Banning City Council
July 8, 2025

as a response to human-induced fear. Proceedings of the Royal Society B: Biological Sciences, 282(1802).

Spooner, F. E. B., Pearson, R. G., & Freeman, R. (2018). Rapid warming is associated with population decline among terrestrial birds and mammals globally. Global Change Biology, 24, 4521–4531.

Suraci, J. P., Clinchy, M., Zanette, L. Y., & Wilmers, C. C. (2019). Fear of humans as apex predators has landscape-scale impacts from mountain lions to mice. Ecology Letters, 22(10), 1578–1586.

Suraci, J. P., Nickel, B. A., & Wilmers, C. C. (2020). Fine-scale movement decisions by a large carnivore inform conservation planning in human-dominated landscapes. Landscape Ecology, 35(7), 1635–1649.

Tassou, S. A., De-lille, G., and Lewis, J. 2009. Food transport refrigeration – Approaches to reduce energy consumption and environmental impacts of road transport. Applied Thermal Engineering. Volume 29, Issues 8–9, June 2009, Pages 1467-1477.

Trisos, C. H., Merow, C., & Pigot, A. L. (2020). The projected timing of abrupt ecological disruption from climate change. Nature, 580, 496–501.

Trombulak, S. C., & Frissell, C. A. (2000). Review of ecological effects of roads on terrestrial and aquatic communities. Conservation Biology, 14(1), 18–30.

U.S. Environmental Protection Agency. (2022, accessed Oct. 3, 2022). Sources of Greenhouse Gas Emissions. Available at: https://www.epa.gov/ghgemissions/sources-greenhousegas-emissions.

USFWS. (1992, accessed September 29, 2022). Classification of Wetlands and Deepwater Habitats of the United States. Available at:
https://www.fws.gov/wetlands/documents/classification-of-wetlands-and-deepwaterhabitats-of-the-united-states.pdf.

Van der Ree, R., Jaeger, J. A. G., van der Grift, E. A., & Clevenger, A. P. (2011). Effects of roads and traffic on wildlife populations and landscape function: Road ecology is moving toward larger scales. Ecology and Society, 16(1), 48.
http://spectrum.library.concordia.ca/974450/
Vickers, T. W. (2020). Project Title: Santa Ana Mountains to Eastern Peninsular Range Conservation Connectivity Infrastructure Planning Project for Interstate 15 and Closely Associated Roadways.

Vickers, T. W., Sanchez, J. N., Johnson, C. K., Morrison, S. A., Botta, R., Smith, T., Cohen, B.

S., Huber, P. R., Ernest, H. B., & Boyce, W. M. (2015). Survival and mortality of pumas (Puma concolor) in a fragmented, urbanizing landscape. PLoS ONE, 10(7), 1–18. 457
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Wang, Y., Smith, J. A., & Wilmers, C. C. (2017). Residential development alters behavior, movement, and energetics in a top carnivore. PlosOne, 1–17.

Ware, H. E., Mcclure, C. J. W., Carlisle, J. D., & Barber, J. R. (2015). A phantom road experiment reveals traffic noise is an invisible source of habitat degradation. Proceedings of the National Academy of Sciences, 112(39), 12105–12109.

Wiens, J. J. (2016). Climate-related local extinctions are already widespread among plant and animal species. PLoS Biology, 14(12), 1–18.

Williams, A. P., Cook, B. I., & Smerdon, J. E. (2022). Rapid intensification of the emerging southwestern North American megadrought in 2020–2021. Nature Climate Change.

Wilmers, C. C., Wang, Y., Nickel, B., Houghtaling, P., Shakeri, Y., Allen, M. L., KermishWells, J., Yovovich, V., & Williams, T. (2013). Scale dependent behavioral responses to human development by a large predator, the puma. PLoS ONE, 8(4).

Wu, X., Hu, S., and Mo, S. 2013. Carbon footprint model for evaluating the global warming impact of food transport refrigeration systems. Journal of Cleaner Production. Volume 54, 1 September 2013: 115-124.

Yap, T. A., Rose, J. P., Anderson, I., & Prabhala, A. (2021). California Connections: How Wildlife Connectivity Can Fight Extinction and Protect Public Safety.

Yap, T. A., Rose, J. P., & Cummings, B. (2019). A Petition to List the Southern California/Central Coast Evolutionarily Significant Unit (ESU) of Mountain Lions as Threatened under the California Endangered Species Act (CESA).

Yovovich, V., Allen, M. L., Macaulay, L. T., & Wilmers, C. C. (2020). Using spatial characteristics of apex carnivore communication and reproductive behaviors to predict responses to future human development. Biodiversity and Conservation, 29(8), 2589–2603. 458

EXHIBIT B
459
August 1, 2024
Sent via email
Emery Papp
Senior Planner
Community Development Department
City of Banning
99 East Ramsey Street,
Banning, California 92220
[email protected]
Re: Draft EIR for the Banning Commerce Center Project, SCH # 2022090102 Dear Mr. Papp:

These comments are submitted on behalf of the Center for Biological Diversity (the regarding the Banning Commerce Center Project, SCH # 2022090102 The Center has reviewed the Draft Environmental Impact Report ( DEIR ) closely and is troubled by its failure to disclose and mitigate significant impacts to biological resources, including mountain lions, burrowing owls, and wildlife connectivity. The Center is also concerned with conclusions of significant and unavoidable impacts regarding the conclusions that ignore relevant,
feasible mitigation measures. The Center urges the City of Banning recirculate a legally compliant EIR that fully analyzes, discloses, and mitigates all significant impacts.

The Center is a non-profit, public interest environmental organization dedicated to the protection of native species and their habitats through science, policy, and environmental law.

The Center has over 1.7 million members and online activists throughout California and the United States. The Center has worked for many years to protect imperiled plants and wildlife, open space, air and water quality, and overall quality of life for people in Riverside County.

I. THE DEIR FAILS TO ADEQUATELY ASSESS AND MITIGATE THE IMPACTS TO BIOLOGICAL RESOURCES.

The California Environmental Quality Act (CEQA) requires an EIR to provide decisionmaking bodies and the public with detailed information about the effect a proposed project is likely to have on the environment, to list ways in which the significant effects of a project might be minimized, and to indicate alternatives to the project. (Pub. Res. Code § 21061.) CEQA further requires a lead agency to mitigate to the extent feasible significant impacts. (CEQA 460
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Guidelines § 15064.4.) The DEIR fails to provide sufficient analyses and mitigation for the The Project must be considered in context of the landscape it is located in and surrounded by. The proposed Project includes destroying more than 130 acres of undeveloped habitat that supports numerous sensitive and special-status species located within an identified vital ecological connectivity area between the transverse and peninsular ranges. Special-status species and sensitive habitats that occur in, near, and downstream of the proposed Project will be significantly impacted by a large warehouse project that will increase traffic, noise and light impacts to wildlife connectivity and the special-status species and sensitive habitats that occur, potentially occur, or historically occurred in and near the Project area.

A. -
status species
1 (Exhibit 1), CEQA requires that an EIR
provide decision-making bodies and the public with detailed information about the effect a proposed project is likely to have on the environment. (Pub. Res. Code § 21061.) The EIR must adequately assess and mitigate impacts to special-status species that are known to occur, have the potential to occur, or historically occurred in and near the Project area. Yet the DEIR fails to -status species
that occur, potentially occur, or historically occurred in or near the Project area, including mountain lions (CESA-candidate species), coastal California gnatcatcher (federally threatened, state species of special concern [SSC]), burrowing owl (state SSC that is currently being petitioned to be listed under CESA (Miller, 2024)), Coachella Valley fringe-toed lizard (federally threatened, state endangered), and many others.
adequately analyze and mitigate -status species that occurs, may occur, or historically occurred in and near the Project area. The existence of State and federal standards does not absolve the City from the duty to do everything that is within its power to mitigate the impacts of this Project. (See Save Our Capitol! v Department of Gen.

Servs. (2023) 87 CA5th 655, 696 (agency could not rely on compliance with LEED and CALGreen building standards to mitigate light and glare impacts in absence of project-specific analysis of impacts and effect of compliance); Californians for Alternatives to Toxics v Department of Food & Agric. (2005) 136 CA4th 1 (EIR failed to analyze environmental and health risks of crop disease control program and instead presumed that no adverse impacts would occur from use of pesticides in accordance with the registration and labeling program of the California Department of Pesticide Regulation). See also Ebbetts Pass Forest Watch v Department of Forestry & Fire Protection (2008) 43 C4th 936, 956 (fact that Department of Pesticide Regulation had assessed environmental effects of certain registered herbicides in general not excuse its failure to assess effects of their use for specific timber harvesting project).) 1 from the DEIR. This is concerning
14 Cal Code Regs §15084(c);
Pub Res C §21082.1.)
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The DEIR buries most information in its appendices; however, analyses need to be provided within the main text of the EIR
Vineyard Area Citizens for Responsible Growth, Inc. v City of Rancho Cordova (2007)). Exhibit 2 lists special-status species that have been documented within the California Natural Diversity Database (CNDDB) quadrant that the Project area is located in; the DEIR should provide adequate analyses and
at least these species within the main text of the EIR. The DEIR fails to accomplish this, and therefore fails to comply with CEQA.

Below are a few incomprehensive list and there are likely other special-status species that require additional impact analyses.
i. Mountain Lions
mountain lions, candidate species under the California Endangered Species Act (CESA). In fact, there is no mention of mountain lions in the main text of the DEIR at all. Instead, the limited information regarding mountain lions is buried in a table in an appendix (DEIR Appendix C1 Table 5) with no mention of their CESA status nor sufficient analysis or discussion regarding the es that is currently experiencing an extinction vortex. The appendix merely mentions mountain lions as an MSHCP Covered Species and states they have evidence to support such claims (DEIR Appendix C1 Table 5), as no movement studies were conducted. The conclusion in the appendix is pure conjecture and not based on the best available science.
methodology by only including such information in appendices. (San Joaquin Raptor Rescue Ctr. v. Cty. of Merced, 57 Cal. Rptr. 3d 663, 675 (Cal. Ct. App. 2007)). As the California Supreme Court has held,
quantity, it must be presented in a manner calculated to adequately inform the public and decision makers, who may not be previously familiar with the details of (Vineyard Area Citizens for Responsible Growth, Inc. v. City of Rancho Cordova (2007) 40 Cal. 4th 412, 442)
Id. (citations omitted). Sufficient information regarding wildlife connectivity must be provided within the main text of an EIR. The DEIR fails to comply with CEQA. local mountain lions are within
the Southern California and Central Coast Evolutionarily Significant Unit (ESU) that is currently a candidate threatened species under CESA. There is ample scientific evidence that indicates mountain lion populations in and around the Project area are struggling to survive and that human activities and land use planning that fail to integrate adequate habitat connectivity can have adverse impacts on mountain lions. Continued habitat loss and fragmentation has led to 10 genetically isolated populations within California. There are six identified mountain lion 462
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inbreeding, low genetic diversity, and high human-caused mortality rates from car strikes on roads, depredation kills, rodenticide poisoning, poaching, disease, and increased human-caused wildfires. (Benson et al., 2016, 2019; Ernest et al., 2003; Gustafson et al., 2018, 2021; Riley et al., 2014; Vickers et al., 2015). The primary driver of this extinction vortex is lack of connectivity. (Yap et al., 2019).

The Project area is located between the San Gabriel/San Bernardino (SGSB) population and the Eastern Peninsular Range (EPR) population, and the Santa Ana Mountains (SAM) population is nearby to the southwest. Scientists have documented physical and reproductive signs of inbreeding depression in local mountain lions (from the EPR and Santa Ana mountains, as well as the nearby Central Coast South [i.e. Santa Monica Mountains]) due to being boxed in by roads and development (Huffmeyer et al., 2021). Researchers have found that, of the California mountain lion subpopulations, the SGSB population has the smallest effective population size and the smallest area of available habitat (Dellinger et al., 2020; Gustafson et al., 2021)
and inbreeding similar to the well-monitored and genetically depauperate Santa Ana and Central Coast South populations (Ernest et al., 2014; Gustafson et al., 2017; Riley et al., 2014) (Gustafson et al., 2021), which are predicted to have a 99% chance of becoming locally extinct within 50 years if inbreeding depression continues. (Benson et al., 2019). This emphasizes the importance of protecting the remaining SGSB population, specifically through maintaining and enhancing connectivity among and between the subpopulations.

Collared mountain lions have been documented moving through the Project area to approach I-10. The proposed Project has the potential to amplify the barrier effects of I-10, an undercrossing that has the best vegetation cover to support mountain lion movement between the San Jacinto and San Bernardino mountains. The proposed Project could degrade this important connectivity area and drive the SGSB, EPR, and SAM puma populations towards extinction.
-
status species and sensitive habitats) extend beyond its physical footprint. Ample evidence documents the effects of human activity on mountain lions. One study found that mountain lions are so fearful of humans and noise generated by humans that they will abandon the carcass of a deer and forgo the feeding opportunity just to avoid humans (Smith et al., 2017). The study -consumptive forms of human disturbance may alter the ecological role (Smith et al.,
2017). In addition, mountain lions have been found to respond fearfully upon hearing human vocalizations, avoiding the area and moving more cautiously when hearing humans (Smith et al., 2017; Suraci et al., 2019). Other studies have demonstrated that mountain lion behavior is negatively affected when exposed to other evidence of human presence, such as lighting or vehicles/traffic (Smith et al., 2015; Wang et al., 2017; Wilmers et al., 2013). Therefore, both physical and behavioral barriers drive genetic isolation, and continued land use that further fragments mountain lion habitat in the region without adequately minimizing impacts to functional connectivity, will drive pumas in the area to extinction. The Project will result in 463
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increased traffic, light, noise, etc. in an important connectivity area between the San Bernardino and San Jacinto mountains, where mountain lions are known to occur and are known to be struggling. The Project will significantly impact how mountain lions navigate the landscape by fortifying existing human-made barriers and decreasing opportunities for them to move between mountain ranges.
mountain lions.

Yovovich et al., (2020) further documented the impacts of human activities on local mountain lions, specifically on communication and reproductive behaviors important for their survival. Males use scrapes to delineate territories as well as attract potential mates (M. L. Allen et al., 2015, 2016), and the males in the study preferred to use relatively flat areas away from human influence as scrape habitat (Yovovich et al., 2020). Similarly, when nursing females (with kittens less than 8 weeks old) shrank their home ranges to an average of 9 km2 while their young were most vulnerable, they also selected undeveloped lands away from human disturbance, opting for habitat with protective cover and sufficient water and prey availability (Yovovich et al., 2020). The loss of adequate undisturbed communication and nursery habitat could disrupt important communication and reproductive behaviors that facilitate social structure and overall survival.

In a study that investigated the drivers of fine-scale movement decisions by pumas in fragmented landscapes in the Santa Cruz Mountains, (Suraci et al., 2020) identified that mountain lions prefer larger habitat patches that are closer together and further away from buildings, and they preferred shrub over tree patches. However, mountain lions were willing to accept higher densities of anthropogenic features if target habitat patch areas were larger or the distance between patches was shorter (Suraci et al., 2020). In addition, pumas were found to travel longer distances through open habitats to access larger habitat patches, perhaps for more protective cover and/or for better hunting opportunities within the larger habitat patch areas (Suraci et al., 2020). These findings corroborate those of (Smith et al., 2019), which found that pumas are able to move through partially developed habitat, though they are less likely to move through parcels with higher densities compared to parcels with less dense housing in and around the parcels. In fact, puma avoidance increased sharply as housing density increased up to 41 houses/km2, after which avoidance remained high. Although these studies demonstrate that mountain lions have some tolerance of human presence, they mostly highlight the negative impacts of increased human use/density on the movement and survival of mountain lions and the importance of habitat connectivity among large, intact, heterogeneous habitat patches.

In addition, (Riley et al., 2021) found that, although pumas had some flexibility to navigate urbanized landscapes, they spent more than 95% of their time away from developed areas and actively avoided open areas like golf courses, cemeteries, and other altered landscaped spaces. Mountain lions consistently selected native vegetation types with dense cover, like chaparral, riparian woodland, and coastal sage scrub, with shrublands being their preferred habitat. This highlights the importance of intact and connected natural heterogeneous landscapes to the long-term health and persistence of constrained mountain lion populations. The authors risk mountain lion
populations in southern California is preserving and enhancing connectivity between larger (Riley et al., 2021). In addition, especially in areas where pumas are severely 464
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isolated and wildlife connectivity is already constrained, like in and near the Project area, it is important to note that even a single migrant from a different population can help enhance genetic diversity in inbred puma populations (Gustafson et al., 2017). This suggests that any area with important connectivity is critical for the long-term survival of local pumas. The proposed Project could drive local puma populations towards extinction while harming other wildlife.

Mountain lions are a key indicator species of wildlife connectivity and healthy ecosystems. As the last remaining wide-ranging top predator in the region, the ability to move through large swaths of interconnected habitat is vital for genetic connectivity and their longterm survival. In addition, impacts to mountain lions in the region could have severe ecological consequences; loss of the ecosystem engineer could have ripple effects on other plant and animal species, potentially leading to a decrease in biodiversity and diminished overall ecosystem function. Many scavengers, including California condors, kit foxes, raptors, and numerous insects, would lose a reliable food source (Barry et al., 2019; Ruth & Elbroch, 2014). Fish, birds, amphibians, reptiles, rare native plants, and butterflies would potentially diminish if this apex predator were lost (Ripple et al., 2014; Ripple & Beschta, 2006, 2008). In fact, a recent literature review found that mountain lions are important ecosystem engineers and have been documented to have ecological interactions with at least 485 plant and animal species (Labarge et al., 2022). ensure their long-term survival as well as the longecosystems.

Wildlife connectivity in this region is paramount for the survival of the Southern California mountain lions. Any project that does not adequately assess and address impacts to mountain lions and wildlife connectivity could lead to the extirpation of local mountain lions and severe loss of biodiversity and ecosystem function in the region. Further destruction of wildlife connectivity in the area will push local mountain lions closer towards extinction. See further rement to adequately describe, assess, and mitigate
impacts to wildlife movement and connectivity.
ii. Special-status and Migratory Birds, including Burrowing Owl Many bird species throughout North America area experiencing declines. The widelypublicized results of a 2019 research study showed that nearly three billion birds have been lost in the last half-century, with grassland birds experiencing the heaviest losses (Rosenberg et al., 2019). Threats to birds are numerous and complex, and include habitat loss, pesticide and rodenticide use, urban and agricultural development, and climate change, among others. burrowing owls. The DEIR fails to mention that local burrowing owls are currently being petitioned to be listed under CESA (Miller, 2024). The DEIR also fails to list burrowing owl as a - -5) despite the
presence of suitable habitat throughout the Project area and nearby burrows. The DEIR states uitable burrowing owl burrows potentially utilized for refugia and/or nesting were documented adjacent to the property including foraging habitat documented throughout the -12), while consultants documented California ground squirrels, whose 465
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burrows burrowing owls depend on, in and near the Project area (DEIR at 4.3-3). According to numerous publicly available databases, including iNaturalist,2 eBird,3 and the Global Biodiversity Information Facility (GBIF),4 burrowing owls have been documented in the vicinity. These owls have been found to forage up to two miles from their burrows. Therefore, the Project area should be considered burrowing owl habitat and the DEIR should assume burrowing owls use the area.
-wash,
feathers, tracks, or pellets were detected within or immediately adjacent to the Project site during -
breeding season surveys were conducted, and lack of detection of burrowing owls in just one breeding season should not lead to the assumption that burrowing owls are absent. Even if the area was not used as breeding habitat in the spring of 2023, it is possible that burrowing owls could establish or re-establish a colony in the area. In addition, it is possible that the Project area supports wintering burrowing owls. The DEIR should include both summer and winter burrowing owl surveys to determine burrowing owl presence. The DEIR fails to adequately Burrowing owls have experienced significant declines in California. The Southwestern California population, which includes burrowing owls local to the Project area, along with two other populations, was recently petitioned for listing as endangered under CESA due to substantial population declines. As the petition states:

Burrowing owls were historically abundant throughout Southwestern California.

Focused surveys from 1991-1993 estimated 263 pairs in the region (227 in the interior and 36 on the coast), a 57-85% decline since the mid-1980s Resurvey efforts from 2006-2007 estimated 150 pairs in the interior, a further 34% decline Significant breeding populations remained in western Riverside and southwestern San Bernardino counties, where further recent declines have been documented and long term persistence is unlikely. Southwestern California owls are threatened by urban development, habitat loss, degradation and fragmentation, ground squirrel eradication, coastal predator management, and disturbance. (Miller, 2024).

Any impacts to burrowing owls in the Project area, including loss of current or potential habitat and further habitat fragmentation, will push this population closer to extinction.

MM BIO-1 and MM BIO-2 require burrowing owl and nesting bird preconstruction surveys, respectively (DEIR at 4.3-14); however, these mitigation measures are insufficient and improperly deferred. Although MM BIO-1 requires a 30-day pre-construction survey for burrowing owls prior to ground-disturbing activities, a Burrowing Owl Protection and Relocation Plan would only be prepared if burrowing owls are documented on site during the surveys (DEIR 2 https://www.inaturalist.org/observations?place_id=any&subview=map&taxon_id=19975 (accessed July 25, 2024) 3 https://ebird.org/species/burowl (accessed July 25, 2024) 4 https://www.gbif.org/occurrence/map?q=burrowing%20owl (accessed July 25, 2024) 466
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at 4.3-14). Meanwhile MM BIO- -specific
measures will be prepared by a qualified biologist and implemented to prevent abandonment of -14) without providing specific measures for burrowing owls or other special-status species. At a minimum, no-work buffers of at least 300 feet should be implemented should burrowing owl or other raptor nests be identified.

The DEIR provides insufficient detail for the public and decision makers to ascertain burrowing owls and
burrowing owl habitat before the Project is approved. (See San Joaquin Raptor Rescue Center v.

County of Merced (2007) 149 Cal.App.4th 645, 670 [EIR inadequate where the success or failure formulated, and have not been subject to analysis and revi circumstances in which deferred mitigation is appropriate, the agency must meet all of the following elements: (1) practical considerations prevented the formulation of mitigation measures during the planning process; (2) the agency committed itself to developing mitigation measures in the future; (3) the agency adopted specific performance criteria prior to project approval; and (4) the EIR lists the mitigation measures to be considered, analyzed, and possibly incorporated into the mitigation plan. (See POET, LLC v. State Air Resources Bd. (2013) 218 Cal.App.4th 681, 736-
criteria.

The California Department of Fish and Wildlife recommends numerous additional mitigation measures, including the development of a Burrowing Owl Exclusion Plan as well as securing and permanently protecting lands to mitigate for loss of habitat before any activities that may impact BUOW begin (CDFW, 2012). Mitigation measures should include the permanent protection of occupied nesting and foraging habitat at a mitigation ratio of 5:1, with adequate resources set aside to protect, monitor, and adaptively manage these areas in perpetuity. The DEIR fails to adhere to best practices regarding BUOW surveys and mitigation.

Numerous other special-status bird species may also be present, including coastal California gnatcatcher (federally threatened, SSC), northern harrier (SSC), loggerhead shrike (SSC), white-tailed kite (a state fully protected species), and many others. These species were included in Table 5 within the Biological Resources Technical Report (Appendix C1) but were not discussed in the EIR itself. As mentioned above, analyses need to be provided within the main text of the EIR a report buried in an appendix is not a substitute for a good faith Vineyard Area Citizens for Responsible Growth, Inc. v City of Rancho Cordova (2007)).
burrowing owls and other special-status birds in and near the Project area, and therefore fails to comply with CEQA.

As discussed in more detail below, edge effects like noise and light from Project construction and operation will have impacts on wildlife and wildlife movement. Negative edge effects from human activity, traffic, lighting, noise, domestic pets, pollutants, and invasive weeds have been found to be biologically significant up to 300 meters (~1000 feet) away from anthropogenic features in terrestrial systems (Environmental Law Institute, 2003). This is important to consider when open space is immediately adjacent to the Project area, as birds and 467
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other wildlife have been found to be sensitive to edge effects. For example, field observations and controlled laboratory experiments have shown that traffic noise can significantly degrade habitat value for migrating songbirds (Ware et al., 2015). Subjects exposed to 55 and 61 dBA (simulated traffic noise) exhibited decreased feeding behavior and duration, as well as increased vigilance behavior (Ware et al. 2015). Such behavioral shifts increase the risk of starvation, thus decreasing survival rates. Another study found a 28% decrease in bird abundance in areas when traffic noise was present compared to when there was no traffic noise (McClure et al., 2013). The DEIR fails to
special-status birds.

B.
wildlife connectivity.
connectivity. Although the Biological Resources Technical Report (Appendix C1) acknowledges that the Project site is within a Special Linkage Area (SLA) within the Western Riverside Multispecies Habitat Conservation Plan (WS-MSHCP) that serves as a connection between the San Bernardino and San Jacinto Mountains via the San Gorgonio River (DEIR Appendix C1 at 50), there is no mention of this within the main text of the DEIR. Th Project site does not serve as a regional travel route, wildlife corridor, or wildlife crossing, the -
-18) without providing substantial evidence to support
such claims. The DEIR is misleading and insufficient.
methodology by only including such information in appendices. (San Joaquin Raptor Rescue Ctr. v. Cty. of Merced, 57 Cal. Rptr. 3d 663, 675 (Cal. Ct. App. 2007)). As the California Supreme Court has held,
quantity, it must be presented in a manner calculated to adequately inform the public and decision makers, who may not be previously familiar with the details of (Vineyard Area Citizens for Responsible Growth, Inc. v. City of Rancho Cordova (2007) 40 Cal. 4th 412, 442)
Id. (citations omitted). Sufficient information regarding wildlife connectivity must be provided within the main text of an EIR. The DEIR fails to comply with CEQA.

Both the U.S. Fish and Wildlife Service (USFWS) and California Department of Fish and Wildlife (CDFW) expressed concerns about the Project being located within the SLA, stating -Baja California border to the
-San Jacinto Connection is
where the Transverse and Peninsular Ranges converge and is in an ecological transition zone mention this.
impacts. In particular, the agencies state:
468
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sediment transportation through fluvial and aeolian riverine systems, which may further impact federally endangered Coachella Valley (Astragalus lentiginosus var. coachellae) and triple-ribbed milkvetch (Astragalus tricarinatus) and the fringe-toed lizard (Uma inornate), species identified within the CV-MSHCP with specific conservation objectives. Additionally, the Special Linkage Area within the WR-MSHCP directly connects to the CV-MSHCP Cabazon Conservation Area providing further wildlife movement and connectivity between the MSHCPs. The primary goal of the Cabazon Conservation Area is conserve lands that provide for vital sand transport functions to the core conservation areas for the CVYet the DEIR fails to mention the importance of the SLA to local and regional wildlife connectivity, fails to conduct any species movement studies in or near the Project area, and fails -status species and sand transport
functions.
o comply with CEQA the EIR
must adequately disclose the existing conditions of the site and adequately assess and mitigate Not only does the DEIR fail to acknowledge that
the Project are is located within an SLA in the WS-MSHCP within the main text, but the DEIR also fails to mention that CDFW has prioritized an adjacent stretch of the I-10 for wildlife connectivity enhancement (CDFW, 2022). The area is particularly important for mountain lions, black bears, bobcats, birds, and bats, and CDFW states that resources should be focused to improve wildlife movement at this priority barrier (CDFW, 2022). It is located within the floodplain of the San Gorgonio River immediately adjacent to an undercrossing that has the best vegetation cover to support mountain lion movement between the San Jacinto and San Bernardino mountains. In fact, it is likely the last-chance connection between the San GabrielSan Bernardino and the Eastern Peninsular Range puma populations.

Given that CDFW is calling for resources to be directed to improve an existing barrier immediately adjacent to the Project area, the DEIR should adequately consider and analyze the The proposed Project will result in
habitat loss and edge effects due to increased human presence and activities (e.g., traffic, noise, light, runoff etc.) that will further degrade this last-remaining connectivity and undermine connectivity enhancement efforts in the area. The DEIR fails to adequately assess and mitigate impacts to wildlife connectivity will be less than significant.

ACE Rank 4
(CDFW, 2019). Importantly, CDFW
also defines the area as having a high ecoregion biodiversity ranking (Figure 1), which makes 469
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movement and habitat connectivity in and near the Project area.

Figure 1: The California Department of Fish and Wildlife Area of Conservation Emphasis Terrestrial Connectivity Rankings (top) and Biodiversity Rankings (bottom) in and near the Project area. The Project is generally located within the highlighted turquoise polygon. Source: https://apps.wildlife.ca.gov/ace/. Accessed July 18, 2024.

As detailed in a 2021 Center Report (Yap et al., 2021), roads and development create barriers that lead to habitat loss and fragmentation, which harms native wildlife, plants, and people. As barriers to wildlife movement, poorly-planned development and roads can affect an lead to significant impacts on individual wildlife, populations, communities, landscapes, and ecosystem function (Brehme et al., 2013; Ceia-Hasse et al., 2018; Haddad et al., 2015; Marsh & Jaeger, 2015; Mitsch & Wilson, 1996; Trombulak & Frissell, 2000; van der Ree et al., 2011). For example, habitat fragmentation from roads and development has been shown to cause mortalities and harmful genetic isolation in mountain lions in southern California (Ernest et al., 2014; Riley et al., 2014; Vickers et al., 2015), increase local extinction risk in amphibians and reptiles (Brehme et al., 2018; Cushman, 2006), cause high levels of avoidance behavior and mortality in birds and insects (Benítez-López et al., 2010; Kantola et al., 2019; Loss et al., 2014), and alter pollinator behavior and degrade habitats (Aguilar et al., 2008; Goverde et al., 2002; Trombulak & Frissell, 2000).

Habitat loss and fragmentation also severely impacts plant communities. An 18-year study found that reconnected landscapes had nearly 14% more plant species compared to fragmented habitats, and that number is likely to continue to rise as time passes (Damschen et al., 2019). The authors conclude that efforts to preserve and enhance connectivity will pay off over the long-term (Damschen et al., 2019). In addition, connectivity is important to allow for range shifts and species migrations as climate changes (Cushman et al., 2013; Heller & Zavaleta, 2009; Krosby et al., 2018). Loss of wildlife connectivity decreases biodiversity and degrades ecosystems. It also prevents the reestablishment of native species, like bald eagles, vernal pool fairy shrimp, and valley elderberry longhorn beetles that may occur in or near the Project area.

Edge effects like noise and light from Project construction and operation will have impacts on wildlife and wildlife movement, particularly next to open space like the IBA as well as the designated critical habitat for numerous fish species, including the federally threatened North American green sturgeon (southern DPS), federally-threatened delta smelt, federally-and 470
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state-threatened Chinook salmon (Central Valley spring run ESU), federally- and stateendangered Chinook salmon (Sacramento winter run ESU), and federally-threatened steelhead (Central Valley DPS).

Negative edge effects from human activity, traffic, lighting, noise, domestic pets, pollutants, and invasive weeds have been found to be biologically significant up to 300 meters (~1000 feet) away from anthropogenic features in terrestrial systems (Environmental Law Institute, 2003). This is important to consider when open space is immediately adjacent to the Project area, as birds and other wildlife have been found to be sensitive to edge effects. For example, field observations and controlled laboratory experiments have shown that traffic noise can significantly degrade habitat value for migrating songbirds (Ware et al., 2015). Subjects exposed to 55 and 61 dBA (simulated traffic noise) exhibited decreased feeding behavior and duration, as well as increased vigilance behavior (Ware et al. 2015). Such behavioral shifts increase the risk of starvation, thus decreasing survival rates. Another study found a 28% decrease in bird abundance in areas when traffic noise was present compared to when there was no traffic noise (McClure et al., 2013). Negative edge effects of roads and development have been documented in wide-ranging predators, such as mountain lions and bobcats (Crooks, 2002; Delaney et al., 2010, 2021, p. 202; Lee et al., 2012; Riley et al., 2006; Smith et al., 2015, 2017; Vickers et al., 2015; Wang et al., 2017), as well as smaller species with poor dispersal abilities, such as song birds, small mammals, and herpetofauna (Benítez-López et al., 2010; Cushman, 2006; Kociolek et al., 2011; Slabbekoorn & Ripmeester, 2008).

The Project will result in significant impacts to wildlife connectivity due to habitat loss as well as increased traffic, noise and light pollution, and runoff. The DEIR fails to analyze these provide appropriate mitigation.

C. -
status species and wildlife connectivity.
biological resources (DEIR at 4.3-23) without providing substantial evidence to support such claims. The DEIR fails to mention other development projects in the region that would cumulatively negatively affect special-status species, sensitive habitats, and wildlife connectivity. For example, there are two important connectivity areas/critical linkages between the San Bernardino Mountains and San Jacinto. The Project area is located in one linkage, while the other linkage is located northwest of the Project area near the City of Calimesa. The linkage near Calimesa is under threat from development. Prior to filing for bankruptcy, the Oak Valley Town Center graded a large area of the critical linkage, and the Oak Valley North warehouse project is being considered within that same linkage. In addition, the Mesa Verde Specific Plan is also being considered for development within that linkage. These projects must be considered in -remaining, mostly-intact corridor for imperiled local mountain lions and other wildlife to be able to move between the San Bernardino Mountains and the San Jacinto range. Further encroachment on this connectivity area will have significant impacts on local pumas, burrowing 471
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owls, and other sensitive and special-status species and habitats. The DEIR fails to adequately The DEIR fails to consider corridor redundancy (i.e. the availability of alternative pathways for movement), which allows for improved functional connectivity and resilience.

Compared to a single pathway, multiple connections between habitat patches increase the probability of movement across landscapes by a wider variety of species, and they provide more habitat for low-mobility species while still allowing for their dispersal (Mcrae et al., 2012; Olson & Burnett, 2013; Pinto & Keitt, 2008). In addition, corridor redundancy provides resilience to uncertainty, impacts of climate change, and extreme events, like flooding or wildfires, by providing alternate escape routes or refugia for animals seeking safety (Cushman et al., 2013; Mcrae et al., 2008, 2012; Olson & Burnett, 2013; Pinto & Keitt, 2008). Ensuring a more permeable landscape will allow bighorn sheep, pumas, and other sensitive and special-status species to safely move through habitats to find the resources they need to survive.

Corridor redundancy is critical when considering the impacts of climate change on wildlife movement and habitat connectivity. Climate change is increasing stress on species and ecosystems, causing changes in distribution, phenology, physiology, vital rates, genetics, ecosystem structure and processes, and increasing species extinction risk (Warren et al., 2011). A 2016 analysis found that climate-related local extinctions are already widespread and have occurred in hundreds of species, including almost half of the 976 species surveyed (Wiens, 2016). A separate study estimated that nearly half of terrestrial non-flying threatened mammals and nearly one-quarter of threatened birds may have already been negatively impacted by climate change in at least part of their distribution (Pacifici et al., 2017). A 2016 meta-analysis reported that climate change is already impacting 82 percent of key ecological processes that form the foundation of healthy ecosystems and on which humans depend for basic needs (Scheffers et al., 2016)
body size are changing, species are moving to try to keep pace with suitable climate space, species are shifting their timing of breeding and migration, and entire ecosystems are under stress (Cahill et al., 2012; Chen et al., 2011; Maclean & Wilson, 2011; Parmesan, 2006; Parmesan & Yohe, 2003; Root et al., 2003; Warren et al., 2011).

It is widely recognized that the continuing fragmentation of habitat by humans threatens biodiversity and diminishes our (humans, plants, and animals) ability to adapt to climate change.

In a report for the International Union for Conservation of Nature (IUCN), world-renowned interconnected protected areas and other areas for biological diversity conservation are much more effective than disconnected areas in human-dominated systems, especially in the face of for ecological connectivity conservation, and begins to measure and monitor the effectiveness of (Hilty et al.,
2020).
wildlife connectivity and sensitive and special-status species.

II. THE DEIR FAILS TO ADEQUATELY ANALYZE OR MITIGATE
GREENHOUSE GAS EMISSIONS.
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A. Climate change is a catastrophic and pressing threat to California.

A strong, international scientific consensus has established that human-caused climate change is causing widespread harms to human society and natural systems, and that climate change threats are becoming increasingly dangerous. The Intergovernmental Panel on Climate Change (IPCC), the leading international scientific body for the assessment of climate change, land use as well as more than a century of burning fossil fuels have unequivocally caused global warming, with global surface temperature reaching 1.1°C above 1850-1900 in 2011- (IPCC 2023.) The increase in global surface temperature has resulted in sea level rise, increased ecosystem levels. (IPCC 2023.) T
National Climate Assessment, prepared by scientific experts and reviewed by the National Academy of Sciences and multiple federal agencies. The 2023 Assessment concluded that global warming observed over the industrial era is unequivocally caused by greenhouse gas emissions from human activities -term responses include

Immediate and aggressive greenhouse gas emissions reductions are necessary to keep warming well below 2°C above pre-industrial levels. The IPCC Sixth Assessment Report and other expert assessments have established global carbon budgets, or the total amount of carbon that can be burned while maintaining some probability of staying below a given temperature target.
beginning of 2020 are 500 GtCO2 for a 50% likelihood of limiting global warming to 1.5°C and -2030 stayed, on average, at the same level as
2019, the resulting cumulative emissions would almost exhaust the remaining carbon budget for (IPCC 2023).

2.7°C of warming, and possibly up to 3.4°C of warming, well above the level needed to avoid the worst dangers of climate change. (Climate Action Tracker, The CAT Thermometer 2023.) In California, climate change will transform our climate, resulting in increased temperature and frequency of wildfires, and a reduction in snowpack, precipitation levels, and water availability. (Turco 2023.) California has taken steps through legislation and regulation to fight climate change and reduce statewide GHG emissions. Enforcement of and compliance with these steps are essential in order to stabilize the climate and avoid catastrophic impacts to our environment.

California has a mandate under AB 1279, the California Climate Crisis Act, to achieve net zero GHG emissions by no later than 2045, and achieve and maintain net negative GHG emissions thereafter, and to ensure that by 2045, statewide GHG emissions are reduced to 85% the level in 1990. (AB 1279 2022.) In 2019, Governor Newsom issued an executive order to -19-19
(2019).) Newsom has continued to issue climate-related executive orders, such as a 2020 order requiring that, by 2035, all passenger vehicles will be zero-emission, in addition to other motor 473
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vehicle emission goals. (Executive Order N-79-20 (2020).) Through these bills and orders, California has laid a path that may allow the state to achieve tangible climate solutions, but there is still work to be done.

Although some sources of GHG emissions may seem insignificant, climate change is a problem with cumulative impacts and effects. (
Traffic Safety Admin. impact of greenhouse gas
must conduct).) One source or one small project may not appear to have a significant effect on climate change, but the combined impacts of many source climate as a whole. Therefore, project-specific GHG emission disclosure, analysis and mitigation is vital to California meeting its climate goals and maintaining our climate.

B. The DEIR fails to disclose and analyze significant greenhouse gas emissions from lost carbon storage and sequestration.

Despite the urgent dangers of the climate crisis, the DEIR fails to adequately calculate the

17.45 acres of non-native grassland, and 6.26 acres of Riversidean sage scrub (DEIR Appendix C1 Table 6). In fact, carbon emissions from destroying these habitats and degrading adjacent impacts, the DEIR must include the carbon storage and sequestration potential of these habitats in the analysis.

Lead agencies are required to quantify and disclose GHG emissions that would occur during construction, and the South Coast Air Quality Management District requires construction GHG emissions to be amortized over the life of the project, defined as 30 years. Yet the DEIR fails to comply with these requirements. When describing the emissions sources during construction equipment and the
transportation of employees and materials to and from the Project site at 4.7-19). The DEIR fails to account for carbon emissions from intact habitats that would be dug up and paved over during construction as well as the annual loss of carbon that existing habitats would have continued to sequester for 30 years if the Project were not constructed. (Yap et al., 2023), diverse native California habitats, including deserts, are important carbon sinks that should be included in carbon calculations. In California, desert landscapes consist of dunes, desert scrub, sandy soil grasslands, juniper-pinyon woodlands and rock formations. The Mojave Desert is dominated by deep-rooted shrub species, including creosote bush and white bursage, as well as many forbs, trees, grasses, and dunes. In the Project area, the landscape consists of a variety of vegetation, including desert scrub, grasses, and Riversidean sage scrub. Although the carbon storage and sequestration potential of such habitats are often overlooked, carbon in these systems is stored in the form of soil organic carbon (e.g., extensive root networks, soil microbial communities, mycorrhizae), soil inorganic carbon (e.g., calcite/caliche), and above-ground vegetation (Janzen, 2004; Meyer, 2012; Mi et al., 2008; Thomey et al., 2014; Wang et al., 2010; Zamanian et al., 2016). 474
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Any loss of nature-based carbon storage must be accounted for when assessing a the types of habitats. Although more research is needed to understand the carbon storage and sequestration potential for desert systems, it is clear that various desert habitats store and sequester different amounts of carbon. For example, desert ceanothus (Ceanothus greggii) was found to store an average of 19.7 metric tons of carbon per acre in their aboveground biomass and 3.23 metric tons of carbon per acre in their belowground biomass while accumulating 2.4 metric tons of carbon per acre per year (this does not include organic or inorganic soil carbon that can store significant amounts of carbon, see Table 1) (Bohlman et al., 2018). Shrublands, including chaparral and sage scrub, have been found to store an estimated average of 22.5 35.3 metric tons of carbon per acre (in their aboveground biomass, leaf litter, and soil) and sequester

0.45 to 1.7 metric tons of carbon per acre per year (Bohlman et al., 2018) while non-native grasslands have been found to store an estimated average of 38.4 60.3 metric tons of carbon per acre and accumulate 1.05-1.94 metric tons of carbon per acre per year (Koteen et al., 2011). creosote bajada scrub and microphyll woodland habitats in California desert as about 2.47 million and 1.23 million metric tons of carbon per acre, respectively (D. M. Allen et al., 2023).

Table 1: Carbon storage and sequestration of different habitat types in California.

Source: Yap et al., (2023).
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Given that the Project area is vegetated and filled with desert scrub, Riversidean sage scrub, and non-native grasslands, it is likely that the area stores and sequesters a significant degrading undeveloped desert habitats could release significant amounts of carbon that must be accounted for. The EIR must disclose the carbon emissions associated with the loss of currently stored carbon as well as the loss of future carbon that would have been sequestered by these habitats over the Project lifetime. The DEIR fails to adequately disclose, assess, and mitigate the C. The DEIR fails to adopt all feasible mitigation measures.

Even despite the emissions it ignores, the DEIR admits that the Project will result in enormous GHG impacts. It says that total mitigated emissions will be 22,969 MT CO2e per year, 20,000 MT above the threshold of significance. (DEIR at 4.7-20.) The mitigation measures managed to reduce emissions by only 4,000 MT. (Ibid.). The City must adopt additional mitigation, such as requiring on-site solar and electric truck infrastructure on site, unless it can demonstrate with substantial evidence and analysis that these measures are infeasible. (Los Angeles Unified Sch. Dist. v. City of Los Angeles (1997) 58 Cal.App.4th 1019, 1029.) Because the DEIR does not contain that evidence, its inadequate mitigation does not comply with CEQA. approve projects as proposed if there are feasible alternatives or feasible mitigation measures CEQA Guidelines, §§ 15092(b), 15043, 15126.4, subd. (a)(1).) i. Electrical Truck Infrastructure on Site
Emissions from heavy-duty diesel trucks are one of the most significant harmful effects related to warehouse developments. (Betancourt 2012.) The only way to fully mitigate this harm is through a rapid transition to all-electric fleets. Considering that warehouse projects are the sites of concentrated, severe diesel impacts, it is crucial that they are readily able to accommodate the transition to all-electric fleets.

