Industry City Council
February 12, 2026

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Table 5 Toxicity Level for CO
Thresholds of Toxicity Level for CO Concentration (ppm) Worst-Case Modeled Distance IDLH 1,200 13 feet
AEGL-3 (30-minute) 600 15 feet
AEGL-2 (30-minute) 150 19 feet
OSHA PEL (8-hour average) 50 42 feet
EPA NAAQ (1-hour) 35 50 feet
Source: Appendix M
Additionally, the only reported TAC emitted from the PowerTitan 2.0 battery cells during thermal runaway testing was carbon monoxide (CO). Although other gases were released during the testing, such as carbon dioxide, hydrogen, methane, ethylene, ethane, and propane, these gases are not classified as TACs; they are primarily flammable gases. Although the presence of acidic gases, such as hydrofluoric acid (HF), hydrogen cyanide (HCN) or hydrogen chloride (HCl), were not tested as part of the plume study, similar studies conducted for similar LFP batteries did not detect these acidic gases during module level testing (Fisher 2023).

Typically, hydrocarbons such as benzene and toluene are the only toxic gas concentrations other than carbon monoxide that are measured as part of the UL 9540A testing process. These do not present significant toxicity hazards compared to carbon monoxide and hydrogen fluoride, as their concentrations in battery gas are usually significantly less.

Flammable Gas Plume
Several thermal runaway scenarios were considered for the flammable gas plume analysis: (1) Average thermal runaway of a single module, (2) Peak thermal runaway of a single module, (3) thermal runaway of a string of modules, and (4) thermal runaway of a BESS unit. Peak thermal runaway is defined as the maximum gas release rate the NFPA 69 ventilation system can handle before the exhaust exceeds 25 percent LFL of the battery gases, a gas release rate representative of the failure of a string of batteries, and a gas release rate representative of a full unit failure.

The average module thermal runaway scenario without ventilation resulted in a flammable region (battery vent gas concentration above LFL) that extended less than four inches vertically only directly over the exhaust fan. The same gas release with ventilation did not result in a flammable region due to the dilution of battery gas resulting from air being mixed in by the exhaust fan.

Neither the low wind nor the high wind unit gas release scenario resulted in the formation of a flammable cloud outside of the enclosure.

Because the unit gas release scenarios did not result in a flammable cloud outside of the enclosure due to the active ventilation system diluting the gas, the active ventilation system would also prevent formation of flammable gas clouds during module and string release

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scenarios. Since the flammable gas cloud is less far reaching than the toxic gas cloud, appropriate setbacks will be dictated by toxic gas plume results.

Conclusion
Based on the model results and the prevailing wind direction at the site (from the southsouthwest), it is unlikely that toxic levels of carbon monoxide that may result in irreversible or serious health effects would reach populated areas in the event of a single BESS unit experiencing a failure event. Carbon monoxide is of primary concern due to its comparatively high concentrations and toxicity. The modeled average carbon monoxide concentrations may be immediately dangerous to life and health up to 13 feet, cause life-threatening health effects (exceed the AEGL-3 level) up to 15 feet, and cause serious health effects (exceed the AEGL-2 level) up to approximately 19 feet from battery unit in a large fire scenario with high winds. The modeled average carbon monoxide concentrations may exceed EPA NAAQ 1-hr levels and cause physical symptoms up to approximately 50 feet from the unit during a unit thermal runaway gas release scenario with high winds. The modeled high wind speed was 15 mph, which is the 99th percentile wind speed at the Project Site and had a concentration of 35 ppm from the nearest residential property which is approximately 111 feet away. No toxicity consequences were present for the modeled scenarios with low wind conditions. Based on worst-case modeled carbon monoxide concentrations that could reach AEGL-2 (irreversible or serious health effects), BESS enclosure setbacks from the property line would exceed 19 feet and a sufficient and reliable means of notification would be provided for areas where the property line is less than 19 feet from the nearest BESS enclosure. Sufficient and reliable means of notification could include, but are not limited to, visual and audible alarms to alert people who may be in the vicinity of the site or providing procedures requiring site personnel to secure the area in the event of a BESS failure.

All non-essential personnel would evacuate the immediate area and emergency response personnel would wear Self-Contained Breathing Apparatus (SCBA) when operating in the vicinity of a unit that is in thermal runaway.

To mitigate exposure to CO and smoke during an unlikely runaway thermal event, the proposed Project would be required to include a formal emergency response plan prepared by a qualified fire safety engineer for the specific design of the project per LACoFD, as identified in APM-4 (which would be included as a condition of approval for the proposed Project). The plan would be reviewed and approved by LACoFD during the building permit process. The emergency response plan would stipulate the following:
 For a runway event involving a single unit in worst-case evacuation of personnel and people within the facility property lines is recommended. Personnel should be evacuated to locations upwind of the facility. During a failure event, evacuation of buildings immediately adjacent to the site and limiting use of public ways adjacent to the site should be considered.

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 All personnel engaged in fire suppression and rescue operations near the container involved should use appropriate PPE such as SCBA and bunker gear.  Support personnel without breathing apparatus and the command post be located at least 42 feet from units involved.
 Monitoring toxic and flammable gas types downwind from the property line may be considered. If toxic and flammable gas types are measured to exceed permissible levels, evacuation or shelter-in-place of downwind areas may be required.  If there is a concern about water pollution, water containment barriers or discontinuation of water use may be considered.
 If a long duration scenario is expected, common interventions include shelter-in-place and evacuation orders for the surrounding area. The exposure distances discussed above may be used to establish shelter-in-place or evacuation distances. If abnormally high wind conditions beyond the 99 percent wind speed (15 mph) occur or more than one enclosure fails, toxic gas concentrations may extend beyond the estimated distances. In this case, it may be appropriate to increase evacuation distances beyond the exposure distances discussed above.

Air quality monitoring may be helpful in determining evacuation distances.

Emergency Air Toxics Analysis
To supplement the information in the Plume Study, PlaceWorks prepared additional air dispersion modeling and risk determinations for pollutants not evaluated in the Marici Plume Study including the smoke generated during a BESS fire which results in fine particulate matter (PM2.5) emissions.

Methodology
Modeling evaluated TAC and PM2.5 emissions from a thermal runaway event resulting from the failure and combustion of all 48 modules within a single battery enclosure and for a 4-hour release period. This modeling is a more conservative assumption than was used in the Appendix M, which assumed a fire duration of two hours. A 30-minute release period was assumed to indicate how long a fire event would burn uncontrolled before first responders would arrive. As previously stated, the BESS would not emit TACs during normal operations and a full health risk assessment (HRA) is not required. However, as a precautionary measure, potential acute risks were determined for nearby sensitive receptors in the case of a battery cell malfunction and thermal runaway event.

It should also be noted that the failure probability of multiple battery racks (or modules) from a thermal runaway event is low due to fire detection and venting systems (Consolidated Edison

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2017). Therefore, the use of a 4-hour release period and the involvement of all 48 modules is conservative.

Air dispersion modeling was conducted to assess how emissions from the unlikely event of a thermal runway could move through the air and affect nearby homes. The study looked at a possible 4-hour release from the battery enclosures, using standard assumptions about release height, temperature, and airflow. Two release points were modeled at the southwest and southeast corners of the Project Site, with the southeast point closest to nearby residential receptors. The model checked air quality on a grid to see how concentrations might spread, focusing especially on the neighborhood to the south.

The results showed that the highest potential exposure for a nearby resident would be at a home about 130 feet south of the site. The study also calculated short-term exposure levels (over one hour and one day) to estimate the maximum possible concentrations at that location.

To determine the significance of air emissions, the 1-hour and 24-hour pollutant concentrations were compared to the Acute Emergency Guideline Levels (AEGLs) for CO. The United States Environmental Protection Agency (USEPA) issues AEGLs to be used by emergency planners and responders as guidance for accidental releases of chemicals into the air. AEGLs represent threshold values for the general public and are determined for short exposure periods (e.g., 10 minutes, 30 minutes, 1 hour, 4 hours, 8 hours) and are presented in parts per millions (ppm) for 3 levels based on severity of the chemical in air.

Concentrations below AEGL-1 represent exposure levels that could produce mild and nondisabling irritation, or asymptomatic, non-sensory effects. Potential impacts from PM2.5 emissions would only occur for a limited period-of-time from an emergency event. Therefore, for PM2.5, the 24-hour PM2.5 ground-level concentrations were compared to the corresponding Air Quality Index (AQI) value. The AQI is a measure of ambient outdoor air concentrations.

Results and Conclusions
The results of the emergency air toxics evaluation for CO are provided in Table 6. Based on the AERMOD receptor grid, the MEIR was determined to be a single-family residence approximately 130 feet south of the Project Site. As demonstrated in Table 6, the maximum 1-hour ground-level concentration for CO did not exceed the AEGL levels for any of the averaging times (i.e., 10 minutes to 8 hours).

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Table 6 Emergency Air Toxics Analysis Results – Maximum Exposed Individual Resident Air Pollutant
Emissions
Rate for
Enclosure
(g/s)
1-Hour
Ground-Level
Concentration
(ppm)
Threshold: 1-hr
AEGL (ppm)
Exceeds
Threshold?
Carbon Monoxide 269.0 7.2
AEGL-1: n/r
AEGL-2: 83
AEGL-3: 330
No, it does not
exceed AEGL-2 or 3
for any averaging
time
Air Pollutant
Emissions
Rate for
Enclosure
(g/s)
24-Hour
Ground-Level
Concentration
(μg/m3)
Threshold:
24-hr AAQS
(μg/m3)
Exceeds
Threshold?
PM2.5 48.76 145.0 35 Yes
Notes: n/r = not recommended due to insufficient data (Appendix O).

The maximum 24-hour PM2.5 concentrations was calculated to be 145 µg/m3 at the MEIR. The resulting AQI for a concentration of 145 µg/m3 would be 220, which is between 201 and 300, and the air would be categorized as very unhealthy (USEPA 2024b). For this AQI category, USEPA recommends that children, active adults, and people with respiratory diseases, such as asthma, should avoid outdoor exertion and all others should limit prolonged outdoor exertion. Studies conducted during wildfire events in California with high PM2.5 concentrations showed that indoor air concentrations were 73 percent lower than outdoor air concentrations due to measures taken to reduce infiltration, such as closing doors and windows, reducing ventilation, and active air filtration (Liang et al 2021). USEPA’s main recommendation for very unhealthy hazardous smoke events is to avoid or limit outdoor activities. Additionally, the Project Site is within 0.15-mile of LACoFD Station No. 43, which would ensure a prompt response in the event of a fire at the Project Site and the proposed Project would implement an EAP that covers any potential onsite fires.

It should also be noted that the Emergency Air Toxics Analysis is based on an emergency scenario that is not reasonably foreseeable. There are no reported failures that would cause thermal runaway to occur in all 4,992 cells that make up a battery enclosure. Also, there have been no reported incidents for fires associated with PowerTitan 2.0 battery enclosures. The PowerTitan

2.0 also uses a closed-loop liquid cooling system to maintain optimal operating temperatures Impacts associated with PM2.5 emissions resulting from smoke would be transient in nature and not likely to last more than 24 hours.

As such, the results indicate that the BESS facility would not expose nearby sensitive receptors (i.e., residents) nor adjacent industrial land uses to TAC concentrations in the event of a thermal runaway event. Given preparation of the EAP which will define emergency response

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requirements, impacts are considered less than significant, and no mitigation measures are necessary.

Los Angeles County Fire Department Requirements for BESS Facilities BESS facilities must meet the requirements of the National Fire Protection Association (NFPA), which issues standards for addressing energy storage systems (NFPA 2022). The proposed BESS battery enclosures would be equipped with fire monitoring systems, controls, and liquid cooling units to keep the batteries at optimal operating temperatures. The fire monitoring systems consist of smoke and heat sensors, gas detectors, alarms, remote monitoring, and an NFPA 69-compliant ventilation system to prevent an explosive atmosphere. The fire protection system would have an alarm that would trigger core power shutdown during a fire, smoke, overheating, overpressure, or other issues. Also, once the concentration of combustible gas reaches 10 percent LEL, the combustible gas detector will activate the exhaust system to turn on. The entire project power shutdown would occur automatically during electrical fault conditions (e.g., high-voltage, highfrequency, ground fault). In addition, the proposed BESS would be equipped with breakers that could be opened manually to power down different equipment at the proposed project.

