Cities Index.
Agenda packet

Industry City Council
February 12, 2026

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Agenda packet
Meeting
February 12, 2026
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Industry City Council
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6,633
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Text extracted from the city's file for reading and search. Open the original on industryca.api.civicclerk.com. That file is the official record.

MARICI BATTERY ENERGY STORAGE SYSTEM FACILITY INITIAL STUDY / MITIGATED

NEGATIVE DECLARATION

CITY OF INDUSTRY

TABLE OF CONTENTS
DECEMBER 2025 i

TABLE OF CONTENTS
Environmental Checklist ........................................................................................................ 1 Project Information............................................................................................................. 1 Environmental Factors Potentially Affected........................................................................ 2 Determination..................................................................................................................... 3

1. Introduction............................................................................................................... 5

1.1 Overview ................................................................................................................. 5

1.2 California Environmental Quality Act...................................................................... 6

1.3 Initial Study ............................................................................................................. 7

1.4 Mitigated Negative Declaration .............................................................................. 7

1.5 Levels of Significance .............................................................................................. 8

2. Project Description..................................................................................................... 9

2.1 Project Location ...................................................................................................... 9

2.2 Environmental Setting............................................................................................. 9

2.3 Project Characteristics .......................................................................................... 17 Transmission.......................................................................................................... 34 Substation ............................................................................................................. 39 Communications................................................................................................... 39

2.4 Required Permits and Approvals........................................................................... 44

3. Environmental Evaluation......................................................................................... 47 I. Aesthetics....................................................................................................................... 47 II. Agriculture and Forestry Resources.............................................................................. 53 III. Air Quality .................................................................................................................... 56 IV. Biological Resources..................................................................................................... 65 V. Cultural Resources......................................................................................................... 69 VI. Energy .......................................................................................................................... 73 VII. Geology and Soils........................................................................................................ 77 VIII. Greenhouse Gas Emissions........................................................................................ 86 IX. Hazards and Hazardous Materials ............................................................................... 89 X. Hydrology and Water Quality...................................................................................... 125 XI. Land Use and Planning............................................................................................... 140 XII. Mineral Resources..................................................................................................... 142 XIII. Noise ........................................................................................................................ 143 XIV. Population and Housing........................................................................................... 158 XV. Public Services........................................................................................................... 159 XVI. Recreation................................................................................................................ 163

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XVII. Transportation ........................................................................................................ 164 XVIII. Tribal Cultural Resources....................................................................................... 170 XIX. Utilities and Service Systems ................................................................................... 174 XX. Wildfire ..................................................................................................................... 179 XXI. Mandatory Findings of Significance......................................................................... 182

4. References ..............................................................................................................185

5. List of Preparers ......................................................................................................189 Lead Agency .................................................................................................................... 189 PlaceWorks...................................................................................................................... 189 Appendices
Appendix A Air Quality and Greenhouse Gas Emissions Report Appendix B Construction Health Risk Assessment
Appendix C Biological Resources Assessment
Appendix D Geotechnical Engineering Report, Terracon, December 2023 Appendix E Revised Geotechnical Engineering Report
Appendix F Phase I ESA – 16207 and 16209 Gale Avenue
Appendix G Phase I ESA – 16233 and 16235 Gale Avenue
Appendix H Phase I ESA – 16253 and 16293 Gale Avenue
Appendix I Limited Site Investigation – 16207 and 16209 Gale Avenue Appendix J Limited Site Investigation – 16233 and 16235 Gale Avenue Appendix K Revised Soil and Groundwater Management Plan Appendix L Hazardous Materials and Safety Memorandum
Appendix M Plume Study
Appendix N EMF Study
Appendix O Emergency Air Toxics Analysis
Appendix P Hydrology Study and Stormwater Quality Management Plan Appendix Q Sound Impact Assessment
Appendix R Transportation Study

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List of Figures
Figure Page
Figure 1 Regional Location.................................................................................................. 11 Figure 2 Local Vicinity ......................................................................................................... 13 Figure 3 Aerial Photograph................................................................................................. 15 Figure 4a Proposed Site Layout ............................................................................................ 19 Figure 4b Proposed Site Layout ............................................................................................ 21 Figure 5 Electrical System Details....................................................................................... 25 Figure 6 Substation Elevations............................................................................................ 29 Figure 7 Tie-Line Pole Details.............................................................................................. 31 Figure 8 Landscaping Plan................................................................................................... 35 Figure 9 Building Elevations and Colors.............................................................................. 37 Figure 10 Proposed Drainage Area Maps........................................................................... 133 Figure 11 Noise Measurement Locations........................................................................... 149 Figure 12 Noise Generating Project Features..................................................................... 155 List of Tables
Table Page
Table 1 Maximum Daily Regional Construction Emissions................................................ 59 Table 2 Localized Construction Emissions......................................................................... 61 Table 3 Construction Risk Summary.................................................................................. 62 Table 4 Chemical Thresholds During Battery Failure ...................................................... 107 Table 5 Toxicity Level for CO ........................................................................................... 110 Table 6 Emergency Air Toxics Analysis Results – Maximum Exposed Individual Resident ............................................................................................ 114 Table 7 Phase I ESAs and LSIs Governmental Databases Summary ................................ 117 Table 8 Water Quality Protection Construction Best Management Practices................ 128 Table 9 50-year Storm Peak Flow Summary.................................................................... 138 Table 10 Los Angeles County Noise Control Ordinance Standards................................... 145 Table 11 Vibration Damage Criteria .................................................................................. 146 Table 12 Closest Noise-Sensitive Receptors...................................................................... 147

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Table 13 Project Construction Noise Level Increases........................................................ 151 Table 14 Construction Noise Levels by Construction Activity ........................................... 151 Table 15 Noise Source Inputs............................................................................................ 153 Table 16 Operational Noise Levels at Receptor Locations................................................ 154 .

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DECEMBER 2025 1

ENVIRONMENTAL CHECKLIST

PROJECT INFORMATION
Project Title: Marici Battery Energy Storage System Facility Lead Agency Name and Address:

City of Industry
15625 Mayor Dave Way
Industry, California 91744
Contact Person and Phone Number:

Eduardo Manriquez, Contract Senior Planner
Mike Poland, Contract Senior Project Manager
626.333.2211
Project Location: The project site has addresses of 16233, 16207, and 16253 Gale Avenue, located on the north side of Gale Avenue immediately north of its intersection with Hinnen Avenue. It is comprised of Assessor’s Parcel Numbers 8242-016-033, -034, -036, -044, and -061.

Project Sponsor’s Name and Address:

Marici Project LLC
11801 Domain Boulevard, Suite 450
Austin, TX 78758
General Plan Designation: Employment
Zoning: Industrial
Description of Project: The proposed project includes redevelopment of the 9.2-acre project site and minor improvements to SCE Walnut Substation that abuts the project site. The proposed project includes the construction and operation of an approximately 400-megawatt battery energy storage system (BESS) facility and associated site and infrastructure improvements on the project site. Development of the BESS facility requires demolition of all existing buildings, structures, hardscapes, and minimal landscaping on-site. The minor improvements to the SCE Walnut Substation will help interconnect and transfer power between the proposed BESS facility and SCE Walnut Substation. At the end of the proposed project’s operational term, which is

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anticipated to be 35 years, the project applicant may determine that the BESS facility could be decommissioned and deconstructed, or it may seek an extension of its use permit.

Surrounding Land Uses and Setting: The project site is bound by Gale Avenue and residential uses to the south, Ward Way and warehouses and commercial properties to the west, Union Pacific Railroad/Metro rail lines and a rail yard to the north, and the Southern California Edison Walnut Substation to the east.

Other Public Agencies Whose Approval Is Required (e.g., Permits, Financing Approval, or Participating Agreement):

Los Angeles County Fire Department
Southern California Edison
Have California Native American tribes traditionally and culturally affiliated with the project area requested consultation pursuant to Public Resources Code Section 21080.3.1? If so, is there a plan for consultation that includes, for example, the determination of significance of impacts to tribal cultural resources, procedures regarding confidentiality, etc.? The City of Industry prepared letters addressed to each Native American Tribe provided on the City’s list of tribes to be contacted for tribal consultation. Outreach letters were sent to tribal representatives initiating consultation with tribes pursuant to Assembly Bill (AB) 52.

ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED
The environmental factors checked below would be potentially affected by this project, involving at least one impact that is a “Potentially Significant Impact,” as indicated by the checklist on the following pages.

Aesthetics Agriculture / Forestry
Resources
Air Quality
Biological Resources Cultural Resources Energy
Geology / Soils Greenhouse Gas
Emissions
Hazards and Hazardous
Materials
Hydrology / Water
Quality
Land Use / Planning Mineral Resources
Noise Population / Housing Public Services
Recreation Transportation Tribal Cultural Resources
Utilities / Service Systems Wildfire Mandatory Findings of Significance

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DETERMINATION
On the basis of this initial evaluation:

I find that the proposed project COULD NOT have a significant effect on the environment, and a NEGATIVE DECLARATION will be prepared.

I find that although the proposed project could have a significant effect on the environment, there will not be a significant effect in this case because revisions in the project have been made by or agreed to by the project proponent. A MITIGATED NEGATIVE DECLARATION will be prepared.

I find that the proposed project MAY have a significant effect on the environment, and an ENVIRONMENTAL IMPACT REPORT is required.

I find that the proposed project MAY have a "potentially significant impact" or "potentially significant unless mitigated" impact on the environment, but at least one effect 1) has been adequately analyzed in an earlier document pursuant to applicable legal standards, and 2) has been addressed by mitigation measures based on the earlier analysis as described on attached sheets. An ENVIRONMENTAL IMPACT REPORT is required, but it must analyze only the effects that remain to be addressed.

I find that although the proposed project could have a significant effect on the environment, because all potentially significant effects (a) have been analyzed adequately in an earlier EIR or NEGATIVE DECLARATION pursuant to applicable standards, and (b) have been avoided or mitigated pursuant to that earlier EIR or NEGATIVE DECLARATION, including revisions or mitigation measures that are imposed upon the proposed project, nothing further is required.

Signature Date

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DECEMBER 2025 5

1. INTRODUCTION

1.1 OVERVIEW
The proposed project includes redevelopment of the 9.2-acre site and minor improvements to SCE Walnut Substation that abuts the project site. The proposed project includes the construction and operation of an approximately 400-megawatt battery energy storage system (BESS) facility and associated site and infrastructure improvements. Development of the BESS facility requires demolition of all existing buildings, structures, hardscapes, and minimal landscaping on-site. The minor improvements to the SCE Walnut Substation will help interconnect and transfer power between the proposed BESS facility and SCE Walnut Substation.

The proposed project is an electric energy storage facility that will utilize lithium-ion batteries and ancillary equipment to store energy received from the regional electric grid to then be returned to the grid when needed. Battery energy storage is a key component of federal, state and local planning to strengthen electric grid reliability, and reduce the emission of greenhouse gasses. The proposed project will help to accomplish these goals by providing capacity to store energy when there is excess generation capacity such as from intermittent renewable sources like wind and sunlight, and then allowing that energy to be used when needed thereby reducing dependence on fossil fuel generation sources.

Project battery modules will be housed in purpose-built enclosures. Inverters and transformers will convert between low-voltage direct current (DC) conveyed in and out of the batteries and the regional electric grid's high-voltage alternating current (AC). The rapid response batteries can be utilized to stabilize rapid changes in electric power demand, which reinforces grid stability. The proposed project will include an onsite substation and an overhead 220 kV electric line across the eastern site boundary into the adjacent Southern California Edison (SCE) Walnut Substation.

Additional ancillary features include auxiliary equipment pads with transformers and control equipment, paved access and fire lane, fire hydrant system, stormwater drainage controls, a 10- foot-high perimeter wall designed to City and fire department requirements, landscaping, and a storage building and containers for spare parts and equipment.

Development of the BESS facility requires demolition of all existing buildings, structures, hardscapes, and minimal landscaping on-site. Also, SCE identified a need for various modifications and improvements to the Walnut Substation to accommodate and support the proposed project’s interconnection. Project development requires City adoption of a Mitigated Negative Declaration and Mitigation Monitoring and Reporting Program, approval of a Zone Code text amendment (Zone Amendment No. 24-07) to allow the use with a CUP, approval of a Conditional Use Permit

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(CUP No. 24-03), approval of Development Plan Application – Long Form Development Plan No. 24-09 (DP-24-09), approval of a Community Benefit Agreement (CBA No. 25-01), and approval of a ROW Agreement (street improvement permit) and Easement Agreement (encroachment permit).

In compliance with the California Environmental Quality Act (CEQA), the City of Industry (City), as lead agency, is preparing the environmental documentation for the proposed project to determine whether approval of the requested discretionary actions and subsequent development would have a significant impact on the environment. As defined by Section 15063 of the CEQA Guidelines, an Initial Study is prepared primarily to provide the lead agency with the information to use as the basis for determining whether an environmental impact report (EIR), negative declaration, or mitigated negative declaration (MND) would provide the necessary environmental documentation and clearance for the proposed project.

1.2 CALIFORNIA ENVIRONMENTAL QUALITY ACT
The environmental compliance process is governed by the California Environmental Quality Act (CEQA) and the CEQA Guidelines (Public Resources Code [PRC], Section 21000 et seq.; California Code of Regulations [CCR], Title 14, Sections 15000 et seq.). CEQA was enacted in 1970 by the California Legislature to disclose to decision-makers and the public the significant environmental effects of projects and to identify ways to avoid or reduce the environmental effects through feasible alternatives or mitigation measures. Compliance with CEQA applies to California government agencies at all levels: local, regional, and State agencies, boards, commissions, and special districts (such as school districts and water districts). The City of Industry (“City”) is the lead agency for the proposed project and is therefore required to conduct an environmental review to analyze the potential environmental effects associated with the proposed project.

PRC Section 21080(a) states that analysis of a project’s environmental impact is required for any “discretionary projects proposed to be carried out or approved by public agencies…”. In this case, the City has determined that an Initial Study is required to determine whether there is substantial evidence that construction and operation of the proposed project would result in environmental impacts.

A “project” means the whole of an action that has a potential for resulting in either a direct physical change in the environment, or a reasonably foreseeable indirect physical change in the environment, and that is any of the following:
 An activity directly undertaken by any public agency including but not limited to public works construction and related activities clearing or grading of land, improvements to existing public structures, enactment and amendment of zoning ordinances, and the adoption and

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amendment of local General Plans or elements thereof pursuant to Government Code sections 65100 to 65700.
 An activity undertaken by a person which is supported in whole or in part through public agency contacts, grants, subsidies, loans, or other forms of assistance from one or more public agencies.
 An activity involving the issuance to a person of a lease, permit, license, certificate, or other entitlement for use by one or more public agencies. (14 CCR Section 15378[a]).

The proposed discretionary actions by the project applicant constitute a “project” because the activity has the potential to result in a direct physical change in the environment and requires issuance of discretionary land use entitlements by the City. All “projects” in the State of California are required to undergo an environmental review to determine the environmental impacts associated with implementation of the project.

1.3 INITIAL STUDY
The purpose of the Initial Study is to: 1) provide the lead agency with information to use as the basis for deciding the proper type of CEQA document to prepare; 2) enable the lead agency to modify a project, mitigating adverse impacts before an Environmental Impact Report (EIR) is prepared, thereby enabling the project to qualify for a negative declaration; 3) assist in the preparation of an EIR, if one is required; 4) facilitate environmental assessment early in the design of a project; 5) provide documentation of the factual basis for the findings in a Mitigated Negative Declaration (MND) or Negative Declaration (ND); 6) eliminate unnecessary EIRs; and 7) determine if a project is covered under a previously prepared EIR. When an Initial Study identifies the potential for immitigable significant environmental impacts, the lead agency must prepare an EIR (14 CCR section 15064); however, if all impacts are found to be less than significant or can be mitigated to a less-than-significant level, the lead agency can prepare an ND, or MND that incorporates mitigation measures into the project (14 CCR section 15070).

1.4 MITIGATED NEGATIVE DECLARATION
The MND includes information necessary for agencies to meet statutory responsibilities related to the proposed project. State and local agencies will use the MND when considering any permit or other approvals necessary to implement the project. A list of the environmental topics that have been identified for study in the MND is provided in the Environmental Checklist.

One of the primary objectives of CEQA is to enhance public participation in the planning process; public involvement is an essential feature of CEQA. Community members are encouraged to participate in the environmental review process, request to be notified, monitor newspapers for

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formal announcements, and submit substantive comments at every possible opportunity afforded by the lead agency. The environmental review process provides several opportunities for the public to participate through public notice and public review of CEQA documents and at public meetings.

1.5 LEVELS OF SIGNIFICANCE
The following terminology is used to describe the level of significance of impacts. Although the criteria for determining significance are different for each topic area, the environmental analysis applies a uniform classification of the impacts based on definitions consistent with CEQA and the CEQA Guidelines:
 No impact. The project would result in no adverse effect on the environment.  Less than significant. The project would not exceed the established significance criteria.  Less than significant with mitigation incorporated. The project would exceed the established significance criteria without mitigation measures, but one or more mitigation measures would reduce the impact to a less-than-significant level successfully.  Potentially significant. The project would exceed the established significance criteria, and either no feasible mitigation measures are available to reduce the impact to a less-thansignificant level, or more analysis is needed to determine if feasible mitigation measures are available to reduce the impact to a less-than-significant level. If any impact is identified as potentially significant, an EIR is required.

Mitigation Measures. If, after incorporation and implementation of federal, state, and local regulations, there are still significant environmental impacts, then feasible and project-specific mitigation measures are required to reduce impacts to less-than-significant levels. Mitigation measures must further reduce significant environmental impacts above and beyond compliance with federal, State, and local laws and regulations. Mitigation under CEQA Guidelines Section 15370 includes:
 Avoiding the impact altogether by not taking a certain action or parts of an action.  Minimizing impacts by limiting the degree or magnitude of the action and its implementation.  Rectifying the impact by repairing, rehabilitating, or restoring the impacted environment.  Reducing or eliminating the impact over time by preservation and maintenance operations during the life of the action.
 Compensating for the impact by replacing or providing substitute resources or environments.

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DECEMBER 2025 9

2. PROJECT DESCRIPTION

2.1 PROJECT LOCATION

2.1.1 Regional Setting
The 9.2-acre project site (Project Site) is at the western end of the City of Industry, in the southeastern part of Los Angeles County. Industry is bordered by the cities of Diamond Bar, Walnut, Pomona, West Covina, La Puente, Baldwin Park, and El Monte and the unincorporated Los Angeles County communities of Rowland Heights and Hacienda Heights (see Figure 1, Regional Location). The Project Site lies in a lowland area in the eastern San Gabriel Valley with Puente Hills to the south. Regional access to the Project Site is from State Route 60 via the Gale Avenue and Hacienda Boulevard freeway ramp approximately 0.75 miles to the southwest.

2.1.2 Local Setting
As shown in Figures 2, Local Vicinity, and 3, Aerial Photograph, the Project Site is bounded by Gale Avenue and residential uses to the south, Ward Way and warehouses and commercial properties to the west, Union Pacific Railroad (UPRR)/Metro rail lines and a rail yard to the north, and the Southern California Edison (SCE) Walnut Substation to the east. The Project Site has addresses of 16233, 16207, and 16253 Gale Avenue and is located on the north side of Gale Avenue north of its intersection with Hinnen Avenue; it consists of five contiguous legal parcels (Assessor’s Parcel Numbers 8242-016-033, -034, -036, -044, and -061). Local access to the Project Site is provided via Stimson Avenue and Gale Avenue.

2.2 ENVIRONMENTAL SETTING

2.2.1 Existing Land Use
The Project Site is currently developed with warehouse, manufacturing, and industrial uses totaling 161,781 square feet of building space, and approximately 205,000 square feet of asphalt and concrete surfacing. Other site features include surface parking areas; outdoor storage and loading/unloading areas; driveways that connect to the internal parking and circulation improvements; and various hardscape and landscape improvements. The Project Site is currently secured on all sides by a mix of tubular-steel fencing, chain-link fencing, solid block walls, and landscaping. Wooden power poles with electrical lines run along a portion of the western/central

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portions of the Project Site. The Project Site is almost entirely covered by impervious surfaces (pavement, buildings, and loading docks). The total existing impervious cover is 8.43 acres, which makes up approximately 92 percent of the total Project Site. Vehicular access to the Project Site is currently provided via three driveways from Gale Avenue.

An SCE overhead electric distribution line currently passes through the eastern portion of the site in a generally north-south direction. A segment of another SCE overhead distribution line is in the western portion of the site.

2.2.2 Existing Zoning and General Plan
The regulatory plans that govern development and use of the Project Site are the Industry General Plan and Municipal Code (including Title 17, Zoning). The development and design standards and regulations in Title 17 implement the City’s General Plan and constitute the zoning regulations that govern development of the Project Site. Per the City’s General Plan land use map, the Project Site’s land use designation is Employment. Per the City’s zoning map, the Project Site is zoned Industrial. Allowed uses under the Employment and Industrial designations include a variety of business and employment uses, including industrial, assembly, printing, machining, milling, welding, research and development, distribution, warehousing, storage, and support office uses.

Currently, the proposed battery energy storage system is not listed as a “Permitted Use” in the City’s Industrial Zone.

2.2.3 Surrounding Land Use
The Project Site is surrounded by a mix of uses, including industrial and warehouse uses to the north and west, the SCE Walnut Substation to the east, and residential uses to the south beyond Gale Avenue in the unincorporated Los Angeles County community of Hacienda Heights. The Project Site and adjacent properties within the City’s boundaries are zoned Industrial (M), with the exception of the SCE Walnut Substation, which is zoned Institutional. The Project Site and surrounding area are urban, disturbed, and developed. The closest sensitive receptors are the residential uses to the south in Hacienda Heights. The closest surface water is the concrete-lined San Jose Creek Channel, about 400 feet north of the Project Site. Figure 3 depicts the surrounding land uses.

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MARICI BATTERY ENERGY STORAGE FACILITY
Hawaiian Hawaiian
Gardens Gardens
Lakewood Lakewood
Artesia Artesia
Long Beach Long Beach
Diamond Bar Diamond Bar
La Puente La Puente Walnut
South El South El
Monte
Covina
West Covina West Covina
El Monte El Monte
Pomona
La Mirada La Mirada
La Habra La Habra
Heights Heights
Bellflower Bellflower
Norwalk Norwalk
Santa Fe Santa Fe
Springs Springs
Commerce Commerce
Pico Rivera Pico Rivera
Rosemead Rosemead
Alhambrara
Temple City Temple City
South
Pasadena asadena
Irwindale Irwindale
Bradbury Bradbury
La
Verne
Azusa
Sierra Madre Sierra Madre
Arcadia Arcadia
Glendora Glendora
Monrovia Monrovia
Duarte
San Dimas San Dimas
Pasadena Pasadena
Baldwin Park Baldwin Park
BBell Gardens ell Gardens
Cypress Cypress
Placentia Placentia
Anaheim
Fullerton Fullerton
La Habra La Habra
Orange
Brea
Buena Park Buena Park
Villa Park Villa Park
Yorba Linda Yorba Linda
La
Palma
0 3
Scale (Miles) Source: ESRI, 2022
Figure XX - Figure Title Here

1. Introduction

PROJECT NAME HERE

CITY OF PROJECT HERE
0 Scale (Miles)
3 Source: Generated using ArcMap 2025. Figure 1
Regional Location
County Boundary
City of Industry Boundary
Project Site
County of Los Angeles
County of Orange
County of
San Bernardino
60 CALIFORNIA
60 CALIFORNIA
60 CALIFORNIA City of Industry
10 210
10 57

CALIFORNIA
57 CALIFORNIA
5 605
605
5 91

CALIFORNIA
91 CALIFORNIA
Chino
Hills
105
210

CALIFORNIA
Hacienda Heights
City of Industry Rowland Heights

CITY OF INDUSTRY

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0 Scale (Feet)
2,000
Source: Generated using ArcMap 2025. Figure 2
Local Vicinity
Project Site Boundary
60 CALIFORNIA
60 CALIFORNIA
60 CALIFORNIA
Hacienda
Heights
San Jose Creek
City of Industry Boundary
Industry
Phoenix Dr
Ward
Wy
Substation Area Boundary

CITY OF INDUSTRY

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0 Scale (Feet)
325
Source: Nearmap 2025. Figure 3
Aerial View
Project Site Boundary
SCE Walnut Substation
(Substation Area)
Ward Wy
UPRR/Metrolink
San Jose Creek
City of
Industry
Phoenix Dr
S Stimson Ave
Los Angeles County
Fire Department Station #43
Gale Ave
Folger St
Glenelder Ave
Shadybend Dr
Barford Ave Barford Ave
Denley St
Hinnen Ave
Hacienda
Heights
Residential
Residential
Industrial and Commercial
City of Industry Boundary Substation Area Boundary

CITY OF INDUSTRY

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2.3 PROJECT CHARACTERISTICS

2.3.1 Project Overview
The proposed project would provide the State of California with a reliable battery energy storage system (BESS) that would receive, store, and discharge electricity from the California Independent System Operator (CAISO) controlled electric grid, including renewable energy produced by existing solar and wind resources in the region.

Battery energy storage is a key component of federal, state, and local planning to strengthen electric grid reliability and reduce the emission of greenhouse gases. The proposed project will help to accomplish these goals by providing capacity to store energy when there is excess generation capacity, such as from intermittent renewable sources like wind and sunlight, then allowing that energy to be used when needed, thereby reducing dependence on fossil fuel generation sources. The rapid response batteries can be utilized to stabilize changes in electric power demand, which reinforces grid stability. The need for facilities such as the proposed project is immediate—on July 30, 2021, Governor Newsom declared a State of Emergency in California regarding statewide electricity shortages caused by climate change, drought, and wildfires. The Governor called upon agencies across the State to take actions to expedite approval of BESSs to bring capacity online in 2022 and beyond. Construction and operation of the proposed project will accomplish the following.
 Use a proven and established energy storage technology that is efficient, has low maintenance requirements, and is recyclable.
 Assist California in meeting its greenhouse gas emissions reduction goals by 2020 and 2030 as required by the California Global Warming Solutions Act (Assembly Bill 32) and amended by Senate Bill 32 in 2016.
 Assist California in achieving its transition from fossil-fuel use by allowing renewables to be stored and discharged back to the market when necessary.

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2.3.2 Proposed Land Use and On-Site Improvements
The proposed Marici BESS facility (proposed Project) includes the construction and operation of an approximately 400-megawatt BESS facility and associated site and infrastructure improvements on the Project Site. Project implementation requires demolition of all existing buildings, structures, hardscapes, and landscaping on-site. Figures 4a and b, Proposed Site Layout, illustrate the layout of the proposed BESS facility and associated improvements and equipment.

As shown in Figure 4a, the southeastern portion of the Project Site would be developed with the on-site collector substation, which is further illustrated in Figure 4b.

The proposed Project would provide a service to the regional electric grid by receiving energy (charging) from the SCE electric transmission system, storing energy on-site, then delivering energy (discharging) back to the SCE Walnut Substation (Substation Area). The proposed BESS facility would generate a total electricity demand of 584,000 kilowatt-hours per year. Power captured or released by the proposed Project would be transferred to and from the Substation Area, which is at 16398 Gale Avenue in the City of Industry (bordering the site to the east), via an overhead tie-line. Project implementation would require several improvements to the Substation Area, which are described below.

Project approval requires City adoption of a Mitigated Negative Declaration and Mitigation Monitoring and Reporting Program, approval of a Zone Code text amendment (Zone Amendment No. 24-07) to allow the use with a CUP, approval of a Conditional Use Permit (CUP No. 24-03), approval of Development Plan Application – Long Form (Development Plan No. 24-09 (DP-24-09), approval of a Community Benefit Agreement (CBA No. 25-01) , approval of a ROW Agreement (street improvement permit), and Easement Agreement (encroachment permit).

The Industrial zoning designation of the Project Site does not permit the development and operation of BESS facilities. Development of the proposed BESS facility on the Project Site does not include or require a change in the zoning designation of the Project Site (e.g., through an amendment to the site’s zoning designation from one zone to another); however, a zone text amendment to list BESS facilities as a use permitted through City approval of a CUP in the Industrial zone is required.

Following is a description of the various components and improvements, both on- and off-site, associated with and needed to implement the proposed Project.

