Agenda packet — Beaumont City Council, June 4, 2024 (part 11 of 30)

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resources documenting prehistoric and historic use of this property, and the poor ground visibility during the survey, there is a potential to impact buried prehistoric archaeological resources during ground disturbance activities (i.e., grading and excavation activities). Like the Project, mitigation measures would be required to reduce potential impacts to less than significant. Therefore, impacts to cultural resources from the Reduced Intensity Alternative would be similar to those of the Project.

F. Energy
Under the Reduced Intensity Alternative, the total building square footage would be reduced and building energy demand would also be proportionately reduced by approximately 10% due to a proportional decrease in building energy consumption and fuel from the reduction in vehicle trips.

Construction and operational activities associated with this alternative would have reduced energy demand compared to the Project and impacts would remain less than significant.

G. Geology and Soils
Grading and development of the Project site would still occur under the Reduced Intensity Alternative, and therefore, impacts to geology and soils would be similar to those that would be generated from the Project. This alternative would also result in a similar potential to impact undiscovered paleontological resources during grading, as the Project. However, like the Project, mitigation measures would be required to reduce potential impacts to less than significant. Therefore, impacts to paleontological resources from the Reduced Intensity Alternative would be similar to those of the Project.

H. Greenhouse Gas Emissions
The Reduced Intensity Alternative would have a reduced amount of building square footage.

Therefore, implementation of the Reduced Intensity Alternative would result in fewer impacts from construction -related GHG emissions that would occur from implementation of the Project.

As previously discussed, Project -related GHG emissions would exceed the 3,000 MTCO2e per year significance threshold for GHG emissions and would result in a cumulatively -considerable impact. No feasible mitigation measures exist that would reduce the Project's GHG emissions to levels that are less than significant.

The Reduced Intensity Alternative would decrease vehicle trips by approximately 10%, which is calculated based on square footage and the types of use. The Project would result in a net increase of 60,638.09 MTCO2e per year (approximately 80% mobile source), which would be reduced to 51,556.08 MTCO2e per year (approximately 84% mobile source) under the Reduced Intensity Alternative (see Technical Appendix P of this EIR). However, the Project's significant ant and unavoidable GHG impacts would remain, since the alternative's GHG emissions would exceed the threshold of 3,000 MTCO2e per year. Therefore, GHG emissions impacts would remain significant and unavoidable, but reduced compared to the Project.

Lead Agency: City of Beaumont SCH No. 2020099007

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1. Hazards and Hazardous Materials
The Reduced Intensity Alternative would develop the Project site for the same uses, and therefore the same type of hazardous materials typically used for construction and operation of the Project would be used under the Reduced Intensity Alternative. Similarly, the use and storage of hazardous materials would be regulated by the same federal, state, and local laws and permitting requirements as would occur with the Project. There were no identified contaminated soils on the Project site, therefore construction activities would not involve the transport of contaminated soils, similar to the Project.

Similar to the Project, this alternative would result in less than significant impacts related to hazards and hazardous materials.

J. Hydrology and Water Quality
The Reduced Intensity Alternative would reduce the total building square footage; however, the area of impervious surfaces would be similar compared to the Project. Therefore, this alternative would result in similar runoff and potential for impacts to drainage, erosion, and water quality. Similar to the Project, this alternative would introduce new sources of water pollutants from construction and operation activities. Additionally, this alternative would be required to include storm drain facility improvements, LID, source control, site design, and treatment control BMPs. Therefore, the Reduced Intensity Alternative would result in similar impacts to hydrology and water quality as the Project and would be less than significant.

K. Land Use and Planning
The Reduced Intensity Alternative would require a General Plan Amendment, Pre -zoning to "Specific Plan, Adoption of the Beaumont Pointe Specific Plan, Tentative Parcel Map and a Pre -Annexation to implement the development similar to the Project. Similar to the Project, this alternative would be consistent with the SCAG's Connect SoCal policies, the City's General Plan and Zoning Ordinance, and Western Riverside County MSHCP. Therefore, the Reduced Development Area and Intensity Alternative would result in a less than significant impact related to land use and planning and impacts would be similar compared to the Project.

L. Mineral Resources
The Project site is not designated as a mineral resource recovery site by the City's General Plan and does not contain any known mineral resources that would be of value to the region or the residents of the State. Therefore, development of the Project would result in less than significant impacts to mineral resources. Similarly, the Reduced Intensity Alternative would have the same development impact area and implementation of this alternative would have less than significant impacts related to mineral resources as the Project. Therefore, the Reduced Intensity Alternative would have similar impacts as the Project.

Lead Agency: City of Beaumont SCH No. 2020099007

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M. Noise
Construction and operation noise impacts would be reduced under the Reduced Intensity Alternative due to the reduction of 499,500 sf of industrial uses and 24,600 sf of general commercial uses.

Although construction of this alternative would generate the same peak noise volumes and similar type and volume of construction noise as the Project, the length of time of construction and the associated noise would be marginally shorter. Operational noise would also be reduced under this alternative as traffic -generated and stationary noise sources would decrease in relation to the reduction in industrial and commercial square footage. However, Project -related off -site traffic -related noise level increases would remain significant and unavoidable. Noise impacts from the Reduced Intensity Alternative would remain significant and unavoidable for off -site traffic -related noise, but reduced compared to the Project.

N. Population and Housing
Under the Reduced Intensity Alternative, buildout would result in a total of 4,836 jobs2, 620 fewer jobs compared to the Project's generated 5,456 jobs. However, as shown in Table 6-5, Estimated Population and Housing Growth in Beaumont with the Reduced Intensity Alternative, under from the Reduced Intensity Alternative and similar to the Project, the employment at buildout would be consistent with the both SCAG and City growth forecasts. This alternative would also contribute to an improved jobs - housing ratio of 0.88 for the City under existing plus Project conditions and 0.91 at Project buildout, similar to the Project's jobs -housing ratio of 0.92 and 0.93, respectively. Overall, impacts to population and housing would remain less than significant with this alternative and similar to the Project.

Table 6-5 Estimated Population and Housing Growth in Beaumont with the Reduced Intensity Alternative
Existing
(2020/21)
Buildout Year
(2027) Without
Project2
Existing (2021)
Plus Project (2027)
Buildout Year
Plus Project

City of Beaumont
General Plan
(2040)
Population
51,4751
58,757
51,475
58,757
131,949
Household
17,2321
19,487
17,232
19,487
40,849
Employment
10,4402
12,808
15,276
17,664
38,224
Job -Housing
Ratio

0.61 0.66

0.88 0.91

0.93 1 Values are from the California Department of Finance (DOF), as shown in Section 4.14.1C. 2 These values are prorated from SCAG's demographic data contained in Table 4.14-1.

0. Public Services
Under the Reduced Intensity Alternative, development would be reduced by approximately 10%. This would result in a corresponding reduction in demands placed on public services, including fire 2 Based on standard employment factors in the City's General Plan. Specifically, 1,000 s.f./employee for 4,045,950 s.f. Industrial Warehouse, 750 s.f./employee for 449,550 s.f. General Light Industrial, and 1,163 s.f./employee for 221,400 s.f. of Commercial.

Lead Agency: City of Beaumont SCH No. 2020099007

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protection and law enforcement. However, as with the Project, impacts would be less than significant.

Overall, impacts associated with public services under the Reduced Intensity Alternative would be less than significant, but reduced when compared to the Project.

P. Recreation
Under the Reduced Intensity Alternative, fewer employees would be introduced to the Project, which would reduce potential impacts resulting from additional demand on parks and recreational facilities in the City. Similar to the Project, this alternative would include active and passive recreational amenities and entertainment. Furthermore, the City currently has a park ratio of 6.52 acres of parkland per 1,000 residents (343.4 acres of parkland in total), exceeding the goal of 5 acres of parkland per 1,000 residents. Similar to the Project, employees and visitors who may occasionally use the City's neighborhood parks, regional parks, or other recreational facilities, would not cause a substantial deterioration of park facilities. Overall, impacts associated with recreation under the Reduced Intensity Alternative would be less than significant and similar to the Project.

Q. Transportation
Construction and operation -related vehicle truck trips would be reduced under the Reduced Intensity Alternative and would decrease by approximately 10%. This would result in a corresponding decrease in overall VMT and proportional decrease in employees. Therefore, the resulting VMT per employee would be similar to the Project since it is based on Project generated VMT divided by number of employees. As shown, in Table 6-6, Comparison of Project VMT to the Reduced Intensity Alternative, this alternative would slightly increase VMT per service population from 39.19 to 39.82 compared to the Project (see Technical Appendix P of this EIR). Therefore, the Reduced Intensity Alternative would continue to exceed the City's baseline VMT threshold and impacts would remain significant and unavoidable, but similar compared to the Project.

Table 6-6 Comparison of Project VMT to the Reduced Intensity Alternative Project
Reduced Intensity Alternative
VMT
213,809
192,575
VMT per SP

39.19 39.82
City Threshold

27.03 27.03
Significant?
Yes
Yes
R. Tribal Cultural Resources
The Reduced Intensity Alternative would result in a similar potential to adversely affect tribal cultural resources as the Project, since the development impact area would be the same. However, like the Project, mitigation measures would be required to reduce potential impacts to less than significant.

Therefore, impacts that could occur by the Reduced Intensity Alternative would be similar to those associated with the Project.

Lead Agency: City of Beaumont
SCH No. 2020099007

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S. Utilities and Service Systems
The Reduced Intensity Alternative would reduce the total allowable building square footage by 499,500 sf of industrial uses and 24,600 sf of general commercial uses. This would reduce the number of employees on the Project site and the demand for utilities and service systems. The water and wastewater generation rates are based on the number of employees and square footage. Therefore, the demand for regional water supplies and generation of wastewater would be reduced by approximately 10%. Similarly, solid waste generation would be less than the Project and require less landfill capacity.

Therefore, impacts to utilities and service system would be less under this alternative when compared to the Project and less than significant.

T. Wildfire
The Project site is designated within a VHFHSZ and HFHSZ. Similar to the Project, the Reduced Development Area and Intensity Alternative would be required to maintain adequate emergency access for emergency vehicles on site, comply with the City's emergency operations plan for evacuations, would be constructed with ignition resistant materials and to the highest fire protective building code standards. In addition, this alternative would be required to create defensible space to protect and create defensible space to protect against wildfire hazards. Similar to the Project, this alternative would require the installation of on -site utility infrastructure that would connect to the existing utility infrastructure within the surrounding roadways. Additionally, as with the Project, this alternative would not result in the modification to existing slopes in a way that would exacerbate fire risk or increase flooding or landslides, and would not exacerbate pollution from wildfires. Therefore, impacts related to wildfire would be similar to the Project and less than significant.

U. Conclusion

1. Avoid or Substantially Lessen the Significant Impacts of the Project The Reduced Intensity Alternative would result in reduced impacts related to air quality, energy, GHG emissions, noise, public services, and utilities and service systems due to the reduction in square footage and associated vehicular trips. However, significant and unavoidable impacts related to air quality, GHG emissions, noise, and transportation would continue to occur from implementation of this alternative. Impacts related to aesthetics, agriculture and forestry resources, biological resources, cultural resources, geology and soils, hazardous and hazardous materials, hydrology and water quality, land use and planning, mineral resources, population and housing, recreation, transportation, tribal cultural resources, and wildfire would be similar to the Project.

2. Attainment of Project Objectives
The Reduced Intensity Alternative would meet Project Objectives, A, B, and F —I, as described in Section 6.1.1. As compared with the Project, this alternative would not meet the following objectives to the same extent, due to the reduced industrial and commercial building square footage and proportional reduction in employees:

Lead Agency: City of Beaumont SCH No. 2020099007

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• Objective C. Maximizing opportunities to develop land in the City's sphere of influence to provide job opportunities and economic benefit to the City and its residents, including new sales and property tax revenues that can be used for City services and providing sufficient fiscal benefit to permit annexation of the Project site into the City. • Objective D. Creating new job opportunities within the City of Beaumont to improve and maximize the jobs to housing balance within the City and reduces the need for members of the existing local workforce to commute long distances.
• Objective E. Fulfilling a need in the City and region for wellness based retail, including entertainment, recreation, hospitality, and restaurants.

6.4.5 TRUCK STORAGE YARD ALTERNATIVE
The Truck Storage Yard Alternative was selected to reduce impacts associated with air quality, GHG emissions, noise, and transportation. The Truck Storage Yard Alternative would be the same as the Project except that it would replace the warehouse building in Planning Area 8 (approximately 1,000,000 sf) with a truck storage and lay down yard. Overall, the Project would allow for up to 246,000 sf of commercial development, a 125 -room hotel, 4,000,000 sf of industrial development, and a truck storage yard for an approximately 20% decrease in total building square footage. It is assumed that the truck storage yard would be an ancillary use to one of the adjacent industrial warehouse buildings. The grading quantities and phases would be the same as the Project. The Truck Storage Yard Alternative would reduce the number of vehicle trips. Trip generation is calculated based on square footage and the types of use. The Truck Storage Yard Alternative would result in a total of 14,136 vehicle trips, compared to the Project's 16,266 trips (see Technical Appendix P to this EIR).

A. Aesthetics
The Project site does not contain any unique aesthetic resources, nor does it serve as a prominent scenic vista. The Truck Storage Yard Alternative would have the same development area as the Project. The existing vacant and undeveloped site would be replaced with 4,000,000 sf of industrial development, 246,000 sf of commercial development, and a 125 -room hotel at the same height as the Project. This alternative would also include design features similar to the Project to create an aesthetically pleasing building and site design. Walls and fences will be provided for screening, buffering, and security purposes along building site perimeters and interior to building sites. Landscaping would include a variety of trees, shrubs, vines, and accent plants along the site's perimeter. Monumentation featuring colorful accent trees, shrubs, and groundcover occur at the Project entrances. Streetscape landscaping presents a combination of evergreen and deciduous trees, low shrubs, and masses of groundcovers to create a visually pleasing experience for pedestrians and passing motorists. Accordingly, implementation of the Truck Storage Yard Alternative would result in the similar impacts as compared to the Project and would be less than significant.

Lead Agency: City of Beaumont SCH No. 2020099007

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B. Agriculture and Forestry Resources
The majority of the Project site is designated as "Other Land" and the remaining portions (60.9 acres) of the site, located around the northern portions of the Project site, is designated "Farmland of Local Importance. The Truck Storage Yard Alternative would continue to cover the same impact area as the Project site. Similar to the Project, this alternative would result in less than significant impacts related to agriculture and forestry resources.

C. Air Quality
The Truck Storage Yard Alternative would have a reduced amount of building square footage.

Therefore, implementation of the Truck Storage Yard Alternative would result in the fewer impacts from construction -related air quality that would occur from implementation of the Project; however, Project -related NOx emissions during construction would remain significant and unavoidable.

The Project's operational emissions of VOC, NOx, PM1o, and PM2.s would exceed the applicable South Coast AQMD regional thresholds for operational -source emissions of VOC, NOx, PM10, and PM2.5 and would therefore contribute to the violation of an air quality standard and result in a cumulatively considerable net increase of an ozone precursor. No feasible mitigation measures exist that would reduce the Project's emissions to levels that are less than significant.

Additionally, the Truck Storage Yard Alternative would reduce the number of vehicle trips and associated VMT, which is calculated based on square footage and the types of use. Under the Truck Storage Yard Alternative, the volume of VOC, NOx, PM10, and PM2.s emissions would be reduced to approximately 162.47, 322.85, 196.97, 57.09 pounds per day during summer and 154.16, 350.34, 196.98, and 57.10 pounds per day during winter, respectively. The South Coast AQMD thresholds for VOC, NOx, PM10, and PM2.5 are 55, 55, 150, and 55, respectively. Therefore, this alternative would not reduce the Project's operational air quality emissions to a less than significant level and a significant unavoidable air quality impact would remain.

D. Biological Resources
The Truck Storage Yard Alternative would generally involve the same physical impact area as the Project. Therefore, this alternative would result in the same temporary and/or permanent impacts to biological resources (including potential impacts to special -status wildlife species, burrowing owl, nesting birds, coastal California gnatcatcher, and jurisdictional waters) as the Project and mitigation measures would be implemented to reduce impacts to such resources to a less than significant level.

Therefore, impacts would be similar to the Project.

E. Cultural Resources
The Truck Storage Yard Alternative would have the same impact area and no known historic resources, archaeological resources, cultural resources, or human remains were identified as occurring within the Project site under existing conditions. However, due to the presence of cultural resources documenting prehistoric and historic use of this property, and the poor ground visibility during the survey, there is Lead Agency: City of Beaumont SCH No. 2020099007

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a potential to impact buried prehistoric archaeological resources during ground disturbance activities (i.e., grading and excavation activities). Like the Project, mitigation measures would be required to reduce potential impacts to less than significant. Therefore, impacts to cultural resources from the Truck Storage Yard Alternative would be similar to those of the Project.

F. Energy
Under the Truck Storage Yard Alternative, the total building square footage would be reduced and building energy demand would also be reduced by 13% due to a proportional decrease in building energy consumption and fuel from the reduction in vehicle trips. Construction and operational activities associated with this alternative would have reduced energy demand compared to the Project and impacts would remain less than significant.

G. Geology and Soils
Grading and development of the Project site would still occur under the Truck Storage Yard Alternative, and therefore, impacts to geology and soils would be similar to those that would be generated from the Project. This alternative would also result in a similar potential to impact undiscovered paleontological resources during grading, as the Project. However, like the Project, mitigation measures would be required to reduce potential impacts to less than significant. Therefore, impacts to paleontological resources from the Truck Storage Yard Alternative would be similar to those associated with the Project.

H. Greenhouse Gas Emissions
The Truck Storage Yard Alternative would have a reduced amount of building square footage.

Therefore, implementation of the Truck Storage Yard Alternative would result in fewer impacts from construction -related GHG emissions that would occur from implementation of the Project.

Additionally, the Truck Storage Yard Alternative would also decrease vehicle trips by 13% from 16,266 trips -ends per day to 14,134 trips -ends per day, which is calculated based on square footage and the types of use. The Project would result in a net increase of 60,638.09 MTCO2e per year (approximately 80% mobile source), which would be reduced to 48,655.28 MTCO2e per year (approximately 83% mobile source) under the Truck Storage Yard Alternative. This alternative would still result in significant and unavoidable GHG impacts, since it would exceed the threshold of 3,000 MTCO2e per year. Therefore, GHG emissions impacts would remain significant and unavoidable, but reduced compared to the Project.

Lead Agency: City of Beaumont SCH No. 2020099007

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1. Hazards and Hazardous Materials
The Truck Storage Yard Alternative would develop the Project site for the same uses, and therefore the same type of hazardous materials typically used for construction and operation of the Project would be used under the Truck Storage Yard Alternative. Similarly, the use and storage of hazardous materials would be regulated by the same federal, state, and local laws and permitting requirements as would occur with the Project. There were no identified contaminated soils on the Project site, therefore construction activities would not involve the transport of contaminated soils, similar to the Project.

Similar to the Project, this alternative would result in less than significant impacts related to hazards and hazardous materials.

J. Hydrology and Water Quality
The Truck Storage Yard Alternative would reduce the total building square footage; however, the area of impervious surfaces would be similar compared to the Project. Therefore, this alternative would result in similar runoff and potential for impacts to drainage, erosion, and water quality. Like the Project, this alternative would introduce new sources of water pollutants from construction and operation activities. Additionally, this alternative would be required to include storm drain facility improvements, LID, source control, site design, and treatment control BMPs. Therefore, the Truck Storage Yard Alternative would result in similar impacts to hydrology and water quality as the Project and would be less than significant.

K. Land Use and Planning
The Truck Storage Yard Alternative would require a General Plan Amendment, Pre -zoning to "Specific Plan, Adoption of the Beaumont Pointe Specific Plan, Tentative Parcel Map and a Pre - Annexation to implement the development similar to the Project. This alternative would have the same type of consistency with the SCAG's Connect SoCal policies, the City's General Plan and Zoning Ordinance, and Western Riverside County MSHCP. While, like the Project, this alternative would not conflict with the SCAG's Connect SoCal policies, it would impede the Connect SoCal goal of growing the Beaumont area as a job center to a greater extent than would the Project. Nevertheless, the Truck Storage Yard Alternative would result in a less than significant impact related to land use and planning and similar compared to the Project.

L. Mineral Resources
The Project site is not designated as a mineral resource recovery site by the City's General Plan and does not contain any known mineral resources that would be of value to the region or the residents of the State. Therefore, development of the Project would result in less than significant impacts to mineral resources. Similarly, the Truck Storage Yard Alternative would have the same impact area and implementation of this alternative would have less than significant impacts related to mineral resources as the Project. Therefore, the Truck Storage Yard Alternative would have similar impacts as the Project.

Lead Agency: City of Beaumont SCH No. 2020099007

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M. Noise
Construction and operation noise impacts would be reduced under the Truck Storage Yard Alternative because this alternative would decrease the development area by 1,000,000 sf of industrial uses.

Although construction of this alternative would generate the same peak noise volumes and similar type and volume of construction noise as the Project, the length of time of construction and the associated noise would be marginally shorter. Operational noise would also be reduced under this alternative as traffic -generated and stationary noise sources would decrease in relation to the reduction in industrial square footage. However, Project -related off -site traffic noise level increases are considered significant and unavoidable. Noise impacts from the Truck Storage Yard Alternative would remain significant and unavoidable, but reduced compared to the Project.

N. Population and Housing
Under the Truck Storage Yard Alternative, buildout would result in a total of 4,345 jobs3, 1,111 fewer jobs compared to the Project's generated 5,456 jobs. However, as shown in Table 6-7, Estimated Population and Housing Growth in Beaumont with the Truck Storage Yard Alternative, similar to the Project, the employment at buildout would be consistent with the both SCAG and City growth forecasts and contribute to an improved jobs -housing ratio of 0.85 for the City under existing plus Project conditions and 0.88 at Project buildout. However, the jobs -housing ratio would decrease from the Project's 0.92 to 0.85 for the City under existing plus Project conditions and from 0.93 to 0.88 under buildout year plus project conditions, creating a greater jobs -housing imbalance as compared to the Project, and would impede the project objective of maximizing the opportunity of increasing the jobs housing balance. Overall, impacts to population and housing would remain less than significant with this alternative, but would be greater than the Project.