LACoFD has experience in the permitting of BESS projects and will be responsible for plan checking and approvals. LACoFD has implemented additional permitting requirements to ensure fire safety related to the BESS, as follows:
 Fire Hydrants. Per LACoFD regulations, the project design must include internal hydrants at distances that would ensure a maximum hose pull of 150 feet. This is a shorter distance than is typical and allows for faster response times for defensive firefighting.  Training. A qualified battery safety engineer would conduct one- or two-day fire department training.
 Hazard Mitigation Plan / Emergency Response Plan. The BESS facility is required to include a formal hazard mitigation analysis and site-level emergency response plan generated by a qualified fire safety engineer for the specific design of the project pursuant to LACoFD requirements. This would be reviewed and approved by LACoFD during the building permit process.
 Fire Suppression Systems. Current standards require a dry standpipe connection to the BESS containers. A standpipe is a port in the BESS container that allows a fire hose to be connected to the container. With the provision of a dry standpipe, the local fire department can contain the fire by flooding the system with water, if determined to be the best firefighting option.  Installation. Each module is tested at the manufacturer's facility and inspected for damage at the Project Site. Once installed and in operational mode, the battery management system

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(BMS) is calibrated for specific use at the site. The BMS protects the battery cells, modules, and racks from current, voltage and temperature design limit deviations by performing an emergency shutdown, when needed.

LACoFD’s review and permitting process would ensure that all necessary measures are implemented and that all requirements are adhered to for the proposed BESS facility, thereby ensuring that impacts related to reasonably foreseeable upset and accident conditions involving the release of hazardous materials would be less than significant and no mitigation measures are necessary.

California Public Utilities Commission - General Order No. 167 On March 13, 2025, the California Public Utilities Commission (CPUC) adopted new maintenance and operation standards for BESS facilities under General Order No. 167. The new maintenance and operation standards for BESS facilities states that each facility should develop an emergency response and action plan as required by Senate Bill (SB) 38. In addition, SB 1383 requires the CPUC to implement and enforce standards for the maintenance and operation of facilities for the storage of electricity owned by an electrical corporation or located in the state. The bill would require the Independent System Operator (ISO), who manages the flow of electricity across highvoltage, long-distance power lines, to maintain records of storage facility outages and to provide those records to the commission on a daily basis. The proposed Project would be required to implement these regulatory requirements. Therefore, impacts related to reasonably foreseeable upset and accident conditions involving the release of hazardous materials would be less than significant and no mitigation measures are necessary.
g) Would the proposed project emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school?
The Project Site is within one-quarter mile of a school. The nearest school to the Project Site is the United Christian Education Center, which is approximately 0.09 miles (approximately 475 feet) southeast. There are no other existing or proposed schools in the vicinity of the Project Site.

As substantiated in Sections 3.9.a and 3.9.b, Project operation would not emit hazardous substances or hazardous wastes in quantities posing substantial hazards to the public or the environment. Additionally, the use of hazardous materials during the proposed Project’s construction phase would not be in such quantities or stored in such a manner as to pose a significant safety hazard. These activities would be short term and would cease upon completion of the proposed Project’s construction phase. All potentially hazardous materials used on the Project Site would be used and stored in accordance with manufacturers’ instructions and handled in compliance with applicable standards and regulations. The proposed Project would also implement an EAP and SGMP, as described above, in the event of an emergency as a result

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of a potential (although unlikely) runaway thermal event. Additionally, any hazardous waste produced as part of the Proposed Project would be disposed of in accordance with federal, state, and local regulations.

Therefore, impacts related to the emission or handling of hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school from the BESS facility would be considered less than significant and no mitigation measures are necessary.

Additionally, as discussed in Section IX.a, the tie line would produce EMF effects. Based on the analysis found in EMF Study (Appendix N), the EMF levels along the tie line are below the recommended thresholds and the school’s occupants would not be affected by the tie line EMF levels.

Based on the preceding, impacts related to the emission or handling of hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school from the Project Site would be less than significant and no mitigation measures are necessary.
h) Would the proposed project 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? Three Phase I ESAs prepared for the proposed Project (Appendices F through H) and involved a search of local, state, and federal databases for known hazardous or contaminated material sites of the Project Site and a one-mile radius. The results of the database search are provided in Table

7. Table 7 Phase I ESAs and LSIs Governmental Databases Summary Facility Name and
Location
Estimated
Distance/Direction
/Gradient Database Listing Findings Summary
Hensim USA dba
TierraMotorsports
16257 Gale Avenue
(a warehousing and
product fulfillment
business)
Site FINDS Not a REC
White & Blue Lion,
Inc.
16265 Gale Avenue
(a warehousing and
Site HAZNET, HWTS Not a REC

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Table 7 Phase I ESAs and LSIs Governmental Databases Summary Facility Name and
Location
Estimated
Distance/Direction
/Gradient Database Listing Findings Summary
product fulfillment
business)
Hal Riger 16207
Gale Avenue
Site HWTS Not a REC
San Gabriel Valley
(Area 4)
Stimpson Avenue &
Old
Valley Road
Encompasses the
site

AOCONCERN,

NPL, SEMS, US
ENG Controls,

ROD, FINDS,

ECHO, ICIS,
PRP
REC, discussed below
Southern California
Edison (SCE)
Walnut
Substation
16333 Gale Avenue
Adjoining / East /
Upgradient

AST, CA FID

UST, CERS HAZ
Waste, CERS
Tanks, Cortese,
E Manifest,

HIST UST,

LUST, UST, UST
Finder Release,

RCRA-LQG,

SWEEPS UST
REC, discussed below
Metal Cutting
Service and
Ceromet Inc.
(DEST) 16233 East
Gale Avenue &
16235 East Gale
Avenue
Site CERS, CIWQS, E

MANIFEST,

ECHO, FINDS,

HAZNET, HWTS,

NPDES, RCRA
NonGen / NLR,

CERS HAZ

WASTE, FINDS,

LOS ANGELES
CO. HMS, CPSSLIC, WIP
REC, discussed below
United Stationers
918 South Stimson
Avenue
Adjoining / Westnorthwest
/ Down- gradient
WIP Not a REC
Challenger
Enterprises,
Inc.

Adjoining / Westnorthwest
/ Down- gradient
CPS-SLIC Not a REC

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Table 7 Phase I ESAs and LSIs Governmental Databases Summary Facility Name and
Location
Estimated
Distance/Direction
/Gradient Database Listing Findings Summary
918 South Stimson
Avenue
Peter Vallejo
16257 Folger Street
Adjoining (130 feet
across Gale
Avenue) /
Southeast /
Upgradient
RCRA
NonGen/NLR
Not a REC
Buccola
Manufacturing,
Inc.
16213 East Gale
Avenue
150 feet / West /
Down-gradient
Drycleaners Not a REC
Crown City
Furniture
Manufacturing
16213 East Gale
Avenue
150 feet / West /
Down-gradient
CPS-SLIC, WIP Not a REC
Lennar Homes of
California LLC
16234 Folger Street
230 feet / South /
Upgradient
E Manifest,
RCRA
NonGen/NLR
Not a REC
Orbis Industries,
Inc., dba Diato
16205 Ward Way
350 feet / West /
Down-gradient
CPS-SLIC, WIP Not a REC
Krall Cast, Inc.
16205 Ward Way
350 feet / West /
Down-gradient
E Manifest,
RCRA
NonGen/NLR
Not a REC
DPS Diesel Parts &
Service
16205 Ward Way
350 feet / West /
Down-gradient
RCRA
NonGen/NLR
Not a REC
Future Hitech
Planning
16207 Ward Way
350 feet / West /
Down-gradient
RCRA
NonGen/NLR
Not a REC
L.V.I.-Paul Taylor
Ent., below.

Inc.
16207 Ward Way
350 feet / West /
Down-gradient
CPS-SLIC, WIP Not a REC

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Table 7 Phase I ESAs and LSIs Governmental Databases Summary Facility Name and
Location
Estimated
Distance/Direction
/Gradient Database Listing Findings Summary
White & Blue Lion
Inc. 16265 Gale
Avenue
Adjoining / East /
Up-gradient
HWTS Not a REC
Hacienda La
Puente Unified
School District
Glenelder
Elementary
215 feet / South /
Up- to Crossgradient

HWTS, NPDES, E

MANIFEST, RCRA
NonGen / NLR
Not a REC
Sun Belt Rentals
16157 Gale Avenue
220 feet / West /
Down-gradient
HWTS Not a REC
Southern California
Edison (SCE)
Walnut Substation
16333 Gale Avenue
290 feet / East /
Up- to Crossgradient

AST, CA FID UST,

CERS HAZ
Waste, CERS
Tanks, Cortese,
E Manifest, HIST

UST, LUST, UST,
UST Finder
Release, RCRALQG, SWEEPS
UST
Not a REC
Southern California
Gas Company 920
South Stimson
Avenue
165 feet / West /
Down-gradient

CERS HAZ

WASTE, CERS

TANKS, HIST

UST, SWEEPS

UST, UST, HWTS,
Cortese, LUST,

UST FINDER

RELEASE, E

MANIFEST,

RCRA-SQG
Not a REC
M.G. Comfort
Apparel Inc. /
Phillips Machine &
Welding / PMW
Manufacturing
16119 East Gale
Avenue
255 feet /
Southwest / Crossgradient

CPS-SLIC,

DRYCLEANERS,

HWTS, E

MANIFEST, RCRA
NonGen / NLR,
WIP
Not a REC

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Table 7 Phase I ESAs and LSIs Governmental Databases Summary Facility Name and
Location
Estimated
Distance/Direction
/Gradient Database Listing Findings Summary
Lennar Homes of
California LLC
16234 Folger Street
230 feet / South /
Upgradient
E Manifest,
RCRA
NonGen/NLR
Not a REC
Robert Spinks
16251 Folger Street
340 feet /
Southeast / Up- to
Cross-gradient
HWTS Not a REC
Phillips Aerospace
16125 East Gale
Avenue
255 feet /
Southwest / Crossgradient

HWTS, E

MANIFEST, RCRA
NonGen / NLR
Not a REC
Sources: Appendices F through H.

Notes: Aboveground Storage Tanks (AST), Area of Concern (AOCONCERN), California Environmental Reporting System (CERS), California Environmental Reporting System Hazardous Waste (CERS HAZ Waste), California Environmental Reporting System Hazardous Waste (CERS HAZ WASTE), California Environmental Reporting System Tanks (CERS Tanks), California Integrated Water Quality System (CIWQS), Enforcement & Compliance History Information (ECHO), Engineering Controls Sites List (US ENG Controls), Facility and Manifest Data (HAZNET), Facility Index System/Facility Registry System (FINDS), Facility Inventory Database (CA FID UST), Hazardous Waste Electronic Manifest System (E Manifest), Hazardous Waste Electronic Manifest System (E Manifest), Hazardous Waste Tracking System (HWTS), Historical Underground Storage Tank (HIST UST), Integrated Compliance Information System (ICIS), Leaking Underground Storage Tank (LUST), Los Angeles County Hazardous Materials Section (LOS ANGELES CO. HMS), Los Angeles County Hazardous Materials Systems (Los Angeles Co. HMS), National Pollutant Discharge Elimination System (NPDES), National Priorities List (NPL), Potentially Responsible Parties (PRP), Records Of Decision (ROD), Resource Conservation and Recovery Act – Large Quantity Generator (RCRA-LQG), Resource Conservation and Recovery Act Non-Generators/No Longer Regulated (RCRA NonGen/NLR), Standardized Emergency Management System (SEMS), Statewide Environmental Evaluation and Planning System – Underground Storage Tank (SWEEPS UST), Statewide SLIC Cases (GEOTRACKER) (CPS-SLIC), Underground Storage Tank (UST), Underground Storage Tank Finder Release (UST Finder Release), and Well Investigation Program (WIP)
As demonstrated in Table 7, the Project Site includes three RECs. These include the Metal Cutting Service and Ceromet, Inc., San Gabriel Valley (Area 4), which is a groundwater plume, and the Southern California Edison (SCE) Walnut Substation. Additionally, all non-REC listings in Table 7 are substantiated in the three Phase I ESAs (Appendices F through H).

Metal Cutting Service and Ceromet, Inc.

The Metal Cutting Service and Ceromet Inc. site was listed on several regulatory databases.

