commitment to inclusivity and effective service delivery, ensuring that all community members can participate fully in local governance.

FISCAL IMPACT: $24,000 contract amount not to exceed $64,000 to be split between the City and APUA ATTACHMENTS:

1. Amendment No. 2 document

2. Amendment No. 2 document

3. Original Agreement
494

CITY OF ADELANTO AND ADELANTO PUBLIC UTILITY AUTHORITY
AMENDMENT NO. 2 TO

PROFESSIONAL SERVICES AGREEMENT AS-NEEDED FOREIGN LAUNGUAGE TRANSLATION AND INTERPRETING SERVICES (PARTIES: MARIA DEL

CARMEN ESQUIVEL, DBA C&C INTERPRETING SERVICES AND THE CITY OF

ADELANTO)
This is Amendment No. Two (“Amendment No.2”) to that certain Professional Services Agreement As-Needed Foreign Language Translation and Interpreting Services (Parties: Maria Del Carmen Esquivel, Dba C&C Interpreting Services and the City Of Adelanto) (“Agreement”) made on August 1, 2022 between City of Adelanto, a California municipal corporation, (“City”), the Adelanto Public Utility Authority, (APUA) a joint powers authority and Amendment No. 1 made on September 25, 2024, and Maria Del Carmen Esquivel, dba C&C Interpreting Services (“Consultant), which this Amendment No. 2 is made and entered into on May 13, 2026, to extend the term.

1. Capitalized terms used but not defined in this Amendment No. 2 shall have the meanings ascribed to them in the Agreement.

2. Subsection 1.1 Term is amended to read as follows:

Section 1.1, “Term of Services” is amended to read as follows:

1.1 Term of Services. The term of this Agreement shall begin on May 13, 2026, and shall end on May 13, 2028, unless the term of the Agreement is otherwise terminated or extended as provided for in Section 5.1. The time provided to C&C Interpreting to complete the services required by this Agreement shall not affect the City's or Adelanto Public Utility Authority right to terminate the Agreement, as provided for in Section 5.1.

SECTION 1.4, “Compensation” is amended to read as follows, increasing the contract amount by: TWENTY-FOUR THOUSAND DOLLARS AND ZERO CENTS ($24,000) 495
AMENDMENT NO. [2]
SECTION 1.4. COMPENSATION.

City and Adelanto Public Utility Authority hereby agree to pay C&C Interpreting a sum not to exceed Sixty-Four Thousand Dollars and Zero Cents ($64,000) notwithstanding any contrary indications that may be contained in C&C Interpreting proposal, for the Services to be performed and reimbursable costs incurred under this Agreement. In the event of a conflict between this Agreement and Exhibit A, regarding the amount of compensation, this Agreement shall prevail. City and APUA shall pay C&C Interpreting for the Services rendered pursuant to this Agreement at the time and in the manner set forth herein. The payments specified below shall be the only payments from City to C&C Interpreting for the Services rendered pursuant to this Agreement. Contractor shall submit all invoices to City in the manner specified herein. Except as specifically authorized in advance by City, C&C Interpreting shall not bill City for duplicate services performed by more than one person.

Exhibit A, “Scope of Services” is supplemented to include the supplement attached as Exhibit A hereto. The supplement to the “Scope of Services” is not intended to replace the original Exhibit A to the Agreement, but instead to augment and increase the scope of work listed in the original Exhibit A to the Agreement. The initial paragraph of the original Exhibit A, “Scope of Services”, to the Agreement is amended to read as follows:

EXHIBIT A

SCOPE OF SERVICES
Contractor shall provide As-Needed Foreign Language Translation and Interpreting Services in an amount not to exceed $64,000.

3. All other terms and conditions of the Agreement remain in full force and effect.

4. This Amendment No. 2 may be executed in multiple counterparts, each of which shall be original and all of which together shall constitute one agreement. (Signatures on Following Page)
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AMENDMENT NO. [2]

CITY OF ADELANTO
Jessie Flores, City Manager
Jessie Flores, Executive Director
Attest:

Brenda Lopez, City Clerk
Approved as to Form:

Todd Litfin, City Attorney

CONSULTANT
Maria Del Carmen Esquivel
Owner C&C Interpreting

«Consultant_Signature_2»

[Note: 2 officer’s signatures required if
Consultant is a corporation, unless provided
with a certificate of secretary in-lieu]
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CITY COUNCIL

AGENDA REPORT
A D E L A N T O G O V E R N M E N T A L C E N T E R | 1 1 6 0 0 A I R E X P R E S S W A Y DATE: May 13, 2026
TO: Honorable Mayor and City Council Members
FROM: Jessie Flores, City Manager
BY: James Hirsch, Planning Manager
SUBJECT: PUBLIC HEARING–ORDINANCE 664 AND ASSOCIATED
DEVELOPMENT AGREEMENT 26-01, LOCATION AND DEVELOPMENT
PLAN 24-07 AND CONDITIONAL USE PERMIT 24-07.

STAFF RECOMMENDATION:

Introduce for the first reading Ordinance 664, approving a Development Agreement between Hidalgo Energy Storage LLC and the City of Adelanto.

AND
Adopt Resolution No. 26-07, Adopt findings and Approve, Location and Development Plan 24- 07, Conditional Use Permit 24-07 and a Section 15183 Exemption.

BACKGROUND:

At the meeting of April 1, 2026, the Planning Commission recommended approval to the City Council (on a vote of 5-0), of Location and Development Plan 24-07, Conditional Use Permit 24- 07, Development Agreement 26-01 and Section 15183 CEQA Exemption subject to the conditions of approval.

Hidalgo Energy Storage LLC proposes Location and Development Plan 24-07, Conditional Use Permit 24-07 and Development Agreement 26-01 to construct and operate a Battery Energy Storage System (BESS) of up to 400 MW including SCE and project substations a vacant 40 acre parcel located on the northeast corner of Raccoon Road and Holly Road within the Manufacturing Industrial (MI) zone in the City of Adelanto (APN: 3128-081-01-0000).

A Development Agreement has been prepared between the City of Adelanto and Hidalgo Energy Storage LLC for a 30-year period to allow a battery energy storage system, (BESS) on a vacant 40-acre parcel located on the northeast corner of Raccoon Road and Holly Road within the Manufacturing Industrial (MI) Zone.
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The Development Agreement establishes design, point of sales tax estimated at from $2,000,000-$4,000,000, DIF fees of approximately $1,600,000 and other provisions including a Minimum Community Benefit Assessment of $1,000,000. In addition, the applicant will provide a permit expediting fee of $100,000.

Lastly, the Development Agreement addresses site decommissioning and closure.

OFF-SITE STREET IMPROVEMENTS
As per the conditions of approval detailed by the City Engineer, the Project applicant will be responsible for construction of certain segments of surrounding public streets as identified in Engineering Condition 29 (i.e. Holly Road from eastern PL to centerline of Raccoon Road, Pansy Road from centerline of Raccoon Road to eastern PL, and Raccoon Road from CL of Holly to CL of Pansy Road). In addition, payment of relevant Development Impact Fees (DIF) is required for the mitigation of impacts related to existing traffic levels plus project traffic. The Project shall also dedicate a roadway for public roadway purposes along the 40 feet along the western side of the property for Raccoon Road.

STAFF RECOMMENDATION:

ADOPT Resolution No. 26-07 to adopt a Section 15183 Exemption based on consistency with the previously approved General Plan EIR SFR # 20142031034 and to approve Location and Development Plan 24-07, Conditional Use Permit 24-07 and Development Agreement 26-01 to develop the subject property and construct a Battery Energy Storage System (BESS) of up to 400 MW including an SCE and project substations on an approximately 40-acre vacant site in the Manufacturing Industrial (MI) zone based on the findings and subject to conditions of approval.

FISCAL IMPACT:

1. If the project is approved, the City and the APUA (as applicable) will receive Development Impact Fees, Community Benefit Assessment Fees, Point of Sales Tax and a permit expediting fee.

ATTACHMENTS:

A. Ordinance 664
B. Resolution 26-07
C. Development Agreement 26-01
D. Planning Commission Staff Report, April 1, 2026
E. Section 15183 Consistency Checklist
F. Site Plan
G. DIF Fee Calculation
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ORDINANCE NO. 664 ATTACHMENT A

AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF ADELANTO

APPROVING AN AGREEMENT BY AND BETWEEN THE CITY OF

ADELANTO AND HIDALGO ENERGY STORAGE LLC FOR DEVELOPMENT

OF THE PROPERTY LOCATED AT THE NORTHEAST CORNER OF
RACCOON ROAD AND HOLLY ROAD, ASSESSOR’S PARCEL NUMBER 3128- 081-01-0000
WHEREAS, the State Planning and Zoning Law, Govt. Code section 65864 et seq., permits cities to enter agreements for the purpose of providing certainty to the development process and to provide a mechanism by which the City and developers can voluntarily agree to the provision of certain facilities and payments in furtherance of development; and WHEREAS, Hidalgo Energy Storage LLC., which has a legal and equitable interest in the real property more particularly described in Exhibit “A” to the draft agreement attached hereto as Exhibit “A”, desires to enter into such agreement covering such real property in connection with its applications to construct and operate a Battery Energy Storage System (BESS) of up to 400MW including SCE and project substations on 40 acres of land (the “Project”); and WHEREAS, the City of Adelanto, as lead agency, has adopted a Section 15183 Exemption in accordance with the California Environmental Quality Act as a Section 15183 Exemption Checklist has concluded that the project is consistent with the previously approved General Plan EIR SCH# 2014031034; and
WHEREAS, the Environmental Determination reflects the independent judgment of the City Council of the City of Adelanto and is deemed adequate for purposes of making decisions in the merits of the Project; and
WHEREAS, in accordance with State law, on May 13, 2026, for first reading and May 27 , 2026 for second reading, the City Council conducted duly noticed public hearings on the Project, reviewed and considered the Project, comments submitted, information presented by City staff and public testimony regarding the Project.

THE CITY COUNCIL FOR THE CITY OF ADELANTO DOES HEREBY ORDAIN AS FOLLOWS:

SECTION 1. The City Council finds that a public hearing has been held before this City Council pursuant to the procedures described in Government Code section 65867. At the hearing, the City Council has considered testimony presented by the public and the Planning Commission’s consideration of the Agreement between the City of Adelanto and Hidalgo Energy Storage LLC, (“Agreement”). The applicant has testified in writing prior to the meeting and at the meeting that it is in favor of the Agreement.

SECTION 2. The City Council hereby finds that the Agreement between the City of Adelanto and 521
Hidalgo Energy Storage LLC:

A. Is consistent with the objectives, policies, general land uses, and programs specified in the General Plan; and
B. Is compatible with the uses authorized in, and the regulations prescribed for, the zoning district in which the real property is and will be located, and is consistent with the City’s Zoning Code; and
C. Is in conformity with and will promote public necessity, public convenience, general welfare, and good land use practices; and
D. Will be beneficial to the health, safety, and general welfare; and E. Will not adversely affect the orderly development of property or the preservation of property values; and
F. Will promote and encourage the development of the proposed project by providing a greater degree of requisite certainty.

SECTION 3. The City Council hereby approves the Agreement in the form attached hereto as Exhibit “A”, and incorporates the Agreement herein by this reference. Within ten (10) days after this Ordinance takes effect, the City Council shall execute the Agreement.

SECTION 4. Within ten (10) days after the execution of the Agreement by all parties, the City Clerk is directed to record the Agreement pursuant to the requirements of Government Code section 65868.5.

SECTION 5. The City Clerk shall certify to the passage and adoption of this Ordinance.

SECTION 6. ENVIRONMENTAL DETERMINATION: The City Council finds that the proposed Agreement and Project has been adequately addressed in the Section 15183 Exemption which is proposed for adoption, in accordance with the guidelines set forth by the California Environmental Quality Act.

SECTION 7. EFFECTIVE DATE: This Ordinance shall be in full force and effect thirty (30) days after adoption.

SECTION 8. POSTING: The City Clerk shall cause this Ordinance to be posted in at least three public places designated by resolution of the City Council, shall certify to the adoption and posting of this Ordinance, and shall cause this Ordinance and its certification, together with proof of posting to be entered into the BOOK of ORDINANCES of the City of Adelanto.

PASSED, APPROVED AND ADOPTED this 27th day of May 2026. 522
___________________________________
Gabriel Reyes
Mayor of the City of Adelanto
___________________________________
Brenda Lopez
City Clerk
APPROVED AS TO FORM:
____________________________________
City Attorney
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I, Brenda Lopez, City Clerk of the City of Adelanto, California, do hereby certify that the foregoing Ordinance No. 664 was duly introduced for first reading on the 13th day of May , 2026 and regularly adopted at a regular meeting of the City Council of the City of Adelanto on this 27th day of May 2026, by the following vote, to-wit:

AYES:

NOES:

ABSENT:

ABSTAIN:

IN WITNESS WHEREOF, I hereunto set my hand and affix the official seal of the City of Adelanto on this 27th day of May 2026.
___________________________________
Brenda Lopez
City Clerk
SEAL
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Exhibit A
Draft Development Agreement
[attached on subsequent pages]
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RESOLUTION NO. 26-07 ATTACHMENT B

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF ADELANTO, SAN

BERNARDINO COUNTY, CALIFORNIA, MAKING FINDINGS ACCEPTING THE

PLANNING COMMISSION RECOMMENDATION OF APPROVAL OF THE
SECTION 15183 EXEMPTION, LOCATION AND DEVELOPMENT PLAN 24-07, AND CONDITIONAL USE PERMIT 24-07 TO DEVELOP A 40-ACRE PARCEL WITH A BATTERY ENERGY STORAGE SYSTEM, (BESS) OF UP TO 400 MW

INCLUDING AN SCE AND PROJECT SUBSTATIONS IN THE

MANUFACTURING INDUSTRIAL (MI) ZONE ON THE NORTHEAST CORNER OF RACCOON ROAD AND HOLLY ROAD IN THE CITY OF ADELANTO APN:
3128-081-01-0000.

WHEREAS, the applicant, Mr. Kurt Nelson representing Hidalgo Energy Storage LLC proposes to develop a 40 acre parcel located on the northeast corner of Raccoon Road and Holly Road within the City of Adelanto, County of San Bernardino with an up to 400 MW Battery Energy Storage System, (BESS) including an SCE and project substations in the Manufacturing Industrial (MI) zone; and WHEREAS, the Planning Commission recommended to the City Council approval of the Section 15183 Exemption, Location and Development Plan 24-07, and Conditional Use Permit 24-07 at their meeting of April 1, 2026; and

WHEREAS, the City of Adelanto, as lead agency, determined that a Section 15183 Exemption based on consistency with the previously approved General Plan EIR SFR #20142031034 should be prepared for adoption pursuant to Sections 21083.3 of the California Public Resources Code and 15183 of the California Environmental Quality Act, Guidelines; and
WHEREAS, the Section 15183 Exemption reflects the independent judgment of the City Council of the City of Adelanto and is deemed adequate for purposes of making decisions in the merits of the Project; and
WHEREAS, a duly noticed public hearing was held by the City Council on the 13th day of May, 2026, to hear and consider testimony for or against the issue; and WHEREAS, the City has complied with the California Environmental Quality Act; and
NOW, THEREFORE, BE IT RESOLVED by the City Council as follows:

SECTION 1. The above recitals are all true and correct.

SECTION 2. The City Council has reviewed and considered the information included in the staff reports prior to taking action on the Section 15183 Exemption, Location and Development Plan 24-07, and Conditional Use Permit 24-07. The City 526
RESOLUTION NO. 26-07
May 13, 2026

Council further finds and determines that the City has complied with the California Environmental Quality Act and the City Council determinations reflect the independent judgment of the City Council.

SECTION 3. The City Council hereby finds the proposed project is covered within the scope of the Section 15183 Exemption in accordance with the guidelines set forth by the California Environmental Quality Act for the proposed project.

LOCATION AND DEVELOPMENT PLAN 24-07:
(a) That the proposed Location and Development Plan is consistent with the General Plan;
The project site is designated MI (Manufacturing/Industrial), which is consistent with Appendix A of Title 17 of the Zoning Code which allows Electricity Distribution and Transmission Substations greater than 5,000 square feet in the MI zone with approval of a LDP.
(b) That the nature, condition, and development of adjacent uses, buildings, and structures have been considered, and that the use will not adversely affect or be materially detrimental to these adjacent uses, buildings, or structures;
Surrounding properties to the north and east are developed industrial uses, the properties to the south and west are vacant, so the project will not adversely affect surrounding properties.
(c) That the site for the proposed use is of adequate size and shape to accommodate the use and buildings proposed;
The overall site is approximately 40 acres in size, which exceeds the minimum 20,000 square feet required in this zoning district and has sufficient width and depth to meet all required setbacks. (d) That the proposed use complies with all applicable development standards of the zoning district.

The proposed project has been designed and conditioned to meet all applicable City zoning and development standards.
(e) That the proposed use observes the spirit and intent of this Zoning Code. 527
RESOLUTION NO. 26-07
May 13, 2026

The proposed project meets the requirements of the Zoning Code.

However, to ensure all Code requirements are met, a condition of approval has been added reflecting these requirements.

CONDITIONAL USE PERMIT 24-07:
(f) That the proposed Conditional Use Permit is consistent with the General Plan;
The project site is designated MI (Manufacturing/Industrial), which is consistent with Appendix A of Title 17 of the Zoning Code which allows Electricity Distribution and Transmission Substations greater than 5,000 square feet in the MI zone with approval of a CUP.
(g) That the nature, condition, and development of adjacent uses, buildings, and structures have been considered, and that the use will not adversely affect or be materially detrimental to these adjacent uses, buildings, or structures;
Surrounding properties to the north and east are developed industrial uses and the properties to the south and west are vacant industrial, so the project will not adversely affect surrounding properties. (h) That the site for the proposed use is of adequate size and shape to accommodate the use and buildings proposed;
The overall site is approximately 40 acres in size, which exceeds the minimum 20,000 square feet required in this zoning district and has sufficient width and depth to meet all required setbacks. (i) That the proposed use complies with all applicable development standards of the zoning district; and
The proposed project has been designed and conditioned to meet all applicable City zoning and development standards.
(j) That the proposed use observes the spirit and intent of this Zoning Code.

The proposed project meets the requirements of the Zoning Code.

However, to ensure all Code requirements are met, a condition of approval has been added reflecting these requirements.
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RESOLUTION NO. 26-07
May 13, 2026

SECTION 5. The City Council hereby approves the Section 15183 Exemption, Location and Development Plan 24-07, and Conditional Use Permit 24-07 subject to the following conditions of approval, attached as Attachment A and incorporated herein.

PASSED, APPROVED AND ADOPTED by the City Council this 13th day of May, 2026.

ATTACHMENTS
Conditions of Approval
________________________________
_
Gabriel Reyes, MAYOR
ATTEST:
___________________________________

BRENDA LOPEZ, CITY CLERK
I, Brenda Lopez, City Clerk of the City of Adelanto, California, do hereby certify that the foregoing Resolution No. 26-07 was duly and regularly adopted at a regular meeting of the City Council of the City of Adelanto on the 13th day of May , 2026, by the following vote, to-wit:

AYES:

NOES:

ABSENT:

ABSTAIN:

IN WITNESS WHEREOF, I hereunto set my hand and affix the official seal of the City of Adelanto on the 13th day of May , 2026.
___________________________________
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RESOLUTION NO. 26-07
May 13, 2026

Brenda Lopez
City Clerk
SEAL
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RECORDING REQUESTED BY

AND WHEN RECORDED

MAIL TO
City of Adelanto
11600 Air Expressway
Adelanto, CA 92301
Attn: City Clerk
Space Above This Line for Recorder’s Use
(Exempt from Recording Fee per Gov’t Code § 6103)

DEVELOPMENT AGREEMENT

BY AND BETWEEN
THE
CITY OF ADELANTO (“CITY”)
AND

HIDALGO ENERGY STORAGE LLC,
A DELAWARE CORPORATION (“DEVELOPER”)

ATTACHMENT C
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DEVELOPMENT AGREEMENT
This Development Agreement (the “Agreement”) is entered into as of the ____ day of ______________, 2026 (“Reference Date”), by and between the CITY OF ADELANTO, a California municipal corporation (the “City”), and HIDALGO ENERGY STORAGE LLC, a Delaware corporation (the “Developer”), with reference to the following:

RECITALS
A. Government Code Sections 65864-65869.5 (the “Development Agreement Act”) authorize the City to enter into a binding development agreement for the development of real property within its jurisdiction with persons having legal or equitable interest in such real property.

B. Developer has an option to purchase the 40.43-acre parcel of real property (“Property”) located southeast of Pansy Road and Calendula Road on Assessor Parcel Number 3128-081-01, in the City of Adelanto, San Bernardino County, State of California. The Property is presently undeveloped, is legally described in Exhibit “A” attached hereto, and is the subject of this Agreement. The Property is located with the City’s MI (Manufacturing/Industrial) Zoning District. The Los Angeles Department of Water & Power (“LADWP”) Adelanto Converter Station is located adjacent to the Property to the north.

C. In connection with the execution of this Agreement, the City approved Location and Development Plan (LDP) 24-07 and Conditional Use Permit (CUP) 24-07 subject to the conditions of approval attached hereto (“Conditions of Approval”) (collectively, the “Project Approvals”). The LDP and CUP provide planning and development criteria for a proposed project on the Property (the “Project”). The Project will consist of the development of the Property with a battery energy system (“BESS”) that would deliver and receive power from the existing Southern California Edison (“SCE”) transmission line located directly adjacent to the Property to the west.

The LDP and CUP are collectively known as the “Development Plan”.

D. The City acknowledges that the LDP and CUP are a valuable property right to the Developer and that the LDP and CUP may not be revoked, rescinded or terminated other than in the manner permitted by existing law or under circumstances where the Developer has taken actions or omissions that violate the LDP or CUP or their conditions.

E. Consistent with the state Development Agreement Act, the parties desire to enter into a binding agreement for purposes of granting Developer a vested right to develop the Property according to the Development Plan in exchange for the Developer granting the City certain community benefits.

F. Among other purposes, this Agreement is intended to be, and shall be construed as, a development agreement within the meaning of the Development Agreement Act. This Agreement will eliminate uncertainty in planning for and secure the orderly development of the Project, ensure a desirable and functional community environment, provide effective and efficient development of public facilities, infrastructure, and services appropriate for the development of the Project, and assure attainment of the maximum effective utilization of resources within the City, by achieving the goals and purposes of the Development Agreement Act. In exchange for these benefits to City, Developer desires to receive the assurance that it may proceed with 532
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development of the Project in accordance with the terms and conditions of this Agreement and the Development Plan, all as more particularly set forth herein.

G. The City Council has determined that the Project and this Agreement are consistent with the City’s General Plan, including the goals and objectives thereof.

H. All actions taken by City have been duly taken in accordance with all applicable legal requirements, including the California Environmental Quality Act (Public Resources Code Section 21000, et seq.) (“CEQA”), and all other requirements for notice, public hearings, findings, votes and other procedural matters.

I. The terms and conditions of this Agreement, including, without limit, the Infrastructure Improvements, have undergone extensive review by Developer, City staff, the City Planning Commission, and the City Council and they each have found the Agreement to be fair, just and reasonable.

J. On XXX, 2026, the City Council adopted its Ordinance No. XXX approving this Agreement.

AGREEMENT
NOW, THEREFORE, in consideration of the mutual covenants and agreements contained herein and other good and valuable consideration, the receipt and legal sufficiency of which is hereby acknowledged, the parties do hereby agree as follows:

1.0 GENERAL.

1.1 Term.

The term of this Agreement (the “Term”) shall commence on the Effective Date hereof and shall continue for thirty (30) years unless the term of this Agreement is otherwise terminated, modified, or extended by circumstances set forth in this Agreement or by mutual consent of the parties hereto after the satisfaction of all applicable public hearing and related procedural requirements. Certain provisions as identified herein or as self-apparently continuing beyond the Term shall continue in full force and effect beyond the term of this Agreement and shall not expire, including but not limited to the requirements to indemnify the Indemnified Parties.

1.2 Effective Date.

This Agreement shall be effective, and the obligations of the parties hereunder shall be effective, as of XXX, 2026, which is the date that Ordinance No. XXX takes effect (“Effective Date”).

1.3 Amendment or Cancellation.

Except as expressly stated to the contrary herein, this Agreement may be amended or canceled in whole or in part only by mutual consent of the parties and in the manner provided for in Government Code Section 65867-65869.5.
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1.4 Termination.

Unless terminated earlier, pursuant to the terms hereof, this Agreement shall automatically terminate and be of no further effect upon the expiration of the Term of this Agreement.

Termination of this Agreement, for any reason, shall not, by itself, affect any right or duty arising from entitlements or approvals set forth under the Project Approvals.

1.5 Incorporation of Recitals.

The recitals are hereby incorporated into this Agreement.

2.0 DEVELOPER’S RIGHTS AND LIMITATIONS REGARDING CONSTRUCTION OF THE PROJECT.

2.1 Right to Develop.

Subject to the terms, conditions, and covenants of this Agreement, Developer shall have the vested right to complete the Project during the Term in accordance with the Existing Development Regulations (as defined in Section 2.2, below) (“Developer’s Vested Rights”). The Developer’s Vested Rights shall not be changed during the Term of this Agreement except upon mutual written consent of the City and Developer. Developer’s Vested Rights shall expire upon the earlier of the following occurrences: (a) termination of this Agreement; or (b) an uncured material default by one or both of the Parties. Notwithstanding anything in this Agreement to the contrary, the Project shall remain subject to the following, to the same extent it would without this Agreement:
(i) all amendments or modifications to Existing Development Regulations after the Effective Date of this Agreement and all ordinances, regulations, rules, laws, plans, policies, and guidelines of the City and its City Council, Planning Commission, and all other City boards, commissions, and committees enacted or adopted after the Effective Date of this Agreement (collectively, “New Laws”), except such New Laws which would in their application to the Project (a) restrict or modify the permitted types of land uses, the density or intensity of use, the maximum height, size, or square footage of the Project, the timing and phasing of development; (b) increase the amount or change the location of the infrastructure required for the Project; (c) impose additional exactions or requirements other than as provided for in the Existing Development Regulations or this Agreement; (d) change design or development standards or the policies or requirements of the Existing Development Regulations; (e) impose a new permit requirement or procedure pertaining to the development of the Project not included within the Existing Development Regulations; (f) increase the cost of development of the Project as those costs existed at the time of the Approval Date; or (g) otherwise preclude or materially impair Developer’s ability to develop according to the Existing Development Regulations or this Agreement, unless such New Laws are applied pursuant to this Agreement, including, but not limited to, Section 2.3; and (ii) all subsequent development approvals and the conditions of approval associated therewith, including but not limited to any future Property development or entitlement permits, tract or parcel maps, and building permits or other construction related permits. 534
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2.2 “Existing Development Regulations” are defined as all Land Use Regulations in effect on the Effective Date. “Land Use Regulations” means all ordinances, resolutions, codes, rules, regulations and official policies of City governing the development and use of land, including, without limitation, the permitted use of land, the density or intensity of use, subdivision requirements, timing and phasing of development, the maximum height and size of Project, the fees applicable to the development of the Project, the provisions for reservation or dedication of land for public purposes, and the design, improvement, construction, and specifications applicable to the Project. “Land Use Regulations” do not include any City ordinance, resolution, code, rule, regulation or official policy governing:

2.2.1 The conduct or taxation of businesses, professions, and occupations applicable to all businesses, professions, and occupations in City;

2.2.2 Taxes and assessments of general application upon all residents of City;

2.2.3 The control and abatement of nuisances.

2.2.4 The payment of costs, user fees, or similar payments for the provision of services to the Property or the Project.

2.3 Additional Applicable Codes and Regulations.

Notwithstanding any other provision of this Agreement, the City also reserves the right to apply the following to the development of the Project:

2.3.1 Changes in Building and Fire Codes. Notwithstanding any provision of this Agreement to the contrary, development of the Project shall be subject to changes which may occur from time to time in the California Building Standards and Fire Codes, as such Codes are adopted by the City.

2.3.2 Changes Mandated by Federal or State Law. This Agreement shall not preclude the application, changes in, or additions to state and federal laws and regulations to development of the Project. In the event state or federal laws or regulations prevent or preclude compliance with one or more provisions of this Agreement, such provisions shall be modified or suspended as may be necessary to comply with such state or federal laws or regulations.

3.0 DEVELOPER’S OBLIGATIONS.

3.1 Indemnification.

Developer agrees to and shall indemnify, hold harmless, and defend, the City and the Adelanto Public Utility Authority (“APUA”) and their respective officers, officials, members, agents, employees, attorneys, and representatives (collectively, the “Indemnified Parties”) from any challenge to the approval or validity of this Agreement or to the City’s implementation of its rights under this Agreement except to the extent that the liability or claims arise from the Indemnified Parties’ negligence, misconduct, breach of this Agreement, or violation of or noncompliance with any applicable law. The Developer shall indemnify, hold harmless, pay all costs 535
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and provide defense for the Indemnified Parities in said action or proceeding with counsel chosen by the City.

3.2 Development Impact Fees.

Notwithstanding anything herein or in Existing Development Regulations to the contrary, the Development Impact Fees for the Project for the Circulation Impact Fee, Fire Impact Fee, and Drainage Impact Fee shall be as follows:
• Circulation Impact Fee: $937,000.00
• Fire Impact Fee: $49,487.00
• Drainage Impact Fee: $659,000.00

3.3 Developer’s Obligation To Commence Operations.

In order that the Property be put to a useful purpose and not remain vacant, Developer shall make all reasonable efforts to apply for building permits for the Project, or any initial phase thereof, as soon as is possible from the Effective Date, with the acknowledgement that to proceed, the Project requires negotiation of a commercial contract and CAISO action.

The Parties understand that the Project may be constructed in phases.

Nothing within this Agreement impacts or supersedes Developer’s requirement to comply with the Development Plan and Conditions of Approval.

3.4 Sales and Use Taxes.

Developer shall make reasonable efforts that any sales or use tax incurred due to the initial and future development and construction on the Property of the Project shall be determined to be from a point of sale in the City and allocated to the City. The Developer shall reasonably work with the City to determine how the receipt of sales and use taxes related to the construction and development of the Project will be maximized for the City. This process may include, if commercially reasonable and compliant with any relevant regulations and laws, but is not limited to, the following: Developer obtaining a street address within the City for acquisition, purchasing, and billing purposes; Developer registering this address with the State Board of Equalization; Developer using this address for acquisition, purchasing, and billing purposes associated with the Project; and Developer allowing City to use this sales tax information publicly for reporting purposes. This obligation continues in full force and effect beyond the expiration date of the Agreement.

Developer shall also make reasonable efforts to cooperate with the City to facilitate any sales or use tax generated from the future sale of items or energy from the Project determined to be from a point of sale in the City and allocated to the City. The Developer shall reasonably work with the City to determine how the receipt of sales and use taxes related to the sale of items from or stored at the Project will be maximized for the City. This process may include, if commercially reasonable and compliant with any relevant regulations and laws, but is not limited to, the following: Developer obtaining a street address within the City for acquisition, purchasing, and 536
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billing purposes; Developer registering this address with the State Board of Equalization; Developer using this address for acquisition, purchasing, and billing purposes associated with the Project; Developer using this address for acquisition, purchasing, and billing purposes associated with the Project; and Developer allowing City to use this sales tax information publicly for reporting purposes. This obligation continues in full force and effect beyond the expiration date of the Agreement.

3.5 Developer’s Payment of a Community Benefit Payment.

Developer shall pay to the City a Community Benefit Payment in the amount of One Million Dollars ($1,000,000.00). One half of the Community Benefit Payment, Five Hundred Thousand Dollars ($500,000.00), shall be due and payable within 120 days of the issuance of the first building permits for any portion of the Project or two years from the Effective Date of this Agreement, whichever is soonest. The second half of the Community Benefit Payment, Five Hundred Thousand Dollars ($500,000.00), shall be due and payable within ninety (90) days after the Commercial Operation Date (defined below) for any portion of the Project. The payments of the Community Benefit Payment are non-refundable once paid. The Community Benefit Payment may be used by the City for police and other emergency related services. The Community Benefit Payment does not replace and is not in lieu of any other required fees, taxes, or payments by the Developer but is a separate and independent payment of the Developer in consideration of the benefits received in this Agreement. As used herein, “Commercial Operation Date” means the date on which the Project has successfully completed all required testing and commissioning procedures, is capable of generating and delivering electricity in accordance with applicable regulatory and contractual requirements, and has been declared by Developer to be commercially operational.

3.6 Additional Payment To City And Reimbursement of City Costs.

In addition to the Community Benefit Payment, Developer shall pay to the City One Hundred Thousand Dollars ($100,000.00) within 60 days of the Effective Date.

3.7 Decommissioning of Project
Developer shall comply with all requirements pertaining to the decommissioning of the Project as contained in the Development Plan and Conditions of Approval.

4.0 CITY’S OBLIGATIONS & ACKNOWLEDGEMENTS.

4.1 Project Approvals Independent.

All approvals required for the Project which may be or have been granted, and all land use entitlements or approvals generally which have been issued or will be issued, by the City with respect to the Project, constitute independent actions and approvals by the City. If any provision of this Agreement or the application of any provision of this Agreement (other than Section 3.1) to a particular situation is held by a court of competent jurisdiction to be invalid or unenforceable, or if this Agreement terminates for any reason other than Developer’s default, then such invalidity, unenforceability or termination of this Agreement or any part hereof shall not affect the validity or effectiveness of any such Project approvals or other land use approvals and entitlements, except that in the event that the payment of the Community Benefit Payment is successfully challenged 537
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and set aside then this this Agreement and any entitlements relating to the Property, including without limit the Development Plan, shall be deemed null and void and of no force or effect whatsoever.

4.2 Review for Compliance.

This Agreement shall require periodic review (every 12 months) as required by state law pursuant to Government Code section 65865.1.

5.0 DEFAULT; REMEDIES; DISPUTE RESOLUTION.

5.1 Notice of Default.

5.2 In the event of failure by either party hereto substantially to perform any material term or provision of this Agreement, the non-defaulting party shall have those rights and remedies provided herein, provided that such non-defaulting party has first provided to the defaulting party a written notice of default in the manner required by Section 8.1 hereof identifying with specificity the nature of the alleged default and the manner in which said default may satisfactorily be cured.

Cure of Default.

Upon the receipt of the notice of default, the alleged defaulting party shall promptly commence to cure, correct, or remedy the identified default at the earliest reasonable time after receipt of the notice of default and shall complete the cure, correction or remedy of such default not later than thirty (30) days after receipt of the notice of default, or, for such defaults that cannot reasonably be cured, corrected or remedied within thirty (30) days, such party shall commence to cure, correct, or remedy such default within such thirty (30) day period, and shall continuously and diligently prosecute such cure, correction or remedy to completion.

5.3 Remedies.

The Parties acknowledge that, except as provided in this Agreement, money damages and remedies at law generally are inadequate and that specific performance is appropriate for the enforcement of this Agreement. The remedy of specific performance or, in the alternative, a writ of mandate, shall be the sole and exclusive remedy available to either Party in the event of the default or alleged default by the other. The limitations on the remedy of damages in this Agreement shall not prevent City from enforcing Developer’s monetary obligations hereunder.

Furthermore, the City, in addition to, or as an alternative to, exercising the remedies set forth in this Agreement, in the event of a material default by Developer, may give notice of its intent to terminate or modify this Agreement pursuant to the Development Agreement Act, in which event the matter shall be scheduled for consideration and review by the City Council in the manner set forth in the Development Agreement Act.

6.0 MORTGAGEE PROTECTION; CERTAIN RIGHTS OF CURE.

6.1 Encumbrances on the Project Property.

This Agreement shall not prevent or limit the Developer from encumbering the Property or any portion thereof or any improvements thereon with any mortgage, deed of trust, sale and leaseback arrangement, or any other form of conveyance in which the Property, or a portion thereof 538
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or interest therein, is pledged as security, and contracted for in good faith and fair value (a “Mortgage”) securing financing with respect to the construction, development, use or operation of the Project.

6.2 Mortgage Protection.

No breach of this Agreement shall defeat, render invalid, diminish, or impair the lien of any Mortgage made in good faith and for value, and any acquisition or acceptance of title or any right or interest in or with respect to the Property or any portion thereof by a holder of a beneficial interest under a Mortgage, or any successor or assignee to said holder (a “Mortgagee”) whether pursuant to foreclosure, trustee’s sale, deed in lieu of foreclosure, lease termination or otherwise shall be subject to all of the terms and conditions of this Agreement.

6.3 Mortgagee Not Obligated.

No Mortgagee will have any obligation or duty under this Agreement to perform the obligations of the Developer or other affirmative covenants of Developer hereunder, or to guarantee such performance, however, to the extent that any covenant to be performed by the Developer is a condition to the performance of a covenant by the City, the performance thereof shall continue to be a condition precedent to the City’s performance hereunder.

6.4 Notice of Default to Mortgagee; Right of Mortgagee to Cure.

City shall, upon written request to the City, deliver to each Mortgagee a copy of any notice of default given to Developer under the terms of this Agreement, at the same time of sending such notice of default to Developer. The Mortgagee shall have the right, but not the obligation, within sixty (60) days after the receipt of such notice from the City, to cure, correct, or remedy the default, or, for such defaults that cannot reasonably be cured, corrected, or remedied within sixty (60) days, the Mortgagee shall commence to cure, correct, or remedy the default within such sixty (60) day period, and shall continuously and diligently prosecute such cure to completion. If the default is of a nature which can only be remedied or cured by such Mortgagee upon obtaining possession of the Property, such Mortgagee shall have the right to seek to obtain possession with diligence and continuity through foreclosure, a receiver or otherwise, and shall be permitted thereafter to remedy or cure the default within such time as is reasonably necessary to cure or remedy said default but in no event more than sixty (60) days after obtaining possession to commence such cure. If any such default cannot, with diligence, be remedied or cured within such sixty (60) day period, then such period shall be extended to permit the Mortgagee to effect a cure or remedy so long as Mortgagee commences said cure or remedy during such sixty (60) day period, and thereafter diligently pursues and completes such cure.

7.0 TRANSFERS OF INTEREST IN PROPERTY OR AGREEMENT.

7.1 Successors and Assigns.

Developer shall have the right to sell, transfer or assign the Property, or any portion thereof (provided that no such transfer shall violate the Subdivision Map Act, Government Code §66410, et seq.) to any person, partnership, joint venture, firm or corporation at any time during the term of this Agreement; provided, however, that any such sale or transfer shall include, with respect to the Property or the portion thereof sold or transferred, the assignment and assumption, in a fully 539
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executed written agreement, in whole or in part, of the rights, duties and obligations of the Developer under the terms of this Agreement. Upon such sale, transfer or assignment, Developer shall, with respect to the Property or the portion thereof sold or transferred, be released from any further obligations under the terms of this Agreement, provided:
(a) Developer no longer has any legal or equitable interest in the Property or the portion thereof sold or transferred, as applicable;
(b) Developer is not, at the time of the transfer, in default under the terms of this Agreement; and
(c) Developer has submitted an executed assignment and assumption agreement in a form and content reasonably acceptable and approved by the City prior to entering such assignment.

8.0 MISCELLANEOUS.

8.1 Notices.

All notices permitted or required hereunder must be in writing and shall be effected by (i) personal delivery, (ii) first class mail, registered or certified, postage fully prepaid, (ii) reputable same-day or overnight delivery service that provides a receipt showing date and time of delivery or (iii) by electronic mail (email), and shall be deemed communicated as of personal delivery, mailing or email verification of delivery. Notices shall be sent to the following addresses or to such other address as any party may from time to time designate in writing in the manner as provided herein:

To City: City of Adelanto
11600 Air Expressway
Adelanto, CA 92301
Attn: City Clerk
Email: [email protected]
With a copy to: Rutan & Tucker, LLP
18575 Jamboree Road, 9th Floor
Irvine, CA 92612
Attn: Todd Litfin
Email: [email protected]
To Developer: Hidalgo Energy Storage LLC
1108 Lavaca St, Ste 110-349
Austin, TX 78701
Attn: Legal
Email: [email protected]
Any written notice, demand or communication shall be deemed received immediately if personally delivered or delivered by delivery service, and shall be deemed received on the third day from the date it is postmarked if delivered by registered or certified mail. 540
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8.2 Force Majeure.

In addition to specific provisions of this Agreement, performance by either party hereunder shall not be deemed to be in default where delays or failures to perform are due to war, insurrection, strikes, walk-outs, riots, floods, earthquakes, fires, casualties, acts of God, acts of the public enemy, terrorism, epidemics, quarantine restrictions, freight embargoes, governmental restrictions imposed or mandated by other governmental entities, governmental restrictions or priority, unusually severe weather, inability to secure labor, materials, or tools necessary for the Project, delays of any contractor, subcontractor or supplier; acts of another party, acts or the failure to act of any public or governmental agency or entity (except that acts or the failure to act of the City shall not excuse performance by the City) or any other causes beyond the control or without the fault of the party claiming an extension of time to perform. An extension of time for any such cause shall only be for the period of the enforced delay, which period shall commence to run from the time of the commencement of the cause. The City and the Developer may also extend times of performance under this Agreement in writing.

8.3 Binding Effect.

This Agreement, and all of the terms and conditions hereof, shall be binding upon and inure to the benefit of the parties, any subsequent owner of all or any portion of the Project or the Property, and their respective assigns, heirs or successors in interest, whether or not any reference to this Agreement is contained in the instrument by which such person acquired an interest in the Project or the Property.

8.4 Independent Entity.

The parties acknowledge that, in entering into and performing this Agreement, each of the Developer and the City is acting as an independent entity and not as an agent of the other in any respect.

8.5 Agreement Not to Benefit Third Parties.

This Agreement is made for the sole benefit of the parties, and no other person shall be deemed to have any privity of contract under this Agreement nor any right to rely on this Agreement to any extent for any purpose whatsoever, nor have any right of action of any kind on this Agreement, nor be deemed to be a third party beneficiary under this Agreement.

8.6 Covenants.

The provisions of this Agreement shall constitute mutual covenants which shall run with the land comprising the Property for the benefit thereof, and the burdens and benefits hereof shall bind and inure to the benefit of each of the parties hereto and all successors in interest to the parties hereto for the term of this Agreement.

8.7 Nonliability of City Officers and Employees.

No official, officer, employee, agent, attorney or representative of the City, acting in his/her official capacity, shall be personally liable to Developer, or any successor or assign, for any loss, 541
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costs, damage, claim, liability, or judgment, arising out of or connection to this Agreement, or for any act or omission on the part of the City.

8.8 Covenant Against Discrimination.

Developer and City covenant and agree, for themselves and their respective successors and assigns, that there shall be no discrimination against, or segregation of, any person or group or persons on account of race, color, creed, religion, sex, marital status, national origin or ancestry, or any other impermissible classification, in the performance of this Agreement. Developer shall comply with the Americans with Disabilities Act of 1990, as amended (42 U.S.C. §§ 12101, et seq.).

8.9 Amendment of Agreement.

This Agreement may be amended from time to time by mutual consent of the original parties or such party to which the Developer assigns all or any portion of its interest in this Agreement, in accordance with the provisions of Government Code Sections 65867 and 65868.

8.10 No Waiver.

No waiver of any provision of this Agreement shall be effective unless in writing and signed by a duly authorized representative of the party against whom enforcement of a waiver is sought and referring expressly to this Section. No delay or omission by either party in exercising any right or power accruing upon non-compliance or failure to perform by the other party under any of the provisions of this Agreement shall impair any such right or power or be construed to be a waiver thereof, except as expressly provided herein. No waiver by either party of any of the covenants or conditions to be performed by the other party shall be construed or deemed a waiver of any succeeding breach or nonperformance of the same or other covenants and conditions hereof.

8.11 Cooperation in Carrying Out Agreement.

Each party shall take such actions and execute and deliver to the other all such further instruments and documents as may be reasonably necessary to carry out this Agreement in order to provide and secure to the other party the full and complete enjoyment of its rights and privileges hereunder.

8.12 Estoppel Certificate.

Any party hereunder may, at any time, deliver written notice to any other party requesting such party to certify in writing that, to the best knowledge of the certifying party, (i) this Agreement is in full force and effect and a binding obligation of the parties, (ii) this Agreement has not been amended or modified either orally or in writing, or if so amended, identifying the amendments, (iii) the requesting party is not in default in the performance of its obligations under this Agreement, or if in default, describing the nature and amount of any such defaults, and (iv) any other reasonable information requested. A party receiving a request hereunder shall execute and return such certificate within thirty (30) days following receipt of such written request. The City Manager is authorized to sign and deliver an estoppel certificate on behalf of the City. The City acknowledges that a certificate hereunder may be relied upon by transferees and Mortgagees. 542
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8.13 Construction.

The terms of this Agreement shall be construed in accordance with the meaning of the language used and shall not be construed for or against either party by reason of the authorship of this Agreement or any other rule of construction that might otherwise apply. As used in this Agreement, and as the context may require, the singular includes the plural and vice versa, and the masculine gender includes the feminine and vice versa.

8.14 Recordation.

This Agreement shall be recorded with the County Recorder of San Bernardino County at Developer’s cost, if any, within the period required by Government Code Section 65868.5.

Amendments approved by the parties, and any cancellation or termination of this Agreement, shall be similarly recorded.

8.15 Captions and References.

The captions of the paragraphs and subparagraphs of this Agreement are solely for convenience of reference, and shall be disregarded in the construction and interpretation of this Agreement. Reference herein to a paragraph or exhibit are the paragraphs, subparagraphs and exhibits of this Agreement.

8.16 Time.

Time is of the essence in the performance of this Agreement and of each and every term and condition hereof as to which time is an element.