The overwhelming majority of GHG emissions associated with the Project (approximately 86 percent) are associated with non-construction-related mobile sources. (DEIR at 4.7-20.) The DEIR states that there are no additional feasible measures available because the Project has no control over these emissions, relying on the fact that emissions from motor vehicles are controlled by State and federal standards. (DEIR at 4.7-21-22.) The DEIR therefore includes minimal to no mitigation measures that could effectively reduce vehicle emissions. This argument ignores what CEQA is meant to do namely, ensure that a lead agency does whatever it can to , beyond what other environmental
laws might already require. (Pub. Resources Code, §21004.) The existence of State and federal standards does not absolve the City from the duty to do everything that is within its power to mitigate the impacts of this Project. (See Save Our Capitol! v Department of Gen. Servs. (2023) 87 CA5th 655, 696 (agency could not rely on compliance with LEED and CAL-Green building standards to mitigate light and glare impacts in absence of project-specific analysis of impacts 476
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and effect of compliance); Californians for Alternatives to Toxics v Department of Food & Agric. (2005) 136 CA4th 1 (EIR failed to analyze environmental and health risks of crop disease control program and instead presumed that no adverse impacts would occur from use of pesticides in accordance with the registration and labeling program of the California Department of Pesticide Regulation). See also Ebbetts Pass Forest Watch v Department of Forestry & Fire Protection (2008) 43 C4th 936, 956 (fact that Department of Pesticide Regulation had assessed environmental effects of certain registered herbicides in general did not excuse its failure to assess effects of their use for specific timber harvesting project).) Addressing the harms from heavy-duty trucks on individual land-use projects is manifestly within the power of lead agencies. The California Attorney General is clear that compliance with laws and regulations is a lead agencies must adopt mitigation measures that go further. (AGO 2021.) Specifically, the Attorney General recommends mitigation like requiring participation in the SmartWay program, requiring tenants to use trucks from certain model years, and requiring electric truck charging. (AGO 2021.) And warehouse projects commonly do. For just one recent example, the Airport South Industrial Project requires 4.5% of heavy-duty vehicles to be zero emission by full buildout of the project. (Airport South Industrial Project DEIR at 2-14.)
The DEIR must require concrete, enforceable measures that prepare the Project to operate with an all-electric fleet, as it will soon be required to do. CARB has developed strategies to achieve 100% zero-emissions from medium and heavy-duty on-road vehicles in the State by 2045 everywhere feasible, and specifically to achieve 100% zero-emissions drayage trucks by 2035. (CARB 2022b.) The DEIR makes a start by requiring a sufficiently-sized electrical room and conduit to facilitate future installation of electrical hookups, but it does not require any actual truck charging stations to be installed when the project starts operation in 2026. (DEIR at

4.7-25.) Preparing for a fully electric drayage fleet in 2035 will require at least some charging infrastructure in place in 2026. Otherwise, the Project will lag behind the much-needed transition. To do this, the Project must include electric truck charging stations sufficient to allow every truck that serves the Project to be charged. Additionally, since the expected use of the warehouse could include refrigeration, the Project must have electric plugs for electric transport refrigeration units at every dock door. In order to account for the increased energy demand associated with these charging stations, the projected energy use of an all-electric fleet must be -site solar
panels.
ii. 100% Rooftop Solar
In order to meet its decarbonization targets, California needs to double its clean energy infrastructure. (Cart 2022, California Energy Commission 2021.) The Joint Agency SB 100 Report calls for building 2.8 GW/year of solar every year for 25 years, which is higher than the previous maximum annual build. (Joint Agency at 116.) The main issue with increasing solar energy infrastructure and capacity at the rate needed to meet these goals is the large quantity of sunny, flat land needed for solar farms to operate. (Groom 2022.) Building solar infrastructure across undeveloped land is an imperfect solution that puts ecosystems at risk, eliminates 477
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opportunities for natural carbon sinks, and is often opposed by local residents. (Groom 2022, Cart 2022, Courage 2021.)
Installing solar infrastructure on the roofs of is an excellent opportunity to use miles of flat, sunny space that would otherwise be wasted. A recent study gigawatt hours of energy from rooftop solar. (Huxley-Reicher 2023.) Warehouses cover an estimated 1 billion square feet in the Inland Empire. (Calma 2022.) The untapped potential for solar energy production is significant.

Each warehouse that is built with the capacity to meet 100% of its own energy demands via rooftop solar brings California closer to the clean energy targets we must meet in order to avoid the most devastating effects of the climate crisis. The DEIR requires that the Project either meet its energy need with onsite solar or acquire renewable energy elsewhere. (DEIR at 1-16.) Allowing the Project to merely consume renewable energy when it has the potential to reduce its impacts even further by producing that energy is a lost opportunity. The California Attorney General recommends that new warehouses are built to produce their own solar energy, and companies and municipalities are following suit. (AGO 2021.) The City of Fontana already requires that every warehouse over 400,000 square feet meet all of its energy needs from on-site rooftop solar, supporting the feasibility of this requirement. (City of Fontana at 9-73.4) This is a feasible mitigation measure, and the DEIR must require rooftop solar to meet 100 percent of the energy needs.

III. THE DEIR FAILS TO PROPERLY ANALYZE OR ADEQUATELY MITIGATE AIR QUALITY IMPACTS.

The Project will have significant air quality impacts because it will result in exceedances of the regional emissions thresholds for NOx. (DEIR at 4.2-16.) NOx is a precursor to ozone, for which the region is in extreme nonattainment. (DEIR at 4.2-10.) Ozone (commonly referred to as smog) is created by the atmospheric mixing of chemicals released from fossil fuel combustion such as NOx and sunlight. Exposure to ozone poses significant health risks, and has been linked to an increased incidence and risk of cancer, birth defects, low birth weights and premature death, in addition to a variety of cardiac and lung diseases such as asthma, COPD, stroke, and heart attack. (Laurent 2016; ALA 2024.)
Air quality is a significant environmental and public health concern in California.

Unhealthy, polluted air contributes to and exacerbates many diseases and increases mortality rates. The U.S. government has estimated that between 10 to 12 percent of total health costs can be attributed to air pollution. (VCAPCD 2003.) Air pollution and its impacts are felt most heavily by young children, the elderly, pregnant women and people with existing heart and lung disease. People living in poverty are also more susceptible to air pollution as they are less able to relocate to less polluted areas, and their homes and places of work are more likely to be located near sources of pollution, such as freeways or ports, as these areas are more affordable. (ALA 2024.) Warehouse projects are well-documented sources of air quality degradation that can create serious, negative health outcomes for surrounding communities. (Betancourt 2012, pp. 4-

5.)
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The DEIR fails to adopt commonsense, available mitigation measures, or explain why adopting such measures would be infeasible. By proposing inadequate mitigation and then of the state that public agencies should not approve projects as proposed if there are feasible alternatives or feasible mitigation measures which will avoid or substantially lessen the 15126.4, subd. (a)(1).)
A. The DEIR fails .

The DEIR concludes that the Project would not expose sensitive receptors to substantial pollutant concentrations and impacts would be less than significant. (DEIR at 4.3-39.) There are many residences within half a mile of the proposed site, and the nearest is four hundred feet away. (DEIR at Figure 4.2-1). Both the California Air Resources Board and the California Attorney General recommend siting warehouses so that their property lines are at least 1,000 ft from the property lines of the nearest sensitive receptors. (AGO 2021.) In ignoring the guidance of these agencies, the City is neglecting its duty to protect residents from the noise, traffic, and health risks that come from living next door to a warehouse. Furthermore, in reaching the conclusion of no significant impacts, the DEIR explains that the localized impacts analysis only includes on-site sources of pollution. (DEIR at 4.2-25.) This analysis completely ignores the offsite effects that will occur from increased vehicle traffic through the neighboring areas. The DEIR must explain what routes trucks will take to access the site and consider the impacts on sensitive receptors along the route. Without a proper analysis and quantification of the effects on B. The DEIR fails to adopt all feasible mitigation measures.

The EIR admits that NOx emissions during operations will exceed regional emissions thresholds. (DEIR at 4.2-16.) Because the impact is significant, the DEIR has an obligation to adopt all feasible mitigation measures. (Los Angeles Unified Sch. Dist. v. City of Los Angeles (1997) 58 Cal.App.4th 1019, 1029.)
i. 2-Minute Idling Restrictions
The DEIR adopts a so-called mitigation measure that allows trucks to idle for up to five minutes more than twice as long as the California
two-minute limit. (DEIR at 1-9, AGO 2021.) Further, a five-minute idling restriction is required by the California Airborne Toxics Control Measure. (DEIR at 4.2-6.) Therefore, it is not truly mitigation measure, it is a promise to follow the law. As the California Attorney General notes, compliance with regulations is a baseline expectation and should not be labeled a mitigation measure. (AGO 2021.) Again the DEIR replaces a recommended, feasible mitigation measure with a much weaker substitute that does not properly mitigate a significant impact. The Project must revise MM AQ-4 to require idling times to be kept under two minutes. The DEIR does not discuss nor provide substantial evidence that limiting idling to two minutes is not feasible. 479
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ii. Measures to Protect Sensitive Receptors
As discussed above, the DEIR fails to adequately consider impacts to sensitive receptors, and the determination of a less than significant impact is improper. The City must perform an adequate analysis of these impacts, and if it is determined that the impacts are significant, to mitigate accordingly. The California Attorney General recommends specific mitigation measures to protect sensitive receptors from trucking impacts. These include:

Creating physical, structural, and/or vegetative buffers that adequately prevent or substantially reduce pollutant dispersal between warehouses and any areas where sensitive receptors are likely to be present, such as homes, schools, daycare centers, hospitals, community centers, and parks.

Providing adequate areas for on-site parking, on-site queuing, and truck check-in that prevents trucks and other vehicles from parking or idling on public streets Locating warehouse dock doors and other onsite areas with significant truck traffic and noise away from sensitive receptors, e.g., placing these dock doors on the north side of the facility if sensitive receptors are adjacent to the south side of the facility.

Screening dock doors and onsite areas with significant truck traffic with physical, structural, and/or vegetative barriers that adequately prevent or substantially reduce pollutant dispersal from the facility towards sensitive receptors (AGO 2021.) IV. CONCLUSION
Thank you for the opportunity to submit comments on the Draft Environmental Impact Report for the Banning Commerce Center Project. We urge the City to revise the DEIR to adequately analyze, disclose, and mitigate significant impacts to greenhouse gas emissions, air pollution, and biological resources.

Given the possibility that the Center will be required to pursue legal remedies in order to ensure that the City complies with its legal obligations including those arising under CEQA, we would like to remind the City of its statutory duty to maintain and preserve all documents and (§ 21167.6(e); Golden Door Properties, LLC v. Superior Court (2020) 53 Cal.App.5th 733, 762-

65.) The administrative record encompasses any and all documents and communications that relate to any and all actions taken by the City
CEQA County of Orange v. Superior Court (2003) 113 Cal.App.4th 1, 8.) The administrative record further includes all correspondence, emails, and text messages sent to or received by the Ci
correspondence, emails, and text messages sent between the Ci administrative record requires that, inter alia, the City (1) suspend all data destruction policies; and (2) preserve all relevant hardware unless an exact replica of each file is made. 480
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Please add the Center to your notice list for all future updates to the Project and do not hesitate to contact us with any questions at the number or email listed below.

Sincerely,

Frances Tinney, Attorney
Tiffany Yap, DEnv/PhD, Senior Scientist
Center for Biological Diversity
1212 Broadway, Suite #800
Oakland, CA 94612
[email protected]
[email protected]
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References
(Provided via OneDrive)

Greenhouse Gas and Air Pollution References
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Chaparral and Coastal Sage Scrub Shrublands. Madroño, 65(1), 28 46.

American Lung Association (ALA), State of the Air 2024. Available at:
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Betancourt, S. & Vallianatos, M. (2012). Storing Harm: The Health and Community Impacts of Goods Movement Warehousing and Logistics. The Impact Project Policy Brief Series.

Available at: https://envhealthcenters.usc.edu/wpcontent/uploads/2016/11/StoringHarm.pdf.

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California Energy Commission, California Releases Report Charting Path to 100 Percent Clean Electricity, March 15, 2021, Available at: https://www.energy.ca.gov/news/2021- 03/california-releases-report-charting-path-100-percent-clean-electricity California Energy Commission. (2021.) SB 100 Joint Agency Report: Charting a path to a 100% Clean Energy Future. Available at: https://www.energy.ca.gov/publications/2021/2021- sb-100-joint-agency-report-achieving-100-percent-clean-electricity California Office of the Attorney General (AGO) (2021, March). Warehouse Projects: Best Practices and Mitigation Measures to Comply with the California Environmental Quality Act. Available at: https://oag.ca.gov/sites/all/files/agweb/pdfs/environment/warehousebest-practices.pdf Calma, Justine. What a billion square feet of warehouses looks like: E-commerce takes up a lot of space, The Verge, May 2, 2022, Available at:
https://www.theverge.com/23053387/billion-square-feet-warehouses-california-inlandempire-online-shopping [CARB] California Air Resources Board. (2022b.) Advanced Clean Fleets Regulation Summary.

Available at: https://ww2.arb.ca.gov/resources/fact-sheets/advanced-clean-fleetsregulation-summary CARB. (2020.) Recommended Air Pollution Emission Reduction Measures for Warehouses and Distribution Centers.
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Cart, Julia. Wrangling over renewables: Counties push back on Newsom administration usurping local control, CalMatters, August 4, 2022, Available at:
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Janzen, H. H. (2004). Carbon cycling in earth systems A soil science perspective. Agriculture, Ecosystems and Environment, 104, 399 417.

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Koteen, L. E., Baldocchi, D. D., & Harte, J. (2011). Invasion of non-native grasses causes a drop in soil carbon storage in California grasslands. Environmental Research Letters, 6.

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Sent via email
Adam B. Rush, M.A., AICP, Director
Community Development Department
99 E. Ramsey Street
Banning, CA 92220
(951) 922-3131 | Fax: (951) 922-3128
[email protected]
RE: Comments on Notice of Preparation of an Environment Impact Report for the Banning Commerce Center Project, SCH # 2022090102
Mr. Rush,
These comments are submitted on behalf of the Center for Biological Diversity (“the Center”) regarding the Notice of Preparation of an Environmental Impact Report (“EIR”) for the Banning Commerce Center Project (“the Project”). The Center urges the City to undertake a thorough and comprehensive environmental review of the Project as required under the California Environmental Quality Act (“CEQA”), prior to considering approval. By replacing open space and riparian habitat with 1.3 million square feet of warehouses, the Project will increase traffic and criteria pollutant and greenhouse gas emissions, as well as harm riparian habitat that likely supports many wetlands species. (See Notice of Preparation (hereinafter “NOP”) at 1, Initial Study (“IS”) at 24-25.) The EIR must fully disclose and analyze the Project’s potential impacts to sensitive species and habitat, air quality, greenhouse gas emissions, traffic, and water quality while thoroughly analyzing all reasonable alternatives, and then must provide effective and enforceable mitigation measures for impacts found to be significant.

The Center is a non-profit, public interest environmental organization dedicated to the protection of native species and their habitats through science, policy, and environmental law.

The Center has over 1.7 million members and online activists throughout California. The Center has worked for many years to protect imperiled plants and wildlife, open space, air and water quality, and overall quality of life for people in Banning and Riverside County.

Under CEQA, an EIR must provide decision-making bodies and the public with detailed information about the effect a proposed project is likely to have on the environment, list ways in which the significant effects of a project might be minimized, and indicate alternatives to the project. (Pub. Res. Code § 21002.2.) The proposed Project will build a high-traffic warehouse facility on 130 undeveloped acres that contain a creek and surrounding wetlands. (NOP at 1-2.) 491
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The EIR must fully disclose the impacts of this land use change, so that the public can fully understand the publicly born costs associated with the Project.

I. The EIR Must Adequately Assess and Mitigate the Project’s Impact on Biological Resources.

A. The proposed Project will have significant impacts on special-status species and species covered by the Western Riverside County Multiple Species Habitat Conservation Plan.

CEQA requires that an EIR provide decision-making bodies and the public with detailed information about the effect a proposed project is likely to have on the environment. (Pub. Res.

Code § 21061.)
The EIR must adequately assess and mitigate impacts to special-status species that are known to occur, have the potential to occur, or historically occurred in and near the Project area.

Although the IS mentions several special-status species that have been documented in the California Natural Diversity Data Base (CNDDB), the IS only looks at occurrences within one mile of the Project site. The search should be expanded to five miles, as is what is commonly provided in EIRs. In addition, occurrence data from other sources should also be consulted, including but not limited to iNaturalist, eBird, and the Global Biodiversity Information Facility (GBIF). CNDDB records are important to consider when assessing existing conditions and a Project’s potential impacts; however, the records are limited because they rely on field biologists voluntarily submitting data to the California Department of Fish and Wildlife (CDFW). CDFW must then add such data to the database, which can take time and result in delay. In addition, the database may be biased toward species that receive more survey effort. The lack of occurrence data (in CNDDB or otherwise) does not equate to a species being absent from the area, as the species may be present but evade observation. If suitable habitat is present in or near the Project area, then it must be assumed that the species occurs, has the potential to occur, or historically occurred in the area.

The IS fails to mention several key special-status species that may occur in the Project area, including but not limited to mountain lions (candidate threatened species under the California Endangered Species Act (CESA) and an MSHCP-covered species), western spadefoot toads (species of special concern (SSC) and an MSHCP-covered species), arroyo toad (SSC and an MSHCP-covered species), American badger (SSC and an MSHCP-covered species), coast range newt (SSC and an MSHCP-covered species), Aguanga kangaroo rat (an MSHCP-covered species), and likely others. The EIR should include analyses of the Project’s potential impacts to these species through extensive literature reviews and targeted species and habitat surveys conducted using CDFW and/or US Fish and Wildlife Service (USFWS) guidelines and protocols.

Movement studies should also be conducted, particularly for wide-ranging species like mountain lions, coyotes, and American badgers.

Of particular importance are local mountain lions, which are within the Southern California and Central Coast Evolutionarily Significant Unit (ESU) that is currently a candidate threatened species under CESA. There is ample scientific evidence that indicates mountain lion 492
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populations in and around the Project area are struggling to survive and that human activities and land use planning that fail to integrate adequate habitat connectivity can have adverse impacts on mountain lions. Continued habitat loss and fragmentation has led to 10 genetically isolated populations within California. There are six identified mountain lion populations in the ESU, and several are facing an “extinction vortex” due to high levels of inbreeding, low genetic diversity, and high human-caused mortality rates from car strikes on roads, depredation kills, rodenticide poisoning, poaching, disease, and increased human-caused wildfires. (Benson et al., 2016, 2019; Ernest et al., 2003, 2014; Gustafson et al., 2018, 2021; Riley et al., 2014; Vickers et al., 2015).

The primary driver of this extinction vortex is lack of connectivity. (Yap et al., 2019).

The Project area is located between the San Gabriel/San Bernardino (SGSB) population and the Eastern Peninsular Range (EPR) population, and the Santa Ana Mountains (SAM) population is nearby to the southwest. Scientists have documented physical and reproductive signs of inbreeding depression in local mountain lions (from the EPR and Santa Ana mountains, as well as the nearby Central Coast South [i.e. Santa Monica Mountains]) due to being boxed in by roads and development (Huffmeyer et al., 2021). Researchers have found that, of the California mountain lion subpopulations, the SGSB population has the smallest effective population size and the smallest area of available habitat (Dellinger et al., 2020; Gustafson et al., 2021). Scientists suggest that the SGSB population “may be approaching levels of genetic drift and inbreeding similar to the well-monitored and genetically depauperate Santa Ana and Central Coast South populations (Ernest et al., 2014; Gustafson et al., 2017; Riley et al., 2014)” (Gustafson et al., 2021), which are predicted to have a 99% chance of becoming locally extinct within 50 years if inbreeding depression continues. (Benson et al., 2019). This emphasizes the importance of protecting the remaining SGSB population, specifically through maintaining and enhancing connectivity among and between the subpopulations.

The proposed Project has the potential to amplify the barrier effects of I-10, especially given the Project’s proximity to a critical riparian corridor (San Gorgonio River) with an undercrossing that has the best vegetation cover to support mountain lion movement between the San Jacinto and San Bernardino mountains. The proposed Project could degrade this important connectivity area and drive the SGSB, EPR, and SAM puma populations towards extinction.

The EIR must consider that the Project’s impacts to mountain lions (and other specialstatus species and sensitive habitats) extend beyond its physical footprint. Ample evidence documents the effects of human activity on mountain lions. One study found that mountain lions are so fearful of humans and noise generated by humans that they will abandon the carcass of a deer and forgo the feeding opportunity just to avoid humans (Smith et al., 2017). The study concluded that even “non-consumptive forms of human disturbance may alter the ecological role of large carnivores by affecting the link between these top predators and their prey” (Smith et al., 2017). In addition, mountain lions have been found to respond fearfully upon hearing human vocalizations, avoiding the area and moving more cautiously when hearing humans (Smith et al., 2017; Suraci et al., 2019). Other studies have demonstrated that mountain lion behavior is negatively affected when exposed to other evidence of human presence, such as lighting or vehicles/traffic (Smith et al., 2015; Wang et al., 2017; Wilmers et al., 2013). Therefore, both physical and behavioral barriers drive genetic isolation, and continued land use that further fragments mountain lion habitat in the region without adequately minimizing impacts to 493
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functional connectivity, will drive pumas in the area to extinction. The Project will result in increased traffic, light, noise, etc. in an important connectivity area between the San Bernardino and San Jacinto mountains, where mountain lions are known to occur and are known to be struggling. The Project will significantly impact how mountain lions navigate the landscape by fortifying existing human-made barriers and decreasing opportunities for them to move between mountain ranges.

Yovovich et al. (2020) further documented the impacts of human activities on local mountain lions, specifically on communication and reproductive behaviors important for their survival. Males use scrapes to delineate territories as well as attract potential mates (Allen et al., 2015, 2016), and the males in the study preferred to use relatively flat areas away from human influence as scrape habitat (Yovovich et al., 2020). Similarly, when nursing females (with kittens less than 8 weeks old) shrank their home ranges to an average of 9 km2 while their young were most vulnerable, they also selected undeveloped lands away from human disturbance, opting for habitat with protective cover and sufficient water and prey availability (Yovovich et al., 2020).

The loss of adequate undisturbed communication and nursery habitat could disrupt important communication and reproductive behaviors that facilitate social structure and overall survival.

In a study that investigated the drivers of fine-scale movement decisions by pumas in fragmented landscapes in the Santa Cruz Mountains, Suraci et al. (2020) identified that mountain lions prefer larger habitat patches that are closer together and further away from buildings, and they preferred shrub over tree patches. However, mountain lions were willing to accept higher densities of anthropogenic features if target habitat patch areas were larger or the distance between patches was shorter (Suraci et al., 2020). In addition, pumas were found to travel longer distances through open habitats to access larger habitat patches, perhaps for more protective cover and/or for better hunting opportunities within the larger habitat patch areas (Suraci et al., 2020). These findings corroborate those of Smith et al. (2019), which found that pumas are able to move through partially developed habitat, though they are less likely to move through parcels with higher densities compared to parcels with less dense housing in and around the parcels. In fact, puma avoidance increased sharply as housing density increased up to 41 houses/km2, after which avoidance remained high. Although these studies demonstrate that mountain lions have some tolerance of human presence, they mostly highlight the negative impacts of increased human use/density on the movement and survival of mountain lions and the importance of habitat connectivity among large, intact, heterogeneous habitat patches.

In addition, Riley et al. (2021) found that, although pumas had some flexibility to navigate urbanized landscapes, they spent more than 95% of their time away from developed areas and actively avoided open areas like golf courses, cemeteries, and other altered landscaped spaces. Mountain lions consistently selected native vegetation types with dense cover, like chaparral, riparian woodland, and coastal sage scrub, with shrublands being their preferred habitat. This highlights the importance of intact and connected natural heterogeneous landscapes to the long-term health and persistence of constrained mountain lion populations. The authors state, “An important requirement for the effective conservation of at‐risk mountain lion populations in southern California is preserving and enhancing connectivity between larger natural areas.” (Riley et al., 2021).
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Mountain lions are a key indicator species of wildlife connectivity and healthy ecosystems. As the last remaining wide-ranging top predator in the region, the ability to move through large swaths of interconnected habitat is vital for genetic connectivity and their longterm survival. In addition, impacts to mountain lions in the region could have severe ecological consequences; loss of the ecosystem engineer could have ripple effects on other plant and animal species, potentially leading to a decrease in biodiversity and diminished overall ecosystem function. Many scavengers, including California condors, kit foxes, raptors, and numerous insects, would lose a reliable food source (Barry et al., 2019; Ruth & Elbroch, 2014). Fish, birds, amphibians, reptiles, rare native plants, and butterflies would potentially diminish if this apex predator were lost (Ripple et al., 2014; Ripple & Beschta, 2006, 2008). In fact, a recent literature review found that mountain lions are important ecosystem engineers and have been documented to have ecological interactions with at least 485 plant and animal species (Labarge et al., 2022).

Adequate assessment and mitigation of the Project’s impacts to mountain lions is necessary to ensure their long-term survival as well as the long-term health of the area’s biodiversity and ecosystems.

Wildlife connectivity in this region is paramount for the survival of the Southern California mountain lions. Any project that does not adequately assess and address impacts to mountain lions and wildlife connectivity could lead to the extirpation of local mountain lions and severe loss of biodiversity and ecosystem function in the region. Further destruction of wildlife connectivity in the area will push local mountain lions closer towards extinction. See further discussion below regarding the DEIR’s requirement to adequately describe, assess, and mitigate impacts to wildlife movement and connectivity.

B. The proposed Project will have significant impacts on wildlife movement and habitat connectivity.

To comply with CEQA, the EIR must adequately disclose the existing conditions of the site and adequately assess and mitigate the Project’s impacts to wildlife connectivity. The Project is located within an area that has been identified as a “Special linkage area in the MSHCP” (the San Gorgonio River/San Bernardino-San-Jacinto Mountains Linkage)1, a “Conservation Planning Linkage” by CDFW,
2 and a south coast missing linkage (San Bernardino-San Jacinto Connection) that is critical for connectivity between coastal and desert ecoregions (SC Wildlands, 2008). In addition, the adjacent segment of I-10 has been identified by CDFW as a “Priority Barrier to Habitat Connectivity,” particularly for mountain lion, black bear, and bobcat, where financial resources should be focused to improve wildlife movement (CDFW, 2020). It is located within the floodplain of the San Gorgonio River immediately adjacent to an undercrossing that has the best vegetation cover to support mountain lion movement between the San Jacinto and San Bernardino mountains. In fact, it is likely the last-chance connection between the SGSB and EPR puma populations. The proposed Project will result in habitat loss and edge effects due to increased human presence and activities (e.g., traffic, noise, light, etc.) 1 See Cores and Linkages within the MSHCP Conservation Area. Available at https://rctlma.org/Portals/0/mshcp/volume1/sec3.html#3.2.3 (Accessed September 28, 2022). 2 See CDFW Areas of Conservation Emphasis Version 3.0. Available at https://apps.wildlife.ca.gov/ace/ (Accessed September 28, 2022).
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that will further degrade this last-remaining connectivity and drive local puma populations towards extinction while harming other wildlife.

As detailed in a 2021 Center Report (Yap et al., 2021), roads and development create barriers that lead to habitat loss and fragmentation, which harms native wildlife, plants, and people. As barriers to wildlife movement, poorly-planned development and roads can affect an animal’s behavior, movement patterns, reproductive success, and physiological state, which can lead to significant impacts on individual wildlife, populations, communities, landscapes, and ecosystem function (Brehme et al., 2013; Ceia-Hasse et al., 2018; Haddad et al., 2015; Marsh & Jaeger, 2015; Mitsch & Wilson, 1996; Trombulak & Frissell, 2000; van der Ree et al., 2011). For example, habitat fragmentation from roads and development has been shown to cause mortalities and harmful genetic isolation in mountain lions in Southern California and along the Central Coast (Ernest et al., 2014; Gustafson et al., 2018, 2021; Riley et al., 2014; Saremi et al., 2019; Vickers et al., 2015). Habitat fragmentation has also been found to increase local extinction risk in amphibians and reptiles (Brehme et al., 2018; Cushman, 2006; Delaney et al., 2021), cause high levels of avoidance behavior and mortality in birds and insects (Benítez-López et al., 2010; Kantola et al., 2019; Loss et al., 2014), and alter pollinator behavior and degrade habitats (Aguilar et al., 2008; Goverde et al., 2002; Trombulak & Frissell, 2000).

Habitat fragmentation also severely impacts plant communities. An 18-year study found that reconnected landscapes had nearly 14% more plant species compared to fragmented habitats, and that number is likely to continue to rise as time passes (Damschen et al., 2019). The authors conclude that efforts to preserve and enhance connectivity will pay off over the longterm (Damschen et al., 2019). In addition, connectivity between high quality habitat areas in heterogeneous landscapes is important to allow for range shifts and species migrations as climate changes (Cushman et al., 2013; Heller & Zavaleta, 2009; Krosby et al., 2018). Loss of wildlife connectivity decreases biodiversity and degrades ecosystems while reducing climate change resilience.

Edge effects of development in and adjacent to critical linkage areas, like the proposed Project, will likely impact key, wide-ranging predators, such as mountain lions and bobcats (Crooks, 2002; Delaney et al., 2010; Lee et al., 2012; Riley et al., 2006; Smith et al., 2015, 2017; Vickers et al., 2015; Wang et al., 2017), as well as smaller species with poor dispersal abilities, such as song birds, small mammals, and herpetofauna (Benítez-López et al., 2010; Cushman, 2006; Delaney et al., 2010; Gray, 2017; Kociolek et al., 2011; Slabbekoorn & Ripmeester, 2008).

Limiting movement and dispersal can affect species’ ability to find food, shelter, mates, and refugia after disturbances like fires or floods. Individuals can die off, populations can become isolated, sensitive species can become locally extinct, and important ecological processes like plant pollination and nutrient cycling can be lost. Negative edge effects from human activity, such as traffic, lighting, noise, domestic pets, pollutants, invasive weeds, and increased fire frequency, have been found to be biologically significant up to 300 meters (~1000 feet) away from anthropogenic features in terrestrial systems (Environmental Law Institute, 2003).

For example, field observations and controlled laboratory experiments have shown that traffic noise can significantly degrade habitat value for migrating songbirds (Ware et al., 2015).

Subjects exposed to 55 and 61 dBA (simulated traffic noise) exhibited decreased feeding 496
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behavior and duration, as well as increased vigilance behavior (Ware et al. 2015). Such behavioral shifts increase the risk of starvation, thus decreasing survival rates. A recent study also highlighted the detrimental impacts of siting development near open space. The study noted that “Anthropogenic noise 3 and 10 dB above natural sound levels . . . has documented effects on wildlife species richness, abundance, reproductive success, behavior, and physiology” (Buxton et al., 2017). The study further noted that “there is evidence of impacts across a wide range of species [] regardless of hearing sensitivity, including direct effects on invertebrates that lack ears and indirect effects on plants and entire ecological communities (e.g., reduced seedling recruitment due to altered behavior of seed distributors)” (Buxton et al. 2017). Moreover, human transportation networks and development resulted in high noise exceedances in protected areas (Buxton et al. 2017).

In addition, preliminary results from studies underway by researchers at UC Davis and University of Southern California, as well as those by other researchers, suggest that the light, noise, and other aspects of highways can have negative impacts on wildlife numbers and diversity near the highways (Shilling, 2020; Vickers, 2020). The researchers found a significant difference between species richness and species type (mammals), with lower richness and fewer species at crossing structures compared to background areas 1 km away from the roads (Shilling, 2020). They also found that as traffic noises surpassed 60 dBC, the number of visits by small to large mammals decreased, and most of the species in their study avoid traffic noise (Shilling, 2020). The proposed Project would increase human activity and traffic, thereby increasing noise, light, and other edge effects in this important connectivity area. The EIR must adequately assess and mitigate the proposed Project’s impacts, including its edge effects, on wildlife connectivity.

C. The proposed Project will have significant impacts on riparian wetland habitats.

The EIR must adequately assess the Project’s impacts to wetland habitats, including perennial and ephemeral riparian habitat that occur in and near the Project area. (CEQA Guidelines, Appendix G(IV)(c).) The Project area is located within the San Gorgonio River’s 100-year floodplain, and as mentioned in the IS, “According to the USFWS National Wetlands Inventory, the Project site is transected by Riverine habitat that is intermittent and potentially seasonally flooded” (IS at 24). Although the IS states that “Project development would potentially have significant impacts on sensitive natural communities and/or riparian habitats” (IS at 25), it then immediately contradicts itself, concluding that the Project “does not contain any wetlands” and therefore “would not adversely affect state or federally protected wetlands” (IS at 25).

A strong presumption in favor of studying an environmental impact is built into CEQA.

This presumption is reflected in what is known as the "fair argument" standard, under which an agency must study an impact in an EIR whenever substantial evidence in the record supports a fair argument that a project may have a significant effect on the environment. (Quail Botanical Gardens Found., Inc. v City of Encinitas (1994) 29 Cal.App.4th 1597, 1602; Friends of "B" St. v City of Hayward (1980) 106 Cal.App.3d 988, 1002.)
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There is substantial evidence sufficient to support a fair argument that impacts to ephemeral waterways could occur and thus should be studied in the EIR. USFWS has identified the Project site as riverine habitat, which includes perennial and ephemeral riparian habitat and extends to the outer limits of where any stream braiding occurs. (IS at 24, USFWS 1992.) Development may impact this habitat and thus the effects of such development must be studied in the EIR.

Riparian ecosystems have long been recognized as biodiversity hotspots performing important ecological functions in a transition zone between freshwater systems and upland habitats. Many species that rely on these aquatic habitats also rely on the adjacent upland habitats (e.g., riparian areas along streams, floodplains, and habitat adjacent to wetlands). In fact, 60% of amphibian species, 16% of reptiles, 34% of birds and 12% of mammals in the Pacific Coast ecoregion depend on riparian-stream systems for survival (Kelsey and West 1998). While many species use riparian areas as live-in habitat, wide-ranging species like mountain lions, bears, and bobcats often use riparian areas as migration corridors or foraging habitat (Dickson et al, 2005; Hilty & Merenlender, 2004; Jennings & Lewison, 2013; Jennings & Zeller, 2017).

Recent scientific literature states that “[i]n many intermittent streams, remnant pools persist after flow ceases and provide refuge for aquatic organisms” (Bogan et al., 2019). The researchers found that remnant pools at nearby Coyote Creek “supported a full assemblage of native fishes and numerous imperiled taxa, including California red‐legged frogs (CRLF) and California floater mussels,” almost all of which were absent from artificially perennial and urbanized reaches of Coyote Creek (Bogan et al., 2019). The researchers concluded:

Remnant pools in intermittent streams should be a focus of conservation efforts in regions with a Mediterranean climate, especially during extreme droughts. Native fauna adapted to harsh intermittent flow regimes can thrive in these habitats, whereas non‐native taxa may fare poorly. Furthermore, remnant pools supported by deep groundwater sources, such as those along geological faults, may provide both ecological refuge and evolutionary refugia for freshwater biota. (Bogan et al., 2019) Hydroperiod diversity is important for native amphibian population stability. Intermittent and ephemeral habitats are important refugia from invasive fish and American bullfrogs that outcompete and prey upon native amphibians in permanent waterbodies. They may also be important refuge and recovery sites for native amphibian species after extreme drought. Many native amphibian species that occur or have the potential to occur in or near the Project area, like western spadefoot toads, arroyo toads, and coast range newts, are adapted to successfully reproduce in seasonally-drying wetlands, including intermittent streams and vernal pools. But during dry years some species may go to permanent waterbodies to breed while species with long-lived adult forms may be able to recover quickly from a skipped breeding season. Although amphibian population declines due to drought have been observed, these adaptations make them more resilient than invasive species to rebound and recover (Moss et al., 2021). In fact, researchers have found that invasive fish and bullfrogs were extirpated from several permanent ponds that had completely dried out during extreme drought, which, once refilled with water, 498
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opened up new sites for native species to re-colonize (Moss et al., 2021). This suggests that conserving intermittent and ephemeral waterways is vital for native amphibians to persist, particularly in areas where invasive species may occur or have the potential to occur. As climate change intensifies, preservation of connected habitats with diverse hydroperiods is vital for the persistence and metapopulation dynamics of native amphibians. The EIR must adequately assess and mitigate the Project’s impacts to perennial and ephemeral waters and the wildlife plants that they support.

With the driest 22-year period in 1,200 years in the western US and drought conditions that will likely continue (Williams et al., 2022) climate change refugia and resilience provided by ecosystems like riparian areas will be ever more critical for species survival and ecosystem health. As discussed in a 2021 Center report (Yap et al., 2021):

Climate change is worsening ecosystem stress and species extinction risk (Trisos et al., 2020). Increasing variability and extremes in temperature, wind, and precipitation are all products of a warming climate, leaving species struggling to adapt. As a result, species’ genes are changing, physiological and physical features such as body size are changing, ranges are shifting as species try to maintain a suitable climate space, and numerous species are expressing new breeding and migration behaviors (Scheffers et al., 2016).

For example, some plants are budding and flowering earlier, some marine and freshwater fishes are spawning either earlier or later, and some species with temperature-dependent sex determination are experiencing shifts in sex ratios.

Climate-related local extinctions have already occurred in hundreds of plant and animal species (Wiens, 2016). And one study found that terrestrial bird and mammal populations that are experiencing greater climate warming are more likely to be experiencing greater population declines (Spooner et al., 2018).

Reportedly, climate change is already impacting 82% of key ecological processes that form the foundation of healthy ecosystems (Scheffers et al., 2016). If climate change goes unabated, more than one-third of all plant and animal species could become extinct in the next 50 years (Román-Palacios & Wiens, 2020).

Wildlife connectivity is critical for biodiversity resilience and climate change adaptability. A permeable landscape that has multiple pathways or linkages between habitat patches allows a wide variety of species to adjust to shifts in resource availability (Mcrae et al., 2012; Olson & Burnett, 2013; Pinto & Keitt, 2008). For smaller species with poor dispersal abilities, like San Francisco garter snakes, CRLF and San Bernardino kangaroo rats, multiple linkages can provide habitat while still allowing for their dispersal.

Multiple connections also help populations persist after extreme events worsened by climate change. During floods, landslides or wildfires, these pathways provide escape routes or refugia for animals seeking safety (Cushman et al., 2013; Mcrae et al., 2008; Olson & Burnett, 2013). Such events can cause local extinctions in small, isolated populations.
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Prior to roads and development severely fragmenting and degrading habitats, a species could persist because individuals from neighboring populations would be able to recolonize an area that experiences a local extinction. But without adequate connectivity, recolonization and species persistence are improbable.

California cannot afford to lose more riparian corridors. It is estimated that 90-95% of historic riparian habitat in the state has been lost (Bowler, 1989; Riparian Habitat Joint Venture, 2009). Using 2002 land cover data from CAL FIRE, the Riparian Habitat Joint Venture estimated that riparian vegetation makes up less than 0.5% of California’s total land area at about 360,000 acres (Riparian Habitat Joint Venture, 2004). This is alarming because riparian habitats perform a number of biological and physical functions that benefit wildlife, plants, and humans, and loss of what little is left will have severe, harmful impacts on special-status species, overall biodiversity, wildlife connectivity, and ecosystem function.

II. The EIR Should Carefully Assess and Mitigate the Project’s Impacts on Air Quality
The EIR must also carefully consider the effects of a project of this scale on air quality for local communities. Warehouse projects are well-documented sources of air quality degradation that can create serious, negative health outcomes for communities. (Betancourt et al. 4-5.) Particulate emissions from diesel vehicles that carry freight to and from warehouses contribute to “cardiovascular problems, cancer, asthma, decreased lung function and capacity, reproductive health problems, and premature death.” (Id. at 5.) Warehouses with refrigeration, called “cold storage” warehouses, produce even more air pollution and greenhouse gas emissions. (CARB 2022.) Refrigerated goods must be kept in cold environments to maintain quality, which requires that cold storage warehouses “continually consume[] energy, contrary to other type of warehouses.” (Dimitrov 2022.) With “cold storage” warehouses, trucks and trailers visiting the Project site are typically equipped with transport refrigeration units (TRU), internal refrigeration systems powered by diesel. TRUs on trucks and trailers can emit large quantities of diesel exhaust while operating within the Project site. (Wu 2013; Tassou 2009.)3 The surrounding area is a mix of open space, residential, and land belonging to the Morongo Band of Mission Indians. High-density affordable housing projects border the western and eastern boundaries of the Project site, with a large residential neighborhood to the west of the site. (Initial Study at 2, 20-21.) Hoffer Elementary School is within 1,500 feet of the Project site. (Ibid.) The Interstate 10 freeway runs along the southern edge of the Project.

A. The Initial Study Omits a Key Threshold of Significance The Initial Study omits a key threshold of significance from the EIR, which has the potential to obscure project impacts. The Initial Study draws its thresholds of significance from 3 This Project proposes to construct up to 1.3 million square feet (sf) of “speculative industrial” warehousing uses.

The NOP and IS fail to mention whether the Project will include refrigerated uses, which significantly drive up the air quality and greenhouse gas impacts. The EIR must disclose whether the Project will include refrigerated uses and then analyze the full slate of environmental impacts associated with those uses. 500
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“Appendix G”—the checklist of potentially significant environmental impacts included as an appendix to the CEQA Guidelines. (Initial Study at 18.) Appendix G contains five separate checklist questions regarding a proposed project’s air quality impacts. The Initial Study considers four air quality-related questions from Appendix G as its thresholds of significance, to define the scope of impacts. (Ibid.) But inexplicably, the Initial Study omits checklist question 2 (whether the Project would “[v]iolate any air quality standard or contribute substantially to an existing or projected air quality violation”). (Guidelines, App. G., subd. III(b).) This omission potentially forecloses consideration of the Project’s full impacts.

Although lead agencies have discretion in their choice of significance thresholds, they may not choose or apply them in a manner that downplays or overlooks potentially significant impacts. (See King & Gardiner Farms, LLC v. County of Kern (2020) 45 Cal.App.5th 814, 892- 894.) Given that the Project will have a potentially significant air quality impact by every metric identified, the EIR should consider whether the Project would violate any air quality standard or contribute substantially to an existing or projected air quality violation.

B. The EIR Must Study Cumulative Impacts and Conduct a Health Risk Assessment.

This community is already highly burdened by pollution. According to CalEnviroScreen

4.0, CalEPA’s screening tool that identifies the California communities most affected by pollution and where people are often especially vulnerable to pollution’s effects, the Project’s census tract is more polluted than 90% of the state’s census tracts, making it among the most polluted areas in the state. (OEHHA 2021.) Residents here suffer from some of the highest exposures statewide to ozone and lead in housing (97th and 91st percentiles, respectively). (Ibid.) The community also currently ranks 81st in the prevalence of poor traffic. Living near freeways already subjects residents to higher rates of asthma, heart attacks, strokes, lung cancer, and preterm births. (Barboza 2017.)4 Approving warehouse development here, which carries increased rates of asthma and cancer, would compound the community’s existing environmental health problems. (Esquivel 2019.) The EIR must pay careful attention to the cumulative impacts of additional air pollution in an area with a high existing pollution burden when drafting the EIR. An EIR must discuss the “cumulative impacts of a project when the project’s incremental effect is cumulatively considerable[.]” (14 CCR § 15130(a).) Even if a project only represents a relatively small contribution to a condition like poor air quality, the EIR must still assess the cumulative impacts of Project completion on unacceptable environmental conditions. (See Kings County Farm Bureau v. City of Hanford (1990) 221 Cal.App.3d 693, 728.) The Project’s effects on air quality should be considered in the context of existing industrial uses and pollution burdens on neighboring properties.
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4 https://www.latimes.com/projects/la-me-freeway-pollution/ 501
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C. The County Must Design the Project to Avoid These Impacts and Adopt Best Practice Mitigation Measures.

This Project will certainly add to and compound the environmental and health problems of people living in the area. The compounded risk of further contributing to air quality degradation in an area already so burdened should be carefully considered in the EIR and stringent mitigation measures should be adopted. (See California Office of Environmental Health Hazard Assessment.) Should the Project proceed, the Project should be designed to avoid serious harm to adjacent residents.

The California Office of the Attorney General has published a document entitled “Warehouse Projects: Best Practices and Mitigation Measures to Comply with the California Environmental Quality Act” to help lead agencies design warehouse projects to minimize and mitigate environmental harms. (AGO 2021.) It contains the following best practices for siting and designing warehouse facilities, along with recommended mitigation measures (not repeated here) that should be incorporated into the Project:
• Per CARB guidance, siting warehouse facilities so that their property lines are at least 1,000 feet from the property lines of the nearest sensitive receptors. • Creating physical, structural, and/or vegetative buffers that adequately prevent or substantially reduce pollutant dispersal between warehouses and any areas where sensitive receptors are likely to be present, such as homes, schools, daycare centers, hospitals, community centers, and parks.
• Providing adequate areas for on-site parking, on-site queuing, and truck check-in that prevent trucks and other vehicles from parking or idling on public streets. • Placing facility entry and exit points from the public street away from sensitive receptors, e.g., placing these points on the north side of the facility if sensitive receptors are adjacent to the south side of the facility. • Locating warehouse dock doors and other onsite areas with significant truck traffic and noise away from sensitive receptors, e.g., placing these dock doors on the north side of the facility if sensitive receptors are adjacent to the south side of the facility. • Screening dock doors and onsite areas with significant truck traffic with physical, structural, and/or vegetative barriers that adequately prevent or substantially reduce pollutant dispersal from the facility towards sensitive receptors. • Posting signs clearly showing the designated entry and exit points from the public street for trucks and service vehicles.
• Posting signs indicating that all parking and maintenance of trucks must be conducted within designated on-site areas and not within the surrounding community or public streets.

The effects the Project will have on the air quality in an area with a sizeable existing pollution burden must be fully and carefully considered in the EIR, and mitigation measures must be clearly described and adopted should this Project move forward. 502
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III. The EIR Should Assess and Mitigate the Impacts of the Project on Climate Change-Causing Greenhouse Gas Emissions
In addition to assessing the impact on traffic, the EIR should carefully consider the project’s effects on statewide goals for reducing greenhouse gas emissions. Where a project will generate greenhouse gas emissions either directly or indirectly, the EIR should describe the expected increase in emissions and discuss mitigation measures. (Sierra Club v. Gilroy City Council (1990) 222 Cal.App.3d 30, 41; Cleveland National Forest Foundation v. San Diego Association of Governments (2017) 17 Cal.App.5th 413, 430-34; Pub. Res. Code §§ 21002; 21083.5.) Major warehouse projects have the documented effect of substantially increasing construction, operation, and vehicle-related emissions, all of which produce climate changecausing greenhouse gases. (Betancourt et al. at 4-5; USEPA 2022.) The EIR must carefully and completely address both the impacts on emissions from construction and operation of the plant, and those from vehicle miles traveled by trucks transporting goods to and from the warehouse and commuting employees.