Table 6-7 Estimated Population and Housing Growth in Beaumont with the Truck Storage Yard Alternative
Existing
(2020/21)
Buildout Year
(2027) Without
Project
Existing (2021)
Plus Project
Buildout Year
(2027) Plus Project
City of Beaumont
General Plan
(2040)
Population
51,4751
58,757
51,475
58,757
131,949
Household
17,2321
19,487
17,232
19,487
40,849
Employment
10,4402
12,808
14,785
17,153
38,224
Job -Housing
Ratio

0.61 0.66

0.85 0.88

0.93 1 Values are from the California Department of Finance (DOF), as shown in Section 4.14.1 C. 2 These values are prorated from SCAG's demographic data contained in Table 4.14-1. 3 Based on standard employment factors in the City's General Plan. Specifically, 1,000 s.f./employee for 3,600,000 s.f. Industrial Warehouse, 750 s.f./employee for 400,000 s.f. General Light Industrial, and 1,163 s.f./employee for 246,000 s.f. of Commercial.

Lead Agency: City of Beaumont
SCH No. 2020099007

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0. Public Services
Under the Truck Storage Yard Alternative, development would be reduced by 20%. This would result in a corresponding reduction in demands placed on public services, including fire protection, law enforcement, schools, and library services. However, as with the Project, impacts would be less than significant. Overall, impacts associated with public services under the Truck Storage Yard Alternative would be less than significant, but slightly reduced compared to the Project.

P. Recreation
Under the Truck Storage Yard Alternative, fewer employees would be introduced to the Project, which would reduce impacts resulting from additional demand on parks and recreational facilities in the City.

Similar to the Project, this alternative would include active and passive recreational amenities and entertainment. Furthermore, the City currently has a park ratio of 6.52 acres of parkland per 1,000 residents (343.4 acres of parkland in total), exceeding the goal of 5 acres of parkland per 1,000 residents. Similar to the Project, employees and visitors who may occasionally use the City's neighborhood parks, regional parks, or other recreational facilities, would not cause a substantial deterioration of park facilities. Overall, impacts associated with recreation under the Truck Storage Yard Alternative would be less than significant and similar compared to the Project.

Q. Transportation
Construction and operation -related vehicle truck trips would be reduced under the Truck Storage Yard Alternative and would decrease by approximately 13%. This would result in a corresponding decrease in overall VMT and proportional decrease in employees. Therefore, the resulting VMT per employee would be similar to the Project since it is based on Project generated VMT divided by number of employees. As shown, in Table 6-8, Comparison of Project VMT to the Truck Storage Yard Alternative, this alternative would result in a slight increase VMT per service population from 39.19 to 39.88 compared to the Project (see Technical Appendix P of this EIR). Therefore, the Truck Yard Alternative would continue to exceed the City's baseline VMT threshold and impacts would remain significant and unavoidable, and similar to the Project.

Table 6-8 Comparison of Project VMT to the Truck Storage Yard Alternative Project
Truck Storage Yard Alternative
VMT
213,809
173,258
VMT per SP

39.19 39.88
City Threshold

27.03 27.03
Significant?
Yes
Yes
Lead Agency: City of Beaumont
SCH No. 2020099007

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R. Tribal Cultural Resources
The Truck Storage Yard Alternative would result in a similar potential to adversely affect any tribal cultural resources as the Project, since the Project would have the same development impact area.

However, like the Project, mitigation measures would be required to reduce potential impacts to less than significant. Therefore, impacts that could occur by the Truck Storage Yard Alternative would be similar to those associated with the Project.

S. Utilities and Service Systems
The Truck Storage Yard Alternative would reduce the total building square footage by 1,000,000 sf of industrial uses. This would reduce the number of employees on the Project site and the demand for utilities and service systems. The water and wastewater generation rates are based on the number of employees and square footage. Therefore, the demand for regional water supplies and generation of wastewater would be approximately 20% less than the Project due to a proportional decrease in building square footage. Similarly, solid waste generation would be less than the Project and require less landfill capacity. Therefore, impacts to utilities and service system would be less under this alternative than the less than significant impacts that would occur from implementation of the Project.

T. Wildfire
The Project site is designated within a VHFHSZ and HFHSZ. Similar to the Project, the Truck Storage Yard Alternative would be required to maintain adequate emergency access for emergency vehicles on site, comply with the City's emergency operations plan for evacuations, and create defensible space to protect against wildfire hazards. Similar to the Project, this alternative would require the installation of on -site utility infrastructure that would connect to the existing utility infrastructure within the surrounding roadways. Additionally, as with the Project, this alternative would not result in the modification to existing slopes in a way that would exacerbate fire risk or increase flooding or landslides, and would not exacerbate pollution from wildfires. Therefore, impacts related to wildfire would be similar to the Project and less than significant.

U. Conclusion

1. Avoid or Substantially Lessen the Significant Impacts of the Project The Truck Storage Yard Alternative would result in reduced impacts related to air quality, energy, GHG emissions, noise, public services, and utilities and service systems due to the reduction in square footage and associated vehicular trips. However, significant and unavoidable impacts related to air quality, GHG emissions, noise, and transportation would continue to occur from implementation of this alternative. Impacts related to aesthetics, agriculture and forestry resources, biological resources, cultural resources, geology and soils, hazardous and hazardous materials, hydrology and water quality, land use and planning, mineral resources, recreation, transportation, tribal cultural resources, and wildfire would be similar to the Project; and impacts related to population and housing would be greater compared to the Project.

Lead Agency: City of Beaumont SCH No. 2020099007

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2. Attainment of Project Objectives
The Truck Storage Yard Alternative would meet Project Objectives, A, B, and E —I, as described in Section 6.1.1. As compared with the Project, this alternative would not meet the following objectives to the same extent, due to the reduced industrial and commercial building square footage and proportional reduction in employees:
• Objective C. Maximizing opportunities to develop land in the City's sphere of influence to provide job opportunities and economic benefit to the City and its residents, including new sales and property tax revenues that can be used for City services and providing sufficient fiscal benefit to permit annexation of the Project site into the City. • Objective D. Creating new job opportunities within the City of Beaumont to improve and maximize the jobs to housing balance within the City and reduces the need for members of the existing local workforce to commute long distances.

6.5 ENVIRONMENTALLY SUPERIOR ALTERNATIVE
CEQA requires the identification of an environmentally superior alternative. Section 15126.6(e)(2) of the CEQA Guidelines states that, if the No Project Alternative is the environmentally superior alternative, then the EIR shall also identify an environmentally superior alternative among the other alternatives.

The No Project/No Development Alternative has the least impact to the environment because it would not involve any construction activities or commercial/industrial operations. There would be no impacts associated with a cumulatively considerable increase of VOC, NOx, PM10, and PM2.5 during construction and operation, and no cumulative impacts related to GHG emissions, off -site traffic - related noise, and VMT. These impacts are considered significant and unavoidable for the Project.

While this alternative would avoid the significant effects of the Project, it would not receive the environmental benefits from conservation of 152.42 acres of natural habitat; implementation of stormwater drainage and water quality filtration features; and ignition resistant structures, parking areas, and irrigated landscaping within a VHFHSZ and HFHSZ that would be constructed by the Project. Additionally, none of the Project Objectives would be met.

The Existing City General Plan Alternative would eliminate the Project's significant and unavoidable impacts related to operational -related air quality, off -site traffic -related noise, and transportation impacts. However, the Existing City General Plan Alternative would result in greater impacts related to population and housing, public services, and recreation compared to the Project due to the increase in residents. Additionally, none of the Project Objectives would be met.

The Reduced Development Area and Intensity Alternative is environmentally superior to the Project because the alternative reduces the commercial and industrial square footage of the Project the most (non -hotel commercial square footage by 50% and the industrial square footage of the Project by Lead Agency: City of Beaumont SCH No. 2020099007

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Environmental Impact Report 6.0 Alternatives
approximately 20%) and also reduces the development footprint, with resulting reductions in grading, construction and off -site vehicular travel. As shown in Table 6-9, Comparison of Alternatives and Project -related Environmental Impacts, the Reduced Development Area and Intensity Alternative would result in reduced impacts related to aesthetics, air quality, biological resources, cultural resources, energy, geology and soils, GHG emissions, hydrology and water quality, noise, public services, transportation, tribal cultural resources, and utilities and service systems, due to the reduction in overall square footage, development area, and associated vehicular trips. Despite the reductions to the Project scope under this alternative, significant and unavoidable impacts related to air quality, GHG emissions, noise, and transportation would be reduced but would continue to occur from implementation of this alternative. Impacts related to population and housing would be greater under this alternative compared to the Project but would not be significant. Impacts related to agriculture and forestry resources, hazardous and hazardous materials, land use and planning, mineral resources, recreation, and wildfire would be similar to the Project.

As shown on Table 6-10, Alternatives Attainment of Project Objectives, the Reduced Development Area and Intensity Alternative would meet Project Objectives A, B, and F —I, as described in Section

6.1.1. As compared with the Project, this alternative would not meet the following objectives to the same extent, due to the reduced industrial and commercial building square footage and proportional reduction in employees and economic benefit:
• Objective C. Maximizing opportunities to develop land in the City's sphere of influence to provide job opportunities and economic benefit to the City and its residents, including new sales and property tax revenues that can be used for City services and providing sufficient fiscal benefit to permit annexation of the Project site into the City. • Objective D. Creating new job opportunities within the City of Beaumont to improve and maximize the jobs to housing balance within the City and reduces the need for members of the existing local workforce to commute long distances.
• Objective E. Fulfilling a need in the City and region for wellness -based retail, including entertainment, recreation, hospitality, and restaurants.

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6.0 Alternatives
Table 6-9 Comparison of Alternatives and Project -related Environmental Impacts Impact Area
Project
No Project/ No
Development
Existing City
General Plan
Reduced
Development
Area and
Intensity
Reduced
Intensity
Truck Storage
I Yard
Aesthetics
LTS
No Impact (less)
LTS (less)
LTS (less)
LTS (similar)
LTS (similar)
Agriculture and
Forestry Resources
LTS
No Impact (less)
p
LTS (similar)

LTS (similar)

LTS similar
(similar)
Air Quality
Construction
SU
No Impact
(less)*
SU (less)
SU (less)
SU (less)
SU (less)
Operation
SU
No Impact
(less)
LTS (less)*
SU (less)
SU (less)
SU (less)
Biological Resources
LTS/M
No Impact (less)
LTS/M
(similar)
LTS/M (less)
LTS/M
(similar)
LTS/M (similar)
Cultural Resources
LTS/M
No Impact (less)
LTS/M
(similar)
LTS/M (less)
LTS/M
(similar)
LTS/M (similar)
Energy
LTS
No Impact (less)
LTS (less)
LTS (less)
LTS (less)
LTS (less)
Geology and Soils
LTS/M
No Impact (less)
LTS/M
(similar)
LTS/M (less)
LTS/M
(similar)
LTS/M (similar)
GHG Emissions
SU
No Impact
(less)*
SU (less)
SU (less)
SU (less)
SU (less)
Hazards and
Hazardous Materials
LTS
No Impact (less)
LTS (less)
LTS (similar)
LTS (similar)
LTS (similar)
Hydrology and Water
Quality
LTS
No Impact
(great• er)
LTS (similar)
LTS (less)
LTS (similar)
LTS (similar)
Land Use and
Planning
LTS
No Impact (less)
LTS (similar)
LTS (similar)
LTS (similar)
LTS (similar)
Mineral Resources
LTS
No Impact (less)
LTS (similar)
LTS (similar)
LTS (similar)
LTS (similar)
Noise
Construction
LTS
No Impact (less)
LTS (less)
LTS (less)
LTS (less)
LTS (less)
On -Site
Operations
LTS
No Impact (less)
LTS (less)
LTS (less)
LTS (less)
LTS (less)
Off -Site Traffic-
Related
SU
No Impact
(less)*
LTS (less)*
SU (less)
SU (less)
SU (less)
Population and
Housing
LTS
No Impact (less)
LTS (greater)
LTS (greater)
LTS (similar)
LTS (greater)
Public Services
LTS
No Impact (less)
LTS (greater)
LTS (less)
LTS (less)
LTS (less)
Recreation
LTS
No Impact (less)
LTS (greater)
LTS (similar)
LTS (similar)
LTS (similar)
Transportation
SU
No Impact
(less)
LTS (less)*
SU (less)
SU (similar)
SU (similar)
Tribal Cultural
Resources
LTS/M
No Impact (less)
LTS/M
(similar)
LTS/M (less)
LTS/M
(similar)
LTS/M (similar)
Utilities and Service
Systems
LTS
No Impact (less)
LTS (similar)
LTS (less)
LTS (less)
LTS (less)
Wildfire
LTS
No Impact (less)
LTS (less)
LTS (similar)
LTS (similar)
LTS (similar)
LTS = Less than Significant; LTS/M = Less than Significant with Mitigation; SU = Significant and Unavoidable * = Eliminates SU impact
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6.0 Alternatives
Table 6-10 Alternatives Attainment of Project Objectives Project Objectives
No Project/
No
Development
Existing
City
General
Plan
Reduced
Development
Area and
Intensity
Reduced
Intensity
Truck Storage
Yard
A. Develop large land areas in the City and
particularly south of SR -60 and adjacent to
existing industrial uses, infrastructure and
truck routes to meet the growing demand for
large scale industrial and warehouse
development in the City while minimizing
impacts of industrial development on
residential and other sensitive receptors in
the City, which are primarily located north of
SR -60.

Not Met
Not Met
Met
Met
Met
B. Providing for conservation of open space
habitat within MSHCP criteria cells in a
manner consistent with the MSHCP
requirements and providing access for
wildlife movement to Caltrans constructed
and proposed wildlife under -crossings along
the SR -60 Freeway that abut the northern
Project boundary to accommodate wildlife
movement.

Not Met
Not Met
Met
Met
Met
C. Maximizing opportunities to develop land
in the City's sphere of influence to provide
job opportunities and economic benefit to the
City and its residents, including new sales
and property tax revenues that can be used
for City services and providing sufficient
fiscal benefit to permit annexation of the
Project site into the City.

Not Met
Not Met
Partially Met
Partially Met
Partially Met
D. Creating new job opportunities within the
City of Beaumont to improve and maximize
the jobs to housing balance within the City
and reduces the need for members of the
existing local workforce to commute long
distances.

Not Met
Not Met
Partially Met
Partially Met
Partially Met
E. Fulfilling a need in the City and region for
wellness -based retail, including
entertainment, recreation, hospitality, and
restaurants.

Not Met
Not Met
Partially Met
Partially Met
Met
F. Developing a center that will
accommodate a variety of future tenants,
including light manufacturing, warehouse,
distribution tenants and other businesses that
rely on transportation efficiency within an
industrial corridor in a location with superior
access to the local and regional
transportation network, thereby minimizing
truck traffic on local streets and reducing
vehicle miles traveled in the region.

Not Met
Not Met
Met
Met
Met
Lead Agency: City of Beaumont
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6.0 Alternatives
Project Objectives
No Project/
No
Development
Existing
City
General
Plan
Reduced
Development
Area and
Intensity
Reduced
Intensity
Truck Storage
Yard
G. Developing a project that utilizes existing
investment in capital improvements for
water, reclaimed water, sewer, storm drain
and circulation facilities to further the
planned development of land in the City and
in its sphere of influence.

Not met
Met
Mct
Met
Met
H. Developing a range of warehouse facility
options, such as varying structure sizes and
building configurations within the City with
high quality businesses to facilitate local and
regional distribution of goods while
minimizing vehicle miles traveled, air
quality and greenhouse gas impacts.

Not met
Not met
Met
Met
Met
I. Minimizing the demand for water
resources by creating a development -wide
landscape concept that features drought -
tolerant plant materials to provide for an
aesthetically pleasing outdoor environment
and developing a project where recycled
water is planned to be available.

Not met
Not met
Met
Met
Met
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Environmental Impact Report 7.0 References

7.0 REFERENCES

7.1 PERSONS CONTRIBUTING TO EIR PREPARATION

7.1.1 CITY OF BEAUMONT
Planning Department
Christina Taylor
Deputy City Manager
Carole Kendrick
Planning Manager
Public Works Department
Jeff Hart
Public Works Director
Robert Vestal
Assistant Director of Public Works
Richard Godsey
Engineering Development Technician
Richard Godsey
Engineering Development Technician
PlaceWorks (CEQA Peer Review Consultant)
Mark Teague
Managing Principal
Nicole Vermilion
Principal

7.1.2 T&B PLANNING, INC.

Nicole Morse, Esq.

Principal
Tracy Chu
Assistant Project Manager
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Christhi Mrosla
Project Planner
Cristina Maxey
Senior GIS/Graphics Specialist
Rhea Smith
GIS/Graphics Technician

7.1.3 TECHNICAL REPORT CONSULTANTS
Brian F. Smith and Associates, Inc.

Phase I and II Cultural Resources Assessment, Paleontological Resource Impact Mitigation Program
Brian F. Smith, Principal Investigator
Todd A. Wirths, Senior Paleontologist
CR Associates
Fire Evacuation Analysis
Phuong Nguyen, PE
Dudek
Fire Protection Plan
Michael Huff, Project Manager
Glenn Lukos Associates, Inc.

Biological Technical Report
David Moskovitz, Principal/Director of Biological Services Kling Consulting Group, Inc.

Preliminary Geotechnical Feasibility Investigation
Henry F. Kling, Principal Geotechnical Engineer
Jeffrey P. Blake, Associate Engineering Geologist
Pacific Advanced Civil Engineering, Inc.

Water Supply Assessment
Proactive Engineering Consultants West, Inc.

Preliminary Hydrology and Hydraulic Study, Project Specific Water Quality Management Plan George Lenfestey, Principal
McAlister GeoScience
Phase I Environmental Site Assessment
Lead Agency: City of Beaumont SCH No. 2020099007

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David C. McAlister, Environmental Professional
Alexis Ceballos, Staff Scientist
Urban Crossroads, Inc.

Air Quality, Energy, Greenhouse Gas Analysis
Haseeb Qureshi, Principal
Alyssa Tamase, Environmental Analyst
Health Risk Assessment
Haseeb Qureshi, Principal
Noise Impact Analysis
Bill Lawson, PE, INCE
Traffic Analysis
Aric Evatt, PTP
Charlene So, PE
Connor Paquin, PE
Vehicle Miles Traveled Analysis
Aric Evatt, PTP
Robert Vu, PE

7.2 DOCUMENTS INCORPORATED BY REFERENCE
The following reports, studies, and supporting documentation were used in the preparation of this EIR and are incorporated by reference within this EIR. A copy of the following reports, studies, and supporting documentation is a matter of public record and is generally available to the public at the location listed.

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Lead Agency: City of Beaumont
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Lead Agency: City of Beaumont
SCH No. 2020099007

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■ D Environmental Impact Report

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Lead Agency: City of Beaumont
SCH No. 2020099007

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Lead Agency: City of Beaumont
SCH No. 2020099007

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■ u Environmental Impact Report

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Lead Agency: City of Beaumont
SCH No. 2020099007

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7.3 PERSONS CONSULTED/WRITTEN OR VERBAL COMMUNICATION

7.3.1 PUBLIC SERVICE CORRESPONDENCE
Beaumont Police Department
Christopher Ramos, Police Sergeant

7.3.2 TRIBAL CONSULTATION
Agua Caliente Band of Cahuilla Indians
Patricia Garcia, Director
Lead Agency: City of Beaumont SCH No. 2020099007

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Augustine Band of Cahuilla Mission Indians
Amanda Vance, Chairperson
Cabazon Band of Mission Indians
Doug Welmas, Chairperson
Cahuilla Band of Indians
Daniel Salgado, Chairperson
Los Coyotes Band of Cahuilla and Cupeno Indians
Shane Chapparosa, Chairperson
Morongo Band of Mission Indians
Robert Martin, Chairperson
Ann Brierty, Cultural Resources Manager
Ramona Band of Cahuilla
Joseph Hamilton, Chairperson
John Gomez, Environmental Coordinator
Santa Rosa Band of Cahuilla Indians
Steven Estrada, Chairperson
Soboba Band of Mission Indians
Scott Cozart, Chairperson
Joe Ontiveros, Tribal Historic Preservation Officer
Torres -Martinez Desert Cahuilla Indians
Michael Mirelez, Cultural Resources Manager
Lead Agency: City of Beaumont SCH No. 2020099007

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BEAUMONT POINTE SPECIFIC PLAN

FINAL ENVIRONMENTAL IMPACT REPORT
S C H NO. 2020099007
r

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CITY OF BEAUMONT
NOVEMBER 2023

Final Environmental Impact Report
SCH No. 2020099007
Beaumont Pointe Specific
Plan
City of Beaumont, California
Lead Agency
City of Beaumont
550 East 6th Street
Beaumont, CA 92223
CEQA Consultant
T&B Planning, Inc.
3200 El Camino Real, Suite 100
Irvine, CA 92602
Project Applicant
JRT BP1, LLC
18032 Lemon Drive, Suite 367
Yorba Linda, CA 9288
Lead Agency Discretionary Permits
General Plan Amendment PLAN2019-0284
Pre -Zone PLAN2019-0283
Beaumont Pointe Specific Plan SP2019-0003
Beaumont Pointe Sign Program PLAN2022-0856
Vesting Tentative Parcel Map No. 38161 PM2022-0012
Development Agreement PLAN2023-0906
Minor Amendment to the Western Riverside County Multiple Species Habitat Conservation Plan
November 16, 2023

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TABLE OF CONTENTS
Section
Page
Section 1.0 Introduction 1-1

1.1 Public Review Process 1-2

1.2 List of EIR Commenters 1-2
Section 2.0 Responses to Comments Received During the Public Review Period 2-1 Section 3.0 Clarifications and Revisions 3-1
Attachments (Provided on USB)
A Preliminary Hydrology and Hydraulic Study for Beaumont Pointe Specific Plan B Project Specific Water Quality Management Plan for Beaumont Pointe C Traffic Analysis
D Fire Protection Plan
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SECTION 1.0 INTRODUCTION
In accordance with Section 15088 of the California Environmental Quality Act (CEQA) Guidelines, the City of Beaumont, as the Lead Agency, has evaluated the comments received on the Draft Environmental Impact Report (Draft EIR) for the Beaumont Pointe Specific Plan Project (Project) (SCH No. 2020099007) and has prepared written responses to these comments. This document has been prepared in accordance with CEQA and represents the independent judgment of the lead agency.

According to State CEQA Guidelines Section 15132, the Final EIR shall consist of:
(a) The Draft EIR or a revision of the draft;
(b) Comments and recommendations received on the Draft EIR either verbatim or in summary; (c) A list of persons, organizations, and public agencies commenting on the Draft EIR; (d) The responses of the Lead Agency to significant environmental points raised in the review and consultation process; and
(e) Any other information added by the Lead Agency.

The Planning Commission will consider certification of the EIR, adoption of a Mitigation Monitoring and Reporting Program, Findings and Facts, and a Statement of Overriding Considerations as part of the approval process for the Project.

This Final EIR document is organized as follows:

Section 1 provides a brief introduction to this document, a summary of the public review process, and a list of commenters.