8.17 Recitals & Exhibits Incorporated; Entire Agreement.

The Recitals to this Agreement and all of the exhibits and attachments to this Agreement are, by this reference, incorporated into this Agreement and made a part hereof. This Agreement, including all Exhibits attached hereto, constitutes the entire agreement between the parties with respect to the subject matter of this Agreement, and this Agreement supersedes all previous negotiations, discussions and agreements between the parties, and no parole evidence of any prior or other agreement shall be permitted to contradict or vary the terms hereof.

8.18 Exhibits.

Exhibit “A” (Legal Description of Property) to which reference is made in this Agreement is deemed incorporated herein in its entirety.

8.19 Counterpart Signature Pages.

For convenience the parties may execute and acknowledge this agreement in counterparts and when the separate signature pages are attached hereto, shall constitute one and the same complete Agreement.
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8.20 Authority to Execute.

Developer warrants and represents that (i) it is duly organized and existing, (ii) it is duly authorized to execute and deliver this Agreement, (iii) by so executing this Agreement, Developer is formally bound to the provisions of this Agreement, (iv) Developer’s entering into and performance of its obligations set forth in this Agreement do not violate any provision of any other agreement to which Developer is bound, and (v) there is no existing or threatened litigation or legal proceeding of which Developer is aware which could prevent Developer from entering into or performing its obligations set forth in this Agreement.

8.21 Governing Law; Litigation Matters.

The internal laws of the State of California shall govern the interpretation and enforcement of this Agreement without regard to conflicts of law principles. Any action at law or in equity brought by any party hereto for the purpose of enforcing, construing, or interpreting the validity of this Agreement or any provision hereof shall be brought in the Superior Court of the State of California in and for the County of San Bernardino, or such other appropriate court in said county, and the parties hereto waive all provisions of law providing for the filing, removal, or change of venue to any other court. Service of process on City shall be made in accordance with California law. Service of process on Developer shall be made in any manner permitted by California law and shall be effective whether served inside or outside of California. In the event of any action between the parties hereto seeking enforcement of any of the terms of this Agreement or otherwise arising out of this Agreement, the prevailing party in such litigation shall be awarded, in addition to such relief to which such party is entitled, its reasonable attorney’s fees, expert witness fees, and litigation costs and expenses.

8.22 No Brokers.

Each of the City and the Developer represents to the other party that it has not engaged the services of any finder or broker and that it is not liable for any real estate commissions, broker’s fees, or finder’s fees which may accrue by means of this Agreement, and agrees to hold harmless the other party from such commissions or fees as are alleged to be due from the party making such representations.
[Remainder of Page Intentionally Left Blank.]
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IN WITNESS WHEREOF, the Developer and the City have executed this Agreement as of the Reference Date.
“DEVELOPER”
HIDALGO ENERGY STORAGE LLC, a
Delaware corporation
By:

Its:

By:

Its:
“CITY”
CITY OF ADELANTO, a California
municipal corporation and charter city
By:

Gabriel Reyes
Mayor
ATTEST:
_________________________________
Brenda Lopez
City Clerk

APPROVED AS TO FORM

RUTAN & TUCKER, LLP
_________________________________
Todd Litfin
City Attorney
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EXHIBIT A
Legal Description of Property
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A Notary Public or other officer completing this certificate verifies only the identity of the individual who signed the document to which this certificate is attached, and not the truthfulness, accuracy, or validity of that document.

State of California )
County of ______________________ )
On _________________________, before me, ,
(insert name and title of the officer)
Notary Public, personally appeared ,
who proved to me on the basis of satisfactory evidence to be the person(s) whose name(s) is/are subscribed to the within instrument and acknowledged to me that he/she/they executed the same in his/her/their authorized capacity(ies), and that by his/her/their signature(s) on the instrument the person(s), or the entity upon behalf of which the person(s) acted, executed the instrument.

I certify under PENALTY OF PERJURY under the laws of the State of California that the foregoing paragraph is true and correct.

WITNESS my hand and official seal.

Signature (Seal)
A Notary Public or other officer completing this certificate verifies only the identity of the individual who signed the document to which this certificate is attached, and not the truthfulness, accuracy, or validity of that document.

State of California )
County of ______________________ )
On _________________________, before me, ,
(insert name and title of the officer)
Notary Public, personally appeared ,
who proved to me on the basis of satisfactory evidence to be the person(s) whose name(s) is/are subscribed to the within instrument and acknowledged to me that he/she/they executed the same in his/her/their authorized capacity(ies), and that by his/her/their signature(s) on the instrument the person(s), or the entity upon behalf of which the person(s) acted, executed the instrument.

I certify under PENALTY OF PERJURY under the laws of the State of California that the foregoing paragraph is true and correct.

WITNESS my hand and official seal.

Signature (Seal)
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A Notary Public or other officer completing this certificate verifies only the identity of the individual who signed the document to which this certificate is attached, and not the truthfulness, accuracy, or validity of that document.

State of California )
County of ______________________ )
On _________________________, before me, ,
(insert name and title of the officer)
Notary Public, personally appeared ,
who proved to me on the basis of satisfactory evidence to be the person(s) whose name(s) is/are subscribed to the within instrument and acknowledged to me that he/she/they executed the same in his/her/their authorized capacity(ies), and that by his/her/their signature(s) on the instrument the person(s), or the entity upon behalf of which the person(s) acted, executed the instrument.

I certify under PENALTY OF PERJURY under the laws of the State of California that the foregoing paragraph is true and correct.

WITNESS my hand and official seal.

Signature (Seal)
A Notary Public or other officer completing this certificate verifies only the identity of the individual who signed the document to which this certificate is attached, and not the truthfulness, accuracy, or validity of that document.

State of California )
County of ______________________ )
On _________________________, before me, ,
(insert name and title of the officer)
Notary Public, personally appeared ,
who proved to me on the basis of satisfactory evidence to be the person(s) whose name(s) is/are subscribed to the within instrument and acknowledged to me that he/she/they executed the same in his/her/their authorized capacity(ies), and that by his/her/their signature(s) on the instrument the person(s), or the entity upon behalf of which the person(s) acted, executed the instrument.

I certify under PENALTY OF PERJURY under the laws of the State of California that the foregoing paragraph is true and correct.

WITNESS my hand and official seal.

Signature (Seal)
548
Project: HILDALGO ENERGY STORAGE PROJECT - CUP 24-07 & LDP 24-07 Date: April 1, 2026
1 CITY OF ADELANTO ENGINEERING DEPARTMENT
Proposed Development: Project: Hildalgo Battery Energy Storage System project General Requirements and Conditions of Approval:

1. Approval of this project in no manner obligates the City of Adelanto to extend water service, or sewer service, or improve streets, or extend any other infrastructure to service this development.

Project does not propose to connect to municipal water or sewer service. Project is agreeing to make certain road improvements.

2. Should Mello-Roos, or Community Facilities Districts, or Community Service Districts, or Assessment Districts, or other special financing districts be formed to provide for City Infrastructure or City Services, this project shall annex into the districts and pay all fees associated with annexation into the districts, and the applicant shall agree to waive the right to protest the formation of said districts.

3. Prior to the approval of any improvement plans and the commencement of any construction associated with the development, the Developer shall be responsible for obtaining all necessary dedications of rights-of-way for offsite infrastructure improvements, right-of-entry for offsite grading, and easements for ingress, egress, drainage, utilities and other legal requirements for impacts associated with the development of this project, as determined and directed by the City Engineer. If the Developer cannot acquire a property interest in property required for off-site improvements, Government Code § 66462.5 shall apply and the City retains the right to:
a. Require the Developer to enter into an agreement to complete the improvements pursuant to Government Code § 66462 at such time as the City acquires an interest in the land that will permit the improvement to be made;
b. Require the Developer to pay the cost of acquiring the offsite real property interests required in connection with the subdivision.

Speaking of the dedications along four-sides of PL.

Access 150’ off the corner is fine. Minimum of 40 technically.

We are not aware of any rights of way dedications required. Please clarify if the City is demanding right of way dedication with this project. Certain off-site road improvements are being agreed to however Applicant assumes these are fully within existing public rights of way and therefore no additional easements or dedications are required.

Applicant needs to understand the scope of these additional requirements if applicable. Applicant is agreeing to this work assuming no Joshua trees occur within the work area for the road improvements.
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Project: HILDALGO ENERGY STORAGE PROJECT - CUP 24-07 & LDP 24-07 Date: April 1, 2026
2 4. The design of all public infrastructure elements shall conform to the requirements of the City General Plan and the current edition of the Green Book standard specifications for construction, and any alterations required and approved by the Public Works Department and Engineering Department staff. Off-site paving in public rights of way is proposed at 26’ face to face with curbs with the intent of being consistent with existing paved road in Pansy on the project’s north boundary.

5. The following plans and reports shall be prepared by a California licensed civil engineer prior to any site development or disturbance of the natural vegetation of the site. All required plans shall be drawn in ink at an appropriate scale on Mylar sheets, for approval by the City Engineer.

Improvement plans for all of the conditioned improvements shall be submitted to the City and reviewed and approved by the City Engineer. All of the conditioned improvement plans shall be approved by the City Engineer concurrently for review.

Plans Required:
a. Street Improvement Plan/Profile at 1" = 40' (Hor), 1" = 4' (Vert), plus Title/Index and Detail Sheets.
b. Precise Grading Plan 1" = 30', A grading plan conforming to the requirements of the CBC, 2022 edition, shall be prepared and submitted to the City Engineer for approval.
c. centerline and hold lines at intersections.
d. A Storm Water Pollution Prevention Plan (SWPPP) shall be prepared and approved by the California State Water Quality Control Board prior to the issuance of any permits for grading. The erosion control plan must be submitted to the City for review and approval and must include an active WDID number.
e. Onsite Underground Utility Plan at 1" = 40’ showing the location of all underground utilities including sewers, water, storm drain, gas, electric, telephone, and data and cable television lines. This plan shall be shown schematically based on plans prepared by utility agencies to illustrate the location of any access valves, manholes and hand holes. Applicable to the extent such features are proposed (e.g. stormwater).

Reports Required:
550
Project: HILDALGO ENERGY STORAGE PROJECT - CUP 24-07 & LDP 24-07 Date: April 1, 2026
3 a. Soils Report. A preliminary soils report as well as a pad certification shall be prepared by a California licensed geotechnical engineer skilled in soils/foundation investigations shall be submitted for review by the Engineering Department staff along with the first submittal of Street Plans and/or other improvement plans for review. Within the required soils report special attention shall be directed to the rip ability of the proposed road cuts and stability of manufactured slopes. The geotechnical engineer shall determine the setback requirements to support loading without failures in the soil mass.
b. Hydrology Report. A detailed drainage plan to the satisfaction of the City Engineer shall be prepared by a licensed Civil Engineer and submitted to the City for approval. The project must accommodate existing drainage flows that impact the project site and impact access to the project site and mitigate offsite drainage that impacts the project. The project must mitigate the increase onsite runoff from pre-development to postdevelopment flows. c.Proper Security Bonds for off-site improvements (i.e. road curb and gutter, striping) at prevailing wage costs of the improvements shall be posted with the City for all the conditioned and required improvements that are to be publicly dedicated, including the setting of proper monumentation for the subdivision. Prior to issuance of any permits to construct any improvements, the developer shall enter into an improvement agreement to construct the project improvements per City approved plans and post securities with the City of Adelanto to guarantee completion of construction and payment of labor and materials and one-year warranty of the improvements. These securities shall be provided by the Developers and all assignees and successors to the City. The following are the required security amounts and release procedure:
d. The developer shall at all times guarantee performance of this entitlement by furnishing to the City, and maintaining, good and sufficient Security as required by the City on forms approved by City for the purposes and in the amounts as follows:
i. To assure faithful performance of this entitlement in regard to said Improvements in an amount of 100% of the estimated cost of the Improvements; and
ii. To secure payment to any contractor, subcontractor, persons renting equipment, or furnishing labor materials for the Improvements required to be constructed or installed pursuant to this entitlement in the additional amount of 100% of the estimated cost of the Improvements; and
iii. To guarantee or warranty the work done pursuant to this entitlement for a period of one year following Acceptance thereof by 551
Project: HILDALGO ENERGY STORAGE PROJECT - CUP 24-07 & LDP 24-07 Date: April 1, 2026
4 City against any defective work or labor done or defective materials furnished in the amount of 20% of the estimated cost of the Improvements.
e. Release of Security. Subject to approval by the City, the Security required by this entitlement shall be released as follows:
i. Security given for faithful performance of any act, obligation, work or agreement shall be released upon Acceptance of the
Improvements, subject to the provisions of subsection (b) hereof. ii. In accordance with the requirements of Government Code Section 64999.7, the City Engineer shall allow a partial release of faithful performance Security pursuant to the following procedures. No partial release of Security for labor and materials shall be allowed. f. Developer shall have one opportunity to engage in the process of pre-warranty partial release of performance Security as described in this subsection (b) between the start of work and completion and acceptance of all work on the Improvements. The process allowing for a partial release of performance Security shall occur only when the cost estimate of the remaining work does not exceed twenty percent (20%) of the total original performance Security.
g. At such time that the Developer believes that the obligation to perform the work for which the performance Security was required is complete, the Developer may notify the City Engineer in writing of the completed work and request a warranty bond walk. This notice shall include with such notification a written list of work completed. Upon receipt of the written notice, the City Engineer shall have twenty (20) business days to review and comment or approve the completion of the required work. If the City Engineer does not agree that all work has been completed in accordance with the plans and specifications for the Improvements, he or she shall supply to the Developer a list of all remaining work to be completed.
f. • Best Management Practices (BMP) Plan:

The developer shall prepare and submit a Best Management Practices (BMP) Plan for the project site to the City for review and approval prior to the issuance of any building permit.
g. • Site Decommissioning and Closure Report:

Upon completion of site decommissioning activities, the developer shall submit a closure report to the City prepared by a qualified environmental engineering firm. The report shall include soil sampling and laboratory analysis (including, but not limited to, heavy metals, petroleum hydrocarbons, and other potential contaminants) performed by a certified laboratory to verify that the site has been properly remediated and that no contamination remains.
h. The developer shall post a performance bond or other acceptable financial security, based on the Engineer’s estimate of the costs associated with site decommissioning, environmental remediation (if required), and 552
Project: HILDALGO ENERGY STORAGE PROJECT - CUP 24-07 & LDP 24-07 Date: April 1, 2026
5 preparation of closure documentation. The security shall ensure that adequate funds are available to properly decommission the site and maintain environmental compliance during and after the project’s operational life.

General Grading Conditions:

6. Prior to the Issuance of a Grading Permit the following must be completed. a. Grading Plan and SWPPP must be approved by the City Engineer prior to the issuance of the grading permit.

7. During grading operations, the flowing must be observed:
a. All grading for the site shall be confined to the property limits unless the Developer first secures letters of permission to grade across property lines from any affected adjacent property owners.
b. Compaction Report. Any grading and/or utility excavations and backfilling, both on and off site, shall be done under the continuous direction of a licensed geotechnical engineer who shall obtain all required permits and submit progress reports and test results to the Engineering Department staff for review and approval as determined by the City.

Upon completion of all soils related work, the geotechnical engineer shall submit a final report to the Engineering Department staff for review and approval, which may require additional tests at the expense of the Developer.
i. All soils within street improvements must be compacted to 90% and 95% within twelve inches of surface.
c. No un-bound or re-vegetated soil shall be left exposed to wind erosion. If construction operations have not begun within a short duration, then the developer shall immediately provide proper soil erosion management techniques including chemical soil binding and re-vegetation of graded pads, or an equivalent technique approved by the Engineering Department staff.

General Construction Conditions:

8. The City of Adelanto shall be “added insured” on all insurance policies for construction activities and general liability during of offsite improvements this project. Proof of insurance shall be provided prior to start of construction.

9. All monuments shall be referenced or reset in accordance with the Business and Professions Code.

10. All improvements shown on the approved plans, as required by the City Engineer, shall be constructed prior to usage and occupancy of any onsite 553
Project: HILDALGO ENERGY STORAGE PROJECT - CUP 24-07 & LDP 24-07 Date: April 1, 2026
6 improvements. All infrastructure improvements required by these conditions of approval, must comply with the City’s standards, Greenbook (latest edition) and any specific requirements established in these conditions of approval.

Any existing infrastructure failing to meet these requirements must be removed and reconstructed at the developer’s expense to meet requirements described in these conditions of approval and current City Standards.

Temporary or Conditional Certificates of Occupancy will be reasonably considered.

11. During construction, temporary pedestrian and traffic control devices shall be constructed as deemed necessary by the City Engineer and Public Works Department staff at locations where construction traffic disrupts normal traffic.

Such measures and devices shall include but are not limited to: flagmen, barricades, portable electric traffic signals and street sweeping. Based on the lack of pedestrian and vehicle traffic in this area, It is the expectation of the City and Applicant that these will only be deemed necessary in limited circumstances and/or if development is pursued on the property to the south.

12. Utility plans must be approved by the City Engineer prior to installation. a. No utility access point, manholes, vaults, or air vents shall be located within sidewalks or pedestrian travel ways or within 12” of curb and gutters.

The project is a utility. The Gen-Tie and certain other components of the project both onsite and off must be above-ground.

13. Inspection. The Developer shall at all times maintain proper facilities and safe access for city inspectors and to the businesses or residences wherein any construction work is in progress. Upon completion of the work the Developer shall request a final inspection by the City Engineer.

All construction work associated with the project shall be subject to inspection by the City’s Public Works Inspector. The contractor shall notify the City and request required inspections at least 48 hours prior to performing any construction activity.

Any required special inspection, materials testing, or deputy inspection services shall be performed by a qualified third-party testing laboratory or inspection firm approved by the City. Such services shall be conducted under the direction and supervision of the City’s Public Works Inspector and the City Engineer.

All costs associated with materials testing, special inspection, and deputy inspection services shall be arranged and paid for by the developer.

14. 554
Project: HILDALGO ENERGY STORAGE PROJECT - CUP 24-07 & LDP 24-07 Date: April 1, 2026
7 Any access road designed to allow Fire Department apparatus circulation shall include an approved turnaround where required. All dead-end or terminating paved access roads exceeding 150 feet in length shall be provided with a standard Fire Department turnaround, or an alternative configuration approved by the Fire Department.

15. All access roads and points of entry to the project site shall be paved.

16. Final sections shall be approved by the City Engineer prior to construction, which shall be submitted along with the soils report & recommendations based on R-value & Traffic Index and shall substantially conform to the sections submitted with the first submittal of the street improvement plans.

17. .

18. There shall be no intersecting street centerlines greater than or less than 90° (+/- 10°) degrees unless otherwise approved by the Engineering Department staff.

19. All curb heights and gutter widths along the project frontage will match existing conditions.

20. All covers for utility manholes, valves, and vaults shall be adjusted to final grade after final paving.

21. Street asphalt concrete pavement shall be placed in multiple lifts depending on design asphalt thickness with the final lift placed after the Repair & Replace (R&R) and Point & Patch is completed.

22. Sleeves for lighting and landscape purposes will be allowed in the public street right-of-way when necessary, subject to the approval of the Engineering Department staff.

23. Any future additional access to the project site shall designed and approved by the City and fire department. .
.

24. All roadways providing access to the project site shall be properly improved and maintained at all times to ensure safe and unobstructed access.

25. Fencing located at the corners of the property shall be set back or cut back as necessary to provide adequate line-of-sight visibility at all four corners of the property in accordance with applicable traffic safety standards. 555
Project: HILDALGO ENERGY STORAGE PROJECT - CUP 24-07 & LDP 24-07 Date: April 1, 2026
8 Street Improvement Conditions:

26. Prior to the issuance of any building permits, street dedications shall be completed.

27. The Developer shall obtain necessary encroachment permits and construct and complete all street improvements necessary to achieve adequate construction and emergency access prior to issuance of building permits, or as directed by the City Engineer. All buildings in all construction phases must have two paved points of access and all terminating paved accesses must have proper standard fire turn-around of not be longer than 150 feet.

28. Offsite street dedications are as follows:
a. Dedication for street and utility purposes per City Standards for all streets to meet the 2022 City of Adelanto General Plan Circulation Map. b. The site will be enclosed by a chain link fence for security on three sides. The south side of the project facing the street will be fenced with a 6-ft high CMU block wall.
c.

29. Offsite street improvements are as follows:
a. Holly Road shall be constructed from eastern property line to centerline of Racoon Road 26’ with curbs consisting of a minimum of 4 inches of asphalt concrete over 6 inches of Class 2 base material, or per “R” value test for a Traffic Index (TI) of 8.0 per City Standards. b. Pansy Road shall be constructed from centerline of Racoon Road to eastern property line at 26’ consisting of a minimum of 4 inches of asphalt concrete over 6 inches of Class 2 base material, or per “R” value test for a Traffic Index (TI) of 8.0 per City Standards. c. Racoon Road shall be constructed CL of Holly Road to CL of Pansy Road at 26’ and join with existing street improvements, curb to dirt consisting of a minimum of minimum of 4 inches of asphalt concrete over 6 inches of Class 2 base, or per “R” value test for a Traffic Index (TI) of 8 per City Standards.
a. .

30. Developer shall pay the applicable Transportation Development Impact Fees 556
Project: HILDALGO ENERGY STORAGE PROJECT - CUP 24-07 & LDP 24-07 Date: April 1, 2026
9 Need to discuss. The project does not result in a transportation impact. As well, PW is requiring improvements to off-site streets which are significant in cost and effort.

31. Street name signs and traffic control devices, including full-width striping and striping transition into existing paving, shall be constructed in accordance with the approved plans and designed per the Manual on Uniform Traffic Control Devices and City Standards at the time of construction as directed by the City Engineer. Street names for this project shall be submitted to the Engineering Department for City Council approval.
a. All signposts shall be installed with anchors when installed into concrete. b. All street name signs shall be installed on 12-inch cap brackets. c. Any sign or post removed by the developer shall be returned to the Street Department undamaged and not vandalized.
d. All striping, onsite and offsite, shall be installed by the developer. This includes “STOP” and stop bars at all “STOP” signs, fog lines and any other traffic safety striping that may apply as directed by the Street Department.
e. Curbs must be painted red 7.5 feet on each side of center in front of all fire hydrants.
f. Curbs must be painted white 7.5 feet on each side of center with 3- minute max stenciled of the curb in front of all mailboxes.

Project does not propose to connect to sewer.

Project does not propose to connect to municipal water. Fire service is available via an existing hydrant.

Drainage Improvements:

32. The Developer shall prepare a Hydrology and Hydraulic Report demonstrating that post-development runoff proposed to be discharged into existing or proposed storm drainage facilities will not exceed the design capacity of those facilities. The report shall be prepared by a licensed Civil Engineer and shall be subject to review and approval by the City Engineer.

33. The Hydrology Report and comprehensive drainage plan shall identify all offsite drainage flows impacting the proposed development and quantify the 557
Project: HILDALGO ENERGY STORAGE PROJECT - CUP 24-07 & LDP 24-07 Date: April 1, 2026
10 increase in on-site runoff resulting from the development. The report shall demonstrate how the project will safely convey off-site flows through the development while protecting proposed improvements and maintaining allweather paved access to the site.

34. The study shall also demonstrate that post-development on-site runoff will be reduced to no more than ninety percent (90%) of pre-development runoff through the use of appropriate stormwater detention or other approved mitigation measures.

35. The analysis shall substantially conform to the accepted Adelanto Master Plan of Drainage and be consistent with the submitted improvement plans. The report shall be prepared using County of San Bernardino Flood Control District hydrology and hydraulic methodologies and shall include supporting calculations, maps, exhibits, diagrams, and a written conclusion identifying recommended measures to mitigate off-site flows and increased on-site runoff.

36. The Subdivider or Developer shall be responsible for obtaining all necessary permits and permissions from the department of Fish and Game and the Army Corps of Engineers and from any other regulatory agency for the alterations to any of the watercourses that are impacted by the proposed development if applicable.
a. All finished building floor elevations shall be 1.0 feet higher than the 100- year base flood elevations.

37. Storm flows may be conveyed in street sections to the extent that right-of-way limits shall accommodate a 100-year storm to a depth less than 0.7 feet deep from the flow line to provide all-weather emergency ingress and egress. If storm flows cannot be adequately conveyed by street sections, underground storm drains and other mitigation measures shall be provided as recommended in the Hydrology/Hydraulics Report and approved by the City Engineer.

38. Prior to construction of any improvements or any land disturbance, the Developer shall construct temporary drainage facilities and implement erosion and sediment control measures as necessary to minimize stormwater runoff, erosion, and siltation.

39. All construction storm drain inlets, catch basins, and other stormwater conveyance structures shall be equipped with appropriate sediment control devices capable of filtering and retaining sediment, grit, oil, and grease to prevent pollutants from entering the storm drainage system, in accordance with the State Water Resources Control Board Best Management Practices (BMPs).

40. The Developer shall obtain coverage under the National Pollutant Discharge Elimination System (NPDES) General Permit for Storm Water Discharges Associated with Construction Activities, as required by the 558
Project: HILDALGO ENERGY STORAGE PROJECT - CUP 24-07 & LDP 24-07 Date: April 1, 2026
11 California State Water Resources Control Board, and subject to review by the City Engineering Department.

41. During construction, all applicable NPDES requirements and BMPs shall be implemented and maintained. For grading activities disturbing one (1) acre or more, the Developer shall prepare and implement a Storm Water Pollution Prevention Plan (SWPPP) in accordance with the requirements of the Regional Water Quality Control Board (RWQCB).

42. The Developer shall provide adequate mitigation for storm drainage to avoid concentrating or increasing offsite flows, subject to review and approval by the City Engineer.

43. A BMP Maintenance Agreement must be prepared and recorded for all postconstruction BMPs onsite.

44. The project shall be subject to the City’s impact fees as applicable.

45. Onsite Improvements:
a. .

No connection to municipal water service is proposed at this time. b. Post-construction BMPs shall be required per the Construction General Permit (CGP).

Park and Landscaping:

46. Prior to the grading permit for any phase of development, the Developer shall prepare final improvement plans for the landscaping and irrigation of landscaped areas, and all open spaces. Said plans shall be prepared by a California licensed Landscape Architect and shall be subject to the review and approval of the Engineering and Planning Department staff. Landscape plans must be consistent with WELO.

Onsite Improvements:

47. The tops of all cut slopes shall be in conformance with City Standards per the City Engineer. Retaining walls shall be utilized where required by Public Works Department staff to ensure that unusable and non-visible slopes are not created.
559
Project: HILDALGO ENERGY STORAGE PROJECT - CUP 24-07 & LDP 24-07 Date: April 1, 2026
12 48. No lot shall drain onto any property adjacent to the project. Lots shall be protected from storm runoff as approved by the Public Works Department staff.

49. Sewer and water service pipelines (if proposed in the future) shall be placed outside of driveway areas unless otherwise approved by the Public Works Department staff.

50. Post-construction BMPs shall be required per the Construction General Permit (CGP).
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PLANNING COMMISSION AGENDA REPORT
DATE: April 1, 2026
TO: Honorable Chairman and Members of the Planning Commission FROM: James Hirsch, Community Development Director
BY: Christian Espinoza, Planning Technician
SUBJECT: Location and Development Plan 24-07, Conditional Use Permit 24-07 and Development Agreement 26-01. Proposal to develop and construct a Battery Energy Storage System, (BESS) of up to 400 MW including an SCE and project substations on a vacant 40-acre parcel located on the northeast corner of Raccoon Road and Holly Road within the Manufacturing Industrial (MI) Zone in the City of Adelanto (APN: 3128-081-01-0000).

STAFF RECOMMENDATION:

ADOPT Resolution No. P-26-02 to adopt a Section 15183 Exemption based on consistency with the previously approved General Plan EIR SFR # 20142031034 and to recommend to the City Council that it approve Location and Development Plan 24-07, Conditional Use Permit 24-07 and Development Agreement 26-01 to develop the subject property and construct a Battery Energy Storage System (BESS) of up to 400 MW including an SCE and project substations on an approximately 40-acre vacant site in the Manufacturing Industrial (MI) zone based on the findings and subject to conditions of approval.

BACKGROUND:

Applicant: Mr. Kurt Nelson
Hidalgo Energy Storage LLC
1108 Lavaca St, Suite 110-349
Austin, TX 78701
General Location: The subject property is located on the northeast corner of Raccoon Street and Holly Road within the
City of Adelanto, San Bernardino County.

Assessor’s Parcel Number: 3128-081-01-0000,
561
Location and Development Plan 24-07, Conditional Use Permit 24-07 and Development Agreement 26-01
April 1, 2026
Environmental Determination: A Section 15183 Exemption based on consistency with the previously approved General Plan EIR SCH #
2014031034.

Existing General Plan &
Zoning Designation: Manufacturing Industrial (MI)
Surrounding General Plan and Zoning:

Direction General Plan Zoning
North Public Utility PU
South Residential R-S5
East Manufacturing Industrial MI
West Manufacturing Industrial MI
Existing Land Use: The subject property is currently an undeveloped vacant lot.

Surrounding Land Uses: The following chart shows the surrounding land uses:

Direction Land Use
North LADWP solar farm and converter station
South Vacant/ Undeveloped Land
East Automotive Business
West Vacant/ Undeveloped Land
PROJECT DESCRIPTION:

The applicant, Mr. Kurt Nelson, representing Hidalgo Energy Storage LLC, is requesting approval to construct a Battery Energy Storage System (BESS) of up to 400 MW on an approximately 40-acre vacant site in the Manufacturing Industrial (MI) zone. The project would include various on-site improvements such as new fencing and lighting, hardscape for battery pads and circulation, and a new SCE substation and loop-in transmission line that would connect to an adjacent existing SCE 220 kV transmission line.

The project area is currently vacant, undeveloped and covered over in native vegetation. Soils on the site consist of sandy alluvial soils. The construction of the BESS and substation on the vacant parcel requires approval of a Location and Development Plan and a Conditional Use Permit.
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Location and Development Plan 24-07, Conditional Use Permit 24-07 and Development Agreement 26-01
April 1, 2026
Off-site improvements include an above-ground Gen-Tie which will connect the project site to existing SCE infrastructure to the north and west. Off-site street improvements are discussed later in this report.

PROJECT ANALYSIS:

GENERAL PLAN AND ZONING CONSISTENCY
The Project site is designated as Manufacturing Industrial (MI) and the proposed battery storage facility use is permitted in this zoning district, which encompasses light and heavy industrial and manufacturing uses. The City of Adelanto Zoning Ordinance addresses allowable uses in the MI zoning districts, which allow Electricity Distribution and Transmission Substations greater than 5,000 square feet with a Conditional Use Permit, (CUP). The City considers BESS within this land use category, and therefore a CUP is being processed.

The project is consistent with the General Plan as the site is designated Manufacturing Industrial (MI), zone which is consistent with Title 17 of the Zoning Code, which allows for the proposed use in the Manufacturing Industrial (MI) zoning district with an approved Location and Development Plan and Conditional Use Permit. The approvals of the LDP and CUP are only valid with the Development Agreement being entered into and executed by both parties.

The project will expand the allowed industrial uses contemplated by the City’s Adelanto North 2035 Sustainable Plan. The project is also consistent with the adjacent PU and MI zoning and land uses. As designed and conditioned, the project provides for the development of industrial uses that have been designed in compliance with the applicable MI development and design standards, policies and guidelines outlined in the City’s Zoning Code. As such, the proposed project is consistent with the City’s Adelanto North 2035 Sustainable Plan.

The proposed project is compatible with the manufacturing and industrial uses contemplated by the City’s Adelanto North 2035 Sustainable Plan. As such, the proposed project is consistent with the Adelanto North 2035 Sustainable Plan.

Also, more specifically, the project is consistent with Chapter 3, Economic Development, in that it helps to implement Economic Development goals and policies, including job creation, infrastructure expansion and revenue generation.

PARKING, LOADING, SITE ACCESS AND CIRCULATION
The lot will have two separate driveway connections on the south, along Holly Road.

The project is an unmanned facility, thus there is no parking requirement. However, Commented [BHFS1]: Jupiter to add details or verify this is still correct
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Location and Development Plan 24-07, Conditional Use Permit 24-07 and Development Agreement 26-01
April 1, 2026
sufficient area within the project site is proposed for improvement to allow for informal parking during regular inspection or maintenance activities.

DRAINAGE
The project Applicant will be required to adhere to the regulations outlined in Section

17.93.050 – Soil Erosion and Sediment Control Plan. The project Applicant will also be required to conform to Section 17.93.060 – Runoff Control of the City’s Municipal Code.

In addition, stormwater discharges from construction activities that disturb one or more acres, or smaller sites disturbing less than one-acre that are part of a common plan of development or sale are regulated under the National Pollutant Discharge Elimination System (NPDES) stormwater permitting program.

The project site contains a potential jurisdictional waterway in its northwest corner. As discussed in the 15183 checklist, the Sustainable Plan includes numerous policies and measures for the protection of stormwater quality and biological resources. In addition, the applicant has provided site-specific analysis of the project site and concludes the project is consistent with the Sustainable Plan and that adherence to the mitigation measures therein, along with adherence to other adopted uniformly applied standards of the City and applicable agencies (e.g. NPDES) would ensure the project would not result in any peculiar effects and would not result in a new or more severe adverse impact that was not previously identified in the Sustainable Plan EIR. Further, the Project would not result in an increase to significant effects – including those to drainage - as a result of new information not previously assessed in the Sustainable Plan EIR. Additional information can be found in the Environmental Considerations section of this staff report.

The Hydrology and Water Quality Study prepared for the proposed project did evaluate this threshold for potential impact to water quality and found the project, as designed, with a 26 foot setback, would avoid the drainage. The project would introduce 25 acres of new impervious surfaces on site but would mitigate the effects of increased runoff with the construction of an approximately 5.3 acre stormwater retention basin that will collect runoff from the project site and will be located along the northeastern boundary of the site.

The City’s Public Works Department has provided conditions requiring the submittal of a grading plan, drainage plan, soils report, hydrology report, water/sewer feasibility, etc., to the satisfaction of the City Engineer and submitted to the City for approval, prior to any construction activities on the project site.

OFF-SITE STREET IMPROVEMENTS
As per the conditions of approval detailed by the City Engineer, the Project applicant will be responsible for construction of certain segments of surrounding public streets as identified in Engineering Condition 29 (i.e. Holly Road from eastern PL to centerline of Raccoon Road, Pansy Road from centerline of Raccoon Road to eastern PL, and 564
Location and Development Plan 24-07, Conditional Use Permit 24-07 and Development Agreement 26-01
April 1, 2026
Raccoon Road from CL of Holly to CL of Pansy Road). In addition, payment of relevant Development Impact Fees (DIF) is required for the mitigation of impacts related to existing traffic levels plus project traffic. The Project shall also dedicate a roadway for public roadway purposes along the 40 feet along the western side of the property for Raccoon Road.

LANDSCAPING, FENCING, SECURITY
The site will be enclosed by a chain link fence for security on three sides. The south side of the site will be fenced with an 6’ CMU block wall.

ENVIRONMENTAL CONSIDERATIONS:

California Public Resources Code section 21083.3 and California Environmental Quality Act (CEQA) Guidelines Section 15183 provide an exemption from additional environmental review for projects that are consistent with the development density established by existing zoning, community plan or general plan policies for which an Environmental Impact Report (EIR) was certified, except as might be necessary to examine whether there are project-specific significant effects which are peculiar to the project or its site. Section 15183 specifies that examination of environmental effects shall be limited to those effects that:
(1) Are peculiar to the project or the parcel on which the project would be located, and were not analyzed as significant effects in a prior EIR on the zoning action, general plan, or community plan, with which the project is consistent, (2) Are potentially significant off-site impacts and cumulative impacts which were not discussed in the prior EIR prepared for the general plan, community plan or zoning action, or
(3) Are previously identified significant effects which, as a result of substantial new information which was not known at the time the EIR was certified, are determined to have a more severe adverse impact than discussed in the prior EIR.

Section 15183(c) further specifies that if an impact is not peculiar to the parcel or to the proposed project, has been addressed as a significant effect in the prior EIR, or can be substantially mitigated by the imposition of uniformly applied development policies or standards, then an additional EIR need not be prepared for that project solely on the basis of that impact.

A comprehensive environmental evaluation has been completed for the Project as documented in the attached §15183 Exemption Checklist. (Attachment G). This evaluation concludes that the Project qualifies for an exemption from additional environmental review because it is consistent with the development density and use characteristics established by the Adelanto North 2035 Comprehensive Sustainable Plan Final Environmental Impact Report, (SFH #20142031034)) March 2014 (General Plan EIR).
565
Location and Development Plan 24-07, Conditional Use Permit 24-07 and Development Agreement 26-01
April 1, 2026
Further, the General Plan EIR adequately anticipated and described the impacts of the Project, identified applicable mitigation measures necessary to reduce Project specific impacts, and the Project implements these mitigation measures.

A public hearing notice was sent to property owners within 300 feet of the project site. As of the writing of this report, no comments have been received by staff.

Site Decommissioning and Closure
a. • Best Management Practices (BMP) Plan:

The developer shall prepare and submit a Best Management Practices (BMP) Plan for the project site to the City for review and approval prior to the issuance of any building permit.
b. • Site Decommissioning and Closure Report:

Upon completion of site decommissioning activities, the developer shall submit a closure report to the City prepared by a qualified environmental engineering firm. The report shall include soil sampling and laboratory analysis (including, but not limited to, heavy metals, petroleum hydrocarbons, and other potential contaminants) performed by a certified laboratory to verify that the site has been properly remediated and that no contamination remains.
c. The developer shall post a performance bond or other acceptable financial security, based on the Engineer’s estimate of the costs associated with site decommissioning, environmental remediation (if required), and preparation of closure documentation. The security shall ensure that adequate funds are available to properly decommission the site and maintain environmental compliance during and after the project’s operational life.

Development Agreement No. DA 26-01: Proposal for a Development Agreement between the City of Adelanto and Hidalgo Energy Storage LLC for a 30-year period to allow a battery energy storage system, (BESS) on a vacant 40-acre parcel located on the northeast corner of Raccoon Road and Holly Road within the Manufacturing Industrial (MI) Zone.

The Development Agreement establishes design, point of sales tax estimated at from $2,000,000-$4,000,000, DIF fees of approximately $1,600,000 and other provisions including a Minimum Community Benefit Assessment of $1,000,000. In addition, the applicant will provide a permit expediting fee of $100,000.

Lastly, the Development Agreement addresses site decommissioning and closure and potential excess capacity in the proposed substation which will be conveyed to Southern California Edison (SCE) upon completion. Should the City finalize the process to become a Community Choice Aggregation (CCA) or an Irrigation District prior to the completion of the substation, the Development Agreement provides that Hidalgo Energy Storage LLC will diligently work to provide that any excess capacity be made available to 566
Location and Development Plan 24-07, Conditional Use Permit 24-07 and Development Agreement 26-01
April 1, 2026
the Adelanto CCA or Irrigation District.

ATTACHMENTS:

A. Resolution P-26-02
B. Planning Conditions of Approval
C. Engineering Conditions of Approval
D. Architectural Plans
E. Zoning and Location Map
F. Development Agreement
G. Consistency Checklist
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Consistency Checklist
Hidalgo Energy
Storage Project
APRIL 2025
Prepared for:

HIDALGO ENERGY STORAGE LLC
Prepared by:
4900 California Avenue
Bakersfield, California 93309
568
Printed on 30% post-consumer recycled material.
569
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Table of Contents
SECTION PAGE NO.
1 Introduction ..........................................................................................................................................................1

1.1 Project Overview.....................................................................................................................................1

1.2 Adelanto North 2035 Comprehensive Sustainable Plan.....................................................................1

1.3 California Environmental Quality Act Compliance ................................................................................2 2 Summary of Findings ...........................................................................................................................................3 3 Consistency Checklist..........................................................................................................................................5

3.1 Aesthetics ............................................................................................................................................ 14

3.2 Agriculture and Forestry Resources ................................................................................................... 19

3.3 Air Quality ............................................................................................................................................. 22

3.4 Biological Resources ........................................................................................................................... 38

3.5 Cultural and Paleontological Resources ............................................................................................ 55

3.6 Energy .................................................................................................................................................. 63

3.7 Geology and Soils ................................................................................................................................ 66

3.8 Greenhouse Gas Emissions................................................................................................................ 72

3.9 Hazards and Hazardous Materials .................................................................................................... 81

3.10 Hydrology and Water Quality............................................................................................................... 89

3.11 Land Use and Planning ....................................................................................................................... 99

3.12 Mineral Resources ............................................................................................................................102

3.13 Noise ..................................................................................................................................................104

3.14 Population and Housing....................................................................................................................110

3.15 Public Services ..................................................................................................................................112

3.16 Recreation..........................................................................................................................................117

3.17 Transportation ...................................................................................................................................120

3.18 Utilities and Service Systems............................................................................................................130

3.19 Wildfire ...............................................................................................................................................136

3.20 Mandatory Findings of Significance .................................................................................................140 4 References and Preparers..............................................................................................................................143

4.1 References Cited ...............................................................................................................................143

4.2 List of Preparers ................................................................................................................................147

FIGURES
1 Project Location ..............................................................................................................................................149 2 Land Use and Zoning ......................................................................................................................................151 3 Site Plan...........................................................................................................................................................153 570

HIDALGO ENERGY STORAGE PROJECT / CONSISTENCY CHECKLIST
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TABLES
1 Surrounding Land Uses .................................................................................................................................... 12 2 Mojave Desert Air Quality Management District Daily Air Quality Significance Thresholds ................................ 26 3 Estimated Maximum Daily Construction Criteria Air Pollutant Emissions – Unmitigated ............................ 28 4 Estimated Maximum Daily Operation Criteria Air Pollutant Emissions – Unmitigated ................................. 29 5 Distance to Receptors ...................................................................................................................................... 32 6 Chemical Constituents Emitted from Lithium-Ion Batteries During Thermal Runaway Event...................... 34 7 Chemical Constituents ERPG and AEGL Values.............................................................................................. 35 8 Battery Off-Gassing Modeling Results ............................................................................................................. 35 9 CNDDB Species Occurrences ........................................................................................................................... 39 10 Estimated Annual Construction Greenhouse Gas Emissions......................................................................... 74 11 Estimated Annual Operational Greenhouse Gas Emissions – Unmitigated.................................................. 74 12 Project Potential to Conflict with 2017 Scoping Plan ..................................................................................... 76 13 Project Potential to Conflict with 2022 Scoping Plan ..................................................................................... 77 14 Peak Construction Trip Generation Estimates ..............................................................................................123

APPENDICES
A Air Quality and Greenhouse Gas Emissions Technical Memorandum B Hazardous Consequence Analysis
C Biological Resources Technical Report
D Cultural Resources Inventory Report
E Paleontological Resources Inventory Memorandum
F Phase I Environmental Site Assessment
G Preliminary Hydrology and Water Quality Study
H Noise and Vibration Assessment
I-1 Project Specific Roadway Segment Analysis
I-2 Transportation Screening Analysis
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1 Introduction
This document is being supplied to the City of Adelanto in concert with an application for a Conditional Use Permit (CUP) to allow a proposed Hidalgo Battery Energy Storage System (BESS) on a 40-acre property accessed off Holly Road and identified as Assessor Parcel 3128-081-01. The document provides an analysis of the Project’s ability to qualify for streamlined environmental review pursuant to Section 15183 of the California Environmental Quality Act (CEQA) Guidelines. Specifically, Section 15183 mandates that “projects which are consistent with the development density established by existing zoning, community plan, or general plan policies for which an EIR was certified shall not require additional environmental review, except as might be necessary to examine whether there are projectspecific significant effects which are peculiar to the project or its site.”

1.1 Project Overview
The Hidalgo Energy Storage Project (Project) is a battery energy storage system (BESS) to be constructed on a 40.43- acre property (Project site), within the City of Adelanto, California (City) (Figure 1, Project Location). The Project would construct an up to 400-megawatt (MW) BESS that would deliver and receive power from the existing Southern California Edison (SCE) 220-kilovolt (kV) transmission line located directly adjacent to the Project site to the west. The Project would include various on-site improvements such as new fencing and lighting, hardscape and hardscape for battery pads, and circulation, and a new SCE substation and loop-in transmission line that would connect to an adjacent existing SCE 220 kV transmission line. SCE will, in support of the Project, undertake a variety of off-site efforts, which include improvements to SCE facilities within existing SCE utility rights-of-way, such as replacement of safety system components (differential protection relays), installing updated telecommunications equipment and fiber optics cables, and installing new transmission lines to loop-in the Project substation to the existing SCE facilities.

Utilizing similar battery technology used in electric vehicles, the Project would provide additional capacity to the electrical grid to assist with serving load during periods of peak demand by charging when demand is low and discharging when demand is high (CAISO 2014). This accommodates the integration of additional intermittent renewable energy sources, such as wind and solar, and reduces the need to operate natural gas power plants. The Project would also serve as an additional local capacity resource that would enhance grid reliability.

1.2 Adelanto North 2035 Comprehensive
Sustainable Plan
The City adopted the Adelanto North 2035 Comprehensive Sustainable Plan (“Sustainable Plan”) and certified the Environmental Impact Report (“Sustainable Plan EIR”) (State Clearinghouse [SCH] No. 2014031034) on March 11, 2014. The Notice of Determination for the Sustainable Plan EIR was filed with the County on March 13, 2014. The adoption of the Sustainable Plan, an amendment to the 1994 General Plan Update (General Plan), resulted in the City having two separate General Plans. The General Plan EIR was certified and the Notice of Determination was filed on May 19, 1995. Since the Sustainable Plan was adopted in 2014, it has served as the City’s General Plan guiding development north of Holly Road (which includes the proposed Project site) while the General Plan has continued to guide development within the City south of Holly Road. As such, the Sustainable Plan is the main document guiding development of this proposed Project; however, some General Plan goals, policies, and implementation measures still apply in the Sustainable Plan area and thus to this Project. 572

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The Sustainable Plan area is generally bound by Oleander Street to the north, Lessing Avenue to the west, Holly Road to the south, and the Southern California Logistics Airport (SCLA) as well as Adelanto and Amethyst Roads to the east (City of Adelanto 2014a). The Sustainable Plan created a framework to promote sustainable development, protect environmental resources, and to forge a strong connection between SCLA jobs centers and new mixed-use neighborhoods (City of Adelanto 2014a). The Plan establishes land use, transportation, infrastructure, and protection strategies that promote sustainable development, particularly by reducing automobile usage, and requiring cluster development approaches to protect and respect the sensitive desert environment. The Sustainable Plan is based on the concept of activity centers surrounded by residential neighborhoods linked to the adjacent jobs/business centers which create new dynamic focal points and transit hubs (City of Adelanto 2014a). “Smart growth” and “healthy community” concepts are keystones in the Plan. The Sustainable Plan area is principally comprised of residential, commercial, and industrial land uses and some of the Plan area contains underdeveloped and vacant lands (City of Adelanto 2014a).