Page 195 of 6633 ends

PlaceWorks

MARICI BATTERY ENERGY STORAGE FACILITY

OE OE OE OE OE OE OE OE

UE UE UE UE UE UE UE UE

UE UE UE UE UE UE UE UE COMM COMM
GAS
COMM

COMM COMM COMM

F F F F F F F
F F F

F F F F F F F F
F

F F F F F

F F F F

UE UE UE UE UE UE UE UE UE UE UE UE UE UE UE UE UE UE

UE UE UE UE UE UE UE UE UE UE
UE

F F F F F F F
F F F

F F F F F F F F
F

F F F F F

F F F F

UE UE UE UE UE UE UE UE UE UE UE UE UE UE UE UE UE UE

UE UE UE UE UE UE UE UE UE UE
UE
ST
ST

ST ST ST ST ST ST ST ST ST
ST ST

ST ST ST ST ST ST ST ST ST ST ST ST ST ST ST

ST ST ST ST ST ST ST
ST

ST ST ST ST ST
SD
SD
SD

HINNEN AVE

WARD WAY

GALE AVENUE

UNION PACIFIC RAILWAY
PROP 10' SCE ELECTRIC

UTILITY EASEMENT
PROP 30' SETBACK

FROM EX BACK OF CURB
PROP 30' SETBACK FROM

EX CURB LINE
3' (MIN )
5'
7'
10'
19'
10'

PROP LANDSCAPE AREA (TYP)

PROP VEHICULAR ACCESS GATE
(SEE NOTE 9)
PROP 10' HIGH BLAST RATED

CMU WALL W/SECURITY WIRE
(SEE NOTE 8)

PROP TRANSFORMER (TYP)

PROP CURB INLET (TYP)

PROP FIRE WATER LINE (TYP)

PROP FIRE HYDRANT
(TYP, SEE NOTE 5)

PROP BATTERY CONTAINER (TYP) PROP STORM DRAIN

MANHOLE (TYP)

SAWCUT EXISTING CURB AND
CONNECT PROP 26' WIDE DRIVEWAY

ENTRANCE TO EX PAVEMENT

PROP GRATE INLET (TYP)

PROPOSED UNDERGROUND TO

OVERHEAD TRANSITION POLE/END

PROP UNDER GROUND ELECTRIC
PROP 10' HIGH BLAST RATED

CMU WALL W/SECURITY WIRE
(SEE NOTE 8)
PROP 10' HIGH

CMU FIRE WALL
PROP 10' HIGH BLAST RATED

CMU WALL W/SECURITY WIRE
(SEE NOTE 8)
PROP 20'X60' O&M BUILDING

PROP CMU TRASH AND

RECYCLING ENCLOSURE
9'(L) X 22'(W) X 6'(H)
7'
10'
PROP 10' HIGH BLAST RATED

CMU WALL W/SECURITY WIRE
(SEE NOTE 8)
APPROX. 80' ROW
25'

EXISTING RETAINING WALL SHALL BE MOVED

TO PROPERTY LINE

PROP PRETREATMENT DEVICE

PROP BOLLARD (TYP)

PROP FIRE COMMAND
CENTER (2'x3')
PROP 20' HIGH POLE

FOR WINDSOCK
PROP FIRE COMMAND CENTER (2'x3')
PROP 20' HIGH POLE

FOR WINDSOCK
5' (TYP) 5' (TYP)
11' (TYP)
4' (TYP)
5' (TYP) 5' (TYP)
11' (TYP) 4' (TYP)
5' (TYP) 5' (TYP)
11' (TYP)
4' (TYP)
11' (TYP)
8' (TYP) 6' (TYP)
5' (TYP)
6' (TYP)
5' (TYP)
8' (TYP)
11' (TYP)

EX ROAD ℄
8'
11'
PROP 2-10'X20' PARKING SPACES
PROP 1-10'X20' ADA PARKING SPACE
W/ 5'X20' ACCESS AISLE

EX ROAD ℄

SAWCUT EXISTING CURB AND
CONNECT PROP 26' WIDE DRIVEWAY

ENTRANCE TO EX PAVEMENT

PROP PEDESTRIAN ACCESS GATE (TYP)

PROP VEHICULAR ACCESS GATE
(SEE NOTE 9)

PROP AUXILIARY PAD (TYP)
30'
14'
3'
20'
13'
PROP 2-10'X20' PARKING SPACES
26' BOC-BOC PRIVATE

DRIVEWAY AND FIRE LANE
(SEE DETAILS SHEET C-6.0)
26' BOC-BOC PRIVATE

DRIVEWAY AND FIRE LANE
(SEE DETAILS SHEET C-6.0)

SAWCUT EXISTING CURB AND
CONNECT PROP 26' WIDE DRIVEWAY

ENTRANCE TO EX PAVEMENT
26' BOC-BOC PRIVATE

DRIVEWAY AND FIRE LANE
(SEE DETAILS SHEET C-6.0

PROP STORAGE CONTAINER (TYP)
PROP 6'(W) X 46' (L) ADA ACCESSIBLE WALKWAY

EX SCE VAULT (TO REMAIN)

EX UTILITY

BOX TYP (TO

REMAIN)

EX STREET TREE TYP (TO REMAIN)

SIDEWALK, CURB AND GUTTER

TO BE REPAIRED AT REMOVED

DRIVEWAY LOCATION

EX LANDSCAPE AREA TYP
(TO REMAIN)

CURB REPAIRED AT

REMOVED DRIVEWAY

LOCATION (TYP)

HEAT PUMP

ASSESSORS PARCEL NUMBER
8242-016-814
(QUASI-PUBLIC: SCE WALNUT SUBSTATION,

NOT A PART OF THE PROJECT)

ASSESSORS PARCEL NUMBER
8242-016-059
(INDUSTRIAL: WHOLESALE WAREHOUSE,

NOT A PART OF THE PROJECT)

ASSESSORS PARCEL NUMBER
8242-016-046
(INDUSTRIAL: ELECTRICAL AND

LIGHTING WHOLESALE WAREHOUSE,

NOT A PART OF THE PROJECT)

ASSESSORS PARCEL NUMBER
8242-016-043
(INDUSTRIAL: DIESEL PARTS AND

SERVICE, NOT A PART OF THE PROJECT)

ASSESSORS PARCEL NUMBER
8242-016-029
(INDUSTRIAL: NOT A PART OF THE PROJECT)

ASSESSORS PARCEL NUMBER
8242-016-062
(RECREATIONAL: VETERANS OF

FOREIGN WARS HALL, NOT PART OF PROJECT)

PROP SUBSTATION
(SEE SHEET C-7.0)

PROP POCO POLE

PROP RISER POLE
PROP 10' HIGH CMU FIRE WALL

PROPOSED UNDERGROUND ELECTRIC

CONNECTION LOCATION TO BE

DETERMINED BY SCE

PROP UNDERGROUND ELECTRIC
6'
1 2
40'

SIDEWALK AND

CURB AND

GUTTER REPAIR
5' (TYP)

PROP FACILITY IDENTIFICATION

SIGN (WALL MOUNT)

EX CONCRETE DRAIN
(TO REMAIN)

EX FIRE HYDRANT
(TO REMAIN)

EX FIRE HYDRANT (TO REMAIN)

EX STREET TREE TYP (TO REMAIN)

EX FIRE HYDRANT
(TO REMAIN)

PROP FACILITY IDENTIFICATION

SIGN (WALL MOUNT)

PROP FACILITY IDENTIFICATION

SIGN (WALL MOUNT)

CURB AND GUTTER REPAIRED AT

REMOVED DRIVEWAY LOCATION
30' OFFER OF DEDICATION

SUMMARY OF KEY FEATURES

PLAN DEPICTION ITEM DIMENSIONS QUANTITY
BATTERY CONTAINER 20'(L) X 8'(W) X 8'(H) 480*
MV TRANSFORMER 20'(L) X 8'(W) X 9.5'(H) 120*
STORAGE CONTAINER 40'(L) X 8'(W) X *'(H) 8
AUXILIARY PAD 20'(L) X 20'(W) 3
30'(L) X 14'(W) 2
BACKUP GENERATOR 17.6'(L) X 7.5'(W) (CONC PAD) 2
TRASH AND RECYCLING ENCLOSURE 9'(L) X 22'(W) X 6'(H) 1
RISER POLE 102'-0"(H) 1
POINT OF CHANGE IN OWNERSHIP POLE 140'-0"(H) 1

FIRE HYDRANT PER FIRE DEPARTMENT
REQUIREMENT 22
STORMWATER DROP INLET (CURB) 3' X 6', 3' X 8', AND 3' X 10' 13 STORMWATER DROP INLET (GRATE) 4' X 4' AND 3' X 3' 2
STORMWATER DRAIN MANHOLE 4' DIAMETER 3
STORMWATER PRETREATMENT DEVICE TO BE DETERMINED 1
LANDSCAPING VARIES 52,349 SQ. FT.

PRIVATE ROAD/FIRE LANE 26'(W) NA
BUILDING 20'(W) X 60'(L) X 15'(H) 1
PARKING SPACE 10'(W) X 20'(L) 4
HANDICAPPED PARKING SPACE 10'(W) X 20'(L) 1
WINDSOCK 20'(H) 2
FIRE COMMAND CENTER 3'(L) x 2'(W) 2
PROJ. NO.:

NO. BY DATE REVISION APP'D.

PERMIT PLAN SET

NOT FOR

CONSTRUCTION

MARICI PROJECT, LLC
16207, 16233, AND 16285 GALE AVENUE
CITY OF INDUSTRY, CA 91745-1719
604109
DG
SH
DATE:

PROFESSIONAL ENGINEER:
3/12/2025

SITE PLAN
C-3.0

GRAPHIC SCALE
NORTH
N
0 50'
1" = 50'
50'
GENERAL NOTES:

1. THIS PLAN SET IS SUBMITTED FOR APPLICATION AND ISSUANCE OF A

LAND USE ENTITLEMENT FOR THE PROJECT FROM THE CITY OF
INDUSTRY.

2. THE LOCATIONS OF PROPOSED IMPROVEMENTS, INCLUDING BUT NOT LIMITED TO: BATTERY ENCLOSURES, TRANSFORMERS, AUXILIARY PADS, FIRE HYDRANTS, ETC., SHOWN ARE APPROXIMATE AND ARE SUBJECT TO

REFINEMENT PRIOR TO GRADING AND BUILDING PERMIT APPLICATIONS

DUE TO SITE CONDITIONS, PERMIT REQUIREMENTS, EQUIPMENT
SPECIFICATIONS, AND/OR OTHER CONSTRAINTS.

3. CONTRACTOR SHALL CALL AT LEAST 72 HOURS PRIOR TO BEGINNING CONSTRUCTION OR EXCAVATION TO HAVE EXISTING UTILITIES LOCATED.

ADDITIONALLY, CONTRACTOR SHALL CONTACT ANY LOCAL UTILITIES THAT PROVIDE THEIR OWN LOCATOR SERVICES.

4. 2-HOUR FIRE WALL TO BE PROVIDED AT HYDRANTS THAT ARE WITHIN 25-FEET OF STRUCTURES

5. FIRE HYDRANTS TO BE PROTECTED BY A FIRE RATED WALL IF REQUIRED BY LACFD.

6. FIRE BEACONS/STROBES WILL BE INCLUDED AS PART OF DETAILED FIRE DESIGN.

7. CAMERAS WILL BE PLACED TO ENSURE VISIBILITY OF ALL MAJOR

EQUIPMENT, THIS DETAIL WILL BE CAPTURED AS PART OF THE DETAILED SECURITY DESIGN.

8. PERIMETER WALL TO BE RATED TO WITHSTAND A POTENTIAL BLAST AND

SHALL BE TOPPED WITH SECURITY WIRE TO MEET LOS ANGELES COUNTY FIRE DEPARTMENT REQUIREMENTS.

9. ALL PROPOSED VEHICULAR ACCESS GATES SHALL BE PROVIDED WITH A FIRE DEPARTMENT APPROVED LOCKING DEVICE.

10. BATTERY CONTAINERS SHALL BE LOCATED A MINIMUM OF 10' INSIDE

THE PROPERTY LINE IN ACCORDANCE WITH LOS ANGELES COUNTY FIRE DEPARTMENT REQUIREMENTS.

PROJECT BOUNDARY

UTILITY EASEMENT

SETBACK

FIRE WATER LINE

STORM DRAIN

UNDERGROUND ELECTRIC LINE

CURB FACE AND BACK

BLAST-RATED CMU WALL

FIRE WALL

ASPHALT PAVEMENT

CONCRETE PAVEMENT

LANDSCAPING (PROPOSED)

LANDSCAPING (PRESERVED)

FIRE HYDRANT

STORM DRAIN MANHOLE

GRATE INLET

CURB INLET

BOLLARD

VEHICULAR ACCESS GATE

PEDESTRIAN ACCESS GATE

BATTERY CONTAINER

TRANSFORMER

AUXILIARY PAD
UE UE
LEGEND

EXISTING FEATURES

PROPOSED FEATURES

GALE AVE

S STIMSON AVE
F F

ST ST ST
UE UE
SD

GENERATOR
SD
NOTES:

ASPHALT PAVEMENT WITH CONCRETE CURB AND GUTTER

CONCRETE DRIVEWAY APRON
1 2

RIGHT-OF-WAY

ADJACENT PARCEL BOUNDARY

ROAD CENTERLINE

ASPHALT PAVEMENT EDGE

CURB FACE AND BACK
TREE

RAILROAD TRACKS

CONCRETE

OVERHEAD ELECTRIC LINE

UNDERGROUND ELECTRIC LINE

GAS LINE

WATER LINE

STORM DRAIN

STORM DRAIN MANHOLE

FIRE HYDRANT

GAS METER

POST INDICATOR VALVE

WATER VALVE

WATER METER

UTILITY POLE

UTILITY BOX

SCE UTILITY VAULT
GAS

OE OE OE
* BASED ON USE OF SUNGROW POWERTITAN 2.0 ST5015kWh-2500kW-2h-US BATTERIES AND POWERTITAN 2.0 MVS5000-LV-US TRANSFORMERS.

Figure 4a
Proposed Site Layout
Source: TRC 2025.
0 Scale (Feet)
130

OE OE OE OE OE OE

F F F F F F F
F F F

F F F F F F F
F

F F F F F

F F F F

UE UE UE UE UE UE UE UE UE UE UE UE UE UE UE UE UE UE

UE UE UE UE UE UE UE UE U

F F F F F F F
F F F

F F F F F F F
F

F F F F F

F F F F

UE UE UE UE UE UE UE UE UE UE UE UE UE UE UE UE UE UE

UE UE UE UE UE UE UE UE U
ST
ST

ST ST ST ST ST ST ST ST ST
ST ST

ST ST ST ST ST ST ST ST ST ST ST ST ST ST ST

ST ST ST ST ST ST ST
ST

ST ST ST ST ST
SD
SD
SD

UNION PACIFIC RAILWAY
PROP 10' SCE ELECTRIC

UTILITY EASEMENT
3' (MIN )
5'
7'
0'
19'
10'

PROP VEHICULAR ACCESS GATE
(SEE NOTE 9)
PROP 10' HIGH BLAST RATED

CMU WALL W/SECURITY WIRE
(SEE NOTE 8)

PROP TRANSFORMER (TYP)

PROP CURB INLET (TYP)

PROP FIRE WATER LINE (TYP)

PROP FIRE HYDRANT
(TYP, SEE NOTE 5)

PROP BATTERY CONTAINER (TYP) PROP STORM DRAIN

MANHOLE (TYP)

PROP GRATE INLET (TYP)

PROPOSED UNDERGROUND TO

OVERHEAD TRANSITION POLE/END

PROP UNDER GROUND ELECTRIC
PROP 10' HIGH BLAST RATED

CMU WALL W/SECURITY WIRE
(SEE NOTE 8)
PROP 10' HIGH

CMU FIRE WALL
PROP 10' HIGH BLAST RATED

CMU WALL W/SECURITY WIRE
(SEE NOTE 8)
PROP 20'X60' O&M BUILDING

PROP CMU TRASH AND

RECYCLING ENCLOSURE
9'(L) X 22'(W) X 6'(H)
7'
10'
25'

EXISTING RETAINING WALL SHALL BE MOVED

TO PROPERTY LINE

PROP PRETREATMENT DEVICE

PROP BOLLARD (TYP)
0' HIGH POLE
NDSOCK
PROP FIRE COMMAND CENTER (2'x3')
5' (TYP) 5' (TYP)
11' (TYP)
4' (TYP)
5' (TYP) 5' (TYP)
11' (TYP) 4' (TYP)
5' (TYP) 5' (TYP)
11' (TYP)
4' (TYP)
11' (TYP)
8' (TYP) 6' (TYP)
5' (TYP)
6' (TYP)
5' (TYP)
8' (TYP)
11' (TYP)
8'
11'
PROP 2-10'X20' PARKING SPACES
PROP 1-10'X20' ADA PARKING SPACE
W/ 5'X20' ACCESS AISLE

PROP PEDESTRIAN ACCESS GATE (TYP)

PROP AUXILIARY PAD (TYP)
30'
14'
3'
20'
13'
PROP 2-10'X20' PARKING SPACES
26' BOC-BOC PRIVATE

DRIVEWAY AND FIRE LANE
(SEE DETAILS SHEET C-6.0)
26' BOC-BOC PRIVATE

DRIVEWAY AND FIRE LANE
(SEE DETAILS SHEET C-6.0)
26' BOC-BOC PRIVATE

DRIVEWAY AND FIRE LANE
(SEE DETAILS SHEET C-6.0

PROP STORAGE CONTAINER (TYP)
PROP 6'(W) X 46' (L) ADA ACCESSIBLE WALKWAY

HEAT PUMP

ASSESSORS PARCEL NUMBER
8242-016-814
(QUASI-PUBLIC: SCE WALNUT SUBSTATION,

NOT A PART OF THE PROJECT)
UMBER

WAREHOUSE,
OJECT)

RS PARCEL NUMBER
242-016-046
AL: ELECTRICAL AND

OLESALE WAREHOUSE,

RT OF THE PROJECT)

PROP SUBSTATION
(SEE SHEET C-7.0)

PROP POCO POLE

PROP RISER POLE
PROP 10' HIGH CMU FIRE WALL

P UNDERGROUND ELECTRIC
6'
1 P)

EX STREET TREE TYP (TO REMAIN)
TY
FT.

PERMIT PLAN SET

NOT FOR

CONSTRUCTION
DATE:

PROFESSIONAL ENGINEER:

GRAPHIC SCALE
NORTH
N
0 50'
1" = 50'
50'
GENERAL NOTES:

1. THIS PLAN SET IS SUBMITTED FOR APPLICATION AND ISSUANCE OF A

LAND USE ENTITLEMENT FOR THE PROJECT FROM THE CITY OF
INDUSTRY.

2. THE LOCATIONS OF PROPOSED IMPROVEMENTS, INCLUDING BUT NOT LIMITED TO: BATTERY ENCLOSURES, TRANSFORMERS, AUXILIARY PADS, FIRE HYDRANTS, ETC., SHOWN ARE APPROXIMATE AND ARE SUBJECT TO

REFINEMENT PRIOR TO GRADING AND BUILDING PERMIT APPLICATIONS

DUE TO SITE CONDITIONS, PERMIT REQUIREMENTS, EQUIPMENT
SPECIFICATIONS, AND/OR OTHER CONSTRAINTS.

3. CONTRACTOR SHALL CALL AT LEAST 72 HOURS PRIOR TO BEGINNING CONSTRUCTION OR EXCAVATION TO HAVE EXISTING UTILITIES LOCATED.

ADDITIONALLYCONTRACTOR SHALL CONTACT ANY LOCAL UTILITIES

PROJECT BOUNDARY

UTILITY EASEMENT

SETBACK

FIRE WATER LINE

STORM DRAIN

UNDERGROUND ELECTRIC LINE

CURB FACE AND BACK

BLAST-RATED CMU WALL

FIRE WALL

ASPHALT PAVEMENT

CONCRETE PAVEMENT

LANDSCAPING (PROPOSED)

LANDSCAPING (PRESERVED)

FIRE HYDRANT

STORM DRAIN MANHOLE

GRATE INLET

CURB INLET

BOLLARD

VEHICULAR ACCESS GATE

PEDESTRIAN ACCESS GATE

BATTERY CONTAINER

TRANSFORMER

AUXILIARY PAD
UE UE
LEGEND

EXISTING FEATURES

PROPOSED FEATURES

GALE AVE

S STIMSON AVE
F F

ST ST ST
UE UE
SD
NOTES:

ASPHALT PAVEMENT WITH CONCRETE CURB AND GUTTER

CONCRETE DRIVEWAY APRON
1 2

RIGHT-OF-WAY

ADJACENT PARCEL BOUNDARY

ROAD CENTERLINE

ASPHALT PAVEMENT EDGE

CURB FACE AND BACK
TREE

RAILROAD TRACKS

CONCRETE

OVERHEAD ELECTRIC LINE

UNDERGROUND ELECTRIC LINE

GAS LINE

WATER LINE

STORM DRAIN

STORM DRAIN MANHOLE

FIRE HYDRANT

GAS METER

POST INDICATOR VALVE

WATER VALVE

WATER METER

UTILITY POLE

UTILITY BOX

SCE UTILITY VAULT
GAS

OE OE OE
(SEE FIGURE 4B FOR DETAIL)

CITY OF INDUSTRY

Page 196 of 6633 ends

MARICI BATTERY ENERGY STORAGE SYSTEM FACILITY INITIAL STUDY / MITIGATED

NEGATIVE DECLARATION

CITY OF INDUSTRY

2. PROJECT DESCRIPTION
20 PlaceWorks
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MARICI BATTERY ENERGY STORAGE FACILITY
F F
X X X

LOW BUS

LOW BUS

LOW BUS

LOW BUS

GENERATOR GENERATOR

34.5 kV PAD MOUNTED

STATION SERVICE

TRANSFORMERS

RISER POLE

FIRE WALL
TRANSFORMER 1
(230/34.5kV)

WITH OIL
CONTAINMENT PIT TRANSFORMER 2
(230/34.5kV)

WITH OIL CONTAINMENT PIT
230kV BREAKER 2

SUBSTATION CONTROL
HOUSE

POCO POLE
230kV BREAKER 1
230kV BUS
TIE SWITCH 1 230kV BUS
TIE SWITCH 2
230kV A-FRAME

W/SURGE ARRESTERS,

MOUNTED SWITCH, AND PTS

MAN GATE

BACK UP

GENERATORS
230kV BUS SUPPORT
6’ HIGH

WROUGHT IRON

STYLE FENCE

MAN GATE
10' HIGH CMU

FIRE WALL
10' HIGH CMU

FIRE WALL
10' HIGH BLAST-RATED CMU

WALL W/ SECURITY WIRE
10' HIGH BLAST-RATED CMU

WALL W/ SECURITY WIRE

PROP VEHICULAR ACCESS GATE

34.5kV CIRCUIT

BREAKER FOR
TRANSFORMER 1
(TYP)

34.5kV FEEDER TERMINATION
FOR TRANSPORMER 1 (TYP)

34.5kV BUS

SUPPORT

34.5kV CIRCUIT BREAKER FOR
TRANSFORMER 2 (TYP)

34.5kV FEEDER TERMINATION
FOR TRANSFORMER 2 (TYP)

34.5kV BUS SUPPORT
230kV 45° BUS
230kV 45° BUS
PROJ. NO.:

NO. BY DATE REVISION

PERMIT PLAN SET

NOT FOR

CONSTRUCTION

MARICI PROJECT, LLC
16207, 16233, AND 16285 GALE AVENUE
CITY OF INDUSTRY, CA 91745-1719
DG
SH
DATE:

PROFESSIONAL ENGINEER:
3/12/2025

SUBSTATION PLAN
C-7.0

SUBSTATION LAYOUT
SCALE: 1" = 15' 1
182.98'
236.40'
119.85'

GRAPHIC SC
0 1" = 15'
15'
NORTH
N
Figure 4b
Proposed Site Layout
Source: TRC 2025.
0 Scale (Feet)
35 CITY OF INDUSTRY

Page 198 of 6633 ends

MARICI BATTERY ENERGY STORAGE SYSTEM FACILITY INITIAL STUDY / MITIGATED

NEGATIVE DECLARATION

CITY OF INDUSTRY

2. PROJECT DESCRIPTION
22 PlaceWorks
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MARICI BATTERY ENERGY STORAGE SYSTEM FACILITY INITIAL STUDY / MITIGATED

NEGATIVE DECLARATION

CITY OF INDUSTRY

2. PROJECT DESCRIPTION
DECEMBER 2025 23

2.3.3 Battery Energy Storage System Enclosures
The proposed project includes lithium-ion batteries that would be housed in purpose-built, freestanding enclosures approximately 10 feet or less in height. The purpose-built enclosures would be designed and installed in accordance with all applicable seismic design requirements of the current California Building Code. The enclosures would also be built in accordance with all pertinent regulations outlined in the Los Angeles County Fire Code (Title 32 of the Los Angeles County Code), which is adopted by reference in the Industry Municipal Code, Chapter 15.28, Fire Code, and NFPA 855, which is the National Fire Protection Association standard for the Installation of stationary energy storage systems. The proposed Project includes the use of the Sungrow PowerTitan 2.0 energy storage system with PowerTitan 2.0 ST5015kWh-2500kW-2h-US battery enclosures.

The battery enclosures include inverters to convert the direct current (DC) flowing in and out of the batteries to alternating current (AC) flowing in and out of the battery containers. Figure 5, Electrical System Details, shows a battery container example. The power inverters would be industry standard, nationally (and internationally) recognized equipment. The inverters would be stand-alone units that operate in both charge and discharge modes in all conditions. They are monitored and controlled remotely with no need for daily staffing on-site. There would be onsite disconnects in the event of an emergency or unscheduled maintenance. The disconnects would allow maintenance personnel and emergency responders to completely de-energize the BESS and connected circuits, preventing electrical hazards during maintenance, repair, or emergencies.

The proposed Project would include 480 battery containers and 120 medium voltage (MV) transformer containers (see Figure 4a for layout and placement of enclosures). Bi-directional MV transformers housed in separate purpose-built containers would be arranged throughout the battery array areas to transform low-voltage AC current from the battery containers to mediumvoltage AC current for collection by medium-voltage conductor cables. Figure 5 shows an example of an MV transformer container. The MV conductor cables would be underground and would connect the MV transformers to an on-site collector substation.

The battery enclosures would contain lithium-ion batteries installed in racks inside the enclosure.

Each enclosure contains six racks with eight modules each, for a total of 48 liquid-cooled battery modules. A Power Conversion System (PCS), which manages how electricity flows between the batteries and the electric grid or facility load, is underneath each rack. The PowerTitan 2.0 includes a vent panel, heat and smoke detectors, a sound beacon, ventilation system, and flammable gas detector. The PowerTitan 2.0 enclosures include an NFPA 69 ventilation system to expel battery vent gas in case of cell failure. The exhaust fan activates upon detection of hydrogen gas and expels air and vent gas. This system is designed to prevent an explosive atmosphere. An inlet louver would be located on the left side of the enclosure near the bottom, and an exhaust

Page 200 of 6633 ends

MARICI BATTERY ENERGY STORAGE SYSTEM FACILITY INITIAL STUDY / MITIGATED

NEGATIVE DECLARATION

CITY OF INDUSTRY

2. PROJECT DESCRIPTION
24 PlaceWorks
fan would be located on top of the enclosure near the right side. The exhaust fan would activate upon detection of hydrogen gas and expels air and vent gas.

2.3.4 Battery Safety
Equipment manufacturing, construction, and operations would include comprehensive measures to ensure safe equipment installation and operation. Each battery module and battery container would be inspected and tested at the manufacturer’s facility. Each container would be inspected for damage at the Project Site prior to installation and testing. Once installed, tested, and in operational mode, each battery module would be continuously monitored from an off-site location for electrical current, voltage, and temperature to optimize performance and mitigate potential failures. Batteries performing out of specification would be immediately taken offline by the automated monitoring system.

Battery enclosures would be spaced following National Fire Protection Association (NFPA) Standard 855, Los Angeles County Fire Department (LACoFD) requirements and manufacturer’s specifications to minimize risk of fire spreading to adjacent containers. NFPA 855 would also require comprehensive safety planning submittals to LACoFD, including results of bench-scale fire and explosion testing by the manufacturer and hazard mitigation analysis for the specific type of battery used. An Emergency Response Plan would be reviewed and approved by LACoFD, designed to ensure well-planned, prompt, safe, and appropriate response in the event of an emergency. These submittals would be made to LACoFD after the specific equipment is selected and prior to issuance of building permits. NFPA 855 additionally mandates initial and annual refresher training for facility staff, and the Applicant would coordinate with LACoFD to facilitate site-specific LACoFD staff training.