Section 2 provides responses to the public comments received on the Draft EIR during the public review period. Responses are provided in the form of individual responses to comment letters received. Comment letters are followed immediately by the responses to each letter.

Section 3 contains revisions and clarifications to the Draft EIR as a result of the comments received from agencies and interested persons as well as errata identified in the EIR. This information does not constitute significant new information and recirculation of the EIR for further review pursuant to CEQA Guidelines Section 15088.5 is not required.

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1.1 PUBLIC REVIEW PROCESS
In compliance with Section 15201 of the State CEQA Guidelines, the City of Beaumont (City) has taken steps to provide opportunities for public participation in the environmental review process. A Notice of Preparation (NOP) was distributed on September 2, 2020 to responsible agencies, local government agencies, and interested parties for a 30 -day public review period (from September 7, 2020 to October 6, 2020) in order to solicit comments and inform agencies and the public of the Project. The NOP was also distributed to the State of California Office of Planning and Research, State Clearinghouse (SCH) for distribution to State agencies. The NOP was posted on the City's website, Press -Enterprise Newspaper, and at the Riverside County Clerk's office on September 2, 2020. The Project was described; potential environmental effects associated with Project implementation were identified; and agencies and the public were invited to review and comment on the NOP. Additionally, the City held a Public Scoping Meeting on September 17, 2020 via live streaming to provide an overview of the Project, explain the CEQA process, and accept public comment. A copy of the NOP and comments received during the 30 -day public review period are included in Appendix A of the Draft EIR. The City received 8 comment letters in response to the NOP. Table 2-2 of the Draft EIR provides a brief summary of the NOP comments received that address environmental and related issues.

CEQA requires that a Draft EIR have a review period lasting at least 45 days for projects that have been submitted to the SCH for review (State CEQA Guidelines, Section 15105(a)). The Draft EIR was distributed to various public agencies, organizations, and individuals on December 22, 2022; the EIR was available for public review and comment for a period of 48 days. The review period ended on February 8, 2023. The City used several methods to elicit comments on the Draft EIR. A Notice of Availability (NOA) and the Draft EIR was distributed to the SCH for distribution to State agencies and was posted on the City's website. The NOA was posted also at the Riverside County Clerk's office on December 21, 2022. The NOA was mailed to responsible agencies, local government agencies, and interested parties that received the NOP, to individuals who had previously requested the NOA or EIR, and to individuals who provided NOP comments on December 21, 2022. The NOA was also published in the Press -Enterprise Newspaper on December 22, 2022; the NOA and Draft EIR were made available for review on the City's website at: https://www.beaumontca.gov/1143Beaumont-Pointe- Specific-Plan.

The Planning Commission, as a recommending body, will consider its recommendation to approve the proposed Project, associated actions, and certification of the Final EIR for the Project.

The City Council, as the final approval body, will hold a public hearing following the Planning Commission hearing to consider approving the proposed Project, associated actions, and certification of the Final EIR for the Project.

1.2 LIST OF EIR COMMENTERS
In accordance with Section 15132 of the State CEQA Guidelines, the following is a list of the agencies, organizations, and individuals that submitted comments on the Draft EIR. The City received a total of 13 comment letters, including 4 from agencies and organizations and 9 individuals.

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Responses to each comment are in Section 2.0. The comment letter has been assigned a letter (i.e., A, B, C) and each comment within the transmittal is divided into sequential numbered comments (i.e., A- 1, A-2, A-3).

Comment Date of Letter
Agencies and Organizations
A. Agua Caliente Band of Cahuilla Indians
B. Blum Collins & Ho, LLP on behalf of Golden State Environmental Justice Alliance
C. Rincon Band of Luiseno Indians
D. South Coast Air Quality Management District
Individuals

1. Geiser, Sharon

2. Jones, Tiya

3. McGee, Norma

4. Rizzo, Richard

5. Roy, Ron

6. Tinker, Bob

7. Walsh, Susan

8. Wayne, Pat

9. Wilson, Geoffrey
January 30, 2023
February 8, 2023
January 11, 2023
February 8, 2023
February 6, 2023
February 7, 2023
February 7, 2023
February 7, 2023
February 8, 2023
February 8, 2023
February 6, 2023
February 5, 2023
February 6, 2023
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SECTION 2.0 RESPONSES TO COMMENTS RECEIVED DURING THE

PUBLIC REVIEW PERIOD
All of the comment letters received by the City within the comment period described in Section 1.0 above have been included and responded to in this Final Environmental Impact Report (Final EIR).

Comments that address environmental concerns have been thoroughly addressed. No comments were received outside of the 45 -day comment period. Comments that do not require a response are indicated below and include those that are outside the scope of CEQA requirements because they (1) do not address the adequacy or completeness of the Draft EIR; (2) do not raise environmental issues; (3) do not address the Project; or (4) request the incorporation of additional information not relevant to environmental issues.

CEQA Guidelines Section 15204(a) outlines the parameters for public agencies and interested parties to submit comments and the Lead Agency's responsibility for responding to specific comments. Per CEQA Guidelines Section 15204(a), comments should be related to:
[TJhe sufficiency of the document in identifying and analyzing the possible impacts on the environment and ways in which the significant effects of the project might be avoided or mitigated. Comments are most helpful when they suggest additional specific alternatives or mitigation measures that would provide better ways to avoid or mitigate the significant environmental effects. At the same time, reviewers should be aware that the adequacy of an EIR is determined in terms of what is reasonably feasible.... CEQA does not require a lead agency to conduct every test or perform all research, study, and experimentation recommended or demanded by commenters. When responding to comments, lead agencies need only respond to significant environmental issues and do not need to provide all information requested by reviewers, as long as a good faith effort at full disclosure is made in the EIR.

CEQA Guidelines Section 15204(c) further advises that, "[r]eviewers should explain the basis for their comments, and should submit data or references offering facts, reasonable assumptions based on facts, or expert opinion supported by facts in support of the comments. Pursuant to [CEQA Guidelines] Section 15064, an effect shall not be considered significant in the absence of substantial evidence." Additionally, CEQA Guidelines Section 15204(d) notes that, "[e]ach responsible agency and trustee agency shall focus its comments on environmental information germane to that agency's statutory responsibility;" but, pursuant to CEQA Guidelines Section 15204(e), "[t]his section shall not be used to restrict the ability of reviewers to comment on the general adequacy of a document or of the lead agency to reject comments not focused as recommended by this section." Section 15088 of the California Environmental Quality Act (CEQA) Guidelines, Evaluation of and Response to Comments, states:
(a) The lead agency shall evaluate comments on environmental issues received from persons who reviewed the draft EIR and shall prepare a written response. The lead agency shall respond to comments raising significant environmental issues received during the noticed comment period and any extensions and may respond to late comments.

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(b) The lead agency shall provide a written proposed response, either in a printed copy or in an electronic format, to a public agency on comments made by that public agency at least 10 days prior to certifying an environmental impact report. (c) The written response shall describe the disposition of significant environmental issues raised (e.g., revisions to the proposed project to mitigate anticipated impacts or objections). In particular, the major environmental issues raised when the lead agency's position is at variance with recommendations and objections raised in the comments must be addressed in detail giving reasons why specific comments and suggestions were not accepted. There must be good faith, reasoned analysis in response. Conclusory statements unsupported by factual information will not suffice. The level of detail contained in the response, however, may correspond to the level of detail provided in the comment (i.e., responses to general comments may be general). A general response may be appropriate when a comment does not contain or specifically refer to readily available information, or does not explain the relevance of evidence submitted with the comment. (d) The response to comments may take the form of a revision to the draft EIR or may be a separate section in the final EIR. Where the response to comments makes important changes in the information contained in the text of the draft EIR, the lead agency should either:
(1) Revise the text in the body of the EIR; or
(2) Include marginal notes showing that the information is revised in the response to comments.

This section includes responses to substantive Draft EIR comments received by the City. With respect to comment letters received, aside from certain courtesy statements, introductions, and closings, individual comments within the body of each letter have been identified and numbered. A copy of each comment letter and the City's responses to each applicable comment are included in this section.

Brackets delineating the individual comments and a numeric identifier have been added to the right margin of the letter. Responses to each comment identified are included on the page(s) following each comment letter.

In accordance with Public Resources Code Section 21092.5, written responses to public agency comments shall be provided to the public agency at least 10 days prior to certifying an EIR.

As described in Section 3.0, Draft EIR Clarifications and Revisions, of this document the Draft EIR, revisions and information presented in response to comments received do not result in any of the conditions set forth in Section 15088.5 of the State CEQA Guidelines requiring recirculation; therefore, the EIR does not need to be recirculated prior to its certification.

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COMMENT LETTER A
AGUA CALIENTE BAND OF CAHUILLA INDIA c

THEBAL HISTORIC PRESERVATION
January 30, 2023
[VIA EMAIL TO:[email protected]]
City of Beaumont
Ms. Carole L. Kendrick
550 E. 6th Street
Beaumont, CA 92223
Re: Beaumont Pointe Specific Plan
Dear Ms. Carole L. Kendrick,
03-036-2020-006
The Agua Caliente Band of Cahuilla Indians (ACBCI) appreciates your efforts to include the Tribal Historic Preservation Office (THPO) in the Beaumont Pointe Specific Plan project. We have reviewed the documents and have the following comments:
*Continued consultation on this project.
*The presence of an approved Agua Caliente Native American Cultural Resource Monitor(s) during any ground disturbing activities (including archaeological testing and surveys). Should buried cultural deposits be encountered, the Monitor may request that destructive construction halt and the Monitor shall notify a Qualified Archaeologist (Secretary of the Interior's Standards and Guidelines) to investigate and, if necessary, prepare a mitigation plan for submission to the State Historic Preservation Officer and the Agua Caliente Tribal Historic Preservation Office. *The presence of an archaeologist that meets the Secretary of Interior's standards during any ground disturbing activities.
*Treatment plan shall be developed prior to any ground -disturbing activities Again, the Agua Caliente appreciates your interest in our cultural heritage. If you have questions or require additional information, please call me at (760) 423-3485. You may also email me at [email protected].

Cordially,
Xitlaly Madrigal
Cultural Resources Analyst
Tribal Historic Preservation Office

AGUA CALIENTE BAND

OF CAHUILLA INDIANS
5401 ❑INAMI SNORT RRIVF, PALM SFRING5, CA 92264
T 760.'6913,6800 F 7611)699./65324 WWW. A.OUACALIENTE-NSN.GOV A-1
A-3
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Responses to Comment A
Agua Caliente Band of Cahuilla Indians, Xitlaly Madrigal, Cultural Resources Analyst, dated January 30, 2023.

A-1
The commenter appreciates the City's efforts to include the Aqua Caliente Band of Cahuilla Indians Tribal Historic Preservation Office input in the Project. The commenter provides comments which are responded to below. No further response is required.

A-2 The commenter requests continued consultation on the Project. The commenter requests approved Agua Caliente Native American Cultural Resource Monitor(s) during any ground disturbing activities (including archaeological testing and surveys) and investigation and preparation of a mitigation plan if requested by that Monitor should buried cultural deposits be encountered. The commenter requests the presence of an archaeologist that meets the Secretary of Interior's standards during ground disturbing -activities. The commenter also requests that a treatment plan be developed prior to any ground -disturbing activities.

As part of the SB 18/AB 52 consultation process required by CEQA for the Project, the City of Beaumont sent notification of the Project to Native American tribes with possible traditional or cultural affiliation to the Project site. Of the 10 tribes that were sent notification letters, three tribes requested government -to -government consultation: Agua Caliente Band of Cahuilla Indians, Morongo Band of Mission Indians, and Soboba Band of Mission Indians. The City submitted the Phase I and Phase II Cultural Resources Assessment to the three tribes. The Agua Caliente Band of Cahuilla Indians and Morongo Band of Mission Indians requested revisions to the cultural resources assessment and mitigation, which were incorporated into the Phase I and Phase II Cultural Resources Assessment.

Mitigation Measure MM 4.5-1 (refer to Page 4.5-18 of the Draft EIR) has been incorporated into the Project to ensure that a qualified archaeologist that meets the Secretary of Interior's standards is retained to implement the monitoring program, be present during all ground - disturbing activities to identify any known or suspected archaeological and/or cultural resources and to conduct Cultural Resource Sensitivity Training in conjunction with the consulting Native American tribes' Tribal Historic Preservation Officer and/or designated Tribal Representative. Mitigation Measure MM 4.5-2 (refer to Pages 4.5-18 to 4.5-20 of the Draft EIR) requires preparation of a Cultural Resource Management Plan (CRMP) and/or Archaeological Monitoring and Treatment Plan (AMTP) written in consultation with the consulting tribe(s) to address the details, timing, and responsibilities of all archaeological and cultural resource activities that occur on the Project site, requires that during all ground - disturbing activities the qualified archaeologist and the Native American monitor shall be on - site full-time and addresses treatment and disposition methods in the event that previously unidentified cultural resources are discovered. With implementation of the required mitigation measures, the Project would not cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code Sections 21074 and 21084.2 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and potential Project and cumulative impacts would be reduced to less than Lead Agency: City of Beaumont SCH No. 2020099007

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significant levels. Mitigation Measures MM 4.5-1 and 4.5-2 address the commenter's request and no further response is required.

A-3 The commenter concludes the letter and provides contact information. No further response is required.

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COMMENT LETTER B
Carole Kendrick,
Planning Manager
City of Beaumont
550 E. 6th Street
Beaumont, CA 92223

BLUM, COLLINS & HO, LLP

ATTORNEYS AT LAW

AON CENTER
707 WILSHIRE BOULEVARD
SUITE 4880
LOS ANGELES, CALIFORNIA 90017
(213) 572-0400
February 6, 2023
VIA EMAIL TO:
[email protected]
SUBJECT: COMMENTS ON BEAUMONT POINTE SPECIFIC PLAN EIR (SCH NO. 2020099007)
Ms. Kendrick:

Thank you for the opportunity to comment on the Environmental Impact Report (EIR) for the proposed Beaumont Pointe Specific Plan. Please accept and consider these comments on behalf of Golden State Environmental Justice Alliance. Also, Golden State Environmental Justice Alliance formally requests to be added to the public interest list regarding any subsequent environmental documents, public notices, public hearings, and notices of determination for this project. Send all communications to Golden State Environmental Justice Alliance P.O. Box 79222 Corona, CA 92877.

1.0 Summary
The project proposes to construct and operate a mixed industrial and commercial project totaling 5,331,000 square feet (sf). The industrial component of the project is the primary land use and proposes 4,995,000 sf of floor area across five buildings ranging in size between approximately 600,000 and 1,379,000 sf and one building with 35,000 sf of self -storage space. The ancillary commercial uses total up to 246,000 sf in addition to a 125 -room hotel (approximately 90,000 sf).

Planning Areas (PAs) 1 and 2 are proposed to change the existing land use designations from Rural Residential to General Commercial and establish "The Experience at Beaumont Pointe." PAs 1 and 2 will include a 125 -room limited -service hotel (approximately 90,000 sf) and a maximum of 246,000 sf of retail and commercial recreation businesses, including approximately 30,000 sf of restaurants and 216,000 sf of retail and commercial recreation businesses.

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PAs 3 through 8 are are proposed to change the existing land use designations from Rural Residential to Industrial. Buildings in PAs 3-8 are envisioned to range in size from approximately 35,000 sf (self -storage) up to 1,379,000 sf and accommodate users such as industrial incubators, light manufacturing, parcel hub, warehouse/storage, fulfillment center, high cube warehouse, cold storage warehouse (up to 100,000 sf), and e -commerce operations and includes self -storage uses permitted only on PA 3. The maximum square footage for all industrial uses is 4,995,000 sf.

PA 9 is proposed to change the existing land use designations from Rural Residential to Open Space. PA 10 is proposed to change the existing land use designations from Rural Residential to Open Space - Conservation.

The following discretionary actions are required for project approval:

1. General Plan Amendment (PLAN2019-0284): The Project site is currently outside of the City's boundaries and is regulated by the County of Riverside. The City has provided initial land use designations in its General Plan for properties in its sphere of influence (SOI), including the Project site, and the Project site is currently designated "Rural Residential." The Project will include a General Plan Amendment (GPA) that would amend the City of Beaumont's General Plan Land Use Map to change the land use designations for the Project site from "Rural Residential" to "Industrial (I)," "General Commercial (GC)," "Open Space (OS)," and "Open Space -Conservation (OS -C)."

2. Pre -Zone (PLAN2019-0283): The Project site is identified within the City of Beaumont Zoning Map as located in the City of Beaumont SOI; no pre -zoning is identified, and the site is currently regulated by the County of Riverside. The Project proposes to pre -zone the Project site within the City's Zoning Map as "Specific Plan". This pre -zoning would become effective upon annexation of the Project site into the City (see Government Code Section 65859[a]).

The proposed Pre -Zone would require future development on the Project site to comply with the applicable development standards and design guidelines from the Beaumont Pointe Specific Plan and, where applicable, the Beaumont Municipal Code.

3. Specific Plan SP2019-0003: Adoption of the proposed Specific Plan is a discretionary action subject to City Council approval. Adopted by Ordinance, the Specific Plan document will serve both planning and regulatory functions. The Specific Plan establishes the necessary land use plan, development standards, design guidelines, infrastructure systems, and implementation strategies on which subsequent, Project -related development activities would be founded.

4. Sign Program: A Sign Program is being processed concurrently with the Specific Plan. The Sign Program provides adequate and appropriate street, building, tenant identification, pedestrian path, and wayfinding signage for the Project's anticipated variety of building sizes, designs, and use.

5. Tentative Parcel Map: The Project would include a Tentative Parcel Map. Additional, subdivision maps (parcel and/or tract maps, including vesting maps) could be processed in

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conjunction with this Specific Plan to subdivide the site into smaller parcels and to regulate development of the physical components of the Project.

6. Western Riverside County Multiple Species Habitat Conservation Plan (MSHCP) Minor Amendment: The City will prepare and submit to the Wildlife Agencies (U.S. Fish and Wildlife Service and the California Department of Fish and Wildlife) a Minor Amendment request for any annexation associated with the Project. The Minor Amendment would be documented in MSHCP (Sections 11.5 and 20.4.1(E) of the MSHCP Implementation Agreement and Section 6.10.2 of the MSHCP). The Project would conserve a total of 230.82 acres of lands that would support the function of Proposed Core 3 consistent with the MSHCP goals of providing live-in habitat and facilitating movement, including 152.42 acres on -site and 78.40 acres off -site.

7. Approval by the City and Riverside County Local Agency Formation Commission (LAFCO) of annexation to the City of Beaumont and approval by Beaumont -Cherry Valley Water District (BCVWD) and LAFCO of annexation to the Beaumont -Cherry Valley Water District.

3.0 Project Description
The EIR does not include the proposed Beaumont Pointe Specific Plan document as an attachment for public review. The Beaumont Pointe SP would include permitted uses and development standards such as maximum height, floor area ratio, parking requirements, and other items that contribute directly to the analysis of environmental impacts. Incorporation by reference (CEQA § 15150 (f)) is not appropriate as the Beaumont Pointe SP contributes directly to analysis of the problem at hand. The EIR must be revised and recirculated to include the Beaumont Pointe SP document for public review in order to comply with CEQA's requirements for adequate informational documents and meaningful disclosure (CEQA § 15121 and 21003(b)).

4.3 Air Quality, 4.6 Energy, and 4.8 Greenhouse Gas Emissions Please refer to attachments from SWAPE for a complete technical commentary and analysis.

The EIR does not include for analysis relevant environmental justice issues in reviewing potential impacts, including cumulative impacts from the proposed project. This is especially significant as the surrounding community is highly burdened by pollution. According to CalEnviroScreen 4.0', Ca1EPA's screening tool that ranks each census tract in the state for pollution and socioeconomic vulnerability. The proposed project's census tract (6065043822) and surrounding community, including residences to the north, bears the impact of multiple sources of pollution and is more polluted than average on several pollution indicators measured by CalEnviroScreen. For example, the project census tract ranks in the 99th percentile for ozone burden, which is attributed to heavy CalEnviroScreen 4.0 https://oehha.ca.gov/calenviroscreen/report/calenviroscreen-40

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truck traffic activity in the area. Ozone can cause lung irritation, inflammation, and worsening of existing chronic health conditions, even at low levels of exposure2.

The census tract also ranks in the 97th percentile for solid waste facility impacts, which can expose people to hazardous chemicals, release toxic gases into the air (even after these facilites are closed), and chemicals can leach into soil around the facility and pose a health risk to nearby populations3.

The census tract also bears more impacts from cleanup sites than 70% of the state. Chemicals in the buildings, soil, or water at cleanup sites can move into nearby communities through the air or movement of water'.

Further, the census tract is a diverse community including 52% Hispanic and 4% Asian -American residents, whom are especially vulnerable to the impacts of pollution. The community is also economically disadvantaged. The community experiences high rates of unemployment (68th percentile), and poverty (42nd percentile) meaning 79% of the households in the census tract have a total income before taxes that is less than the poverty level. Income can affect health when people cannot afford healthy living and working conditions, nutritious food and necessary medical cares. Poor communities are often located in areas with high levels of pollution'. Poverty can cause stress that weakens the immune system and causes people to become ill from pollution'.

Living in poverty is also an indication that residents may lack health insurance or access to medical care. Medical care is vital for this census tract as it ranks in the 87th percentile for incidence of cardiovascular disease and 60th percentile for incidence of asthma.

California's Building Energy Code Compliance Software (CBECC) is the State's only approved energy compliance modeling software for non-residential buildings in compliance with Title 248.

CalEEMod is not listed as an approved software. The CalEEMod-based modeling in the EIR and appendices does not comply with the 2022 Building Energy Efficiency Standards and under- reports the project's significant Energy impacts and fuel consumption to the public and decision makers. Since the EIR did not accurately or adequately model the energy impacts in compliance with Title 24, a finding of significance must be made. A revised EIR with modeling using the 2 OEHHA Ozone https://oehha.ca.gov/calenviroscreen/indicator/air-quality-ozone 3 OEHHA Solid Waste Facilities https://oehha.ca.gov/calenviroscreen/indicator/solid-waste-sites-and- facilities
° OEHHA Cleanup Sites https://oehha.ca.gov/calenviroscreen/indicator/cleanup-sites 5 OEHHA Poverty https://oehha.ca.gov/calenviroscreen/indicator/poverty 6 Ibid.
' Ibid.
8 California Energy Commission 2022 Energy Code Compliance Software https://www.energy.ca . gov/programs-and-topics/programs/building-energy-efficiency-standards/2022- building-energy-efficiency-1

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approved software (CBECC) must be circulated for public review in order to adequately analyze the project's significant environmental impacts. This is vital as the EIR utilizes Ca1EEMod as a source in its methodology and analysis, which is clearly not the approved software.