According to the regulatory databases and a review of GeoTracker online databases, the facility was identified as being associated with the San Gabriel Valley (Area 4) because it was part of the

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multiple manufacturing facilities located throughout the valley in which San Gabriel Valley (Area 4) is located. However, based on review of the databases, the constituents of concern (PCE and TCE) were not identified; the facility was not reported as a contributor to the San Gabriel Valley (Area 4) groundwater plume; and the case was closed on May 1, 1989. Additionally, the facility was identified under Metal Cutting Service, dated from 1990 and last updated in September 2024, as a hazardous waste generating facility with on-site waste treatment, and waste steams identified as “universal waste”; “unspecified aqueous solution”; “waste oil and mixed oil”; “oil/water separation sludge”; and “other organic solids”. Based on the longevity of business operations (approximately 49 years), the likely use of petroleum and solvents/chemicals as part of the current and historical operations represents a REC to the site. As stated above, to mitigate potential exposure to VECs, a VIMS would be implemented with the planned future building construction to address the documented soil gas concentrations detected. Design of this VIMS will be included within the Building Permit Submittal, as is typical for this type of system.

Additionally, as stated above, a SGMP was created to provide BMPs for use in the event impacted soil or excavation water is encountered during construction of the proposed Project (Appendix K). BMPs for the proposed Project are included above and would be implemented during the construction phase.

San Gabriel Valley (Area 4)
The Project Site is within the boundaries of the San Gabriel Valley (Area 4) Superfund Site. The San Gabriel Valley Superfund Site includes multiple areas with contaminated groundwater in the 170-square-mile San Gabriel Valley. Over 30 square miles of groundwater in the valley may be contaminated with VOCs from past releases at multiple manufacturing facilities located throughout the valley. The proposed Project would be occupied by two employees and could be subject to vapor encroachment conditions (VECs). As stated above, to mitigate potential exposure to VECs, a VIMS would be implemented with the planned future building construction to address the documented soil gas concentrations detected. Design of this VIMS will be included within the Building Permit Submittal, as is typical for this type of system.

Southern California Edison (SCE) Walnut Substation
The SCE Walnut Substation was identified as a facility with waste streams that consisted of “Other inorganic solids”; “Polychlorinated biphenyls and material containing PCBs”; “Other organic solids”; “Unspecified oil-containing waste”; “Asbestos containing waste”; “Halogenated solvents”; “Off-specification, aged or surplus organics”; “Waste oil and mixed oil”; “Unspecified solvent mixture”; “Pesticides/Pesticide Production Waste”; “Tank Bottom Waste”; “Liquids with PCBs” (greater than or equal to 50 milligrams per liter); and “Liquids with halogenated organic compounds (greater than or equal to 1000 milligrams per liter); “Hydrocarbon solvents”; “Polymeric resin waste”; “Detergent and soap”; “Ignitable”; “Corrosives”; “” Chlordane”; “Chloroform”; “Lead”; “Mercury”; “Benzene”; “Tetrachloroethylene (PCE)”; Trichloroethylene

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(TCE)”; and “Nonhalogenated solvents”. Based on review of the regulatory databases and the generated waste streams identified (including halogenated solvents), the absence of analytical data for the presence of halogenated solvents, the longevity of operations, the close proximity to the site, and the shallow depth to groundwater (approximately 19 feet bgs), the potential exists for halogenated solvent impact to the site; therefore, the SCE database listings represents a REC to the site.

As stated above, the BMPs contained in the SGMP would be implemented during the construction phase.

With the implementation of the VIMS project design feature and the SGMP, impacts would be less than significant, and no mitigation measures are necessary. i) 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? There are no public airports or private airfields within two miles of the Project Site. The nearest public airport is the San Gabriel Valley Airport and is approximately 7 miles northwest of the Project Site. Additionally, there are no helipads within the vicinity of the Project Site (AirNav 2025). The closest helipads to the Project Site include one government- and one private-operated helipad—the Los Angeles County Sheriff’s station ground-level helipad at 150 Hudson Avenue and a private rooftop heliport at 450 Baldwin Park Boulevard (AirNav 2025). The sheriff’s helipad is approximately 0.9 miles north of the Project Site; the roof-top heliport is approximately 3.2 miles northwest of the Project Site. At these distances, development of the proposed Project would not alter the flight path of this airport or helipads and would not increase safety hazards or noise levels in the vicinity of the Project Site. Therefore, no impact related to airport safety hazards would occur and no mitigation measures are necessary.
j) Would the proposed project impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan? The proposed Project would not interfere with implementation of the County of Los Angeles Operation Area Emergency Operations Plan (OAEOP) and any of the daily operations of LACoFD or the Los Angeles County Sherriff’s Department. The Los Angeles OAEOP provides guidance and procedures for the county to prepare for, respond to, and recover from the effects of large-scale emergencies regardless of cause, location, or complexity. The City is in Area D of the Los Angeles OAEOP (OAEOP 2023). Additionally, the City’s General Plan includes a Safety Element that identifies natural and man-made environmental hazards and ways to reduce the risk of property damage, injuries, or loss of life. The Safety Element also addresses emergency preparedness within the City.

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Neither the Los Angeles OAEOP nor the City’s Safety Element provide specific evacuation routes.

However, the City Safety Element does state that the City’s major roadways and access to major freeways provide numerous evacuation routes in the event of an emergency. The Project Site is not located on or abutting any major freeways. The nearest freeway is SR-60 with the closest freeway ramp approximately 0.3 miles to the southwest via Gale Avenue and Hacienda Boulevard.

The Project Site is on Gale Avenue, which is a Secondary Highway and is defined in the City’s General Plan as carrying high volumes of traffic and providing access to abutting properties as a secondary function.

Therefore, the proposed Project would not impair implementation of or physically interfere with the City’s or Los Angeles County’s emergency response or evacuation plans. Impacts would be less than significant, and no mitigation measures are necessary. k) Would the proposed project expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires? A wildland fire hazard area is typically characterized by areas with limited access, rugged terrain, limited water supply, and combustible vegetation.

As shown in Figure 3, Aerial Photograph, the Project Site is in an urbanized area of Industry with surrounding uses consisting mainly of industrial uses. There is no combustible wildland vegetation on or anywhere near the Project Site. The Project Site has well-defined access and would be served by adequate water infrastructure for fire protection purposes. The proposed Project would also be required to be designed and constructed in accordance with the most current California Building Code and California Fire Code, as well as all applicable requirements of LACoFD.

Furthermore, there would be no impact for wildland fire risks due to implementation of the proposed Project, as substantiated in Section XX, Wildfire. The Project Site is not on or near land classified as a very high fire hazard severity zone. The proposed Project would include the development of a BESS facility on the Project Site that would be staffed with up to two employees.

Additionally, the proposed Project would include interior paved access and fire lanes for emergency access. Therefore, implementation of the proposed project would not introduce people or structures to substantial hazards from wildland fires. No impact would occur, and no mitigation measures are necessary.

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X. Hydrology and Water Quality
Would the project:

Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Violate any water quality standards or
waste discharge requirements or
otherwise substantially degrade surface or
ground water quality?
☐ ☐ ☒ ☐
b) Substantially decrease groundwater
supplies or interfere substantially with
groundwater recharge such that the
project may impede sustainable
groundwater management of the basin?
☐ ☐ ☒ ☐
c) Substantially alter the existing drainage
pattern of the site or area, including
through the alteration of the course of a
stream or river or through the addition of
impervious surfaces, in a manner which
would:
☐ ☐ ☐ ☐
i) result in a substantial erosion or
siltation on- or off-site;
☐ ☐ ☒ ☐
ii) substantially increase the rate or
amount of surface runoff in a manner
which would result in flooding on- or
offsite;
☐ ☐ ☐ ☒
iii) create or contribute runoff water
which would exceed the capacity of
existing or planned stormwater
drainage systems or provide
substantial additional sources of
polluted runoff; or
☐ ☐ ☐ ☒
iv) impede or redirect flood flows? ☐ ☐ ☐ ☒
d) In flood hazard, tsunami, or seiche zones,
risk release of pollutants due to project
inundation?
☐ ☐ ☐ ☒
e) Conflict with or obstruct implementation
of a water quality control plan or
sustainable groundwater management
plan?
☐ ☐ ☒ ☐

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The analysis in this section is based partly on the following technical studies, which are included as Appendices P, K, and E to this Initial Study:
 Hydrology Study and Stormwater Quality Management Plan, February 2025. (Appendix P)  Soil and Groundwater Management Plan, May 29, 2025. (Appendix K)  Revised Geotechnical Engineering Report, February 7, 2025. (Appendix E)

DISCUSSION
a) Would the proposed project have a substantial adverse effect on a scenic vista? The Project Site is in the San Gabriel watershed (Los Angeles County 2007). The San Gabriel River receives drainage from 689 square miles of eastern Los Angeles County, and its headwaters are in the San Gabriel Mountains. The watershed consists of extensive areas of undisturbed riparian and woodland habitats in its upper reaches. The upper watershed also contains a series of flood control dams. Further downstream, toward the middle of the watershed, are large spreading grounds used for groundwater recharge. Land use in the middle and lower parts of the watershed are primarily urban land and highly developed (SWRCB 2024).

Water quality in the City is regulated by the Los Angeles Regional Water Quality Control Board (RWQCB) and its Water Quality Control Plan (Basin Plan), which contains water quality standards and identifies beneficial uses for receiving waters (wildlife habitat, agricultural supply, fishing, etc.). The Basin Plan also includes water quality criteria and standards necessary to support the beneficial uses consistent with federal and state water quality laws. All runoff from the Project Site drains to the San Gabriel River via the San Jose Creek channel. The San Jose Creek Diversion Channel is located approximately 450 feet north from the Project Site.

A development project generally affects the quality of receiving waters over three different phases:
 During the earthwork and construction phase the potential for erosion, siltation, and sedimentation would be the greatest.
 Following construction and before the establishment of ground cover, the erosion potential may remain relatively high.
 Following project completion, impacts related to sedimentation could decrease markedly, but those associated with urban runoff would generally increase.

Following is a discussion of the potential water quality impacts resulting from urban runoff that would be generated during the construction and operational phases of the proposed Project.

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Project Construction
Construction-related runoff pollutants are typically generated from waste and hazardous materials handling or from storage areas, outdoor work areas, material storage areas, and general maintenance areas (e.g., vehicle or equipment fueling and maintenance, including washing). The proposed Project’s construction phase may cause deterioration in the quality of downstream receiving waters if construction-related sediments or pollutants wash into the existing storm drain system and facilities in the area.

Construction-related activities that are primarily responsible for sediment releases are related to exposing previously stabilized soils to potential mobilization by rainfall/runoff and wind. Such activities include removing vegetation from the site, grading the site, and trenching for infrastructure improvements. Environmental factors that affect erosion include topographic, soil, and rainfall characteristics. Non-sediment-related pollutants are also of concern and generally include demolition and construction materials (e.g., paint and stucco); chemicals, liquid products, and petroleum products used in building construction or the maintenance of heavy equipment; and concrete and related cutting or curing residues. As discussed in the proposed Project’s SGMP (Appendix K), while no impacted soils have been identified on-site, during excavation and grading, there is a potential to encounter unknown impacted soils, for example, when buildings, foundations or paving are removed or underlying soils are excavated.

The Project Site and surrounding area also overly the San Gabriel (Area 4) Superfund Site regional groundwater plume (EPA 2021). Based on the regional plume maps the plume is mostly located north/northeast of the Project Site and extends underneath the Project Site in the vicinity of Gale Avenue. Additionally, the adjoining SCE Walnut Substation was identified as a potential source for halogenated solvent impacts to shallow groundwater beneath the Project Site based on the generated waste streams identified, the close proximity to the Project Site, and the shallow depth to groundwater (approximately 19 feet below grade [fbg])3. 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. Therefore, should construction activities under the proposed Project encounter impacted soils or require dewatering or soil boring to levels where groundwater is encountered and the groundwater be released without pretreatment, surface water quality may be degraded.

Discharge of untested and/or untreated groundwater or impacted stormwater to the ground surface, storm drain, or sanitary sewer system is prohibited under state and federal law. The 3 According to the Geotechnical Engineering Report prepared for the proposed Project (Appendix D), groundwater was encountered at depths ranging between approximately 21 and 26 fbg in on-site borings performed in December of 2024. Groundwater levels fluctuate due to seasonal variations in the amount of rainfall, runoff, and other factors.

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proposed Project’s general contractor would be required to obtain the necessary permit from the California State Water Resources Control Board to conduct the dewatering and discharging activities and to ensure that the required characterization of such water occurs. If either groundwater or stormwater that has contacted impacted soils must be handled, the general contractor is responsible for sampling and testing to ensure handling is in accordance with applicable regulations.

