Antioch City Council
November 4, 2025

noise section states “General Plan Policy 11.8.2 (f) requires a detailed noise attenuation study to be prepared by a qualified acoustical engineer to determine appropriate mitigation and ways to incorporate such mitigation into project design and implement ation.” And that “compliance with Code of Ordinance 9-5.1901 (A) and General Plan Policy 11.8.2 (f) would ensure that future development under the Project would not result in a substantial temporary or permanent increase in ambient noise levels from statio nary sources, and this impact would be less than significant” (Housing Element DEIR page IV.L-13).

Similarly, for construction noise, General Plan Policy 11.8.2 “requires development adjacent to occupied noise sensitive land uses to implement a construction-related noise mitigation plan and requires that all construction equipment utilize noise reductio n features” Additionally, the construction-related noise mitigation plan should “depict the location of construction equipment and how the noise from this equipment will be mitigated during construction through the use of noise reduction methods” that are listed in General Plan Policy 11.8.2 (m) (DEIR page IV.L-12).

General Plan 11.8.2 (f) and (m) proceed to list several design guidelines that reduce noise. None of these are guaranteed to reduce noise, depending on the unique characteristics of each site. In Section m, mufflers are already included in construction noise source models of the cited FTA database, which takes its source values from measurements of modern equipment already equipped with mufflers. Nighttime construction restrictions do not mitigate daytime noise levels. Strategic staging will reduce the length of unnecessary noise impacts, but will not mitigate the worst-case construction noise scenarios when necessary activities occur adjacent to sensitive uses. Similarly for section f, most of these best practices do not mitigate worst-case noise and are already included in modeling assumptions. Strategic project design and orientation will reduce some potential impacts. However, this does not preclude there being operational noise impacts, either due to the constraints set by the geometry of each individual site plan, or project orientation that was set by considerations other than efficiency of reducing on-site noise.

The Housing Element DEIR establishes that the general plan will reduce noise to less than significant if followed, but the same DEIR cites the general plan requirement s that projects which can result in the “development of proposed uses could result in a significant increase in noise a detailed noise attenuation study to be prepared by a qualified acoustical engineer to determine appropriate mitigation and ways to incorporate such mitigation into project design and implementation” (DEIR page IV.L-13). Those steps have not been taken here, and we believe that this project has the potential to result in a significant increase in noise and vibration, and thus a detailed analysis is required, as detailed in this letter.

Construction Noise Impacts are Potentially Significant.

To estimate construction noise, the Federal Highway Administration’s Roadway Construction Noise Model (RCNM) 3 was used for this analysis. Typically, multiple pieces of equipment are used in a construction noise analysis, based on a realistic estimation of a construction environment where multiple activities occur simultaneously. Up to three pieces of equipment were modeled at once as a conservative estimate, based on typical construction procedures and timelines. The one exception to this was pile driving, which is a typically more intense procedure than most construction methods. 3 https://www.fhwa.dot.gov/ENVIRonment/noise/construction_noise/rcnm/rcnmcover.cfm E21

WILSON IHRIG
Slatten Ranch Townhomes
Comments on Noise Analysis

Program default usage factors, or the percentage of time the equipment generally operates, were used for all pieces of analyzed equipment. Source levels typically used in a construction noise analysis are shown in Table 1.

Table 1: Typical Construction Equipment Noise Levels
Equipment Lmax Sound Level
at 50 feet (dBA)
Utilization %
Backhoe 77.6 40%
Compactor (ground) 80.0 20%
Compressor (air) 78.0 40%
Concrete Mixer Truck 79.0 40%
Concrete Pump Truck 81.0 20%
Concrete Saw 89.6 20%
Crane 81.0 16%
Dozer 81.7 40%
Excavator 80.7 40%
Forklift 75.0 10%
Pneumatic Tools 85.0 50%
Generator 81.0 50%
Mounted Impact
Hammer (hoe ram) 90.0 20%
Impact Pile Driver 95.0 20%
Front End Loader 79.0 40%
Paver 77.0 50%
Roller 80.0 20%
Tractor 84.0 40%
Welder / Torch 73.0 40%
Source: RCNM 1.1
The results of this analysis at the closest sensitive receiver, which are the townhomes approximately 90 feet northeast of the project boundary4, are shown in Table 2.

Table 2: Modeled Noise Levels from the Proposed Project and Nearest Sensitive Receiver Noise Source(s) Modeled Noise Level (dBA)
Impact Pile Driver Only 83
Impact Pile Driver + Pneumatic Tools +
Concrete Saw 85
Concrete Saw + Pneumatic Tools 80
City of Antioch General Plan 5 section 11.6.2i-n addresses construction noise. It limits construction hours to 7am to 7pm Monday through Saturday. However, during daytime hours, no limits are set. 4 This is measured via google earth to the project site 5 https://www.antiochca.gov/fc/community-development/planning/Antioch_Adopted_General_Plan.pdf E22

WILSON IHRIG
Slatten Ranch Townhomes
Comments on Noise Analysis

Even if the city does not set its own construction noise daytime limits, the IS should set thresholds based on other similar documents. For example, the County of Los Angeles code has a construction noise limit of 75 dBA 6. Certainly, that has no jurisdiction for this project, but other government agencies and other municipalities do have daytime construction noise limits. It is the responsibility of the project applicant to find an applicable guideline to use and determine if noise levels will create an adverse impact on the community. If the applicant finds, chooses and properly cites another threshold that they feel is more appropriate, it is within their right to do so. Many such thresholds are based on ambient noise levels, which are not present here. Either way, the IS must be revised to include such a threshold to evaluate, identify, and potentially mitigate construction noise impacts.

All three modeled scenarios yield noise levels that match or exceed the 75 dBA construction noise guideline. As it currently stands, this is an exceedance of the recommended construction noise threshold which would require mitigation, such as a temporary soundwall. A study should be developed, consistent with the General Plan Policy 11.8.2, that shows how implementation of recommended barriers reduce noise levels below significance limits.

Operational Noise Impacts are Potentially Significant.

Operational noise from the project may represent long -term changes in the surrounding noise environment for nearby receptors. Typically, operational noise sources can include rooftop mechanical units and noise from outdoor spaces and balconies. In order to model the noise, the following assumptions were used:
• Mechanical equipment, such as HVAC units, can generate sound power levels as high as 91 dBA7.
• The HVAC units would be located on building rooftops and are 10 feet behind the edge of the building.
• The distance from the new buildings to the residence to the southeast is 180 feet. • Three units were assumed, 10 feet apart
• 4 dB of reduction was assumed from a rooftop parapet
• HVAC systems may run constantly, especially in the City of Antioch where summer average heat can reach as high as 90 degrees Fahrenheit8.

Based on the above assumptions, the potential nighttime operational noise levels are shown in Table 3. No rooftop amenity space was indicated in the Initial Study, so it was not studied. If more detailed plans show balconies or rooftop amenity space, those should be analyzed as well. 6 https://codelibrary.amlegal.com/codes/los_angeles/latest/lamc/0-0-0-193925 7 https://www.americanstandardair.com/content/dam/Trane/en- engineer/products/rooftopunits/Voyager/Voyager%20III/RT-PRC022-E4_0513.pdf, page 23 8 https://weatherspark.com/y/1111/Average-Weather-in-Antioch-California-United-States-Year-Round E23

WILSON IHRIG
Slatten Ranch Townhomes
Comments on Noise Analysis

Table 3: Predicted Project Operational Noise Levels
Receiver Modeled Noise
Level (dBA)
Noise Criteria Exceedance
Townhomes to the
Northeast
53 n/a a Unknown
a Without measured ambient levels, increases over the ambient are impossible to determine.

Since there is no ambient measurement, there is no criteria, because nighttime criteria levels are typically based on ambient levels. Suburban areas at night can be as quiet as 40 dBA 9. Based on the housing element DEIR, a significance threshold is used in the city of 3 dBA over ambient limits, of which this scenario exceeds. Due to the proximity of highway SR-4, ambient levels may be higher than this, but this is why it is important to measure ambient noise levels to establish a baseline.

The available Project plans are unclear as to the placement of HVAC units. More developed plans may show an HVAC arrangement that is less intrusive, or ambient measurements may present a higher criterion. But the potential for significant impacts do exist, and more thorough study is needed.

The project has the potential to result in significant operational noise levels, which should be considered in a noise study, as required by General Plan Policy 11.8.2. This noise study should determine potential mitigation measures, such as shielding of the HVAC units’ noise emissions to the southeast, to reduce community exposure to excessive noise. The noise study must also measure ambient noise levels and determine if the increase over ambient levels would be significant.

Construction Vibration Impacts are Potentially Significant.

The DEIR on pages IV.L-14 and IV.L-15 describes the construction vibration analysis used for housing with the city limits of Antioch, based on procedures and thresholds found in the Caltrans Transportation and Construction Vibration Guidance Manual and the Federal Transit Administration Transit Noise and Vibration Impact Assessment Manual. The DEIR states that “a buffer distance of about 115 feet” is required “to protect vibration sensitive structures (below the

0.12 in/sec criterion in Table IV.L-4).” The closest structure for this project is 90 feet away.

The DEIR continues, “if sensitive receptors are located within these buffer distances, future developments under the Project should prepare a screening level vibration analysis for City review in accordance with General Plan Policy 11.8.2 (k).” This was not completed for this project as required by the City and should be part of a noise study associated with this project. The DEIR continues, stating that if the “ screening level analysis shows that construction has the potential to result in damage to structures” then a “detailed vibration impact assessment must be prepared by a structural engineer or other appropriate professional to determine appropriate design means and methods of construction to avoid the potential damage” (DEIR pages IV.L-14 and IV.L-1). This is vital to study, as a potential impact would not just impact people’s day to day lives, but could result in damage to nearby housing, and thus should be studied more thoroughly. 9 https://ehs.yale.edu/sites/default/files/files/decibel-level-chart.pdf E24

WILSON IHRIG
Slatten Ranch Townhomes
Comments on Noise Analysis

Baseline Noise not Established.

CEQA requires evaluation of whether a project would cause a “substantial temporary or permanent increase in ambient noise levels.” Without knowing how loud the environment is, it is impossible to determine if the new project will increase noise in the surrounding community. B aseline noise measurements are the preferred way to determine background noise sources. These measurements serve as a crucial reference point for evaluating the potential noise impacts of proposed projects or activities. Without establi shing the baseline noise conditions before any new development occurs, decision-makers cannot effectively determine whether the project complies with noise regulations nor identify any potential adverse effects on the surrounding environment and communities. Given the proximity to both local streets and highway SR-4 along with noise from nearby residences, as well as shielding from nearby structures, noise levels should be physically measured to be accurately determined.

The Federal Transit Administration’s 2018 Transit Noise and Vibration Impact Assessment Manual10 (FTA Manual) Appendix E recommends a minimum of three one-hour Equivalent Sound Level (Leq) noise measurements (peak-hour roadway traffic, typical midday conditions, and typical nighttime conditions) to estimate the Day-Night Sound Level ( Ldn) at site, which can be used to establish baseline noise conditions for the project , including the Community Noise Equivalent Level (CNEL) .

An EIR should be prepared with these baseline noise measurements to properly describe the noise environment.

Conclusions
Considering the potentially significant impacts from construction and operational noise and vibration on the surrounding community, it is imperative that an EIR be conducted to disclose and analyze these potentially significant impacts. Failure to evaluate the se impacts would be a violation of CEQA's core purpose of providing a transparent and comprehensive assessment of a project's environmental effects.

Very truly yours,

WILSON IHRIG

Jack Meighan
Associate
meighan - updated wildflower noise analysis.docx

10 https://www.transit.dot.gov/sites/fta.dot.gov/files/docs/research-innovation/118131/transit-noise-and- vibration-impact-assessment-manual-fta-report-no-0123_0.pdf E25

JACK MEIGHAN
Associate

Jack joined Wilson Ihrig in 2021 and is an experienced acoustics engineer with expertise in projects involving rail transit systems, highways, CEQA analysis, environmental noise reduction, mechanical drawing reviews, and construction noise and vibration mitigation. He has hands-on experience with project management, including client coordination and presentations, as well as in designing, developing, and testing MATLAB code used in acoustics applications. Additionally, his expertise includes taking field measurements, developing test plans and specifying, purchasing, setting up and repairing acoustic measurement equipment. He has experience in using Traffic Noise Model (TNM), CadnaA, EASE, Visual Basic, LabView, and CAD software.

Education
 B.S. in Mechanical Engineering, University of Southern California, Los Angeles, CA

Project Experience
Metro Regional Connector, Los Angeles CA
Planned, took, and processed measurements as part of a team to determine the effectiveness of floating slab trackwork for a new subway in downtown Los Angeles that travels below the Walt Disney Concert Hall and the Colburn School of Music.

Rodeo Credit Enterprise CEQA Analysis for New Construction, Palmdale, CA Wrote an accepted proposal and executed it for a noise study project to determine noise mitigation requirements on a new housing development. Led all aspects of the project and managed the budget during all phases of project completion. Completed 5 separate projects of this type for this developer.

Blackhall Studios, Santa Clarita, CA
Led the vibration measurement effort for a new soundstage directly adjacent to an existing freight and commuter rail line. Tested equipment, processed data, and analyzed results to determine the vibration propagation through the soil to the proposed soundstage locations, and was part of the team that developed mitigation techniques for the office spaces directly next to the rail line.

Octavia Residential Condos CEQA Study, San Francisco, CA Calculated the STC ratings for the proposed windows to meet Title 24 requirements, modeled the acoustic performance of floor and ceiling structures, researched noise codes, helped with a mechanical design review, and wrote a report summarizing the results for a new Condominium project being developed in San Francisco.

San Diego International Airport Terminal I Re
placement, CA
Conducted interior noise and vibration measurements, analyzed measurement data to help determine project criteria, modeled the existing and future terminals in CadnaA, and was part of a team that did a complete HVAC analysis of the entire terminal, as part of a CEQA analysis where a new terminal for the airport is being designed.

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Jack Meighan – Page 2

* Work done prior to working for Wilson Ihrig
Five Points Apartments Noise Study, Whittier, CA
Took measurements, researched sound data and solutions, and recommended mitigation for a new apartment complex that was located next to an existing car wash, as part of a CEQA review.

USC Ellison Vibration Survey, Los Angeles, CA
Conducted vibration measurements as part of a survey to determine the effectiveness of vibration isolation platforms that are used to insulate cell growth in a cancer research facility. Determined the effectiveness and presented this information to the client. Researched and recommended a permanent monitoring system so the client could view data in real time.

TEN50 Condos ‘Popping’ Noise Investigation, Los Angeles, CA Was part of a team that investigated the noise source of an unwanted popping noise in luxury condos in Downtown Los Angeles. Helped isolate the noise source location with accelerometers to determine where vibrations were occurring first and used an acoustic camera to determine where in the condo the noise was coming from.

2000 University Project, Berkely, CA
Wrote a construction noise monitoring plan based on environmental noise calculations, wrote a report summarizing the results, and attending a meeting with the client to discuss options.

Bay Area Rapid Transit (BART) On‐Track, CA, San Francisco Bay Area, CA* Day to day project manager, responsible for meetings, presentations, and coordination with the client for an ongoing noise study on the BART system. Developed MATLAB code to process measurements and determine areas where high corrugation was present, contributing to excessively high in-car noise levels. Performed noise measurements inside both the right of way and the vehicle cabin, in addition to rail corrugation measurements.

California I‐605/SR‐60 Interchange Improvement, Los Angeles, CA* Developed a noise model of the area that predicted sound levels for abatement design, in addition to conducting noise measurements and analysis. Led the Team in use of the FHWA Traffic Noise Model Software for the project, involving three major highways and two busy interchanges extending over 17 miles in southern California.

Sound Transit On‐Track, Seattle, WA*
Took measurements, fixed equipment, and developed software in MATLAB to process Corrugation Analysis Trolley measurements as part of an ongoing noise study on the Sound Transit Link system.

Tested vibration data to determine the best measurement and processing techniques to store the data in an online database for in-car measurements.

LA Metro CRRC Railcar Testing, Los Angeles, CA*
Led the effort to plan the measurements, determine measurement locations and finalize the test plan. Formulated a method to capture speed data directly from legacy train vehicles. Executed noise and vibration specification measurements for new rail cars delivered by CRRC.

City of Los Ang
eles, Pershing Square Station Rehabilitation Noise Monitoring, CA* Built noise models, wrote a construction noise plan, and assisted in on-site construction noise issues as they arose for a renovation of the Pershing Square metro station in downtown Los E27
WILSON IHRIG
Jack Meighan – Page 3

* Work done prior to working for Wilson Ihrig
Angeles. Trained construction personnel in techniques for noise reduction and how to conduct noise monitoring measurements to meet project specifications.

City of Orange Metrolink Parking Garage Construction Monitoring, CA* Wrote an adaptive management vibration monitoring plan, set up equipment to monitor live vibration levels, and generated weekly reports as part of an effort to build a new parking garage.

Designed, planned, and completed measurements to predict and mitigate pile driving construction impacts at three historic building locations adjacent to the construction site. Coordinated with the client whenever an on-site problem arose.

LA Metro Westside Subway Construction, Los Angeles, CA* Planned, organized, and processed noise measurements for the Purple Line extension construction.

Implemented both long term microphones to measure noise levels and accelerometers to measure vibration levels in existing subway tunnels. Oversaw noise monitoring at sensitive construction sites for the project and worked with the contractor to find ways to reduce construction noise levels by approximately 10dB.

Montreal Réseau Express Métropolitain, Canada*
Conducted vibration propagation measurements used to create models to predict operational vibration levels for an under-construction transit line. Managed equipment, solved problems in the field, and wrote parts of the report summarizing the findings of the acoustic study.

NHCRP Barrier*
Took on-highway measurements and wrote, designed, developed, and tested MATLAB code to identify specific spectrograms to use for analyses for a project evaluating barrier reflected highway traffic noise differences in the presence of a single absorptive or reflective noise barrier.

Siemens Railcar Testing for Sound Transit, Seattle, WA* Measured in-car noise and vibration for new rail cars delivered by Siemens. Developed new internal techniques for measurements based on the written specifications. Contributed to the team that helped identify issues that new cars had in
meeting the Sound Transit specifications for noise
and vibration. Participated in developing the test plan and specified then acquired new equipment for the measurement.

Toronto/Ontario Eglinton Crosstown Light Rail, Final Design, Canada* Assisted in vibration propagation measurements, analysis, and recommendations for mitigation for a 12-mile light-rail line both on and under Eglinton Avenue. Set up and ran equipment for at-grade measurements with an impact hammer for underground measurements with an impact load cell that was used during pre-construction borehole drilling.

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INTRODUCTION
This Responses to Comments document contains comments received on the Wildflower Townhomes Project (proposed project) for which a 15183 Consistency Memorandum was prepared.

Unlike for an Environmental Impact Report (EIR), comments received regarding the 15183 Consistency Memorandum are not required to be attached to the document, nor must the lead agency provide specific written responses to public comments. Nonetheless, the lead agency has chosen to provide responses to the comments for consideration by the City decision makers.

COMMENT LETTERS
The City of Antioch received one comment letter on the proposed project that includes comments regarding the 15183 Consistency Memorandum. The comment letter was received from Adams Broadwell Joseph & Cardozo on behalf of the Contra Costa Residents for Responsible Development. The comment letter is included in the Responses to Comments section below.

RESPONSES TO COMMENTS
The Responses to Comments section below includes the comment letter received regarding the proposed project, as well as responses to each comment. The bracketed comment letter is followed by numbered responses to each bracketed comment.

RESPONSES TO COMMENTS
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1-1
Letter 1
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Letter 1 cont.
1-1
cont.

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1-1
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1-8
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LETTER 1: CONTRA COSTA RESIDENTS FOR RESPONSIBLE

DEVELOPMENT (ADAMS BROADWELL J OSEPH &

CARDOZO)

Response to Comment 1-1
The comment provides background information and is introductory to the remainder of the comment letter. Responses to the specific concerns summarized within the comment are addressed in detail below.

Response to Comment 1-2
The Housing Element EIR is a program -level EIR. According to CEQA Guidelines Section 15168(a), a program-level EIR is an EIR that may be prepared on a series of actions that could be characterized as one large project and are related either: 1) geographically; 2) as logical parts in the chain of contemplated actions; 3) in connection with issuance of rules, regulations, plans, or other general criteria to govern the conduct of a continuing program; or 4) as individual activities carried out under the same authorizing statutory or regulatory authority and having generally similar environmental effects which can be mitigated in similar ways.

The programmatic level of CEQA analysis was appropriate based on criterion 1 through 3 above, as well as due to the fact that s ite-specific details, including development proposals or technical studies, were not available. Nonetheless, the Housing Element EIR does provide a project-level analysis where possible, including for issues related to project -level construction, operational emissions, and VMT.

CEQA Guidelines Section 15183 does not require a “project -level” analysis but, rather, an examination of whether a proposed project would result in environmental effects peculiar to the project or project site from what was addressed in the Housing Element EIR. Because the Housing Element EIR addresses air quality, health risks, transportation, and noise impacts, the 15183 Consistency Memorandum appropriately addresses whether the proposed project would result in any peculiar effects related to such. In addition, contrary to the comment, the 15183 Consistency Memorandum does include specific sections discussing potential impacts related to air quality, including health risks, and transportation on pages 12 and 13, respectively.

Response to Comment 1-3
Contrary to the comment, the 15183 Consistency Memorandum clearly describes the applicable policies and mitigation measures from the Housing Element EIR. For example, as discussed on page 11, the City would require compliance with Mitigation Measure AIR -3a of the Housing Element EIR as a Condition of Approval, which would ensure impacts related to expos ing sensitive receptors to substantial pollutant concentrations would not be peculiar. In addition, page 13 of the 15183 Consistency Memorandum includes the following:

According to the Housing Element EIR, implementation of General Plan policies, such as Policy 11.7.2(c) and 11.7.2(d) (which were updated as part of the Housing Element Update), would comply with Options A and B of the BAAQMD’s recommend ed plan-level thresholds of significance and ensure that future development would not result in a cumulatively considerable contribution to global climate change. Finally, implementation of existing General Plan Policies 7.4.2, 10.6.2, 10.7.2, 10.8.2, and Housing Element Pol icy

4.1 would help to reduce GHG emissions from transportation, energy use, and water use.

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Response to Comment 1-4
In response to the comment, page 12 of the 15183 Consistency Memorandum is hereby revised as follows:

Transportation
Pursuant to Mitigation Measure TRANS -1 as set forth in the Housing Element EIR, individual housing project development proposals that do not screen out from a VMT impact analysis are required to provide a quantitative VMT analysis; however, the Housing Element EIR provides that any project that meets the screening criteria set forth in the Housing Element EIR is exempt from CEQA is not required to conduct a VMT analysis pursuant to Mitigation Measure TRANS-1. The screening criteria set forth in the Housing Element EIR include, but are not limited to, proximity to a major transit stop and projects located in low VMT areas. As shown in Figure IV.B -6 of the Housing Element EIR, the project site is located within a Transit Priority Area, defined by the Housing Element EIR as the 0.5-mile (walking radius) surrounding the City’s Bay Area Rapid Transit (BART) and Amtrak stations. In addi tion, the project site is identified as Sites 158 through 161 by the Housing Element, which are shown in Figure IV.B-6 of the Housing Element EIR as having VMT below the significance threshold under the 2020 and 2040 scenarios, which include buildout of the City in addition to the development anticipated by the Housing Element through the horizon years 2020 and 2040. Based on such, the proposed project would be considered to screen out from a VMT impact analysis and would not be anticipated to result in a significant VMT impact. As demonstrated through this 15183 Consistency Memorandum, the proposed project would not result in a significant impact that is peculiar to the project or project site, a significant effect that was not previously identified in the Housing Element EIR, or a substantially more severe significant effect related to transportation beyond what was identified in the Housing Element EIR. Therefore, pursuant to Section 15183 of the CEQA Guidelines, the proposed project qualifies for exemption from further environmental review under CEQA. Because the proposed project would meet the screening criteria set forth in the Housing Element EIR and not be anticipated to result in a significant VMT impact, be considered exempt, Mitigation Measure TRANS -1 is not applicable. Thus, the proposed project would not result in a significant impact that is peculiar to the project or the project site, was not identified as a significant effect in the Housing Element EIR, and would not result in a more severe adverse impact than the significant effects previously identified within the Housing Element EIR.

The above changes do not modify the overall conclusion of the 15183 Consistency Memorandum that, pursuant to CEQA Guidelines Section 15183, additional environmental review under CEQA is not required for the proposed project.

Response to Comment 1-5
Please see Response to Comment 1-2 above.

Response to Comment 1-6
Mitigation Measures AIR-1 and AIR-2 are not required for all future housing proposals, but, rather, only for projects that exceed the Bay Area Air District’s (BAAD) screening criteria. It should be noted that BAAD was formerly known as the Bay Area Air Quality Management District (BAAQMD) and is referred to as such in both the Housing Element EIR and the 15183 Consistency Memorandum. As discussed on page IV.C-14 and IV.C-15 of the Housing Element EIR, “… BAAQMD recommends using their project -level thresholds of significance to identify levels at which individual projects could cause significant air quality impacts related to emissions of ozone precursors (ROG and NOX), PM10, PM2.5, and TACs.” The screening criteria set forth by BAAD include the number of units for typical residential development types that, if exceeded, E59
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would result in emissions that would exceed the BAAD’s project-level thresholds of significance.

Because, as explained in the 15183 Consistency Memorandum, the project is below the screening criteria, the project’s emissions are expected to be below the applicable threshold of significance and, thus, implementation of Mitigation Measures AIR- 1 and AIR-2 of the Housing Element EIR is not required.

Mitigation Measure AIR-3(b) is specific to residential emergency generators, as, according to the Housing Element EIR, generators could substantially contribute to the existing poor air quality in the City and expose sensitive receptors to substantial pollutant concentrations. As stated in the 15183 Consistency Memorandum, the proposed project would not include emergency generators and, thus, is not subject to Mitigation Measure AIR-3(b).

Mitigation Measure AIR -3(a) is only required for projects that involve a construction duration greater than six months that are located in a BAAD Planning Healthy Place Map area. The mapped areas are described by the Housing Element EIR on page IV.C-21 as areas with elevated levels of toxic air contaminants (TACs) and/or particulate matter pollution. As stated in the 15183 Consistency Memorandum, a portion of the project site is located within a BAAD Planning Healthy Place Map area defined as needing “Best Practices ,” and project construction is anticipated to take longer than six months. Thus, the proposed project would be subject to Mitigation Measure AIR-3a, which would be included as a Condition of Approval for the project imposed by the City.

AIR-3a, as stated in the 15183 Consistency Memorandum and presented on page IV.C-22 of the Housing Element EIR, requires that one of two measures be implemented, as well as the preparation of a Construction Emissions Minimization Plan. The Housing Element EIR specifically concluded on page IV.C -23 that “implementation of Mitigation Measures AIR -3a and AIR -3b would ensure that impacts from future residential development under the Project would be less than significant related to plan- and project -level generation of TACs and PM

2.5.” Mitigation
Measure AIR -3a would be considered a uniformly applicable development policy or standard identified by the Housing Element EIR to substantially mitigate impacts associated with buildout of the Housing Element. With compliance with Mitigation Measure AIR-3a, pursuant to CEQA Guidelines Section 15183(f), the project’s impacts associated with exposure of sensitive receptors to substantial pollutant concentrations would not be considered peculiar. Because impacts related to exposure of sensitive receptors to substantial pollutant concentrations are not peculiar to the project site or project, in accordance with Section 15183(c) of the CEQA Guidelines, the proposed project qualifies for exemption from further environmental review under CEQA. The comment does not provide any substantial new information to suggest that, pursuant to CEQA Guidelines Section 15183(b)(4), the project’s impacts related to exposure of sensitive receptors to substantial pollutant concentrations would be more severe than discussed in the Housing Element EIR.

would be subject to the same regulations governing criteria air pollutants and emissions as were identified for the development projects evaluated in the Housing Element EIR.” Such regulations include the BAAD’s dust control measures to be implemented during construction, as enforced by General Plan Policy 10.6.2(a), and measures sourced from the BAAD 2017 Clean Air Plan. As noted on page IV.C -18 of the Housing Element EIR, BAAD considers implementation of best management practices (BMPs) to control dust during construction sufficient to reduce potential impacts to a less -than-significant level. Thus, the 15183 Consistency Memorandum provides sufficient supporting evidence that the project’s compliance with all applicable regulations would ensure that the proposed project would not result in a significant impact that is peculiar to the project or the project site and would not result in a more severe adverse impact than the significant effects previously identified within the Housing Element EIR.

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Responses to Comments
Wildflower Townhomes Project
August 2025

Response to Comment 1-7
Please see Response to Comment 1-6.

Response to Comment 1-8
Please see Response to Comment 1-2. The proposed project is consistent with the General Plan land use and zoning designations for the project site and, thus, was considered as part of the Housing Element EIR’s analysis. The Housing Element EIR concluded that compliance with General Plan Policy 11.8.2 would be sufficient to reduce potentially significant noise impacts to less-than-significant levels. Thus, General Plan Policy 11.8.2 is a uniformly applicable development policy identified by the Housing Element EIR as being sufficient to substantially mitigate impacts associated with buildout of the Housing Element related to noise. The proposed project would be subject to all measures and standards within Policy 11.8.2. For example, as discussed in further detail in Response to Comment 1-11, construction noise would be mitigated by Policy 11. 8.2’s requirements related to limited hours, noise reduction features, and the preparation and implementation of a construction- related noise mitigation plan. A noise attenuation study is not required, as the City has determined that the project would not result in a significant increase in noise and because the project is not located in an area exceeding the General Plan noise standards. Therefore,
consistent with the conclusions of the 15183
Consistency Memorandum and pursuant to CEQA Guidelines Section 15183(f), noise associated with the proposed project is not peculiar. With respect to specific aspects of noise impacts, such as operational noise generation, construction noise and vibration, please see Responses to Comments 1-10 through 1-12 below.

Response to Comment 1-9
Please see Response to Comment 1 -8. With respect to specific aspects of noise impacts, such as operational noise generation, construction noise and vibration, please see Responses to Comments 1-10 through 1-12 below.

Response to Comment 1-10
The proposed project is consistent with the General Plan land use and zoning designations for the project site and, thus, was considered as part of the Housing Element EIR’s analysis.

Residential uses are not typically considered significant noise- generating uses. T he proposed project does not include any operational noise-generating uses outside of typical residential uses.

Typical residential uses include heating, ventilation, and air conditioning (HVAC) units . The Housing Element EIR identifies that, according to the City’s General Plan EIR, areas within 50 feet of studied roadways could be exposed to noise levels of approximately 60 dBA CNEL.

Because Hillcrest Avenue is located adjacent to the project site, a noise level associated with potential HVAC units on the project site of 53 dB, as cited by the comment, would reasonably not be expected to result in a substantial increase in noise levels in the project vicinity. In addition, any proposed HVAC units would be shielded to reduce noise, as required by the City’s adopted Multi-family Residential Objective Design Standards.

The proposed project would be subject to the aforementioned standard, as well as the requirements within General Plan Policy 11.8.2. General Plan Policy 11.8.2 is a uniformly applicable development polic y identified by the Housing Element EIR as being sufficient to substantially mitigate impacts associated with buildout of the Housing Element related to noise.

For example, as discussed in further detail in Response to Comment 1- 11, construction noise would be mitigated by Policy 11. 8.2’s requirements related to limited hours, noise reduction features, and the preparation of a construction-related noise mitigation plan. Therefore, consistent E61
Responses to Comments
Wildflower Townhomes Project
August 2025

with the conclusions of the 15183 Consistency Memorandum and pursuant to CEQA Guidelines Section 15183(f), noise associated with the proposed project is not peculiar.