Further, Table 4.8-7: SCAG Connect SoCal Applicability Analysis finds that the project does not conflict with all goals of Connect SoCal, resulting in less than significant impacts. However, the consistency analysis in the EIR is misleading to the public and decision makers. The project results in several significant and unavoidable cumulatively considerable impacts, including Air Quality (cumulatively considerable), Greenhouse Gas Emissions (cumulatively considerable), Noise (cumulatively considerable), and Transportation/VMT (cumulatively considerable). For example, the EIR finds the project is consistent with Goal 5: "Reduce greenhouse gas emissions and improve air quality," because "impacts would be reduced to the maximum extent feasible through the implementation of Mitigation Measures and Project Design Features." However, as determined in the EIR itself, the project will impede the SCAG region's ability to reduce greenhouse gas emissions and improve air quality because it will result in significant and unavoidable cumulatively considerable impacts to Air Quality and Greenhouse Gas Emissions. This information must be included for analysis with all Connect SoCal Goals and a finding of significance must be made.

4.11 Land Use and Planning
The EIR has not provided a complete consistency analysis of the proposed project and General Plan goals and policies. The EIR provides no discussion of the project's required General Plan Amendment and change in Zoning designation from Rural Residential to Beaumont Pointe SP.

This does not comply with CEQA's requirements for meaningful disclosure and does not present an adequate environmental analysis. A revised EIR must be prepared with a consistency analysis with all General Plan policies goals and policies, including the following items that the project has significant potential for direct inconsistency:

1. Goal 3.3: A City that preserves its existing residential neighborhoods and promotes development of new housing choices.

2. Policy 3.3.1 Support the development of new housing opportunities, as defined by the Land Use Plan contained in this Element.

3. Policy 3.3.9 Ensure new development projects and infill construction are of a compatible scale in existing neighborhoods and provide adequate transitions to adjacent residential properties.

4. Policy 3.4.5 Focus economic development efforts on attracting high paying jobs to the City.

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5. Policy 3.8.4 Prioritize access to health -promoting uses in new development, including neighborhood markets, grocery stores, medical centers, pharmacies, parks, gyms, community space and gardens.

6. Policy 4.1.1 Reduce vehicular congestion on auto -priority streets to the greatest extent possible. Policy 4.1.2 Maintain LOS D on all auto -priority streets in Beaumont. LOS E is considered acceptable on non -auto -priority streets.

7. Goal 4.6: An efficient goods movement system that ensures timely deliveries without compromising quality of life, safety, or smooth traffic flow for Beaumont residents.

8. Policy 5.1.4 Encourage growth and expansion of businesses and employment centers near public transit to increase transportation options for employees and limit traffic congestion.

9. Goal 6.1: A City that improves the overall health and welfare of its residents.

10. Policy 6.4.1 Ensure convenient access to affordable, fresh produce and healthy foods in all neighborhoods, including grocery stores, farmers 'markets, and community gardens, particularly in communities with low incomes and low access.

11. Policy 6.4.3 Limit fast food and liquor stores in neighborhoods with a significant concentration of stores (e.g., multiple stores on the same block or intersection) and child - sensitive areas, such as schools, parks, and childcare facilities.

12. Policy 6.5.5 Promote development of a variety of housing types that meet the needs of residents of all income levels. This policy is implemented through the Land Use and Community Design Element.

13. Policy 6.5.8 Encourage health -promoting uses in new development, including neighborhood markets, grocery stores, pharmacies, parks, gyms, and community gardens. -4— Further, the EIR omits discussion and analysis regarding the project's inconsistency with other land use plans, policies, or regulations adopted for the purpose of avoiding or mitigating an environmental effect. For example, the project will have a significant and unavoidable cumulatively considerable impact to Air Quality because it will exceed the assumptions in the AQMP and generate operational -source emissions not reflected within the current 2016 AQMP regional emissions inventory for the SCAB. The project will also have a significant and unavoidable cumulatively considerable impact to Greenhouse Gas Emissions because it will conflict with an applicable plan, policy, or regulation of an agency adopted for the purpose of reducing GHG emissions. The Land Use and Planning analysis omits any discussion regarding inconsistencies with the AQMP and California's statewide GHG reduction goals for 2030 and 2050. The EIR must be revised to include these significant and unavoidable cumulatively considerable impacts for analysis and include a finding of significance.

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Table 4.11-2 SCAG Connect SoCal Consistency Analysis provides a misleading and erroneous consistency analysis with SCAG's 2020-2045 Connect SoCal RTP/SCS that concludes the project does not conflict with any Connect SoCal Goals. The project requires a change in General Plan land use designation to proceed, which indicates that it is not consistent with the analysis provided in Connect SoCal. Due to errors in modeling, modeling without supporting evidence (as noted throughout this comment letter and attachments), and the EIR' s conclusion the project will result in significant and unavoidable cumulatively considerable impacts to Air Quality, Greenhouse Gas Emissions, Noise, and Transportation, the proposed project is directly inconsistent with Goal 5 to reduce greenhouse gas emissions and improve air quality, Goal 6 to support healthy and equitable communities, and Goal 7 to adapt to a changing climate. The EIR must be revised to include a finding of significance due to these direct inconsistencies with SCAG's 2020-2045 Connect SoCal RTP/SCS.

The project is significantly inconsistent with statutory requirements of the Housing Crisis Act/SB 330. The Housing Crisis Act (HCA) of 2019/Senate Bill (SB) 3309 require replacement housing sites when land designated for housing development is changed to a non -housing use to ensure no net loss of housing capacity. Government Code Section 66300(b)(1)(A) requires that agencies shall not "change the general plan land use designation, specific plan land use designation, or zoning to a less intensive use below what was allowed under the land use designation and zoning ordinances in effect on January 1, 2018." Under Government Code Section 66300(b)(1)(A), a "less intensive use" includes, but is not limited to, reductions to height, density, or floor area ratio, new or increased open space or lot size requirements, or new or increased setback requirements, minimum frontage requirements, or maximum lot coverage limitations, or anything that would lessen the intensity of housing. Pursuant to SB 330, replacement capacity for any displaced residential units must be provided at the time of project approval.

Due to the required land use changes to implement the proposed project, the site would not be used for the development of residential units and replacement sites must be proposed and analyzed as part of the project. The EIR does not act in conformance with these laws and has not identified replacement sites for housing. Approval of the EIR and the proposed project will result in a net loss of housing. Specifically, the EIR states that the existing land use designations permit the development of up to 383 residential dwelling units. The lost capacity of 383 dwelling units is a significant environmental impact in violation of the HCA/SB 330. The EIR must be revised to include a finding of significance due to this inconsistency. 9 Housing Crisis Act of 2019/SB 330
https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill id=201920200SB330

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Additionally, deferring the identification of replacement sites to a later date is project piecemealing in violation of CEQA. The EIR does not accurately or adequately describe the project, meaning "the whole of an action, which has a potential for resulting in either a direct physical change in the environment, or a reasonably foreseeable indirect physical change in the environment" (CEQA § 15378). The whole of the action must statutorily and legally include identified replacement sites to accommodate the lost capacity of 383 dwelling units.

4.14 Population and Housing
SCAG adopted 2045 growth projections as part of the 2020 RTP/SCS (Connect SoCal) on September 3, 2020. SCAG's Connect SoCal Demographics and Growth Forecast 1° notes that Beaumont will add 6,600 jobs between 2016 - 2045. Utilizing the EIR's calculation of 5,456 employees, the project represents 82.6% of Beaumont's employment growth from 2016 - 2045.

SCAG's Growth Forecast notes that Beaumont's population will increase by 34,700 residents between 2016 - 2045. Utilizing the EIR's calculation of 5,456 employees, the project represents

15.7% of Beaumont's population growth from 2016 - 2045. A single project accounting for 82.6% of the projected employment growth and 15.7% of the projected population growth within Beaumont over 29 years represents a significant amount of growth.

The EIR must be revised to include this analysis, and also provide a cumulative analysis discussion of projects approved since 2016 and projects "in the pipeline" to determine if the project will exceed SCAG's employment and/or population growth forecast. For example, other recent industrial projects such as Portrero Logistics Center (771 employees) and Beaumont Summit Station Specific Plan (4,010 employees) combined with the proposed project will cumulatively generate 10,237 employees, which nearly double the City's employment growth forecast over 29 years. This total increases exponentially when commercial development activity and other industrial projects are added to the calculation. The EIR must be revised to include this information for analysis and also include a cumulative development analysis of projects approved since 2016 and projects "in the pipeline" to determine if the proposed project exceeds the General Plan growth estimates and/or SCAG's growth forecasts.

The EIR utilizes uncertain language by stating that, "91% of Beaumont residents commute outside of the City for work and more housing units are expected to be built within the City over the next 20 years," without providing specific information regarding the type of employment commuter residents qualify for or the quantity of housing units that are in development. Additionally, the EIR relies upon the entire unemployed workforce of the metropolitan Riverside -San Bernardino - 10 SCAG Connect SoCal Demographics and Growth Forecast adopted September 3, 2020 https://scag.ca.gov/sites/main/files/file-attachments/0903fconnectsocal demographics-and-growth- forecast.pdf? 1606001579

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Ontario region to fill the project's jobs. Relying upon the entire workforce population of the metropolitan Riverside -San Bernardino -Ontario region will increase the VMT per employee reported in the EIR. This will also increase GHG emissions during all phases of construction and operations and the EIR must be revised to account for longer worker trip distances. For example, the project site is approximately 45 miles from Eastvale, 67 miles from Victorville, and 55 miles from Temecula while the VMT analysis only assumed a 39.19 mile trip for employees. The revised EIR must also include information and analysis regarding the number of construction jobs generated by the project, construction worker employment analysis, and their potential to relocate to the City.

4.17 Transportation
The EIR has not adequately analyzed the project's potential to substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses; or the project's potential to result in inadequate emergency access. The EIR has not provided any exhibits depicting the available truck/trailer turning radius at the intersection of the project driveways to determine if there is enough space available to accommodate heavy truck maneuvering. There are also no exhibits depicting emergency vehicle access. Deferring this environmental analysis required by CEQA to the construction permitting phase is improper mitigation and does not comply with CEQA's requirement for meaningful disclosure and adequate informational documents. A revised EIR must be prepared for the proposed project with this analysis in order to provide an adequate and accurate environmental analysis.

Further, the EIR has underreported the quantity VMT generated by the proposed project operations by excluding the project's truck/trailer/delivery van activity. A revised EIR must be prepared to include all truck/trailer/delivery van activity for quantified VMT analysis in accordance with the impact threshold. Appendix K2: VMT Analysis includes Table 3: Project Heavy Truck VMT "for informational purposes" only. The operational nature of industrial/warehouse uses involves high rates of truck/trailer/delivery van VMT due to traveling from large import hubs to regional distribution centers to smaller industrial parks and then to their final delivery destinations. Once employees arrive at the industrial buildings for work, they will conduct their jobs by driving truck/trailer/delivery vans across the region as part of the daily operations as a warehouse/parcel hub facility, which will drastically increase project -generated VMT. The project's truck/trailer and delivery van activity is unable to utilize public transit or active transportation and it is misleading to the public and decision makers to exclude this activity from VMT analysis. A revised EIR must be prepared to reflect a quantified VMT analysis that includes all truck/trailer and delivery van activity.

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5.0 Other CEQA Considerations

5.1 Significant Irreversible Environmental Impacts and 5.2 Significant Irreversible Environmental Changes Which Would be Caused by the Project
The EIR relies upon erroneous Energy modeling to determine that the project will meet sustainability requirements. As noted above, the EIR did not model the project's energy consumption in compliance with Title 24 modeling software. Further, the EIR states here that "this commitment of resources would not be substantial and would be consistent with regional and local growth forecasts and development goals for the area." The EIR does not discuss the project's significant and unavoidable cumulatively considerable Air Quality (inconsistency with AQMP), Greenhouse Gas Emissions, Noise, and Transportation impacts or the project's required changes in land use designations (General Plan Amendment, Annexation, Prezone). The EIR must be revised to include a finding of significance due to the project's significant and unavoidable cumulatively considerable Air Quality, Greenhouse Gas Emissions, Noise, and Transportation impacts and direct contribution to climate change.

The EIR does not adequately discuss or and analyze the commitment of resources is not consistent with regional and local growth forecasts. As noted throughout this comment letter, the project represents a significant amount of growth in the City and in tandem with only two other recent industrial projects account for a significant amount of the City's employment growth over 29 years. The EIR must also include a cumulative analysis discussion here to demonstrate the impact of the proposed project in a cumulative setting.

5.3 Growth Inducing Impacts
The EIR does not meaningfully discuss or analyze the project's required land use designation changes (General Plan Amendment, Annexation, Prezone) from residential to industrial and commercial. This increases the developable nonresidential area of the City without providing any information or analysis on the buildout conditions of the General Plan. The growth generated by the proposed project was not anticipated by the General Plan, RTP/SCS, or AQMP. A revised EIR must be prepared with a finding of significance.

The EIR has not provided an adequate or accurate cumulative analysis discussion here to demonstrate the impact of the proposed project in a cumulative setting. For example, other recent industrial projects such as Portrero Logistics Center (771 employees) and Beaumont Summit Station Specific Plan (4,010 employees) combined with the proposed project will cumulatively generate 10,237 employees, which nearly double the City's employment growth forecast over 29 years with only three projects. This total increases exponentially when commercial development activity and other industrial projects are added to the calculation. The EIR must be revised to include this information for analysis and also include a cumulative development analysis of projects approved since 2016 and projects "in the pipeline" to determine if the proposed project

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exceeds the General Plan growth estimates and/or SCAG's growth forecasts.

Conclusion
For the foregoing reasons, GSEJA believes the EIR is flawed and a revised EIR must be prepared for the proposed project and circulated for public review. Golden State Environmental Justice Alliance requests to be added to the public interest list regarding any subsequent environmental documents, public notices, public hearings, and notices of determination for this project. Send all communications to Golden State Environmental Justice Alliance P.O. Box 79222 Corona, CA 92877.

Sincerely,
Gary Ho
Blum, Collins & Ho LLP
Attachment: SWAPE Analysis from January 13, 2023

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SWAPE
Technical Consultation, Data Analysis and
Litigation Support for the Environment
2656 29th Street, Suite 201
Santa Monica, CA 90405
Matt Hagemann, P.G, C.Hg.
(949) 887-9013
[email protected]
Paul E. Rosenfeld, PhD
(310) 795-2335
[email protected]
February 1, 2023
Gary Ho
Blum Collins LLP
707 Wilshire Blvd, Ste. 4880
Los Angeles, CA 90017
Subject: Comments on the Beaumont Pointe Specific Project (SCH No. 2020099007) Dear Mr. Ho,
We have reviewed the December 2022 Draft Environmental Impact Report ("DEIR") for the Beaumont Pointe Specific Plan ("Project") located in the City of Beaumont ("City"). The Project proposes to construct a 246,000 -square -feet ("SF") commercial building, a 125 -room hotel, a 4,995,000 -SF industrial building, and 124.7 -acres of open space on the 539.9 -acre site.

Our review concludes that the DEIR fails to adequately evaluate the Project's air quality, health risk, and greenhouse gas impacts. As a result, emissions and health risk impacts associated with construction and operation of the proposed Project are underestimated and inadequately addressed. A revised EIR should be prepared to adequately assess and mitigate the potential air quality, health risk, and greenhouse gas impacts that the Project may have on the environment.

Air Quality
Unsubstantiated Input Parameters Used to Estimate Project Emissions The DEIR concludes that the Project's construction -related and operational air quality emissions would be significant -and -unavoidable. Specifically, the DEIR estimates that the Project's construction -related VOC and NO.emissions, as well as operational VOC, NOx, CO, PM10, and PM2.semissions would exceed the applicable South Coast Air Quality Management District thresholds (see excerpts below) (p. 4.3-38 —

4.3-39, Table 4.3-6; p. 4.3-39 — 4.3-41, Table 4.3-7).

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Construction Emissions:

Year
Emissions ( bs/day)
VOC
NOx
CO
SOx
PMio
PM:.;
2022

83.42 333.70
350.44

11.79 111.06

34.56 2023

68.37 338.50
362.45

2.53 110.93

35.61 2024
119.56
321.22
393.54

2.61 114.65

36.36 2025

64.96 99.97
132.05

0.44 31.30

10.66 2026

64.63 60.90

69.09 0.20

11.28 4.56
Maximum Daily Emissions
120.39
338.50
416.97

11.79 114.65

36.36 South Coast AQMD Regional Threshold
75 100
550
150
150
55 Threshold Exceeded?
YES
YES
NO
NO
NO
NO
Source: (Urban Crossroads, 2022a, Table 3 6)
Operational Emissions:

Phase
Source
Emissions (lbs/day)
VOC
NOx
CO
SOx
PMio
PM2.5
Total Maximum Daily Emissions
(Phase 2)
155.69
485.80
462.53

3.27 195.00

57.71 South Coast AQMD Regional Threshold
55 55
550
150
150
55 Threshold Exceeded?
YES
YES
NO
NO
YES
YES
Phase 3 (2027)
Area Source
123.16

0.02 1.73

1.30E-
04 6.15E-
03 6.15E-03
Energy Source

1.61 14.65

12.31 0.09

1.11 1.11
Mobile Source

52.49 455.28
551.67

3.36 234.68

67.53 TRUs

0.88 9.97

13.03 0.00

0.08 0.07
On -Site Equipment

1.81 14.50

13.46 0.06

0.56 0.51
Total Maximum Daily Emissions
(Phase 3)
179.96
494.43
592.19

3.51 236.44

69.23 South Coast AQMD Regional Threshold
55 55
550
150
150
55 Threshold Exceeded?
YES
YES
YES
NO
YES
YES
Source: (Urban Crossroads, 2022a, Table 3-10)
As such, the DEIR concludes that the Project's construction and operation would be significant -and - unavoidable (p. 4.3-54 - 4.3-55). Specially, regarding the DEIR's construction -related air quality impact, the DEIR states:
"The Project construction -source emissions have the potential to exceed South Coast AQMD regional thresholds for VOC and NO, emissions prior to mitigation. After application of regulatory controls such as Rule 403, only VOCs and NO. are anticipated to exceed South Coast AQMD regional thresholds. As shown in Table 4.3-11, Maximum Daily Peak Construction Emission Summary with Mitigation, with the implementation of Mitigation Measure MM 4.3-1, 2 B-26
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Project construction -source emissions of VOCs would be reduced to less than significant levels.

However, even after implementation of Mitigation Measure MM 4.3-2, NOx emissions would still exceed applicable South Coast AQMD thresholds" (p. 4.3-54).

Furthermore, regarding the DEIR's operational air quality impact, the DEIR states:
"The Project would exceed regional thresholds of significance established by the South Coast AQMD for emissions of VOC, NOx, PM1o, and PM25. During Phase 1, the Project would exceed the numerical thresholds of significance established by the South Coast AQMD for emissions of NOx. During Phase 2, the Project will exceed the thresholds of significance for emissions of VOC, NOx, PM1o, and PM2s. During Phase 3, the Project would exceed the numerical thresholds of significance for emissions of VOC, NOx, CO, PM1o, and PM2.s Even with the Project's compliance with applicable rules, and the imposition of all feasible mitigation measures identified above (see MM 4.3-3 through MM 4.3-12), the Project's operational NOx, CO, PM10, and PM2.semissions would exceed the applicable regional thresholds of significance. As such, Project operational -source NOx, CO, PM1o, and PM2.5 emissions are considered significant and unavoidable" (p. 4.3-56).

However, while we agree that the Project would result in significant air quality impacts, the DEIR's assertion that this impact is significant -and -unavoidable is incorrect. According to CEQA Guidelines § 15096(g)(2):
"When an updated EIR has been prepared for a project, the Responsible Agency shall not approve the project as proposed if the agency finds any feasible alternative or feasible mitigation measures within its powers that would substantially lessen or avoid any significant effect the project would have on the environment."1
As such, the DEIR is required under CEQA to implement all feasible mitigation to reduce impacts to a less -than -significant level. However, the DEIR's claim that are "no additional feasible mitigation measures" is incorrect. While the DEIR implements MM Air 4.3-1 through MM 4.3-12, the DEIR fails to implement all feasible mitigation (p. 1-7 — 1-15). Therefore, the DEIR's conclusion that Project's air quality emissions would be significant -and -unavoidable is unsubstantiated. To reduce the Project's air quality impacts to the maximum extent possible, additional feasible mitigation measures should be incorporated, such as those suggested in the section of this letter titled "Feasible Mitigation Measures Available to Reduce Emissions." Thus, the Project should not be approved until a revised EIR is prepared, incorporating all feasible mitigation to reduce emissions to less -than -significant levels. 1 "Cal. Code Regs. tit. 14 § 15096." California Legislature, available at: https://casetext.com/regulation/california- code-of-regulations/title-l4-natural-resources/division-6-resources-axencv/chapter-3-gu idel fines-for- i mplementation-of-the-ca I iforn is-envi ronmenta I -qua I ity-act/a rticle-7-eir-process/section-15096-process-for-a- responsible-axencv.
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Diesel Particulate Matter Emissions Inadequately Evaluated The DEIR concludes that the proposed Project would result in a less -than -significant health risk impact based on a quantified construction and mobile -source operational HRA, which is detailed in the Mobile Source Health Risk Assessment ("HRA Report") as Appendix B2 to the DEIR. Specifically, the HRA Report estimates that the maximum cancer risk posed to nearby, existing residential sensitive receptors associated with construction and operation would be 1.33 in one million, which would not exceed the SCAQMD significance threshold of 10 in one million (see excerpt below) (p. 3, Table ES -3).

TABLE ES -3: SUMMARY OF COMBINED CONSTRUCTION AND OPERATIONAL CANCER AND NON -

CANCER HEALTH RISKS
Time Period
Location
Maximum
Lifetime
Cancer Risk
(Risk per
Million)
Significance
Threshold
(Risk per
Million(
Exceeds
Significance
Threshold
30 Year Exposure
Maximum Exposed Sensitive Receptor
I 1.33 I
10 NO
Time Period
Location
Maximum
Hazard
Index
Significance
Threshold
Exceeds
Significance
Threshold
Annual Average
Maximum Exposed Sensitive Receptor
<_0.01

1.0 NO
However, the DEIR's evaluation of the Project's potential health risk impacts, as well as the subsequent less -than -significant impact conclusion, is incorrect for two reasons.