Significant environmental impacts were identified in the Sustainable Plan EIR for the resource areas of Noise and Transportation and Traffic. These impacts were determined to be significant and unavoidable, and a Statement of Overriding Consideration was adopted by the City Council pursuant to CEQA Guidelines Section 15093. All other environmental impacts were found to be less than significant or less than significant upon implementation of various existing policies, standards, and plans.

1.3 California Environmental Quality Act Compliance
This Consistency Checklist has been prepared in accordance with CEQA Guidelines Section 15183 to evaluate whether the previous environmental analysis in the certified Sustainable Plan EIR adequately addresses the potential environmental effects of the proposed Project or if additional environmental review is warranted pursuant to the requirements of CEQA. Specifically, as explained further below, this Consistency Checklist identifies whether the proposed Project is within the scope of the Sustainable Plan EIR and if the Project’s effects are adequately addressed in the Sustainable Plan EIR and/or uniformly applied development policies or standards.

As described in Section 3, Consistency Checklist, the proposed Hidalgo Energy Storage Project proposes the construction of battery energy storage system consisting of lithium-ion batteries inside containers and associated electrical equipment, including medium-voltage transformers and power conversion systems1 on a 40.43-acre property permitted under the Sustainable Plan. The Sustainable Plan EIR considers the adoption of the Adelanto North 2035 Comprehensive Sustainable Plan as well as the General Plan and Zoning Code Amendments required to implement the Plan, but no site-specific development projects are identified (see Sustainable Plan, p. 1).

Therefore, this Consistency Checklist considers if the proposed Project would result in new project-specific or sitespecific impacts. The Checklist then considers if any such project or site-specific impacts are addressed by the Sustainable Plan EIR and/or addressed by uniformly applied development policies and standards. If a projectspecific or site-specific impact is not adequately addressed by the prior EIR or uniformly applied development policies, and the impact is potentially significant, it would warrant the preparation of a supplemental CEQA document. Finally, the Consistency Checklist addresses the conditions identified in CEQA Guidelines Section 15162 that could require the preparation of a subsequent (or supplemental) CEQA document. 1 The battery energy storage batteries and containers would be manufactured by Hithium, Samsung Sungrow, Tesla, Fluence, CATL, LG Chem, and a number of other manufacturers. A specific technology has not been selected at this time and will be finalized during detailed design. 573
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2 Summary of Findings
No additional CEQA review is required for projects which are consistent with the development density established by existing zoning and analyzed in its certified EIR except as might be necessary to examine whether there are Project-specific effects which are peculiar2 to the Project or its site (Public Resources Code Section 21083.3 and CEQA Guidelines Section 15183).

The proposed Project is consistent with zoning, and therefore development of this type and density is consistent with the Sustainable Plan and the analysis of the Plan EIR. However, Project-specific components were not specifically analyzed in the Sustainable Plan EIR. Therefore, this Checklist was prepared to determine if there would be Project-specific effects that are peculiar to the Project or the site that cannot be avoided or reduced to a lessthan-significant level through application of the measures identified in the Sustainable Plan EIR or other uniformly applied development policies or standards,3 therefore requiring a supplemental CEQA document to be prepared.

As demonstrated below, all potential impacts associated with the proposed Project fall within the scope of analysis performed in the prior EIR (Sustainable Plan) and/or are addressed by uniformly applied development policies and standards. Therefore, conditions that could trigger the preparation of a subsequent or supplemental CEQA document are not present, and in accordance with CEQA Guidelines Section 15183, the Project qualifies for streamlining as follows: The Project is consistent with the development density established by existing zoning, community plan or General Plan policies for which an EIR was certified.

The Project site is zoned Manufacturing/Industrial (MI) and MI (Manufacturing/Industrial) Zone District (Figure 2, Land Use and Zoning). Allowable uses within the MI designation under the Sustainable Plan include correctional facilities and controlled hazard uses. Conditionally permitted uses include renewable energy facilities, manufacturing, distribution and warehousing, and automotive-related business. The proposed Project is a BESS, a conditionally permitted use, consistent with the zoning and allowed uses, and which advances the industrial development plans, goals, and policies established by the Sustainable Plan. The Project would also be consistent with applicable development standards and design guidelines and would be developed in accordance with the industrial vision of the Sustainable Plan area. Because the Project is an allowable use and consistent with the MI use regulations, it is consistent with the development density established by the Sustainable Plan and the certified Sustainable Plan EIR.

There are no Project-specific effects that are peculiar to the Project or its site, and which the General Plan or Sustainable Plan EIR failed to analyze as significant effects.

As explained throughout this document, the subject property is comparable to other properties in the surrounding area, and there are no Project-specific effects which are peculiar to the Project or its site. The Project site is located in an area developed with similarly sized industrial uses. The property does not support any peculiar environmental features, and the Project would not result in any peculiar effects that were not anticipated in the Sustainable Plan EIR that cannot be avoided or substantially mitigated to a less2 Peculiar impacts are those environmental impacts that are distinctive and unique to the project (i.e., impacts on the surrounding environment that could not have been anticipated by the prior environmental impact report). See Wal-Mart Stores, Inc. v. City of Turlock (2006) 138 Cal.App.4th 274, 294; Hilltop Group, Inc. v. County of San Diego (2024) 99 Cal.App.5th 890, 917.b 3 15183 (g) “Examples of uniformly applied development policies or standards include, but are not limited to: (1) Parking ordinances, (2) Public access requirements, (3) Grading ordinances, (4) Hillside development ordinances, (5) Flood plain ordinances, (6) Habitat protection or conservation ordinances, (7) View protection ordinances, (8) Requirements for reducing greenhouse gas emissions, as set forth in adopted land use plans, policies, or regulations.” 574

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than-significant level through implementation of EIR mitigation measures or uniformly applied development policies or standards.

There are no potentially significant off-site and/or cumulative impacts which the Sustainable Plan or General Plan EIRs failed to evaluate.

Off-site activities and impacts include improvements to SCE facilities within existing SCE utility rights-ofway, such as replacement of safety system components (differential protection relays), installing updated telecommunications equipment and fiber optics cables, and installing new transmission lines to loop-in the Project substation to the existing SCE facilities. These types of impacts related to development and buildout of the Plan area were considered in the City of Victorville General Plan EIR (SCH #2021100136) and San Bernardino County General Plan EIRs (SCH #2017101033). The Victor and Kramer Substations are existing allowable uses. In other words, the Sustainable Plan EIR analyzed the potential impacts, including cumulative impacts of buildout of plan area consistent with zoning, of which the Project would represent a small part. As detailed herein, no potentially significant off-site or cumulative impacts have been identified which were not previously evaluated.

There is no substantial new information which results in more severe impacts than anticipated by the General Plan and Sustainable Plan EIRs.

As outlined herein, no new information has been identified which would result in a determination that the Project would result in a more severe impact than what had been anticipated by the General Plan and Sustainable Plan EIRs.

The Project will undertake feasible mitigation measures specified in the General Plan and Sustainable Plan EIR.

As outlined herein, the Project will incorporate the applicable Plan Implementing Programs identified in the Sustainable Plan EIR. This will be achieved through Project design and through compliance with the measures along with other uniformly applied development policies and standards. 575
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3 Consistency Checklist

1. Project title:

Hidalgo Energy Storage Project

2. Lead agency name and address:

City of Adelanto
Community Development Department
Planning Division
11600 Air Expressway
Adelanto, California 92301

3. Lead agency contact person(s) and phone number:

Jim Hirsch, City Planner
760.246.2300

4. Project location:

The approximately 40.43-acre Project site is located at Holly Road in the City of Adelanto, within San Bernardino County, California and is identified by Assessor Parcel Number (APN) 3128-081-01 (Figure 1).

The Project site is bound by Holly Road to the south, Racoon Road to the west, Pansy Road to the north, and the largely undeveloped Copart Adelanto vehicle storage lot. The Project site is comprised of vacant land and access to the site would be provided via a new driveway off Racoon Road.

5. Project sponsor’s name and address:

Hidalgo Energy Storage LLC
1108 Lavaca Street, Suite 110-349
Austin, Texas 78701

6. General Plan/Specific Plan designation:

The Sustainable Plan designates the Project site as Manufacturing/Industrial (MI) (Figure 2). This land use designation within the Sustainable Plan considers more employment-intensive developments at key locations that are protected in a manner that minimizes exposure to its surroundings (City of Adelanto 2014a).

7. Zoning:

The Project is sited in the MI (Manufacturing/Industrial) Zone District (City of Adelanto 2024) (Figure 2).

The Zoning designation for the property is consistent with the Adelanto North 2035 Comprehensive Sustainable Plan and General Plan. Allowable uses within the MI designation under the Sustainable Plan include correctional facilities and controlled hazard uses. Conditionally allowed uses include renewable energy facilities, manufacturing, distribution and warehousing, and automotive related business. 576

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8. Description of project (i.e., the whole action involved, including but not limited to later phases of the project, and any secondary, support, or off-site features necessary for its implementation):

The proposed Project consists of the construction and operation of an up to 400-MW BESS that would deliver and receive power from the existing SCE 220-kV transmission line located directly adjacent to the Project site to the west. The Project would also include a new SCE substation on site and loop-in transmission line that would connect to the existing SCE transmission line. It should be noted that the Adelanto Converter Station located immediately north of the Project site is owned and operated by Los Angeles Department of Water and Power (LADWP) and is not associated with this specific project; therefore, no Project-related activities would occur at the LADWP Adelanto Converter Station. The Project is designed to charge, store, and discharge electricity to and from the grid as energy production and demand fluctuate throughout the day. The proposed Project is expected to create approximately 40 jobs during construction, many of which can be sourced from the City and adjacent areas. The Project would be operated remotely through the SCADA system and would require periodic maintenance to be performed by regional employees and contractors. Maintenance operations would require weekly visits by one or two employees and would include one major maintenance inspection annually.

Project Overview
The proposed Project includes an up to 400-MW BESS, a Project substation, inverters, collector lines, allweather access roads, Supervisory Control and Data Acquisition (SCADA) system, hardscape for battery pad and ancillary equipment (e.g., transformers), stormwater improvements, and other ancillary facilities or equipment. Additionally, the Project would include a loop-in transmission line. Other Project components include a fire protection systems and power conversion systems, as well as perimeter fencing, signage, landscaping, and lighting. The Project site plan is included as Figure 3. The following sections describe the Project components in more detail.

I. On-Site Components
A. Battery Energy Storage System
The Project includes the placement of battery energy storage containers and associated electrical equipment, including medium-voltage transformers and power conversation systems.4 Each unit will consist of a storage container/non-occupiable steel cabinet that houses battery modules and power conversion system equipment. Each battery energy storage container would have insulation, a module cooling system, a battery management system, fire detection equipment, power conversion system (PCS) equipment containing the electronic controls, inverters, and a separate medium-voltage step-up transformer. The primary storage components would consist of self-contained electrochemical battery systems using conventional storage technologies with proven safety and performance records. While the components and total megawatts of the Project may change, the overall area for the Project will remain within the development footprint shown on Project plans. The battery modules would be installed in self-supporting racks electrically connected either in a series or parallel to each other. The individual battery racks are connected in series or parallel configuration to deliver the BESS power rating. The battery racks would be fused. At this time, the battery technology 4 The battery energy storage containers are manufactured by Hithium, Samsung, Sungrow, Tesla, Fluence, CATL, LG Chem, and a number of other manufacturers. A specific technology has not been selected at this time and will be finalized during detailed design.
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for the Project has not yet been finalized; Hidalgo Energy Storage LLC will determine battery type based on the technology available at the time of construction.

The battery storage units are pre-fabricated off site and arrive to the site ready to be installed and operated. Batteries are either not charged or charged at a very low-level during transport to the site as a safety precaution. The number of energy storage containers and types are approximate and subject to change based on available battery technology at the time of construction; however, they would be placed within the same Project area footprint shown on the Project plans and would be designed such that the periodic maintenance and replacement of battery components can be easily performed on an as-needed basis without replacing the entire module. The battery energy storage containers supplier has not been selected at this time; however, dimensions are expected to be approximately 20 feet long, 8 feet wide, and 12 feet high.

Fire detection measures are intrinsic to the Project design in accordance with National Fire Protection Association (NFPA) safety standards, International Fire Code (IFC) and California Fire Code (CFC). Should a thermal event occur, the BESS units are designed and certified so that fire will not propagate from one cabinet to the neighboring cabinet.

The BESS facility would be unstaffed and would include remote operational control; inspections and maintenance would be performed as necessary. The BESS facility would be unmanned but would include a 7,500-square-foot Project operations and maintenance (O&M) building, which is intended to be used for O&M personnel when on site, parts storage, temporary workstations and restroom facilities. Project operations would be monitored remotely through the SCADA system adjacent to the Project substation. Weekly inspections and maintenance activities performed by one or two workers would occur on the Project site.

B. Project Collector and SCE Substation
The Project collector substation gathers the electricity stored in the on-site batteries prior to transmitting the electricity to the new on-site SCE substation, referred to as Q2096 Substation. The collected electricity is then passed through transformers within the collector substation. These transformers step up the voltage to a higher level suitable for transmission over long distances. A final interconnection step-up transformer within the Q2096 Substation would convert it from 34.5 kV to 220 kV. The open-air Project collector and SCE substation is anticipated to be constructed adjacent to the BESS facilities within the Project boundary. The specific size and equipment for the substation would be finalized at the detailed engineering stages as the Project progresses. The site plan provided in Figure 3 demonstrates a typical collector and substation size and equipment to allow for the environmental review prepared in this Consistency Checklist.

II. Off-Site
A. Upgrades to SCE Victor Substation and SCE Kramer Substation SCE would implement the following improvements and upgrades to the SCE Victor Substation located approximately 3.8 miles to the southeast of the BESS and within the City of Victorville, and the SCE Kramer Substation located approximately 30 miles to the north of the BESS, and 4.5 miles east of the town of Boron. All improvements and updates would be located within the existing substation footprints and existing transmission line rights-of-way disturbance areas.

Kramer Substation
▪ Replace a pair of line differential protection relays on the new Q2096 220 kV line that will connect the new Q2096 Substation to the Kramer Substation. A line differential protection relay is a type of 578

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safety equipment used to detect faults on electrical transmission and distribution lines. The system includes two points that send communications back and forth through the transmission lines and if there is a reduction or loss of voltage, or an unexpected increase in voltage the relays send a communication to alert the operator of potential issues. Improvements will utilize existing poles and structures and construction activities would occur within existing utility rights-of-way.

Victor Substation
▪ Replace a pair of line differential protection relays on the new Q2096 220 kV line that will connect the new Q2096 Substation to the Victor Substation. See the description included in the Kramer Substation scope of work detailed above. Improvements will utilize existing poles and structures and construction activities would occur within existing utility rights-of-way.

Kramer to Victor 220 kV Transmission Line
▪ Modify the existing Kramer-Victor 220 kV line to connect it to the new Q2096 Substation, creating two new lines: Kramer to Q2096 and Q2096 to Victor. This involves installing four new steel structures to support the new 220 kV line in the existing SCE right-of-way, and removing one existing steel structure from the existing SCE right-of-way. Maximum disturbance area for new steel structures would be approximately 5 feet by 5 feet (25 square feet) per structure.

Telecommunications
▪ Install necessary fiber optics and telecommunications (Lightwave, channel banks and cross connects), and related equipment at the Q2096, Kramer, and Victor Substations to support transmission line safety and protection. Improvements and upgrades would be located within the existing substation footprints.
▪ Extend the existing dual diverse-path channels (separate and independent communications pathways) between Kramer and Victor Substations into the new Q2096 Substation to ensure redundancy and reliability. This includes adding:
- Main Path Fiber Optic: 16,000 feet of fiber optic cable, 200 feet of underground conduits, one new 35-foot-high wood pole, and one new vault within the existing SCE right-of-way. - Diverse Path Fiber Optic: 28,000 feet of fiber optic cable, 200 feet of underground conduits, one new 35-foot-high wood pole, and one new vault within the existing SCE right-of-way.

Description of Construction
Construction would be primarily composed of the following activities:
▪ Site Preparation: The site would be prepared for construction which is anticipated to include, clearing, grubbing and rough grading where required to accommodate the support structures, equipment pads and foundations and all-weather access roads. Retention basins would be created for hydrologic control. All-weather access roads would be comprised of an aggregate base. A temporary staging area within the site would be constructed to hold materials and construction equipment. ▪ Fencing: An approximately 8-foot-tall chain-link perimeter security fence that may be topped with 1 foot of barbed wire perimeter security fence would be installed around the Project site. 579

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▪ Electrical Work: A substation pad for the step-up transformer would be poured, followed by the installation of the medium-voltage stations, wiring of the modules through combiner boxes, and construction of the Project substation and grid interconnection. The medium-voltage stations would sit on concrete foundations or driven piles, pending final design.

The Project is anticipated to be built over an approximately 15-month period from the onset of site preparation activities through testing and commissioning of the facility. It is anticipated that construction crews would work 8 or 10 hours per day, with work occurring Monday through Friday. Overtime and weekend work would be used only as necessary to meet scheduled milestones or accelerate schedule and would comply with local conditions regarding construction timing if required, and applicable California labor laws.

Grading of the site would occur as necessary for the construction of roads, on-site substation, foundations for equipment and the battery containers, and inverter pads. This would be accomplished with scrapers, graders, water trucks, dozers, and compaction equipment. Grading would implement MDAQMD Rule 403 best management practices (BMPs) to eliminate fugitive dust that could occur during grading and earthmoving activities. Rule 403 requires that the Project Proponent prepare a Fugitive Dust Plan which includes BMPs such as periodic watering of disturbed surfaces, reducing track-out from the Project site onto paved surfaces, stabilization of graded surfaces, minimizing earthmoving activities during high-wind events, and covering haul truck loads carrying soil or bulk materials. Equipment containers would be offloaded and installed using cranes, boom trucks, forklifts, rubber-tired loaders, rubber-tired backhoes, and other small- to medium-sized construction equipment, as needed. Construction equipment would be delivered to the site on low-bed trucks unless the equipment can be driven to the site (e.g., boom trucks).

Estimated cubic yards of grading is approximately 8,720 cubic yards of cut and 27,900 cubic yards of fill for a net 19,180 cubic yards of material to be imported..

Employees
The Project is expected to create approximately 40 jobs during construction, many of which can be sourced from the City and adjacent areas. As many of the required construction workers would be sourced as locally as possible based on the qualifications of the task being performed. The Project would be operated remotely but would require periodic maintenance to be performed by regional employees and contractors.

Traffic
Access to the Project site would be from two new driveways, one driveway off Racoon Road and one driveway off Holly Road. Delivery of material and supplies would reach the site through on-road truck delivery. The majority of the truck deliveries would be for the containers with batteries, as well as any aggregate material that may be required for site preparation. The heaviest delivery loads to the site would consist of rock truck deliveries, concrete trucks, and the step-up transformer. Typically, the rock is delivered in “bottom dump trucks” or “transfer trucks” with six axles. Low-bed transport trucks would transport the construction equipment to the site as needed. The size of the low-bed trucks (axles for weight distribution) would depend on the equipment/materials transported.

Water Use
Water would be used for dust suppression during grading and ground-disturbing activity. Operational water demand for landscape irrigation would be minimal. The fire hydrant loop on site will require limited nonpotable water for annual testing and maintenance. Construction and operational water would be provided 580

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by on-site groundwater through an improved existing well, a new well permitted and drilled (if necessary), or through an off-site source delivered by truck. An on-site diesel generator may be used to power pumps for well water use during construction. It is anticipated that approximately 35 acre-feet of water would be used for construction activities. Any existing wells on site that are not used for the Project would be capped in place.

Description of Operations
During Project operation, the BESS facility would be monitored remotely through the SCADA system. The Project would construct a one-story control shelter with Project equipment, including the SCADA system, relays, and battery backup (approximately 400 to 700 square feet and a height of about 15 feet) near the Project substation. The Project would also include a 7,500-square-foot Project operations and maintenance (O&M) building which is intended to be used for operations and maintenance personnel, parts storage, temporary workstations and restroom facilities. Periodic augmentation of batteries within the Project site would occur to maintain the capacity over an approximately 30-year life. Occasionally, on-site maintenance would be required, which would include replacement of inverter power modules, filters, and miscellaneous electrical repairs on an as-needed basis.

Operating Hours
Once constructed, the Project is expected to operate 24 hours per day, 7 days per week, 365 days per year as an unmanned facility under constant remote monitoring.

Operating Traffic
The Project would be operated remotely through the SCADA system but would require periodic maintenance to be performed by regional employees and contractors. During operation of the substation, operation and maintenance staff would visit the substation periodically for switching and other operation activities.

Maintenance operations would require weekly visits by one or two employees and would include one major maintenance inspection annually. Worker trips would generally be conducted in light-duty pick-up trucks; however, deliveries for maintenance and repairs requiring replacement of large equipment would be conducted using heavy-duty trucks and low-bed trucks.

Hazardous Materials
The Project would not utilize, store, or produce hazardous materials that would pose a significant hazard to the public. Hazardous waste would not be generated on site. Field equipment used during construction and maintenance will contain various hazardous materials such as hydraulic oil, diesel fuel, grease, lubricants, solvents, adhesives, paints, and other petroleum-based products contained in construction vehicles; however, the level of hazardous materials used, or waste generated on the Project site are anticipated to be negligible. Used biodegradable dielectric fluid and mineral oil from the transformers and miscellaneous electrical equipment are potentially hazardous materials. The Project expects oil-filled equipment to be delivered to the Project site filled with product upon arrival. If spent oil is generated, or in the event of a spill, the Project would comply with Department of Toxic Substance Control regulations, specifically the California Code of Regulations (CCR) Title 22, Division 4.5, Environmental Health Standards for the Management of Hazardous Waste.
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Other items that may be used on site, such as smaller container lubricants, paints, thinners, solvents, cleaners, batteries, and sealants, would be kept in a locked utility structure with integral secondary containment that meet Certified Unified Program Agencies (CUPA) and Resource Conservation and Recovery Act (RCRA) requirements for hazardous waste storage until removal for proper disposal and recycling. It is anticipated that all oils and batteries would be recycled at an appropriate facility. Site personnel involved in handling these materials would be trained to properly handle them. Containers used to store hazardous materials would be inspected regularly for any signs of failure or leakage. Additional procedures would be specified in a Hazardous Materials Business Plan submitted to the CUPA.

Transportation of the removed hazardous materials would comply with regulations for transporting hazardous materials, including those set by the Department of Transportation, the U.S. Environmental Protection Agency, California Department of Toxic Substances Control, California Highway Patrol, and California State Fire Marshal. Additionally, handling of hazardous materials would be incorporated into the emergency response and emergency action plan as required by Senate Bill (SB) 38 as discussed in Section

3.6 herein.

Description of Decommissioning
The Project is anticipated to have a lifespan of approximately 30 years. At the end of the Project life the Project would either request a time extension or be decommissioned. If decommissioned, most of the Project’s electrical equipment (breakers, transformers, inverters) would be deenergized prior to removal and recycled to the extent feasible or disposed of at an appropriately licensed disposal facility. The batteries would be returned to the battery manufacturer for recycling. Equipment foundations and pads would be demolished and removed. Site structures and equipment would include metals, wood, and asphalt or concrete. These materials can be recycled, and recycling facilities occur in the region. Metal and scrap equipment and parts that do not have free-flowing oil may be sent for salvage. Fuel, hydraulic fluids, used oil, and asphalt waste would be recycled or disposed of pursuant to the RCRA. Transport of hazardous materials is regulated under the Department of Transportation, the U.S. Environmental Protection Agency, California Department of Toxic Substances Control, California Highway Patrol, and California State Fire Marshal. It is therefore foreseeable that these materials would be recycled or disposed of consistent with applicable law.

The Project operator will submit a Decommissioning Plan to the City of Adelanto for review and approval prior to decommissioning activities.

9. Surrounding land uses and setting (Briefly describe the project’s surroundings):

The Project site is presently vacant. Parcels immediately adjacent to the site to the west and south are also vacant. An existing solar energy facility is located directly to the north of the Project site; with the existing Adelanto Power Conversion Station is located north of the solar facility. An automobile business is located directly to the east of the Project site. More broadly, lands to the west are developed with various industrial and manufacturing uses, and the Adelanto Detention Center. Adelanto High School occurs approximately

0.64 acres to the south, with no intervening development. The nearest residentially developed parcels are approximately 0.64 miles to the northeast, and more than 1 mile to the southeast. See Table 1, Surrounding Land Uses, for further details.
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Table 1. Surrounding Land Uses
Direction
from Project
Site Zoning Land Use Existing Use
North Public Utilities (PU) Sustainable Plan:

Public Utilities (PU)
Solar energy facility, Adelanto
Power Conversion Station,
Adelanto ICE Processing Center -
West
South Single Family Residential
(R-S5)
General Plan:

Single Family Residential
(R-S5)
Vacant lands, Adelanto High
School, Single-family residences
East Manufacturing/Industrial
(MI)
Sustainable Plan:

Manufacturing/Industrial
(MI)
Automobile business, vacant
lands, Victoria Magathan
Elementary School
West Manufacturing/Industrial
(MI)
Sustainable Plan:

Manufacturing/Industrial
(MI)
Vacant lands, High Desert
Detention Center, Engineering
business, Adelanto Airport-52CL
The Project site was selected because of its proximity to existing SCE transmission infrastructure which is an ideal electrical location to interconnect an energy storage facility to maximize the benefits the Project will have for the electrical grid locally and for the region.

The Project site is currently zoned Manufacturing/Industrial (MI) under the City’s Zoning Ordinance (City of Adelanto 2024). The parcels to the east and west of the Project site are also zoned Manufacturing/Industrial (MI), parcels to the north are zoned Public Utility (PU), and parcels to the south are zoned Single Family residential (R-S5). The Manufacturing/Industrial (MI) district provides for a wide range of industrial uses, including light and heavy industrial and manufacturing uses (City of Adelanto 2023). The City of Adelanto Zoning Ordinance addresses allowable uses in the MI zoning districts, which allow Electricity Distribution and Transmission Substations greater than 5,000 square feet with a Conditional Use Permit (CUP). The City considers BESS within this land use category, and therefore a CUP is being obtained.

The Project site is located within the boundary of the Adelanto North 2035 Sustainable Plan (City of Adelanto 2014a). Within the Adelanto North 2035 Sustainable Plan, the Manufacturing/Industrial land use designation considers more employment-intensive developments at key locations that are protected in a manner that minimizes exposure to its surroundings. Permitted and conditionally permitted uses in this zone include correctional facilities, controlled hazard uses, renewable energy facilities, manufacturing, distribution and warehousing, and automotive related businesses. The Sustainable Plan encourages orderly development of infrastructure by identifying two growth areas. The Project site is located within Growth Area 1.

10. Project Local Approvals:

City of Adelanto
▪ Community Development Department
- Conditional Use Permit (CUP)
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- Grading Permit
- Encroachment permit for new driveways/access off Holly or Raccoon Road San Bernardino County Fire Department
▪ Facility Fire Protection and Suppression Plans
▪ Emergency Response and Emergency Action Plan
▪ Hazardous Materials Business Plan
Lahontan Regional Water Quality Control Board
▪ Construction Stormwater General Permit
The Project is also subject to approval process(es) with the following agencies:
▪ California Department of Fish and Wildlife (CDFW)
▪ Mojave Desert Air Quality Management District
Off-site project components occur within existing SCE rights-of-way and within existing SCE substations located in the City of Victorville at the Victor Substation located approximately 3.8 miles southeast of the Project site and the Kramer Substation located approximately 30 miles north of the Project site, and east of the town of Boron. SCE would obtain all necessary permits and approvals for work within its rights-of-way and substation.

Evaluation of Environmental Impacts:

In order to analyze the applicability of CEQA streamlining, as allowed by CEQA Guidelines Section 15183(b), the following Initial Study has been prepared pursuant to CEQA Guidelines Section 15063(c) to determine whether the Project could result in any potential effects that were not previously examined in an adopted environmental document. As codified in CEQA Guidelines Section 15183, no further analysis is needed unless the City identifies effects which:
(1) Are peculiar to the Project or the parcel on which the Project would be located; (2) Were not analyzed as significant effects in a prior EIR5 on the zoning action, general plan, or community plan, with which the Project is consistent;
(3) Are potentially significant off-site impacts and cumulative impacts which were not discussed in the prior EIR prepared for the general plan, community plan or zoning action; or (4) Are previously identified significant effects which, as a result of substantial new information which was not known at the time the EIR was certified, are determined to have a more severe adverse impact than discussed in the prior EIR.

The row titles of this Initial Study Checklist include the full range of environmental topics, as presented in Appendix G of the State CEQA Guidelines. The column titles of the Environmental Checklist have been modified from the Appendix G presentation to answer the questions in relation to the proposed Project’s 5 In this case, the Prior EIR is the City of Adelanto’s Sustainable Plan EIR or General Plan EIR. 584

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potential environmental effects within the parameters outlined in CEQA Guidelines Section 15183. So long as no new information has been identified which would result in a determination that the Project would result in a more severe impact than what had been anticipated by the General Plan and Sustainable Plan EIRs and the proposed Project is consistent with the Sustainable Plan which was analyzed in the Sustainable Plan EIR, no additional environmental review would be required for the proposed Project beyond that provided in the Sustainable Plan EIR and this Project-specific Consistency Checklist in accordance with Public Resources Code Section 21083.3 and CEQA Guidelines Section 15183.

Potential Project impacts and the Plan Implementing Programs in the Sustainable Plan EIR relevant to the proposed Project are discussed under each section in this Consistency Checklist. Many of these impacts were determined to be less than significant or reduced to less-than-significant levels through the incorporation of uniformly applied development standards or Plan Implementing Programs.

3.1 Aesthetics

Significant
Project Impact
Analyzed in the
Prior EIR
Substantial
New
Information
I. AESTHETICS – Except as provided in Public Resources Code Section 21099, would the project:
a) Have a substantial adverse effect on a scenic
vista?
b) Substantially damage scenic resources,
including, but not limited to, trees, rock
outcroppings, and historic buildings within a
state scenic highway?
c) In non-urbanized areas, substantially degrade
the existing visual character or quality of
public views of the site and its surroundings?
(Public views are those that are experienced
from publicly accessible vantage point). If the
project is in an urbanized area, would the
project conflict with applicable zoning and
other regulations governing scenic quality?
d) Create a new source of substantial light or
glare which would adversely affect day or
nighttime views in the area?
Prior Environmental Impact Report Summary
Aesthetic impacts were analyzed in the Sustainable Plan EIR on pages 4.1-1 through 4.1-22. Potential impacts on scenic vistas and resources, degradation of the existing visual character or quality of public views within the study area, and sources of light and glare were evaluated. The Plan EIR determined that with implementation of General Plan, Sustainable Plan, and other existing policies, impacts relating to scenic vistas, scenic resources within a state scenic highway, and degradation of existing visual character or quality would be less than significant. The Plan EIR also determined that impacts regarding light or glare would be less than significant upon implementation of existing zoning standards.
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Applicable Policies
General Plan
No policies are applicable to the topic of aesthetics.

Sustainable Plan
Land Use and Community Design Chapter
Goal LC 17: A more aesthetically pleasing environments with landscape materials that reflect the Mojave Desert environment.

Policy LC 17.1: Use landscaping to reflect a ‘sense of place’ that blends in with Mojave Desert and native plant materials.

Policy LC 17.2: Provide landscaping plants and materials that complement the Mojave Desert environment and wildlife, lower maintenance requirements, and require low to moderate irrigation requirements.

Policy LC 17.3: Use plants that are native to the Southwest and suited to the host desert climates.

Goal LC 18: A higher level of design through landscaping and plant materials.

Open Space and Conservation Chapter
Goal OS 1: Natural resources including land features, viewsheds, and drainages are strategically preserved.

Policy OS 1.3: Preserve views of the desert landscape and existing topography and landforms including Shadow Mountains.

Implementing Program OS-3: Development Impacts on Viewsheds. For new development proposals, analyze existing viewsheds and scenic resources. Where possible, provide for the protection of enhancement of the viewsheds and scenic resources.

Project-Specific Analysis
a) Would the project have a substantial adverse effect on a scenic vista? The analysis under the Sustainable Plan EIR remains accurate with respect to the proposed Project, which would develop an industrial BESS facility in accordance with the provisions of the Sustainable Plan and would occur within the Plan area previously evaluated. The Sustainable Plan EIR determined potential impacts to scenic vistas would be less than significant upon implementation of existing General Plan policy and standards, as well as proposed Sustainable Plan policy. The rural and low-density character of the area provides generally uninterrupted views of scenic resources like mountain ranges and desert open space, with the exception of electrical towers and powers lines that transect the City (City of Adelanto 2014a). 586

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Allowed uses in the Industrial Zone contemplated in the Sustainable Plan EIR include comparatively more substantial uses such as renewable energy facilities, manufacturing, distribution and warehousing, and automotive related business, which can result in significant continuous building wall faces. The maximum height of the M-1 zone for areas north of Holly Road is 65 feet. 6 The proposed BESS is anticipated to have a maximum cabinet height of 12 feet, and the use will be consistent with neighboring land use (solar, storage). Due to the low profile of the BESS, it is unlikely to block the views of mountain ranges from any public viewpoint, and given the distance from those ranges and the lack of development surrounding the Project site. As well, there is a limited potential for blocked views given the absence of viewers (lack of development, public lands) in the area..

Notwithstanding, if development were to block some portion of the view of these ranges within the immediate Project area, these views would be visible from many other locations throughout the Project site and Sustainable Plan area and therefore would not be impacted on an area-wide basis. The nearest future residential development would be a minimum 50 feet south of the Project site given the Project setbacks, intervening road(s), and the setbacks required in the residential zones. Further, because of the natural slope of the site, battery modules would sit lower than the Project fence along the Holly Road frontage, and presumably lower than future residences south of Holly Road, reducing obstruction of views by nearby residential users. Taller components of the Project such as transmission lines and transmission line support structures would be consistent with other electrical transmission infrastructure in the area or would be located in the existing, utilized transmission lines rights-of-way. Furthermore, proposed upgrades to the SCE Victor Substation and SCE Kramer Substation would be located within the existing substation footprints and would blend in with existing equipment at the substations.

Consistent with the prior EIR, the Project site would not have a direct adverse effect on a scenic vista. In addition, the proposed Project would adhere to the applicable development standards and design guidelines outlined in the Sustainable Plan and Adelanto Zoning Ordinance including screening requirements, height limits and on-site lighting standards. Additionally, the Project would be consistent with the applicable provisions of the Sustainable Plan, which contemplates manufacturing/industrial uses for the Project site. Therefore, impacts from Project implementation would remain less than significant.

As such, impacts associated with the development of the proposed Project within the Sustainable Plan area would be consistent with the analysis in the Plan EIR and would result in less-than-significant impacts. The proposed Project would not result in any peculiar effects related to scenic vistas and would not result in a new or more severe adverse impact that was not previously identified in the prior EIR. Further, the Project would not result in an increase to significant effects as a result of new information not previously assessed in the Sustainable Plan EIR.
b) Would the project substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway? The Sustainable Plan EIR determined there would be no impact to scenic resources within a state scenic highway as scenic corridors or highways do not currently exist in the area and none are proposed (City of Adelanto 2014b). Furthermore, the Project would not alter any topography or landforms, as none exist on 6 Maximum height allowed in the M-1 zone per Table 30-1, Section 17.30.040 is 65 feet north of Holly Road, and 75 feet south of Holly Road.
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site. Because the Project site does not contain scenic resources within or near a state scenic highway, no impact related to scenic resources as part of Project implementation would occur. Off-site improvements to the SCE Victor Substation and SCE Kramer Substation would be located within the existing substation footprints, while transmission lines and transmission line support structures would be located within the existing utilized transmission lines rights-of-way and would not damage any existing scenic resources.

As such, impacts associated with the development of the proposed Project within the Sustainable Plan area would be consistent with the analysis in the Plan EIR. The proposed Project would not result in any peculiar effects related to scenic resources and would not result in a new or more severe adverse impact that was not previously identified in the prior EIR. Further, the Project would not result in an increase to significant effects as a result of new information not previously assessed in the Sustainable Plan EIR. c) In non-urbanized areas, would the project substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from publicly accessible vantage point). If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality?
The Sustainable Plan EIR determined that the potential degradation of the visual character of the Plan area due to buildout consistent with zoning would be less that significant with implementation of various policies designed to protect and enhance visual character. The Sustainable Plan EIR analyzed industrial development of this site including uses such as those proposed by the Project. Community Design standards established in the Sustainable Plan promote placemaking and thematic landscaping and would ensure quality aesthetic design, would be required to be implemented for the proposed Project which is located in an industrial area. Sustainable Plan policies and Implementing Programs would improve the aesthetic and visual character of the Plan area (City of Adelanto 2014b).

The Project site is currently vacant but is in an area zoned for Manufacturing/Industrial (MI) development with many industrial operations in the area surrounding the Project site. Development of the Project site as an industrial use would be similar in nature to several other nearby industrial uses and has been analyzed within the Sustainable Plan and City Zoning Code. The proposed Project is consistent with the site’s MI zoning and development would be required to adhere to the applicable development standards and design guidelines for industrial areas established in the Sustainable Plan and the Zoning Code, such as screening requirements, height limits and on-site lighting standards. This would ensure that Project implementation would not result in a substantial degradation of existing visual character of the site and its surroundings.

Off-site transmission lines and transmission line support structures would be consistent with other electrical transmission infrastructure in the area and would be located in the existing transmission lines rights-of-way. Furthermore, proposed upgrades to the SCE Victor Substation and SCE Kramer Substation would be located within the existing substation footprints and would blend in with existing equipment at the substations. As such, off-site improvements would not result in substantial degradation of existing visual character or quality of public views. Therefore, impacts from Project implementation would remain less than significant.

As such, impacts associated with the development of the proposed Project within the Sustainable Plan area would be consistent with the analysis in the Plan EIR. The proposed Project would not result in any peculiar effects related to the degradation of the visual character of the site and would not result in a new or more severe adverse impact that was not previously identified in the prior EIR. Further, the Project would not 588

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result in an increase to significant effects as a result of new information not previously assessed in the Sustainable Plan EIR.
d) Would the project create a new source of substantial light or glare which would adversely affect day or nighttime views in the area?
The Sustainable Plan EIR concluded that proposed development under the Plan would produce new sources of light and glare. However, the City’s Zoning Code regulates glare and outdoor lighting in Chapter 17.90, which prohibits direct or reflected glare originating on a property from being visible from the property line (City of Adelanto 2023). As stated in the Sustainable Plan EIR, the proposed Project would be required to go through the City’s routine plan check procedures that will ensure the Project is appropriately designed and maintained to minimize light and glare impacts to a level of less than significant (City of Adelanto 2014b).

As described in the Sustainable Plan EIR, development of the proposed Project would be similar to other industrial uses analyzed and would introduce new sources of light and glare to the Project site and the vicinity. This would primary be due to the installation of indoor and outdoor lighting required for safety and security purposes and light and glare due to reflective building and hardware exteriors as the facility would operate 24 hours a day, 7 days a week. Under the proposed Project, lighting would only be in areas where it is required for safety, security, or operations, and would be directed inward to the site and include shielding as necessary to minimize illumination of the night sky or potential impacts to surrounding viewers.

New lighting mounted on off-site transmission line support structures would be consistent with existing support structure lighting at the SCE Victor Substation and the SCE Kramer Substation and in the in the existing transmission line rights-of-way and would be subject to requirements set forth in the San Bernadino County Light Trespass Ordinance or the applicable design guidelines for lighting and glare set forth in the City of Victorville Municipal Code (City of Victorville 2024a; County of San Bernardino 2024a). Therefore, impacts from Project implementation would remain less than significant.

As such, impacts associated with the development of the proposed Project within the Sustainable Plan area would be consistent with the analysis in the Plan EIR. The proposed Project would not result in any peculiar effects related to light and glare and would not result in a new or more severe adverse impact that was not previously identified in the prior EIR. Further, the Project would not result in an increase to significant effects as a result of new information not previously assessed in the Sustainable Plan EIR.

Conclusion
The proposed Project is consistent with the development evaluated in the Sustainable Plan EIR and would not result in any new impacts or increase the severity of any previously identified impacts as compared to what was already identified and disclosed, either individually or cumulatively. Further environmental analysis is not required because:

No peculiar impacts that are not substantially mitigated have been identified as a result of the proposed Project or its site. Application of uniformly applied Sustainable Plan policies and standards, along with regulations of the City of Adelanto Zoning Code would ensure that impacts would be less than significant.

There are no potentially significant impacts that were not analyzed as significant in the Sustainable Plan EIR.

There are no potentially significant off-site and/or cumulative impacts that were not discussed in the Sustainable Plan EIR.
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No substantial new information has been identified that results in an impact that is more severe than anticipated by the Sustainable Plan EIR.

3.2 Agriculture and Forestry Resources

Significant
Project
Impact
Analyzed in
the Prior
EIR
Substantially
Substantial New
Information
II. AGRICULTURE AND FORESTRY RESOURCES – In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Dept. Conservation as an optional model to use in assessing impacts on agriculture and farmland. In determining whether impacts to forest resources, including timberland, are significant environmental effects, lead agencies may refer to information compiled by the California Department of Forestry and Fire Protection regarding the state’s inventory of forest land, including the Forest and Range Assessment Project and the Forest Legacy Assessment project; and forest carbon measurement methodology provided in Forest Protocols adopted by the California Air Resources Board. Would the project:
a) Convert Prime Farmland, Unique Farmland, or
Farmland of Statewide Importance (Farmland),
as shown on the maps prepared pursuant to the
Farmland Mapping and Monitoring Program of
the California Resources Agency, to nonagricultural use? b) Conflict with existing zoning for agricultural use,
or a Williamson Act contract?
c) Conflict with existing zoning for, or cause
rezoning of, forest land (as defined in Public
Resources Code section 12220(g)), timberland
(as defined by Public Resources Code section
4526), or timberland zoned Timberland
Production (as defined by Government Code
section 51104(g))?
d) Result in the loss of forest land or conversion of
forest land to non-forest use?
e) Involve other changes in the existing
environment which, due to their location or
nature, could result in conversion of Farmland,
to non-agricultural use or conversion of forest
land to non-forest use?
Prior Environmental Impact Report Summary
Agriculture and forest resources impacts were analyzed in the Sustainable Plan EIR on pages 4.2-1 through

4.2-10. The Sustainable Plan EIR evaluated the development of the industrial uses proposed by the Project.

The EIR determined that within the City and its unincorporated Sphere of Influence (SOI), there is not any designated agricultural uses, there are no lands subject to Williamson Act contracts, and there are not any forest or timberland resources (City of Adelanto 2014b). 590

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Applicable Policies
General Plan
No policies are applicable to the topic of agriculture and forestry resources.

Sustainable Plan
No policies are applicable to the topic of agriculture and forestry resources.

Project-Specific Analysis
a) Would the project convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use? The City does not have any land within its jurisdictional boundaries or within its unincorporated SOI that is designated as Farmland by the California Department of Conservation, and all lands within the Sustainable Plan area are comprised of either desert scrub habitat or developed and disturbed lands (City of Adelanto 2014b). Furthermore, neither the SCE Kramer Substation nor the SCE Victor Substation nor the surrounding areas are located on lands designated as Farmland by the California Department of Conservation (DOC 2024a). The analysis under the Sustainable Plan EIR remains accurate with respect to the proposed Project. As such, there would be no impact to farmland as disclosed in the Sustainable Plan EIR. Therefore, the Project would not result in any peculiar effects and would not result in a new or more severe adverse impact that was not previously identified in the prior EIR. Further, the Project would not result in an increase to significant effects as a result of new information not previously assessed in the Sustainable Plan EIR. b) Would the project conflict with existing zoning for agricultural use, or a Williamson Act contract? The Project site is not zoned for agricultural use nor subject to a Williamson Act contract, nor are there such lands in the vicinity. The prior EIR identified that Williamson Act contract land does not exist within the City or its SOI at the time of drafting the EIR and stated that future Williamson Act contracts are not anticipated because no agriculturally zoned land exists (City of Adelanto 2014b). The analysis under the Plan EIR remains accurate with respect to the proposed Project. As such, the Sustainable Plan stated there would be no impact. The analysis under the Plan EIR remains accurate with respect to the proposed Project.

Furthermore, neither the SCE Victor Substation nor the SCE Kramer Substation are zoned for agricultural use or subject to a Williamson Act contract (City of Victorville 2024b; County of San Bernadino 2024b; DOC 2024b). All off-site improvements would take place within the existing transmission line rights-of-way or within the existing substation footprints at the SCE Victor Substation and the SCE Kramer Substation.