Impacted water must be managed in accordance with applicable waste regulations. Impacted water may be shipped offsite by a licensed hauler to a permitted treatment facility or treated onsite and discharged under a valid permit. Stormwater that comes in contact with contaminated soils at the site would be removed and disposed or treated in accordance with the National Pollutants Discharge Elimination Permit System (NPDES) General Permit for Stormwater Discharges Associated with Construction and Land Disturbance Activities, under the State Water Resources Control Board Construction General Permit (CGP) Order 2022-0057-DWQ, adopted September 8, 2022, effective date of September 1, 2023 (CSWRCB 2022). Projects obtain coverage by developing and implementing a Stormwater Pollution Prevention Plan (SWPPP), which includes estimating sediment risk from construction activities to receiving waters and specifying best management practices (BMPs) that would be implemented as a part of the proposed Project to minimize pollution of stormwater. Categories of BMPs used in SWPPPs are described in Table 8, Water Quality Protection Construction Best Management Practices.

Table 8 Water Quality Protection Construction Best Management Practices Category Purpose Examples
Erosion Controls
and Wind Erosion
Controls
Use project scheduling and planning to
reduce soil or vegetation disturbance
(particularly during the rainy season)
Prevent or reduce erosion potential by
diverting or controlling drainage
Prepare and stabilize disturbed soil areas
Scheduling, preservation of existing
vegetation, hydraulic mulch,
hydroseeding, soil binders, straw
mulch, geotextile and mats, wood
mulching, earth dikes and drainage
swales, velocity dissipation devices,
slope drains, streambank
stabilization, compost blankets, soil
preparation/roughening, and nonvegetative stabilization Sediment Controls Prevent the mobilization of soil particles through the use of tarping, matting, or
other covers.

Silt fence, sediment basin, sediment
trap, check dam, fiber rolls, gravel
bag berm, street sweeping and
vacuuming, sandbag barrier, straw
bale barrier, storm drain inlet
protection, manufactured linear
sediment controls, compost socks
and berms, and biofilter bags

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Table 8 Water Quality Protection Construction Best Management Practices Category Purpose Examples
Wind Erosion
Controls
Apply water or other dust palliatives to
prevent or minimize dust nuisance
Dust control soil binders, chemical
dust suppressants, covering
stockpiles, permanent vegetation,
mulching, watering, temporary
gravel construction, synthetic
covers, and minimization of
disturbed area
Non-stormwater
Management
Controls
Prohibit discharge of materials other than
stormwater, such as discharges from the
cleaning, maintenance, and fueling of
vehicles and equipment
Conduct various construction operations,
including paving, grinding, and concrete
curing and finishing, in ways that
minimize non-stormwater discharges and
contamination of any such discharges
Water conservation practices,
temporary stream crossings, clear
water diversions, illicit
connection/discharge, potable and
irrigation water management, and
the proper management of the
following operations: paving and
grinding, dewatering, vehicle and
equipment cleaning, fueling and
maintenance, pile driving, concrete
curing, concrete finishing,
demolition adjacent to water,
material over water, and temporary
batch plants
Waste
Management and
Controls (i.e.,
good
housekeeping
practices)
Manage materials and wastes to avoid
contamination of stormwater
Stockpile management, spill
prevention and control, solid waste
management, hazardous waste
management, contaminated soil
management, concrete waste
management, sanitary/septic waste
management, liquid waste
management, and management of
material delivery storage and use
Tracking Controls Minimize the tracking of soil off site by vehicles
Stabilized construction roadways
and construction entrances/exits,
and entrance/outlet tire wash
Source: Compiled by PlaceWorks from information provided in the California Stormwater Quality Association’s (CASQA’s Construction BMP Handbook).

The proposed Project’s construction contractor would be required to prepare and implement a SWPPP and associated BMPs in compliance with the CGP during grading and construction. The SWPPP would specify BMPs, such as those outlined in Table 8, that the construction contractor

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would implement to protect water quality by eliminating and/or minimizing stormwater pollution prior to and during grading and construction and show the placement of those BMPs. Project construction activities would also be required to be implemented in accordance with the requirements of Chapter 13.16, Stormwater and Urban Runoff Pollution Control, of the Industry Municipal Code.

Furthermore, the proposed Project’s SGMP (Appendix K) outlines additional measures that address the management of impacts soils if encountered, as detailed further in Section IX, Hazards and Hazardous Materials. The soil management measures include removing and segregating the impacted soils in a manner to minimize over-excavation or mixing with clean soil.

In addition, impacted soils would 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 would be protected from stormwater runon 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.

Groundwater is not expected to be encountered during construction except potentially for construction of the deep foundations for the electric tie-line support poles, and potentially in borings if additional geotechnical drilling is conducted. If stormwater collects in any excavation during construction, it should be visually inspected for evidence of sheen or other indication of potential constituents 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 be managed as potentially contaminated and evaluated through chemical analysis prior to discharge and/or off-site disposal. Samples shall be collected by qualified personnel and characterization shall be coordinated with the Owner. As applicable, 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. Secondary containment of the containerized water shall be established for volumes greater than 100 gallons and shall have a capacity of 110 percent of the total volume of the containers, regardless of actual volume stored in the containers. Additional BMPs such as regular inspection of the containers and secondary containment and proper labeling shall be maintained.

Adherence to the BMPs in the SWPPP, Industry Municipal Code requirements, and the additional requirements outlined in the proposed Project’s SGMP (which would be added as a condition of approval to the proposed Project) would reduce, prevent, minimize, and/or treat pollutants and prevent degradation of downstream receiving waters. BMPs identified in the SWPPP would reduce or avoid contamination of stormwater with sediment and other pollutants. Based on the preceding, water quality and waste-discharge impacts from Project demolition, grading, and

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construction activities at the Project Site would be less than significant and no mitigation measures are necessary.

Project Operation
Operational-related activities at the Project Site (e.g., runoff from parking areas and roads) could generate pollutants that could adversely affect the water quality of downstream receiving waters if effective measures are not used to keep pollutants out of and remove pollutants from urban runoff.

Standards governing discharges to stormwater from Project operation are provided in the MS4 Permit for Los Angeles County in the jurisdiction of the Los Angeles RWQCB (Order No. R4-2021- 0105). The City of Industry has adopted the Los Angeles County Department of Public Works’ (LACDPW) Low Impact Development Standards Manual and all revisions/updates. The LACDPW’s Low Impact Development (LID) Standards Manual was adopted in 2014 and provides guidance for the implementation of stormwater quality control measures in new development and redevelopment projects in unincorporated areas of the County with the intention of improving water quality and mitigating potential water quality impacts from stormwater and nonstormwater discharges.

LID is a stormwater management and land development strategy that combines a hydrologically functional site design with pollution prevention measures to compensate for land development impacts on hydrology and water quality. LID techniques mimic the site predevelopment hydrology by using treatment control BMPs that store, infiltrate, evapotranspire, biofilter, or detain runoff close to its source. Source control BMPs reduce the potential for pollutants to enter runoff and are classified in two categories—structural and nonstructural. Structural source control BMPs have a physical or structural component, such as inlet trash racks, trash bin covers, and an efficient irrigation system, to prevent pollutants from contacting stormwater runoff.

Nonstructural source control BMPs are procedures or practices used in project operation, such as stormwater training or trash management and litter control practices.

According to the LID Standards Manual, the proposed Project is a designated project defined as redevelopment project adding 5,000 square feet or more of impervious surface on a site that was previously developed (LADPW 2014). Mitigation for designated projects includes retaining 100 percent of the stormwater quality design volume (SWQDv)4 onsite through infiltration, evapotranspiration, stormwater runoff harvest and use, or a combination thereof. 4 The design storm, from which the SWQDv is calculated, is defined as the greater of the 0.75-inch, 24-hour rain event or the 85th percentile, 24-hour rain event, as determined from the Los Angeles County 85th percentile precipitation isoheytal map.

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Under the proposed project the Project Site would be split up into four drainage areas that would flow into four separate discharge points. The proposed stormwater design consists of an underground storm drain system, curb and gutters, and open vegetated ditches.

As shown in Figure 10, Proposed Drainage Area Maps, the drainage areas are identified as A, B, C, and G. Drainage Area A would be 7.53 acres of the Project Site and sheet flow to the northern corner of the Project Site before connecting to an existing northwest curb inlet. Drainage area A would have a pretreatment device that would be designed per the LACDPW’s LID Standards Manual. Discharge area B would be 0.07 acres and flow offsite towards the train tracks in the northern corner of the project site. Discharge area C would be 4.35 acres and flow to the western edge of the Project Site into a grate inlet on the adjacent parcel to the Project Site. Discharge area G would be 0.21 acres and flow southwest offsite along Gale Avenue.

The project developer would prepare and submit a standard urban stormwater mitigation plan (SUSMP), which would include applicable LID requirements in the MS4 permit and Low Impact Development Standards Manual. The proposed Project would be designed to control pollutants, pollutant loads, and runoff volume to the maximum extent feasible by minimizing impervious surface area and controlling runoff from impervious surfaces through infiltration, evapotranspiration, bioretention, and/or rainfall harvest and use. The final BMPs to be implemented for the proposed Project, including the proposed pretreatment device, would be determined through the City’s review of the SUSMP, which would occur during the City’s development review and building plan check process.

The BMPs incorporated into future project development would mitigate at a minimum the first flush or the equivalent of the greater between the 85th percentile storm and first 0.75-inch of rainfall for any storm event.5 The installed BMP systems would be designed with an internal bypass or overflow system to prevent upstream flooding due to large storm events. Furthermore, the SUSMP would include the following information:
 Feasibility of infiltrating captured stormwater at the project site.  Source control measure(s) proposed to be implemented.  Calculation of the volume of stormwater that needs to be treated on the project site.  Discussion on whether stormwater runoff harvest and use are feasible.  Stormwater quality control measure(s) proposed to be implemented and sizing calculations. 5 Stormwater quality control measures are designed to handle the frequent, smaller storm events or the initial volume of stormwater runoff from larger storm events (typically referred to as first-flush events). The first flush of larger storm events is the initial period of the storm where stormwater runoff typically carries the highest concentration of pollutants. Small, frequent storm events represent most of the total annual average precipitation in the county.

PlaceWorks

MARICI BATTERY ENERGY STORAGE FAC ILITY

OE OE OE OE OE OE OE OE
GAS
HINNEN
AVENUE

WARD WAY

GALE AVENUE

7.16AC
PR-A

4.71AC
PR-C2
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ASSESSORS PARCEL NUMBER
8242-016-814

ASSESSORS PARCEL NUMBER
8242-016-059

ASSESSORS PARCEL NUMBER
8242-016-046

ASSESSORS PARCEL NUMBER
8242-016-043

UNION PACIFIC RAILWAY

ASSESSORS PARCEL NUMBER
8242-016-029

ASSESSORS PARCEL NUMBER
8242-016-062
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CU SOIL TYPE NO. 003
CU SOIL TYPE NO. 017
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0.21 AC
PR-G

0.07 AC
X-B
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:
2/6/2025

PROPOSED DRAINAGE AREA MAP
D-002

EX CONCRETE GUTTER

APPROXIMATE

LOCATION OF

EX CURB INLET

EX CURB INLET

DISCHARGE POINT B

DISCHARGE POINT A

DISCHARGE POINT G

LONGEST FLOW PATH
(TYP)
DISCHARGE POINT C2

EX GRATE INLET
EXISTING DISCHARGE POINT C1
(NO LONGER A POINT OF INTEREST IN PROPOSED CONDITIONS)

GRAPHIC SCALE
0 50'
1" = 50'
50'

GENERAL NOTES

GRAPHIC SCALE
NORTH
N
0 50'
1" = 50'
50'
X-A
xx AC

1. EXISTING CONTOURS OBTAINED FROM USGS, AND MAY NOT REFLECT ON-THE GROUND TOPOGRAPHIC SURVEY.

2. SITE VISITS, AERIAL IMAGERY, SURVEY DATA ON APN 8242-016-061,

AND PUBLIC INFORMATION WAS USED TO IDENTIFY DISCHARGE POINTS FOR THE SITE.