First, the DEIR's construction and operational HRAs underestimate the Fraction of Time At Home ("FAH") values. Specifically, the HRAs utilize a FAH value of 0.85 for the third trimester (age -0.25 to 0) and infant (age 0 to 2) receptors, and an FAH value of 0.72 for the child receptors (age 2 to 16) (see excerpts below) (Appendix B2, p. 21, Table 2-4, Table 2-5).
4 F
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TABLE 2-4: EXPOSURE ASSUMPTIONS FOR INDIVIDUAL CANCER RISK (CONSTRUCTION ACTIVITY) Age2
Daily
Breathing
Rate (L/kg-
day)
Age
Specific
Factor
Exposure
Duration
(years)
Fraction
of Time
at Home
Exposure
Frequency
(days/year)
Exposure
Time
(hours/day)
-0.25 to 0
361
10 0.25

0.85 350
8 0 to 2
1,090
10 2

0.85 350
8 2 to 16
572
3 2.5

0.72 350
8 TABLE 2-5: EXPOSURE ASSUMPTIONS FOR INDIVIDUAL CANCER RISK (30 YEAR RESIDENTIAL) Age3
Daily
Breathing
Rate (L/kg-
day)
Age
Specific
Factor
Exposure
Duration
(years)
Fraction
of Time
at Home
Exposure
Frequency
(days/year)
Exposure
Time
(hours/day)
-0.25 to 0
361
10 0.25

0.85 350
24 0 to 2
1,090
10 2

0.85 350
24 2 to 16
572
3 14

0.72 350
24 16 to 30
261
1 14

0.73 350
24 However, the FAH values used for the third trimester, infant, and childhood receptors are incorrect, as SCAQMD guidance clearly states:
"For Tiers 1, 2, and 3 screening purposes, the FAH is assumed to be 1 for ages third trimester to

16. As a default, children are assumed to attend a daycare or school in close proximity to their home and no discount should be taken for time spent outside of the area affected by the facility's emissions. People older than age 16 are assumed to spend only 73 percent of their time at home."'
As stated above, per SCAQMD guidance, the HRAs should have relied on an FAH value of 1 for the third trimester, infant, and child receptors. Thus, by utilizing incorrect FAH values, the DEIR underestimates the cancer risk posed to nearby, existing sensitive receptors as a result of Project construction and operation.

Second, further review of the HRA Report demonstrates that the HRAs may fail to include Age Sensitivity Factors ("ASFs"). Regarding ASFs, OEHHA guidance states:
"Studies have shown that young animals are more sensitive than adult animals to exposure to many carcinogens (OEHHA, 2009). Therefore, OEHHA developed age sensitivity factors (ASFs) to take into account the increased sensitivity to carcinogens during early -in -life exposure (Table

8.3). These factors were developed and described in detail in OEHHA (2009). In the absence of chemical -specific data, OEHHA recommends a default ASF of 10 for the third trimester to age 2 2 "Risk Assessment Procedures." SCAQMD, August 2017, available at: http://www.agmd.gov/docs/default- source/rule-book/Proposed-Rules/1401/riskassessmentprocedures 2017 080717.pdf, p. 7. 5 -4—
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years, and an ASF of 3 for ages 2 through 15 years to account for potential increased sensitivity to carcinogens during childhood."
However, while the HRA Report includes ASFs in their exposure assumption tables, the equation to produce carcinogenic risk estimates, as shown below, is incorrect and underestimated (p. 22).

RISKair = DOSEair x CPF x ED/AT
Where:

DOSEair chronic daily intake (mg/kg/day)
CPF cancer potency factor
ED number of years within particular age group
AT averaging time
Instead, the HRA Report should have used the following equation that includes ASFs:

ED
Cancer Risk R = DosegfR x CPF x ASF X FAH x AT
Thus, by potentially failing to include ASF values in the carcinogenic risk estimate equation, the DEIR's HRAs underestimate the cancer risk posed to nearby, existing sensitive receptors as a result of Project construction and operation. As such, a revised EIR should be prepared to include an updated analysis correctly accounting for ASF values.

Greenhouse Gas
Failure to Adequately Evaluate Greenhouse Gas Impacts
The DEIR estimates that the Project would result in net annual greenhouse gas ("GHG") emissions of 60,638.09 metric tons of carbon dioxide equivalents per year ("MT CO2e/year") (see excerpt below) (p.

4.8-61, Table 4.8-10).
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Table 4.8-10 2027 Project Buildout GHG Emissions with Mitigation Emission Source
Emissions (\1T!vi)
CO2
CH4
N20
Total CO2e
Annual construction -related emissions amortized
over 30 years

1.160.95

0.18 0.05

1.,200.61
Area Source°

0.23 0.00

0.00 0.24
Energy Source'
5,155.53

0.22 0.07
5,183.39
Mobile Source`
48,209.87

1.27 5.45
49,865.32
TRU Source
-
236.63
On -Site Equipment Source
915,15

0.06 0.00
922.58
Waste Source
1,231.61

72.79 0.00
3,051.27
Water Usage Sourced
138.82

1.19 0.03
178.05
Total CO_e (All Sources) I
60,638.09
As such, the DEIR concludes that the Project would result in a significant -and -unavoidable GHG impact, stating:
"No additional feasible mitigation measures are available that can reduce impacts to less than significant. The Project incorporates all feasible mitigation measures that could be implemented to further reduce the Project's GHG emissions below the 3,000 MTCO2e threshold. There are no additional measures available that would further reduce emissions because the majority of the Project's emissions come from mobile sources which are regulated by the State and not the City of Beaumont" (p. 4.8-61).

However, while we agree that the Project would result in a significant GHG impact, the DEIR's assertion that this impact is significant -and -unavoidable is incorrect. As previously discussed, according to CEQA Guidelines § 15096(g)(2):
"When an updated EIR has been prepared for a project, the Responsible Agency shall not approve the project as proposed if the agency finds any feasible alternative or feasible mitigation measures within its powers that would substantially lessen or avoid any significant effect the project would have on the environment."
As indicated above, an impact can only be labeled as significant -and -unavoidable after all available, feasible mitigation is considered. Here, while the DEIR implements MM Air 4.3-1 through MM 4.3-12, the DEIR fails to implement all feasible mitigation (p. 1-7 — 1-15). Therefore, the DEIR's conclusion that the Project's GHG emissions would be significant -and -unavoidable is unsubstantiated. To reduce the Project's GHG impacts to the maximum extent possible, additional feasible mitigation measures should be incorporated, such as those suggested in the section of this letter titled "Feasible Mitigation Measures Available to Reduce Emissions." Thus, the Project should not be approved until a revised EIR is prepared, incorporating all feasible mitigation to reduce emissions to less -than -significant levels. 7 B-32
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Mitigation
Feasible Mitigation Measures Available to Reduce Emissions Our analysis demonstrates that the Project would result in potentially significant air quality and GHG impacts that should be mitigated further. As such, in an effort to reduce the Project's emissions, we identified several mitigation measures that are applicable to the proposed Project. Feasible mitigation measures can be found in the California Department of Justice Warehouse Project Best Practices document.' Therefore, to reduce the Project's emissions, consideration of the following measures should be made:
• Prohibiting off -road diesel -powered equipment from being in the "on" position for more than 10 hours per day.
• Designating an area in the construction site where electric -powered construction vehicles and equipment can charge.
• Limiting the amount of daily grading disturbance area. • Prohibiting grading on days with an Air Quality Index forecast of greater than 100 for particulates or ozone for the project area.
• Forbidding idling of heavy equipment for more than three minutes. • Keeping onsite and furnishing to the lead agency or other regulators upon request, all equipment maintenance records and data sheets, including design specifications and emission control tier classifications.
• Conducting an on -site inspection to verify compliance with construction mitigation and to identify other opportunities to further reduce construction impacts. • Requiring all heavy-duty vehicles engaged in drayage to or from the project site to be zero - emission beginning in 2030.
• Requiring tenants to use zero -emission light- and medium -duty vehicles as part of business operations.
• Forbidding trucks from idling for more than three minutes and requiring operators to turn off engines when not in use.
• Installing solar photovoltaic systems on the project site of a specified electrical generation capacity that is equal to or greater than the building's projected energy needs, including all electrical chargers.
• Designing all project building roofs to accommodate the maximum future coverage of solar panels and installing the maximum solar power generation capacity feasible. • Constructing zero -emission truck charging/fueling stations proportional to the number of dock doors at the project.
• Running conduit to designated locations for future electric truck charging stations. • Unless the owner of the facility records a covenant on the title of the underlying property ensuring that the property cannot be used to provide refrigerated warehouse space, 3 "Warehouse Projects: Best Practices and Mitigation Measures to Comply with the California Environmental Quality Act." State of California Department of Justice, September 2022, available at:
https://oag.ca.gov/system/files/media/warehouse-best-practices.pdf , p. 8 —10. 8 B-34
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constructing electric plugs for electric transport refrigeration units at every dock door and requiring truck operators with transport refrigeration units to use the electric plugs when at loading docks.
• Oversizing electrical rooms by 25 percent or providing a secondary electrical room to accommodate future expansion of electric vehicle charging capability. • Constructing and maintaining electric light -duty vehicle charging stations proportional to the number of employee parking spaces (for example, requiring at least 10% of all employee parking spaces to be equipped with electric vehicle charging stations of at least Level 2 charging performance)
• Running conduit to an additional proportion of employee parking spaces for a future increase in the number of electric light -duty charging stations.
• Installing and maintaining, at the manufacturer's recommended maintenance intervals, air filtration systems at sensitive receptors within a certain radius of facility for the life of the project.
• Installing and maintaining, at the manufacturer's recommended maintenance intervals, an air monitoring station proximate to sensitive receptors and the facility for the life of the project, and making the resulting data publicly available in real time. While air monitoring does not mitigate the air quality or greenhouse gas impacts of a facility, it nonetheless benefits the affected community by providing information that can be used to improve air quality or avoid exposure to unhealthy air.
• Requiring all stand-by emergency generators to be powered by a non -diesel fuel. • Requiring facility operators to train managers and employees on efficient scheduling and load management to eliminate unnecessary queuing and idling of trucks. • Requiring operators to establish and promote a rideshare program that discourages single - occupancy vehicle trips and provides financial incentives for alternate modes of transportation, including carpooling, public transit, and biking.
• Meeting CalGreen Tier 2 green building standards, including all provisions related to designated parking for clean air vehicles, electric vehicle charging, and bicycle parking. • Designing to LEED green building certification standards. • Providing meal options onsite or shuttles between the facility and nearby meal destinations. • Posting signs at every truck exit driveway providing directional information to the truck route. • Improving and maintaining vegetation and tree canopy for residents in and around the project area.
• Requiring that every tenant train its staff in charge of keeping vehicle records in diesel technologies and compliance with CARB regulations, by attending CARB-approved courses. Also require facility operators to maintain records on -site demonstrating compliance and make records available for inspection by the local jurisdiction, air district, and state upon request. • Requiring tenants to enroll in the United States Environmental Protection Agency's SmartWay program, and requiring tenants who own, operate, or hire trucking carriers with more than 100 trucks to use carriers that are SmartWay carriers.
9 B-48
(CONT.)
• B-49
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These measures offer a cost-effective, feasible way to incorporate lower -emitting design features into the proposed Project, which subsequently, reduce emissions released during Project construction and operation.

Furthermore, as it is policy of the State that eligible renewable energy resources and zero -carbon resources supply 100% of retail sales of electricity to California end -use customers by December 31, 2045, we emphasize the applicability of incorporating solar power system into the Project design. Until the feasibility of incorporating on -site renewable energy production is considered, the Project should not be approved.

A revised EIR should be prepared to include all feasible mitigation measures, as well as include updated air quality and GHG analyses to ensure that the necessary mitigation measures are implemented to reduce emissions to below thresholds. The revised EIR should also demonstrate a commitment to the implementation of these measures prior to Project approval, to ensure that the Project's significant emissions are reduced to the maximum extent possible.

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

Sincerely,
Opt �y�
Matt Hagemann, P.G., C.Hg.
(fk,_ Cy., 1,2i A
Paul E. Rosenfeld, Ph.D.

Attachment A: Matt Hagemann CV
Attachment B: Paul Rosenfeld CV
10 4
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SWAPE
Technical Consultation, Data Analysis and
Litigation Support for the Environment
Matthew F. Hagemann, P.G., C.Hg., QSD, QSP
Attachment A
2656 29th Street, Suite 201
Santa Monica, CA 90405
Matt Hagemann, P.G, C.Hg.
(949) 887-9013
[email protected]
Geologic and Hydrogeologic Characterization
Investigation and Remediation Strategies
Litigation Support and Testifying Expert
Industrial Stormwater Compliance
CEQA Review
Education:

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

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

Professional Certifications:

California Professional Geologist
California Certified Hydrogeologist
Qualified SWPPP Developer and Practitioner
Professional Experience:

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

Positions Matt has held include:
• Founding Partner, Soil/Water/Air Protection Enterprise (SWAPE) (2003 — present); • Geology Instructor, Golden West College, 2010 — 2104, 2017; • Senior Environmental Analyst, Komex H2O Science, Inc. (2000 -- 2003); B-68
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• Executive Director, Orange Coast Watch (2001 — 2004); • Senior Science Policy Advisor and Hydrogeologist, U.S. Environmental Protection Agency (1989- 1998);
• Hydrogeologist, National Park Service, Water Resources Division (1998 — 2000); • Adjunct Faculty Member, San Francisco State University, Department of Geosciences (1993 — 1998);
• Instructor, College of Marin, Department of Science (1990 —1995); • Geologist, U.S. Forest Service (1986 —1998); and
• Geologist, Dames & Moore (1984 —1986).

Senior Regulatory and Litigation Support Analyst:

With SWAPE, Matt's responsibilities have included:
• Lead analyst and testifying expert in the review of over 300 environmental impact reports and negative declarations since 2003 under CEQA that identify significant issues with regard to hazardous waste, water resources, water quality, air quality, greenhouse gas emissions, and geologic hazards. Make recommendations for additional mitigation measures to lead agencies at the local and county level to include additional characterization of health risks and implementation of protective measures to reduce worker exposure to hazards from toxins and Valley Fever.
• Stormwater analysis, sampling and best management practice evaluation at more than 100 industrial facilities.
• Expert witness on numerous cases including, for example, perfluorooctanoic acid (PFOA) contamination of groundwater, MTBE litigation, air toxins at hazards at a school, CERCLA compliance in assessment and remediation, and industrial stormwater contamination. • Technical assistance and litigation support for vapor intrusion concerns. • Lead analyst and testifying expert in the review of environmental issues in license applications for large solar power plants before the California Energy Commission. • Manager of a project to evaluate numerous formerly used military sites in the western U.S. • Manager of a comprehensive evaluation of potential sources of perchlorate contamination in Southern California drinking water wells.
• Manager and designated expert for litigation support under provisions of Proposition 65 in the review of releases of gasoline to sources drinking water at major refineries and hundreds of gas stations throughout California.

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

Executive Director:

As Executive Director with Orange Coast Watch, Matt led efforts to restore water quality at Orange County beaches from multiple sources of contamination including urban runoff and the discharge of wastewater. In reporting to a Board of Directors that included representatives from leading Orange County universities and businesses, Matt prepared issue papers in the areas of treatment and disinfection of wastewater and control of the discharge of grease to sewer systems. Matt actively participated in the development of countywide water quality permits for the control of urban runoff and permits for the discharge of wastewater. Matt worked with other nonprofits to protect and restore water quality, including Surfrider, Natural Resources Defense Council and Orange County CoastKeeper as well as with business institutions including the Orange County Business Council.

Hydrogeology:

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

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

As a hydrogeologist with the EPA Groundwater Protection Section, Matt worked with provisions of the Safe Drinking Water Act and NEPA to prevent drinking water contamination. Specific activities included the following:
• Received an EPA Bronze Medal for his contribution to the development of national guidance for the protection of drinking water.
• Managed the Sole Source Aquifer Program and protected the drinking water of two communities through designation under the Safe Drinking Water Act. He prepared geologic reports, conducted 3 B-68
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public hearings, and responded to public comments from residents who were very concerned about the impact of designation.
• Reviewed a number of Environmental Impact Statements for planned major developments, including large hazardous and solid waste disposal facilities, mine reclamation, and water transfer.

Matt served as a hydrogeologist with the RCRA Hazardous Waste program. Duties were as follows:
• Supervised the hydrogeologic investigation of hazardous waste sites to determine compliance with Subtitle C requirements.
• Reviewed and wrote "part B" permits for the disposal of hazardous waste. • Conducted RCRA Corrective Action investigations of waste sites and led inspections that formed the basis for significant enforcement actions that were developed in close coordination with U.S.

EPA legal counsel.
• Wrote contract specifications and supervised contractor's investigations of waste sites.

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

Policy:

Served senior management as the Senior Science Policy Advisor with the U.S. Environmental Protection Agency, Region 9.

Activities included the following:
• Advised the Regional Administrator and senior management on emerging issues such as the potential for the gasoline additive MTBE and ammonium perchlorate to contaminate drinking water supplies.
• Shaped EPA's national response to these threats by serving on workgroups and by contributing to guidance, including the Office of Research and Development publication, Oxygenates in Water: Critical Information and Research Needs.
• Improved the technical training of EPA's scientific and engineering staff. • Earned an EPA Bronze Medal for representing the region's 300 scientists and engineers in negotiations with the Administrator and senior management to better integrate scientific 4 B-68
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principles into the policy -making process.
• Established national protocol for the peer review of scientific documents.

Geology:

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

As a consultant with Dames and Moore, Matt led geologic investigations of two contaminated sites (later listed on the Superfund NPL) in the Portland, Oregon, area and a large hazardous waste site in eastern Oregon. Duties included the following:
• Supervised year -long effort for soil and groundwater sampling. • Conducted aquifer tests.
• Investigated active faults beneath sites proposed for hazardous waste disposal.

Teaching:

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

Matt is currently a part time geology instructor at Golden West College in Huntington Beach, California where he taught from 2010 to 2014 and in 2017.

Invited Testimony, Reports, Papers and Presentations:

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

Hagemann, M.F., 2008. Disclosure of Hazardous Waste Issues under CEQA. Invited presentation to U.S.

EPA Region 9, San Francisco, California.

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

Hagemann, M.F., 2004. Perchlorate Contamination of the Colorado River and Impacts to Drinking Water in Nevada and the Southwestern U.S. Presentation to a meeting of the American Groundwater Trust, Las Vegas, NV (served on conference organizing committee).
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Hagemann, M.F., 2004. Invited testimony to a California Senate committee hearing on air toxins at schools in Southern California, Los Angeles.

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

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

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

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

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

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

Hagemann, M.F., 2003. Impact of Perchlorate on the Colorado River and Associated Drinking Water Supplies. Invited presentation to the Inter -Tribal Meeting, Torres Martinez Tribe.

Hagemann, M.F., 2003. The Emergence of Perchlorate as a Widespread Drinking Water Contaminant.

Invited presentation to the U.S. EPA Region 9.

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

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

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

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

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

Hagemann, M.F., 2002. An Estimate of Costs to Address MTBE Releases from Underground Storage Tanks and the Resulting Impact to Drinking Water Wells. Presentation to a meeting of the U.S. EPA and State Underground Storage Tank Program managers.
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Hagemann, M.F., 2001. From Tank to Tap: A Chronology of MTBE in Groundwater. Unpublished report.

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

Unpublished report.

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

Hagemann, M.F., and VanMouwerik, M., 1999. Potential W a t e r Quality Concerns Related to Snowmobile Usage. Water Resources Division, National Park Service, Technical Report.

VanMouwerik, M. and Hagemann, M.F. 1999, Water Quality Concerns Related to Personal Watercraft Usage. Water Resources Division, National Park Service, Technical Report.

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

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

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

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

Hagemann, M. F., Fukanaga, G. L., 1996, Ranking Groundwater Vulnerability in Central Oahu, Hawaii. Proceedings, Geographic Information Systems in Environmental Resources Management, Air and Waste Management Association Publication VIP -61.

Hagemann, M.F., 1994. Groundwater Char acterization and Cleanup at Closing Military Bases in California. Proceedings, Califomia Groundwater Resources Association Meeting.

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

Hagemann, M.F., 1993. U.S. EPA Policy on the Technical Impracticability of the Cleanup of DNAPL- contaminated Groundwater. California Groundwater Resources Association Meeting. 7 B-68
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Hagemann, M.F., 1992. Dense Nonaqueous Phase Liquid Contamination of Groundwater: An Ounce of Prevention... Proceedings, Association of Engineering Geologists Annual Meeting, v. 35.

Other Experience:

Selected as subject matter expert for the California Professional Geologist licensing examinations, 2009-2011.
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SWAPE
Technical Consultation, Data Analysis and
Litigation Support for the Environment
Attachment B

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

Mobil: (310) 795-2335
Office: (310) 452-5555
Fax: (310) 452-5550
Email: prosenfeld(n.swape.com
Paul Rosenfeld, Ph.D.

Chemical Fate and Transport & Air Dispersion Modeling
Principal Environmental Chemist Risk Assessment & Remediation Specialist Education
Ph.D. Soil Chemistry, University of Washington, 1999. Dissertation on volatile organic compound filtration.

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

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

Professional Experience
Dr. Rosenfeld has over 25 years of experience conducting environmental investigations and risk assessments for evaluating impacts to human health, property, and ecological receptors. His expertise focuses on the fate and transport of environmental contaminants, human health risk, exposure assessment, and ecological restoration. Dr.

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

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

Paul E. Rosenfeld, Ph.D.

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Professional History:

Soil Water Air Protection Enterprise (SWAPE); 2003 to present; Principal and Founding Partner UCLA School of Public Health; 2007 to 2011; Lecturer (Assistant Researcher) UCLA School of Public Health; 2003 to 2006; Adjunct Professor UCLA Environmental Science and Engineering Program; 2002-2004; Doctoral Intern Coordinator UCLA Institute of the Environment, 2001-2002; Research Associate Komex H2O Science, 2001 to 2003; Senior Remediation Scientist National Groundwater Association, 2002-2004; Lecturer
San Diego State University, 1999-2001; Adjunct Professor Anteon Corp., San Diego, 2000-2001; Remediation Project Manager Ogden (now Amec), San Diego, 2000-2000; Remediation Project Manager Bechtel, San Diego, California, 1999 — 2000; Risk Assessor King County, Seattle, 1996 — 1999; Scientist
James River Corp., Washington, 1995-96; Scientist
Big Creek Lumber, Davenport, California, 1995; Scientist Plumas Corp., California and USFS, Tahoe 1993-1995; Scientist Peace Corps and World Wildlife Fund, St. Kitts, West Indies, 1991-1993; Scientist Publications:

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

Remy, L.L., Clay T., Byers, V., Rosenfeld P. E. (2019) Hospital, Health, and Community Burden After Oil Refinery Fires, Richmond, California 2007 and 2012. Environmental Health. 18:48 Simons, R.A., Seo, Y. Rosenfeld, P., (2015) Modeling the Effect of Refinery Emission On Residential Property Value. Journal of Real Estate Research. 27(3):321-342
Chen, J. A, Zapata A. R., Sutherland A. J., Molmen, D.R., Chow, B. S., Wu, L. E., Rosenfeld, P. E., Hesse, R. C.. (2012) Sulfur Dioxide and Volatile Organic Compound Exposure To A Community In Texas City Texas Evaluated Using Aermod and Empirical Data. American Journal of Environmental Science, 8(6), 622-632.