To mitigate the known environmental harms of warehouse projects, the EIR should identify specific measures that the developers will take to minimize any increase in greenhouse gas emissions caused by the Project. These measures should include sustainability measures, like ensuring roofs are white to minimize the need for air conditioning and including rooftop solar for energy production. (AGO 2021; Betancourt et al. at 6.) Moreover, the Project should incorporate features to minimize greenhouse gas emissions, like zero-emissions off-road vehicles and construction equipment, electric vehicle charging stations, and a plan to adopt zero-emissions heavy trucks. (AGO 2021; id.) Mitigation measures must be “fully enforceable through permit conditions, agreements, or other measures” so “that feasible mitigation measures will actually be implemented as a condition of development.” (Federation of Hillside & Canyon Ass’ns v. City of Los Angeles (2000) 83 Cal.App.4th 1252, 1261.) Mitigation measures should be designed so benefits are realized by the local community and could include funding zero emission public transit, solar installations on residential homes, or providing publicly accessible electric vehicle charging infrastructure.

Finally, the EIR must fully describe the greenhouse gases the warehouse’s construction will produce and outline all feasible mitigation measures that will be taken to address them.

Construction of such a large warehouse will require substantial quantities of construction materials, such as concrete. Cement and concrete manufacture is extremely energy intensive and produces a large amount of greenhouse gas emissions. (Masanet et al. at 89.) Concrete manufacturing accounts for roughly 3 percent of California’s greenhouse gas emissions. (Id.) This and other sources of greenhouse gas and particulate emissions—such as dust and emissions from heavy machinery used during construction—should be thoroughly examined and mitigated in the EIR.

IV. The EIR Must Adequately Assess and Mitigate the Project’s Impact on Local Traffic.

CEQA requires that the EIR fully assess the impact the construction of 1.3 million square feet of high cube warehouse facilities will have on transportation and traffic. (Pub. Res. Code § 503
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21099; NOP at 2.) During construction, all the materials, heavy machinery, and construction workers will need to drive through the community daily, potentially creating disruptive and unpredictable traffic patterns during construction. After completion, the Project will bring additional traffic to the area from trucks picking up goods and employees commuting to work in the warehouses. (Betancourt et al. at 4; Initial Study at 19, 61.) Trucks serving facilities often idle on public streets and clog local roads when warehouses are at capacity, creating traffic congestion and hazards to local drivers who depend on these roads. (See Betancourt at 5.) The City must assess how the traffic increases associated with this project will affect the species in the surrounding area. (Pub. Res. Code § 21099.) As discussed in later sections, traffic congestion can hurt air quality and harm habitat through generating waste that is carried into waterways through stormwater runoff. The potential harms of increased runoff should be carefully considered and mitigated in the EIR. Moreover, even if substantial increased congestion would not result from the Project, the EIR should assess the project’s impact on Vehicle Miles Traveled. (14 CCR § 15064.3(a).) Should the project substantially increase Vehicle Miles Traveled, the EIR should adopt reasonable mitigation measures, such as requiring the use of highly efficient or electric trucks to transport goods.

After assessing the Project’s impact on transportation and traffic, the EIR must fully comply with CEQA’s mandates for mitigating the harms associated with increased traffic in the area. Mitigation of a project’s environmental impacts is one of the “most important” functions of CEQA and it is the “policy of the state that public agencies should not approve projects as proposed if there are feasible alternatives or feasible mitigation measures which will avoid or substantially lessen the significant environmental effects of such projects.” (Sierra Club v. Gilroy City Council (1990) 222 Cal.App.3d 30, 41; Pub. Res. Code § 21002.) Particular care should be taken to ensure that the traffic impacts of this project are fully assessed and mitigated, because there are already many warehouses drawing trucks to the area.

The Project should be designed to avoid congestion caused by truck staging on local roads and limit the number of trucks travelling during normal commuting hours to avoid serious harm to locals who rely on nearby roads. Moreover, the City must ensure the EIR includes mitigation for the traffic that construction of such a large project would likely cause.

V. The EIR Should Carefully Assess and Mitigate the Impacts of the Project on Water Quality
The EIR must adequately assess the Project’s effects on Hathaway creek, any surrounding wetlands and the riverine habitat located on the property, and connected bodies of water. (Initial Study at 24-25.) The United States Fish and Wildlife Survey National Wetlands Inventory identifies the Project site as transected by riverine habitat that can seasonally flood. (See Initial Study at 24.) This inquiry should detail at a minimum the municipal control over activities on privately held land, associated impacts on sensitive biological resources, habitat connectivity, and the efficacy of proposed mitigation measures.

First, mitigation measures for preserving the on-site riverine habitat should include adequate buffer zones between built features (like roads and buildings) and the habitat. The 504
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terrestrial land surrounding riverine habitat is essential for both preserving water quality by serving as a water filter and providing upland habitat for wetland-dwelling species. (Semlitsch & Bodie at 1220.) To ensure that riverine habitat and water quality are preserved, the EIR should ensure there are sufficient buffer zones surrounding Hathaway Creek and its wetlands to maintain the quality of the creek and surrounding wetlands.

Moreover, the EIR must detail long-term management plans for the creek and wetlands, as well as measures that will be taken to protect the creek from the long-term effects of operating warehouses nearby. Notably, there is evidence that roadway runoff produced by the vehicles that will be picking up and dropping off goods significantly contributes to water pollution. (See Nixon & Saphores at 1.) Sediments from construction and road erosion, oils from car operation, heavy metals from exhaust, and anti-freeze and other chemicals all can be carried into streams by stormwater runoff. (See Nixon & Saphores at 1-2; Shore Stewards.) Additionally, the construction of the warehouses on the property will likely leave behind significant quantities of loose sediment from grading and excavation that can runoff into water and significantly harm wetlands by increasing turbidity, which harms plant growth and destroys habitat for fish species. (See id. at 1-2; Shore Stewards.) Spoils from grading must be properly disposed of, and adequate erosion control and spill prevention measures should be implemented to avoid impacts to adjacent wetlands.

The EIR should fully detail the potential risks to water quality operation and construction of the warehouses may cause and adopt binding mitigation measures to minimize these harms.

VI. The EIR Must Thoroughly Consider Reasonable and Prudent Alternatives The EIR must present and consider “a range of reasonable alternatives . . . which would feasibly attain most of the basic objectives of the project” in order to facilitate “informed decision-making and public participation.” (14 CCR § 15126.6(a).) The EIR’s alternative analysis should assess the proposed size and location of the Project. The EIR should also assess whether there is sufficient need for another warehouse in this region. Importantly, even if alternatives are costly or would interfere with achievement of some of the project goals, they should be considered if they can substantially reduce the environmental harms of the project. (14 CCR §15126.6(b).) Moreover, the City should avoid adopting overly narrow project objectives to attempt to avoid a broad analysis of alternative mechanisms for achieving the Project’s purpose. (North Coast Rivers Alliance v. Kawamura (2015) 243 Cal.4th 647, 669.) VII. Other Impacts That Must Be Analyzed in the EIR
In addition to those issues raised above, the EIR must also thoroughly address a variety of other related issues. For example, the EIR must fully disclose and analyze the Project’s impacts on aesthetics and noise, and discuss alternatives and effective mitigation measures to avoid, reduce, and mitigate these impacts. Additionally, it is essential that the EIR consider the cumulative effects of the Project, such as air quality and traffic, in light of the many existing warehouses nearby. (See IS at 9-11.)
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VIII. Conclusion
Thank you for the opportunity to submit comments on the Notice of Preparation of an Environmental Impact Report for the Banning Commerce Center. The environmental effects of the Project will include direct and indirect impacts on biological resources, air quality, climate change, traffic, and water quality. Evaluation of each of these impacts as well as analysis of a reasonable range of alternatives and mitigation measures must be included in the EIR.

Given the possibility that the Center will be required to pursue legal remedies to ensure that the City complies with its legal obligations including those arising under CEQA, we would like to remind the City of its statutory duty to maintain and preserve all documents and communications that may constitute part of the “administrative record” of this proceeding. (§ 21167.6(e); Golden Door Properties, LLC v. Superior Court (2020) 53 Cal.App.5th 733, 762-

65.) The administrative record encompasses any and all documents and communications that relate to any and all actions taken by the City with respect to the Project, and includes “pretty much everything that ever came near a proposed [project] or [] the agency’s compliance with CEQA . . . .” (County of Orange v. Superior Court (2003) 113 Cal.App.4th 1, 8.) The administrative record further includes all correspondence, emails, and text messages sent to or received by the City’s representatives or employees, that relate to the Project, including any correspondence, emails, and text messages sent between the City’s representatives or employees and the Applicant’s representatives or employees. Maintenance and preservation of the administrative record requires that, inter alia, the City (1) suspend all data destruction policies; and (2) preserve all relevant hardware unless an exact replica of each file is made.

Please add the Center to your notice list for all future updates to the Project and do not hesitate to contact the Center with any questions at the number or email listed below.

Sincerely,
Hallie Kutak
Staff Attorney | Senior Conservation Advocate
Center for Biological Diversity
1212 Broadway, Suite #800
Oakland, CA 94612
[email protected]
Tel: (510) 844-7117
506
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Exhibit 2
516
List of California Natural Diversity Database (CNDDB) records of sensitive plant and animal species in and near the Project area (within the Cabazon quadrant). This is not a comprehensive list of sensitive species that occur, potentially occur, or historically occurred in and/or near the Project area.

Type Scientific_Name Common_Name
Animals - Amphibians Rana muscosa
southern mountain yellowlegged frog
Animals - Amphibians Spea hammondii western spadefoot
Animals - Birds Accipiter cooperii Coopers hawk
Animals - Birds Accipiter striatus sharp-shinned hawk
Animals - Birds Aquila chrysaetos golden eagle
Animals - Birds Buteo regalis ferruginous hawk
Animals - Birds Circus hudsonius northern harrier
Animals - Birds Elanus leucurus white-tailed kite
Animals - Birds Eremophila alpestris actia California horned lark Animals - Birds Chaetura vauxi Vauxs swift
Animals - Birds Ardea herodias great blue heron
Animals - Birds Botaurus lentiginosus American bittern
Animals - Birds Falco mexicanus prairie falcon
Animals - Birds Falco peregrinus anatum American peregrine falcon Animals - Birds Spinus lawrencei Lawrences goldfinch
Animals - Birds Progne subis purple martin
Animals - Birds Xanthocephalus xanthocephalus yellow-headed blackbird Animals - Birds Lanius ludovicianus loggerhead shrike
Animals - Birds Toxostoma lecontei Le Contes thrasher
Animals - Birds Pandion haliaetus osprey
Animals - Birds Setophaga petechia yellow warbler
Animals - Birds Aimophila ruficeps canescens
southern California rufouscrowned sparrow
Animals - Birds Artemisiospiza belli belli Bells sparrow Animals - Birds Passerculus sandwichensis rostratus large-billed savannah sparrow Animals - Birds Spizella breweri Brewers sparrow
Animals - Birds Melanerpes lewis Lewis woodpecker
Animals - Birds Polioptila californica californica coastal California gnatcatcher Animals - Birds Polioptila melanura black-tailed gnatcatcher Animals - Birds Athene cunicularia burrowing owl
Animals - Birds Strix occidentalis occidentalis California Spotted Owl Animals - Birds Calypte costae Costas hummingbird
Animals - Birds Selasphorus rufus rufous hummingbird
Animals - Birds Contopus cooperi olive-sided flycatcher Animals - Birds Empidonax traillii willow flycatcher
517
Animals - Birds Empidonax traillii extimus southwestern willow flycatcher Animals - Birds Vireo bellii pusillus least Bells vireo Animals - Insects Bombus crotchii Crotchs bumble bee
Animals - Insects Bombus pensylvanicus American bumble bee Animals - Insects Stenopelmatus cahuilaensis
Coachella Valley jerusalem
cricket
Animals - Mammals Neotoma lepida intermedia San Diego desert woodrat Animals - Mammals Lynx rufus pallescens pallid bobcat
Animals - Mammals Chaetodipus fallax fallax
northwestern San Diego pocket
mouse
Animals - Mammals Chaetodipus fallax pallidus pallid San Diego pocket mouse Animals - Mammals Dipodomys simulans Dulzura kangaroo rat Animals - Mammals Perognathus longimembris bangsi Palm Springs pocket mouse Animals - Mammals Perognathus longimembris brevinasus Los Angeles pocket mouse Animals - Mammals Lepus californicus bennettii San Diego black-tailed jackrabbit Animals - Mammals Taxidea taxus American badger
Animals - Mammals Xerospermophilus tereticaudus chlorus Palm Springs round-tailed
ground squirrel
Animals - Mammals Antrozous pallidus pallid bat
Animals - Mammals Corynorhinus townsendii Townsends big-eared bat Animals - Reptiles Anniella stebbinsi Southern California legless lizard Animals - Reptiles Arizona elegans occidentalis California glossy snake Animals - Reptiles Salvadora hexalepis virgultea coast patch-nosed snake Animals - Reptiles Thamnophis hammondii two-striped gartersnake Animals - Reptiles Phrynosoma blainvillii coast horned lizard Animals - Reptiles Uma inornata
Coachella Valley fringe-toed
lizard
Animals - Reptiles Aspidoscelis tigris stejnegeri coastal whiptail Animals - Reptiles Gopherus agassizii desert tortoise
Animals - Reptiles Crotalus ruber red-diamond rattlesnake Plants - Vascular Deinandra mohavensis Mojave tarplant
Plants - Vascular Deinandra paniculata paniculate tarplant Plants - Vascular Symphyotrichum defoliatum San Bernardino aster Plants - Vascular Caulanthus simulans Paysons jewelflower Plants - Vascular Astragalus lentiginosus var. borreganus Borrego milk-vetch Plants - Vascular Astragalus lentiginosus var. coachellae Coachella Valley milk-vetch Plants - Vascular Astragalus pachypus var. jaegeri Jaegers milk-vetch Plants - Vascular Juglans californica southern California black walnut Plants - Vascular Calochortus plummerae Plummers mariposa-lily Plants - Vascular Petalonyx linearis narrow-leaf sandpaper-plant Plants - Vascular Abronia villosa var. aurita chaparral sand-verbena Plants - Vascular Chorizanthe parryi var. parryi Parrys spineflower 518
Plants - Vascular Chorizanthe xanti var. leucotheca white-bracted spineflower Plants - Vascular Delphinium parishii ssp. subglobosum Colorado Desert larkspur Plants - Vascular Delphinium parryi ssp. purpureum Mt. Pinos larkspur Plants - Vascular Horkelia cuneata var. puberula mesa horkelia FP: Fully Protected
SSC: Species of Special Concern
WL: Watch List
519

EXHIBIT C
520












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CITY OF BANNING

STAFF REPORT
TO: CITY COUNCIL
FROM: Robert Fisher, Acting City Manager
PREPARED BY: Nate Smith, Deputy Director of Public Works/City Engineer Art Vela, Director of Public Works
MEETING DATE: July 8, 2025
SUBJECT: Consideration of Accepting Easements from North Pointe Development for Right of Way, Maintenance and Access, and Temporary Construction necessary for the Sun Lakes Boulevard Extension Project RECOMMENDATION:

Accept Easements from North Pointe Development for Right of Way, Maintenance and Access, and Temporary Construction necessary for the Sun Lakes Boulevard Extension Project BACKGROUND:

The proposed Sun Lakes Boulevard Extension Project (“SLB Extension Project”) is identified on the Council approved Capital Improvement Program and, once constructed, would complete a gap in the roadway and circulation network along Sun Lakes Boulevard between Highland Home Road and Sunset Avenue. This unfinished portion of Sun Lakes Boulevard has been identified on the City's circulation element dating back to at least 1994. The SLB Extension Project has been a vision for the City since the construction of the Sun Lakes Country Club starting in the mid 1980's to provide an important secondary access point from the Sun Lakes Country Club community to Sunset Avenue, relieving pressure of Highland Springs Avenue. Initial steps were taken with a Right of Way dedication to the City of Banning on Parcel Map 25541 in February of 1990. In 2020, the City Council revived efforts to complete the SLB Extension Project with the following actions:

Resolution 2020-21 (adopted on 2/11/20): Accepting the lots dedicated to the City on Parcel Map 25541
Resolution 2020-48 (adopted on 4/14/20): Awarding a Professional Services Agreement for the design of the SLB Extension Project to Albert A Webb Associates Resolution 2020-97 (adopted on 7/14/20): Approving A TUMF Reimbursement Agreement with the Western Riverside Council Of Governments for $1,000,000 in TUMF funds City expenditures related to the SLB Extension Project. This agreement has been revised to increase the reimbursement total from $1,000,000 to $12,000,000, and will be adjusted again to $20,000,000 to reflect recent approved funding from WRCOG.

The City Council's adoption of the resolutions listed above in 2020 started the City's efforts to design the proposed SLB Extension Project and, once designed, prepare the environmental review documents for the SLB Extension Project based on the project scope identified in the design documents. In the time since the initiation of the design contract in 2020, City staff and the City's consultant, Albert A. Webb Associated, have engaged continuously to get the SLB Extension Project to an environmentally cleared and shovel ready condition. A redesign effort was necessitated when comments were received from (1) the U.S. Fish and Wildlife Service ("USFWS"), (2) the California Department of Fish and Wildlife 523
("CDFW"), and (3) utility holders within the existing utility corridor. These comments required the City to revise the initial project design and negotiate with the stakeholders mentioned above on an acceptable design solution. Once those efforts were completed, City staff and the City's Consultant revised the necessary studies, reports, and plans.

The Right of Way offer that is included with this package is consistent with the agreed upon revised alignment described above. The other easements for Maintenance and Access, and Temporary Construction were prepared with the revised right of way as well. The easements offered are necessary for the construction and operation of the roadway, and are described in more detail below.

Right of Way Dedication - Road and Utility Purposes: This easement is required for the ultimate roadway alignment, and would be held permanently by the City of Banning. The legal and plat were prepared by the City's design consultant for the SLB Extension Project and peer reviewed by the City's plan check consultant for technical accuracy.

Easement - Public Maintenance and Access Purposes: This easement is required for the City to maintain cut slope and embankments, as well as drainage devices installed to protect those slopes and convey storm water to the culvert crossings. The legal and plat were prepared by the City's design consultant for the SLB Extension Project and peer reviewed by the City's plan check consultant for technical accuracy. There were two (2) clauses added to the grant deed at the request of the Grantor;

1. A clause that states that if the SLB Extension Project is not initiated by the City by June 1, 2027, that the easement shall terminate and the City would forfeit the easement rights. City staff reviewed the request internally and with the City's legal counsel, and agreed to the addition of the clause. Delay to initiate the project to June 1, 2027 would also forfeit the RCTC grant, making construction impractical in this particular case.

2. A clause that states that if and when development occurs adjacent to the road right of way that would alter the cut slopes, embankments, or drainage devices are substantially completed, and that would render the City's need to maintain as moot, that the City shall quitclaim this easement back to the underlying land owner. City staff reviewed the request internally and with the City's legal counsel, and agreed to the clause. It is typical that private development is responsible for the maintenance of their private property, and this action is consistent with that practice utilized throughout the City, and would ultimately reduce the City's maintenance liability.

Temporary Construction Easement: This easement is required during the construction phase of the project to allow for contractors to access Grantor's private property to construct necessary cuts, fills, drainage, and roadway improvements. The legal and plat were prepared by the City's design consultant for the SLB Extension Project and peer reviewed by the City's plan check consultant for technical accuracy. The Grantor has agreed to provide the easement for a term of 24 months, with one (1) 12-month extension, if necessary. The Grantor has also agreed to provide the easement at no cost to the City of Banning. It is typical that and the end of the construction project, that the Temporary Construction Easement would terminate, as it is no longer necessary for the City to hold onto.

JUSTIFICATION:

It is necessary to obtain the easements for the construction, operation, and maintenance of the SLB Extension Project. The three (3) easements are being provided to the City at no cost.

FISCAL IMPACT:

There is no direct cost to the City of Banning to obtain the easements offered with this action.

ALTERNATIVES:

Do not accept the easements and provide alternate direction to staff.

BUDGETED?:
524
No
CONTRACT/AGREEMENT:

No
ATTACHMENTS:

1. Att. 1 - SLB ROW CofA, Grant Deed, Legal, Plat.pdf

2. Att. 2 - SLB Maint Easement CofA, Grant Deed, Legal, Plat.pdf

3. Att. 3 - SLB TCE CofA, Grant Deed, Legal, Plat.pdf
525
4907-6988-9362.6/
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EXEMPT RECORDING

REQUESTED BY
City of Banning
PER GOV’T CODE 6103

AND WHEN RECORDED
MAIL TO:

City of Banning – City Clerk
P.O. Box 998
Banning, CA 92220

MAIL TAX STATEMENTS
TO:

City of Banning – City Clerk
P.O. Box 998
Banning, CA 92220
APN: SPACE ABOVE THIS LINE FOR RECORDER' S USE
The undersigned grantor declares that NO documentary transfer tax is payable, because this is merely the conveyance of an easement and the consideration and value is less than $100. R&T 11911.

RIGHT-OF-WAY DEDICATION – ROAD AND UTILITIES PURPOSES
The undersigned (“Grantor”), being the present title owner(s) of record of the herein described parcel of land, does hereby make an irrevocable R.O.W. DEDICATION to the City of Banning, a general law city (“City”), and its successors or assigns, for public road, street, highway, and utilities purposes (the “Easement”), over, on and across portions of the real property situated in the City of Banning, County of Riverside, State of California, described in Exhibit “A” (legal description) and shown on Exhibit “B” (plat map) attached hereto and incorporated herein by this reference as though set forth in full.

It is understood and agreed that the City of Banning and its successors or assigns shall incur no liability with respect to such offer of dedication, and shall not assume any responsibility for the offered parcel of land or any improvements thereon or therein, until such offer has been accepted by appropriate action of the City Council, or of the local governing bodies or its successors or assigns.

The provisions hereof shall inure to the benefit of and be binding upon heirs, successors, assigns, and personal representatives of the respective parties hereto. 526
When Recorded Mail To:

City Clerk
City of Banning
P.O. Box 998
Banning, CA 92220
NO RECORDING FEE PER SECTION SPACE FOR RECORDER’S USE
6103 OF THE GOVERNMENT CODE.

CERTIFICATE OF ACCEPTANCE
This is to certify that the RIGHT OF WAY DEDICATION – ROAD AND UTILITY PURPOSES from NP Banning Industrial, LLC dated 7/1/25, is hereby accepted by THE CITY OF BANNING pursuant to authority conferred by the City Council this 8th day of July, 2025, and the grantees consent to recordation thereof by its duly authorized agent.

Dated:______________

CITY OF BANNING
By_________________________
Vicki Sellers
City Clerk
527
528
EXHIBIT “A”

LEGAL DESCRIPTION
(Attached)
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EXHIBIT “A”

LEGAL DESCRIPTION
(Attached)
529
EXHIBIT “A”

PUBLIC STREET AND UTILITY EASEMENT

LEGAL DESCRIPTION
PARCEL 1:

BEING A PORTION OF PARCEL 3 AS SHOWN BY PARCEL MAP NO. 25541 ON FILE IN BOOK 166 OF PARCEL MAPS, PAGES 27 THROUGH 35, INCLUSIVE, RECORDS OF

RIVERSIDE COUNTY, LYING WITHIN THE CITY OF BANNING, COUNTY OF RIVERSIDE, STATE OF CALIFORNIA, SECTION 7, TOWNSHIP 3 SOUTH, RANGE 1

EAST, SAN BERNARDINO MERIDIAN, MORE PARTICULARLY DESCRIBED AS FOLLOWS:

COMMENCING AT THE SOUTHWESTERLY CORNER OF SAID SECTION 7, SAID

CORNER ALSO BEING THE CENTERLINE INTERSECTION OF WESTWARD AVENUE (55.00 FEET IN NORTHERLY HALF-WIDTH) WITH HIGHLAND HOME ROAD (50.00 FEET IN EASTERLY HALF-WIDTH) AS SHOWN ON SAID MAP;
THENCE ALONG THE WESTERLY LINE OF SAID SECTION 7 NORTH 00°09°58” EAST, A DISTANCE OF 79.56 FEET;
THENCE LEAVING SAID SECTION LINE, AT A RIGHT-ANGLE, SOUTH 89°50’02” EAST A DISTANCE OF 50.00 FEET TO A POINT ON THE EASTERLY RIGHT-OF-WAY LINE OF HIGHLAND HOME ROAD, SAID POINT BEING THE BEGINNING OF A NONTANGENT CURVE, CONCAVE NORTHEASTERLY, HAVING A RADIUS OF 25.00 FEET, AND TO WHICH A RADIAL BEARING TO SAID POINT BEARS NORTH 89°50’02” WEST, ALSO BEING THE TRUE POINT OF BEGINNING;

THENCE ALONG SAID EASTERLY RIGHT-OF-WAY LINE OF HIGHLAND HOME ROAD AND THE NORTHERLY RIGHT-OF-WAY LINE WESTWARD AVENUE (55.00 FEET IN HALF-WIDTH) THE FOLLOWING TWO (2) COURSES:
1) SOUTHERLY, SOUTHEASTERLY, AND EASTERLY ALONG SAID CURVE, THROUGH A CENTRAL ANGLE OF 89°39'47", AN ARC DISTANCE OF 39.12 FEET:
2) SOUTH 89°29°49” EAST, A DISTANCE OF 23.22 FEET;

THENCE LEAVING SAID WESTWARD AVENUE NORTHERLY RIGHT-OF-WAY LINE NORTH 79°43°21” WEST, A DISTANCE OF 27.18 FEET TO THE BEGINNING OF A TANGENT CURVE, CONCAVE NORTHEASTERLY, HAVING A RADIUS OF 21.00 FEET;

THENCE WESTERLY, NORTHWESTERLY, AND NORTHERLY ALONG SAID CURVE, THROUGH A CENTRAL ANGLE OF 79°02'38", AN ARC DISTANCE OF 28.97 FEET; Page | of 8
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EXHIBIT “A”

PUBLIC STREET AND UTILITY EASEMENT

LEGAL DESCRIPTION
THENCE NORTH 89°50’02” WEST, A DISTANCE OF 4.00 FEET TO THE TRUE POINT OF BEGINNING.

CONTAINING 197 SQ. FT. (0.004 AC.) MORE OR LESS
PARCEL 2:

BEING A PORTION OF PARCEL 3, AS SHOWN BY PARCEL MAP NO. 25541 ON FILE IN BOOK 166 OF PARCEL MAPS, PAGES 27 THROUGH 35, INCLUSIVE, RECORDS OF

RIVERSIDE COUNTY, LYING WITHIN THE CITY OF BANNING, COUNTY OF RIVERSIDE, STATE OF CALIFORNIA, SECTION 7, TOWNSHIP 3 SOUTH, RANGE 1

EAST, SAN BERNARDINO MERIDIAN, MORE PARTICULARLY DESCRIBED AS FOLLOWS:

COMMENCING AT THE SOUTHWESTERLY CORNER OF SAID SECTION 7, SAID

CORNER ALSO BEING THE CENTERLINE INTERSECTION OF WESTWARD AVENUE (55.00 FEET IN NORTHERLY HALF-WIDTH) WITH HIGHLAND HOME ROAD (50.00 FEET IN EASTERLY HALF-WIDTH) AS SHOWN ON SAID MAP;
THENCE ALONG THE SOUTHERLY LINE OF SAID SECTION 7 AND SAID CENTERLINE OF WESTWARD AVENUE, SOUTH 89°29°49” EAST, A DISTANCE OF 119.08 FEET;
THENCE LEAVING SAID SOUTHERLY LINE OF SECTION 7 AND SAID CENTERLINE OF WESTWARD AVENUE, AT A RIGHT ANGLE, NORTH 00°30°11” EAST, A DISTANCE OF 55.00 TO A POINT ON THE NORTHERLY RIGHT-OF-WAY LINE OF SAID

WESTWARD AVENUE FOR THE TRUE POINT OF BEGINNING, SAID POINT ALSO

BEING THE BEGINNING OF A NON-TANGENT CURVE, CONCAVE NORTHERLY, HAVING A RADIUS OF 1145.00 FEET, A RADIAL BEARING TO SAID CURVE BEARS SOUTH 00°30°11” WEST;
THENCE EASTERLY ALONG SAID CURVE, AN ARC DISTANCE OF 338.83 FEET, THROUGH A CENTRAL ANGLE OF 16°57°19”;
THENCE NORTH 73°32’52” EAST, A DISTANCE OF 156.63 FEET TO THE BEGINNING OF A TANGENT CURVE, CONCAVE SOUTHERLY, HAVING A RADIUS OF 1255.00 FEET;

H-32020120-0/26\Drawings\Mapping\Legals & Plats\RW'\20-0126-ROW-WESTWARD AVE.doc Albert A. Webb Associates 4907-6988-9362.6/
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531
EXHIBIT “A”

PUBLIC STREET AND UTILITY EASEMENT

LEGAL DESCRIPTION
THENCE EASTERLY ALONG SAID CURVE, AN ARC DISTANCE OF 371.39 FEET, THROUGH A CENTRAL ANGLE OF 16°57°19” TO A POINT ON A LINE PARALLEL WITH AND DISTANT 205.00 FEET NORTHERLY MEASURED AT RIGHT ANGLES TO SAID SOUTHERLY SECTION LINE OF SECTION 7;
THENCE ALONG SAID PARALLEL LINE, SOUTH 89°29°49” EAST, A DISTANCE OF 462.06 FEET TO A POINT OF CUSP OF A TANGENT CURVE, CONCAVE SOUTHERLY, SAID CURVE HAVING A RADIUS OF 1255.00 FEET, SAID POINT ALSO BEING ON THE NORTHERLY LINE OF SAID LOT “D”, REFERRED TO HEREAFTER AS POINT “A”; THENCE ALONG THE NORTHERLY LINE OF SAID LOT “D” THE FOLLOWING THREE (3) COURSES:

1. WESTERLY ALONG SAID CURVE, AN ARC DISTANCE OF 371.39 FEET, THROUGH A CENTRAL ANGLE OF 16°57°19”;

2. SOUTH 73°32’52” WEST, A DISTANCE OF 156.63 FEET TO THE BEGINNING OF A TANGENT CURVE, CONCAVE NORTHERLY, HAVING A RADIUS OF 1145.00 FEET;

3. WESTERLY ALONG SAID CURVE, AN ARC DISTANCE OF 54.92. FEET, THROUGH A CENTRAL ANGLE OF 2°44°53” TO THE BEGINNING OF A NONTANGENT CURVE CONCAVE SOUTHERLY HAVING A RADIUS OF 1145.00 FEET, A RADIAL BEARING TO SAID CURVE BEARS NORTH 04°50°28” WEST, SAID CURVE LYING 110.00 FEET SOUTHERLY, MEASURED RADIALLY, AND CONCENTRIC WITH THE AFORMENTIONED 1255.00 FOOT RADIUS CURVE; THENCE LEAVING SAID NORTHERLY LINE OF LOT “D”, ALONG SAID CURVE, AN ARC DISTANCE OF 196.74 FEET, THROUGH A CENTRAL ANGLE OF 09°50°41” TO A POINT ON THE NORTHERLY RIGHT-OF-WAY LINE OF SAID WESTWARD AVENUE;

THENCE ALONG SAID NORTHERLY RIGHT-A-WAY LINE OF WESTWARD AVENUE NORTH 89°29°49” WEST, A DISTANCE OF 549.73 FEET TO THE TRUE POINT OF BEGINNING.

CONTAINING 1.575 ACRES, MORE OR LESS.

H-32020120-0/26\Drawings\Mapping\Legals & Plats\RW'\20-0126-ROW-WESTWARD AVE.doc Albert A. Webb Associates 4907-6988-9362.6/
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EXHIBIT “A”

PUBLIC STREET AND UTILITY EASEMENT

LEGAL DESCRIPTION
PARCEL 3:

THOSE PORTIONS OF PARCELS 3 AND 4, AS SHOWN BY PARCEL MAP NO. 25541 ON FILE IN BOOK 166 OF PARCEL MAPS, PAGES 27 THROUGH 35, INCLUSIVE,

RECORDS OF RIVERSIDE COUNTY, LYING WITHIN THE CITY OF BANNING, COUNTY OF RIVERSIDE, STATE OF CALIFORNIA, SECTION 7, TOWNSHIP 3 SOUTH, RANGE 1 EAST, SAN BERNARDINO MERIDIAN, MORE PARTICULARLY DESCRIBED AS FOLLOWS:

COMMENCING AT POINT “A” REFERRED TO HEREON;
THENCE SOUTH 89°29°49” EAST, ALONG THE NORTH LINE OF LOT “D” AS SHOWN ON SAID PARCEL MAP, A DISTANCE OF 202.29 FEET TO THE BEGINNING OF A TANGENT CURVE, CONCAVE SOUTHERLY, HAVING A RADIUS OF 1255.00 FEET FOR THE TRUE POINT OF BEGINNING:

THENCE LEAVING SAID NORTHERLY LINE OF LOT “D”, SOUTH 89°29°49” EAST, A DISTANCE OF 84.19 FEET;
THENCE SOUTH 89°14°50” EAST, A DISTANCE OF 2305.40 FEET, SAID COURSE AND

DISTANCE HEREAFTER REFERRED TO AS COURSE B, TO A POINT OF CUSP OF A

NON-TANGENT CURVE, CONCAVE SOUTHERLY, SAID CURVE HAVING A RADIUS OF 1255.00 FEET, A RADIAL BEARING TO SAID CURVE BEARS NORTH 00°30711” EAST, SAID POINT ALSO BEING ON THE NORTHERLY LINE OF LOT “E”, AS SHOWN ON SAID PARCEL MAP;
THENCE ALONG THE NORTHERLY LINE OF SAID LOT “E” THE FOLLOWING THREE (3) COURSES:

1. WESTERLY ALONG SAID CURVE, AN ARC DISTANCE OF 359.05 FEET, THROUGH A CENTRAL ANGLE OF 16°26°31”;

2. SOUTH 74°06’40” WEST, A DISTANCE OF 150.25 FEET TO THE BEGINNING OF A TANGENT CURVE, CONCAVE NORTHERLY, HAVING A RADIUS OF 1145.00 FEET;

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EXHIBIT “A”

PUBLIC STREET AND UTILITY EASEMENT

LEGAL DESCRIPTION

3. WESTERLY ALONG SAID CURVE, AN ARC DISTANCE OF 54.73 FEET, THROUGH A CENTRAL ANGLE OF 2°44°20" TO A POINT ON A LINE PARALLEL WITH AND 110.00 FEET SOUTHERLY MEASURED AT RIGHT ANGLES TO SAID AFOREMENTIONED COURSE B;
THENCE LEAVING SAID NORTHERLY LINE OF LOT “E” ALONG SAID PARALLEL LINE, NORTH 89°14’50” WEST, A DISTANCE OF 376.04 FEET;
THENCE SOUTH 41°56’33” WEST, A DISTANCE OF 45.35 FEET TO A POINT ON SAID NORTHERLY LINE OF LOT “A”;
THENCE ALONG SAID NORTHERLY LINE, NORTH 89°29°49” WEST, A DISTANCE OF

99.43 FEET;
THENCE LEAVING SAID NORTHERLY LINE, NORTH 41°01°41” WEST, A DISTANCE OF 46.34 FEET TO A POINT ON A LINE PARALLEL WITH AND 110.00 FEET

SOUTHERLY MEASURED AT RIGHT ANGLES TO SAID AFOREMENTIONED COURSE B;
THENCE NORTH 89°14°50” WEST, A DISTANCE OF 745.99 FEET TO A POINT ON THE NORTHERLY LINE OF SAID LOT “D”, SAID POINT ALSO THE BEGINNING OF A NONTANGENT CURVE, CONCAVE NORTHERLY, HAVING A RADIUS OF 1145.00 FEET, A RADIAL BEARING TO SAID CURVE BEARS SOUTH 15°17°41” WEST ;

THENCE WESTERLY ALONG SAID NORTHERLY LINE AND SAID CURVE, AN ARC DISTANCE OF 45.86 FEET, THROUGH A CENTRAL ANGLE OF 2°17°41”; THENCE NORTH 72°24°38” WEST, 150.01 FEET TO THE BEGINNING OF A TANGENT CURVE, CONCAVE SOUTHERLY, HAVING A RADIUS OF 1255.00 FEET; THENCE WESTERLY ALONG SAID CURVE, AN ARC DISTANCE OF 374.26 FEET, THROUGH A CENTRAL ANGLE OF 17°05°11” TO THE TRUE POINT OF BEGINNING.

CONTAINING 4.359 ACRES, MORE OR LESS.

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EXHIBIT “A”

PUBLIC STREET AND UTILITY EASEMENT

LEGAL DESCRIPTION
PARCEL 4:

BEING A PORTION OF LOT “G” AS SHOWN BY PARCEL MAP NO. 25541 ON FILE IN BOOK 166 OF PARCEL MAPS, PAGES 27 THROUGH 35, INCLUSIVE, RECORDS OF

RIVERSIDE COUNTY, LYING WITHIN THE CITY OF BANNING, COUNTY OF RIVERSIDE, STATE OF CALIFORNIA, SECTION 7, TOWNSHIP 3 SOUTH, RANGE 1

EAST, SAN BERNARDINO MERIDIAN, MORE PARTICULARLY DESCRIBED AS FOLLOWS:

COMMENCING AT THE SOUTHEASTERLY CORNER OF SAID SECTION 7, SAID

CORNER ALSO BEING A POINT ON THE CENTERLINE OF WESTWARD AVENUE (55.00 FEET INNORTHERLY HALF-WIDTH) AS SHOWN ON SAID MAP; THENCE ALONG SAID SOUTHERLY LINE OF SECTION 7 AND SAID CENTERLINE OF WESTWARD AVENUE, NORTH 89°29°49” WEST, A DISTANCE OF 679.34 FEET; THENCE LEAVING SAID SOUTHERLY LINE OF SECTION 7 AND SAID CENTERLINE OF WESTWARD AVENUE, AT A RIGHT ANGLE, NORTH 00°30711” EAST, A DISTANCE OF 55.00 FEET TO A POINT ON THE NORTHERLY LINE OF THE EASEMENT FOR

ROADWAY AND UTILITY PURPOSES GRANTED TO THE CITY OF BANNING, RECORDED MAY 1, 1985, AS INSTRUMENT NO. 91551, OFFICIAL RECORDS OF SAID COUNTY, FOR THE TRUE POINT OF BEGINNING;

THENCE ALONG SAID NORTHERLY LINE AND PARALLEL WITH SAID CENTERLINE OF WESTWARD AVENUE, SOUTH 89°29°49” EAST, A DISTANCE OF 131.46 FEET TO A POINT OF CUSP OF A NON-TANGENT CURVE, CONCAVE SOUTHERLY, HAVING A RADIUS OF 1145.00 FEET, A RADIAL LINE TO SAID POINT BEARS NORTH 13°38°09” EAST, SAID POINT ALSO BEING ON THE SOUTHERLY LINE OF LOT “E” AS SHOWN ON SAID PARCEL MAP;
THENCE WESTERLYALONG SAID SOUTHERLY LINE OF LOT “E” AND SAID CURVE, AN ARC DISTANCE OF 262.44 FEET, THROUGH A CENTRAL ANGLE OF 13°07°58”; THENCE CONTINUING ALONG SAID SOUTHERLY LINE OF LOT “E”, NORTH 89°29°49” WEST, A DISTANCE OF 131.46 FEET TO A POINT OF CUSP OF A TANGENT CURVE, CONCAVE SOUTHERLY, HAVING A RADIUS OF 1145.00 FEET; THENCE EASTERLY ALONG SAID CURVE, AN ARC DISTANCE OF 262.44 FEET, THROUGH A CENTRAL ANGLE OF 13°07°58” TO THE TRUE POINT OF BEGINNING.

CONTAINING 3,967 SQ. FT. (0.091 AC.), MORE OR LESS.

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EXHIBIT “A”

PUBLIC STREET AND UTILITY EASEMENT

LEGAL DESCRIPTION
PARCEL 5:

BEING A PORTION OF PARCEL 4 AS SHOWN BY PARCEL MAP NO. 25541 ON FILE IN BOOK 166 OF PARCEL MAPS, PAGES 27 THROUGH 35, INCLUSIVE, RECORDS OF

RIVERSIDE COUNTY, STATE OF CALIFORNIA, LYING WITHIN THE CITY OF BANNING, COUNTY OF RIVERSIDE, STATE OF CALIFORNIA, SECTION 7, TOWNSHIP 3 SOUTH, RANGE 1 EAST, SAN BERNARDINO MERIDIAN, MORE PARTICULARLY DESCRIBED AS FOLLOWS:

COMMENCING AT THE SOUTHEAST CORNER OF SAID SECTION 7 AS SHOWN ON SAID PARCEL MAP;
THENCE ALONG THE EASTERLY LINE OF SAID SECTION 7 NORTH 00°04°18” EAST, A DISTANCE OF 108.73 FEET;
THENCE LEAVING SAID SECTION LINE, AT A RIGHT ANGLE, NORTH 89°55°42” WEST A DISTANCE OF 30.00 FEET TO THE WESTERLY RIGHT-OF-WAY LINE OF SUNSET AVENUE, ALSO BEING THE TRUE POINT OF BEGINNING;

THENCE ALONG THE SAID WESTERLY RIGHT-OF-WAY LINE OF SUNSET AVENUE AND THE NORTHERLY LINE OF LOT “E” AS SHOWN ON SAID PARCEL MAP, THE FOLLOWING THREE (3) COURSES:
1) SOUTH 00°04’18” WEST, A DISTANCE OF 26.59 FEET TO THE BEGINNING

OF A TANGENT CURVE, CONCAVE NORTHWESTERLY, AND HAVING A RADIUS OF 25.00 FEET;
2) SOUTHERLY, SOUTHWESTERLY, AND WESTERLY ALONG SAID CURVE, THROUGH A CENTRAL ANGLE OF 93°33'46", AN ARC DISTANCE OF 40.82

FEET, TO THE BEGINNING OF A COMPOUND CURVE CONCAVE
NORTHERLY, AND HAVING A RADIUS OF 1145.00 FEET, AND TO WHICH A RADIAL BEARING TO SAID CURVE BEARS SOUTH 03°38°05” WEST; 3) WESTERLY ALONG SAID CURVE, THROUGH A CENTRAL ANGLE OF 01°34'S6", AN ARC DISTANCE OF 31.62 FEET, TO A POINT OF CUSP OF A CURVE CONCAVE NORTHWESTERLY, HAVING A RADIUS OF 53.00 FEET,

AND TO WHICH A RADIAL BEARING TO SAID POINT BEARS SOUTH 22°00°19” EAST;

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EXHIBIT “A”

PUBLIC STREET AND UTILITY EASEMENT

LEGAL DESCRIPTION

THENCE NORTHEASTERLY AND NORTHERLY ALONG SAID CURVE, THROUGH A CENTRAL ANGLE 67°40°09”, AN ARC DISTANCE OF 62.60 FEET; THENCE NORTH 89°28°10” EAST, A DISTANCE OF 25.00 FEET TO THE TRUE POINT OF BEGINNING.

CONTAINING 1,645 SQ. FT. (0.04 AC.), MORE OR LESS.

SEE PLAT ATTACHED HERETO AS EXHIBIT “B” AND MADE A PART HEREOF.

PREPARED UNDER MY SUPERVISION
wy f— 11/13/2024
Michael E. J ohnson, L.S. 7673 Date
Prepared By: CGS \ NO. 7673 Checked By: MEJ \ \

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EXHIBIT “B”

DEPICTION
(Attached)
4907-6988-9362.6/
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EXHIBIT “B”

DEPICTION
(Attached)
538

EXHIBIT ”B”

PARCEL 1 = 197 SQ. FT. (0.004 AC.) MORE OR LESS
PARCEL 2 = 1.575 ACRES MORE OR LESS
PARCEL 3 = 4.359 ACRES MORE OR LESS
| PARCEL 4 = 3,967 SQ. FT. (0.091 AC.) MORE OR LESS
a PARCEL 5 = 1,645 SQ. FT. (0.037 AC.) MORE OR LESS
[ag
a S ////14 = RESTRICTED ACCESS
ee. ee
Q —— 7 0 Z ae W'LY LINE SEC. 7 , < = Za E’LY LINE SEC. ™ “ = PARCEL 5— || (i J
SHEET 8 I <1
SHEET 3 SHEET 4 SHEET 5 SHEET 6 SHEET 7 n
[sneer 2. PARCEL 2 PARCEL 3-\ |= 12) 47 —_—<_ eo = 7 Hil 8 FIVITITITTTT TIT ITI TAIT TTT TTT 77777777 4 TL i
i WESTWARD AVE. / | | / 18 17
S’LY LINE SEC. 7 PARCEL 4
1” = 800’
ee 1113/2024

800 0 800 SEC. 7, T3S, R1E, SBM
AL BE RT A.