3. STORMWATER ANALYSIS SHALL BE RE-EVALUATED UPON RECEIVING DETAILED TOPOGRAPHIC SURVEY PRIOR TO CONSTRUCTION PLANS.

EXISTING MAJOR CONTOUR

EXISTING MINOR CONTOUR

PROPOSED MAJOR CONTOUR

PROPOSED MINOR CONTOUR

PROJECT BOUNDARY

SURFACE WATER FLOW

DRAINAGE AREA ID AND ACREAGE

FLOW PATH
LEGEND

GALE AVE

S STIMSON AVE
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Figure 10
Proposed Drainage Area Maps
Source: TRC 2025.
0 Scale (Feet)
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ASSESSORS PARCEL NUMBER
8242-016-059
EX
DIS
DI
DISCHARGE POINT C2

EX GRATE INLET

EXISTING DISCHAR
(NO LONGER A POINT OF INTEREST IN PROPOSED

OE OE OE

7.16AC
PR-A

4.71AC
PR-C2
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ASSESSORS PARCEL NUMBER
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MBER

UNION PACIFIC RAILWAY
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CU SOIL TYPE NO. 017
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Tc
>>> Tc >>> Tc >>> Tc >>> Tc >>> Tc >>> Tc >>> Tc
>>>
Tc
>>>
Tc
>>>
Tc
>>>
Tc
>>>
Tc
>>>
Tc
>>>
Tc
>>>
Tc
>>>
Tc >>> Tc

0.07 AC
X-B

PERMIT PLAN SET

NOT FOR

CONSTRUCTION
DATE:

PROFESSIONAL ENGINEER:

EX CONCRETE GUTTER

EX CURB INLET

DISCHARGE POINT B

DISCHARGE POINT A

LONGEST FLOW PATH
(TYP)
EXISTING DISCHARGE POINT C1

OF INTEREST IN PROPOSED CONDITIONS)

GRAPHIC SCALE
0 50'
1" = 50'
50'

GENERAL NOTES

GRAPHIC SCALE
NORTH
N
0 50'
1" = 50'
50'
X-A
xx AC

1. EXISTING CONTOURS OBTAINED FROM USGS, AND MAY NOT REFLECT ON-THE GROUND TOPOGRAPHIC SURVEY.

2. SITE VISITS, AERIAL IMAGERY, SURVEY DATA ON APN 8242-016-061,

AND PUBLIC INFORMATION WAS USED TO IDENTIFY DISCHARGE POINTS FOR THE SITE.

3. STORMWATER ANALYSIS SHALL BE RE-EVALUATED UPON RECEIVING DETAILED TOPOGRAPHIC SURVEY PRIOR TO CONSTRUCTION PLANS.

EXISTING MAJOR CONTOUR

EXISTING MINOR CONTOUR

PROPOSED MAJOR CONTOUR

PROPOSED MINOR CONTOUR

PROJECT BOUNDARY

SURFACE WATER FLOW

DRAINAGE AREA ID AND ACREAGE

FLOW PATH
LEGEND

GALE AVE

S STIMSON AVE
>>> Tc
340
340
340
340

OE OE OE OE OE

7.16AC
PR-A

4.71AC
PR-C2
345
350
342 342
343
344
344
344
346
347
348348
348
349
351
352
343
343
343 344 344
344
344
9 49
351
351
52353
354
350
346
347
348
349
351
352
353

ASSESSORS PARCEL NUMBER
8242-016-814
UMBER

UNION PACIFIC RAILWAY
345
344
346
347
348
349
350
7 348
348
348
348
349
349
349
351
352
342
343
343
344
344
CU SOIL TYPE NO. 003
CU SOIL TYPE NO. 017
>>> Tc >>> Tc
>>> Tc >>> Tc
>>> Tc
>>>
Tc
>>> Tc >>> Tc >>> Tc >>> Tc >>> Tc >>> Tc >>> Tc
>>>
Tc
>>>
Tc
>>>
Tc
>>>
Tc
>>>
Tc
>>>
Tc
>>>
Tc
>>>
Tc
>>>
Tc
>>>
Tc
>>>
Tc >>> Tc

0.07 AC
X-B

PERMIT PLAN SET

NOT FOR

CONSTRUCTION
DATE:

PROFESSIONAL ENGINEER:

EX CONCRETE GUTTER

EX CURB INLET

DISCHARGE POINT B

DISCHARGE POINT A

LONGEST FLOW PATH
(TYP)
EXISTING DISCHARGE POINT C1

NT OF INTEREST IN PROPOSED CONDITIONS)

GRAPHIC SCALE
0 50'
1" = 50'
50'

GENERAL NOTES

GRAPHIC SCALE
NORTH
N
0 50'
1" = 50'
50'
X-A
xx AC

1. EXISTING CONTOURS OBTAINED FROM USGS, AND MAY NOT REFLECT ON-THE GROUND TOPOGRAPHIC SURVEY.

2. SITE VISITS, AERIAL IMAGERY, SURVEY DATA ON APN 8242-016-061,

AND PUBLIC INFORMATION WAS USED TO IDENTIFY DISCHARGE POINTS FOR THE SITE.

3. STORMWATER ANALYSIS SHALL BE RE-EVALUATED UPON RECEIVING DETAILED TOPOGRAPHIC SURVEY PRIOR TO CONSTRUCTION PLANS.

EXISTING MAJOR CONTOUR

EXISTING MINOR CONTOUR

PROPOSED MAJOR CONTOUR

PROPOSED MINOR CONTOUR

PROJECT BOUNDARY

SURFACE WATER FLOW

DRAINAGE AREA ID AND ACREAGE

FLOW PATH
LEGEND

GALE AVE

S STIMSON AVE
>>> Tc
340
340
340
340

CITY OF INDUSTRY

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 Proposed hydromodification controls and calculations (if necessary). 6  Proposed maintenance plan (if necessary).

Additionally, the proposed project would incorporate into the project plans a stormwater mitigation plan, including the BMPs necessary to control stormwater pollution from facility operations as set forth in the SUSMP. Structural or treatment control BMPs in project plans would meet the design standards in the SUSMP and MS4 permit. The project developer would also provide verification of maintenance provisions for treatment and structural control BMPs.

The proposed Project would comply with all state, county, and local regulations regarding stormwater runoff during the operational phase, which would ensure that water quality standards and waste discharge requirements would not be exceeded, and surface water and groundwater quality would not be degraded. Therefore, operation of the proposed project would not be expected to violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality, and impacts would be less than significant, and no mitigation measures are necessary.
b) Substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin?
The Project Site is over the Main San Gabriel Valley Groundwater Basin (Main Basin). Suburban Water Systems (SWS) currently provides water service to the Project Site. SWS’s water supply sources include groundwater pumped from the Main Basin and Central Basin and can purchase treated surface and groundwater from Covina Irrigation Company, treated groundwater from Cal Domestic. Furthermore, SWS purchases water imported by MWD through its MWD member agencies: Central Basin Municipal Water District (CBMWD), Upper San Gabriel Valley Municipal Water District (USGVMWD), and Three Valleys Municipal Water District (TVMWD) (SWS 2021).

SWS estimates that water demand in its service area for normal years would increase from approximately 1,402,000 acre-feet per year (afy) in 2025 to approximately 1,457,000 afy in 2045.

SWS forecasts that it will have sufficient water supplies to meet water demands in its service area for normal, single dry, and multiple dry years. Operation of the proposed Project would result in a decrease in water demand because the existing conditions at the Project Site have a higher water demand than the proposed conditions at the Project Site. 6 Hydromodification means the change in the natural hydrologic processes and runoff characteristics due to land use changes that result in increased stream flows and changes in sediment transport, thus affecting water quality in natural waterways.

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The groundwater in the site vicinity is anticipated to be encountered at a depth of approximately 19 fbg7 (Appendix K). Depending upon the depth of excavation and seasonal conditions, groundwater may be encountered within the excavations planned on the Project Site. Should construction activities require dewatering, the SGMP (Appendix K) identifies that it is the responsibility of the general contractor and/or its subcontractors to obtain the necessary permits and equipment to conduct any dewatering activities that might be needed (refer to Section X.a.

Furthermore, the Project Site is not in or near a groundwater recharge area/facility, nor does the proposed Project represent a source of groundwater recharge (LADPW 2025).

Therefore, implementation of the proposed Project would not substantially interfere with groundwater supplies or recharge. Impacts would be less than significant, and no mitigation measures are necessary.
c) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would:
i. Result in substantial erosion or siltation on- or off-site? Erosion and siltation impacts potentially resulting from the proposed Project’s alteration of the drainage pattern would, for the most part, occur during the proposed Project’s construction phase, which would include site preparation and grading activities.

Environmental factors that affect erosion include topography, soil and wind and rainfall characteristics. Siltation is most often caused by soil erosion.

Following is a discussion of the potential erosion and siltation impacts that could occur during the construction and operational phases of the proposed Project.

Project Construction
As discussed in Section X.a, the proposed Project’s construction contractor would be required to prepare and implement a SWPPP pursuant to the CGP during grading and construction at the Project Site. The SWPPP would specify erosion- and sediment-control BMPs that the project construction contractor would implement prior to and during grading and construction to minimize erosion and siltation impacts on- and off-site. Erosion-control BMPs are designed to prevent erosion, and sediment controls are designed to trap or filter sediment once it has been 7 According to the Geotechnical Engineering Report prepared for the proposed Project (Appendix D), groundwater was encountered at depths ranging between approximately 21 and 26 fbg in on-site borings performed in December 2024. Groundwater levels fluctuate due to seasonal variations in the amount of rainfall, runoff, and other factors.

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mobilized. BMPs that would be implemented during the proposed Project’s construction phase are discussed in detail in Section X.a.

Adherence to the BMPs in the SWPPP would reduce, prevent, or minimize soil erosion from project-related grading and construction activities. The construction-phase BMPs would also ensure effective control of sediment discharge and pollutants associated with sediments (e.g., nutrients, heavy metals, and certain pesticides). Therefore, Project-related construction activities would not result in substantial erosion or siltation on- or off-site. Construction-related impacts would be less than significant, and no mitigation measures are necessary.

Project Operation
Under the proposed Project, there would be no bare or disturbed soil at the Project Site at project completion that would be vulnerable to erosion or siltation. The surface of the Project Site would be covered with the BESS enclosures, an on-site collector substation, a tie-line and associated infrastructure, an interior paved access road, file lanes, parking spaces, hardscaping, and native landscaping. Landscaping would include deciduous trees, street trees, shrubs, grasses, meadows, and ground cover.

The proposed Project would not substantially alter the existing drainage pattern of the Project Site and would not alter the course of a stream or a river. The proposed Project would abide by the requirements of the MS4 permit and the LID Standards Manual.

Project development would also be required to comply with the standards of Chapter 13.16, Stormwater and Urban Runoff Pollution Control, of the Industry Municipal Code, which prohibits the discharge of specific pollutants into storm drains and requires development projects to implement permanent BMPs on individual sites to reduce pollutants in stormwater. Therefore, Project development would not substantially alter the existing drainage pattern of the Project Site or surrounding area in a manner that would result in substantial erosion or siltation on- or off-site.

Therefore, operation-related impacts would be less than significant, and no mitigation measures are necessary.
ii. Substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or offsite?
As detailed in the proposed Project’s Hydrology Study and Stormwater Quality Management Plan (Appendix P), the proposed Project would result in a decrease of 4.54 acres of impervious surfaces at the Project Site when compared to existing conditions.

Figure 10 shows the drainage areas under proposed conditions and the four proposed discharge points. As shown in Table 9, for the 50-year storm peak flow runoff flow at

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Discharge Point A would decrease by 0.04 cubic feet per second (cfs) when compared to the existing flow. At Discharge Point B, the flow would remain the same between existing and proposed conditions. At Discharge Point C1, the proposed flow would decrease by 5.43 cfs when compared to the existing flow. At Discharge Point C2, the proposed flow would decrease by 1.73 cfs when compared to the existing flow. At Discharge Point G, the flow would remain the same between existing and proposed conditions. Therefore, the proposed project would reduce post development peak flows to below pre-development peak flows.

Pervious surfaces at the Project Site would include trees, shrubs, grass, meadow and ground cover.

Table 9 50-year Storm Peak Flow Summary
Discharge Point Existing Flow (cfs) Proposed Flow (cfs) Difference (cfs) A 21.15 21.11 -0.04
B 0.24 0.24 0.00
C1 5.43 0.00 -5.43
C2 13.32 11.59 -1.73
G 0.69 0.69 0.00
Total 40.83 33.63 -7.2
Source: Appendix P.

Based on the preceding, development of the proposed Project would reduce the rate or amount of surface runoff in a manner which would result in reduced flooding on- or off-site.

Therefore, no impact would occur, and no mitigation measures are necessary. iii. Create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff?
The proposed Project’s impacts on the capacity of storm drainage systems would be less than significant, as substantiated in Section X.c.ii. Post development 50-year storm peak flows are less than predevelopment flows due to less impervious area. No mitigation measures are necessary.
iv. Impede or redirect flood flows?

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The Project Site is not in a 100-year flood hazard zone or a dam breach inundation zone (FEMA 2008; Industry 2014). Therefore, no impact on flood flows would occur, and no mitigation measures are necessary.
d) In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation?
As noted in Section X.c.iv, the Project Site is not in a 100-year flood zone or dam breach inundation zone.