Response to Comment 1-11
The Housing Element EIR concluded that implementation of the City of Antioch Code of Ordinances and General Plan policies would ensure that the construction of individual residential developments under the Housing Element would not result in a substantial temporary increase in ambient noise levels related to construction activities, and impacts were determined to be less than significant. Specifically, as noted on pages IV.L-11 and IV.L-12 of the Housing Element EIR and pursuant to General Plan Policy 11.8.2, temporary construction periods would be subject to various measures, including the following:

• C onstruction activities shall be regulated to hours of operation within Section 5-17.05(B) of the City of Antioch Code of Ordinances in order to avoid or mitigate noise impacts on adjacent noise-sensitive land uses;
• P roposed development adjacent to occupied noise sensitive land uses shall implement a construction-related noise mitigation plan that depict s the location of construction equipment storage and maintenance areas, and document s methods to be employed to minimize noise impacts on adjacent noise sensitive land uses; and • A ll construction equipment shall use noise reduction features (e.g., mufflers and engine shrouds) that are at least as effective as those originally installed by the manufacturer.

With respect to the construction-related noise mitigation plan, as noted within General Plan Policy

11.8.2(o), the City shall condition approval of subdivisions located adjacent to any developed/occupied noise-sensitive land uses to
submit such a plan for review and approval prior
to the issuance of any grading plans. The plan would depict the location of construction equipment and how such equipment noise would be mitigated, including through temporary noise-attenuation fences, equipment mufflers, staging area locations, and limiting construction-related activities (including truck deliveries) to the hours of 7:00 AM and 7:00 PM, Monday through Saturday.

Lastly, the construction- related noise mitigation plan shall incorporate any other restrictions imposed by the City. General Plan Policy 11.8.2(o) is a uniformly applicable development policy identified by the Housing Element EIR as being sufficient to substantially mitigate impacts associated with buildout of the Housing Element related to construction noise. The comment does not provide any substantial new information that shows that compliance with General Plan Policy

11.8.2 would not substantially mitigate construction noise. General Plan Policy 11. 8.2(o) specifically states, “ The construction contractor shall use temporary noise- attenuation fences, where feasible, to reduce construction noise impacts on adjacent noise sensitive land uses.” The proposed project would be subject to such measures, which the Housing Element EIR concluded would be sufficient to reduce project construction noise to a less-than-significant level. Therefore, pursuant to CEQA Guidelines Section 15183(f), construction noise associated with the proposed project is not peculiar and the 15183 Consistency Memorandum’s conclusion is appropriate.

It should be noted that Comment 1-14 uses the Los Angeles County construction noise limit threshold of 75 dBA, which is inapplicable to the proposed project (located in the City of Antioch within Contra Costa County). The City does not have an established daytime noise level threshold for construction, but does limit the hours of construction within Section 5-17.05(B) of the Antioch Code of Ordinances, as enforced by General Plan Policy 11.8.2.

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Responses to Comments
Wildflower Townhomes Project
August 2025

Because the proposed project is consistent with the type of on -site development anticipated by the Housing Element EIR, which concluded that compliance with the standards contained within the City of Antioch Code of Ordinances and with the applicable General Plan policies would be sufficient to ensure potential impacts related to noise would be less than significant, the 15183 Consistency Memorandum’s conclusion that noise associated with the proposed project would not be peculiar remains adequate.

Response to Comment 1-12
As discussed on page IV.L-15 of the Housing Element EIR, the requirement for a screening level vibration analysis is based specifically on the use of impact pile drivers during construction. The use of pile drivers is generally required for the construction of deep foundations, bridges , docks, or skyscrapers, or excavations associated with temporary retaining walls. Pile drivers are not typically used for standard residential developments; therefore, the requirements of Policy

11.8.2(k) would not be required for the proposed project. Thus, consistent with the conclusions within the 15183 Consistency Memorandum, the proposed project would not result in any peculiar impacts related to noise.

Response to Comment 1-13
Please see Responses to Comments 1-2 through 1-12 above.

Response to Comment 1-14
Please see Responses to Comments 1-8 through 1-12 above.

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KEVIN T. CARMICHAEL
CHRISTINA M. CARO
THOMAS A. ENSLOW
KELILAH D. FEDERMAN
RICHARD M. FRANCO
ANDREW J. GRAF
TANYA A. GULESSERIAN
DARION N. JOHNSTON
RACHAEL E. KOSS
AIDAN P. MARSHALL
ALAURA R. McGUIRE

ISABEL TAHIR
Of Counsel
DANIEL L. CARDOZO
MARC D. JOSEPH

SACRAMENTO OFFICE
520 C
APITOL MALL, SUITE 350
SACRAMENTO, CA 95814 -4721
TEL: (916) 444- 6201
FAX: (916) 444 - 6209

ADAMS BROADWELL JOSEPH & CARDOZO

A PROFESSIONAL CORPORATION

ATTORNEYS AT LAW
601 GATEWAY BOULEVARD, SUITE 1000
SOUTH SAN FRANCISCO, CA 94080 - 7037
___________
TEL: (650) 589- 1660
FAX: (650) 589 - 5062
[email protected]
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A
ugust 19, 2025
V
ia Email and Overnight Mail
City of Antioch Planning Commission
Kevin Riley, Chair
Seth Webber, Vice-Chair
Commissioners Jennifer Perez,
Robert Martin, Ramesh Suman,
Cortney L. Jones
City of Antioch
200 H Street
Antioch, CA 94531
Email: [email protected]
V
ia Email Only
Kevin Scudero, Acting Director
Community Development Department
200 H Street
Antioch, CA 94531
Email: [email protected]
Zoe Merideth, Senior Planner
Email: [email protected]
R
e: Antioch Planning Commission Hearing, Agenda Item 6-1; Wildflower Station Townhomes 2 Multifamily Residential Project (TM-02, AR-23-05)
D
ear Chair Riley, Vice-Chair Webber, Commissioners, Mr. Scudero, and Ms.

Merideth:

W
e are writing on behalf of Contra Costa Residents for Responsible Development (“Contra Costa Residents”) to provide comments on Agenda Item 6-1, the Wildflower Station Townhomes 2 Multifamily Residential Project (TM-02, AR- 23-05) (“Wildflower Townhomes Project” or “Project”) proposed by DeNova Homes, Inc. (“Applicant”). The Project consists of a vesting tentative map to create 19 residential lots for 19 townhome buildings, containing 159 residential units total. 1 1 City of Antioch, Wildflower Townhomes Section 15183 Consistency Memorandum , p. 2.

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The Project site is a 10.35 acre undeveloped site located east of Hillcrest Avenue and west of Wildflower Station Place in the City of Antioch (“City”).2 The Staff Report claims that the Project is exempt from further CEQA review pursuant to CEQA Guidelines Section 15183 because it was adequately analyzed by the Antioch Housing, Environmental Hazards, and Environmental Justice Elements Project Environmental Impact Report (“Housing Element EIR”). 3 As such,
the Staff Report asks the Commission to recommend that the City Council approve the Project’s Vesting Tentative Subdivision Map (“VTSM”), and Design Review (“DR”).4
O
n July 15, 2025, Contra Costa Residents submitted comments, supported by expert evidence, explaining that the Project is likely to result in peculiar impacts that were not identified or analyzed in the Housing Element EIR or the 15183 Consistency Memorandum, thereby requiring preparation of a full EIR. Specifically, Contra Costa Residents’ expert reports included evidence demonstrating that the Project may result in potentially significant and peculiar impacts on air quality, public health, and noise. The City failed to analyze noise impacts specific to the Project, while our noise expert identified significant construction noise and vibration impacts that are unique to the Project site and were not addressed in the Housing Element EIR. Additionally, neither the Consistency Memorandum nor the Housing Element EIR included emissions modeling to assess potential air quality and public health impacts.

T
he Commission’s Staff Report includes responses to these comments (“Responses”).5 However, the City’s responses fail to resolve the deficiencies in the Project’s impact analysis. As discussed in detail below, the Project will result in significant, site-specific air quality, public health, and noise impacts that were not previously analyzed in the Housing Element EIR. In addition, the City has failed to provide substantial evidence demonstrating that Housing Element policies and/or standards will substantially mitigate these Project-specific impacts. These comments are supported by additional expert evidence. Contra Costa Residents’ air quality and public health experts Matt Hagemann, P.G., C.Hg, and Paul Rosenfeld, Ph.D. of Soil Water Air Protection Enterprises (“SWAPE”), provide substantial 2 Id.
3 City of Antioch, Wildflower Townhomes Staff Report to the Antioch Planning Commission Regular Meeting of August 2025 (“Wildflower Staff Report”), p. 9, available at:
https://www.antiochca.gov/fc/government/agendas/PC/staff-reports/082025-6-1.pdf. 4 Wildflower Staff Report, p. 1.
5 Wildflower Staff Report, Attachment E, p. E29.

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evidence demonstrating that the Project will have peculiar air quality and public health impacts from construction-related diesel particulate matter (“DPM”) emissions that the Housing Element EIR did not address.6 Contra Costa Residents’ noise consultant, Jack Meighan, demonstrates that the City lacks substantial evidence to conclude that the Project’s noise levels will not exceed General Plan policies or result in peculiar noise impacts because it failed to conduct a noise attenuation study.
7 T
he City has failed to provide substantial evidence demonstrating that the Project will not result in significant site-specific environmental impacts. Contra Costa Residents’ expert consultants have also provided substantial evidence that the Project will result in significant impacts that neither the Housing Element EIR nor the 15183 Consistency Memorandum addressed. As a result, the Project is not exempt from further CEQA review and the City must prepare an EIR that analyzes all of the Project’s potentially significant environmental impacts before the Commission may consider approving the Project or its entitlements.

I. S

TATEMENT OF INTEREST
C
ontra Costa Residents is an unincorporated association of individuals and labor organizations that may be adversely affected by the potential public and worker health and safety hazards, and the environmental and public service impacts of the Project. The coalition includes the International Brotherhood of Electrical Workers Local 302, Plumbers & Steamfitters Local 159, Sheet Metal Workers Local 104, Sprinkler Fitters Local 483, along with their members, their families, and other individuals who live and work in the City of Antioch and Contra Costa County.

Co
ntra Costa Residents’ individual members live, work, recreate, and raise their families in the City of Antioch and surrounding communities. Accordingly, they would be directly affected by the Project’s environmental, health, and safety impacts. Individual members may also work on the Project itself. They will be first in line to be exposed to any health and safety hazards that exist on site. 6 See Exhibit A, SWAPE, Comments on Wildflower Townhomes 8.20 Planning Commission Hearing Staff Report (August 18, 2025) (“SWAPE Comments”).
7 See Exhibit B, Jack Meighan, Comments on Wildflower Townhomes 8.20 Planning Commission Hearing Staff Report (August 18, 2025) (“Meighan Comments”).

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Contra Costa Residents also has an interest in enforcing environmental laws that encourage sustainable development and ensure a safe working environment for its members. Environmentally detrimental projects can jeopardize future jobs by making it more difficult and more expensive for businesses and industries to expand in the region, and by making the area less desirable for new businesses and new residents. Indeed, continued environmental degradation can, and has, caused construction moratoriums and other restrictions on growth that, in turn, reduce future employment opportunities.

II. THE PROJECT INVOLVES POTENTIALLY SIGNIFICANT OR

PECULIAR IMPACTS THAT PRECLUDE RELIANCE ON CEQA
GUIDELINES SECTION 15183 EXEMPTION

CEQA Guidelines Section 15183 provides an exemption for projects which are consistent with the development density established by existing zoning, community plan or general plan policies for which an EIR was certified, except as necessary to evaluate whether there are project-specific significant impacts which are peculiar to the project or project site.
8 In relying on section 15183 to approve a project, a lead agency may not forgo further analysis of potentially significant impacts unless it makes certain findings. An agency is required to perform further analysis as to impacts that (1) are peculiar to the proposed project or parcel, (2) were not analyzed as significant effects in a prior EIR for the zoning, community or general plan with which the project is consistent, (3) are potentially significant off-site or cumulative impacts that were not discussed in the prior EIR, or (4) are previously identified significant impacts which, due to substantial new information not known at the time the EIR was certified, are determined to have a more severe impact than discussed in the prior EIR.
9 Under section 15183(f), an effect of a project on the environment is not considered peculiar to the project or project site if “uniformly applied development policies or standards have been previously adopted …with a finding that the development policies or standards will substantially mitigate the environmental effect when applied to future projects, unless substantial new information shows that the policies or standards will not substantially mitigate the environmental effect.”
10 8 14 CCR § 15183(a).
9 14 CCR § 15183(b)(1)-(4).
10 14 CCR § 15183(f).

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Agency determinations under Guidelines section 15183 are reviewed under the substantial evidence standard.11 In determining whether an agency’s findings concerning the use of a statutory exemption from CEQA may be upheld, courts review the administrative record to see that substantial evidence supports each element of the exemption.
12 This includes the determination that “uniformly applied development policies or standards” will substantially mitigate the project’s environmental effects.
13 Agency findings must specifically address the effect of uniform policies and standards on potential environmental impacts.14

In addition, CEQA Guidelines Section 15168’s two-step inquiry of a program EIR’s applicability to later activities holds that “if a later activity would have effects that were not examined in the program EIR, a new initial study would need to be prepared leading to either an EIR or a negative declaration.” The City insists that, pursuant to sections 15162 and 15183, the Project is within the scope of the program EIR and no subsequent EIR is required. “Whether a later activity is within the scope of a program EIR is a factual question that the lead agency determines based on substantial evidence in the record.”
15 Contra Costa Resident’s previous comments explained that the 15183 Consistency Memo failed to examine several of the Project’s significant impacts related to air quality, health risks, transportation, and noise that were not analyzed in the Housing Element EIR and are thus peculiar to the proposed Project. In response to these comments, the City revised its 15183 Consistency Memorandum and now reasserts that the Project would not result in any significant or peculiar environmental impacts that require the preparation of an EIR.

The City’s response fails to address the concerns in Contra Costa Residents’ comments, and its conclusion that the Project will not result in significant and peculiar impacts is not supported by substantial evidence. As the comments below demonstrate, there is substantial evidence that the Project will result in significant and peculiar impacts to air quality, public health, and noise that the Housing Element EIR and the City’s responses and the revised Consistency Memorandum fail to address. This evidence precludes the City from relying on the CEQA

11 Lucas v. City of Pomona (2023) 92 Cal.App.5th 508, 538, citing Concerned Dublin Citizens v. City of Dublin (2103) 214 Cal.App.4th 1301, 1311; see also, Hilltop Group v. County of San Diego (2024) 99 Cal.App.5th 890, 909-10.
12 Lucas, 92 Cal.App.5th at 538.
13 14 CCR § 15183(f).
14 Hilltop Group, 99 Cal.App.5th at 918.
15 CEQA Guidelines § 15168.

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Guidelines Section 15183 exemption to avoid further CEQA review. In order to comply with CEQA, the City must prepare an EIR that analyzes the Project’s potentially significant and peculiar impacts.

A. The Project’s Diesel Particulate Matter Emissions Will Have Significant, Unmitigated Air Quality and Public Health Impacts That are More Severe Than Analyzed in The Housing Element EIR

Contra Costa Residents’ previous comments demonstrated that the City lacks substantial evidence to conclude that the Project would not result in significant air quality or public health impacts peculiar to the Project or Project site. The Housing Element EIR did not evaluate Project-specific emissions, and the City did not conduct any emissions modeling to assess the potential impacts from the Project’s construction or operation.

The City’s response continues to ignore potentially significant and site- specific air quality and health risks associated with DPM emissions during construction. In particular, the City failed to prepare a health risk analysis (“HRA”).

Contra Costa Residents’ air quality experts, SWAPE, conducted a screening-level HRA for the Project
16 and found that the Project would emit approximately 31 pounds of DPM during its 565-day construction period and an additional 20 net pounds annually during operation.17 Based on these emissions, SWAPE calculated lifetime cancer risks (30 years) of 16.3 in one million.18 This exceeds the Bay Area Air Quality Management District’s (“BAAQMD”) significance threshold of 10 in one million.
19 This is a significant and peculiar air quality and public health risk that was not addressed in the Housing Element EIR or the City’s 15183 Consistency Memo.20 Because of this, SWAPE explains that a refined HRA should be conducted to adequately and accurately evaluate the Project’s potential health risks from DPM emissions.
21 The City also fails to provide substantial evidence demonstrating that the Project’s DPM emissions will be reduced to less-than-significant levels. The City has not identified or committed to any Project-specific mitigation measures to address

16 SWAPE Comments, pp. 1-6.
17 SWAPE Comments, p. 2.
18 SWAPE Comments, p. 6.
19 Id.
20 Id.
21 Id.

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these emissions. Instead, the City asserts that general compliance with existing air quality regulations is sufficient to avoid significant impacts. As SWAPE explains, if the City’s refined HRA finds that the Project would result in significant health risk impacts, then mitigation measures should be incorporated to reduce DPM emissions to the greatest extent feasible, as required by CEQA.
22 SWAPE goes on to identify
several feasible, cost-effective mitigation measures that the City could implement to substantially reduce DPM emissions.23

There is substantial evidence that the Project will result in significant and site-specific air quality and health risk impacts. These impacts were not addressed in the Housing Element EIR or the City’s 15183 Consistency Memorandum. The City has also failed to propose any DPM specific mitigation measures or provide any evidence to demonstrate that impacts from DPM emissions will be mitigated to the greatest extent feasible. Accordingly, the City cannot rely on the CEQA Guidelines Section 15183 exemption. The City must prepare an EIR that evaluates the Project- specific, significant air quality and health risk impacts and proposes mitigation measures that will reduce impacts to the greatest extent feasible, as required by CEQA.

B. The Project Will Have Significant, Unmitigated Noise Impacts That are More Severe Than Analyzed in The Housing Element EIR

Contra Costa Residents’ and its noise expert’s previous comments demonstrated that the City lacks substantial evidence to conclude that the Project will not result in significant and peculiar noise impacts to existing sensitive receptors. The City failed to conduct any site-specific noise analysis to evaluate the Project’s potential to generate excessive construction noise or vibration. Our noise expert also provided substantial evidence showing that the Project is likely to result in significant construction and vibration impacts that are peculiar to the Project- site.

In response, the City claims that the Project’s noise impacts will not be peculiar because construction noise would be mitigated through compliance with the City of Antioch Code of Ordinance and General Plan policies. Specifically, the City asserts that compliance with General Plan Policy 11.8.2 (“Policy”) will substantially mitigate impacts. But, the City also claims that the Project does not need to prepare a noise attenuation study—as required under subsection (f) of the

22 Id.
23 SWAPE Comments, pp. 7-8.

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Policy—because “the City has determined that the Project would not result in a significant increase in noise and because the project is not located in an area exceeding the General Plan noise standards.24 This response is inadequate, unsupported, and misrepresents the housing Element EIR’s own findings.

The Housing Element EIR explicitly states that “[i]ndividual housing developments proposed under the Project would result in a potentially significant impact if they cause a new exceedance of the General Plan noise objectives, or an audible (3.0 dBA) increase in noise in areas where the General Plan noise objectives are already exceeded as the result of existing development….”25 In such cases, “General Plan Policy 11.8.2(f) requires a detailed noise attenuation study to be prepared by a qualified acoustical engineer to determine appropriate mitigation and ways to incorporate such mitigation into project design and implementation.” 26 Yet
the City has provided no analysis to determine whether either of these conditions apply to the Project.27 Instead, it simply asserts, without baseline noise measurements or supporting data, that the Project would not trigger these thresholds.28

As Mr. Meighan explains, site-specific baseline noise measurements are essential to determining whether the Project will exceed General Plan noise thresholds or cause a significant increase in ambient noise. 29 Site-specific noise
levels vary significantly based on factors such as surrounding land uses, topography, traffic patterns, and building design.
30 Absent this data, the City lacks
the substantial evidence necessary to determine whether the Project will comply with General Plan noise standards, and therefore cannot justify its conclusion that a noise attenuation study is not necessary.
31 Moreover, Mr. Meighan’s previous comments provided substantial evidence that the project may result in significant construction-related noise and vibration impacts. The City has failed to provide any evidence to rebut this analysis. Instead, it relies solely on the assertion that compliance with the City of Antioch Code of Ordinances and General Plan policies will be sufficient to reduce noise impacts to

24 Wildflower Staff Report, Attachment E, p. E61.
25 Housing Element EIR, p. IV.L-10.
26 Housing Element EIR, p. IV.L-13.
27 Meighan Comments, p. 1.
28 Meighan Comments, p. 1.
29 Meighan Comments, p. 1.
30 Id.
31 Id. at pp. 1-2.

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less-than-significant levels. While the Housing Element EIR generally found that compliance with these standards could mitigate impacts, the City has not demonstrated that it is complying with these policies. Specifically, it has failed to prepare the noise attenuation study required by Policy 11.8.2(f), nor has it provided any site-specific analysis or data to justify its conclusion that the study is unnecessary. Without this, the City lacks substantial evidence to support its determination that the Project’s noise impacts will not be significant or peculiar to the site.

Because the City has failed to demonstrate—based on substantial evidence— that the Project will not result in significant and peculiar noise impacts, it cannot rely on the CEQA Guidelines Section 15183 exemption. The City must prepare an EIR that includes an analysis of the Project-specific noise impacts.

III. THE CITY LACKS SUBSTANTIAL EVIDENCE TO MAKE THE

REQUIRED FINDINGS TO APPROVE THE PROJECTS

ENTITLEMENTS

The Project requires the City to approve a VTSM for condominium purposes that would subdivide the project site for the development of 19 townhome buildings totaling 159 residential units.
32 However, as discussed above, the City has failed to
adequately address Contra Costa Residents’ previous comments and thus still fails to adequately analyze or mitigate several new Project-specific environmental impacts that were not addressed by the Housing Element EIR. As a result, the City cannot make the requisite findings to approve the Project’s VTSM.

California’s Subdivision Map Act precludes the approval of a tentative map where the design or improvement of the proposed subdivision is not consistent with the applicable general plan, is likely to cause substantial environmental damage, or is likely to cause serious public health problems.
33 Additionally, Antioch Municipal Code Section 9-4.323 states that a VTSM may be made conditional or denied if any of the following is determined:

• A failure to do so would place the residents of the subdivision or the immediate community, or both, in a condition dangerous to their health or safety, or both; or

32 Wildflower Staff Report, p. 1.
33 Government Code § 66474(b), (e) and (f).

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• The condition or denial is required in order to comply with state or federal laws.

As detailed in our comments and those of our experts, there is substantial evidence that the Project may result in several potentially significant environmental impacts peculiar to the Project, including: (1) construction noise and vibration, and (2) air quality and related health risks. These impacts remain unaddressed and could pose serious risks to public health and safety—both for future subdivision residents and the surrounding community. Therefore, the City cannot make the required findings under the Subdivision Map Act and Antioch’s Municipal Code to approve the VTSM until all of the Project’s potentially significant impacts are thoroughly analyzed and effectively mitigated.

IV. CONCLUSIONS

As discussed herein, the City lacks substantial evidence to rely on a CEQA Guidelines Section 15183 exemption for Project approval. The Project will result in potentially significant impacts which are peculiar to the Project and Project site and will require mitigation. Therefore, the Commission cannot approve the Project until the City complies with CEQA by preparing an EIR.

Sincerely,

Alaura McGuire

Attachments
ARM:acp
F10

EXHIBIT A
F11

2656 29th Street, Suite 201
Santa Monica, CA 90405
Matt Hagemann, P.G, C.Hg.
(949) 887-9013
[email protected]
Paul E. Rosenfeld, PhD
(310) 795-2335
[email protected]
August 19, 2025
Alaura McGuire
Adams Broadwell Joseph & Cardozo
601 Gateway Blvd #1000
South San Francisco, CA 94080
Subject: Comments on the Wildflower Townhomes Project
Dear Ms. McGuire,
We have reviewed the March 2024 Consistency Memorandum (“Memo”) and the Staff Report for the August 20, 2025, Planning Commission meeting for the Wildflower Townhomes Project (“Project”) located in the City of Antioch (“City”). The Project proposes to construct 159 dwelling units on a 10.35- acre site.

Our review concludes that the Memo fails to adequately evaluate the Project’s health risk impacts. As a result, emissions and health risk impacts associated with construction and operation of the proposed Project may be underestimated and inadequately addressed. A full CEQA analysis should be prepared to adequately assess and mitigate the potential health risk impacts that the project may have on the environment.

Air Quality
Screening-Level Analysis Demonstrates Potentially Significant Health Risk Impact In order to conduct our screening-level risk assessment we relied upon AERSCREEN, which is a screening level air quality dispersion model.1 AERSCREEN is included in the California Office of Environmental Health Hazard Assessment (“OEHHA”) and the California Air Pollution Control Officers Associated (“CAPCOA”) guidance as the appropriate air dispersion model for Level 2 health risk screening

1 “Air Quality Dispersion Modeling - Screening Models,” U.S. EPA, available at: https://www.epa.gov/scram/air- quality-dispersion-modeling-screening-models.

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2 assessments (“HRSAs”).2, 3 A Level 2 HRSA utilizes a limited amount of site-specific information to generate maximum reasonable downwind concentrations of air contaminants to which nearby sensitive receptors may be exposed. If an unacceptable air quality hazard is determined to be possible using AERSCREEN, a more refined modeling approach should be conducted prior to approval of the Project.

In an effort to quantitatively estimate the Project’s construction-related and operational emissions, we used the California Emissions Estimator Model (“CalEEMod”) Version 2022.1.1.29,4 as well as Project- specific information provided by the Memo. In our model, we included 159 dwelling units of the “Apartments Mid Rise” land use (Memo, p. 2). Consistent with the Memo, we also assumed Tier 4 mitigation for all construction equipment (p. 11). All other values were left as default.

We then prepared a preliminary health risk analysis (“HRA”) of the Project’s construction and operational health risk impacts to residential sensitive receptors using the annual particulate matter 2.5 (“PM2.5”) exhaust estimates from SWAPE’s CalEEMod output files.5 Consistent with recommendations set forth by OEHHA, we assumed residential exposure begins during the third trimester stage of life. 6 SWAPE’s CalEEMod model indicates that construction activities will generate approximately 31 pounds of diesel particulate matter (“DPM”) over the 565-day construction period.7 The AERSCREEN model relies on a continuous average emission rate to simulate maximum downward concentrations from point, area, and volume emission sources. To account for the variability in equipment usage and truck trips over Project construction, we calculated an average DPM emission rate by the following equation:

𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸 𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅 �𝑔𝑔𝑔𝑔𝑅𝑅𝐸𝐸𝐸𝐸
𝐸𝐸 𝑅𝑅 𝑠𝑠 𝐸𝐸𝐸𝐸 𝑠𝑠� = 31.0 𝑙𝑙𝑙𝑙 𝐸𝐸
565 𝑠𝑠 𝑅𝑅𝑑𝑑 𝐸𝐸 × 453.6 𝑔𝑔𝑔𝑔𝑅𝑅𝐸𝐸𝐸𝐸
𝑙𝑙 𝑙𝑙 𝐸𝐸 × 1 𝑠𝑠 𝑅𝑅 𝑑𝑑
24 ℎ𝐸𝐸𝑜𝑜 𝑔𝑔𝐸𝐸 × 1 ℎ𝐸𝐸 𝑜𝑜𝑔𝑔
3,600 𝐸𝐸 𝑅𝑅 𝑠𝑠 𝐸𝐸𝐸𝐸𝑠𝑠 𝐸𝐸 = 𝟎𝟎. 𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎/𝒔𝒔
Using this equation, we estimated a construction emission rate of 0.000288 grams per second (“g/s”).

Subtracting the 565-day construction period from the total residential duration of 30 years, we assumed that after Project construction, the sensitive receptor would be exposed to the Project’s operational DPM for an additional 28.45 years. SWAPE’s operational CalEEMod emissions indicate that operational activities will generate approximately 20 net pounds of DPM per year throughout operation. Applying the same equation used to estimate the construction DPM rate, we estimated the following emission rate for Project operation:

𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸 𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅 �𝑔𝑔𝑔𝑔𝑅𝑅𝐸𝐸𝐸𝐸
𝐸𝐸 𝑅𝑅 𝑠𝑠 𝐸𝐸𝐸𝐸 𝑠𝑠� = 20 𝑙𝑙𝑙𝑙 𝐸𝐸
365 𝑠𝑠 𝑅𝑅𝑑𝑑 𝐸𝐸 × 453.6 𝑔𝑔𝑔𝑔𝑅𝑅 𝐸𝐸𝐸𝐸
𝑙𝑙 𝑙𝑙 𝐸𝐸 × 1 𝑠𝑠 𝑅𝑅 𝑑𝑑
24 ℎ𝐸𝐸𝑜𝑜 𝑔𝑔𝐸𝐸 × 1 ℎ𝐸𝐸 𝑜𝑜𝑔𝑔
3,600 𝐸𝐸 𝑅𝑅 𝑠𝑠 𝐸𝐸𝐸𝐸𝑠𝑠 𝐸𝐸 = 𝟎𝟎. 𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎/𝒔𝒔

2 “Risk Assessment Guidelines: Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February 2015, available at: https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf. 3 “Health Risk Assessments for Proposed Land Use Projects.” CAPCOA, July 2009, available at:
http://www.valleyair.org/transportation/CAPCOA_HRA_LU_Guidelines_8-6-09.pdf. 4 “CalEEMod” CAPCOA, available at: https://caleemod.com/. 5 See Attachment A for SWAPE’s CalEEMod output files.
6 “Risk Assessment Guidelines: Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February 2015, available at: https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf, p. 8-18. 7 See Attachment B for health risk calculations.

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3 Using this equation, we estimated an operational emission rate of 0.00028 g/s. Construction and operation were simulated as a 10.35-acre rectangular area source in AERSCREEN, with approximate dimensions of 289- by 145-meters. A release height of three meters was selected to represent the height of stacks of operational equipment and other heavy-duty vehicles, and an initial vertical dimension of one and a half meters was used to simulate instantaneous plume dispersion upon release.

An urban meteorological setting was selected with model-default inputs for wind speed and direction distribution. The population of Antioch was obtained from U.S. 2024 Census data. 8 The AERSCREEN model generates maximum reasonable estimates of single-hour DPM concentrations from the Project Site. The Environmental Protection Agency (“EPA”) suggests that the annualized average concentration of an air pollutant be estimated by multiplying the single-hour concentration by 10% in screening procedures.
9 Review of the Memo indicates that the nearest sensitive receptors are immediately adjacent to the Project site (p. 2). However, review of the AERSCREEN output files demonstrates that the maximally exposed individual receptor (“MEIR”) is located approximately 150 meters from the Project site. Thus, the single-hour concentration estimated by AERSCREEN for Project construction is approximately 0.2761 µg/m3 DPM at approximately 150 meters downwind. Multiplying this single-hour concentration by 10%, we get an annualized average concentration of 0.02761 µg/m3 for Project construction at the MEIR. For Project operation, the single-hour concentration estimated by AERSCREEN is 0.2761 µg/m3 DPM at approximately 150 meters downwind. Multiplying this single-hour concentration by 10%, we get an annualized average concentration of 0.02761 µg/m3 for Project operation at the MEIR. 10
We calculated the excess cancer risk to the MEIR using applicable HRA methodologies prescribed by OEHHA, as recommended by the Bay Area Air Quality Management District (“BAAQMD”). 11 Specifically,
guidance from OEHHA and the California Air Resources Board (“CARB”) recommends the use of a standard point estimate approach, including high-point estimate (i.e. 95th percentile) breathing rates and age sensitivity factors (“ASF”) in order to account for the increased sensitivity to carcinogens during early-in-life exposure and accurately assess risk for susceptible subpopulations such as children. The residential exposure parameters, such as the daily breathing rates (“BR/BW”), exposure duration (“ED”), ASFs, fraction of time at home (“FAH”), and exposure frequency (“EF”) utilized for the various age groups in our screening-level HRA are as follows:

8 “Antioch.” U.S. Census Bureau, 2024, available at:
https://datacommons.org/place/geoId/0602252?q=Antioch%2C+CA%2C+USA. 9 “Screening Procedures for Estimating the Air Quality Impact of Stationary Sources Revised.” U.S. EPA, October 1992, available at: https://www.epa.gov/sites/default/files/2020-09/documents/epa-454r-92-019_ocr.pdf 10 See Attachment C for AERSCREEN output files.
11 “California Environmental Quality Act Air Quality Guidelines.” BAAQMD, May 2017, available at:
http://www.baaqmd.gov/~/media/files/planning-and-research/ceqa/ceqa_guidelines_may2017-pdf.pdf?la=en, p. 56; see also “Recommended Methods for Screening and Modeling Local Risks and Hazards.” BAAQMD, May 2012, available at: https://www.baaqmd.gov/~/media/files/planning-and-research/ceqa/risk-modeling-approach-may- 2012.pdf, p. 65, 86.