Therefore, the proposed Project would not result in any peculiar effects and would not result in a new or more severe adverse impact that was not previously identified in the prior EIR. Further, the Project would not result in an increase to significant effects as a result of new information not previously assessed in the Sustainable Plan EIR.
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c) Would the project conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g))? As analyzed in the Sustainable Plan EIR, no forest land, timberland, or timberland zoned Timberland Production is present within the City or its SOI (City of Adelanto 2014b). The analysis under the Plan EIR remains accurate with respect to the proposed Project. The Project site, the transmission line rights-of-way, and the existing Kramer and Victor Substations do not contain forest land or timberland, and no conflicts with forest land zoning would occur as part of Project implementation. Therefore, the proposed Project would not result in any peculiar effects and would not result in a new or more severe adverse impact that was not previously identified in the prior EIR. Further, the Project would not result in an increase to significant effects as a result of new information not previously assessed in the Sustainable Plan EIR. d) Would the project result in the loss of forest land or conversion of forest land to non-forest use? As analyzed in the Sustainable Plan EIR, no forest land, timberland, or timberland zoned Timberland Production is present within the City or its SOI (City of Adelanto 2014b). The analysis under the Plan EIR remains accurate with respect to the proposed Project. The Project site, the transmission line rights-of-way, and the existing Kramer and Victor Substations do not contain forest land or timberland, and no loss of forest land would occur as part of Project implementation. Therefore, the proposed Project would not result in any peculiar effects and would not result in a new or more severe adverse impact that was not previously identified in the prior EIR. Further, the Project would not result in an increase to significant effects as a result of new information not previously assessed in the Sustainable Plan EIR. e) Would the project involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use or conversion of forest land to non-forest use? The Sustainable Plan EIR the development of the industrial uses proposed by the Project. The City does not have any land within its jurisdictional boundaries or within its unincorporated SOI that is designated as Farmland (City of Adelanto 2014b). As such, implementation of the Sustainable Plan would not create conflicts involving agricultural or forest zoning and would not result in other changes to the existing environment which, due to their location or nature, could result in conversion of Farmland or forests, to non-agricultural or non-forestry use. As discussed above, all off-site improvements and updates would be located within the existing Victor and Kramer Substation footprints or transmission lines rights-of-way.

These off-site improvement areas are not located on Farmland or forest land and do not contain any agriculture or forestry resources. As such, the proposed off-site improvements would not result in conversion of Farmland to non-agricultural use or conversion of forest land to non-forest use.

Conclusion
The analysis under the prior EIR remains accurate with respect to the proposed Project. As such, impacts associated with the development of the proposed Project within the Sustainable Plan area would be consistent with the analysis in the Plan EIR and impacts would not occur. The proposed Project would not result in any peculiar effects related to farmland or forest land and would not result in a new or more severe adverse impact that was not previously identified in the prior EIR. Further, the Project would not result in an increase to significant effects as a result of new information not previously assessed in the Sustainable Plan EIR. 592

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The proposed Project is consistent with the development evaluated in the Sustainable Plan EIR and would not result in any new impacts or increase the severity of any previously identified impacts as compared to what was already identified and disclosed, either individually or cumulatively. Further environmental analysis is not required because:

No peculiar impacts that are not substantially mitigated have been identified as a result of the proposed Project or its site.

There are no potentially significant impacts that were not analyzed as significant in the Sustainable Plan EIR.

There are no potentially significant off-site and/or cumulative impacts that were not discussed in the Sustainable Plan EIR.

No substantial new information has been identified that results in an impact that is more severe than anticipated by the Sustainable Plan EIR.

3.3 Air Quality

Significant
Project Impact
Analyzed in
the Prior
EIRs
Substantial New
Information
III. AIR QUALITY – Where available, the significance criteria established by the applicable air quality management district or air pollution control district may be relied upon to make the following determinations. Would the project:
a) Conflict with or obstruct implementation of
the applicable air quality plan?
b) Result in a cumulatively considerable net
increase of any criteria pollutant for which
the project region is non-attainment under
an applicable federal or state ambient air
quality standard?
c) Expose sensitive receptors to substantial
pollutant concentrations?
d) Result in other emissions (such as those
leading to odors) adversely affecting a
substantial number of people?
Prior Environmental Impact Report Summary
Air Quality impacts were analyzed in the Sustainable Plan EIR on pages 4.3-1 through 4.3-28. The Sustainable Plan EIR evaluated potential impacts relating to whether development of the Plan area would conflict with or obstruct implementation of an applicable air quality plan, violate air quality standards, result in cumulatively considerable increases in air pollutants, expose sensitive receptors to substantial pollutant concentrations, or create objectionable odors. The Sustainable Plan EIR contemplated uses on the Project site involving industrial uses such as warehousing, which would be a more intensive use resulting in higher transportation related emissions and potentially higher operational emissions than the proposed Project. The Mojave Desert Air Basin (MDAB) is in nonattainment for State and federal standards for 8-hour ozone and PM10 and state standards for 1-hour ozone and PM2.5. However, the Sustainable Plan EIR determined impacts related to these non-attainment status criteria pollutants would be less than significant at a program-level. The Plan EIR also determined that impacts relating to 593

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the exposure of sensitive receptors to substantial pollutant concentrations, or the creation of objectionable odors would be less than significant with the incorporation of Sustainable Plan Implementing Programs.

Applicable Policies
General Plan
No policies are applicable to the topic of air quality.

Sustainable Plan
Open Space and Conservation Chapter
Goal OS 6: Local air quality is good; local contributions of airborne pollutants to the air basin is reduced.

Policy OS 6.1: Pursue efforts to reduce air pollution and greenhouse gas emissions by promoting the use of renewable energy (e.g., solar and wind power), and implement effective energy conservation and efficiency measures.

Policy OS 6.2: Integrate air quality planning with land use, economic development, and transportation planning.

Policy OS 6.3: Require projects that generate potentially significant levels of air pollutants and odors to incorporate the most effective air quality mitigation into project design, as feasible.

Implementing Program OS-19: Air Quality Impacts to Sensitive Receptors. During the City’s standard environmental and development review processes and prior to approval of entitlements, potential air quality impacts to sensitive receptors shall be analyzed. Screening procedures may be implemented based on emissions source/sensitive receptor proximity or using other reasonable methods promulgated by the Mojave Desert Air Quality Management District, the California Air Resources Board, or other qualified source. A detailed analysis shall be required when a project fails screening procedures to include dispersion modeling and detailed receptor inventories. Mitigation shall be incorporated where potentially significant impacts are identified that may include, but is not limited to, project siting and proximity changes, mechanical filtration and/or scrubbing, and increased equipment and/or vehicle fleet efficiency. The analysis shall be reviewed and approved by the Development Services Director (or designee) and the results incorporated into the project environmental documentation.

Implementing Program OS-20: Odor Impacts. The City shall determine if there is a potential for the use to be located in an area with negative odors or if the use will generate negative odors. If it is determined that an odor issue may occur, potential odor impacts shall be analyzed. Screening procedures may be implemented based on land use or using other reasonable methods promulgated by the Mojave Desert Air Quality Management District, the California Air Resources Board, or other qualified source. A detailed analysis shall be required when a project fails screening procedures that may include American Society of Testing Materials Standard Method D- 1391, E679-79, or other applicable method. Mitigation shall be incorporated where potentially significant impacts are identified that may include, but is not limited to, project siting and proximity changes, mechanical filtration and/or scrubbing, and operational restrictions. The analysis shall be reviewed and approved by the Development Services Director (or designee) and the results incorporated into the project environmental documentation. 594

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Project-Specific Analysis
Consistent with the above Implementing Program, a Project-specific analysis was prepared for the proposed Project.

The discussion provided below is based on the Air Quality and Greenhouse Gas Emissions Technical Memorandum (Technical Memorandum) prepared by Dudek in May 2024 (Appendix A). a) Would the project conflict with or obstruct implementation of the applicable air quality plan? The Sustainable Plan EIR evaluated whether the full build out of the Plan area would conflict with or obstruct implementation of applicable air quality plans and determined that the Sustainable Plan and its implementing actions would not conflict with or obstruct this plan, and impacts would be less than significant. The proposed Project is consistent with the allowed uses of the M-1 zone and is therefore contemplated and included as part of the build out projected under the Sustainable Plan.

Construction Emissions
As described in the Sustainable Plan EIR, development under the Plan will result in short-term criteria pollutant emissions during site preparation, grading, building construction, paving, and painting activities.

Emissions will occur from the use of equipment, worker, vendor, and hauling trips, and disturbance of onsite soils (fugitive dust) (City of Adelanto 2014b). The Sustainable Plan EIR states that mitigation will be applied, if necessary, and typically includes requirements for use of low-VOC paints, installation of diesel particulate filters on older construction equipment, and limitations on hauling distances and/or daily trips.

A detailed discussion of the Project’s consistency with applicable air quality follows.

Project Consistency with Air Quality Plan
The Sustainable Plan EIR states that a proposed project would be considered conforming if it complies with all applicable District rules and regulations, complies with all proposed control measures that are not yet adopted from the applicable plan, and is consistent with the growth forecasts in the applicable plan. The Sustainable Plan EIR states that conformity with growth forecasts can be established by demonstrating that a project is consistent with the land use plan that was used to generate the growth forecast. Consistency with the Mojave Desert Air Quality Management District’s (MDAQMD) Air Quality Management Plan (AQMP) is determined by performing an analysis of a project with the assumptions in the AQMP.

The Sustainable Plan EIR states that long-term criteria air pollutant emissions, which are categorized as area source emissions, energy demand emissions, and operational emissions, will result from future development within the City. Area source emissions are defined in the Plan EIR as the combination of many small emissions sources that include the use of landscape maintenance equipment, consumer products such as cleaning products, and periodic repainting of proposed buildings. Based on the consistency analysis provided in the Sustainable Plan EIR, the Sustainable Plan and its implementing actions would not increase the dwelling unit density, vehicle trips, or vehicle miles traveled (VMT) beyond the maximum build out conditions examined for the existing General Plan Land Use Plan. Therefore, the Sustainable Plan and its implementing actions are consistent with the MDAQMD AQMP and would result in less-than-significant impacts.

Furthermore, policies within the Sustainable Plan support attainment of air quality goals through assessment and mitigation of development under the Plan, if necessary (City of Adelanto 2014b). The Sustainable Plan EIR states that these policies support reductions of operational criteria air pollutant 595

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emissions by reducing reliance on single-rider vehicle trips while construction-related emission would be reduced through scheduling and programming techniques and reduce fugitive dust emissions through daily site watering. The attainment plans are projected to achieve attainment of criteria pollutants and potential violations of any air quality standard or contribution to an existing or projected air quality violation would be avoided (City of Adelanto 2014b). As discussed in the Sustainable Plan EIR, the Sustainable Plan would support criteria air pollutant attainment plan implementation, and impacts relating to conflicts with an applicable air quality plan would be less than significant.

As discussed in the Air Quality and Greenhouse Gas Emissions Technical Memorandum, the Federal Particulate Matter Attainment Plan (MDAQMD 1995) and Ozone Attainment Plan (MDAQMD 2008) for the Mojave Desert set forth a comprehensive set of programs that will lead the MDAB into compliance with federal and state air quality standards. The control measures and related emission reduction estimates within the Federal Particulate Matter Attainment Plan and Ozone Attainment Plan are based upon emissions projections for a future development scenario derived from land use, population, and employment characteristics defined in consultation with local governments (Appendix A).

The Project site is currently zoned Manufacturing/Industrial (MI) in the City’s Zoning Map, and the proposed Project would be consistent with the land use designations and zoning for the Project site (City of Adelanto 2024; Appendix A). All off-site improvements and updates would be located within the existing, improved, Victor and Kramer Substation footprints or transmission lines rights-of-way. Project construction and operational emissions would not exceed applicable MDAQMD thresholds, and the Project would also be required to comply with all applicable MDAQMD rules and regulations, including, but not limited to Rules 401 (Visible Emissions), 402 (Nuisance), and 403 (Fugitive Dust Control for the Mojave Desert Planning Area) (Appendix A). Given the preceding considerations, and as discussed in the Technical Memorandum, it was determined that the Project would not conflict with or obstruct implementation of the Federal Particulate Matter Attainment Plan and Ozone Attainment Plan for the MDAB, and that impacts would be less than significant.

Summary
The proposed Project would be consistent with the growth assumptions and the related emission reduction estimates within the applicable AQMPs and would implement all applicable control measures. It would also be consistent with the Manufacturing/Industrial development designated in the Sustainable Plan and analyzed in the Plan EIR. The Project would also implement all applicable MDAQMD rules and regulations, which are uniformly applied development policies and standards.

As such, impacts associated with the development of the proposed Project would be consistent with the analysis in the Plan EIR and would result in less-than-significant impacts. The proposed Project would not conflict with or obstruct implementation of the applicable air quality plan. The Project would not result in any peculiar effects and would not result in a new or more severe adverse impact, or a potentially significant off-site or cumulative impact, that was not previously identified in the prior EIR. Further, the Project would not result in an increase to significant effects as a result of new information not previously assessed in the Sustainable Plan EIR.
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b) Would the project result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard? The Sustainable Plan EIR evaluated whether the full build out of the Plan area would result in a cumulatively considerable increase of any criteria pollutant and determined that the Sustainable Plan and its implementing actions would not result in a cumulatively considerable increase of any criteria pollutant and impacts would be less than significant at a program-level. The analysis under the Sustainable Plan EIR remains accurate with respect to the proposed Project, which would develop an industrial BESS facility in accordance with the provisions of the Sustainable Plan and would occur within the Plan area previously evaluated.

As discussed above in 3.3(a), the proposed Project would be consistent with the growth assumptions and the related emission reduction estimates within the applicable AQMPs, would implement all applicable control measures, would be consistent with the Manufacturing/Industrial development designated in the Sustainable Plan and analyzed in the Plan EIR, and would implement all applicable MDAQMD rules and regulations. Furthermore, as discussed in the Air Quality and Greenhouse Gas Emissions Technical Memorandum, the Federal Particulate Matter Attainment Plan (MDAQMD 1995) and Ozone Attainment Plan (MDAQMD 2008) for the Mojave Desert set forth a comprehensive set of programs that will lead the MDAB into compliance with federal and state air quality standards. The Technical Memorandum states that the non-attainment status of regional pollutants is a result of past and present development. Although the area of the MDAB where the Project site is located is currently designated a non-attainment area for federal and state O3 standards and federal and state PM10 standards, the MDAB has experienced a substantial reduction in maximum 8-hour concentrations of O3 over the past 30 years, as well as reductions in PM10 over time, as described in the respective MDAQMD O3 and PM10 attainment plans (Appendix A). CEQA thresholds are established at levels that the air basin can accommodate without affecting the attainment date for the ambient air quality standards. Based on these considerations, Project-level thresholds of significance for criteria pollutants are relevant in the determination of whether a project’s individual emissions would have a cumulatively significant impact on air quality. Therefore, to determine if the Project would have a cumulatively considerable impact, it must first be determined whether it would have a Projectlevel impact on air quality.

The MDAQMD CEQA Guidelines (MDAQMD 2020) sets forth quantitative emission significance thresholds for criteria air pollutants below which a project would not have a significant impact on ambient air quality, as discussed in the Technical Memorandum. Project-related air quality emissions estimated in this environmental analysis would be considered significant if any of the applicable significance thresholds presented in Table 2 are exceeded (Appendix A). The emission-based thresholds for O3 precursors are intended to serve as a surrogate for an “ozone significance threshold” (i.e., the potential for adverse O3 impacts to occur) because O3 itself is not emitted directly. MDAQMD recommends that its quantitative air pollution thresholds be used to determine the significance of Project emissions.

Table 2. Mojave Desert Air Quality Management District Daily Air Quality Significance Thresholds
Pollutant Daily Threshold (pounds per day)
VOC 137
NOx 137
CO 548
SOx 137
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Table 2. Mojave Desert Air Quality Management District Daily Air Quality Significance Thresholds
Pollutant Daily Threshold (pounds per day)
PM10 82
PM2.5 65
Hydrogen sulfidea 54
Leada 3
Source: MDAQMD 2020.

Notes: VOC = volatile organic compound; NOx = oxides of nitrogen; CO = carbon monoxide; SOx = sulfur oxides; PM10 = coarse particulate matter; PM2.5 = fine particulate matter.
a The Project includes typical equipment and on-road vehicles, which result in negligible (if any) emissions of hydrogen sulfide and lead.

Therefore, these pollutants are not discussed in this analysis.Regarding localized CO, although the MDAQMD does not have screening levels for intersection traffic that could result in potential CO hotspots, several other air districts have established these levels, which are described below to provide context of the magnitude of hourly volumes that could result in significant localized CO:
▪ The South Coast Air Quality Management District (SCAQMD) conducted CO modeling for its 2003 Air Quality Management Plan (SCAQMD 2003) for the four worst-case intersections in the South Coast Air Basin. At the time the 2003 Air Quality Management Plan was prepared, the intersection of Wilshire Boulevard and Veteran Avenue was the most congested intersection in Los Angeles County, with an average daily traffic volume of approximately 100,000 vehicles per day. Using CO emission factors for 2002, the peak modeled CO 1-hour concentration was estimated to be 4.6 ppm at the intersection of Wilshire Boulevard and Veteran Avenue. Accordingly, CO concentrations at congested intersections would not exceed the 1-hour or 8-hour CO ambient air quality standard unless projected daily traffic would be at least more than 100,000 vehicles per day.
▪ The Bay Area Air Quality Management District determined that projects would result in a less-thansignificant impact to localized CO concentrations if (1) project traffic would not increase traffic volumes at affected intersections to more than 44,000 vehicles per hour, or (2) project traffic would not increase traffic volumes at affected intersections to more than 24,000 vehicles per hour where vertical and/or horizontal mixing is substantially limited (e.g., tunnel, parking garage, bridge underpass, natural or urban street canyon, below-grade roadway) (BAAQMD 2023).

Based on the Project’s proximity to the South Coast Air Basin, the SCAQMD screening criterion of 100,000 vehicles per day has been applied to this Project as a metric to evaluate CO hotspots.

Project Construction Emissions
Proposed construction activities would result in the temporary addition of pollutants to the local airshed caused by on-site sources (i.e., off-road construction equipment and soil disturbance) and off-site sources (i.e., on-road vendor trucks, haul trucks, and worker vehicle trips). Construction emissions can vary substantially from day to day, depending on the level of activity, the specific type of operation, and, for particulate matter, the prevailing weather conditions. Therefore, such emission levels can only be approximately estimated.

CalEEMod Version 2022 was used to estimate emissions from construction of the Project in the Technical Memorandum (Appendix A). Internal combustion engines used by construction equipment, trucks, and worker vehicles would result in emissions of VOCs, NOx, CO, PM10, and PM2.5. PM10 and PM2.5 emissions would also be generated by entrained dust, which results from the exposure of earth surfaces to wind from the direct disturbance and movement of soil. Although not accounted for in the emissions estimates, the 598

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Project, including off-site improvements located within the existing Victor and Kramer Substation footprints or transmission lines rights-of-way, would be required to comply with MDAQMD Rule 403 to control dust emissions generated during the grading activities, which requires standard construction practices to reduce fugitive dust.

CalEEMod calculates maximum daily emissions for summer and winter periods. As such, the estimated maximum daily construction emissions for both summer and winter periods are summarized in Table 3 below (Appendix A). Details of the emission calculations are provided in Appendix A, the Air Quality and Greenhouse Gas Emissions Technical Memorandum.

Table 3. Estimated Maximum Daily Construction Criteria Air Pollutant Emissions – Unmitigated
Year
VOC NOx CO SOx PM10 PM2.5
Pounds per Day
Summer
2025 (Construction) 8.99 82.88 97.05 0.19 5.06 3.25
2026 (Construction) 3.78 28.43 45.80 0.08 4.41 1.68
2050 (Decommissioning) 2.34 29.31 23.53 0.20 6.68 2.32
Winter
2025 (Construction) 8.90 83.13 94.88 0.19 19.15 9.34
2026 (Construction) 3.67 28.69 40.65 0.08 4.41 1.68
2050 (Decommissioning) 2.29 30.41 23.26 0.20 6.68 2.32
Maximum Daily Emissions 8.99 83.13 97.05 0.20 19.15 9.34 MDAQMD Threshold 137 137 548 137 82 65
Threshold Exceeded? No No No No No No
Source: Appendix A.

Notes: VOC = volatile organic compound; NOx = oxides of nitrogen; CO = carbon monoxide; SOx = sulfur oxides; PM10 = coarse particulate matter; PM2.5 = fine particulate matter; MDAQMD= Mojave Desert Air Quality Management District.

The analysis assumed a construction start of 2025, which represents the earliest possible period construction would initiate. Assuming the earliest start date for construction represents the worst-case scenario for criteria air pollutant and greenhouse gas emissions because equipment and vehicle emission factors for later years would be slightly less due to more stringent standards for in-use offroad equipment and heavy-duty trucks, as well as fleet turnover replacing older equipment and vehicles in later years.

As depicted in Table 3 above, short-term construction criteria pollutant emissions generated by the Project would not exceed the respective MDAQMD thresholds and would result in a less-than-significant impact. See Appendix A for more details.

Operational Emissions
Operation of the Project would generate criteria pollutant emissions from mobile sources (vehicular traffic), area sources (consumer products, landscaping equipment), off-road equipment (infrequent container movement), and stationary sources (emergency generator), while no natural gas would be used by the Project (Appendix A). There would be no operational emissions associated with off-site improvements to the Victor and Kramer Substations or within the existing rights-of-way. Table 4 below summarizes the unmitigated maximum daily operational emissions associated with the Project. Detailed operational model outputs are presented in Attachment A of Appendix A.
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Table 4. Estimated Maximum Daily Operation Criteria Air Pollutant Emissions – Unmitigated
Emissions Source
VOC NOx CO SOx PM10 PM2.5
Pounds per Day
Summer
Mobile 0.31 0.39 3.69 0.01 0.77 0.20
Area 0.03 <0.01 0.04 <0.01 <0.01 <0.01
Energy 0.00 0.00 0.00 0.00 0.00 0.00
Off-Road 0.37 3.45 3.07 0.01 0.14 0.13
Stationary 0.33 0.92 0.84 <0.01 0.05 0.05
Total Daily Summer Emissions 1.04 4.75 7.64 0.02 0.96 0.38 Winter
Mobile 0.28 0.42 2.76 0.01 0.77 0.20
Area 0.02 0.00 0.00 0.00 0.00 0.00
Energy 0.00 0.00 0.00 0.00 0.00 0.00
Off-Road 0.37 3.45 3.07 0.01 0.14 0.13
Stationary 0.33 0.92 0.84 <0.01 0.05 0.05
Total Daily Winter Emissions 1.00 4.78 6.67 0.02 0.96 0.38 Maximum Daily Emissions 1.04 4.78 7.64 0.02 0.96 0.38
MDAQMD Threshold 137 137 548 137 82 65
Threshold Exceeded? No No No No No No
Source: Appendix A.

Notes: VOC = volatile organic compound; NOx = oxides of nitrogen; CO = carbon monoxide; SOx = sulfur oxides; PM10 = coarse particulate matter; PM2.5 = fine particulate matter; MDAQMD = Mojave Desert Air Quality Management District.

As depicted in Table 4 above, long-term operational criteria pollutant emissions generated by the Project would not exceed the respective MDAQMD thresholds and would result in a less-than-significant impact.

Based on the preceding considerations, the Project would not result in a cumulatively considerable net increase of any criteria pollutant for which the Project region is non-attainment during construction or operation. Therefore, the proposed Project is consistent with the findings disclosed in the Sustainable Plan EIR. As such, the Project would not result in any peculiar effects and would not result in a new or more severe adverse impact, or a potentially significant off-site or cumulative impact, that was not previously identified in the prior EIR. Further, the Project would not result in an increase to significant effects as a result of new information not previously assessed in the Sustainable Plan EIR. c) Would the project expose sensitive receptors to substantial pollutant concentrations? The Sustainable Plan EIR evaluated the full build out of the Plan area and potential impacts related to exposure of sensitive receptor to substantial toxic air pollutants and determined that with incorporation of Sustainable Plan Implementing Program OS-19, impacts would be less than significant.

The analysis under the Sustainable Plan EIR remains accurate with respect to the proposed Project, which would develop an industrial BESS facility in accordance with the provisions of the Sustainable Plan and would occur within the Plan area previously evaluated.
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The MDAQMD identifies sensitive receptors as residences, schools, playgrounds, childcare centers, and medical facilities (MDAQMD 2020). Existing sensitive receptors are a substantial distance from the Project site, with the closest being Adelanto High School (3,635 feet to the south), a single-family residence along Cassia Road (3,800 feet to the east), the High Desert Detention Center (3,875 feet to the west), singlefamily residences in South Adelanto (nearest at 5,680 feet to the south), the Donald F. Bradach Elementary School (6,850 feet to the southeast), and the Victoria Magathan Elementary School (7,300 feet to the east).Although land located south of Holly Road is zoned for residential, no residences are currently built in that area which is within the Growth Area 2 boundary. The Project site is within Growth Area 1, which is prioritized for development prior to Growth Area 2. It is currently unknown if and when residential development may occur south of Holly Road, adjacent to the Project site. Here we note that the City’s Sustainable Plan and EIR addressed industrial-type development on this site and the proximity of residential development to the south. Based on the CARB recommended siting standards, land designated for residential development within 1,000 feet downwind of a designated industrial land use concentration is considered to be a potentially significant. However, 5 years of monitoring indicates that wind patterns in Adelanto come primarily from the southwest direction at speeds of 1.3 to 19 miles an hour, which is in the opposite direction of the residential development. Impacts to nearby receptors is discussed below.

The Mohave River Academy (West Victorville) is located approximately 600 feet northwest of the SCE Victor Substation. All off-site improvements would occur within the existing substation footprint or within the existing transmission line rights-of-way.

As discussed in Section 3.3(b) above, the Project’s construction and operational air emissions fall well below the applicable MDAQMD thresholds, and the Project would not present a significant health risk nor are any screening criteria for a health risk assessment triggered, discussed just below and in Appendix A.

Therefore, the Project would have a less-than-significant impact to sensitive receptors. Additional analysis of localized potential impacts is presented below.

Valley Fever Exposure
The Project has the potential to generate fugitive dust during construction and possibly suspend valley fever spores within that dust. Those spores have the potential to expose nearby sensitive receptors and/or onsite workers to valley fever. Even if present at the site, construction activities may not result in increased incidence of valley fever. Propagation of valley fever is dependent on climatic conditions, with the potential for growth and surface exposure highest following early seasonal rains and long dry spells. valley fever spores can be released when filaments are disturbed by earthmoving activities, although receptors must be exposed to and inhale the spores to be at increased risk of developing valley fever. Moreover, exposure to valley fever does not guarantee that an individual will become ill—approximately 60% of people exposed to the fungal spores are asymptomatic and show no signs of an infection (USGS 2000).

To reduce fugitive dust from the Project and minimize adverse air quality impacts, the Project would be required to address dust in accordance with the MDAQMD Rules 401 and 403.2, which limit the amount of fugitive dust generated during construction. Further, regulations designed to minimize exposure to valley fever hazards are included in Title 8 of the California Code of Regulations and would be complied with during the Project’s construction phase (California Department of Industrial Relations 2022). The Project would not result in a significant impact attributable to valley fever exposure based on its geographic location and compliance with applicable regulatory standards and dust mitigation measures, which will serve to 601

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minimize the release of and exposure to fungal spores. Therefore, impacts associated with valley fever exposure for sensitive receptors would be less than significant.

Health Impacts of Toxic Air Contaminants
A substance is considered toxic if it has the potential to cause adverse health effects in humans, including increasing the risk of cancer upon exposure, or acute (immediate) and/or chronic (cumulative) non-cancer health effects. A toxic substance released into the air is considered a toxic air contaminant (TAC). Adverse health effects associated with exposure to TACs may include carcinogenic (i.e., cancer-causing) and noncarcinogenic effects. Project construction would result in emissions of diesel particulate from heavy construction equipment and trucks accessing the Project site, which is characterized as a TAC by the State of California. The Office of Environmental Health Hazard Assessment (OEHHA) has identified carcinogenic and chronic noncarcinogenic effects from long-term exposure but has not identified health effects due to short-term exposure to diesel exhaust. According to OEHHA, health risk assessments, which determine the exposure of sensitive receptors to toxic emissions, should be based on a 30-year exposure period for the maximally exposed individual resident; however, such assessments should be limited to the period/duration of activities associated with the Project (OEHHA 2015). Thus, the duration of the proposed construction activities would only constitute a small percentage of the total 30-year exposure period. Due to this relatively short period of exposure (15 months), the substantial distance to the closest sensitive receptors, and minimal diesel particulate matter (DPM) emissions7 on site, TACs generated by the Project would not result in concentrations causing significant health risks. For long-term operations, the Project would emit minimal TACs associated with infrequent routine inspection and maintenance activities. Based on the preceding considerations, the Project would result in a less-than-significant health risk impact at the nearest sensitive receptors.

Health Impacts of Carbon Monoxide
Regionally, Project-related travel would add to regional trip generation and increase VMT within the local airshed and the MDAB. Locally, Project-generated traffic would be added to the roadway system near the Project site. If such traffic occurs during periods of poor atmospheric ventilation, is composed of a large number of vehicles “cold-started” and operating at pollution-inefficient speeds, and operates on roadways already crowded with non-Project traffic, there is a potential for the formation of microscale CO hotspots in the area immediately around points of congested traffic. However, because of continued improvement in vehicular emissions at a rate faster than the rate of vehicle growth and/or congestion, the potential for CO hotspots in the MDAB is steadily decreasing. The MDAQMD thresholds of significance for local CO emissions is the 1-hour and 8-hour CAAQS of 20 ppm and 9 ppm, respectively. By definition, these represent levels that are protective of public health. The MDAB is currently designated attainment for both state and national CO ambient air quality standards.

As described in Section 3.1 of Appendix A, to verify that the Project would not cause or contribute to a violation of the CO standard, a screening evaluation was conducted comparing the highest hourly traffic volumes at any studied intersection in proximity to the Project site to the 100,000 vehicles per day criterion from the SCAQMD Air Quality Management Plan (SCAQMD 2003). As described in Section 2.2.1 of Appendix A, routine/scheduled operations would require one or two workers in a light utility truck to visit the facility on a weekly basis. In addition, one major maintenance inspection would take place annually, requiring 7 Exhaust PM10 considered surrogate for DPM.
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approximately 20 personnel for approximately 1 week. In addition, it was assumed that every 2 to 3 years the site would be visited by a six-person work crew in order to add or connect additional batteries to the facility. If these activities all were to occur at the same time, the Project could result in about 54 trips on the same day, which would result in a negligible contribution to the roadway network and substantially less than the 100,000 vehicles per day screening criterion applied. Therefore, impacts associated with CO hotspots would be less than significant.

Health Impacts of Other Criteria Air Pollutants
Sensitive receptors are those individuals more susceptible to the effects of air pollution than the population at large. People most likely to be affected by air pollution include children, the elderly, and people with cardiovascular and chronic respiratory diseases. According to MDAQMD, among the population that is most negatively affected by poor air quality are children, elderly, and individuals with respiratory or cardiovascular health issues. There are several pollutants that are released into the air, and depending on the severity and chronic exposure, they could have lasting health impacts (MDAQMD 2024).

The nearest sensitive receptor to the Project is utilized in the analysis. The distance to receptors’ property boundaries proximate to the site are listed in Table 5. Because the study evaluates short-term acute impacts from a thermal runaway, all nearby receptors are considered where a person may be present for at least an hour.

Table 5. Distance to Receptors
Receptor
Receptor Distance to Closest Battery Energy
Storage System Cabinet (feet)
Copart 1,075
Southern California Edison Station 1,910
Premier Wood Products 3,320
Adelanto High School 3,635
Tikun Olam 3,930
Source: Appendix A.

A substance is considered toxic if it has the potential to cause adverse health effects in humans, including increasing the risk of cancer upon exposure, or acute (immediate) and/or chronic (cumulative) non-cancer health effects. A toxic substance released into the air is considered a toxic air contaminant (TAC). Adverse health effects associated with exposure to TACs may include carcinogenic (i.e., cancer-causing) and noncarcinogenic effects. Noncarcinogenic effects typically affect one or more target organ systems and may be experienced on either short-term (acute) or long-term (chronic) exposure to a given TAC.

TACs are identified by federal and state agencies based on a review of available scientific evidence. In the state of California, TACs are identified through a two-step process that was established in 1983 under the Toxic Air Contaminant Identification and Control Act. This two-step process of risk identification and risk management and reduction was designed to protect residents from the health effects of toxic substances in the air. In addition, the California Air Toxics “Hot Spots” Information and Assessment Act, Assembly Bill (AB) 2588, was enacted by the legislature in 1987 to address public concern over the release of TACs into the atmosphere.
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Examples include certain aromatic and chlorinated hydrocarbons, certain metals, and asbestos. TACs are generated by a number of sources, including stationary sources, such as dry cleaners, gas stations, combustion sources, and laboratories; mobile sources, such as automobiles; and area sources, such as landfills. Adverse health effects associated with exposure to TACs may include carcinogenic (i.e., cancercausing) and noncarcinogenic effects. Noncarcinogenic effects typically affect one or more target organ systems and may be experienced on either short-term (acute) or long-term (chronic) exposure to a given TAC.

Health effects associated with O3 include respiratory symptoms, worsening of lung disease leading to premature death, and damage to lung tissue (CARB 2023a). The Project would not exceed the significance thresholds for VOC or NOx; therefore, implementation of the Project would contribute minimally to regional O3 concentrations and the associated health effects.

Health effects associated with NOx and NO2 (which is a constituent of NOx) include lung irritation and enhanced allergic responses (CARB 2023b). Because the Project would not exceed the MDAQMD NOx thresholds, the Project would not contribute to significant health effects associated with NOx and NO2.

Health effects associated with CO include chest pain in patients with heart disease, headache, lightheadedness, and reduced mental alertness (CARB 2023c). CO tends to be a localized impact associated with congested intersections. The potential for CO hotspots was discussed previously and determined to be less than significant. Thus, the Project’s CO emissions would not contribute to significant health effects associated with CO.

Health effects associated with PM10 and PM2.5 include premature death and hospitalization, primarily for worsening of respiratory disease (CARB 2023d). Construction and operation of the Project would not exceed the MDAQMD threshold for PM10 or PM2.5. As such, the Project would not contribute to exceedances of the NAAQS and CAAQS for particulate matter or obstruct the MDAB from coming into attainment for these pollutants or result in associated health effects.

In summary, and as discussed above in 3.3(b), the construction and operation of the Project would not result in exceedances of the MDAQMD significance thresholds, and because the MDAQMD thresholds are based on levels that the MDAB can accommodate without affecting the attainment date for the ambient air quality standards and the ambient air quality standards are established to protect public health and welfare, the Project is not anticipated to result in health effects associated with NOX, VOCs, CO, SOx, PM10, or PM2.5. The potential health effects associated with criteria air pollutants are considered less than significant.

The Health Consequence Analysis (HCA) (Appendix B) prepared for the Project analyzes the dispersion of emissions in the event of a battery cell malfunction, such as thermal runaway. In the case of thermal runaway, a fire could occur. Lithium-ion battery system fires are generally considered Class A (plastics fires, from materials such as the separator) and Class B (flammable liquids, from materials such as the electrolyte) but may also have characteristics of Class C (electrical fires) as well. As such, the pollutants generated are not dissimilar from other common residential and commercial fires.

In the unlikely event of a battery cell malfunction, the primary emissions released would be carbon dioxide (CO2) and carbon monoxide (CO), along with lesser amounts of other compounds. The emissions also include the chemicals released by the fire suppression system (for non-water-based systems). Table 6 provides a list of chemical constituents that could be emitted from lithium-ion batteries during a thermal runaway event.
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Table 6. Chemical Constituents Emitted from Lithium-Ion Batteries During Thermal Runaway Event
Chemical Formula Chemical Name
CH4 Methane
C2H2 Acetylene
C2H4 Ethylene
C2H6 Ethane
C3H6 Propene
C3H8 Propane
C4 (Total) N/A
C5 (Total) N/A
C6 (Total) N/A
C7 (Total) N/A
CO Carbon Monoxide
CO2 Carbon Dioxide
H2 Hydrogen
C6H6 Benzene
C7H8 Toluene
C3H6O3 Dimethyl Carbonate
C4H8O3 Ethyl Methyl Carbonate
Source: Contemporary Amperex Technology Co. Ltd 2022.

Note: N/A = not available.

Based upon recent testing data for representative Project components, four of these constituents are hazardous substances that could be potentially released during an accidental event within a BESS that may have an impact on nearby receptors. The hazardous substances include benzene, carbon monoxide, propane, and toluene.

The following describes the potential air toxics, potential effects from acute inhalation exposure, Emergency Response Planning Guidelines (ERPG) values, and Acute Exposure Guideline Levels (AEGLs). The descriptions of health effects are summarized from the National Institute of Health PubChem database.

ERPGs are developed by the Emergency Response Planning committee of the American Industrial Hygiene Association (AIHA). AEGLs are developed by the National Academy of Sciences. Both the ERPGs and AEGLs have three levels, categorized by severity of impact.

The ERPG values are defined as follows:
▪ ERPG-1 is the maximum airborne concentration below which nearly all individuals could be exposed to for up to one hour without experiencing more than mild, transient adverse health effects or without perceiving a clearly defined objectionable odor. ▪ ERPG-2 is the maximum airborne concentration below which nearly all individuals could be exposed to for up to one hour without experiencing or developing irreversible or other serious health effects or symptoms which could impair an individual’s ability to take protective action. ▪ ERPG-3 is the maximum airborne concentration below which nearly all individuals could be exposed to for up to one hour without experiencing or developing life-threatening health effects. 605

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The AEGL values are defined as:
▪ AEGL-1 is the airborne concentration (expressed as parts per million (ppm) or milligrams per cubic meter (mg/m3)) of a substance above which it is predicted that the general population, including susceptible individuals, could experience notable discomfort, irritation, or certain asymptomatic non-sensory effects. However, the effects are not disabling and are transient and reversible upon cessation of exposure.
▪ AEGL-2 is the airborne concentration (expressed as ppm or mg/m3) of a substance above which it is predicted that the general population, including susceptible individuals, could experience irreversible or other serious, long-lasting adverse health effects or an impaired ability to escape. ▪ AEGL-3 is the airborne concentration (expressed as ppm or mg/m3) of a substance above which it is predicted that the general population, including susceptible individuals, could experience lifethreatening health effects or death.

The distance of toxic endpoints uses the ERPG-2 and AEGL-2 values per Environmental Protection Agency (EPA) guidance to evaluate potential risk to nearby receptors or first responders. The applicable ERPG-2 and AEGL-2 values for the pollutants in Table 2 with an acute reference exposure level are shown below in Table 7.

Table 7. Chemical Constituents ERPG and AEGL Values
Chemical Name ERPG-2 (ppm) AEGL-2 (ppm)
Benzene 150 1,100
Carbon monoxide 350 150
Propane N/A 17,000
Toluene 300 760
Sources: AIHA 2022; EPA 2018; Appendix B.

Notes: ERPG = Emergency Response Planning Guidelines; AEGL = Acute Exposure Guideline Level; ppm = parts per million; N/A = not applicable.

The distance of toxic endpoints uses the ERPG-2 and AEGL-2 values per EPA guidance to evaluate potential risk to nearby receptors or first responders. If the ERPG-2 or AEGL-2 values shown in Table 3 are exceeded at the distance closest receptors are to the Project as shown in Table 1, there would be a potentially significant impact during a thermal runaway event. Table 8 presents the results of the ALOHA modeling of the thermal runaway scenario of 1.5 modules as discussed in the methodology above.

Table 8. Battery Off-Gassing Modeling Results
Pollutant Scenario
Threat Zone
Distance (Feet)
Distance to Nearest
Receptor (Feet)
Receptor Inside
Threat Zone?
Benzene Day 33 1,075 No
Night 39 1,075 No
Santa Ana 33 3,635 No
Carbon monoxide Day 33 1,075 No
Night 81 1,075 No
Santa Ana 33 3,635 No
Propane Day 33 1,075 No
Night 36 1,075 No
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Table 8. Battery Off-Gassing Modeling Results
Pollutant Scenario
Threat Zone
Distance (Feet)
Distance to Nearest
Receptor (Feet)
Receptor Inside
Threat Zone?
Santa Ana 33 3,635 No
Toluene Day 33 1,075 No
Night 33 1,075 No
Santa Ana 33 3,635 No
Source: Appendix B.

The results of the off-site consequence analysis showed that concentrations at the ERPG-2 or AEGL-2 thresholds may extend to a toxic endpoint of up to approximately 81 feet from the toxic release. There are no receptors within that distance and none of the sensitive receptors identified would be exposed to concentrations at or above the ERPG-2 or AEGL-2 levels. Therefore, the Project would result in a less-thansignificant impact due to thermal runway of battery modules off site.

Summary
The Project’s construction and operational air emissions fall well below the applicable MDAQMD thresholds, and the Project would not present a significant health risk, nor are any screening criteria for a health risk assessment triggered, discussed, above. The proposed Project would be required to implemental all applicable MDAQMD and Title 14 CFR rules and regulations. Further, the HCA (Appendix B) concludes that an emissions release during a thermal runaway event could impact sensitive receptors within 81 feet of the battery cabinet experiencing a battery malfunction, and given that no receptors are located within 81 feet of the nearest battery cabinet given intervening roadways and applicable setbacks, the Project would have a less-than-significant impact due to thermal runaway of battery modules. Given the above, the Project is consistent with the findings disclosed in the Sustainable Plan EIR. Therefore, the Project would not result in any peculiar effects and would not result in a new or more severe adverse impact, or a potentially significant off-site or cumulative impact, that was not previously identified in the prior EIR. Further, the Project would not result in an increase to significant effects as a result of new information not previously assessed in the Sustainable Plan EIR.
d) Would the project result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
The Sustainable Plan EIR evaluated the full build out of the Plan area and potential impacts related to objectionable odors affecting a substantial number of people and determined impacts would be a potentially significant impact in this regard. Therefore, the Sustainable Plan EIR incorporates Implementing Program OS-20, which would ensure that potential odor impacts are identified during development review.

With incorporation of Implementing Program OS-20, impacts would be less than significant.

The analysis under the Sustainable Plan EIR remains accurate with respect to the proposed Project, which would develop an industrial BESS facility in accordance with the provisions of the Sustainable Plan and would occur within the Plan area previously evaluated, as well as off-site improvements within the existing Victor and Kramer Substation footprints and within the existing telecommunications line rights-of-way. 607

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As discussed in the Technical Memorandum, odors would be potentially generated from vehicles and equipment exhaust emissions during construction of the Project. Potential odors produced during construction would be attributable to concentrations of unburned hydrocarbons from tailpipes of construction equipment. Such odors would disperse rapidly from the Project site and off-site construction areas and generally occur at magnitudes that would not affect substantial numbers of people. Therefore, impacts associated with odors during construction would be less than significant.

Land uses most commonly associated with odor complaints generally include agricultural uses (livestock and farming), wastewater treatment plants, food-processing plants, chemical plants, composting operations, refineries, landfills, dairies, and fiberglass molding facilities. The Project does not include uses that would be substantive sources of objectionable odors. As such, Project operations would result in an odor impact that would be less than significant. Therefore, impacts would be less than significant, and the proposed Project would not result in any peculiar effects and would not result in a new or more severe adverse impact that was not previously identified in the prior EIR. Further, the Project would not result in an increase to significant effects as a result of new information not previously assessed in the Sustainable Plan EIR.

Conclusion
The proposed Project is consistent with the development evaluated in the Sustainable Plan EIR and would not result in any new impacts or increase the severity of any previously identified impacts as compared to what was already identified and disclosed, either individually or cumulatively. Further environmental analysis is not required because:

No peculiar impacts that are not substantially mitigated have been identified as a result of the proposed Project or its site.

There are no potentially significant impacts that were not analyzed as significant in the Sustainable Plan EIR.

There are no potentially significant off-site and/or cumulative impacts that were not discussed in the Sustainable Plan EIR.

No substantial new information has been identified that results in an impact that is more severe than anticipated by the Sustainable Plan EIR.
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3.4 Biological Resources
Significant
Project Impact
Analyzed in
the Prior EIR
Substantial New
Information
IV. BIOLOGICAL RESOURCES – Would the project:
a) Have a substantial adverse effect, either
directly or through habitat modifications, on any
species identified as a candidate, sensitive, or
special status species in local or regional plans,
policies, or regulations, or by the California
Department of Fish and Game or U.S. Fish and
Wildlife Service?
b) Have a substantial adverse effect on any
riparian habitat or other sensitive natural
community identified in local or regional plans,
policies, regulations, or by the California
Department of Fish and Game or U.S. Fish and
Wildlife Service?
c) Have a substantial adverse effect on state or
federally protected wetlands (including, but not
limited to, marsh, vernal pool, coastal, etc.)
through direct removal, filling, hydrological
interruption, or other means?
d) 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?
e) Conflict with any local policies or ordinances
protecting biological resources, such as a tree
preservation policy or ordinance?
f) Conflict with the provisions of an adopted
Habitat Conservation Plan, Natural Community
Conservation Plan, or other approved local,
regional, or state habitat conservation plan?
Prior Environmental Impact Report Summary
Biological Impacts were analyzed in the Sustainable Plan EIR on pages 4.4-1 through 4.4-30. References in this section to Plan Area are to the land area comprising the Sustainable Plan area and analyzed in the Sustainable Plan. The Project-specific discussion occurs in a subsequent section herein.