A seiche is an oscillating surface wave in a restricted or enclosed body of water, generated by ground motion, usually during an earthquake. Seiches are of concern for water storage facilities because inundation from a seiche can occur if the wave overflows a containment wall, such as the wall of a reservoir, water storage tank, dam, or other artificial body of water. The closest enclosed water body to the Project Site is the Main Street reservoirs operated by La Puente Valley County Water District, which is approximately 0.8 miles to the northeast (LPVCWD 2017). Due to the distance, the reservoir would not pose a flood hazard due to a seiche.

Tsunamis are a type of earthquake-induced flooding produced by large-scale sudden disturbances of the sea floor. Tsunami waves interact with the shallow sea floor when approaching a landmass, resulting in an increase in wave height and a destructive wave surge into low-lying coastal areas.

The Project Site is approximately 27 miles inland from the Pacific Ocean and therefore outside the tsunami hazard zone. Therefore, the Project Site would not be affected by a tsunami.

Based on the preceding, the proposed Project would not release pollutants as the result of floods, tsunami, or seiches. Therefore, no impact would occur, and no mitigation measures are necessary. e) Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?
Water quality in the City is regulated by the Los Angeles RWCQB and its Basin Plan for the Coastal Watersheds of Los Angeles and Ventura counties. The Basin Plan contains water quality standards and identifies beneficial uses for receiving waters (wildlife habitat, agricultural supply, fishing, etc.) and the water quality criteria and standards necessary to support these uses, consistent with federal and state water quality laws. As substantiated in Section X.a, the proposed Project would not violate any water quality standards and therefore would not obstruct the implementation of the Basin Plan.

Additionally, the Project Site is in the Main San Gabriel Groundwater Basin, which is categorized as a very low priority basin (DWR 2025). The Sustainable Groundwater Management Act requires only medium- and high-priority basins to form groundwater sustainability agencies, develop groundwater sustainability plans, and manage groundwater for long-term sustainability. The Main San Gabriel Groundwater Basin does not require a groundwater sustainability plan. As also

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substantiated in Section X.b, all activities associated with the proposed Project would not decrease groundwater supplies or interfere substantially with groundwater recharge.

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

XI. Land Use and Planning
Would the project:

Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Physically divide an established
community? ☐ ☐ ☐ ☒
b) Cause a significant environmental impact
due to a conflict with any land use plan,
policy, or regulation adopted for the
purpose of avoiding or mitigating an
environmental effect?
☐ ☐ ☒ ☐

DISCUSSION
a) Physically divide an established community?
Development of the proposed Project on the Project Site would not introduce a new land use that would disrupt existing land use patterns, nor would it introduce a physical barrier that would separate land uses that are not already separated. The proposed Project would be developed within the confines of the Project Site. The proposed Project would not introduce roadways or other infrastructure improvements that would bisect or transect the surrounding uses. The proposed Project would utilize the existing circulation routes in the surrounding area. Access to the Project Site would continue to be from Gale Avenue and Ward Way via existing driveways.

Access to the surrounding uses and properties would also not be interrupted as a result of Project development since surrounding uses and properties do not have to cross the Project Site to access any property surrounding the site. Development of the proposed Project would not physically change the surrounding street patterns or otherwise impede movement through the surrounding areas. Therefore, no impact would occur, and no mitigation measures are necessary.

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b) Cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect? General Plan Consistency
The General Plan land use designation for the Project Site is Employment. According to the Employment land use designation, the designation allows for a variety of businesses including industrial manufacturing, assembly, printing, machining, milling, welding, research and development, distribution, warehousing, storage, and supporting office uses. As the Project Site would be developed with the proposed Project, which is considered an industrial use, the proposed Project would be consistent with the City’s General Plan as the Employment designation allows for a variety of businesses that are industrial in nature.

Therefore, project implementation would not conflict with the Industry General Plan. No land use impact related to general plan consistency would occur and no mitigation measures are necessary.

Zoning Consistency
The Project Site’s zoning designation is Industrial (M). The Industrial zoning designation 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. With approval of the zone text amendment, development of the proposed BESS facility would be consistent with the Industrial zoning designation.

Through the City’s development review process—which includes both Industry Planning Commission and City Council review and consideration of the CUP—the City would ensure that approval of the CUP would not conflict with any applicable land use plan, policies, or regulations that have been adopted for the purpose of avoiding or mitigating an environmental effect. In determining the appropriateness of the proposed Project’s CUP, the City’s Planning Department and Planning Commission, and City Council would review the CUP’s conformance with the objectives and requirements of the Industry Municipal Code (including Title 17, Zoning); consistency with the Industry General Plan and any potential effect to the public health, safety and welfare, and traffic effects; and general compliance with the development standards of Title

17. Furthermore, Project development would not require a variance or any adjustments from the Title 17 standards, which help ensure that development projects are designed and implemented in a manner that is not detrimental to the Project Site or its surroundings. The proposed Project has been designed and would be developed in accordance with all applicable development and

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design standards of Title 17, including those related to setbacks, walls and screening, landscaping, and parking. Compliance with the applicable development and design standards would be ensured through the City’s development review process.

Therefore, project implementation would not conflict with the Industry Municipal Code. Land use impacts related to zoning consistency would be less than significant and no mitigation measures are necessary.

XII. Mineral Resources
Would the project:

Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Result in the loss of availability of a
known mineral resource that would be a
value to the region and the residents of
the state?
☐ ☐ ☐ ☒
b) Result in the loss of availability of a locally
important mineral resource recovery site
delineated on a local general plan,
specific plan or other land use plan?
☐ ☐ ☐ ☒

DISCUSSION
a) Result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state?
Pursuant to the mineral land classifications of the California Geologic Survey, the Project Site is not located in a mineral resource zone (CGS 2010). No mineral resource areas that would be of value to the region and residents of the state exist on or near the Project Site. Additionally, no locally important mineral resource recovery sites are on or near the Project Site. The Project Site is also not in an area with active mineral extraction operations, nor do they support such operations.

According to the Division of Mine Reclamation, there are no mines on or near the Project Site (DOC 2016). Mining would be incompatible with the surrounding uses and is not a permitted use under the City of Industry General Plan (General Plan) and zoning designations of the Project Site, which is in a highly urbanized area and surrounded mainly by industrial uses.

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Furthermore, no mining sites are designated in the General Plan, and the nearest mine to the Project Site mapped on the Mines Online website is over 5 miles away (DMR 2022).

Finally, no oil or energy extraction and/or generation activities exist on the Project Site. A review of California Geologic Energy Management Division’s well finder indicates that there are no oil or energy wells located on or within proximity of the Project Site (CalGEM 2022).

Therefore, no impact of a known mineral resource would occur, and no mitigation measures are necessary.
b) Result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan or other land use plan? See response to Section XII.a, above. As substantiated in this section, no impact related to loss of locally important mineral recovery sites would occur and no mitigation measures are necessary.

XIII. Noise
Would the project result in:

Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Generation of a substantial temporary or
permanent increase in ambient noise
levels in the vicinity of the project in
excess of standards established in the local
general plan or noise ordinance, or
applicable standards of other agencies?
☐ ☒ ☐ ☐
b) Generation of excessive groundborne
vibration or groundborne noise levels? ☐ ☐ ☒ ☐
c) For a project located within the vicinity of
a private airstrip or an airport land use
plan or, where such a plan has not been
adopted, within two miles of a public
airport or public use airport, would the
project expose people residing or working
in the project area to excessive noise
levels?
☐ ☐ ☒ ☐

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The analysis in this section is based in part on the following technical study, which is included as Appendix Q to this Initial Study. Additional information on noise and vibration fundamentals and applicable regulations is contained in Appendix Q.
 Sound Impact Assessment, TRC, September 2025.

As shown in Figures 3, Aerial Photograph, the Project Site is in a highly urbanized area of Industry and is surrounded by mostly industrial uses.

Regulatory Setting
City of Industry General Plan
The City of Industry General Plan addresses noise in Section 4.2.6 of its Safety Element. According to the Land Use Compatibility figure of the City’s General Plan, the normally acceptable CNEL for office and commercial land uses is 70 CNEL (dBA) range. The conditionally acceptable CNEL for office and commercial land uses is the 68-78 CNEL (dBA) range. In addition, the Industry General Plan states that public noise nuisances are regulated by Chapter 1.30 (Public Nuisances) of the Industry Municipal Code.

City of Industry Municipal Code
Chapter 1.30 (Public Nuisances) of the Industry Municipal Code does not contain noise standards applicable to warehouse or industrial uses. Other sections of the Industry Municipal Code restrict noise in City parks and noise from entertainment uses, wireless telecommunication facilities, and recycling facilities, but do not contain regulations applicable to the proposed Project. The Industry Municipal Code does not restrict construction noise levels or the time frame of construction activity and rather relies on the County of Los Angeles noise ordinance for environmental noise assessments.

Los Angeles County General Plan
The Noise Element of the Los Angeles County General Plan addresses noise mitigation regulations, goals, and policies for unincorporated portions of the county such as the Hacienda Heights community, the nearest residential uses to the Project Site (see Figure 3, Aerial Photograph). Los Angeles County General Plan policies are not applicable to the proposed Project.

Los Angeles County Code of Ordinances
Construction Noise
Section 12.08.440, Construction Noise, of the Los Angeles County Code of Ordinances (County Code) prohibits construction that would create a noise disturbance across a residential or

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commercial real-property line from 7:00 p.m. to 7:00 a.m. on weekdays and at any time on Sundays or holidays. Construction noise is additionally addressed in Section 12.12.030, Construction Noise Prohibited When, which prohibits disturbing noise near residential occupancies between 8:00 p.m. and 6:30 a.m. on any day, and all day on Sunday. For the noise study conducted for the proposed Project, the more recent and restrictive 7:00 a.m. to 7:00 p.m. noise standard was applied, and it was assumed that construction on Saturdays is permissible.

Section 12.12.030 also establishes maximum construction noise levels at various receiving land uses. During the specified daytime weekday hours, the maximum hourly noise level for singlefamily residences is 75 dB Leq for mobile equipment, and for stationary equipment the maximum noise hourly level is 60 dB Leq. The maximum noise level at multifamily residential structures is 80 dB Leq for mobile equipment and 65 dB Leq for stationary equipment.

Operational Noise
Section 12.08.390, Exterior Noise Standards, of the County Code establishes maximum exterior noise levels that shall not be exceeded within a designated noise zone, which are shown in Table

14. Section 12.08.390 also provides adjustments for the length of time a noise level occurs, also included in Table 10.

Table 10 Los Angeles County Noise Control Ordinance Standards Noise
Zone
Land Use Receptor
Property Time
Exterior Noise Standard (dB)
L50 L25 L8.3 L1.7 Lmax
I Noise-Sensitive Area Anytime 45 50 55 60 65
II Residential Properties 7 a.m. to 10 p.m.
(Daytime)
45 50 55 60 65
10 p.m. to 7 a.m.
(Nighttime)
50 55 60 65 70
III Commercial Properties 10 p.m. to 7 a.m.
(Nighttime)
55 60 65 70 75
7 a.m. to 10 p.m.
(Daytime)
60 65 70 75 80
IV Industrial Properties Anytime 70 75 80 85 90
Source: Los Angeles County Noise Control Ordinance, Exterior Noise Standards, Section 12.08.390.

Notes: LN represents the noise level that is exceeded for N percent of a period of time, e.g., L25 is the noise level that is exceeded 25 percent of the time measured.

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Operational Vibration
County Code Section 12.08.020, Declaration of Policy—Nuisances Deemed Misdemeanors, defines the level of human perception for groundborne vibration as a peak particle velocity (PPV) of 0.01 inch per second over the range of 1 to 100 hertz and prohibits the operation of devices that create vibration above this level for an individual at or beyond the property boundary. This standard is not applicable to construction activities, and the Los Angeles County General Plan EIR addressed construction vibration with the Federal Transit Administration guidelines (Los Angeles County 2014).

Caltrans Groundborne Vibration Criteria
When construction equipment travels over unpaved surfaces or engages in soil movement, construction activities generate groundborne vibration. The effects of groundborne vibration include the discernible movement of building floors, rattling of windows, shaking of items on shelves or hanging on walls, and rumbling sounds. Vibration-related problems generally occur due to resonances in the structural components of a building because structures amplify groundborne vibration. The “soft” sedimentary conditions of much of southern California dampen groundborne vibration over a relatively short distance.

Groundborne vibration from construction activities rarely reaches levels that can damage structures. Although there are no officially adopted regulatory standards for the point at which groundborne vibration levels could cause structural damage, Caltrans provides vibration guidelines for structural damage, which are provided in Table 11.