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

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

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

Procedia Environmental Sciences. 113-125.

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

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

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

Paul E. Rosenfeld, Ph.D.

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

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

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

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

Rosenfeld, P.E., J. J. J. Clark, A. R. Hensley, M. Suffet. (2007). The Use of an Odor Wheel Classification for Evaluation of Human Health Risk Criteria for Compost Facilities. Water Science & Technology 55(5), 345-357.

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

Sullivan, P. J. Clark, J.J.J., Agardy, F. J., Rosenfeld, P.E. (2007). Toxic Legacy, Synthetic Toxins in the Food, Water, and Air in American Cities. Boston Massachusetts: Elsevier Publishing Rosenfeld, P.E., and Suffet I.H. (2004). Control of Compost Odor Using High Carbon Wood Ash. Water Science and Technology. 49(9),171-178.

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

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

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

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

Rosenfeld, P.E., Grey, M and Suffet, M. (2002). Compost Demonstration Project, Sacramento California Using High -Carbon Wood Ash to Control Odor at a Green Materials Composting Facility. Integrated Waste Management Board Public Affairs Office, Publications Clearinghouse (MS -6), Sacramento, CA Publication 8442-02-008.

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

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

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

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

Paul E. Rosenfeld, Ph.D.

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

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

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

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

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

Rosenfeld, P. E. (1998). Characterization, Quantification, and Control of Odor Emissions From Biosolids Application To Forest Soil. Doctoral Thesis. University of Washington College of Forest Resources.

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

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

Presentations:

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

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

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

Urban Environmental Pollution. Lecture conducted from Boston, MA.

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

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

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

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

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

Paul E. Rosenfeld, Ph.D.

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Rosenfeld, P. E. (October 15-18, 2007). The Repeated Trespass of Tritium -Contaminated Water Into A Surrounding Community Form Repeated Waste Spills From A Nuclear Power Plant. The 23'd Annual International Conferences on Soils Sediment and Water. Platform lecture conducted from University of Massachusetts, Amherst MA.

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

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

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

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

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

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

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

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

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

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

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

International Society of Environmental Forensics: Focus On Emerging Contaminants. Lecture conducted from Sheraton Oceanfront Hotel, Virginia Beach, Virginia.

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

Lecture conducted from Wyndham Baltimore Inner Harbor, Baltimore Maryland.

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

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

Paul E. Rosenfeld, Ph.D.

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

Lecture conducted from Phoenix Arizona.

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

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

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

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

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

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

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

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

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

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

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

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

Northwest Biosolids Management Association. Lecture conducted from Vancouver Washington..

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

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

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

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

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

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

Paul E. Rosenfeld, Ph.D.

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

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

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

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

Teaching Experience:

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

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

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

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

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

University Of Washington, Soil Science Program, Teaching Assistant for several courses including: Soil Chemistry, Organic Soil Amendments, and Soil Stability.

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

Academic Grants Awarded:

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

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

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

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

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

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

Paul E. Rosenfeld, Ph.D.

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

United State Forest Service, Tahoe National Forest: $15,000 grant was awarded to investigating fire ecology of the Tahoe National Forest. 1995.

Kellogg Foundation, Washington D.C. $500 grant was awarded to construct a large anaerobic digester on St. Kitts in West Indies. 1993
Deposition and/or Trial Testimony:

In the Superior Court of the State of California, County of San Bernardino Billy Wildrick, Plaintiff vs. BNSF Railway Company
Case No. CIVDS1711810
Rosenfeld Deposition 10-17-2022
In the State Court of Bibb County, State of Georgia
Richard Hutcherson, Plaintiff vs Norfolk Southern Railway Company Case No. 10-SCCV-092007
Rosenfeld Deposition 10-6-2022
In the Civil District Court of the Parish of Orleans, State of Louisiana Millard Clark, Plaintiff vs. Dixie Carriers, Inc. et al.

Case No. 2020-03891
Rosenfeld Deposition 9-15-2022
In The Circuit Court of Livingston County, State of Missouri, Circuit Civil Division Shirley Rails, Plaintiff vs. Canadian Pacific Railway and Soo Line Railroad Case No. 18-LV-CC0020
Rosenfeld Deposition 9-7-2022
In The Circuit Court of the 13th Judicial Circuit Court, Hillsborough County, Florida Civil Division Jonny C. Daniels, Plaintiff vs. CSX Transportation Inc.

Case No. 20 -CA -5502
Rosenfeld Deposition 9-1-2022
In The Circuit Court of St. Louis County, State of Missouri Kieth Luke et. al. Plaintiff vs. Monsanto Company et. al.

Case No. 19SL-CC03191
Rosenfeld Deposition 8-25-2022
In The Circuit Court of the 13th Judicial Circuit Court, Hillsborough County, Florida Civil Division Jeffery S. Lamotte, Plaintiff vs. CSX Transportation Inc.

Case No. NO. 20 -CA -0049
Rosenfeld Deposition 8-22-2022
In State of Minnesota District Court, County of St. Louis Sixth Judicial District Greg Bean, Plaintiff vs. Soo Line Railroad Company
Case No. 69 -DU -CV -21-760
Rosenfeld Deposition 8-17-2022
In United States District Court Western District of Washington at Tacoma, Washington John D. Fitzgerald Plaintiff vs. BNSF
Case No. 3:21-cv-05288-RJB
Rosenfeld Deposition 8-11-2022
Paul E. Rosenfeld, Ph.D.

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In Circuit Court of the Sixth Judicial Circuit, Macon Illinois Rocky Bennyhoff Plaintiff vs. Norfolk Southern
Case No. 20-L-56
Rosenfeld Deposition 8-3-2022
In Court of Common Pleas, Hamilton County Ohio
Joe Briggins Plaintiff vs. CSX
Case No. A2004464
Rosenfeld Deposition 6-17-2022
In the Superior Court of the State of California, County of Kern George LaFazia vs. BNSF Railway Company.

Case No. BCV-19-103087
Rosenfeld Deposition 5-17-2022
In the Circuit Court of Cook County Illinois
Bobby Earles vs. Penn Central et. al.

Case No. 2020-L-000550
Rosenfeld Deposition 4-16-2022
In United States District Court Easter District of Florida Albert Hartman Plaintiff vs. Illinois Central
Case No. 2:20-cv-1633
Rosenfeld Deposition 4-4-2022
In the Circuit Court of the 4ih Judicial Circuit, in and For Duval County, Florida Barbara Steele vs. CSX Transportation
Case No.16-219-Ca-008796
Rosenfeld Deposition 3-15-2022
In United States District Court Easter District of New York Romano et al. vs. Northrup Grumman Corporation
Case No. 16-cv-5760
Rosenfeld Deposition 3-10-2022
In the Circuit Court of Cook County Illinois
Linda Benjamin vs. Illinois Central
Case No. No. 2019 L 007599
Rosenfeld Deposition 1-26-2022
In the Circuit Court of Cook County Illinois
Donald Smith vs. Illinois Central
Case No. No. 2019 L 003426
Rosenfeld Deposition 1-24-2022
In the Circuit Court of Cook County Illinois
Jan Holeman vs. BNSF
Case No. 2019 L 000675
Rosenfeld Deposition 1-18-2022
In the State Court of Bibb County State of Georgia
Dwayne B. Garrett vs. Norfolk Southern
Case No. 20-SCCV-091232
Rosenfeld Deposition 11-10-2021
Paul E. Rosenfeld, Ph.D.

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In the Circuit Court of Cook County Illinois
Joseph Ruepke vs. BNSF
Case No. 2019 L 007730
Rosenfeld Deposition 11-5-2021
In the United States District Court For the District of Nebraska Steven Gillett vs. BNSF
Case No. 4:20-cv-03120
Rosenfeld Deposition 10-28-2021
In the Montana Thirteenth District Court of Yellowstone County James Eadus vs. Soo Line Railroad and BNSF
Case No. DV 19-1056
Rosenfeld Deposition 10-21-2021
In the Circuit Court Of The Twentieth Judicial Circuit, St Clair County, Illinois Martha Custer et al.cvs. Cerro Flow Products, Inc.

Case No. 0i9 -L-2295
Rosenfeld Deposition 5-14-2021
Trial October 8-4-2021
In the Circuit Court of Cook County Illinois
Joseph Rafferty vs. Consolidated Rail Corporation and National Railroad Passenger Corporation d/b/a

AMTRAK,
Case No. 18-L-6845
Rosenfeld Deposition 6-28-2021
In the United States District Court For the Northern District of Illinois Theresa Romcoe vs. Northeast Illinois Regional Commuter Railroad Corporation d/b/a METRA Rail Case No. 17-cv-8517
Rosenfeld Deposition 5-25-2021
In the Superior Court of the State of Arizona In and For the Cunty of Maricopa Mary Tryon et al. vs. The City of Pheonix v. Cox Cactus Farm, L.L.C., Utah Shelter Systems, Inc.

Case No. CV20127-094749
Rosenfeld Deposition 5-7-2021
In the United States District Court for the Eastern District of Texas Beaumont Division Robinson, Jeremy et al vs. CNA Insurance Company et al.

Case No. 1:17-cv-000508
Rosenfeld Deposition 3-25-2021
In the Superior Court of the State of California, County of San Bernardino Gary Garner, Personal Representative for the Estate of Melvin Garner vs. BNSF Railway Company.

Case No. 1720288
Rosenfeld Deposition 2-23-2021
In the Superior Court of the State of California, County of Los Angeles, Spring Street Courthouse Benny M Rodriguez vs. Union Pacific Railroad, A Corporation, et al.

Case No. 18STCV01162
Rosenfeld Deposition 12-23-2020
In the Circuit Court of Jackson County, Missouri
Karen Cornwell, Plaintiff, vs. Marathon Petroleum, LP, Defendant.

Case No. 1716 -CV 10006
Rosenfeld Deposition 8-30-2019
Paul E. Rosenfeld, Ph.D.

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

Case No. 2:17-cv-01624-ES-SCM
Rosenfeld Deposition 6-7-2019
In the United States District Court of Southern District of Texas Galveston Division M/'T Carla Maersk vs. Conti 168., Schiffahrts-GMBH & Co. Bulker KG MS "Conti Perdido" Defendant.

Case No. 3:15 -CV -00106 consolidated with 3:15 -CV -00237 Rosenfeld Deposition 5-9-2019
In The Superior Court of the State of California In And For The County Of Los Angeles — Santa Monica Carole-Taddeo-Bates et al., vs. Ifran Khan et al., Defendants Case No. BC615636
Rosenfeld Deposition 1-26-2019
In The Superior Court of the State of California In And For The County Of Los Angeles — Santa Monica The San Gabriel Valley Council of Governments et al. vs El Adobe Apts. Inc. et al., Defendants Case No. BC646857
Rosenfeld Deposition 10-6-2018; Trial 3-7-19
In United States District Court For The District of Colorado Bells et al. Plaintiffs vs. The 3M Company et al., Defendants Case No. 1:16-cv-02531-RBJ
Rosenfeld Deposition 3-15-2018 and 4-3-2018
In The District Court Of Regan County, Texas, 112th Judicial District Phillip Bales et al., Plaintiff vs. Dow Agrosciences, LLC, et al., Defendants Cause No. 1923
Rosenfeld Deposition 11-17-2017
In The Superior Court of the State of California In And For The County Of Contra Costa Simons et al., Plaintifs vs. Chevron Corporation, et al., Defendants Cause No. C12-01481
Rosenfeld Deposition 11-20-2017
In The Circuit Court Of The Twentieth Judicial Circuit, St Clair County, Illinois Martha Custer et al., Plaintiff vs. Cerro Flow Products, Inc., Defendants Case No.: No. 0i9 -L-2295
Rosenfeld Deposition 8-23-2017
In United States District Court For The Southern District of Mississippi Guy Manuel vs. The BP Exploration et al., Defendants
Case No. 1:19-cv-00315-RHW
Rosenfeld Deposition 4-22-2020
In The Superior Court of the State of California, For The County of Los Angeles Warrn Gilbert and Penny Gilber, Plaintiff vs. BMW of North America LLC Case No. LC102019 (c/w BC582154)
Rosenfeld Deposition 8-16-2017, Trail 8-28-2018
In the Northern District Court of Mississippi, Greenville Division Brenda J. Cooper, et al., Plaintiffs, vs. Meritor Inc., et al., Defendants Case No. 4:16-cv-52-DMB-JVM
Rosenfeld Deposition July 2017
Paul E. Rosenfeld, Ph.D.

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In The Superior Court of the State of Washington, County of Snohomish Michael Davis and Julie Davis et al., Plaintiff vs. Cedar Grove Composting Inc., Defendants Case No. 13-2-03987-5
Rosenfeld Deposition, February 2017
Trial March 2017
In The Superior Court of the State of California, County of Alameda Charles Spain., Plaintiff vs. Thermo Fisher Scientific, et al., Defendants Case No. RG14711115
Rosenfeld Deposition September 2015
In The Iowa District Court In And For Poweshiek County
Russell D. Winburn, et al., Plaintiffs vs. Doug Hoksbergen, et al., Defendants Case No. LALA002187
Rosenfeld Deposition August 2015
In The Circuit Court of Ohio County, West Virginia
Robert Andrews, et al. v. Antero, et al.

Civil Action No. 14-C-30000
Rosenfeld Deposition June 2015
In The Iowa District Court for Muscatine County
Laurie Freeman et. al. Plaintiffs vs. Grain Processing Corporation, Defendant Case No. 4980
Rosenfeld Deposition May 2015
In the Circuit Court of the 17th Judicial Circuit, in and For Broward County, Florida Walter Hinton, et. al. Plaintiff, vs. City of Fort Lauderdale, Florida, a Municipality, Defendant.

Case No. CACE07030358 (26)
Rosenfeld Deposition December 2014
In the County Court of Dallas County Texas
Lisa Parr et al, Plaintiff, vs. Aruba et al, Defendant.

Case No. cc -11-01650-E
Rosenfeld Deposition: March and September 2013
Rosenfeld Trial April 2014
In the Court of Common Pleas of Tuscarawas County Ohio
John Michael Abicht, et al., Plaintiffs, vs. Republic Services, Inc., et al., Defendants Case No. 2008 CT 10 0741 (Cons. w/ 2009 CV 10 0987)
Rosenfeld Deposition October 2012
In the United States District Court for the Middle District of Alabama, Northern Division James K. Benefield, et al., Plaintiffs, vs. International Paper Company, Defendant.

Civil Action No. 2:09-cv-232-WHA-TFM
Rosenfeld Deposition July 2010, June 2011
In the Circuit Court of Jefferson County Alabama
Jaeanette Moss Anthony, et al., Plaintiffs, vs. Drummond Company Inc., et al., Defendants Civil Action No. CV 2008-2076
Rosenfeld Deposition September 2010
In the United States District Court, Western District Lafayette Division Ackle et al., Plaintiffs, vs. Citgo Petroleum Corporation, et al., Defendants.

Case No. 2:07CV1052
Rosenfeld Deposition July 2009
Paul E. Rosenfeld, Ph.D.

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Responses to Comment B
Blum Collins & Ho, LLP on behalf of Golden State Environmental Justice Alliance, Gary Ho, dated February 8, 2023.

B-1
This comment consists of introductory remarks and identifies that the comments on the Draft EIR are being provided by Blum Collins & Ho, LLP on behalf of the Golden State Environmental Justice Alliance (GSEJA). GSEJA requests to be added to the public interest list regarding any subsequent environmental documents, public notices, public hearings, and notices of determination for this Project. The statement of interest is acknowledged and the City will include GSEJA on the mailing list for future CEQA notices related to the Project.

B-2 This comment provides a general summary of the Project Description as provided in the Draft EIR. This comment does not raise any issues concerning or relating to the adequacy of the environmental analysis provided in the Draft EIR and thus no further response is required.

B-3 The commenter incorrectly states that the Beaumont Pointe Specific Plan document was not attached for public review. The draft Specific Plan was incorporated by reference in the EIR at p. 2-7. CEQA Guidelines section 15150(b) only requires that a document to be incorporated by reference be made available to the public for inspection. The draft Specific Plan was posted at the same time and in the same location as the Draft EIR and its technical appendices on the City's website and remained available for review throughout the DEIR public comment period, as was documented in the Notice of Availability for the Draft EIR, at:
https://www.beaumontca.gov/1143/Beaumont-Pointe-Specific-Plan . The EIR p. 2-6 also states that the Specific Plan is available on the City's website. Therefore, no further response is required.

B-4 The commenter refers to the attachments from the Soil / Water / Air Protection Enterprise (SWAPE) letter for a complete technical commentary and analysis. Comments related to potential environmental concerns in the SWAPE letter are responded below in the response to Comments B-25 to B-68. Thus, no further response is required.

B-5 The commenter summarizes existing air quality conditions within the census tract where the Project site is located using data obtained from the California Environmental Protection Agency (CalEnviroScreen 4.0). The commenter also notes that the Project site is located in proximity to several census tracts that are classified by the State of California as "disadvantaged communities" and states that air pollution from the Project represents an environmental justice issue.

Environmental justice is not a topic that is required to be evaluated or considered pursuant to CEQA Guidelines Sections 15120-15132 (Contents of Environmental Impact Reports). In addition, air quality impacts are not required to be assessed based on census tract locations.

Notwithstanding, the air quality analysis contained in the Draft EIR demonstrates that the Project would not expose any sensitive receptor, which includes receptors located in disadvantaged communities, to substantial concentrations of localized criteria pollutants or diesel particulate matter source emissions. To the contrary, the Project would not expose sensitive receptors to substantial pollutant concentrations and impacts would be less than significant (refer to Pages 4.3-42 to 4.3-48 of the Draft EIR).

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B-6 The commenter states that the California Building Energy Code Compliance (CBECC) software is the State's only approved energy compliance software for non-residential buildings in compliance with Title 24. The commenter incorrectly states that Ca1EEMod-based modeling should not have been used to calculate the Project's potential impacts because it does not comply with 2022 Building Energy Efficiency Standards and underreports the Project's energy impacts and fuel consumption.

The Draft EIR and underlying technical studies correctly use Ca1EEMod to estimate energy demand based on average intensity factors for similar land use types based on the Project's site plan provided to the City for entitlement. Since the occupant(s) of the Project's buildings are unknown at this time, and information about the future building user's energy use is also not available at this time, it is appropriate to rely upon the Ca1EEMod default assumptions which have been derived by the California Air Pollution Control Officers Association (CAPCOA) based on survey data. There is no requirement in CEQA to show specific compliance with 2022 Building Energy Efficiency Standards based on conceptual building designs proposed at the entitlement stage of a project's approval process, but such compliance is a standard regulatory requirement. This will be a requirement pursuant to State law prior to issuance of each building permit and verified by the City's Building and Safety Department.

The commenter is correct that CBECC software is approved specifically for Title 24 compliance, which would be required to be used for any development project at the time of its physical building construction, which occurs approximately 12-18 months after entitlement.

The compliance modeling software referenced by the commenter is used to confirm that a final building design, with detailed information included in its construction drawings, is Title 24 compliant. The proposed Project's final designs and construction drawings are not available at this time and are not typically prepared until after a proposed development project is approved/entitled.

B-7 The commenter incorrectly states that the Draft EIR should conclude that the Project would conflict with the goals of the Southern California Association of Governments' (SCAG) Connect SoCal (2020-2045 Regional Transportation Plan/Sustainable Communities Strategy) due to the Project's significant and unavoidable impacts related to air quality, greenhouse gas emissions, noise and transportation (VMT) and provides Goal 5 as an example. The City of Beaumont is identified as one of the priority growth areas for job centers in the region under the Connect SoCal Plan. When growth is concentrated in job centers, the length of vehicle trips for residents can be reduced, thereby reducing greenhouse gas emissions and improving air quality.

In addition, as stated in Section 4.8, Greenhouse Gas Emissions, Tables 4.8-5, 4.8-6, 4.8-7, and Pages 4.8-60 and -61, of the Draft EIR, the Project would not conflict with Connect SoCal Goal 5, Reduce greenhouse gas emissions and improve air quality, because impacts to air quality would be reduced to the maximum extent feasible through the implementation of Mitigation Measures 4.3-1 through 4.3-12 and Project Design Features, which include limiting truck idling, provide incentives for using clean engines and equipment, require installation of conduit for EV truck charging stations, electric indoor material handling equipment and off - road equipment, preferential parking for fuel -efficient and carpool/van vehicles, and EV charging stations.

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Additionally, the Project would incorporate measures related to building design, landscaping, and energy systems to promote the efficient use of energy. The Project would be consistent with the County of Riverside Climate Action Plan (CAP) requirement by achieving 581 points, which is significantly more than the required minimum of 100 points to determine consistency.

Furthermore, as demonstrated in Table 4.8-5 of the Draft EIR, the Project would not conflict with the City's Sustainable Beaumont: The City's Roadmap to Greenhouse Gas Reductions, which serves as a long-term plan to achieve sustainability in the City by reducing GHG emissions from existing and future development. Although the Project would exceed the City's GHG significance threshold of 3,000 MTCO2e per year, all feasible mitigation measures, including PDFs, have been included to reduce GHG impacts. Specifically, Mitigation Measures 4.3-3 through 4.3-13 relating to air quality would also reduce GHG impacts and Mitigation Measure 4.8-1 requires verification that the Project would achieve 581 points from the County CAP Screening Table for GHG Implementation Measures.

Therefore, the Project would not conflict with SCAG's Connect SoCal. Nevertheless, inconsistency with a goal or policy of an applicable plan is not itself an environmental impact.

Therefore, no revisions to the Draft EIR are required.

B-8 The commenter incorrectly states that there is no discussion or analysis regarding the proposed General Plan Amendment (GPA) and Zone Change required for the Project and incomplete consistency analysis of the proposed Project and General Plan goals and policies.

Details regarding the GPA and Zone Change are discussed in Section 3.0, Project Description, of the Draft EIR (refer to Page 3-8), Additionally, the Project's consistency with the City's General Plan and zoning is provided in Section 4.10, Land Use and Planning, of the Draft EIR (refer to Pages 4.11-9 to 4.11-39). As discussed, although the Project would result in a change to the General Plan land use designations for the Project site to allow for implementation of the Specific Plan, these changes would not result in a conflict with applicable plans, policies, or regulations adopted for the purpose of avoiding or reducing an environmental effect.