Each of the BESS enclosures would be equipped with fire prevention, detection, and isolation methods and materials; monitoring systems and controls; and cooling units to keep the batteries at optimal operating temperatures. At a minimum, this would include smoke/fire detection sensors, ground fault detection, alarms, and systems to automatically shut down cooling fans and open electrical contacts in the battery system. In addition, monitoring systems would include heat sensors, gas detectors, and an NFPA 69–compliant explosion prevention system. Each protection system would have a signal that would trigger core power-down during fire, overheating, or other malfunction. The entire project would power down automatically during electrical-fault conditions (e.g., high-voltage, high-frequency, ground fault). In addition, the proposed BESS would be equipped with breakers that could be opened manually to power down different equipment on the Project Site.

Page 201 of 6633 ends

PlaceWorks

MARICI BATTERY ENERGY STORAGE FACILITY
PROJ. NO.:

NO. BY DATE REVISION APP'D.

PERMIT PLAN SET

NOT FOR

CONSTRUCTION

MARICI PROJECT, LLC
16207, 16233, AND 16285 GALE AVENUE
CITY OF INDUSTRY, CA 91745-1719
604109
DG
SH
3/12/2025

PACK CABINET
BATTERY CONTAINER EXAMPLE 1

AIR INLET

PCS CABINET

EXPLOSION VENTING PANEL

AIR COOLER INTEGRATION CABINET

LIQUID COOLING UNIT AREA

DISTRIBUTION AREA

FSS AREA

EXHAUST FAN

LEFT VIEW FRONT VIEW RIGHT VIEW
GENERAL NOTES:

1. EXPOSED SURFACES OF ALL EQUIPMENT SHOWN ARE PAINTED SHEET METAL.

2. COLOR SELECTIONS:

BATTERY CONTAINER - MATTE FINISH WHITE;
MEDIUM VOLTAGE TRANSFORMER CONTAINER - MATTE FINISH WHITE; STATION SERVICE TRANSFORMER - ANSI 70 MATTE FINISH GRAY.

3. SEE SHEET Z1-3610991 FOR EXAMPLE HIGH VOLTAGE TRANSFORMER.

FRONT VIEW
MEDIUM VOLTAGE TRANSFORMER CONTAINER EXAMPLE 3

LC CABINET

LC CABINET

TRANSFORMER

ISOMETRIC VIEW
APPROX. 8'
APPROX. 19.88'
APPROX. 9.5'

LEFT VIEW

RIGHT VIEW

REAR VIEW

ELECTRICAL DETAILS
E-1.0
APPROX 20'
APPROX 8'
APPROX. 8'

TOP VIEW

FRONT VIEW SIDE VIEW

TOP VIEW
STATION SERVICE TRANSFORMER EXAMPLE 2
OVERALL HEIGHT 68.3"

67.8"

59.6"

31.7" 25.6"
OVERALL DEPTH 60.8"
OVERALL WIDTH 68.6"
Figure 5
Electrical System Details
Source: TRC 2025.

CITY OF INDUSTRY

Page 202 of 6633 ends

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NEGATIVE DECLARATION

CITY OF INDUSTRY

2. PROJECT DESCRIPTION
26 PlaceWorks
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MARICI BATTERY ENERGY STORAGE SYSTEM FACILITY INITIAL STUDY / MITIGATED

NEGATIVE DECLARATION

CITY OF INDUSTRY

2. PROJECT DESCRIPTION
DECEMBER 2025 27

2.3.5 On-Site Collector Substation
A collector substation would also be provided on-site. As shown in Figure 4a, the collector substation would be at the southeast end of the Project Site. Figure 4b illustrates the enlarged collector substation plan and the various components of the substation. The on-site collector substation would include two high-voltage (HV) bi-directional transformers that would convert between the on-site MV systems and the regional electric grid’s high-voltage AC. The HV side of the on-site substation would be 220 kilovolts (kV) and would connect to the adjacent SCE Walnut Substation via a new 220 kV overhead tie line that would cross the eastern site boundary directly into the Walnut Substation. The point of change in ownership (POCO) between the proposed Project and SCE facilities would be an approximately 140-foot-high steel pole. In addition, there would be two station transformers in the on-site substation to provide on-site power. Locations and details of these features are provided in Figure 4b. The substation elevations are shown in Figure 6, Substation Elevations. The main power transformers, which are the tallest feature of the substation, would reach a maximum height of 38 feet and 4 inches above grade.

Substation equipment would include 230 kV and 34.5 kV bus work, circuit breakers, disconnect switches, instrument transformers, metering transformers, two 220/34.5 kV bi-directional transformers, two auxiliary transformers for station service, two back-up generators, a control house with relay protection, a supervisory control and data acquisition (SCADA) system, and a telemetry system.

All outside electrical equipment would be housed in the appropriate National Electrical Manufacturers Association–rated enclosures to withstand outdoor conditions and would be screened from view to the extent feasible on all sides. With the exception of the tie line between the on-site collector substation and the SCE Walnut Substation, all outside electrical cabling onsite would be placed underground.

2.3.6 Telecommunication Facilities
The proposed Project would include telecommunication facilities to meet the communication requirements for interconnecting and communicating with the SCE/CAISO facilities and to support remote operations monitoring. To provide communication with SCE facilities, a fiberoptic line would be used to connect the proposed Project’s collector substation with the SCE substation. Utility interconnection regulations require the installation of a second, separate and redundant, diverse telecom option. Accordingly, the proposed Project would include a diverse fiber route as well as a backup cellular modem to ensure redundancy and reliability.

Project development also includes the provision of a SCADA system. The SCADA system is critical to the CAISO and SCE utility interconnection and for the proper operation and maintenance of the proposed Project. The SCADA system would aggregate all project information from the BESS,

Page 204 of 6633 ends

MARICI BATTERY ENERGY STORAGE SYSTEM FACILITY INITIAL STUDY / MITIGATED

NEGATIVE DECLARATION

CITY OF INDUSTRY

2. PROJECT DESCRIPTION
28 PlaceWorks
inverters, transformers, breakers, Fire Alarm Control Panel, and transmission lines. The SCADA system would also communicate with the transmission service provider, grid operator, and the proposed Project’s remote operations center. The SCADA system can also control critical site functions, including charge/discharge, breaker status, and total output.

2.3.7 Tie Line
The high voltage (east) side of the on-site substation would include an A-frame dead-end structure, a riser pole, and a POCO pole that would be extended to connect the 220 kV overhead lines to the POCO and into the adjacent SCE Substation. The design includes an A-frame, riser pole, and POCO pole with heights of 80.5 feet, 102 feet, and 140 feet, respectively (see Figure 7, Tie-Line Pole Details). The heights would be designed to allow the 220 kV line to cross into the SCE Substation above an existing 66 kV line with required clearances for safety. The dead end, poles, and other collector substation structural steel would have a galvanized or other neutralcolored, low-reflective finish.

2.3.8 Site Access, Parking, and Security
The proposed Project would include interior paved access and fire lanes, five parking spaces, and a solid perimeter wall topped with security wire designed to City and LACoFD requirements from Title 32 of Los Angeles County’s Code of Ordinances.

As shown in Figure 4a, access to the Project Site would be provided from two driveways on Gale Avenue and one driveway on Ward Way. The driveways would provide access to the 26-foot internal drive aisle. The drive aisle would meet LACoFD requirements and be designed for twoway circulation. The Project Site would be secured from public entry so only project vehicles would be on-site. Five parking spaces would be provided to accommodate on-site employees and maintenance vehicles. Three of these parking spaces would be adjacent to the office building, and two would be in the central part of the Project Site.

The entire BESS facility would be enclosed by a 10-foot-high solid perimeter wall with security wire whose function would include safety, security, and aesthetics (see Figure 4a). The wall would be set back 30 feet from existing curb lines with landscaping outside the wall. The wall would be constructed of reinforced concrete block designed to withstand a potential explosion and prevent the passage of related projectiles, as required by the LACoFD and Chapter 8-4 of the Los Angeles County’s 2023 Building Code. The wall would also be designed to withstand a potential fire and pressure wave according to LACoFD requirements.

Page 205 of 6633 ends

Pl
Y
aceWorks
2, 4, 6 1, 3, 5

22.5093
2, 4, 6 1, 3, 5
PROJ. NO.:

NO. BY DATE REVISION APP'D.

PERMIT PLAN SET

NOT FOR

CONSTRUCTION

MARICI PROJECT, LLC
16207, 16233, AND 16285 GALE AVENUE
CITY OF INDUSTRY, CA 91745-1719
604109
DG
SH
DATE:

PROFESSIONAL ENGINEER:
3/12/2025

SUBSTATION ELEVATIONS
E-2.0
80'
50'
10'-1"
64'
4'
4' 4'
4' 4'
12'-8" 16'-5" 20' 20'-1" 12'-3" 16'-2" 13'-2"
13' 18'-7" 20'-5" 23'-4" 23'-4"
80'-5"
10'
26'
16'-6"
30'-8"
10'
21'-4"
38'-4"
24'-10"

34.5 KV

CIRCUIT

BREAKER

34.5 KV

CIRCUIT

BREAKER

34.5 KV

CIRCUIT

BREAKER

34.5 KV

CIRCUIT

BREAKER
NOTES:

1. PROJECT SECTION ELEVATIONS ARE FOR LAND PERMITTING.

EOR IS RESPONSIBLE FOR ENSURING ALL REQUIRED

CLEARANCES ARE MAINTAINED AND ALL CODES AND

STANDARDS ARE FOLLOWED AS APPLICABLE UPON
FINALIZING THE DESIGN.

2. MPT OIL CONTAINMENT PIT ASSUMED TO RISE ABOVE
GRADE WITH MPT ON A PEDESTAL IN THE CENTER. MPT
UNIT ASSUMED TO STAND APPROXIMATELY 26' TALL, WITH

ADDITIONAL HEIGHT FROM DIMENSION ACCOUNTED FOR IN
THE PEDESTAL. FINAL HEIGHT OF MPT AND REQUIRED BUS

PENDING FINAL CONTAINMENT PIT DESIGN AND SUBJECT
TO CHANGE.

3. ALL EQUIPMENT AND BUS DIMENSIONS AND DESIGN ARE

ASSUMED AS TYPICAL, ACTUAL DIMENSIONS MAY VARY
BASED ON EQUIPMENT PURCHASED.

4. NEED FOR LIGHTING MAST OF ADDITIONAL LIGHTING
PROTECTION TBD BASED ON ENGINEERING STUDY.
230 KV
45° BUS
230 KV A-FRAME WITH SURGE

ARRESTORS, MOUNTED
SWITCH, AND PTS 230 KV BUS TIE
SWITCH 1
230 KV BUS TIE
SWITCH 2
230 KV
45° BUS

34.5 KV
FEEDER

TERMINATIONS

34.5 KV

CIRCUIT

BREAKER

34.5 KV
BUS

SUPPORT
TRANSFORMER 1
(230/34.5 KV) WITH

OIL CONTAINMENT PIT
230 KV CIRCUIT 230 KV 45° BUS

BREAKER

A-FRAME AND BUSWORK - SOUTH VIEW

BREAKERS, TRANSFORMERS AND BUSWORK - WEST VIEW

A-FRAME - EAST VIEW

GRAPHIC SCALE
0 10'
1" = 10'
10'
230 KV
BUS

SUPPORT
TYPICAL 34.5 KV FEEDER TERMINATION AND

CIRCUIT BREAKER BAY - SOUTH VIEW
(DIMENSIONS ARE TYPICAL)
2, 4, 6 1, 3, 5

22.5093
2, 4, 6 1, 3, 5
PROJ. NO.:

NO. BY DATE REVISION APP'D.

PERMIT PLAN SET

NOT FOR

CONSTRUCTION

MARICI PROJECT, LLC
16207, 16233, AND 16285 GALE AVENUE
CITY OF INDUSTRY, CA 91745-1719
604109
DG
SH
DATE:

PROFESSIONAL ENGINEER:
3/12/2025

SUBSTATION ELEVATIONS
E-2.0
80'
50'
10'-1"
64'
4'
4' 4'
4' 4'
12'-8" 16'-5" 20' 20'-1" 12'-3" 16'-2" 13'-2"
13' 18'-7" 20'-5" 23'-4" 23'-4"
80'-5"
10'
26'
16'-6"
30'-8"
10'
21'-4"
38'-4"
24'-10"

34.5 KV

CIRCUIT

BREAKER

34.5 KV

CIRCUIT

BREAKER

34.5 KV

CIRCUIT

BREAKER

34.5 KV

CIRCUIT

BREAKER
NOTES:

1. PROJECT SECTION ELEVATIONS ARE FOR LAND PERMITTING.

EOR IS RESPONSIBLE FOR ENSURING ALL REQUIRED

CLEARANCES ARE MAINTAINED AND ALL CODES AND

STANDARDS ARE FOLLOWED AS APPLICABLE UPON
FINALIZING THE DESIGN.

2. MPT OIL CONTAINMENT PIT ASSUMED TO RISE ABOVE
GRADE WITH MPT ON A PEDESTAL IN THE CENTER. MPT
UNIT ASSUMED TO STAND APPROXIMATELY 26' TALL, WITH

ADDITIONAL HEIGHT FROM DIMENSION ACCOUNTED FOR IN
THE PEDESTAL. FINAL HEIGHT OF MPT AND REQUIRED BUS

PENDING FINAL CONTAINMENT PIT DESIGN AND SUBJECT
TO CHANGE.

3. ALL EQUIPMENT AND BUS DIMENSIONS AND DESIGN ARE

ASSUMED AS TYPICAL, ACTUAL DIMENSIONS MAY VARY
BASED ON EQUIPMENT PURCHASED.

4. NEED FOR LIGHTING MAST OF ADDITIONAL LIGHTING
PROTECTION TBD BASED ON ENGINEERING STUDY.
230 KV
45° BUS
230 KV A-FRAME WITH SURGE

ARRESTORS, MOUNTED
SWITCH, AND PTS 230 KV BUS TIE
SWITCH 1
230 KV BUS TIE
SWITCH 2
230 KV
45° BUS

34.5 KV
FEEDER

TERMINATIONS

34.5 KV

CIRCUIT

BREAKER

34.5 KV
BUS

SUPPORT
TRANSFORMER 1
(230/34.5 KV) WITH

OIL CONTAINMENT PIT
230 KV CIRCUIT 230 KV 45° BUS

BREAKER

A-FRAME AND BUSWORK - SOUTH VIEW

BREAKERS, TRANSFORMERS AND BUSWORK - WEST VIEW

A-FRAME - EAST VIEW

GRAPHIC SCALE
0 10'
1" = 10'
10'
230 KV
BUS

SUPPORT
TYPICAL 34.5 KV FEEDER TERMINATION AND

CIRCUIT BREAKER BAY - SOUTH VIEW
(DIMENSIONS ARE TYPICAL)
Figure 6
Substation Elevations
Source: TRC 2025.

MARICI BATTERY ENERGY STORAGE FACILIT

CITY OF INDUSTRY

Page 206 of 6633 ends

MARICI BATTERY ENERGY STORAGE SYSTEM FACILITY INITIAL STUDY / MITIGATED

NEGATIVE DECLARATION

CITY OF INDUSTRY

2. PROJECT DESCRIPTION
30 PlaceWorks
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Page 207 of 6633 ends

Plac
LITY
eWorks

MARICI BATTERY ENERGY STORAGE FACI
PROJ. NO.:

NO. BY DATE REVISION APP'D.

PERMIT PLAN SET

NOT FOR

CONSTRUCTION

MARICI PROJECT, LLC
16207, 16233, AND 16285 GALE AVENUE
CITY OF INDUSTRY, CA 91745-1719
604109
DG
SH
DATE:

PROFESSIONAL ENGINEER:
3/12/2025

TIE-LINE POLE DETAILS
C-8.0
RISER POLE 1 POINT OF CHANGE OF OWNERSHIP (POCO) 2 (NTS) JKT 12/18/24 POLE REVISION 1

GROUND LINE
102'-0"
℄
11'-0" 15'-0" 15'-0"

GROUND LINE
℄

GROUND LINE
140'-0"
℄
11'-0" 15'-0" 15'-0"

GROUND LINE
℄ SOUTH VIEW WEST VIEW SOUTH VIEW WEST VIEW
Figure 7
Tie-Line Pole Details
Source: TRC 2025.
0 Scale (Feet)
15 CITY OF INDUSTRY

Page 208 of 6633 ends

MARICI BATTERY ENERGY STORAGE SYSTEM FACILITY INITIAL STUDY / MITIGATED

NEGATIVE DECLARATION

CITY OF INDUSTRY

2. PROJECT DESCRIPTION
32 PlaceWorks
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MARICI BATTERY ENERGY STORAGE SYSTEM FACILITY INITIAL STUDY / MITIGATED

NEGATIVE DECLARATION

CITY OF INDUSTRY

2. PROJECT DESCRIPTION
DECEMBER 2025 33
Existing street trees and landscaping adjacent to the sidewalk within the right-of-way on the Gale Avenue frontage would be preserved. Existing landscaping farther away from the street and sidewalk would need to be removed for perimeter wall construction, and new perimeter landscaping would be planted. Features that would be visible above the wall include the higher items in the collector substation (see Figure 6) and the overhead electric line that would cross directly into the SCE Walnut Substation. The proposed on-site substation would be secured from unauthorized entry, with signage in accordance with code requirements for high-voltage electricity. Limiting access to the Project Site would be necessary both to ensure the safety of the public and to protect the equipment from potential theft and vandalism.

The Project Site would be closed to public access with gates that would be maintained and secure.

Internal on-site roads, access gates, and fire hydrants would be designed in accordance with LACoFD requirements. A Knox rapid access system would be provided at gates for fire department access. Roads would be designed for two-way circulation of on-site traffic, which would be minimal, consisting of visits by employees, contractors, and vendors providing periodic maintenance and monitoring visits. Project infrastructure would include two diesel-fired generators to provide backup power for critical functions. Aside from the backup generators, the project does not have any emission sources that require an emissions permit from the South Coast Air Quality Management District. Shielded, downward-directed night-lighting would be provided for safety and security.

2.3.9 Stormwater Drainage Controls and Landscaping
The final finished grade throughout the Project Site will consist of stable surfaces, including asphalt roads and parking spaces, concrete footings and slabs, landscaped areas, and gravel or asphalt in equipment areas not covered by footings or slabs. Under existing conditions, stormwater flows to a public stormwater drain in Gale Avenue that connects to a storm drain in South Stimson Avenue. This storm drain outfalls into the San Joe Creek channel. The proposed surface grading, drop inlets, and underground piping would convey stormwater to the same locations it currently flows, and peak stormwater runoff volumes would be reduced compared to existing conditions because the area of impermeable surfaces would be less (88 percent vs. 92 percent). Biofiltration systems will be included in the drainage design to remove pollutants before stormwater is discharged.

The project is designed with landscaping that exceeds the City’s 12 percent minimum requirement and is more than three feet wide at the Gale Avenue frontage and areas whose views are not obstructed from public vantage points (see Figure 8, Landscaping Plan). The project’s landscaping would comply with the City’s water efficient landscape regulations and guidelines.

Pursuant to City Municipal Code Section 13.18.060, documentation of compliance needs to be submitted prior to construction. The landscaping plan is based on drought-tolerant plant species and would include efficient drip irrigation systems.

Page 210 of 6633 ends

MARICI BATTERY ENERGY STORAGE SYSTEM FACILITY INITIAL STUDY / MITIGATED

NEGATIVE DECLARATION

CITY OF INDUSTRY

2. PROJECT DESCRIPTION
34 PlaceWorks
As shown in Figure 8, the proposed landscape plan includes the provision of numerous trees along the southern site boundary to screen the Project Site. The trees would assist in visually softening and obscuring views of the Project Site’s various components. In addition to the trees, droughttolerant, low-profile shrubs would be planted along the southern and eastern site boundaries.

Existing landscaping along Gale Avenue would be preserved.

2.3.10 Office and Storage Building
The proposed Project includes a 20-foot by 60-foot building in the northeast part of the Project Site that would contain six offices and a conference room for employees and for occasional use by contractors and vendors. The proposed Project is anticipated to have up to two employees onsite daily. The building would include a break area and sanitary facilities and would be designed with architectural elements that comply with City development guidelines (see Figure 9, Building Elevations and Colors). The proposed building would have a stucco exterior and would be 15 feet high. Five parking spaces would be included on the Project Site, including three adjacent to the proposed building.

2.3.11 Southern California Edison Facility Modifications SCE improvements associated with the proposed Project would be designed and implemented by SCE. The following description of anticipated SCE facilities is preliminary and subject to change.

Transmission
From the POCO pole in the proposed Project’s high voltage substation, three overhead 220 kV conductors and a ground wire would cross the eastern property line of the Project Site directly into the SCE Walnut Substation. The design includes a POCO pole that is 140 feet high to provide minimum required clearance passing over an existing power line located just offsite to the east.

The conductors would terminate at dead-end structures at both the proposed Project’s substation and the SCE Walnut substation. SCE would install an approximate 120-foot-tall Tubular Steel Pole with footing and approximately 600 linear feet of 220 kV conductor and ground wire between the POCO pole and an existing 220 kV position located within Walnut Substation.

Page 211 of 6633 ends

PlaceWorks

MARICI BATTERY ENERGY STORAGE FACI LITY

OE OE OE OE OE OE OE OE

UE UE UE UE UE UE UE UE

UE UE UE UE UE UE UE UE
GAS

HINNEN AVE

WARD WAY

GALE AVENUE

F F F F F F F
F
F
F
F
F
F
F
F
F
F
F

F F F F F F

F F F F

UE UE UE UE UE UE UE UE UE UE UE UE UE UE UE UE UE UE

UE UE UE UE UE UE UE UE UE UE
UE
NOTE: PRESERVED EXISTING
LANDSCAPE AREA (TYP.)
NOTE: PRESERVED EXISTING
LANDSCAPE AREA (TYP.)

UNION PACIFIC RAILWAY

ASSESSORS PARCEL NUMBER
8242-016-814
(QUASI-PUBLIC: SCE WALNUT SUBSTATION,

NOT A PART OF THE PROJECT)

ASSESSORS PARCEL NUMBER
8242-016-059
(INDUSTRIAL: WHOLESALE WAREHOUSE,

NOT A PART OF THE PROJECT)

ASSESSORS PARCEL NUMBER
8242-016-046
(INDUSTRIAL: ELECTRICAL AND

LIGHTING WHOLESALE WAREHOUSE,

NOT A PART OF THE PROJECT)

ASSESSORS PARCEL NUMBER
8242-016-043
(INDUSTRIAL: DIESEL PARTS AND

SERVICE, NOT A PART OF THE PROJECT)

ASSESSORS PARCEL NUMBER
8242-016-029
(INDUSTRIAL: NOT A PART OF THE PROJECT)

ASSESSORS PARCEL NUMBER
8242-016-062
(RECREATIONAL: VETERANS OF

FOREIGN WARS HALL, NOT PART OF PROJECT)
NOTE: PRESERVED EXISTING
LANDSCAPE AREA (TYP.)
PROJ. NO.:

NO. BY DATE REVISION APP'D.

PERMIT PLAN SET

NOT FOR

CONSTRUCTION

MARICI PROJECT, LLC
16207, 16233, AND 16285 GALE AVENUE
CITY OF INDUSTRY, CA 91745-1719
604109
DG
SH
DATE:

PROFESSIONAL ENGINEER:
3/12/2025

LANDSCAPE PLAN
L-1.0

GRAPHIC SCALE

NORTH N
0 50'
1" = 50'
50'

EXISTING FEATURES

PROPOSED FEATURES GALE AVE

S STIMSON AVE
LANDSCAPE NOTES:

1. PLEASE REFERENCE UTILITY PROTECTION AND PLANT INSTALLATION GUIDELINES AND NOTES ON SHEET L-2.0 (LANDSCAPE DETAILS).

2. LANDSCAPE AREA CALCULATIONS:
- LANDSCAPE AREA (PROPOSED): 48,421 SQ. FT.
- EXISTING LANDSCAPE AREA (PRESERVED): 2,951 SQ. FT.
- TOTAL LANDSCAPE AREA (12.81%): 51,372 SQ. FT.

GENERAL NOTES:

1. THIS PLAN SET IS SUBMITTED FOR APPLICATION AND ISSUANCE OF A

LAND USE ENTITLEMENT FOR THE PROJECT FROM THE CITY OF
INDUSTRY.

2. THE LOCATIONS OF PROPOSED IMPROVEMENTS, INCLUDING BUT NOT LIMITED TO: BATTERY ENCLOSURES, TRANSFORMERS, AUXILIARY PADS, FIRE HYDRANTS, ETC., SHOWN ARE APPROXIMATE AND ARE SUBJECT TO

REFINEMENT PRIOR TO GRADING AND BUILDING PERMIT APPLICATIONS

DUE TO SITE CONDITIONS, PERMIT REQUIREMENTS, EQUIPMENT
SPECIFICATIONS, AND/OR OTHER CONSTRAINTS.

3. CONTRACTOR SHALL CALL AT LEAST 72 HOURS PRIOR TO BEGINNING CONSTRUCTION OR EXCAVATION TO HAVE EXISTING UTILITIES LOCATED.

ADDITIONALLY, CONTRACTOR SHALL CONTACT ANY LOCAL UTILITIES THAT PROVIDE THEIR OWN LOCATOR SERVICES.

4. 2-HOUR FIRE WALL TO BE PROVIDED AT HYDRANTS THAT ARE WITHIN 25-FEET OF STRUCTURES

5. FIRE HYDRANTS TO BE PROTECTED BY A FIRE RATED WALL IF REQUIRED BY LACFD.

6. FIRE BEACONS/STROBES WILL BE INCLUDED AS PART OF DETAILED FIRE DESIGN.

7. CAMERAS WILL BE PLACED TO ENSURE VISIBILITY OF ALL MAJOR

EQUIPMENT, THIS DETAIL WILL BE CAPTURED AS PART OF THE DETAILED SECURITY DESIGN.

8. ALL PROPOSED VEHICULAR ACCESS GATES SHALL BE PROVIDED WITH A FIRE DEPARTMENT APPROVED LOCKING DEVICE.

9. BATTERY CONTAINERS SHALL BE LOCATED A MINIMUM OF 10' INSIDE

THE PROPERTY LINE IN ACCORDANCE WITH LOS ANGELES COUNTY FIRE DEPARTMENT REQUIREMENTS.

RIGHT-OF-WAY

ADJACENT PARCEL

ROAD CENTERLINE

ASPHALT PAVEMENT EDGE

CURB FACE AND BACK

STORM DRAIN MANHOLE

LIGHT POLE
TREE

RAILROAD TRACKS

CONCRETE

BUILDING

PROJECT BOUNDARY

CURB FACE AND BACK

CMU WALL W/ SECURITY WIRE

CONCRETE FIRE PROOF WALL

ASPHALT PAVEMENT

CONCRETE PAVEMENT

POWER POLE

VEHICULAR ACCESS GATE

PEDESTRIAN ACCESS GATE

BATTERY STORAGE CONTAINER

TRANSFORMER

AUXILIARY PAD

TRASH AND RECYCLING ENCLOSURE
LEGEND

QUANTITY SIZE/ROOT COMMENT
CA
3 BOTANICAL NAME/

COMMON PLANT NAME SYMBOL MATURE
HEIGHT

CINNAMOMUM CAMPHORA
CAMPHOR TREE 24" BOX 50'-65' HT. MULTI
CO1 CERCIS OCCIDENTALIS
WESTERN REDBUD 15 GAL. 12'-20' HT. MULTI

AD ARCTOSTAPHYLOS DENSIFLORA 'HOWARD MCMINN'

MANZANITA
9 CC CEANOTHUS 'CONCHA'
CEANOTHUS 20
5'-7' HT.
6'-8' HT.

DM DYMONDIA MARGARETAE
DYMONDIA 13,770 SF

MR MUHLENBERGIA RIGENS
DEERGRASS 209

BD BUCHLOE DACTYLOIDES
BUFFALO GRASS 30,675 SF
64/FLAT
#1 CONT.

SOD
1"-3" HT.
3'-5' HT.
4"-6" HT.
#5 CONT.
#5 CONT.