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4 Exposure Assumptions for Residential Individual Cancer Risk Age Group
Breathing
Rate
(L/kg-day)12
Age
Sensitivity
Factor13
Exposure
Duration
(years)
Fraction of
Time at
Home14
Exposure
Frequency
(days/year)15
Exposure
Time
(hours/day)
3rd Trimester 361 10 0.25 0.85 350 24
Infant (0 – 2) 1090 10 2 0.85 350 24
Child (2 – 16) 572 3 14 0.72 350 24
Adult (16 – 30) 261 1 14 0.73 350 24
For the inhalation pathway, the procedure requires the incorporation of several discrete variates to effectively quantify dose for each age group. Once determined, contaminant dose is multiplied by the cancer potency factor (“CPF”) in units of inverse dose expressed in milligrams per kilogram per day (mg/kg/day
-1) to derive the cancer risk estimate. Therefore, to assess exposures, we utilized the following dose algorithm:

𝐷𝐷𝐸𝐸𝐸𝐸
𝑅𝑅𝐴𝐴𝐴𝐴𝐴𝐴,𝑝𝑝𝑝𝑝𝑝𝑝 𝑎𝑎𝑎𝑎𝑝𝑝 𝑎𝑎 𝑝𝑝 𝑔𝑔𝑔𝑔𝑝𝑝 = 𝐶𝐶𝑎𝑎𝑎𝑎𝑝𝑝 × 𝐸𝐸𝐸𝐸 × � 𝐵𝐵 𝑅𝑅 𝐵𝐵𝐵𝐵� × 𝐴𝐴 × 𝐶𝐶 𝐸𝐸
w
here:

DoseAIR = dose by inhalation (mg/kg/day), per age group Cair = concentration of contaminant in air (μg/m3)
EF = exposure frequency (number of days/365 days)
BR/BW = daily breathing rate normalized to body weight (L/kg/day)

12 “Air Toxics NSR Program Health Risk Assessment Guidelines.” BAAQMD, December 2016, available at:
https://www.baaqmd.gov/~/media/files/planning-and-research/permit- modeling/hra_guidelines_12_7_2016_clean-
pdf.pdf?la=en#:~:text=To%20assess%20potential%20inhalation%20exposure%20to%20offsite%20workers%2C%20 OEHHA%20recommended,for%20an%20eight%2Dhour%20day, p. 6; see also “Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February 2015, available at:
https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf. 13 “Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February 2015, available at: https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf, p. 8-5 Table 8.3. 14 “Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February 2015, available at: https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf, p. 5-24; see also: “Air Toxics NSR Program Health Risk Assessment Guidelines.” BAAQMD, December 2016, available at:
https://www.baaqmd.gov/~/media/files/planning-and-research/permit- modeling/hra_guidelines_12_7_2016_clean-
pdf.pdf?la=en#:~:text=To%20assess%20potential%20inhalation%20exposure%20to%20offsite%20workers%2C%20 OEHHA%20recommended,for%20an%20eight%2Dhour%20day, p. 4, 5. 15 “Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February 2015, available at: https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf, p. 5-24.

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5 A = inhalation absorption factor (default = 1)
CF = conversion factor (1x10-6, μg to mg, L to m3)
To calculate the overall cancer risk, we used the following equation for each appropriate age group:

𝐶𝐶
𝑅𝑅𝐸𝐸𝑠𝑠𝑅𝑅𝑔𝑔 𝑅𝑅𝐸𝐸𝐸𝐸𝑅𝑅𝐴𝐴𝐴𝐴𝐴𝐴 = 𝐷𝐷𝐸𝐸𝐸𝐸 𝑅𝑅 𝐴𝐴𝐴𝐴𝐴𝐴 × 𝐶𝐶𝐶𝐶 𝐸𝐸 × 𝐴𝐴𝐴𝐴 𝐸𝐸 × 𝐸𝐸𝐴𝐴 𝐹𝐹 × 𝐸𝐸 𝐷𝐷 𝐴𝐴𝐴𝐴
where:

DoseAIR = dose by inhalation (mg/kg/day), per age group CPF = cancer potency factor, chemical-specific (mg/kg/day)-1 ASF = age sensitivity factor, per age group
FAH = fraction of time at home, per age group (for residential receptors only) ED = exposure duration (years)
AT = averaging time period over which exposure duration is averaged (always 70 years) Consistent with the 565-day construction schedule, the annualized average concentration for construction was used for the entire third trimester of pregnancy (0.25 years), as well as the first 1.30 years of the infantile stage of life (0 – 2 years). The annualized average concentration for operation was used for the remainder of the 30-year exposure period, which makes up the latter 0.70 years of the infantile stage of life, the entire child (2 – 16 years) stage of life, as well as the entire adult (16 – 30 years) stage of life. The results of our calculations are shown in the table below.

The Maximally Exposed Individual at an Existing Residential Receptor Age Group Emissions Source Duration (years) Concentration (ug/m3) Cancer Risk
3rd Trimester Construction 0.25 0.0276 3.19E-07
Construction 1.30 0.0276 5.00E-06
Operation 0.70 0.0276 2.71E-06
Infant (0 - 2) Total 2 7.71E-06
Child (2 - 16) Operation 14 0.0276 7.20E-06
Adult (16 - 30) Operation 14 0.0276 1.11E-06
Lifetime 30 1.63E-05

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6 As demonstrated in the table above, the excess cancer risks for the 3rd trimester of pregnancy, infants, children, and adults at the MEIR located approximately 150 meters away, over the course of Project construction and operation, are approximately 0.319, 7.71, 7.2, and 1.11 in one million, respectively.

The excess cancer risk over the course of a residential lifetime (30 years) is approximately 16.3 in one million. The lifetime cancer risk exceeds the BAAQMD threshold of 10 in one million, thus resulting in a potentially significant impact not previously addressed or identified by the Memo.

Our analysis represents a screening-level HRA, which is known to be conservative and tends to err on the side of health protection. The purpose of the screening-level HRA is to demonstrate the potential link between Project-generated emissions and adverse health risk impacts. According to the EPA:
“EPA’s Exposure Assessment Guidelines recommend completing exposure assessments iteratively using a tiered approach to ‘strike a balance between the costs of adding detail and refinement to an assessment and the benefits associated with that additional refinement’ (U.S.

EPA, 1992).

In other words, an assessment using basic tools (e.g., simple exposure calculations, default values, rules of thumb, conservative assumptions) can be conducted as the first phase (or tier) of the overall assessment (i.e., a screening-level assessment).

The exposure assessor or risk manager can then determine whether the results of the screening- level assessment warrant further evaluation through refinements of the input data and exposure assumptions or by using more advanced models.” As demonstrated above, screening-level analyses warrant further evaluation in a refined modeling approach. As our screening-level HRA demonstrates that construction and operation of the Project could result in a potentially significant health risk impact, a full CEQA analysis should be prepared to include a refined health risk analysis which adequately and accurately evaluates health risk impacts associated with both Project construction and operation. If the refined analysis similarly concludes that the Project would result in a significant health risk impact, then mitigation measures should be incorporated, as described below in the “Feasible Mitigation Measures Available to Reduce Emissions” section.

Mitigation
Feasible Mitigation Measures Available to Reduce Emissions As discussed above in the section titled “Screening-Level Analysis Demonstrates Potentially Significant Health Risk Impact,” the Memo demonstrates that the Project would result in potentially significant cancer risk to nearby sensitive receptors due to Project-related DPM emissions. According to the EPA, sources of DPM include “autos, trucks, and heavy on-road and offroad equipment,” which represent a “significant threat to air quality and human health.” 16

16 “Diesel Particulate Matter (PM) Air Toxics.” EPA, January 2021, available at:
https://enviroatlas.epa.gov/enviroatlas/DataFactSheets/pdf/Supplemental/DieselPMairtoxics.pdf.

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7 To comply with CEQA, the City must propose mitigation measures that will reduce DPM emissions to less than significant levels or to the greatest extent feasible if a refined HRA shows a significant impact. To reduce DPM emissions during Project construction and operations from engine exhaust, the CalEEMod User’s Guide recommends the following mitigation measures:
“The emissions mitigation measures for onsite off-road construction diesel equipment include use of alternative fuel, electric equipment, diesel particulate filters (DPF), oxidation catalysts, newer tier engines, and dust suppression.” 17
Furthermore, we recommend several applicable mitigation measures pulled from Southern California Association of Governments (“SCAG”)’s 2020 RTP/SCS Program Environment Impact Report’s Air Quality Project Level Mitigation Measures (“PMM-AQ-1”) that target Project-related DPM sources: 18 • Minimize unnecessary vehicular and machinery activities. • Require contractors to assemble a comprehensive inventory list (i.e., make, model, engine year, horsepower, emission rates) of all heavy-duty off-road (portable and mobile) equipment (50 horsepower and greater) that could be used an aggregate of 40 or more hours for the construction project. Prepare a plan for approval by the applicable air district demonstrating achievement of the applicable percent reduction for a CARB-approved fleet. Daily logging of the operating hours of the equipment should also be required. • Ensure that all construction equipment is properly tuned and maintained. • Minimize idling time to 5 minutes or beyond regulatory requirements —saves fuel and reduces emissions.

As demonstrated above, we have provided several mitigation measures that would reduce construction- related and operational DPM emissions. These measures offer a cost-effective, feasible way to incorporate lower-emitting design features into the proposed Project, which subsequently reduce emissions released during Project construction and operation.

A full CEQA analysis should be prepared that includes an updated, refined HRA as well as any necessary mitigation measures to reduce emissions to the maximum extent feasible. The full CEQA analysis should also demonstrate a commitment to the implementation of these measures prior to Project approval, to ensure that the Project’s potentially significant emissions are reduced to the maximum extent possible.

Disclaimer
SWAPE has received limited discovery regarding this project. Additional information may become available in the future; thus, we retain the right to revise or amend this report when additional

17 “Calculation Details for CalEEMod.” CAPCOA, May 2021, available at: http://www.aqmd.gov/docs/default- source/caleemod/user-guide-2021/appendix-a2020-4-0.pdf?sfvrsn=6, Appendix A, p. 60. 18 “4.0 Mitigation Measures.” Connect SoCal Program Environmental Impact Report Addendum #1, September 2020, available at: https://scag.ca.gov/sites/main/files/file- attachments/fpeir_connectsocal_addendum_4_mitigationmeasures.pdf?1606004420, p. 4.0-2 – 4.0-10; 4.0-19 –

4.0-23; See also: “Certified Final Connect SoCal Program Environmental Impact Report.” SCAG, May 2020, available at: https://scag.ca.gov/peir.

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8 information becomes available. Our professional services have been performed using that degree of care and skill ordinarily exercised, under similar circumstances, by reputable environmental consultants practicing in this or similar localities at the time of service. No other warranty, expressed or implied, is made as to the scope of work, work methodologies and protocols, site conditions, analytical testing results, and findings presented. This report reflects efforts which were limited to information that was reasonably accessible at the time of the work, and may contain informational gaps, inconsistencies, or otherwise be incomplete due to the unavailability or uncertainty of information obtained or provided by third parties.

Sincerely,

Matt Hagemann, P.G., C.Hg.

Paul E. Rosenfeld, Ph.D.

Attachment A: CalEEMod Output Files
Attachment B: Health Risk Calculations
Attachment C: AERSCREEN Output Files
Attachment D: Matt Hagemann CV
Attachment E: Paul Rosenfeld CV
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Wildflower Townhomes Custom Report
Table of Contents

1. Basic Project Information

1.1. Basic Project Information

1.2. Land Use Types

1.3. User-Selected Emission Reduction Measures by Emissions Sector

2. Emissions Summary

2.1. Construction Emissions Compared Against Thresholds

2.2. Construction Emissions by Y ear, Unmitigated

2.4. Operations Emissions Compared Against Thresholds

2.5. Operations Emissions by Sector, Unmitigated

3. Construction Emissions Details

3.1. Demolition (2026) - Unmitigated

3.3. Site Preparation (2026) - Unmitigated

3.5. Grading (2026) - Unmitigated

3.7. Building Construction (2026) - Unmitigated

3.9. Building Construction (2027) - Unmitigated
Attachment A
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3.11. Paving (2027) - Unmitigated

3.13. Architectural Coating (2027) - Unmitigated

4. Operations Emissions Details

4.1. Mobile Emissions by Land Use

4.1.1. Unmitigated

4.2. Energy

4.2.1. Electricity Emissions By Land Use - Unmitigated

4.2.3. Natural Gas Emissions By Land Use - Unmitigated

4.3. Area Emissions by Source

4.3.1. Unmitigated

4.4. Water Emissions by Land Use

4.4.1. Unmitigated

4.5. Waste Emissions by Land Use

4.5.1. Unmitigated

4.6. Refrigerant Emissions by Land Use

4.6.1. Unmitigated

4.7. Offroad Emissions By Equipment Type

4.7.1. Unmitigated
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4.8. Stationary Emissions By Equipment Type

4.8.1. Unmitigated

4.9. User Defined Emissions By Equipment Type

4.9.1. Unmitigated

4.10. Soil Carbon Accumulation By Vegetation Type

4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated

4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated

4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated

5. Activity Data

5.1. Construction Schedule

5.2. Off-Road Equipment

5.2.1. Unmitigated

5.3. Construction Vehicles

5.3.1. Unmitigated

5.4. Vehicles

5.4.1. Construction Vehicle Control Strategies

5.5. Architectural Coatings

5.6. Dust Mitigation
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5.6.1. Construction Earthmoving Activities

5.6.2. Construction Earthmoving Control Strategies

5.7. Construction Paving

5.8. Construction Electricity Consumption and Emissions Factors

5.9. Operational Mobile Sources

5.9.1. Unmitigated

5.10. Operational Area Sources

5.10.1. Hearths

5.10.1.1. Unmitigated

5.10.2. Architectural Coatings

5.10.3. Landscape Equipment

5.11. Operational Energy Consumption

5.11.1. Unmitigated

5.12. Operational Water and Wastewater Consumption

5.12.1. Unmitigated

5.13. Operational Waste Generation

5.13.1. Unmitigated

5.14. Operational Refrigeration and Air Conditioning Equipment F23
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5.14.1. Unmitigated

5.15. Operational Off-Road Equipment

5.15.1. Unmitigated

5.16. Stationary Sources

5.16.1. Emergency Generators and Fire Pumps

5.16.2. Process Boilers

5.17. User Defined

5.18. Vegetation

5.18.1. Land Use Change

5.18.1.1. Unmitigated

5.18.1. Biomass Cover Type

5.18.1.1. Unmitigated

5.18.2. Sequestration

5.18.2.1. Unmitigated

8. User Changes to Default Data
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1. Basic Project Information

1.1. Basic Project Information
Data Field Value
Project Name Wildflower Townhomes
Construction Start Date 1/1/2026
Operational Y ear 2027
Lead Agency —
Land Use Scale Project/site
Analysis Level for Defaults County
Windspeed (m/s) 3.60
Precipitation (days) 20.6
Location 37.99029248818165, -121.78321479853687
County Contra Costa
City Antioch
Air District Bay Area AQMD
Air Basin San Francisco Bay Area
TAZ 1359
EDFZ 1
Electric Utility Pacific Gas & Electric Company
Gas Utility Pacific Gas & Electric
App Version 2022.1.1.29

1.2. Land Use Types
Land Use Subtype Size Unit Lot Acreage Building Area (sq ft) Landscape Area (sq ft)
Special Landscape
Area
(sq ft)
Population Description
Apartments Mid
Rise
159 Dwelling Unit 10.3 152,640 20,000 — 460 —
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1.3. User-Selected Emission Reduction Measures by Emissions Sector No measures selected

2. Emissions Summary

2.1. Construction Emissions Compared Against Thresholds Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Un/Mit. TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 108 108 9.56 19.1 0.03 0.09 1.07 1.16 0.09 0.25 0.34 — 3,837 3,837 0.14 0.12 4.73 3,882 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 0.87 0.86 19.5 36.0 0.06 0.20 19.8 19.9 0.19 10.1 10.2 — 6,757 6,757 0.27 0.13 0.12 6,782 Average
Daily
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 6.11 6.09 7.90 14.7 0.02 0.08 1.89 1.97 0.08 0.72 0.80 — 2,946 2,946 0.11 0.08 1.15 2,973 Annual
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 1.12 1.11 1.44 2.69 < 0.005 0.01 0.35 0.36 0.01 0.13 0.15 — 488 488 0.02 0.01 0.19 492

2.2. Construction Emissions by Y ear, Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Y ear TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily -
Summer
(Max)
— — — — — — — — — — — — — — — — — —
2026 0.76 0.72 9.56 19.1 0.03 0.09 1.07 1.16 0.09 0.25 0.34 — 3,837 3,837 0.14 0.12 4.73 3,882 F26
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2027 108 108 9.53 18.8 0.03 0.09 1.07 1.16 0.09 0.25 0.34 — 3,810 3,810 0.14 0.12 4.26 3,854 Daily -
Winter
(Max)
— — — — — — — — — — — — — — — — — —
2026 0.87 0.86 19.5 36.0 0.06 0.20 19.8 19.9 0.19 10.1 10.2 — 6,757 6,757 0.27 0.13 0.12 6,782 2027 0.72 0.66 9.61 18.1 0.03 0.09 1.07 1.16 0.09 0.25 0.34 — 3,727 3,727 0.14 0.13 0.11 3,768 Average
Daily
— — — — — — — — — — — — — — — — — —
2026 0.52 0.48 7.90 14.7 0.02 0.08 1.89 1.97 0.08 0.72 0.80 — 2,946 2,946 0.11 0.08 1.15 2,973 2027 6.11 6.09 3.14 5.74 0.01 0.03 0.31 0.34 0.03 0.07 0.11 — 1,152 1,152 0.04 0.04 0.54 1,164 Annual — — — — — — — — — — — — — — — — — —
2026 0.09 0.09 1.44 2.69 < 0.005 0.01 0.35 0.36 0.01 0.13 0.15 — 488 488 0.02 0.01 0.19 492 2027 1.12 1.11 0.57 1.05 < 0.005 0.01 0.06 0.06 0.01 0.01 0.02 — 191 191 0.01 0.01 0.09 193

2.4. Operations Emissions Compared Against Thresholds
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Un/Mit. TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 8.28 7.89 4.28 34.9 0.07 0.20 5.61 5.81 0.20 1.42 1.62 74.5 8,991 9,066 7.85 0.28 21.2 9,366 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 7.28 6.91 4.60 24.0 0.07 0.20 5.61 5.80 0.19 1.42 1.62 74.5 8,545 8,619 7.88 0.30 1.61 8,908 Average
Daily
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 7.32 7.04 2.82 25.9 0.06 0.07 5.26 5.33 0.07 1.33 1.40 74.5 6,375 6,449 7.81 0.27 9.33 6,736 Annual
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 1.34 1.29 0.51 4.73 0.01 0.01 0.96 0.97 0.01 0.24 0.26 12.3 1,055 1,068 1.29 0.05 1.55 1,115 F27
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2.5. Operations Emissions by Sector, Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Sector TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Mobile 3.37 3.13 2.27 25.1 0.06 0.04 5.61 5.65 0.04 1.42 1.46 — 6,202 6,202 0.24 0.24 20.1 6,299 Area 4.88 4.74 1.66 9.69 0.01 0.13 — 0.13 0.13 — 0.13 0.00 2,016 2,016 0.04 < 0.005 — 2,018 Energy 0.04 0.02 0.35 0.15 < 0.005 0.03 — 0.03 0.03 — 0.03 — 752 752 0.09 0.01 — 756 Water — — — — — — — — — — — 11.1 21.7 32.8 1.14 0.03 — 69.5 Waste — — — — — — — — — — — 63.4 0.00 63.4 6.33 0.00 — 222 Refrig. — — — — — — — — — — — — — — — — 1.09 1.09
Total 8.28 7.89 4.28 34.9 0.07 0.20 5.61 5.81 0.20 1.42 1.62 74.5 8,991 9,066 7.85 0.28 21.2 9,366 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Mobile 3.20 2.94 2.67 23.2 0.06 0.04 5.61 5.65 0.04 1.42 1.46 — 5,779 5,779 0.28 0.26 0.52 5,865 Area 4.04 3.95 1.57 0.67 0.01 0.13 — 0.13 0.13 — 0.13 0.00 1,992 1,992 0.04 < 0.005 — 1,994 Energy 0.04 0.02 0.35 0.15 < 0.005 0.03 — 0.03 0.03 — 0.03 — 752 752 0.09 0.01 — 756 Water — — — — — — — — — — — 11.1 21.7 32.8 1.14 0.03 — 69.5 Waste — — — — — — — — — — — 63.4 0.00 63.4 6.33 0.00 — 222 Refrig. — — — — — — — — — — — — — — — — 1.09 1.09
Total 7.28 6.91 4.60 24.0 0.07 0.20 5.61 5.80 0.19 1.42 1.62 74.5 8,545 8,619 7.88 0.30 1.61 8,908 Average
Daily
— — — — — — — — — — — — — — — — — —
Mobile 3.01 2.77 2.38 21.3 0.05 0.04 5.26 5.30 0.04 1.33 1.37 — 5,540 5,540 0.25 0.24 8.24 5,626 Area 4.27 4.25 0.08 4.47 < 0.005 0.01 — 0.01 < 0.005 — < 0.005 0.00 61.0 61.0 < 0.005 < 0.005 — 61.1 Energy 0.04 0.02 0.35 0.15 < 0.005 0.03 — 0.03 0.03 — 0.03 — 752 752 0.09 0.01 — 756 Water — — — — — — — — — — — 11.1 21.7 32.8 1.14 0.03 — 69.5 Waste — — — — — — — — — — — 63.4 0.00 63.4 6.33 0.00 — 222 F28
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Refrig. — — — — — — — — — — — — — — — — 1.09 1.09
Total 7.32 7.04 2.82 25.9 0.06 0.07 5.26 5.33 0.07 1.33 1.40 74.5 6,375 6,449 7.81 0.27 9.33 6,736 Annual — — — — — — — — — — — — — — — — — —
Mobile 0.55 0.51 0.44 3.88 0.01 0.01 0.96 0.97 0.01 0.24 0.25 — 917 917 0.04 0.04 1.36 932 Area 0.78 0.78 0.01 0.82 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 0.00 10.1 10.1 < 0.005 < 0.005 — 10.1 Energy 0.01 < 0.005 0.06 0.03 < 0.005 0.01 — 0.01 0.01 — 0.01 — 124 124 0.01 < 0.005 — 125 Water — — — — — — — — — — — 1.84 3.60 5.44 0.19 < 0.005 — 11.5 Waste — — — — — — — — — — — 10.5 0.00 10.5 1.05 0.00 — 36.7 Refrig. — — — — — — — — — — — — — — — — 0.18 0.18
Total 1.34 1.29 0.51 4.73 0.01 0.01 0.96 0.97 0.01 0.24 0.26 12.3 1,055 1,068 1.29 0.05 1.55 1,115

3. Construction Emissions Details

3.1. Demolition (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.41 0.41 11.9 18.2 0.03 0.20 — 0.20 0.19 — 0.19 — 3,427 3,427 0.14 0.03 — 3,438 Demoliti
on
— — — — — — 0.00 0.00 — 0.00 0.00 — — — — — — —
Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 F29
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Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.02 0.02 0.65 1.00 < 0.005 0.01 — 0.01 0.01 — 0.01 — 188 188 0.01 < 0.005 — 188 Demoliti
on
— — — — — — 0.00 0.00 — 0.00 0.00 — — — — — — —
Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent
< 0.005 < 0.005 0.12 0.18 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 31.1 31.1 < 0.005 < 0.005 — 31.2 Demoliti
on
— — — — — — 0.00 0.00 — 0.00 0.00 — — — — — — —
Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.05 0.04 0.04 0.50 0.00 0.00 0.12 0.12 0.00 0.03 0.03 — 119 119 < 0.005 0.01 0.01 120 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.03 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 — 6.57 6.57 < 0.005 < 0.005 0.01 6.67 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 F30
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Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 1.09 1.09 < 0.005 < 0.005 < 0.005 1.10 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.3. Site Preparation (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.64 0.64 14.7 28.3 0.05 0.10 — 0.10 0.10 — 0.10 — 5,298 5,298 0.21 0.04 — 5,316 Dust
F
rom
Material
Movement
— — — — — — 19.7 19.7 — 10.1 10.1 — — — — — — —
Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.02 0.02 0.40 0.78 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 145 145 0.01 < 0.005 — 146 Dust
F
rom
Material
Movement
— — — — — — 0.54 0.54 — 0.28 0.28 — — — — — — —
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Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent
< 0.005 < 0.005 0.07 0.14 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 24.0 24.0 < 0.005 < 0.005 — 24.1 Dust
F
rom
Material
Movement
— — — — — — 0.10 0.10 — 0.05 0.05 — — — — — — —
Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.06 0.05 0.05 0.58 0.00 0.00 0.14 0.14 0.00 0.03 0.03 — 138 138 < 0.005 0.01 0.01 140 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 3.83 3.83 < 0.005 < 0.005 0.01 3.89 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.63 0.63 < 0.005 < 0.005 < 0.005 0.64 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 F32
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3.5. Grading (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.80 0.80 19.4 35.3 0.06 0.18 — 0.18 0.18 — 0.18 — 6,599 6,599 0.27 0.05 — 6,621 Dust
F
rom
Material
Movement
— — — — — — 9.20 9.20 — 3.65 3.65 — — — — — — —
Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.07 0.07 1.60 2.91 0.01 0.01 — 0.01 0.01 — 0.01 — 542 542 0.02 < 0.005 — 544 Dust
F
rom
Material
Movement
— — — — — — 0.76 0.76 — 0.30 0.30 — — — — — — —
Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
F33
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90.1—< 0.005< 0.00589.889.8—< 0.005—< 0.005< 0.005—< 0.005< 0.0050.530.290.010.01Off-Roa d
Equipm
ent
Dust
F
rom
Material
Movement
— — — — — — 0.14 0.14 — 0.05 0.05 — — — — — — —
Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.07 0.06 0.06 0.66 0.00 0.00 0.17 0.17 0.00 0.04 0.04 — 158 158 < 0.005 0.01 0.02 160 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.01 < 0.005 < 0.005 0.05 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 — 13.1 13.1 < 0.005 < 0.005 0.02 13.3 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 2.18 2.18 < 0.005 < 0.005 < 0.005 2.21 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.7. Building Construction (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) F34
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Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.32 0.32 8.74 14.3 0.02 0.09 — 0.09 0.08 — 0.08 — 2,397 2,397 0.10 0.02 — 2,405 Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.32 0.32 8.74 14.3 0.02 0.09 — 0.09 0.08 — 0.08 — 2,397 2,397 0.10 0.02 — 2,405 Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.17 0.17 4.75 7.78 0.01 0.05 — 0.05 0.05 — 0.05 — 1,304 1,304 0.05 0.01 — 1,309 Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.03 0.03 0.87 1.42 < 0.005 0.01 — 0.01 0.01 — 0.01 — 216 216 0.01 < 0.005 — 217 Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
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Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.40 0.39 0.25 4.49 0.00 0.00 0.95 0.95 0.00 0.22 0.22 — 990 990 0.02 0.04 3.64 1,005 Vendor 0.04 0.01 0.58 0.28 < 0.005 0.01 0.12 0.13 0.01 0.03 0.04 — 451 451 0.03 0.07 1.09 472 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.38 0.34 0.32 3.78 0.00 0.00 0.95 0.95 0.00 0.22 0.22 — 905 905 0.03 0.04 0.09 918 Vendor 0.04 0.01 0.61 0.29 < 0.005 0.01 0.12 0.13 0.01 0.03 0.04 — 451 451 0.02 0.07 0.03 471 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.21 0.18 0.16 2.01 0.00 0.00 0.51 0.51 0.00 0.12 0.12 — 498 498 0.01 0.02 0.85 505 Vendor 0.02 0.01 0.32 0.15 < 0.005 < 0.005 0.06 0.07 < 0.005 0.02 0.02 — 245 245 0.01 0.04 0.25 257 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker 0.04 0.03 0.03 0.37 0.00 0.00 0.09 0.09 0.00 0.02 0.02 — 82.4 82.4 < 0.005 < 0.005 0.14 83.7 Vendor < 0.005 < 0.005 0.06 0.03 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 40.6 40.6 < 0.005 0.01 0.04 42.5 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.9. Building Construction (2027) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
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2,405—0.020.102,3972,397—0.08—0.080.09—0.090.0214.38.740.320.32Off-Roa d
Equipm
Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.32 0.32 8.74 14.3 0.02 0.09 — 0.09 0.08 — 0.08 — 2,397 2,397 0.10 0.02 — 2,405 Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.09 0.09 2.45 4.00 0.01 0.02 — 0.02 0.02 — 0.02 — 671 671 0.03 0.01 — 673 Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.02 0.02 0.45 0.73 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 111 111 < 0.005 < 0.005 — 111 Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.39 0.35 0.24 4.21 0.00 0.00 0.95 0.95 0.00 0.22 0.22 — 971 971 0.02 0.04 3.30 986 Vendor 0.04 0.01 0.55 0.27 < 0.005 0.01 0.12 0.13 0.01 0.03 0.04 — 442 442 0.02 0.07 0.96 463 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 F37
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Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.37 0.33 0.29 3.56 0.00 0.00 0.95 0.95 0.00 0.22 0.22 — 888 888 0.02 0.04 0.09 901 Vendor 0.04 0.01 0.58 0.28 < 0.005 0.01 0.12 0.13 0.01 0.03 0.04 — 442 442 0.02 0.07 0.02 462 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.10 0.09 0.08 0.97 0.00 0.00 0.26 0.26 0.00 0.06 0.06 — 251 251 0.01 0.01 0.40 255 Vendor 0.01 < 0.005 0.16 0.08 < 0.005 < 0.005 0.03 0.03 < 0.005 0.01 0.01 — 124 124 0.01 0.02 0.12 129 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker 0.02 0.02 0.01 0.18 0.00 0.00 0.05 0.05 0.00 0.01 0.01 — 41.6 41.6 < 0.005 < 0.005 0.07 42.2 Vendor < 0.005 < 0.005 0.03 0.01 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 20.5 20.5 < 0.005 < 0.005 0.02 21.4 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.11. Paving (2027) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.23 0.23 7.21 10.6 0.01 0.09 — 0.09 0.08 — 0.08 — 1,511 1,511 0.06 0.01 — 1,516 Paving 0.00 0.00 — — — — — — — — — — — — — — — —
Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 F38
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——————————————————Daily,
Winter
(Max)
Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.01 0.01 0.39 0.58 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 82.8 82.8 < 0.005 < 0.005 — 83.1 Paving 0.00 0.00 — — — — — — — — — — — — — — — —
Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent
< 0.005 < 0.005 0.07 0.11 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 13.7 13.7 < 0.005 < 0.005 — 13.8 Paving 0.00 0.00 — — — — — — — — — — — — — — — —
Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.05 0.05 0.03 0.55 0.00 0.00 0.12 0.12 0.00 0.03 0.03 — 127 127 < 0.005 < 0.005 0.43 129 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.02 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 — 6.45 6.45 < 0.005 < 0.005 0.01 6.54 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 F39
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Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 1.07 1.07 < 0.005 < 0.005 < 0.005 1.08 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.13. Architectural Coating (2027) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.02 0.02 1.07 0.96 < 0.005 0.03 — 0.03 0.03 — 0.03 — 134 134 0.01 < 0.005 — 134 Architect
ur
al
Coating
s
107 107 — — — — — — — — — — — — — — — —
Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent
< 0.005 < 0.005 0.06 0.05 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 7.32 7.32 < 0.005 < 0.005 — 7.34 F40
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————————————————5.895.89Architect
ur
al
Coating
Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent
< 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 1.21 1.21 < 0.005 < 0.005 — 1.22 Architect
ur
al
Coating
s