The Sustainable Plan EIR notes that the Mojave Desert is characterized by hot summer temperatures (average daily highs above 100°F) and low annual precipitation (approximately 5 inches). Daily temperature ranges of 40 degrees F can occur, with lows in the winder below or near freezing. Precipitation extremes are also common. Vegetation communities mapped within the Plan area include Mojave Creosote Bush Scrub, desert saltbush scrub, rabbitbrush scrub, Mojave wash scrub, and ruderal/developed lands. Approximately 100 wildlife species are expected to occur 609

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within or in the immediate vicinity of the Planning Area. Special-status wildlife species are those listed under federal or state Endangered Species acts, listed as Species of Special Concern by the state, protected under official conservation programs (e.g., Multi-Species Conservation Programs), and/or those designated by local legislation as requiring protection. Special-status plants are those listed under federal or state endangered species acts, protected under official conservation programs (e.g., Multi-Species Conservation Programs), and/or considered sensitive, such as those listed by the California Native Plant Society (CNPS). The CNPS utilizes a ranking system to define the status of sensitive plant species, as follows:
1A: Plants presumed extinct in California
1B: Plants that are rare, threatened, or endangered in California and elsewhere 2: Plants that are rare, threatened, or endangered in California but more common elsewhere 3: Plants about which the CNPS needs more information. This is a review list. 4: Plants of limited distribution. This is a watch list.

The California Natural Diversity Database (CNDDB) inventories occurrences of rare, threatened, endangered, and sensitive animals, plants, and natural communities in California. The CNDDB inventories both aquatic and terrestrial natural communities that are extremely high quality, very limited distribution, or threatened. The CNDDB inventory provides species occurrences within and near the Planning Area. Species occurrences and status within and near the Planning Area are summarized in Table 9 (CNDDB Species Occurrences) and illustrated in Sustainable Plan EIR Exhibit 4.4-2 (CNDDB Species Occurrences). According to the CNDDB, 25 species occur within or near the Planning Area. Additional information regarding these species is provided herein. The shoulderband and Mohave River vole have confirmed occurrences along the Mojave River corridor; however, they are not discussed in the Sustainable Plan EIR because their occurrence was not observed within the Planning Area during site surveys conducted for the Sustainable Plan EIR. The presence of prairie falcon is indicated in the northern portion of the Planning Area. The species is not discussed in the Sustainable Plan EIR because CNDDB records for prairie falcon are not location specific and are instead mapped as large polygons. In addition, the Planning Area is absent of the topographic features that are typically associated with nesting prairie falcon. Information related to species listing is provided in the Planning and Regulatory Framework section of the Sustainable Plan EIR.

Five special-status wildlife species (and/or their sign) were directly observed or have recent records within the Planning Area or in the immediate vicinity during field surveys of the Planning Area, and/or were previously recorded within the Planning Area. Thirteen special-status plant species and four wildlife species have a high probability of occurrence in the Planning Area. Table 9 provides the potential for special-status species to occur within the Plan area.

Table 9. CNDDB Species Occurrences
Common Name Scientific Name
Federal
Status State Status
CNPS/
CDFG
Status
Status in
the
Planning
Area
Plants
small-flowered
androstephium
Androstephium breviflorum None None 2.2 May Occur
Booth’s eveningprimroseCamissonia boothii ssp.
boothii
None None 2.3 May Occur
white pygmy- poppy Canbya candida None None 4.2 May Occur 610

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Table 9. CNDDB Species Occurrences
Common Name Scientific Name
Federal
Status State Status
CNPS/
CDFG
Status
Status in
the
Planning
Area
Mojave paintbrush Castilleja plagiotoma None None 4.3 May Occur Mojave spineflower Chorizanthe spinosa None None 4.2 May Occur desert cymopterus Cymopterus deserticola None None 1B.2 May Occur Barstow wooly
sunflower
Eriophyllum mohavense None None 1B.2 May Occur
sagebrush
loeflingia
Loeflingia squarrosa
var. artemisiarum
None None 2.2 May Occur
Mojave
monkeyflower
Mimulus mohavensis None None 1B.2 May Occur
crowned muilla Muilla coronate None None 4.2 May Occur
short-joint
beavertail
Opuntia basilaris var.
brachyclada
None None 1B.2 May Occur
Beaver Dam
breadroot
Pediomelum castoreum None None 1B.2 May Occur
Mojave fish- hook
cactus
Sclerocactus polyancistrus None None 4.2 May occur
Wildlife
Invertebrates
Victorville
shoulderband
Helminthoglypta
mohaveana
None None None Absent
Fish
Mohave tui chub Siphateles bicolor
mohavensis
Endangered Endangered None Absent
Amphibians
California redlegged frogRana draytonii Threatened None SSC Absent Reptiles
desert tortoise Gopherus agassizii Threatened Threatened None Present Birds
burrowing owl Athene cunicularia None None SSC Present
ferruginous hawk
(wintering)
Buteo regalis None None WL May Occur
Swainson’s
Hawk (nesting)
Buteo swainsoni None Threatened None May Occur
California horned
lark
(nesting)
Eremophila alpestris actia None None WL Present
Loggerhead shrike
(nesting)*
Lanius ludovicianus None None SSC Present
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Table 9. CNDDB Species Occurrences
Common Name Scientific Name
Federal
Status State Status
CNPS/
CDFG
Status
Status in
the
Planning
Area
Le Conte’s thrasher Toxostoma lecontei None None WL May Occur Mammals
pallid San Diego
pocket mouse
Chaetodipus fallax pallidus None None SSC May Occur
Mohave ground
squirrel
Xerospermophilus
mohavensis
None Threatened None Present
CNPS Status:
1A CNPS Priority List 1A: plant presumed extinct in California 1B CNPS Priority List 1B: plant Rate, Threatened, or Endangered in California and elsewhere; eligible for state listing. 2 CNPS Priority List 2: plant Rare, Threatened, or Endangered in California, but more common elsewhere; eligible for state listing. 3 CNPS Priority List 3: more information is needed about this species; some eligible for state listing. 4 CNPS Priority List 4: on watch list for plants of limited distribution.

The CNPS Threat Rank is an extension added onto the CNPS List and designates the level of endangerment by a 1 to 3 ranking as follows:
.1 Seriously threatened in California (high degree/immediacy of threat) .2 Fairly threatened in California (moderate degree/immediacy of threat) .3 Not very threatened in California (low degree/immediacy of threats or no current threats known) CDFG Status:

FP: Fully Protected. The species may not be taken or possessed at any time and no provision of this code or any other law shall be construed to authorize the issuance of permits of licenses to take any fully protected species.

SSC: Species of Special Concern; native species not having state or federal Threatened or Endangered Species status, but thought to warrant monitoring due to declining population numbers.

WL: Watch List. The species warrants further monitoring and review, but no actions or legal protection are given.

Source: Adelanto North 2035 Sustainable Plan EIR (City of Adelanto 2014a).

Potential impacts to special-status species and their habitat and riparian or other sensitive natural communities resulting from implementation of the Sustainable Plan, General Plan Amendment, Zone Change, and design guidelines were determined to be less than significant with adherence to the proposed Plan Implementing Program.

The Sustainable Plan and implementing actions would not conflict with other existing local policies, regulations, or standards and no impact to the Mojave River wildlife corridors or any wildlife nurseries would occur. Future development within the Plan area would be subject to the Western Mojave Plan and the Desert Renewable Energy Conservation Plan and impacts were determined to be less than significant with implementation of applicable goals, polices, and implementation measures.

Applicable Policies
General Plan
Goal BIO 1: To protect and conserve its natural, cultural and historical resources to the greatest extent possible.

Goal BIO 2: To assure adequate protection and conservation of all native vegetation and wildlife habitats within the Planning Area.

Goal BIO 3: To plan for the most energy efficient use of natural resources for activities with take place within the Planning Area.
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Goal BIO 4: To provide recreational and open space facilities to meet the needs of all segments of the community for both active and passive recreational uses.

Goal BIO 5: To provide pedestrian access to all parks and open space areas utilizing linear parkways and the natural and m an made drainage corridors that traverse the city.

Sustainable Plan
Open Space and Conservation Chapter
Goal OS 1: Natural resources including land features, viewsheds, and drainages are strategically preserved.

Policy OS 1.1: Designate open space areas to preserve natural desert landscape and habitat.

Policy OS 1.2: Preserve drainages and washes in their natural state or limit concrete-lined channels to protect the community from flooding hazards and enhance conservation.

Policy OS 1.3: Preserve views of the desert landscape and existing topography and landforms including Shadow Mountains.

Goal OS 2: Open spaces, sensitive biological resources, native habitat, and vegetation communities that support wildlife species are identified, protected, and restored.

Policy OS 2.1: Survey and map potential habitat for sensitive biological resources, including special-status plant and wildlife species and sensitive natural communities.

Policy OS 2.2: Develop a habitat conservation plan that establishes a mitigation banking program and habitat preserve aimed at protecting sensitive biological resources and native habitat area.

Policy OS 2.3: Ensure that new development and major transportation projects minimize encroachment into sensitive desert habitats, and minimize direct or indirect impact to sensitive biological resources while optimizing the potential for mitigation.

Implementing Program OS-21: Biological Assessments. The City will require biological assessments and reports for projects in known or suspected natural habitat areas prior to project approval. These reports will be used to establish significant natural habitat areas and ecologically sensitive zones in order to prevent disturbance and degradation of these areas. Recommended mitigation measures as identified in the reports will be required to be implemented as development occurs.

Implementing Program OS-22: Desert Tortoise Protection. For future development projects proposed within desert scrub habitats in the Project Area, informal consultation with the US Fish and Wildlife Service (USFWS) and CDFW shall be undertaken by the project proponent to determine the need for desert tortoise surveys. The surveys will be performed in accordance with USFWS (2010) protocols.

The project proponent shall retain a qualified biologist with demonstrated expertise with desert tortoise to monitor all construction activities and assist the project proponent in the implementation of the monitoring program. The biologist will be approved by the US Fish and Wildlife Service prior to the commencement of project activities and 613

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will be the authorized Biologist for the project. The Authorized Biologist will be present during all activities immediately adjacent to or within habitat that supports desert tortoise.

Prior to the onset of construction activities, the project proponent shall provide a workers environmental awareness program (WEAP) training regarding desert tortoise for all personnel who will be present on work areas within or adjacent to the project area. The WEAP shall cover the natural history of the species, its legal protection, repercussions for violating the legal protection, protective measures being implemented to protect the species, and a guidelines and point of contact if the species is observed on the project site.

If construction occurs within an area where desert tortoise numbers are considered high by USFWS, then work areas will be fenced in a manner that prevents equipment and vehicles from straying from the designated work area into adjacent habitat. The Authorized Biologist will assist in determining the boundaries of the area to be fenced in consultation with the USFWS and CDFW. All workers will be advised that equipment and vehicles must remain within the fenced work areas. Installation of the fencing and any necessary surveys will be directed and/or conducted by the Authorized Biologist in concurrence with the USFWS and CDFW.

If desert tortoises are found within an area that has been fenced to exclude the species, activities will cease until the Authorized Biologist moves the desert tortoises. If desert tortoises are found in a construction area where fencing was deemed unnecessary, work will cease until the Authorized Biologist moves the individual(s). Any desert tortoises found during clearance surveys or otherwise removed from work areas will be placed in nearby suitable undisturbed habitat. The Authorized Biologist will determine the best location for their release, based on the condition of the vegetation, soil, and other habitat features and the proximity to human activities. Clearance surveys shall occur on a daily basis in the work area.

Implementing Program OS-23: Swainson’s Hawks. To assure that nesting Swainson’s hawks are not disturbed by construction activities, a qualified ornithologist shall conduct pre-construction surveys within one mile of the proposed project in regions with suitable nesting habitat for Swainson’s hawks. The survey periods and schedule shall follow those described in the CDFW’s staff report.

Nest trees affected by a proposed project shall not be removed unless avoidance measures are determined to be infeasible. If a nest tree must be removed, a Management Authorization (including conditions to offset the loss of the nest tree) must be obtained from the CDFW. The Management Authorization will specify the tree removal period, generally between the first of October and the first of February. If construction or other project-related activities that may cause nest abandonment or forced fledging are necessary within the specified buffer zone, monitoring of the nest site (funded by the applicant) by a qualified biologist shall be required to determine if the nest is abandoned.

If the nest is abandoned, and if the nestlings are still alive, the applicant shall fund the recovery and hacking (controlled release of captive reared young) of the nestling(s).

Loss of foraging habitat for Swainson’s hawks shall be mitigated by providing Habitat Management (HM) land as described in the CDFW’s staff report because the site is known foraging habitat for Swainson’s hawks. The final acreage of HM lands to be provided on site shall depend on the distance between the proposed project area and the nearest active nest site, as determined by nest surveys conducted in the spring prior to project implementation. The acreage of HM lands provided shall be derived from the recommendations included in the 2010 CDFW staff report.

Implementing Program OS-24: Burrowing Owl Protection. In conformance with Federal and State regulations regarding the protection of burrowing owls, a preconstruction survey for burrowing owls, in conformance with CDFW guidelines, shall be completed no more than 30 days prior to the start of construction within suitable habitat at the 614

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project site(s) and buffer zone(s). Three additional protocol level surveys shall also be completed per CDFW guidelines prior to construction. Occupied burrows shall not be disturbed during the nesting season (February 1 through August 31) unless a qualified biologist approved by CDFW verifies through noninvasive methods that either 1) the birds have not begun egg-layering and incubation or 2) that juveniles from the occupied burrows are foraging independently and are capable of independent survival. Eviction outside the nesting season may be permitted pending evaluation of eviction plans and receipt of formal written approval from the CDFW authorizing the eviction.

A 250-foot buffer, within which no new activity will be permissible, shall be maintained between project activities and nesting burrowing owls during the nesting season. This protected area shall remain in effect until August 31, or at the CDFW’s discretion and based upon monitoring evidence, until the young owls are foraging independently.

If surveys determine that burrowing owls occupy the site and avoiding development of occupied areas is not feasible, then habitat compensation on off-site mitigation lands shall be implemented. Habitat Management lands comprising existing burrowing owl foraging and breeding habitat shall be acquired and preserved. An area of 6.5 acres (the amount of land found to be necessary to sustain a pair or individual owl) shall be secured for each pair of owls, or individual in the case of an odd number of birds. As part of an agreement with CDFW, the project proponent shall secure the performance of its mitigation duties by providing CDFW with security in the form of funds that would: 1) allow for the acquisition and/or preservation of 6.5 acres of habitat management lands per pair of owls. 2) provide initial protection and enhancement activities on the habitat management lands, potentially including, but not limited to, such measures as fencing, trash clean-up, artificial burrow creation, grazing or mowing, and any habitat restoration deemed necessary by CDFW, and 3) establish an endowment for the long-term management of the habitat management lands.

Implementing Program OS-25: Habitat Suitability. Future project applicants shall have a qualified biologist ascertain the suitability of the project site to support burrowing owl, ferruginous hawk, California horned lark, loggerhead shrike, Le Conte’s thrasher and pallid San Diego pocket mouse if the proposed project site is located in an area suitable for these fauna. If the biologist determines that the habitats are unsuitable, then no further mitigation is necessary. If one or more of these species is observed, known to occupy the site, or suitable habitat is present, avoidance and minimization measures shall be developed and implemented by the project proponent.

Implementing Program OS-26: Nest Surveys. If construction or vegetation removal activities must occur during the bird breeding season (February through mid-September) in areas identified as habitat for burrowing owl, ferruginous hawk, California horned lark, loggerhead shrike, and the Conte’s thrasher, surveys for active nests shall be conducted by a qualified biologist no more than 30 days prior to the start of construction. A minimum nodisturbance buffer of 250 feet shall be established around active nests and demarcated with fencing or flagging.

No project-related activities shall occur within the buffer zone until a qualified biologist has determined that the birds have fledged and are no long reliant on the nest or parental care for survival. The buffer distance may be reduced, depending on the sensitivity of the species and nest location, in consultation with the CDFW.

Implementing Program OS-27: Special-Status Plant Species Surveys. Future project sites located in areas where suitable habitat occurs, the applicant will have a qualified biologist conduct florist surveys of the project site for the thirteen special status plant species that have potential to occur in the Project Area. The surveys will be conducted according to CDFW protocols and shall occur throughout the blooming season for each species. If any of the species are found to occur in the proposed impact area, a report shall be prepared in accordance with the CNPS Botanical Survey Guidelines and submitted to the CDFW prior to commencement of maintenance activities. The report shall recommend measures to avoid significant impacts to populations of the species and offer mitigation to reduce any impacts to less than significant levels. Depending on the abundance of individuals within the proposed impact area, 615

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mitigation measures could include a salvage program, which would involve the transplantation and propagation of the species, or acquiring/preserving land with similar population structure.

Implementing Program OS-28: Jurisdictional Waters Delineation. Future project applicants will have a qualified biologist survey the areas to be impacted for the occurrence of hydrological features on the project site. Should hydrological features be found during the initial surveys, a formal jurisdictional waters delineation will be conducted.

The formal delineation will be used along with the proposed project plans for the particular site to determine if waters of the State or US will be impacted by project implementation. The results of the jurisdictional delineation will be submitted to the USACE for a formal determination of the jurisdictional status. If it is determined that waters of the US are present and will be impacted, then a permit will be acquired from the USACE. For most discharges that will have only minimal adverse effects, a general permit may be suitable. General permits are issued on a nationwide, regional, or State basis for particular categories of activities. The general permit process eliminates individual review and allows certain activities to proceed with little or no delay, provided that the general or specific conditions for the general permit are met.

If jurisdictional riparian resources or Waters of the State on a particular project site will be impacted by the implementation of the proposed project, then a report of water discharge will be submitted and, if deemed necessary, Waste Discharge Requirements will be obtained. A Notification of Lake or Streambed Alteration will be submitted to the CDFW and, if deemed necessary, a Lake or Streambed Alteration Agreement will be obtained.

Conditions for the certification and agreement may require off-site mitigation.

Implementing Program OS-35: Protect, Preserve, And Manage Biological Resources. As an overall effort to minimize cumulative impacts to natural resources in the Project Area from increased development proposed by the Plan, the City shall continue to work on identifying critical habitat areas, biological corridors, and ecosystems functions that must be preserved to maintain a healthy, self-sustaining environment. The City shall work with local, state, and regional agencies to protect, preserve, and manage biological resources, especially threatened, endangered, and sensitive plants and wildlife species and their habitats. Areas containing valuable habitat shall be managed accordingly for the preservation and protection of their biological and natural resources, and if not already designated as Open Space such lands shall be considered for an open space land use designation as appropriate.

Project-Specific Analysis
The analysis contained within this section is based on the Biological Resources Technical Memorandum (the Bio Study) prepared by Dudek in October 2024 (Appendix C). References in this section to the Biological Study Area (“BSA”) refer to the Project site plus a surrounding buffer of 100 feet. a) Would the project have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service? The analysis under the Sustainable Plan EIR remains accurate with respect to the proposed Project, which would develop a BESS facility in accordance with the provisions of the Sustainable Plan and would occur within the Plan area previously evaluated (with the exception of proposed off-site improvements within the existing Victor and Kramer Substation footprints and within the existing telecommunications line rights-ofway). The Sustainable Plan EIR evaluated whether the full build out of the Plan area would impact biological resources and determined that Sustainable Plan impacts would be less than significant. 616

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One listed special-status plant species (i.e., western Joshua tree) was detected outside of the proposed disturbance area for the Project, but within the BSA. Two special-status wildlife species (i.e., loggerhead shrike and desert kit fox) have a moderate potential to occur within the BSA due to presence of suitable habitat and site conditions. Additionally, two wildlife species that are listed or proposed for listing have a low potential to occur (i.e., Mojave desert tortoise, burrowing owl) have a low potential to occur within the BSA. Project implementation may result in impacts to special-status species from injury or mortality of individuals from construction activities or habitat loss. Impacts to these species, consistency with the Sustainable Plan EIR, and relevant Implementing Programs are discussed below.

No non-listed special-status plant species were observed or have a high or moderate potential to occur within the BSA; therefore, the Project would have no impacts to non-listed special-status plant species. In addition, the BSA does not occur within federally designated critical habitat for any special-status species, and there would be no impacts to critical habitat.

Western Joshua Tree
Western Joshua tree, a candidate for state listing under CESA, was observed within the BSA. Four western Joshua trees were mapped within the BSA. However, no western Joshua trees would be directly impacted (located within the disturbance footprint) or would be indirectly impacted (within a 50-foot buffer for Size Class B and C or within 25-foot buffer for Size Class A). In addition, as part of the Project design (PDF-BIO1), all western Joshua trees within 100 feet of the ground disturbance footprint would be protected in place and a 50-foot avoidance buffer will be clearly delineated in the field around each individual. Therefore, implementation of the Project would result in no impacts to western Joshua trees. Accordingly, no new impacts to special-status plant species would occur as a result of Project implementation.

Loggerhead Shrike
The BSA supports suitable loggerhead shrike foraging and nesting habitat (e.g., open desert scrub with scattered shrubs). Additionally, there are CNDDB occurrences from 2020 approximately 2.8 miles northwest of the BSA (CDFW 2024a). Therefore, loggerhead shrike has a moderate potential to occur within the BSA.

The Sustainable Plan EIR determined that potentially significant direct and indirect impacts may occur to loggerhead shrike as a result of development proposed by the Sustainable Plan. The EIR provides Implementing Programs that would reduce impacts to loggerhead shrikes that may move into the Project boundary and vicinity prior to and during construction to less than significant. Implementing Program OS25 (Habitat Suitability) would require habitat suitability assessment to determine levels of avoidance and minimization measures that would be necessary for the Project and Implementing Program OS 26 (Nest Surveys) would require pre-construction nesting bird surveys and establishment of no-disturbance buffers around active nests that may be found.

Accordingly, Implementing Programs OS-25 and OS-26 would reduce potential impacts to loggerhead shrike to less than significant. No new impacts would occur as a result of Project implementation. 617

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Desert Kit Fox
The BSA supports suitable desert kit fox habitat (e.g., creosote bush scrub with abundant rodent presence).

Desert kit fox was incidentally observed approximately 0.5 miles north of the BSA during a camera trapping study conducted as part of focused Mohave ground squirrel surveys; however, this species was not observed within the BSA. While the buffer and utility corridor provide suitable creosote bush flat habitat for this species, it is minimal and there are no existing burrows suitable for use as desert kit dens. Therefore, there is a moderate potential for desert kit fox to occupy the BSA prior to the start of construction.

This species has not been considered special status in the past as it is not listed under CESA or FESA and is not designated as a CDFW Species of Special Concern or fully protected species. However, desert kit fox has been included in this analysis as a fur-bearing mammal protected under the California Fish and Game Commission’s Mammal Hunting Regulations (Subdivision 2, Chapter 5) due to its presence in the region.

While the Sustainable Plan EIR does not specifically call out desert kit fox as a species that could be impacted, it does identify impacts that would occur to special-status species, in general, as a result of conversion of open space areas to development. Specifically, the EIR states that the “conversion of any Open Space that affects desert scrub or other habitat supporting native species may directly affect occupied habitat, cause take, or harm individual species as defined by federal and state agencies or cause indirect effect through the loss of foraging and breeding habitat. Development supported by the proposed Plan will directly and indirectly affect other plant and wildlife that would potentially result in loss of prey, species diversity, or other resources that resident or migratory species may use.” The EIR also provides Implementing Programs that would reduce impacts to desert kit foxes that may move into the Project boundary and vicinity prior to and during construction to less than significant. Implementing Program OS 24 (Burrowing Owl Protection) would require burrow-focused pre-construction surveys that would identify any potentially occupied desert kit fox dens present within the Project impact area and Implementing Program OS-25 (Habitat Suitability) would require the Project to develop and implement avoidance and minimization measures for special-status species such as desert kit fox.

Accordingly, Implementing Programs OS-24 and OS-25 would reduce potential impacts to desert kit fox to less than significant. No new impacts would occur as a result of Project implementation.

Burrowing Owl
CDFW protocol surveys conducted in 2024 were negative and resulted in no observations of burrowing owl individuals, diagnostic sign (i.e., feathers, pellets), or suitable burrows within the BSA. However, burrowing owl is a mobile species that could enter the BSA in future years due to presence of suitable habitat and nearby occurrences. Therefore, this species is considered to have a low potential to occur within the BSA.

The Sustainable Plan EIR determined that potentially significant direct and indirect impacts may occur to burrowing owl as a result of development proposed by the Sustainable Plan. The EIR provides Implementing Programs that would reduce impacts to burrowing owls that may migrate into the Project boundary and vicinity prior to and during construction to less than significant. Implementing Program OS-24 (Burrowing Owl Protection) would require pre-construction surveys, occupied burrow avoidance, and habitat compensation if occupied areas are unavoidable; Implementing Program OS-25 (Habitat Suitability) would require habitat suitability assessment to determine levels of avoidance and minimization measures that 618

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would be necessary for the Project; and Implementing Program OS 26 (Nest Surveys) would require nesting bird surveys to further ensure avoidance of breeding burrowing owls.

Accordingly, Implementing Programs OS-24, OS-25, and OS-26 of the Sustainable Plan would reduce potential impacts to burrowing owl to less than significant. The Project would not result in any peculiar effects and would not result in a new or more severe adverse impact, or a potentially significant off-site or cumulative impact, that was not previously identified in the prior EIR. Further, the Project would not result in an increase to significant effects as a result of new information not previously assessed in the Sustainable Plan EIR.

Mojave Desert Tortoise
CDFW protocol surveys in 2024 were negative and resulted in no observations of individual desert tortoises, active desert tortoise burrows, or other desert tortoise sign (e.g., scat, drink basins, footprints, tortoise remains) within the BSA. However, Mojave desert tortoise is a mobile species that could enter the BSA in future years due to presence of suitable habitat and nearby occurrences. Therefore, this species is considered to have a low potential to occur within the BSA.

The Sustainable Plan EIR determined that potentially significant direct and indirect impacts may occur to Mojave desert tortoise as a result of foreseeable development consistent with zoning under the Sustainable Plan. The EIR provides Implementing Programs that would reduce impacts to desert tortoises that may migrate into the Project boundary and vicinity prior to and during construction to less than significant.

Implementing Program OS-22 (Desert Tortoise Protection) would require informal consultation with USFWS and CDFW, biological monitoring by an USFWS-authorized biologist, a workers environmental awareness program training regarding desert tortoise for all personnel who will be present in or adjacent to work areas, installation of desert tortoise fencing in consultation with USFWS and CDFW, and relocation instructions if desert tortoise is found during construction.

Accordingly, Implementing Program OS-22 would reduce potential impacts to Mojave desert tortoise to less than significant. No new impacts would occur as a result of Project implementation.

Nesting Birds and Raptors
The BSA contains shrubs and herbaceous vegetation suitable for bird species to nest on site. During 2024 surveys an active western meadowlark nest was detected by Dudek biologists. Native nesting bird species with potential to occur within the BSA are protected by California Fish and Game Code Sections 3503 and 3503.5, and by the federal MBTA (16 USC 703–711).

The Sustainable Plan EIR determined that potentially significant impacts may occur to active bird nests and nestlings covered under the MBTA and California Fish and Game Code as a result of development proposed by the Sustainable Plan. The EIR provides an Implementing Program that would reduce impacts to nesting birds that may nest within the Project boundary and vicinity prior to and during construction to less than significant. Implementing Program OS-26 would require pre-construction nesting bird surveys and establishment of no-disturbance buffers around active nests that may be found. The MBTA is a uniformly applied development policy, and the Project would be consistent with it and all other applicable laws. 619

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Accordingly, Implementing Program OS-26 would reduce potential impacts to nesting birds to less than significant. No new impacts would occur as a result of Project implementation.

Summary
The proposed Project would result in no new impacts that were either not previously considered in the Sustainable Plan EIR or will not be mitigated through implementation of uniformly applied standards, while Implementing Programs OS-25 and OS-26 would reduce potential impacts to loggerhead shrike to less than significant; Implementing Programs OS-24 and OS-25 would reduce potential impacts to desert kit fox to less than significant; Implementing Programs OS-24, OS-25, and OS-26 would reduce potential impacts to burrowing owl to less than significant; Implementing Program OS-22 would reduce potential impacts to Mojave desert tortoise to less than significant; and Implementing Program OS-26 would reduce potential impacts to nesting birds to less than significant. The proposed Project would be consistent with the Manufacturing/Industrial development designated in the Sustainable Plan and analyzed in the Sustainable Plan EIR.

All off-site improvements would occur within the existing footprints for the Victor and Kramer Substations or within the existing transmission lines rights-of-way. The substations are entirely developed and have no potential for sensitive plant or wildlife species to occur. Any trees or shrubs suitable for bird species to nest located within the transmission lines rights-of-way would be maintained and protected to the extent feasible. Thus, the proposed off-site activity has no potential to adversely affect, either directly or through habitat modifications, any species identified as a candidate, sensitive, or special-status species in local or regional plans, policies, or regulations, or by the CDFW or U.S. Fish and Wildlife Service.

As such, impacts associated with the development of the proposed Project within the Sustainable Plan area would be consistent with the analysis in the Plan EIR and would result in less-than-significant impacts. The proposed Project would comply with uniformly applied development policies such as CESA and MBTA and all applicable law, would not result in any peculiar effects, and would not result in a new or more severe adverse impact that was not previously identified in the Sustainable Plan EIR. Further, the Project would not result in an increase to significant effects as a result of new information not previously assessed in the Sustainable Plan EIR.
b) Would the project have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service?
A total of 31.28 acres would be impacted by the Project within the BSA (Appendix C). These impacts are comprised of the 31.13 acres within the battery energy storage system and substation disturbance footprint and 0.14 acres within the transmission line loop-in pole installation and work areas. The BSA does not contain any riparian habitat or vegetation communities considered a sensitive biological resource by CDFW under CEQA. All off-site improvements would occur within existing fully developed substation footprints or within the existing disturbed transmission lines rights-of-way. The proposed off-site improvements would not impact any riparian habitat or other sensitive natural community. Therefore, Project implementation would have no impact on sensitive vegetation communities.

The analysis under the Sustainable Plan EIR remains accurate with respect to the proposed Project, which would develop a BESS facility consistent with existing zoning and in accordance with the provisions of the 620

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Sustainable Plan and would occur within the Plan area previously evaluated. The Sustainable Plan EIR evaluated whether the full build out of the Plan area would impact biological resources and determined that Sustainable Plan impacts would be less than significant.

As such, impacts associated with the development of the proposed Project within the Sustainable Plan area would be consistent with the analysis in the Plan EIR and would result in less-than-significant impacts. The proposed Project would not result in any peculiar effects and would not result in a new or more severe adverse impact that was not previously identified in the prior EIR. Further, the Project would not result in an increase to significant effects as a result of new information not previously assessed in the Sustainable Plan EIR.
c) Would the project have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?
The BSA supports two ephemeral drainages consisting of 0.18 acres of non-wetland waters of the state under RWQCB, and 0.21 acres of jurisdictional streambed under CDFW. These drainages are presumed to be non-jurisdictional by USACE because they do not meet the relatively permanent standard as waters of the United States. No areas within the review area supported hydrophytic vegetation, and therefore features within the BSA were considered non-wetland waters of the state.

The Project would not result in direct impacts to waters or wetlands under USACE, RWQCB, or CDFW jurisdiction (see Appendix C). However, the Project could indirectly impact the two ephemeral drainages present in the BSA and vicinity.

The Sustainable Plan EIR determined that potentially significant direct and indirect impacts may occur to ephemeral desert washes present in the plan area as a result of development proposed by the Sustainable Plan. The EIR provides Implementing Programs that would reduce indirect impacts to ephemeral drainages in the BSA to less than significant. Implementing Program OS-28 (Jurisdictional Waters Delineation) would require that the results of the jurisdictional delineation be submitted to the USACE for a formal jurisdictional determination. The Implementing Program also requires the appropriate permitting from USACE, RWQCB or CDFW if it is determined that waters of the United States, waters of the state, or CDFW streambeds are present and will be impacted. In addition, Implementing Program PF-7 (Water Quality Management) requires the preparation and implementation of a stormwater pollution prevention plan, implementation of BMPs, and monitoring of stormwater discharges.

Accordingly, Implementing Programs OS-28 and PF-7 would reduce potential impacts to state and federally protected wetlands and waters to less than significant. All off-site improvements would occur within the existing footprints of the fully developed Victor and Kramer Substations or within the existing transmission lines rights-of-way. These improvements would not have a substantial adverse effect on any state or federally protected wetlands. As such, no new impacts would occur as a result of Project implementation.

The analysis under the Sustainable Plan EIR remains accurate with respect to the proposed Project, which would develop a BESS facility consistent with zoning and in accordance with the provisions of the Sustainable Plan. The Sustainable Plan EIR evaluated whether the full build out of the Plan area would impact biological resources and determined that Sustainable Plan impacts would be less than significant with implementation of Implementing Programs as discussed above. 621

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As such, impacts associated with the development of the proposed Project within the Sustainable Plan area would be consistent with the analysis in the Plan EIR and would result in less-than-significant impacts. The proposed Project would not result in any peculiar effects and would not result in a new or more severe adverse impact that was not previously identified in the prior EIR. Further, the Project would not result in an increase to significant effects as a result of new information not previously assessed in the Sustainable Plan EIR.
d) Would the project 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?
Existing nearby habitat linkages and wildlife corridor functions would remain intact while construction activities are conducted and following Project completion. Nearby corridors and habitat linkages that could support wildlife movement in the region, such as the Mojave River, which is approximately 6.2 miles northeast of the BSA, and the Fremont Wash, which is 2.6 miles west of the BSA, respectively would not be impacted by the Project. The southeastern corner of the BSA is within the structural connectivity linkage for small species in the West Mojave (Gallo et al. 2019); however, protocol surveys for the two focal small wildlife species (i.e., Mohave ground squirrel and Mojave desert tortoise) were negative. Additionally, the modeling indicates the small portion of the BSA within this linkage ranks as having low structural connectivity (Conservation Biology Institute 2019). The Project site does not contain nursery sites, such as bat colony roosting sites or colonial bird nesting areas. All off-site improvements would occur within the fully developed Kramer and Victor Substations or within the existing transmission lines rights-of-way. Any trees or shrubs suitable for native or migratory species to nest or roost in located within the transmissions lines rights-of-way would be maintained and protected to the extent feasible. Therefore, Project implementation would have no impact on wildlife movement, native resident or migratory wildlife corridors, or native wildlife nursery sites.

The analysis under the Sustainable Plan EIR remains accurate with respect to the proposed Project, which would develop a BESS facility consistent with zoning and in accordance with the provisions of the Sustainable Plan. The Sustainable Plan EIR evaluated whether the full build out of the Plan area would impact biological resources and determined that Sustainable Plan impacts would not occur with implementation of Implementing Programs as discussed above.

As such, impacts associated with the development of the proposed Project within the Sustainable Plan area would be consistent with the analysis in the Plan EIR. The proposed Project would not result in any peculiar effects and would not result in a new or more severe adverse impact that was not previously identified in the Sustainable Plan EIR. Further, the Project would not result in an increase to significant effects as a result of new information not previously assessed in the Sustainable Plan EIR. e) Would the project conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
Applicable local ordinances protecting biological resources within the BSA include the San Bernardino Countywide Plan, San Bernardino County Development Code, City of Adelanto General Plan, City of Adelanto Municipal Code, City of Victorville General Plan, City of Victorville Municipal Code, and the locally enforced California Desert Native Plants Act. Biological resources protected under these ordinances and policies are present within the BSA. As such, these local policies and ordinances are discussed below. 622

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San Bernardino Countywide Plan
Off-site improvements within the SCE Kramer Substation and transmission lines rights-of-way would be located in the unincorporated area of the County. The Kramer Substation is fully developed and is zoned/designated for commercial use (which conditionally permits utility facilities such as substations) (County of San Bernadino 2020a, 2024a). Other improvements would be limited to the existing transmission lines rights-of-way, which would not conflict with any applicable policies set forth in the Countywide Plan’s Natural Resources Element. Therefore, the Project would not conflict with the Countywide Plan.

San Bernardino County Development Code
The San Bernardino County Development Code Chapter 88.01.060, Desert Native Plant Protection, ensures coordination with California Desert Native Plants Act and requires the issuance of a Tree or Plant Removal Permit in compliance with Section 88.01.050 for specified desert tree species. The code also emphasizes compliance with the California Desert Native Plants Act for all plants regulated under the act, including those not explicitly stated in the Development Code Chapter 88.01.060.

No direct or indirect impacts would occur to western Joshua trees within unincorporated areas of the County. Therefore, the Project would not conflict with the San Bernardino County Development Code.

City of Adelanto General Plan
The City of Adelanto General Plan Land Use and Zoning Map shows that the Project site is planned for manufacturing/industrial use (City of Adelanto 2023). The Project would not conflict with the City of Adelanto General Plan.

City of Adelanto Municipal Code
The City of Adelanto Municipal Code requires development projects to comply with the County of San Bernardino for the relocation of western Joshua trees. The San Bernardino County Development Code Chapter 83.10.080, Regional Landscaping Standards, requires western Joshua trees present on site and proposed for relocation to be relocated on site in the landscaped areas, unless the Director of the Land Use Services Department specifically allows another option in writing.

The BSA contains western Joshua trees protected under the San Bernardino County Development Code.

However, no direct or indirect impacts would occur to western Joshua trees. Therefore, the Project would not conflict with the City of Adelanto Municipal Code.

City of Victorville General Plan
Off-site improvements within the SCE Victor Substation and existing transmission lines rights-of-way would be located in the City of Victorville. The City of Victorville Zoning Checker shows that the substation site is planned for light industrial use (City of Victorville 2024b). Therefore, the Project would not conflict with the City of Victorville General Plan.
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City of Victorville Municipal Code
City of Victorville Municipal Code Chapter 13.33, Preservation and Removal of Joshua Trees, states that is unlawful for any person to cut, damage, destroy, dig up, or harvest any Joshua tree without the prior written consent of the director of parks and recreation or his designee (City of Victorville 2024a). Although the BSA contains western Joshua trees, all off-site improvements in the City of Victorville would occur within the existing Victor Substation footprint or within the existing transmission line rights-of-way where no direct or indirect impacts would be anticipated to occur to western Joshua trees. Therefore, the Project would not conflict with the City of Victorville Municipal Code.

California Desert Native Plants Act
The BSA contains western Joshua trees protected under the California Desert Native Plants Act. However, no direct or indirect impacts would occur to western Joshua trees. No other desert native plant species were observed within the BSA during the focused desert native plant survey. Therefore, the Project would not conflict with the California Desert Native Plants Act.

Summary
The proposed Project would not conflict with any of the applicable plans listed above. The analysis under the Sustainable Plan EIR remains accurate with respect to the proposed Project, which would develop an BESS facility consistent with zoning and in accordance with the provisions of the Sustainable Plan and would occur within the Plan area previously evaluated. The Sustainable Plan EIR evaluated whether the full build out of the Plan area would impact biological resources and determined that significant impacts would not occur.

As such, impacts associated with the development of the proposed Project within the Sustainable Plan area would be consistent with the analysis in the Plan EIR. Furthermore, all off-site improvements would occur within the existing Victor and Kramer Substation footprints or within the existing transmission lines rightsof-way and would not conflict with any of the applicable plans listed above and no impact would occur. The proposed Project would not result in any peculiar effects and would not result in a new or more severe adverse impact that was not previously identified in the Sustainable Plan EIR. Further, the Project would not result in an increase to significant effects as a result of new information not previously assessed in the Sustainable Plan EIR.
f) Would the project conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan? The Project is not located within any formally adopted Natural Community Conservation Plan/Habitat Conservation Plan (CDFW 2024b). However, the Project does occur within the Draft West Mojave Plan area (BLM 2005) and the DRECP area (BLM 2016). The West Mojave Plan and DRECP are amendments to the BLM California Desert Conservation Area Plan (BLM 1980).

The Project is not located within BLM-managed lands that are subject to the West Mojave Plan. Additionally, the Project would not conflict with the conservation criteria associated with the California Desert Conservation Area Plan or DRECP. All off-site improvements would occur within the existing Victor and 624

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Kramer Substation footprints or within the existing transmission lines rights-of-way. Therefore, impacts to biological resources associated with habitat conservation plans would be less than significant.

The analysis under the Sustainable Plan EIR remains accurate with respect to the proposed Project, which would develop a BESS facility consistent with zoning and in accordance with the provisions of the Sustainable Plan and would occur within the Plan area previously evaluated. The Sustainable Plan EIR evaluated whether the full build out of the Plan area would impact biological resources and determined that Sustainable Plan impacts would be less than significant with Implementing Programs.

As such, impacts associated with the development of the proposed Project within the Sustainable Plan area would be consistent with the analysis in the Plan EIR and would result in less-than-significant impacts. The proposed Project would not result in any peculiar effects and would not result in a new or more severe adverse impact that was not previously identified in the Sustainable Plan EIR. Further, the Project would not result in an increase to significant effects as a result of new information not previously assessed in the Sustainable Plan EIR.

Conclusion
The proposed Project is consistent with the development evaluated in the Sustainable Plan EIR and would not result in any new impacts or increase the severity of any previously identified impacts as compared to what was already identified and disclosed, either individually or cumulatively in the prior EIR. Further environmental analysis is not required because:

No peculiar impacts that are not substantially mitigated have been identified as a result of the proposed Project or its site.

There are no potentially significant impacts that were not analyzed as significant in the Sustainable Plan EIR.

There are no potentially significant off-site and/or cumulative impacts that were not discussed in the Sustainable Plan EIR.

No substantial new information has been identified that results in an impact that is more severe than anticipated by the in the Sustainable Plan EIR.
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3.5 Cultural and Paleontological Resources

Significant
Project Impact
Analyzed in
the Prior EIR
Substantial New
Information
V. CULTURAL AND PALEONTOLOGICAL RESOURCES – Would the project:
a) Cause a substantial adverse change in the
significance of a historical resource pursuant
to §15064.5?
b) Cause a substantial adverse change in the
significance of an archaeological resource
pursuant to §15064.5?
c) Directly or indirectly destroys a unique
paleontological resource or site or unique
geologic feature?
d) Disturb any human remains, including those
interred outside of formal cemeteries?
Prior Environmental Impact Report Summary
Potential impacts to cultural and paleontological resources were analyzed in the Sustainable Plan EIR on pages

4.5-1 through 4.5-22.

Future development within the Sustainable Plan Project area subject to the goals and policies of the Comprehensive Sustainable Plan could impact historic resources where new development supplants older development. Adverse modification of historic resources may also occur if appropriate restoration methods are not implemented, thereby permanently altering the historic character of the resource. Records indicate there is one property in the Sustainable Plan Planning Area that has been determined eligible for the NRHP and is therefore considered a historical resource under CEQA. The Edison Company Kramer-Victory Transmission Line (P-36-010316) is a linear feature that runs adjacent to US 395. The records search further identified two historic-era residences in the town center area that have been recorded but not evaluated for historic significance. US 395 (P-36-007545) was also found ineligible for the NRHP but was not evaluated for state or local significance. A review of historic USGS topographic maps identified areas in the Planning Area with potential for historic-era Buildings, Structures, and Objects (BSOs). Although more recent modern development has occurred in outlying areas to the west and south, the early development of Adelanto occurred primarily in the town center area, and following the establishment of George Air Force Base, expanded westward across US 395. Additional early development occurred less frequently in the areas outside of the town center, connected by a series of roads. These areas have not been comprehensively surveyed and buildings or structures of historic age that may qualify as historical resources pursuant to CEQA may also exist.

With regard to paleontological resources, the Sustainable Plan EIR found that there is potential for the disturbance of paleontological resources with future development in the northwestern portion of the Planning Area near the Shadow Mountains and along the Fremont Wash. Excavation and other earthmoving activities required for future development pursuant to Plan policy within surface and subsurface exposures of Pleistocene era alluvium materials could disturb paleontological resources. Failure to survey development sites and if necessary, monitor earthmoving activities to ensure proper identification and recovery of paleontological resources could result in a significant impact to fossil resources due to the loss of information important to understanding pre-historic life and evolution. The Project site is not located within a high or moderately high sensitivity area according to Sustainable Plan Exhibit 4.5-1, Prehistoric Sensitivity. 626

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Potential impacts to historical resources, archaeological resources, paleontological resources, and the disturbance of human remains resulting from implementation of the Sustainable Plan were determined to be less than significant with adherence to the Plan Implementing Program. The Sustainable Plan and implementing actions would not conflict with other existing local policies, regulations, or standards, and impacts were determined to be less than significant with the incorporation of Sustainable Plan Implementing Programs and existing policies, regulations and uniformly applied standards.

Applicable Policies
General Plan
Goal CUL 1: To preserve any known or undiscovered archaeological sites and/or artifacts which may be present within the Planning Area.

Policy CUL 1.3: The city will place developers responsible for the destruction of historic and archaeologically significant resources on file with the County of San Bernardino and the State of California, Office of Historic Preservation.

Policy CUL 1.4: The city will require that all archeological resources, historic or prehistoric be evaluated in accordance with CEQA regulations and appropriate California guidelines prior to the adoption of mitigation measures and the acceptance of conditions of approval and required permit approvals.

Goal CUL 2: To assure that proposed development policies will not eliminate any significant archaeologic or historic resources.

Goal CUL 3: To provide a mechanism for the identification and preservation of archaeologic or historic resources within the Planning Area.

Long Term Strategy CUL 1.2.1: The city will coordinate efforts with the Adelanto School District and the San Bernardino County Public Library in providing new library facilities within the Planning Area.

Long Term Strategy CUL 1.2.2: As part of the city’s land development review process and project environmental assessment, city staff will review proposed developments for sites that may have potential archaeological significance. If determined necessary by the city, an archeological survey will be performed by a licensed archaeologist and appropriate site-specific mitigation measures shall be implemented, including possible extraction and cataloging of significant resources.

Sustainable Plan
Open Space and Conservation Chapter
Goal OS 10: Cultural and historical resources are protected and preserved.

Policy OS 10.1: Identify, protect, and minimize impacts to archaeological and paleontological resources.