EXISTING LANDSCAPING (PRESERVED)

DECIDUOUS AND STREET TREES
SHRUBS

GRASS, MEADOW, AND GROUND COVER
LEGEND

OE OE OE OE OE OE OE OE
GAS

HINNEN AVE

WARD WAY

F F F F F F F
F
F
F
F

F F F F

UE UE UE UE UE UE UE UE UE UE UE UE UE UE UE UE UE UE

UE UE UE UE UE UE UE UE UE UE
UE

ASSESSORS PARCEL NUMBER
8242-016-059
(INDUSTRIAL: WHOLESALE WAREHOUSE,

NOT A PART OF THE PROJECT)

ASSESSORS PARCEL NUMBER
8242-016-046
(INDUSTRIAL: ELECTRICAL AND

LIGHTING WHOLESALE WAREHOUSE,

NOT A PART OF THE PROJECT)

ASSESSORS PARCEL NUMBER
8242-016-043
(INDUSTRIAL: DIESEL PARTS AND

SERVICE, NOT A PART OF THE PROJECT)

ASSESSORS PARCEL NUMBER
8242-016-029
(INDUSTRIAL: NOT A PART OF THE PROJECT)

ASSESSORS PARCEL NUMBER
8242-016-062
(RECREATIONAL: VETERANS OF

FOREIGN WARS HALL, NOT PART OF PROJECT)
NOTE: PRESERVED EXISTING
LANDSCAPE AREA (TYP.)
LEGEND

QUANTITY SIZE/ROOT COMMENT
CA
3 BOTANICAL NAME/

COMMON PLANT NAME SYMBOL MATURE
HEIGHT

CINNAMOMUM CAMPHORA
CAMPHOR TREE 24" BOX 50'-65' HT. MULTI
CO1 CERCIS OCCIDENTALIS
WESTERN REDBUD 15 GAL. 12'-20' HT. MULTI

AD ARCTOSTAPHYLOS DENSIFLORA 'HOWARD MCMINN'

MANZANITA
9 CC CEANOTHUS 'CONCHA'
CEANOTHUS 20
5'-7' HT.
6'-8' HT.

DM DYMONDIA MARGARETAE
DYMONDIA 13,770 SF

MR MUHLENBERGIA RIGENS
DEERGRASS 209

BD BUCHLOE DACTYLOIDES
BUFFALO GRASS 30,675 SF
64/FLAT
#1 CONT.

SOD
1"-3" HT.
3'-5' HT.
4"-6" HT.
#5 CONT.
#5 CONT.

EXISTING LANDSCAPING (PRESERVED)

DECIDUOUS AND STREET TREES
SHRUBS

GRASS, MEADOW, AND GROUND COVER
Figure 8
Landscaping Plan
Source: TRC 2025.
0 Scale (Feet)
130

CITY OF INDUSTRY

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PlaceWorks

MARICI BATTERY ENERGY STORAGE FACIL ITY
1 STUCCO WITH INTEGRAL COLOR
FIELD COLOR : DE 6211 LIGHT BEIGE

EXTERIOR COLOR LEGEND
(DUNN EDWARDS PAINT OR EQUAL)
2 STUCCO WITH INTEGRAL COLOR
ACCENT COLOR : DE 6214 PIGEON GRAY
3 STUCCO WITH INTEGRAL COLOR
ACCENT COLOR : DE 6058 THICK FOG
3 1 3
2 3 3
2 3 1 3
2 3
3 1 3
2 3
3 1 3
2 3
3 2 2
2 2
3 2
3 PROJ. NO.:

NO. BY DATE REVISION APP'D.

PERMIT PLAN SET

NOT FOR

CONSTRUCTION

MARICI PROJECT, LLC
16207, 16233, AND 16285 GALE AVENUE
CITY OF INDUSTRY, CA 91745-1719
604109
DG
SH
DATE:

PROFESSIONAL ENGINEER:
3/12/2025

BUILDING ELEVATIONS AND COLORS
A-3
COLOR - WEST ELEVATION 1/4"= 1'-0"
1/4"= 1'-0"
JAN-31-2025
COLOR - SOUTH ELEVATION 1/4"= 1'-0" COLOR - EAST ELEVATION COLOR - NORTH ELEVATION 1/4"= 1'-0"

GRAPHIC SCALE
0 4'
1/4" = 1'
4'
(1"=4')
2'
1 STUCCO WITH INTEGRAL COLOR
FIELD COLOR : DE 6211 LIGHT BEIGE

EXTERIOR COLOR LEGEND
(DUNN EDWARDS PAINT OR EQUAL)
2 STUCCO WITH INTEGRAL COLOR
ACCENT COLOR : DE 6214 PIGEON GRAY
3 STUCCO WITH INTEGRAL COLOR
ACCENT COLOR : DE 6058 THICK FOG
3 1 3
2 3 3
2 COLOR - WEST ELEVATION 1/4"= 1'-0"
/4"= 1'-0"
Figure 9
Building Elevations and Colors
Source: TRC 2025.
0 Scale (Feet)
8 CITY OF INDUSTRY

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Substation
The proposed Project’s 220 kV line would be terminated at the dead-end structure of an existing 220 kV position within the SCE Walnut Substation. To accommodate the proposed Project’s line terminating at the existing position, the existing SCE Mesa 220 kV line would be relocated to a new double bus-double breaker 220 kV position within the SCE Walnut Substation. Additional physical structures include two 220 kV circuit breakers, four disconnect switches, 220 kV bus work, support structures, underground conduit and cabling, and breaker/line protection. New 220 kV conductor and ground wire would be installed from the new 220 kV position to an existing transmission tower within the SCE Walnut Substation.

Communications
The proposed Project includes the installation of two diverse communications routes between the proposed Project’s substation and the SCE Walnut Substation. SCE would install communications fiber from two 4x4x6 manhole structures (POCO) located along the eastern Project Site property line to the existing SCE Walnut Substation communications room. For one route, SCE will install approximately 700 linear feet of new fiber in a new underground conduit.

For the second route, SCE will install approximately 600 linear feet of new fiber in a new underground conduit.

Construction equipment and methods for SCE’s work within the SCE Walnut Substation is similar to that which would on the Project Site under the proposed Project. It is anticipated that SCE would construct interconnection facilities during the later months of BESS construction, to be completed when the BESS construction is complete. All SCE construction would be within already developed areas.

2.3.12 Operation and Maintenance Activities
The BESS is designed for remote operation and would be available to charge or discharge electric energy 24 hours per day and seven days per week. One or two staff would be on-site as needed.

In addition to on-site staff, the proposed Project is expected to typically require a four- to sixperson crew for maintenance visits, once every two to three months on average. The proposed Project is estimated to generate six to ten direct technical jobs for site staff, periodic maintenance crews, and technicians. Water demand for operations would be minimal and limited to occasional flushing of fire water supply systems; potable water for a break room and restroom for the employees, contractors, and vendors; and water for landscaping to meet City requirements.

Electrical equipment and motors and fans for cooling the electrical equipment would generate low levels of noise, typically in the range of 60 to 80 dBA within several feet. Equipment would be

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set back from property lines, and the 10-foot-high reinforced concrete perimeter would attenuate noise between the sources and the property line.

WASTE GENERATION
The proposed Project would not generate litter or large waste streams. Waste generated during routine operations would primarily be small quantities of packaging and shipping materials from occasional equipment replacement or maintenance, and small quantities of household-type waste from maintenance crews.

The proposed Project would occasionally generate spent batteries that would be returned to the battery manufacturer for recycling. Other equipment may also require replacement from time to time and would be removed from the site and recycled or disposed of in accordance with applicable State regulations for waste management.

Small quantities of hazardous waste such as aerosol cans or used rags may be generated by some maintenance activities and would be managed in accordance with California Code of Regulations Title 22 (22 CCR) requirements. Electronic waste would be managed as Universal Waste in accordance with 22 CCR.

OIL SPILL PREVENTION, CONTROL, AND COUNTERMEASURES
Oil-filled transformers would be subject to the Code of Federal Regulations Title 40, Part 112, and California Health and Safety Code Chapter 6.67 requirements for development and implementation of a Spill Prevention Control and Countermeasures Plan (SPCC), including secondary containment for aboveground bulk oil storage containers; routine inspections for oil containment integrity and ensuring collected stormwater is oil-free before it is released; and contingency planning for prompt and appropriate response to a potential release. SPCC requirements would also apply if a bulk fuel tank were provided on-site during construction.

HAZARDOUS MATERIALS, DESIGN SAFETY FEATURES, AND CONTINGENCY

PLANNING
No routine storage of hazardous materials is anticipated, but some on-site equipment could contain hazardous materials. These include mineral oil in transformers, pressurized gas and coolant in climate control equipment, and backup generator fuel. Lithium-ion batteries occasionally become damaged and would be hazardous. The precise volume of mineral oil that would be present on-site as well as the quantities of lithium-ion batteries and refrigerant would not be known until equipment is selected for final design. Additional materials with a hazard of pressure release may also be included in the final design, such as compressed nitrogen in cylinders and fire suppression agent in equipment enclosures. All hazardous materials on-site that meet California Hazardous Materials Business Plan reporting requirements would be reported to

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the online California Environmental Reporting System, including quantities, locations, largest containers, hazardous characteristics, and emergency response planning.

The proposed Project is required to obtain permits from the LACoFD for hazardous materials use and for battery energy storage, and Applicant coordination with LACoFD is required by the City as part of the application process, including submittal of a hazardous material disclosure form. The proposed Project is required to comply with all applicable regulations and standards for hazardous materials usage, including but not limited to, preparation of a Hazardous Materials Business Plan for hazardous materials in reportable quantities; a Spill Prevention, Control and Countermeasure Plan for oil storage in transformers and other equipment; and emergency response plans in accordance with multiple regulations.

DECOMMISSIONING
The proposed BESS is designed to be in operation for 35 years. After completion of operations, if not repowered with then-current technology, the proposed Project would be decommissioned, and equipment and facilities would be removed from the site except as agreed by the landowner and the City. The proposed Project would include measures to ensure the collection and recycling of batteries and to avoid the potential for batteries to be disposed of as municipal waste. All decommissioning activities would adhere to the requirements set by the City and be in accordance with all applicable federal and state regulations at the time of decommissioning and as determined by the City.

All equipment would be de-energized prior to removal, salvaged (where possible), placed in appropriate shipping containers, and secured in a truck transport trailer for shipment off-site to be recycled or disposed of at an appropriately licensed disposal facility. The demolition debris and removed equipment may be cut or dismantled into pieces that can be safely lifted or carried with the equipment being used. A collection and recycling program would be implemented during the decommissioning phase to promote recycling of the proposed Project’s components and to minimize disposal in landfills.

APPLICANT PROPOSED MEASURES
To mitigate any potential impacts related to hazards and hazardous materials, the following Applicant-Proposed Measures (APM) will be implemented as a part of the proposed Project.  APM-1, Best Management Practices. The project applicant will implement the Revised Soil and Groundwater Management Plan (SGMP) prepared for the proposed Project, which outlines best management practices (BMPs) for use in the event impacted soil or groundwater is encountered during construction of the proposed Project (Appendix K). The detailed list of BMPs to be implemented are outlined in the SMGP.

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 APM-2, Vapor Intrusion Mitigation System. A vapor intrusion mitigation system (VIMS) will be implemented for the proposed office building to address the documented soil gas concentrations detected on-site.
 APM-3, Emergency Action Plan. The project applicant will prepare an Emergency Action Plan (EAP) for submittal to and approval by the Occupational Safety and Health Administration (OSHA) in accordance with the provisions of Standard 1910.38 (Emergency action plans) of Part 1910 (Occupational Safety and Health Standards). A copy of the OSHA-approved EPA will be submitted to the City of Industry for its records.
 APM-4, Emergency Response Plan. To mitigate exposure to carbon monoxide and smoke as a result of a potential (although unlikely) runaway thermal event, an emergency response plan will be prepared by a qualified fire safety engineer for the specific design of the proposed BESS facility pursuant to the Los Angeles County Fire Department’s requirements. The plan will be reviewed and approved by the Los Angeles County Fire Department during the building permit process.

To mitigate any potential impacts related to biological resources, the following APM will be implemented as a part of the proposed Project.
 APM-5, Pre-construction Nesting Bird Survey. If construction is scheduled to commence during the nonnesting season (i.e., September 1 to January 31), no preconstruction surveys or additional measures are required. To avoid impacts to nesting birds on the project site, a qualified wildlife biologist shall conduct preconstruction surveys of all potential nesting habitat within the project site for construction activities that are initiated during the breeding season (i.e., February 1 to August 31). The surveying biologist must be qualified to determine the status and stage of nesting by migratory birds and all locally breeding raptor species without causing intrusive disturbance. The raptor survey shall focus on potential nest sites (e.g., cliffs, large trees, windrows) around the project site. Surveys shall be conducted no more than 14 days prior to construction activities. If active nests are found, a suitable buffer (e.g. 200-300 feet for common raptors; 30-50 feet for passerine species) shall be established around active nests and no construction within the buffer allowed until a qualified biologist has determined that the nest is no longer active (e.g. the nestlings have fledged and are no longer reliant on the nest). Encroachment into the buffer may occur at the discretion of a qualified biologist.

Implementation of the APMs would be provided as conditions of approval of the proposed Project and would be ensured through the City’s building plan check and development review process.

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2.3.13 Project Phasing and Construction
The proposed Project is scheduled to start construction in February 2026 and is expected to achieve its commercial operations date by early 2027. Project development, specifically all proposed improvements to be conducted within the confines of the Project Site, is anticipated to be completed in three general development phases: site preparation, including demolition, clearing, and grading; system construction and installation; and testing, commissioning, and cleanup.

The proposed Project would comply with the Occupational Safety and Health Administration Standards during and after the construction phase. Additionally, NFPA 70E Standards for hot electrical work would be strictly adhered to and enforced.

Construction would start with the removal of existing buildings, foundations, asphalt, concrete, and landscaping in the area to be developed. The existing street trees on the Gale Avenue frontage would be preserved, and additional street trees would be planted where existing driveways are removed for project construction. After all hazardous materials and universal wastes are removed from the buildings and fuel and water and power sources have been safely disconnected, the buildings, foundations, asphalt, and concrete would be demolished and the debris hauled off-site using common construction equipment such as excavators, bulldozers, and haul trucks. Most demolition debris would be metal and concrete rubble that would be sent to a recycler following City and State requirements. Because the Project Site is currently developed and relatively flat, minimal grading would be required to prepare the site for redevelopment.

Rough grading would include conditioning foundation areas as needed to achieve proper and consistent compaction in the subgrade and over the rough graded surface, and achieving a cut/fill balance. Finish grading would consist of bringing the ground surface elevation contours to final grade with a gentle slope for positive drainage.

The existing SCE electric distribution line through the site would be maintained during demolition and grading until the replacement line can be installed and commissioned. Then the existing overhead line would be removed.

Following grading, BESS equipment foundations would be installed. Equipment placement and MV underground duct bank installation would begin after the equipment foundations have adequately cured. The on-site substation and SCE interconnection improvements would overlap with BESS equipment installation and would be scheduled to accommodate testing and commissioning prior to the scheduled commercial operating date. Installation of foundations, equipment, and underground duct banks and construction of the collector substation and interconnection improvements would use conventional earthmoving and building equipment, such as a truck-mounted drills, water truck, dump trucks, loader/backhoes, bobcats, man-lifts, and cranes. SCE would be responsible for all construction within the Walnut Substation.

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A water truck would be kept on-site during construction and used to prevent excessive dust in accordance with South Coast Air Quality Management District (AQMD) requirements. The construction contractor would comply with all applicable South Coast AQMD requirements during construction. Permits to construct would be obtained from South Coast AQMD for the back-up generators.

Staging and parking for site construction would occur on-site as work progresses. If bulk fuel is temporarily stored on-site for construction, secondary containment would be provided. Sanitary facilities for construction workers would be provided by portable, self-contained units maintained by a licensed contractor. Staging and parking for SCE’s construction is expected to occur within currently developed SCE property.

All constructed electrical equipment would be inspected and tested as appropriate prior to energizing. Construction would occur in strict accordance with all applicable local, state, and federal safety regulations, and a safety professional would be on-site full-time to monitor and implement a comprehensive project-specific safety program. Dust and construction emission controls would be implemented in accordance with South Coast AQMD requirements.

Construction would occur in compliance with the State General Permit for stormwater discharges from construction sites, including implementation of a Storm Water Pollution Prevention Plan (SWPPP) with best management practices developed by a California Qualified SWPPP Developer and implemented by a Qualified SWPPP Practitioner. Areas where construction is complete or would not be active for an interim period would be stabilized as soon as practical. Compliance with the General Permit would continue until it is demonstrated to the Regional Water Quality Control Board that surface stabilization is complete and a Notice of Termination is accepted.

Waste generation from demolition would be short term and would be mostly recyclable materials, including concrete, asphalt, steel, and other metals. Waste from construction would primarily be reusable or recyclable packaging and shipping material such as wood pallets and crates, cardboard, and plastic.

2.4 REQUIRED PERMITS AND APPROVALS

2.4.1 Discretionary Actions and Approvals
Under CEQA Guidelines Section 15357, a discretionary action means a project that calls for an exercise of judgment or deliberation when the public agency (for the proposed Project, the public agency is the City of Industry) decides to approve or disapprove a particular activity, as distinguished from situations where the public agency or body merely has to determine whether there has been conformity with applicable statutes, ordinances, regulations, or other fixed standards. Industry is the lead agency under CEQA and has the principal approval authority over

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the proposed Project. Following is a list of the discretionary actions and approvals required for implementation of the proposed Project.
 Adoption of a Mitigated Negative Declaration and Mitigation Monitoring and Reporting Program
 Approval of Zone Code text amendment (Zone Amendment No. 24-07) to allow the use with a CUP
 Approval of a Conditional Use Permit (CUP No. 24-03)
 Approval of Development Plan Application – Long Form (Development Plan No. 24-09)  Approval of a Community Benefit Agreement (DA No. 25-01)  Approval of a ROW Agreement (street improvement permit)  Approval of an Easement Agreement
Additionally, City review of the proposed Project would produce a comprehensive set of draft conditions of approval that would be available for public review prior to consideration of the proposed Project for approval by the City’s decision-making body. If approved, the proposed Project would be required to comply with all imposed conditions of approval in addition to mitigation measures included in this MND.

2.4.2 Non-discretionary Actions and Approvals
Under CEQA Guidelines Section 15369, non-discretionary or ministerial actions or approvals are those that involve little or no discretion but merely apply a checklist or clear requirements to the facts as presented and are often issued over the counter by a county or city staff (e.g., connections to utility infrastructure). These actions or approval are ones that require only conformance with a fixed standard or objective measurement and require little or no personal judgment by a government agency as to the wisdom or manner of carrying out the action. Generally, nondiscretionary or ministerial permits require a public official to determine only that the project conforms with applicable zoning and building code requirements and that applicable fees have been paid.

The nondiscretionary/ministerial approvals required for implementation of the proposed Project include the issuance of demolition, grading, and building permits.

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DECEMBER 2025 47

3. ENVIRONMENTAL EVALUATION
This section includes a checklist for each environmental topic, evaluates the significance criteria in the checklists, and, if necessary, provides mitigation measures to reduce potential impacts.

I. Aesthetics
Except as provided in Public Resources Code Section 21099, would the project:

Issues
Potentially
Significant
Impact
Less-thanSignificant
Impact
with
Mitigation
Incorporated
Less-thanSignificant
Impact
No
Impact
a) Have a substantial adverse effect on a
scenic vista? ☐ ☐ ☐ ☒
b) Substantially damage scenic resources,
including, but not limited to, trees, rock
outcroppings, and historic buildings within
a state scenic highway?
☐ ☐ ☐ ☒
c) In nonurbanized areas, substantially
degrade the existing visual character or
quality of public views of the site and its
surroundings? (Public views are those that
are experienced from publicly accessible
vantage point). If the project is in an
urbanized area, would the project conflict
with applicable zoning and other
regulations governing scenic quality?
☐ ☐ ☒ ☐
d) Create a new source of substantial light or
glare which would adversely affect day or
nighttime views in the area?
☐ ☐ ☒ ☐

DISCUSSION
a) Have a substantial adverse effect on a scenic vista? No Impact. For purposes of determining significance under CEQA, a scenic vista is generally considered a viewpoint that provides expansive views of a highly valued landscape for the benefit

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of the general public. Some scenic vistas are officially designated by public agencies. Vistas provide visual access or panoramic views to a large geographic area and are generally located at a point where surrounding views are greater than one mile away. Panoramic views are usually associated with vantage points over a section of urban or natural areas that provide a geographic orientation not commonly available. Examples of panoramic views might include an urban skyline, valley, mountain range, a large open space area, the ocean, or other water bodies. A substantial adverse effect to a scenic vista is one that degrades the view from such a designated view spot.

As shown in Figure 3, Aerial Photograph, the Project Site is heavily disturbed and in an urbanized area of the City that is surrounded by a mix of industrial, warehouse, and residential uses to the south in the unincorporated community of Hacienda Heights. The urban landscape character and features of the Project Site and surrounding area are consistent with and typical of urbanized areas of Industry. The proposed Project is an industrial project that would be consistent with the type of development in the area, which mainly consists of industrial and warehouse uses to the north, east, and west. The Project Site and surrounding area do not contain any visual resources or scenic vistas. Additionally, the City’s General Plan does not designate any areas within the City as scenic vistas or visual resources (Industry 2014).

Furthermore, overall site topography can be characterized as relatively flat, with no notable change in elevation. There are no visible landforms (e.g., mountains, hills, creeks) from the Project Site or surrounding area; and no landforms are on or within proximity of the Project Site. Also, there are no designated open space resources on-site or in the vicinity of the Project Site, a designation typically used to determine the value of certain public vistas in order to gauge adverse effects. Therefore, based on the preceding, no impact would occur, and no mitigation measures are necessary.
b) Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway? Scenic highways are a unique component of the region’s circulation system as they traverse areas of scenic or aesthetic value. Per Caltrans, a highway may be designated as scenic depending on how much of the natural landscape can be seen by travelers, the scenic quality of the landscape, and the extent to which development intrudes upon the traveler's enjoyment of the view (Caltrans 2025).

The Project Site is in an urbanized area of the City and is not within or near an official statedesignated scenic highway or an eligible state scenic highway. The nearest eligible state scenic highway is California State Route 57 (CA-57), between State Route 90 and State Route 60, and is approximately 6.5 miles east of the Project Site. The nearest official state-designated scenic highway is California State Route 91 (CA-91), between State Route 55 and South Weir Canyon Road near Anaheim Hills, and is approximately 16.8 miles southeast of the Project Site (Caltrans

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2018). Due to the distance, topography, and intervening development, the proposed Project would not impact scenic resources within a state scenic highway.

Furthermore, the Project Site area does not contain unique or locally important scenic resources.

There are no rock outcroppings, significant vegetation, or historic buildings on-site. The existing industrial, warehouse, and manufacturing buildings on the Project Site are not of historic significance.

Therefore, no impact would occur, and no mitigation measures are necessary. c) In nonurbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from publicly accessible vantage point). If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality? The assessment of aesthetic impacts is subjective by nature. Aesthetics generally refers to the identification of visual resources and their quality, as well as an overall visual perception of the environment. The Project Site is in an area of the City that qualifies as an “urbanized area”.

The Project Site is in an urbanized area of the City that is surrounded by a mix of industrial, warehouse, and residential uses to the south in the unincorporated community of Hacienda Heights. The urban landscape character of the Project Site is consistent with the surrounding uses and the urbanized areas of the City. As shown in Figure 3, the Project Site is currently developed with 161,781 square feet of building space and approximately 205,000 square feet of asphalt and concrete surfacing. Other site features include surface parking areas; outdoor storage and loading/unloading areas; driveways that connect to the internal parking and circulation improvements; and various hardscape and landscape improvements.

Project Construction Phase
Project construction activities would occur from February 2026 till early 2027 and would temporarily change the visual character of the Project Site and its surroundings. These effects would be typical of any site in Industry that undergoes development or redevelopment.

Construction activities may be unsightly during the site preparation and construction phases; however, they would be temporary and would cease upon completion.

Additionally, and where necessary, construction fencing would be erected to help shield the construction areas and would also be temporary. The typical fencing to be provided (i.e., chainlink fencing with mesh fabric or similar screening material) would screen views of the construction site, including stockpiles, graded areas, construction equipment, and building materials.

Therefore, Project-related construction activities would not have a significant effect on the existing visual character or quality of the Project Site and its surroundings. Impacts would be less than significant, and no mitigation measures are necessary.

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Project Operation Phase
The proposed Project includes the operation of an approximately 400-megawatt BESS facility and associated site and infrastructure improvements on the Project Site. Figure 4a, Proposed Site Layout, illustrates the layout of the proposed BESS facility and associated improvements and equipment. Figures 5 and 6, Proposed Site Elevations, illustrate how the proposed Project would appear from the surrounding roadways and properties. Other site improvements include power inverters, transformers and other outdoor electrical equipment, telecommunication facilities, and site access, security, parking, and landscape improvements.

As shown in Figure 4a, Proposed Site Layout, the collector substation would be located in the southeastern part of the Project Site, just south and east of the battery enclosures. Figure 6, Substation Elevation, illustrates the profile view and the various components of the substation.

As seen in Figure 7, Tie-Line Pole Details, an A-frame, riser pole, and POCO pole would be 80.5 feet, 102 feet, and 140 feet, respectively.

The proposed Project design would conform with the design parameters and standards of Title 17, Zoning, of the Industry Municipal Code, which is ensured through the City’s development review process. The proposed Project would be designed and constructed in accordance with the applicable provisions of Title 17, including those related to landscaping, screening, and setbacks.

Also, as shown in Figure 9, Landscaping Plan, the proposed landscape plan includes the provision of trees along the northern boundary to further help screen the improvements of the Project Site.

The trees would assist in visually softening and impeding views of the Project Site’s various components as seen from Gale Avenue and residential uses to the south across Gale Avenue. In addition to the trees, the existing landscaping would be utilized along Gale Avenue. The Project Site would also include landscaping along the northeast part of Ward Way. This would include shrubs and ground cover. The proposed landscaping would occur within the setback provided along the Gale Avenue and Ward Way Project Site frontage.

Project design would also go through the City’s building plan check and development review process, which would ensure that the Project is implemented in a manner that would provide visual cohesiveness and compatibility along the Project Site frontages and with its surroundings.

Furthermore, the proposed Project would be consistent with the surrounding industrial uses and urban character as it would introduce a use that is compatible with the Project Site and its surroundings. Project development would not introduce a land use that is incompatible with the industrial nature and character of the surrounding area.

Based on the preceding, the proposed Project would not conflict with applicable zoning or regulations governing scenic quality, nor would it substantially degrade the visual character or quality of the Project Site and its surroundings. Therefore, impacts would be less than significant, and no mitigation measures are necessary.

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d) Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area?
Lighting effects are associated with the use of artificial light during the evening hours. There are two primary sources of light—light emanating from building interiors passing through windows and openings, and light from exterior sources (i.e., street lighting, architectural building illumination, security lighting, parking lot lighting, landscape lighting, and signage). Excessive light and/or glare can impair vision, cause a nuisance, affect sleep patterns, and generate safety hazards when experienced by drivers. Uses such as residences, elderly care facilities, schools, and hotels are considered light sensitive, since occupants have expectations of privacy during evening hours and may be subject to disturbance by bright light sources. Light spill or trespass is considered a nuisance and is typically defined as the presence of unwanted light on properties adjacent to the property being illuminated. With respect to lighting, the degree of illumination may vary widely depending on the amount of light generated, height of the light source, presence of barriers or obstructions, type of light source, and weather conditions.

Glare is primarily a daytime occurrence caused by the reflection of sunlight or artificial light on surfaces of buildings or objects, including highly polished surfaces such as glass windows or reflective materials and, to a lesser degree, from broad expanses of light-colored surfaces.

Perceived glare is the unwanted and potentially objectionable sensation experienced by a person as they look directly into the light source of a luminaire. Daytime glare generation is common in urban areas and is typically associated with buildings with exterior façades largely or entirely composed of highly reflective glass. Daytime glare can also be generated by light reflecting off passing or parked cars. Glare is produced during evening and nighttime hours by the reflection of artificial light sources such as automobile headlights. Glare generation is typically related to either moving vehicles or sun angles, although glare resulting from reflected sunlight can occur regularly at certain times of the day and year. Excessive glare not only impedes visibility but also increases the ambient heat reflectivity in a given area. Glare-sensitive uses include residences, hotels, transportation corridors, and aircraft landing corridors.

As shown in Figure 3, the Project Site is in an urbanized, heavily disturbed site and is surrounded by a mix of industrial and warehouse uses, which are not considered light-sensitive receptors (land uses that are sensitive to lighting). However, residential uses are located south of the Project Site and are considered light-sensitive receptors. Additionally, sources of light and glare already exist on-site and in the surrounding area.