Moreover, since the Project site is within the City's SOI within unincorporated Riverside County, the City has not adopted any zoning designations for the site. The City's approval and implementation of Pre -Zone PLAN2019-0283 would ensure that the Project would be consistent with the proposed General Plan land use designation and zoning regulations identified in the Specific Plan. Therefore, the Project would be consistent with the City's General Plan and zoning and no revision to the Draft EIR is required.

B-9 The commenter states that the Draft EIR did not provide a consistency analysis for all applicable General Plan goals, policies, and programs. The comment lists a total of 13 goals and policies that should be added to the Draft EIR.

In numerous instances, CEQA case law has held that a project's consistency with a General Plan is not an environmental consideration and does not need to be addressed in a CEQA document (See, e.g., North Coast Rivers Alliance et al. v. Marin Municipal Water District (2013) 216 Cal.App.4th 614, 633; City of Long Beach v. Los Angeles Unified Sch. Dist., (2009) 176 Cal. App. 4th 889, 919). What a CEQA document must address is whether the Project would conflict with the General Plan in such a way that it would result in an environmental effect. In the absence of a planning inconsistency that results in an environmental effect, it is adequate to state that no conflict would occur, which was done in the Draft EIR. Separately, as Lead Agency: City of Beaumont SCH No. 2020099007

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a matter of consistency with City planning documents, the City is required to determine whether the Project is consistent its General Plan, which will be provided in a staff report to the decision makers (Planning Commission and City Council). The commenter does not provide any evidence that the Project would result in an environmental effect due to a conflict with the City's General Plan. Notwithstanding, the reasoning for why each goal and policy was not included are as follows:
• Goal 3.3: A City that preserves its existing residential neighborhoods and promotes development of new housing choices. Policy 3.3.1 Support the development of new housing opportunities, as defined by the Land Use Plan contained in this Element.

As discussed in Section 4.11, Land Use and Planning, of the Draft EIR, the land use regulations for the Project site are currently under the jurisdiction of Riverside County and set forth in the Pass Area Plan with a designation of Rural Mountainous. The Project site is located in the City's Sphere of Influence and is designated in the City's General Plan as Rural Residential 1 (refer to Pages 4.11-2 to 4.11-3). Even though the City's General Plan designates the Project site as residential, the Project site is governed by the County of Riverside General Plan unless the Project site is annexed into the City. Additionally, the Project site has not been zoned or pre -zoned by the City and there is currently no allowed development at the Project site. Without zoning and annexation, the property cannot be determined to have an allowable residential use under City planning and regulation at any level. Therefore, Goal 3.3 and Policy 3.3.1 are not applicable to the Project and no revision to the Draft EIR is required. • Policy 3.3.9: Ensure new development projects and infill construction are of a compatible scale in existing neighborhoods and provide adequate transitions to adjacent residential properties.

Policy 3.4.5: Focus economic development efforts on attracting high paying jobs to the City.

Policies 3.3.9 and 3.4.5 are not applicable to the Project since these policies do not mitigate an environmental effect. Thus, no further response is required. • Policy 3.8.4: Prioritize access to health promoting uses in new development, including neighborhood markets, grocery stores, medical centers, pharmacies, parks, gyms, community space and gardens.

Policy 3.8.4 is not applicable to the Project since these policies do not mitigate an environmental effect. Nevertheless, the Project does propose 30.2 acres of General Commercial uses designed to be a multi -generational, regional destination focusing on entertainment, physical activity and wellness -based retail (refer to Page 3-9 of the Draft EIR), which is consistent with health -promoting uses. The Project does not propose uses including neighborhood markets, grocery stores, medical centers, pharmacies, parks, gyms, community space and gardens. Therefore, no revision to the Draft EIR is required. • Policy 4.1.1: Reduce vehicular congestion on auto priority streets to the greatest extent possible. Policy: 4.1.2 Maintain LOS D on all auto priority streets in Beaumont. LOS E is considered acceptable on non -auto -priority streets.

Automobile delay, as measured by LOS and other similar metrics, no longer constitutes a significant environmental effect under CEQA. Lead agencies in California are required to use Lead Agency: City of Beaumont SCH No. 2020099007

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VMT to evaluate project -related transportation impacts. This statewide mandate went into effect July 1, 2020. CEQA Guidelines Section 15064.3, effective January 1, 2019, "describes specific considerations for evaluating a project's transportation impacts" and provides that, except for roadway capacity projects, "a project's effect on automobile delay (or LOS)" shall not constitute a significant environmental impact" (CEQA Guidelines Section 15064.3(a)).

Moreover, vehicle congestion is not a CEQA issue as it pertains to LOS. Therefore, Policies

4.1.1 and 4.1.2 are not applicable to the Project and no revision to the Draft EIR is required.

Table 1-4 of the Traffic Analysis (Attachment C of this Final EIR) has identified improvements needed to maintain LOS D or better on City streets. As discussed in Section 4.17, Transportation, Table 4.17-1 of the Draft EIR, the Project Applicant would be required to pay TUMF fees, DIF fees, and fair share improvement fees that the City would use to ensure the implementation of roadway improvements in the area in order to minimize traffic congestion.

Additionally, the Project would include the following improvements to accommodate site access and maintain acceptable peak hour operations: install a traffic signal, and construct southbound left turn lane with a minimum of 200 -feet of storage and a right turn lane, an eastbound left turn lane with a minimum of 100 -feet of storage and a through lane, and westbound through lane and a right turn lane with a minimum of 100 -feet of storage at the intersection of Jack Rabbit Trail & 4th Street; construct an eastbound shared left -through lane and stripe the southbound right turn lane at the intersection of Potrero Boulevard and 4th Street; construct 4th Street at its ultimate full -width as a Modified Secondary (78 -foot right-of-way) from the western Project boundary to Jack Rabbit Trail and with a minimum of one lane of travel in each direction from Jack Rabbit Trail to Potrero Boulevard consistent with City standards. Therefore, the Project would not conflict with General Plan Policies 4.1.1 and 4.1.2. • Goal 4.6: An efficient goods movement system that ensures timely deliveries without compromising quality of life, safety, or smooth traffic flow for Beaumont residents.

Goal 4.6 and Policies 4.6.1 and 4.6.2 are included in Table 4.17-1 of the Draft EIR (refer to

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EIR:

Policy 4.6.1: Prioritize goods movement along specific routes in the City, consistent with the adopted layered network, to foster efficient freight logistics. The Project site is situated in close proximity to the regional transportation network which connects the site to the Ports of Long Beach and Los Angeles, both major gateways for international trade, the Inland Empire and the Western United States. Located along the south side of the SR -60 Freeway, access to the regional transportation system from the site is provided via 4th Street through an industrial area to the east. Interim regional access to the Project site is available from the SR -60 Freeway via Western Knolls and Veile Avenue/6th Street interchanges and the I-10 Freeway via the Oak Valley Parkway and Beaumont Avenue interchanges. Once the Potrero Boulevard interchange is constructed, regional access to the Project site would be available from the SR -60 Freeway/Potrero Boulevard and I-10 Freeway/Oak Valley Parkway interchanges. Due to the Project site's proximity to SR -60, trucks accessing the Project site would efficiently reach the State highway system to facilitate the movement of goods throughout the region. In addition, the Project would be consistent with SCAG's Connect SoCal goals, which are described in Lead Agency: City of Beaumont SCH No. 2020099007

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detail in EIR Section 4.11, Land Use and Planning. Based on the foregoing, the Project would not conflict with General Plan Policy 4.6.1.

Policy 4.6.2: Minimize or restrict heavy vehicle traffic near sensitive areas such as schools, parks, and neighborhoods.

The closest sensitive area to the Project site is an existing single-family residence located approximately 483 feet south of the Project site's southernmost boundary. Other residential uses are located north across Frontage Road (1,253 feet) and beyond SR -60. However, the Project would not restrict access to or from the existing residence; the Project would provide private residential access on -site to the existing residence, cars and trucks will not pass by this residence under the proposed roadway plan. Truck trips would be routed through an industrial area to the SR -60 and I-10 and would not pass by sensitive areas. Based on these restrictions, the Project would not conflict with General Plan Policy 4.6.2. • Policy 5.1.4: Encourage growth and expansion of businesses and employment centers near public transit to increase transportation options for employees and limit traffic congestion.

The vicinity of the Project site is served by Pass Transit with bus services along 6th Street, California Avenue, and Beaumont Avenue via Route 3 and Route 4. Riverside Transit Agency (RTA) Route 34 and Route 210 run along SR -60, but do not provide bus service/stops within the Project site vicinity. Currently, the Project site is vacant and there are no existing transit routes that serve the site. Transit service is reviewed and updated by Pass Transit and RTA periodically to address ridership, budget, and community demand needs. Changes in land use can affect these periodic adjustments which may lead to either enhanced or reduced service where appropriate. Therefore, Policy 5.1.4 is not applicable to the Project because the City and transit agencies can make adjustments to transit based on business and employment center locations. The Project does not conflict with this policy and no revision to the Draft EIR is required.
• Goal 6.1: A City that improves the overall health and welfare of its residents.

Goal 6.1 is directive to the City and would not apply to the threshold of whether a Project would cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect.

Therefore, Goal 6.1 is not applicable to the Project and no revision to the Draft EIR is required. • Policy 6.4.1: Ensure convenient access to affordable, fresh produce and healthy foods in all neighborhoods, including grocery stores, farmers 'markets, and community gardens, particularly in communities with low incomes and low access.

Policy 6.4.1 is directive to the City to ensure convenient access to affordable, fresh produce and healthy foods and would not apply to the threshold of whether a Project would cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect. Therefore, Policy

6.4.1 is not applicable to the Project and no revision to the Draft EIR is required.

Lead Agency: City of Beaumont SCH No. 2020099007

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• Policy 6.4.3: Limit fast food and liquor stores in neighborhoods with a significant concentration of stores (e.g., multiple stores on the same block or intersection) and child sensitive areas, such as schools, parks, and childcare facilities.

The Project does not propose uses such fast food and liquor stores and there are no child sensitive areas or a significant concentration of stores within close proximity to the Project site.

Policy 6.4.3 would not apply to the threshold of whether a Project would cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect. Therefore, Policy 6.4.3 is not applicable to the Project and no revision to the Draft EIR is required. • Policy 6.5.5: Promote development of a variety of housing types that meet the needs of residents of all income levels. This policy is implemented through the Land Use and Community Design Element.

The City has not pre -zoned the Project site for residential uses, and the County zoning for the Project site is not relevant to land uses once the site is annexed into the City. The Project does not propose the development of housing. Therefore, Policy 6.5.5 is not applicable to the Project and no revision to the Draft EIR is required.
• Policy 6.5.8: Encourage health promoting uses in new development, including neighborhood markets, grocery stores, pharmacies, parks, gyms, and community gardens.

Policy 6.5.8 is not applicable to the Project since it does not mitigate an environmental effect.

Nevertheless, the Project does propose 30.2 acres of General Commercial uses designed to be a multi -generational, regional destination focusing on entertainment, physical activity and wellness -based retail (refer to Page 3-9 of the Draft EIR), which is consistent with health - promoting uses. The Project does not propose uses including neighborhood markets, grocery stores, medical centers, pharmacies, parks, gyms, community space and gardens. Therefore, no revision to the Draft EIR is required.

B-10 The commenter incorrectly states that the Land Use and Planning analysis of the Draft EIR omits discussion to the 2016 Air Quality Management Plan and Greenhouse Gas Emissions reduction goals for 2030 and 2050. The 2016 Air Quality Management Plan and Greenhouse Gas Emissions reduction goals are discussed in Section 4.3. Air Quality, and Section 4.8, Greenhouse Gas Emissions, of the Draft EIR, respectively.

B-11
The commenter incorrectly states that the Project is inconsistent with SCAG's Connect SoCal Goals 5, 6, and 7 due to the Project's error in modeling and significant and unavoidable impacts related to air quality, greenhouse gas emissions, noise and transportation (VMT). Goal 5 of the SCAG's Connect SoCal is to reduce greenhouse gas emissions and improve air quality. Refer to response to Comment B-7 for the Project's consistency with Goal 5.

Goal 6 of the SCAG's Connect SoCal is to support healthy and equitable communities. As discussed in the Draft EIR under Threshold c in Section 4.2 (starting on Page 4.3-42), (1) the Project's localized construction and operational emissions would not exceed the South Coast AQMD localized significance thresholds; (2) based on the Project -specific mobile source health risk assessment (HRA) (Technical Appendix B2 of the Draft EIR), the Project would not Lead Agency: City of Beaumont SCH No. 2020099007

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result in significant health impacts due to diesel particulate matter (DPM) emissions; and (3) the Project would not cause or contribute to any CO "hot spots". Therefore, the Project is consistent with Goal 6 of the SCAG's Connect SoCal, and no revisions to the Draft EIR are required.

Goal 7 of the SCAG's Connect SoCal is to adapt to a changing climate and support an integrated regional development. As stated in Section 4.10, Land Use and Planning, of the Draft EIR (refer to Pages 4.8-42 and 4.8-43), the Project is consistent with this goal since the Project would develop the Project site that has been historically vacant and undeveloped, with industrial and commercial buildings that would diversify the City's economy and bring employment opportunities closer to the local workforce. Co -locating jobs near housing improves the jobs to housing balance within the City and reduces greenhouse gas emissions caused by long commutes and contributes to integrated development patterns. Moreover, Connect SoCal identifies the City and surrounding area as a center for job growth. Further, the Project site is located adjacent to an area surrounded by industrial development in the City, which is in close proximity to key freeway infrastructure (e.g., I-215, SR -60, I-10, etc.), thereby reducing travel distances. Development of the Project in western Riverside County also would shorten the distance that goods need to travel between a logistics facility to their final destinations ("last mile" transit times). Therefore, the Project is consistent with Goal 7 of the SCAG's Connect SoCal, and no revisions to the Draft EIR are required.

As such, the Draft EIR provided ample information about the Project's impacts for informed decision -making. Last, inconsistency with a goal or policy of an applicable plan is not itself an environmental impact. (See Orinda Ass 'n v. Board of Supervisors (1986) 182 Cal.App.3d 1145.) In this case, the underlying environmental impacts regarding Project consistency with the AQMP and statewide GHG reductions goals are already disclosed in Subsections 4.3, Air Quality, and 4.8, Greenhouse Gas Emissions, of the Draft EIR respectively. Moreover, under the Supreme Court's decision in Center for Biological Diversity v. Cal. Dept. Fish and Wildlife (2015) 62 Ca1.4"' 204, the use of statewide GHG reduction goals as the basis for determining project impacts on the significance of GHG emissions is no longer allowed, and consistency with localized GHG reduction plans or numeric thresholds of significance are identified as the basis for determining the significance of GHG emissions.

B-12 The commenter incorrectly states that the Project is inconsistent with the statutory requirements of the Housing Crisis Act/Senate Bill (SB) 330 and provides a summary of Government Code Section 66300(b)(1)(A). Refer to response to Comment B-13 for a detailed discussion on why the Project is not subject to SB 330. Contrary to the commenter's statement, the Draft EIR does not need to be revised to include a finding of significance. Thus, no further response is required.

B-13 The commenter incorrectly states that the Project would result in a net loss of 383 dwelling units in violation of SB 330 due to land uses changes required to implement the Project. The Project site is not subject to SB 330 since it is currently regulated by Riverside County, outside of the City's jurisdiction. This area of the County is not subject to SB330 as it is outside of the urbanized area. The land use regulations for the Project site are currently under the jurisdiction of Riverside County and set forth in the Pass Area Plan with a designation of Rural Mountainous. Although the Project site is located in the City's sphere of influence, the City Lead Agency: City of Beaumont SCH No. 2020099007

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has no ability to zone the property (it can only prezone) and therefore cannot regulate uses within its sphere of influence.

Even if the City is considered an "affected City" with respect to land in its sphere of influence, residential uses are not an "allowed use" 1 on the Project site due to the following reasons: (1) The Project site has not been zoned or pre -zoned by the City so there is no allowed development by the City at the Project site. Without zoning and annexation, the property cannot be determined to have an allowable use under City planning and regulation at any level. As such, any modification to the general plan of the City would not increase or reduce allowed residential land use. (2) The Project site was not subject to SB 330 as of the benchmark date of January 1, 2018 and therefore should be excluded from the City's analysis.2 Moreover, Government Code Section 66300(0(4) specifically provides that the no net loss provisions of SB 330 do not apply to housing projects in Very High Fire Hazard Severity Zones (VHFHSZ) in local responsibility areas (LRAs).3 Upon annexation into the City (which is a prerequisite to allowing development under the City Code), the Project site will be within the City's LRA and no longer under the state responsibility area (SRA). As shown in Figure 4.20- 3, Fire Hazard Severity Zones, of the Draft EIR, slightly more than half of the Project site is within a VHFHSZ under the SRA. Any housing project constructed in a VHFHSZ would not be subject to the provisions of SB 330. Even if subject to SB 330, units in the portions of the Project site with the Very High Fire Severity designation would be excluded from application of SB 330 and would not need to be accounted for elsewhere. There is a clear presumption in the SB 330 text against construction of housing in VHFHSZ. In light of numerous recent wildfires, the City could determine that construction of housing on the Project site or portions thereof would be inconsistent with State and City public policy with respect to public health and safety.

Based on the preceding analysis, the Project site is not subjected to SB 330 and no revisions to the Draft EIR are required.
1 The no residential loss land use provisions of SB 330, codified at Govt. Code Section 66300, apply "with respect to land where housing is an allowable use" Govt. Code Section 66300(b)(1). 2 Govt Code Section 66300(b) (1) states: "Notwithstanding any other law except as provided in subdivision (i), with respect to land where housing is an allowable use, an affected county or an affected city shall not enact a development policy, standard, or condition that would have any of the following effects:
(A) Changing the general plan land use designation, specific plan land use designation, or zoning of a parcel or parcels of property to a less intensive use or reducing the intensity of land use within an existing general plan land use designation, specific plan land use designation, or zoning district below what was allowed under the land use designation and zoning ordinances of the affected county or affected city, as applicable, as in effect on January 1, 2018, except as otherwise provided in clause (ii) of subparagraph (B). For purposes of this subparagraph, "less intensive use" includes, but is not limited to, reductions to height, density, or floor area ratio, new or increased open space or lot size requirements, or new or increased setback requirements, minimum frontage requirements, or maximum lot coverage limitations, or anything that would lessen the intensity of housing." 3 Govt. Code Section 66300(0(4) states: "This section shall not apply to a housing development project located within a very high fire hazard severity zone. For purposes of this paragraph, "very high fire hazard severity zone" has the same meaning as provided in Section 51177." Section 51177 addresses LRAs.

Lead Agency: City of Beaumont SCH No. 2020099007

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B-14 The commenter incorrectly states that deferring the identification of replacement sites to a later date is project piecemealing in violation of CEQA. As concluded under response to Comment B-13, the Project site is not subjected to SB 330 and, therefore, is not required to identify the replacement of housing sites. Thus, no revisions to the Draft EIR are required.

B-15 The commenter incorrectly states that the projected employment growth from the Project represents a significant amount of growth based on SCAG's projections from 2016-2045. The key question in determining whether a project would result in a significant impact to population and housing is whether the project would induce substantial unplanned population growth in the area.

As discussed in Section 4.14, Population and Housing, the City's December 2020 Updated General Plan contains newer projections than SCAG used. The Updated General Plan forecasted that the City would provide 21,497 jobs within the City limits (exceeding SCAG forecasts) and 16,727 jobs within the Sphere of Influence (SOI), totaling 38,224 jobs within the City and its SOI by 2040. As shown in Table 4.14-4, Estimated Population and Housing Growth in Beaumont with Project, the Project would be within the anticipated business growth projections of the City and would contribute new employment to a housing -rich area, resulting in an improved and balanced job -housing ratio (refer to Page 4.14-9). Therefore, no revisions to the Draft EIR are required.

Furthermore, it is anticipated that the employees would come from within the City or the surrounding region because there is an imbalance of jobs and housing in Western Riverside County and the jobs that an industrial and commercial project in the region is likely to provide would be consistent with the job skills of residents in the area. For example, according to SCAG's Pre -Certified Local Housing Data, Beaumont has 19,385 workers living within its borders who work across 13 major industrial sectors. The most prevalent industry is Education & Social Services with 5,714 employees (29.5% of total) and the second most prevalent industry is Retail trade with 2,593 employees (13.4% of total). Additionally, the Construction industry has 1,071 employees (0.06% of total) and the Manufacturing industry has 1,483 employees (0.08% of total). The Project's employment generation would not induce substantial growth in the area because the Project would result in service -oriented and industrial -oriented jobs, which are jobs that are anticipated to be filled by residents of the City and surrounding area.

According to the Bureau of Labor Statistics (BLS), in August 2021, the Riverside -San Bernardino -Ontario region's civilian labor force exceeded 2,090,800 persons with more than 1,931,500 people employed and an unemployment rate of 7.6% (or 159,300 persons) (BLS, 2021). Accordingly, the Riverside -San Bernardino -Ontario region contains an ample supply of potential employees under existing conditions and the Project's labor demand is not expected to draw a substantial number of new, unplanned residents to the area. Furthermore, approximately 91.1% of Beaumont residents commute outside of the City for work and more housing units are expected to be built within the City over the next 20 years. The Project would provide job opportunities close to home for existing and future Beaumont residents, which would subsequently help achieve a better job -to -housing balance within the City (refer to Page

4.14-8).

Lead Agency: City of Beaumont SCH No. 2020099007

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B-16 The commenter incorrectly states that the Draft EIR needs to be revised to include cumulative development analysis of projects approved since 2016 and projects "in the pipeline" to determine if the proposed project exceeds the General Plan growth estimates and/or SCAG's growth forecasts. As discussed in Section 4.14, Population and Housing, the Project's cumulative analysis includes a list of related projects that were prepared through consultation with planning and engineering staff from the City of Beaumont. As shown in Table 4.14-5, Cumulative Projects Population, Housing, and Employment Growth Trends in Beaumont, the projected population, housing units, and employment growth generated by the Project and related projects would be within the anticipated growth for the City under the City's General Plan growth projections (refer to Page 4.14-11). Additionally, the City's General Plan growth projection, as analyzed in the City's General Plan EIR, assumes buildout of all vacant land within the City and its SOI, which provides a cumulative analysis of the Project in addition to potential projects that will be built in the future. Therefore, the Project would not result in cumulative impacts related to population and housing and no revisions to the Draft EIR are required.