1.07 1.07 — — — — — — — — — — — — — — — —
Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.08 0.07 0.05 0.84 0.00 0.00 0.19 0.19 0.00 0.04 0.04 — 194 194 < 0.005 0.01 0.66 197 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.04 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 — 9.84 9.84 < 0.005 < 0.005 0.02 9.98 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 1.63 1.63 < 0.005 < 0.005 < 0.005 1.65 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 F41
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Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

4. Operations Emissions Details

4.1. Mobile Emissions by Land Use

4.1.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Apartme
nts
Mid
Rise

3.37 3.13 2.27 25.1 0.06 0.04 5.61 5.65 0.04 1.42 1.46 — 6,202 6,202 0.24 0.24 20.1 6,299 Total 3.37 3.13 2.27 25.1 0.06 0.04 5.61 5.65 0.04 1.42 1.46 — 6,202 6,202 0.24 0.24 20.1 6,299 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Apartme
nts
Mid
Rise

3.20 2.94 2.67 23.2 0.06 0.04 5.61 5.65 0.04 1.42 1.46 — 5,779 5,779 0.28 0.26 0.52 5,865 Total 3.20 2.94 2.67 23.2 0.06 0.04 5.61 5.65 0.04 1.42 1.46 — 5,779 5,779 0.28 0.26 0.52 5,865 Annual — — — — — — — — — — — — — — — — — —
Apartme
nts
Mid
Rise

0.55 0.51 0.44 3.88 0.01 0.01 0.96 0.97 0.01 0.24 0.25 — 917 917 0.04 0.04 1.36 932 Total 0.55 0.51 0.44 3.88 0.01 0.01 0.96 0.97 0.01 0.24 0.25 — 917 917 0.04 0.04 1.36 932

4.2. Energy
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4.2.1. Electricity Emissions By Land Use - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Apartme
nts
Mid
Rise
— — — — — — — — — — — — 303 303 0.05 0.01 — 306
Total — — — — — — — — — — — — 303 303 0.05 0.01 — 306
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Apartme
nts
Mid
Rise
— — — — — — — — — — — — 303 303 0.05 0.01 — 306
Total — — — — — — — — — — — — 303 303 0.05 0.01 — 306
Annual — — — — — — — — — — — — — — — — — —
Apartme
nts
Mid
Rise
— — — — — — — — — — — — 50.2 50.2 0.01 < 0.005 — 50.7
Total — — — — — — — — — — — — 50.2 50.2 0.01 < 0.005 — 50.7

4.2.3. Natural Gas Emissions By Land Use - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Apartme
nts
Mid
Rise

0.04 0.02 0.35 0.15 < 0.005 0.03 — 0.03 0.03 — 0.03 — 449 449 0.04 < 0.005 — 450 F43
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Total 0.04 0.02 0.35 0.15 < 0.005 0.03 — 0.03 0.03 — 0.03 — 449 449 0.04 < 0.005 — 450 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Apartme
nts
Mid
Rise

0.04 0.02 0.35 0.15 < 0.005 0.03 — 0.03 0.03 — 0.03 — 449 449 0.04 < 0.005 — 450 Total 0.04 0.02 0.35 0.15 < 0.005 0.03 — 0.03 0.03 — 0.03 — 449 449 0.04 < 0.005 — 450 Annual — — — — — — — — — — — — — — — — — —
Apartme
nts
Mid
Rise

0.01 < 0.005 0.06 0.03 < 0.005 0.01 — 0.01 0.01 — 0.01 — 74.3 74.3 0.01 < 0.005 — 74.5 Total 0.01 < 0.005 0.06 0.03 < 0.005 0.01 — 0.01 0.01 — 0.01 — 74.3 74.3 0.01 < 0.005 — 74.5

4.3. Area Emissions by Source

4.3.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Source TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Hearths 0.18 0.09 1.57 0.67 0.01 0.13 — 0.13 0.13 — 0.13 0.00 1,992 1,992 0.04 < 0.005 — 1,994 Consum
er
Product
s

3.27 3.27 — — — — — — — — — — — — — — — —
Architect
ur
al
Coating
s

0.59 0.59 — — — — — — — — — — — — — — — —
Landsca
pe
Equipm
ent

0.84 0.79 0.09 9.03 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 24.1 24.1 < 0.005 < 0.005 — 24.2 F44
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Total 4.88 4.74 1.66 9.69 0.01 0.13 — 0.13 0.13 — 0.13 0.00 2,016 2,016 0.04 < 0.005 — 2,018 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Hearths 0.18 0.09 1.57 0.67 0.01 0.13 — 0.13 0.13 — 0.13 0.00 1,992 1,992 0.04 < 0.005 — 1,994 Consum
er
Product
s

3.27 3.27 — — — — — — — — — — — — — — — —
Architect
ur
al
Coating
s

0.59 0.59 — — — — — — — — — — — — — — — —
Total 4.04 3.95 1.57 0.67 0.01 0.13 — 0.13 0.13 — 0.13 0.00 1,992 1,992 0.04 < 0.005 — 1,994 Annual — — — — — — — — — — — — — — — — — —
Hearths < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 0.00 8.13 8.13 < 0.005 < 0.005 — 8.14 Consum
er
Product
s

0.60 0.60 — — — — — — — — — — — — — — — —
Architect
ur
al
Coating
s

0.11 0.11 — — — — — — — — — — — — — — — —
Landsca
pe
Equipm
ent

0.08 0.07 0.01 0.81 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 1.97 1.97 < 0.005 < 0.005 — 1.98 Total 0.78 0.78 0.01 0.82 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 0.00 10.1 10.1 < 0.005 < 0.005 — 10.1

4.4. Water Emissions by Land Use

4.4.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) F45
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CO2eRN2OCH4CO2TNBCO2BCO2PM2.5TPM2.5DPM2.5EPM10TPM10DPM10ESO2CONOxROGTOGLand Use
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Apartme
nts
Mid
Rise
— — — — — — — — — — — 11.1 21.7 32.8 1.14 0.03 — 69.5
Total — — — — — — — — — — — 11.1 21.7 32.8 1.14 0.03 — 69.5 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Apartme
nts
Mid
Rise
— — — — — — — — — — — 11.1 21.7 32.8 1.14 0.03 — 69.5
Total — — — — — — — — — — — 11.1 21.7 32.8 1.14 0.03 — 69.5 Annual — — — — — — — — — — — — — — — — — —
Apartme
nts
Mid
Rise
— — — — — — — — — — — 1.84 3.60 5.44 0.19 < 0.005 — 11.5 Total — — — — — — — — — — — 1.84 3.60 5.44 0.19 < 0.005 — 11.5

4.5. Waste Emissions by Land Use

4.5.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Apartme
nts
Mid
Rise
— — — — — — — — — — — 63.4 0.00 63.4 6.33 0.00 — 222
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Total — — — — — — — — — — — 63.4 0.00 63.4 6.33 0.00 — 222 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Apartme
nts
Mid
Rise
— — — — — — — — — — — 63.4 0.00 63.4 6.33 0.00 — 222
Total — — — — — — — — — — — 63.4 0.00 63.4 6.33 0.00 — 222 Annual — — — — — — — — — — — — — — — — — —
Apartme
nts
Mid
Rise
— — — — — — — — — — — 10.5 0.00 10.5 1.05 0.00 — 36.7
Total — — — — — — — — — — — 10.5 0.00 10.5 1.05 0.00 — 36.7

4.6. Refrigerant Emissions by Land Use

4.6.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Apartme
nts
Mid
Rise
— — — — — — — — — — — — — — — — 1.09 1.09
Total — — — — — — — — — — — — — — — — 1.09 1.09
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Apartme
nts
Mid
Rise
— — — — — — — — — — — — — — — — 1.09 1.09
Total — — — — — — — — — — — — — — — — 1.09 1.09
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Annual — — — — — — — — — — — — — — — — — —
Apartme
nts
Mid
Rise
— — — — — — — — — — — — — — — — 0.18 0.18
Total — — — — — — — — — — — — — — — — 0.18 0.18

4.7. Offroad Emissions By Equipment Type

4.7.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipm
ent
T
ype
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.8. Stationary Emissions By Equipment Type

4.8.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipm
ent
T
ype
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e F48
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——————————————————Daily,
Summer
(Max)
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.9. User Defined Emissions By Equipment Type

4.9.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipm
ent
T
ype
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.10. Soil Carbon Accumulation By Vegetation Type

4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated F49
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Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Vegetati
on
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Species TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e F50
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Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Sequest
ered
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Remove
d
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
— — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Sequest
ered
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Remove
d
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
— — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Sequest
ered
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Remove
d
— — — — — — — — — — — — — — — — — —
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Subtotal — — — — — — — — — — — — — — — — — —
— — — — — — — — — — — — — — — — — — —

5. Activity Data

5.1. Construction Schedule
Phase Name Phase Type Start Date End Date Days Per Week Work Days per Phase Phase Description Demolition Demolition 1/1/2026 1/29/2026 5.00 20.0 —
Site Preparation Site Preparation 1/30/2026 2/13/2026 5.00 10.0 — Grading Grading 2/14/2026 3/28/2026 5.00 30.0 —
Building Construction Building Construction 3/29/2026 5/23/2027 5.00 300 — Paving Paving 5/24/2027 6/21/2027 5.00 20.0 —
Architectural Coating Architectural Coating 6/22/2027 7/20/2027 5.00 20.0 —

5.2. Off-Road Equipment

5.2.1. Unmitigated
Phase Name Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor Demolition Rubber Tired Dozers Diesel Tier 4 Interim 2.00 8.00 367 0.40 Demolition Excavators Diesel Tier 4 Interim 3.00 8.00 36.0 0.38 Demolition Concrete/Industrial
Sa
ws
Diesel Tier 4 Interim 1.00 8.00 33.0 0.73
Site Preparation Rubber Tired Dozers Diesel Tier 4 Interim 3.00 8.00 367 0.40 Site Preparation Tractors/Loaders/Back
hoes
Diesel Tier 4 Interim 4.00 8.00 84.0 0.37
Grading Graders Diesel Tier 4 Interim 1.00 8.00 148 0.41 Grading Excavators Diesel Tier 4 Interim 2.00 8.00 36.0 0.38 Grading Tractors/Loaders/Back
hoes
Diesel Tier 4 Interim 2.00 8.00 84.0 0.37
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Grading Scrapers Diesel Tier 4 Interim 2.00 8.00 423 0.48 Grading Rubber Tired Dozers Diesel Tier 4 Interim 1.00 8.00 367 0.40 Building Construction Forklifts Diesel Tier 4 Interim 3.00 8.00 82.0 0.20 Building Construction Generator Sets Diesel Tier 4 Interim 1.00 8.00 14.0 0.74 Building Construction Cranes Diesel Tier 4 Interim 1.00 7.00 367 0.29 Building Construction Welders Diesel Tier 4 Interim 1.00 8.00 46.0 0.45 Building Construction Tractors/Loaders/Back
hoes
Diesel Tier 4 Interim 3.00 7.00 84.0 0.37
Paving Pavers Diesel Tier 4 Interim 2.00 8.00 81.0 0.42 Paving Paving Equipment Diesel Tier 4 Interim 2.00 8.00 89.0 0.36 Paving Rollers Diesel Tier 4 Interim 2.00 8.00 36.0 0.38 Architectural Coating Air Compressors Diesel Tier 4 Interim 1.00 6.00 37.0 0.48

5.3. Construction Vehicles

5.3.1. Unmitigated
Phase Name Trip Type One-Way Trips per Day Miles per Trip Vehicle Mix Demolition — — — —
Demolition Worker 15.0 11.7 LDA,LDT1,LDT2
Demolition Vendor — 8.40 HHDT,MHDT
Demolition Hauling 0.00 20.0 HHDT
Demolition Onsite truck — — HHDT
Site Preparation — — — —
Site Preparation Worker 17.5 11.7 LDA,LDT1,LDT2
Site Preparation Vendor — 8.40 HHDT,MHDT
Site Preparation Hauling 0.00 20.0 HHDT
Site Preparation Onsite truck — — HHDT
Grading — — — —
Grading Worker 20.0 11.7 LDA,LDT1,LDT2
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Grading Vendor — 8.40 HHDT,MHDT
Grading Hauling 0.00 20.0 HHDT
Grading Onsite truck — — HHDT
Building Construction — — — —
Building Construction Worker 114 11.7 LDA,LDT1,LDT2
Building Construction Vendor 17.0 8.40 HHDT,MHDT
Building Construction Hauling 0.00 20.0 HHDT
Building Construction Onsite truck — — HHDT
Paving — — — —
Paving Worker 15.0 11.7 LDA,LDT1,LDT2
Paving Vendor — 8.40 HHDT,MHDT
Paving Hauling 0.00 20.0 HHDT
Paving Onsite truck — — HHDT
Architectural Coating — — — —
Architectural Coating Worker 22.9 11.7 LDA,LDT1,LDT2
Architectural Coating Vendor — 8.40 HHDT,MHDT
Architectural Coating Hauling 0.00 20.0 HHDT
Architectural Coating Onsite truck — — HHDT

5.4. Vehicles

5.4.1. Construction Vehicle Control Strategies
Non-applicable. No control strategies activated by user.

5.5. Architectural Coatings
Phase Name Residential Interior Area
Coated
(sq ft)
Residential Exterior Area
Coated
(sq ft)
Non-Residential Interior Area
Coated
(sq ft)
Non-Residential Exterior Area
Coated
(sq ft)
Parking Area Coated (sq ft)
Architectural Coating 309,096 103,032 0.00 0.00 —
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5.6. Dust Mitigation

5.6.1. Construction Earthmoving Activities
Phase Name Material Imported (cy) Material Exported (cy) Acres Graded (acres) Material Demolished (sq. ft.) Acres Paved (acres) Demolition 0.00 0.00 0.00 — —
Site Preparation — — 15.0 0.00 —
Grading — — 90.0 0.00 —
Paving 0.00 0.00 0.00 0.00 —

5.6.2. Construction Earthmoving Control Strategies
Non-applicable. No control strategies activated by user.

5.7. Construction Paving
Land Use Area Paved (acres) % Asphalt
Apartments Mid Rise — 0%

5.8. Construction Electricity Consumption and Emissions Factors kWh per Y ear and Emission Factor (lb/MWh)
Y ear kWh per Y ear CO2 CH4 N2O
2026 0.00 204 0.03 < 0.005
2027 0.00 204 0.03 < 0.005

5.9. Operational Mobile Sources

5.9.1. Unmitigated
Land Use Type Trips/Weekday Trips/Saturday Trips/Sunday Trips/Y ear VMT/Weekday VMT/Saturday VMT/Sunday VMT/Y ear Apartments Mid
Rise
865 781 650 300,124 7,943 7,169 5,972 2,756,074
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5.10. Operational Area Sources

5.10.1. Hearths

5.10.1.1. Unmitigated
Hearth Type Unmitigated (number)
Apartments Mid Rise —
Wood Fireplaces 0
Gas Fireplaces 81
Propane Fireplaces 0
Electric Fireplaces 0
No Fireplaces 78
Conventional Wood Stoves 0
Catalytic Wood Stoves 0
Non-Catalytic Wood Stoves 0
Pellet Wood Stoves 0

5.10.2. Architectural Coatings
Residential Interior Area Coated (sq
ft)
Residential Exterior Area Coated (sq
ft)
Non-Residential Interior Area Coated
(sq
ft)
Non-Residential Exterior Area
Coated
(sq ft)
Parking Area Coated (sq ft)
309096 103,032 0.00 0.00 —

5.10.3. Landscape Equipment
Season Unit Value
Snow Days day/yr 0.00
Summer Days day/yr 180
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5.11. Operational Energy Consumption

5.11.1. Unmitigated
Electricity (kWh/yr) and CO2 and CH4 and N2O and Natural Gas (kBTU/yr) Land Use Electricity (kWh/yr) CO2 CH4 N2O Natural Gas (kBTU/yr) Apartments Mid Rise 542,421 204 0.0330 0.0040 1,399,847

5.12. Operational Water and Wastewater Consumption

5.12.1. Unmitigated
Land Use Indoor Water (gal/year) Outdoor Water (gal/year) Apartments Mid Rise 5,786,380 291,748

5.13. Operational Waste Generation

5.13.1. Unmitigated
Land Use Waste (ton/year) Cogeneration (kWh/year)
Apartments Mid Rise 118 —

5.14. Operational Refrigeration and Air Conditioning Equipment

5.14.1. Unmitigated
Land Use Type Equipment Type Refrigerant GWP Quantity (kg) Operations Leak Rate Service Leak Rate Times Serviced Apartments Mid Rise Average room A/C &
Other
residential A/C
and heat pumps
R-410A 2,088 < 0.005 2.50 2.50 10.0
Apartments Mid Rise Household
refr
igerators and/or
freezers
R-134a 1,430 0.12 0.60 0.00 1.00
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5.15. Operational Off-Road Equipment

5.15.1. Unmitigated
Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor

5.16. Stationary Sources

5.16.1. Emergency Generators and Fire Pumps
Equipment Type Fuel Type Number per Day Hours per Day Hours per Y ear Horsepower Load Factor

5.16.2. Process Boilers
Equipment Type Fuel Type Number Boiler Rating (MMBtu/hr) Daily Heat Input (MMBtu/day) Annual Heat Input (MMBtu/yr)

5.17. User Defined
Equipment Type Fuel Type

5.18. Vegetation

5.18.1. Land Use Change

5.18.1.1. Unmitigated
Vegetation Land Use Type Vegetation Soil Type Initial Acres Final Acres

5.18.1. Biomass Cover Type

5.18.1.1. Unmitigated
Biomass Cover Type Initial Acres Final Acres
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5.18.2. Sequestration

5.18.2.1. Unmitigated
Tree Type Number Electricity Saved (kWh/year) Natural Gas Saved (btu/year)

8. User Changes to Default Data
Screen Justification
Land Use Consistent with the Staff Report.

Construction: Off-Road Equipment Consistent with the Staff Report.

F59
Annual Emissions (tons/year) 0.01 Total DPM (lbs) 30.96890411 Annual Emissions (tons/year) 0.01 Daily Emissions (lbs/day) 0.054794521 Total DPM (g) 14042.9589 Daily Emissions (lbs/day) 0.054794521 Construction Duration (days) 365 Emission Rate (g/s) 0.000287671 Total DPM (lbs) 20 Total DPM (lbs) 20 Release Height (meters) 3 Emission Rate (g/s) 0.000287671 Total DPM (g) 9072 Total Acreage 10.35 Release Height (meters) 3 Start Date 1/1/2026 Max Horizontal (meters) 289.43 Total Acreage 10.35 End Date 1/1/2027 Min Horizontal (meters) 144.72 Max Horizontal (meters) 289.43 Construction Days 365 Initial Vertical Dimension (meters) 1.5 Min Horizontal (meters) 144.72 Setting Urban Initial Vertical Dimension (meters) 1.5
Annual Emissions (tons/year) 0.01 Population 118,453 Setting Urban Daily Emissions (lbs/day) 0.054794521 Start Date 1/1/2026 Population 118,453 Construction Duration (days) 200 End Date 7/20/2027
Total DPM (lbs) 10.95890411 Total Construction Days 565 Total DPM (g) 4970.958904 Total Years of Construction 1.55 Start Date 1/1/2027 Total Years of Operation 28.45
End Date 7/20/2027
Construction Days 200
2027
Construction Operation
2026 Total Emission Rate
Attachment B
F60
Age Group Emissions Source D uration (years) Concentration (ug/m3) Cancer Risk
3 rd Trimester Construction 0. 25 0.0276 3.19E-07
Construction 1.30 0. 0276 5.00E-06
Operation 0.70 0.0276 2.71E-06
Infant (0 - 2) Total 2 7. 71E-06
Child (2 - 16) Operation 14 0. 0276 7.20E-06
Adult (16 - 30) Operation 14 0. 0276 1.11E-06
Lifetime 30 1. 63E-05
The Maximally Exposed Individual at an Existing Residential Receptor F61
AERSCREEN 21112 / AERMOD 21112                                      08/11/25 14:15:18
TITLE: Wildflower, Construction
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ ******************************  AREA PARAMETERS  **************************** ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ SOURCE EMISSION RATE:         0.288E‐03 g/s             0.228E‐02 lb/hr AREA EMISSION RATE:           0.687E‐08 g/(s‐m2)        0.545E‐07 lb/(hr‐m2) AREA HEIGHT:                       3.00 meters               9.84 feet AREA SOURCE LONG SIDE:           289.43 meters             949.57 feet AREA SOURCE SHORT SIDE:          144.72 meters             474.80 feet INITIAL VERTICAL DIMENSION:        1.50 meters               4.92 feet RURAL OR URBAN:                   URBAN
POPULATION:                      118453
INITIAL PROBE DISTANCE =          5000. meters             16404. feet ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ ***********************  BUILDING DOWNWASH PARAMETERS  ********************** ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ BUILDING DOWNWASH NOT USED FOR NON‐POINT SOURCES
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ **************************  FLOW SECTOR ANALYSIS  *************************** 25 meter receptor spacing: 1. meters ‐ 5000. meters
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ MAXIMUM  IMPACT  RECEPTOR
Zo        SURFACE   1‐HR CONC  RADIAL  DIST   TEMPORAL
SECTOR    ROUGHNESS  (ug/m3)    (deg)   (m)    PERIOD
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐
1*       1.000    0.2761      15   150.0     WIN
* = worst case diagonal
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ Attachment C
F62
**********************  MAKEMET METEOROLOGY PARAMETERS  ********************* ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ MIN/MAX TEMPERATURE:    250.0 / 310.0 (K)
MINIMUM WIND SPEED:       0.5 m/s
ANEMOMETER HEIGHT:     10.000 meters
SURFACE CHARACTERISTICS INPUT: AERMET SEASONAL TABLES
DOMINANT SURFACE PROFILE: Urban
DOMINANT CLIMATE TYPE:    Average Moisture
DOMINANT SEASON:          Winter
ALBEDO:                  0.35
BOWEN RATIO:             1.50
ROUGHNESS LENGTH:       1.000 (meters)
SURFACE FRICTION VELOCITY (U*) NOT ADUSTED
METEOROLOGY CONDITIONS USED TO PREDICT OVERALL MAXIMUM IMPACT ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ YR MO DY JDY HR
‐‐ ‐‐ ‐‐ ‐‐‐ ‐‐
10 01 10  10 01
H0     U*     W*  DT/DZ ZICNV ZIMCH  M‐O LEN    Z0  BOWEN ALBEDO  REF WS ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐1.30  0.043 ‐9.000  0.020 ‐999.   21.      6.0 1.000   1.50   0.35    0.50 HT  REF TA     HT
‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐

10.0   310.0    2.0
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ ************************ AERSCREEN AUTOMATED DISTANCES ********************** OVERALL MAXIMUM CONCENTRATIONS BY DISTANCE
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ MAXIMUM                             MAXIMUM
DIST     1‐HR CONC                  DIST     1‐HR CONC
(m)      (ug/m3)                    (m)      (ug/m3)
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐               ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐

1.00    0.2109                   2525.00    0.6025E‐02
F63

25.00    0.2252                   2550.00    0.5945E‐02

50.00    0.2381                   2575.00    0.5867E‐02

75.00    0.2495                   2600.00    0.5790E‐02 100.00    0.2595                   2625.00    0.5716E‐02 125.00    0.2687                   2650.00    0.5642E‐02 150.00    0.2761                   2675.00    0.5571E‐02 175.00    0.2158                   2700.00    0.5560E‐02 200.00    0.1670                   2725.00    0.5490E‐02 225.00    0.1406                   2750.00    0.5422E‐02 250.00    0.1237                   2775.00    0.5355E‐02 275.00    0.1103                   2800.00    0.5290E‐02 300.00    0.9920E‐01               2825.00    0.5226E‐02 325.00    0.8989E‐01               2850.00    0.5163E‐02 350.00    0.8198E‐01               2875.00    0.5102E‐02 375.00    0.7519E‐01               2900.00    0.5042E‐02 400.00    0.6929E‐01               2925.00    0.4983E‐02 425.00    0.6417E‐01               2950.00    0.4925E‐02 450.00    0.5965E‐01               2975.00    0.4868E‐02 475.00    0.5567E‐01               3000.00    0.4813E‐02 500.00    0.5208E‐01               3025.00    0.4759E‐02 525.00    0.4891E‐01               3050.00    0.4705E‐02 550.00    0.4606E‐01               3075.00    0.4653E‐02 575.00    0.4347E‐01               3100.00    0.4602E‐02 600.00    0.4112E‐01               3125.00    0.4551E‐02 625.00    0.3900E‐01               3150.00    0.4502E‐02 650.00    0.3703E‐01               3175.00    0.4454E‐02 675.00    0.3524E‐01               3200.00    0.4406E‐02 700.00    0.3361E‐01               3225.00    0.4359E‐02 725.00    0.3211E‐01               3250.00    0.4314E‐02 750.00    0.3070E‐01               3275.00    0.4269E‐02 775.00    0.2939E‐01               3300.00    0.4224E‐02 800.00    0.2818E‐01               3325.00    0.4181E‐02 825.00    0.2705E‐01               3350.00    0.4138E‐02 850.00    0.2601E‐01               3375.00    0.4096E‐02 875.00    0.2504E‐01               3400.00    0.4055E‐02 900.00    0.2413E‐01               3425.00    0.4015E‐02 925.00    0.2326E‐01               3450.00    0.3975E‐02 950.00    0.2245E‐01               3475.00    0.3936E‐02 975.00    0.2169E‐01               3500.00    0.3898E‐02 1000.00    0.2096E‐01               3525.00    0.3860E‐02 1025.00    0.2028E‐01               3550.00    0.3823E‐02 1050.00    0.1964E‐01               3575.00    0.3786E‐02 1075.00    0.1903E‐01               3600.00    0.3750E‐02 1100.00    0.1846E‐01               3625.00    0.3715E‐02 1125.00    0.1792E‐01               3650.00    0.3680E‐02 1150.00    0.1740E‐01               3675.00    0.3646E‐02 1175.00    0.1690E‐01               3700.00    0.3612E‐02 1200.00    0.1643E‐01               3725.00    0.3579E‐02 1225.00    0.1598E‐01               3750.00    0.3546E‐02 1250.00    0.1556E‐01               3775.00    0.3514E‐02 F64
1275.00    0.1515E‐01               3800.00    0.3483E‐02 1300.00    0.1476E‐01               3825.00    0.3452E‐02 1325.00    0.1439E‐01               3849.99    0.3421E‐02 1350.00    0.1404E‐01               3875.00    0.3391E‐02 1375.00    0.1370E‐01               3900.00    0.3361E‐02 1400.00    0.1337E‐01               3925.00    0.3332E‐02 1425.00    0.1305E‐01               3950.00    0.3303E‐02 1450.00    0.1275E‐01               3975.00    0.3275E‐02 1475.00    0.1246E‐01               4000.00    0.3247E‐02 1500.00    0.1218E‐01               4025.00    0.3219E‐02 1525.00    0.1192E‐01               4050.00    0.3192E‐02 1550.00    0.1166E‐01               4075.00    0.3165E‐02 1575.00    0.1141E‐01               4100.00    0.3139E‐02 1600.00    0.1117E‐01               4125.00    0.3113E‐02 1625.00    0.1094E‐01               4149.99    0.3087E‐02 1650.00    0.1071E‐01               4175.00    0.3062E‐02 1675.00    0.1050E‐01               4200.00    0.3037E‐02 1700.00    0.1029E‐01               4225.00    0.3013E‐02 1725.00    0.1009E‐01               4250.00    0.2988E‐02 1750.00    0.9894E‐02               4275.00    0.2964E‐02 1775.00    0.9706E‐02               4300.00    0.2941E‐02 1800.00    0.9524E‐02               4325.00    0.2918E‐02 1825.00    0.9347E‐02               4350.00    0.2895E‐02 1850.00    0.9177E‐02               4375.00    0.2872E‐02 1875.00    0.9012E‐02               4400.00    0.2850E‐02 1900.00    0.8853E‐02               4425.00    0.2828E‐02 1925.00    0.8698E‐02               4450.00    0.2806E‐02 1950.00    0.8548E‐02               4475.00    0.2785E‐02 1975.00    0.8402E‐02               4500.00    0.2764E‐02 2000.00    0.8261E‐02               4525.00    0.2743E‐02 2025.00    0.8124E‐02               4550.00    0.2722E‐02 2050.00    0.7991E‐02               4575.00    0.2702E‐02 2075.00    0.7862E‐02               4600.00    0.2682E‐02 2100.00    0.7736E‐02               4625.00    0.2662E‐02 2125.00    0.7613E‐02               4650.00    0.2642E‐02 2150.00    0.7494E‐02               4675.00    0.2623E‐02 2175.00    0.7378E‐02               4700.00    0.2604E‐02 2200.00    0.7264E‐02               4725.00    0.2585E‐02 2225.00    0.7154E‐02               4750.00    0.2567E‐02 2250.00    0.7047E‐02               4775.00    0.2548E‐02 2275.00    0.6943E‐02               4800.00    0.2530E‐02 2300.00    0.6840E‐02               4825.00    0.2512E‐02 2325.00    0.6740E‐02               4850.00    0.2494E‐02 2350.00    0.6643E‐02               4875.00    0.2477E‐02 2375.00    0.6548E‐02               4900.00    0.2460E‐02 2400.00    0.6455E‐02               4924.99    0.2443E‐02 2425.00    0.6365E‐02               4950.00    0.2426E‐02 2450.00    0.6277E‐02               4975.00    0.2409E‐02 2475.00    0.6191E‐02               5000.00    0.2393E‐02 2500.00    0.6107E‐02
F65
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ **********************  AERSCREEN MAXIMUM IMPACT SUMMARY  ********************* ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ 3‐hour, 8‐hour, and 24‐hour scaled
concentrations are equal to the 1‐hour concentration as referenced in SCREENING PROCEDURES FOR ESTIMATING THE AIR QUALITY
IMPACT OF STATIONARY SOURCES, REVISED (Section 4.5.4)
Report number EPA‐454/R‐92‐019
http://www.epa.gov/scram001/guidance_permit.htm
under Screening Guidance
MAXIMUM      SCALED      SCALED      SCALED      SCALED 1‐HOUR      3‐HOUR      8‐HOUR     24‐HOUR      ANNUAL
CALCULATION          CONC        CONC        CONC        CONC        CONC PROCEDURE         (ug/m3)     (ug/m3)     (ug/m3)     (ug/m3)     (ug/m3) ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐    ‐‐‐‐‐‐‐‐‐‐  ‐‐‐‐‐‐‐‐‐‐  ‐‐‐‐‐‐‐‐‐‐  ‐‐‐‐‐‐‐‐‐‐  ‐‐‐‐‐‐‐‐‐‐ FLAT TERRAIN       0.2761      0.2761      0.2761      0.2761         N/A DISTANCE FROM SOURCE        150.00 meters
IMPACT AT THE
AMBIENT BOUNDARY   0.2109      0.2109      0.2109      0.2109         N/A DISTANCE FROM SOURCE          1.00 meters
F66
AERSCREEN 21112 / AERMOD 21112                                      08/11/25 15:42:25
TITLE: Wildflower, operation
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ ******************************  AREA PARAMETERS  **************************** ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ SOURCE EMISSION RATE:         0.288E‐03 g/s             0.228E‐02 lb/hr AREA EMISSION RATE:           0.687E‐08 g/(s‐m2)        0.545E‐07 lb/(hr‐m2) AREA HEIGHT:                       3.00 meters               9.84 feet AREA SOURCE LONG SIDE:           289.43 meters             949.57 feet AREA SOURCE SHORT SIDE:          144.72 meters             474.80 feet INITIAL VERTICAL DIMENSION:        1.50 meters               4.92 feet RURAL OR URBAN:                   URBAN
POPULATION:                      118453
INITIAL PROBE DISTANCE =          5000. meters             16404. feet ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ ***********************  BUILDING DOWNWASH PARAMETERS  ********************** ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ BUILDING DOWNWASH NOT USED FOR NON‐POINT SOURCES
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ **************************  FLOW SECTOR ANALYSIS  *************************** 25 meter receptor spacing: 1. meters ‐ 5000. meters
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ MAXIMUM  IMPACT  RECEPTOR
Zo        SURFACE   1‐HR CONC  RADIAL  DIST   TEMPORAL
SECTOR    ROUGHNESS  (ug/m3)    (deg)   (m)    PERIOD
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐
1*       1.000    0.2761      15   150.0     WIN
* = worst case diagonal
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ F67
**********************  MAKEMET METEOROLOGY PARAMETERS  ********************* ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ MIN/MAX TEMPERATURE:    250.0 / 310.0 (K)
MINIMUM WIND SPEED:       0.5 m/s
ANEMOMETER HEIGHT:     10.000 meters
SURFACE CHARACTERISTICS INPUT: AERMET SEASONAL TABLES
DOMINANT SURFACE PROFILE: Urban
DOMINANT CLIMATE TYPE:    Average Moisture
DOMINANT SEASON:          Winter
ALBEDO:                  0.35
BOWEN RATIO:             1.50
ROUGHNESS LENGTH:       1.000 (meters)
SURFACE FRICTION VELOCITY (U*) NOT ADUSTED
METEOROLOGY CONDITIONS USED TO PREDICT OVERALL MAXIMUM IMPACT ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ YR MO DY JDY HR
‐‐ ‐‐ ‐‐ ‐‐‐ ‐‐
10 01 10  10 01
H0     U*     W*  DT/DZ ZICNV ZIMCH  M‐O LEN    Z0  BOWEN ALBEDO  REF WS ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐1.30  0.043 ‐9.000  0.020 ‐999.   21.      6.0 1.000   1.50   0.35    0.50 HT  REF TA     HT
‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐

10.0   310.0    2.0
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ ************************ AERSCREEN AUTOMATED DISTANCES ********************** OVERALL MAXIMUM CONCENTRATIONS BY DISTANCE
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ MAXIMUM                             MAXIMUM
DIST     1‐HR CONC                  DIST     1‐HR CONC
(m)      (ug/m3)                    (m)      (ug/m3)
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐               ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐

1.00    0.2109                   2525.00    0.6025E‐02
F68

25.00    0.2252                   2550.00    0.5945E‐02

50.00    0.2381                   2575.00    0.5867E‐02

75.00    0.2495                   2600.00    0.5790E‐02 100.00    0.2595                   2625.00    0.5716E‐02 125.00    0.2687                   2650.00    0.5642E‐02 150.00    0.2761                   2675.00    0.5571E‐02 175.00    0.2158                   2700.00    0.5560E‐02 200.00    0.1670                   2725.00    0.5490E‐02 225.00    0.1406                   2750.00    0.5422E‐02 250.00    0.1237                   2775.00    0.5355E‐02 275.00    0.1103                   2800.00    0.5290E‐02 300.00    0.9920E‐01               2825.00    0.5226E‐02 325.00    0.8989E‐01               2850.00    0.5163E‐02 350.00    0.8198E‐01               2875.00    0.5102E‐02 375.00    0.7519E‐01               2900.00    0.5042E‐02 400.00    0.6929E‐01               2925.00    0.4983E‐02 425.00    0.6417E‐01               2950.00    0.4925E‐02 450.00    0.5965E‐01               2975.00    0.4868E‐02 475.00    0.5567E‐01               3000.00    0.4813E‐02 500.00    0.5208E‐01               3025.00    0.4759E‐02 525.00    0.4891E‐01               3050.00    0.4705E‐02 550.00    0.4606E‐01               3075.00    0.4653E‐02 575.00    0.4347E‐01               3100.00    0.4602E‐02 600.00    0.4112E‐01               3125.00    0.4551E‐02 625.00    0.3900E‐01               3150.00    0.4502E‐02 650.00    0.3703E‐01               3175.00    0.4454E‐02 675.00    0.3524E‐01               3200.00    0.4406E‐02 700.00    0.3361E‐01               3225.00    0.4359E‐02 725.00    0.3211E‐01               3250.00    0.4314E‐02 750.00    0.3070E‐01               3275.00    0.4269E‐02 775.00    0.2939E‐01               3300.00    0.4224E‐02 800.00    0.2818E‐01               3325.00    0.4181E‐02 825.00    0.2705E‐01               3350.00    0.4138E‐02 850.00    0.2601E‐01               3375.00    0.4096E‐02 875.00    0.2504E‐01               3400.00    0.4055E‐02 900.00    0.2413E‐01               3425.00    0.4015E‐02 925.00    0.2326E‐01               3450.00    0.3975E‐02 950.00    0.2245E‐01               3475.00    0.3936E‐02 975.00    0.2169E‐01               3500.00    0.3898E‐02 1000.00    0.2096E‐01               3525.00    0.3860E‐02 1025.00    0.2028E‐01               3550.00    0.3823E‐02 1050.00    0.1964E‐01               3575.00    0.3786E‐02 1075.00    0.1903E‐01               3600.00    0.3750E‐02 1100.00    0.1846E‐01               3625.00    0.3715E‐02 1125.00    0.1792E‐01               3650.00    0.3680E‐02 1150.00    0.1740E‐01               3675.00    0.3646E‐02 1175.00    0.1690E‐01               3700.00    0.3612E‐02 1200.00    0.1643E‐01               3725.00    0.3579E‐02 1225.00    0.1598E‐01               3750.00    0.3546E‐02 1250.00    0.1556E‐01               3775.00    0.3514E‐02 F69
1275.00    0.1515E‐01               3800.00    0.3483E‐02 1300.00    0.1476E‐01               3825.00    0.3452E‐02 1325.00    0.1439E‐01               3849.99    0.3421E‐02 1350.00    0.1404E‐01               3875.00    0.3391E‐02 1375.00    0.1370E‐01               3900.00    0.3361E‐02 1400.00    0.1337E‐01               3925.00    0.3332E‐02 1425.00    0.1305E‐01               3950.00    0.3303E‐02 1450.00    0.1275E‐01               3975.00    0.3275E‐02 1475.00    0.1246E‐01               4000.00    0.3247E‐02 1500.00    0.1218E‐01               4025.00    0.3219E‐02 1525.00    0.1192E‐01               4050.00    0.3192E‐02 1550.00    0.1166E‐01               4075.00    0.3165E‐02 1575.00    0.1141E‐01               4100.00    0.3139E‐02 1600.00    0.1117E‐01               4125.00    0.3113E‐02 1625.00    0.1094E‐01               4149.99    0.3087E‐02 1650.00    0.1071E‐01               4175.00    0.3062E‐02 1675.00    0.1050E‐01               4200.00    0.3037E‐02 1700.00    0.1029E‐01               4225.00    0.3013E‐02 1725.00    0.1009E‐01               4250.00    0.2988E‐02 1750.00    0.9894E‐02               4275.00    0.2964E‐02 1775.00    0.9706E‐02               4300.00    0.2941E‐02 1800.00    0.9524E‐02               4325.00    0.2918E‐02 1825.00    0.9347E‐02               4350.00    0.2895E‐02 1850.00    0.9177E‐02               4375.00    0.2872E‐02 1875.00    0.9012E‐02               4400.00    0.2850E‐02 1900.00    0.8853E‐02               4425.00    0.2828E‐02 1925.00    0.8698E‐02               4450.00    0.2806E‐02 1950.00    0.8548E‐02               4475.00    0.2785E‐02 1975.00    0.8402E‐02               4500.00    0.2764E‐02 2000.00    0.8261E‐02               4525.00    0.2743E‐02 2025.00    0.8124E‐02               4550.00    0.2722E‐02 2050.00    0.7991E‐02               4575.00    0.2702E‐02 2075.00    0.7862E‐02               4600.00    0.2682E‐02 2100.00    0.7736E‐02               4625.00    0.2662E‐02 2125.00    0.7613E‐02               4650.00    0.2642E‐02 2150.00    0.7494E‐02               4675.00    0.2623E‐02 2175.00    0.7378E‐02               4700.00    0.2604E‐02 2200.00    0.7264E‐02               4725.00    0.2585E‐02 2225.00    0.7154E‐02               4750.00    0.2567E‐02 2250.00    0.7047E‐02               4775.00    0.2548E‐02 2275.00    0.6943E‐02               4800.00    0.2530E‐02 2300.00    0.6840E‐02               4825.00    0.2512E‐02 2325.00    0.6740E‐02               4850.00    0.2494E‐02 2350.00    0.6643E‐02               4875.00    0.2477E‐02 2375.00    0.6548E‐02               4900.00    0.2460E‐02 2400.00    0.6455E‐02               4924.99    0.2443E‐02 2425.00    0.6365E‐02               4950.00    0.2426E‐02 2450.00    0.6277E‐02               4975.00    0.2409E‐02 2475.00    0.6191E‐02               5000.00    0.2393E‐02 2500.00    0.6107E‐02
F70
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ **********************  AERSCREEN MAXIMUM IMPACT SUMMARY  ********************* ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ 3‐hour, 8‐hour, and 24‐hour scaled
concentrations are equal to the 1‐hour concentration as referenced in SCREENING PROCEDURES FOR ESTIMATING THE AIR QUALITY
IMPACT OF STATIONARY SOURCES, REVISED (Section 4.5.4)
Report number EPA‐454/R‐92‐019
http://www.epa.gov/scram001/guidance_permit.htm
under Screening Guidance
MAXIMUM      SCALED      SCALED      SCALED      SCALED 1‐HOUR      3‐HOUR      8‐HOUR     24‐HOUR      ANNUAL
CALCULATION          CONC        CONC        CONC        CONC        CONC PROCEDURE         (ug/m3)     (ug/m3)     (ug/m3)     (ug/m3)     (ug/m3) ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐    ‐‐‐‐‐‐‐‐‐‐  ‐‐‐‐‐‐‐‐‐‐  ‐‐‐‐‐‐‐‐‐‐  ‐‐‐‐‐‐‐‐‐‐  ‐‐‐‐‐‐‐‐‐‐ FLAT TERRAIN       0.2761      0.2761      0.2761      0.2761         N/A DISTANCE FROM SOURCE        150.00 meters
IMPACT AT THE
AMBIENT BOUNDARY   0.2109      0.2109      0.2109      0.2109         N/A DISTANCE FROM SOURCE          1.00 meters
F71
1 2656 29th Street, Suite 201
Santa Monica, CA 90405

(949) 887-9013
[email protected]

Matthew F. Hagemann, P.G., C.Hg.
• Geologic and Hydrogeologic Characterization, Investigation and Remediation Strategies • Industrial Stormwater Compliance
• CEQA Review
• Expert Testimony

Professional Certifications:

California Professional Geologist, P.G.

California Certified Hydrogeologist, C.Hg.

Education:

M.S. Degree, Geology, California State University Los Angeles, Los Angeles, CA, 1984.

B.A. Degree, Geology, Humboldt State University, Arcata, CA, 1982.

Professional Experience:
30 years of experience in environmental policy, contaminant assessment and remediation, stormwater compliance, and CEQA review. Spent nine years with the U.S. EPA in the Resource Conservation Recovery Act (RCRA) and Superfund programs and served as EPA’s Senior Science Policy Advisor in the Western Regional Office where I identified emerging threats to groundwater. While with EPA, I served as a Senior Hydrogeologist in the oversight of the assessment of seven major military facilities undergoing base closure. Led numerous enforcement actions under provisions of the Resource Conservation and Recovery Act (RCRA) and directed efforts to improve hydrogeologic characterization and water quality monitoring. For the past 15 years, as a founding partner with SWAPE, I developed extensive client relationships and has managed complex projects that include consultations as an expert witness and a regulatory specialist, and managing projects ranging from industrial stormwater compliance to CEQA review of impacts from hazardous waste, air quality and greenhouse gas emissions.

Positions held include:

Government:

Senior Science Policy Advisor and Hydrogeologist, U.S. Environmental Protection Agency (1989– 1998); Hydrogeologist, National Park Service, Water Resources Division (1998 – 2000); Attachment D
F72
2 Geologist, U.S. Forest Service (1986 – 1998).

Educational:

Geology Instructor, Golden West College, 2010 – 2104, 2017; Adjunct Faculty Member, San Francisco State University, Department of Geosciences (1993 – 1998); Instructor, College of Marin, Department of Science (1990 – 1995).

Private Sector:

Founding Partner, Soil/Water/Air Protection Enterprise (SWAPE) (2003 – present); S
enior Environmental Analyst, Komex H2O Science, Inc. (2000 -- 2003);
E
xecutive Director, Orange Coast Watch (2001 – 2004);
Geologist, Dames & Moore (1984 – 1986).

Senior Regulatory and Litigation Support Analyst:

With SWAPE, responsibilities have included:
• Lead analyst and testifying expert, for both plaintiffs and defendants, in the review of over 300 environmental impact reports and negative declarations since 2003 under CEQA that identify significant issues with regard to hazardous waste, water resources, water quality, air quality, greenhouse gas emissions, and geologic hazards.
• Recommending additional mitigation measures to lead agencies at the local and county level to include additional characterization of health risks and implementation of protective measures to reduce exposure to hazards from toxins.
• Stormwater analysis, sampling and best management practice evaluation, for both government agencies and corporate clients, at more than 150 industrial facilities. • Serving as expert witness for both plaintiffs and defendants in cases including contamination of groundwater, CERCLA compliance in assessment and remediation, and industrial stormwater contamination.
• Technical assistance and litigation support for vapor intrusion concerns, for both government agencies and corporate clients.
• Lead analyst and testifying expert in the review of environmental issues in license applications for large solar power plants before the California Energy Commission. • Manager of a project to evaluate numerous formerly used military sites in the western U.S. • Manager of a comprehensive evaluation of potential sources of perchlorate contamination in Southern California drinking water wells.
• Manager and designated expert for litigation support under provisions of Proposition 65 in the review of releases of gasoline to sources drinking water at major refineries and hundreds of gas stations throughout California.

With Komex H2O Science Inc., duties included the following:
• Senior author of a report on the extent of perchlorate contamination that was used in testimony by the former U.S. EPA Administrator and General Counsel.
• Senior researcher in the development of a comprehensive, electronically interactive chronology of MTBE use, research, and regulation.
• Senior researcher in the development of a comprehensive, electronically interactive chronology of perchlorate use, research, and regulation.
• Senior researcher in a study that estimates nationwide costs for MTBE remediation and drinking water treatment, results of which were published in newspapers nationwide and in testimony F73
3 against provisions of an energy bill that would limit liability for oil companies. • Research to support litigation to restore drinking water supplies that have been contaminated by MTBE in California and New York.
• Lead author for a multi - volume remedial investigation report for an operating school in Los Angeles that met strict Sate of California regulatory requirements. • Development of strategic approaches for cleanup of contaminated sites in consultation with clients and regulators.

Hydrogeology:

As a Senior Hydrogeologist with the U.S. Environmental Protection Agency, led investigations to characterize and cleanup closing military bases, including Mare Island Naval Shipyard, Hunters Point Naval Shipyard, Treasure Island Naval Station, Alameda Naval Station, Moffett Field, Mather Army Airfield, and Sacramento Army Depot. Specific activities included:
• Leading efforts to model groundwater flow and contaminant transport, ensured adequacy of monitoring networks, and assessed cleanup alternatives for contaminated sediment, soil, and groundwater.
• Initiating a regional program for evaluation of groundwater sampling practices and laboratory analysis at military bases.
• Identifying emerging issues, wrote technical guidance, and assisted in policy and regulation development through work on four national U.S. EPA workgroups, including the Superfund Groundwater Technical Forum and the Federal Facilities Forum.

At the request of the State of Hawaii, developed a methodology to determine the vulnerability of groundwater to contamination on the islands of Maui and Oahu. Used analytical models and a GIS to show zones of vulnerability, and the results were adopted and published by the State of Hawaii and County of Maui.

As a hydrogeologist with the EPA Groundwater Protection Section, worked with provisions of the Safe Drinking Water Act and NEPA to prevent drinking water contamination. Specific activities included the following:
• Received an EPA Bronze Medal for contribution to the development of national guidance for the protection of drinking water.
• Managed the Sole Source Aquifer Program and protected the drinking water of two communities through designation under the Safe Drinking Water Act. Prepared geologic reports, conducted hearings, and responded to public comments from residents who were very concerned about the impact of designation.

• Reviewed a number of Environmental Impact Statements for planned major developments, including large hazardous and solid waste disposal facilities, mine reclamation, and water transfer.

Served as a hydrogeologist with the RCRA Hazardous Waste program. Duties included:
• Supervised the hydrogeologic investigation of hazardous waste sites to determine compliance with Subtitle C requirements.
• Reviewed and wrote ʺpart Bʺ permits for the disposal of hazardous waste. • Conducted RCRA Corrective Action investigations of waste sites and led inspections that formed the basis for significant enforcement actions that were developed in close coordination with U.S. EPA legal counsel.
• Wrote contract specifications and supervised contractor’s investigations of waste sites.

F74
4 With the National Park Service, directed service-w ide investigations of contaminant sources to prevent degradation of water quality, including the following:
• Applied pertinent laws and regulations including CERCLA, RCRA, NEPA, NRDA, and the Clean Water Act to control military, mining, and landfill contaminants. • Conducted watershed -s cale investigations of contaminants at parks, including Yellowstone and Olympic National Park.
• Identified high- levels of perchlorate in soil adjacent to a national park in New Mexico and advised park superintendent on appropriate response actions under CERCLA. • Served as a Park Service representative on the Interagency Perchlorate Steering Committee, a national workgroup.
• Developed a program to conduct environmental compliance audits of all National Parks while serving on a national workgroup.
• Co-a uthored two papers on the potential for water contamination from the operation of personal watercraft and snowmobiles, these papers serving as the basis for the development of nation - wide policy on the use of these vehicles in National Parks.
• Contributed to the Federal Multi-A gency Source Water Agreement under the Clean Water Action Plan.

Policy:

Served as senior management as the Senior Science Policy Advisor with the U.S. Environmental Protection Agency, Region 9. Activities included the following:
• Advising the Regional Administrator and senior management on emerging issues such as the potential for the gasoline additive MTBE and ammonium perchlorate to contaminate drinking water supplies.
• Shaping EPA’s national response to these threats by serving on workgroups and by contributing to guidance, including the Office of Research and Development publication, Oxygenates in Water:

Critical Information and Research Needs.
• Improving the technical training of EPAʹs scientific and engineering staff. • Earning an EPA Bronze Medal for representing the region’s 300 scientists and engineers in negotiations with the Administrator and senior management to better integrate scientific principles into the policy-
making process.
• Establishing national protocol for the peer review of scientific documents.

Geology:

With the U.S. Forest Service, led investigations to determine hillslope stability of areas proposed for timber harvest in the central Oregon Coast Range. Specific activities included:
• Mapping geology in the field, and used aerial photographic interpretation and mathematical models to determine slope stability.
• Coordinating research with community stakeholders who were concerned with natural resource protection.
• Characterizing the geology of an aquifer that serves as the sole source of drinking water for the city of Medford, Oregon.

As a consultant with Dames and Moore, led geologic investigations of two contaminated sites (later listed on the Superfund NPL) in the Portland, Oregon, area and a large RCRA hazardous waste site in eastern Oregon.

F75
5 Duties included the following:
• Supervising year -l ong effort for soil and groundwater sampling. • Conducting aquifer tests.
• Investigating active faults beneath sites proposed for hazardous waste disposal.

Teaching:

From 1990 to 1998, taught at least one course per semester at the community college and university levels:
• At San Francisco State University, held an adjunct faculty position and taught courses in environmental geology, oceanography (lab and lecture), hydrogeology, and groundwater contamination.
• Served as a committee member for graduate and undergraduate students. • Taught courses in environmental geology and oceanography at the College of Marin. • Part time geology instructor at Golden West College in Huntington Beach, California from 2010 to 2014 and in 2017.

Summary of Testimony Experience Over Past Four Years

In Re New Jersey Department of Environmental Protection et al. vs. E.I. DuPont de Nemours and Company, in the United States District Court, District of New Jersey, Civil Action No. 1:19-cv-14766-RMB-JBC. Deposition in 2025.

Representing Plaintiffs in matters regarding contamination of groundwater, wastewater, soil, and air with per- and poly- fluoroalkyl substances.

In Re Edmond Asher, et al., vs. RTX Corporation (f/k/a Raytheon Technologies Corporation, et al.) in the County of Huntington Superior Court, Indiana, Cause number 35D01-2006-CT-000338. Deposition in 2024. Representing Plaintiffs in matters regarding contamination of groundwater and soil vapor with trichlorethylene.

In Re Wright vs Consolidated Rail Corporation In the Circuit Court of Cook County, Illinois, Case No: 21L3966.

Deposition in 2023, Representing Plaintiff in matters involving groundwater and drinking water contamination of perchloroethylene, trichlorethylene, 1,2-dichloroethane, and carbon tetrachloride.

In Re Behr Dayton Thermal Products LLC In the United States District Court for the Southern District of Ohio Western Division at Dayton, Case No: 08-cv-326. Deposition in 2022. Representing Plaintiff in matters regarding contamination of groundwater and indoor air with perchloroethylene and trichloethelene.

Orange County Water District vs. Sabic Innovative Plastics US, LLC, et al. In the Court of Appeal, Fourth District, Division 1, California, Case No: D070553. Deposition in 2020. Representing Plaintiff in matters involving compliance with The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA).

F76
6 Los Angeles Waterkeeper vs. AAA Plating and Inspection, Inc. In the United States District Court for the Central District of California, Case No: No. CV 18-5916 PA (GJSx). Deposition in 2019. Expert witness representing Plaintiff in matters involving contaminated stormwater runoff at an industrial facility in Compton, California.

Californians for Alternatives to Toxics vs. Schneider Dock and Intermodal Facility. In the United States District Court for the Northern District of California, Case No: 3:17-cv-05287-JST. Deposition in 2019. Expert witness representing Plaintiff in matters involving contaminated stormwater runoff at an industrial facility in Eureka, California.

Bells et al. vs. The 3M Company et al. In the United States District Court for the District of Colorado, Case No: 1:16-CV- 02531-RBJ. Deposition in 2018. Expert witness representing Plaintiff on matters regarding the general hydrogeological conditions present in an area impacted by per- and poly-fluoroalkyl substances.

Ungar vs. Foundation for Affordable Housing. In the Superior Court, State of California, Los Angeles County, Case No.

BC628890 Deposition in 2017. Expert witness representing defendant on matters involving alleged drinking water contamination.

Invited Testimony, Reports, Papers and Presentations:

Hagemann, M.F., 2008. Disclosure of Hazardous Waste Issues under CEQA. Presentation to the Public Environmental Law Conference, Eugene, Oregon.

Hagemann, M.F., 2008. Disclosure of Hazardous Waste Issues under CEQA. Invited presentation to U.S. EPA Region 9, San Francisco, California.

Hagemann, M.F., 2005. Use of Electronic Databases in Environmental Regulation, Policy Making and Public Participation. Brownfields 2005, Denver, Coloradao.

Hagemann, M.F., 2004. Perchlorate Contamination of the Colorado River and Impacts to Drinking Water in Nevada and the Southwestern U.S. Presentation to a meeting of the American Groundwater Trust, Las Vegas, NV (served on conference organizing committee).

Hagemann, M.F., 2004. Invited testimony to a California Senate committee hearing on air toxins at schools in Southern California, Los Angeles.

Brown, A., Farrow, J., Gray, A. and Hagemann, M., 2004. An Estimate of Costs to Address MTBE Releases from Underground Storage Tanks and the Resulting Impact to Drinking Water Wells.

Presentation to the Ground Water and Environmental Law Conference, National Groundwater Association.

Hagemann, M.F., 2004. Perchlorate Contamination of the Colorado River and Impacts to Drinking Water in F77
7 Arizona and the Southwestern U.S. Presentation to a meeting of the American Groundwater Trust, Phoenix, AZ (served on conference organizing committee).

Hagemann, M.F., 2003. Perchlorate Contamination of the Colorado River and Impacts to Drinking Water in the Southwestern U.S. Invited presentation to a special committee meeting of the National Academy of Sciences, Irvine, CA.

Hagemann, M.F., 2003. Perchlorate Contamination of the Colorado River. Invited presentation to a tribal EPA meeting, Pechanga, CA.

Hagemann, M.F., 2003. Perchlorate Contamination of the Colorado River. Invited presentation to a meeting of tribal representatives, Parker, AZ.

H
agemann, M.F., 2003. Impact of Perchlorate on the Colorado River and Associated Drinking Water Supplies.

Invited presentation to the Inter-Tr
ibal Meeting, Torres Martinez Tribe.

H
agemann, M.F., 2003. The Emergence of Perchlorate as a Widespread Drinking Water Contaminant. Invited presentation to the U.S. EPA Region 9.

Hagemann, M.F., 2003. A Deductive Approach to the Assessment of Perchlorate Contamination. Invited presentation to the California Assembly Natural Resources Committee.

Hagemann, M.F., 2003. Perchlorate: A Cold War Legacy in Drinking Water. Presentation to a meeting of the National Groundwater Association.

Hagemann, M.F., 2002. From Tank to Tap: A Chronology of MTBE in Groundwater. Presentation to a meeting of the National Groundwater Association.

Hagemann, M.F., 2002. A Chronology of MTBE in Groundwater and an Estimate of Costs to Address Impacts to Groundwater. Presentation to the annual meeting of the Society of Environmental Journalists.

Hagemann, M.F., 2002. An Estimate of the Cost to Address MTBE Contamination in Groundwater (and Who Will Pay). Presentation to a meeting of the National Groundwater Association.

H
agemann, M.F., 2002. An Estimate of Costs to Address MTBE Releases from Underground Storage Tanks and the Resulting Impact to Drinking Water Wells. Presentation to a meeting of the U.S. EPA and State Underground Storage Tank Program managers.

Hagemann, M.F ., 2001. From Tank to Tap: A Chronology of MTBE in Groundwater. Unpublished report.

Hagemann, M.F., 2001. Estimated Cleanup Cost for MTBE in Groundwater Used as Drinking Water.

Unpublished report.

Hagemann, M.F., 2001. Estimated Costs to Address MTBE Releases from Leaking Underground Storage Tanks.

Unpublished report.

Hagemann, M.F ., and VanMouwerik, M., 1999. Potential Water Concerns Related to Snowmobile Usage.

F78
8 Water Resources Division, National Park Service, Technical Report.

VanMouwerik, M. and Hagemann, M.F. 1999, Water Quality Concerns Related to Personal Watercraft Usage.

Water Resources Division, National Park Service, Technical Report.

Hagemann, M.F ., 1999, Is Dilution the Solution to Pollution in National Parks? The George Wright Society Biannual Meeting, Asheville, North Carolina.

Hagemann, M.F ., 1997, The Potential for MTBE to Contaminate Groundwater. U.S. EPA Superfund Groundwater Technical Forum Annual Meeting, Las Vegas, Nevada.

Hagemann, M.F ., and Gill, M., 1996, Impediments to Intrinsic Remediation, Moffett Field Naval Air Station,
Conference on Intrinsic Remediation of Chlorinated Hydrocarbons, Salt Lake City.

Hagemann, M.F., Fukunaga, G.L., 1996, The Vulnerability of Groundwater to Anthropogenic Contaminants on the Island of Maui, Hawaii. Hawaii Water Works Association Annual Meeting, Maui, October 1996.

Hagemann, M. F., Fukanaga, G. L., 1996, Ranking Groundwater Vulnerability in Central Oahu, H
awaii. Proceedings, Geographic Information Systems in Environmental Resources Management, Air and Waste Management Association Publication VIP-6

1. Hagemann, M.F., 1994. Groundwater Ch ar ac te r i z a t i o n and Cl ean up a t Closing Military Bases in California. Proceedings, California Groundwater Resources Association Meeting.

Hagemann, M.F. and Sabol, M.A., 1993. Role of the U.S. EPA in the High Plains States Groundwater Recharge Demonstration Program. Proceedings, Sixth Biennial Symposium on the Artificial Recharge of Groundwater.

H
agemann, M.F., 1993. U.S. EPA Policy on the Technical Impracticability of the Cleanup of DNAPL- cont
aminated Groundwater. California Groundwater Resources Association Meeting.

Hagemann, M.F., 1992. Dense Nonaqueous Phase Liquid Contamination of Groundwater: An Ounce of Prevention... Proceedings, Association of Engineering Geologists Annual Meeting, v. 35.

Other Experience:

S
elected as subject matter expert for the California Professional Geologist licensing examinations, 2009 -201

1. F79

SOIL WATER AIR PROTECTION ENTERPRISE
2656 29th Street, Suite 201
Santa Monica, California 90405
Attn: Paul Rosenfeld, Ph.D.

Mobil: (310) 795-2335
Office: (310) 452-5555
Fax: (310) 452-5550
Email: [email protected]

Paul E. Rosenfeld, Ph.D. Page 1 of 17 March 2025
Paul Rosenfeld, Ph.D. Chemical Fate and Transport & Air Dispersion Modeling Principal Environmental Chemist Risk Assessment & Remediation Specialist

Education
Ph.D. Soil Chemistry, University of Washington, 1999. Dissertation on volatile organic compound filtration.

M.S. Environmental Science, U.C. Berkeley, 1995. Thesis on organic waste economics.

B.A. Environmental Studies, U.C. Santa Barbara, 1991. Focus on wastewater treatment.

Professional Experience

Dr. Rosenfeld has over 25 years of experience conducting environmental investigations and risk assessments for evaluating impacts to human health, pr operty, and ecological receptors. Hi s expertise focuses on the fate and transport of environmental contaminants, human health ri sk, exposure assessment, and ecological restoration. Dr.

Rosenfeld has evaluated and modeled emissions from oil sp ills, landfills, boilers and incinerators, process stacks, storage tanks, confined animal feeding operations, indu strial, military and agricultural sources, unconventional oil drilling operations, and locomotive and construction engines. His project experience ranges from monitoring and modeling of pollution sources to evaluating impacts of pollu tion on workers at industrial facilities and residents in surrounding communities. Dr. Rosenfeld has also successful ly modeled exposure to contaminants distributed by water systems and via vapor intrusion.