Policy OS 10.2: Review proposed development for the possibility of cultural resources and for compliance with the cultural resources program.
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Implementing Program OS-8: Historical Resources Assessment. Prior to any construction activities that may affect historical resources, a historical resources assessment shall be performed by an architectural historian or historian who meets the PQS in architectural history or history. This shall include a records search at the SBAIC to determine if any resources that may be potentially affected by the project have been previously recorded, evaluated, and/or designated in the NRHP or CRHR. Following the records search, the qualified architectural historian or historian shall conduct a reconnaissance-level and/or intensive-level survey in accordance with the California Office of Historic Preservation guidelines to identify any previously unrecorded potential historical resources that may be potentially affected by the proposed project. Resources shall be evaluated pursuant to CEQA Guidelines and Public Resources Code Section 21083.2.

Implementing Program OS-9: Alteration to Historical Resource. To ensure that projects requiring the relocation, rehabilitation, or alteration of a historical resource not impair its significance, the Secretary of the Interior’s Standards for the Treatment of Historic Properties shall be used to the maximum extent possible. The application of the standards shall be overseen by a qualified architectural historian or historic architect meeting the PQS. Prior to any construction activities that may affect the historical resource, a report identifying and specifying the treatment of character-defining features and construction activities shall be provided to the City of Adelanto.

Implementing Program OS-10: Historical Resource Demolition. If a proposed project would result in the demolition or significant alteration of a historical resource, it cannot be mitigated to a less than significant level.

However, recordation of the resource prior to construction activities will assist in reducing adverse impacts to the resource to the greatest extent possible. Recordation shall take the form of Historic American Building Survey (HABS), Historic American Engineering Record (HAER), or Historic American Landscape Survey (HALS) documentation, and shall be performed by an architectural historian or historian who meets the PQS.

Documentation shall include an architectural and historical narrative; medium- or large format black and white photographs, negatives, and prints; and supplementary information such as building plans and elevations, and/or historic photographs. Documentation shall be reproduced on archival paper and curated with a qualified scientific or educational repository, as defined by the Guidelines for the Curation of Archaeological Collections. The specific scope and details of documentation are determined for each project.

Implementing Program OS-11: Archaeological Sensitivity. To determine the archaeological sensitivity of a proposed planning area, archaeological resources assessments shall be performed under the supervision of an archaeologist that meets the Secretary of the Interior’s Professional Qualifications Standards (PQS) in either prehistoric or historic archaeology. Assessments shall include a CHRIS records search at the SBAIC and of the Sacred Lands File maintained by the NAHC. The records searches will determine if the proposed planning area has been previously surveyed for archaeological resources, identify and characterize the results of previous cultural resource surveys, and disclose any cultural resources that have been recorded and/or evaluated. A pedestrian survey shall be undertaken in undeveloped areas of the planning area to locate any surface cultural materials. By performing a records search, consultation with the NAHC, and a pedestrian survey, a qualified archaeologist will classify the planning area as having High, Medium, or Low sensitivity for archaeological resources.

Implementing Program OS-12: Archaeological Significance Evaluation. If potentially significant archaeological resources are identified through an archaeological resource assessment, and impacts to these resources cannot be avoided, an Archaeological Significance Evaluation investigation shall be performed by an archaeologist who meets the PQS prior to any construction-related ground-disturbing activities to determine significance under CEQA and/or Section 106 of the NHPA. If resources are determined to be significant or unique through significance evaluation, and site avoidance is not possible, appropriate site-specific mitigation measures shall be established and undertaken. This might include an archaeological data recovery program that would be implemented by a 628

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qualified archaeologist and performed in accordance with the Office of Historic Preservation’s Archaeological Resource Management Reports (ARMR).

Implementing Program OS-13: Disturbances of Archaeological Resources. If the archaeological assessment did not identify potentially significant archaeological resources in the proposed planning area, but indicates the area to be of medium or high sensitivity for archaeological resources, an archaeologist who meets the PQS shall be retained on an on-call basis. The archaeologist shall inform all construction personnel prior to construction activities about the proper procedures in the event of an archaeological discovery. The training shall be held in conjunction with the project’s initial on-site safety meeting and shall explain the importance and legal basis for the protection of significant archaeological resources. In the event that archaeological resources (artifacts or features) area exposed during ground disturbing activities, construction activities within a 50-foot radius of the discovery shall be halted while the on-call archaeologist is contacted. If the resource is determined to be significant or unique through significance evaluation, and site avoidance is not possible, appropriate site-specific mitigation measures shall be established and undertaken.

These might include an archaeological data recovery program that would be implemented by a qualified archaeologist and performed in accordance with the Office of Historic Preservation’s Archaeological Resource Management Reports (ARMR). If the discovery proves to be significant, it shall be curated with a qualified scientific of educational repository, as defined by the Guidelines for the Curation of Archaeological Collections.

Implementing Program OS-14: Paleontological Resources. Future development proposals subject to environmental review pursuant to the California Environmental Quality Act (CEQA) are subject to the following provisions at the expense of the project proponent, as directed by the Development Services Director.

Paleontological Assessment. In areas containing middle to late Pleistocene era sediments (Qof) where it is unknown if paleontological resources exist, prior to grading an assessment shall be made by a qualified paleontological professional to establish the need for paleontologic monitoring. Should paleontological monitoring be required after recommendation by the professional paleontologist and approval by the Development Services Director, paleontological monitoring shall be implemented.

Paleontological Monitoring. A project that requires grading plans and is located in an area of known fossil occurrence or that has been demonstrated to have fossils present in a paleontological field survey or other appropriate assessment shall have all grading monitored by trained paleontologic crews working under the direction of a qualified professional, so that fossils exposed during grading can be recovered and preserved. Paleontologic monitors shall be equipped to salvage fossils as they are unearthed, to avoid construction delays, and to remove samples of sediments that are likely to contain the remains of small fossil invertebrates and vertebrates. Monitors shall be empowered to temporarily halt or divert equipment to allow removal of abundant or large specimens.

Monitoring is not necessary if the potentially fossiliferous units described for the property in question are not present or if present are determined upon exposure and examination by qualified paleontologic personnel to have low potential to contain fossil resources. Should significant paleontological resources be discovered, paleontological recovery, identification, and curation shall be implemented.

Paleontological Recovery, Identification, and Curation. Qualified paleontologic personnel shall prepare recovered specimens to a point of identification and permanent preservation, including washing of sediments to recover small invertebrates and vertebrates. Qualified paleontologic personnel shall identify and curate specimens into the collections of the Division of Geological Sciences, San Bernardino County Museum or a similar established, accredited museum repository with permanent retrievable paleontologic storage. The paleontologist must have a written repository agreement in hand prior to the initiation of mitigation activities. This measure is not considered complete until curation into an established museum repository has been fully completed and documented. 629

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Paleontological Findings. Qualified paleontologic personnel shall prepare a report of findings with an appendix of itemized specimens subsequent to implementation of paleontological recovery, identification, and curation. A preliminary report shall be submitted to and approved by the Development Services Director before granting of building permits, and a final report shall be submitted to and approved by the Development Services Director before granting of occupancy permits.

Project-Specific Analysis
a) Would the project cause a substantial adverse change in the significance of a historical resource pursuant to §15064.5?
The Sustainable Plan EIR determined that full buildout of the Plan area could impact historical resources pursuant to Section 15064.5. However, the Sustainable Plan EIR determined that incorporation of Sustainable Plan Implementing Programs and existing policies, regulation, and uniformly applied standards would reduce any potential impacts to a less-than-significant level. In addition to the requirement to comply with state and local policies and regulations, Implementing Programs OS-8, OS-9, and OS-10 will ensure that historical resources are protected by requiring that a records search be performed prior to construction activities and that any impacts are mitigated to a less-than-significant level (City of Adelanto 2014b).

The analysis under the Sustainable Plan EIR remains accurate with respect to the proposed Project, which would develop an BESS facility consistent with zoning and in accordance with the provisions of the Sustainable Plan and would occur within the Plan area previously evaluated.

Additional evaluation of historical resources within the Project area have been conducted by Dudek specialists in the Cultural Resources Inventory Report, attached as Appendix D, which determines there is a low potential for the inadvertent discovery of cultural resources during Project implementation. Record search results from the California Historical Resources Information System (CHRIS) Central California Information Center for the Project site and a 1-mile record search buffer indicate that no resources are recorded within the Project site (Appendix D). The Cultural Resources Inventory Report found seven previously recorded resources outside the Project site, within the record search buffer, including numerous pre-historic and historic resources located within 1 mile of the Project site, but none of these resources would be impacted by the Project. The majority of these resources are historic refuse scatters associated with the historic development of Adelanto over the twentieth century. All off-site improvements would occur within previously disturbed or developed areas, such as the existing footprints of the Victor and Kramer Substations or within the existing transmission line rights-of way. The Project would not result in any off-site impacts to historical resources (Appendix D).

On June 6, 2024, Dudek archaeologists conducted an intensive pedestrian survey of the Project site where no pre-historic or historic-era resources were identified (Appendix D). All survey work was conducted employing standard archaeological procedures and techniques consistent with the Secretary of the Interior Standards. Fifteen-meter interval survey transects were conducted where plausible for the Project area.

The ground surface was examined for prehistoric artifacts (e.g., flaked stone tools, tool-making debris, stone milling tools, ceramics, fire-affected rock), soil discoloration that might indicate the presence of a cultural midden, soil depressions, features indicative of the current or former presence of structures or buildings (e.g., standing exterior walls, post holes, foundations), and historic artifacts (e.g., metal, glass, ceramics, building materials). Ground disturbances such as burrows, cut banks, and drainages were also visually inspected for exposed subsurface materials. In addition, a review of historic topographic maps and 630

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aerial imagery indicate the Project area has not been disturbed by past development; however, contemporary impacts appear to include disking and mowing, creating superficial disturbance.

Dudek contacted the NAHC on April 25, 2024, and requested a review of their Sacred Lands File (SLF) for the proposed Project area and a 1-mile radius of the Project area. The NAHC SLF search results provided on May 13, 2024, were negative for Native American resources within 1 mile of the Project area (Appendix D). However, in the event that Native American resources or other historical resources are inadvertency discovered or found to be encompassed within the Project’s off-site construction areas, work would stop, and the applicable jurisdiction would be notified to determine next steps per applicable municipal code requirements (City of Victorville 2024a; County of San Bernadino 2024a) and state law.

As such, impacts associated with the development of the proposed Project within the Sustainable Plan area would be consistent with the analysis in the Plan EIR and would result in less-than-significant impacts with the incorporation of Sustainable Plan Implementing Programs and existing policies and regulations. The proposed Project would not result in any peculiar effects and would not result in a new or more severe adverse impact that was not previously identified in the prior EIR. Further, the Project would not result in an increase to significant effects as a result of new information not previously assessed in the Sustainable Plan EIR.
b) Would the project cause a substantial adverse change in the significance of an archaeological resource pursuant to §15064.5?
The Sustainable Plan EIR determined that full buildout of the Plan area could cause a substantial adverse change in the significance of an archaeological resource pursuant to Section 15064.5 during excavation and other earthmoving activities if there is a failure to properly survey development sites and, if necessary, monitor earthmoving activities to ensure proper identification and recovery of archaeological resources.

However, the Plan EIR determined that incorporation of Sustainable Plan Implementing Programs and existing policies and regulations would reduce impacts to a less-than-significant level. In addition to the requirement to comply with state and local policies and regulations, Implementing Programs OS-11, OS-12, and OS-13 which will assist in the avoidance and mitigation of impacts to archaeological resources by requiring surveys, documentation, and protection of all resources (City of Adelanto 2014b).

Furthermore, as described in the Sustainable Plan EIR, in addition to the extensive framework of federal, state, and local laws protecting archaeological resources, the existing General Plan Conservation/Open Space Element also includes goals, policies, and implementation measures designed to protect and maintain local archaeological resources. These policies include goals to identify, designate, and preserve archaeological resources. Specifically, Policies 1.3 and 1.4, as well as Implementing Strategy 1.2.2 are designed to protect archaeological resources (City of Adelanto 2014b).

The analysis under the Sustainable Plan EIR remains accurate with respect to the proposed Project, which would develop a BESS facility consistent with zoning and in accordance with the provisions of the Sustainable Plan. Grading and excavation would occur as part of Project construction. Construction and operation of the proposed Project would not affect any known archaeological resources, as there are no known archaeological resources on site.

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during construction activities for the proposed Project, all construction work occurring within a 50-foot radius of the discovery shall be halted while the on-call archaeologist is contacted. If the resource is determined to be significant or unique through significance evaluation, and site avoidance is not possible, appropriate site-specific mitigation measures shall be established and undertaken. These might include an archaeological data recovery program that would be implemented by a qualified archaeologist and performed in accordance with the Office of Historic Preservation’s Archaeological Resource Management Reports (ARMR). If the discovery proves to be significant, it shall be curated with a qualified scientific of educational repository, as defined by the Guidelines for the Curation of Archaeological Collections. (Appendix D). SCE would implement a measure similar to Implementation Program OS-13 for the off-site construction areas within the Victor and Kramer Substation footprints and within the existing transmission lines rights-of-way.

As such, impacts associated with the development of the proposed Project within the Sustainable Plan area would be consistent with the analysis in the Plan EIR and would result in less-than-significant impacts with the incorporation of Sustainable Plan Implementing Programs and uniformly applied development policies and standards. The proposed Project would not result in any peculiar effects and would not result in a new or more severe adverse impact that was not previously identified in the prior EIR. Further, the Project would not result in an increase to significant effects as a result of new information not previously assessed in the Sustainable Plan EIR.
c) Directly or indirectly destroys a unique paleontological resource or site or unique geologic feature? The Sustainable Plan EIR determined that full buildout of the Plan area could cause a substantial adverse change in the significance of a paleontological resource during excavation and other earthmoving activities within surface and subsurface exposures of Pleistocene era alluvium materials if there is a failure to properly survey development sites and, if necessary, monitor earthmoving activities to ensure proper identification and recovery of paleontological resources. The Plan EIR determined that there is potential for the disturbance of paleontological resources in the northwestern portion of the Planning Area, which does not include the proposed Project site.

Furthermore, the Sustainable Plan EIR determined that incorporation of Sustainable Plan Implementing Program OS-14 will ensure that development sites are surveyed and monitored, and all resources are avoided, if possible, or they are identified, recovered, and catalogued to disseminate and preserve applicable paleontological information. This Implementing Program will ensure that potential impacts to paleontological resources will be less than significant, and all monitoring activities are to be implemented by qualified vertebrate professional paleontologists in accordance with the Society of Vertebrate Paleontology (City of Adelanto 2014b).

Additional evaluation of the Project site has been conducted by Dudek specialists in the Paleontological Resources Inventory Memorandum for the proposed Project, attached as Appendix E. No paleontological resources were identified within the Project site as a result of the paleontological survey, institutional records search, or the desktop geological and paleontological review, and no unique geological features are present on the surface or anticipated at depth (Appendix E). The Project site is underlain by Holocene alluvial fan deposits that have low paleontological resource sensitivity or potential on the surface that increases with depth (as little as 3 feet below ground surface [bgs] according to the San Bernardino County Museum [SBCM]) (Appendix E). The paleontological records search conducted by the SBCM revealed two nearby fossil localities from Pleistocene alluvial fan deposits which have high paleontological resource 632

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sensitivity or potential throughout their geographic and stratigraphic extent. Based on the records search and survey results and map and literature review, the Project site has high potential to produce paleontological resources during planned construction activities below a depth of 3 feet bgs (Appendix E).

As discussed in the Paleontological Resources Inventory Memorandum (Appendix E), in the event paleontological resources are encountered during ground-disturbing activities associated with construction of the Project the Project would have the potential to destroy a unique paleontological resource or site.

However, the Project will incorporate Sustainable Plan Implementing Program OS-14 which, at the direction of a qualified paleontological professional would include paleontological monitoring, recovery, identification, curation, and reporting. which would reduce any potential impacts to a level of less than significant (Appendix E). SCE would implement a measure similar to Sustainable Plan Implementing Program OS-14 for off-site construction areas within the Victor and Kramer Substation footprints and within the existing transmission lines rights-of-way.

As such, impacts associated with the development of the proposed Project within the Sustainable Plan area would be consistent with the analysis in the Plan EIR and would result in less-than-significant impacts with the incorporation of Sustainable Plan Implementing Program OS-14. The proposed Project would not result in any peculiar effects or a unique geologic feature and would not result in a new or more severe adverse impact that was not previously identified in the Sustainable Plan EIR. Further, the Project would not result in an increase to significant effects as a result of new information not previously assessed in the Sustainable Plan EIR.
d) Would the project disturb any human remains, including those interred outside of formal cemeteries? The Sustainable Plan EIR determined that full buildout of the Plan area could impact human remains during excavation and other earthmoving activities if there is a failure to properly survey development sites and, if necessary, monitor earthmoving activities to ensure proper identification and recovery of archaeological resources. However, the Sustainable Plan EIR determined that incorporation of Sustainable Plan Implementing Programs and existing policies and regulations would reduce impacts to a less-thansignificant level. In addition to the requirement to comply with state and local policies and regulations, Implementing Programs OS-11, OS-12, and OS-13 which will assist in the avoidance and mitigation of impacts to archaeological resources and human remains by requiring surveys, documentation, and protection of all resources (City of Adelanto 2014b). The Sustainable Plan EIR also states that in the event human remains are encountered, the discovery would be required to comply with State of California Public Resources Health and Safety Code Sections 7050.5–7055 and Section 5097.98 of the California Public Resources Code. Furthermore, if human remains are found during excavation, excavation must stop in the vicinity of the find and any area that is reasonably suspected to overlie adjacent remains until the County Coroner has been contacted, the remains investigated, and appropriate recommendations made for the treatment and disposition of the remains (City of Adelanto 2014b).

The analysis under the Sustainable Plan EIR remains accurate with respect to the proposed Project, which would develop a BESS facility consistent with zoning and in accordance with the provisions of the Sustainable Plan and would occur within the Plan area previously evaluated.

As described in the Cultural Resources Inventory Report, in accordance with Section 7050.5 of the California Health and Safety Code, if human remains are found, the County Coroner shall be immediately notified of the discovery. No further excavation or disturbance of the Project site, off-site improvement areas, or any nearby area reasonably suspected to overlie adjacent remains shall occur until the County 633

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Coroner has determined, within 2 working days of notification of the discovery, the appropriate treatment and disposition of the human remains (Appendix D). If the County Coroner determines that the remains are, or are believed to be, Native American, he or she shall notify the NAHC in Sacramento within 24 hours. In accordance with California Public Resources Code Section 5097.98, the NAHC must immediately notify those persons it believes to be the most likely descendant (MLD) (Appendix D). The MLD shall complete inspection within 48 hours of being granted access to the site. The designated MLD would then determine, in consultation with the property owner, the disposition of the human remains (Appendix D).

As such, impacts associated with the development of the proposed Project within the Sustainable Plan area would be consistent with the analysis in the Sustainable Plan EIR and would result in less-than-significant impacts with the incorporation of the Sustainable Plan Implementing Programs and uniformly applied development policies and regulations. The proposed Project would not result in any peculiar effects and would not result in a new or more severe adverse impact that was not previously identified in the prior EIR.

Further, the Project would not result in an increase to significant effects as a result of new information not previously assessed in the Sustainable Plan EIR.

Conclusion
The proposed Project is consistent with the development evaluated in the Sustainable Plan EIR and would not result in any new impacts or increase the severity of any previously identified impacts as compared to what was already identified and disclosed, either individually or cumulatively. Further environmental analysis is not required because:

No peculiar impacts related to the Project or site have been identified. Application of Sustainable Plan Implementing Programs, General Plan policies, along with existing state and local policies and regulations would substantially mitigate potentially significant impacts to a less-than-significant level.

There are no potentially significant impacts that were not analyzed as significant in the Sustainable Plan EIR.

There are no potentially significant off-site and/or cumulative impacts that were not discussed in the Sustainable Plan EIR.

No substantial new information has been identified that results in an impact that is more severe than anticipated by the in the Sustainable Plan EIR.

3.6 Energy
Significant
Project Impact
Analyzed in
the Prior EIR
Substantial New
Information
VI. Energy – Would the project:
a) Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary
consumption of energy resources, during project
construction or operation?
b) Conflict with or obstruct a state or local plan for
renewable energy or energy efficiency?
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Prior Environmental Impact Report Summary
Energy use was not specifically analyzed within the Sustainable Plan EIR as a separate issue under CEQA. At the time, energy use was contained within Appendix F of the CEQA Guidelines and the Sustainable Plan analyzed energy use within the Greenhouse Gas section of the Plan’s EIR. The EIR analyzed the Sustainable Plan’s consistency with CARB’s Scoping Plan (AB 32) and determined the Sustainable Plan promotes energy-efficient building design, as well as implementation of existing building and other codes regulating minimum energy, water, and waste efficiency consistent with CALGREEN requirements and would thus be consistent and not interfere with CARB’s Scoping Plan.

In addition, the Scoping Plan included a Renewables Portfolio Standards, which strive to achieve 33% renewable energy mix statewide by 2020. The EIR determined the Sustainable Plan and implementing actions would not interfere with the implementation of this program. The Sustainable Plan also implements local measures the encourage and support green building principles.

Project-Specific Analysis
a) Would the project result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation? As detailed below, the Project would temporarily increase the demand for electricity, gasoline, and diesel during grading and construction activities, but would be used minimally during operational activities.

Natural gas is not expected to be used during construction or operational activities.

Construction
Construction of the proposed Project would involve on-site and off-site energy demand and consumption related to the use of gasoline and diesel fuel for construction worker vehicle trips, hauling and material delivery truck trips, and operation of off-road construction equipment. In addition, diesel fueled portable generators may be necessary to provide additional electricity demands for temporary on-site and off-site lighting, welding, and supplying energy to areas of the sites where energy supply cannot be met via a hookup to the existing electricity grid. All off-site improvements would be limited to the existing Victor and Kramer Substation footprints or transmission lines rights-of-way. Construction is anticipated to last approximately 15 months.

The Project would include typical construction techniques and not involve unusual or energy-intensive practices. The structures and equipment are fairly standardized and the overall construction schedule and process would be designed to be efficient in order to avoid excess monetary costs. Equipment and fuel are not typically used in a wasteful manner due to the added expense associated with equipment operations, maintenance, and fueling. Therefore, the construction phase of the proposed Project would not result in the wasteful, inefficient, and unnecessary consumption of energy.

Operations
Following the completion of Project construction, the Project would switch from that of energy consumption to that of energy storage. As stated above, the Project would not increase the demand for electricity or natural gas at the Project site during operations. The Project does not include any permanent components that would increase demand for existing sources of energy except for gasoline usage for routine maintenance visits. The development of a battery storage facility and associated off-site improvements as 635

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proposed by the Project would provide a secure and reliable electricity supply, improve community infrastructure, and support sustainable electricity generation. By building the Project, a clean, reliable resource would be gained to help integrate renewable energy sources and reduce GHG and criteria air pollutant emissions. Therefore, no significant impact to energy resources would result.

In conclusion, Project construction and operation would not conflict with the Sustainable Plan’s goals and policies related to energy use, nor would it result in the wasteful, inefficient, or unnecessary consumption of energy resources, as specified within Appendix G of the CEQA Guidelines. b) Would the project conflict with or obstruct a state or local plan for renewable energy or energy efficiency? There is no renewable energy or energy efficiency plan that is applicable to the Project. The Project itself would assist in increasing the state’s renewable energy goals by constructing a battery storage technology and associated off-site substation and transmission line improvements that allow for energy generated by renewables to be stored and discharged back to the grid when the need arises. The technology is advancing rapidly as a grid resource and will support system load balancing by CAISO when sun and wind resources are intermittently not available. Power from these renewable generation sources often is produced at different times of day, which may not align with peak use (CAISO 2014). As such, no conflicts with renewable energy or energy efficiency plans would occur and there would be no significant energy-related impacts from the Project.

As previously discussed, the Sustainable Plan EIR did not analyze energy use as a separate topic under CEQA. However, energy use was analyzed within the Sustainable Plan EIR under Greenhouse Gas Emissions. The Project would not conflict with policies within the Sustainable Plan related to energy use or conflict with or obstruct a state or local plan for renewable energy or energy efficiency as specified within Appendix G of the CEQA Guidelines.

Conclusion
The proposed Project is consistent with the development evaluated in the Sustainable Plan EIR and would not result in any new impacts or increase the severity of any previously identified impacts as compared to what was already identified and disclosed, either individually or cumulatively. Further environmental analysis is not required because:

No peculiar impacts related to the Project or the Project site have been identified.

There are no potentially significant impacts that were not analyzed as significant in the Sustainable Plan EIR.

There are no potentially significant off-site and/or cumulative impacts that were not discussed in the Sustainable Plan EIR.

No substantial new information has been identified that results in an impact that is more severe than anticipated by the Sustainable Plan EIR.
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3.7 Geology and Soils
Significant
Project Impact
Analyzed in
the Prior EIR
Substantial New
Information
VII. GEOLOGY AND SOILS – Would the project:
a) Directly or indirectly cause potential substantial
adverse effects, including the risk of loss, injury,
or death involving:
i) Rupture of a known earthquake fault, as
delineated on the most recent Alquist-Priolo
Earthquake Fault Zoning Map issued by the
State Geologist for the area or based on
other substantial evidence of a known
fault? Refer to Division of Mines and
Geology Special Publication 42.
ii) Strong seismic ground shaking?
iii) Seismic-related ground failure, including
liquefaction?
iv) Landslides?
b) Result in substantial soil erosion or the loss of
topsoil?
c) Be located on a geologic unit or soil that is
unstable, or that would become unstable as a
result of the project, and potentially result in onor off-site landslide, lateral spreading, subsidence, liquefaction or collapse?
d) Be located on expansive soil, as defined in
Table 18-1-B of the Uniform Building Code
(1994), creating substantial direct or indirect
risks to life or property?
e) Have soils incapable of adequately supporting
the use of septic tanks or alternative waste
water disposal systems where sewers are not
available for the disposal of waste water?
Prior Environmental Impact Report Summary
Potential impacts to geology and soils were analyzed in the Sustainable Plan EIR on pages 4.6-1 through 4.6-28.

Potential impacts related to geology and soils were determined to be less than significant with implementation of the City’s existing standards and regulations or were determined to have no impact.

Applicable Policies
General Plan
Goal Safety 2: To minimize potential hazards to public health, safety and the well being of the community resulting from natural and man-made hazards.
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Policy Safety 1.2/1.7: The City will ensure that all appropriate construction and safety standards are incorporated into all new development.

Policy Safety 1.9: The City will restrict development in those areas where slope exceeds fifteen (15) percent and in those areas subject to flooding.

Policy Safety 1.11: The City will require all proposed developments to submit a soils and geologic report prepared by a certified geologist which shall include mitigation if any geologic hazards are identified.

Sustainable Plan
Public Health and Safety Chapter
Goal HS 1: Potential damage to structures and loss of life that can result from earthquakes and other geologic hazards are minimized.

Policy HS 1.1: Identify structural types, land uses, and sites that are highly sensitive to earthquake activity and other geological hazards, and seek to abate or modify them to achieve acceptable levels of risk.

Policy HS 1.2: Enforce the most recent building codes governing seismic safety and structural design to minimize damage from earthquakes.

Implementing Program HS-1: Seismic Safety/CEQA. Require environmental documents prepared in connection with CEQA to address seismic safety issues and provide adequate mitigation for existing and potential hazards.

Implementing Program HS-2: Geotechnical Analysis. Require a geotechnical analysis for construction in areas with potential geological hazards and implement appropriate mitigation recommendations.

Implementing Program HS-3: International Building Code. Continue to implement seismic safety standards for construction of new buildings as specified by the currently adopted International Building Code, and update the City’s codes as needed to respond to new information, standards, and technology.

Implementing Program HS-4: Construction Technologies. Require the use of available technologies and earthquake-resistant materials in the design and construction of all infrastructure projects.

Project-Specific Analysis
a) Would the project directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving:
i) Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault? Refer to Division of Mines and Geology Special Publication 42.

There are no Alquist-Priolo Fault Zones designated in the Sustainable Plan area and no other evidence of active faults within the Plan area exists, thus, future development will not be exposed to the potential for fault rupture (City of Adelanto 2014b). Should new Alquist-Priolo Fault Zones be designated in the future or active faults become known through other sources, projects would be subject to Policy 1.11 of 638

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the General Plan Safety Element that requires all proposed developments to submit a soils and geologic report. This standard is implemented as part of the City’s routine development project review process, pursuant to CEQA, and will avoid placement of buildings within areas potentially exposed to fault rupture hazards (City of Adelanto 2014b). As evaluated in the Sustainable Plan EIR, no impact would occur.

Furthermore, the off-site improvement areas (consisting of the SCE Victor Substation, the SCE Kramer Substation, and the applicable transmission lines rights-of-way) are not on or adjacent to an Alquist-Priolo Fault Zone (DOC 2024c). As such, no impacts related to a known earthquake fault would as a result of proposed off-site improvements.

The analysis under the prior EIR remains accurate with respect to the proposed Project. As such, impacts associated with the development of the proposed Project within the Sustainable Plan area would be consistent with the analysis in the Plan EIR and would result in no impact. Therefore, the proposed Project would not result in any peculiar effects and would not result in a new or more severe adverse impact that was not previously identified in the prior EIR. Further, the Project would not result in an increase to significant effects as a result of new information not previously assessed in the Sustainable Plan EIR. ii) Strong seismic ground shaking?
Although the Sustainable Plan area is subject to potential earthquake hazards due to the seismically active nature of Southern California, the City’s plan check and code compliance procedures include requirements to design structures in accordance with the appropriate ground shaking design parameters set forth in the California Building Code (CBC) (City of Adelanto 2014b). The CBC parameters are based on the seismic setting and potential intensity levels of the earthquake faults most likely to generate significant ground shaking in the Plan area (City of Adelanto 2014b). Requirements related to seismic safety set forth in the CBC would also be applicable to off-site improvements within the Victor and Kramer Substations and the transmission lines rights-of-way. Upon implementation of the above requirements as well as Safety Implementation Strategy 1.1.2 from the General Plan Safety Element that requires the use of CBC construction standards related to seismic safety, potential impacts would be reduced to less than significant (City of Adelanto 2014b).

The analysis under the Sustainable Plan EIR remains accurate with respect to the proposed Project. As such, impacts associated with the development of the proposed Project within the Sustainable Plan area would be consistent with the analysis in the Plan EIR and would result in less-than-significant impacts.

Therefore, the proposed Project would not result in any peculiar effects and would not result in a new or more severe adverse impact that was not previously identified in the prior EIR. Further, the Project would not result in an increase to significant effects as a result of new information not previously assessed in the Sustainable Plan EIR.
iii) Seismic-related ground failure, including liquefaction? As discussed in the Sustainable Plan EIR, no potential for liquefaction exists within the Plan area, although, liquefaction conditions could occur along the Mojave River or in sandy areas with high water tables, while deferential settlement could occur in areas of young, unconsolidated alluvium (City of Adelanto 2014b).

Furthermore, according to the Department of Conservation, there are no liquefaction zones located within the Victor or Kramer substations or within the applicable transmission lines rights-of-way (DOC 2024c).

General Plan Safety Element Policy 1.11 requires developers to prepare soils reports on a project-by-project basis and to identify any geologic hazards pursuant to the CBC (City of Adelanto 2014b). Upon 639

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implementation of existing standards and application of standard engineering techniques detailed in the Sustainable Plan EIR, potential impacts relating to liquefaction would be reduced to less than significant (City of Adelanto 2014b).

The analysis under the Sustainable Plan EIR remains accurate with respect to the proposed Project, which would develop an industrial BESS facility in accordance with existing standards and requirements, including the most recent CBC standards. As such, impacts associated with the development of the proposed Project within the Sustainable Plan area would be consistent with the analysis in the Plan EIR and would result in less-than-significant impacts. Therefore, the proposed Project would not result in any peculiar effects and would not result in a new or more severe adverse impact that was not previously identified in the previous EIR. Further, the Project would not result in an increase to significant effects as a result of new information not previously assessed in the Sustainable Plan EIR.
iv) Landslides?
The Sustainable Plan EIR evaluated the full build out of the Plan area and the potential impacts related to the possibility of landslides (City of Adelanto 2014b). The only Plan areas potentially vulnerable to seismic failure are the slopes of the Shadow Mountains and Shadow Hills, which the proposed Project site is not near (City of Adelanto 2014b). Furthermore, according to the Department of Conservation, there are there are no landslide zones located within the Victor or Kramer substations or within the applicable transmission lines rights-of-way (DOC 2024c). The City has also adopted Chapter 18 and Appendix J of the 2010 CBC (as well as all CBC iterations since then and in the future) to regulate all grading design and criteria for development on slopes or hillsides and at the foot of hillsides; however, the proposed Project site is not near a hillside and is relatively flat where the potential for landslides to occur is low (City of Adelanto 2014b).

The Sustainable Plan EIR determined impacts would be less than significant with implementation of existing standards and regulations, including General Plan Safety Element Policy 1.11 and the most recent CBC.

The most recent CBC regulations would also be applicable for all off-site improvements.

The analysis under the Sustainable Plan EIR remains accurate with respect to the proposed Project, which would develop an industrial BESS facility on a relatively flat site, that would be developed in accordance with existing standards and requirements. As such, impacts associated with the development of the proposed Project within the Sustainable Plan area would be consistent with the analysis in the Plan EIR and would result in less-than-significant impacts. Therefore, the proposed Project would not result in any peculiar effects and would not result in a new or more severe adverse impact that was not previously identified in the previous EIR. Further, the Project would not result in an increase to significant effects as a result of new information not previously assessed in the Sustainable Plan EIR. b) Would the project result in substantial soil erosion or the loss of topsoil? The Sustainable Plan EIR evaluated the full build out of the Plan area and the potential impacts related to substantial soil erosion or loss of topsoil, which primarily involve air quality (increased fugitive dust) during construction and water quality degradation due to increased sedimentation (see Sections 4.3, Air Quality, and 4.9, Hydrology and Water Quality, of the Sustainable Plan EIR for more information regarding these impacts). Wind-blown erosion within the Sustainable Plan area is expected to decrease over the long-term as new development replaces exposed soils (City of Adelanto 2014b). As determined in the Sustainable Plan EIR, impacts relating to soil erosion or topsoil loss would be less than significant. Furthermore, off-site improvements within previously developed areas such as the existing Victor and Kramer Substation 640

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footprints as well as improvements within the existing transmission lines rights-of-way would be required to adhere to applicable BMPs related to sedimentation and erosion control set forth in the City of Victorville Municipal Code (e.g., Chapter 10.30, Storm Water and Urban Runoff Management and Discharge Control) or San Bernadino County Code (e.g., Chapter 88.02, Soil and Water Conservation and Chapter 85.11, PreConstruction Flood Hazard Mitigation and Erosion Control Inspection) (City of Victorville 2024a; County of San Bernadino 2024a). As such, off-site improvements would not be anticipated to result in substantial soil erosion or the loss of topsoil.

The analysis under the Sustainable Plan EIR remains accurate with respect to the proposed Project, which would develop an industrial BESS facility in accordance with existing standards and requirements. As such, impacts associated with the development of the proposed Project within the Sustainable Plan area would be consistent with the analysis in the Sustainable Plan EIR and would result in less-than-significant impacts.

Therefore, the proposed Project would not result in any peculiar effects and would not result in a new or more severe adverse impact that was not previously identified in the previous EIR. Further, the Project would not result in an increase to significant effects as a result of new information not previously assessed in the Sustainable Plan EIR.
c) Would the project be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction or collapse?
The Sustainable Plan area is susceptible to settlement, collapse, and subsidence of soils due to the widespread presence of young, unconsolidated alluvial soils that is generally loose and dry and therefore is susceptible to weakness under pressure (City of Adelanto 2014b). However, as mentioned in Section

3.7(a) above, General Plan Policy 1.11 requires the preparation of a soils report that identifies any geologic hazards pursuant to the CBC, including liquefaction, collapse, subsidence, and any other ground failure potential, and requires implementation of appropriate design measures accordingly. Chapter 18 and Appendix J of the CBC that the City has adopted also requires soils reports and other soil stability measures (City of Adelanto 2014b). The CBC requirements would also be applicable to off-site substation and transmission line improvements within the City of Victorville and unincorporated County of San Bernadino (City of Victorville 2024a; County of San Bernadino 2024a). However, as discussed above, the off-site improvement areas are not located within landslide or liquefaction zones as identified by the Department of Conservation (DOC 2024c).

The Sustainable Plan EIR also mentions that development within the Plan area will increase groundwater extraction that could result in potential for ground subsidence due to the withdrawal of groundwater that weakens soil cohesion and could lead to collapse if not controlled or offset appropriately (City of Adelanto 2014b). The proposed Project would require approximately 35 acre-feet of water during construction for dust suppression and earthwork. Construction and operational water would be provided by on-site groundwater through an improved existing well, a new well permitted and drilled (if necessary), or through off-site source delivered by truck. The Adelanto Urban Water Management Plan (UWMP) (managed by the Water District) and the General Plan include policies that are designed to ensure adequate groundwater recharge occurs (City of Adelanto 2014b). As determined in the Sustainable Plan EIR, implementation of existing standards and regulations would reduce impacts to less than significant by maintaining adequate groundwater levels.
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As such, impacts associated with the development of the proposed Project within the Sustainable Plan area would be consistent with the analysis in the Plan EIR and the Project would result in less-than-significant impacts related to unstable soils. Therefore, the proposed Project would not result in any peculiar effects and would not result in a new or more severe adverse impact that was not previously identified in the previous EIR. Further, the Project would not result in an increase to significant effects as a result of new information not previously assessed in the Sustainable Plan EIR. d) Would the project be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property? The Sustainable Plan EIR evaluated the full build out of the Plan area and the potential to directly or indirectly cause potential substantial adverse impacts involving expansive soil and determined that impacts would be less than significant with the implementation of existing City regulations (City of Adelanto 2014b). As detailed in the Sustainable Plan EIR, expansive soils could impact industrial development through the Airport Development District, Business Park, and Light Manufacturing designations located along the eastern portion of the Plan area (City of Adelanto 2014b). The Project site is not within any of these land use designations.

Chapter 18 and Appendix J of the CBC also require soil testing to determine expansive soils potential, which would be applicable to both on-site and off-site improvement areas. As discussed in the Sustainable Plan EIR, implementation of existing City regulations would reduce impacts to less than significant.

The analysis under the Sustainable Plan EIR remains accurate with respect to the proposed Project, which would develop an industrial BESS facility in accordance with the provisions of the Sustainable Plan and existing regulations. As such, impacts associated with the development of the proposed Project within the Sustainable Plan area would be consistent with the analysis in the Plan EIR and the Project would result in less-than-significant impacts related to expansive soils. Therefore, the proposed Project would not result in any peculiar effects and would not result in a new or more severe adverse impact that was not previously identified in the previous EIR. Further, the Project would not result in an increase to significant effects as a result of new information not previously assessed in the Sustainable Plan EIR. e) Would the project have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of waste water? The Sustainable Plan EIR evaluated the full build out of the Plan area and the potential impacts related to substantial adverse direct or indirect impacts involving the use of septic tanks or alternative wastewater systems and identified there would be a less-than-significant impact in this regard because the Plan area would be served by the public sewer system. Furthermore, off-site improvements would not involve construction of or require use of septic tanks or alternative wastewater disposal systems. Therefore, septic tanks or alternative wastewater systems would not be used, and impacts would be less than significant.

The analysis under the Sustainable Plan EIR remains accurate with respect to the proposed Project as the Project would not require wastewater facilities and does not propose the use of septic tanks or alternative wastewater disposal systems. As such, impacts associated with the development of the proposed Project within the Sustainable Plan area would be consistent with the analysis in the Plan EIR and the Project would not result in any significant impacts. Therefore, the proposed Project would not result in any peculiar effects and would not result in a new or more severe adverse impact that was not previously identified in the prior EIR. Further, the Project would not result in an increase to significant effects as a result of new information not previously assessed in the Sustainable Plan EIR.
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Conclusion
The proposed Project is consistent with the development evaluated in the Sustainable Plan EIR and would not result in any new impacts or increase the severity of any previously identified impacts as compared to what was already identified and disclosed, either individually or cumulatively. Further environmental analysis is not required because:

No peculiar impacts that are not substantially mitigated have been identified as a result of the proposed Project or its site. Application of Sustainable Plan Implementing Program OS-14 substantially reduces potentially significant impacts to a less-than-significant level consistent with the conclusions in the Sustainable Plan EIR.

There are no potentially significant impacts that were not analyzed as significant in the Sustainable Plan EIR.

There are no potentially significant off-site and/or cumulative impacts that were not discussed in the Sustainable Plan EIR.

No substantial new information has been identified that results in an impact that is more severe than anticipated by the Sustainable Plan EIR.

3.8 Greenhouse Gas Emissions

Significant
Project Impact
Analyzed in
the Prior EIR
Substantial New
Information
VIII. GREENHOUSE GAS EMISSIONS – Would the project:
a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the
environment?
b) Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of
greenhouse gases?
Prior Environmental Impact Report Summary
Impacts related to greenhouse gas (GHG) emissions were analyzed in the Sustainable Plan EIR on pages 4.7-1 through 4.7-25. The Sustainable Plan EIR contemplated uses on the Project site involving industrial uses such as warehousing, which would be a more intensive use resulting in higher transportation related emissions and potentially higher operational emissions than the proposed Project. The Sustainable Plan EIR did not identify any significant impacts related to GHG emissions and was found to be consistent with the State Scoping Plan and the San Bernardino County Regional Greenhouse Gas Reduction Plan and therefore would not substantially contribute to global climate change impacts.

Applicable Policies
General Plan
No policies are applicable to the topic of greenhouse gas emissions. 643

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Sustainable Plan
Land Use and Community Design Chapter
Goal OS 6: Local air quality is good; local contributions of airborne pollutants to the air basin is reduced.

Policy OS 6.1: Pursue efforts to reduce air pollution and greenhouse gas emissions by promoting the use of renewable energy (e.g., solar and wind power), and implement effective energy conservation and efficiency measures.

Implementing Program OS-18: San Bernardino County Regional Greenhouse Gas Reduction Plan. Implement the strategies identified in the San Bernardino County Regional Greenhouse Gas Reduction Plan to reduce its community greenhouse gas emissions (GHG) to a level that is 30 percent below its projected GHG emissions level in 2020.

Public Services and Infrastructure Chapter
Policy PF 8.2: Reduce greenhouse gas emissions by increasing the use of new technologies as alternatives and supplements to the consumption of gasoline in City vehicles and equipment.

Project-Specific Impacts
The analysis contained within this section is based, in part, on the Air Quality and Greenhouse Gas Emissions Technical Memorandum (Technical Memorandum) for the proposed Project prepared by Dudek in June 2024 (Appendix A). The Technical Memorandum quantifies GHG emissions and analyzes the Project and cumulative impacts according to Appendix G of the CEQA Guidelines. a) Would the project generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment?
The analysis under the Sustainable Plan EIR remains accurate with respect to the proposed Project, which would develop an industrial BESS facility in accordance with the provisions of the Sustainable Plan and would occur within the Plan area previously evaluated. The Plan EIR evaluated whether the full build out of the Plan area would generate GHG emissions that may have a significant impact on the environment. It was determined impacts related to the full build out of the planned growth area of the Sustainable Plan would be less than significant.

Construction and Decommissioning Emissions
Construction and decommissioning of the Project would result in GHG emissions, which are primarily associated with use of off-road construction equipment, on-road vendor trucks, and worker vehicles. The MDAQMD follows the SCAQMD recommendation in calculating the total GHG emissions for construction activities by amortizing the emissions over the life of a project. As such, Project construction emissions were amortized over a 30-year period and added to the annual operational phase GHG emissions.

CalEEMod was used to estimate GHG emissions during construction and decommissioning. Construction of the Project is anticipated to last up to 15 months and decommissioning 7 months. On-site sources of GHG emissions include off-road equipment and off-site sources include on-road vehicles (vendor trucks 644

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and worker vehicles). Table 10 presents construction and decommissioning GHG emissions for the Project from on-site and off-site emission sources (Appendix A).

Table 10. Estimated Annual Construction Greenhouse Gas Emissions Year
CO2 CH4 N2O R CO2e
metric tons per year
2025 (Construction) 1,978.36 0.06 0.09 0.74 2,006.21
2026 (Construction) 357.11 0.01 0.02 0.23 363.52
2050 (Decommissioning) 1,513.54 0.02 0.18 0.07 1,566.82 Total 3,849.01 0.09 0.28 1.03 3,936.55
Amortized Over 30-Years 131.22
Source: Appendix A.

Notes: GHG= greenhouse gas; CO2 = carbon dioxide; CH4 = methane; N2O = nitrous oxide; R = refrigerants; CO2e = carbon dioxide equivalent.

Totals may not sum due to rounding.

As shown in Table 10, the estimated total GHG emissions during construction and decommissioning of the Project would be approximately 3,937 MT CO2e. Estimated Project-generated construction and decommissioning emissions amortized over 30 years would be approximately 131 MT CO2e per year. As with Project-generated construction air quality pollutant emissions, GHG emissions generated during construction of the Project (including off-site construction areas) would be short term in nature, lasting only for the duration of the construction period, and would not represent a long-term source of GHG emissions.

Because there is no separate GHG threshold for construction, the evaluation of significance is determined by adding the amortized construction emissions to the operational emissions and comparing them to the operational threshold.

Operational Emissions
CalEEMod was used to estimate potential Project-generated operational GHG emissions from mobile sources, area sources, energy, water and wastewater, solid waste, refrigerants, off-road equipment, and stationary sources. For additional details, see Section 2.2 of the Technical Memorandum for a discussion of operational emission calculation methodology and assumptions. Operational year 2026 was assumed as the first year of operation. Table 11 shows the estimated operational emissions from the Project.