Project Construction Phase
Construction activities that would occur within the Project Site would be limited to the hours set forth by Los Angeles County, which prohibits construction between 8 PM and 6:30 AM on weekdays and Saturdays, and all day on Sundays. With the exception of illumination during nighttime hours for safety and security purposes, no other nighttime lighting would be required until the proposed Project is operational. Additionally, construction activities are not anticipated

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to result in flat, shiny surfaces that would reflect sunlight or cause other natural glare and all material resulting from building demolition within the Project Site would be removed from the Project Site. Therefore, no short-term, construction-related impacts associated with light and glare would occur. Impacts would be less than significant, and no mitigation measures are necessary.

Project Operation Phase
Daytime Glare
The proposed Project will introduce buildings and structures on the Project Site that would be visible from the surrounding roadways and properties. These include the substation, battery energy storage enclosures for the lithium-ion batteries, power inverters and transformers, and overhead telecommunication equipment. However, the buildings and structures would not include reflective elements or materials such as glass windows and doors; the building and structures would be constructed of non-reflective materials and not result in any daytime glare.

Therefore, daytime glare impacts from Project-related buildings and structures would be less than significant and no mitigation measures are necessary.

Nighttime Lighting and Glare
Under existing conditions, the Project Site is developed with uses that currently contain sources of artificial lighting on-site. Project operation would introduce new sources of artificial light to the Project Site and surrounding area. These new sources of artificial lighting have the potential to increase nighttime light and glare in the project area, as well as create off-site light spill or trespass. Nighttime lighting and glare from the Project Site would be visible from the surrounding roadways and land uses.

Exterior security lighting for the BESS facility would be provided from dusk until dawn. Permanent motion-sensitive, directional security lights would be installed on-site to provide adequate illumination around the Project Site and points of ingress/egress. The proposed lighting system would provide operations and maintenance personnel with illumination for both normal and emergency conditions. Lighting would be designed to provide the minimum illumination needed to achieve safety and security objectives.

Although Project development would introduce new light sources to the Project Site and surrounding area, the proposed light sources would be similar to existing on-site lighting and to those of the surrounding mix of industrial, warehouse, and residential uses. Considering the existing sources of lighting on-site and in the surrounding vicinity, the amount and intensity of nighttime lighting proposed on-site would not be substantially greater than existing lighting. It is unlikely that conventional lighting and illuminated operations under the proposed Project would discernibly, much less adversely, affect ambient light conditions.

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Additionally, all exterior lighting will be oriented inward into the Project Site so as not to interfere with adjacent areas or vehicular traffic on adjacent public streets. Lighting provisions are intended to prevent glare, light trespass, and light pollution. All proposed exterior lighting would be designed, arranged, installed, directed, shielded, operated, and maintained in such a manner as to contain direct illumination on-site and prevent light and glare impacts -, thereby preventing excess illumination and light spillover onto surrounding land uses and/or roadways. Through the City’s established site plan review processes, the City would ensure that final design of the proposed Project effectively minimizes potential light/glare overspill onto adjacent properties or roadways.

Furthermore, as shown in Figure 4a, the western and southern site boundaries would include the construction of a ten-foot wall. Construction of the wall along the southern boundary would help shield light and glare generated from the Project Site onto the residential uses to the south of the Project Site.

The provision of a minimum 10-foot-high solid perimeter wall would ensure that the proposed Project does not result in significant light impacts on surrounding uses or roadways. Compliance with these provisions is ensured through the City’s development review and building plan check process. Therefore, operational nighttime light and glare impacts related to the on-site improvements would be less than significant and no mitigation measures are necessary.

II. Agriculture and Forestry Resources
In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Dept. of Conservation as an optional model to use in assessing impacts on agriculture and farmland. In determining whether impacts to forest resources, including timberland, are significant environmental effects, lead agencies may refer to information compiled by the California Department of Forestry and Fire Protection regarding the state’s inventory of forest land, including the Forest and Range Assessment Project and the Forest Legacy Assessment project; and forest carbon measurement methodology provided in Forest Protocols adopted by the California Air Resources Board. Would the project:

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Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Convert Prime Farmland, Unique
Farmland, or Farmland of Statewide
Importance (Farmland), as shown on the
maps prepared pursuant to the Farmland
Mapping and Monitoring Program of the
California Resources Agency, to nonagricultural use?
☐ ☐ ☐ ☒
b) Conflict with existing zoning for
agricultural use, or a Williamson Act
contract?
☐ ☐ ☐ ☒
c) Conflict with existing zoning for, or cause
rezoning of, forest land (as defined in
Public Resources Code Section 12220(g)),
timberland (as defined by Public Resources
Code Section 4526), or timberland zoned
Timberland Production (as defined by
Government Code Section 51104(g))?
☐ ☐ ☐ ☒
d) Result in the loss of forest land or
conversion of forest land to non-forest
use?
☐ ☐ ☐ ☒
e) Involve other changes in the existing
environment which, due to their location
or nature, could result in conversion of
Farmland, to non-agricultural use or
conversion of forest land to non-forest
use?
☐ ☐ ☐ ☒

DISCUSSION
a) Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use? The Project Site is mapped as Urban and Built-Up Land, and not as farmland on the California Important Farmland Finder (DOC 2022). As shown in Figure 2.3, Aerial Photograph, the Project Site is in a highly urbanized area of the City, and is mainly surrounded by industrial and warehouse land uses and residential uses. The Project Site does not contain farmland or other agricultural uses and is not adjacent or in proximity to such uses. Therefore, the proposed Project would not

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convert mapped farmland to nonagricultural use. No impact would occur, and no mitigation measures are necessary.
b) Conflict with existing zoning for agricultural use, or a Williamson Act contract? According to the City’s zoning map, the Project Site is zoned Industrial. As shown in Figure 2.3, Aerial Photograph, the Project Site is urbanized and heavily disturbed and is surrounded predominantly by industrial and warehouse land uses. The Project Site does not contain active farmland or other agricultural uses and is not adjacent or in proximity to such uses. Additionally, the Project Site is not subject to a Williamson Act contract (CDC 2018). Therefore, Project implementation would not conflict with zoning for agricultural uses or a Williamson Act contract.

Accordingly, no impact would occur, and no mitigation measures are necessary. c) Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code Section 12220(g)), timberland (as defined by Public Resources Code Section 4526), or timberland zoned Timberland Production (as defined by Government Code Section 51104(g))?
Forest land is defined as “land that can support 10-percent native tree cover of any species, including hardwoods, under natural conditions, and that allows for management of one or more forest resources, including timber, aesthetics, fish and wildlife, biodiversity, water quality, recreation, and other public benefits” (California Public Resources Code § 12220(g)). Timberland is defined as “land…which is available for, and capable of, growing a crop of trees of any commercial species used to produce lumber and other forest products, including Christmas trees” (California Public Resources Code § 4526).

As shown in Figure 3, Aerial Photograph, the Project Site is urbanized and heavily disturbed (developed with industrial uses and adjacent to an electrical substation) and is surrounded predominantly by industrial and warehouse land uses. The Project Site is zoned Industrial. It is not zoned for agricultural use, and no such uses are present on-site or nearby. Additionally, the Industry General Plan and Municipal Code do not provide for any forest land preservation in the City, as there is no forest land within the City’s jurisdiction. Furthermore, all trees on the Project Site are ornamental trees and are not cultivated for forest resources. Therefore, the proposed Project would not conflict with agricultural zoning. No impact would occur, and no mitigation measures are necessary.
d) Result in the loss of forest land or conversion of forest land to non-forest use? See response to Section II.c, above. The Project Site is not designated or zoned for forest or timber land or used for forestry. As stated above, it is zoned Industrial. As substantiated in this section, no impact would occur, and no mitigation measures are necessary.

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e) Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use or conversion of forest land to non-forest use?
See responses to Sections 3.2.a, b, and c, above. The Project Site does not contain farmland or other agricultural uses and are not adjacent to or in proximity to such uses. As substantiated in these sections, no impact would occur, and no mitigation measures are necessary.

III. Air Quality
Where available, the significance criteria established by the applicable air quality management district or air pollution control district may be relied upon to make the following determinations.

Would the project:

Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Conflict with or obstruct implementation
of the applicable air quality plan? ☐ ☐ ☒ ☐
b) Result in a cumulatively considerable net
increase of any criteria pollutant for which
the project region is non-attainment under
an applicable federal or state ambient air
quality standard?
☐ ☐ ☒ ☐
c) Expose sensitive receptors to substantial
pollutant concentrations? ☐ ☐ ☒ ☐
d) Result in other emissions (such as those
leading to odors) adversely affecting a
substantial number of people?
☐ ☐ ☒ ☐
The analysis in this section is based partly on the following technical studies, which are included as Appendices A and B to this Initial Study:
 Air Quality and Greenhouse Gas Emissions Report, TRC, September 2025. (Appendix A)  Construction Health Risk Assessment, TRC, June 2025. (Appendix B)

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DISCUSSION
a) Conflict with or obstruct implementation of the applicable air quality plan? A consistency determination with the South Coast Air Quality Management District’s (South Coast AQMD) Air Quality Management Plan (AQMP) plays an important role in local agency project review by linking local planning and individual projects to the AQMP. It fulfills the CEQA goal of informing decision makers of the environmental effects of the proposed Project under consideration early enough to ensure that air quality concerns are fully addressed. It also provides the local agency with ongoing information as to whether they are contributing to the clean air goals in the AQMP.

The regional emissions inventory for the South Coast Air Basin (SoCAB) is compiled by South Coast AQMD and Southern California Association of Governments (SCAG). Regional population, housing, and employment projections developed by SCAG are based, in part, on cities’ general plan land use designations. These projections form the foundation for the emissions inventory of the AQMP. These demographic trends are incorporated into SCAG’s 2024-2050 RTP/SCS, Connect SoCal, to determine priority transportation projects and vehicle miles traveled in the SCAG region (SCAG 2024). Because the AQMP strategy is based on projections from local general plans and SCAG’s regional growth forecasts, projects that are consistent with the local general plan and would not introduce substantial population or employment growth not accounted for in the general plan are considered consistent with the AQMP.

As discussed in Section XIV, Population and Housing, the Project Site is in a developed industrial area of the City, and the proposed Project would establish a new BESS facility that would not introduce additional housing or significant number of employment opportunities. The proposed BESS facility would benefit the City and Southern California Edison (SCE) economically by creating temporary construction jobs, supporting ongoing maintenance services, and enhancing energy efficiency and reliability. Construction activities associated with the proposed Project would result in short-term employment only and would end upon Project completion. Therefore, proposed Project development would not induce substantial population or housing growth in the area.

According to the Air Quality and Greenhouse Gas Emissions Report prepared for the proposed Project (Appendix A), the proposed Project would be consistent with existing rules and measures contained in the South Coast AQMD 2022 Air Quality Management Plan (the 2022 Plan) via compliance with all applicable South Coast AQMD rules and regulations (Appendix A). The purpose of the 2022 Plan is to regulate long term emissions in accordance with population and infrastructure growth in the SoCAB. During construction activities that necessitate the use of heavy construction equipment, the proposed Project would be required to adhere to existing South Coast AQMD rules and regulations intended to reduce emissions of criteria pollutants. One of the key goals of the 2022 Plan is to meet the 2015 federal ozone standard which will require

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reducing emissions of NOX (the key pollutant that creates ozone) by 67 percent more than is required by the current South Coast AQMD adopted rules and regulations. The primary way to achieve the required NOX reductions is through replacing fossil fuel combustion with zero emission technologies. BESS facilities are an integral part of facilitating the growth of zero emission power generation technologies (South Coast AQMD 2022).

Moreover, as presented in the Air Quality impact discussion b), construction and operation of the proposed Project would not generate criteria air pollutant emissions that exceed South Coast AQMD’s thresholds. Therefore, the proposed Project would not result in a cumulatively considerable net increase of any criteria air pollutant for which the project region is nonattainment under an applicable federal or State ambient air quality standards (AAQS).

Considering these factors, the proposed Project would not conflict or obstruct implementation of the 2022 Plan and would advance key goals therein to support zero emission power generation in the SoCAB. The proposed Project’s impacts related to the 2022 Plan would be less than significant and no mitigation measures are necessary.
b) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard?
Air pollution is largely a cumulative impact. The nonattainment status of regional pollutants is a result of past and present development, and South Coast AQMD develops and implements plans for future attainment of AAQS. Based on these considerations, project-level thresholds of significance for criteria pollutants are relevant in the determination of whether a project’s individual emissions would have a cumulatively significant impact on air quality.

Construction and Decommissioning Emissions
Construction impacts were evaluated using the California Emissions Estimator Model (CalEEMod) Version 2022.1.1.30 (Appendix A). CalEEMod is a computer model prepared for the California Air Pollution Control Officers Association which provides a uniform platform for government agencies, land use planners, and environmental professionals to estimate air quality and greenhouse gas impacts from land use development projects in California.

The construction activities would last approximately 12 months from February 2026 to January 2027 (Appendix A). The Air Quality and Greenhouse Gas Emissions Report prepared for the proposed Project (Appendix A) details on the construction phase duration, equipment utilized, and daily equipment operating hours. A five-day construction workweek was assumed. Emissions from construction vehicle trips were estimated using default CalEEMod vendor and hauling trip lengths and vehicle class data in combination with Project specific estimated onsite truck trip lengths and vehicle trip data (employee/vendor/hauling trips to the site) which is also provided in Attachment 1 of Appendix A. Limiting onsite vehicle speeds on unpaved roads to 25 miles per

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hour was used assuming site safety protocols are unlikely to allow any higher speeds on the construction site. Watering of exposed surfaces, active demolition sites, and onsite hauling routes two times per day was assumed as a conservative minimum for consistency with South Coast AQMD Rule 403 requirements to minimize regional and localized particulate matter impacts.

Additional details regarding the CalEEMod modeling can be found in The CalEEMod Summary Report provided as Attachment 2 of Appendix A.

Emissions that would occur from decommissioning at the end of the proposed Project’s expected 35-year life cannot be reliably estimated given the likely advances in equipment, emissions controls, and energy. It is reasonably foreseeable that emissions from decommissioning activities will be no more than those for construction.

Table 1 shows that maximum daily emissions for VOC, NOX, CO, SO2, PM10, and PM2.5 from construction-related activities would be less than their respective South Coast AQMD regional significance threshold values. Therefore, air quality impacts from Project-related construction activities would be less than significant and no mitigation measures are necessary.

Table 1 Maximum Daily Regional Construction Emissions
Construction Phase
Pollutants (lbs./day)1, 2
VOC NOX CO SO2 PM10 PM2.5
Impact Analysis
Maximum Daily Construction Emissions 3 22 27 <1 4 1
South Coast AQMD Regional Significance
Threshold 75 100 550 150 150 55
Significant? No No No No No No
Source: CalEEMod Version 2022.1.1.30, South Coast AQMD 2023. (Appendix A) 1 Includes implementation of fugitive dust control measures required by South Coast AQMD under Rule 403, including watering of exposed surfaces, active demolition sites, and onsite hauling routes two times per day and reducing speed limit to 25 miles per hour on unpaved surfaces.

Operational Emissions
According to the Air Quality and Greenhouse Gas Emissions Report prepared for the proposed Project (Appendix A), the proposed Project operation would not have stationary emissions and would have up to two employees on-site daily which would result in negligible operational mobile source emissions from worker trips as the proposed Project is designed for remote operation (Appendix A). The proposed Project’s operational air quality impacts would primarily consist of emissions from the low number of worker trips and other vehicles used for occasional deliveries, maintenance, and other infrequent and minimal site visits.

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Overall, given the role of energy storage in State and regional planning for reduced pollutant emissions, the emission reductions that can be achieved with the proposed Project’s additional storage capacity for renewable energy can be expected to exceed the proposed Project’s operating emissions. Therefore, only emissions associated with construction of the proposed Project were quantified. Battery energy storage is a key component of local, state, and federal goals for reducing reliance on fossil fueled electric generation to reduce pollutant and greenhouse gas emissions and help limit climate change. Considering this, proposed Project operations can be expected to result in an overall reduction in pollutant emissions regionally and a net beneficial impact on air quality. The magnitude of the expected net reduction in emissions cannot be accurately determined and, therefore, has not been quantified.

Therefore, operation of the proposed Project would generate nominal operational emissions and would not exceed the South Coast AQMD’s regional operation-phase significance thresholds.

Impacts to the regional air quality associated with operation of the proposed Project would be less than significant and no mitigation measures are necessary. c) Expose sensitive receptors to substantial pollutant concentrations? The proposed Project could expose sensitive receptors to elevated pollutant concentrations if it causes or significantly contributes to elevated pollutant concentration levels. Unlike regional emissions, localized emissions are typically evaluated in terms of air concentration rather than mass so they can be more readily correlated to potential health effects.

Construction
Construction-Phase Localized Impacts
As part of South Coast AQMD’s environmental justice program, there has been increased attention focused on localized effects of air quality. South Coast AQMD has developed localized significance threshold (LST) methodology and mass rate look-up tables by source receptor area (SRA) that can be used voluntarily to determine whether a project may generate significant adverse localized air quality impacts. Additionally, South Coast AQMD has developed specific guidance for projects evaluating construction impacts using CalEEMod. The LST methodology and mass rate look-up tables require completion of a few key steps, which are summarized in the Appendix A.

Air pollutant emissions generated by construction activities would cause temporary increases in air pollutant concentrations. Table 2, Localized Construction Emissions, shows the maximum daily construction emissions (pounds per day) generated during on-site construction activities compared with the South Coast AQMD’s LST lookup tables for sensitive receptors within 30 meters of the Project Site for NOX, CO, PM10 and PM2.5 in SRA 11: South San Gabriel Valley. As shown in Table 2, construction of the proposed Project would not generate construction-related on-site emissions that would exceed South Coast AQMD’s LST 2-acre lookup table. Thus, proposed

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Project-related construction activities would not have the potential to expose sensitive receptors to substantial pollutant concentrations. Localized air quality impacts from construction activities would be less than significant and no mitigation measures are necessary.

Table 2 Localized Construction Emissions
Pollutants(lbs/day)1
NOX
CO PM10 PM2.5
Maximum Daily Onsite Emissions 21.5 26.9 3.41 0.82
South Coast AQMD 2.00 Acre LST2 121 1,031 7 5
Exceeds LST? No No No No
Source: CalEEMod Version 2022.1.1.30. (Appendix A)
1 Total proposed Project daily onsite and offsite maximum emissions for NOX and CO were conservatively used. 2 The South Coast AQMD LST lookup tables are provided for 1, 2, and 5 maximum daily disturbed acres. The 2- acre lookup table was conservatively used based on the equipment usage and estimated maximum disturbed acreage for the proposed Project.

Construction Health Risk Assessment
Project impacts related to increased health risk can occur by generating emissions of toxic air contaminants (TACs) and air pollutants. Construction activity under the proposed Project would generate dust and equipment exhaust that can affect nearby sensitive receptors. The nearest sensitive-receptor land use is the residences located approximately 30 meters to the south of the Project Site on Gale Avenue. Thus, a construction health risk assessment (HRA) has been prepared for the proposed Project (Appendix B).

Emissions from construction equipment primarily consist of diesel particulate matter (DPM). In 2015, the Office of Environmental Health Hazards Assessment (OEHHA) adopted guidance for preparation of health risk assessments, which included the development of a cancer risk factor and non-cancer chronic reference exposure level for DPM over a 30-year time frame (OEHHA 2015). The complete methodology is found within Appendix Construction HRA Memo of this Initial Study and the results of the construction HRA are shown in Table 3.

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Table 3 Construction Risk Summary
Receptor
Cancer Risk
(per million) Chronic Hazards Cancer Burden
MER – Resident 5 <0.1 <0.1
MER – Worker <1 <0.1 NA
South Coast AQMD’s Significance Threshold 10 1.0 0.5
Significant? No No No
Source: Lakes AERMOD View, Version 13.0.0. (Appendix Construction B) Notes: Cancer risk calculated using 2015 OEHHA HRA Guidance Manual. Bold = exceeds threshold. MER = maximally exposed receptor.

As shown in Table 3, the maximum offsite cancer risk for the residential MER from the proposed Project-related construction emissions was calculated to be approximately 5 in one million and the worker MER to be less than 1 in one million. Consequently, cancer risks experienced by nearby receptors would be within acceptable limits. For non-carcinogenic effects, the chronic hazard index identified for each toxicological endpoint equaled less than one for each identified receptor.

Therefore, chronic non-carcinogenic hazards are within acceptable limits. Lastly, the cancer burden is determined by the product of population within the 1 in one million cancer risk impact zone, which includes fewer than 50 homes in the project vicinity. Therefore, to reach a community cancer burden of 0.5, there would need to be 500,000 people within the 1 in one million cancer risk impact zone or 100,000 people within the 5 in one million cancer risk impact zone. Because the cancer risk impact zone for both 1 and 5 in one million cancer risk includes only 50 homes, the community cancer burden resulting from construction of the proposed Project was identified as orders of magnitude less than 0.5, the South Coast AQMD’s significance threshold, and would not result in a significant impact.

Because the cancer risk, chronic hazards, and cancer burden for the residential and worker MER would not exceed the South Coast AQMD’s significance thresholds during the proposed Project’s construction, the proposed Project-related construction activities would not expose sensitive receptors to substantial TAC concentrations.

Based on the preceding, impacts would be less than significant, and no mitigation measures are necessary.

Operation
Operational Health Risks
In general, no TACs are emitted during normal operation of a BESS facility. However, there is the potential for TAC emissions in the event of an emergency fire that can occur if batteries overheat

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leading to a thermal runaway reaction and shutdown systems malfunction. Section IX, Hazards and Hazardous Materials, includes information pertaining to an unlikely hazardous release due to an emergency event.

CO Hotspots
Vehicle congestion has the potential to create pockets of CO called hotspots. Hotspots are typically produced at intersections, where traffic congestion is highest and vehicles back up and idle for longer periods and are subject to reduced speeds. These pockets could exceed the state one-hour standard of 20 parts per million (ppm) or the eight-hour standard of 9.0 ppm. Because CO is produced in greatest quantities from vehicle combustion and does not readily disperse into the atmosphere, adherence to AAQS is typically demonstrated through an analysis of localized CO concentrations.

The SoCAB has been designated attainment under both the national and California AAQS for CO.

However, South Coast AQMD does not have an adopted screening criteria to determine whether a project may have the potential to generate a CO hotspot. According to Bay Area Air District, under existing and future vehicle emission rates, a project would have to increase traffic volumes at a single intersection to more than 44,000 vehicles per hour—or 24,000 vehicles per hour where vertical and/or horizontal mixing is substantially limited—in order to generate a significant CO impact (Bay Area Air District 2023).

Based on the traffic study, traffic associated with the proposed Project construction phase is not expected to have an adverse effect on the surrounding transportation network. The existing industrial land use generates 218 more daily trips and 33 more peak hour trips than those estimated for the proposed Project’s construction phase (Appendix Traffic). With respect to proposed Project operation, the proposed Project would have up to two employees on-site daily and require infrequent maintenance vehicle trips, which would result in negligible impacts from worker trips as the proposed Project is designed for remote operation. Therefore, the proposed BESS facility would generate negligible daily trips and would not increase peak hour traffic volumes at affected intersections to more than the Bay Area Air District’s recommended hourly screening criteria. Based on these considerations, the proposed Project would result in a less than significant impact to air quality with regard to potential CO hotspots. No mitigation measures are necessary.
d) Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
The threshold for odor is if a project creates an odor nuisance pursuant to South Coast AQMD Rule 402, Nuisance, which states:

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A person shall not discharge from any source whatsoever such quantities of air contaminants or other material which cause injury, detriment, nuisance, or annoyance to any considerable number of persons or to the public, or which endanger the comfort, repose, health or safety of any such persons or the public, or which cause, or have a natural tendency to cause, injury or damage to business or property. The provisions of this rule shall not apply to odors emanating from agricultural operations necessary for the growing of crops or the raising of fowl or animals.

Construction
Emissions from construction equipment, such as diesel exhaust and volatile organic compounds from architectural coatings and paving activities may generate odors. However, these odors would be low in concentration, temporary, and would not affect a substantial number of people.

By the time such emissions reached any sensitive receptor sites, they would be diluted to well below any level of air quality concern. Therefore, impacts associated with construction-generated odors are considered less than significant and no mitigation measures are necessary.

Operation
The type of facilities that are considered to have objectionable odors include wastewater treatment plants, compost facilities, landfills, solid waste transfer stations, fiberglass manufacturing facilities, paint/coating operations (e.g., auto body shops), dairy farms, petroleum refineries, asphalt batch plants, chemical manufacturing, and food manufacturing facilities. The proposed Project involves the operation of an approximately 400-megawatt (MW) BESS facility and associated infrastructure improvements. As a result, the proposed Project would not fall within the objectionable odors land uses. Odor impacts would be less than significant, and no mitigation measures are necessary.

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IV. Biological Resources
Would the project:

Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Have a substantial adverse effect, either
directly or through habitat modifications,
on any species identified as a candidate,
sensitive, or special status species in local
or regional plans, policies, or regulations,
or by the California Department of Fish
and Wildlife or U.S. Fish and Wildlife
Service?
☐ ☐ ☐ ☒
b) Have a substantial adverse effect on any
riparian habitat or other sensitive natural
community identified in local or regional
plans, policies, regulations or by the
California Department of Fish and Wildlife
or U.S. Fish and Wildlife Service?
☐ ☐ ☐ ☒
c) Have a substantial adverse effect on state
or federally protected wetlands (including,
but not limited to, marsh, vernal pool,
coastal, etc.) through direct removal,
filling, hydrological interruption, or other
means?
☐ ☐ ☐ ☒
d) Interfere substantially with the movement
of any native resident or migratory fish or
wildlife species or with established native
resident or migratory wildlife corridors, or
impede the use of native wildlife nursery
sites?
☐ ☐ ☒ ☐
e) Conflict with any local policies or
ordinances protecting biological resources,
such as a tree preservation policy or
ordinance?
☐ ☐ ☐ ☒
f) Conflict with the provisions of an adopted
Habitat Conservation Plan, Natural
Community Conservation Plan, or other
approved local, regional, or state habitat
conservation plan?
☐ ☐ ☐ ☒

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The analysis in this section is based partly on the following technical study, which is included as Appendix C to this Initial Study:
 Biological Resources Assessment, TRC, June 2024.

DISCUSSION
a) Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S.

Fish and Wildlife Service?
The Project Site is an urbanized, heavily disturbed site and is surrounded predominantly by industrial and warehouse uses (see Figure 3, Aerial Photograph). According to the biological resources analysis (BRA) prepared for the proposed Project (Appendix C), no sensitive plant or wildlife species have a moderate or high potential to occur on or within proximity of the Project Site. No historical occurrences of federally or state-listed species were identified within the Project Site boundary, and the site is not located within any designated critical habitat. The proposed Project would not result in direct or indirect impacts on special-status species. No impact would occur, and no mitigation measures are necessary. b) Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service? According to the BRA prepared for the proposed Project (Appendix B), the Project Site does not support any riparian habitat or sensitive natural communities. The site is fully developed and disturbed, with no surface water bodies, drainages, streams, or other habitat types that would support riparian vegetation or communities considered sensitive by the California Department of Fish and Wildlife (CDFW) or U.S. Fish and Wildlife Service (USFWS). As such, implementation of the proposed Project would not impact any riparian habitat or sensitive natural communities. No impact would occur, and no mitigation measures are necessary. c) Have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?
According to the BRA prepared for the proposed Project (Appendix B), no jurisdictional features, such as wetlands or other waters subject to regulation under the Clean Water Act or California Fish and Game Code, were identified on the Project Site. The site is fully developed and does not contain any hydrologic features that would support wetland vegetation or soil conditions.

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Therefore, implementation of the proposed Project would not affect any state or federally protected wetlands. No impact would occur, and no mitigation measures are necessary. d) Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites?
Wildlife corridors refer to established migration routes commonly used by resident and migratory species for passage from one geographic location to another. Movement corridors may provide favorable locations for wildlife to travel between different habitat areas, such as foraging sites, breeding sites, cover areas, and preferred summer and winter range locations. They may also function as dispersal corridors allowing animals to move between various locations within their range.