Dr. Rosenfeld has investigated and designed remediation programs and risk assessments for contaminated sites containing lead, heavy metals, mold, bacteria, particulat e matter, petroleum hydrocarbons, chlorinated solvents, pesticides, radioactive waste, dioxins and furans, semi - and volatile organic compounds, PCBs, PAHs, creosote, perchlorate, asbestos, per- and poly-fluoroalkyl substances (PFOA/PFOS), unusual polymers, fuel oxygenates (MTBE), among other pollutants. Dr. Rosenfeld also has experience evaluating greenhouse gas emissions from various projects and is an expert on the assessment of odo rs from industrial and agricultural sites, as well as the evaluation of odor nuisance impacts an d technologies for abatement of odorous emissions. As a principal scientist at SWAPE, Dr. Rosenfeld directs air dispersion modeling and exposure a ssessments. He has served as an expert witness and testified about pollution source s causing nuisance and/or personal injury at sites and has testified as an expert witness on numerous cases involving exposure to so il, water and air contaminants from industrial, railroad, agricultural, and military sources.

Attachment E
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Professional History:

Soil Water Air Protection Enterprise (SWAPE); 2003 to present; Principal and Founding Partner UCLA School of Public Health; 2007 to 2011; Lecturer (Assistant Researcher) UCLA School of Public Health; 2003 to 2006; Adjunct Professor UCLA Environmental Science and Engineering Program; 2002-2004; Doctoral Intern Coordinator UCLA Institute of the Environment, 2001-2002; Research Associate Komex H
2O Science, 2001 to 2003; Senior Remediation Scientist
National Groundwater Association, 2002-2004; Lecturer
San Diego State University, 1999-2001; Adjunct Professor Anteon Corp., San Diego, 2000-2001; Remediation Project Manager Ogden (now Amec), San Diego, 2000-2000; Remediation Project Manager Bechtel, San Diego, California, 1999 – 2000; Risk Assessor King County, Seattle, 1996 – 1999; Scientist
James River Corp., Washington, 1995-96; Scientist
Big Creek Lumber, Davenport, California, 1995; Scientist Plumas Corp., California and USFS, Tahoe 1993-1995; Scientist Peace Corps and World Wildlife Fund, St. Kitts, West Indies, 1991-1993; Scientist

Publications:

Rosenfeld, P.E., Spaeth, K.R., McCarthy, S.J. et al. Camp Lejeune Marine Cancer Risk Assessment for Exposure to Contaminated Drinking Water From 1955 to 1987. Water Air Soil Pollut 235, 124 (2024). https://doi.org/10.1007/s11270-023-06863-y.

Rosenfeld P.E., Spaeth K.R., Remy L.L., Byers V., Muerth S.A., Hallman R,C., Summers-Evans J., Barker S. (2023) Perfluoroalkyl substances exposure in firefighters: Sources and implications, Environmental Research, Volume 220, https://doi.org/10.1016/j.envres.2022.115164.

Rosenfeld P.E. and Spaeth K.R., (2023) Authors’ Response to Letter to the Editor from Bullock and Ramacciotti, Water Air Soil Pollution Volume 234, https://doi.org/10.1007/s11270-023-06165-3

Rosenfeld P. E., Spaeth K., Hallman R., Bressler R., Smith, G., (2022) Cancer Risk and Diesel Exhaust Exposure Among Railroad Workers. Water Air Soil Pollution. 233, 171.

Remy, L.L., Clay T., Byers, V., Rosenfeld P. E. (2019) Hospital, Health, and Community Burden After Oil Refinery Fires, Richmond, California 2007 and 2012. Environmental Health. 18:48

Simons, R.A., Seo, Y. Rosenfeld, P., (2015) Modeling the Effect of Refinery Emission On Residential Property Value. Journal of Real Estate Research. 27(3):321-342

Chen, J. A, Zapata A. R., Sutherland A. J., Molmen, D.R., Chow, B. S., Wu, L. E., Rosenfeld, P. E., Hesse, R. C., (2012) Sulfur Dioxide and Volatile Organic Compound Exposure To A Community In Texas City Texas Evaluated Using Aermod and Empirical Data. American Journal of Environmental Science, 8(6), 622-632.

Rosenfeld, P.E. & Feng, L. (2011). The Risks of Hazardous Waste. Amsterdam: Elsevier Publishing.

Cheremisinoff, N.P., & Rosenfeld, P.E. (2011). Handbook of Pollution Prevention and Cleaner Production: Best Practices in the Agrochemical Industry, Amsterdam: Elsevier Publishing.

Gonzalez, J., Feng, L., Sutherland, A., Waller, C., Sok, H., Hesse, R., Rosenfeld, P. (2010). PCBs and Dioxins/Furans in Attic Dust Collected Near Former PCB Production and Secondary Copper Facilities in Sauget, IL.

Procedia Environmental Sciences. 113–125.

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Feng, L., Wu, C., Tam, L., Sutherland, A.J., Clark, J.J., Rosenfeld, P.E. (2010). Dioxin and Furan Blood Lipid and Attic Dust Concentrations in Populations Living Near Four Wood Treatment Facilities in the United States. Journal of Environmental Health. 73(6), 34-46.

Cheremisinoff, N.P., & Rosenfeld, P.E. (2010). Handbook of Pollution Prevention and Cleaner Production: Best Practices in the Wood and Paper Industries. Amsterdam: Elsevier Publishing.

Cheremisinoff, N.P., & Rosenfeld, P.E., (2009). Handbook of Pollution Prevention and Cleaner Production: Best Practices in the Petroleum Industry. Amsterdam: Elsevier Publishing.

Wu, C., Tam, L., Clark, J., Rosenfeld, P. (2009). Dioxin and furan blood lipid concentrations in populations living near four wood treatment facilities in the United States. WIT Transactions on Ecology and the Environment, Air Pollution, 123 (17), 319-327.

Cheremisinoff, N.P., Rosenfeld, P.E. Davletshin, A.R. (2008). Responsible Care. Gulf Publishing. Texas.

Tam L. K., Wu C. D., Clark J. J. and Rosenfeld, P.E. (2008). A Statistical Analysis Of Attic Dust And Blood Lipid Concentrations Of Tetrachloro-p-Dibenzodioxin (TCDD) Toxicity Equivalency Quotients (TEQ) In Two Populations Near Wood Treatment Facilities. Organohalogen Compounds, 70, 002252-002255.

Tam L. K., Wu C. D., Clark J. J. and Rosenfeld, P.E. (2008). Methods For Collect Samples For Assessing Dioxins And Other Environmental Contaminants In Attic Dust: A Review. Organohalogen Compounds , 70, 000527- 000530.

Hensley, A.R. A. Scott, J. J. J. Clark, Rosenfeld, P.E. (2007). Attic Dust and Human Blood Samples Collected near a Former Wood Treatment Facility. Environmental Research. 105, 194-197.

Rosenfeld, P.E., J . J . J . C l a r k , A . R . H e n s l e y , M . S u f f e t . ( 2 0 0 7 ) . T h e U s e o f a n O d o r W h e e l C l a s s i f i c a t i o n f o r Evaluation of Human Health Risk Criteria for Compost Facilities. Water Science & Technology 55(5), 345-357.

Rosenfeld, P. E., M. Suffet. (2007). The Anatomy of Odour Wheels for Odours of Drinking Water, Wastewater, Compost And The Urban Environment. Water Science & Technology 55(5), 335-344.

Sullivan, P. J. Clark, J.J.J., Agardy, F. J., Rosenfeld, P.E. (2007). Toxic Legacy, Synthetic Toxins in the Food, Water, and Air in American Cities. Boston Massachusetts: Elsevier Publishing

Rosenfeld, P.E., and Suffet I.H. (2004). Control of Compost Odor Using High Carbon Wood Ash. Water Science and Technology. 49(9),171-178.

Rosenfeld P. E., J.J. Clark, I.H. (Mel) Suffet (2004). The Value of An Odor-Qua lity-Wheel Classification Scheme for The Urban Environment. Water Environment Federation’s Technical Exhibition and Conference (WEFTEC) 2004. New Orleans, October 2-6, 2004.

Rosenfeld, P.E., and Suffet, I.H. (2004). Understanding Odorants Associated with Compost, Biomass Facilities, and the Land Application of Biosolids. Water Science and Technology. 49(9), 193-199.

Rosenfeld, P.E., and Suffet I.H. (2004). Control of Compost Odor Using High Carbon Wood Ash, Water Science and Technology, 49(9), 171-178.

Rosenfeld, P. E ., Grey, M. A., Sellew, P. (2004). Measurement of Biosolids Odor and Odorant Emissions from Windrows, Static Pile and Biofilter. Water Environment Research. 76(4), 310-315.

Rosenfeld, P.E., Grey, M and Suffet, M. (2002). Compost Demo nstration Project, Sacramento California Using High-Carbon Wood Ash to Control Odor at a Green Materials Composting Facility. Integrated Waste Management Board Public Affairs Office, Publications Clearinghouse (MS–6), Sacramento, CA Publication #442-02-008.

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Rosenfeld, P.E., and C.L. Henry. (2001). Characterization of odor emissions from three different biosolids. Water Soil and Air Pollution. 127(1-4), 173-191.

Rosenfeld, P.E., and Henry C. L., (2000). Wood ash control of odor emissions from biosolids application. Journal of Environmental Quality. 29, 1662-1668.

Rosenfeld, P.E., C.L. Henry and D. Bennett. (2001). Wastewater dewatering polymer affects on biosolids odor emissions and microbial activity. Water Environment Research. 73(4), 363-367.

Rosenfeld, P.E., and C.L. Henry. (2001). Activated Carbon and Wood Ash Sorption of Wastewater, Compost, and Biosolids Odorants. Water Environment Research, 73, 388-393.

Rosenfeld, P.E., and Henry C. L., (2001). High carbon wood ash effect on biosolids microbial activity and odor.

Water Environment Research. 131(1-4), 247-262.

Chollack, T. and P. Rosenfeld. ( 1998). Compost Amendment Handbook for Landscaping. Prepared for and distributed by the City of Redmond, Washington State.

Rosenfeld, P. E. (1992). The Mount Liamuiga Crater Trail. Heritage Magazine of St. Kitts, 3(2).

Rosenfeld, P. E. (1993). High School Biogas Project to Prevent Deforestation on St. Kitts. Biomass Users Network, 7(1).

R o s e n f e l d , P . E . (1998). Characterization, Quan tification, and Control of Odor Emissions from Biosolids Application To Forest Soil. Doctoral Thesis. University of Washington College of Forest Resources.

Rosenfeld, P. E. (1994). Potential Utilization of Small Diameter Trees on Sierra County Public Land. Master’s thesis reprinted by the Sierra County Economic Council. Sierra County, California.

Rosenfeld, P. E. (1991). How to Build a Small Rural Anaerobic Digester & Uses Of Biogas In The First And Third World. Bachelor’s Thesis. University of California.

Presentations:

Rosenfeld, P.E ., "The science for Perfluorinated Chemicals (P FAS): What makes remediation so hard?" Law Seminars International, (May 9-10, 2018) 800 Fifth Avenue, Suite 101 Seattle, WA.

Rosenfeld, P.E., Sutherland, A; Hesse, R.; Zapa ta, A. (October 3-6, 2013). Air dispersion modeling of volatile organic emissions from multiple natural gas wells in Decatur, TX. 44th Western Regional Meeting, American Chemical Society. Lecture conducted from Santa Clara, CA.

Sok, H.L.; Waller, C.C.; Feng, L.; Gonzalez, J.; Sutherland, A.J.; Wisdom-S tack, T.; Sahai, R.K.; Hesse, R.C.; Rosenfeld, P.E. (June 20-23, 2010). Atrazine: A Persistent Pesticide in Urban Drinking Water .

Urban Environmental Pollution. Lecture conducted from Boston, MA.

Feng, L.; Gonzalez, J.; Sok, H.L.; Sutherland, A.J.; Waller, C.C.; Wisdom-S tack, T.; Sahai, R.K.; La, M.; Hesse, R.C.; Rosenfeld, P.E. (June 20-23, 2010). Bringing Environmental Justice to East St. Louis, Illinois. Urban Environmental Pollution. Lecture conducted from Boston, MA.

Rosenfeld, P.E . (April 19-23, 2009). Perfluoroctanoic Acid (PFOA) and Perfluoroactane Sulfonate (PFOS) Contamination in Drinking Water From the Use of Aqueous Film Forming Foams (AFFF) at Airports in the United States. 2009 Ground Water Summit and 2009 Ground Water Protection Council Spring Meeting, Lecture conducted from Tuscon, AZ.

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Rosenfeld, P.E. (April 19-23, 2009). Cost to Filter Atrazine Contamination from Drinking Water in the United States” Contamination in Drinking Water From the Use of Aqueous Film Forming Foams (AFFF) at Airports in the United States. 2009 Ground Water Summit and 2009 Ground Water Protection Council Spring Meeting . Lecture conducted from Tuscon, AZ.

Wu, C., Tam, L., Clark, J., Rosenfeld, P . (20-22 July (2009). Dioxin and furan blood lipid concentrations in populations living near four wood treatment facilities in the United States. Brebbia, C.A. and Popov, V., eds., Air Pollution XVII: Proceedings of the Seventeenth International Conference on Modeling, Monitoring and Management of Air Pollution. Lecture conducted from Tallinn, Estonia.

Rosenfeld, P. E. (October 15-18, 2007). Moss Point Community Exposure To Contaminants From A Releasing Facility. The 23
rd Annual International Conferences on Soils Sediment and Water. Platform lecture conducted at University of Massachusetts, Amherst MA.

Rosenfeld, P. E. (October 15-18, 2007). The Repeated Trespa ss of Tritium-Contaminated Water Into A Surrounding Community Form Repeated Wa ste Spills From A Nuclear Power Plant . The 23 rd Annual International
Conferences on Soils Sediment and Water . Platform lecture conducted from Un iversity of Massachusetts, Amherst MA.

Rosenfeld, P. E. (October 15-18, 2007). Somerville Community Exposure To Contaminants From Wood Treatment Facility Emissions. The 23rd Annual International Conferences on Soils Sediment and Water . Lecture conducted from University of Massachusetts, Amherst MA.

Rosenfeld P. E. (March 2007). Production, Chemical Properties, Toxicology, & Treatment Case Studies of 1,2,3- Trichloropropane (TCP). The Association for Environmental Health and Sciences (AEHS) Annual Meeting . Lecture conducted from San Diego, CA.

Rosenfeld P. E. (March 2007). Blood and Attic Sampling for Dioxin/Furan, PAH, and Metal Exposure in Florala, Alabama. The AEHS Annual Meeting. Lecture conducted from San Diego, CA.

Hensley A.R., Scott, A., Rosenfeld P.E., Clark, J.J.J. (August 21 – 25, 2006). Dioxin Containing Attic Dust And Human Blood Samples Collected Near A Former Wood Treatment Facility. The 26th International Symposium on Halogenated Persistent Organic Pollutants – DIOXIN2006 . Lecture conducted from Radisson SAS Scandinavia Hotel in Oslo Norway.

Hensley A.R., Scott, A., Rosenfeld P.E., Clark, J.J.J. (November 4-8, 2006). Dioxin Containing Attic Dust And Human Blood Samples Collected Near A Former Wood Treatment Facility . APHA 134 Annual Meeting & Exposition. Lecture conducted from Boston Massachusetts.

Paul Rosenfeld Ph.D . (October 24-25, 2005). Fate, Transport and Persistence of PFOA and Related Chemicals.

Mealey’s C8/PFOA. Science, Risk & Litigation Conference. Lecture conducted from The Rittenhouse Hotel, Philadelphia, PA.

Paul Rosenfeld Ph.D. (September 19, 2005). Bromin ated Flame Retardants in Groundwater: Pathways to Human Ingestion, Toxicology and Remediation PEMA Emerging Contaminant Conference . Lecture conducted from Hilton Hotel, Irvine California.

Paul Rosenfeld Ph.D . (September 19, 2005). Fate, Transport, Toxicity, And Persistence of 1,2,3-TCP. PEMA Emerging Contaminant Conference. Lecture conducted from Hilton Hotel in Irvine, California.

Paul Rosenfeld Ph.D. (September 26-27, 2005). Fate, Transport and Persistence of PDBEs. Mealey’s Groundwater Conference. Lecture conducted from Ritz Carlton Hotel, Marina Del Ray, California.

Paul Rosenfeld Ph.D . (June 7-8, 2005). Fate, Transport and Persistence of PFOA and Related Chemicals.

International Society of Environmental Fo rensics: Focus on Emerging Contaminants . Lecture conducted from Sheraton Oceanfront Hotel, Virginia Beach, Virginia.

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Paul Rosenfeld Ph.D . (July 21-22, 2005). Fate Transport, Pers istence and Toxicology of PFOA and Related Perfluorochemicals. 2005 National Groundwater Association Ground Water and Environmental Law Conference .

Lecture conducted from Wyndham Baltimore Inner Harbor, Baltimore Maryland.

Paul Rosenfeld Ph.D . (July 21-22, 2005). Brominated Flame Retardants in Groundwater: Pathways to Human Ingestion, Toxicology and Remediation. 2005 National Groundwater Association Ground Water and Environmental Law Conference. Lecture conducted from Wyndham Baltimore Inner Harbor, Baltimore Maryland.

Paul Rosenfeld, Ph.D. and James Clark Ph.D. and Rob Hesse R.G. (M ay 5-6, 2004). Tert-butyl Alcohol Liability and Toxicology, A National Problem and Unquantified Liability. National Groundwater Association. Environmental Law Conference. Lecture conducted from Congress Plaza Hotel, Chicago Illinois.

Paul Rosenfeld, Ph.D. (March 2004). Perchlorate Toxicology. Meeting of the American Groundwater Trust .

Lecture conducted from Phoenix Arizona.

Hagemann, M.F., Paul Rosenfeld, Ph.D. and Rob Hesse (2004). Perchlorate Contamination of the Colorado River.

Meeting of tribal representatives. Lecture conducted from Parker, AZ.

Paul Rosenfeld, Ph.D. (April 7, 2004). A National Damage Assessment Model for PCE and Dry Cleaners.

Drycleaner Symposium. California Ground Water Association. Lecture conducted from Radison Hotel, Sacramento, California.

Rosenfeld, P. E ., Grey, M., (June 2003) Two stage biofilte r for biosolids composting odor control. Seventh International In Situ And On Site Bioremediation Symposium Battelle Conference Orlando, FL.

Paul Rosenfeld, Ph.D. and James Clark Ph.D. (February 20-21, 2003) Understanding Historical Use, Chemical Properties, Toxicity and Regulatory Guidance of 1,4 Dioxane. National Groundwater Association. Southwest Focus Conference. Water Supply and Emerging Contaminants. Lecture conducted from Hyatt Regency Phoenix Arizona.

Paul Rosenfeld, Ph.D. (February 6-7, 2003). Underground Stor age Tank Litigation and Remediation. California CUPA Forum. Lecture conducted from Marriott Hotel, Anaheim California.

Paul Rosenfeld, Ph.D . (October 23, 2002) Underground Storage Tank Litigation and Remediation. EPA Underground Storage Tank Roundtable. Lecture conducted from Sacramento California.

Rosenfeld, P.E . and Suffet, M. (October 7- 10, 2002). Understanding Odor from Compost, Wastewater and Industrial Processes. Sixth Annual Symposium on Off Fl avors in the Aquatic Environment. International Water Association. Lecture conducted from Barcelona Spain.

Rosenfeld, P.E. and Suffet, M. (October 7- 10, 2002). Using High Carbon Wood Ash to Control Compost Odor.

Sixth Annual Symposium on Off Flavors in the Aquatic Environment. International Water Association . Lecture conducted from Barcelona Spain.

Rosenfeld, P.E. and Grey, M. A. (September 22-24, 2002). Biocycle Composting for Coastal Sage Restoration.

Northwest Biosolids Management Association. Lecture conducted from Vancouver Washington.

Rosenfeld, P.E. and Grey, M. A. (November 11-14, 2002). Using High-Carbon Wood Ash to Control Odor at a Green Materials Composting Facility. Soil Science Society Annual Conference. Lecture conducted from Indianapolis, Maryland.

Rosenfeld. P.E. (September 16, 2000). Two stage biofilter for biosolids composting odor control. Water Environment Federation.

Lecture conducted from Anaheim California.

Rosenfeld. P.E. ( October 16, 2000). Wood ash and biofilter control of compost odor. Biofest. Lecture conducted from Ocean Shores, California.

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Rosenfeld, P.E. ( 2000). Bioremediation Using Organic Soil Amendments. California Resource Recovery Association. Lecture conducted from Sacramento California.

Rosenfeld, P.E ., C.L. Henry, R. Harrison. (1998). Oat and Grass Seed Germination and Nitrogen and Sulfur Emissions Following Biosolids Incorporation with High-Carbon Wood-Ash. Water Environment Federation 12th Annual Residuals and Biosolids Management Conference Proceedings . Lecture conducted from Bellevue Washington.

Rosenfeld, P.E., and C.L. Henry. (1999). An evaluation of ash incorporation with biosolids for odor reduction. Soil Science Society of America. Lecture conducted from Salt Lake City Utah.

Rosenfeld, P.E., C.L. Henry, R. Harrison. (1998). Comparison of Microbial Activity and Odor Emissions from Three Different Biosolids Applied to Forest Soil. Brown and Caldwell. Lecture conducted from Seattle Washington.

Rosenfeld, P.E. , C.L. Henry. (1998). Characterization, Quantification, and Control of Odor Emissions from Biosolids Application To Forest Soil. Biofest. Lecture conducted from Lake Chelan, Washington.

Rosenfeld, P.E, C.L. Henry, R. Harrison. (1998). Oat and Gr ass Seed Germination and Nitrogen and Sulfur Emissions Following Biosolids Incorporation with High-Carbon Wood-Ash. Water Environment Federation 12th Annual Residuals and Biosolids Management Conference Proceedings. Lecture conducted from Bellevue Washington.

Rosenfeld, P.E., C.L. Henry, R. B. Ha rrison, and R. Dills. (1997). Compar ison of Odor Emissions from Three Different Biosolids Applied to Forest Soil. Soil Science Society of America. Lecture conducted from Anaheim California.

Teaching Experience:

UCLA Department of Environmental Health (Summer 2003 through 20010) Taught Environmental Health Science 100 to students, including undergrad, medical doctors, public health professionals and nurses. The course focused on the health effects of environmental contaminants.

National Ground Water Association, Successful Remediation Technologies. Custom Course in Sante Fe, New Mexico. May 21, 2002. Focused on fate and transport of fuel contaminants associated with underground storage tanks.

National Ground Water Association; Successful Remediation Technologies Course in Chicago Illinois. April 1, 2002. Focused on fate and transport of contaminants associated with Superfund and RCRA sites.

California Integrated Waste Management Board, April an d May 2001. Alternative Land fill Caps Seminar in San Diego, Ventura, and San Francisco. Focused on both prescriptive and innovative landfill cover design.

UCLA Department of Environmental Engineering, February 5, 2002. Seminar on Successful Remediation Technologies focusing on Groundwater Remediation.

University Of Washington, Soil Scien ce Program, Teaching Assistant for seve ral courses including Soil Chemistry, Organic Soil Amendments, and Soil Stability.

U.C. Berkeley, Environmental Science Program Teaching Assistant for Environmental Science 10.

Academic Grants Awarded:

California Integrated Waste Management Board. $41,000 grant awarded to UCLA Ins titute of the Environment.

Goal: To investigate the effect of high carbon wood ash on volatile organic emissions from compost. 2001.

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Synagro Technologies, Corona California: $10,000 grant awarded to San Diego State University.

Goal: investigate the effect of biosolids for restoration and remediation of degraded coastal sage soils. 2000.

King County, Department of Research and Technology, Washington State. $100,000 grant awarded to University of Washington: Goal: To investigate odor emissions from biosolids application and the effect of polymers and ash on VOC emissions. 1998.

Northwest Biosolids Management Association, Washington St ate. $20,000 grant awarded to investigate the effect of polymers and ash on VOC emissions from biosolids. 1997.

James River Corporation, Oregon: $10 ,000 grant was awarded to investigate the success of genetically engineered Poplar trees with resistance to round-up. 1996.

United State Forest Service, Tahoe National Forest: $15,0 00 grant was awarded to investigating fire ecology of the Tahoe National Forest. 1995.

Kellogg Foundation, Washington D.C. $500 grant was awarded to construct a large anaerobic digester on St. Kitts in West Indies. 1993

Deposition and/or Trial Testimony:

In the District Court of Harris County Texas
Mt Davis Interest, Inc v Sesco Cement Corp
Cause No 2023-26512
Trial 6-6-2-25

In the United States Southern District of New York
Gallo vs Avon Products Inc., et al
Civil Action No.: 1:23-cv-2023
Deposition 4-24-2025

In Vanderburgh Superior Court 5, County of Vanderburgh, Indiana Markello v CSX
Civil Action No 82D05-2011-CT-004962
Deposition 3-26-25

Iin the Circuit Court of Cook County Illinois
Jarosiewicz v Northeast Regional Railroad
Case No 2023 L 002290
Deposition 2-27-25

In the District Court 191st Judicial District Dallas County Acklin v Poly America International
Cause No DC-22-08610
Deposition 1-8-2025

United States District Court, Norther District of California Asustin Vs Monsanto
Case No 2:23-cv-272
Deposition 12-20-25

In Jefferson Circuit Court Division One, Louisville, Kentucky Stafford vs, CSX
Case No. 18-CI-001790
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Deposition: 8-27-24

In the Twenty-Second Judicial Circuit of St. Louis. State of Missouri Patricia Godfrey vs, Amtrak
Case No. 2122-CC-00525
Deposition: 7-17-24

In the Circuit Court of Jefferson County Alabama
Linda Early Vs. CSX
Case number CV-2021-00241
Deposition 6-24-24

In the Court of Common Please Lucas County, Ohio
Brenda Conkright vs. CSX
Case No. G-4801-CI-0202102664-000
Deposition: 6-4-24

In the Commonwealth of Kentucky, Greenup Circuit Court
Patsy Sue Napier vs. CSX
Case No. 19-CI-0012
Deposition: 5-8-2-24

In United States District Court of Hawaii
Patrick Feindt, Jr. et al. vs. The United States of America Case No. 1:22-cv-LEK-KJM
Trial 3-29-24 and 4-5-24

In the District Court of Hood County State of Texas
Artie Gray vs. Exxon Mobil
Case No. C-2018047
Rosenfeld Deposition:4-22-2024

In the Elkhart Superior Court State of Indiana
Estate of Clark Stacy vs. Penn Central Corporation
Cause No 2D01-2001-CT-00007
Rosenfeld Deposition 1-25-2024 and 3-7-2024

In the Circuit Court of Trempealeau County, State of Wisconsin Michael J. Sylla et al. vs. High-Crush Whitehall LLC
Case No. 2019-CV-63, 2019-CV-64, 2019-CV-65, 2019-CV-66 Rosenfeld Deposition: 3-5-2024

In the Circuit Court of Trempealeau County, State of Wisconsin Leland Drangstveit vs. High-Crush Blair LLC
Case No. 19-CV-66
Rosenfeld Deposition 3-5-2024

In the Circuit Court of Jefferson County Alabama
Donald Lee Ashworth vs. CSX Transportation Inc.

Case No CV-2021-901261
Rosenfeld Deposition 1-23-2024

In the United States District Court for the Eastern District of Wisconsin Gary L Siepe vs. Soo Line Railroad
Case No. 2:21-cv-00919
Rosenfeld Deposition 1-19-2024
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In the United States District Court for the Western District of Louisiana Ricky Bush v. Clean Harbors Colfax LLC
Case No. 1:22-cv-02026-DDD-JPM
Rosenfeld Deposition 12-18-2023 and 1-15-2024

In United States District Court of Hawaii
Patrick Feindt, Jr. et al. vs. The United States of America Case No. 1:22-cv-LEK-KJM
Rosenfeld Deposition 11-29-2023

In the Circuit Court for the Twentieth Judicial Circuit St. Clair County, Illinois Timothy Gray vs. Rural King et al.

Case No 2022-LA-355
Rosenfeld Deposition 9-26-2023

In United States District Court Eastern District of Wisconsin Gary L. Siepe vs. Soo Line Railroad Company
Case No. 2:21-cv-00919
Rosenfeld Deposition 9-15-2023

In the Circuit Court of Cook County Illinois
Donald Fox vs. BNSF
Case No. 2021 L12
Rosenfeld Deposition 9-12-2023

In the Court of Common Please Cuyahoga County, Ohio
Thomas Schleich vs. Penn Central Corporation
Lead Case No. CV-20-939184
Rosenfeld Deposition 8-27-2023

In the Circuit Court of Jackson County Missouri at Kansas City Timothy Dalsing vs. BNSF
Case No. No. 2216-cv06539
Rosenfeld Deposition 7-28-2023

In the United States District Court for the Southern District of Texas Houston Division International Terminals Company LLC Deer Park Fire Litigation Lead Case No. 4:19-cv-01460
Rosenfeld Deposition 7-25-2023

In the Circuit Court of Livingston County Missouri
Shirley Ralls vs. Canadian Pacific Railway and Soo Lind Railroad Case No. 28LV-CV0020
Rosenfeld Daubert Hearing 7-18-2023 Trial Testimony 7-19-2023

In the Circuit Court of Cook County Illinois
Brenda Wright vs. Penn Central and Conrail
Case No. No. 2032L003966
Rosenfeld Deposition 6-13-2023

In the Circuit Court Common Please Philadelphia of Jefferson County Alabama Frank Belle vs. Birmingham Southern Railroad Company et al.

Case No. 01-cv-2021-900901.00
Rosenfeld Deposition 4-6-2023

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In the Circuit Court of Jefferson County Alabama
Linda De Gregorio vs. Penn Central
Case No. 002278
Rosenfeld Deposition 3-27-20203

In the United States District Court Eastern District of New York Rosalie Romano et al. vs. Northrup Grumman Corporation Case No. 16-cv-5760
Rosenfeld Deposition 3-16-2023

In the Superior Court of Washington, Spokane County
Judy Cundy vs. BNSF
Case No. 21-2-03718-32
Rosenfeld Deposition 3-9-2023

In The Court of Common Pleas of Philadelphia County, PA Civil Trial Division Feaster v Conrail
Case No. 001075
Rosenfeld Deposition 2-1-2023

In United States District Court for the Central District of Illinois Sherman vs. BNSF
Case No. 3:17-cv-01192
Rosenfeld Deposition 1-18-2023

In United States District Court District of Colorado
Gonzales vs. BNSF
Case No. 1:21-cv-01690
Rosenfeld Deposition 1-17-2023

In United States District Court District of Colorado
Abeyta vs. BNSF
Case No. 1:21-cv-01689-KMT
Rosenfeld Deposition 1-3-2023

In United States District Court For The Easter District of Louisiana Nathaniel Smith vs. Illinois Central Railroad
Case No. 2:21-cv-01235
Rosenfeld Deposition 11-30-2022

In the Superior Court of the State of California, County of San Bernardino Billy Wildrick, Plaintiff vs. BNSF Railway Company
Case No. CIVDS1711810
Rosenfeld Deposition 10-17-2022

In the State Court of Bibb County, State of Georgia
Richard Hutcherson, Plaintiff vs Norfolk Southern Railway Company Case No. 10-SCCV-092007
Rosenfeld Deposition 10-6-2022

In the Civil District Court of the Parish of Orleans, State of Louisiana Millard Clark, Plaintiff vs. Dixie Carriers, Inc. et al.