Table 11. Estimated Annual Operational Greenhouse Gas Emissions – Unmitigated Emission Source
CO2 CH4 N2O R CO2e
metric tons per year
Mobile 2.25 <0.01 <0.01 <0.01 2.29
Area 0.01 <0.01 <0.01 0.00 0.01
Energy 21,832.70 2.08 0.25 0.00 21,959.90
Water 0.81 <0.01 <0.01 0.00 0.82
Waste 0.00 0.00 0.00 0.00 0.00
Refrigerants 0.00 0.00 0.00 195.14 195.14
Off-Road 0.45 <0.01 <0.01 0.00 0.45
Stationary 3.81 <0.01 <0.01 0.00 3.82
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Table 11. Estimated Annual Operational Greenhouse Gas Emissions – Unmitigated Emission Source
CO2 CH4 N2O R CO2e
metric tons per year
Total 21,840.04 2.08 0.25 195.14 22,162.43
Amortized Construction Emissions 131.22
Operational Emissions plus Amortized Construction Emissions 22,293.65 Source: Appendix A.

Notes: CO2 = carbon dioxide; CH4 = methane; N2O = nitrous oxide; R=refrigerants; CO2e = carbon dioxide equivalent; GHG = greenhouse gas.

Values of “<0.01” indicate that the estimated emissions are less than 0.01 metric tons per year. Totals may not sum due to rounding.

As shown in Table 11, the estimated total GHG emissions during operation of the Project would be approximately 22,294 MT CO2e per year, including amortized construction and decommissioning emissions, which would not exceed the MDAQMD threshold of 90,719 MT CO2e (100,000 short tons per year). In addition, the Project would improve energy grid reliability and support the integration of renewable energy sources, such as wind and solar, reducing the need to operate natural gas power plants and displacing GHG emissions. Furthermore, there would be no new operational GHG emissions associated with off-site improvements. Based on the preceding considerations, the Project would not generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment and impacts would be less than significant.

The Project is thus consistent with the findings disclosed in the Sustainable Plan EIR, which determined that GHG emissions would be less than significant. Therefore, the Project would not result in significant new or substantially more severe adverse impact than was previously identified in the prior EIR. Further, the Project would not result in an increase to significant effects as a result of new information not previously assessed in the Sustainable Plan EIR.
b) Would the project conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases?
The analysis under the Sustainable Plan EIR remains accurate with respect to the proposed Project, which would develop an industrial BESS facility in accordance with the provisions of the Sustainable Plan and would occur within the Plan area previously evaluated. The Sustainable Plan EIR evaluated whether the full build out of the Plan area would generate GHG emissions that may have a significant impact on the environment. It was determined impacts related to the full build out of the planned growth area of the Sustainable Plan would be less than significant.

As discussed in the Technical Memorandum, pursuant to Section 15064.4(a) of the CEQA Guidelines, a lead agency may rely on qualitative analysis or performance-based standards to determine the significance of impacts from GHG emissions (Appendix A). Thus, the Project’s consistency with SB 32 (2017 Scoping Plan) and AB 1279 (2022 Scoping Plan), the SCAG Connect SoCal, and the County Greenhouse Gas Reduction Plan (GHGRP) are discussed below.
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Potential to Conflict with State Reduction Targets and the California Air Resources Board’s Scoping Plans
The 2017 Scoping Plan included measures to promote renewable energy and energy efficiency (including the mandates of SB 350),
8 increase stringency of the Low Carbon Fuel Standard, measures identified in the Mobile Source and Freight Strategies, measures identified in the proposed Short-Lived Climate Pollutants plan, and increase stringency of SB 375 targets.9 The 2022 Scoping Plan builds upon and accelerates programs currently in place, including moving to zero-emission transportation; phasing out use of fossil gas use for heating homes and buildings; reducing chemical and refrigerants with high GWP; providing communities with sustainable options for walking, biking, and public transit; and displacement of fossil-fuel fired electrical generation through use of renewable energy alternatives (e.g., solar arrays and wind turbines) (CARB 2022). Table 12 summarizes the Project’s potential to conflict with the applicable 2017 Scoping Plan actions.

Table 12. Project Potential to Conflict with 2017 Scoping Plan Action Potential to Conflict
Implement SB 350 by 2030
▪ Increase Renewable Portfolio Standard
▪ Establish annual targets for statewide
energy efficiency
▪ Reduce GHG emissions in the
electricity sector
No Conflict. This action is directed towards policymakers and would not be directly applicable to the Project. Nonetheless, the Project would use energy from Southern California Edison (SCE).

SCE has committed to diversify its portfolio of energy sources by increasing energy from wind and solar sources. The Project would not interfere with or obstruct SCE energy source diversification efforts. Rather, the Project would provide additional capacity to the electrical grid and support the integration of additional intermittent renewable energy sources, such as wind and solar.

The Project would also serve as an additional local capacity resource that would enhance grid reliability.

Implement Mobile Source Strategy
(Cleaner Technology and Fuels)
▪ Increase zero emission and plug-in
hybrid electric vehicles
▪ Increase GHG stringency on light-duty
vehicles beyond Advanced Clean Cars
▪ Medium- and heavy-duty GHG Phase 2
▪ Innovative Clean Transit
▪ Last Mile Delivery
▪ Further reduce VMT through SB 375
and regional Sustainable Communities
Strategy
No Conflict. These actions are part of the CARB Mobile Source Strategy that pertains to vehicle fleet standards. As this is a CARB enforced standard, vehicles that access the Project are required to comply with the standards and will therefore comply with the strategy.

Implement California Sustainable Freight
Action Plan
No Conflict. This measure would apply to all trucks accessing the Project sites, including existing trucks or new trucks that are part of the statewide goods movement sector. The Project would not obstruct or interfere with agency efforts to improve freight system efficiency. 8 SB 350 expanded the Renewables Portfolio Standard program by establishing a goal that 50% of the total electricity sold to retail customers in California per year be from renewable energy sources by December 31, 2030. In addition, SB 350 included the goal to double the energy efficiency savings in electricity and natural gas final end uses (such as heating, cooling, lighting, or class of energy uses on which an energy efficiency program is focused) of retail customers through energy conservation and efficiency. 9 Pursuant to SB 375, CARB set per-capita GHG emissions reduction targets from passenger vehicles for each of the state’s 18 metropolitan planning organizations.
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Table 12. Project Potential to Conflict with 2017 Scoping Plan Action Potential to Conflict
Adopt a Low Carbon Fuel Standard with a
Carbon Intensity reduction of 18%
No Conflict. This measure, which was increased to 20% reduction in carbon intensity by 2030, applies to all fuel purchased and used by the Project in the state. The Project would not obstruct or interfere with agency efforts to implement a Low Carbon Fuel Standard.

Utilize wood and agricultural products to
increase the amount of carbon stored in
the natural and built environments
No Conflict. To the extent appropriate for the Project, wood products would be used in construction.

Source: CARB 2017.

Table 13 below highlights the measures from the 2022 Scoping Plan that are relevant to the Project.

Table 13. Project Potential to Conflict with 2022 Scoping Plan Sector Action Potential to Conflict
GHG Emissions
Reductions
Relative to the
SB 32 Target
40% below 1990 levels by 2030 No Conflict. While the SB 32 GHG emissions reduction target is not an action that is analyzed
independently, it is included in Table 2-1 of the
2022 Scoping Plan for reference. The Project
would not obstruct or interfere with agency efforts
to meet the SB 32 reduction goal. Rather, the
Project would allow for increased energy storage
from intermittent renewable energy sources,
thereby increasing grid reliability and increasing
the opportunity for renewable energy
development.

Smart Growth/
VMT
VMT per capita reduced 25% below
2019 levels by 2030, and 30% below
2019 levels by 2045
No Conflict. The Project would not obstruct or
interfere with agency efforts to meet this regional
VMT reduction goal, including through
implementation of SB 375. As detailed below, the
Project would be consistent with the SCAG 2024–
2050 RTP/SCS, which is the regional growth
management strategy that targets per-capita GHG
reduction from passenger vehicles and light trucks in
the Southern California Region pursuant to SB 375.

Light-duty
Vehicle (LDV)
Zero Emission
Vehicles (ZEVs)
100% of LDV sales are ZEV by 2035 No Conflict. As this action pertains to LDV sales within California, the Project would not obstruct or
interfere with its implementation.

Truck ZEVs 100% of medium-duty vehicle (MDV)/
heavy-duty vehicle (HDV) sales are ZEV
by 2040
No Conflict. As this action pertains to MDV and
HDV sales within California, the Project would not
obstruct or interfere with its implementation.

Electricity
Generation
Sector GHG target of 38 million metric tons
of carbon dioxide equivalent (MMTCO2e) in
2030 and 30 MMTCO2e in 2035
Retail sales load coverage1
20 gigawatts (GW) of offshore wind by 2045
No Conflict. As this action pertains to the
statewide procurement of renewably generated
electricity, the Project would not obstruct or
interfere with its implementation. Rather, the
Project would support increased usage of
renewable electricity by allowing for a more
reliable local electric grid and reducing reliance on
natural gas power plants.
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Table 13. Project Potential to Conflict with 2022 Scoping Plan Sector Action Potential to Conflict
Meet increased demand for electrification
without new fossil gas-fired resources
New
Residential and
Commercial
Buildings
All electric appliances beginning 2026
(residential) and 2029 (commercial),
contributing to 6 million heat pumps
installed statewide by 2030
No Conflict. The Project would not obstruct or
interfere with agency efforts to meet the allelectric appliance and heat pump goals.

Construction
Equipment
25% of energy demand electrified by
2030 and 75% electrified by 2045
No Conflict. As this Action pertains to the
electrification of off-road equipment across
California, the Project would not obstruct or
interfere with its implementation.

Low Carbon
Fuels for
Transportation
Biomass supply is used to produce
conventional and advanced biofuels, as
well as hydrogen
No Conflict. The Project would not obstruct or
interfere with agency efforts to increase the
provision of low carbon fuels for transportation.

The development and use of biofuels in trucks
and automobiles would occur at the state and
regional level.

Low Carbon
Fuels for
Buildings and
Industry
In 2030s biomethane blended in pipeline
Renewable hydrogen blended in fossil gas
pipeline at 7% energy (~20% by volume),
ramping up between 2030 and 2040
In 2030s, dedicated hydrogen pipelines
constructed to serve certain industrial
clusters
No Conflict. The Project would not obstruct or
interfere with agency efforts to increase the
provision of low carbon fuels for use in buildings
and industry. The blending of biomethane and use
of renewable hydrogen in existing natural gas
pipelines would happen at the scale of the utility
provider and without action required by the
Project.

High-GWP
Potential
Emissions
Low-GWP refrigerants introduced as
building electrification increases,
mitigating HFC emissions
No Conflict. The Project would not obstruct or
interfere with agency efforts to introduce low-GWP
refrigerants. The State has established a
prohibition on the sale or distribution of bulk HFCs
identified as having a high GWP through SB 1206.

Source: CARB 2022.

Notes:
1 As noted in Table 2-1 of the 2022 Scoping Plan, SB 100 speaks only to retail sales and state agency procurement of electricity (i.e., wholesale or non-retail sales and losses from storage and transmission and distribution lines are not subject to the law).

Based on the analysis in Table 12 and Table 13, the Project would be consistent with the applicable strategies and measures in the 2017 Scoping Plan and 2022 Scoping Plan, respectively.

The 2045 carbon neutrality goal required CARB to expand proposed actions in the 2022 Scoping Plan to include those that capture and store carbon in addition to those that reduce only anthropogenic sources of GHG emissions. However, the 2022 Scoping Plan emphasizes that reliance on carbon sequestration in the state’s natural and working lands will not be sufficient to address residual GHG emissions, and achieving carbon neutrality will require research, development, and deployment of additional methods to capture atmospheric GHG emissions (e.g., mechanical direct air capture). Given that the specific path to neutrality will require development of technologies and programs that are not currently known or available, the Project’s role in supporting the statewide goal would be speculative and cannot be wholly identified at this time.

Overall, the Project would comply with all regulations adopted in furtherance of the Scoping Plan to the extent applicable and required by law. As demonstrated above, the Project would not conflict with CARB’s 649

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2017 or 2022 Scoping Plan updates and with the state’s ability to achieve the 2030 and 2045 GHG reduction and carbon neutrality goals.

Potential to Conflict with the Southern California Association of Governments’ Regional Transportation Plan/Sustainable Communities Strategy As detailed in the Technical Memorandum, the SCAG Connect SoCal 2024 (2024–2050 RTP/SCS) is a regional growth management strategy that targets per-capita GHG reduction from passenger vehicles and light trucks in the Southern California Region pursuant to SB 375 by achieving per-capita GHG emissions reductions relative to 2005 of 8% by 2020 and 19% by 2035 (SCAG 2024). In addition to demonstrating the region’s ability to attain the GHG emission reduction targets set forth by CARB, Connect SoCal 2024 outlines a series of actions and strategies for integrating the transportation network with an overall land use pattern that responds to projected growth, housing needs, changing demographics, and transportation demands. Thus, successful implementation of Connect SoCal 2024 would result in more complete communities with a variety of transportation and housing choices, while reducing automobile use. The following strategies are intended to be supportive of implementing the environmental goals of Connect SoCal 2024: Sustainable Development, Air Quality, Clean Transportation, Natural and Agricultural Lands Preservation, and Climate Resilience (SCAG 2024). An analysis of the Project’s compliance with the applicable strategies is presented below (Appendix A).
▪ Sustainable Development. Connect SoCal 2024 identifies sustainable development, including water and energy-efficient building practices and green infrastructure, as a strategy to reduce GHG emissions. Although this strategy would not apply to the Project, the Project would support increased usage of renewable electricity by allowing for a more reliable local electric grid and reducing reliance on natural gas power plants. ▪ Air Quality. Connect SoCal 2024 identifies air quality and meeting federal and state ambient air quality standards as a co-benefit of reducing GHG emissions. The Project would not exceed MDAQMD’s thresholds of significance for any criteria air pollutant during construction or operations and would not result in any significant impacts related to air quality. ▪ Clean Transportation. Connect SoCal 2024 identifies electric vehicle charging infrastructure, adoption of zero-emission vehicles, and clean transit as ways to reduce GHG emissions from mobile sources. The Project would not conflict with this strategy, as the BESS facility would be unstaffed and instead would include remote operational control and would only require only infrequent routine inspection and maintenance. Additionally off-site improvements within the existing Victor and Kramer Substations would not result in new operational vehicle trips.
▪ Natural and Agricultural Lands Preservation. Connect SoCal 2024 promotes the conservation and restoration of natural and agricultural lands through several policies, such as quantifying the carbon sequestration potential of natural and agricultural lands and prioritization of sensitive habitat and wildlife corridors for permanent protection. The Project would be consistent with the land use designations and zoning for the site and off-site improvement areas and would not conflict with this strategy.

Based on the analysis above, the Project would be consistent with the Connect SoCal 2024 (Appendix A). 650

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Potential to Conflict with the County Greenhouse Gas Reduction Plan An informal partnership, led by the San Bernardino Council of Governments (SBCOG), compiled a GHG emissions inventory and an evaluation of reduction measures that could be adopted by the 25 Partnership Cities of San Bernardino County, including the City of Adelanto, as part of the County GHGRP. The City of Adelanto selected a goal to reduce its community GHG emissions to a level that is 40% below its 2020 GHG emissions level by 2030, which the City is anticipated to meet and exceed subject to reduction measures that are technologically feasible and cost effective through a combination of state (~60%) and local (~40%) efforts (SBCOG 2021). Regarding off-site improvement areas, the City of Victorville selected a goal to reduce its community GHG emissions to a level that is 40% below its 2008 GHG emissions level by 2030, while the unincorporated County selected a goal to reduce its community GHG emissions to a level that is 40% below its 2020 GHG emissions level by 2030 (SBCOG 2021). The City of Victorville will meet and exceed its GHG goal for 2020 primarily through state measures (~75%) as well as through the selected local (~25%) measures while the unincorporated Couty will meet and exceed their goal through a combination of state (~80%) and local (~20%) efforts (SBCOG 2021). Of the state measures, the majority of reductions are in the building energy and on-road transportation sectors and for the local measures, the majority of reductions are in the building energy sector (SBCOG 2021). Overall, the Project would not conflict with the City of Adelanto’s, City of Victorville’s, or the unincorporated County’s reduction goals in the County GHGRP since the Project would provide additional capacity to the electrical grid and support the integration of additional intermittent renewable energy sources, such as wind and solar, which would increase grid reliability and reduce reliance on natural gas power plants (Appendix A).

Summary
The Project would not conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs, nor would it conflict with the relevant goals and objectives of any other local or regional plan. Thus, the Project would result in an impact that would be less than significant. The Project is therefore consistent with the findings disclosed in the Sustainable Plan EIR. Therefore, the Project would not result in any peculiar effects and would not result in a new or more severe adverse impact that was not previously identified in the prior EIR. Further, the Project would not result in an increase to significant effects as a result of new information not previously assessed in the Sustainable Plan EIR.

Conclusion
The proposed Project is consistent with the development evaluated in the Sustainable Plan EIR and would not result in any new impacts or increase the severity of any previously identified impacts as compared to what was already identified and disclosed, either individually or cumulatively. Further environmental analysis is not required because:

No peculiar impacts that are not substantially mitigated have been identified as a result of the proposed Project or its site.

There are no potentially significant impacts that were not analyzed as significant in the Sustainable Plan EIR.

There are no potentially significant off-site and/or cumulative impacts that were not discussed in the Sustainable Plan EIR.

No substantial new information has been identified that results in an impact that is more severe than anticipated by the in the Sustainable Plan EIR.
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3.9 Hazards and Hazardous Materials

Significant
Project Impact
Analyzed in
the Prior EIR
Substantial New
Information
IX. HAZARDS AND HAZARDOUS MATERIALS – Would the project:
a) Create a significant hazard to the public or the
environment through the routine transport, use, or
disposal of hazardous materials?
b) Create a significant hazard to the public or the
environment through reasonably foreseeable upset
and accident conditions involving the release of
hazardous materials into the environment?
c) Emit hazardous emissions or handle hazardous or
acutely hazardous materials, substances, or waste
within one-quarter mile of an existing or proposed
school?
d) Be located on a site that is included on a list of
hazardous materials sites compiled pursuant to
Government Code Section 65962.5 and, as a result,
would it create a significant hazard to the public or
the environment?
e) For a project located within an airport land use plan or, where such a plan has not been adopted, within
two miles of a public airport or public use airport,
would the project result in a safety hazard or
excessive noise for people residing or working in the
project area?
f) People residing or working in the Planning Area are
subject to safety hazards due to the Planning Area or
portions thereof being located within the vicinity of a private airstrip?
g) The program impairs implementation of or physically
interferes with an adopted emergency response plan
or emergency evacuation plan?
h) Expose people or structures, either directly or
indirectly, to a significant risk of loss, injury or death involving wildland fires?
Prior Environmental Impact Report Summary
Potential impacts due to hazards and hazardous materials were analyzed in the Sustainable Plan EIR on pages 4.8-1 through 4.8-22. Potential impacts related to the routine transport, use, or disposal of hazardous materials, the release of hazardous materials into the environment, hazardous emissions or materials near an existing or proposed school, development on a hazardous waste site, safety hazards relating to a location near a public or private airport, impairment or interference with an adopted emergency response plan or emergency evacuation plan, and exposure of people or structures to wildland fires were determined to be less than significant with the incorporation of Sustainable Plan Implementing Programs and uniformly applied development policies and standards. 652

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Applicable Policies
General Plan
Policy Safety 2.3: Requires environmental review for contaminated development sites.

Policy Safety 3.3: Minimizes fire hazards posed by expanding development in the wildland/urban intermix areas through the application of regulations found in the County’s Fire Safety Overlay Ordinance.

Sustainable Plan
Public Health and Safety Chapter
Goal HS 2: Property damage, injuries, and loss of life from fire are minimized.

Policy HS 2.1: Enforce building fire codes and ordinances, and continue to research and adopt best practices pertaining to fire management and fire hazards.

Goal HS 4: City residents, businesses, and employees are protected from potential hazards associated with the use, production, storage, disposal, and transport of hazardous materials.

Policy HS 4.1: Comply with all applicable local, State, and Federal regulations regarding the transport, use, and disposal of solid and hazardous waste.

Implementing Program HS-8: Environmental Assessments. Applications for new development projects requiring City discretionary approval shall include the results of a Phase I Environmental Site Assessment (ESA), prepared in accordance with the latest ASTM protocol for such assessments. If the Phase I ESA indicates some evidence of site contamination exists that could require cleanup to avoid danger to people or damage to the environment, a Phase II level review shall be completed to fully characterize the nature and extent of such contamination, and the scope of required clean up procedures. The results of the Phase II assessment shall be considered as part of the CEQA compliance process prior to any action on the project.

Implementing Program HS-25: Hazard Safety Demands. All proposals for businesses involved in hazardous materials use, storage, or transport areas must submit a Hazards Safety Plan to appropriate City agencies and the Fire Department for review of potential hazards.

Regulation, Standards, and Codes
2021 International Fire Code contains regulations to safeguard against fires and other hazards and addresses general precautions, emergency planning and preparedness, fire department access and water supplies, automatic sprinkler systems, fire alarm systems, special hazards, and other matters.

California Fire Code Battery energy storage systems are highly regulated under Chapter 12 of the California Fire Code. These regulations set strict standards for installation and operation of such systems, including internal fire detection and suppression systems and require hazard assessments prior to commercial operation.

Senate Bill 38 signed into law by Governor Newsome in October 2023, amended Section 761.3 of the California Public Utilities Code to address safety concerns with battery energy storage (BESS) facilities. The law requires that 653

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every battery energy storage facility located in California establish an emergency response and emergency action plan that covers the facility. The owner/operator of the facility must coordinate with local emergency management agencies, unified program agencies, and local first responders to develop the response and action plan, establish a notification and communication procedure, and consider potential off-site impacts to the surrounding community and environment.

NFPA 855 Standard for the Installation of Stationary Energy Storage Systems provides the minimum requirements for mitigating the hazards associated with energy storage systems. The design, installation, commissioning, operation, maintenance and decommissioning of energy storage Facilities must comply with standards outlined by NFPA 855. The standard includes site design standards such as maximum energy and spacing between units.

Compliance with these standards is documented through several studies and reports that must be submitted to the regulating governmental entity, including (1) Hazard Mitigation Analysis (HMA), (2) Emergency Response Plan, (3) details of all safety systems, and more.

UL 9540 is the safety standard for energy storage equipment, including batteries, that is required under NFPA 855.

NFPA 855 requires that batteries included in energy storage projects are listed to the safety specifications included in UL 9540 and undergo rigorous fire testing. This standard ensures that equipment incorporated into battery energy storage facilities are tested, certified and safe for operation on the electric grid Project-Specific Analysis
a) Would the project create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials?
The Sustainable Plan EIR evaluated whether the full buildout of the Plan area anticipated under the Sustainable Plan would result in a significant hazardous materials impact related to the routine transport, use, or disposal of hazardous materials. The Sustainable Plan EIR determined impacts would be less than significant.

The analysis under the Sustainable Plan EIR remains accurate with respect to the proposed Project, which would develop a BESS facility consistent with zoning and in accordance with the provisions of the Sustainable Plan. The proposed Project involves the transport, use, or disposal of typical hazardous materials (e.g., diesel fuels, lubricants, solvents, asphalt, pesticides) during construction and operation, although hazardous materials would not be accepted at the facility.

The proposed Project would be required to comply with all applicable federal, state, and local laws and regulations related to the safe transport, use, and disposal of hazardous materials, including the standards for solid waste handling and disposal set forth in Title 22 of the California Code of Regulations and the Hazardous Materials Transportation Act, among others (City of Adelanto 2014b). The proposed Project (including off-site improvements) would also be subject to the Hazardous Materials Disclosure Program managed by the Certified Unified Program Agency (CUPA) for the City of Adelanto, City of Victorville, and unincorporated County of San Bernadino, which is the San Bernardino County Fire Department Hazardous Materials Division (HMD). During Project operations, minimal amounts of hazardous materials would be present under normal conditions, and regular operation and maintenance of the Project would not result in significant impacts involving use, storage, transport or disposal of hazardous wastes and substances. A Phase IZ ESA (Appendix F) was prepared for the Project site, in accordance with Implementing Program HS8. The Phase I ESA determined no listings were identified on the subject property or any adjoining or surrounding properties that might indicate a release that might have impacted the environmental condition 654

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of the subject property. Further, the assessment did not reveal evidence of recognized environmental condition (RECs), historical RECs (HRECs), controlled RECs (CRECs), or vapor encroachment conditions (VECs) on the Project site (Appendix F). Additionally, the Project site, the SCE Kramer Substation, and the SCE Victor Substation are not included on the list of hazardous waste sites (Cortese List) complied by the Department of Toxic Substances Control (DTSC) pursuant to Government Code Section 65962.5 and therefore would not release known hazardous materials due to ground-disturbing activities (DTSC 2024; SWRCB 2024).

Both the Environmental Protection Agency (EPA) and the U.S. Department of Transportation (DOT) regulate the transport of hazardous waste and material, including transport via highway. The U.S. EPA administers permitting, tracking, reporting, and operations requirements established by the Resource Conservation and Recovery Act. The DOT regulates the transportation of hazardous materials through enforcement of the Hazardous Materials Transportation Act. This act includes requirements for container design and labeling, as well as for driver training. The established regulations are intended to track and manage the safe interstate transportation of hazardous materials and waste. Additionally, state and local agencies enforce the application of these acts and coordinate safety and mitigation responses in the case that accidents involving hazardous materials occur.

The proposed Project does not propose or facilitate any activity involving significant use, routine transport, or disposal of hazardous substances. The use and handling of hazardous materials during construction and operation would occur in accordance with applicable federal, state, and local laws, including California Division of Occupational Safety and Health (Cal/OSHA) requirements. Given the above, impacts are expected to be less than significant.

As such, impacts associated with the development of the proposed Project would be consistent with the analysis in the Sustainable Plan EIR and the proposed Project would not result in any impacts that would not be mitigated to a less-than-significant level through application of Implementing Programs and uniformly applied development policies and standards. Therefore, the proposed Project would not result in any peculiar effects and would not result in a new or more severe adverse impact that was not previously identified in the Sustainable Plan EIR. Further, the Project would not result in an increase to significant effects as a result of new information not previously assessed in the Sustainable Plan EIR. b) Would the project create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment? The Sustainable Plan EIR evaluated whether full buildout of the development anticipated under the Plan would create a substantial hazard to the public or the environment through reasonably foreseeable upset or accident conditions involving the release of hazardous materials into the environment and determined impacts would be less than significant.

The analysis under the Sustainable Plan EIR remains accurate with respect to the proposed Project, which would develop a BESS facility consistent with zoning and in accordance with the provisions of the Sustainable Plan. Additionally, numerous nationally and internationally recognized standards and codes have been developed to inform safe manufacturing, construction, installation, and operation of energy storage systems as listed below.
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Construction of the Project is not expected to result in the release of hazardous materials into the environment. A Phase I ESA (Appendix F) was prepared for the Project site, in accordance with Implementing Program HS-8. The Phase I ESA determined no listings were identified on the subject property or any adjoining or surrounding properties that might indicate a release that might have impacted the environmental condition of the subject property. Further, the assessment did not reveal evidence of recognized environmental condition (RECs), historical RECs (HRECs), controlled RECs (CRECs), or vapor encroachment conditions (VECs) on the Project site (Appendix F).

All BESS facilities contain quantities of hazardous materials, and in the event of an emergency or failure, can potentially create a toxic environment. BESS facility failure can occur due to thermal abuse, physical/mechanical damage, electrical abuse, environmental impacts, internal faults within the battery cell, and other electrical faults or system failures, etc.

During normal operations of the Project, there would be the potential for hazards and accidents typical with that of other BESS operations. These hazards and potential accidents, while infrequent and minimized through routine maintenance and inspection, include, but are not limited to fires, explosions, and the release of toxic gases. The primary potential upset and accident condition for the Project would be the risk of a thermal runaway event occurring, where the system increases in temperature, in turn releasing energy that further increases temperature. This could potentially cause a fire due to the overheating of the battery system. A fire may release toxic chemicals into the air and atmosphere.

Dudek prepared a Hazardous Consequence Analysis for the proposed Project in May 2024 (attached as Appendix B) evaluating the potential for a thermal runaway event to occur and the potential impacts that may result from a worst-case thermal runaway event. In the analysis, Dudek found that the applicable EPA thresholds may be exceeded up to approximately 81 feet from the thermal runaway event toxic release (Appendix B). However, the closest sensitive receptor identified (Copart) is located approximately 1,075 feet away from the closest BESS cabinet, and therefore no existing sensitive receptors would be exposed to concentrations at or above the EPA threshold levels (Appendix B). Land located south of Holly Road is zoned for residential; however, no residences are currently built in that area which is within the Growth Area 2 boundary. The Project site is within Growth Area 1, which is prioritized for development prior to Growth Area 2. It is currently unknown if and when residential development may occur south of Holly Road, adjacent to the Project site. Future residential property lines would be at least 93 feet from the nearest battery container, which would exceed the 81-foot range of a significant hazard impact from a thermal runaway event. Additionally, the proposed Project would incorporate a fire suppression system to limit the risk of a release of toxic chemicals from fire. As such, potential impacts from thermal runway of battery modules off site would be less than significant.

The proposed Project, including off-site improvements within the existing Victor and Kramer Substations and within the existing transmission lines rights-of-way, would also be required to comply with all federal, state, and local requirements relating to Project design, operations, and accident responses. Further, the Project would be subject to and implemented in accordance with the National Fire Protection Association (NFPA), Occupational Safety and Health Administration, the California Fire Code, and California Environmental Protection Agency requirements. In addition, fire detection measures are intrinsically incorporated in the Project design in accordance with National Fire Protection Association safety standards. The proposed BESS would also be equipped with monitoring and control systems, fire detection and protection systems, and gas ventilation systems, among others, to prevent, monitor, and/or control 656

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any battery cell malfunctions. During normal operations, there will be no toxic air emissions from the Project (Appendix B).

All federal, state, and local hazardous waste laws and regulations would be followed. As such, impacts associated with the development of the proposed Project within the Sustainable Plan area would be consistent with the analysis in the Sustainable Plan EIR and the proposed Project would not result in any impacts that would not be reduced to a less-than-significant level with the implementation of existing regulations. Therefore, the proposed Project would not result in any peculiar effects and would not result in a new or more severe adverse impact that was not identified in the previous EIR. Further, the Project would not result in an increase to significant effects as a result of new information not previously assessed in the Sustainable Plan EIR.
c) Would the project emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school? The Sustainable Plan EIR evaluated whether the development allowed under the Plan would emit hazardous substances or involve handling hazardous or acutely hazardous substances or waste within 0.25 miles of an existing or proposed school and determined this would be a less-than-significant impact.

There are no schools within 0.25 miles of the Project site. The nearest school is Adelanto High School, located approximately 0.61 miles south of the Project site. However, the Mojave River Academy, West Victorville (12384 Palmdale Road, Victorville, California, 92392) is located approximately 0.11 miles northwest of the SCE Kramer Substation and within approximately 100 feet of existing transmission lines rights-of-way along Palmdale Road. The proposed Project would adhere to all applicable federal, state, and local laws and regulations related to the handling of hazardous substances. As such, impacts associated with the development of the proposed Project would be consistent with the analysis in the Sustainable Plan EIR and the proposed Project would not result in any significant impacts. Therefore, the proposed Project would not result in any peculiar effects and would not result in a new or more severe adverse impact that was not previously identified in the previous EIR. Further, the Project would not result in an increase to significant effects as a result of new information not previously assessed in the Sustainable Plan EIR. d) Would the project be located on a site that is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment?
The Sustainable Plan EIR contemplated development on sites located on the Cortese List of hazardous materials and determined that impacts would be less than significant with the incorporation of Implementing Program HS-8. According to a search on the Department of Toxic Substances Control EnviroStor Database, the Project site and off-site improvement areas are not included on the list of hazardous waste sites (DTSC 2024; SWRCB 2024). A Phase I ESA was conducted in accordance with Implementing Program HS-8. The Phase I ESA determined no listings were identified on the subject property or any adjoining or surrounding properties that might indicate a release that might have impacted the environmental condition of the subject property. Further, the assessment did not reveal evidence of recognized environmental condition (RECs), historical RECs (HRECs), controlled RECs (CRECs), or vapor encroachment conditions (VECs) on the Project site (Appendix F). Therefore, the proposed Project would not result in any peculiar effects and would not result in a new or more severe adverse impact that was not 657

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previously identified in the prior EIRs. Further, the Project would not result in an increase to significant effects as a result of new information not previously assessed in the Sustainable Plan EIR. e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area? -andf) People residing or working in the Planning Area are subject to safety hazards due to the Planning Area or portions thereof being located within the vicinity of a private airstrip? The Sustainable Plan EIR evaluated potential impacts to the Southern California Logistic Airport, the Adelanto Airport, and the IMPA Adelanto Heliport and determined impacts would be less than significant with implementation of existing standards ad recommendations. The nearest airport, the privately owned Adelanto Residential Airpark, is approximately 1 mile southwest of the Project site. Construction and operation of the proposed Project would not contribute to an air traffic hazard or otherwise interfere with the operation of the private airstrip; the height of the batteries is limited to approximately 12 feet, and there are no light, glint, or glare characteristics related to batteries. Changes or improvements to transmission lines are to existing poles and wires, and/or within existing transmission rights-of-way, and will adhere to all applicable laws and regulations related to height, notifications, and appropriate lighting where applicable. In addition, the Project would not create a safety hazard or excessive noise for people working in the Project area. During operations, employees would travel to the site intermittently for maintenance activities; however, these activities would not conflict with the operation of, or interfere with, the use of the private airstrip. The proposed Project would not result in any peculiar effects and would not result in a new or more severe adverse impact that was not previously identified in the Sustainable Plan EIR. Further, the Project would not result in an increase to significant effects as a result of new information not previously assessed in the Sustainable Plan EIR.
g) Would the project impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?
The Sustainable Plan EIR evaluated whether development under the Plan would impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan. The Plan EIR determined no impact would occur since no physical changes to the organization of the Planning Area would occur.

The analysis under the Sustainable Plan EIR remains accurate with respect to the proposed Project, which would develop existing vacant parcel into a BESS facility consistent with zoning and in accordance with the provisions of the Sustainable Plan. Access to the Project site would be from two new driveways: one off Racoon Road and one off Holly Road. Development of the Project would not interfere with the City’s emergency response or evaluation procedures pursuant to the National Incident Management System, Standardized Emergency Management System, of the City’s response plan. These disaster response procedures are designed to be flexible in nature in order to adapt to the volatile and unpredictable nature of disasters and hazards. This allows the City to respond to varying emergencies regardless of location, size, or number of persons affected. See additional discussion in Section 3.15, Public Services, regarding police and fire services, and details related to uniformly applied standards and regulations such as NFPA 658

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855 and SB 38 which requires battery storage facilities to develop an emergency response plan in close coordination with local emergency response agencies, to establish a notification and communication procedure, and consider potential off-site impacts to the surrounding community and environment.

Furthermore, off-site improvements located within the existing Kramer and Victor Substation footprints and within the existing transmission line rights-of-way would not interfere with implementation of the San Bernadino County Emergency Operations Plan or emergency and evacuation procedures set forth in the City of Victorville General Plan. The proposed Project would not result in an increase in population beyond what is envisioned in the Sustainable General Plan. As such, impacts associated with the development of the proposed Project would be consistent with the analysis of the Sustainable Plan EIR and would have no impact. Therefore, the proposed Project would not result in any peculiar effects and would not result in a new or more severe adverse impact that was not previously identified in the prior EIR. Further, the Project would not result in an increase to significant effects as a result of new information not previously assessed in the Sustainable Plan EIR.
h) Would the project expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires?
The Sustainable Plane EIR did not identify any potentially significant effects related to the loss, injury, or death involving wildfires. The City of Adelanto, City of Victorville, and County of San Bernadino have adopted Section 701A of the California Building Code to minimize the potential for property destruction due to wildland fires by requiring materials and construction methods that are fire resistant. The Project applicant would be required to coordinate with the San Bernardino Fire Department as part of the entitlement process and design in accordance with their requirements for access, defensible space, fire protection and response, and the like. The Project will be required to comply with applicable building and fire code, including NFPA 855, and prepare an emergency response plan in close coordination with local emergency response agencies, to establish a notification and communication procedure, and consider potential offsite impacts to the surrounding community and environment consistent with SB 38. The Project would also be required to pay all applicable fair share costs and fees if applicable. See additional discussion in Section

3.15 for more information regarding Fire response. Therefore, impacts related to the development of the proposed Project would be consistent with the analysis of the Sustainable Plan EIR and the proposed Project would have less-than-significant impacts in this regard, and the proposed Project would not result in any peculiar effects and would not result in a more severe adverse impact that was not previously identified in the prior EIR. Further, the Project would not result in an increase to significant effects as a result of new information not previously assessed in the Sustainable Plan EIR.

Conclusion
The proposed Project is consistent with the development evaluated in the Sustainable Plan EIR and would not result in new impacts or increase the severity of previously identified impacts as compared to what was already identified and disclosed, either individually or cumulatively. Further environmental analysis is not required because:

No peculiar impacts that are not substantially mitigated have been identified as a result of the proposed Project or its site.

There are no potentially significant impacts that were not analyzed as significant in the Sustainable Plan EIR.

There are no potentially significant off-site and/or cumulative impacts that were not discussed in the Sustainable Plan EIR.
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No substantial new information has been identified that results in an impact that is more severe than anticipated by the in the Sustainable Plan EIR.

3.10 Hydrology and Water Quality
Significant
Project Impact
Analyzed in
the Prior EIR
Substantial New
Information
X. HYDROLOGY AND WATER QUALITY – Would the project:
a) Violate any water quality standards or waste
discharge requirements or otherwise substantially
degrade surface or ground water quality?
b) Substantially decrease groundwater supplies or
interfere substantially with groundwater recharge
such that the project may impede sustainable
groundwater management of the basin?
c) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the
course of a stream or river or through the addition of
impervious surfaces, in a manner which would:
i) result in substantial erosion or siltation on- or offsite; ii) substantially increase the rate or amount of
surface runoff in a manner which would result in
flooding on- or off site;
iii) create or contribute runoff water which would
exceed the capacity of existing or planned
stormwater drainage systems or provide
substantial additional sources of polluted runoff;
or
iv) impede or redirect flood flows?
d) In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation?
e) Conflict with or obstruct implementation of a water
quality control plan or sustainable groundwater
management plan?
Prior Environmental Impact Report Summary
Potential impacts to hydrology and water quality were analyzed in the Sustainable Plan EIR on pages 4.9-1 through

4.9-22. The Sustainable Plan EIR found impacts to be less than significant with the incorporation of existing standards and regulations, and Sustainable Plan policies.

Applicable Policies
General Plan
Goal WQ 3: To assure that storm runoff in industrial sectors of the Planning Area does not contaminate the groundwater resources of the Planning Area.
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Municipal Code
Chapter 14.12, California Codes: The City has adopted the 2010 California Building Code (CBC) and other applicable codes pursuant to this Chapter. The CBC includes grading and erosion control provisions requiring implementation of erosion control measures, as necessary.

Chapter 17.93, Erosion and Sediment Control: The purpose of this chapter is to eliminate and prevent accelerated erosion that has led to, or could lead to, degradation of water quality, loss of fish habitat, damage to property, loss of topsoil and vegetation cover, disruption of water supply, increased danger from flooding and the deposition of sediments and association nutrients.

Sustainable Plan
Open Space and Conservation Chapter
Goal OS 4: Water consumption is reduced through aggressive implementation of conservation policies and programs.

Policy OS 4.1: Require the use of water conserving appliances and fixtures in new development per CALGreen building requirements.

Goal OS 5: Land use and water supply planning processes are coordinated so that adequate water supplies are available for proposed development.

Policy OS 5.1: Require new development outside of the boundary of Growth Area 1 to demonstrate that adequate water is available before project approval and to fund its fair-share costs associated with the provision of water service.

Policy OS 5.2: Access reliable data and information on water use and supply to thoroughly evaluate the potential water supply impacts and needs of proposed development projects and promote effective decision-making.

Public Services and Infrastructure Chapter
Goal PF 1: Sufficient water sources and quality to meet current and projected use requirements.

Goal PF 5: Storm drainage and flood control facilities provide life protection and structure protection against flooding.

Policy PF 5.4: Encourage developers to minimize impervious surfaces to reduce storm water runoff and increase flood protection.

Policy PF 5.6: Enforce requirements for new constructions’ protection against flooding.

Goal PF 6: Sustainable storm water management practices.

Policy PF 6.1: Promote open channels with soft earthen bottoms allowing for increased infiltration and provide a natural habitat.
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Policy PF 6.4: Ensure developers comply with current standards for stormwater management and consistent with State Water Resources Control Board requirements.

Policy PF 6.6: Encourage storm water sustainable designs by developers.

Implementing Program PF-3: Water Efficient and Sustainable Designs. Through the development review process and community outreach programs, encourage developers and residents to utilize water and stormwater efficient practices. Developers shall implement water efficient irrigation and the use of drought tolerant plants. Residents should be encouraged to minimize irrigation and consider landscaping that requires less irrigation.

Implementing Program PF-6: Storm Water Sustainability. Through the development application review process, strongly encourage the treatment and re-use storm water on site trough bio-filtration, bio-retention, and storm water re-use.

Implementing Program PF-7: Water Quality Management. Through the development application review process, ensure future development complies with the latest water quality standards. For applicable projects, builders, developers, or agencies engaging in construction must prepare a Storm Water Pollution Prevention Plan (SWPPP), implement Best Management Practices (BMPs), and monitor storm water discharges against specified water quality standards.

Public Health and Safety Chapter
Policy HS 5.2: Ensure emergency preparedness for all critical infrastructure including potable water, wastewater, stormwater, recycled water, telecommunications, energy, and streets.

Project-Specific Analysis
a) Would the project violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality?
The Sustainable Plan EIR evaluated the potential for full build out of the Plan area to violate water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality and determined there would be a less-than-significant impact in this regard with implementation of existing regional water quality regulations and the City’s local water quality control standards for new development and redevelopment.

The analysis under the Sustainable Plan EIR remains accurate with respect to the proposed Project, which would develop a BESS facility consistent with zoning and in accordance with the provisions of the Sustainable Plan. Furthermore, according to the Preliminary Hydrology and Water Quality Study (Hydrology and Water Quality Study) (Appendix G) prepared for the proposed Project, while the exact amount of earthwork and grading is unknown, it is assumed that grading will take place to create level pads for Project infrastructure. While site preparation and grading are occurring, soil erosion may result in discharges of sediment-laden stormwater runoff downstream of the site. Construction could temporarily concentrate flows from storms and construction water usage, thus resulting in increased sedimentation and erosion of existing soils (Appendix G).

The Hydrology and Water Quality Study states that BMPs such as fiber rolls and gravel bag barriers would limit the increase in sedimentation and siltation from construction activities on the Project site which could otherwise temporarily violate Lahontan Basin Plan objectives for sediment. Excessive sedimentation could 662

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impair the protection of the beneficial uses of downstream intermittent drainages. In addition to sediment, other pollutants associated with construction activity could include heavy metals, oil/grease, fuels, trash, and other pollutants from accidental spills or releases of refuse, paints, solvents, sanitary wastes, and concrete curing compounds. BMPs such as drip pans and proper waste management would be used during construction to reduce pollutant and/or sediment mobilization to ensure compliance with Lahontan Basin Plan objectives and protection of beneficial uses (Appendix G). Furthermore, as detailed in the Sustainable Plan EIR, the Construction General Permit Order 2009-0009-DWQ regulates stormwater runoff from construction sites and requires post-construction BMPs and includes performance standards specifically to address water quality and channel protection events. The General Permit requires that post-construction runoff match pre-Project runoff water balance (City of Adelanto 2014b).

Ground disturbance in off-site areas would be minimal and would be limited to previously disturbed and developed areas within the Victor and Kramer Substation footprints and the transmission lines rights-ofway. However, improvements in off-site areas would also be required to adhere to the Construction General Permit Order 2009-0009-DWQ, as well as City of Victorville Municipal Code Chapter 10.30, Stormwater and Urban Runoff Management and Discharge Control (for off-site improvements in the City of Victorville) or San Bernardino County Code Division 5, Chapter 1, Pollutant Discharge Elimination System Regulations. (for improvements in the unincorporated County), which would reduce potential impacts related to stormwater runoff.

In addition, the Hydrology and Water Quality Study states that a Stormwater Pollution Prevention Plan (SWPPP) would be prepared for the proposed Project to address potential construction-related impacts on water quality. A SWPPP’s minimum standard BMPs include erosion and sediment controls; site management/housekeeping/waste management; management of non-stormwater discharges; run-on and runoff controls; and BMP inspection, maintenance, and repair activities. The SWPPP will also include a construction site monitoring program that identifies specific requirements for dry weather visual observations of pollutants at all discharge locations, and any additional measures, as appropriate. The applicant’s erosion control plan should include the placement of fiber rolls around the perimeter of disturbed areas to filter out sediment, debris, and floatable material; use of hazardous material spill kits; and stabilized construction zone ingress/egress. Upon implementation of BMPs, the construction-related impact of the Project on water quality would be less than significant (Appendix G).

Based on the City’s requirements and on the conditions of the Construction General Permit Order 2009- 0009-DWQ, appropriate BMPs would be implemented to prevent the discharge of sediment and polluted surface water during construction of the Project. The only post-construction BMP that would be required for Project operations is the construction of retention areas in both the northern and southern development areas which would be designed to capture and retain 3 and 4.7 acre-feet of water in the northern and southern development areas, respectively. Project operations would comply with all RWQCB regulations and standards. The detention basins constructed would limit discharge from the Project site (Appendix G).