WEBB CITY OF BANNING
H:\2020\20-0126\Drawings\Mapping\Legals & Plats\RW\20-0126—RW WESTWARD AVE 1 OF 2.dwg

ASSOCIATES | 44/;3/0094 9:57 AM Carlossi
W.O. THIS PLAT IS SOLELY AN AID IN LOCATING THE PARCEL(S) IN THE ATTACHED DOCUMENT. SHEET 1 OF 8 ALL PRIMARY CALLS ARE LOCATED IN THE WRITTEN DOCUMENT. ort } 20-0126 SCALE: 1” = Boo") WN By GBS DATE B/RB/2084 cr. PUBLIC STREET AND UTILITY EASEMENT

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539

EXHIBIT ”B”

BE |. | , 20° | 50 |
!
| LOT ”B”
W’LY LINE OF SEC. 7 /
| $89°50'02”E 50.00’
APN: 537-110-013
E’LY RIGHT-OF-WAY LINE

OF HIGHLAND HOME ROAD

PARCEL MAP
NO. 25541 PMB 166/27-35
N89°50’02"W 4.00’(R)
$89°19'17°W(R) PARCEL 3
R=21.00’ A=79°02’38” L=28.97’
N79°43'21"W 27.18’

SEE SHEET 3
$89°29'49"E 23.22’
iQ Te)

WESTWARD AVENUE

EASEMENT FOR ROADWAY AND UTILITY PURPOSES PER
INST. #91551, REC. 05/01/1985, O.R.

EXISTING DEDICATION PER PM 166/27-35, AND
CERTIFICATE OF ACCEPTANCE PER RESOLUTION 2020-21,
RECORDED MARCH 05, 2020, AS INST. NO.
2020-0103469
() RECORD INFORMATION PER PM 166/27-35
$89°29'49"E me (S89°26'17"E 5330.96’) —-
, | Jif W’LY RIGHT—OF—WAY — — — — LINE OF HIGHLAND I T.P.0.B. HOME ROAD 2 | PARCEL 1 J ae 197 SF
[o>] Lad m'——____ (R=25.00’)
Le 7 So uw A=89°39'47” Tw (L=39.12’) QA Zo 38 LOT ”A” Oo ~ P.0.C. = PARCEL 1 SW COR. OF SEC. 7 | SUN LAKES BOULEVARD 12 7 > : 13 1” = 30 ; S'LY LINE OF SEC. 7 Se ee AND & OF WESTWARD AVENUE 0 30 11/13/2024

SEC. 7, T3S, RIE, SBM
AL BE RT A.

CITY OF BANNING WEBB
ASSOCIATES 11/13/2024 9:57 AM Carlossi

H:\2020\20-0126\Drawings\Mapping\Legals & Plats\RW\20—0126—RW WESTWARD AVE 2 OF 2.dwa

THIS PLAT IS SOLELY AN AID IN LOCATING THE PARCEL(S) IN THE ATTACHED DOCUMENT. SHEET OF W.0.

ALL PRIMARY CALLS ARE LOCATED IN THE WRITTEN DOCUMENT. 2 2 0 8 20-0126 ” » 1DRW TSW VATE 6/6/2022)

SCALE:1° = 30 aie iy MEU _ ee 6/6/2022 | SUBJECT: PUBLIC STREET & UTILITY EASEMENT 4907-6988-9362.6/
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-3-
540

=

EXHIBIT ”B”

EASEMENT FOR ROADWAY AND UTILITY PURPOSES
PER INST. #91551, REC. 05/01/1985, O.R.

EXISTING DEDICATION PER PM 166/27-35, AND

CERTIFICATE OF ACCEPTANCE PER RESOLUTION
2020-21, RECORDED MARCH 05, 2020, AS INST.

NO. 2020-0103469

a () = RECORD INFORMATION PER PM 166/27—35
~
lu ‘iLL = RESTRICTED ACCESS 5 = APN: 537-110-013
9 | 50’ PM 166/27-35
s WLY LINE PARCEL 3 SEE SHEET 4
a SEC. 7 R=1255.00"
© f =16'57'19 aa
Ilo SEE SHEET 2 (2371.39) ~e
Rae FOR PARCEL 1 SARCEL 2
[e) O/S, / ss pettf5.00, Ng 6S" NO4'50'28"W (R) W'
7 LOT ”D”

00°30'11"W (R) L3 » R=1145.00
LoT "A” of Nt 548 b=2'44'53 =196.7" —|——_| =54.99
P.O.C.

S/W COR. SEC. 7

PARCEL 2
T.P.0.B C/L WESTWARD AVENUE ea
“eee 777 ° ’ m ’ ° ? ” ,
PARCEL 2 N89°29°49"W 5330.85’ (N89°26'17"W 5330.96’)

PM 83/13-15 PARCEL 1 TO S/E COR. SEC. 7 11/13/2024

PARCEL LINE TABLE
LINE #| DIRECTION | LENGTH
L1 | Noo 30’ 11"E | 55.00
L2 | S73" 32’ 52°W | 156.63
150 L3__ | N89" 29’ 49"W | 549.73 | ceo 7 35, RIE, SBM

AL BE RT A.

WEBB

CITY OF BANNING

H:\2020\20-0126\Drawings\Mapping\Legals & Plats\RW\20—0126—-RW WESTWARD AVE 1 OF 2.dwg ASSOCIATES | 11/13/2024 9:57 AM Carlossi THIS PLAT IS SOLELY AN AID IN LOCATING THE PARCEL(S) IN THE ATTACHED DOCUMENT. SHEET a Wo, ALL PRIMARY CALLS ARE LOCATED IN THE WRITTEN DOCUMENT. ot 3 OF 8 | 20-0126 Aye DRWN BY CGS DATE 872872024 SCALE: 1" = 150’ CHKD 3Y MEd DATE 9704/2024 SUBJECT: PUBLIC STREET & UTILITY EASEMENT

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541

EXHIBIT ”B”
= EASEMENT FOR ROADWAY AND UTILITY PURPOSES PER INST. #91551, REC. 05/01/1985, O.R. = EXISTING DEDICATION PER PM 166/27-35, AND

CERTIFICATE OF ACCEPTANCE PER RESOLUTION
2020-21, RECORDED MARCH 05, 2020, AS INST.

NO. 2020-0103469

() = RECORD INFORMATION PER PM 166/27-35
LLiLL = RESTRICTED ACCESS
PM 166/27-35 APN: 537-110-013 PARCEL 3 P.O.C. PARCEL 3
POINT “A” T.P.0.B SEE SHEET 5 SEE SHEET 3 NOO'30'11"E (R) ADOCEI teietetaten\ PARCEL 3 lam $89°29'49"E 748.54 \ —, [— 462.06’ =y—__ 202.29" 84.19’\— S89°14’50"F_ 2305.40’ PARCEL 2 Re1299.00 ~ _ R=1255,00 PARCEL 3
A=i657 19 LOT ”D” /e\ = A=17°05 "4" — \2 =371.59 L=374. 96) l7 —— — a 99 99 — C/L WESTWARD AVE. LOT F - wy = | — S'LY LINE SEC. 7 \ J 8 ig FITITTTTITITTI TT TTT TT TTT TT 777777 77?"'N89°29'49"W 5330.85’ (N89°26'17"W 5330.96’)4 e—_— \ To s Is COR SEC. 7 PM 83/13-15 GOR SEC. 7 PM 198/8-10 14/43/2024 PARCEL 1 PARCEL 1

PARCEL LINE TABLE
LINE # DIRECTION | LENGTH
— 1” = 150’
SEC. 7, T3S, RIE, SBM L7 N72° 24’ 38"W | 150.01 150 0 150 AL BERT A.

W ‘EBB CITY OF BANNING
H:\2020\20-0126\Drawings\Mapping\Legals & Plats\RW\20-0126—RW WESTWARD AVE 1 OF 2.dwg ASSOCIATES 1/13/2024 9:57 AM Carlossi THIS PLAT IS SOLELY AN AID IN LOCATING THE PARCEL(S) IN THE ATTACHED DOCUMENT. Clecer ~ W.0.

ALL PRIMARY CALLS ARE LOCATED IN THE WRITTEN DOCUMENT. SHEET 4 OF 8 20-0126

SCALES 1” = 150°) 25WN By GOS Dare B/RB/20R4 cr PUBLIC STREET & UTILITY EASEMENT 4907-6988-9362.6/
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Q
PM
P
SEE SHEET 4
APN: 537-110-013
EXHIBIT ”B”
NO. 2020-0103469
166/27-35
ARCEL 3

COURSE B
$89°14’50"E_2305.40’

EASEMENT FOR ROADWAY AND UTILITY PURPOSES
PER INST. #91551, REC. 05/01/1985, O.R.

EXISTING DEDICATION PER PM 166/27-35, AND

CERTIFICATE OF ACCEPTANCE PER RESOLUTION
2020-21, RECORDED MARCH 05, 2020, AS INST.

RECORD INFORMATION PER PM 166/27-35
PM 166/27-35
PARCEL 4
APN: 537-110-014

SEE SHEET 6

« PARCEL 3

4.359 AC.

R=1145.00' | ~~ N89°14’50’W 745.99” “A S77)
nl _9 ? ” 4) _& q; WK A=2°17 41 lo LOT *A” L5
L=45.86’ = wo ? ” ; N89°29'49"W 5330.85’ — C/L WESTWARD AVE. in (+ (NB9"26"17°W 5330.96’ }> _— __ nan PM 198/8-10 S’LY LINE SEC. I” 1 S/W J 7 PARCEL 1 COR. SEC. 7 | PM 198/8-10 ra PARCEL 3 PARCEL LINE TABLE PM 198/8-10 sx 11/13/2024 PARCEL 2 | Z| LINE #| DIRECTION | LENGTH =
| — L4 S41" 56’ 33’W | 45.35 Zz
L5 Ngg° 29’ 49°W | 99.43 it 1” = 150’ >
L7 | n72° 24’ 38°w | 150.01 | 150 0 150 VA | SEC. 7,

AL BE RT A.

CITY OF BANNING

‘WEBB. H:\2020\20-0126\Drawings\Mapping\Legals & Plats\RW\20-0126—RW WESTWARD AVE 1 OF 2.dwg ASSOCIATES | 44/;3/0094 9:57 AM Carlossi THIS PLAT IS SOLELY AN AID IN LOCATING THE PARCEL(S) IN THE ATTACHED DOCUMENT. SHEET OF W.0, ALL PRIMARY CALLS ARE LOCATED IN THE WRITTEN DOCUMENT. orl 5 OF 8 | 20-0126 DRWN BY CGS DATE 8/28/2024 sca: 1” = 1507)200N 2Y Meg A> 846845094 susvect: PUBLIC STREET & UTILITY EASEMENT

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543

EXHIBIT ”B”
= EASEMENT FOR ROADWAY AND UTILITY PURPOSES
PER INST. #91551, REC. 05/01/1985, O.R.
= EXISTING DEDICATION PER PM 166/27-—35, AND

CERTIFICATE OF ACCEPTANCE PER RESOLUTION
2020-21, RECORDED MARCH 05, 2020, AS INST.

NO. 2020-—0103469
() = RECORD INFORMATION PER PM 166/27-35
PM 166/27-35

PARCEL 4 APN: 537-110-014
EXISTING R.O.W. ANGLE POINT SEE SHEET 5 NOO'30’11"E (R) | SEE SHEET 7 COURSE B — {\ RUB OTE AW . | nas'29"49"W <_s89°14'50"E 2305.40” 368.64"
= PARCEL 3 @n1755.00" — TO B.C:
= $13'09'00"E (R) 4.359 AC. — j=ie°25 3 LOT ”E”
> S74°06'40"W\ ,=359.05 = N89°14’50"W 376.047 —”

R=1145.00’ 150.25’ —_——
9499 A=2'44'20" oo vA? a SAA LOT “A L=54.73° TN LOT ”G
wa ; N89°29°49"W 5330.85 —> TO S/E ___ C/L WESTWARD AVE—~ in a (N89'26'17°W 5330.96" 10 S/ | S’LY LINE SEC. 7 TO S/W ) SEC. 7
PARCEL 4 PARCEL 5
1” = 150’ | 13/2020
150 0 150

SEC. 7, T3S, R1E, SBM

AL BE RT

ASSOCIAT
A.

WEBB
E S$

CITY OF BANNING
H:\2020\20-0126\Drawings\Mapping\Legals & Plats\RW\20-0126—RW WESTWARD AVE 1 OF 2.dwg

11/13/2024 9:57 AM Carlossi

ALL PRIMARY CALLS ARE
THIS PLAT IS SOLELY AN AID IN LOCATING THE PARCEL(S) IN THE ATTACHED DOCUMENT. SHEET OF 8 a LOCATED IN THE WRITTEN DOCUMENT. orit 6 } 20-0126
W.0 WU
SCALE: 1" = 150’
QRWN By GOS DATE B/RB/2029 «ect. PUBLIC STREET & UTILITY EASEMENT 4907-6988-9362.6/
390086.00004/6-30-25/Ipm/Ipm
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-7-
544

EXHIBIT ”B”

RQ

= EASEMENT FOR ROADWAY AND UTILITY PURPOSES PER
INST. #91551, REC. 05/01/1985, O.R. W
= EXISTING DEDICATION PER PM 166/27-35, AND CERTIFICATE OF ACCEPTANCE PER RESOLUTION 2020-21, RECORDED MARCH 05, 2020, AS INST. NO. 2020-0103469 S () = RECORD INFORMATION PER PM 166/27-35 }

PARCEL MAP C/L SUNSET.

APN: 537-110-014 NO. 25541 AVENUE PMB 166/27-35 N
SEE SHEET 6 PARCEL 4 ELY SeOTION 7 |
SEE SHEET 8 MN
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0 150 150 LINE TABLE
CURVE TABLE # DIRECTION | LENGTH
CURVE # | RADIUS | LENGTH | DELTA L8 | Noo’ 30’ 11"E | 55.00 C1 1145.00 | 262.44 | 13°07’58” || LO | sgg° 29° 496 | 131.46 C2 1145.00 | 262.44 | 130758” || L10 | N89° 29° 49°W| 131.46 | sec. 7, 13S, RIE, SBM

AL BE RT A.

WEBB CITY OF BANNING
H:\2020\20-0126\Drawings\Mapping\Legals & Plats\RW\20—0126—RW WESTWARD AVE 2 OF 2.dwa

ASSOCIATES |
44/;3/0094 9:57 AM Carlossi
W.O. THIS PLAT IS SOLELY AN AID IN LOCATING THE PARCEL(S) IN THE ATTACHED DOCUMENT. | oycc> ALL PRIMARY CALLS ARE RI LOCATED IN THE WRITTEN DOCUMENT. 7 SHEET 7 OF 8 | 20-0126 SCALE: 1" = 150°)DRWN BY Bes DATE TAD Abe nSq Susvect: PUBLIC STREET & UTILITY EASEMENT

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EXHIBIT ”B” S'LY LINE OF
SEC. 7 & C/L WESTWARD AVE.
| | @ OF LOT ”A”
PARCEL MAP | , , ; NO, 25541 j—30"____ 25 LL F SEO7 PMB 166/27-35 | - _ = E’LY LINE OF SEC. 7 | P.0.C. T.P.0.B- | N S/E COR ws PARCEL 4 ptanerhe | | SEC. 7 “ . Yr | ° ? mM APN: 537-110-014 & ; N8Q°55'42"W — Levy tine ; oy ; 30.00 | 2 SEC. 8 & C/L R=53.00 A=67°4009 L=62.60 | © WESTWARD AVE. () INDICATES wn 7 ul LL — — _ = OF RECORD DATA PER \3 = DETAIL A SUNSET PMB 166/27-35 2m = _ AVENUE ©, 1645 S0.|/ a D PER PM SEE SHEET 7 \a FT. +/-/) | x Zz | 198/8-10 a ——— — \2 | San = a 7 | - | ib) 30’
” — _f-- a 5S oO (R= 1145.00’) =01°34’56 L=31.62’ 0S MB 134/71-76 6 R=25.000’ A=093'33'46” |=40.82’ POC. 32 134/71- (R=25.00’ A=93'33'52” L=40.83’) PARCEL 5 \ |& \ | —___ (R=1200.00' A=17°08'44” S/E COR. < N89°36'27°W 8.64’ IE Ra471200.00" Aa7-9g%45» 1=959.07') OF SEC. 7 (N89°57'09"W 8.64) “(R=1900 ~1200.00" 1200.00" A= 17'55°36" A=t7"55°300 [x 355 “7 te sesso. 78 — \\ / C/L WESTWARD AVE. —— N89°29’ "49°W 5330.85" 45’) c N89°36’27"W (N89°57’09"W) (N89°26'17"W 5330.96’) ~ 18 17 is SEE DETAIL — S'LY LINE OF SEC. 7 "A” HEREON
LINE TABLE | |
# | DIRECTION | LENGTH ‘\ \ L11 | soo’ 04’ 18°W | 26.59 | PM 198/8-10 4a’ Daan PARCEL 7 11/13/2024 L12 | N89° 28’ 10"E | 25.00 SEC. 7. T3S RIE. SBM ALBERT .

WEBB CITY OF BANNING
H:\2020\20-0126\Drawings\Mapping\Legals & Plats\RW\20-0126-—RW WESTWARD AVE 2 OF 2.dwg ASSOCIATES 1/13/2024 9:57 AM Carlossi THIS PLAT IS SOLELY AN AID IN LOCATING THE PARCEL(S) IN THE ATTACHED DOCUMENT. c c la WO. ALL PRIMARY CALLS ARE LOCA ED IN THE WRITTEN DOCUMEN . . SHEET 8 OF 8 | 20-0126 SCALE:NTS. —PDRVIN BY TRH NT BABAZORET <evecr. PUBLIC STREET & UTILITY EASEMENT

4907-6988-9362.6/
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-9-
546
When Recorded Mail To:

City Clerk
City of Banning
P.O. Box 998
Banning, CA 92220
NO RECORDING FEE PER SECTION SPACE FOR RECORDER’S USE
6103 OF THE GOVERNMENT CODE.

CERTIFICATE OF ACCEPTANCE
This is to certify that the EASEMENT – PUBLIC MAINTENANCE AND ACCESS PURPOSES from NP Banning Industrial, LLC dated 7/1/25, is hereby accepted by THE CITY OF BANNING pursuant to authority conferred by the City Council this 8th day of July, 2025, and the grantees consent to recordation thereof by its duly authorized agent.

Dated:______________

CITY OF BANNING
By_________________________
Vicky Sellers
City Clerk
547
APN: SPACE ABOVE THIS LINE FOR RECORDER' S USE
The undersigned grantor declares that NO documentary transfer tax is payable, because this is merely the conveyance of an easement and the consideration and value is less than $100. R&T 11911.

EASEMENT – PUBLIC MAINTENANCE AND ACCESS PURPOSES
The undersigned (“Grantor”), being the present fee simple title owner(s) of record of the herein described parcel of land, does hereby grant to the City of Banning, a general law city (“City”), and its successors or assigns (“Grantee”) an easement for public maintenance and access purposes for cut and fill manufactured slopes and drainage devices and the construction thereof (the “Easement”), on the real property situated in the City of Banning, County of Riverside, State of California, described in Exhibit “A” (legal description) and shown on Exhibit “B” (plat map) attached hereto and incorporated herein by this reference as though set forth in full (the “Property”).

It is understood and agreed that the City of Banning and its successors or assigns shall incur no liability with respect to such Easement, and shall not assume any responsibility for the Easement or any improvements thereon or therein, until such offer has been accepted by a Certificate of Acceptance approved by the City Council of the City, or of the local governing bodies or its successors or assigns.

It is further understood that Grantor has agreed to grant this Easement for the purpose of allowing Grantee’s construction of cut and fill manufactured slopes and drainage facilities on the Easement in connection with the a potential extension of Sun Lakes Boulevard, (also referred to as Westward Avenue), from Sunset Avenue to Highland Home Road in the City (the “Extension Improvements”), as detailed in an Agreement for the Funding of Measure A Regional Arterial Improvements with the City of Banning, dated October 30,2023, between the Riverside County Transportation Commission and the City (“Agreement No. 23-72-091-00). This Easement shall terminate on June 1, 2027, if construction of the Extension Improvements has not commenced prior to that date.

EXEMPT

RECORDING

REQUESTED BY
City of Banning
PER GOV’T CODE
6103 AND WHEN

RECORDED MAIL
TO:

City of Banning – City
Clerk
P.O. Box 998
Banning, CA 92220

MAIL TAX
STATEMENTS TO:

City of Banning – City
548
549
EXHIBIT “A”

LEGAL DESCRIPTION
(Attached)
550
551
552
553
554
555
556
557
558
559
EXHIBIT “B”

DEPICTION
(Attached)
560
561
562
563
564
565
566
567
568
569

SPACE ABOVE THIS LINE FOR RECORDER' S USE
Assessor 's Parcel No. 537-110-013 [X] Portions
Assessor 's Parcel No. 537-110-014 [X] Portions
Documentary Transfer Tax $0.00
This Instrument is for the benefit of the City of Banning and is exempt from Recording Fees (Govt. Code § 27383), Filing Fees (Govt. Code § 6103), and Documentary Transfer Tax (Rev & Tax Code§ 11922).

TEMPORARY CONSTRUCTION EASEMENT AGREEMENT
ThisTemporary Construction Easement Agreement ("TCE Agreement") is entered into by and between the undersigned ("Grantor") and the CITY OF BANNING, a general law city ("City" or "Grantee") and is effective as of the date it is fully executed by the Parties.

ThisTCE Agreement is based on the following facts, which are incorporated herein by this reference:

A. Grantor is the record fee owner of that certain real property located north of Westward Avenue, east of Highland Home Road, and west of Sunset Ave in the City of Banning, State of California, identified asRiversideCountyTaxAssessor's Parcel Numbers 537-110-013 and 537-110-014 (the “Grantor Property”).

B. Grantor hereby grant to the City an easement to utilize approximately 8.518 acres (the “Easement”) of the Grantor Property, as described on Exhibit “A” and such Easement as depicted on Exhibit “B”, attached hereto and made a part hereof by this reference, for temporary public use, namely public street purposes and all uses necessary or convenient thereto in connection with the Sun Lakes Boulevard Extension Street Improvement Project (“Project”). The Project is intended to improve circulation in this area of the City. The Project, as planned and designed, is intended to provide for the construction of Sun Lakes Boulevard for approximately 1.01 miles concurrent or northerly of existing Westward Ave from Highland Home Road to the west and Sunset Avenue to the east. The Project is intended to include grading of the roadbed, drainage culverts and devices, roadway improvements, electric utility improvements, City owned and third party utility relocations, street lighting, signing, and striping.

C. Grantor agrees to allow the City to access Grantor’s property for a term of 24 months (the “Initial Term”) from the issuance of a notice to proceed to the City’s contractor. The 570
When Recorded Mail To:

City Clerk
City of Banning
P.O. Box 998
Banning, CA 92220
NO RECORDING FEE PER SECTION SPACE FOR RECORDER’S USE
6103 OF THE GOVERNMENT CODE.

CERTIFICATE OF ACCEPTANCE
This is to certify that the TEMPORARY CONSTRUCTION EASEMENT from NP Banning Industrial, LLC dated 7/1/25, is hereby accepted by THE CITY OF BANNING pursuant to authority conferred by the City Council this 8th day of July, 2025, and the grantees consent to recordation thereof by its duly authorized agent.

Dated:______________

CITY OF BANNING
By_________________________
Vicky Sellers
City Clerk
571
572
573
EXHIBIT “A”

LEGAL DESCRIPTION
(Attached)
574
575
576
577
578
579
580
581
582
583
EXHIBIT “B”

DEPICTION
(Attached)
584
585
586
587
588
589
590
591
592
593

CERTIFICATE OF ACCEPTANCE
(California Government Code Section 27281)
This is to certify that the interest in real property conveyed to the City of Banning by that certain Temporary Construction Easement dated __, 2025, executed by _____________ on behalf of __________________, is hereby accepted by the undersigned on behalf of the City of Banning pursuant to authority conferred by City Council on ________________2025 and the City of Banning consents to recordation thereof by its duly authorized officer.

Dated: ____________, 2025

CITY OF BANNING,
a municipal corporation,
By: ____________________________________
594

CITY OF BANNING

STAFF REPORT
TO: CITY COUNCIL
FROM: Robert Fisher, Acting City Manager
PREPARED BY: Shah Nawaz, Deputy Water/Wastewater Director Art Vela, Director of Public Works
MEETING DATE: July 8, 2025
SUBJECT: City of Banning’s Hexavalent Chromium Compliance Plan RECOMMENDATION:

Receive and file.

BACKGROUND:

The City of Banning (‘City’) operates multiple groundwater production wells that are critical to its municipal water supply. In June 2023, the California State Water Resources Control Board Division of Drinking Water (SWRCB-DDW) released SWRCB-DDW-21-003, an order of a proposed new maximum contaminant level (MCL) for Hexavalent Chromium (Cr6) of 10 parts per billion (ppb) in drinking water.

Furthermore, this Order required an initial Cr6 MCL sampling by April 1, 2025, and a compliance timeline (Cr6 Compliance Plan) within 90-days after initial sampling.

Chromium is a metal found in natural deposits of ores containing other elements, mostly as chrome iron ores. It is also widely present in soil and plants. Under most conditions, natural chromium in the environment occurs as Trivalent Chromium (Cr3), but under oxidizing conditions chromium can exist as Hexavalent Chromium (Cr6). Chromium also originates as a contaminant in the environment from the discharges of dye and paint pigments, wood preservatives, chrome-plating liquid wastes, and leaching from hazardous waste sites. At an MCL of 10 ppb (equivalent to 10 drops of water in a 100,000 gallon water tank), the health risk from hexavalent chromium in drinking water is limited to a one-in-twothousand chance of developing cancer during a lifetime (70 years) of exposure.

Since 1977, California has regulated Total Chromium (Cr3 and Cr6) at a MCL of 50 ppb. The United States Environmental Protection Agency (EPA) had also adopted the 50 ppb standard, but in 1991 raised it to the current standard of 100 ppb. Initially, in 2014, the California SWRCB established a Cr6 MCL of 10 ppb. However, California was sued over this regulation in 2017 and the Superior Court of Sacramento County ruled that the state “did not adequately document why the MCL was economically feasible.” Economic feasibility evaluates how costly Cr6 treatment technologies are and whether the price tag is within a water utility’s budget.

Since the Superior Court's invalidation of the Cr6 MCL, the State continued to work on establishing a new MCL for Cr6. In 2020, SWRCB published a white paper "Discussion on Economic Feasibility Analysis in Consideration of a Hexavalent Chromium Maximum Level". In 2023, the SWRCB started the formal rulemaking process for establishing a new Cr6 MCL and in 2024 adopted the new regulation setting the Cr6 MCL at 10 ppb, which became effective on October 1, 2024.

The City’s water division was expecting many wells to test positive for Cr6 and the initial water quality 595
sampling results due prior to April 1, 2025 indicated that four (4) of the City’s 21 municipal wells exceeded the newly established MCL, thus requiring regulatory compliance through mitigation. It shall also be noted that another 5 wells are either at or very close to the MCL, refer to table below for Cr6 MCL results:

Well Cr6 MCL (ppb) Well Capacity (gpm)
C2A 16 1,100
C3 14 1,100
C4 12 1,300
C6 12 900
M10 10 800
M11 10 800
C5 9.5 900
M3 8.3 800
C8 * 1,000
* The compliance MCL for recently drilled well C8 which is currently being equipped will be reported once sampled during production (during development of well C8, it resulted in 12 ppb).

Since the initial Cr6 MCL rulemaking in 2014, the City anticipated many wells to test positive for Cr6; therefore, it conducted several studies throughout the years to evaluate different approaches for complying with the Cr6 MCL:
2016 Cr6 Compliance Study – initial evaluation of treatment options and costs. 2022 Cr6 Compliance Study Updates – update to the original 2016 Cr6 compliance study, incorporating treatment technology advancements and updating costs. 2024 Cr6 Compliance Study Update – system-wide update to the 2022 Cr6 compliance study providing cost and non-cost (reliability and resiliency, operations and maintenance complexity, water loss, residuals handling, environmental and community impacts) analysis of options.

The objective of the 2024 Cr6 Compliance Study was to evaluate options for addressing Cr6 and to develop cost estimates including capital, operations and maintenance all to support the development of a treatment strategy for compliance. The 2024 Cr6 Compliance Study evaluated best available technologies (BATs) including weak base anion exchange (WBA), strong base anion exchange (SBA) and reduction coagulation and filtration/microfiltration (RCF/RCMF).

BATs were assessed based on lifecycle costs and operability considerations (chemical consumption, residual waste generation, and staffing requirements). While the accuracy range of lifecycle costs overlap for alternatives, it was found that the RCF with horizontal filter configuration located at the clustered treatment facilities and individual sites was the lowest point estimate lifecycle cost compared with WBA and SBA.

It shall be noted that the 2024 Cr6 Compliance Study did not evaluate include any non-treatment options i.e., existing well screen modifications, blending, repurposing potable wells to non-potable, or drilling new wells.

JUSTIFICATION:

The objective of this Compliance Plan is for the City to come into compliance with the established MCL via RCF treatment or non-treatment options (e.g. existing well screen modifications, blending, repurposing potable wells to non-potable, or drilling new wells). Prior to doing so, the City plans to take a wholistic approach to meet the stated objective by achieving the following milestones listed below:
i. Well profile to determine well screen modification opportunities for reducing levels of Cr6 below the MCL; and
ii. Hire an owner’s advisor (consultant) to evaluate and design treatment and non-treatment options, 596
prepare plans, specifications, capital and annual operations and maintenance costs; and iii. Raise capital via grants, rate increases, loans, bond issuance, etc., to implement the City’s compliance strategy; and
iv. Construct treatment and/or non-treatment improvements and proceed with operations.

Since the 2024 Cr6 Compliance Study did not evaluate any non-treatment options, it would be fiscally and operationally prudent for the City to explore these options first. As indicated above, Cr6 levels were detected in 9 wells, but only 4 wells exceeded the MCL. However, based on the initial Cr6 sampling results, there are 5 additional wells (as listed in table above) that may exceed the MCL in the future; therefore, to be proactive, the City will take a system-wide approach and include these 5 additional wells as part of it’s compliance strategy.

It is anticipated that milestones listed above from well profiling to construction of treatment/non-treatment improvements will begin in 2025 and will last through mid-2033.

FISCAL IMPACT:

The 2024 Cr6 Compliance Study developed a high-level range of costs to treat 9 Cr6 wells consistent with Association for the Advancement of Cost engineering (AACE) Class 4 costs with an accuracy range of 30% to +50%, resulting in $23,200,000 to $84,700,000 with an additional $2,000,000 to $3,000,000 in annual operation and maintenance.

Although the Water Operations Fund (Fund 660) currently has an approximate revenue budget from metered sales of $13,000,000; it is important to note that the City’s current water rate structure does not support the required financial investment to comply with the new Cr6 regulation. A new rate study will need to be completed to determine the rate impacts. Staff will have to work on having more detailed cost estimates developed during the treatment/non-treatment design phase in order to include those costs in a future rate study.

Once the rate study is approved by the City Council, the City shall carry out a rate approval process in compliance with Proposition 218. Once rate increases are approved, the City will proceed with acquiring the necessary funding, likely through debt financing, to move forward with the identified compliance improvements. City staff also plans to aggressively seek grant funding for the implementation of the Compliance Plan.

ALTERNATIVES:

N/A
BUDGETED?:

No
CONTRACT/AGREEMENT:

No
ATTACHMENTS:

1. City of Banning Hexavalent Chromium Compliance Plan.pdf 597
City of Banning
Hexavalent Chromium Compliance Plan Report Page 1 of 6
City of Banning
Public Works Department
June 18, 2025
To: Mitchell Martinez, PE
Water Resources Control Engineer
Division of Drinking Water – Riverside District
2375 Northside Drive, Suite 100
San Diego, CA 92108
From: Shah Nawaz, PE, Deputy Water/Wastewater Director, City of Banning Art Vela, PE, Director of Public Works, City of Banning Perry Gerdes, Water/Wastewater Superintendent, City of Banning Agustine Garcia, Assistant Water/Wastewater Superintendent, City of Banning City of Banning – Hexavalent Chromium
Compliance Plan
Water System Name: City of Banning
Water System Number: CA3310006
Water System Size: 10,000 service connections or more
598
City of Banning
Hexavalent Chromium Compliance Plan Report Page 2 of 6
Table of Contents1. ..................................................................................... Introduction .................................................................................................................................. 3

1.1 Results of Initial Sampling for Cr6 MCL......................................................................................3

1.2 Background.................................................................................................................................3

2. Objectives and Approach.......................................................................................... 4

2.1 Objective .....................................................................................................................................4

2.2 Approach.....................................................................................................................................5

2.2.1 Dynamic Well Profiling...................................................................................................5

2.2.2 Design Phase.................................................................................................................5

2.2.3 Procure Capital Funding ................................................................................................5

2.2.4 Construction Phase........................................................................................................6

2.2.5 Operations Implementation Phase ................................................................................6 Appendix A: 2024 Chromium 6 Treatment and Compliance Technical Memorandum Update ...................................................................................................................... 1 List of Tables
Table 1-1: Well Cr6 MCL and Pumping Capacity .................................................................... 3 599
City of Banning
Hexavalent Chromium Compliance Plan Report Page 3 of 6

1. Introduction
The City of Banning (‘City’) operates multiple groundwater production wells that are critical to its municipal water supply. In June 2023, the California State Water Resources Control Board Division of Drinking Water (SWRCB-DDW) released SWRCB-DDW-21-003, a notice of a proposed new maximum contaminant level (MCL) for Hexavalent Chromium (Cr6) of 10 parts per billion (ppb) in drinking water.

Furthermore, this Order required an initial Cr6 MCL sampling by April 1, 2025, and a compliance timeline (Compliance Plan) within 90-days after initial sampling.

As predicted, the initial Cr6 water quality sampling indicated that four (4) of the City’s 21 municipal wells exceeded the newly established MCL, thus requiring regulatory compliance through mitigation.

1.1 Results of Initial Sampling for Cr6 MCL
The results of the initial sampling along with each well’s pumping capacity are listed in Table 1-1 below:

Table 1-1: Well Cr6 MCL and Pumping Capacity
Well Max Cr6 (ppb) Well Capacity (gpm)
C2A 16 1,100
C3 14 1,100
C4 12 1,300
C6 12 900
M10* 10 800
M11* 10 800
C5* 9.5 900
M3* 8.3 800
C8 - 1,000
Note: Wells with asterisk are at or near the MCL but have not exceeded.

Well C8 is currently being equipped, once equipped, Cr6 MCL will be reported once sampled during production (during testing/development of Well C8 in 2023, it tested at 12 ppb).

1.2 Background
The City’s Water Division was expecting many wells to test positive for Cr6; it conducted several studies to evaluate different approaches for complying with the Cr6 MCL:
• 2016 Cr6 Compliance Study – initial evaluation of treatment options and costs. • 2022 Cr6 Compliance Study Updates – update to the original 2016 Cr6 compliance study, incorporating treatment technology advancements and updating costs. • 2024 Cr6 Compliance Study Update – system-wide update to the 2022 Cr6 compliance study providing cost and non-cost (reliability and resiliency, operations and maintenance complexity, water loss, residuals handling, environmental and community impacts) analysis of options.
600
City of Banning
Hexavalent Chromium Compliance Plan Report Page 4 of 6
The objective of the 2024 Cr6 Compliance Study was to evaluate options for addressing Cr6 and to develop cost estimates including capital, operations and maintenance all to support the development of a treatment strategy. The 2024 Cr6 Compliance Study evaluated best available technologies (BATs) including weak base anion exchange (WBA), strong base anion exchange (SBA) and reduction coagulation and filtration/microfiltration (RCF/RCMF).

BATs were assessed based on lifecycle costs and operability considerations (chemical consumption, residual waste generation, and staffing requirements). While the accuracy range of lifecycle costs overlap for alternatives, it was found that the RCF with horizontal filter configuration located at the clustered treatment facilities and individual sites was the lowest point estimate lifecycle cost compared with WBA and SBA.

The 2024 Cr6 Compliance Study developed a high-level range of costs to treat nine (9) Cr6 wells consistent with Association for the Advancement of Cost engineering (AACE) Class 4 costs with an accuracy range of 30% to +50%, resulting in $23,200,000 to $84,700,000 with an additional $2,000,000 to $3,000,000 in annual operation and maintenance.

It is important to note that the City’s current water rate structure does not support the required financial investment to comply with the new Cr6 regulation. A new rate study will need to be completed to determine the rate impacts. Staff will have to work on having more detailed cost estimates developed in order to include those costs in a future rate study.

It shall also be noted that the 2024 Cr6 Compliance Study did not include any non-treatment options (existing well screen modifications, blending, repurposing potable wells to non-potable, or drilling new wells).

2. Objectives and Approach

2.1 Objective
The main objective of this Compliance Plan is for the City to come into compliance with the established MCL via RCF treatment or non-treatment options (e.g. existing well screen modifications, blending, repurposing potable wells to non-potable, or drilling new wells). Prior to doing so, the City plans to take a wholistic approach to meet the stated objective by achieving the following milestones listed below:

1. Well profile to determine well screen modification opportunities for reducing levels of Cr6 below the MCL; and

2. Hire an owner’s advisor (consultant) to evaluate and design treatment and non-treatment options, prepare plans, specifications, capital and annual operations and maintenance costs; and

3. Raise capital via grants, rate increases, loans, bond issuance, etc., to implement the City’s compliance strategy; and

4. Construct treatment and/or non-treatment improvements proceed with operations. 601
City of Banning
Hexavalent Chromium Compliance Plan Report Page 5 of 6

2.2 Approach
Since the 2024 Cr6 Compliance Study did not evaluate any non-treatment options, it would be fiscally and operationally prudent for the City to explore these options first. The City currently has 9 wells that were Cr6 has been detected, but only 4 wells have exceeded the MCL. However, based on the initial sampling results, there are 5 additional (as shown on Table 1-1) that may exceed the MCL in the future; therefore, to be proactive, the City will take a system-wide approach and include these 5 additional wells as part of it’s compliance strategy.

It is anticipated that milestones listed under section 2.1 from well profiling to construction of treatment/non-treatment improvements will begin in 2025 and will last through mid-2033. These tasks do overlap each other and a brief description of each milestone, and its timeline are listed below.

2.2.1 Dynamic Well Profiling
The City will conduct water quality “well profiling” to identify opportunities for well screen modifications to reduce levels of Cr6. Based on the collected information, detailed recommendations for zonal isolation, packer installation, or other mitigation measures to reduce or eliminate Cr6 from the production stream will be evaluated. It shall be noted that zonal isolation (screening off) will likely result in loss in production capacity. These recommendations will be further evaluated by the City’s owner advisor (OA) and evolve into detailed designed plans, specifications and construction cost estimates for bidding and construction purposes.

Task Timeline – This task is expected to begin in August 2025 through December 2026.

2.2.2 Design Phase
Towards the end of the dynamic well profiling project, the City will advertise a request for qualifications (RFQ) to hire an OA that will be tasked with evaluating the dynamic well profiling project’s recommendations and prepare detailed plans, specification and estimates. In addition, the OA team will review the 2024 Cr6 Compliance Study and guide the City towards critical decision making that will lead to a final compliance strategy, which will identify both treatment and/or non-treatment alternatives.

The design phase is critical and will be labor-intensive and comprehensive, as it will produce detailed plans, specifications and costs estimates for all 9 well sites. These costs estimates will be critical in order to procure the necessary capital funding for the Cr6 Compliance Plan improvements.

Task Timeline – This task is expected to begin in June 2026 through December 2028.

2.2.3 Procure Capital Funding
As previously stated, the Cr6 Compliance Plan improvements are not included in the current water rate structure. Once detailed cost estimates have been prepared by the OA, the City will need to hire consultant to prepare a Rate Study, which will include several public workshops. Once the Rate Study is approved by City Council, the City shall carry out a rate approval process in compliance with Proposition 218. The City anticipates the process of approving new rates (e.g. development of Rate Study and 602
City of Banning
Hexavalent Chromium Compliance Plan Report Page 6 of 6
Proposition 218 process) will take approximately 1.5 years. Once rate increases are approved, the City will proceed with acquiring the necessary funding, likely through debt financing, to move forward with the identified compliance improvements. The City also plans to aggressively seek grant funding.

Task Timeline – This task is expected to begin in June 2028 through December 2029.

2.2.4 Construction Phase
Once the City secures the necessary loans (and any available grants) to fund these projects, it will begin advertising bid packages in phases to ensure effective project funding, manageable construction schedules, and a positive cash flow balance. In addition, in order to maintain a reliable water supply source to meet the City’s demands, only a few wells will be improved per year.

Task Timeline – This task is expected to begin in March 2029 through December 2032.

2.2.5 Operations Implementation Phase
Depending on the type of improvement (treatment vs. non-treatment) the City will have an operations plan developed, which will be implemented immediately following construction and commissioning of the project.

Task Timeline – This task is expected to begin in January 2031 through June 2033. 603
City of Banning
Hexavalent Chromium Compliance Plan Report
Appendix A: 2024 Chromium 6 Treatment and
Compliance Technical Memorandum Update
604
City of Banning
Chromium 6 Treatment and Compliance Technical Memorandum Update Page 1 of 26 FINAL
May 8, 2025
To: Art Vela, PE, City of Banning
From: Nicole Blute, PhD, PE, Hazen and Sawyer
Stephen Diamond, PE, Hazen and Sawyer
Megan Watt, Hazen and Sawyer
Katelyn Nguyen, Hazen and Sawyer
Chris Portner, CEP, PE, Hazen and Sawyer
Banning – Chromium 6 Treatment and Compliance
Technical Memorandum Update
FINAL
605
City of Banning
Chromium 6 Treatment and Compliance Technical Memorandum Update Page 2 of 26 FINAL
Table of Contents

1. Introduction ............................................................................................................... 4

1.1 Background ................................................................................................................................. 4

1.2 Approach and Objectives ............................................................................................................ 5

2. Project Definition ....................................................................................................... 5

2.1 Raw Water Quality ...................................................................................................................... 5

2.1.1 Hexavalent Chromium and Total Chromium ................................................................. 5

2.2 Treated Water Quality Goals ...................................................................................................... 6

2.3 Treatment Flows ......................................................................................................................... 6

3. Technology Advances............................................................................................... 7

3.1.1 Strong Base Anion Exchange ........................................................................................ 7

3.1.2 Reduction, Coagulation, and Filtration/Microfiltration .................................................. 10

3.1.3 Weak Base Anion Exchange ....................................................................................... 11

4. Treatment Evaluation .............................................................................................. 12

4.1 Treatment System Conceptual Design ..................................................................................... 12

4.1.1 SBA .............................................................................................................................. 13

4.1.2 RCF .............................................................................................................................. 14

4.1.3 WBA ............................................................................................................................. 15

4.2 Residual Disposal ..................................................................................................................... 15

4.2.1 Sewer Capacity Analysis ............................................................................................. 16

4.2.2 SBA .............................................................................................................................. 17

4.2.3 RCF .............................................................................................................................. 17

4.2.4 WBA ............................................................................................................................. 18

5. Cost Estimating ....................................................................................................... 18

6. Technology Screening ............................................................................................ 19

6.1 Screening Results ..................................................................................................................... 21

7. Conclusions ............................................................................................................ 23

7.1 Next Steps ................................................................................................................................ 24

7.1.1 Piloting Options ............................................................................................................ 24 Appendix A: Sewer Capacity Analysis
Appendix B: Cost Estimates
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Appendix C: Hazen Converge Analysis
Appendix D: RCF Pilot Options
List of Figures
Figure 2-1: Banning Well Concentrations of Cr6 and Total Cr...................................................... 6 Figure 3-1: SBA Treatment Process Flow Diagram ....................................................................... 8 Figure 3-2: RCF Treatment Process Flow Diagram ..................................................................... 11 Figure 3-3: WBA Treatment Process Flow Diagram ................................................................... 12 Figure 4-1: Clustered and Individual Wellhead Treatment Locations.......................................... 13 Figure 4-2: Kutter’s Formula - Sewer Capacity ........................................................................... 16 List of Tables
Table 2-1: Design Cr6 Concentrations and Capacities of Tier 1 Wells .......................................... 6 Table 4-1: Well Utilization for O&M Estimates .......................................................................... 12 Table 4-2: SBA Design Criteria .................................................................................................... 13 Table 4-3: RCF Design Criteria .................................................................................................... 15 Table 4-4: WBA Design Criteria .................................................................................................. 15 Table 4-5: Sewer Accessibility ..................................................................................................... 17 Table 4-6: RCF Vertical Configuration Backwash Tank Sizing .................................................. 17 Table 4-7: RCF Horizontal Configuration Backwash Tank Sizing .............................................. 18 Table 5-1: Capital, O&M and Total Annual Cost Estimates of Different Treatment Strategies .. 19 Table 6-1: Explanations of Criteria Scoring Values ..................................................................... 20 Table 6-2: Weightings of Non-Cost Evaluation Criteria .............................................................. 21 Table 6-3: Unweighted Non-Cost Scores by Treatment Technology ........................................... 22 Table 6-4: Unweighted Total Project Annual Cost Scores by Treatment Technology ................ 22 Table 6-5: Hazen Converge and Sensitivity Analysis Ranking .................................................... 23 Table 7-1: RCF Pilot Quotations .................................................................................................. 24 607
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1. Introduction
The California State Water Resources Control Board Division of Drinking Water (SWRCB-DDW) released SWRCB-DDW-21-003, a notice of a proposed new maximum contaminant level (MCL) for hexavalent chromium (Cr6) of 10 micrograms per liter (µg/L) in drinking water in June 2023. The proposed rule is effective as of October 1st 2024, with a two-year Cr6 compliance timeline for systems serving 10,000 connections or greater. The two-year compliance timeline established under the effective Cr6 MCL includes initial Cr6 sampling by Apil 1, 2025 and compliance plans required 90-days after initial sampling for systems that exceedance the Cr6 MCL.