Case No. 2020-03891
Rosenfeld Deposition 9-15-2022

In The Circuit Court of Livingston County, State of Missouri, Circuit Civil Division F90

Paul E. Rosenfeld, Ph.D. Page 12 of 17 March 2025

Shirley Ralls, Plaintiff vs. Canadian Pacific Railway and Soo Line Railroad Case No. 18-LV-CC0020
Rosenfeld Deposition 9-7-2022

In The Circuit Court of the 13th Judicial Circuit Court, Hillsborough County, Florida Civil Division Jonny C. Daniels, Plaintiff vs. CSX Transportation Inc.

Case No. 20-CA-5502
Rosenfeld Deposition 9-1-2022

In The Circuit Court of St. Louis County, State of Missouri Kieth Luke et. al. Plaintiff vs. Monsanto Company et. al.

Case No. 19SL-CC03191
Rosenfeld Deposition 8-25-2022

In The Circuit Court of the 13th Judicial Circuit Court, Hillsborough County, Florida Civil Division Jeffery S. Lamotte, Plaintiff vs. CSX Transportation Inc.

Case No. NO. 20-CA-0049
Rosenfeld Deposition 8-22-2022

In State of Minnesota District Court, County of St. Louis Sixth Judicial District Greg Bean, Plaintiff vs. Soo Line Railroad Company
Case No. 69-DU-CV-21-760
Rosenfeld Deposition 8-17-2022

In United States District Court Western District of Washington at Tacoma, Washington John D. Fitzgerald Plaintiff vs. BNSF
Case No. 3:21-cv-05288-RJB
Rosenfeld Deposition 8-11-2022

In Circuit Court of the Sixth Judicial Circuit, Macon Illinois Rocky Bennyhoff Plaintiff vs. Norfolk Southern
Case No. 20-L-56
Rosenfeld Deposition 8-3-2022, Trial 1-10-2023

In Court of Common Pleas, Hamilton County Ohio
Joe Briggins Plaintiff vs. CSX
Case No. A2004464
Rosenfeld Deposition 6-17-2022

In the Superior Court of the State of California, County of Kern George LaFazia vs. BNSF Railway Company.

Case No. BCV-19-103087
Rosenfeld Deposition 5-17-2022

In the Circuit Court of Cook County Illinois
Bobby Earles vs. Penn Central et. al.

Case No. 2020-L-000550
Rosenfeld Deposition 4-16-2022

In United States District Court Easter District of Florida Albert Hartman Plaintiff vs. Illinois Central
Case No. 2:20-cv-1633
Rosenfeld Deposition 4-4-2022

In the Circuit Court of the 4
th Judicial Circuit, in and For Duval County, Florida
Barbara Steele vs. CSX Transportation
F91

Paul E. Rosenfeld, Ph.D. Page 13 of 17 March 2025

Case No.16-219-Ca-008796
Rosenfeld Deposition 3-15-2022

In United States District Court Easter District of New York Romano et al. vs. Northrup Grumman Corporation
Case No. 16-cv-5760
Rosenfeld Deposition 3-10-2022

In the Circuit Court of Cook County Illinois
Linda Benjamin vs. Illinois Central
Case No. No. 2019 L 007599
Rosenfeld Deposition 1-26-2022

In the Circuit Court of Cook County Illinois
Donald Smith vs. Illinois Central
Case No. No. 2019 L 003426
Rosenfeld Deposition 1-24-2022

In the Circuit Court of Cook County Illinois
Jan Holeman vs. BNSF
Case No. 2019 L 000675
Rosenfeld Deposition 1-18-2022

In the State Court of Bibb County State of Georgia
Dwayne B. Garrett vs. Norfolk Southern
Case No. 20-SCCV-091232
Rosenfeld Deposition 11-10-2021

In the Circuit Court of Cook County Illinois
Joseph Ruepke vs. BNSF
Case No. 2019 L 007730
Rosenfeld Deposition 11-5-2021

In the United States District Court For the District of Nebraska Steven Gillett vs. BNSF
Case No. 4:20-cv-03120
Rosenfeld Deposition 10-28-2021

In the Montana Thirteenth District Court of Yellowstone County James Eadus vs. Soo Line Railroad and BNSF
Case No. DV 19-1056
Rosenfeld Deposition 10-21-2021

In the Circuit Court Of The Twentieth Judicial Circuit, St Clair County, Illinois Martha Custer et al. vs Cerro Flow Products, Inc.

Case No. 0i9-L-2295
Rosenfeld Deposition 5-14-2021
Trial October 8-4-2021

In the Circuit Court of Cook County Illinois
Joseph Rafferty vs. Consolidated Rail Corporation and National Railroad Passenger Corporation d/b/a

AMTRAK,
Case No. 18-L-6845
Rosenfeld Deposition 6-28-2021

In the United States District Court For the Northern District of Illinois F92

Paul E. Rosenfeld, Ph.D. Page 14 of 17 March 2025

Theresa Romcoe vs. Northeast Illinois Regional Commuter Railroad Corporation d/b/a METRA Rail Case No. 17-cv-8517
Rosenfeld Deposition 5-25-2021

In the Superior Court of the State of Arizona In and For the Cunty of Maricopa Mary Tryon et al. vs. The City of Pheonix v. Cox Cactus Farm, L.L.C., Utah Shelter Systems, Inc.

Case No. CV20127-094749
Rosenfeld Deposition 5-7-2021

In the United States District Court for the Eastern District of Texas Beaumont Division Robinson, Jeremy et al vs. CNA Insurance Company et al.

Case No. 1:17-cv-000508
Rosenfeld Deposition 3-25-2021

In the Superior Court of the State of California, County of San Bernardino Gary Garner, Personal Representative for the Esta te of Melvin Garner vs. BNSF Railway Company.

Case No. 1720288
Rosenfeld Deposition 2-23-2021

In the Superior Court of the State of California, County of Los Angeles, Spring Street Courthouse Benny M Rodriguez vs. Union Pacific Railroad, A Corporation, et al.

Case No. 18STCV01162
Rosenfeld Deposition 12-23-2020

In the Circuit Court of Jackson County, Missouri
Karen Cornwell, Plaintiff, vs. Marathon Petroleum, LP, Defendant.

Case No. 1716-CV10006
Rosenfeld Deposition 8-30-2019

In the United States District Court For The District of New Jersey Duarte et al, Plaintiffs, vs. United States Metals Refining Company et. al. Defendant.

Case No. 2:17-cv-01624-ES-SCM
Rosenfeld Deposition 6-7-2019

In the United States District Court of Southern District of Texas Galveston Division M/T Carla Maersk vs. Conti 168., Schiffahrts-GMBH & Co. Bulker KG MS “Conti Perdido” Defendant.

Case No. 3:15-CV-00106 consolidated with 3:15-CV-00237
Rosenfeld Deposition 5-9-2019

In The Superior Court of the State of California In And For The County Of Los Angeles – Santa Monica Carole-Taddeo-Bates et al., vs. Ifran Khan et al., Defendants Case No. BC615636
Rosenfeld Deposition 1-26-2019

In The Superior Court of the State of California In And For The County Of Los Angeles – Santa Monica The San Gabriel Valley Council of Governments et al. vs El Adobe Apts. Inc. et al., Defendants Case No. BC646857
Rosenfeld Deposition 10-6-2018; Trial 3-7-19

In United States District Court For The District of Colorado Bells et al. Plaintiffs vs. The 3M Company et al., Defendants Case No. 1:16-cv-02531-RBJ
Rosenfeld Depositio n 3-15-2018 and 4-3-2018

In The District Court Of Regan County, Texas, 112
th Judicial District
Phillip Bales et al., Plaintiff vs. Dow Agrosciences, LLC, et al., Defendants F93

Paul E. Rosenfeld, Ph.D. Page 15 of 17 March 2025

Cause No. 1923
Rosenfeld Deposition 11-17-2017

In The Superior Court of the State of California In And For The County Of Contra Costa Simons et al., Plaintifs vs. Chev ron Corporation, et al., Defendants Cause No. C12-01481
Rosenfeld Deposition 11-20-2017

In The Circuit Court of The Twentieth Judicial Circuit, St Clair County, Illinois Martha Custer et al., Plaintiff vs. Cerro Flow Products, Inc., Defendants Case No.: No. 0i9-L-2295
Rosenfeld Deposition 8-23-2017

In United States District Court For The Southern District of Mississippi Guy Manuel vs. The BP Explor ation et al., Defendants
Case No. 1:19-cv-00315-RHW
Rosenfeld Deposition 4-22-2020

In The Superior Court of the State of California, For The County of Los Angeles Warrn Gilbert and Penny Gilber, Plai ntiff vs. BMW of North America LLC Case No. LC102019 (c/w BC582154)
Rosenfeld Deposition 8-16-2017, Trail 8-28-2018

In the Northern District Court of Mississippi, Greenville Division Brenda J. Cooper, et al., Plaintifs, vs. Meritor Inc., et al., Defendants Case No. 4:16-cv-52-DMB-JVM
Rosenfeld Deposition July 2017

In The Superior Court of the State of Washington, County of Snohomish Michael Davis and Julie Davis et al., Plaintiff vs. Cedar Grove Composting Inc., Defendants Case No. 13-2-03987-5
Rosenfeld Deposition, February 2017
Trial March 2017

In The Superior Court of the State of California, County of Alameda Charles Spain., Plaintiff vs. Thermo Fi sher Scientific, et al., Defendants Case No. RG14711115
Rosenfeld Deposition September 2015

In The Iowa District Court In And For Poweshiek County
Russell D. Winburn, et al., Plaintiffs vs. Doug Hoksbergen, et al., Defendants Case No. LALA002187
Rosenfeld Deposition August 2015

In The Circuit Court of Ohio County, West Virginia
Robert Andrews, et al. vs. Antero, et al.

Civil Action No. 14-C-30000
Rosenfeld Deposition June 2015

In The Iowa District Court for Muscatine County
Laurie Freeman et. al. Plaintiffs vs. Grain Processing Corporation, Defendant Case No. 4980
Rosenfeld Deposition May 2015

In the Circuit Court of the 17
th Judicial Circuit, in and For Broward County, Florida Walter Hinton, et. al. Plaintiff, vs. City of Fort Lauderdale, Florida, a Municipality, Defendant.

F94

Paul E. Rosenfeld, Ph.D. Page 16 of 17 March 2025

Case No. CACE07030358 (26)
Rosenfeld Deposition December 2014

In the United States District Court Western District of Oklahoma Tommy McCarty, et al., Plaintiffs, vs. Oklahoma City Landfill, LLC d/b/a Southeast Oklahoma City Landfill, et al. Defendants.

Case No. 5:12-cv-01152-C
Rosenfeld Deposition: July 2014

In the County Court of Dallas County Texas
Lisa Parr et al, Plaintiff, vs. Aruba et al, Defendant.

Case Number cc-11-01650-E
Rosenfeld Deposition: March and September 2013
Rosenfeld Trial: April 2014

In the County of Kern, Unlimited Jurisdiction
Rose Propagation Services vs. Heppe Enterprises
Case No. S-1500-CV-278190, LHB
Rosenfeld Deposition: May 2014

In the Circuit Court of Baltimore County Maryland
Philip E. Cvach, II et al., Plaintiffs vs. Two Farms, Inc. d/b/a Royal Farms, Defendants Case Number: 03-C-12-012487 OT
Rosenfeld Deposition: September 2013

In the Court of Galveston County, Texas 56
th Judicial District
MDL Litigation Regarding Texas City Refinery Ultracracker Emission Event Litigation Cause No. 10-UC-0001
Rosenfeld Deposition: March 2013
Rosenfeld Trial: September 2013

In the United States District Court of Southern District of Texas Galveston Division Kyle Cannon, Eugene Donovan, Genaro Ramirez, Carol Sassler, and Harvey Walton, each Individually and on behalf of those similarly situated, Plaintiffs, vs. BP Products North America, Inc., Defendant.

Case 3:10-cv-00622
Rosenfeld Deposition: February 2012
Rosenfeld Trial: April 2013

In the United States District court of Southern District of California United States of America, Plaintiff vs. 2,560 Acres of Land, more or less, located in Imperial County, State of California; and Donald L. Crawford, et. al.

Civil No. 3:11-cv-02258-IEG-RBB
Rosenfeld Deposition: December 2012, January 2013

In the Court of Common Pleas of Tuscarawas County Ohio
John Michael Abicht, et al., Plaintiffs, vs . Republic Services, Inc., et al., Defendants Case No. 2008 CT 10 0741 (Cons. w/ 2009 CV 10 0987)
Rosenfeld Deposition October 2012

In the Court of Common Pleas of Tuscarawas County Ohio
John Michael Abicht, et al., Plaintiffs, vs. Republic Services, Inc., et al., Defendants Case Number: 2008 CT 10 0741 (Cons. w/ 2009 CV 10 0987) Rosenfeld Deposition: October 2012

In the United States District Court for the Middle District of Alabama, Northern Division James K. Benefield, et al., Plaintiffs, vs. International Paper Company, Defendant.

F95

Paul E. Rosenfeld, Ph.D. Page 17 of 17 March 2025

Civil Action No. 2:09-cv-232-WHA-TFM
Rosenfeld Deposition July 2010, June 2011

F96

EXHIBIT B
F97

Letter EMY
WI #25-001
August 18, 2025

Alaura R. McGuire
Adams Broadwell Joseph & Cardozo
601 Gateway Boulevard, Suite 1000
South San Francisco, CA 94080

SUBJECT: Wildflower 2 Section 15183 Consistency Memorandum Antioch, CA
Response to Staff Report Comments

Dear Ms. McGuire,

As requested, we have reviewed Staff Report agenda item 6 -1 for the August 20, 2025 Planning Commission meeting in Antioch, California. The Staff Report includes a response to our letter dated July 12th, 2024, regarding our belief that the noise impact analysis for the Wildflower 2 Townhomes Project in Antioch, CA has the potential to create significant impacts from construction and operational noise as well as construction vibration on the surrounding community that are peculiar to the Project.

The City’s response to comment 1-8 states that a “noise attenuation study is not required, as the City has determined that the project would not result in a significant increase in noise and because the project is not located in an area exceeding the General Plan noise standards.” The Housing Element EIR claims that compliance with General Plan Policy 11.8.2 would ensure impacts remain less than significant. However, Policy 11.8.2 states that for developments in areas exceeding the noise levels identified in the General Plan noise objectives, or where the development of proposed uses could result in a significant increase in noise, General Plan Policy 11.8.2(f) requires a detailed noise attenuation study to be prepared by a qualified acoustical engineer to determine appropriate mitigation and ways to incorporate such mitigation into project design and implementation. (Housing Element pg. IV.L -13). The City has not provided any evidence to demonstrate that the Project will not exceed General Plan noise objectives or require a noise attenuation study.

Specifically, no baseline noise measurements were taken. Baseline noise measurements are the preferred way to determine background noise sources. Noise measurements are required to determine if General Plan noise objectives are exceeded because they provide objective, site-specific data on existing and potential sound levels in the community. General Plan noise objectives are established to protect public health, safety, and quality of life, but these objectives cannot be meaningfully evaluated without quantifiable inf ormation. Noise impacts vary depending on surrounding land uses, traffic volumes, building design, and other environmental factors, making actual measurements necessary to assess compliance with established thresholds. Without reliable F98

WILSON IHRIG
Slatten Ranch Townhomes
Comments on Noise Analysis

measurements, the City risks relying on assumptions that may underestimate or overstate impacts, leading to flawed planning decisions and inadequate mitigation , in addition to no proof that the project does not result in a significant increase in noise.

The City also failed to address the Project’s peculiar construction and vibration impacts. Our previous letter demonstrated how construction noise could reach as high as 85 dBA , and that construction vibration is within the buffer zone required by the Housing Element DEIR . Construction activities have the potential to create significant impacts compared to reasonable criteria for daytime construction noise and damage to buildings due to construction.

For construction noise, General Plan Policy 11.8.2 “requires development adjacent to occupied noise sensitive land uses to implement a construction -related noise mitigation plan and requires that all construction equipment utilize noise reduction features” Additionally, the construction-related noise mitigation plan should “depict the location of construction equipment and how the noise from this equipment will be mitigated during construction through the use of noise reduction methods” that are listed in General Plan Policy 11.8.2 (m) (DEIR page IV.L-12).

The City’s response to comment 1-9 details several design guidelines that reduce noise. None of these are guaranteed to reduce noise and depend on the unique characteristics of each site. ‘Noise reduction features are already included in construction noise source models of the cited FTA database, which takes its source values from measurements of modern equipment already equipped with mufflers. Nighttime construction restrictions do not mitigate daytime noise level s. Strategic staging will reduce the length of unnecessary noise impacts, but will not mitigate the worst -case construction noise scenarios when necessary activities occur adjacent to sensitive uses.

The Staff Report states that any “proposed development adjacent to occupied noise sensitive land uses shall implement a construction -related noise mitigation plan that depicts the location of construction equipment storage and maintenance areas, and documents methods to be employed to minimize noise impacts on adjacent noise sensitive land uses.” A construction -related noise mitigation plan alone is not sufficient to reduce impacts under CEQA guidelines because CEQA requires that all feasible mitigation measures be identified, analyzed, and implemented to the extent possible—not just as broadly planned. A plan submitted after project approval does not ensure that noise impacts will actually be reduced to less-than-significant levels, since effectiveness depends on site-specific conditions, timing, equipment, and enforcement. CEQA requires substantial evidence demonstrating that proposed measures will meaningfully reduce noise exposure; simply adopting a mitigation plan without quantifying reductions or evalua ting feasibility leaves uncertainty about whether impacts are adequately addressed. In other words, compliance with CEQA is based on demonstrated effectiveness, not on the existence of a plan alone.

Finally, the City’s response to comment 1 -12 states that the “requirement for a screening level vibration analysis is based specifically on the use of impact pile drivers during construction.” The Staff Report states that pile driving is not typically used on residential projects. If this is the case, this should be included somewhere within the terms of approval for the project. Without this assurance that pile drivers will not be used during Project construction , the proposed project may not follow the mitigation required by the Housing Element DEIR and could generate significant impacts.

F99

WILSON IHRIG
Slatten Ranch Townhomes
Comments on Noise Analysis

Therefore, the City fails to adequately address my previous comments related to the 15183 Consistency Memo’s inadequate noise impact analysis. The City fails to establish baseline noise measurements or conduct a noise attenuation study to properly identify potentially significant noise impacts peculiar to the Project or Project site. The City also fails to adequately address the Project’s significant and peculiar construction noise and vibration impacts, which must be analyzed in an EIR prior to Project approval.

Very truly yours,

WILSON IHRIG

Jack Meighan
Associate
meighan -wildflower response to staff report comments.docx F100

JACK MEIGHAN
Associate

Jack joined Wilson Ihrig in 2021 and is an experienced acoustics engineer with expertise in projects involving rail transit systems, highways, CEQA analysis, environmental noise reduction, mechanical drawing reviews, and construction noise and vibration mitigation. He has hands-on experience with project management, including client coordination and presentations, as well as in designing, developing, and testing MATLAB code used in acoustics applications. Additionally, his expertise includes taking field measurements, developing test plans and specifying, purchasing, setting up and repairing acoustic measurement equipment. He has experience in using Traffic Noise Model (TNM), CadnaA, EASE, Visual Basic, LabView, and CAD software.

Education
 B.S. in Mechanical Engineering, University of Southern California, Los Angeles, CA

Project Experience
Metro Regional Connector, Los Angeles CA
Planned, took, and processed measurements as part of a team to determine the effectiveness of floating slab trackwork for a new subway in downtown Los Angeles that travels below the Walt Disney Concert Hall and the Colburn School of Music.

Rodeo Credit Enterprise CEQA Analysis for New Construction, Palmdale, CA Wrote an accepted proposal and executed it for a noise study project to determine noise mitigation requirements on a new housing development. Led all aspects of the project and managed the budget during all phases of project completion. Completed 5 separate projects of this type for this developer.

Blackhall Studios, Santa Clarita, CA
Led the vibration measurement effort for a new soundstage directly adjacent to an existing freight and commuter rail line. Tested equipment, processed data, and analyzed results to determine the vibration propagation through the soil to the proposed soundstage locations, and was part of the team that developed mitigation techniques for the office spaces directly next to the rail line.

Octavia Residential Condos CEQA Study, San Francisco, CA Calculated the STC ratings for the proposed windows to meet Title 24 requirements, modeled the acoustic performance of floor and ceiling structures, researched noise codes, helped with a mechanical design review, and wrote a report summarizing the results for a new Condominium project being developed in San Francisco.

San Diego International Airport Terminal I Re
placement, CA
Conducted interior noise and vibration measurements, analyzed measurement data to help determine project criteria, modeled the existing and future terminals in CadnaA, and was part of a team that did a complete HVAC analysis of the entire terminal, as part of a CEQA analysis where a new terminal for the airport is being designed.

F101
WILSON IHRIG
Jack Meighan – Page 2

* Work done prior to working for Wilson Ihrig
Five Points Apartments Noise Study, Whittier, CA
Took measurements, researched sound data and solutions, and recommended mitigation for a new apartment complex that was located next to an existing car wash, as part of a CEQA review.

USC Ellison Vibration Survey, Los Angeles, CA
Conducted vibration measurements as part of a survey to determine the effectiveness of vibration isolation platforms that are used to insulate cell growth in a cancer research facility. Determined the effectiveness and presented this information to the client. Researched and recommended a permanent monitoring system so the client could view data in real time.

TEN50 Condos ‘Popping’ Noise Investigation, Los Angeles, CA Was part of a team that investigated the noise source of an unwanted popping noise in luxury condos in Downtown Los Angeles. Helped isolate the noise source location with accelerometers to determine where vibrations were occurring first and used an acoustic camera to determine where in the condo the noise was coming from.

2000 University Project, Berkely, CA
Wrote a construction noise monitoring plan based on environmental noise calculations, wrote a report summarizing the results, and attending a meeting with the client to discuss options.

Bay Area Rapid Transit (BART) On‐Track, CA, San Francisco Bay Area, CA* Day to day project manager, responsible for meetings, presentations, and coordination with the client for an ongoing noise study on the BART system. Developed MATLAB code to process measurements and determine areas where high corrugation was present, contributing to excessively high in-car noise levels. Performed noise measurements inside both the right of way and the vehicle cabin, in addition to rail corrugation measurements.

California I‐605/SR‐60 Interchange Improvement, Los Angeles, CA* Developed a noise model of the area that predicted sound levels for abatement design, in addition to conducting noise measurements and analysis. Led the Team in use of the FHWA Traffic Noise Model Software for the project, involving three major highways and two busy interchanges extending over 17 miles in southern California.

Sound Transit On‐Track, Seattle, WA*
Took measurements, fixed equipment, and developed software in MATLAB to process Corrugation Analysis Trolley measurements as part of an ongoing noise study on the Sound Transit Link system.

Tested vibration data to determine the best measurement and processing techniques to store the data in an online database for in-car measurements.

LA Metro CRRC Railcar Testing, Los Angeles, CA*
Led the effort to plan the measurements, determine measurement locations and finalize the test plan. Formulated a method to capture speed data directly from legacy train vehicles. Executed noise and vibration specification measurements for new rail cars delivered by CRRC.

City of Los Ang
eles, Pershing Square Station Rehabilitation Noise Monitoring, CA* Built noise models, wrote a construction noise plan, and assisted in on-site construction noise issues as they arose for a renovation of the Pershing Square metro station in downtown Los F102
WILSON IHRIG
Jack Meighan – Page 3

* Work done prior to working for Wilson Ihrig
Angeles. Trained construction personnel in techniques for noise reduction and how to conduct noise monitoring measurements to meet project specifications.

City of Orange Metrolink Parking Garage Construction Monitoring, CA* Wrote an adaptive management vibration monitoring plan, set up equipment to monitor live vibration levels, and generated weekly reports as part of an effort to build a new parking garage.

Designed, planned, and completed measurements to predict and mitigate pile driving construction impacts at three historic building locations adjacent to the construction site. Coordinated with the client whenever an on-site problem arose.

LA Metro Westside Subway Construction, Los Angeles, CA* Planned, organized, and processed noise measurements for the Purple Line extension construction.

Implemented both long term microphones to measure noise levels and accelerometers to measure vibration levels in existing subway tunnels. Oversaw noise monitoring at sensitive construction sites for the project and worked with the contractor to find ways to reduce construction noise levels by approximately 10dB.

Montreal Réseau Express Métropolitain, Canada*
Conducted vibration propagation measurements used to create models to predict operational vibration levels for an under-construction transit line. Managed equipment, solved problems in the field, and wrote parts of the report summarizing the findings of the acoustic study.

NHCRP Barrier*
Took on-highway measurements and wrote, designed, developed, and tested MATLAB code to identify specific spectrograms to use for analyses for a project evaluating barrier reflected highway traffic noise differences in the presence of a single absorptive or reflective noise barrier.

Siemens Railcar Testing for Sound Transit, Seattle, WA* Measured in-car noise and vibration for new rail cars delivered by Siemens. Developed new internal techniques for measurements based on the written specifications. Contributed to the team that helped identify issues that new cars had in
meeting the Sound Transit specifications for noise
and vibration. Participated in developing the test plan and specified then acquired new equipment for the measurement.

Toronto/Ontario Eglinton Crosstown Light Rail, Final Design, Canada* Assisted in vibration propagation measurements, analysis, and recommendations for mitigation for a 12-mile light-rail line both on and under Eglinton Avenue. Set up and ran equipment for at-grade measurements with an impact hammer for underground measurements with an impact load cell that was used during pre-construction borehole drilling.

F103

Aug 20, 2025

City of Antioch
200 H St.

Antioch, CA 94509

Re: Proposed Housing Development Project “Wildflower Station Townhomes 2”

By email: [email protected]

Cc: [email protected]; [email protected]; [email protected];

Dear Antioch Planning Commission,

The California Housing Defense Fund (“CalHDF”) submits this letter to remind the City of its obligation to abide by all relevant state laws when evaluating the proposed 159-unit housing development project “Wildflower Station Townhomes 2” at APNs 052-140-013, -014, -015, and -016, located east of Hillcrest Avenue and west of Wildflower Station Place. These laws include the Housing Accountability Act (“HAA”) and California Environmental Quality Act (“CEQA”) guidelines.

The HAA provides the project legal protections. It requires approval of zoning and general plan compliant housing development projects unless findings can be made regarding specific, objective, written health and safety hazards. (Gov. Code, § 65589.5, subd. (j).) The HAA also bars cities from imposing conditions on the approval of such projects that would or reduce the project’s density unless, again, such written findings are made. (Ibid.) As a development with at least two-thirds of its area devoted to residential uses, the project falls within the HAA’s ambit, and it complies with local zoning code and the City’s general plan.

The HAA’s protections therefore apply, and the City may not reject the project except based on health and safety impacts that exceed written standards, as outlined above. Furthermore, if the City rejects the project or impairs its feasibility, it must conduct “a thorough analysis of the economic, social, and environmental effects of the action.” (Id. at subd. (b).)

Furthermore, the project is exempt from further state environmental review pursuant to section 15183 of the CEQA Guidelines. Caselaw from the California Court of Appeal affirms that local governments err, and may be sued, when they improperly refuse to grant a project

2201 Broadway, PH1, Oakland, CA 94612
www.calhdf.org
F104

a CEQA exemption or streamlined CEQA review to which it is entitled. (Hilltop Group, Inc. v.

County of San Diego (2024) 99 Cal.App.5th 890, 911.)

As you are well aware, California remains in the throes of a statewide crisis-level housing shortage. New housing such as this is a public benefit; it will bring increased tax revenue, it will help the city’s businesses, and it will ease the competition for existing housing. While no one project will solve the statewide housing crisis, the proposed development is a step in the right direction. CalHDF urges the City to approve it, consistent with its obligations under state law.

CalHDF is a 501(c)3 non-profit corporation whose mission includes advocating for increased access to housing for Californians at all income levels, including low-income households.

You may learn more about CalHDF at www.calhdf.org.

Sincerely,

Dylan Casey
CalHDF Executive Director

James M. Lloyd
CalHDF Director of Planning and Investigations

2 of 2
F105

CITY OF ANTIOCH

PLANNING COMMISSION

REGULAR MEETING
R
egular Meeting July 16, 2025
6:30 p.m. City Council Chambers

1. CAL

L TO ORDER
C
hairperson Webber called the meeting to order at 6:30 P.M. on Wednesday, July 16, 2025, in Council Chambers. He welcomed Commissioner Spijker to the Planning Commission.

P
lanning Manager Merideth introduced Commissioner Spijker and welcomed him to the Planning Commission.

2. RO

LL CALL
P
resent: Commissioners Spijker, Martin, Riley, Perez, Vice Chairperson Jones and Chairperson Webber

Absent: Commissioner Suman
S
taff: Interim City Attorney, Derek Cole
Planning Manager, Zoe Merideth
Minutes Clerk, Kitty Eiden

3. P

LEDGE OF ALLEGIANCE
C
hairperson Webber led the Pledge of Allegiance.

4. P
UBLIC COMMENT – None

5. CO

NSENT CALENDAR
5 -1 Planning Commission Meeting Minutes June 4, 2025
O
n motion by Commissioner Martin , seconded by Commissioner Riley the Planning Commission members present unanimously approved Item 5 -1. The motion carried the following vote:

A
YES: Spijker, Martin, Riley, Perez, Jones and Webber
NOES: None
ABSTAIN: None
ABSENT: Suman

6. NE

W PUBLIC HEARING
6 -1. Wildflower Station Townhomes 2 | TM -02, AR-23-05 | Northeast corner of Hillcrest Avenue and Wildflower Drive (APN: 052- 140-013, 014, 015, and 016) The applicant, Kathryn Watt on behalf of DeNova Homes, Inc., is seeking approval of a Vesting Tentative ATTACHMENT "G"
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Subdivision Map and Design Review for the creation of 19 residential lots and 17 common area parcels for 159 multifamily townhome units in 19 buildings on a +/ - 7.93-acre site.

The project includes an internal road network, open space, landscaping, stormwater facilities, and utilities to serve the project site.

Interim City Attorney Cole announced that the City and Commission had received correspondence from a law firm regarding this agenda item. He stated that staff, the consultant, and himself request additional time to review and respond to the issues raised. On their behalf, he asked the Planning Commission to continue the Public Hearing to August 20, 2025. He also noted that the applicant’s general counsel did not oppose the continuance. He requested the Planning Commission allow for public comment on the agenda item as well as the recommended action to continue the Public Hearing.

Chairperson Webber opened the public comment period.

Mauricio Ulloa, Wildflower Station Place Homeowners Association (HOA), thanked DeNova for incorporating resident feedback into the revised proposal to help address ongoing challenges related to security. He confirmed that the HOA accepted the offer to contribute their fair share toward the maintenance of fencing and gates.

Chairperson Webber closed the public comment period.

On motion by Commissioner Jones, seconded by Commissioner Martin the Planning Commission members present unanimously continued Public Hearing Item #6 -1 to August 20, 2025. The motion carried the following vote:

AYES: Spijker, Martin, Riley, Perez, Jones and Webber
NOES: None
ABSTAIN: None
ABSENT: Suman

6-2. Slatten Ranch Town Homes | TM -01, AR -23-01 | North of Wicklow Way, East of Slatten Ranch Road, and West of Empire Avenue (APN: 056-120-098) The applicant, Kathryn Watt on behalf of DeNova Homes, Inc., is seeking approval of a Vesting Tentative Subdivision Map and Design Review for the creation of 17 residential lots and 13 common area parcels for 129 multifamily townhome units in 17 buildings on a +/- 6.41-acre site.