Given the above, impacts associated with the development of the proposed Project within the Sustainable Plan area would be consistent with the analysis in the Plan EIR and the Project would result in less-thansignificant impacts both in construction and operation. Therefore, the Project would not result in any peculiar effects and would not result in a new or more severe adverse impact, or a potentially significant off-site or cumulative impact, that was not previously identified in the prior EIR. Further, the Project would not result in an increase to significant effects as a result of new information not previously assessed in the Sustainable Plan EIR.
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b) Substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin? The Sustainable Plan EIR evaluated the potential for full build out of the Plan area to substantially decrease groundwater supplies or interfere substantially with groundwater recharge and determined there would be a less-than-significant impact in this regard with implementation of existing standards and regulations including applicable Urban Water Management Plan (UWMP) programs for the long-term management of area groundwater basins (where the City draws its water from), existing General Plan policies that support water conservation through use of natural and drought-tolerant vegetation, and City Water Department policies and programs designed to ensure groundwater is recharged both through natural and assisted means. Furthermore, the Sustainable Plan includes additional water conservation goals and policies including the use of water efficient fixtures, drought-tolerant landscaping, and increased use of recycled water to conserve groundwater supplies from which the City draws its water supplies from. The proposed Project site is within the Upper Mojave River Groundwater Basin, which is an adjudicated basin that has established safe yield limits to prevent over-drafting of groundwater. The Sustainable Plan does not include policies that would interfere with this determination or enforcement of the Basin’s safe yield limits.

Therefore, upon implementation of these applicable standards and regulations, potential impacts to groundwater would be less than significant (City of Adelanto 2014b).

The analysis under the Sustainable Plan EIR remains accurate with respect to the proposed Project, which would develop a BESS facility consistent with zoning and in accordance with the provisions of the Sustainable Plan and would occur within the Plan area previously evaluated. Furthermore, the Hydrology and Water Quality Study states that construction and operational water would be provided by on-site groundwater through an improved existing well, a new well permitted and drilled (if necessary), or through off-site source delivered by truck. The Project site is within the adjudicated Upper Mojave River Groundwater Basin which is managed by a court-appointed water master and is designated as very low priority. Project water demand is expected to be minimal and is not anticipated to substantially deplete groundwater supplies and the Project will not use groundwater or public water supplies (Appendix G). With respect to groundwater recharge, the Project site is currently undeveloped, and the surface is pervious, allowing groundwater recharge of all runoff. The Project would introduce 25 acres of new impervious surfaces which could decrease the amount of groundwater recharge within the Project site. However, the proposed installation of a retention basin in the northern corner of the site is expected to mitigate this impact by allowing the runoff generated by the impervious area to collect and infiltrate in a new location. As a result, the Project would not interfere substantially with groundwater recharge (Appendix G). Ground disturbance in off-site areas would be minimal and would be limited to previously disturbed and developed areas within the Victor and Kramer Substation footprints and the transmission lines rights-of-way and thus would not be anticipated to decrease groundwater supplies or interfere substantially with groundwater recharge.

As such, impacts associated with the development of the proposed Project within the Sustainable Plan area would be consistent with the analysis in the Plan EIR and the Project would result in less-than-significant impacts. Therefore, the proposed Project would not result in any peculiar effects and would not result in a new or more severe adverse impact that was not previously identified in the previous EIR. Further, the Project would not result in an increase to significant effects as a result of new information not previously assessed in the Sustainable Plan EIR.
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c) Would the project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would:
i) Result in substantial erosion or siltation on- or off-site? The Sustainable Plan EIR evaluated the potential for full build out of the Plan area to result in substantial erosion or siltation on or off site and determined impacts would be less than significant with implementation of existing City standards.

The Sustainable Plan EIR states that the construction of the land uses included in buildout of the Plan area, could potentially result in erosion and siltation impacts as a result of alteration of natural drainage patterns, and that siltation is typically associated with site grading and deforestation. However, the potential for the alteration of drainage patterns only exists within the Sustainable Plan’s Desert Living Zoning District, which the Project site is not located in. Furthermore, as discussed previously, the Sustainable Plan incorporates Goal PF 6, and Policies PF 6.1, 6.4 and 6.6, and Implementing Programs PF-3, PF-6, and PF-7, along with uniformly applied standards. Implementation of these goals, policies, implementation programs and standards ensures that drainage facilities are designed to effectively contain stormwater on site and within existing drainage patterns and thereby minimize on-site and off-site flooding due to development associated with changes in drainage patterns (City of Adelanto 2014b). Therefore, impacts related to drainage and on- or off-site flooding, erosion, or sedimentation would be less than significant.

The analysis under the Sustainable Plan EIR remains accurate with respect to the proposed Project, which would develop a BESS facility consistent with zoning and in accordance with the provisions of the Sustainable Plan and uniformly applied standards. Furthermore, as detailed in the Hydrology and Water Quality Study, the existing hydrological conditions would be preserved in a similar manner, and a proposed

5.3-acre-foot infiltration basin would be built into the northeastern portion of the Project site to retain additional runoff from the increase in impervious surfaces on the Project site. Water will be channeled towards the retention area along the northern boundary of the site through a series of 6-foot-wide drainage swales. In addition, compliance with the requirement for a SWPPP and incorporation of BMPs would limit the sedimentation/siltation from construction on the Project site that could otherwise temporarily violate Lahontan Basin Plan objectives for sediment. Upon incorporation of the proposed retention basin and BMPs, potential erosion, siltation, runoff, or flooding impacts would be reduced to a level of less than significant (Appendix G). As noted above, the Project would be required to implement City erosion standards and the Construction General Permit, as well as all other applicable regulatory requirements. Furthermore, off-site improvements within previously developed areas such as the existing Victor and Kramer Substation footprints as well as improvements within the existing transmission line rights-of-way would be required to adhere to applicable BMPs related to siltation and erosion control set forth in the City of Victorville Municipal Code (e.g., Chapter 10.30, Storm Water and Urban Runoff Management and Discharge Control) or San Bernadino County Code (e.g., Chapter 88.02, Soil and Water Conservation and Chapter 85.11, PreConstruction Flood Hazard Mitigation and Erosion Control Inspection) (City of Victorville 2024a; County of San Bernadino 2024a). Compliance with applicable regulations and standards and the construction of an on-site retention basin would ensure potential impacts related to flooding and erosion or siltation on or off site are less than significant.

As such, impacts associated with the development of the proposed Project within the Sustainable Plan area would be consistent with the analysis in the Plan EIR and the Project would result in less-than-significant 665

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impacts. Therefore, the proposed Project would not result in any peculiar effects and would not result in a new or more severe adverse impact that was not identified in the previous EIR. Further, the Project would not result in an increase to significant effects as a result of new information not previously assessed in the Sustainable Plan EIR.
ii) Substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off site?
The Sustainable Plan EIR evaluated the potential for full build out of the Plan area to result in substantial flooding on or off site and determined impacts would be less than significant with implementation of existing City standards. As discussed in the Sustainable Plan EIR and Section 3.10(c)(i) above, the proposed Project would be required to implement City erosion standards and comply with the City’s Master Plan of Drainage and the Construction General Permit, as well as all other applicable regulatory requirements. In addition, as mentioned in the Hydrology and Water Quality Study, the proposed Project would construct an on-site retention basin in the northern portion of the Project site to accommodate increased flow of runoff from the Project’s addition of impervious surfaces on site. The incorporation of existing City standards and regulations mentioned above during- and post-construction, and the site’s proposed stormwater design inclusive of such things as avoiding an existing drainage and installing a retention basin, would reduce impacts related to flooding on or off site to a less-than-significant level (City of Adelanto 2014b). Therefore, potential flooding impacts would be less than significant.

The analysis under the Sustainable Plan EIR remains accurate with respect to the proposed Project, which would develop a BESS facility consistent with zoning and in accordance with the provisions of the Sustainable Plan and would occur within the Plan area previously evaluated. The Project would construct and maintain an on-site retention basin to handle increased levels of runoff on the Project site. The basin would be constructed to meet all regulatory standards and requirements, which would reduce any potential of on- or off-site flooding to less than significant. Improvements in off-site areas would be minimal and would be limited to previously disturbed and developed areas within the Victor and Kramer Substation footprints and the transmission lines rights-of-way. These improvements would not result in new impervious surface area through expansion of paved areas or by other means and thus would not be anticipated to increase the rate or amount of surface runoff.

As such, impacts associated with the development of the proposed Project within the Sustainable Plan area would be consistent with the analysis in the Plan EIR and the Project would result in less-than-significant impacts. Therefore, the proposed Project would not result in any peculiar effects and would not result in a new or more severe adverse impact that was not previously identified in the previous EIR. Further, the Project would not result in an increase to significant effects as a result of new information not previously assessed in the Sustainable Plan EIR.
iii) Create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff? The Sustainable Plan EIR evaluated the potential for full build out of the Plan area to create or contribute runoff water that would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff and determined there would be a less-than-significant impact with implementation of existing standards and regulations. As mentioned above, construction of impervious surfaces would cause increased runoff rates and volumes on the Project site. The Sustainable 666

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Plan EIR states that there is no extensive storm drainage system within the Plan area and that drainage improvements are handled on a project-by-project basis in accordance with the City’s Master Plan of Drainage which describes two methods for addressing high water velocities within the channels: armor all sides of the channels or use drop structures to reduce the velocity to non-erosive levels. Furthermore, the Master Plan of Drainage includes development impact fees (Section 14.36.040) to pay for operation, administration, maintenance, improvement, environmental restoration, and replacement of the existing and future storm drainage system. The Sustainable Plan also includes policies and Implementing Programs that encourage the retention and infiltration of stormwater. The incorporation of existing City standards and regulations mentioned above (and as discussed in response to item ii above), would reduce impacts related to runoff water to a less-than-significant level (City of Adelanto 2014b). Therefore, potential runoff water impacts would be less than significant.

The analysis under the Sustainable Plan EIR remains accurate with respect to the proposed Project, which would develop a BESS facility consistent with zoning and in accordance with the provisions of the Sustainable Plan. The development of the Project site’s vacant land would increase impervious surfaces.. As discussed above, the Project would construct an on-site retention basin to handle the increased runoff on the Project site and would be required to implement existing standards and regulations. In addition, existing freeboard requirements and the placement of BESS containers on concrete pads or foundations would ensure that any equipment proposed within the Project area will be sufficiently elevated above floodwaters and would not release pollutants during flooding (Appendix G). As discussed above, off-site improvements would not result in new impervious surface area through expansion of paved areas or by other means and thus would not be anticipated to contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff.

Accordingly, adherence to the goals and Implementing Programs of the Sustainable Plan EIR, and with uniformly applied development standards, and project design, including the proposed retention basin for example, the proposed Project would not result in a significant increase in off-site storm drainage such that existing facilities would be overburdened. As such, impacts associated with the development of the proposed Project within the Sustainable Plan area would be consistent with the analysis in the Plan EIR and the Project would result in less-than-significant impacts. Therefore, the proposed Project would not result in any peculiar effects and would not result in a new or more severe adverse impact that was not previously identified in the previous EIR. Further, the Project would not result in an increase to significant effects as a result of new information not previously assessed in the Sustainable Plan EIR. iv) Impede or redirect flood flows?
The Sustainable Plan EIR did not directly analyze this impact threshold. However, the Hydrology and Water Quality Study prepared for the proposed Project did evaluate this threshold and found the Project, as designed, would avoid the drainage located in the northwestern portion of the Project site, and that this condition would be preserved after completion of the Project. The Project would introduce 25 acres of new imperious surfaces on site but would mitigate the effects of increased runoff with the construction of 5.3- acre-foot infiltration basin in the northeastern portion of the Project site to retain the addition runoff. As discussed above, off-site improvements would not result in new impervious surface area through expansion of paved areas or by other means and thus would not be anticipated to impede or redirect flood flows.

Therefore, impacts relating to flood flows would be less than significant. The proposed Project would not result in any peculiar effects and would not result in a new or more severe adverse impact that was not 667

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previously identified in the previous EIR. Further, the Project would not result in an increase to significant effects as a result of new information not previously assessed in the Sustainable Plan EIR. d) In flood hazard, tsunami, or seiche zones, would the project risk release of pollutants due to project inundation?
The Sustainable Plan EIR evaluated the potential for full build out of the Plan area to result in mudflows, tsunami, and seiche and determined there would be a less-than-significant impact with implementation of existing City standards and regulations. Due to the Sustainable Plan area’s distance from the Pacific Ocean, no portion of the City is subject to tsunami hazards and there are no open reservoirs or other bodies of water within the Plan area that could expose development to seiche hazards (City of Adelanto 2014b). See Section 3.10(c) above for more details.

The analysis under the Sustainable Plan EIR remains accurate with respect to the proposed Project, which would develop an industrial BESS facility in accordance with the provisions of the Sustainable Plan and would occur within the Plan area previously evaluated. Furthermore, the Project site as well as the Victor Substation are located within FEMA Flood Zone X, an area of minimal flood hazard, and would not be subject to a substantial risk of flooding (FEMA 2024). The Kramer Substation is located in Flood Zone D, an area where there are possible but undetermined flood hazards or unstudied areas (FEMA 2024). However, offsite improvements within Flood Zone D areas would occur within the previously developed Kramer Substation footprint or within the existing transmission line rights-of-way and would not be anticipated to result in a flood hazard. In addition, the Project would construct an infiltration basin to accommodate increased runoff on the Project site. Therefore, the risk of release of pollutants due to inundation of the Project site would be less than significant.

As such, impacts associated with the development of the proposed Project within the Sustainable Plan area would be consistent with the analysis in the Plan EIR and the Project would result in less-than-significant impacts. Therefore, the proposed Project would not result in any peculiar effects and would not result in a new or more severe adverse impact that was not previously identified in the previous EIR. Further, the Project would not result in an increase to significant effects as a result of new information not previously assessed in the Sustainable Plan EIR.
e) Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?
As described in further detail in Section 3.10(a) above, the Sustainable Plan EIR evaluated the potential for full build out of the Plan area to violate water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality and determined there would be a less-thansignificant impact in this regard with implementation of existing regional water quality regulations and the City’s local water quality control standards for new development and redevelopment.

The analysis under the Sustainable Plan EIR remains accurate with respect to the proposed Project, which would develop an industrial BESS facility in accordance with the provisions of the Sustainable Plan and would occur within the Plan area previously evaluated. Furthermore, as discussed in the Hydrology and Water Quality Study, the Project would comply with the applicable regulations and permits designed to comply with the Basin Plan and the SWPPP would be effective at meeting water quality objectives of the Basin Plan during construction. The retention basin will satisfy City requirements in regard to post668

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construction BMPs. In addition, the Project site is within the adjudicated Upper Mojave River Groundwater Basin managed by a court-appointed watermaster and is designated as very low priority and is thus not subject to the statewide requirements of the Sustainable Groundwater Management Act (SGMA). Therefore, Project water demand is not anticipated to conflict with or obstruct implementation of a sustainable groundwater management plan (Appendix G). As discussed above, ground disturbance in off-site areas would be minimal and would be limited to previously disturbed and developed areas within the Victor and Kramer Substation footprints and the transmission lines rights-of-way and would not be anticipated to substantially degrade surface water or groundwater quality.

As such, impacts associated with the development of the proposed Project within the Sustainable Plan area would be consistent with the analysis in the Plan EIR and the Project would result in less-than-significant impacts. Therefore, the proposed Project would not result in any peculiar effects and would not result in a new or more severe adverse impact that was not previously identified in the previous EIR. Further, the Project would not result in an increase to significant effects as a result of new information not previously assessed in the Sustainable Plan EIR.

Conclusion
The proposed Project is consistent with the development evaluated in the Sustainable Plan EIR and would not result in any new impacts or increase the severity of any previously identified impacts as compared to what was already identified and disclosed, either individually or cumulatively. Further environmental analysis is not required because:

No peculiar impacts that are not substantially mitigated have been identified as a result of the proposed Project or its site. Incorporation of the identified Project design features substantially mitigate potentially significant impacts to a less-than-significant level consistent with the conclusions in the Sustainable Plan EIR.

There are no potentially significant impacts that were not analyzed as significant in the Sustainable Plan EIR.

There are no potentially significant off-site and/or cumulative impacts that were not discussed in the Sustainable Plan EIR.

No substantial new information has been identified that results in an impact that is more severe than anticipated by the in the Sustainable Plan EIR.
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3.11 Land Use and Planning

Significant
Project Impact
Analyzed in
the Prior EIR
Substantial New
Information
XI. LAND USE AND PLANNING – Would the project:
a) Physically divide an established community?
b) Cause a significant environmental impact due to a
conflict with any land use plan, policy, or regulation
adopted for the purpose of avoiding or mitigating an
environmental effect?
Prior Environmental Impact Report Summary
Potential impacts due to land use and planning were analyzed in the Sustainable Plan EIR on pages 4.10-1 through

4.10-14. Potential impacts related to physically dividing an existing community were evaluated in the EIR and it determined there would be no impact with incorporation of Sustainable Plan implementing actions. The EIR also analyzed potential impacts related to conflicting with a land use plan, policy, or regulation and determined impacts would be less than significant with incorporation of General Plan EIR policies and Implementing Program OS-29.

Applicable Policies
General Plan
Goal MI 1: Assure that the manufacturing/industrial development in the city continues to thrive.

Goal MI 2: Assure the provision of infrastructure, circulation and public services adequate to serve the MI district.

Goal MI 3: Minimize MI intrusion on surrounding residential neighborhoods.

Goal MI 5: Encourage the introduction of “clean industry” to the Manufacturing/Industrial district and Light Manufacturing district.

Sustainable Plan
Land Use and Community Design Chapter
Goal LC 3: Diverse employment and business opportunities.

Policy LC 3.4: Provide incentives to encourage businesses to locate within the Mixed Use, Business Park, Light Manufacturing, and Manufacturing/Industrial land use designations.

Policy LC 4.4: Promote the use of solar, wind, and other alternative energy generation systems as part of new planned development.

Policy LC 4.6: Accommodate renewable energy generation facilities within the Public Utilities, Business Park, Light Manufacturing, and Manufacturing/Industrial land use designations. 670

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Policy LC 5.1: Require new development to pay its fair share of the cost of public facilities, services, and infrastructure, including but not limited to transportation, incremental water supply, sewer and wastewater treatment, solid waste, flood control and drainage, schools, fire and police protection, and parks and recreation.

Implementing Program LC-4: Design Guidelines. Prepare design guidelines identifying the City’s expectations for planning, designing, and reviewing development proposals. Include form based guidelines for neighborhoods, streetscapes, major roadway corridors and US 395, and Mixed Use Centers. The design guidelines may take the form of citywide guidelines or guidelines developed for identified neighborhoods, mixed use centers, and street corridors. Guidelines should discuss the private and public realms, landscaping, gateways, signage, site planning, building form and scale, pedestrian features, and other design approaches.

Until such guidelines are developed, individual projects will be reviewed for consistency with the design goals and policies of this Plan.

Project-Specific Analysis
a) Would the project physically divide an established community? The Sustainable Plan governs the northern portion of the City and designates various land uses throughout the City, including more intense industrial development at the center of the City (City of Adelanto 2014b).

The Project is sited in the central area of the City currently surrounded by industrial development and is zoned for industrial development. Regarding off-site improvements, the Kramer Substation is fully developed and is zoned/designated for commercial use (which conditionally permits utility facilities such as substations) (County of San Bernadino 2020a, 2024a). The Victor Substation is also fully developed and is zoned/designated for light industrial use (City of Victorville 2024b). Other off-site improvements would occur within the existing transmission line rights-of-way, which would not result in the physical division of an established community.

The analysis under the Sustainable Plan EIR remains accurate with respect to the proposed Project. As such, impacts associated with the development of the proposed Project within the Sustainable Plan area would be consistent with the analysis in the Sustainable Plan EIR and would result in no impact related to dividing an established community. Therefore, the proposed Project would not result in any peculiar effects and would not result in a new or more severe adverse impact that was not previously identified in the prior EIR. Further, the Project would not result in an increase to significant effects as a result of new information not previously assessed in the Sustainable Plan EIR.
b) Would the project cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect? The Sustainable Plan EIR evaluated whether full buildout of the development of the Plan area would create a significant environmental impact due to the conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect and determined that less-than-significant impacts would occur. The Sustainable Plan is founded on guiding principles including but not limited to protecting the environment, creating healthy and safe neighborhoods, and providing transportation options, and addresses various specific environmental topic issues such as land use, population and housing, cultural resources, parks and recreation, transportation, and more. As such, the Sustainable Plan is 671

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inherently designed to minimize long-term impacts to the environment. The Sustainable Plan also includes policies consistent with the General Plan EIR that reduce, minimize, or avoid environmental impacts (City of Adelanto 2014b).

The analysis under the prior EIR remains accurate with respect to the proposed Project, which would develop an industrial BESS facility in accordance with the provisions of the Sustainable Plan and would occur within the Plan area previously evaluated. The Project site is designated as MI (Manufacturing/Industrial) by the Sustainable Plan and is also zoned MI in the City’s Zoning Map (City of Adelanto 2024). As discussed above, regarding off-site improvements, the Kramer Substation is fully developed and is zoned/designated for commercial use (which conditionally permits utility facilities such as substations) (County of San Bernadino 2020a, 2024a). The Victor Substation is also fully developed and is zoned/designated for light industrial use (City of Victorville 2024b). Other off-site improvements would occur within the existing transmission line rights-of-way. The development of the proposed Project would be consistent with these designations and would not require a General Plan or Specific Plan Amendment or rezone. The proposed Project advances the industrial development plans, goals, and policies established by the Sustainable Plan. The Project would also be consistent with all applicable development standards and design guidelines and would be developed in accordance with the industrial vision of the Sustainable Plan area.

As such, impacts associated with the development of the proposed Project within the Sustainable Plan area would be consistent with the analysis in the Plan EIR and would result in less-than-significant land use impacts. Therefore, the proposed Project would not result in peculiar effects and would not result in a new or more severe adverse impact that was not previously identified in the prior EIR. Further, the Project would not result in an increase to significant effects as a result of new information not previously assessed in the Sustainable Plan EIR.

Conclusion
The proposed Project is consistent with the development evaluated in the Sustainable Plan EIR and would not result in any new impacts or increase the severity of any previously identified impacts as compared to what was already identified and disclosed, either individually or cumulatively. Further environmental analysis is not required because:

No peculiar impacts have been identified as a result of the proposed Project or its site. The Project would be consistent with Sustainable Plan land use designations and policies.

There are no potentially significant impacts that were not analyzed as significant in the Sustainable Plan EIR.

There are no potentially significant off-site and/or cumulative impacts that were not discussed in the Sustainable Plan EIR.

No substantial new information has been identified that results in an impact that is more severe than anticipated by the Sustainable Plan EIR.
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3.12 Mineral Resources

Significant
Project Impact
Analyzed in
the Prior EIR
Substantial New
Information
XII. MINERAL RESOURCES – Would the project:
a) Result in the loss of availability of a known mineral resource that would be of value to the region and the
residents of the state?
b) 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?
Prior Environmental Impact Report Summary
Potential impacts to mineral resources were analyzed in the Sustainable Plan EIR on pages 4.11-1 through 4.11-8.

Potential impacts due to the loss of availability of a known mineral resource of value to the region or state were determined to be less than significant while the EIR determined there would be no impact relating to 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.

Applicable Policies
General Plan
Goal NR 1: To preserve and protect the area’s renewable and non-renewable resources to the maximum extent possible.

Policy NR 1.5: The City will restrict development in those areas which are determined to have significant reserves of natural resources, including gas, oil, and aggregate materials.

Sustainable Plan
No policies are applicable to the topic of mineral resources.

Project-Specific Analysis
a) Would the project result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state?
The Sustainable Plan EIR evaluated potential impacts due to the loss of availability of a known mineral resource of value to the region or state and determined impacts would be less than significant. As described in the Sustainable Plan EIR, the General Plan states there may be areas with minerals extraction potential within many portions of the Sustainable Plan area and includes goals and policies, such as Policy NR 1.5, that are designed to restrict development in areas that are determined to have significant mineral reserves (City of Adelanto 2014b). Areas within the City that have mineral resource extraction potential are zoned low-density residential or industrial, such as the Project site which is zoned as MI. The Sustainable Plan does not contain policies that conflict with Policy NR 1.5 and, as such, mineral resource deposits would be 673

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protected. The analysis under the Sustainable Plan EIR remains accurate with respect to the proposed Project, which would develop an industrial BESS facility in accordance with the provisions of the Sustainable Plan and would occur within the Plan area previously evaluated. With incorporation of General Plan Policy NR 1.5, the proposed Project would have a less-than-significant impact related to the loss of known mineral resources. Off-site impacts would be limited to previously disturbed and developed areas within the Victor and Kramer Substation footprints and the transmission lines rights-of-way. The Victor Substation and surrounding areas is located within Mineral Resource Zone (MRZ)-3a, which are areas containing known mineral occurrences of undetermined mineral resource significance, while the Kramer Substation is located within MRZ-4, which is an area of no known mineral occurrences where geologic information does not rule out either the presence or absence of significant mineral resources (City of Victorville 2008; DOC 2025; County of San Bernardino 2020). The substations are fully developed and are not currently used for mineral extraction. Improvements in the transmission line rights-of-way would not be anticipated to preclude mineral resources extraction activities, should they occur in the future.

As such, impacts associated with the development of the proposed Project within the Sustainable Plan area would be consistent with the analysis in the Plan EIR and would result in less-than-significant impacts.

Therefore, the proposed Project would not result in any peculiar effects and would not result in a new or more severe adverse impact that was not previously identified in the previous EIR. Further, the Project would not result in an increase to significant effects as a result of new information not previously assessed in the Sustainable Plan EIR.
b) Would the project 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? As discussed in the Sustainable Plan EIR, the General Plan and other City planning documents do not identify any locally important mineral resources and, as such, no impact would occur. The analysis under the Sustainable Plan EIR remains accurate with respect to the proposed Project, which would develop an industrial BESS facility in accordance with the provisions of the Sustainable Plan and would occur within the Plan area previously evaluated. Off-site impacts would be limited to previously disturbed and developed areas within the Victor and Kramer Substation footprints and the transmission lines rights-of-way. Neither the City of Victorville General Plan nor the San Bernardino County Countywide Plan identify locally important mineral resource recovery sites within the Kramer or Victor substations (City of Victorville 2008; County of San Bernadino 2020a). Improvements in the transmission line rights-of-way would not be anticipated to preclude mineral resources recovery activities, should they occur in the future. Therefore, the proposed Project would have no impact to locally important mineral resources.

As such, impacts associated with the development of the proposed Project within the Sustainable Plan area would be consistent with the analysis in the Plan EIR and the Project would not result in any significant impacts. Therefore, the proposed Project would not result in any peculiar effects and would not result in a new or more severe adverse impact that was not previously identified in the previous EIR. Further, the Project would not result in an increase to significant effects as a result of new information not previously assessed in the Sustainable Plan EIR.
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Conclusion
The proposed Project is consistent with the development evaluated in the Sustainable Plan EIR and would not result in any new impacts or increase the severity of any previously identified impacts as compared to what was already identified and disclosed, either individually or cumulatively. Further environmental analysis is not required because:

No peculiar impacts have been identified as a result of the proposed Project or its site.

There are no potentially significant impacts that were not analyzed as significant in the Sustainable Plan EIR.

There are no potentially significant off-site and/or cumulative impacts that were not discussed in the Sustainable Plan EIR.

No substantial new information has been identified that results in an impact that is more severe than anticipated by the in the Sustainable Plan EIR.

3.13 Noise

Significant
Project Impact
Analyzed in
the Prior EIR
Substantial New
Information
XIII. NOISE – Would the project result in:
a) Generation of a substantial temporary or permanent
increase in ambient noise levels in the vicinity of the project in excess of standards established in the
local general plan or noise ordinance, or applicable
standards of other agencies?
b) Generation of excessive groundborne vibration or
groundborne noise levels?
c) For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a
plan has not been adopted, within two miles of a
public airport or public use airport, would the project expose people residing or working in the project area
to excessive noise levels?
Prior Environmental Impact Report Summary
Potential noise and vibration impacts were analyzed in the Sustainable Plan EIR on pages 4.12-1 through 4.12-28.

The Plan EIR determined that projected long-term traffic volumes and proposed land uses within the Plan area near sensitive land uses would result in significant and unavoidable exposure of persons to noise levels in excess of established standards. The Plan EIR determined that with implementation of policies within the Sustainable Plan, General Plan, and Municipal Code, impacts relating to excessive groundborne vibration and noise levels, a substantial permanent increase in ambient noise levels above established levels, a substantial temporary or periodic increase in ambient noise levels above established levels, and exposure of people residing or working within the noise contours of the Southern California Logistics Airport (SCLA) would be less than significant.

The Plan EIR includes Sustainable Plan policies HS-9.1 though HS-9.6 and HS-9.8 in addition to General Plan Policies NS 1.4, NS 1.6 through NS 1.11, and NS 1.13 through NS 1.17, to reduce the identified potential noise impacts from future development in the Plan area to less than significant. 675

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Applicable Policies
General Plan
Goal NS 1: To reduce the number of persons and land uses exposed to excessive noise levels within the Planning Area.

Policy NS 1.4: Encourage the School District to design and locate schools so that exterior noise exposures do not exceed 65 CNEL and interior peak noise levels do not exceed 60 dBA as a result of exterior noise sources.

Policy NS 1.6: Ensure through the design review process that interior noise levels for hospital and convalescent homes do not exceed 55 CNEL in interior living areas and 45 CNEL in interior sleeping areas.

Policy NS 1.7: Ensure through the design review process that re creational areas intended for quiet or passive activities are designed and located so that noise levels do not exceed 70 dB.

Policy NS 1.8: Ensure through the design review process that re creational areas intended for noise or active uses are buffered from passive use areas and from surrounding noise sensitive land uses.

Policy NS 1.9: Ensure through the design review process that business and professional offices, where effective communication is essential, mitigate interior noise to 50 CNEL.

Policy NS 1.10: Ensure through the design review process that exterior noise levels at commercial and industrial areas do not exceed 75 dB.

Policy NS 1.11: Ensure through the design review process that noise tolerant land uses are located in areas irrevocably committed to noise producing land uses, such as transportation corridors or railroads.

Policy NS 1.13: Assist in the formation of special assessment districts or other funding opportunities to install noise barriers or berm and barrier combinations in areas where existing residences back up to major thoroughfares.

Policy NS 1.14: Consider the following uses noise sensitive and discourage them in areas where exterior noise levels exceed 65 CNEL unless measures are implemented which reduce the noise exposure below this level: single and multiple family residential uses, group homes, hospitals, schools, and other learning institutions, parks and open space areas where quiet is a basis for use.

Policy NS 1.15: Acoustical privacy consistent with the Noise Insulation Standards (California Administrative Code, Title 25, Chapter1, Subchapter 1, Article 4) and all existing and future requirements outlined in the State Housing Code will be enforced for both single and multiple family residential construction.

Policy NS 1.16: Noise sensitive land uses, including: residences, hospitals, and long-term medical care facilities, educational facilities, libraries, churches and places of public assembly will not be allowed near major stationary noise sources.

Policy NS 1.17: The application of noise insulation and other noise control techniques in new schools, hospitals, and convalescent homes shall be consistent with State and Federal regulations. 676

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Goal NS 2: To provide a safe and comfortable living environment for new residential, business, and commercial developments in Adelanto which are minimally affected by noise.

Sustainable Plan
Public Health and Safety Chapter
Goal HS 8: Noise levels throughout the community support public health and welfare, and contribute to a high quality of life.

Policy HS 8.1: Continue to enforce City and State noise regulations to protect residents from excessive noise levels.

Policy HS 8.2: Require noise-sensitive land use development to incorporate measures to reduce interior and exterior noise levels.

Policy HS 8.3: Require mixed-use structures to be designed to account for noise from adjacent uses, and minimize transfer of noise and vibration from commercial/retail to residential use.

Policy HS 8.4: Use site planning and project design strategies to achieve acceptable noise level standards as outlined in the noise/land use compatibility guidelines. The use of noise barriers shall be considered after all practical design-related noise measures have been integrated into project design.

Policy HS 8.5: Require a detailed analysis of proposed noise reduction measures to determine whether the proposed use is compatible when a project is to be located in an area that exceeds normally acceptable noise thresholds.

Policy HS 8.6: Minimize noise impacts on noise-sensitive land uses (“sensitive receptors”), such as residential uses, schools, hospitals, child care facilities, wildlife habitat areas, and other noise sensitive areas.

Policy HS 8.7: Restrict noise levels from stationary sources through enforcement of the Noise Ordinance.

Policy HS 8.8: Continue to consider noise impacts as part of the development review process.

Implementing Program HS-20: Noise/Vibration Reduction Measures. Require development that will be affected by aircraft noise and/or vibration to include appropriate measures to minimize adverse effects on residents and businesses.

Implementing Program HS-21: Noise Suppression Techniques. Require all exterior noise sources (such as construction operations, air compressors, leaf blowers, among others) to use available noise suppression devices and techniques to reduce noise to acceptable levels that are compatible with adjacent uses. 677

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Project-Specific Analysis
a) Would the project result in generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies?
The Sustainable Plan EIR evaluated the full buildout of the Plan area and determined development would generate significant temporary or permanent increase in ambient noise levels in excess of applicable standards due to projected long-term traffic volumes and proposed land uses near sensitive land uses that would result in exceedances of the City’s noise performance standards. The Plan EIR states that roadway noise could permanently increase ambient noise levels due to a proposed expansion of a roadway segment or where roadways will carry increasing traffic volumes. The Plan EIR determined that residential uses along several roadways would be exposed to noise levels in excess of established standards under full build out conditions and impacts to these sensitive receptors would be significant and unavoidable at a programlevel. However, as analyzed in the Sustainable Plan EIR, the proposed Project site is not located in an area where noise is expected to exceed established City standards as a result of projected long-term traffic volumes or proposed land uses. The proposed Project is consistent with the significant and unavoidable determination made in the Sustainable Plan EIR, although Project-specific impacts are anticipated to be less than significant.

Construction Noise
The analysis under the Sustainable Plan EIR remains accurate with respect to the proposed Project, which would develop an industrial BESS facility in accordance with the provisions of the Sustainable Plan and would occur within the Plan area previously evaluated. The proposed Project would involve industrial construction and associated construction noise, which is consistent with the uses evaluated in the Sustainable Plan EIR. As discussed in the Noise and Vibration Assessment (Noise Assessment) prepared for the Project by Dudek in May 2024 (Appendix H), construction of the Project is expected to occur over approximately 15 months and would be temporary in nature. Construction noise levels were predicted at the nearest sound-sensitive land uses in the general vicinity of the Project site, which include rural residences located about 0.65 to 1 mile to the east of the site along Cassia Road, Primrose Road, and Verbena Road, as well as Adelanto High School, located about 0.65 miles south of the site (Appendix H).

As indicated in Table 4 of the Noise Assessment, worst-case construction noise levels would range from 46 to 57 dBA (A-weighted decibel) Leq 8hr which, at the worst-case exposure receiver (residence to the east on Cassia Road), would be up to 8 decibels (dB) above the documented daytime level during substation installation, and would be clearly noticeable. During other phases of construction and as construction equipment travels around the site, sound levels would be lower and may be barely noticeable. The average construction noise levels would be similar to or below daytime sound levels at Adelanto High School (Appendix H).

Construction noise related to the SCE improvements would result in temporary but less-than-significant noise increases to the outdoor ambient sound environment. All SCE related work would comply with the City of Victorville and County of San Bernardino noise ordinance requirements and would occur during hours allowed by the respective Municipal Codes. Thus, there would be minimal noise impacts from SCE construction-related activities.
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However, as detailed in the Noise Assessment, construction activities would comply with the Federal Transit Authority (FTA) recommended construction noise limit of 80 dBA Leq 8hr, and all stationary equipment would be located more than 100 feet from residences in accordance with the Municipal Code. The average noise levels at exterior areas would not be harmful, nor would they present a deterrent to use of outdoor activity, yard, or patio areas (Appendix H). The Noise Assessment states that with typical outdoor to indoor attenuation of 15 dBA for standard construction residential structures with windows open, interior noise levels at the closest residences during construction would be as high as approximately 42 dBA Leq, which should not interfere with conversation or other daytime activities indoors. Consequently, on-site construction noise levels would result in a less-than-significant temporary noise impact (Appendix H).

As it relates to construction traffic noise, per Adelanto Municipal Code Chapter 17.90, construction routes are limited to City designated truck routes, which include Palmdale Road, U.S. Highway 395, Rancho Road, Koala Road, Air Expressway Road, and Adelanto Road. Given the location of the Project, construction vehicles are most likely to travel along Rancho Road, Koala Road, Palmdale Road, and U.S. Highway 395 (Appendix H). As analyzed in the Noise Assessment, the highest daily construction volume would be equivalent to 240 light vehicles (accounting for 40 autos and 40 trucks), occurring during the substation installation and battery container installation phases of construction. An increase of 240 vehicles per day on a roadway with an existing daily traffic volume of 4,330 would result in a daily increase of less than 0.5 dB and this overall increase would be negligible (Appendix H). During decommissioning, the daily light vehicle equivalent would be 3,800 (accounting for 40 autos and 304 trucks), resulting in an increase in traffic noise levels (again assuming a worst-case condition with all vehicles traveling along Koala Road) of less than 3 dB. This increase would be considered barely perceptible. In reality, construction traffic would most likely be spread around the local construction routes and not only limited to a single worst-case route. Consequently, construction traffic would result in lower sound level increases than those calculated in the Noise Assessment, and this would result in a less-than-significant temporary noise impact (Appendix H).

Given the above, the proposed Project’s construction-related impacts would be less than significant. As such, impacts associated with the development of the proposed Project within the Sustainable Plan area would be consistent with the analysis in the Plan EIR and would not result in any significant impacts. The proposed Project would not result in any peculiar effects related to historical resources and would not result in a new or more severe adverse impact that was not previously identified in the prior EIR. Further, the Project would not result in an increase to significant effects as a result of new information not previously assessed in the Sustainable Plan EIR.

Operational Noise
The analysis under the Sustainable Plan EIR remains accurate with respect to the proposed Project, which would develop an industrial BESS facility in accordance with the provisions of the Sustainable Plan and would occur within the Plan area previously evaluated. The proposed Project includes the operation of a BESS facility with associated stationary noise sources. As discussed in the Noise Assessment, the nearest sound-sensitive locations are well outside of the sound level limit of 48 dBA Leq (which would equate to the City’s Land Use Compatibility guideline for residential land uses of 55 dBA CNEL if occurring for a 24-hour period).

Furthermore, the highest sound level exposure at a residence would be 31 dBA Leq, and the sound level at Adelanto High School would be 33 dBA Leq (Table 5, Appendix H). The Noise Assessment assumed continuous operation of worst-case conditions, finding that this would equate to Community Noise Equivalent Level (CNEL) sound levels of 38 dBA CNEL at the worst-case residence and 40 dBA CNEL at Adelanto High School.

Therefore, Project-generated sound levels would be well below existing background sound levels and would 679

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not result in a measurable increase in the ambient sound environment (Appendix H). The SCE substations are existing facilities and the minor upgrades would not significantly increase noise impacts. As a result, the Noise Assessment found that Project operational noise levels would be less than significant.

Given the above, the proposed Project’s operational-related impacts would be less than significant. As such, impacts associated with the development of the proposed Project within the Sustainable Plan area would be consistent with the analysis in the Plan EIR and would not result in any significant impacts. The proposed Project would not result in any peculiar effects related to historical resources and would not result in a new or more severe adverse impact that was not previously identified in the prior EIR. Further, the Project would not result in an increase to significant effects as a result of new information not previously assessed in the Sustainable Plan EIR.
b) Would the project result in generation of excessive groundborne vibration or groundborne noise levels? The Sustainable Plan EIR evaluated the full buildout of the Plan area and determined development would not generate excessive groundborne vibration or noise levels in excess of applicable standards with incorporation of existing policies. The Plan EIR determined that with incorporation of Sustainable Plan and General Plan policies, impacts would be less than significant.

The analysis under the Sustainable Plan EIR remains accurate with respect to the proposed Project, which would develop an industrial BESS facility in accordance with the provisions of the Sustainable Plan and would occur within the Plan area previously evaluated. Construction of the proposed Project is temporary and is expected to take approximately 15 months. Furthermore, as discussed in the Project’s Noise Assessment, Project construction-related vibration levels at the nearest structures would in all cases remain several orders of magnitude below the significance threshold for damage to older residential structures (0.2 in/sec PPV [peak particle velocity]) and further below the human annoyance level of 0.24 in/sec PPV, and they would thus not be perceptible in these locations. Project construction would result in vibration and groundborne noise levels that are well below the applicable significance thresholds at the closest sensitive receptor (Adelanto High School) and at the closest off-site structure to the Project site and would therefore meet the applicable Municipal Code limits at a distance of 25 feet or greater from heavy equipment (Table 8, Appendix H). Construction of the SCE upgrades would not require pile driving or other vibration heavy activities and there would be minimal impacts from SCE construction-related vibration. As such, impacts associated with the development of the proposed Project within the Sustainable Plan area would be consistent with the analysis in the Plan EIR and would not result in any significant impacts. The proposed Project would not result in any peculiar effects related to historical resources and would not result in a new or more severe adverse impact that was not previously identified in the prior EIR. Further, the Project would not result in an increase to significant effects as a result of new information not previously assessed in the Sustainable Plan EIR.
c) For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels? The Adelanto Residential Airport, located about 1 mile southwest of the Project site, is a private airport owned and managed by the Adelanto Airport Property Owner’s Association (Appendix H). There are no other private or public airports within 2 miles of the site. San Bernadino County provides Airport Land Use Compatibility Plans for airports located within the County; however, a plan for Adelanto Residential Airport 680

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is not provided. Given this information, the 60 dBA CNEL contour for the airport is most likely within the airport site and the Project site would not expose construction workers or operations employees to substantial airport noise. The Project is not located within the vicinity of a public airport or public use airport.

As such, impacts associated with the development of the proposed Project within the Sustainable Plan area would be consistent with the analysis in the Plan EIR and would not result in any significant impacts. The proposed Project would not result in any peculiar effects related to noise impacts within the vicinity of an air strip or an airport land use plan and would not result in a new or more severe adverse impact that was not previously identified in the prior EIR. Further, the Project would not result in an increase to significant effects as a result of new information not previously assessed in the Sustainable Plan EIR.

Conclusion
The proposed Project is consistent with the development evaluated in the Sustainable Plan EIR and would not result in any new impacts or increase the severity of any previously identified impacts as compared to what was already identified and disclosed, either individually or cumulatively. Further environmental analysis is not required because:

No peculiar impacts that are not substantially mitigated have been identified as a result of the proposed Project or its site, which is consistent with the conclusions in the Sustainable Plan EIR.

There are no potentially significant impacts that were not analyzed as significant in the Sustainable Plan EIR.

There are no potentially significant off-site and/or cumulative impacts that were not discussed in the Sustainable Plan EIR.

No substantial new information has been identified that results in an impact that is more severe than anticipated by the in the Sustainable Plan EIR.

3.14 Population and Housing

Significant
Project Impact
Analyzed in
the Prior EIR
Substantial
New
Information
XIV. POPULATION AND HOUSING – Would the project:
a) Induce substantial unplanned population growth in an area, either directly (for example, by proposing new
homes and businesses) or indirectly (for example,
through extension of roads or other infrastructure)?
b) Displace substantial numbers of existing people or
housing, necessitating the construction of
replacement housing elsewhere?
Prior Environmental Impact Report Summary
Potential impacts to population and housing were analyzed in the Sustainable Plan EIR on pages 4.13-1 through

4.13-6. Potential impacts related to unplanned population growth, displacement of existing housing, and displacement of people were determined to be less than significant. 681

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Applicable Policies
General Plan
No policies are applicable to the topic of population and housing.

Sustainable Plan
No policies are applicable to the topic of population and housing.

Project-Specific Analysis
a) Would the project induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)?
The analysis under the Sustainable Plan EIR remains accurate with respect to the proposed Project, which would develop an industrial BESS facility in accordance with the provisions of the Sustainable Plan and would occur within the Plan area previously evaluated. The Sustainable Plan created a framework to promote sustainable development, protect environmental resources, and to forge a strong connection between SCLA jobs centers and new mixed-use neighborhoods (City of Adelanto 2014a). The Plan establishes land use, transportation, infrastructure, and protection strategies that promote sustainable development, particularly by reducing automobile usage, and requiring cluster development approaches to protect and respect the sensitive desert environment.

The proposed BESS facility Project would employ approximately 40 employees during construction, and it is anticipated that employees would come from the existing labor force within or near the City. The Project is not anticipated to create any unplanned population growth in the City or surrounding area, certainly any individual relocation of a future employee to the area would not constitute substantial growth, and impacts would remain less than significant. As well, the roadway improvements and localized infrastructure proposed as part of the Project would occur for the benefit of the Project and therefore would not create the new capacity likely to induce area growth. The SCE upgrades would be completed by local SCE employees or subcontractors and would not require new permanent employees. Therefore, impacts from Project implementation would remain less than significant.

As such, impacts associated with the development of the proposed Project within the Sustainable Plan area would be consistent with the analysis in the Plan EIR and would result in less-than-significant impacts.

Therefore, the proposed Project would not result in any peculiar effects and would not result in a new or more severe adverse impact that was not previously identified in the prior EIR. Further, the Project would not result in an increase to significant effects as a result of new information not previously assessed in the Sustainable Plan EIR.
b) Would the project displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere?
The analysis under the Sustainable Plan EIR remains accurate with respect to the proposed Project, which would develop an industrial BESS facility in accordance with the provisions of the Sustainable Plan and would occur within the Plan area previously evaluated. As discussed in the Sustainable Plan EIR, the Plan 682