According to the BRA prepared for the proposed Project (Appendix B), the Project Site is developed, disturbed, and surrounded by industrial and warehouse uses (see Figure 3, Aerial Photograph). No natural open space, water features, or vegetated corridors are present that could support native wildlife movement or serve as migratory corridors or nursery sites. The proposed Project would not obstruct any established movement pathways or disrupt access to nursery habitat. The Project Site is not located in any regional wildlife corridor or habitat linkage.

On a local level, the Project Site is just north of State Route 60, which is a nearly unsurpassable barrier for north-south wildlife movement. Although the Project Site may provide some habitat for limited wildlife movement and live-in habitat—particularly for avian species and small to medium mammals that are adapted to urban settings—the Project Site does not function as a wildlife corridor or nursery site. Additionally, the site and environs are not identified or designated as a wildlife corridor or nursery site.

Additionally, the Migratory Bird Treaty Act (Code of Federal Regulations Title 50, Part 10 and Part 21) protects migratory birds, their occupied nests, and their eggs from disturbance or destruction. “Migratory birds” include all nongame, wild birds found in the U.S. except for the house sparrow (Passer domesticus), European starling (Sturnus vulgaris), and rock pigeon (Columba livia). There are mature ornamental trees and some vegetation within the Project Site that could provide nesting habitat for migratory birds and raptors.

However, removal of ornamental trees and vegetation from the Project Site would be required to implement the proposed Project; therefore, the proposed Project could result in direct impacts on migratory birds if they are nesting in the affected trees and vegetation during construction.

Implementation of APM-5 (which is in Chapter 3, Project Description, and reproduced below), which would be added as a condition of approval for the proposed Project and ensure compliance with the Migratory Bird Treaty Act, would reduce potential impacts to migratory birds to less than significant.

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 APM-5 - Pre-construction Nesting Bird Survey. If construction is scheduled to commence during the nonnesting season (i.e., September 1 to January 31), no preconstruction surveys or additional measures are required. To avoid impacts to nesting birds on the Project site, a qualified wildlife biologist shall conduct preconstruction surveys of all potential nesting habitat within the project site for construction activities that are initiated during the breeding season (i.e., February 1 to August 31). The surveying biologist must be qualified to determine the status and stage of nesting by migratory birds and all locally breeding raptor species without causing intrusive disturbance. The raptor survey shall focus on potential nest sites (e.g., cliffs, large trees, windrows) around the Project site. Surveys shall be conducted no more than 14 days prior to construction activities. If active nests are found, a suitable buffer (e.g., 200 to 300 feet for common raptors; 30 to 50 feet for passerine species) shall be established around active nests and no construction within the buffer allowed until a qualified biologist has determined that the nest is no longer active (e.g., the nestlings have fledged and are no longer reliant on the nest). Encroachment into the buffer may occur at the discretion of a qualified biologist.

Less than significant, with the incorporation of the aforementioned APM. e) Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
The City does not have an adopted tree preservation ordinance or other biological resource policies that apply to the Project Site. The BRA confirmed that the site does not support any native trees or protected biological resources. Therefore, the proposed Project would not conflict with any applicable local biological protection policies or ordinances. No impact would occur, and no mitigation measures are necessary.
f) Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan? The Project Site area is urbanized, heavily disturbed and is surrounded predominantly by industrial and warehouse uses (see Figure 3). According to the BRA prepared for the proposed Project (Appendix B), the Project Site is not located within the boundaries of any Habitat Conservation Plan, Natural Community Conservation Plan, or other adopted conservation plan.

The proposed Project would not interfere with or conflict with the goals or provisions of any such plan. No impact would occur, and no mitigation measures are necessary.

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V. Cultural Resources
Would the project:

Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Cause a substantial adverse change in the
significance of a historical resource
pursuant to § 15064.5?
☐ ☐ ☒ ☐
b) Cause a substantial adverse change in the
significance of an archaeological resource
pursuant to § 15064.5?
☐ ☒ ☐ ☐
c) Disturb any human remains, including
those interred outside of dedicated
cemeteries?
☐ ☒ ☐ ☐
The analysis in this section is based on the following technical study, which is confidential and not available for public review pursuant to CEQA Guidelines Section 15120(d):
 Cultural Records Search Results, TRC, June 2024

DISCUSSION
a) Cause a substantial adverse change in the significance of a historical resource pursuant to § 15064.5?
Section 15064.5 defines historic resources as resources listed or determined to be eligible for listing by the State Historical Resources Commission, a local register of historical resources, or the lead agency. Generally a resource is considered “historically significant” if it meets one of the following criteria:
i) Is associated with events that have made a significant contribution to the broad patterns of California’s history and cultural heritage; ii) Is associated with the lives of persons important in our past; iii) Embodies the distinctive characteristics of a type, period, region or method of construction, or represents the work of an important creative individual, or possesses high artistic values;

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iv) Has yielded, or may be likely to yield, information important in prehistory or history.

According to the Cultural Records Search conducted for the proposed Project (TRC 2024), a review of historic maps and aerials indicated that the Project Site remained undeveloped until sometime between 1953 and 1966, when development and paving appeared. The Project Site is currently developed with industrial buildings and is located in an area characterized by industrial and warehouse uses. Development of the proposed Project would require demolition of all buildings and structures on-site.

As part of cultural records search conducted for the Project Site, the following resource listings were reviewed: the California Register of Historical Resources (CRHR), the California State Historic Resources Inventory, the National Register of Historic Places (NRHP), the Office of Historic Preservation (OHP), the California Historical Landmarks, the California Points of Historical Resources (TCR 2024). Based on the search, no historical buildings or structures were listed or determined eligible for listing on any of the resource listings.

Additionally, historic maps and aerial photos indicate that the buildings and associated infrastructure features that exist on-site were developed after 2000, which would make them ineligible for local, state, or federal listing. Therefore, the Project Site does not contain any historic resources as defined by CEQA (TRC 2024).

Therefore, the proposed Project would not cause a substantial adverse change in the significance of a historical resource. Impacts would be less than significant, and no mitigation measures are necessary.
b) Cause a substantial adverse change in the significance of an archaeological resource pursuant to § 15064.5?
Archaeological resources are prehistoric or historic evidence of past human activities, including structural ruins and buried resources. The Project Site is in a highly urbanized area and has already been disturbed due to grading and construction activities associated with current and past uses.

The Project Site is largely flat, and the proposed Project would be above ground level, with no subterranean floors or basements. Accordingly, limited ground disturbance would be required to implement the proposed Project. Given the highly disturbed condition of the Project Site and its surroundings and the limited ground disturbance proposed, the potential for development of the proposed Project to impact an unidentified archaeological resource is considered low.

However, there is the potential for encountering intact, buried cultural resources during ground disturbance. In the event that unanticipated archaeological resources are encountered during Project implementation, impacts to these resources could be significant. As such, Mitigation Measures CUL-1 and CUL-2 would be implemented to ensure that impacts to unanticipated

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archaeological resources and human remains would be treated properly resulting in a less than significant impact.
 Mitigation Measure CUL-1 Retention of a Qualified Archaeologist. Prior to the issuance of grading permits, a qualified archaeologist shall be retained by the project applicant to monitor during ground-disturbing activities in native soils and address any inadvertent discoveries identified for the duration of construction activities. In consideration of the potential to encounter intact cultural deposits beneath imported (non-native) fill soils and/or existing development, the qualified archaeologist shall survey the development area once fill soils have been removed to ensure that no cultural deposits underly the fill layer. If it is determined, based on the surveys during ground-disturbing activities into native soils, that cultural resources are present or may be present that may be impacted during project construction, further study including subsurface testing as well as archaeological monitoring may be warranted. If it is determined that monitoring is warranted, a qualified archaeological principal investigator, meeting the Secretary of the Interior’s Professional Qualification Standards, shall oversee and adjust monitoring efforts as needed (increase, decrease, or discontinue monitoring frequency) based on the observed potential for construction activities to encounter cultural deposits or material. The archaeological monitor shall be responsible for maintaining daily monitoring logs.
 Mitigation Measure CUL-2 Inadvertent Discovery Treatment and Protocol. In the event that archaeological resources (sites, features, or artifacts) are exposed during construction activities, all construction work occurring within 50 feet of the find shall immediately stop and a qualified archaeologist shall be notified immediately to assess the significance of the find and determine whether or not additional study is warranted. If human remains or suspected human remains are discovered, all construction work occurring within 50 feet of the find shall immediately stop. Depending on the significance of the find, the archaeologist may simply record the find and allow work to continue. If the discovery proves to be significant under CEQA as determined by the qualified archaeologist, additional work such as preparation of an archaeological treatment plan, testing, data recovery, or monitoring may be warranted.

Within 60 days following completion of ground disturbance, an archaeological monitoring report shall be prepared and submitted to the City of Industry for

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review. The report shall document compliance with approved mitigation, document the monitoring efforts, and include an appendix with daily monitoring logs. The final report shall be submitted to the South Central Coastal Information Center.

Less than significant impact, with the incorporation of the aforementioned mitigation measures.
c) Disturb any human remains, including those interred outside of dedicated cemeteries? There are no known human remains or cemeteries on or near the Project Site. The Project Site is a heavily disturbed, urbanized area that has previously been graded and developed with industrial uses and associated infrastructure. The surrounding vicinity is similarly developed with existing buildings, roadways, and other urbanized land uses. The Project Site is largely flat and previously disturbed, and implementation of the proposed Project would not require deep excavation.

Accordingly, the likelihood that human remains may be discovered during site clearing and grading activities is considered extremely low.

However, the proposed Project would involve grading and excavation that could extend into native soils and therefore could disturb previously undiscovered subsurface human remains. In the unlikely event that human remains are uncovered during ground-disturbing activities, California Health and Safety Code Section 7050.5 requires that disturbance of the site shall halt and the Los Angeles County Coroner be notified. The Coroner must determine the nature of the remains within two working days. If the remains are determined to be of Native American origin, the Coroner must contact the Native American Heritage Commission (NAHC) within 24 hours, and the NAHC would then designate a Most Likely Descendant (MLD). The MLD would be provided access to the discovery and given 48 hours to make recommendations regarding treatment of the remains.

Additionally, implementation of Mitigation Measures TCR-1 through TCR-3 would ensure that the Coroner is immediately notified and that appropriate procedures are followed in the event that human remains are encountered. Compliance with existing law and these mitigation measures would reduce potential impacts to human remains to a less than significant level.

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VI. Energy
Would the project:

Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Result in potentially significant
environmental impact due to wasteful,
inefficient, or unnecessary consumption of
energy resources, during project
construction or operation?
☐ ☐ ☒ ☐
b) Conflict with or obstruct a state or local
plan for renewable energy or energy
efficiency?
☐ ☐ ☐ ☒

DISCUSSION
a) Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation? The following discusses the potential energy demands from short-term construction and longterm operational energy consumption associated with the proposed Project.

Short-Term Construction Impacts
Electrical Energy
Electricity use during construction of the proposed Project would vary during different phases of construction. Construction of the proposed Project would not require electricity to power most construction equipment. Later construction phases could result in the use of electricity-powered equipment for interior construction and architectural coatings. It is anticipated that the majority of electric-powered construction equipment would be hand tools (e.g., power drills, table saws) and lighting, which would result in minimal electricity usage during construction activities.

Therefore, proposed Project-related construction activities would not result in wasteful or unnecessary electricity demands. Impacts would be less than significant, and no mitigation measures are necessary.

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Natural Gas Energy
It is not anticipated that construction equipment used for the proposed Project would be powered by natural gas, and no natural gas demand is anticipated during construction. Therefore, impacts would be less than significant with respect to natural gas usage and no mitigation measures are necessary.

Transportation Energy
Transportation energy use during construction would come from the transport and use of construction equipment, delivery vehicles and haul trucks, and construction employee vehicles.

In addition, transportation energy demand would come from use of off-road construction equipment. It is anticipated that the majority of off-road construction equipment, such as those used during demolition, drilling, grading, and foundation, would be gas or diesel powered.

The use of energy resources by vehicles and equipment would fluctuate according to the phase of construction and would be temporary. In addition, all construction equipment would cease operating upon completion of proposed Project construction. Thus, impacts related to transportation energy use during construction would be temporary and would not require expanded energy supplies or the construction of new infrastructure.

Moreover, to limit wasteful and unnecessary energy consumption, the construction contractors are anticipated to minimize nonessential idling of construction equipment during construction, in accordance with Section 2449 of the California Code of Regulations, Title 13, Article 4.8, Chapter

9. Construction trips would also not result in unnecessary use of energy since the Project Site is located in the southeastern part of Los Angeles County area and is served by numerous regional freeway systems (e.g., State Route 60) that provide the most direct routes from various areas of the region. Thus, energy use during construction of the proposed Project would not be considered inefficient, wasteful, or unnecessary. Impacts would be less than significant, and no mitigation measures are necessary.

Long-Term Impacts During Operation
Electrical and Natural Gas Energy
The proposed Project would be all-electric and would not use natural gas during operation. The proposed Project would provide a service to the regional electric grid by receiving energy (charging) from the Southern California Edison (SCE) electric transmission system, storing energy on-site, then delivering energy (discharging) back to the SCE Walnut Substation (Substation Area).

Overall, implementation of the proposed Project would result in operation of an approximately 400-megawatt BESS facility and generate a total electricity demand of 584,000 kilowatt-hours per year. While operation of the proposed Project would result in increased electricity demand from

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on-site lighting, climate control, and security appurtenances, it would also facilitate the integration of renewable energy from regional solar and wind resources into the electric grid, supporting overall grid reliability and resilience.

Overall, the proposed Project would support the use of renewable energy sources and would be consistent with the goals outlined in Appendix F of the CEQA Guidelines. Therefore, the proposed Project would not result in wasteful or unnecessary consumption of energy resources. Impacts would be less than significant, and no mitigation measures are necessary.

Transportation Energy
The proposed Project would consume transportation energy during operations from the use of motor vehicles associated with employees. The proposed Project would have up to two employees on-site daily and require infrequent maintenance vehicle trips, which will result in negligible impacts from worker trips as the proposed Project is designed for remote operation.

Therefore, the proposed BESS facility would generate negligible daily trips, and the proposed Project would screen out from the City’s screening threshold of 110 vehicle trips per day for a vehicle miles traveled (VMT) assessment and would result in a less than significant VMT impact (Appendix R). The limited number of proposed Project-related vehicle trips would contribute to minimizing VMT and transportation fuel demands.

Furthermore, the Project Site would be accessible by the regional freeway systems (e.g., State Route 60) that provide the most direct routes from various areas of the region. Thus, operationrelated fuel usage associated with the proposed Project would not be considered inefficient, wasteful, or unnecessary. Overall, energy impacts as it pertains to operation-related transportation energy would be less than significant and no mitigation measures are necessary. b) Conflict with or obstruct a state or local plan for renewable energy or energy efficiency? The following evaluates consistency of the proposed Project with California’s Energy Action Plan and Long-Term Energy Efficiency Strategic Plan.

Energy Action Plan
The Energy Action Plan was last updated in 2008 and was developed by the California Public Utilities Commission (CPUC), California Energy Commission (CEC), and California Power Authority to create a unified State energy policy framework. It serves as one of the State’s strategies for planning for reliable, affordable, and environmentally responsible energy procurement and supply. The Energy Action Plan further establishes a “loading order” in identifying priorities for statewide energy planning efforts, which translates into first prioritizing meeting existing demand with cost-effective energy efficiency and demand response efforts, then using renewable energy resources and distributed generation, and finally meeting the remaining energy demand with renewable or otherwise “clean” fossil-fuel power generation resources (e.g., renewable natural

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gas). Other priorities identified in the Energy Action Plan but not directly related to local agencies, include modernizing transmission and distribution infrastructure, enhancing reliability in electricity and natural gas markets, and ensuring affordable access to all Californians. Therefore, a project can be assessed for consistency with the Energy Action Plan by examining how the proposed development generally supports or conflicts with the strategies of the plan, such as promoting energy resource deployment consistent with the plan’s loading order.

The proposed BESS facility supports the Energy Action Plan by enhancing grid reliability and enabling storage of renewables and discharged back to the SCE Walnut Substation (Substation Area) when necessary. By storing excess electricity generated from solar and wind resources and discharging it during periods of high demand or low renewable output, BESS helps balance the grid and reduce reliance on fossil-fuel-powered plants. It is intended to reliably capture and manage renewable energy, using proven and established energy storage technology that is efficient, has low maintenance requirements, and is recyclable. Operation of the proposed BESS facility would store electricity when excess generation capacity is available for use at a later time, thereby allowing more use of intermittent renewable energy sources. In general, the installation of a BESS facility would further CARB’s goals for renewable energy production and the state’s goal of transitioning to 100 percent carbon-free electricity. Therefore, the proposed Project would be considered consistent with the Energy Action Plan strategies. No impact would occur and no mitigation measures are necessary.

Long-Term Energy Efficiency Strategic Plan
The Long-Term Energy Efficiency Strategic Plan was last updated in 2011 and serves as the State’s long-term roadmap to make energy efficiency a top priority in supporting California’s grid harmonization and renewable energy integration efforts. The Long-Term Energy Efficiency Strategic Plan serves as a living strategic document for State and local agencies and emphasizes the integration of energy efficiency policies and measures into planning efforts as a critical component to advancing the objectives of the plan. Therefore, a project can be assessed for consistency with the Long-Term Energy Efficiency Strategic Plan by examining how its proposed development generally supports or conflicts with the strategies of the plan, such as green building standards and zero net energy readiness.

The proposed BESS facility aligns with the goals of the state’s Long-Term Energy Efficiency Strategic Plan by supporting a more efficient and flexible energy infrastructure. By storing electricity during periods of low demand or high renewable generation and discharging it during peak demand, the proposed BESS facility helps reduce the reliance on fossil fuel generation sources and eases pressure on the electric grid. The proposed BESS facility also supports renewable energy integration by allowing cleaner energy and renewable energy produced by existing solar and wind resources to be stored and used efficiently. Therefore, the proposed Project would be considered consistent with the Long-Term Energy Efficiency Strategic Plan strategies. No impact would occur and no mitigation measures are necessary.

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VII. Geology and Soils
Would the project:

Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Directly or indirectly cause potential
substantial adverse effects, including the
risk of loss, injury, or death involving:
☐ ☐ ☐ ☐
i) Rupture of a known earthquake fault,
as delineated on the most recent
Alquist-Priolo Earthquake Fault
Zoning Map, issued by the State
Geologist for the area or based on
other substantial evidence of a known
fault? Refer to Division of Mines and
Geology Special Publication 42.
☐ ☐ ☒ ☐
ii) Strong seismic ground shaking? ☐ ☐ ☒ ☐
iii) Seismic-related ground failure,
including liquefaction? ☐ ☐ ☒ ☐
iv) Landslides? ☐ ☐ ☐ ☒
b) Result in substantial soil erosion or the
loss of topsoil? ☐ ☐ ☒ ☐
c) Be located on a geologic unit or soil that is
unstable, or that would become unstable
as a result of the project, and potentially
result in on- or off-site landslide, lateral
spreading, subsidence, liquefaction or
collapse?
☐ ☐ ☒ ☐
d) Be located on expansive soil, as defined in
Table 18-1-B of the Uniform Building Code
(1994), creating substantial direct or
indirect risks to life or property?
☐ ☐ ☒ ☐
e) Have soils incapable of adequately
supporting the use of septic tanks or
alternative waste water disposal systems
where sewers are not available for the
disposal of waste water?
☐ ☐ ☐ ☒

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Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
f) Directly or indirectly destroy a unique
paleontological resource or site or unique
geologic feature?
☐ ☒ ☐ ☐
The analysis in this section is based partly on the following technical studies, which is included as Appendices D and E to this Initial Study:
 Geotechnical Engineering Report, Terracon, December 2023. (Appendix D)  Revised Geotechnical Engineering Report, Terracon, February 2025. (Appendix E)

DISCUSSION
a) Would the proposed project directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving:
i. Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map, issued by the State Geologist for the area or based on other substantial evidence of a known fault? Refer to Division of Mines and Geology Special Publication 42.

The Alquist-Priolo Earthquake Fault Zoning Act was passed in 1972 to mitigate the hazard of surface faulting to structures for human occupancy. Surface rupture is the most easily avoided seismic hazard. Fault rupture generally occurs within 50 feet of an active fault line and is limited to the immediate area of the fault zone where the fault breaks along the surface. The main purpose of the Alquist-Priolo Earthquake Fault Zoning Act is to prevent construction of buildings used for human occupancy on the surface of active faults, in order to minimize the hazard of surface rupture of a fault to people and habitable buildings. Before cities and counties can permit development within Alquist-Priolo Earthquake Fault Zones, geologic investigations are required to show that the proposed development site is not threatened by surface rupture from future earthquakes.

According to the geotechnical engineering reports prepared for the proposed Project (Appendices D and E), the Project Site is not located in an Alquist-Priolo Earthquake Fault Zone. The nearest mapped active fault is the Whittier Fault approximately three miles south of the Project Site (Appendices D and E). Due to the distance to the active fault, the potential for surface rupture of a fault on-site is considered very low. Therefore, Project development would not subject people or structures to hazards arising from surface rupture of a known

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active fault. Impacts would be less than significant, and no mitigation measures are necessary.
ii. Strong seismic ground shaking?
The most significant geologic hazard to the design life of the proposed Project is the potential for moderate to strong ground shaking resulting from earthquakes generated on the faults in seismically active southern California. The type and magnitude of seismic hazards affecting the Project Site is dependent on the distance to causative faults, the intensity, and the magnitude of the seismic event.

As noted previously, the Whittier Fault is approximately three miles south of the Project Site (Appendices D and E). These faults, as well as others in the region, are considered capable of producing strong shaking at the Project Site, thereby exposing people or structures on the site to potential substantial adverse effects, including the risk of loss, injury, or death.

The intensity of ground shaking on the Project Site would depend on the magnitude of the earthquake, distance to the epicenter, and the geology of the area between the epicenter and the Project Site.

Seismic shaking is a risk throughout southern California, and the Project Site is not at a greater risk of seismic activity or impacts than other sites in southern California. Additionally, the State regulates development in California through a variety of tools that reduce hazards from earthquakes and other geologic hazards. The Los Angeles County Building Code (LACBC; Title 26 of the Los Angeles County Code) and the California Building Code (CBC; California Code of Regulations, Title 24, Part 2) 2022 edition, adopted by reference in Title 15 (Buildings and Construction), Chapter 15.04 of the Industry Municipal Code, contain provisions to safeguard against major structural failures or loss of life caused by earthquakes or other geologic hazards. The CBC contains provisions for earthquake safety based on factors including occupancy type, the types of soil and rock on-site, and the strength of ground motion with specified probability of occurring at the site. Project development would be required to adhere to the provisions of the LACBC and CBC, which are enforced by the City during the building plan check and development review process. Compliance with the requirements of the LACBC and CBC for structural safety during a seismic event would reduce hazards from strong seismic ground shaking.

Furthermore, incorporation of the recommended design parameters from the Geotechnical Engineering Reports prepared for the proposed Project (Appendices D and E), such as parameters for shallow and deep foundations, lateral earth pressures, and pavement design, would also reduce hazards from strong seismic ground shaking. The City would impose the recommended design parameters as a condition of approval, and compliance would be ensured through the City’s building plan check and development review process.

Compliance with the provisions of the LACBC and CBC and implementation of the recommended design parameters outlined in the geotechnical engineering reports would

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reduce impacts resulting from strong seismic ground shaking. Therefore, impacts would be less than significant, and no mitigation measures are necessary. iii. Seismic-related ground failure, including liquefaction? Liquefaction is a phenomenon that occurs when soil undergoes a transformation from a solid state to a liquified condition. It refers to loose, saturated sand or silt deposits that behave as a liquid and lose their load-supporting capability when strongly shaken. Loose granular soils and silts that are saturated by relatively shallow groundwater are susceptible to liquefaction. When subjected to seismic ground shaking, affected soils lose strength during liquefaction and foundation failure can occur.

According to the geotechnical engineering reports prepared for the proposed Project (Appendices D and E), the Project Site has been mapped and is located within a liquefaction hazard zone as designated by the California Geological Survey (CGS). To evaluate the presence of liquefiable soils and determine the amount of settlement of saturated/unsaturated soils during seismic shaking, a liquefaction analysis was performed for the Project Site in accordance with the Los Angeles County guidelines. According to the geotechnical engineering reports prepared for the proposed Project (Appendices D and E), groundwater was observed at approximately 21 and 27 feet below grade surface (bgs).

Historic high groundwater levels in the project area were recorded at approximately 12 to 14 feet bgs, which was the depth utilized for the liquefaction analysis. Based on the calculation results, the seismically induced settlement is estimated to be approximately one inch or less.

In response to the findings and conclusions of the liquefaction analysis conducted, Project Site grading, design, and construction would conform with the recommended design parameters of the geotechnical engineering reports prepared for the proposed Project. The City would impose the recommended design parameters as a condition of approval, and compliance would be ensured through the City’s building plan check and development review process. Therefore, impacts would be less than significant, and no mitigation measures are necessary.
iv. Landslides?
Landslides are the downslope movement of geologic materials. Slope failures in the form of landslides are common during strong seismic shaking in areas of steep hills.

The Project Site its surroundings are relatively flat and developed. There are no steep hills or bluffs on, adjacent to, or in the vicinity of the Project Site. The United States Geological Survey (USGS) landslide inventory tool illustrates that that no landslides have occurred at or in the immediate vicinity of the Project Site, and they are not susceptible to possible landslides in the area (USGS 2024). Therefore, no impact related to landslides would occur and no mitigation measures are necessary.

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a) Would the proposed project result in substantial soil erosion or the loss of topsoil? Erosion is the movement of rock and soil from place to place and is a natural process. Common agents of erosion in the project region include wind and flowing water. Significant erosion typically occurs on steep slopes where stormwater and high winds can carry topsoil down hillsides. Erosion can be increased greatly by earth-moving activities (e.g., excavation and grading) if erosion control measures are not used.

Construction Phase
Development at the Project Site involvessite preparation, grading, and construction activities that would disturb soil and temporarily leave exposed soil on the ground surface. Common means of soil erosion from construction sites include water, wind, and being tracked off-site by vehicles.

However, development on the Project Site is subject to local and state codes and requirements for erosion control and grading during construction. For example, Project development is required to comply with standard regulations, including South Coast AQMD Rules 402 (Nuisance) and 403 (Fugitive Dust), which would reduce construction erosion impacts. Rule 403 requires that fugitive dust be controlled with best available control measures so that the presence of such dust does not remain visible in the atmosphere beyond the property line of the emissions source. Rule 402 requires dust suppression techniques be implemented to prevent dust and soil erosion from creating a nuisance off site. For example, as outlined in Table 1 of Rule 403 (Best Available Control Measures), control measures to reduce erosion during grading and construction activities include stabilizing backfilling materials when not actively handling, stabilizing soils during clearing and grubbing activities, and stabilizing soils during and after cut-and-fill activities.

Additionally, the Construction General Permit (CGP) issued by the State Water Resources Control Board (SWRCB), effective July 17, 2012, regulates construction activities to minimize water pollution, including sediment risk from construction activities to receiving waters. Project development, which would occur on a site greater than one acre, would be subject to the NPDES permitting regulations, including the development and implementation of a Stormwater Pollution Prevention Plan (SWPPP), which is further discussed in Section X, Hydrology and Water Quality.

The proposed Project’s construction contractor would be required to prepare and implement a Stormwater Pollution Prevention Plan (SWPPP) and associated best management practices (BMP) in compliance with the CGP during grading and construction. For example, types of BMPs that are incorporated in SWPPPs and would help minimize impacts from soil erosion include:
 Erosion controls. Cover and/or bind soil surface, to prevent soil particles from being detached and transported by water or wind. Erosion control BMPs include mulch, soil binders, and mats.  Sediment controls. Filter out soil particles that have been detached and transported in water.

Sediment control BMPs include barriers and cleaning measures such as street sweeping.

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 Tracking controls. Tracking control BMPs minimize the tracking of soil off site by vehicles; for instance, stabilizing construction roadways and entrances/exits.

Adherence to the BMPs in the SWPPP and with local and state codes and requirements for erosion control and grading during construction would reduce, prevent, or minimize soil erosion from project-related grading and construction activities. Therefore, soil erosion impacts from Projectrelated grading and construction activities would be less than significant and no mitigation measures are necessary.

Operation Phase
The Project Site is relatively flat and is not adjacent to or in the vicinity of any waterways or any major slopes or bluffs. The Project Site would include landscaping along most of the perimeter of the Project Site, but would include ground cover, trees, and shrubs that would reduce potential erosion. Additionally, most of the Project Site would be developed with hard surfaces.