B-17 The commenter states that the EIR provides uncertain language by stating "91% of Beaumont residents commute outside of the City for work and more housing units are expected to be built within the City over the next 20 years," without providing specific information regarding the type of employment commuter residents qualify for or the quantity of housing units that are in development. The statement is from the Beaumont General Plan 2040 Program Draft EIR, Section 5.13, Population and Housing. Pursuant to the commenter's request, this citation has been added to Page 4.14-4 of the Draft EIR.

Additionally, the commenter incorrectly states that (1) the EIR relies upon the entire unemployed workforce of the metropolitan Riverside -San Bernardino Ontario region to fill the project's jobs and (2) relying upon the entire workforce population of the metropolitan Riverside -San Bernardino -Ontario region would increase VMT per employee and GHG emissions due to longer worker trip distances.

The commenter is conflating the Draft EIRs description of the availability of workforce in the area for purposes evaluating impacts to population and housing with worker commute VMT distances. As shown on Pages 4.14-8 through 4.18-9 of the Draft EIR, there is an ample supply of available workers within the City and the immediately surrounding area, and the Project would be within the anticipated growth projections contributing to an improved jobs -housing ratio.

The commenter does not present evidence to suggest that the VMT analysis (Technical Appendix K2 to the Draft EIR) which relies on the Riverside County Travel Demand Model inaccurately accounts for commute trips. The Riverside County Travel Demand Model is based on socio-economic data and considers the interaction of population, households, and employment between different land uses. Additionally, the City's required VMT metric of VMT per service population uses origin -destination methodology for all trips by all trip purposes, not only commute trips by employees only. Therefore, no revisions to the Draft EIR are required.

Lead Agency: City of Beaumont SCH No. 2020099007

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B-18 The commenter states that the Draft EIR has not provided any exhibits depicting the available truck/trailer turning radius at the intersection of the project driveways to determine if there is enough space available to accommodate heavy truck maneuvering and emergency access vehicles. As part of the EIR process, projects are required to comply with all design standards.

These include roadway street sections, ADA requirements, driveway standards, truck turns and emergency vehicle access requirements to name a few. Since the final site plan and buildings for each parcel are not determined at this stage, detailed truck turns will be prepared during the entitlement of each parcel to ensure final design meets all City requirements. All roadway striping, driveway design and location, ADA access, on-site/off-site truck turns and emergency vehicle access and turning movements will be developed to ensure all design elements result in a safe final design for each parcel and public roadways and will comply with applicable requirements. Therefore, no revisions to the Draft EIR are required.

Furthermore, the Beaumont Pointe Specific Plan, Section 4.4, Supplemental Guidelines for Industrial Uses, sets forth additional guidelines to address the design of building sites and considerations unique to all permitted uses within the Industrial land uses. Specifically, Section

4.4(3) states:

Site design shall specifically address the needs ofpick-up, delivery, and service vehicles related to Industrial.
a. Design interior driveways and drive aisles to provide adequate stacking and prevent queuing of vehicles on public streets.
b. Locate and design service entrances so they do not interfere with owner/tenant/customer access.
c. Design loading areas to provide for tractor trailer backing and maneuvering on -site and not from a public street.
d. Provide appropriate on -site service vehicle parking/turnouts in an efficient, non -obtrusive location appropriate to the scale and needs of the development. e. Vehicle loading/unloading when parked, shall not impede normal traffic flow.

With the requirements of the Specific Plan, future development with be required to provide adequate vehicle access, turning movements, and queuing.

B-19 The commenter states that the Draft EIR has underreported the quantity VMT generated by Project operations by excluding the Project's truck/trailer/delivery van activity. The Project's VMT analysis (Technical Appendix K2 to the Draft EIR) was developed based on the City of Beaumont's adopted Resolution No. 2020-20 "Vehicle Miles Traveled" Thresholds of Significance for Purposes of Analyzing Transportation Impacts under the California Environmental Quality Act (June 16, 2020) (City Guidelines), which was developed based on OPR's Technical Advisory on Evaluation Transportation Impacts in CEQA (OPR, December 2018). The City Guidelines require analyses to use methodology that include all trips by all trip purposes (i.e., passenger cars, delivery vans, and trucks). The VMT analysis has quantified all of the Project's truck/trailer and delivery van activity.

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The OPR Technical Advisory was prepared to assist lead agencies in compliance with SB 743's new framework. As an initial point, CEQA Guidelines Section 15064.3(a) defines VMT as "the amount and distance of automobile travel attributable to a project." CEQA Guidelines Section 15064.3(a) focusses on "automobile travel." The OPR Technical Advisory states that "automobile" refers to on -road passenger vehicles, specifically cars and light trucks. It does not include heavy-duty trucks, semi -trailers, construction equipment, or other commercial -type vehicles. Therefore, the Project Heavy Truck VMT was presented in Table 3 of the VMT analysis (Technical Appendix K2 of the Draft EIR) to identify and disclose any heavy -truck activity related project VMT. However, this was prepared for information purposes to disclose VMT of heavy trucks.

The issue is best concisely summarized by the County of Santa Barbara: "As a result, the VMT criteria and thresholds in the CEQA Guidelines and this chapter related to employment generating uses do not apply to those components of proposed projects that involve commercial vehicles. However, the VMT criteria and thresholds would apply to those components that involve passenger vehicles. For example, a proposed oil production or agricultural processing facility may involve significant numbers of commercial trucks and semi -trailers that would haul supplies and products to and from the facility. The project may also involve employees and others who would travel to and from the facility in passenger vehicles. In this case, the VMT analysis would not address potential VMT generated by the commercial trucks and semi- trailers and, therefore, would not consider such VMT a significant transportation impact.

Rather, the VMT analysis would focus on VMT generated by passenger vehicles traveling to and from the facility."4
As confirmed by other lead agencies, "OPR has clarified in the Technical Advisory and recent informational presentations that heavy-duty truck VMT is not required to be included in the estimation of a project's VMT."5; see also "[a]s such, VMT analysis of truck trips is not a prescribed method to assess [a]projects' transportation impacts under CEQA."6 OPR Guidance focuses on the reduction of automobile (i.e., cars and light duty trucks) to address CARB's GHG emission reduction targets from cars and light duty trucks. CEQA Guidelines section 15064.3 limits VMT to "automobile travel." The OPR Guidance states that "the term 'automobile' travel refers to on road passenger vehicles, specifically cars and light trucks." The potential mitigation measures proposed by OPR indicate that VMT analyzes mileage for commuting to jobs. The OPR Technical Advisory lists a whole host of "potential measures to reduce vehicle miles traveled." None of them refer to measures which could reduce vehicle miles of a heavy-duty truck (and are all focused on employee trips), as follows:
• Improve or increase access to transit.
4http: //www. countyofsb. org/uploadedFiles/pindev/Content/Projects/FINAL%20Ch. %2018 %20Environmental%20T hresholds%20Update.pdf
S https://www . sandiegocounty. gov/content/dam/sdc/pds/cega/JVR/DEIR/Chapters/JVR%20DEIR%203.1.7%20Tran sportation.pdf
6 https://www.longbeach.gov/globalassets/city-manager/media-library/documents/memos-to-the-mayor-tabbed-file- list-folders/2020/june-3 0--2020---vehicle-miles-traveled--vmt--standards-for-development-review Lead Agency: City of Beaumont SCH No. 2020099007

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Increase access to common goods and services, such as groceries, schools, and daycare.

Incorporate affordable housing into the project.

Incorporate neighborhood electric vehicle network.

Orient the project toward transit, bicycle and pedestrian facilities.

Improve pedestrian or bicycle networks, or transit service.

Provide traffic calming.

Provide bicycle parking.

Limit or eliminate parking supply.

Unbundle parking costs.

Provide parking cash -out programs.

Implement roadway pricing.

Implement or provide access to a commute reduction program.

Provide car -sharing, bike sharing, and ride -sharing programs.

Provide transit passes.

Shifting single occupancy vehicle trips to carpooling or vanpooling, for example providing ride -matching services.

Providing telework options.

Providing incentives or subsidies that increase the use of modes other than single occupancy vehicle.

Providing on -site amenities at places of work, such as priority parking for carpools and vanpools, secure bike parking, and showers and locker rooms.

Providing employee transportation coordinators at employment sites.

Providing a guaranteed ride home service to users of non -auto modes.

Nonetheless, heavy -truck trips have been calculated within the traffic study for modeling convenience and in order to account for other potential environmental impacts related to trucks/goods movement, such as air quality and GHG emissions and noise, which have been considered and analyzed throughout the Draft EIR, specifically Sections 4.3, Air Quality, 4.8, Lead Agency: City of Beaumont SCH No. 2020099007

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Greenhouse Gas Emissions, and 4.13, Noise. Therefore, no revisions to the Draft EIR are required.

B-20 The commenter incorrectly states that Section 5.0 of the Draft EIR did not include a finding of significance due to the Project's significant and unavoidable cumulatively considerable air quality, greenhouse gas emissions, noise, and transportation impacts and direct contribution to climate change. Refer to response to Comment B-6 for the discussion regarding Title 24 modeling software. Contrary to the commenter's assertion, Section 5.1 of the Draft EIR discloses the Project's significant environmental effects related to air quality, greenhouse gas emissions, noise, and transportation (refer to Pages 5-1 to 5-4). Additionally, details of the Project's required changes in land use designations (General Plan Amendment, Annexation, Prezone) are discussed throughout the Draft EIR (refer to Pages 3-8, 4.11-9, and 4.11-39).

Therefore, no revisions to the Draft EIR are required.

B-21 The commenter incorrectly states that the Draft EIR does not adequately discuss or and analyze the commitment of resources and is not consistent with regional and local growth forecasts.

Refer to response to Comments B-15 and B-16 for a detailed discussion on the Project's cumulative analysis and its consistency with regional and local growth forecasts. Additionally, cumulative analysis related to each environmental topic is provided within each section of the Draft EIR. Therefore, no revisions to the Draft EIR are required.

B-22 The commenter incorrectly states that the Draft EIR does not meaningfully discuss or analyze the Project's required land use designation changes (General Plan Amendment, Annexation, Prezone) from residential to industrial and commercial in the discussion of growth inducing impacts. As discussed in Section 5.0, Other CEQA Considerations, of the Draft EIR, the Project's required land use designation changes are limited to the Project site's boundaries and do not include any components that would indirectly affect existing or planned uses on neighboring properties. The development of the proposed commercial, industrial, and open space uses on the Project site would not reasonably or foreseeably cause the redevelopment of other properties or cause development on other properties. Infrastructure additions are limited to those needed for the Project or already planned, and the Project would not result in the need to expand any public services to maintain levels of service. Moreover, operation and maintenance of the Project would generate jobs, but any potential growth -inducing impact of the employment of persons at the Project site was accounted for in the City's General Plan, as the Project's proposed 5,456 total jobs represent approximately 33% of the anticipated jobs within the City's SOI and approximately 14% of the City's total job pool. These jobs were within the City's growth forecast and will contribute to an improved job -housing ratio.

Accordingly, the Project would not directly promote growth either at the Project site, at the adjacent and surrounding properties, or within the City that were not accounted for in the City's General Plan. Therefore, no revisions to the Draft EIR are required.

B-23 The commenter incorrectly states that the Draft EIR has not provided an adequate or accurate cumulative analysis discussion to demonstrate the impact of the Project in a cumulative setting.

Refer to response to Comment B-16 for a detailed discussion of the Project's cumulative analysis and its consistency with the City's General Plan growth projections.

Lead Agency: City of Beaumont SCH No. 2020099007

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B-24 This comment provides conclusionary remarks. The City acknowledges the statement of interest and will include GSEJA on the mailing list for future CEQA notices related to the Project. No further response is required.

B-25 The commenter summarizes the Project description and incorrectly claims that the Draft EIR's air quality, health risk, and greenhouse gas impacts are underestimated and request preparation of an updated EIR based on subsequent comments. This is a summary of the detailed comments provided in the body of the commenter letter, which are responded to the in following responses to Comments B-26 through B-68. Thus, no further response is required.

B-26 The commenter correctly summarizes sections of the Draft EIR related to construction and operational air quality impacts. This comment does not raise any issues concerning or relating to the adequacy of the environmental analysis provided in the Draft EIR and thus no further response is required.

B-27 The commenter states that the Draft EIR fails to implement all feasible mitigations based on the subsequent comments and that Project's conclusion that air quality impacts would be significant -and -unavoidable is unsubstantiated. In addition, the commenter relies on CEQA Guidelines Section 15096 which applies to responsible agencies and is inapplicable. Refer to response to Comments B-34 to B-63 for a detailed discussion of the suggested mitigation measures. Thus, no further response is required.

B-28 The commenter further refers to the list of additional feasible mitigation measures provided in the subsequent portion of the letter. Refer to response to Comments B-34 to B-63 for a detailed discussion on the suggested mitigation measures. Thus, no further response is required.

B-29 The commenter correctly summarizes the Project's health risk impacts and that these impacts would not exceed the South Coast AQMD significance threshold of 10 in one million and would be less than significant. This comment does not raise any issues concerning or relating to the adequacy of the environmental analysis provided in the Draft EIR and thus no further response is required.

B-30 In response to the first issue raised in this comment asserting that the fraction of time at home (FAH) values relied upon by the Draft EIR's Health Risk Assessment (HRA) are inconsistent with those recommended by the South Coast AQMD. South Coast AQMD recommends using Office Of Environmental Health Hazard Assessment (OEHHA) guidance. The HRA followed South Coast AQMD-approved and OEHHA Air Toxics Hot Spots Program Risk Assessment Guidelines: Guidance Manual for Preparation of Health Risk Assessments (February 2015).' The time at home factors used in the assessment are consistent with OEHHA-recommended factors and, therefore, follow South Coast AQMD recommended guidance.

B-31 The commenter incorrectly states that Age Sensitivity Factors (ASF) were omitted from the analysis. As noted on Page 20 of Technical Appendix B2, of the Draft EIR, and illustrated on Tables 2-4 through 2-6, the "Age Specific Factor" is clearly identified. Furthermore, the Risk Calculations contained in Appendix 2.4 of the Health Risk Assessment (Technical Appendix B2, of the Draft EIR), shows the quantification of carcinogenic risk and noncarcinogenic ' https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf Lead Agency: City of Beaumont SCH No. 2020099007

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hazards based on each ASF scenario. As shown, the ASFs were appropriately included in the analysis. The analysis uses the same equation proposed by the commenter; however, a simplified version of this formula is presented in the Health Risk Assessment (refer to Section

2.5 of Technical Appendix B2 of the Draft EIR).

B-32 The commenter summarizes the Project's greenhouse gas emissions conclusion, restating data presented in the Draft EIR that the Project would exceed the City's threshold of 3,000 MT CO2e/year. This comment does not raise any issues concerning or relating to the adequacy of the environmental analysis provided in the Draft EIR and thus no further response is required.

B-33 The commenter relies on CEQA Guidelines section 15096 which applies to responsible agencies and is inapplicable. The commenter states that the Draft EIR fails to implement all feasible mitigations based on the subsequent comments and that Project's conclusion that greenhouse emissions would be significant -and -unavoidable is unsubstantiated. The commenter further refers to the list of additional feasible mitigation measures provided in the subsequent portion of the letter. Refer to responses to Comments B-34 to B-63 for a detailed discussion of the suggested mitigation measures. In addition, the commenter assumes, without support, that implementation of its suggested mitigation measures would result in less than significant GHG emissions. No further response is required.

B-34 The commenter recommends consideration of measures (identified below) found in the Department of Justice Warehouse Project Best Practices document be included in the Draft EIR. The commenter requests prohibition of off -road diesel -powered equipment from being in the "on" position for more than 10 hours per day. Mitigation Measure MM 4.3-2 in the Draft EIR requires that all 50 -horsepower or greater diesel -powered equipment shall comply with Environmental Protection Agency (EPA)/California Air Resources Board (CARB) Tier 4 off - road emissions standards or equivalent. Tier 4 compliant engines significantly reduce emissions of particulate matter (PM) and oxides of nitrogen (NOx) to near zero levels.

Furthermore, construction activities are only permitted between the hours of 7:00 a.m. and 6:00 p.m. In addition, construction workers take time off for lunch and breaks. Thus, the City determines that additional mitigation is not warranted.

B-35 The commenter requests designation of an area in the construction site where electric -powered construction vehicles and equipment can charge. Pursuant to the commenter's request the following mitigation measure has been added to Page 4.3-54 of the Draft EIR. The mitigation measure further supports the conclusions in the Draft EIR and is not evidence of a new or greater impact not previously disclosed.

MM 4.3-13
Plans submitted for grading permit issuance and building permit issuance shall specify a designated area of the construction site where electric or non -diesel vehicles, equipment, and tools can be fueled or charged. The provision of temporary electric infrastructure for such purpose shall be approved by the utility provider, Southern California Edison (SCE). If SCE will not approve the installation of temporary power for this purpose, the establishment of a temporary electric charging area will not be required. If electric equipment will not be used on the construction site because the construction contractor(s) does not have such equipment in its fleet (as specified in Mitigation Measure MM

4.3-14), the establishment of a temporary electric charging area also will not Lead Agency: City of Beaumont SCH No. 2020099007

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be required. If electric powered equipment is in the contractor(s) equipment fleet, and SCE approval is secured, the temporary charging location is required to be established upon issuance of grading permits and building permits.

MM 4.3-14
If electric or non -diesel off -road trucks and construction support equipment, including but not limited to hand tools, forklifts, aerial lifts, materials lifts, hoists, pressure washers, plate compactors, and air compressors are available in the construction contractor's equipment fleet and can fulfill the Project's construction requirements during the building construction, paving, and architectural coating phases of Project construction, such equipment shall be used during Project construction. This requirement shall be noted on plans submitted for building permit issuance.

B-36 The commenter requests mitigation to limit the amount of daily grading disturbance area but does not provide an exact quantity. The construction analysis included extremely conservative assumptions on the amount of acres that could be actively graded per day to provide a worst case analysis of air quality impacts. Specifically, grading activities assumed 60 acres per day could be actively disturbed during grading for Phase 1, 33 acres for Phase 2, and 25 acres for Phase 3. Additionally, limiting the amount of grading per day will not change the overall amount of grading required for the Project, which would result in the same overall impact.

Therefore, the Draft EIR made reasonable assumptions based on equipment and schedule and disclosed the maximum emissions per day, therefore, no further mitigation is required.

B-37 The commenter requests mitigation to prohibit grading on days with an Air Quality Index forecast of greater than 100 for particulates or ozone for the project area.

Table 4.3-9, Localized Significant Summary - Construction, of the Draft EIR, identifies the localized impacts at the nearest receptor location in the vicinity of the Project. For analytical purposes, emissions associated with peak grading activities are considered for purposes of LSTs since these phases represents the maximum localized emissions that would occur. Any other construction phases of development that overlap would result in lesser emissions and consequently lesser impacts than what is disclosed herein. As shown, Project -related construction emissions would not exceed the applicable South Coast AQMD LSTs for CO, NOX, PM10, or PM2.5 at the maximally impacted receptor location. All other modeled locations in the study area would experience a lesser concentration and consequently a lesser impact. Accordingly, construction of the Project would not result in the exposure of any sensitive receptors to substantial pollutant concentrations. Therefore, localized emissions from construction of the Project would result in less than significant impacts.

Furthermore, the land use with the greatest potential exposure to Project construction DPM source emissions is Location R4, which represents the existing residence at 14157 Bosana Lane, approximately 1,151 feet north of the Project site. At this location, the maximum incremental cancer risk attributable to Project DPM source emissions is estimated at 0.47 in one million, which is less than the South Coast AQMD's significance threshold of 10 in one million. At this same location, non -cancer health risks were estimated to be < 0.01, which would not exceed the applicable threshold of 1.0. As such, the Project would not cause a significant human health or cancer risk to people in adjacent land uses as a result of Project construction activity. All other receptors during construction activity (even if they are located Lead Agency: City of Beaumont SCH No. 2020099007

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at a nearer distance to the site) would experience less risk than what is identified for the maximally exposed individual receptor due to modeled meteorological conditions, source locations, and relative spatial distance from emission sources to other receptor locations (refer to Pages 4.3-42 to 4.3-43 of the Draft EIR).

Lastly, with respect to the request to limit activities if the Air Quality Index (AQI) exceeds 100, it should be noted that pursuant to EPA documentation,8 an AQI of over 100 is generally correlated when the ambient air quality standards are exceeded. Further, AQI is monitored at a regional level and not necessarily representative of local conditions that would occur adjacent to the Project site — which is important for determining local construction impacts. As noted above, the Project does not exceed any of the applicable ambient air quality standards during construction activity as evidenced by the modeling conducted in support of the LST analysis.

Because the Project would not result in a significant health risk to sensitive receptors during construction, there is no need to limit grading activities. Thus, the City determines that additional mitigation is not warranted.

B-38 The commenter requests mitigation to forbid idling of heavy equipment for more than three minutes. As discussed in Section 4.6, Energy, of the Draft EIR, CCR Title 13, Title 13, Motor Vehicles, Section 2449(d)(3) Idling, limits idling times of construction vehicles to no more than 5 minutes, thereby precluding unnecessary and wasteful consumption of fuel due to unproductive idling of construction equipment or potential additional pollutants generated by starting equipment as opposed to idling. Best Available Control Measure (BACMs) inform construction equipment operators of this requirement. Enforcement of idling limitations is realized through periodic site inspections conducted by City building officials, and/or in response to citizen complaints (refer to Page 4.6-25 of the Draft EIR). However, pursuant to the commenter's request PDF 8-5 and MM 4.3-4 has been modified to reduce idling time from five minutes to three minutes, as shown below. The revised PDF and mitigation measure further support the conclusions in the Draft EIR and are not evidence of a new or greater impact not previously disclosed.

PDF 8-5
MM 4.3-4
Tenant lease agreements for the Project shall include contractual language restricting trucks and support equipment from nonessential idling longer than 3 5 minutes while on site in exceedance of the City of Beaumont Idling Ordinance.

Legible, durable, weather-proof signs shall be placed at truck access gates, loading docks, and truck parking areas that identify applicable CARB anti - idling regulations. At a minimum, each sign shall include: 1) instructions for truck drivers to shut off engines when not in use; 2) instructions for drivers of diesel trucks to restrict idling to no more than three (3) five (5) minutes once the vehicle is stopped, the transmission is set to "neutral" or "park," and the parking brake is engaged; and 3) telephone numbers of the building facilities manager and the CARB to report violations. Prior to the issuance of an $ https://www.airnow.gov/sites/default/files/2020-05/aqi-technical-assistance-document-sept2018.pdf Lead Agency: City of Beaumont SCH No. 2020099007

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Beaumont City CouncilJune 4, 2024

Beaumont City Council
June 4, 2024