The City of Banning (Banning) has multiple wells with Cr6 concentrations exceeding the MCL. Banning retained Hazen and Sawyer (Hazen) to evaluate treatment options to comply with the MCLs at wells where the Cr6 concentrations exceed the MCL. This memorandum summarizes the results of this evaluation, including water quality data, assessment of treatment options including costs, and next steps for Banning to use wells without exceeding the MCLs. The study aimed to analyze the treatment technology alternatives through cost and non-cost factors such as performance, and to develop a compliance strategy.

1.1 Background
Two previous studies were completed, the Cr6 compliance study update in 2022 and the original evaluation completed in 2016, and the treatment technologies previously determined feasible were further assessed to identify a preferred approach for compliance.

Banning’s water system includes a total of twenty-one active groundwater wells, which are operated throughout the year as needed. Among these are three co-owned wells with the Beaumont-Cherry Valley Water District (BCVWD), where the City has rights to half of the capacity, which is accessed through an interconnection near the intersection of Highland Springs Avenue and Sun Lakes Boulevard. The wells range in depth from 1,000 to 1,500 feet. Several of the wells impacted by Cr6 pump water directly into the distribution system including wells C6, C8 (a potential new well), M3, M10, M11, and M12.

Meanwhile, Wells C2, C3, C4, and C5 pump into forebay tanks at the respective sites, after which the water is boosted into the distribution system. Additionally, the City has 13 existing reservoirs, including the forebay tanks at the wells C2, C3, C4, and C5, with a total above-ground storage capacity of 19.7 million gallons.

Banning has conducted several studies to evaluate the optimal approach for addressing the Cr6 MCL, including the:
• 2016 Cr6 Compliance Study – initial evaluation of treatment options and costs. • 2022 Cr6 Compliance Study Update – update to the original compliance study, incorporating treatment technology advancements and refreshing cost information. • 2024 Cr6 Compliance Study Update – system-wide update to the 2022 Cr6 compliance study providing cost and non-cost analysis of options (this document). 608
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1.2 Approach and Objectives
This technical memorandum (TM) was written in support of Banning to determine a treatment strategy for the SWRCB-DDW Cr6 MCL that is now final. To achieve this goal, the following objectives were undertaken:
• Evaluate options for addressing Cr6 at Banning’s sites. • Develop cost estimates, including capital, operation and maintenance (O&M), and lifecycle costs.

2. Project Definition
This section addresses the project water quality.

2.1 Raw Water Quality
Historical water quality information was reviewed in the 2015 Compliance Study to define treatment requirements, select applicable treatment technologies, and evaluate parameters that affect operational costs and available groundwater well data were compiled to create a water quality database for analysis at that time. More recent water quality data was available and used for this analysis compared to the 2023 Compliance Study Update, which also leverages the existing 2015 water quality data. The 2015 Compliance Study focused on Cr6 and co-occurring constituents such as arsenic, nitrate, sulfate, total dissolved solids (TDS), and volatile organic compounds that could impact treatment decisions. It also evaluated treatment decisions in relation to potential future regulations for emerging constituents, such as 1,4-dioxane, antimony, cobalt, chlorate, molybdenum, nitrosamines, perchlorate, selenium, strontium, and vanadium.

2.1.1 Hexavalent Chromium and Total Chromium
In the 2016 Compliance Study and 2022 Study Update, Cr6 and total chromium (Cr) data were analyzed to identify wells impacted by the draft maximum contaminant level (MCL) for Cr6 and to assess trends in chromium variability over time. Cr6 and Cr measurements were obtained using Environmental Protection Agency methods 218.6 and 200.8, respectively. No Cr6 samples appeared to be statistical outliers in the dataset, therefore treatment decisions were based on the highest observed Cr6 concentrations for conservatism.

Nine of the City’s twenty-one wells with Cr concentrations at or near the Cr6 MCL (wells C2, C3, C4, C5, C6, C8, M3, M10, M11). The average total Cr and Cr6 concentrations in City wells are shown in Figure 2-1, with error bars representing the maximum and minimum readings. 609
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Figure 2-1: Banning Well Concentrations of Cr6 and Total Cr

2.2 Treated Water Quality Goals
Based on a review of raw water quality and Cr6 regulations, the following Cr6 water quality objectives were identified:
• Establish compliance with the Cr6 MCL.
• Wells requiring Cr6 treatment will have a treated Cr6 concentration goal of less than 8.0 µg/L.

The target goal is less than the MCL to account for potential fluctuations in the raw water or treated water Cr6 concentration.

2.3 Treatment Flows
A summary of well data including the design capacity and the design Cr6 concentration used in this analysis is presented in Table 2-1.

Table 2-1: Design Cr6 Concentrations and Capacities of Tier 1 Wells Well Max Cr6 (µg/L) Well Capacity (gpm)
M10, M11 13 1,400
C2, C4, C8, M3 17 4,700
C3 16 1,100
C5 9.6 900
C6 14 900
0 5
10 15
20 25
30 MT 7
WELL 1
WELL 10WELL 11WELL 12
WELL 2WELL 3WELL 4WELL 5WELL 7WELL 8WELL 9
WELL C2WELL C3WELL C4WELL C5WELL C6WELL C8
WELL M3
WELL M10WELL M11
WELL M12A
Chromium Concentration (µg/L)
Cr6 Total Cr Cr6 MCL
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3. Technology Advances
Cr6 treatment technologies were assessed with respect to recent advancements in treatment processes and residuals management (including quantity and quality of waste generated and treatment and disposal options). Technologies evaluated included:
• Weak base anion exchange (WBA),
• Strong base anion exchange (SBA), and
• Reduction, coagulation, and filtration/microfiltration (RCF/RCMF).

Each of these treatment processes is characterized by a different approach to Cr6 removal. Key features of each technology along with their advantages and disadvantages were summarized in the 2016 Compliance Study and are not repeated here. The sections that follow briefly summarize the three technologies and discuss process optimization and waste management. Key advancements compared with the 2016 Compliance Study and 2022 update include:
• Horizontal filter vessels for RCF

3.1.1 Strong Base Anion Exchange
In the SBA process, water passes through a resin bed and removes Cr6 by replacing other negatively charged ions (e.g., chloride) on the resin with the Cr6 from the water. Particles are removed using bag or cartridge filters upstream to minimize pressure drop through the resin bed and avoid the need for backwashing. As the ion exchange capacity of the resin is consumed, the Cr6 concentration in the treated water gradually increases over time. Other ions in the water with a charge similar to Cr6, such as sulfate, can compete with Cr6 in the ion exchange process and lessen the Cr6 removal capacity of the resin bed. A process flow schematic depicting the SBA process is provided in Figure 3-1. 611
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Figure 3-1: SBA Treatment Process Flow Diagram
SBA is regenerated with a salt (brine) solution when the treated Cr6 concentration reaches a maximum acceptable level. Regeneration involves elution of the Cr6 off the resin into the brine, which restores the capacity of the resin for additional Cr6 removal. Pilot testing should be conducted to confirm throughput and resin regeneration procedure effectiveness.

Three different brine management approaches were considered in this analysis:
•
• Brine treatment with disposal of non-hazardous brine offsite (Option 1) • Brine treatment with disposal of non-hazardous brine into the sewer (Option 2) • Hauling hazardous brine for offsite treatment and/or disposal (Option 3) A discussion of these brine management approaches is provided below.

SBA Option 1 - Treatment with disposal off-site, including non-hazardous liquid waste and hazardous solid waste
In Option 1, onsite brine treatment would use ferrous chloride, aeration, and a filter belt press to separate non-hazardous liquid waste from hazardous solid waste. The brine treatment process will vary depending on the concentrations of various constituents (e.g. selenium, uranium) that may be present in Banning’s wells. The non-hazardous liquid waste and the hazardous solid waste can be separately hauled offsite for disposal at appropriate facilities. Regeneration steps that result in non-hazardous brine or slow rinse water 612
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can be recycled (2 bed volumes (BV) from the brine regeneration and 1 BV from the slow rinse). The first BV from the brine regeneration process yields non-saline water to be recycled. Sites without sewer access will need to haul 3 BV of fast rinse water offsite, which is assumed to be non-saline non-hazardous liquid waste. Experience at other utilities has shown that brine treatment can decrease disposal costs compared to hauling hazardous brine for treatment and disposal elsewhere.

Spent brine is characterized according to federal and California regulations for hazardous waste. In addition to the sanitary sewer limits for treated non-hazardous brine disposal, the uranium concentration may not exceed 4.5 mg/L based on the limit set forth by California Code of Regulations Title 17 §30253.

Pilot testing would need to be conducted to test brine and determine if uranium concentrations are below this threshold.

Solids generated during brine treatment will require analysis to determine if elevated levels of uranium are present, and whether the uranium content results in waste characterization as a technologically enhanced naturally occurring radioactive material (TENORM) or low-level radioactive waste (LLRW).

Solids with greater than or equal to 500 µg uranium per gram of solid (i.e., 0.05%) are classified as LLRW. Solids that have accumulated uranium but are below this value, are considered TENORM.

Disposal facilities and permitting requirements vary depending on the waste characterization.

Pilot testing is recommended on the solids generated if Banning is interested in conducting brine treatment. For this evaluation, sites without sewer access were assumed to have non-hazardous brine disposal and non-saline, non-hazardous waste, disposal off-site.

SBA Option 2 – Treatment and disposal of non-hazardous liquid waste to the wastewater treatment plant (WWTP) and hazardous solid waste off-site
In Option 2, brine is treated onsite with ferrous chloride, aeration, and filter belt press to separate nonhazardous liquid waste from hazardous solid waste. Regeneration steps that result in non-hazardous brine or slow rinse water are recycled (2 BV from the brine regeneration and 1 BV from the slow rinse). The first BV from the brine regeneration process yields non-saline water to be recycled. The non-hazardous saline liquid waste and non-hazardous non-saline liquid waste would be discharged to the sanitary sewer.

The hazardous solid waste is hauled offsite for disposal at an appropriate facility. The feasibility of this option would require further analysis and discussions with the WWTP.

To assess the feasibility of discharging brine to the sewer, industrial discharge limits to the WWTP should be further evaluated to determine the maximum concentration limits to ensure Cr6 and As concentrations do not exceed WWTP requirements. Pilot testing may be needed to prove discharge quality for permitting.

Solids generated during brine treatment will require analysis to determine if elevated levels of uranium are present, and whether the uranium content was characterized to determine whether the waste is considered a TENORM or LLRW. Solids with greater than or equal to 500 µg uranium per gram of solid (i.e., 0.05%) are classified as LLRW. Solids that have accumulated uranium but are below this value, are considered TENORM.
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SBA Option 3 - Disposal offsite without treatment as hazardous liquid waste In Option 3, brine is hauled off as-is, requiring treatment and/or disposal as hazardous liquid waste.

Regeneration steps that result in non-hazardous brine or rinse water are recycled. Hauling of hazardous brine would require the least amount of infrastructure but presents a risk to Banning for long-term liability or if the contracted company stops accepting the brine.

Hazen has conducted testing indicating the concentrations of constituents in the brine, such as Cr6, make the brine hazardous unless brine treatment is provided. Prior pilot testing results for another agency showed that one of the new resins, PGW6002E (Purolite®, King of Prussia, PA) had approximately 60% greater capacity compared with other resins on the market at only a 3% higher cost, resulting in proportionally less brine generation. On average, brine generation is 0.0125% of treated water flow, but varies based on sulfate concentration. However, piloting of this product would be required to confirm brine production at Banning’s wells.

Regeneration steps that result in non-hazardous brine or slow rinse water can be recycled (2 bed volumes (BV) from the brine regeneration and 1 BV from the slow rinse). The first BV from the brine regeneration process yields non-saline water to be recycled approximately. Sites without sewer access will need to haul offsite 3 BV of fast rinse water, which is assumed to be non-saline non-hazardous liquid waste for disposal offsite.

3.1.2 Reduction, Coagulation, and Filtration/Microfiltration The RCF process involves reduction of Cr6 to Cr3 followed by removal of particles by filtration, as shown in Equation 1 below.
(1) 3Fe2+ + CrO4
2− + 8H2O → 3 Fe(OH)3(s) + Cr(OH)3(s) + 4H+

As shown in Equation 1, reducing Cr6 to Cr3 converts ferrous iron into ferric iron. Cr3 attaches to ferric hydroxide precipitates that are then removed from the water by granular media or membrane filtration.

An alternative reductant chemical is stannous (tin) that could be used in place of ferrous iron. Since RCF with ferrous is currently the best available technology and use of stannous requires more testing, RCF with ferrous was considered in this comparative analysis. In a preliminary design phase and pilot testing, Banning may wish to consider the alternative coagulant.

Figure 3-2 illustrates a schematic of the RCF treatment process. Components in the RCF process include ferrous iron or stannous addition, a reduction tank or piping that provides time for ferrous iron to reduce Cr6 to Cr3 and coagulate, hypochlorite addition to oxidize the remaining ferrous iron to ferric iron, polymer addition to a rapid mixing tank to enhance floc formation (if granular filters), granular media filtration, and backwash recovery (Figure 3-2).
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Figure 3-2: RCF Treatment Process Flow Diagram
Instead of granular media filters, microfiltration (MF) could be used – a process termed RCMF. Testing indicates that granular media filters can reliably decrease total chromium to below 3 to 5 μg/L, while MF can decrease total chromium to below the method reporting limit of 1 μg/L. In general, raw water quality (e.g., sulfate) does not affect RCF and RCMF like it affects SBA. Since the proposed draft MCL is 10 μg/L, costs were considered for only RCF because the additional cost of using MF would not provide a regulatory benefit at this time.

3.1.3 Weak Base Anion Exchange
Weak Base Anion (WBA) resin effectively removes Cr6 from water, reducing it to trivalent chromium (Cr3) on the resin’s surface. Over time, as the resin’s capacity for Cr6 is gradually exhausted, Cr6 concentrations in the treated water begin to increase. When the Cr6 level exceeds the target threshold, the WBA resin is replaced rather than regenerated.

Figure 3-3 shows a schematic of the WBA treatment process. Before the ion exchange, suspended particles are removed from groundwater using bag or cartridge filters to minimize pressure drop in the resin bed and reduce the need for backwashing. WBA resins are pH-sensitive and work most effectively at a pH of approximately 6.0 for Cr6 removal. pH adjustment, typically achieved by adding carbon dioxide (CO2) or an acid (such as sulfuric or hydrochloric acid), is necessary to reach this range. The required dose of CO2 or acid depends on the groundwater’s alkalinity and initial pH. In this analysis, CO2 was selected for pH adjustment due to safety considerations associated with sulfuric acid. Banning wells have moderate alkalinity (approximately 130 mg/L as CaCO3), resulting in an estimated required CO2 dose of approximately 300 mg/L. Chemical expenses for pH adjustment were included in the O&M cost estimates.
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Figure 3-3: WBA Treatment Process Flow Diagram

4. Treatment Evaluation

4.1 Treatment System Conceptual Design
This section describes the conceptual designs and operating parameters that were used to calculate the well treatment system cost estimates for a specific treatment technology. Capital, annual O&M, and total annual costs were estimated for WBA, SBA, and RCF. This section describes the assumptions used to develop cost estimates. Well historical well utilization was used to estimate annual O&M costs for each treatment location and the utilization percentage is presented in Table 4-1. It should be noted that O&M costs for SBA are sensitive to the utilization percentage to estimate resin regeneration frequencies.

Table 4-1: Well Utilization for O&M Estimates
Well Well Capacity (gpm) Utilization %
M10, M11 1,400 9%
C2, C4, C8, M3 4,700 8%
C3 1,100 27%
C5 900 31%
C6 900 23%
The proposed clustered and wellhead treatment locations and proposed raw water transmission piping is shown in Figure 4-1. Individual wellhead treatment would require available footprint at each well site for the equipment associated with the type of selected treatment technology. An analysis of treatment options was completed in the prior Study 2022 and indicated the space constraints at Well C3 and C5. It was noted that Well C5 only has an available footprint of 1,000 ft2 and would require obtaining nearby land
for treatment, while Well C3 does not have available footprint for RCF and WBA, making those treatment technologies infeasible without the acquisition of land. 616
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Figure 4-1: Clustered and Individual Wellhead Treatment Locations

4.1.1 SBA
The brine handling strategy employed at an SBA treatment facility impacts the equipment needed at that location. The three SBA brine handling options, SBA Option 1, SBA Option 2, SBA Option 3 are further discussed in Section 3.1.1. The assumptions used for estimating SBA treatment system costs are shown in Table 4-2.

Table 4-2: SBA Design Criteria
Parameter Value Units
Vessel Diameter 10 ft
Resin Volume 368 cf
Vessel Area 78.54 sq ft
Hydraulic Loading Rate
(HLR) 15 (maximum) gpm/ft2
Empty Bed Contact Time
(EBCT) 2.0 – 4.0 min/vessel
Configuration Parallel (minimum 2) -
Full-time equivalents for
operation (FTE) 1.25 -
Resin life 7 years
Additional assumptions include:
• Bag filters for particle removal, resin regeneration, spent brine treatment process. 617
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• No caustic soda feed system.
• Resin regeneration frequency was based on maximum historical sulfate concentration in raw water, which was derived from full-scale experience showing bed volumes versus sulfate concentrations. Resin regeneration was assumed when the effluent Cr6 concentration reached 6 µg/L.
• The resin regeneration procedure consists of regen (12% brine, 4 BVs total comprised of 3 BVs to be recycled and 1 BV to waste), slow rinse (1 BV, recycled), and fast rinse (3 BVs, all to waste).
o Hazen is confirming recommended resin regeneration waste volumes with vendors.

For the SBA options, ranges are included in the O&M to represent the sensitivity of cost estimates to key assumptions, including:
• SBA Option 1 - This option includes on-site treatment of hazardous brine using ferrous chloride, aeration, and belt filter presses to convert it into non-hazardous brine suitable for offsite hauling, along with hazardous solids requiring disposal. Costs account for treatment and disposal of both non-hazardous liquid and hazardous solid wastes. The brine treatment process will vary depending on the constituents present and their concentrations (e.g., selenium, uranium), which may be variable depending on the well.
• SBA Option 2 - In this option, hazardous brine undergoes on-site treatment, with nonhazardous liquid waste discharged to a wastewater treatment facility and hazardous solids disposed of off-site. Costs include the treatment and disposal of both non-hazardous liquid and hazardous solids. The feasibility of this option depends on further analysis and coordination with the wastewater treatment facility.
• SBA Option 3 - This option involves hauling hazardous brine directly to a disposal facility as hazardous liquid waste. Costs exclude on-site brine treatment. Any bed volumes in the regeneration processes producing non-hazardous brine are recycled. Rinse water is disposed of as non-hazardous liquid waste.

4.1.2 RCF
For the RCF option, ferrous chloride as a bulk chemical was assumed as the coagulant. As discussed previously, other options (on-site generation or use of stannous chloride) could be considered in preliminary design. The assumptions used for estimating RCF treatment system costs are shown in Table 4-3. Sites without adequate sewer capacity assumed recycling the supernatant to the head of the plant and dewatering solids to be disposed of offsite. Site constraints will need to be evaluated further in preliminary design to confirm that placement of equipment is feasible with underground piping and other site features. Residual disposal is further discussed in Section 4.2. 618
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Table 4-3: RCF Design Criteria
Parameter Value Unit
Vessel Configuration Vertical Horizontal --
Vessel Diameter 12 10 ft
Number of Cells - 4 4
Reduction Time 2 min
Hydraulic Loading Rate 8 gpm/ft2
Media Sand/Anthracite type
Media Depth 3 ft
Freeboard 1.5 ft
Media Replacement (Attrition) 10% Annual
Ferrous Chloride Dose 2.0 mg/L (as Fe)
Sodium Hypochlorite Dose 3.5 mg/L
Non-ionic polymer (filter aid) 0.1 mg/L
Backwash Rate 15 gpm/ft2
Backwash Duration 10 min
Backwash Frequency 12 hours
FTE 1.5 -

4.1.3 WBA
The assumptions used for estimating WBA treatment system costs are shown in Table 4-4.

Table 4-4: WBA Design Criteria
Parameter Value Unit
Vessel Diameter 12 ft
Hydraulic Loading Rate 8 gpm/ft2
EBCT 4.0 min/vessel
Configuration Lead/lag -
Target pH 6.0 -
Anti-scalant Dose
(Polyphosphate) 1.0 mg/L
FTE 1.0 -
Resin Volume 420 cf
Resin Purolite S106

4.2 Residual Disposal
Residual disposal for the treatment technologies is a major factor in selection. This section describes the disposal options for SBA, WBA, and RCF and the impact of residuals disposal to the wastewater collection system.
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4.2.1 Sewer Capacity Analysis
A sewer capacity analysis was completed to evaluate if backwash flow rates can be accommodated in the system. The sewer capacity was calculated using Kutter’s formula (Figure 4-2) and depth to diameter (d/D) ratio per ASCE and WEF recommendation.

Figure 4-2: Kutter’s Formula - Sewer Capacity
The following coefficients and ratios were used as the basis of the analysis:
• Manning’s roughness coefficient (n):
o Vitrified Clay Pipe: n = 0.013
o Polyvinyl Chloride Pipe n = 0.007
• Flow depth to diameter ratio:
o When D > 15”, d/D ≤ 75 %
o When D ≤ 15”, d/D ≤ 50%
City land use via the 2016 City of Banning General Plan was used. Each site was reviewed to confirm the sewer connection location and the downstream gravity mains were analyzed until they no longer had adequate capacity or until a connection to a trunk line. Trunk lines are found along Westward Avenue and Portner Street. Table 4-5 summarizes the full flow sewer capacity for each proposed treatment site.

However, sewer modeling was not conducted within this study to determine available sewer capacity.

Appendix A contains sewer capacity calculations.
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Table 4-5: Sewer Accessibility
Plant Name Sewer Access Sewer Full Flow
Capacity (cfs)
M10, M11 Yes 75.8
C2, C4, C8, M3 Yes 3.3
C3 Yes 1.8
C5 Yes 8.5
C6 Yes 0.7

4.2.2 SBA
Without brine treatment onsite, the brine would need to be transported to a facility for treatment and/or disposal. The treatment of brine onsite to render it non-hazardous could make it feasible to discharge the brine to the sewer if sewer access for brine disposal is available. The advantage of this approach is that it eliminates hauling and disposal of the non-hazardous brine, but the disadvantage is increased salt loading into the sewer and the wastewater treatment plant (WWTP), which can affect the ability to satisfy the TDS limit in the Waste Discharge Requirements (WDR). The current WDR of the City WWTP limits the TDS discharged from that facility to 300 mg/L higher than the domestic water supply. An analysis presented in that WDR noted that the average TDS increase over the domestic water supply was about 220 mg/L from 2011 to 2015. As the previous 2023 Study Update estimates, the cumulative effect of all treatment systems may increase the average TDS to exceed the WDR TDS limit of 300 mg/L, indicating this approach may not be an option that could be implemented at all well treatment locations without revisions to the WDR.

4.2.3 RCF
RCF generates backwash waste that either requires disposal to the sewer or treatment to separate the backwash water from the solids so the water can be recycled to the head of the plant and the solids can be transported offsite for disposal. A conservative estimate was used to determine if the discharge of filter backwash water from RCF would impact the sewer capacity. If the backwash discharge was less than 10% of the total sewer capacity, backwash discharge to sewer was assumed to be potentially feasible.

However, if the backwash discharge exceeded 10% then further analysis is recommended to confirm backwash discharge feasibility. Backwash flows from both horizontal and vertical filter vessels were evaluated. Table 4-6 presents the full flow sewer capacity compared to the discharge rates from backwashing vertical filter vessels and the backwash volume. This analysis indicates discharging attenuated backwash flow via a backwash holding tank would result in the discharge flow being under 10% and therefore assumed to be feasible at a number of sites. Table 4-7 summarizes the discharge flows for horizontal vessel configuration and backwash volumes.

Table 4-6: RCF Vertical Configuration Backwash Tank Sizing Plant Backwash Volume
(gallons)
Peak Backwash
Flow for Sewer
Discharge (cfs)
Percent of Sewer
Capacity
Iron (as Fe) to
Sewer (mg/L)
M10, M11 43,529 0.16 0.2% 52.9
C2, C4, C8, M3 191,788 0.71 21.6% 37.5
C3 41,129 0.15 8.8% 42.0
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Plant Backwash Volume
(gallons)
Peak Backwash
Flow for Sewer
Discharge (cfs)
Percent of Sewer
Capacity
Iron (as Fe) to
Sewer (mg/L)
C5 40,529 0.15 3.6% 39.1
C6 39,929 0.15 22.2% 36.1
Table 4-7: RCF Horizontal Configuration Backwash Tank Sizing Plant Backwash Volume
(gallons)
Peak Backwash
Flow for Sewer
Discharge (cfs)
Percent of Sewer
Capacity
Iron (as Fe) to
Sewer (mg/L)
M10, M11 44,800 0.17 0.2% 51.2
C2, C4, C8, M3 140,000 0.52 15.8% 51.5
C3 33,600 0.12 7.1% 51.4
C5 30,800 0.11 3.3% 51.8
C6 15,558 0.10 15.1% 51.1

Sites with backwash discharge exceeding 10% of the sewer capacity were bolded in Table 4-6 and Table 4-7 above and were initially flagged as requiring further analysis to determine the current sewer usage and available capacity. After discussions with Banning, it was noted that sewer at Well C6 does not have high usage and therefore may be able accommodate discharge flows from Well C6. However, further analysis is recommended at Foothill Cluster (C2, C4, C8, M3) to confirm the available capacity accounting for demands from other sources.

4.2.4 WBA
WBA resin will accumulate uranium, and the disposal will vary depending on the concentration of that element. Spent resin is expected to be a hazardous waste due to a high Cr concentration above the California Total Threshold Limit Concentration (TTLC), as experienced at the Glendale, CA Cr6 treatment facility. Due to the removal and concentration of naturally occurring uranium from source waters, the waste is likely to be a technologically enhanced naturally occurring radioactive material (TENORM) waste and may be a low-level radioactive waste (LLRW) that requires special disposal. The impact is additional cost and permitting complexity.

5. Cost Estimating
The ranges of costs developed reflect the accuracy of estimates at this phase of planning and are consistent with Association for the Advancement of Cost Engineering (AACE) Class 4 costs with an accuracy range of -30% to +50%. No design contingency was added to the estimate based on how the cost estimate was developed. Total annual costs are presented as the sum of annual O&M and capital debt service based on a 30-year lifecycle and assumed State Revolving Fund loan rate of 2%. Cost estimate details are included in Appendix B.

Cost estimates summarized in Table 5-1 are limited to sites that do not currently have treatment. The costs indicate that the ranges of capital, O&M, and annualized costs overlap within the accuracy range of the estimates.
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Chromium 6 Treatment and Compliance Technical Memorandum Update Page 19 of 26 FINAL
Table 5-1: Capital, O&M and Total Annual Cost Estimates of Different Treatment Strategies Well Name
Treatment Strategy Cost Estimates ($ Million)

WBA SBA
Option 1
SBA
Option 2
SBA
Option 3 RCF (H) RCF (V)
M10, M11 12.6 12.6 11.2 9.4 7.1 8.5
C2, C4, C8, M3 18.4 17.7 16.2 13.9 13.5 17.8
C3 8.1 8.7 8.7 6.4 4.3 6.3
C5 8.1 8.7 8.7 6.4 4.2 6.3
C6 8.1 8.7 8.7 6.4 4.0 6.3
Total Project Capital Costs (Sum
of capital costs for each site) 55.2 56.4 53.6 42.6 33.2 45.2 Total Project Capital Costs
Accuracy Range (-30 to +50%) 38.7 - 82.9 39.5 - 84.7 37.5 - 80.3 29.8 - 63.9 23.2 - 49.7 31.6 - 67.8 Total Project Annual O&M Costs
($M/Year):

Estimate

2.0 1.6 1.5 1.6 1.8 1.8
Total Project Annual O&M Costs
(Accuracy Range -30 to +50%,
$M/Year)

1.4 – 3 1.1 - 2.4 1.1 - 2.3 1.1 - 2.4 1.3 - 2.7 1.3 - 2.7 Total Project Annual Cost
(Annualized Capital + Annual
O&M) ($M/Year)

4.7 4.5 4.3 3.8 3.5 4.1
Total Project Annual Costs
(Annualized Capital + Annual
O&M Costs over Accuracy Range
of -30 to +50%, $M/Year)

3.3 - 7.1 3.1 - 6.7 3 - 6.4 2.6 - 5.7 2.4 - 5.2 2.9 - 6.2 General Notes: Values in the table are rounded to one decimal place. V = Vertical pressure vessels; H = Horizontal pressure vessels.

6. Technology Screening
Due to the overlap in technology costs observed in the 2022 Study Update, Hazen and Sawyer evaluated non-monetary factors that factor into selection of treatment technology. Total annual cost estimates and non-cost ranking criteria were developed to compare technologies that met Banning criteria to be considered for implementation.

Treatment options for Cr6 removal were first screened for critical flaws and the remaining options were then assessed using non-cost criteria. Treatment options were scored on a scale from 1 (least favorable) to 10 (most favorable) across criteria. Decision-making criteria are described below and scoring explanations are provided in Table 6-1.

Reliability and Resilience to Changing Water Quality – This criterion evaluates the treatment technology’s resilience to fluctuations in water quality, change in treatment goals long term performance, and impact from competing constituents.

O&M Complexity – This criterion evaluates the ease of operation and the magnitude of maintenance for a unit process.
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Water Loss – This criterion evaluates the amount of water loss associated with the treatment technology (e.g., regeneration waste or backwash water).

Residual Handling – This criterion indicates the complexity of disposal of liquid and solid waste and evaluates whether the waste is hazardous.

Environmental and Community Impacts – This criterion scores the ability of the selected treatment technology process to obtain permits and achieve community acceptance.

Table 6-1: Explanations of Criteria Scoring Values
Category Criteria Definition High Score Definition Low Score Definition Reliability and
Resilience
Reliability to Meet Cr6
Treatment Goal Treatment reliability
Treatment technology
is not limited to
reliability or
dependency on
vendors
Relatively low number of
vendors offering
treatment technology
approach or residual
disposal solutions
System resilience to
change
Ability to handle
fluctuations in water
quality or change in the
treatment goal without
significant operational
changes
Yes, without additional
operational cost
No, operational changes
and higher costs would
be realized
Impact from competing
constituents
Interfering constituents
(i.e., sulfate, silica, iron,
manganese)
High selectivity,
primary removal of
Cr(VI) only
Interfering constituents
decreasing Cr(VI)
removal efficiency
O&M
Complexity
Equipment complexity
Chemical feed system
requirements and the
need for constant
monitoring. Multiple
components require
frequent maintenance.

Very few feed systems
requiring little
monitoring/
maintenance
Multiple chemical feeds,
constant
monitoring/maintenance
Chemical deliveries Frequency of chemical
deliveries Less frequent More frequent
Number of full-time
employees needed
(FTEs)
The number of staff
required to maintain
operation and the need
for operator attention.

Low-level staffing
requirement
High-level staffing
requirement
Water Loss
Water loss to waste
associated from
process
Little to no water loss High water loss
Residuals
Handling
Complexity of Liquid
Waste Disposal
How complicated is
disposal of liquid
waste?
Not difficult Difficult
Offsite Disposal of
Solid Waste
How frequent are truck
trips to dispose of
waste offsite? Is solid
waste hazardous?
Less frequent and/or
non-hazardous
More frequent and/or
hazardous
Environmental /
Community
Impacts
Ability to obtain
environmental permits --
Low complexity to
obtain permits
High complexity to obtain
permits
Community acceptance --
Low Community
Acceptance
High Community
Acceptance
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Non-cost criteria weightings were developed in consultation with Banning, and Hazen’s multi-criteria decision analysis tool used these criteria and weightings as inputs to compare alternative technologies (Table 6-2). The scores assigned for each category were scaled based on the weightings to provide a total score for each technology out of a maximum of 100. The technologies included in this analysis were SBA Option 1, SBA Option 2, SBA Option 3, RCF and WBA.

Table 6-2: Weightings of Non-Cost Evaluation Criteria
Category Category Weight Criteria Criteria Weight in
Category
Ranking (Low to
High)
Reliability & Resiliency 30%
Reliability of LongTerm Performance 40% 1 – 10
System Resilience to
Change
30% 1 – 10
Impact from Competing
Constituents 30% 1 – 10
O&M 20%
Equipment Complexity 40% 1 – 10
Chemical Deliveries 50% 1 – 10
Number of FTE 10% 1 – 10
Water Loss 5% Water Loss 100% 1 – 10
Residuals Handling 30%
Disposal of Liquid
Waste 80% 1 – 10
Disposal of Solid
Waste 20% 1 – 10
Environmental /
Community 15%
Ability to Obtain
Environmental Permits 50% 1 – 10
Community
Acceptance 50% 1 – 10
Cost 20% Total Project Annual
Cost 100% 1 – 10

6.1 Screening Results
A summary the unweighted scores of the technologies for each non-cost criterion are shown in Table 6-3.

Key differentiating factors include:
• SBA has a good history of use, but all brine handling options include either hazardous liquid or hazardous solids.
• RCF is ranked the highest in terms of reliability and resilience, and residual handling, making RCF the favorable option for sites with high sulfate concentrations. Additionally, RCF has the highest community acceptance score due to less frequent truck trips, for chemicals and/or residual hauling.
• WBA has a relatively low equipment complexity. However, community acceptance is low due to noise of CO2 fills, and disposal of hazardous, LLRW spent resin is a consideration with this technology.
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Table 6-3: Unweighted Non-Cost Scores by Treatment Technology Category Criteria SBA
Option 1
SBA
Option 2
SBA
Option 3 WBA RCF
Reliability &
Resiliency
Reliability of LongTerm
Performance
10 10 10 10 10
System Resilience
to Change 8 8 8 10 10
Impact from
Competing
Constituents
4 4 4 6 10
O&M
Equipment
Complexity 4 4 6 9 8
Chemical
Deliveries 8 8 9 8 6
Number of FTE 8 8 8 9 7
Water Loss Water Loss 8 8 8 8 6
Residuals
Handling
Redundancy of
Liquid Waste
Disposal
2 10 2 8 10
Disposal of Solid
Waste 4 4 10 6 10
Environmental /
Community
Ability to Obtain
Environmental
Permits
6 6 6 6 6
Community
Acceptance 4 4 4 2 8
Total annual costs were scored on a site-specific basis to determine the treatment technology ranking for each location. The non-weighted scoring for the total annual project cost is presented in Table 6-4.

Table 6-4: Unweighted Total Project Annual Cost Scores by Treatment Technology Category RCF WBA SBA
Option 1
SBA
Option 2
SBA
Option 3
M10, M11 10 8 7 9 10
C2, C4, C8, M3 10 6 8 9 9
C3 10 8 9 9 10
C5 10 8 9 9 10
C6 10 8 8 8 9
Additionally, a sensitivity analysis was conducted to evaluate the impact of the cost vs. non-cost criteria.

In sensitivity analysis 1, the cost weighting was increased to 35% while the non-cost category weightings were decreased proportionally. In sensitivity analysis 2, the cost weightings were increased to 50% and the non-cost category weightings were proportionally decreased. Treatment alternative rankings for each location are presented in Table 6-5, with 1 as the highest ranking and 5 as the lowest ranking. RCF is ranked as the highest treatment alternative at all locations and in both sensitivity analysis 1 and 2. RCF is 626
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viewed as the preferred treatment technology to achieve Banning’s goals. The Hazen converge results for each site are presented in Appendix C.

Table 6-5: Hazen Converge and Sensitivity Analysis Ranking Category Criteria RCF WBA SBA
Option 1
SBA
Option 2
SBA
Option 3
M10, M11
Hazen Converge 1 2 4 3 5
Sensitivity Analysis #1 1 2 4 3 5
Sensitivity Analysis #2 1 3 5 2 4
C2, C4, C8, M3
Hazen Converge 1 2 4 3 5
Sensitivity Analysis #1 1 2 4 3 5
Sensitivity Analysis #2 1 2 5 3 4
C3
Hazen Converge 1 2 4 3 5
Sensitivity Analysis #1 1 2 4 3 5
Sensitivity Analysis #2 1 3 5 2 4
C5
Hazen Converge 1 2 4 3 5
Sensitivity Analysis #1 1 2 4 3 5
Sensitivity Analysis #2 1 3 5 4 2
C6
Hazen Converge 1 2 4 3 5
Sensitivity Analysis #1 1 2 4 3 5
Sensitivity Analysis #2 1 2 5 3 4

7. Conclusions
The best available technologies (BATs) evaluated for the City wells included WBA, SBA, and RCF.

Technologies were assessed based on lifecycle costs and operability considerations (chemical consumption, residuals waste generation, and staffing requirements). While the accuracy range of lifecycle costs overlap for each of the alternatives, it was found that the RCF with horizontal filter configuration located at clustered treatment facilities and individual sites was the lowest point estimate lifecycle cost compared with WBA and SBA. As the previous study indicated, there is not enough available footprint to house RCF and WBA equipment at Wells C3 and C5, making those treatment technologies infeasible at those locations without the acquisition of additional land.

RCF has the lowest annualized lifecycle costs of all treatment strategies, although there is considerable overlap between the lifecycle costs of the other technologies. WBA and SBA Option 1 had the highest capital cost and WBA has the highest O&M costs. SBA with onsite brine treatment had the lowest O&M costs, but had a higher lifecycle cost than RCF with either vertical or horizontal vessel configuration and SBA with no brine treatment. Due to the overlap in technology costs, Hazen and Sawyer evaluated nonmonetary factors that factor into selection of treatment technology, as outlined in Section 6 and 6.1. Total 627
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annual cost estimates and non-cost ranking criteria were developed to compare technologies and RCF ranked as the preferred treatment technology when considering cost and non-cost factors. This study focused on evaluating BATs (RCF, SBA, WBA) for the City wells and non-treatment solutions were not evaluated, further assessment is required to determine the potential for non-treatment solutions.

7.1 Next Steps
This study has developed a foundation for future work considerations as the City continues down the path of project implementation. Next steps for the City before, or during, preliminary design include:
• Further analysis of sewer disposal at C2, C4, C8, M3 to confirm available sewer capacity. • Confirm if brine can be sent to the wastewater reclamation facility. • Further assessment of site layouts for Wells C3 and C5, which may require the purchase of additional land.
• Consider pilot unit options to train operation staff in advance of design and/or startup.

7.1.1 Piloting Options
Banning is interested in acquiring a pilot system to provide training on the equipment for operators and optimize treatment design, as part of this study pilot system options were evaluated. The pilot configuration is intended to provide two minutes of reduction time for the ferrous chloride, multiple filter columns to evaluate various filter medias such as sand/anthracite, GreensandPlus, and pyrolusite, and chemical tanks for ferrous chloride, sodium hypochlorite, and polymer. Quotes for pilot systems were obtained from vendors and summarized in Table 7-1.