In accordance with the City’s initial requirements for development projects, specifically Industry Municipal Code Section 13.16, Stormwater and Urban Runoff Pollution Control, a preliminary Hydrology Study and Stormwater Quality Management Plan was prepared for the Project Site (Appendix P). BMPs specified in the plan would help minimize sediment pollution of stormwater and include common area catch basin inspection; common area landscape management; sweeping of streets; and activity restrictions. BMPs are discussed further in Section X, Hydrology and Water Quality. Implementation of the BMPs would help ensure that soil erosion would not occur under the proposed Project’s operation phase. BMP implementation would be ensured through the City’s building plan check and development review process. Upon Project completion, the potential for soil erosion or the loss of topsoil would be expected to be extremely low.

Therefore, soil erosion impacts from the proposed Project’s operation phase would be less than significant and no mitigation measures are necessary.
b) Would the proposed project be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction or collapse? Hazards from liquefaction are addressed above in Section VII.a.iii and landslide hazards are addressed above in Section VII.a.iv. As concluded in these sections, impacts would be less than significant, and no mitigation measures are necessary.

Lateral Spreading
Lateral spreading is a phenomenon that occurs in association with liquefaction and includes the movement of non-liquefied soil materials. As stated in Section X.a.iii, the Project Site is located in

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a liquefaction hazard zone. Project Site grading, design, and construction would conform with the recommended design parameters of the geotechnical engineering reports prepared for the proposed Project (Appendices D and E). The City would impose the recommended design parameters as a condition of approval, and compliance would be ensured through the City’s building plan check and development review process. Therefore, impacts would be less than significant, and no mitigation measures are necessary.

Ground Subsidence
The major cause of ground subsidence is the excessive withdrawal of groundwater. Soils with high silt or clay content are particularly susceptible to subsidence. The Project Site overlies the San Gabriel Valley Groundwater Basin, a large alluvial groundwater basin with storage in excess of ten million acre-feet. The basin has a long history of groundwater use for various uses dating back to the late 1800s. Based on a review of the US Geological Survey map, “Areas of Land Subsidence in California,” the San Gabriel Valley Groundwater Basin is not in an area of subsidence. Although the California Department of Water Resources lists the basin with a high potential for future subsidence, no evidence of substantial subsidence has been observed (DWR 2014). The Main San Gabriel Basin Watermaster, the agency responsible for groundwater basin management, annually establishes a safe water yield for the next four years in order to prevent any permanent lowering of the land surface (MSGBW 2024).

Additionally, Project Site development would not substantially increase groundwater pumping in the basin, as there would be limited operational uses that consume water operating onsite.

Therefore, Project Site development would not subject people or structures to substantial hazards arising from ground subsidence. Impacts would be less than significant, and no mitigation measures are necessary.

Collapsable Soils
Collapsible soils shrink upon being wetted and/or being subject to a load. Soils susceptible to hydro-collapse (or collapsible soils) are predominately sand, silty sand, and sandy silt held in a relatively loose structure by a temporary cementing agent. If the soil remains dry it generally maintains its structure, but the addition of water will greatly weaken the structure, and the soil experiences immediate collapse. This collapse can result in rapid soil settlement and potential damage to any improvements within the zone of influence of the collapsible soils. Fine-grained soils such as clays and silty clays are generally not considered susceptible to hydro-collapse.

Laboratory testing for hydro-collapse at the Project Site was performed per the American Society for Testing and Materials (ASTM) Test D1557 as a part of the geotechnical engineering reports prepared for the proposed Project (Appendices D and E). The testing found in Appendix D indicated that near surface soils tested have a maximum dry density of 123.8 pounds per cubic feet (pcf) and optimum water contents of 12.1 percent. Additionally, the testing found in

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Appendix E indicated that near surface soils tested have a maximum dry density of 114 pounds pcf and optimum water contents of 16.5 percent. A consolidation test completed for both Appendices indicates that the clayey soils encountered at an approximate depth of 2.5 feet bgs have a negligible collapse/swell potential when saturated under normal footing loads of 2,000 psf.

Additionally, Project Site grading, design, and construction would conform with the design parameters of the geotechnical engineering report. The City would impose the recommended design parameters as a condition of approval, and compliance would be ensured through the City’s building plan check and development review process.

Therefore, impacts would be less than significant, and no mitigation measures are necessary. c) Would the proposed project be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property?
Expansive soils shrink or swell as the moisture content decreases or increases; the shrinking or swelling can shift, crack, or break structures built on such soils. According to the Appendix D prepared for the proposed Project, expansive soils are present on the Project Site. These expansive soils have an expansion index value of approximately 37, which is considered a medium expansion potential. Project Site development would be required to incorporate the recommendations provided in the geotechnical exploration report, which would be imposed as a condition of approval, and adhere to the provisions of the CBC. Therefore, impacts would be less than significant, and no mitigation measures are necessary. d) Would the proposed project have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of waste water?
Development of the proposed BESS facility on the Project Site would not propose or require the construction or use of a septic tank or an alternative wastewater disposal system. Therefore, no impact would occur, and no mitigation measures are necessary. e) Would the proposed project directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
Paleontological resources are commonly known as fossils, that is, the recognizable physical remains or evidence of past life forms found on earth in past geological periods, including bones, shells, leaves, tracks, burrows, and impressions.

As shown in Figure 3, Aerial Photograph, the Project Site is in an urbanized area of the City, and the Project Site is disturbed and developed with warehouse, manufacturing, and industrial uses

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and associated improvements. Given the highly disturbed and developed condition of the Project Site and its surroundings, the potential for development of the proposed Project to impact an unidentified paleontological resource is considered low. Additionally, there are no unique geological features on-site or adjacent to or surrounding the Project Site.

Ground-disturbing activities in deeper native sediments could unearth unique paleontological resources. The Project Site would include subsurface work during construction. The operational phase would not include any subsurface activities. While the possibility of finding archaeological resources is considered low due to the disturbed and developed nature of the Project Site, it is possible that fossils could be discovered during grading and earthwork activities. Unknown fossils encountered during excavation would have the potential to be unintentionally damaged.

Implementation of Mitigation Measure GEO-1, which outlines precautionary measures and action measures for an event resulting in the discovery of unknown paleontological resources, would ensure that impacts to unknown paleontological resources are less than significant.

Mitigation Measure GEO-1: In the event that fossils or fossil locality deposits are discovered during ground disturbing activities (e.g., trenching, soil removal), excavation within 100 feet of the fossil locality shall be temporarily halted until removal occurs. The contractor shall notify a qualified paleontologist to investigate its significance. If the fossil locality is determined to be significant by the qualified paleontologist, the paleontologist shall work with the project applicant and construction contractor to follow accepted professional standards, such as further testing for evaluation or data recovery, as necessary. The paleontologist shall notify the appropriate agencies to determine procedures that shall be followed before construction is allowed to resume at the location of the find. If the project applicant determines that avoidance is not feasible, the paleontologist shall prepare an excavation plan for mitigating the effect of the project based on the qualities that make the resource important.

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VIII. Greenhouse Gas Emissions
Would the project:

Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Generate greenhouse gas emissions,
either directly or indirectly, that may have
a significant impact on the environment?
☐ ☐ ☒ ☐
b) Conflict with an applicable plan, policy or
regulation adopted for the purpose of
reducing the emissions of greenhouse
gases?
☐ ☐ ☒ ☐
The analysis in this section is based partly on the following technical study, which is included as Appendix A to this Initial Study:
 Air Quality and Greenhouse Gas Emissions Report, TRC, September 2025.

DISCUSSION
a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment?
Global climate change is not confined to a particular project area and is generally accepted as the consequence of global industrialization over the last 200 years. A typical project, even a very large one, does not generate enough greenhouse gas emissions on its own to influence global climate change significantly; hence, the issue of global climate change is, by definition, a cumulative environmental impact.

Construction and Decommissioning Emissions
According to Appendix A, the GHG emissions from the proposed Project construction and decommissioning would be temporary and minimal.1 Construction emissions were evaluated using the California Emissions Estimator Model (CalEEMod) Version 2022.1.1.30. The South Coast AQMD recommends that construction emissions be amortized over a project’slifetime; therefore, 1 Emissions from decommissioning at the end of the proposed Project’s expected 35-year life cannot be reliably estimated given the likely advances in equipment, emissions controls, and energy. It is reasonably foreseeable that they will be no more than those for construction.

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the total construction GHG emissions were calculated, amortized over 35-year lifetime, and included in the emissions inventory to account for one-time GHG emissions from construction phase of the proposed Project.

The estimated total GHG emissions during construction and decommissioning of the proposed Project would be approximately 968 metric tons of carbon dioxide equivalent emissions (MTCO2e). Estimated Project-generated construction and decommissioning emissions amortized over 35 years would be approximately 28 MTCO2e per year (Appendix A). Therefore, impacts would be less than significant, and no mitigation measures are necessary.

Operational Emissions
Long-term reduction in regional GHG emissions from proposed Project operations is expected to more than offset the emissions during construction and decommissioning, resulting in an overall net benefit in terms of GHG emission reduction. Even with decommissioning emissions included, the proposed Project’s annual amortized GHG impact of 28 MTCO2e/yr would be less than 1 percent of the current interim South Coast AQMD GHG significance threshold of 3,000 MTCO2e/yr (Appendix A).

Additionally, the proposed Project would provide the City and State of California with a reliable BESS facility designed to receive, store, and discharge electricity from the electric grid managed by the California Independent System Operator (CAISO), including renewable energy produced by existing solar and wind resources in the region. The proposed BESS facility is intended to efficiently capture and manage renewable energy, using a proven and established energy storage technology that is efficient, has low maintenance requirements, and is recyclable. In turn, this would help reduce GHG emissions.

Overall, development and operation of the proposed Project would not generate annual GHG emissions that exceed the South Coast AQMD GHG bright-line threshold of 3,000 MTCO2e per year for development projects (South Coast AQMD 2010). Therefore, the proposed Project’s cumulative contribution to GHG emissions would be less than significant and no mitigation measures are necessary.
b) Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases??
The following evaluates consistency of the proposed Project to the CARB’s 2022 Scoping Plan and SCAG’s RTP/SCS.

CARB Scoping Plan
The latest 2022 Climate Change Scoping Plan outlines the State’s strategies to reduce GHG emissions in accordance with the targets established under AB 32, SB 32, and AB 1279 (CARB

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2022). The Scoping Plan is applicable to State agencies and is not directly applicable to cities/counties and individual projects. However, new regulations adopted by the state agencies outlined in the Scoping Plan result in GHG emissions reductions at the local level. As a result, local jurisdictions benefit from reductions in transportation emissions rates, increases in water efficiency in the building and landscape codes, and other statewide actions that affect a local jurisdiction’s emissions inventory from the top down. Statewide strategies to reduce GHG emissions include the Low Carbon Fuel Standard (LCFS) and changes in the corporate average fuel economy standards (e.g., Pavley I and Pavley California Advanced Clean Cars program).

The proposed Project’s GHG emissions would be reduced through compliance with the programs and regulations identified by the Scoping Plan and implemented by state, regional, and local agencies to achieve the statewide GHG reduction goals of AB 32, SB 32, and AB 1279. Specifically, the proposed BESS facility is intended to efficiently capture and manage renewable energy. By storing excess electricity generated from solar and wind resources and discharging it during periods of high demand or low renewable output, BESS helps balance the grid and reduce reliance on fossil-fuel-powered plants. The proposed BESS facility would also support grid reliability and contribute to California’s carbon neutrality goal aligned with CARB 2022 Scoping Plan.

Furthermore, the proposed Project is expected to result in an overall net benefit in terms of GHG emission reductions by supporting zero emission power generation technology and providing storage capacity for intermittent renewable energy (Appendix A). Thus, the proposed Project would not conflict with the strategies identified to implement the CARB 2022 Scoping Plan.

Impacts would be less than significant, and no mitigation measures are necessary.

SCAG’s Regional Transportation Plan/Sustainable Communities Strategy Connect SoCal is a long-term plan for Southern California region that details the development, integrated management and operation of transportation systems and facilities that will function as an intermodal transportation network for the SCAG metropolitan planning area (SCAG 2024).

This plan outlines a forecasted development pattern that demonstrates how the region can sustainably accommodate needed housing and job centers with multimodal mobility options. The overarching vision is to expand alternatives to driving, advance the transition to cleantransportation technologies, promote integrated and safe transit networks, and foster transitoriented development in compact and mixed-use developments (SCAG 2024).

In addition, Connect SoCal is supported by a combination of transportation and land use strategies that outline how the region can achieve California’s GHG-emission-reduction goals and federal Clean Air Act requirements. The projected regional development, when integrated with the proposed regional transportation network in Connect SoCal, would reduce per-capita GHG emissions related to vehicular travel and achieve the GHG reduction per capita targets for the SCAG region. The Connect SoCal Plan does not require that local general plans, specific plans, or zoning be consistent with the SCS, but provides incentives for consistency to governments and developers.

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Based on the traffic study, the proposed Project would have up to two employees on-site daily and require infrequent maintenance vehicle trips, which will result in negligible impacts from worker trips as the proposed Project is designed for remote operation. As further described in Section XVII, Transportation, worker and vendor trips during construction would be temporary and operation of the proposed BESS facility would result in negligible vehicle trips. Therefore, the proposed Project screens out of the vehicle miles traveled (VMT) analysis and would not result in a VMT impact. Overall, the proposed Project would not interfere with SCAG’s ability to implement the regional strategies in Connect SoCal. Therefore, impacts would be less than significant, and no mitigation measures are necessary.

IX. Hazards and Hazardous Materials
Would the project:

Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Create a significant hazard to the public or
the environment through the routine
transport, use, or disposal of hazardous
materials?
☐ ☐ ☒ ☐
b) Create a significant hazard to the public or
the environment through reasonably
foreseeable upset and accident conditions
involving the release of hazardous
materials into the environment?
☐ ☐ ☒ ☐
c) Emit hazardous emissions or handle
hazardous or acutely hazardous materials,
substances, or waste within one-quarter
mile of an existing or proposed school?
☐ ☐ ☒ ☐
d) Be located on a site which is included on a
list of hazardous materials sites compiled
pursuant to Government Code § 65962.5
and, as a result, would it create a
significant hazard to the public or the
environment?
☐ ☒ ☐ ☐

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Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
e) For a project located within an airport land
use plan or, where such a plan has not
been adopted, within two miles of a public
airport or public use airport, would the
project result in a safety hazard or
excessive noise for people residing or
working in the project area?
☐ ☐ ☐ ☒
f) Impair implementation of or physically
interfere with an adopted emergency
response plan or emergency evacuation
plan?
☐ ☐ ☒ ☐
g) Expose people or structures, either
directly or indirectly, to a significant risk of
loss, injury or death involving wildland
fires?
☐ ☐ ☐ ☒
The analysis in this section is based partly on the following technical studies, which are included as Appendices F through O to this Initial Study.
 Phase I Environmental Site Assessment – 16207 Gale Avenue 16207 and 16209 Gale Avenue, Terracon, January 27, 2025. (Appendix F)
 Phase I Environmental Site Assessment – 16233 Gale Avenue 16233 and 16235 Gale Avenue, Terracon, January 27, 2025. (Appendix G)
 Phase I Environmental Site Assessment – 16253 – 16293 Gale Avenue, Terracon, August 23, 2024. (Appendix H)
 Limited Site Investigation – 16207 Gale Avenue 16207 and 16209 Gale Avenue, Terracon, March 26, 2025. (Appendix I)
 Limited Site Investigation – 16233 Gale Avenue 16233 and 16235 Gale Avenue, Terracon, March 26, 2025. (Appendix J)
 Revised Soil and Groundwater Management Plan, TRC, September 2025. (Appendix K)  Hazardous Materials and Safety Memorandum, TRC, February 2025. (Appendix L)

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 Plume Study, Hazard Dynamics, August 14, 2025. (Appendix M)  EMF Study Report, Quanta Technology, August 14, 2025. (Appendix N)  Emergency Air Toxics Analysis, PlaceWorks, September 17, 2025. (Appendix O)

DISCUSSION
a) Would the proposed project create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials? The term “hazardous material” can be defined in different ways. For purposes of this environmental document, the definition of “hazardous material” is the one outlined in the California Health and Safety Code, Section 25501, summarized below:

Hazardous materials that, because of their quantity, concentration, or physical or chemical characteristics, pose a significant present or potential hazard to human health and safety or to the environment if released into the workplace or the environment. Hazardous materials include, but are not limited to, hazardous substances, hazardous waste, and any material that a handler or the unified program agency has a reasonable basis for believing that it would be injurious to the health and safety of persons or harmful to the environment if released into the workplace or the environment.
“Hazardous waste” is a subset of hazardous materials, and the definition is essentially the same as in the California Health and Safety Code, Section 25117, and in the California Code of Regulations, Title 22, Section 66261.2:

Hazardous wastes are those that, because of their quantity, concentration, or physical, chemical, or infectious characteristics, may either cause, or significantly contribute to an increase in mortality or an increase in serious illness, or pose a substantial present or potential hazard to human health or the environment when improperly treated, stored, transported, disposed of, or otherwise managed.

Hazardous materials can be categorized as hazardous nonradioactive chemical materials, radioactive materials, and biohazardous materials (infectious agents such as microorganisms, bacteria, molds, parasites, viruses, and medical waste).

Exposure of the public or the environment to hazardous materials could occur through but not limited to the following means: improper handling or use of hazardous materials or waste, particularly by untrained personnel; transportation accident; environmentally unsound disposal methods; and/or fire, explosion, or other emergencies. The severity of potential effects varies

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with the activity conducted, the concentration and type of hazardous material or wastes present, and the proximity of sensitive receptors.

The Project Site is developed with warehouse, manufacturing, and industrial uses. Other site features include surface parking areas; outdoor storage and loading/unloading areas; driveways that connect to the internal parking and circulation improvements; and various hardscape and landscape improvements. The Project Site is almost entirely covered by impervious surfaces (pavement, buildings, and loading docks). An SCE overhead electric distribution line currently passes through the eastern portion of the site in a generally north-south direction. A segment of another SCE overhead distribution line is in the western portion of the site. The Project Site is surrounded by a mix of uses, including industrial and warehouse uses to the north and west, the SCE Walnut Substation to the east, and residential uses to the south beyond Gale Avenue in the unincorporated Los Angeles County community of Hacienda Heights (see Figure 3, Aerial View).

Construction Activities
Project-related construction activities would involve the use of hazardous materials including cleansers and degreasers; fluids used in routine maintenance and operation of construction equipment, such as oil and lubricants; fertilizers; pesticides; and architectural coatings including paints. Additionally, petroleum such as diesel or gasoline may be stored onsite during construction to fuel construction equipment though it is not anticipated to be stored onsite during the operation of the site. However, the materials used would not be in such quantities or stored in such a manner as to pose a significant safety hazard. These activities would also be short-term or one time in nature and would cease upon completion of the proposed Project’s construction phase.

The use, storage, transport, and disposal of construction-related hazardous materials would be required to conform to federal, state, and local requirements as set forth by the US Environmental Protection Agency, Department of Toxic Substances Control (DTSC), California Occupational Safety and Health Administration (Cal/OSHA), Caltrans, Resource Conservation and Recovery Act, and Los Angeles County Fire Department (LACoFD)(the Certified Unified Program Agency for Los Angeles County), and the US Department of Transportation Lithium Battery Guide for Shippers The US Department of Transportation Lithium Battery Guide for Shippers assist shippers to safely package lithium cells and batteries for transport by all modes according to the latest (May 10, 2024; HM-215Q) regulatory requirements. Compliance with applicable laws and regulations governing the use, storage, transportation, and disposal of hazardous materials would ensure that all potentially hazardous materials are used and handled in an appropriate manner and would minimize the potential for safety impacts. For example, all spills or leakage of petroleum products during construction activities are required to be immediately contained, the hazardous material identified, and the material remediated in compliance with applicable state and local regulations for the cleanup and disposal of that contaminant. All contaminated waste would be

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required to be collected and disposed of at an appropriately licensed disposal or treatment facility.

Additionally, because construction would disturb more than one acre, the proposed Project will be required to apply for and comply with the State General Permit for stormwater discharges from construction sites. For coverage under the permit, the proposed Project would need to submit a Storm Water Pollution Prevention Plan (SWPPP) with best management practices to be implemented to prevent stormwater pollution. Construction best management practices include storage and use of hazardous materials under safeguards to prevent releases to soil or water.

The proposed Project would also include the construction of a gen-tie line that would connect the Project Site to the existing SCE Substation. Construction of the gen-tie line would include typical hazardous materials found during a construction phase, which is described above.

Additionally, the materials used would not pose a significant safety hazard and would be shortterm or one time in nature and would cease upon completion of the proposed Project’s construction phase. Furthermore, the existing SCE overhead power lines that abut the entire stretch of eastern Project Site boundary would not be affected as a result of Project implementation.

Site Reconnaissance
As part of the Phase I ESAs, two separate site reconnaissance occurred with one occurring on August 21, 2024, and the other on October 28, 2024. Per the Phase I ESAs, there was evidence of the following occurring on the Project Site:
 Air Compressors;
 Ventilation hoods and/or incinerators;
 Heating and/or cooling systems;
 Other processes or equipment;
 Aboveground storage tanks;
 Drums, barrels, and/or containers ≥ 5 gallons;
 Sumps, cisterns, French drains, catch basins, and/or dry wells;  Interior floor drains;
 Transformers and/or capacitors;
 Stained pavement or similar surface;
 Trash, debris, and/or other waste materials;
 Dumping or disposal areas;
 Soil Borings.

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Though these site characteristics did occur during both site reconnaissance, none of the site characteristics represented a REC.

Phase I ESAs and LSIs
Three Phase I Environmental Site Assessment Reports (Phase I ESAs) and two Limited Site Investigations (LSIs) were prepared for the proposed Project. These Phase I ESAs involved a search of local, state, and federal databases for known hazardous or contaminated material sites, a site reconnaissance, a review of historical aerial photographs, and research and interviews with representatives of the public, property ownership, site manager, and regulatory agencies (Appendices F through H). The purpose of the Phase I ESAs was to evaluate the likelihood that hazardous materials may be present in soil beneath the Project Site as a result of on- or off-site activities.

The objective of the LSIs was to assess the presence of chemicals commonly associated with RECs on the Project Site at concentrations above laboratory reporting and/or method detection limits in the on-site soil, and soil gas (Appendices I and J).

The Phase I ESAs were performed in conformance with the scope and limitations of the American Society for Testing and Materials (ASTM) E1527-21 standards. The ASTM E1527-21 Standard defines a Recognized Environmental Concern (REC) in part as “the presence or likely presence of any hazardous substances or petroleum products in, on, or at a property: (1) due to any release to the environment; (2) under conditions indicative of a release to the environment; or (3) under conditions that pose a material threat of a future release to the environment.” The Phase I ESAs and LSIs concluded that there is evidence of four RECs on the Project Site.

Historical records show that the site remained undeveloped or in agricultural use from as early as 1894 until 1962. Although the site itself was used for agriculture from at least 1928 to 1964, no evidence of pesticide or herbicide misuse was observed, and redevelopment in 1962 likely mixed shallow soils. Because the site is now mostly covered by buildings and pavement, the historical agricultural use does not represent a REC.

In approximately 1962, the site was developed with the existing industrial warehouse, located in the northern portion of the Project Site and abutting Ward Way, and a parking lot. In 1970, the site was occupied by a stainless-steel commercial appliance manufacturer, which operated for nearly 39 years until 2009. In 1990, an auxiliary roofed area was added to the Project Site, and the site was also home to a stainless-steel sheet metal manufacturer. From 2009 to 2020, a machine shop operated on-site, overlapping with an auto and tent parts warehouse that occupied the property from 2009 to 2022.

Based on the longevity of industrial operations associated with a stainless-steel commercial appliance manufacturer (approximately 39 years), lack of information concerning waste streams

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for the site, irregular asphalt patching in the pavement areas during the site reconnaissance, and the likely use of petroleum and solvents/chemicals as part of the historical operations, the former manufacturing operations represents a REC to the site.

Based on the longevity of the Metal Cutting Service operations (approximately 49 years), the likely use of solvents/chemicals as part of the current and historical operations and the proximity and relative topographic up-gradient position to the site, the Metal Cutting Service represents a REC to the site.

The surrounding area also transitioned from agricultural land to developed uses over time. By 1952, a homestead was established on the adjoining southern and western properties, and by the mid-1960s, agricultural uses were replaced with warehouses, parking lots, and Ward Way.

The Project Site was developed with industrial warehouses and parking lots by the early 1980s, while the eastern adjoining properties transitioned from a Christmas tree farm in the 1970s to multi-tenant industrial uses in the 1990s.

As part of the proposed Project, site preparation would include grading and excavation which has the potential to encounter impacted soils and groundwater as described above. The proposed Project has the potential to include constituents of concern (COCs) that could include total petroleum hydrocarbons (TPH) and volatile organic compounds (VOCs). If excavated, impacted soils may result in the generation of waste that would require management and additional precautions during construction. The groundwater in the Project Site vicinity is anticipated to be encountered at depths ranging from approximately 21 to 26 feet below ground (fbg). Based on the maximum depth of the proposed excavation activities (up to 10 fbg), groundwater is not anticipated to be encountered at the Project Site during routine earthwork. However, geotechnical exploration soil borings and/or deep foundations for the interconnection support poles have the potential to encounter groundwater. The proposed Project would implement the Revised Soil and Groundwater Management Plan (SGMP), which provides best management practices (BMPs) for use in the event impacted soil or groundwater is encountered during construction of the proposed Project (Appendix K). BMPs, which would be required as conditions of approval for the proposed Project include (APM 1):
 Requiring the General Contractor (GC) and its subcontractors to instruct and train workers of the potential for encountering soil contaminated by past activities and to implement measures consistent with the SGMP. If impacted soil or unexpected underground features (e.g., storage tanks, septic pits, hydraulic lifts, clarifiers) suspected of containing hazardous substances are discovered during excavation, the Project owner must be notified immediately.

Signs such as odors, staining, or debris require the Foreman to notify the Project owner, who must then seek guidance from a qualified environmental professional on further testing or remediation.

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 Implementing Health and Safety Plans (HASPs) during all phases of work. The HASP must be prepared by a qualified professional in compliance with OSHA and Cal-OSHA HAZWOPER standards and outline administrative and engineering controls and personal protective equipment (PPE) to protect workers throughout all project stages. The GC, environmental consultant, and subcontractor HASPs and BMPs should include hazard assessment and mitigation measures to eliminate or minimize potential exposure pathways including inhalation of dust and vapors; dermal contact with impacted soil; and dermal contact or ingestion of groundwater.
 The environmental consultant shall be onsite when substantive grading or excavations are occurring in soils not previously disturbed by project construction. The GC and environmental consultant shall implement procedures and practices to ensure that their respective workers are trained to be continually observant for potentially impacted soils.

The Project owner, or the GC and environmental consultant at the Project owner’s direction, shall provide for active, periodic field oversight including:
 Screening exposed and excavated soils:
- Using visual indicators and instrumentation (e.g., calibrated photoionization detector) to identify potentially TPH- and VOC-impacted soils.
- Based on visual indicators or instrumentation, potential collection of select soil samples for laboratory analysis for contaminants of concern (COCs) including TPH, VOCs, and any additional profile testing that may be required by waste disposal facilities, using EPA approved methods. At a minimum, this testing would include profiling removed soil waste that will be transported for off-site disposal.  Excavation, separation, and documentation of potentially impacted soils.  If appropriate, collection of select samples for laboratory analysis:
- Soils remaining where impacted soils have been removed. - Impacted soils designated for reuse, additional sampling, and/or for off-site disposal.  Impacted soils designated for reuse, additional sampling, and/or for off-site disposal.  If impacted soil is encountered, it should be removed and segregated in a manner to minimize over-excavation or mixing with clean soil. Impacted soils should be removed from the Project Site frequently to minimize the potential for contact between stormwater and any impacted soils identified during excavation. Excavation in areas where impacted soil is encountered should be protected from stormwater run-on by clean soil berms or other diversionary features to direct water away from any exposed impacted soils. Other BMP measures such as covering impacted soils with plastic shall be implemented to prevent or minimize stormwater contact with impacted soils.