Table 11 Vibration Damage Criteria
Structure and Condition
Maximum PPV (in/sec)
Transient1 Transient2
Extremely fragile historic buildings 0.12 0.08
Fragile buildings 0.2 0.1
Historic and some old buildings 0.5 0.25
Older residential structures 0.5 0.3
New residential structures 1.0 0.5
Modern industrial/commercial buildings 2.0 0.5
Source: Caltrans 2020.

Notes: PPV = peak particle velocity; in/sec = inches per second 1 Sources creating a single isolated vibration event, such as blasting or drop balls. 2 Frequent or intermittent sources include impact or vibratory pile drivers, pogo-stick compactors, crack-andseat equipment, and vibratory compaction equipment.

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As shown in Table 2, the criteria for structural vibration damage are 0.5 PPV in/sec for modern industrial/commercial structures for intermittent sources and 0.3 PPV in/sec for older residential structures for intermittent sources, which are the standards that were used for the vibration analysis contained herein.8
Existing Conditions
Sensitive Uses
The nearest sensitive land uses to the Project Site are the residential areas immediately south of the Project Site along Gale Avenue and Folger Street. The closest of these residences is approximately 130 feet south of the Project Site, as shown in Table 12. The land uses to the north, east, and west are predominantly industrial and commercial and are not considered areas of sensitive land use.

Table 12 Closest Noise-Sensitive Receptors
Noise-Sensitive Receptor Description
Approximate Distance from
Project Site to Receptor
1 Residence 600
2 Residence 340
3 Residence 180
4 Residence 200
5 Residence 260
6 Residence 150
7 Residence 130
8 Residence 140
9 Residence 130
10 Residence 140
11 Residence 140
12 Residence 150
13 Residence 190
14 Residence 240
15 Residence 290
Source: Appendix Q.
8 The Caltrans guidance manual does not explicitly define older residences, but provides example analyses that categorize residences constructed in the 1940s as “older.”

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Ambient Noise Levels
Transportation systems are a primary source of urban noise. Management of noise from the most significant of these sources (aircraft, trains, and freeways) is generally preempted by federal and state authority. Primary municipal authority is regulation of land use. Management of noise emanating from freeways is generally within the authority of federal and state jurisdictions, namely, the Federal Highway Administration (FHWA) and Caltrans.

A long-term pre-construction ambient noise survey was conducted at the Project Site from August 20th to August 25th, 2025, to characterize the existing sound environment in the project area.

The measurements were taken using a Larson Davis SoundExpert® LxT sound level meter that meets the requirements of the American National Standards Institute (ANSI) Standards for Type I instruments. The location of the measurements is shown in Figure 11, Noise Measurement Locations. The Leq measured at the Project Site during this period was 68.0 dBA while the L90 was 48.6 dBA.

DISCUSSION
a) Generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies? The following analysis evaluates the potential noise levels resulting from the proposed Project during construction and operation. The analysis then considers whether these effects would exceed applicable standards and/or thresholds of significance based on Sections 12.08.440 and

12.08.390 of the County Code. The noise and vibration analysis presents quantitative estimates of the proposed Project’s construction and operational noise generation to the surrounding environment, which consists of a mix of industrial, commercial, and residential land uses (see Figure 3, Aerial Photograph).

Construction Noise
Short-term, localized increases in sound levels are likely to occur during construction. Standard construction equipment will be used in the construction of the facility. To be conservative in the construction noise calculations, all Project construction equipment was included in the noise model as operating at the same time. The highest sound levels during construction are expected during the early earthmoving phase. Based on the proposed Project’s equipment usage predictions, a sound level calculation was performed using the Federal Highway Administration’s Roadway Construction Noise Model version 1.1 (FHWA 2006).

Pl
Y
aceWorks
DATE:

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FILE:

TITLE:

PROJECT:
604109 AypaMarici BESS Noise.aprx
Coordinate System: NAD 1983 StatePlane California V FIPS 0405 Feet; Map Rotation: 0 -- Saved By: MERNSTING on 9/10/2025, 13:02:09 PM; File Path: K:\604109 Aypa Marici BESS Noise\04 GRAPHICS\APRX\604109 AypaMarici BESS Noise.aprx; Layout Name: 1. Site Layout F
1:1,800
1" = 150' 0 100 200
FEET
/NOTES:

1. BASE MAP IMAGERY, ESRI, 1/29/2024.

2. DRAFT LAYOUT, TRC, 2/5/2025

3. ELEVATION DATA, USGS 3DEP, 2024
SEPTEMBER 2025
J. STENGER
M. FEINBLATT
M. ERNSTING
FIGURE 1
604109.0000.0000

SITE LAYOUT

BESS SOUND STUDY

MARICI PROJECT, LLC

INDUSTRY, CALIFORNIA
LEGEND
EQUIPMENT LOCATIONS "/ BATTERY CONTAINER "/ TRANSFORMER (! MEASUREMENT LOCATION

POTENTIAL NSA

PROPERTY LINE
1-METER CONTOUR LINE
10-FT CMU WALL
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(!
S S timson Ave
Gale Ave
Barford Ave
Union Pacific RR
Gale Ave
Gale Ave
Ward Way
Folger S t
Hinnen Ave
Barford Ave
Folger S t
Union Pacific RR Union Pacific RR
Gale Ave
Gale Ave
Union Pacific RR
109 08
1 107 0
1 605
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NSA07
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NSA06
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NSA15
LT-1
Figure 11
Noise Measurement Locations
Source: TRC 2025.
0 Scale (Feet)
200
F
1:1,800
/NOTES:

1. BASE MAP IMAGERY, ESRI, 1/29/2024.

2. DRAFT LAYOUT, TRC, 2/5/2025

3. ELEVATION DATA, USGS 3DEP, 2024
LEGEND
EQUIPMENT LOCATIONS "/ BATTERY CONTAINER "/ TRANSFORMER (! MEASUREMENT LOCATION

POTENTIAL NSA

PROPERTY LINE
1-METER CONTOUR LINE
10-FT CMU WALL
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Ave
Union Pacific RR
Gale Ave
Ward Way
Union Pacific RR Union Pacific RR
Union Pacific RR
08 1
107 0
1 605
1 104
1 05 100
01 5
104
10099
103
102
101
104
103
10 NSA02

MARICI BATTERY ENERGY STORAGE FACILIT

CITY OF INDUSTRY

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Table 13 summarizes the results of the construction noise modeling for all the nearby receptor areas using the loudest construction phase. For construction noise modeling purposes, all equipment listed for each phase is assumed to be operating simultaneously at the nearest possible site location to each receptor group.

Table 13 Project Construction Noise Level Increases
Noise Sensitive
Receptor Area
Noise Sensitive
Receptor Number
Measured
Ambient Sound
Level (L90)
Max. Predicted
Sound Level, Single
Daytime Shift (dBA)
Combined Sound
Level (dBA)
Group 1 1 48.6 79.4 79.4
Group 2 2 48.6 84.1 84.1
Group 3 3, 4, 13 48.6 86.9 86.9
Group 4 5, 14, 15 48.6 89.2 89.2
Group 5 6, 7, 8, 9, 10, 11, 12 48.6 91.7 91.7
Source: Appendix Q
Table 14 lists the predicted construction sound levels for each phase at each receptor group listed in Table 13. The highest modeled impacts occur during the equipment installation phase. The maximum impact is below the 75 dBA daytime residential threshold established by the County Code during the majority of construction.

Table 14 Construction Noise Levels by Construction Activity Construction Phase Schedule
Sound Level (Leq) at Receptor Group
Group 1 Group 2 Group 3 Group 4 Group 5
Demolition Phase 1 Month 1 60.6 65.3 68.2 70.4 72.9
Demolition Phase 2 Month 2 61.7 66.5 69.3 71.6 74.1
Demolition Phase 3 Month 3 61.7 66.5 69.3 71.6 74.1
Site Prep Month 4 60.7 65.5 68.3 70.6 73.1
Grading Month 5 60.9 65.6 68.4 70.7 73.2
Drilling Month 6.5 50.3 55.0 57.8 60.1 62.6
Foundations Month 6-9 59.5 64.2 67.0 69.3 71.8
Collector Substation
Prep Month 7-12 57.0 61.7 64.5 66.8 69.3
Crane Work Month 8 50.7 55.4 58.3 60.6 63.0
Equipment Installation Month 8-11 79.4 84.1 86.9 89.2 91.7

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Table 14 Construction Noise Levels by Construction Activity Construction Phase Schedule
Sound Level (Leq) at Receptor Group
Group 1 Group 2 Group 3 Group 4 Group 5
Trenching Month 9-10 58.0 62.7 65.6 67.8 70.3
Tie Line Install Month 12 45.8 50.6 53.4 55.7 58.2
Pave/Surface/Landscape Month 12 57.3 62.0 64.8 67.1 69.6 Source: Appendix Q
As shown above, the proposed Project would result in moderate temporary increases in sound levels at the nearby sensitive receptor areas during Project construction activities. The proposed Project would comply with County Code Section 12.08.440, Construction Noise; however, construction noise would exceed thresholds and be potentially significant. The proposed Project would implement Mitigation Measure NOI-1 requiring the use of sound control devices on construction equipment, which would further ensure noise levels during construction are reduced.

Mitigation Measure NOI-1: The construction contractor shall limit construction activities to between the hours of 7:00 a.m. and 7:00 p.m. on weekdays, as required by the Los Angeles County Code 12.08.440, Construction Noise. Construction is prohibited outside these hours during weekdays and anytime on weekends. The construction contractor shall also implement the following best practices:
 Utilize sound control devices no less effective than those provided by the manufacturer.
 Maintain equipment in accordance with the manufacturer's recommendations.
 No equipment will have unmuffled exhausts.
 Equipment idling will be kept to a minimum.

Compliance with the County Code and Mitigation Measure NOI-1 would ensure that the proposed Project would not result in generation of a substantial temporary or permanent increase in ambient noise levels in excess of applicable noise ordinances. Therefore, impacts would be less than significant with mitigation.

Operational Noise
The primary noise-producing sources on the site during Project operation would be the BESS containers and medium-voltage transformers, as well as two substation step-up transformers. A

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total of 480 BESS containers and 120 transformers are proposed throughout the site. Two additional 34.5/220 kV station service transformers would be located within the substation in the southeast portion of the site. The location of these sources is shown in Figure 12, Noise Generating Project Features. The Cadna-A® noise model was used to predict future sound levels resulting from the operation of the proposed BESS containers and associated equipment at the property line.

The source model inputs and locations were based on proposed electrical equipment specifications in design drawings by TRC dated February 5, 2025. The sound power level for the proposed battery containers, the Sungrow PowerTitan 2.0, is 75 dBA according to manufacturer specifications. The sound level for the transformer units, the Sungrow MVS5000-LV-US, is not listed in manufacturer specifications, so the modeled sound levels are based on a generic 5,140 kVA, 2-winding, KNAN transformer. The noise levels of the proposed Project’s infrastructure are shown in Table 15, Noise Source Impacts. Since the sound-producing equipment were assumed to be continuously operating, the L90 (background level) and Leq (equivalent constant level) of the proposed equipment are the same for the purposes of this assessment.

Table 15 Noise Source Inputs
Equipment Source Height (meters) dBA
Transformers (120) 1.2 77
Substation Transformer (2) 1.2 62
Battery Containers (480) 1.4 75
Source: Appendix Q
Note: Heights based on component dimensions and mounting orientation, assumed pad-mounted equipment.

Source levels are extrapolated from manufacturer-provided or generic sound pressure level specifications.

Cadna-A® allows the user to place receptors at selected locations and predicts sound levels at those specific receptor locations. For this analysis, specific receptors were placed at the closest exterior walls of the nearest residential receptors, listed in Table 16. The model also calculated sound levels for the surrounding area, using a 10-foot receptor grid, with a receptor height of 5.1 feet (representative of average ear height). This data is displayed in the isopleths9 in Figure 12, which show lines of equal sound level at the site and the surrounding area.

Table 16 lists the steady-state, A-weighted sound level results at each modeled receptor, along with the calculated increase over the ambient sound level (assumed to be the measured L90 value). These results take into account the terrain of the area and a 10-foot-high masonry perimeter wall as shown in Figure 4a, Proposed Site Layout. The model assumed continuous and 9 An isopleth is a line on a map connecting points having equal incidence of a specified meteorological feature.

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simultaneous operation of all sound-producing equipment. This was a conservative assumption, since not all equipment will be operating continuously at full load.