Table 7-1: RCF Pilot Quotations
Category
Purchase Lease
Skid Mounted Container/Trailer Mounted Trailer Mounted
Intuitech1 WQTS Intuitech1 Filtronics1 Tonka Tonka1
Cost $242,000 $325,000 $410,000 $85,000 $107,500 $32,500 (first week)
Additional
Add-on
Turbidity
Meters (Add
$22,000)
--
(fully customized
system)
Turbidity Meters
(Add $22,000)
Additional
Customization
Available
Additional
Tonka
Visits (Add
$7,000 per)
Additional Week
(Add $2,500 per)
Additional Tonka
Visits (Add $7,000
per)
Size 12.2’ L x 4.2’
W x 10.2’ H
10’ H x 10’ L x 2.83’
W2
20’ Enclosure 14’ trailer 20’ trailer 20’ trailer
Lead Time 6-7 months 6-7 months 6-7 months 2 – 3 months 3 months 1 – 1.5 months 1 Quote received is for a standard RCF pilot system, additional customization resulting in price change 2 Dimensions for the skid do not include additional chemical tanks and backwash tank 628
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Intuitech offers skid-mounted or containerized pilot systems, with the containerized option featuring air conditioning. The pilot system is fully automated with a SCADA system, enabling unmanned operation and offering optional turbidity meters and are available for purchase. WQTS provides skid-mounted pilot systems equipped with a fully automated SCADA system and a data logger. The WQTS systems include advanced features like pressure sensors, temperature sensors, turbidity meters, flow meters, and flow control valves. WQTS also allocates time for setup and training to ensure smooth pilot operation, and their systems are available for purchase. Filtronics delivers trailer-mounted pilot systems with automated filtration and semi-automatic electric valves, available for purchase. Tonka offers a trailer-mounted pilot system that is more manual but can be customized to meet specific needs. Tonka systems are available for lease or purchase. Specific quotation details for each pilot system can be found in Appendix D. 629
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Appendix A: Sewer Capacity Analysis
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1 Sewer Capacity Analysis
17 Background
18 • 5 treatment sites
• Foothill West Cluster (Wells C2, C4, C8, M3)• Well M10 + M11 Cluster• Well C3 Individual Treatment• Well C5 Individual Treatment• Well C6 Individual Treatment • Treatment Technology: RCF• Backwash Design Parameters:
• 15 gpm/ft2• Duration 10 mins• Media: Sand/Anthracite• Backwash estimated every 12 hours• Conservatively assumed no backwash to be recycled• Iron concentration to sewer was calculated as a function of the Ferrous dose
• Two potential vessel arrangements
• Horizontal Filter Vessels
• 4 cells per vessel
• Vertical Filter Vessels
• Assumptions
• Vertical
• Backwash volume is calculated assuming all duty vessels to be backwashed • Backwash volume for 12-hour period• Backwash waste to be discharged within 10 hours • Horizontal
• Backwash volume is calculated assuming 2 out of 4 cells to be backwashed per vessel within a 6-hour period
• Backwash waste to be discharged within 5 hours.
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2 Sewer Capacity Analysis Calculations
19 • Calculated design capacity using Kutter’s Formula & d/D ratio• Manning’s roughness coefficient (n):
• Vitrified Clay Pipe: n=0.013• Polyvinyl Chloride Pipe: n=0.007 • Flow depth to diameter ratio (d/D) per ASCE and WEF
recommendations
• When D > 15”, d/D ≤ 75 %• When D ≤ 15”, d/D ≤ 50%
• City land use via 2016 City of Banning General Plan• Analyze downstream until gravity main does not have adequate capacity or until it connects into trunk line
• Trunk lines are along Westward Avenue and Porter Street • Used a conservative estimate to determine if the discharge from RCF would impact sewer capacity.
• If the Discharge/Sewer Capacity was under 10%, backwash discharge was assumed to be feasible
Where
C = Chezy’s resistance coefficient
S = Slope
R = Hydraulic radius
n = Manning’s roughness coefficient
A = Area
Foothill West Cluster (Wells C2, C4, C8, M3)
20 • Sewer Capacity Analysis Findings:
• Vertical Configuration
• Discharge flow: 0.71 cfs• Sewer Capacity: 3.30 cfs• Discharge flow from backwash exceeds 10% of Highland Home Rd / Wilson St Sewer Capacity (21.59% Discharge/Capacity) – Further Sewer Analysis Required to determine available sewer capacity/other sewer flows. • Horizontal Configuration
• Discharge flow: 0.52 cfs• Sewer Capacity: 3.30 cfs• Discharge flow from backwash exceeds 10% of Highland Home Rd / Wilson St Sewer Capacity (15.76% Discharge/Capacity) – Further Sewer Analysis Required to determine available sewer capacity/other sewer flows. • Potential Solutions (if required):
• Treating wash water and recycling supernatant to head of plant • Increase capital and O&M cost for dewatering equipment and sludge disposal (haz.) • Individual RCF treatment instead of clustered treatment • Transmission pipe estimated capital cost $4 M• Individual wellhead RCF treatment estimate ($4 M - $8M) for depending on vessel configuration for design flows 1,000 – 1,600 gpm
• Alternate Treatment Technology (WBA or SBA)
• Conclusion:
• Flows exceed the sewer capacity screening criteria
used; however, further evaluation is required to confirm if discharging to sewer at Highland Home Rd / Wilson St. is feasible. 1920
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3 Foothill West Cluster (Wells C2, C4, C8, M3) - Calculations 21 Backwash Discharge Calculations
Vertical Configuration Sewer Capacity Analysis
% Full
(Cumulati
ve
Flow/Cap
acity)
Calculated
Discharge
Flow (cfs)
Design capacity
sewer (cfs) Segment Pipe
Site
Description
Street Name 3/4 Full
(> 15")
1/2
Full
(≤ 15")
*Slope
Nominal
Diameter
(in.)
DS
M.H. #
US
M.H. #
218 188 15 0.0024 3.30 - 0.71 21.59%
Foothill West
Cluster
Treatment
Site
Highland Home Rd/ Wilson St
Horizontal Configuration Sewer Capacity Analysis
% Full
(Cumulati
ve
Flow/Cap
acity)
Calculated
Discharge
Flow (cfs)
Design capacity
sewer (cfs) Segment Pipe
Site
Description
Street Name 3/4 Full
(> 15")
1/2
Full
(≤ 15")
*Slope
Nominal
Diameter
(in.)
DS
M.H. #
US
M.H. #
218 188 15 0.0024 3.30 - 0.52 15.76%
Foothill West
Cluster
Treatment
Site
Highland Home Rd/ Wilson St
Vertical Configuration
Foothill West
Cluster Parameter Units
Backwash duration min 600
gal 191,788 Backwash volume (for all duty vessels)
gpm 320
Backwash flow rate
cfs 0.71
Iron (as Fe) to Sewer from Ferrous mg/L 37.5
Horizontal Configuration
Foothill West
Cluster Parameter Units
Backwash duration min 600
gal 140,000 Backwash volume (for 2 out of 4 cells per vessel) gpm 233
Backwash flow rate
cfs 0.52
Iron (as Fe) to Sewer Ferrous mg/L 51.4
Sewer Capacity Calculations
M10 & M11 Cluster
22 • Sewer Capacity Analysis Findings:
• Vertical Configuration
• Discharge flow: 0.16 cfs• Sewer Capacity: 75.84 cfs• Discharge flow from backwash is under 10% of W Westward Ave Sewer Capacity (0.21% Discharge/Capacity) • Horizontal Configuration
• Discharge flow: 0.17 cfs• Sewer Capacity: 75.84 cfs• Discharge flow from backwash is under 10% of W Westward Ave Sewer Capacity (0.22% Discharge/Capacity) • Conclusion:
• Discharge rates to sewer from vertical or horizontal filter vessel configurations do not appear to present an issue for the available sewer capacity, based on the information provided 2122
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4 M10 & M11 Cluster - Calculations
23 Backwash Discharge Calculations
Vertical Configuration Sewer Capacity Analysis
% Full
(Cumulati
ve
Flow/Cap
acity)
Calculated
Discharge
Flow (cfs)
Design capacity
sewer (cfs) Segment Pipe
Site
Description
Street Name 3/4 Full
(> 15")
1/2
Full
(≤ 15")
*Slope
Nominal
Diameter
(in.)
DS
M.H. #
US
M.H. #
104 107 21 0.4080 - 75.84 0.16 0.21%
Well M10 and
M11 Cluster
Treatment Site
W Westward Ave
Horizontal Configuration Sewer Capacity Analysis
% Full
(Cumulati
ve
Flow/Cap
acity)
Calculated
Discharge
Flow (cfs)
Design capacity
sewer (cfs) Segment Pipe
Site
Description
Street Name 3/4 Full
(> 15")
1/2
Full
(≤ 15")
*Slope
Nominal
Diameter
(in.)
DS
M.H. #
US
M.H. #
104 107 21 0.4080 - 75.84 0.17 0.22%
Well M10 and
M11 Cluster
Treatment Site
W Westward Ave
Vertical Configuration
M10 and M11
Cluster Parameter Units
Backwash duration min 600
gal 43,529 Backwash volume (for all duty vessels)
gpm 73
Backwash flow rate
cfs 0.16
Iron (as Fe) to Sewer from Ferrous mg/L 52.9
Horizontal Configuration
M10 and M11
Cluster Parameter Units
Backwash duration min 600
gal 44,800 Backwash volume (for 2 out of 4 cells per vessel) gpm 75
Backwash flow rate
cfs 0.17
Iron (as Fe) to Sewer from Ferrous mg/L 51.4
Sewer Capacity Calculations
Well C5
24 • Sewer Capacity Analysis Findings:
• Vertical Configuration
• Discharge flow: 0.15 cfs• Sewer Capacity: 8.54 cfs• Discharge flow from backwash is under 10% of W Westward Ave Sewer Capacity (3.66% Discharge/Capacity) • Horizontal Configuration
• Discharge flow: 0.11 cfs• Sewer Capacity: 8.54 cfs• Discharge flow from backwash is under 10% of W Westward Ave Sewer Capacity (3.29% Discharge/Capacity) • Conclusion:
• Discharge rates to sewer from vertical or horizontal filter vessel configurations do not appear to present an issue for the available sewer capacity, based on the information provided 2324
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5 Well C5 - Calculations
25 Backwash Discharge Calculations
Vertical Configuration Sewer Capacity Analysis
% Full
(Cumulati
ve
Flow/Cap
acity)
Calculated
Discharge
Flow (cfs)
Design capacity
sewer (cfs) Segment Pipe
Site
Description
Street Name 3/4 Full
(> 15")
1/2
Full
(≤ 15")
*Slope
Nominal
Diameter
(in.)
DS
M.H. #
US
M.H. #
106 108 21 0.0052 - 8.54 0.15 3.66%
Well C5
Individual
Treatment Site
W Westward Ave
Horizontal Configuration Sewer Capacity Analysis
% Full
(Cumulati
ve
Flow/Cap
acity)
Calculated
Discharge
Flow (cfs)
Design capacity
sewer (cfs) Segment Pipe
Site
Description
Street Name 3/4 Full
(> 15")
1/2
Full
(≤ 15")
*Slope
Nominal
Diameter
(in.)
DS
M.H. #
US
M.H. #
106 108 21 0.0052 - 8.54 0.11 3.29%
Well C5
Individual
Treatment Site
W Westward Ave
Vertical Configuration
Parameter Units Well C5Backwash duration min 600
gal 40,529 Backwash volume (for all duty vessels)
gpm 68
Backwash flow rate
cfs 0.15
Iron (as Fe) to Sewer from Ferrous mg/L 39.1
Horizontal Configuration
Parameter Units Well C5Backwash duration min 600
gal 30,800 Backwash volume (for 2 out of 4 cells per vessel) gpm 51
Backwash flow rate
cfs 0.11
Iron (as Fe) to Sewer from Ferrous mg/L 51.4
Sewer Capacity Calculations
Well C3
26 • Sewer Capacity Analysis Findings:
• Vertical Configuration
• Discharge flow: 0.15 cfs• Sewer Capacity: 1.75 cfs• Discharge flow from backwash is under 10% of Brooklawn Dr Sewer Capacity (8.75% Discharge/Capacity)
• Horizontal Configuration
• Discharge flow: 0.12 cfs• Sewer Capacity: 1.75 cfs• Discharge flow from backwash is under 10% of Brooklawn Dr Sewer Capacity (7.14% Discharge/Capacity)
• Conclusion:
• Discharge rates to sewer from vertical or horizontal filter vessel configurations do not appear to present an issue for the available sewer capacity, given the information provided 2526
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6 Well C3 - Calculations
27 Backwash Discharge Calculations
Vertical Configuration Sewer Capacity Analysis
% Full
(Cumulati
ve
Flow/Cap
acity)
Calculated
Discharge
Flow (cfs)
Design capacity
sewer (cfs) Segment Pipe
Site
Description
Street Name 3/4 Full
(> 15")
1/2
Full
(≤ 15")
*Slope
Nominal
Diameter
(in.)
DS
M.H. #
US
M.H. #
134 133 8 0.0196 1.75 - 0.15 8.75%
Well C3
Individual
Treatment
Site
Brooklawn Dr
Horizontal Configuration Sewer Capacity Analysis
% Full
(Cumulati
ve
Flow/Cap
acity)
Calculated
Discharge
Flow (cfs)
Design capacity
sewer (cfs) Segment Pipe
Site
Description
Street Name 3/4 Full
(> 15")
1/2
Full
(≤ 15")
*Slope
Nominal
Diameter
(in.)
DS
M.H. #
US
M.H. #
134 133 8 0.0196 1.75 - 0.12 7.14%
Well C3
Individual
Treatment
Site
Brooklawn Dr
Vertical Configuration
Parameter Units C3 Backwash duration min 600
gal 41,129 Backwash volume (for all duty vessels)
gpm 69
Backwash flow rate
cfs 0.15
Iron (as Fe) to Sewer mg/L 42.0
Horizontal Configuration
Parameter Units C3 Backwash duration min 600
gal 33,600 Backwash volume (for 2 out of 4 cells per vessel) gpm 56
Backwash flow rate
cfs 0.12
Iron (as Fe) to Sewer mg/L 51.4
Sewer Capacity Calculations
Well C6
28 • Lincoln St Sewer Information – Insufficient
• Hand drawn records that don’t include elevation
• Only pipe segments and lengths • Assume backwash volume will be sent to gravity main on Barbour St instead • Sewer Capacity Analysis Findings:
• Vertical Configuration
• Discharge flow: 0.15cfs• Sewer Capacity: 8.54cfs• Discharge flow from backwash exceeds 10% of Barbour St Sewer Capacity (22.24% Discharge/Capacity) - Further Sewer Analysis Required to determine available sewer capacity/other sewer flows. • Horizontal Configuration
• Discharge flow: 0.10cfs• Sewer Capacity: 8.54cfs• Discharge flow from backwash exceeds 10% of Barbour St Sewer Capacity (15.14% Discharge/Capacity) - Further Sewer Analysis Required to determine available sewer capacity/other sewer flows. • Conclusion:
• Flows exceed the sewer capacity screening criteria used; however, further evaluation is required to confirm if discharging to sewer at Lincoln St and Barbour St is feasible. • Potential Solutions (if required):
• Treating wash water and recycling supernatant to
head of plant
• Increase capital and O&M cost for dewatering equipment and hazardous solids disposal
• Alternate Treatment Technology (WBA, or SBA)
2728
636
12/31/2024
7 Well C6 - Calculations
29 Backwash Discharge Calculations
Vertical Configuration Sewer Capacity Analysis
% Full
(Cumulati
ve
Flow/Cap
acity)
Calculated
Discharge
Flow (cfs)
Design capacity
sewer (cfs) Segment Pipe
Site
Description
Street Name 3/4 Full
(> 15")
1/2
Full
(≤ 15")
*Slope
Nominal
Diameter
(in.)
DS
M.H. #
US
M.H. #
101 102 8 0.0154 0.69 - 0.15 22.24% Well C6 Treatment Site Barbour St Horizontal Configuration Sewer Capacity Analysis
% Full
(Cumulati
ve
Flow/Cap
acity)
Calculated
Discharge
Flow (cfs)
Design capacity
sewer (cfs) Segment Pipe
Site
Description
Street Name 3/4 Full
(> 15")
1/2
Full
(≤ 15")
*Slope
Nominal
Diameter
(in.)
DS
M.H. #
US
M.H. #
101 102 8 0.0154 0.69 - 0.10 15.14% Well C6 Treatment Site Barbour St Vertical Configuration
Parameter Units C6Backwash duration min 600
gal 39,929 Backwash volume (for all duty vessels)
gpm 67
Backwash flow rate
cfs 0.15
Iron (as Fe) to Sewer mg/L 36.1
Horizontal Configuration
Parameter Units C6Backwash duration min 300
gal 15,558 Backwash volume (for 2 out of 4 cells per vessel) gpm 47
Backwash flow rate
cfs 0.10
Iron (as Fe) to Sewer mg/L 51.4
Sewer Capacity Calculations
29 637
City of Banning
Chromium 6 Treatment and Compliance Technical Memorandum Update FINAL B-1
Appendix B: Cost Estimates
638
City of Banning
Chromium 6 Treatment and Compliance Technical Memorandum Update FINAL B-2
WBA Cost Estimate Details
Description M10 & M11
Cluster
Foothill West
Cluster Well C3 Well C5 Well C6
Bag Filter $ 254,577 $ 280,543 $ 171,500 $ 171,500 $ 171,500 WBA $ 2,486,824 $ 5,194,763 $ 2,443,383 $ 2,443,383 $ 2,443,383 Carbon Dioxide $ 958,462 $ 972,863 $ 939,402 $ 939,402 $ 939,402 Chemical Dosing $ 96,567 $ 96,572 $ 96,565 $ 96,565 $ 96,565 Site Work $ 266,020 $ 414,088 $ 258,174 $ 258,174 $ 258,174 Yard Piping $ 560,703 $ 872,794 $ 544,169 $ 544,169 $ 544,169 Electrical and
Controls $ 1,292,432 $ 2,011,805 $ 1,254,319 $ 1,254,319 $ 1,254,319 Booster Pump $ 183,565 $ 183,573 $ 183,560 $ 183,560 $ 183,560 M12 Transmission
Pipe $ 1,612,000
Foothill Transmission
Pipe $ 3,150,000
Initial Fill $ 480,000 $ 940,000 $ 340,000 $ 340,000 $ 340,000 Probable
Construction Cost
(rounded):
$ 8,191,000 $ 14,117,000 $ 6,231,000 $ 6,231,000 $ 6,231,000 Engineering,
Construction
Management, Legal,
Administration (30%)
$ 2,457,300 $ 4,235,100 $ 1,869,300 $ 1,869,300 $ 1,869,300 Probable Project
Cost (rounded): $ 10,648,000 $ 18,352,000 $ 8,100,000 $ 8,100,000 $ 8,100,000 Annual O&M
($/Year) $ 332,000 $ 609,000 $ 378,000 $ 381,000 $ 320,000 Annualized Capital
and O&M ($M/Year) $ 0.88 $ 1.55 $ 0.79 $ 0.79 $ 0.73
639
City of Banning
Chromium 6 Treatment and Compliance Technical Memorandum Update FINAL B-3
SBA w/ On-site Brine Treatment and Off-site Disposal (Hauling) Cost Estimate Details Description M10 & M11
Cluster
Foothill West
Cluster Well C3 Well C5 Well C6
Bag Filter $ 254,654 $ 280,579 $ 171,566 $ 171,566 $ 171,566 SBA $ 2,069,515 $ 3,370,199 $ 2,096,560 $ 2,096,560 $ 2,096,560 Site Work $ 135,107 $ 206,577 $ 132,088 $ 132,088 $ 132,088 Yard Piping $ 284,773 $ 435,412 $ 278,410 $ 278,410 $ 278,410 Electrical and Controls $ 656,406 $ 1,003,636 $ 641,739 $ 641,739 $ 641,739 Booster Pump $ 183,619 $ 183,596 $ 183,631 $ 183,631 $ 183,631 On-Site Brine
Treatment $ 2,910,000 $ 2,928,000 $ 2,863,000 $ 2,863,000 $ 2,863,000 Offsite Brine Disposal $ 1,103,000 $ 1,103,000
M12 Transmission
Pipe $ 1,612,000
Foothill Transmission
Pipe $ 3,150,000
Initial Fill $ 480,000 $ 940,000 $ 340,000 $ 340,000 $ 340,000 Probable Construction
Cost (rounded): $ 9,689,000 $ 13,601,000 $ 6,707,000 $ 6,707,000 $ 6,707,000 Engineering,
Construction
Management, Legal,
Administration (30%)
$ 2,906,700 $ 4,080,300 $ 2,012,100 $ 2,012,100 $ 2,012,100 Probable Project
Cost (rounded): $ 12,596,000 $ 17,681,000 $ 8,719,000 $ 8,719,000 $ 8,719,000 Annual O&M ($/Year) $ 313,000 $ 406,000 $ 294,000 $ 295,000 $ 302,000 Annualized Capital
and O&M ($M/Year) $ 0.96 $ 1.31 $ 0.74 $ 0.74 $ 0.75
640
City of Banning
Chromium 6 Treatment and Compliance Technical Memorandum Update FINAL B-4
SBA w/ On-site Brine Treatment and Off-site Disposal to Sewer Cost Estimate Details Description M10 & M11
Cluster
Foothill West
Cluster Well C3 Well C5 Well C6
Bag Filter $ 254,654 $ 280,579 $ 171,566 $ 171,566 $ 171,566 SBA $ 2,069,515 $ 3,370,199 $ 2,096,560 $ 2,096,560 $ 2,096,560 Site Work $ 135,107 $ 206,577 $ 132,088 $ 132,088 $ 132,088 Yard Piping $ 284,773 $ 435,412 $ 278,410 $ 278,410 $ 278,410 Electrical and Controls $ 656,406 $ 1,003,636 $ 641,739 $ 641,739 $ 641,739 Booster Pump $ 183,619 $ 183,596 $ 183,631 $ 183,631 $ 183,631 On-Site Brine
Treatment $ 2,910,000 $ 2,928,000 $ 2,863,000 $ 2,863,000 $ 2,863,000 Offsite Brine Disposal $ 1,103,000 $ 1,103,000
M12 Transmission
Pipe $ 1,612,000
Foothill Transmission
Pipe $ 3,150,000
Initial Fill $ 480,000 $ 940,000 $ 340,000 $ 340,000 $ 340,000 Probable Construction
Cost (rounded): $ 9,689,000 $ 13,601,000 $ 6,707,000 $ 6,707,000 $ 6,707,000 Engineering,
Construction
Management, Legal,
Administration (30%)
$ 2,906,700 $ 4,080,300 $ 2,012,100 $ 2,012,100 $ 2,012,100 Probable Project
Cost (rounded): $ 12,596,000 $ 17,681,000 $ 8,719,000 $ 8,719,000 $ 8,719,000 Annual O&M ($/Year) $ 313,000 $ 406,000 $ 294,000 $ 295,000 $ 302,000 Annualized Capital
and O&M ($M/Year) $ 0.96 $ 1.31 $ 0.74 $ 0.74 $ 0.75
641
City of Banning
Chromium 6 Treatment and Compliance Technical Memorandum Update FINAL B-5
SBA w/ off-site Disposal No Treatment Cost Estimate Details Description M10 & M11
Cluster
Foothill West
Cluster Well C3 Well C5 Well C6
Bag Filter $ 254,654 $ 280,579 $ 171,566 $ 171,566 $ 171,566 SBA $ 2,069,515 $ 3,370,199 $ 2,096,560 $ 2,096,560 $ 2,096,560 Site Work $ 135,107 $ 206,577 $ 132,088 $ 132,088 $ 132,088 Yard Piping $ 284,773 $ 435,412 $ 278,410 $ 278,410 $ 278,410 Electrical and Controls $ 656,406 $ 1,003,636 $ 641,739 $ 641,739 $ 641,739 Booster Pump $ 183,619 $ 183,596 $ 183,631 $ 183,631 $ 183,631 Off-site Brine Disposal $ 1,103,000 $ 1,103,000 $ 1,103,000 $ 1,103,000 $ 1,103,000 M12 Transmission
Pipe $ 1,612,000
Foothill Transmission
Pipe $ 3,150,000
Initial Fill $ 940,000 $ 940,000 $ 340,000 $ 340,000 $ 340,000 Probable Construction
Cost (rounded): $ 7,239,000 $ 10,673,000 $ 4,947,000 $ 4,947,000 $ 4,947,000 Engineering,
Construction
Management, Legal,
Administration (30%)
$ 2,171,700 $ 3,201,900 $ 1,484,100 $ 1,484,100 $ 1,484,100 Probable Project
Cost (rounded): $ 9,411,000 $ 13,875,000 $ 6,431,000 $ 6,431,000 $ 6,431,000 Annual O&M ($/Year)
$ 310,000 $ 407,000 $ 294,000 $ 295,000 $ 302,000
Annualized Capital
and O&M ($M/Year) $ 0.79 $ 1.11 $ 0.62 $ 0.62 $ 0.63
642
City of Banning
Chromium 6 Treatment and Compliance Technical Memorandum Update FINAL B-6
RCF Horizontal Cost Estimate Details
Description M10 & M11
Cluster
Foothill West
Cluster Well C3 Well C5 Well C6
RCF $ 1,909,279 $ 4,012,215 $ 1,570,381 $ 1,496,977 $ 1,418,171 Chemical Dosing $ 193,192 $ 193,192 $ 193,192 $ 193,192 $ 193,192 Backwash $ 598,445 $ 856,526 $ 563,862 $ 563,862 $ 552,950 Site Work $ 145,718 $ 272,917 $ 125,596 $ 121,641 $ 116,808 Yard Piping $ 307,136 $ 575,242 $ 264,725 $ 256,390 $ 246,202 Electrical and Controls $ 707,954 $ 1,325,942 $ 610,197 $ 590,984 $ 567,501 M12 Transmission
Pipe $ 1,612,000
Foothill Transmission
Pipe $ 3,150,000
Probable Construction
Cost (rounded): $ 5,474,000 $ 10,386,000 $ 3,328,000 $ 3,223,000 $ 3,095,000 Engineering,
Construction
Management, Legal,
Administration (30%)
$ 1,642,200 $ 3,115,800 $ 998,400 $ 966,900 $ 928,500
Probable Project
Cost (rounded): $ 7,116,000 $ 13,502,000 $ 4,326,000 $ 4,190,000 $ 4,024,000 Annual O&M
($M/Year) $ 327,000 $ 426,000 $ 361,000 $ 351,000 $ 331,000 Annualized Capital
and O&M ($M/Year) $ 0.69 $ 1.11 $ 0.58 $ 0.56 $ 0.54

643
City of Banning
Chromium 6 Treatment and Compliance Technical Memorandum Update FINAL B-7
RCF Vertical Cost Estimate Details
Description M10 & M11
Cluster
Foothill West
Cluster Well C3 Well C5 Well C6
RCF $ 2,660,620 $ 6,127,074 $ 2,660,620 $ 2,660,620 $ 2,660,620 Chemical Dosing $ 193,192 $ 193,192 $ 193,192 $ 193,192 $ 193,192 Backwash $ 567,441 $ 1,075,721 $ 537,945 $ 537,945 $ 537,945 Site Work $ 184,526 $ 398,664 $ 182,936 $ 182,936 $ 182,936 Yard Piping $ 388,934 $ 840,285 $ 385,584 $ 385,584 $ 385,584 Electrical and Controls $ 896,500 $ 1,936,872 $ 888,780 $ 888,780 $ 888,780 M12 Transmission
Pipe $ 1,612,000
Foothill Transmission
Pipe $ 3,150,000
Probable Construction
Cost (rounded): $ 6,503,000 $ 13,722,000 $ 4,849,000 $ 4,849,000 $ 4,849,000 Engineering,
Construction
Management, Legal,
Administration (30%)
$ 1,950,900 $ 4,116,600 $ 1,454,700 $ 1,454,700 $ 1,454,700 Probable Project
Cost (rounded): $ 8,454,000 $ 17,839,000 $ 6,304,000 $ 6,304,000 $ 6,304,000 Annual O&M
($M/Year) $ 327,000 $ 426,000 $ 361,000 $ 351,000 $ 331,000 Annualized Capital
and O&M ($M/Year) $ 0.76 $ 1.34 $ 0.68 $ 0.67 $ 0.65
644
City of Banning
Chromium 6 Treatment and Compliance Technical Memorandum Update FINAL C-1
Appendix C: Hazen Converge Analysis
645
12/31/2024
1 Task 3 – Technology SelectionJuly 31, 2024
Chromium 6 Treatment and Compliance Technical Memo Updates Treatment Alternatives
2 • Weak Base Anion Exchange (WBA)• Strong Base Anion Exchange (SBA) Option 1 – Brine Treatment, Offsite Non-Hazardous Disposal
• SBA Option 2 – Brine Treatment, Sewer Disposal• SBA Option 3 – No Brine Treatment, Offsite Hazardous Disposal
• Reduction Coagulation Filtration (RCF)
12 646
12/31/2024
2 Hazen Converge Results
3 Hazen Converge Weightings
4 Ranking
(Low to High)
Criteria Weight in Category
Category CriteriaWeight
Category
40% 1 - 10 Reliability to Meet Cr6 Treatment Goal
Reliability & Resiliency 25% System Resilience to Change 30% 1 - 10 Impact from Competing Constituents 30% 1 - 10Equipment Complexity 40% 1 - 10 O&M 15% Chemical Deliveries 50% 1 - 10
Number of FTE 10% 1 - 10
Water Loss 5% Water Loss 100% 1 - 10
Disposal of Liquid Waste 80% 1 - 10
Residuals Handling 25%
Disposal of Solid Waste 20% 1 - 10
50% 1 - 10 Ability to Obtain Environmental Permits 10% Environmental / Community Community Acceptance 50% 1 - 10
Cost 20% Annualized Lifecycle Cost 100% 1 - 10
34 647
12/31/2024
3 Foothill West Cluster
5 M10 & M11 Cluster
6 56
648
12/31/2024
4 Well C3
7 Well C5
8 78
649
12/31/2024
5 Well C6
9 Sensitivity Analysis Rev #1
10 910
650
12/31/2024
6 Sensitivity Analysis #1 Weightings
11 Ranking
(Low to High)
Criteria Weight in Category
Category CriteriaWeight
Category
40% 1 - 10 Reliability to Meet Cr6 Treatment Goal
Reliability & Resiliency 22% System Resilience to Change 30% 1 - 10 Impact from Competing Constituents 30% 1 - 10Equipment Complexity 38% 1 - 10 O&M 13% Chemical Deliveries 47% 1 - 10
Number of FTE 16% 1 - 10
Water Loss 4% Water Loss 100% 1 - 10
Disposal of Liquid Waste 80% 1 - 10
Residuals Handling 20%
Disposal of Solid Waste 20% 1 - 10
50% 1 - 10 Ability to Obtain Environmental Permits 8% Environmental / Community Community Acceptance 50% 1 - 10
Cost 35% Annualized Lifecycle Cost 100% 1 - 10
Foothill West Cluster
12 1112
651
12/31/2024
7 M10 & M11 Cluster
13 Well C3
14 1314
652
12/31/2024
8 Well C5
15 Well C6
16 1516
653
12/31/2024
9 Sensitivity Analysis Rev #2
17 Sensitivity Analysis #2 Weightings
18 Ranking
(Low to High)
Criteria Weight in Category
Category CriteriaWeight
Category
43% 1 - 10 Reliability to Meet Cr6 Treatment Goal
Reliability & Resiliency 14% System Resilience to Change 29% 1 - 10 Impact from Competing Constituents 29% 1 - 10Equipment Complexity 60% 1 - 10 O&M 10% Chemical Deliveries 30% 1 - 10
Number of FTE 10% 1 - 10
Water Loss 4% Water Loss 100% 1 - 10
Disposal of Liquid Waste 57% 1 - 10
Residuals Handling 14%
Disposal of Solid Waste 43% 1 - 10
50% 1 - 10 Ability to Obtain Environmental Permits 8% Environmental / Community Community Acceptance 50% 1 - 10
Cost 50% Annualized Lifecycle Cost 100% 1 - 10
1718
654
12/31/2024
10 Foothill West Cluster
19 M10 & M11 Cluster
20 1920
655
12/31/2024
11 Well C3
21 Well C5
22 2122
656
12/31/2024
12 Well C6
23 Sensitivity Analysis Summary
24 Treatment Alternative Ranking Location Ranking Results RCF WBA SBA 1 SBA 2 SBA 3 Hazen Converge 1 2 4 3 5
Foothill West Cluster Sensitivity Analysis #1 1 2 4 3 5 Sensitivity Analysis #2 1 2 5 3 4Hazen Converge 1 2 4 3 5 M10 & M11 Cluster Sensitivity Analysis #1 1 2 4 3 5
Sensitivity Analysis #2 1 3 5 2 4Hazen Converge 1 2 4 3 5 Well C3 Sensitivity Analysis #1 1 2 4 3 5
Sensitivity Analysis #2 1 3 5 2 4Hazen Converge 1 2 4 3 5 Well C5 Sensitivity Analysis #1 1 2 4 3 5
Sensitivity Analysis #2 1 3 5 4 2Hazen Converge 1 2 4 3 5 Well C6 Sensitivity Analysis #1 1 2 4 3 5
Sensitivity Analysis #2 1 2 5 3 4
• Rankings are
assigned as 1 is the highest ranking and 5 is the lowest ranking 2324
657
12/31/2024
13 Cost Estimates
25 Capital, O&M, Lifecycle Cost Estimates
26 Annual Lifecycle
Cost ($M/Year)
Annual O&M
($M/Year)
Total Project
Capital Costs
($M)
Capital Costs ($M)
Treatment Strategy
Well C3 Well C5 Well C6
M10 &
M11
Cluster
Foothill
West
Cluster

16.1 13.4 5.0 5.0 5.0 31.2 to 66.8 1.1 to 2.4 2.7 to 5.8 SBA Option 1 (Brine Treatment Offsite Disposal)

14.7 12.0 5.0 5.0 5.0 29.2 to 62.5 1.1 to 2.3 2.6 to 5.5 SBA Option 2 (Brine Treatment Sewer Disposal)

12.6 10.5 5.0 5.0 5.0 26.7 to 57.1 1.1 to 2.4 2.5 to 5.3 SBA Option 3 (No Brine Treatment) WBA 17.1 11.7 8.1 8.1 8.1 37.2 to 79.7 1.4 to 3.0 3.3 to 7.1 RCF 14.8 10.7 7.3 7.3 7.3 33.2 to 71.2 1.3 to 2.8 3.0 to 6.4 2526
658
12/31/2024
14 O&M Cost Assumptions
27 O&M Cost Assumptions
28 Name Units Cost Treatment Technology
Electricity ($/kWh) $ 0.16 RCF, WBA, SBA Option 1, 2, and 3Labor Annual Salary ($/yr) $ 151,551.04 RCF, WBA, SBA Option 1, 2, and 3Sewer Discharge ($/cf) $ 3.15 RCF, WBA, SBA Option 1, 2, and 3Sewer Quarterly Fee ($/DEU/month) $ 945 RCF, WBA, SBA Option 1, 2, and 35% Ferrous Chloride ($/gal) $ 2.50 SBA Option 1 and 2Salt ($/ton) $ 147.59 SBA Option 1, 2, and 3Polymer ($/gal) $ 32.56 RCF, SBA Option 1 and 2 2728
659
12/31/2024
15 Questions
29 Question
30 • How does Banning intend on operating the wells/facilities; for compliance and to meet water demands?
2930
660
City of Banning
Chromium 6 Treatment and Compliance Technical Memorandum Update FINAL D-1
Appendix D: RCF Pilot Options
661
12/31/2024
1 RCF Piloting Options
2 Potential RCF Pilot PFD
23 662
12/31/2024
2 Pilot Configuration
Filter Media:• Anthracite/sand• GreensandPlus• Pyrolusite Reduction Time:• 2 minutes
Chemicals:• Ferrous chloride• Hypochlorite• Polymer
RCF Pilot Vendors
5 • Intuitech
• Skid Mounted or Containerized Pilot System
• Containerized system has AC
• Fully automated with SCADA System, ability to operate pilot unmanned
• Includes option for turbidity meters
• Pilot for Purchase
• WQTS
• Skid mounted pilot system• Fully automated SCADA system with data logger • Includes pressure sensors, temperature sensors,
turbidity meters, flow meters and flow control valves
• Includes allocated time for setup and training for pilot operation
• Pilot for Purchase
• Filtronics
• Trailer Mounted Pilot System• Automated filtration system with semi-automatic electric valves
• Pilot for Purchase
• Tonka
• Trailer Mounted System• More manual system quoted, but the pilot can be further customized.
• Pilot for Lease or Purchase
• Culligan
• Pilot for Purchase
• Pending quotation for purchase
• Pureflow
• Pilot for Lease
45 663
3 Configuration Options
6 • Skid Mounted
• Cost Range1 (Purchase): $242,000 - $400,000
• Enclosure Cost
• Cost estimate for enclosure/trailer only• Trailer: $116,000• Enclosure: $132,000 • Container/Trailer Mounted Pilot
• Cost Range (Purchase): $85,000 - $443,000• Lease Cost2: $32,000 • Chemical/Media Cost
• Estimated Chemical Cost: $400/month• Estimated Media Cost: ($1,500) 1Intuitech quote with and without turbidity meters2Cost includes 1 week of pilot rental with the vendor onsite for three (3) days allotted for set-up, tear-down, data collection, or etc.

RCF Pilot Estimates
7 Purchase Lease
Category
Skid Mounted Container/Trailer Mounted Trailer Mounted
Filtronics1 Tonka Tonka1 WQTS Intuitech1 Intuitech1
Cost $242,000 $325,000 $410,000 $85,000 $107,500 $32,500 (first week) Additional Week
(Add $2,500 per)
Additional Tonka Visits (Add
$7,000 per)
Additional Tonka
Visits (Add $7,000
per)
Additional
Customization
Available
Turbidity Meters
(Add $22,000)
--
(fully customized
system)
Turbidity Meters
(Add $22,000) Additional Add-on
20’ Enclosure 14’ trailer 20’ trailer 20’ trailer 10’ H x 10’ L x 2.83’ W2 12.2’ L x 4.2’ W x 10.2’ H Size Lead Time 6-7 months 6-7 months 6-7 months 2 – 3 months 3 months 1 – 1.5 months 1 Quote received is for a standard RCF pilot system, additional customization resulting in price change2 Dimensions for the skid do not include additional chemical tanks and backwash tank 67 664
4 Intuitech Pilot Details
8 Intuitech RCF Pilot
9 DESCRIPTION PART NUMBER COST
GRANULAR MEDIA FILTRATION PILOT PLANT1 F40610-SAP-41PC-4TU-4CF $243,459GRANULAR MEDIA FILTRATION PILOT PLANT F40610-SAP-41PC-0TU-4CF $221,707PILOT MODULE ENCLOSURE E201112-2ED-1SD-1PS-HVAC-SVN-FWS $168,042 $179,504
E401112-2ED-1SD-1PS-HVAC-SVN-4LABPILOT MODULE ENCLOSURE FWS STARTUP - 1 DAYS $5,633SHIPPING (EST) $14,145TAX TBD
1 Includes Turbidity Meters
Quotation Details:• Enclosure (Options)
• Plug and play ready for operation,
treatment modules will be prewired and pre-plumbed at the factory. • Allow for single electrical connection with
NEMA 4x panel and exterior electric disconnect panel
• Wall mount HVAC unit, AC, and heater
included
• Optional laboratory module included
cabinets, chemically resistant countertops, outlets, sink and water • 20’ Enclosure (Option)• 40’ Enclosure (Option)
• Turbidity Meters
• With or without turbidity meters
• First column can be configured as a reaction
vessel feeding into the three columns
• Quotation does not include chemicals or
media but does include equipment such as chemical tanks, pumps, etc. • Approximately 6-7 months lead time
89 665
5 Intuitech Pilot Additional Details
10 Example Specification
Maximum Total Flow Rate 5.2 gpm (19.7 L/min)Filters 4 @ 6 x 112 inch (152 x 2,840 mm)Maximum Media Depth 72 inch (183 cm)Media Retention Size > 0.0059 inch (149 µm)Filtration Rate 1.3…6.6 gpm/sf (3.2…16.1 m/h)Backwash Rate 5.1…51.0 gpm/sf (12.4…124.7 m/h)Backwash Tank Volume 150 gal (568 L) Air Scour Rate 2.6…9.2 scfm/sf (46.6…164.9 m/h)
Maximum Headloss 25 feet (7.6 m)Chemical Feed Systems 4Chemical Feed Rate 0.03…57 mL/minChemical Tank Volume 4 gallon (15.1 L) Dimensions 146 inch (3.71 m) L x 50 inch (1.27 m) W x 122.5 inch (3.11 m) HDry Weight 2,700 lbs. (1,315 kg)Operating Weight 4,200 lbs. (1,905 kg)Electrical Requirements 1 Phase, 18.8 A @ 120 VAC or 1 Phase, 9.4A @ 240 VAC, 50/60Hz Flow Rate, Headloss, Effluent Turbidity, and Column Level for each filter, Chemical Dosage, Chemical Flow, and Chemical Tank Level for each feed system, Air Scour Flow, Backwash Flow, Backwash Tank Level, Spare Analog Signals (3 qty.) Monitored Parameters
Filtronics Pilot Details
11 1011
666
6 Filtronics RCF Pilot
12 Quotation Details:• Purchase Cost: $85,000• Enclosure • Double-axle 14’ trailer (right)
• Fully Automated filtration system with semiautomatic electric valves• Standard quotation, depending on specifications, the final purchase cost could go up or down. • Lead time is approximately 6 – 8 weeks for
the trailer and an additional 2 – 4 weeks for filtration system assembly • Turnaround time is based on the
availability of the trailer.

WQTS Pilot Details
13 1213
667
7 WQTS RCF Pilot
14 Quotation Details:• General
• Number of Pre-Contactor Columns: 1 column
• Contactor Column Diameter: 6 inches• Contactor Column Height: 60 inches• Contactor Column Volume: 9.7 gallons 2.0 min. HRT with 3 filters at 8 gpm/sf
• Number of Filters: 3 columns• Filter Column Diameter: 6 inches• Filter Column Internal Height: 92 inches• Max Media Depth: 60 inches• Filter Loading Rate Range: 1.5-13 gpm/sf• Filter Flow Range: 0.3-2.6 gpm• Back Wash Air Scour Rate Range: 1 - 5 scfm/sf• Air Scour Flow Range: 0.2 - 1.0 scfm (5.6 - 21.8 slpm)• Backwash Loading Rate Range: 2.5-45 gpm/sf• Backwash Flow Range: 0.5-9 gpm• Number of Pre-Contactor/Filter Chemical Pumps: 5 pumps 2 for Pre-Contactor and 1 per Filter
• Feed Range: 0.035 - 69 mL/min• Number of Chemical Day Tanks: 5 tanks• Capacity of Chemical Day Tanks: 7 gallons• Number of Clearwell/Backwash Supply Tanks: 1 tank• Clearwell/Backwash Tank Volume: 200 gallon • Physical
• Assembled Dimensions: 120"H x 120"W x 34"D
• Electrical
• Phase: 1• Frequency: 60 Hz• Voltage: 120 VAC• Current: 20 amp max • Instrumentation
• Pressure Sensors: 4 Transducer Pre-contacor/1 per
Filter column*
• Temperature Sensor: 2 Transducer Inlfuent/Clearwell*• Turbidimeter: 3 online analyzers 1 per column*• Clearwell Tank Pressure Sensor: 1 Transducer Tank volume*
• Backwash Mag Flow Meter: 1 meter• Flow Conrol Valve/ Mag Meter: 3 meter/flow control Filter Flow rate*
• Mass Flow Controller: 1 controller• Electrical requirement: 120VAC/1PH/60HZ, 20 AMP Note: Chemical supply and backwash tank(s) not accounted for in pilot footprint. • Typical 7 gallon chemical tank 12”(W) x 12” (D) x 12” (H)• Typical 200 gallon backwash supply/clearwell tank 34”(Dia.) x 56” (H)
Tonka Pilot Details (Lease)
15 1415
668
8 Tonka RCF Pilot (Lease)
16 Quotation Details:• Lease Cost: $32,500
• Standard quotation, depending on specifications, the final cost could go up or down.• Including pilot for 1 week, with a technician onsite to set up equipment and train on-site personnel on operation.
• Tonka engineer will be available for the duration of the pilot for questions and consultation• Add-ons:
• Additional trips for Tonka support: $7,000.00 per trip• Additional time for pilot equipment rental $2,500.00 per week • Pilot Specifics
• 20’ trailer with 120V, 30A connection to power the pilot equipment • Miscellaneous equipment consisting of flexible tubes, valves, fittings, and other necessary appurtenances to provide a fully operable system.
• Fully Automated filtration system with semi-automatic electric valves • Three (3) 8” diameter media filtration columns (GreensandPlus , pyrolusite, and sand/anthracite) • Columns will have valve manifold to accommodate all modes of service and backwash and will include a loss of head gauge and sample taps.
• Filtration assembly is approx. 4’ x 8’ and height of approximately 8’ and requires a continuous flow. • The filter column is intended to be operated at 8 gpm/sft • (Optional) Detention basin(s) with multiple outlet ports to calibrate the desired amount of reduction time • Delivery is approximately 4 – 6 weeks after PO.
16 669
City of Banning
Chromium 6 Treatment and Compliance Technical Memorandum Update Page 1 of 26 FINAL
May 8, 2025
To: Art Vela, PE, City of Banning
From: Nicole Blute, PhD, PE, Hazen and Sawyer
Stephen Diamond, PE, Hazen and Sawyer
Megan Watt, Hazen and Sawyer
Katelyn Nguyen, Hazen and Sawyer
Chris Portner, CEP, PE, Hazen and Sawyer
Banning – Chromium 6 Treatment and Compliance
Technical Memorandum Update
FINAL
670
City of Banning
Chromium 6 Treatment and Compliance Technical Memorandum Update Page 2 of 26 FINAL
Table of Contents

1. Introduction ............................................................................................................... 4

1.1 Background ................................................................................................................................. 4

1.2 Approach and Objectives ............................................................................................................ 5

2. Project Definition ....................................................................................................... 5

2.1 Raw Water Quality ...................................................................................................................... 5

2.1.1 Hexavalent Chromium and Total Chromium ................................................................. 5

2.2 Treated Water Quality Goals ...................................................................................................... 6

2.3 Treatment Flows ......................................................................................................................... 6

3. Technology Advances............................................................................................... 7

3.1.1 Strong Base Anion Exchange ........................................................................................ 7

3.1.2 Reduction, Coagulation, and Filtration/Microfiltration .................................................. 10

3.1.3 Weak Base Anion Exchange ....................................................................................... 11

4. Treatment Evaluation .............................................................................................. 12

4.1 Treatment System Conceptual Design ..................................................................................... 12

4.1.1 SBA .............................................................................................................................. 13

4.1.2 RCF .............................................................................................................................. 14

4.1.3 WBA ............................................................................................................................. 15

4.2 Residual Disposal ..................................................................................................................... 15

4.2.1 Sewer Capacity Analysis ............................................................................................. 16

4.2.2 SBA .............................................................................................................................. 17

4.2.3 RCF .............................................................................................................................. 17

4.2.4 WBA ............................................................................................................................. 18

5. Cost Estimating ....................................................................................................... 18

6. Technology Screening ............................................................................................ 19

6.1 Screening Results ..................................................................................................................... 21

7. Conclusions ............................................................................................................ 23

7.1 Next Steps ................................................................................................................................ 24

7.1.1 Piloting Options ............................................................................................................ 24 Appendix A: Sewer Capacity Analysis
Appendix B: Cost Estimates
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Appendix C: Hazen Converge Analysis
Appendix D: RCF Pilot Options
List of Figures
Figure 2-1: Banning Well Concentrations of Cr6 and Total Cr...................................................... 6 Figure 3-1: SBA Treatment Process Flow Diagram ....................................................................... 8 Figure 3-2: RCF Treatment Process Flow Diagram ..................................................................... 11 Figure 3-3: WBA Treatment Process Flow Diagram ................................................................... 12 Figure 4-1: Clustered and Individual Wellhead Treatment Locations.......................................... 13 Figure 4-2: Kutter’s Formula - Sewer Capacity ........................................................................... 16 List of Tables
Table 2-1: Design Cr6 Concentrations and Capacities of Tier 1 Wells .......................................... 6 Table 4-1: Well Utilization for O&M Estimates .......................................................................... 12 Table 4-2: SBA Design Criteria .................................................................................................... 13 Table 4-3: RCF Design Criteria .................................................................................................... 15 Table 4-4: WBA Design Criteria .................................................................................................. 15 Table 4-5: Sewer Accessibility ..................................................................................................... 17 Table 4-6: RCF Vertical Configuration Backwash Tank Sizing .................................................. 17 Table 4-7: RCF Horizontal Configuration Backwash Tank Sizing .............................................. 18 Table 5-1: Capital, O&M and Total Annual Cost Estimates of Different Treatment Strategies .. 19 Table 6-1: Explanations of Criteria Scoring Values ..................................................................... 20 Table 6-2: Weightings of Non-Cost Evaluation Criteria .............................................................. 21 Table 6-3: Unweighted Non-Cost Scores by Treatment Technology ........................................... 22 Table 6-4: Unweighted Total Project Annual Cost Scores by Treatment Technology ................ 22 Table 6-5: Hazen Converge and Sensitivity Analysis Ranking .................................................... 23 Table 7-1: RCF Pilot Quotations .................................................................................................. 24 672
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1. Introduction
The California State Water Resources Control Board Division of Drinking Water (SWRCB-DDW) released SWRCB-DDW-21-003, a notice of a proposed new maximum contaminant level (MCL) for hexavalent chromium (Cr6) of 10 micrograms per liter (µg/L) in drinking water in June 2023. The proposed rule is effective as of October 1st 2024, with a two-year Cr6 compliance timeline for systems serving 10,000 connections or greater. The two-year compliance timeline established under the effective Cr6 MCL includes initial Cr6 sampling by Apil 1, 2025 and compliance plans required 90-days after initial sampling for systems that exceedance the Cr6 MCL.

The City of Banning (Banning) has multiple wells with Cr6 concentrations exceeding the MCL. Banning retained Hazen and Sawyer (Hazen) to evaluate treatment options to comply with the MCLs at wells where the Cr6 concentrations exceed the MCL. This memorandum summarizes the results of this evaluation, including water quality data, assessment of treatment options including costs, and next steps for Banning to use wells without exceeding the MCLs. The study aimed to analyze the treatment technology alternatives through cost and non-cost factors such as performance, and to develop a compliance strategy.

1.1 Background
Two previous studies were completed, the Cr6 compliance study update in 2022 and the original evaluation completed in 2016, and the treatment technologies previously determined feasible were further assessed to identify a preferred approach for compliance.

Banning’s water system includes a total of twenty-one active groundwater wells, which are operated throughout the year as needed. Among these are three co-owned wells with the Beaumont-Cherry Valley Water District (BCVWD), where the City has rights to half of the capacity, which is accessed through an interconnection near the intersection of Highland Springs Avenue and Sun Lakes Boulevard. The wells range in depth from 1,000 to 1,500 feet. Several of the wells impacted by Cr6 pump water directly into the distribution system including wells C6, C8 (a potential new well), M3, M10, M11, and M12.