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 If impacted soil is encountered, it should be removed and segregated in a manner to minimize over-excavation or mixing with clean soil.
 Impacted soils should be removed from the Project Site frequently to minimize the potential for contact between stormwater and any impacted soils identified during excavation.  Excavation in areas where impacted soil is encountered should be protected from stormwater run-on by clean soil berms or other diversionary features to direct water away from any exposed impacted soils.
 The GC and subcontractors should be aware of the regulatory implications of improper management or disposal of contaminated soils. If changed conditions are encountered (i.e., petroleum hydrocarbons, USTs, or obviously impacted soils), the excavated impacted soil shall be stockpiled separately on plastic sheeting under the direction of the environmental consultant, covered with plastic sheeting, and secured with fiber rolls or equivalent until they can be properly evaluated. Workers in physical contact with obviously impacted environmental media should have OSHA HAZWOPER training consistent with 29 CFR 1910.120.

If chemical odors, stained or saturated soils, a sheen on water collected in excavations, detected concentrations of COCs from laboratory analysis of select soil samples, or other evidence of potential chemical contamination is encountered during excavation activities, work in the area of the discovery shall cease immediately and the Project owner shall be notified.  If impacted soils are identified, the impacted soil shall be characterized as needed to determine which of the waste categories it fits in. If off-site disposal is required characterization will also be required by the receiving facility. Based on historical knowledge of the Site and vicinity, if impacted soils are encountered, typical waste profiling parameters may include TPH carbon chain by EPA Method 8015M and VOCs by EPA Method 8260B. If impacted soil is excavated, proper classification is the responsibility of the Generator, which will be the Project owner unless otherwise dictated by contract or state law. All impacted soil characterization and results as well as manifesting shall be coordinated with the Project owner.

Only an authorized transporter can transport soils offsite. Transport and shipping documentation shall be coordinated with the Project owner. Receiving facilities must be licensed to receive the types and concentrations of COCs in the soil shipment.
 If stormwater collects in any excavation during construction, it should be visually inspected for evidence of sheen or other indication of Contaminants of Concern (COC) presence such as visually impacted soil in the excavation wall. If groundwater or storm water that has come in contact with potentially impacted soils is to be removed from an excavation, the water shall

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be managed as potentially contaminated and evaluated through chemical analysis prior to discharge and/or off-site disposal. Samples shall be collected by a qualified person and characterization shall be coordinated with the GC.
 Produced and/or captured groundwater or stormwater that has contacted impacted soils shall be containerized in suitable portable aboveground storage tanks (ASTs) compatible with the potential COCs and properly secured to prevent unsafe exposure, contact with stormwater, or discharge to the surface, storm drains, or waterways.  Dust control measures will be implemented in accordance with SCAQMD requirements.  Project construction will require coverage under State Water Resources Control Board Construction General Permit Order 2022-0057-DWQ for storm water discharges from construction sites.
 Document excavation activities and receipt of any necessary laboratory analytical results and waste manifest documentation.

Demolition Activities
Construction would start with the removal of existing buildings, foundations, asphalt, concrete, and landscaping on the Project Site. After all hazardous materials and universal wastes are removed from the buildings and fuel and water and power sources have been safely disconnected, the buildings, foundations, asphalt, and concrete would be demolished and the debris hauled off-site using common construction equipment such as excavators, bulldozers, and haul trucks. Most demolition debris would be metal and concrete rubble that would be sent to a recycler following City and State requirements.

Given the age of the buildings currently on the Project Site (prior to 1980), they have the potential to contain asbestos containing materials (ACMs) and lead based paints. Impacts related to lead concentrations would not be significant because the project developer would be required to follow all applicable federal and state regulations regarding lead concentrations. During demolition activities, all building materials containing lead-based paint would be required to be removed in accordance with Cal/OSHA standards contained in Title 8 of the California Code of Regulations (CCR), Section 1532.1, including employee training, employee air monitoring, and dust control. Any debris or soil containing lead-based paint or coatings would be required to be disposed of at landfills that meet acceptance criteria for the type of lead being disposed.

In addition, the proposed Project would be required to follow all applicable federal, state, and local regulations, standards, and codes governing abatement, transport, and disposal of ACMs.

These would include the following:

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 Work performed during any activities (i.e., drilling, cutting, sanding, scraping) that disturb identified ACM materials must be done in compliance with the most recent edition of all applicable federal, state, and local regulations, standards, and codes governing abatement, transport, and disposal of ACMs.
 Materials encountered in the buildings that are not part of the HMS must be properly sampled for the content of asbestos or assumed to be asbestos containing prior to any disturbance.  Prior to activities that will disturb identified or assumed ACMs, a Cal/OSHA registered and California licensed asbestos contractor must be utilized for abatement of ACM that will be impacted and that all abatement operations be conducted under the direction of a California Certified Asbestos Consultant.
 Removal of ≥100 square feet of identified or suspected ACM requires a 14-calendar day written notification to the South Coast AQMD, notification to Cal/OSHA in writing at least 24 hours prior to the initiation of such activities and obtaining the appropriate LACoFD permit.  Notification to employees and contractors working within the building should be made in accordance with the California Health and Safety Code, Section 25915 et. seq. and Proposition

65.  All potentially friable ACMs shall be removed in accordance with National Emission Standards for Air Pollution guidelines prior to demolition or renovation activities that may disturb ACMs.

All demolition activities shall be undertaken in accordance with Cal/OSHA standards contained in Title 8, CCR, Section 1529, to protect workers from asbestos exposure.

Project Operation
The proposed Project would be designed for remote operation and would also be staffed with up to two employees on-site daily, with the ability to charge and discharge electricity around the clock. Routine office operations would not generate significant litter or waste streams, aside from small amounts of packaging materials, shipping waste, and household-type refuse from maintenance activities. Operation of lithium iron phosphate (LFP) energy storage facilities requires few hazardous materials. Hazardous materials expected to be needed include mineral oil, coolant, and refrigerant. In addition, the backup generator would have a fuel tank and lubricating oil. LFP also contains hazardous materials and spent or damaged batteries can fall under hazardous or universal waste management regulations. Spent batteries would be returned to the manufacturer for recycling, while other replaced equipment would be recycled or disposed of in compliance with state regulations.

The proposed Project may generate small quantities of hazardous waste, including used rags, aerosol cans, and electronic waste, that would be subject to regulation under CCR Title 22,

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Division 4.5 and would be expected to meet the criteria for Small Quantity Generator. State regulations in CCR Title 22 Division 4.5 require facilities generating hazardous waste to have preparedness and prevention measures in place for emergency response minimizing the potential for a release of hazardous waste and to support prompt and appropriate response in the event of an incident including internal communications or alarm systems, fire control, spill control and decontamination equipment, fire suppression water systems, and posted emergency information. Hazardous waste generators are required to ensure that employees are trained and knowledgeable on emergency procedures and to attempt to make arrangement with local emergency responder appropriate for the wastes managed (Appendix L).

Additionally, oil-filled transformers will be subject to Code of Federal Regulations Title 40 Part 112 and California Health and Safety Code Chapter 6.67 requirements for development and implementation of a Spill Prevention Control and Countermeasures Plan (SPCC) including secondary containment for aboveground bulk oil storage containers, routine inspections for oil containment integrity and ensuring collected stormwater is oil-free before it is released, and contingency planning for prompt and appropriate response to a potential release. SPCC requirements would also apply to a back-up generator fuel tank and if a temporary bulk fuel tank is provided onsite during construction. The requirements in these regulations are designed to minimize the potential for an oil spill from equipment to impact waters.

Although routine storage of hazardous materials is not anticipated, certain equipment would contain potentially hazardous substances such as mineral oil in transformers, refrigerant and pressurized gases in cooling systems, and lithium-ion batteries. Additional materials with pressure-release hazards, such as nitrogen cylinders or fire suppression agents, may also be included in the final design. All hazardous materials meeting California reporting thresholds would be documented in the state’s Environmental Reporting System. The proposed Project would also be required to obtain permits from the Los Angeles County Fire Department (LACoFD), submit a hazardous materials disclosure form, and comply with all applicable regulations through the preparation of required plans, including a Hazardous Materials Business Plan, SPCC Plan, and emergency response plans.

The proposed Project would also adhere to Section 311 in the Federal Emergency Planning and Community Right-to-Know Act (EPCRA) which requires facilities that have hazardous chemicals to report the presence of such chemicals onsite to the State and local emergency planning committees (LEPC) if the chemicals are present above threshold quantities. The proposed Project would also adhere to the Federal and State OSHA regulations that require all employees to be informed and trained on hazardous materials in their work area at the time of their assignments.

During operations, the proposed Project would need to implement and maintain engineering and other best management practices required under the Los Angeles County Municipal Separate Storm Sewer System (MS4) permit. Operations requirements for the proposed Project also

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include best management practices for prevention of stormwater pollution. These measures include proper waste management to prevent contact with runoff, and storage and handling hazardous materials following measures to prevent spills or other releases that could be contacted by precipitation or runoff.

Soil Gas Sampling
On February 17, 2025, four soil borings were completed at a maximum depth of 20 feet below ground to collect soil samples to study the above-mentioned RECs on the Project Site (Appendices I and J). On February 17, 2024, 2 single nested soil gas probes and 2 dual-nested soil gas probes were installed adjacent to the existing building on the Project Site for the collection of soil gas samples. The samples were analyzed using standard Environmental Protection Agency (EPA) methods.

The analytical data was screened using the current residential and commercial Environmental Screening Levels (ESLs) published by San Francisco Bay Regional Water Quality Control Board. For analytes without an applicable ESL, EPA's Vapor Intrusion Screening Levels (VISLs) were used to supplement the ESLs for the soil gas samples, as applicable and necessary. The detection of an analyte at a concentration above a screening level does not necessarily indicate an adverse impact to human health or the environment; however, an exceedance of a screening level may indicate that additional investigation is warranted.

The soil analytical results indicate VOCs, TPH gasoline range organics (TPH-GRO), diesel range organics (TPH-DRO), and motor oil range organics (TPH-MORO) were not detected above laboratory reporting limits (RLs). The soil analytical results indicated metals were not detected above the specified laboratory RLs with the exception of arsenic, barium, chromium, cobalt, copper, lead, nickel, vanadium, and zinc. The concentrations of the listed metals are within the range of naturally occurring “background” concentrations, and/or were below residential, commercial, and construction worker ESLs except for Arsenic, which was detected in one sample.

Soil gas sample analytical results indicate that several VOCs were detected above their respective laboratory method detection limits (MDLs). The soil gas sample analytical results were compared to the ESLs, which revealed that concentrations of 1,1,2,2-Tetrachloroethane, 1,3-Butadiene, Benzene, tetrachloroethane (PCE), and trichloroethene (TCE) were detected in one or more samples above their respective ESLs for residential or commercial land use.

The proposed Project would include the construction of an occupied building on the Project Site.

As a result of the soil gas sample analytical results, a vapor intrusion mitigation system (VIMS) would be implemented with the planned future building construction to address the documented soil gas concentrations detected (APM 2, which would be included as a condition of approval for the proposed Project). Vapor intrusion mitigation methods are classified as either “passive” or “active.” Passive methods prevent the entry of chemical vapors into the building, while active

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methods change the pressure difference between the sub-slab and the inside of the building to keep vapors out. Passive vapor intrusion methods could include the following:
 Sealing openings involves filling in cracks in the floor slab and gaps around pipes and utility lines found in basement walls. Concrete can be poured over unfinished dirt floors.  Installing vapor barriers involves placing sheets of “geomembrane” or strong plastic beneath a building to prevent vapor entry. Vapor barriers are best installed during building construction but can be installed in existing buildings that have crawl spaces.  Passive venting involves installing a venting layer beneath a building. Wind or the build-up of vapors causes vapors to move through the venting layer toward the sides of the building where it is vented outdoors. A venting layer can be installed prior to building construction as well as within existing buildings. It is usually used with a vapor barrier.

Active vapor intrusion methods could include the following:
 Sub-slab depressurization involves connecting a blower (an electric fan) to a small suction pit dug into the slab in order to vent vapors outdoors.
 Building over-pressurization involves adjusting the building’s heating, ventilation, and airconditioning system to increase the pressure indoors relative to the sub-slab area. This method is typically used for office buildings and other large structures (EPA 2012).

Design of this VIMS would be included within the proposed Project’s building permit submittal, as is typical for this type of system, and would be part of the proposed Project design.

Gen-Tie Line EMF Study
The Gen-Tie Line EMF study (Appendix N) evaluated the electric field and magnetic field of the proposed Project. The proposed Project would include a single-circuit 230 kV transmission line extending approximately 72 feet. To ensure conservative and realistic modeling, the study adopted the lowest vertical conductor clearance—68 feet—as the reference height for the analysis. This approach aligns with industry best practices for worst-case exposure modeling under adverse weather conditions.

The methodology for the study of each aspect is as follows:
 Electric Field (EF). The intensity of the EF is measured approximately 6.5 feet above ground.

According to the Institute of Electrical and Electronics Engineers (IEEE) Standard C95.6, under normal load conditions, for the public, the maximum permissible exposure (MPE) to electric fields is 10 kV/m, and MPE outside the line right of way (ROW) is 5 kV/m.

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 Magnetic Field (MF). The intensity of the MF is measured 6.5 feet above the ground. Based on the technical research, the International Commission on Non-Ionizing Radiation Protection (ICNIRP) has made a series of recommendations for limiting EMF exposure to human beings:
public exposure to magnetic fields should be limited to 2,000 mG (200 mT) (ICNIRP 2010). The International Commission on Non-ionizing Radiation Protection (INIRC-IRPA) recommends a public exposure MF guideline of 1 gauss.

The EMF study concluded that the gen-tie line emitted a maximum of just over 0.9 kV/m at about 20 feet from the gen-tie line. As stated above, the MPE to electric fields is 10 kV/m with the proposed gen-tie line below the MPE. The magnetic field exposure measured at 0.03 G or 30mG at the center of the gen-tie line. Public exposure to magnetic fields should be limited to 1 G or 2,000 mG. The proposed Project’s gen-tie line would be below the maximum magnetic field exposure.

Emergency Action Plan
Pursuant to the provisions of Section 761.3(g)(1) of the Public Utilities Code, battery energy storage facilities are required to have an emergency response and an emergency action plan (EAP). As stated in APM-3, the project applicant would prepare an EAP for submittal to and approval by OSHA in accordance with the provisions of Standard 1910.38 (Emergency action plans) of Part 1910 (Occupational Safety and Health Standards). An EAP is a written document outlining employee and employer actions for workplace emergencies like fires, chemical releases, or natural disasters, requiring procedures for reporting, evacuation, accounting for personnel, and performing rescue/medical duties.

The EAP covers any potential onsite chemical spills, fires, and earthquakes involving hazardous materials such as diesel fuel, gasoline, and motor oil for vehicles and LFP batteries. In the event of an accidental release of hazardous materials, various notifications would be made. These include notifying internal and onsite personnel, emergency responders including LACoFD, neighboring facilities that may be affected by an onsite release, and the local Certified Unified Program Agency (CUPA) and the State Warning Center, if needed. Additionally, prior to resuming operation of the site use, the local CUPA and LACoFD are required to be notified that the Project Site is in compliance with the requirements for storage and disposal of recovered waste, contaminated soil or surface water, or any other material that results from an explosion, fire, or release at the facility and ensure that no material that is incompatible with the released material is transferred, stored, or disposed of in areas of the facility affected by the incident until clean up procedures are completed. All agencies responsible for emergency response to the Project Site and surrounding area are required to be included in the EAP.

The EAP also provides guidance for evacuation procedures if there is a need to evacuate the Project Site. These procedures include installing an onsite alarm system(s) that would broadcast

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a warning siren or horn to alert employees to evacuate, utilizing the established muster points near the facility entrances and ensuring no workers or visitors leave the site without checking in with the emergency coordinator, and posting the established evacuation routes visibly and clearly for employees.

Additionally, the lithium-ion batteries, which contain hazardous materials, would be provided on racks within battery enclosures. As a condition of approval, the proposed Project would be properly segregated from other surrounding industrial uses and would include all proper safeguards, including a reinforced 10-foot-high CMU block wall to be built along southern boundary of the Project Site. Additionally, per the conditions of approval, none of the battery enclosures would be permitted to be within 25 feet of any property line, and the battery enclosures would be required to be equipped with internal, failsafe heat and gas detection and alarm systems, which shall provide audio and visual early warnings of increases in heat or gas in any battery enclosure to a third-party reporting station that actively monitors for such warnings on a 24/7/365 basis. Furthermore, whenever any of the batteries fail, reach the end of their useful life, or need to be disposed of due to a legal requirement or due to their continued presence posing an added risk to public health or safety, the project applicant would be required to promptly discontinue use and dispose of such batteries in accordance with all applicable laws and regulations, including but not limited to those related to hazardous materials and hazardous waste.

Hazardous Materials Business Plan
Section 25505 of the Health & Safety Code establishes requirements for hazardous material business plans (HMBPs) in California. An HMBP would be required to be prepared for the proposed Project in accordance with established requirements and submitted to the City and LACoFD for review and approval. The requirements for HMBPs, which will be added as a condition of approval for the proposed Project, include:
 An inventory of hazardous materials onsite.
 An Emergency Action Plan including procedures and contacts for communicating an immediate response to a reportable release or threatened release of a hazardous material, and procedures to mitigate a release or threatened release.  Employee training in project safety procedures and emergency response plans and procedures in the event of a reportable release or threatened release.  A site map that depicts north orientation, loading areas, internal roads, adjacent streets, storm and sewer drains, access and exit points, emergency shutoffs, evacuation staging areas, hazardous material handling and storage areas, and emergency response equipment.

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Decommissioning
For purposes of this analysis, the proposed Project is anticipated to be decommissioned after 35 years of operation. Decommissioning activities would involve de-energizing all equipment prior to removal. Where possible, equipment would be salvaged, placed in appropriate shipping containers, and secured in a truck transport trailer for shipment off-site to be recycled or disposed of at an appropriately licensed disposal facility. The demolition debris and removed equipment may be cut or dismantled into pieces that can be safely lifted or carried with the equipment being used. Additionally, the batteries would be collected and recycled to avoid the potential for batteries to be disposed of as municipal waste. All decommissioning activities would adhere to the requirements set forth by the City, and be in accordance with all applicable federal and state regulations at the time of decommissioning and as determined by City. Adherence to the applicable regulations would help ensure that the proposed project would not create a significant hazard to the public or the environment as a result of the decommission activities that would be undertaken. Therefore, compliance with the above requirements would reduce impacts to less than significant and no mitigation measures are necessary. f) Would the proposed project create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment?
The proposed Project includes modular outdoor-rated PowerTitan 2.0 battery units made by Sungrow. The units contain lithium-ion batteries installed in racks inside the enclosure. Each enclosure contains six racks with eight modules each, for a total of 48 liquid-cooled battery modules. A Power Conversion System (PCS), which manages how electricity flows between the batteries and the electric grid or facility load, is underneath each rack. The PowerTitan 2.0 includes a vent panel, heat and smoke detectors, a sound beacon, ventilation system, and flammable gas detector. The PowerTitan 2.0 enclosures include an NFPA 69 ventilation system to expel battery vent gas in case of cell failure. The exhaust fan activates upon detection of hydrogen gas and expels air and vent gas. This system is designed to prevent an explosive atmosphere. An inlet louver would be located on the left side of the enclosure near the bottom, and an exhaust fan would be located on top of the enclosure near the right side. The exhaust fan would activate upon detection of hydrogen gas and expels air and vent gas.

Following is a discussion of the potential hazardous impacts that could arise through the accidental release of hazardous materials from the proposed Project. No toxic air contaminants are emitted during normal operation of a BESS. However, there is the potential for toxic air

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contaminant emissions to be released during a thermal runaway2 event if a fire occurs within a container due to battery malfunction, elevated temperatures, and battery combustion.

Plume Study
A plume study was conducted for the proposed Project to determine toxicity and flammability hazards posed to nearby areas in the unlikely event of a battery failure scenario (Hazard Dynamics 2025; Appendix M). The study considered toxic materials that can be released by lithium iron phosphate (LFP) batteries during thermal failures. It should be noted that the proposed project would use LFP batteries instead which have better thermal stability, longer lifespan, and less air toxic emissions compared to lithium-ion battery packs (i.e., nickel-manganese-cobalt [NMC] lithium-ion batteries) used at older BESS facilities.

Accumulation of flammable battery vent gas outside a failing BESS enclosure was also considered.

Computational fluid dynamics models were utilized to simulate plumes resulting from theoretical battery failure scenarios. The modeled scenarios considered a non-fire scenario in which battery vent gas is released; a small fire scenario; and a large fire scenario. Low and high wind conditions were evaluated based on nearby meteorological data. Toxic gas concentrations 6.6 feet from ground level and flammable gas accumulation surrounding the BESS enclosure were estimated using Fire Dynamics Simulator. The analysis was conducted using a set of worst-case scenarios and included up to a fully involved fire in a single battery unit.

Toxicity hazards may exist alone or in combination with fire and explosion hazards. A significant amount of the gas released during thermal runaway is carbon monoxide (CO), which is toxic.

Depending on the conditions, the combustion of battery gases may burn off some carbon monoxide or create additional carbon monoxide from partially reacted hydrocarbons. Smaller amounts of other toxic gases may also be released depending on the battery cell, whether the gases burn, and if water or other suppression agents are added. Lithium-ion cells in thermal runaway may release hydrogen fluoride (HF), hydrogen chloride (HCl), hydrogen cyanide (HCN), nitrogen dioxide (NO2), sulfur dioxide (SO2), and other gases. When the gases burn, some of the toxic components may be consumed, although others may be generated. Smoke from many fires, including battery fires, is considered hazardous. Smoke typically includes asphyxiant gases, irritant toxic gases, and particulate matter. The introduction of water to a fire may change the composition of the smoke and can create water runoff, which may also contain hazardous substances and alter the toxic release profile. Additionally, when a lithium-ion cell is exposed to high temperatures such as those due to fire exposure or propagating thermal runaway, it produces toxic compounds.
2 Thermal runaway chain reaction is when a battery cell rapidly overheats and cannot cool itself down, leading to escalating temperatures, gas release, and sometimes fire or explosion.

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Failure of lithium-ion cells may result in gas production inside of the cells. When enough gas is produced, a safety vent may open, or the cell package may rupture. The gas mixture released is flammable and toxic and is primarily made up of CO, carbon dioxide (CO2), hydrogen (H2), and an assortment of hydrocarbons. If ignited, the combustion of these gases can lead to a fire or an explosion.

When a lithium-ion cell is exposed to high temperatures such as those due to fire exposure or propagating thermal runaway, it produces toxic compounds. Plastic contained in the battery system may contribute to these toxic combustion products. Such products may include CO, nitrogen oxides (NOx), SO2, HCl, and HF. The quantity of HF produced is related to the electrolyte solvent and the chemical reactions initiated.

Harmful levels of toxic gases are defined as immediately dangerous to life or health (IDLH) and acute exposure guideline levels (AEGL). IDLH is defined as a concentration of any toxic, corrosive, or asphyxiant substance that poses an immediate threat to life, would cause irreversible or delayed adverse health effects, or would interfere with an individual’s ability to escape from a dangerous atmosphere. AEGLs are defined as the health effects of a once-in-a-lifetime exposure to airborne chemicals. AEGL concentrations are provided for different exposure times and health effect levels. Level 1 is discomfort or irritation, Level 2 is the onset of irreversible or serious health effects, and Level 3 describes life-threatening health effects. Toxic gases related to battery energy storage systems along with their IDLH, AEGL-2, and AEGL-1 concentrations are shown in Table 4, Chemical Thresholds During Battery Failure, and are based on an exposure time of 30 minutes.

Table 4 Chemical Thresholds During Battery Failure
Chemical IDLH (ppm) AEGL-3 (ppm) AEGL-2 (ppm) AEGL-1 (ppm) Carbon Monoxide 1,200 600 150 NR
Carbon Dioxide 40,000 NR NR NR
Hydrogen Chloride 50 210 43 1.8
Hydrogen Cyanide 50 21 10 2.5
Hydrogen Fluoride 30 62 34 1
Nitrogen Dioxide 13 25 15 0.50
Nitric Oxide 100 NR NR NR
Sulfur Dioxide 100 30 0.75 0.20
Benzene 500 5,600 1,100 73
Toluene 500 5,200 760 67
Source: Appendix M
Note: NR = Not recommended due to insufficient data

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In case of a toxic gas release, it is expected that the impacted area would be downwind of the site. Prevailing winds generally come from the south-southwest, have an average wind speed of

6.9 mph, have a peak wind speed of 20 mph or more, with conditions calm approximately 20 percent of the time. The assumed wind speed is 15 mph. The nearest residential property is 111 feet away from the BESS enclosure at the edge of the site.

Fire and Toxicity Modeling
Data from the UL 9540A test was used to conduct plume modeling for a number of different failure scenarios. A UL 9540A test forces individual cells, modules, and units into a thermal runaway to evaluate gas release and failure behavior. Gases generated during thermal runaway are collected and analyzed for key chemicals. The Plume Study scenarios included various failure conditions, including different wind speeds, fire sizes, and whether burning occurred. Two heat release rates; a full enclosure fire, and a smaller fire where the enclosure does not fully burn. Fire spreading between modules or units was not modeled, as test data did not show such behavior.

It was assumed that all cells and modules would burn over the course of two hours (half an hour ramp-up, steady burn for an hour, and half an hour ramp-down).

Non-fire scenarios examined the release of lithium-ion battery vent gases without burning.

Several cases were modeled to represent different levels of thermal runaway, including average gas release from a module, the peak module release rate, the maximum release the NFPA 69 ventilation system can handle before exceeding 25 percent of the lower flammability limit (LFL), the failure of a string of batteries, and the failure of an entire unit.

Two cases modeled the average module release both with and without active ventilation. The gas release rate used approximates the average release rate expected from five cells failing at different times. The peak release scenario used the highest instantaneous gas release from a single cell, representing a worst-case module failure. This same rate was also applied to string and unit failure scenarios, assuming two modules fail together for a string and four for a unit.

Simultaneous failure of all modules is highly unlikely. This peak rate was also used to assess larger failures of a string and a unit. The string failure scenario assumes that two modules are failing at the same time, and the unit failure scenario assumes that four modules fail at the same time.

While other modules in a string or unit may also fail, it is unlikely that they would all fail at the same time. For modeling purposes, the most significant components which account for more than 95 percent of the gas are modeled in the non-fire gas release mixture, while minor hydrocarbon elements are approximated as propane.

Plume Toxicity Results
Results were collected for battery vent gases in non-fire scenarios and combustion products in fire scenarios. Concentrations were measured at 6.6 feet above ground—the typical level people would breathe when standing near an incident. Vent gas concentrations remain relatively low

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even near the enclosure and diminish significantly away from the enclosure in scenarios without fire.

In fire scenarios, combustion product concentrations at 6.6 feet above ground stay low when wind speeds are 3.4 mph. At higher wind speeds (15 mph which is in the 99th percentile wind speed at the Project Site), concentrations are higher near the enclosure but decrease quickly with distance. Since only part of the vent gas or combustion products is toxic, actual toxic gas concentrations would be much lower than the total measured values.

The trajectory of the battery vent gas coming out of the enclosure in scenarios without burning depends on the size of gas release, whether the ventilation system is active, and the wind speed.

Because the exhaust fan is on top of the enclosure, it lofts the battery gas upward when activated.

This results in much of the battery gas being above the 6.6-foot level and more rapid mixing of the battery gas with the surrounding air.

The speed of the wind also affects the path and mixing of the battery vent gas expelled from the enclosure. The fire scenarios with greater wind speeds resulted in higher concentrations of combustion products 6.6 ft above ground level. The heat from fire conditions makes gases more buoyant such that they rise away from the ground. In most common wind conditions, fire product concentrations are low at ground level. However, under conditions of high wind, this buoyant effect may be partially overcome. The scenarios with both fire and high winds yielded the highest gas concentrations at the greatest distances. In low wind conditions, combustion products for a small fire also rise but to a lesser degree than for a large fire scenario.

Although multiple toxic gases may be components of battery vent gas, CO is generally the most abundant toxic gas of concern. Many different toxicity levels exist for CO. Table 5 shows the CO concentration thresholds for different toxicity levels and the maximum modeled distance exceeding each threshold including the EPA National Ambient Air Quality Standards (NAAQs), which was created to protect public health from chemical exposure, and OSHA Permissible Exposure Limits (PELs) which were created to protect workers against health effects resulting from exposure to hazardous chemicals. The large fire, high wind scenario was the only scenario with carbon monoxide concentrations that exceeded the IDLH and AEGL levels at 6.6 feet above ground level. The unit gas release scenario with high winds resulted in the worst-case distances at 6.6 feet above ground level. The fire scenarios with low wind remained below all reported toxicity thresholds at 6.6 feet above ground level at all distances.

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