The project includes an internal road network, open space, landscaping, stormwater facilities, and utilities to serve the project site.

Interim City Attorney Cole announced that the City and Commission had received correspondence from a law firm regarding this agenda item. He stated that staff, the consultant, and himself requested additional time to review and respond to the issues raised. On their behalf, he asked the Planning Commission to continue the Public Hearing to August 20, 2025. He requested the Planning Commission allow for public comment on the agenda item as well as the recommended action to continue the Public Hearing.

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Chairperson Webber opened and closed the public comment period with no members of the public requesting to speak.

On motion by Commissioner Martin , seconded by Commissioner Jones the Planning Commission members present continued Public Hearing Item #6 -2 to August 20, 2025.

The motion carried the following vote:

AYES: Spijker, Martin, Riley, Perez, Jones and Webber
NOES: None
ABSTAIN: None
ABSENT: Suman

7. ORAL/WRITTEN COMMUNICATIONS

Planning Manager Merideth reported on her attendance at a Planning Directors meeting, and she provided an update on new California Environmental Quality Act ( CEQA) laws. She announced the City had received responses to their RFP for the General Plan Update and staff was in the process of evaluating and interviewing firms and anticipated bringing a contract to Council for consideration soon.

8. COMMITTEE REPORTS

Commissioner Jones reported on her attendance at the TRANSPLAN Committee meeting.

9. NEXT MEETING: August 6, 2025

Planning Manager Merideth announced that the August 6, 2025, Planning Commission meeting would likely be canceled, and the next Planning Commission meeting would be held on August 20, 2025.

10. ADJOURNMENT

On motion by Commissioner Martin, seconded by Commissioner Jones, the Planning Commission members present unanimously adjourned the meeting at 6:51 P.M. The
motion carried the following vote:

AYES: Spijker, Martin, Riley, Perez, Jones and Webber
NOES: None
ABSTAIN: None
ABSENT: Suman

Respectfully submitted:

Kitty Eiden
KITTY EIDEN, Minutes Clerk
G3
5-1
Agenda Item #

CITY OF ANTIOCH

PLANNING COMMISSION

REGULAR MEETING

Regular Meeting August 20, 2025 6:30 p.m. City Council Chambers

1. CALL TO ORDER

Chairperson Webber called the meeting to order at 6: 56 P.M. on Wednesday, August 20, 2025,
in Council Chambers.

2. ROLL CALL

Present: Commissioners Suman, Jones, Martin, Spijker, Riley, Vice Chairperson Jones and Chairperson Webber

Absent: Commissioner Perez

Staff: Interim City Attorney, Derek Cole
Planning Manager, Zoe Merideth
Contract Planner, Kevin Valente
City Engineer/Director of Public Works, Scott Buenting
Minutes Clerk, Kitty Eiden

3. PLEDGE OF ALLEGIANCE

Chairperson Webber led the Pledge of Allegiance.

4. PUBLIC COMMENT – None

5. CONSENT CALENDAR

5-1 Planning Commission Meeting Minutes July 16, 2025

On motion by Commissioner Martin , seconded by Commissioner Suman the Planning Commission members present unanimously approved Item 5 -1. The motion carried the following vote:

AYES: Suman, Jones, Martin, Spijker, Webber, Riley
NOES: None
ABSTAIN: None
ABSENT: Perez

6. CONTINUED PUBLIC HEARINGS (Continued from July 16, 2025)

6-1.

Wildflower Station Townhomes 2 | TM -02, AR-23-05 | Northeast corner of Hillcrest Avenue and Wildflower Drive (APN: 052- 140-013, 014, 015, and 016) The applicant, Kathryn Watt on behalf of DeNova Homes, Inc., is seeking approval of a Vesting Tentative G4

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Subdivision Map and Design Review for the creation of 19 residential lots and 17 common area parcels for 159 multifamily townhome units in 19 buildings on a +/ - 7.93-acre site.

The project includes an internal road network, open space, landscaping, stormwater facilities, and utilities to serve the project site.

Contract Planner Valente presented the staff report dated August 20, 2025, recommending the Planning Commission adopt the resolution recommending City Council approval of a Vesting Tentative Subdivision Map and Design Review for the development of the Wildflower Station Townhomes 2 Multifamily Residential Project.

Chairperson Webber opened the public comment period.

Kerri Watt, Director of Entitlements/DeNova Homes , highlighted that as part of this application they had an SB330 preliminary housing application. She gave a history of their approval process and the Wildflower Station Townhomes 2 Multifamily Residential Project PowerPoint presentation. She stated that they agreed with all the conditions of approval as presented.

Alaura McGuire, Adams, Broadwell, Joseph & Cardozo, on behalf of Contra Costa Residents for Responsible Development, request ed the Planning Commission continue the hearing and remand the project back to staff to prepare an EIR specifically to address air quality, noise and public health impacts.

Vicki Williams, Wildflower Station Place 1 Homeowner, stated they welcomed the project if it met all health and environmental standards. She offered to work with this project to install a gate to secure both communities.

Chairperson Webber closed the public comment period.

In response to Commissioner Jones, Ms. Watt stated the Homeowner’s Association ( HOA) for this development and previous phases would be separate entities. She noted the gate access was a viable option provided the original HOA approved the shared cost.

Planning Manager Merideth explained park in lieu fees.

In response to Commission , Ms. Watt clarified that this development would be overparked for guest parking. She also confirmed that it was their intent to work with the existing HOA to address their requests pertaining to access, EV charging stations and fencing.

Commissioner Martin stated he liked the project as proposed noting it would complement the northern development.

In response to Commissioner Martin, Planning Manager Merideth clarified staff had provided a response to comments from the Adams, Broadwell, Joseph & Cardozo letter. She noted earlier today they received a letter from the California Housing Defense Fund (CalHDF) which was part of SB330 that required the project to conform to Objective Standards.

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Interim City Attorney Cole added that staff and the consultant reviewed letters from Adams, Broadwell, Joseph & Cardozo and the hearing was previously continued to address the law firm’s letter, which was thoroughly responded to in the staff report. He noted the additional letter had not raise new issues, and staff was confident that CEQA requirements had been fully satisfied.

He noted if anyone disagreed with staff’s response, it could be appealed to the City Council.

In response to Commissioner Riley, Ms. Watt reviewed bicycle parking and storage areas within the project. She stated that most likely the temporary speed bumps would be replaced with permanent speed bumps.

In response to Mr. Spijker , Planning Manager Merideth stated staff did not have any concerns related to these developments having separate HOAs.

In response to the Commission, Ms. Watt explained that all units would have one parking space within the garage that would be EV-ready, and there would also be some guest parking spaces designated as EV-ready. Additionally, she noted the gates between buildings 10 and 11 would be equipped with a key fob entry for residents and fiber optics would be provided for each unit.

Commissioner Spijker stated he liked the overall esthetics of the project and landscaping plan.

In response to Commissioner Webber, Planning Manager Merideth stated f rom a C ity perspective, the focus was on locating housing developments in proximity to BART stations and key amenities.

On motion by Commissioner Martin, seconded by Commissioner Suman the Planning Commission members present unanimously adopted the resolution of the Planning Commission of the City of Antioch forwarding a recommendation to the City Council to adopt the proposed vesting tentative subdivision map (TM-02) and design review (AR-23- 05) for the development of the Wildflower Station 2 townhomes multifamily residential project. The motion carried the following vote:

AYES: Suman, Jones, Martin, Spijker, Webber, Riley
NOES: None
ABSTAIN: None
ABSENT: Perez

6-2. Slatten Ranch Town Homes | TM -01, AR -23-01 | North of Wicklow Way, East of Slatten Ranch Road, and West of Empire Avenue (APN: 056-120-098) The applicant, Kathryn Watt on behalf of DeNova Homes, Inc., is seeking approval of a Vesting Tentative Subdivision Map and Design Review for the creation of 17 residential lots and 13 common area parcels for 129 multifamily townhome units in 17 buildings on a +/- 6.41-acre site.

The project includes an internal road network, open space, landscaping, stormwater facilities, and utilities to serve the project site.

Contract Planner Valente presented the staff report dated August 20, 2025, recommending the Planning Commission adopt the resolution recommending City Council approval of a Vesting G6

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Tentative Subdivision Map and Design Review for the development of the Slatten Ranch Townhomes Project.

Chairperson Webber opened the public comment period.

Kerri Watt, Director of Entitlements/DeNova Homes , thanked staff for assisting in the process on this application. She stated that this project was also SB330 Housing Application. She provided a history of their project and gave a Slatten Ranch Townhomes Project PowerPoint presentation. She noted that Slatten Ranch conform ed to and was consistent with the City’s General Plan and housing objectives, multifamily objective design standards and development standards for R-25 Zoning under the Antioch Municipal Code. She agreed with all the conditions of approval as presented.

Alaura McGuire, Adams, Broadwell, Joseph & Cardozo, on behalf of Contra Costa Residents for Responsible Development, request ed the Planning Commission continue the hearing and remand the project back to staff to prepare an EIR specifically to address air quality, public health, transportation and noise impacts.

Chairperson Webber closed the public comment period.

In response to Commissioner Jones, Planning Manager Merideth confirmed that the applicant was under the maximum lot coverage.

In response to the Commission, Ms. Watt explained the City’s code as it related to trash enclosures and confirmed that there would be fencing around the bioretention basin and northern property line. Additionally, she stated that these units would be market rate.

Commissioner Martin stated he preferred the colors proposed for the previous project; however, he like the variety of colors presented. He stated he did not support eliminating retail space and the tax revenue associated; however, he understood the market demand.

In response to Commissioner Martin, Interim City Attorney Cole explained that the hearing was previously continued to address the law firm’s letter. Staff reviewed the letter with the consultant and counsel, and they concluded that the existing environmental document was appropriate.

They believed that all issues had been fully addressed, and, from a CEQA perspective, the City had conducted a proper and thorough review. He stated that staff considered it appropriate for the Planning Commission to deliberate and make a decision based on the merits of the project.

In response to Commissioner Martin, Planning Manager Merideth stated the fire district had reviewed the project and provided a letter stating it met their requirements. She noted that she along with Contract Planner Valente and engineering staff met with the fire district to discuss the street widths. She further noted the applicant would be submit ting their development plans to the fire department for a separate development permit and at that time they would be reviewed and approved.

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In response to the Commission, Director of Public Works/City Engineer Buenting stated staff would work with the developer to find the storage necessary to make the left -hand turn lane function. He also explained shared cost and timing for the traffic signal.

In response to Chairperson Webber, Planning Manager Merideth stated all conditions of approval are currently recommended and she explained the park in-lieu fee ordinance.

In response to Commissioner Spijker, Ms. Watt confirmed that they were committed to installing EV chargers in twelve (12) common area spaces and the garages would be EV ready.

On motion by Commissioner Martin , seconded by Commissioner Riley the Planning Commission members present unanimously adopted the resolution of the Planning Commission of the City of Antioch forwarding a recommendation to the City Council to adopt the proposed vesting tentative subdivision map (TM-01) and design review (AR-23- 01) for the development of the Slatten Ranch townhomes project. The motion carried the following vote:

AYES: Suman, Jones, Martin, Spijker, Webber, Riley
NOES: None
ABSTAIN: None
ABSENT: Perez

7. NEW PUBLIC HEARING

7-1 Lone Tree Retail Tentative Parcel Map | PW 357-301-25 | Lone Tree Wy & Blue Rock Center The applicant, ISHC Properties LLC, is proposing a Tentative Parcel Map (TPM) which is creating (5) lots from seven (7) existing parcels. This application does not include the entitlement of any development and only pertains to the TPM.

Planning Manager Merideth introduced Engineering Consultant/Project Manager Little who presented the staff report dated August 20, 2025, recommending the Planning Commission adopt a resolution approving a Tentative Parcel Map (PW 357-301-25) for the Lone Tree Retail and Apartments projects. The site is identified by Assessor’s Parcel Numbers (APNs) 072-500- 001 through 072-500-007.

Chairperson Webber opened the public comment period.

Justin Petrini, RAK Engineering, stated they were proposing a tentative parcel map to support the updated overall site plan and approved uses. He noted the primary change consists of consolidating the multi family parcels into a single dedicated parcel to enable more cohesive infrastructure, utility coordination and future ownership structure. He further noted the map adjusts interior parcel lines to accommodate the approved site plans while complying with state and city regulations. Additionally, it would also update the private and public easements. He stated they would also comply with all current CCRs and City requirements. He provided an overview of the approved site plans and architectural renderings.

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Chairperson Webber closed the public comment period.

In response to Commissioner Jones, Mr. Petrini explained that some parking spaces were being relocated and Planning Manager Merideth reviewed the circulation plan.

In response to Chairperson Webber , Planning Manager Merideth explained that this item was related to merging lot lines to accommodate the projects and clarified that rezoning of the Commercial Infill Housing (CIH) project was approved administratively in 2022.

Commissioner Spijker expressed concern for a 4- story building looking down into the adjacent properties.

In response to Commissioner Jones, Planning Manager Merideth explained that the CIH project could not be built until the tentative parcel map was approved. She stated she believe d the housing development would be a market rate rental project.

On motion by Commissioner Riley, seconded by Commissioner Spijker the Planning Commission adopted the resolution of the Planning Commission of the City of Antioch approving the tentative parcel map for a five (5) lot subdivision for Lone Tree Retail and Apartments P.W. 357-301-25. The motion carried the following vote:

AYES: Suman, Jones, Martin, Spijker, Riley
NOES: Webber
ABSTAIN: None
ABSENT: Perez

8. ORAL/WRITTEN COMMUNICATIONS

Planning Manager Merideth announced the General Plan Consultant contract would be before the City Council on August 26, 2025, and Principal Planner Scudero would be the project manager. She noted a joint Planning Commission and City Council meeting was proposed to kick off the project. She also announced the September 3, 2025, Planning Commission meeting would be canceled, and the next meeting would be on September 17, 2025. She noted the City Council would be holding a Study Session on the Infill Housing Ordinance (IHO) at 6:00 P.M. on
August 26, 2025.

Commissioner Jones requested a future Study Session on city -owned surplus properties to discuss opportunities for determining what could be developed on those sites.

Planning Manager Merideth responded that Community Development did not control that type of planning, and she could not commit other staff for that effort. She noted as part of the General Plan Update there would be opportunities for involvement from the Commission.

Interim City Attorney Cole added that this matter was not within the purview of this Commission; however, Commissioner Jones could discuss this subject with City Manager Scott or Assistant G9

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City Manager Helfenberger. He noted she could also recommend the City Council address this matter.

Chairperson Webber expressed concern that the City had not implemented an option for affordable housing.

9. COMMITTEE REPORTS

Commissioner Jones reported the TRANSPLAN meeting was canceled.

10. NEXT MEETING: September 3, 2025

Commissioner Webber announced the next Planning Commission meeting would be held on September 17, 2025.

11. ADJOURNMENT

On motion by Commissioner Jones , seconded by Commissioner Riley , the Planning Commission members present unanimously adjourned the meeting at 8: 46 P.M. The
motion carried the following vote:

AYES: Suman, Jones, Martin, Spijker, Webber, Riley
NOES: None
ABSTAIN: None
ABSENT: Perez

Respectfully submitted:

Kitty Eiden
KITTY EIDEN, Minutes Clerk

G10
560 Mission Street, Suite 1900 | San Francisco, CA 94105 | T 415.743.6900 | F 415.743.6910 Holland & Knight LLP | www.hklaw.com
Atlanta | Austin | Birmingham | Boston | Century City | Charlotte | Chattanooga | Chicago | Dallas | Denver | Fort Lauderdale Houston | Jacksonville | Los Angeles | Miami | Nashville | Newport Beach | New York | Orlando | Philadelphia | Portland Richmond | San Francisco | Seattle | Stamford | Tallahassee | Tampa | Tysons | Washington, D.C. | West Palm Beach September 23, 2025
City of Antioch City Council
Ron Bernal, Mayor
200 H Street
Antioch, CA 94531
Re: Wildflower Station Townhomes 2 Project – Antioch City Council Hearing, Agenda Item #5 (TM-02 and AR-23-05)
Dear Mayor Bernal and Councilmembers:

Holland & Knight represents DeNova Homes, Inc. (the “Applicant”) with respect to the 159-unit project proposed at the Wildflower Station site (“WFTH2” or the “Project”) at the east side of Hillcrest Avenue and the north side of Wildflower Drive (the “Project Site”) in the City of Antioch (the “City”). Our West Coast Land Use and Environmental Group focuses particularly on enforcing California’s recently reformed housing laws, including the Housing Accountability Act (the “HAA”) and Housing Element Law.
1 As you know, state law imposes increasingly strict requirements upon cities to plan for regional housing needs and then to approve housing development projects that implement those plans. Here, the City of Antioch has done exactly as state law requires. Specifically, the City planned for regional housing growth in its Housing Element, identified sites where housing growth was anticipated and desirable, analyzed and disclosed the impacts of that growth in a comprehensive Environmental Impact Report, and is now processing individual project approvals through an environmental review process expressly sanctioned under state law. Now that the City is on the verge of approving the projects for which the City has already planned in its Housing Element, a group of labor unions have filed comments which invite the City to violate state housing law and expose the City to “Builder’s Remedy” by refusing to actually approve the housing for which the City has already planned and analyzed in a prior EIR that is now no longer subject to challenge. 2 It is in this context that we respond to the July 15, 2025 and August 19, 2025 letters to the Planning 1 Gov. Code §§ 65589.5 et seq.
2 Because the Staff Report well describes the limits imposed upon the Council by state housing law, there is no need to go into detail about the substantial limits that state law imposes upon the Project. However, we must note for the record that the City would violate housing laws including Housing Element Law and the HAA, and potentially expose the entire City to the “Builders’ Remedy” if it were to do as the Labor Unions demand by disapproving, delay or improperly conditioning the approval of the Project. As set forth in the staff report and related materials (and entirely undisputed by the Labor Unions), the Project fully conforms to all objective requirements in the City’s General Plan, zoning and Housing Element and as such it is fully protected by the H AA.

ATTACHMENT "H"
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City of Antioch City Council
September 23, 2025

Commission (the “Comment Letters”) submitted by coalition of labor unions (the “Labor Unions”). As set forth in this letter, these Comment Letters raise no legally valid issue about the City’s careful environmental review of this Project, and the Labor Union’s effort to delay the Project approvals should be seen as an attempt to use CEQA to extract benefits from the Project unrelated to environmental interests. This is the exact type of tactic about which the Legislature and the California courts have shown increasingly strong disapproval.

I. The Comment Letters Reflect an Effort to Extract a Labor Agreement from the Applicant.

As an initial matter, it is evident that the Comment Letters do not reflect a genuine concern for the environment, the proper application of the California Environmental Quality Act (“CEQA”), 3 or
the adequacy of environmental review for the Project in particular. Rather, the Comment Letter s are part of an effort by labor organizations to extract concessions from the Applicant.4 Indeed, the Comment Letters themselves appear to be form letters, and are nearly identical to other letters prepared by Adams Broadwell Joseph & Cardozo PC (“Adams Broadwell”), counsel for the Labor Unions. For example, an April 1, 2019 comment letter prepared by Adams Broadwell with respect to a housing project in the City of Oakland likewise challenged that City’s finding that the project was not entitled to the CEQA exemption set forth in CEQA Guidelines Section 15183.
5 As it does here, Adams Broadwell argued in that letter that the project would have significant unmitigated air quality and health impacts due to the release of diesel particulate matter by construction equipment, as well as significant unmitigated construction- related noise impacts, and thus did not qualify for the Section 15183 CEQA exemption. 6 Adams Broadwell and its clients
regularly submit such letters, and withdraw their complaints not when the alleged environmental issues are addressed, but rather when the project applicant enters into an agreement to engage union labor to develop their project.

The City may consider these practices when assessing the credibility of the arguments raised in the Comment Letter s and the opinions of the consultants the Labor Unions commissioned to oppose the Project .
7 Specifically, the City “is entitled to … disbelieve even uncontradicted

3 Pub. Res. Code §§ 21000 et seq.
4 As the July 15, 2025 Comment Letter indicates, “Contra Costa Residents for Responsible Development” is comprised of the International Brotherhood of Electrical Workers Local 302, Plumbers & Steamfitters Local 159, Sheet Metter Workers Local 104, and Sprinkler Fitters Local 483. July 15, 2025 Comment Letter at 3. 5 See East Bay Residents for Responsible Development, “Appeal to City Council re 1750 Broadway” (Apr. 1, 2019), at 11-21 (https://phonyuniontreehuggers.com/wp-content/uploads/2020/01/2019-04-01-Adams-Broadwell-Joseph- Cardozo-East-Bay-Residents-for-Responsible-Development-1750-Broadway-Project-City-of-Oakland-Letter.pdf); attached also as Exhibit A with other cited material.
6 Id. at 12-21.
7 A review of Adams Broadwell form letters also reveals a similar pattern of form analysis of air quality and public health from its affiliated consultant Soil Water Air Protection Enterprises (“SWAPE”).

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September 23, 2025

testimony of a witness if the witness has an interest in the matter under dispute.” Newberry Springs Water Assn. v. County of San Bernardino (1984) 150 Cal.App.3d 740, 750; Nassiri v. City of Lafayette (2024) 103 Cal.App.5th 910, 930. Further, courts “give the lead agency the benefit of the doubt on any legitimate, disputed issues of credibility.” Citizens for Responsible Equitable Environmental Development v. City of Chula Vista (2011) 197 Cal.App.4th 327, 331.

Thus, the City may reasonably conclude that a coalition of labor unions has no genuine interest in, for example, the Project’s purported operational noise impacts on neighboring properties, and may discount the Comment Letters’ arguments and evidence on that point as not credible. The Unions and their commissioned consultants have made a number of assumptions in their analysis – for example, regarding the Project’s construction schedule, planned buildout, and anticipated construction equipment – which were never confirmed with the Project applicant, are not based on any actual knowledge about the Project, and as a result are not accurate. “[U]nsubstantiated opinion, even expert opinion, is not substantial evidence …” Dunning v. Clews (2021) 64 Cal.App.5th 156, 174 (citation omitted) (also holding that an improperly brought CEQA action can give rise to a potentially viable claim for malicious prosecution not subject to protection by the anti-SLAPP statute).

Using CEQA to pursue non-environmental goals has always been highly disfavored in the law, but the Legislature’s most recent enactments put the question beyond any reasonable doubt: “ CEQA should not be used primarily for economic interests, to stifle competition, to gain competitive advantage, or to delay a project for reasons unrelated to environmental protection.” 8 The
Legislature so disfavors these types of CEQA claims that it has amended the HAA to all -but- prohibit an award of attorneys’ fees to petitioners who challenge such projects, even if the challenge is successful.9 If the Labor Unions were to litigate the CEQA issues they have raised, it will be seen by any reviewing court not as a legitimate effort to enforce environmental law but rather as an attempt to cause “delays to essential projects that are key to solving the state’s housing crisis and to strategic development that is necessary to maintain California’s position as the fourth largest economy in the world.”
10 II. The Project May Not Lawfully Be Required to Undergo Further CEQA Review.

Section 21083.3 of the Public Resources Code , which is implemented via CEQA Guidelines Section 15183, creates a firm statutory exemption from CEQA for the Project . As Guidelines Section 15183 states, “CEQA mandates that projects which are consistent with the development density established by existing zoning, community plan, or general plan policies for which an EIR

8 Stats. 2025, Ch. 24, § 2(c),
9 Gov. Code § 65589.5(p)(1) (“It is the intent of the Legislature that attorney’s fees and costs shall rarely, if ever, be awarded if a local agency, acting in good faith, approved a housing development project that satisfies conditions established in paragraph (1), (2), or (3) of subdivision (a) of Section 65589.5.1 or paragraph (1), (2), or (3) of subdivision (a) of Section 65589.5.2.”).
10 Stats. 2025, Ch. 24, § 2(a).

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September 23, 2025

was certified shall not require additional environmental review, except as might be necessary to examine whether there are project-specific significant effects which are peculiar to the project or its site. This streamlines the review of such projects and reduces the need to prepare repetitive environmental studies.”
11 The City’s 6th Cycle Housing Element identified the Project Site in its inventory of sites for future multi-family development.
12 The Environmental Impact Report (“EIR”) for the 6th Cycle Housing Element, adopted by the City in February 2023 (the “Housing Element EIR”) , analyzed the environmental impacts associated with all sites identified in the Housing Element sites inventory, including the Project Site.
13 To the extent development of the Project and other projects analyzed in the Housing Element EIR were anticipated to result in significant and unavoidable impacts, the City exercised its discretion to adopt a statement of overriding considerations confirming that such impacts were acceptable in light of the important overriding consideration of complying with state housing law. The statute of limitations has long since lapsed to challenge the City’s Housing Element or Housing Element EIR, and both are now fully presumed legally valid. 14 The Project is “consistent with the development density” set forth in the Housing Element for the Project Site.15 After thorough analysis of the Project, City staff concluded that the Project will not have significant environmental impacts peculiar to the Project that were not analyzed in the Housing Element EIR. As such, Guidelines Section 15183 dictates that the Project shall not require additional environmental review.

Section 21083.3 of CEQA and Guidelines Section 15183 establish a CEQA exemption, meaning 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” are not required to undergo any CEQA review, except to the limited extent necessary to ascertain “whether there are

11 Cal. Code Regs. Tit. 14, § 15183(a) (emphasis added). 12 City of Antioch, 2023-2031 Housing Element Update (Oct. 2023), at 6-18 (https://www.antiochca.gov/fc/community-development/planning/housing-element/certified-housing-element.pdf). 13 City of Antioch, “Antioch Housing, Environmental Hazards, and Environmental Justice (EJ) Elements, Draft Environmental Impact Report” (Sept. 2022), at III-20, III-32 (https://www.antiochca.gov/fc/community- development/planning/housing-element/DHEEIR-DEIR_22_0902.pdf). 14 Pursuant to Gov. Code § 65009(c)(2), the statute of limitations to challenge to the City Housing Element ran in 2023, 60 days after the Department of Housing and Community Development reported its findings on the Housing Element. See Dept. of Housing & Comm. Dev., Housing Element EIR Certification Letter (Oct. 12, 2023) (hcd- certification-letter.pdf). A challenge to the Housing Element EIR was also due in 2023, 30 days after the City’s January 2023 Notice of Determination filing for the Housing Element EIR. Pub. Res. Code § 21167(c); Cal. Code Regs. Tit. 14, §15112(c)(1); NOD for the Antioch Housing, Environmental Hazards, and Environmental Justice Elements Project EIR (Jan. 25, 2023) (https://ceqanet.lci.ca.gov/2021110146/4). 15 July 16, 2025, Planning Commission Staff Report, Agenda Item 6-1, at 3-4 (“The R-25 High Density Residential zoning district allows for multiple-family development at a minimum of 20 dwelling units per acre (du/ac) and a maximum of 25 du/ac. Consistent with the R-25 district, the proposed project has a proposed net density of 20.05 du/ac.”).

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project-specific significant effects which are peculiar to the project or its site. ” 16 Thus, the
Applicant may not lawfully be required to prepare an initial study —much less an EIR —as the Comment Letters request.17 Because the Project’s entitlement to the Section 15183 exemption is enforceable in mandamus, the Labor Unions’ request that the City require the Project to undergo CEQA review is an invitation to commit an actionable violation of the law.18 We request that the City Council disregard this invitation to err.

We note for completeness that the refusal to acknowledge a project’s entitlement to a CEQA exemption is a defined violation of the HAA, where the project meets certain qualifying criteria.19 The Project qualifies for this protection. 20 If the City Council were to agree with the Comment Letters and compel the Project to undergo further CEQA review, the Applicant expressly reserves the right to invoke these statutory protections.21
III. The City’s Determination that the Project Qualifies for the Section 15183 CEQA Exemption Is Supported by Substantial Evidence.

City staff prepared a thorough Section 15183 Consistency Memorandum (the “Consistency Memorandum”), which establishes that “the project has been adequately analyzed in the previous environmental review under CEQA and that further evaluation is not required.” 22 The Comment
Letters take issue with the Consistency Memorandum’s conclusions with respect to air quality and noise impacts. Contrary to the Comment Letter s’ assertions, substantial evidence supports the Consistency Memorandum’s analysis and conclusions, as set forth below.

A. Air Quality and Health Impacts.

The Comment Letter s allege that “the Project will have significant, unmitigated air quality and public health impacts that are more severe than previously analyzed.” 23 The Labor Unions specifically reference the toxic air contaminant (“TAC”) diesel particulate matter (“DPM”),

16 Hilltop Group, Inc. v. County of San Diego (2024) 99 Cal.App.5th 890, 912. 17 Union of Medical Marijuana Patients, Inc. v. City of San Diego (2019) 7 Cal.5th 1171, 1186 (“Environmental review is required under CEQA only if a public agency concludes that a proposed activity is a project and does not qualify for an exemption. In that case, the agency must first undertake an initial study to dete rmine whether the project ‘may have a significant effect on the environment.’”) (quoting Cal. Code Regs. Tit. 14, § 15063(a)). 18 See Hilltop Group, Inc. v. County of San Diego (2024) 99 Cal.App.5th 890, 927 (“The Board of Supervisors did not proceed in a manner required by law when they denied the exemption and failed to limit further environmental review to those effects enumerated in Guidelines section 15183, subdivision (b)(1) through (4).”). 19 Gov. Code § 65589.5.1(a).
20 See generally Gov. Code § 65589.5.1(a)(1)-(4).
21 Gov. Code § 65589.5.1(5).
22 July 16, 2025 Planning Commission Staff Report, Agenda Item 6-1, at 9. 23 July 15, 2025 Comment Letter at 10.

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discussing the health risks associated with DPM.
24 And, the Comment Letters reject as
unsupported the Consistency Memorandum’s conclusion that the Project’s implementation of Mitigation Measure AIR -3a (requiring the use of Tier 4 engines for off -road construction equipment, plus a preparation of a Construction Emissions Mitigation Plan) would ensure that no significant impacts peculiar to the Project exist.
25 As discussed, because the Project is consistent with the density set forth in the Housing Element, and the Housing Element EIR was certified, Section 15183 mandates that “the agency shall limit its examination of significant environmental effects which it determines: ‘ (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 EIR 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 substantia l 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.’”
26 As City staff noted in response to the July 15, 2025 Comment Letter:

Mitigation Measure AIR -3a would be considered a uniformly applicable development policy or standard identified by the Housing Element EIR to substantially mitigate impacts associated with buildout of the Housing Element.

With compliance with Mitigation Measure AIR-3a, pursuant to CEQA Guidelines Section 15183(f), the project’s impacts associated with exposure of sensitive receptors to substantial pollutant concentrations would not be considered peculiar.

Because impacts related to exposure of sensitive receptors to substantial pollutant concentrations are not peculiar to the project site or project, in accordance with Section 15183(c) of the CEQA Guidelines, the proposed project qualifies for exemption from further environmental review under CEQA. 27 In the August 19, 2025 Comment Letter, the Labor Unions purported to produce evidence showing that the Project’s DPM emissions “will have significant, unmitigated air quality and public health impacts that are more severe than analyzed in the Housing Element EIR.” 28 This argument appears
to invoke Section 15183(b)(4), which allows limited analysis to ascertain whether there are “previously identified significant effects which, as a result of substantial new information which

24 July 15, 2025 Comment Letter at 10-11.
25 July 15, 2025 Comment Letter at 11.
26 Hilltop Group, Inc. v. County of San Diego (2024) 99 Cal.App.5th 890, 913 (quoting Cal. Code Regs., Tit. 14, § 15183(b)(1)-(4)).
27 Response to Comment 1-6, Responses to Comments, page 32. 28 August 19, 2025 Comment Letter at 6.

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