Meanwhile, Wells C2, C3, C4, and C5 pump into forebay tanks at the respective sites, after which the water is boosted into the distribution system. Additionally, the City has 13 existing reservoirs, including the forebay tanks at the wells C2, C3, C4, and C5, with a total above-ground storage capacity of 19.7 million gallons.

Banning has conducted several studies to evaluate the optimal approach for addressing the Cr6 MCL, including the:
• 2016 Cr6 Compliance Study – initial evaluation of treatment options and costs. • 2022 Cr6 Compliance Study Update – update to the original compliance study, incorporating treatment technology advancements and refreshing cost information. • 2024 Cr6 Compliance Study Update – system-wide update to the 2022 Cr6 compliance study providing cost and non-cost analysis of options (this document). 673
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1.2 Approach and Objectives
This technical memorandum (TM) was written in support of Banning to determine a treatment strategy for the SWRCB-DDW Cr6 MCL that is now final. To achieve this goal, the following objectives were undertaken:
• Evaluate options for addressing Cr6 at Banning’s sites. • Develop cost estimates, including capital, operation and maintenance (O&M), and lifecycle costs.

2. Project Definition
This section addresses the project water quality.

2.1 Raw Water Quality
Historical water quality information was reviewed in the 2015 Compliance Study to define treatment requirements, select applicable treatment technologies, and evaluate parameters that affect operational costs and available groundwater well data were compiled to create a water quality database for analysis at that time. More recent water quality data was available and used for this analysis compared to the 2023 Compliance Study Update, which also leverages the existing 2015 water quality data. The 2015 Compliance Study focused on Cr6 and co-occurring constituents such as arsenic, nitrate, sulfate, total dissolved solids (TDS), and volatile organic compounds that could impact treatment decisions. It also evaluated treatment decisions in relation to potential future regulations for emerging constituents, such as 1,4-dioxane, antimony, cobalt, chlorate, molybdenum, nitrosamines, perchlorate, selenium, strontium, and vanadium.

2.1.1 Hexavalent Chromium and Total Chromium
In the 2016 Compliance Study and 2022 Study Update, Cr6 and total chromium (Cr) data were analyzed to identify wells impacted by the draft maximum contaminant level (MCL) for Cr6 and to assess trends in chromium variability over time. Cr6 and Cr measurements were obtained using Environmental Protection Agency methods 218.6 and 200.8, respectively. No Cr6 samples appeared to be statistical outliers in the dataset, therefore treatment decisions were based on the highest observed Cr6 concentrations for conservatism.

Nine of the City’s twenty-one wells with Cr concentrations at or near the Cr6 MCL (wells C2, C3, C4, C5, C6, C8, M3, M10, M11). The average total Cr and Cr6 concentrations in City wells are shown in Figure 2-1, with error bars representing the maximum and minimum readings. 674
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Figure 2-1: Banning Well Concentrations of Cr6 and Total Cr

2.2 Treated Water Quality Goals
Based on a review of raw water quality and Cr6 regulations, the following Cr6 water quality objectives were identified:
• Establish compliance with the Cr6 MCL.
• Wells requiring Cr6 treatment will have a treated Cr6 concentration goal of less than 8.0 µg/L.

The target goal is less than the MCL to account for potential fluctuations in the raw water or treated water Cr6 concentration.

2.3 Treatment Flows
A summary of well data including the design capacity and the design Cr6 concentration used in this analysis is presented in Table 2-1.

Table 2-1: Design Cr6 Concentrations and Capacities of Tier 1 Wells Well Max Cr6 (µg/L) Well Capacity (gpm)
M10, M11 13 1,400
C2, C4, C8, M3 17 4,700
C3 16 1,100
C5 9.6 900
C6 14 900
0 5
10 15
20 25
30 MT 7
WELL 1
WELL 10WELL 11WELL 12
WELL 2WELL 3WELL 4WELL 5WELL 7WELL 8WELL 9
WELL C2WELL C3WELL C4WELL C5WELL C6WELL C8
WELL M3
WELL M10WELL M11
WELL M12A
Chromium Concentration (µg/L)
Cr6 Total Cr Cr6 MCL
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3. Technology Advances
Cr6 treatment technologies were assessed with respect to recent advancements in treatment processes and residuals management (including quantity and quality of waste generated and treatment and disposal options). Technologies evaluated included:
• Weak base anion exchange (WBA),
• Strong base anion exchange (SBA), and
• Reduction, coagulation, and filtration/microfiltration (RCF/RCMF).

Each of these treatment processes is characterized by a different approach to Cr6 removal. Key features of each technology along with their advantages and disadvantages were summarized in the 2016 Compliance Study and are not repeated here. The sections that follow briefly summarize the three technologies and discuss process optimization and waste management. Key advancements compared with the 2016 Compliance Study and 2022 update include:
• Horizontal filter vessels for RCF

3.1.1 Strong Base Anion Exchange
In the SBA process, water passes through a resin bed and removes Cr6 by replacing other negatively charged ions (e.g., chloride) on the resin with the Cr6 from the water. Particles are removed using bag or cartridge filters upstream to minimize pressure drop through the resin bed and avoid the need for backwashing. As the ion exchange capacity of the resin is consumed, the Cr6 concentration in the treated water gradually increases over time. Other ions in the water with a charge similar to Cr6, such as sulfate, can compete with Cr6 in the ion exchange process and lessen the Cr6 removal capacity of the resin bed. A process flow schematic depicting the SBA process is provided in Figure 3-1. 676
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Figure 3-1: SBA Treatment Process Flow Diagram
SBA is regenerated with a salt (brine) solution when the treated Cr6 concentration reaches a maximum acceptable level. Regeneration involves elution of the Cr6 off the resin into the brine, which restores the capacity of the resin for additional Cr6 removal. Pilot testing should be conducted to confirm throughput and resin regeneration procedure effectiveness.

Three different brine management approaches were considered in this analysis:
•
• Brine treatment with disposal of non-hazardous brine offsite (Option 1) • Brine treatment with disposal of non-hazardous brine into the sewer (Option 2) • Hauling hazardous brine for offsite treatment and/or disposal (Option 3) A discussion of these brine management approaches is provided below.

SBA Option 1 - Treatment with disposal off-site, including non-hazardous liquid waste and hazardous solid waste
In Option 1, onsite brine treatment would use ferrous chloride, aeration, and a filter belt press to separate non-hazardous liquid waste from hazardous solid waste. The brine treatment process will vary depending on the concentrations of various constituents (e.g. selenium, uranium) that may be present in Banning’s wells. The non-hazardous liquid waste and the hazardous solid waste can be separately hauled offsite for disposal at appropriate facilities. Regeneration steps that result in non-hazardous brine or slow rinse water 677
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can be recycled (2 bed volumes (BV) from the brine regeneration and 1 BV from the slow rinse). The first BV from the brine regeneration process yields non-saline water to be recycled. Sites without sewer access will need to haul 3 BV of fast rinse water offsite, which is assumed to be non-saline non-hazardous liquid waste. Experience at other utilities has shown that brine treatment can decrease disposal costs compared to hauling hazardous brine for treatment and disposal elsewhere.

Spent brine is characterized according to federal and California regulations for hazardous waste. In addition to the sanitary sewer limits for treated non-hazardous brine disposal, the uranium concentration may not exceed 4.5 mg/L based on the limit set forth by California Code of Regulations Title 17 §30253.

Pilot testing would need to be conducted to test brine and determine if uranium concentrations are below this threshold.

Solids generated during brine treatment will require analysis to determine if elevated levels of uranium are present, and whether the uranium content results in waste characterization as a technologically enhanced naturally occurring radioactive material (TENORM) or low-level radioactive waste (LLRW).

Solids with greater than or equal to 500 µg uranium per gram of solid (i.e., 0.05%) are classified as LLRW. Solids that have accumulated uranium but are below this value, are considered TENORM.

Disposal facilities and permitting requirements vary depending on the waste characterization.

Pilot testing is recommended on the solids generated if Banning is interested in conducting brine treatment. For this evaluation, sites without sewer access were assumed to have non-hazardous brine disposal and non-saline, non-hazardous waste, disposal off-site.

SBA Option 2 – Treatment and disposal of non-hazardous liquid waste to the wastewater treatment plant (WWTP) and hazardous solid waste off-site
In Option 2, brine is treated onsite with ferrous chloride, aeration, and filter belt press to separate nonhazardous liquid waste from hazardous solid waste. Regeneration steps that result in non-hazardous brine or slow rinse water are recycled (2 BV from the brine regeneration and 1 BV from the slow rinse). The first BV from the brine regeneration process yields non-saline water to be recycled. The non-hazardous saline liquid waste and non-hazardous non-saline liquid waste would be discharged to the sanitary sewer.

The hazardous solid waste is hauled offsite for disposal at an appropriate facility. The feasibility of this option would require further analysis and discussions with the WWTP.

To assess the feasibility of discharging brine to the sewer, industrial discharge limits to the WWTP should be further evaluated to determine the maximum concentration limits to ensure Cr6 and As concentrations do not exceed WWTP requirements. Pilot testing may be needed to prove discharge quality for permitting.

Solids generated during brine treatment will require analysis to determine if elevated levels of uranium are present, and whether the uranium content was characterized to determine whether the waste is considered a TENORM or LLRW. Solids with greater than or equal to 500 µg uranium per gram of solid (i.e., 0.05%) are classified as LLRW. Solids that have accumulated uranium but are below this value, are considered TENORM.
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SBA Option 3 - Disposal offsite without treatment as hazardous liquid waste In Option 3, brine is hauled off as-is, requiring treatment and/or disposal as hazardous liquid waste.

Regeneration steps that result in non-hazardous brine or rinse water are recycled. Hauling of hazardous brine would require the least amount of infrastructure but presents a risk to Banning for long-term liability or if the contracted company stops accepting the brine.

Hazen has conducted testing indicating the concentrations of constituents in the brine, such as Cr6, make the brine hazardous unless brine treatment is provided. Prior pilot testing results for another agency showed that one of the new resins, PGW6002E (Purolite®, King of Prussia, PA) had approximately 60% greater capacity compared with other resins on the market at only a 3% higher cost, resulting in proportionally less brine generation. On average, brine generation is 0.0125% of treated water flow, but varies based on sulfate concentration. However, piloting of this product would be required to confirm brine production at Banning’s wells.

Regeneration steps that result in non-hazardous brine or slow rinse water can be recycled (2 bed volumes (BV) from the brine regeneration and 1 BV from the slow rinse). The first BV from the brine regeneration process yields non-saline water to be recycled approximately. Sites without sewer access will need to haul offsite 3 BV of fast rinse water, which is assumed to be non-saline non-hazardous liquid waste for disposal offsite.

3.1.2 Reduction, Coagulation, and Filtration/Microfiltration The RCF process involves reduction of Cr6 to Cr3 followed by removal of particles by filtration, as shown in Equation 1 below.
(1) 3Fe2+ + CrO4
2− + 8H2O → 3 Fe(OH)3(s) + Cr(OH)3(s) + 4H+

As shown in Equation 1, reducing Cr6 to Cr3 converts ferrous iron into ferric iron. Cr3 attaches to ferric hydroxide precipitates that are then removed from the water by granular media or membrane filtration.

An alternative reductant chemical is stannous (tin) that could be used in place of ferrous iron. Since RCF with ferrous is currently the best available technology and use of stannous requires more testing, RCF with ferrous was considered in this comparative analysis. In a preliminary design phase and pilot testing, Banning may wish to consider the alternative coagulant.

Figure 3-2 illustrates a schematic of the RCF treatment process. Components in the RCF process include ferrous iron or stannous addition, a reduction tank or piping that provides time for ferrous iron to reduce Cr6 to Cr3 and coagulate, hypochlorite addition to oxidize the remaining ferrous iron to ferric iron, polymer addition to a rapid mixing tank to enhance floc formation (if granular filters), granular media filtration, and backwash recovery (Figure 3-2).
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Figure 3-2: RCF Treatment Process Flow Diagram
Instead of granular media filters, microfiltration (MF) could be used – a process termed RCMF. Testing indicates that granular media filters can reliably decrease total chromium to below 3 to 5 μg/L, while MF can decrease total chromium to below the method reporting limit of 1 μg/L. In general, raw water quality (e.g., sulfate) does not affect RCF and RCMF like it affects SBA. Since the proposed draft MCL is 10 μg/L, costs were considered for only RCF because the additional cost of using MF would not provide a regulatory benefit at this time.

3.1.3 Weak Base Anion Exchange
Weak Base Anion (WBA) resin effectively removes Cr6 from water, reducing it to trivalent chromium (Cr3) on the resin’s surface. Over time, as the resin’s capacity for Cr6 is gradually exhausted, Cr6 concentrations in the treated water begin to increase. When the Cr6 level exceeds the target threshold, the WBA resin is replaced rather than regenerated.

Figure 3-3 shows a schematic of the WBA treatment process. Before the ion exchange, suspended particles are removed from groundwater using bag or cartridge filters to minimize pressure drop in the resin bed and reduce the need for backwashing. WBA resins are pH-sensitive and work most effectively at a pH of approximately 6.0 for Cr6 removal. pH adjustment, typically achieved by adding carbon dioxide (CO2) or an acid (such as sulfuric or hydrochloric acid), is necessary to reach this range. The required dose of CO2 or acid depends on the groundwater’s alkalinity and initial pH. In this analysis, CO2 was selected for pH adjustment due to safety considerations associated with sulfuric acid. Banning wells have moderate alkalinity (approximately 130 mg/L as CaCO3), resulting in an estimated required CO2 dose of approximately 300 mg/L. Chemical expenses for pH adjustment were included in the O&M cost estimates.
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Figure 3-3: WBA Treatment Process Flow Diagram

4. Treatment Evaluation

4.1 Treatment System Conceptual Design
This section describes the conceptual designs and operating parameters that were used to calculate the well treatment system cost estimates for a specific treatment technology. Capital, annual O&M, and total annual costs were estimated for WBA, SBA, and RCF. This section describes the assumptions used to develop cost estimates. Well historical well utilization was used to estimate annual O&M costs for each treatment location and the utilization percentage is presented in Table 4-1. It should be noted that O&M costs for SBA are sensitive to the utilization percentage to estimate resin regeneration frequencies.

Table 4-1: Well Utilization for O&M Estimates
Well Well Capacity (gpm) Utilization %
M10, M11 1,400 9%
C2, C4, C8, M3 4,700 8%
C3 1,100 27%
C5 900 31%
C6 900 23%
The proposed clustered and wellhead treatment locations and proposed raw water transmission piping is shown in Figure 4-1. Individual wellhead treatment would require available footprint at each well site for the equipment associated with the type of selected treatment technology. An analysis of treatment options was completed in the prior Study 2022 and indicated the space constraints at Well C3 and C5. It was noted that Well C5 only has an available footprint of 1,000 ft2 and would require obtaining nearby land
for treatment, while Well C3 does not have available footprint for RCF and WBA, making those treatment technologies infeasible without the acquisition of land. 681
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Figure 4-1: Clustered and Individual Wellhead Treatment Locations

4.1.1 SBA
The brine handling strategy employed at an SBA treatment facility impacts the equipment needed at that location. The three SBA brine handling options, SBA Option 1, SBA Option 2, SBA Option 3 are further discussed in Section 3.1.1. The assumptions used for estimating SBA treatment system costs are shown in Table 4-2.

Table 4-2: SBA Design Criteria
Parameter Value Units
Vessel Diameter 10 ft
Resin Volume 368 cf
Vessel Area 78.54 sq ft
Hydraulic Loading Rate
(HLR) 15 (maximum) gpm/ft2
Empty Bed Contact Time
(EBCT) 2.0 – 4.0 min/vessel
Configuration Parallel (minimum 2) -
Full-time equivalents for
operation (FTE) 1.25 -
Resin life 7 years
Additional assumptions include:
• Bag filters for particle removal, resin regeneration, spent brine treatment process. 682
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• No caustic soda feed system.
• Resin regeneration frequency was based on maximum historical sulfate concentration in raw water, which was derived from full-scale experience showing bed volumes versus sulfate concentrations. Resin regeneration was assumed when the effluent Cr6 concentration reached 6 µg/L.
• The resin regeneration procedure consists of regen (12% brine, 4 BVs total comprised of 3 BVs to be recycled and 1 BV to waste), slow rinse (1 BV, recycled), and fast rinse (3 BVs, all to waste).
o Hazen is confirming recommended resin regeneration waste volumes with vendors.

For the SBA options, ranges are included in the O&M to represent the sensitivity of cost estimates to key assumptions, including:
• SBA Option 1 - This option includes on-site treatment of hazardous brine using ferrous chloride, aeration, and belt filter presses to convert it into non-hazardous brine suitable for offsite hauling, along with hazardous solids requiring disposal. Costs account for treatment and disposal of both non-hazardous liquid and hazardous solid wastes. The brine treatment process will vary depending on the constituents present and their concentrations (e.g., selenium, uranium), which may be variable depending on the well.
• SBA Option 2 - In this option, hazardous brine undergoes on-site treatment, with nonhazardous liquid waste discharged to a wastewater treatment facility and hazardous solids disposed of off-site. Costs include the treatment and disposal of both non-hazardous liquid and hazardous solids. The feasibility of this option depends on further analysis and coordination with the wastewater treatment facility.
• SBA Option 3 - This option involves hauling hazardous brine directly to a disposal facility as hazardous liquid waste. Costs exclude on-site brine treatment. Any bed volumes in the regeneration processes producing non-hazardous brine are recycled. Rinse water is disposed of as non-hazardous liquid waste.

4.1.2 RCF
For the RCF option, ferrous chloride as a bulk chemical was assumed as the coagulant. As discussed previously, other options (on-site generation or use of stannous chloride) could be considered in preliminary design. The assumptions used for estimating RCF treatment system costs are shown in Table 4-3. Sites without adequate sewer capacity assumed recycling the supernatant to the head of the plant and dewatering solids to be disposed of offsite. Site constraints will need to be evaluated further in preliminary design to confirm that placement of equipment is feasible with underground piping and other site features. Residual disposal is further discussed in Section 4.2. 683
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Table 4-3: RCF Design Criteria
Parameter Value Unit
Vessel Configuration Vertical Horizontal --
Vessel Diameter 12 10 ft
Number of Cells - 4 4
Reduction Time 2 min
Hydraulic Loading Rate 8 gpm/ft2
Media Sand/Anthracite type
Media Depth 3 ft
Freeboard 1.5 ft
Media Replacement (Attrition) 10% Annual
Ferrous Chloride Dose 2.0 mg/L (as Fe)
Sodium Hypochlorite Dose 3.5 mg/L
Non-ionic polymer (filter aid) 0.1 mg/L
Backwash Rate 15 gpm/ft2
Backwash Duration 10 min
Backwash Frequency 12 hours
FTE 1.5 -

4.1.3 WBA
The assumptions used for estimating WBA treatment system costs are shown in Table 4-4.

Table 4-4: WBA Design Criteria
Parameter Value Unit
Vessel Diameter 12 ft
Hydraulic Loading Rate 8 gpm/ft2
EBCT 4.0 min/vessel
Configuration Lead/lag -
Target pH 6.0 -
Anti-scalant Dose
(Polyphosphate) 1.0 mg/L
FTE 1.0 -
Resin Volume 420 cf
Resin Purolite S106

4.2 Residual Disposal
Residual disposal for the treatment technologies is a major factor in selection. This section describes the disposal options for SBA, WBA, and RCF and the impact of residuals disposal to the wastewater collection system.
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4.2.1 Sewer Capacity Analysis
A sewer capacity analysis was completed to evaluate if backwash flow rates can be accommodated in the system. The sewer capacity was calculated using Kutter’s formula (Figure 4-2) and depth to diameter (d/D) ratio per ASCE and WEF recommendation.

Figure 4-2: Kutter’s Formula - Sewer Capacity
The following coefficients and ratios were used as the basis of the analysis:
• Manning’s roughness coefficient (n):
o Vitrified Clay Pipe: n = 0.013
o Polyvinyl Chloride Pipe n = 0.007
• Flow depth to diameter ratio:
o When D > 15”, d/D ≤ 75 %
o When D ≤ 15”, d/D ≤ 50%
City land use via the 2016 City of Banning General Plan was used. Each site was reviewed to confirm the sewer connection location and the downstream gravity mains were analyzed until they no longer had adequate capacity or until a connection to a trunk line. Trunk lines are found along Westward Avenue and Portner Street. Table 4-5 summarizes the full flow sewer capacity for each proposed treatment site.

However, sewer modeling was not conducted within this study to determine available sewer capacity.

Appendix A contains sewer capacity calculations.
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Table 4-5: Sewer Accessibility
Plant Name Sewer Access Sewer Full Flow
Capacity (cfs)
M10, M11 Yes 75.8
C2, C4, C8, M3 Yes 3.3
C3 Yes 1.8
C5 Yes 8.5
C6 Yes 0.7

4.2.2 SBA
Without brine treatment onsite, the brine would need to be transported to a facility for treatment and/or disposal. The treatment of brine onsite to render it non-hazardous could make it feasible to discharge the brine to the sewer if sewer access for brine disposal is available. The advantage of this approach is that it eliminates hauling and disposal of the non-hazardous brine, but the disadvantage is increased salt loading into the sewer and the wastewater treatment plant (WWTP), which can affect the ability to satisfy the TDS limit in the Waste Discharge Requirements (WDR). The current WDR of the City WWTP limits the TDS discharged from that facility to 300 mg/L higher than the domestic water supply. An analysis presented in that WDR noted that the average TDS increase over the domestic water supply was about 220 mg/L from 2011 to 2015. As the previous 2023 Study Update estimates, the cumulative effect of all treatment systems may increase the average TDS to exceed the WDR TDS limit of 300 mg/L, indicating this approach may not be an option that could be implemented at all well treatment locations without revisions to the WDR.

4.2.3 RCF
RCF generates backwash waste that either requires disposal to the sewer or treatment to separate the backwash water from the solids so the water can be recycled to the head of the plant and the solids can be transported offsite for disposal. A conservative estimate was used to determine if the discharge of filter backwash water from RCF would impact the sewer capacity. If the backwash discharge was less than 10% of the total sewer capacity, backwash discharge to sewer was assumed to be potentially feasible.

However, if the backwash discharge exceeded 10% then further analysis is recommended to confirm backwash discharge feasibility. Backwash flows from both horizontal and vertical filter vessels were evaluated. Table 4-6 presents the full flow sewer capacity compared to the discharge rates from backwashing vertical filter vessels and the backwash volume. This analysis indicates discharging attenuated backwash flow via a backwash holding tank would result in the discharge flow being under 10% and therefore assumed to be feasible at a number of sites. Table 4-7 summarizes the discharge flows for horizontal vessel configuration and backwash volumes.

Table 4-6: RCF Vertical Configuration Backwash Tank Sizing Plant Backwash Volume
(gallons)
Peak Backwash
Flow for Sewer
Discharge (cfs)
Percent of Sewer
Capacity
Iron (as Fe) to
Sewer (mg/L)
M10, M11 43,529 0.16 0.2% 52.9
C2, C4, C8, M3 191,788 0.71 21.6% 37.5
C3 41,129 0.15 8.8% 42.0
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Plant Backwash Volume
(gallons)
Peak Backwash
Flow for Sewer
Discharge (cfs)
Percent of Sewer
Capacity
Iron (as Fe) to
Sewer (mg/L)
C5 40,529 0.15 3.6% 39.1
C6 39,929 0.15 22.2% 36.1
Table 4-7: RCF Horizontal Configuration Backwash Tank Sizing Plant Backwash Volume
(gallons)
Peak Backwash
Flow for Sewer
Discharge (cfs)
Percent of Sewer
Capacity
Iron (as Fe) to
Sewer (mg/L)
M10, M11 44,800 0.17 0.2% 51.2
C2, C4, C8, M3 140,000 0.52 15.8% 51.5
C3 33,600 0.12 7.1% 51.4
C5 30,800 0.11 3.3% 51.8
C6 15,558 0.10 15.1% 51.1

Sites with backwash discharge exceeding 10% of the sewer capacity were bolded in Table 4-6 and Table 4-7 above and were initially flagged as requiring further analysis to determine the current sewer usage and available capacity. After discussions with Banning, it was noted that sewer at Well C6 does not have high usage and therefore may be able accommodate discharge flows from Well C6. However, further analysis is recommended at Foothill Cluster (C2, C4, C8, M3) to confirm the available capacity accounting for demands from other sources.

4.2.4 WBA
WBA resin will accumulate uranium, and the disposal will vary depending on the concentration of that element. Spent resin is expected to be a hazardous waste due to a high Cr concentration above the California Total Threshold Limit Concentration (TTLC), as experienced at the Glendale, CA Cr6 treatment facility. Due to the removal and concentration of naturally occurring uranium from source waters, the waste is likely to be a technologically enhanced naturally occurring radioactive material (TENORM) waste and may be a low-level radioactive waste (LLRW) that requires special disposal. The impact is additional cost and permitting complexity.

5. Cost Estimating
The ranges of costs developed reflect the accuracy of estimates at this phase of planning and are consistent with Association for the Advancement of Cost Engineering (AACE) Class 4 costs with an accuracy range of -30% to +50%. No design contingency was added to the estimate based on how the cost estimate was developed. Total annual costs are presented as the sum of annual O&M and capital debt service based on a 30-year lifecycle and assumed State Revolving Fund loan rate of 2%. Cost estimate details are included in Appendix B.

Cost estimates summarized in Table 5-1 are limited to sites that do not currently have treatment. The costs indicate that the ranges of capital, O&M, and annualized costs overlap within the accuracy range of the estimates.
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Table 5-1: Capital, O&M and Total Annual Cost Estimates of Different Treatment Strategies Well Name
Treatment Strategy Cost Estimates ($ Million)

WBA SBA
Option 1
SBA
Option 2
SBA
Option 3 RCF (H) RCF (V)
M10, M11 12.6 12.6 11.2 9.4 7.1 8.5
C2, C4, C8, M3 18.4 17.7 16.2 13.9 13.5 17.8
C3 8.1 8.7 8.7 6.4 4.3 6.3
C5 8.1 8.7 8.7 6.4 4.2 6.3
C6 8.1 8.7 8.7 6.4 4.0 6.3
Total Project Capital Costs (Sum
of capital costs for each site) 55.2 56.4 53.6 42.6 33.2 45.2 Total Project Capital Costs
Accuracy Range (-30 to +50%) 38.7 - 82.9 39.5 - 84.7 37.5 - 80.3 29.8 - 63.9 23.2 - 49.7 31.6 - 67.8 Total Project Annual O&M Costs
($M/Year):

Estimate

2.0 1.6 1.5 1.6 1.8 1.8
Total Project Annual O&M Costs
(Accuracy Range -30 to +50%,
$M/Year)

1.4 – 3 1.1 - 2.4 1.1 - 2.3 1.1 - 2.4 1.3 - 2.7 1.3 - 2.7 Total Project Annual Cost
(Annualized Capital + Annual
O&M) ($M/Year)

4.7 4.5 4.3 3.8 3.5 4.1
Total Project Annual Costs
(Annualized Capital + Annual
O&M Costs over Accuracy Range
of -30 to +50%, $M/Year)

3.3 - 7.1 3.1 - 6.7 3 - 6.4 2.6 - 5.7 2.4 - 5.2 2.9 - 6.2 General Notes: Values in the table are rounded to one decimal place. V = Vertical pressure vessels; H = Horizontal pressure vessels.

6. Technology Screening
Due to the overlap in technology costs observed in the 2022 Study Update, Hazen and Sawyer evaluated non-monetary factors that factor into selection of treatment technology. Total annual cost estimates and non-cost ranking criteria were developed to compare technologies that met Banning criteria to be considered for implementation.

Treatment options for Cr6 removal were first screened for critical flaws and the remaining options were then assessed using non-cost criteria. Treatment options were scored on a scale from 1 (least favorable) to 10 (most favorable) across criteria. Decision-making criteria are described below and scoring explanations are provided in Table 6-1.

Reliability and Resilience to Changing Water Quality – This criterion evaluates the treatment technology’s resilience to fluctuations in water quality, change in treatment goals long term performance, and impact from competing constituents.

O&M Complexity – This criterion evaluates the ease of operation and the magnitude of maintenance for a unit process.
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Water Loss – This criterion evaluates the amount of water loss associated with the treatment technology (e.g., regeneration waste or backwash water).

Residual Handling – This criterion indicates the complexity of disposal of liquid and solid waste and evaluates whether the waste is hazardous.

Environmental and Community Impacts – This criterion scores the ability of the selected treatment technology process to obtain permits and achieve community acceptance.

Table 6-1: Explanations of Criteria Scoring Values
Category Criteria Definition High Score Definition Low Score Definition Reliability and
Resilience
Reliability to Meet Cr6
Treatment Goal Treatment reliability
Treatment technology
is not limited to
reliability or
dependency on
vendors
Relatively low number of
vendors offering
treatment technology
approach or residual
disposal solutions
System resilience to
change
Ability to handle
fluctuations in water
quality or change in the
treatment goal without
significant operational
changes
Yes, without additional
operational cost
No, operational changes
and higher costs would
be realized
Impact from competing
constituents
Interfering constituents
(i.e., sulfate, silica, iron,
manganese)
High selectivity,
primary removal of
Cr(VI) only
Interfering constituents
decreasing Cr(VI)
removal efficiency
O&M
Complexity
Equipment complexity
Chemical feed system
requirements and the
need for constant
monitoring. Multiple
components require
frequent maintenance.

Very few feed systems
requiring little
monitoring/
maintenance
Multiple chemical feeds,
constant
monitoring/maintenance
Chemical deliveries Frequency of chemical
deliveries Less frequent More frequent
Number of full-time
employees needed
(FTEs)
The number of staff
required to maintain
operation and the need
for operator attention.

Low-level staffing
requirement
High-level staffing
requirement
Water Loss
Water loss to waste
associated from
process
Little to no water loss High water loss
Residuals
Handling
Complexity of Liquid
Waste Disposal
How complicated is
disposal of liquid
waste?
Not difficult Difficult
Offsite Disposal of
Solid Waste
How frequent are truck
trips to dispose of
waste offsite? Is solid
waste hazardous?
Less frequent and/or
non-hazardous
More frequent and/or
hazardous
Environmental /
Community
Impacts
Ability to obtain
environmental permits --
Low complexity to
obtain permits
High complexity to obtain
permits
Community acceptance --
Low Community
Acceptance
High Community
Acceptance
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Non-cost criteria weightings were developed in consultation with Banning, and Hazen’s multi-criteria decision analysis tool used these criteria and weightings as inputs to compare alternative technologies (Table 6-2). The scores assigned for each category were scaled based on the weightings to provide a total score for each technology out of a maximum of 100. The technologies included in this analysis were SBA Option 1, SBA Option 2, SBA Option 3, RCF and WBA.

Table 6-2: Weightings of Non-Cost Evaluation Criteria
Category Category Weight Criteria Criteria Weight in
Category
Ranking (Low to
High)
Reliability & Resiliency 30%
Reliability of LongTerm Performance 40% 1 – 10
System Resilience to
Change
30% 1 – 10
Impact from Competing
Constituents 30% 1 – 10
O&M 20%
Equipment Complexity 40% 1 – 10
Chemical Deliveries 50% 1 – 10
Number of FTE 10% 1 – 10
Water Loss 5% Water Loss 100% 1 – 10
Residuals Handling 30%
Disposal of Liquid
Waste 80% 1 – 10
Disposal of Solid
Waste 20% 1 – 10
Environmental /
Community 15%
Ability to Obtain
Environmental Permits 50% 1 – 10
Community
Acceptance 50% 1 – 10
Cost 20% Total Project Annual
Cost 100% 1 – 10

6.1 Screening Results
A summary the unweighted scores of the technologies for each non-cost criterion are shown in Table 6-3.

Key differentiating factors include:
• SBA has a good history of use, but all brine handling options include either hazardous liquid or hazardous solids.
• RCF is ranked the highest in terms of reliability and resilience, and residual handling, making RCF the favorable option for sites with high sulfate concentrations. Additionally, RCF has the highest community acceptance score due to less frequent truck trips, for chemicals and/or residual hauling.
• WBA has a relatively low equipment complexity. However, community acceptance is low due to noise of CO2 fills, and disposal of hazardous, LLRW spent resin is a consideration with this technology.
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Table 6-3: Unweighted Non-Cost Scores by Treatment Technology Category Criteria SBA
Option 1
SBA
Option 2
SBA
Option 3 WBA RCF
Reliability &
Resiliency
Reliability of LongTerm
Performance
10 10 10 10 10
System Resilience
to Change 8 8 8 10 10
Impact from
Competing
Constituents
4 4 4 6 10
O&M
Equipment
Complexity 4 4 6 9 8
Chemical
Deliveries 8 8 9 8 6
Number of FTE 8 8 8 9 7
Water Loss Water Loss 8 8 8 8 6
Residuals
Handling
Redundancy of
Liquid Waste
Disposal
2 10 2 8 10
Disposal of Solid
Waste 4 4 10 6 10
Environmental /
Community
Ability to Obtain
Environmental
Permits
6 6 6 6 6
Community
Acceptance 4 4 4 2 8
Total annual costs were scored on a site-specific basis to determine the treatment technology ranking for each location. The non-weighted scoring for the total annual project cost is presented in Table 6-4.

Table 6-4: Unweighted Total Project Annual Cost Scores by Treatment Technology Category RCF WBA SBA
Option 1
SBA
Option 2
SBA
Option 3
M10, M11 10 8 7 9 10
C2, C4, C8, M3 10 6 8 9 9
C3 10 8 9 9 10
C5 10 8 9 9 10
C6 10 8 8 8 9
Additionally, a sensitivity analysis was conducted to evaluate the impact of the cost vs. non-cost criteria.

In sensitivity analysis 1, the cost weighting was increased to 35% while the non-cost category weightings were decreased proportionally. In sensitivity analysis 2, the cost weightings were increased to 50% and the non-cost category weightings were proportionally decreased. Treatment alternative rankings for each location are presented in Table 6-5, with 1 as the highest ranking and 5 as the lowest ranking. RCF is ranked as the highest treatment alternative at all locations and in both sensitivity analysis 1 and 2. RCF is 691
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viewed as the preferred treatment technology to achieve Banning’s goals. The Hazen converge results for each site are presented in Appendix C.

Table 6-5: Hazen Converge and Sensitivity Analysis Ranking Category Criteria RCF WBA SBA
Option 1
SBA
Option 2
SBA
Option 3
M10, M11
Hazen Converge 1 2 4 3 5
Sensitivity Analysis #1 1 2 4 3 5
Sensitivity Analysis #2 1 3 5 2 4
C2, C4, C8, M3
Hazen Converge 1 2 4 3 5
Sensitivity Analysis #1 1 2 4 3 5
Sensitivity Analysis #2 1 2 5 3 4
C3
Hazen Converge 1 2 4 3 5
Sensitivity Analysis #1 1 2 4 3 5
Sensitivity Analysis #2 1 3 5 2 4
C5
Hazen Converge 1 2 4 3 5
Sensitivity Analysis #1 1 2 4 3 5
Sensitivity Analysis #2 1 3 5 4 2
C6
Hazen Converge 1 2 4 3 5
Sensitivity Analysis #1 1 2 4 3 5
Sensitivity Analysis #2 1 2 5 3 4

7. Conclusions
The best available technologies (BATs) evaluated for the City wells included WBA, SBA, and RCF.

Technologies were assessed based on lifecycle costs and operability considerations (chemical consumption, residuals waste generation, and staffing requirements). While the accuracy range of lifecycle costs overlap for each of the alternatives, it was found that the RCF with horizontal filter configuration located at clustered treatment facilities and individual sites was the lowest point estimate lifecycle cost compared with WBA and SBA. As the previous study indicated, there is not enough available footprint to house RCF and WBA equipment at Wells C3 and C5, making those treatment technologies infeasible at those locations without the acquisition of additional land.

RCF has the lowest annualized lifecycle costs of all treatment strategies, although there is considerable overlap between the lifecycle costs of the other technologies. WBA and SBA Option 1 had the highest capital cost and WBA has the highest O&M costs. SBA with onsite brine treatment had the lowest O&M costs, but had a higher lifecycle cost than RCF with either vertical or horizontal vessel configuration and SBA with no brine treatment. Due to the overlap in technology costs, Hazen and Sawyer evaluated nonmonetary factors that factor into selection of treatment technology, as outlined in Section 6 and 6.1. Total 692
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annual cost estimates and non-cost ranking criteria were developed to compare technologies and RCF ranked as the preferred treatment technology when considering cost and non-cost factors. This study focused on evaluating BATs (RCF, SBA, WBA) for the City wells and non-treatment solutions were not evaluated, further assessment is required to determine the potential for non-treatment solutions.

7.1 Next Steps
This study has developed a foundation for future work considerations as the City continues down the path of project implementation. Next steps for the City before, or during, preliminary design include:
• Further analysis of sewer disposal at C2, C4, C8, M3 to confirm available sewer capacity. • Confirm if brine can be sent to the wastewater reclamation facility. • Further assessment of site layouts for Wells C3 and C5, which may require the purchase of additional land.
• Consider pilot unit options to train operation staff in advance of design and/or startup.

7.1.1 Piloting Options
Banning is interested in acquiring a pilot system to provide training on the equipment for operators and optimize treatment design, as part of this study pilot system options were evaluated. The pilot configuration is intended to provide two minutes of reduction time for the ferrous chloride, multiple filter columns to evaluate various filter medias such as sand/anthracite, GreensandPlus, and pyrolusite, and chemical tanks for ferrous chloride, sodium hypochlorite, and polymer. Quotes for pilot systems were obtained from vendors and summarized in Table 7-1.

Table 7-1: RCF Pilot Quotations
Category
Purchase Lease
Skid Mounted Container/Trailer Mounted Trailer Mounted
Intuitech1 WQTS Intuitech1 Filtronics1 Tonka Tonka1
Cost $242,000 $325,000 $410,000 $85,000 $107,500 $32,500 (first week)
Additional
Add-on
Turbidity
Meters (Add
$22,000)
--
(fully customized
system)
Turbidity Meters
(Add $22,000)
Additional
Customization
Available
Additional
Tonka
Visits (Add
$7,000 per)
Additional Week
(Add $2,500 per)
Additional Tonka
Visits (Add $7,000
per)
Size 12.2’ L x 4.2’
W x 10.2’ H
10’ H x 10’ L x 2.83’
W2
20’ Enclosure 14’ trailer 20’ trailer 20’ trailer
Lead Time 6-7 months 6-7 months 6-7 months 2 – 3 months 3 months 1 – 1.5 months 1 Quote received is for a standard RCF pilot system, additional customization resulting in price change 2 Dimensions for the skid do not include additional chemical tanks and backwash tank 693
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Intuitech offers skid-mounted or containerized pilot systems, with the containerized option featuring air conditioning. The pilot system is fully automated with a SCADA system, enabling unmanned operation and offering optional turbidity meters and are available for purchase. WQTS provides skid-mounted pilot systems equipped with a fully automated SCADA system and a data logger. The WQTS systems include advanced features like pressure sensors, temperature sensors, turbidity meters, flow meters, and flow control valves. WQTS also allocates time for setup and training to ensure smooth pilot operation, and their systems are available for purchase. Filtronics delivers trailer-mounted pilot systems with automated filtration and semi-automatic electric valves, available for purchase. Tonka offers a trailer-mounted pilot system that is more manual but can be customized to meet specific needs. Tonka systems are available for lease or purchase. Specific quotation details for each pilot system can be found in Appendix D. 694
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Appendix A: Sewer Capacity Analysis
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1 Sewer Capacity Analysis
17 Background
18 • 5 treatment sites
• Foothill West Cluster (Wells C2, C4, C8, M3)• Well M10 + M11 Cluster• Well C3 Individual Treatment• Well C5 Individual Treatment• Well C6 Individual Treatment • Treatment Technology: RCF• Backwash Design Parameters:
• 15 gpm/ft2• Duration 10 mins• Media: Sand/Anthracite• Backwash estimated every 12 hours• Conservatively assumed no backwash to be recycled• Iron concentration to sewer was calculated as a function of the Ferrous dose
• Two potential vessel arrangements
• Horizontal Filter Vessels
• 4 cells per vessel
• Vertical Filter Vessels
• Assumptions
• Vertical
• Backwash volume is calculated assuming all duty vessels to be backwashed • Backwash volume for 12-hour period• Backwash waste to be discharged within 10 hours • Horizontal
• Backwash volume is calculated assuming 2 out of 4 cells to be backwashed per vessel within a 6-hour period
• Backwash waste to be discharged within 5 hours.
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2 Sewer Capacity Analysis Calculations
19 • Calculated design capacity using Kutter’s Formula & d/D ratio• Manning’s roughness coefficient (n):
• Vitrified Clay Pipe: n=0.013• Polyvinyl Chloride Pipe: n=0.007 • Flow depth to diameter ratio (d/D) per ASCE and WEF
recommendations
• When D > 15”, d/D ≤ 75 %• When D ≤ 15”, d/D ≤ 50%
• City land use via 2016 City of Banning General Plan• Analyze downstream until gravity main does not have adequate capacity or until it connects into trunk line
• Trunk lines are along Westward Avenue and Porter Street • Used a conservative estimate to determine if the discharge from RCF would impact sewer capacity.
• If the Discharge/Sewer Capacity was under 10%, backwash discharge was assumed to be feasible
Where
C = Chezy’s resistance coefficient
S = Slope
R = Hydraulic radius
n = Manning’s roughness coefficient
A = Area
Foothill West Cluster (Wells C2, C4, C8, M3)
20 • Sewer Capacity Analysis Findings:
• Vertical Configuration
• Discharge flow: 0.71 cfs• Sewer Capacity: 3.30 cfs• Discharge flow from backwash exceeds 10% of Highland Home Rd / Wilson St Sewer Capacity (21.59% Discharge/Capacity) – Further Sewer Analysis Required to determine available sewer capacity/other sewer flows. • Horizontal Configuration
• Discharge flow: 0.52 cfs• Sewer Capacity: 3.30 cfs• Discharge flow from backwash exceeds 10% of Highland Home Rd / Wilson St Sewer Capacity (15.76% Discharge/Capacity) – Further Sewer Analysis Required to determine available sewer capacity/other sewer flows. • Potential Solutions (if required):
• Treating wash water and recycling supernatant to head of plant • Increase capital and O&M cost for dewatering equipment and sludge disposal (haz.) • Individual RCF treatment instead of clustered treatment • Transmission pipe estimated capital cost $4 M• Individual wellhead RCF treatment estimate ($4 M - $8M) for depending on vessel configuration for design flows 1,000 – 1,600 gpm
• Alternate Treatment Technology (WBA or SBA)
• Conclusion:
• Flows exceed the sewer capacity screening criteria
used; however, further evaluation is required to confirm if discharging to sewer at Highland Home Rd / Wilson St. is feasible. 1920
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3 Foothill West Cluster (Wells C2, C4, C8, M3) - Calculations 21 Backwash Discharge Calculations
Vertical Configuration Sewer Capacity Analysis
% Full
(Cumulati
ve
Flow/Cap
acity)
Calculated
Discharge
Flow (cfs)
Design capacity
sewer (cfs) Segment Pipe
Site
Description
Street Name 3/4 Full
(> 15")
1/2
Full
(≤ 15")
*Slope
Nominal
Diameter
(in.)
DS
M.H. #
US
M.H. #
218 188 15 0.0024 3.30 - 0.71 21.59%
Foothill West
Cluster
Treatment
Site
Highland Home Rd/ Wilson St
Horizontal Configuration Sewer Capacity Analysis
% Full
(Cumulati
ve
Flow/Cap
acity)
Calculated
Discharge
Flow (cfs)
Design capacity
sewer (cfs) Segment Pipe
Site
Description
Street Name 3/4 Full
(> 15")
1/2
Full
(≤ 15")
*Slope
Nominal
Diameter
(in.)
DS
M.H. #
US
M.H. #
218 188 15 0.0024 3.30 - 0.52 15.76%
Foothill West
Cluster
Treatment
Site
Highland Home Rd/ Wilson St
Vertical Configuration
Foothill West
Cluster Parameter Units
Backwash duration min 600
gal 191,788 Backwash volume (for all duty vessels)
gpm 320
Backwash flow rate
cfs 0.71
Iron (as Fe) to Sewer from Ferrous mg/L 37.5
Horizontal Configuration
Foothill West
Cluster Parameter Units
Backwash duration min 600
gal 140,000 Backwash volume (for 2 out of 4 cells per vessel) gpm 233
Backwash flow rate
cfs 0.52
Iron (as Fe) to Sewer Ferrous mg/L 51.4
Sewer Capacity Calculations
M10 & M11 Cluster
22 • Sewer Capacity Analysis Findings:
• Vertical Configuration
• Discharge flow: 0.16 cfs• Sewer Capacity: 75.84 cfs• Discharge flow from backwash is under 10% of W Westward Ave Sewer Capacity (0.21% Discharge/Capacity) • Horizontal Configuration
• Discharge flow: 0.17 cfs• Sewer Capacity: 75.84 cfs• Discharge flow from backwash is under 10% of W Westward Ave Sewer Capacity (0.22% Discharge/Capacity) • Conclusion:
• Discharge rates to sewer from vertical or horizontal filter vessel configurations do not appear to present an issue for the available sewer capacity, based on the information provided 2122
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4 M10 & M11 Cluster - Calculations
23 Backwash Discharge Calculations
Vertical Configuration Sewer Capacity Analysis
% Full
(Cumulati
ve
Flow/Cap
acity)
Calculated
Discharge
Flow (cfs)
Design capacity
sewer (cfs) Segment Pipe
Site
Description
Street Name 3/4 Full
(> 15")
1/2
Full
(≤ 15")
*Slope
Nominal
Diameter
(in.)
DS
M.H. #
US
M.H. #
104 107 21 0.4080 - 75.84 0.16 0.21%
Well M10 and
M11 Cluster
Treatment Site
W Westward Ave
Horizontal Configuration Sewer Capacity Analysis
% Full
(Cumulati
ve
Flow/Cap
acity)
Calculated
Discharge
Flow (cfs)
Design capacity
sewer (cfs) Segment Pipe
Site
Description
Street Name 3/4 Full
(> 15")
1/2
Full
(≤ 15")
*Slope
Nominal
Diameter
(in.)
DS
M.H. #
US
M.H. #
104 107 21 0.4080 - 75.84 0.17 0.22%
Well M10 and
M11 Cluster
Treatment Site
W Westward Ave
Vertical Configuration
M10 and M11
Cluster Parameter Units
Backwash duration min 600
gal 43,529 Backwash volume (for all duty vessels)
gpm 73
Backwash flow rate
cfs 0.16
Iron (as Fe) to Sewer from Ferrous mg/L 52.9
Horizontal Configuration
M10 and M11
Cluster Parameter Units
Backwash duration min 600
gal 44,800 Backwash volume (for 2 out of 4 cells per vessel) gpm 75
Backwash flow rate
cfs 0.17
Iron (as Fe) to Sewer from Ferrous mg/L 51.4
Sewer Capacity Calculations
Well C5
24 • Sewer Capacity Analysis Findings:
• Vertical Configuration
• Discharge flow: 0.15 cfs• Sewer Capacity: 8.54 cfs• Discharge flow from backwash is under 10% of W Westward Ave Sewer Capacity (3.66% Discharge/Capacity) • Horizontal Configuration
• Discharge flow: 0.11 cfs• Sewer Capacity: 8.54 cfs• Discharge flow from backwash is under 10% of W Westward Ave Sewer Capacity (3.29% Discharge/Capacity) • Conclusion:
• Discharge rates to sewer from vertical or horizontal filter vessel configurations do not appear to present an issue for the available sewer capacity, based on the information provided 2324
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5 Well C5 - Calculations
25 Backwash Discharge Calculations
Vertical Configuration Sewer Capacity Analysis
% Full
(Cumulati
ve
Flow/Cap
acity)
Calculated
Discharge
Flow (cfs)
Design capacity
sewer (cfs) Segment Pipe
Site
Description
Street Name 3/4 Full
(> 15")
1/2
Full
(≤ 15")
*Slope
Nominal
Diameter
(in.)
DS
M.H. #
US
M.H. #
106 108 21 0.0052 - 8.54 0.15 3.66%
Well C5
Individual
Treatment Site
W Westward Ave
Horizontal Configuration Sewer Capacity Analysis
% Full
(Cumulati
ve
Flow/Cap
acity)
Calculated
Discharge
Flow (cfs)
Design capacity
sewer (cfs) Segment Pipe
Site
Description
Street Name 3/4 Full
(> 15")
1/2
Full
(≤ 15")
*Slope
Nominal
Diameter
(in.)
DS
M.H. #
US
M.H. #
106 108 21 0.0052 - 8.54 0.11 3.29%
Well C5
Individual
Treatment Site
W Westward Ave
Vertical Configuration
Parameter Units Well C5Backwash duration min 600
gal 40,529 Backwash volume (for all duty vessels)
gpm 68
Backwash flow rate
cfs 0.15
Iron (as Fe) to Sewer from Ferrous mg/L 39.1
Horizontal Configuration
Parameter Units Well C5Backwash duration min 600
gal 30,800 Backwash volume (for 2 out of 4 cells per vessel) gpm 51
Backwash flow rate
cfs 0.11
Iron (as Fe) to Sewer from Ferrous mg/L 51.4
Sewer Capacity Calculations
Well C3
26 • Sewer Capacity Analysis Findings:
• Vertical Configuration
• Discharge flow: 0.15 cfs• Sewer Capacity: 1.75 cfs• Discharge flow from backwash is under 10% of Brooklawn Dr Sewer Capacity (8.75% Discharge/Capacity)
• Horizontal Configuration
• Discharge flow: 0.12 cfs• Sewer Capacity: 1.75 cfs• Discharge flow from backwash is under 10% of Brooklawn Dr Sewer Capacity (7.14% Discharge/Capacity)
• Conclusion:
• Discharge rates to sewer from vertical or horizontal filter vessel configurations do not appear to present an issue for the available sewer capacity, given the information provided 2526
700
12/31/2024
6 Well C3 - Calculations
27 Backwash Discharge Calculations
Vertical Configuration Sewer Capacity Analysis
% Full
(Cumulati
ve
Flow/Cap
acity)
Calculated
Discharge
Flow (cfs)
Design capacity
sewer (cfs) Segment Pipe
Site
Description
Street Name 3/4 Full
(> 15")
1/2
Full
(≤ 15")
*Slope
Nominal
Diameter
(in.)
DS
M.H. #
US
M.H. #
134 133 8 0.0196 1.75 - 0.15 8.75%
Well C3
Individual
Treatment
Site
Brooklawn Dr
Horizontal Configuration Sewer Capacity Analysis
% Full
(Cumulati
ve
Flow/Cap
acity)
Calculated
Discharge
Flow (cfs)
Design capacity
sewer (cfs) Segment Pipe
Site
Description
Street Name 3/4 Full
(> 15")
1/2
Full
(≤ 15")
*Slope
Nominal
Diameter
(in.)
DS
M.H. #
US
M.H. #
134 133 8 0.0196 1.75 - 0.12 7.14%
Well C3
Individual
Treatment
Site
Brooklawn Dr
Vertical Configuration
Parameter Units C3 Backwash duration min 600
gal 41,129 Backwash volume (for all duty vessels)
gpm 69
Backwash flow rate
cfs 0.15
Iron (as Fe) to Sewer mg/L 42.0
Horizontal Configuration
Parameter Units C3 Backwash duration min 600
gal 33,600 Backwash volume (for 2 out of 4 cells per vessel) gpm 56
Backwash flow rate
cfs 0.12
Iron (as Fe) to Sewer mg/L 51.4
Sewer Capacity Calculations
Well C6
28 • Lincoln St Sewer Information – Insufficient
• Hand drawn records that don’t include elevation
• Only pipe segments and lengths • Assume backwash volume will be sent to gravity main on Barbour St instead • Sewer Capacity Analysis Findings:
• Vertical Configuration
• Discharge flow: 0.15cfs• Sewer Capacity: 8.54cfs• Discharge flow from backwash exceeds 10% of Barbour St Sewer Capacity (22.24% Discharge/Capacity) - Further Sewer Analysis Required to determine available sewer capacity/other sewer flows. • Horizontal Configuration
• Discharge flow: 0.10cfs• Sewer Capacity: 8.54cfs• Discharge flow from backwash exceeds 10% of Barbour St Sewer Capacity (15.14% Discharge/Capacity) - Further Sewer Analysis Required to determine available sewer capacity/other sewer flows. • Conclusion:
• Flows exceed the sewer capacity screening criteria used; however, further evaluation is required to confirm if discharging to sewer at Lincoln St and Barbour St is feasible. • Potential Solutions (if required):
• Treating wash water and recycling supernatant to
head of plant
• Increase capital and O&M cost for dewatering equipment and hazardous solids disposal
• Alternate Treatment Technology (WBA, or SBA)
2728
701
12/31/2024
7 Well C6 - Calculations
29 Backwash Discharge Calculations
Vertical Configuration Sewer Capacity Analysis
% Full
(Cumulati
ve
Flow/Cap
acity)
Calculated
Discharge
Flow (cfs)
Design capacity
sewer (cfs) Segment Pipe
Site
Description
Street Name 3/4 Full
(> 15")
1/2
Full
(≤ 15")
*Slope
Nominal
Diameter
(in.)
DS
M.H. #
US
M.H. #
101 102 8 0.0154 0.69 - 0.15 22.24% Well C6 Treatment Site Barbour St Horizontal Configuration Sewer Capacity Analysis
% Full
(Cumulati
ve
Flow/Cap
acity)
Calculated
Discharge
Flow (cfs)
Design capacity
sewer (cfs) Segment Pipe
Site
Description
Street Name 3/4 Full
(> 15")
1/2
Full
(≤ 15")
*Slope
Nominal
Diameter
(in.)
DS
M.H. #
US
M.H. #
101 102 8 0.0154 0.69 - 0.10 15.14% Well C6 Treatment Site Barbour St Vertical Configuration
Parameter Units C6Backwash duration min 600
gal 39,929 Backwash volume (for all duty vessels)
gpm 67
Backwash flow rate
cfs 0.15
Iron (as Fe) to Sewer mg/L 36.1
Horizontal Configuration
Parameter Units C6Backwash duration min 300
gal 15,558 Backwash volume (for 2 out of 4 cells per vessel) gpm 47
Backwash flow rate
cfs 0.10
Iron (as Fe) to Sewer mg/L 51.4
Sewer Capacity Calculations
29 702
City of Banning
Chromium 6 Treatment and Compliance Technical Memorandum Update FINAL B-1
Appendix B: Cost Estimates
703
City of Banning
Chromium 6 Treatment and Compliance Technical Memorandum Update FINAL B-2
WBA Cost Estimate Details
Description M10 & M11
Cluster
Foothill West
Cluster Well C3 Well C5 Well C6
Bag Filter $ 254,577 $ 280,543 $ 171,500 $ 171,500 $ 171,500 WBA $ 2,486,824 $ 5,194,763 $ 2,443,383 $ 2,443,383 $ 2,443,383 Carbon Dioxide $ 958,462 $ 972,863 $ 939,402 $ 939,402 $ 939,402 Chemical Dosing $ 96,567 $ 96,572 $ 96,565 $ 96,565 $ 96,565 Site Work $ 266,020 $ 414,088 $ 258,174 $ 258,174 $ 258,174 Yard Piping $ 560,703 $ 872,794 $ 544,169 $ 544,169 $ 544,169 Electrical and
Controls $ 1,292,432 $ 2,011,805 $ 1,254,319 $ 1,254,319 $ 1,254,319 Booster Pump $ 183,565 $ 183,573 $ 183,560 $ 183,560 $ 183,560 M12 Transmission
Pipe $ 1,612,000
Foothill Transmission
Pipe $ 3,150,000
Initial Fill $ 480,000 $ 940,000 $ 340,000 $ 340,000 $ 340,000 Probable
Construction Cost
(rounded):
$ 8,191,000 $ 14,117,000 $ 6,231,000 $ 6,231,000 $ 6,231,000 Engineering,
Construction
Management, Legal,
Administration (30%)
$ 2,457,300 $ 4,235,100 $ 1,869,300 $ 1,869,300 $ 1,869,300 Probable Project
Cost (rounded): $ 10,648,000 $ 18,352,000 $ 8,100,000 $ 8,100,000 $ 8,100,000 Annual O&M
($/Year) $ 332,000 $ 609,000 $ 378,000 $ 381,000 $ 320,000 Annualized Capital
and O&M ($M/Year) $ 0.88 $ 1.55 $ 0.79 $ 0.79 $ 0.73
704
City of Banning
Chromium 6 Treatment and Compliance Technical Memorandum Update FINAL B-3
SBA w/ On-site Brine Treatment and Off-site Disposal (Hauling) Cost Estimate Details Description M10 & M11
Cluster
Foothill West
Cluster Well C3 Well C5 Well C6
Bag Filter $ 254,654 $ 280,579 $ 171,566 $ 171,566 $ 171,566 SBA $ 2,069,515 $ 3,370,199 $ 2,096,560 $ 2,096,560 $ 2,096,560 Site Work $ 135,107 $ 206,577 $ 132,088 $ 132,088 $ 132,088 Yard Piping $ 284,773 $ 435,412 $ 278,410 $ 278,410 $ 278,410 Electrical and Controls $ 656,406 $ 1,003,636 $ 641,739 $ 641,739 $ 641,739 Booster Pump $ 183,619 $ 183,596 $ 183,631 $ 183,631 $ 183,631 On-Site Brine
Treatment $ 2,910,000 $ 2,928,000 $ 2,863,000 $ 2,863,000 $ 2,863,000 Offsite Brine Disposal $ 1,103,000 $ 1,103,000
M12 Transmission
Pipe $ 1,612,000
Foothill Transmission
Pipe $ 3,150,000
Initial Fill $ 480,000 $ 940,000 $ 340,000 $ 340,000 $ 340,000 Probable Construction
Cost (rounded): $ 9,689,000 $ 13,601,000 $ 6,707,000 $ 6,707,000 $ 6,707,000 Engineering,
Construction
Management, Legal,
Administration (30%)
$ 2,906,700 $ 4,080,300 $ 2,012,100 $ 2,012,100 $ 2,012,100 Probable Project
Cost (rounded): $ 12,596,000 $ 17,681,000 $ 8,719,000 $ 8,719,000 $ 8,719,000 Annual O&M ($/Year) $ 313,000 $ 406,000 $ 294,000 $ 295,000 $ 302,000 Annualized Capital
and O&M ($M/Year) $ 0.96 $ 1.31 $ 0.74 $ 0.74 $ 0.75
705
City of Banning
Chromium 6 Treatment and Compliance Technical Memorandum Update FINAL B-4
SBA w/ On-site Brine Treatment and Off-site Disposal to Sewer Cost Estimate Details Description M10 & M11
Cluster
Foothill West
Cluster Well C3 Well C5 Well C6
Bag Filter $ 254,654 $ 280,579 $ 171,566 $ 171,566 $ 171,566 SBA $ 2,069,515 $ 3,370,199 $ 2,096,560 $ 2,096,560 $ 2,096,560 Site Work $ 135,107 $ 206,577 $ 132,088 $ 132,088 $ 132,088 Yard Piping $ 284,773 $ 435,412 $ 278,410 $ 278,410 $ 278,410 Electrical and Controls $ 656,406 $ 1,003,636 $ 641,739 $ 641,739 $ 641,739 Booster Pump $ 183,619 $ 183,596 $ 183,631 $ 183,631 $ 183,631 On-Site Brine
Treatment $ 2,910,000 $ 2,928,000 $ 2,863,000 $ 2,863,000 $ 2,863,000 Offsite Brine Disposal $ 1,103,000 $ 1,103,000
M12 Transmission
Pipe $ 1,612,000
Foothill Transmission
Pipe $ 3,150,000
Initial Fill $ 480,000 $ 940,000 $ 340,000 $ 340,000 $ 340,000 Probable Construction
Cost (rounded): $ 9,689,000 $ 13,601,000 $ 6,707,000 $ 6,707,000 $ 6,707,000 Engineering,
Construction
Management, Legal,
Administration (30%)
$ 2,906,700 $ 4,080,300 $ 2,012,100 $ 2,012,100 $ 2,012,100 Probable Project
Cost (rounded): $ 12,596,000 $ 17,681,000 $ 8,719,000 $ 8,719,000 $ 8,719,000 Annual O&M ($/Year) $ 313,000 $ 406,000 $ 294,000 $ 295,000 $ 302,000 Annualized Capital
and O&M ($M/Year) $ 0.96 $ 1.31 $ 0.74 $ 0.74 $ 0.75
706
City of Banning
Chromium 6 Treatment and Compliance Technical Memorandum Update FINAL B-5
SBA w/ off-site Disposal No Treatment Cost Estimate Details Description M10 & M11
Cluster
Foothill West
Cluster Well C3 Well C5 Well C6
Bag Filter $ 254,654 $ 280,579 $ 171,566 $ 171,566 $ 171,566 SBA $ 2,069,515 $ 3,370,199 $ 2,096,560 $ 2,096,560 $ 2,096,560 Site Work $ 135,107 $ 206,577 $ 132,088 $ 132,088 $ 132,088 Yard Piping $ 284,773 $ 435,412 $ 278,410 $ 278,410 $ 278,410 Electrical and Controls $ 656,406 $ 1,003,636 $ 641,739 $ 641,739 $ 641,739 Booster Pump $ 183,619 $ 183,596 $ 183,631 $ 183,631 $ 183,631 Off-site Brine Disposal $ 1,103,000 $ 1,103,000 $ 1,103,000 $ 1,103,000 $ 1,103,000 M12 Transmission
Pipe $ 1,612,000
Foothill Transmission
Pipe $ 3,150,000
Initial Fill $ 940,000 $ 940,000 $ 340,000 $ 340,000 $ 340,000 Probable Construction
Cost (rounded): $ 7,239,000 $ 10,673,000 $ 4,947,000 $ 4,947,000 $ 4,947,000 Engineering,
Construction
Management, Legal,
Administration (30%)
$ 2,171,700 $ 3,201,900 $ 1,484,100 $ 1,484,100 $ 1,484,100 Probable Project
Cost (rounded): $ 9,411,000 $ 13,875,000 $ 6,431,000 $ 6,431,000 $ 6,431,000 Annual O&M ($/Year)
$ 310,000 $ 407,000 $ 294,000 $ 295,000 $ 302,000
Annualized Capital
and O&M ($M/Year) $ 0.79 $ 1.11 $ 0.62 $ 0.62 $ 0.63
707
City of Banning
Chromium 6 Treatment and Compliance Technical Memorandum Update FINAL B-6
RCF Horizontal Cost Estimate Details
Description M10 & M11
Cluster
Foothill West
Cluster Well C3 Well C5 Well C6
RCF $ 1,909,279 $ 4,012,215 $ 1,570,381 $ 1,496,977 $ 1,418,171 Chemical Dosing $ 193,192 $ 193,192 $ 193,192 $ 193,192 $ 193,192 Backwash $ 598,445 $ 856,526 $ 563,862 $ 563,862 $ 552,950 Site Work $ 145,718 $ 272,917 $ 125,596 $ 121,641 $ 116,808 Yard Piping $ 307,136 $ 575,242 $ 264,725 $ 256,390 $ 246,202 Electrical and Controls $ 707,954 $ 1,325,942 $ 610,197 $ 590,984 $ 567,501 M12 Transmission
Pipe $ 1,612,000
Foothill Transmission
Pipe $ 3,150,000
Probable Construction
Cost (rounded): $ 5,474,000 $ 10,386,000 $ 3,328,000 $ 3,223,000 $ 3,095,000 Engineering,
Construction
Management, Legal,
Administration (30%)
$ 1,642,200 $ 3,115,800 $ 998,400 $ 966,900 $ 928,500
Probable Project
Cost (rounded): $ 7,116,000 $ 13,502,000 $ 4,326,000 $ 4,190,000 $ 4,024,000 Annual O&M
($M/Year) $ 327,000 $ 426,000 $ 361,000 $ 351,000 $ 331,000 Annualized Capital
and O&M ($M/Year) $ 0.69 $ 1.11 $ 0.58 $ 0.56 $ 0.54

708
City of Banning
Chromium 6 Treatment and Compliance Technical Memorandum Update FINAL B-7
RCF Vertical Cost Estimate Details
Description M10 & M11
Cluster
Foothill West
Cluster Well C3 Well C5 Well C6
RCF $ 2,660,620 $ 6,127,074 $ 2,660,620 $ 2,660,620 $ 2,660,620 Chemical Dosing $ 193,192 $ 193,192 $ 193,192 $ 193,192 $ 193,192 Backwash $ 567,441 $ 1,075,721 $ 537,945 $ 537,945 $ 537,945 Site Work $ 184,526 $ 398,664 $ 182,936 $ 182,936 $ 182,936 Yard Piping $ 388,934 $ 840,285 $ 385,584 $ 385,584 $ 385,584 Electrical and Controls $ 896,500 $ 1,936,872 $ 888,780 $ 888,780 $ 888,780 M12 Transmission
Pipe $ 1,612,000
Foothill Transmission
Pipe $ 3,150,000
Probable Construction
Cost (rounded): $ 6,503,000 $ 13,722,000 $ 4,849,000 $ 4,849,000 $ 4,849,000 Engineering,
Construction
Management, Legal,
Administration (30%)
$ 1,950,900 $ 4,116,600 $ 1,454,700 $ 1,454,700 $ 1,454,700 Probable Project
Cost (rounded): $ 8,454,000 $ 17,839,000 $ 6,304,000 $ 6,304,000 $ 6,304,000 Annual O&M
($M/Year) $ 327,000 $ 426,000 $ 361,000 $ 351,000 $ 331,000 Annualized Capital
and O&M ($M/Year) $ 0.76 $ 1.34 $ 0.68 $ 0.67 $ 0.65
709
City of Banning
Chromium 6 Treatment and Compliance Technical Memorandum Update FINAL C-1
Appendix C: Hazen Converge Analysis
710
12/31/2024
1 Task 3 – Technology SelectionJuly 31, 2024
Chromium 6 Treatment and Compliance Technical Memo Updates Treatment Alternatives
2 • Weak Base Anion Exchange (WBA)• Strong Base Anion Exchange (SBA) Option 1 – Brine Treatment, Offsite Non-Hazardous Disposal
• SBA Option 2 – Brine Treatment, Sewer Disposal• SBA Option 3 – No Brine Treatment, Offsite Hazardous Disposal
• Reduction Coagulation Filtration (RCF)
12 711
12/31/2024
2 Hazen Converge Results
3 Hazen Converge Weightings
4 Ranking
(Low to High)
Criteria Weight in Category
Category CriteriaWeight
Category
40% 1 - 10 Reliability to Meet Cr6 Treatment Goal
Reliability & Resiliency 25% System Resilience to Change 30% 1 - 10 Impact from Competing Constituents 30% 1 - 10Equipment Complexity 40% 1 - 10 O&M 15% Chemical Deliveries 50% 1 - 10
Number of FTE 10% 1 - 10
Water Loss 5% Water Loss 100% 1 - 10
Disposal of Liquid Waste 80% 1 - 10
Residuals Handling 25%
Disposal of Solid Waste 20% 1 - 10
50% 1 - 10 Ability to Obtain Environmental Permits 10% Environmental / Community Community Acceptance 50% 1 - 10
Cost 20% Annualized Lifecycle Cost 100% 1 - 10
34 712
12/31/2024
3 Foothill West Cluster
5 M10 & M11 Cluster
6 56
713
12/31/2024
4 Well C3
7 Well C5
8 78
714
12/31/2024
5 Well C6
9 Sensitivity Analysis Rev #1
10 910
715
12/31/2024
6 Sensitivity Analysis #1 Weightings
11 Ranking
(Low to High)
Criteria Weight in Category
Category CriteriaWeight
Category
40% 1 - 10 Reliability to Meet Cr6 Treatment Goal
Reliability & Resiliency 22% System Resilience to Change 30% 1 - 10 Impact from Competing Constituents 30% 1 - 10Equipment Complexity 38% 1 - 10 O&M 13% Chemical Deliveries 47% 1 - 10
Number of FTE 16% 1 - 10
Water Loss 4% Water Loss 100% 1 - 10
Disposal of Liquid Waste 80% 1 - 10
Residuals Handling 20%
Disposal of Solid Waste 20% 1 - 10
50% 1 - 10 Ability to Obtain Environmental Permits 8% Environmental / Community Community Acceptance 50% 1 - 10
Cost 35% Annualized Lifecycle Cost 100% 1 - 10
Foothill West Cluster
12 1112
716
12/31/2024
7 M10 & M11 Cluster
13 Well C3
14 1314
717
12/31/2024
8 Well C5
15 Well C6
16 1516
718
12/31/2024
9 Sensitivity Analysis Rev #2
17 Sensitivity Analysis #2 Weightings
18 Ranking
(Low to High)
Criteria Weight in Category
Category CriteriaWeight
Category
43% 1 - 10 Reliability to Meet Cr6 Treatment Goal
Reliability & Resiliency 14% System Resilience to Change 29% 1 - 10 Impact from Competing Constituents 29% 1 - 10Equipment Complexity 60% 1 - 10 O&M 10% Chemical Deliveries 30% 1 - 10
Number of FTE 10% 1 - 10
Water Loss 4% Water Loss 100% 1 - 10
Disposal of Liquid Waste 57% 1 - 10
Residuals Handling 14%
Disposal of Solid Waste 43% 1 - 10
50% 1 - 10 Ability to Obtain Environmental Permits 8% Environmental / Community Community Acceptance 50% 1 - 10
Cost 50% Annualized Lifecycle Cost 100% 1 - 10
1718
719
12/31/2024
10 Foothill West Cluster
19 M10 & M11 Cluster
20 1920
720
12/31/2024
11 Well C3
21 Well C5
22 2122
721
12/31/2024
12 Well C6
23 Sensitivity Analysis Summary
24 Treatment Alternative Ranking Location Ranking Results RCF WBA SBA 1 SBA 2 SBA 3 Hazen Converge 1 2 4 3 5
Foothill West Cluster Sensitivity Analysis #1 1 2 4 3 5 Sensitivity Analysis #2 1 2 5 3 4Hazen Converge 1 2 4 3 5 M10 & M11 Cluster Sensitivity Analysis #1 1 2 4 3 5
Sensitivity Analysis #2 1 3 5 2 4Hazen Converge 1 2 4 3 5 Well C3 Sensitivity Analysis #1 1 2 4 3 5
Sensitivity Analysis #2 1 3 5 2 4Hazen Converge 1 2 4 3 5 Well C5 Sensitivity Analysis #1 1 2 4 3 5
Sensitivity Analysis #2 1 3 5 4 2Hazen Converge 1 2 4 3 5 Well C6 Sensitivity Analysis #1 1 2 4 3 5
Sensitivity Analysis #2 1 2 5 3 4
• Rankings are
assigned as 1 is the highest ranking and 5 is the lowest ranking 2324
722
12/31/2024
13 Cost Estimates
25 Capital, O&M, Lifecycle Cost Estimates
26 Annual Lifecycle
Cost ($M/Year)
Annual O&M
($M/Year)
Total Project
Capital Costs
($M)
Capital Costs ($M)
Treatment Strategy
Well C3 Well C5 Well C6
M10 &
M11
Cluster
Foothill
West
Cluster

16.1 13.4 5.0 5.0 5.0 31.2 to 66.8 1.1 to 2.4 2.7 to 5.8 SBA Option 1 (Brine Treatment Offsite Disposal)

14.7 12.0 5.0 5.0 5.0 29.2 to 62.5 1.1 to 2.3 2.6 to 5.5 SBA Option 2 (Brine Treatment Sewer Disposal)

12.6 10.5 5.0 5.0 5.0 26.7 to 57.1 1.1 to 2.4 2.5 to 5.3 SBA Option 3 (No Brine Treatment) WBA 17.1 11.7 8.1 8.1 8.1 37.2 to 79.7 1.4 to 3.0 3.3 to 7.1 RCF 14.8 10.7 7.3 7.3 7.3 33.2 to 71.2 1.3 to 2.8 3.0 to 6.4 2526
723
12/31/2024
14 O&M Cost Assumptions
27 O&M Cost Assumptions
28 Name Units Cost Treatment Technology
Electricity ($/kWh) $ 0.16 RCF, WBA, SBA Option 1, 2, and 3Labor Annual Salary ($/yr) $ 151,551.04 RCF, WBA, SBA Option 1, 2, and 3Sewer Discharge ($/cf) $ 3.15 RCF, WBA, SBA Option 1, 2, and 3Sewer Quarterly Fee ($/DEU/month) $ 945 RCF, WBA, SBA Option 1, 2, and 35% Ferrous Chloride ($/gal) $ 2.50 SBA Option 1 and 2Salt ($/ton) $ 147.59 SBA Option 1, 2, and 3Polymer ($/gal) $ 32.56 RCF, SBA Option 1 and 2 2728
724
12/31/2024
15 Questions
29 Question
30 • How does Banning intend on operating the wells/facilities; for compliance and to meet water demands?
2930
725
City of Banning
Chromium 6 Treatment and Compliance Technical Memorandum Update FINAL D-1
Appendix D: RCF Pilot Options
726
12/31/2024
1 RCF Piloting Options
2 Potential RCF Pilot PFD
23 727
12/31/2024
2 Pilot Configuration
Filter Media:• Anthracite/sand• GreensandPlus• Pyrolusite Reduction Time:• 2 minutes
Chemicals:• Ferrous chloride• Hypochlorite• Polymer
RCF Pilot Vendors
5 • Intuitech
• Skid Mounted or Containerized Pilot System
• Containerized system has AC
• Fully automated with SCADA System, ability to operate pilot unmanned
• Includes option for turbidity meters
• Pilot for Purchase
• WQTS
• Skid mounted pilot system• Fully automated SCADA system with data logger • Includes pressure sensors, temperature sensors,
turbidity meters, flow meters and flow control valves
• Includes allocated time for setup and training for pilot operation
• Pilot for Purchase
• Filtronics
• Trailer Mounted Pilot System• Automated filtration system with semi-automatic electric valves
• Pilot for Purchase
• Tonka
• Trailer Mounted System• More manual system quoted, but the pilot can be further customized.
• Pilot for Lease or Purchase
• Culligan
• Pilot for Purchase
• Pending quotation for purchase
• Pureflow
• Pilot for Lease
45 728
3 Configuration Options
6 • Skid Mounted
• Cost Range1 (Purchase): $242,000 - $400,000
• Enclosure Cost
• Cost estimate for enclosure/trailer only• Trailer: $116,000• Enclosure: $132,000 • Container/Trailer Mounted Pilot
• Cost Range (Purchase): $85,000 - $443,000• Lease Cost2: $32,000 • Chemical/Media Cost
• Estimated Chemical Cost: $400/month• Estimated Media Cost: ($1,500) 1Intuitech quote with and without turbidity meters2Cost includes 1 week of pilot rental with the vendor onsite for three (3) days allotted for set-up, tear-down, data collection, or etc.

RCF Pilot Estimates
7 Purchase Lease
Category
Skid Mounted Container/Trailer Mounted Trailer Mounted
Filtronics1 Tonka Tonka1 WQTS Intuitech1 Intuitech1
Cost $242,000 $325,000 $410,000 $85,000 $107,500 $32,500 (first week) Additional Week
(Add $2,500 per)
Additional Tonka Visits (Add
$7,000 per)
Additional Tonka
Visits (Add $7,000
per)
Additional
Customization
Available
Turbidity Meters
(Add $22,000)
--
(fully customized
system)
Turbidity Meters
(Add $22,000) Additional Add-on
20’ Enclosure 14’ trailer 20’ trailer 20’ trailer 10’ H x 10’ L x 2.83’ W2 12.2’ L x 4.2’ W x 10.2’ H Size Lead Time 6-7 months 6-7 months 6-7 months 2 – 3 months 3 months 1 – 1.5 months 1 Quote received is for a standard RCF pilot system, additional customization resulting in price change2 Dimensions for the skid do not include additional chemical tanks and backwash tank 67 729
4 Intuitech Pilot Details
8 Intuitech RCF Pilot
9 DESCRIPTION PART NUMBER COST
GRANULAR MEDIA FILTRATION PILOT PLANT1 F40610-SAP-41PC-4TU-4CF $243,459GRANULAR MEDIA FILTRATION PILOT PLANT F40610-SAP-41PC-0TU-4CF $221,707PILOT MODULE ENCLOSURE E201112-2ED-1SD-1PS-HVAC-SVN-FWS $168,042 $179,504
E401112-2ED-1SD-1PS-HVAC-SVN-4LABPILOT MODULE ENCLOSURE FWS STARTUP - 1 DAYS $5,633SHIPPING (EST) $14,145TAX TBD
1 Includes Turbidity Meters
Quotation Details:• Enclosure (Options)
• Plug and play ready for operation,
treatment modules will be prewired and pre-plumbed at the factory. • Allow for single electrical connection with
NEMA 4x panel and exterior electric disconnect panel
• Wall mount HVAC unit, AC, and heater
included
• Optional laboratory module included
cabinets, chemically resistant countertops, outlets, sink and water • 20’ Enclosure (Option)• 40’ Enclosure (Option)
• Turbidity Meters
• With or without turbidity meters
• First column can be configured as a reaction
vessel feeding into the three columns
• Quotation does not include chemicals or
media but does include equipment such as chemical tanks, pumps, etc. • Approximately 6-7 months lead time
89 730
5 Intuitech Pilot Additional Details
10 Example Specification
Maximum Total Flow Rate 5.2 gpm (19.7 L/min)Filters 4 @ 6 x 112 inch (152 x 2,840 mm)Maximum Media Depth 72 inch (183 cm)Media Retention Size > 0.0059 inch (149 µm)Filtration Rate 1.3…6.6 gpm/sf (3.2…16.1 m/h)Backwash Rate 5.1…51.0 gpm/sf (12.4…124.7 m/h)Backwash Tank Volume 150 gal (568 L) Air Scour Rate 2.6…9.2 scfm/sf (46.6…164.9 m/h)
Maximum Headloss 25 feet (7.6 m)Chemical Feed Systems 4Chemical Feed Rate 0.03…57 mL/minChemical Tank Volume 4 gallon (15.1 L) Dimensions 146 inch (3.71 m) L x 50 inch (1.27 m) W x 122.5 inch (3.11 m) HDry Weight 2,700 lbs. (1,315 kg)Operating Weight 4,200 lbs. (1,905 kg)Electrical Requirements 1 Phase, 18.8 A @ 120 VAC or 1 Phase, 9.4A @ 240 VAC, 50/60Hz Flow Rate, Headloss, Effluent Turbidity, and Column Level for each filter, Chemical Dosage, Chemical Flow, and Chemical Tank Level for each feed system, Air Scour Flow, Backwash Flow, Backwash Tank Level, Spare Analog Signals (3 qty.) Monitored Parameters
Filtronics Pilot Details
11 1011
731
6 Filtronics RCF Pilot
12 Quotation Details:• Purchase Cost: $85,000• Enclosure • Double-axle 14’ trailer (right)
• Fully Automated filtration system with semiautomatic electric valves• Standard quotation, depending on specifications, the final purchase cost could go up or down. • Lead time is approximately 6 – 8 weeks for
the trailer and an additional 2 – 4 weeks for filtration system assembly • Turnaround time is based on the
availability of the trailer.

WQTS Pilot Details
13 1213
732
7 WQTS RCF Pilot
14 Quotation Details:• General
• Number of Pre-Contactor Columns: 1 column
• Contactor Column Diameter: 6 inches• Contactor Column Height: 60 inches• Contactor Column Volume: 9.7 gallons 2.0 min. HRT with 3 filters at 8 gpm/sf
• Number of Filters: 3 columns• Filter Column Diameter: 6 inches• Filter Column Internal Height: 92 inches• Max Media Depth: 60 inches• Filter Loading Rate Range: 1.5-13 gpm/sf• Filter Flow Range: 0.3-2.6 gpm• Back Wash Air Scour Rate Range: 1 - 5 scfm/sf• Air Scour Flow Range: 0.2 - 1.0 scfm (5.6 - 21.8 slpm)• Backwash Loading Rate Range: 2.5-45 gpm/sf• Backwash Flow Range: 0.5-9 gpm• Number of Pre-Contactor/Filter Chemical Pumps: 5 pumps 2 for Pre-Contactor and 1 per Filter
• Feed Range: 0.035 - 69 mL/min• Number of Chemical Day Tanks: 5 tanks• Capacity of Chemical Day Tanks: 7 gallons• Number of Clearwell/Backwash Supply Tanks: 1 tank• Clearwell/Backwash Tank Volume: 200 gallon • Physical
• Assembled Dimensions: 120"H x 120"W x 34"D
• Electrical
• Phase: 1• Frequency: 60 Hz• Voltage: 120 VAC• Current: 20 amp max • Instrumentation
• Pressure Sensors: 4 Transducer Pre-contacor/1 per
Filter column*
• Temperature Sensor: 2 Transducer Inlfuent/Clearwell*• Turbidimeter: 3 online analyzers 1 per column*• Clearwell Tank Pressure Sensor: 1 Transducer Tank volume*
• Backwash Mag Flow Meter: 1 meter• Flow Conrol Valve/ Mag Meter: 3 meter/flow control Filter Flow rate*
• Mass Flow Controller: 1 controller• Electrical requirement: 120VAC/1PH/60HZ, 20 AMP Note: Chemical supply and backwash tank(s) not accounted for in pilot footprint. • Typical 7 gallon chemical tank 12”(W) x 12” (D) x 12” (H)• Typical 200 gallon backwash supply/clearwell tank 34”(Dia.) x 56” (H)
Tonka Pilot Details (Lease)
15 1415
733
8 Tonka RCF Pilot (Lease)
16 Quotation Details:• Lease Cost: $32,500
• Standard quotation, depending on specifications, the final cost could go up or down.• Including pilot for 1 week, with a technician onsite to set up equipment and train on-site personnel on operation.
• Tonka engineer will be available for the duration of the pilot for questions and consultation• Add-ons:
• Additional trips for Tonka support: $7,000.00 per trip• Additional time for pilot equipment rental $2,500.00 per week • Pilot Specifics
• 20’ trailer with 120V, 30A connection to power the pilot equipment • Miscellaneous equipment consisting of flexible tubes, valves, fittings, and other necessary appurtenances to provide a fully operable system.
• Fully Automated filtration system with semi-automatic electric valves • Three (3) 8” diameter media filtration columns (GreensandPlus , pyrolusite, and sand/anthracite) • Columns will have valve manifold to accommodate all modes of service and backwash and will include a loss of head gauge and sample taps.
• Filtration assembly is approx. 4’ x 8’ and height of approximately 8’ and requires a continuous flow. • The filter column is intended to be operated at 8 gpm/sft • (Optional) Detention basin(s) with multiple outlet ports to calibrate the desired amount of reduction time • Delivery is approximately 4 – 6 weeks after PO.
16 734

CITY OF BANNING

STAFF REPORT
TO: CITY COUNCIL
FROM: Robert Fisher, Acting City Manager
PREPARED BY: Brandon Robinson, Electrical Engineering Supervisor Art Vela, Director of Public Works
MEETING DATE: July 8, 2025
SUBJECT: Accepting a Quitclaim of Existing City Easements Related to the Improvement of Tract Map No. 37389-6, PA 9A Within the Atwell Specific Plan
RECOMMENDATION:

Staff recommends that the City Council accept a quitclaim of existing easements from Tri Pointe Homes for electric utility purposes for Tract Map No. 37389-6, PA 9A within the Atwell development for the maintenance of the City-owned electric distribution system.

BACKGROUND:

The recommended action would quitclaim portions of easements for electric utility purposes that was originally recorded February 4, 1960 for the Highland Estates tract map and included with Atwell Final Map 37389-6, PA 6A. The existing electric facilities were adjusted with the Lot Line Adjustment between Tri-Pointe Homes and the existing homeowners within Highland Estates per an agreement between the parties and the City of Banning's Electric Utility. The portion of easement to be quitclaimed provides no benefit to the City of Banning across private properties within the Highland Estates and the Atwell development, and would not cause any harm to the City of Banning to quitclaim the portion of the easement.

JUSTIFICATION:

City Council action on this item is necessary in order for Tri Pointe Homes to comply with the conditions of approval for Tract Map No. 37389-6, and for the construction of the subdivision without hinderances or obstruction caused by electric utility facilities.

FISCAL IMPACT:

There is no fiscal impact associated with the acceptance of the quitclaim.

ALTERNATIVES:

Do not accept the quitclaim and provide alternative direction.

BUDGETED?:

No
CONTRACT/AGREEMENT:

No
ATTACHMENTS:
735

1. QUITCLAIM DEED_Tract 37389-6 PA 9A.doc

2. Quitclaim Easement Legal & Boundary 37389-_PA 9A.pdf 736
Escrow No.

Loan No.

Recording Requested by:

City of Banning
P.O. Box 998
Banning, CA 92220
NO RECORDING FEE PER SECTION 6103 OF

THE GOVERNMENT CODE SPACE ABOVE THIS LINE FOR RECORDERS USE APN: 408-570-049, 055
DOCUMENTARY TRANSFER TAX $..........................................

Computed on the consideration or value of property conveyed: OR Computed on the consideration or value less liens or encumbrances remaining at time of sale
_____________________________________________________
Signature of Declarant or Agent determining tax - Firm Name

QUITCLAIM DEED
FOR A VALUABLE CONSIDERATION, receipt of which is hereby acknowledged, THE CITY OF BANNING, a public body corporate and politic (“Grantee”), does hereby remise, release and forever quitclaim to: TRI POINTE HOMES IE-SD, INC. a California Corporation portions of a Grant of Easement for electric maintenance purpose, on the real property in the City of Banning, County of Riverside, State of California, and described in Exhibit A, Legal Description and Exhibit B, Boundary Survey attached hereto and a made a part hereof (the “Property”).

Dated: _____________________
Sheri Flynn, Mayor
City of Banning
737

APPROVED AS TO FORM:

John Pinkney, City Attorney
SBEMP
State of California
County of Riverside
On ___________________ (date), before me, S. Caroline Patton, Notary Public, personally appeared , who proved to me on the basis of
satisfactory evidence to be the person(s) whose name(s) is/are subscribed to the within instrument and acknowledged to me that he/she/they executed the same in his/her/their authorized capacity(ies), and that by his/her/their signature(s) on the instrument the person(s), or the entity upon behalf of which the person(s) acted, executed the instrument.

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

WITNESS my hand and official seal.

Signature (Seal)
Vickie Sellers, City Clerk
City of Banning
}
738
State of California
County of Riverside
On ___________________ (date), before me, S. Caroline Patton, Notary Public, personally appeared , who proved to me on the basis of
satisfactory evidence to be the person(s) whose name(s) is/are subscribed to the within instrument and acknowledged to me that he/she/they executed the same in his/her/their authorized capacity(ies), and that by his/her/their signature(s) on the instrument the person(s), or the entity upon behalf of which the person(s) acted, executed the instrument.

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

WITNESS my hand and official seal.

Signature (Seal)
}
739
740
EXHIBIT "B"
741

CITY OF BANNING

STAFF REPORT
TO: CITY COUNCIL
FROM: Robert Fisher, Acting City Manager
PREPARED BY: David Newell, Community Development Director David Newell, Community Development Director
MEETING DATE: July 8, 2025
SUBJECT: Consideration of Second Reading and Adoption of Ordinance 1610, Adopting the Fire Hazard Severity Zones within the City of Banning Based on Maps Provided by the California Department of Forestry and Fire Protection by Amending the Banning Municipal Code Section

8.16.020 and Chapter 15.28
RECOMMENDATION:

Waive the second reading of the text in its entirety, read by title only, and adopt Ordinance 1610:

AN ORDINANCE OF THE CITY OF BANNING, CALIFORNIA, ADOPTING THE FIRE HAZARD

SEVERITY ZONES WITHIN THE CITY OF BANNING BASED ON MAPS PROVIDED BY THE

CALIFORNIA DEPARTMENT OF FORESTRY AND FIRE PROTECTION BY AMENDING THE BANNING MUNICIPAL CODE SECTION 8.16.020 AND CHAPTER 15.28 BACKGROUND:

On June 24, 2025, the City Council held a public hearing on an ordinance (Ordinance 1610) adopting the Fire Hazard Severity Zones (FHSZ) within the City of Banning, as required by Section 51179 of the California Government Code. The ordinance proposes repealing Chapter 15.28, Fire Districts, and amending Chapter 8.16, Fire Protection Code. Chapter 15.28 of Title 15 (Buildings and Construction) includes old references that are no longer applicable and therefore requires repealing this Section.

Chapter 8.16 is proposed to be amended by identifying the FHSZ Map received on March 24, 2025, as the City's adopted map within the paragraph referenced as Chapter 49 of Section 8.16.020. After closing the public hearing, the City Council voted 5-0 to introduce by title only Ordinance 1610.

Because there were no changes directed by Council when first introduced, the second reading of Ordinance 1610 is the same as first reading. If the Council adopts the ordinance, it would go into effect 30 days thereafter.

JUSTIFICATION:

The designation of Fire Hazard Severity Zones (FHSZ) under Government Code section 51178 requires local agencies to engage in a transparent and participatory process to ensure that affected communities have access to updated wildfire hazard information. The updated Fire Hazard Severity Zones (FHSZ) maps were released on March 24, 2025, triggering the requirement for local agencies to make this information available for public review and comment within 30 days of receipt. In compliance with this requirement, the map was posted on the City of Banning’s website for public access and review on April 2, 2025. The City also held an informational workshop with the City Council on April 22, 2025. 742
Under Government Code Section 51179, cities and other local agencies are required to adopt the State’s Fire Hazard Severity Zones (FHSZ) Map recommendation for Local Responsibility Areas (LRA’s) within 120 days of receiving them. Government Code section 51179(b)(3) prohibits any local agency from decreasing the severity of the zones as identified by the State Fire Marshal for any area within the jurisdiction.

FISCAL IMPACT:

There is no fiscal impact on the City of Banning.

ALTERNATIVES:

Do not conduct the second reading of Ordinance 1610 and provide alternative direction to staff.

However, it is important to note that the City's adoption of the updated Local Responsibility Area (LRA) FHSZ map is mandated by the California Government Code.

BUDGETED?:

No
CONTRACT/AGREEMENT:

No
ATTACHMENTS:

1. Ordinance 1610

2. City of Banning Local Responsibility Area Fire Hazard Severity Zones.pdf

3. Existing Chapter 8.16 Fire Protection Code

4. Existing Chapter 15.28 Fire Districts
743
Ordinance 1610