Table 16 Operational Noise Levels at Receptor Locations Noise Sensitive Receptor
Sound Level (dBA)
Modeled Ambient Combined Increase
1 36.6 48.6 48.9 0.3
2 39.1 48.6 49.1 0.5
3 41.1 48.6 49.3 0.7
4 40.9 48.6 49.3 0.7
5 40.1 48.6 49.2 0.6
6 43.0 48.6 49.7 1.1
7 44.1 48.6 49.9 1.3
8 43.0 48.6 49.7 1.1
9 42.1 48.6 49.5 0.9
10 41.1 48.6 49.3 0.7
11 40.5 48.6 49.2 0.6
12 39.9 48.6 49.1 0.5
13 38.9 48.6 49.0 0.4
14 38.3 48.6 49.0 0.4
15 37.9 48.6 49.0 0.4
Source: Appendix Q
As shown in Table 16, the maximum predicted sound level from the proposed Project at nearby potential noise-sensitive locations is 44.1 dBA at receptor location 7, which when combined with the existing ambient noise level at this location, would be 49.9 dBA. The model assumes all sound sources are in continuous operation, so the Leq over any duration would be the same. Overall, the proposed Project would generate a maximum 1.3 dBA increase, which is considered to be imperceptible to the human ear. These noise levels would not exceed the maximum exterior noise levels of any noise zone, per County Code Section 12.08.390, Exterior Noise Standards (see Table 10, Los Angeles County Noise Control Ordinance Standards).

Pla
Y
ceWorks
DATE:

APPROVED BY:

CHECKED BY:

DRAWN BY: PROJ. NO.:

FILE:

TITLE:

PROJECT:
604109 AypaMarici BESS Noise.aprx
Coordinate System: NAD 1983 StatePlane California V FIPS 0405 Feet; Map Rotation: 0 -- Saved By: MERNSTING on 9/10/2025, 13:02:09 PM; File Path: K:\604109 Aypa Marici BESS Noise\04 GRAPHICS\APRX\604109 AypaMarici BESS Noise.aprx; Layout Name: 2. Modeling Results F
1:2,400
1" = 200'
0 100 200
FEET
/NOTES:

1. BASE MAP IMAGERY, ESRI, 1/29/2024.

2. DRAFT LAYOUT, TRC, 2/5/2025

3. CADNAA MODELING DATA, TRC, 2025
SEPTEMBER 2025
J. STENGER
M. FEINBLATT
M. ERNSTING
FIGURE 2
604109.0000.0000

MODELING RESULTS

BESS SOUND STUDY

MARICI PROJECT, LLC

INDUSTRY, CALIFORNIA
LEGEND
EQUIPMENT LOCATIONS "/ BATTERY CONTAINER "/ TRANSFORMER (! MEASUREMENT LOCATION

POTENTIAL NSAS

PROPERTY LINE
10-FT CMU WALL

SOUND LEVEL (DBA)
25 - 30
35 - 40
45 - 50
55 - 60
> 60
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Gale Ave
S S timson Ave
Robin Way Phoenix
Dr Shadybend Dr
Union Pacific RR
Union Pacific RR
Union Pacific RR
Gale
Ave
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Fo
Hi
lger S t
nnen Ave
Gale Ave
Hinnen Ave
Barford Ave
Folger
S t
Glenelder
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School
Gale Ave
(!
45 40
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55 35
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65 65
65 40
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65 65
65 65
65 65
65 45
45 40
40 30
NSA01
NSA02
NSA03
NSA04
NSA05 NSA06 NSA07
NSA08
NSA09
NSA10
NSA11 NSA12
NSA13
NSA14
NSA15
LT-1
F
1:2,400
/NOTES:

1. BASE MAP IMAGERY, ESRI, 1/29/2024.

2. DRAFT LAYOUT, TRC, 2/5/2025

3. CADNAA MODELING DATA, TRC, 2025
LEGEND
EQUIPMENT LOCATIONS "/ BATTERY CONTAINER "/ TRANSFORMER (! MEASUREMENT LOCATION

POTENTIAL NSAS

PROPERTY LINE
10-FT CMU WALL

SOUND LEVEL (DBA)
25 - 30
35 - 40
45 - 50
55 - 60
> 60
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e
S S timson Ave
Union Pacific RR
Union Pacific RR
Union Pacific RR
Gale
Ave
Ward Way
(!
45 40
35 60
55 35
30 35
30 65
60 50
60 60
65 65
65 40
40 65
65 65
65 65
65 65
65 65
65 45
45 40
40 30
NSA01
NSA02
NSA03
NSA04
NSA07
LT-1
Figure 12
Noise Generating Project Features
Source: TRC 2025.
0 Scale (Feet)
225

MARICI BATTERY ENERGY STORAGE FACILIT

CITY OF INDUSTRY

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Furthermore, with respect to the proposed Project’s interconnection at the adjacent Walnut Substation, no interconnection infrastructure to be installed within the Walnut Substation would be a material source of noise. Sound levels associated with transmission electrostatic effects (also known as “corona” effects) occur during precipitation events or very high humidity and generally are only discernable during very high humidity because the corona effect noise can be masked by the rainfall itself. Since corona effect noise is substantially quieter than the onsite noise sources of the proposed Project and is dependent on humid conditions that are not typical of the area, corona noise from the short electric tie-line is not expected to be routinely discernable.

Therefore, operational noise from the proposed Project would not increase ambient noise levels in excess of applicable noise ordinances. Impacts would be less than significant, and no mitigation measures are necessary.
b) Generation of excessive groundborne vibration or groundborne noise levels? Construction Vibration
Vibration impacts during construction are assumed to be minor based on the preliminary list of construction equipment (Appendix Q). No rock blasting is anticipated, and all equipment that will have the potential to generate groundborne vibration, such as trucks and tracked construction vehicles, will be mobile/transient and used over short durations. Equipment is anticipated to be used within the interior of the site rather than along the property line on a frequent basis. Traffic along Gale Avenue and railroad activity in the vicinity may have more significant vibration impact than construction equipment.

The FTA Transit Noise and Vibration Impact Assessment Manual provides methodology and vibration reference levels for certain equipment. Specified by County Code Section 12.08.020, Declaration of Policy—Nuisances Deemed Misdemeanors, the highest estimated vibration level during construction is 0.006 in/sec at 150 feet, based on a large bulldozer with a reference PPV of 0.089 in/sec at 25 feet (FTA 2018). This level is below the 0.01 in/sec threshold established by the ordinance.

Therefore, vibration impacts during construction are expected to be minimal, and construction vibration impacts would be less than significant. No mitigation measures are necessary.

Operational Vibration
Operational vibration impacts for both the proposed Project would be similar to existing surrounding uses and would not include any sources of substantial groundborne vibration. Truck trips on paved roads are unlikely to generate substantial vibration levels and would be similar to existing and surrounding uses. Therefore, impacts associated with operational vibration would be less than significant and no mitigation measures are necessary.

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c) For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels?
There are no public airports or private airfields within two miles of the Project Site, and the Project Site is far from any aviation traffic noise contour greater than 65 dBA CNEL. The nearest public airport is the San Gabriel Valley Airport, which is approximately 7 miles northwest of the Project Site. At this distance, implementation of the proposed Project would not expose people residing or working in the project area to excessive levels. Additionally, there is one governmentand two private-operated helipads within the vicinity of the Project Site: these include the Los Angeles County Sheriff’s station ground-level helipad at 150 Hudson Avenue (approximately 0.95 mile to the north), a private rooftop helipad of the Pacific Palms Resort at 1 Industry Hills parkway (approximately 1.65 miles to the northeast), and a private roof-top helipad at 450 Baldwin Park Boulevard (approximately 3.7 miles to the northwest)(AirNav 2025). One of the airstrips (Los Angeles County Sheriff’s station ground-level helipad) is in proximity (less than one mile) of the Project Site; however, implementation of the proposed Project would not alter the flight path of this helipad that would increase safety hazards or noise levels in the vicinity of the Project Site.

The proposed Project would not expose people on-site (during either the construction or operation phases) to excessive airport-related noise. No impact would occur no mitigation measures are necessary.

XIV. Population and Housing
Would the project:

Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Induce substantial unplanned population
growth in an area, either directly (for
example, by proposing new homes and
businesses) or indirectly (for example,
through extension of roads or other
infrastructure)?
☐ ☐ ☐ ☒
b) Displace substantial numbers of existing
people or housing, necessitating the
construction of replacement housing
elsewhere?
☐ ☐ ☐ ☒

MARICI BATTERY ENERGY STORAGE SYSTEM FACILITY INITIAL STUDY / MITIGATED

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DISCUSSION
a) Induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)?
The Project Site is in a developed industrial area of the City. No residential development is proposed under the proposed Project; therefore, the proposed Project would not directly induce population growth in Industry. The proposed Project would establish a new BESS facility that would benefit the City and Southern California Edison (SCE) economically by providing construction jobs, construction and maintenance services, and increased energy efficiency and reliability. The proposed Project would not require new infrastructure or extension of existing infrastructure that could indirectly induce population growth nearby. Therefore, no impact on population and housing would occur and no mitigation measures are necessary. b) Displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere?
No housing exists on the Project Site, and it is currently developed with industrial uses a (see Figure 3, Aerial Photograph). Therefore, Project development would not displace housing or people. No impact would occur, and no mitigation measures are necessary.

XV. Public Services
Would the project:

Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Result in substantial adverse physical
impacts associated with the provision of
new or physically altered governmental
facilities, need for new or physically
altered governmental facilities, the
construction of which could cause
significant environmental impacts, in order
to maintain acceptable service ratios,
response times, or other performance
objectives for any of the public services:
☐ ☐ ☐ ☐
Fire protection? ☐ ☐ ☒ ☐
Police protection? ☐ ☐ ☒ ☐

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Schools? ☐ ☐ ☐ ☒
Parks? ☐ ☐ ☐ ☒
Other public facilities? ☐ ☐ ☐ ☒

DISCUSSION
a) Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for any of the public services:

Fire protection?
The Los Angeles County Fire Department (LACoFD) provides fire protection and emergency medical services to the City of Industry, including the Project Site. Industry is served by Battalion 12 of LACoFD, which mans and operates six fire stations: Fire Stations 26, 43, 87, 91, 118, and 155. The nearest and first response fire station to the Project Site is Fire Station 43 at 921 South Stimson Avenue in Industry, which is approximately 800 feet west of the proposed Project. LACoFD also has mutual aid agreements with other fire departments in the county.

Development of the proposed Project could result in the need for fire protection and emergency medical services in the unlikely event of an emergency incident occurring at the BESS facility (e.g., fire, explosion). Implementation of the proposed Project is not anticipated to result in a need for fire protection and emergency medical services.

As discussed in Section IX, Hazards and Hazardous Materials, BESS facilities are required to meet the requirements of the NFPA, which issues standards for addressing energy storage systems (NFPA 2022). The proposed Project’s battery enclosures would be equipped with fire monitoring systems, controls, and cooling units to keep the batteries at optimal operating temperatures. The fire monitoring systems consist of smoke and heat sensors, gas detectors, alarms, remote monitoring, and an NFPA 69-compliant explosion prevention system. Each fire protection system would have a signal that would trigger core power-down during a fire, electrical fire, overheating, or other issues. The entire project power-down would occur automatically in the event of electrical fault conditions (e.g., high-voltage, highfrequency, ground fault). In addition, the proposed BESS facility would be equipped with breakers that could be opened manually to power down different equipment or the BESS facility.

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LACoFD is responsible for issuing required permits to BESS facilities and would be responsible for plan checking and approvals of the proposed Project’s BESS facility. LACoFD has implemented additional permitting requirements to ensure fire safety related to proposed BESS facilities, which are detailed in Section IX.d.

Additionally, Project development would be required to adhere 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. The fire code imposes design standards and requirements that seek to minimize and mitigate fire risk. Project development would also be required to adhere to NFPA 855, which is the National Fire Protection Association standard for the Installation of stationary energy storage systems; it setting minimum safety requirements for battery systems. The City also involves LACoFD in the development review process in order to ensure that the necessary fire prevention and emergency response features are incorporated into development projects.

Additionally, in the event of an emergency that required more resources than Station 43 could provide, LACoFD would direct resources to the site from other nearby stations in Industry and, if needed, would request assistance from other nearby fire departments. Also, the Project Site is already served by LACoFD; therefore, the proposed Project would not result in an expansion of LACoFD’s service area.

Further, as shown in Figure 4, Proposed Site Layout, emergency vehicle access to the Project Site would be provided via two driveways, one off Gale Avenue and the other off Ward Way.

All site and structural improvements proposed under the proposed Project would be subject to review and approval by LACoFD prior to building permit issuance.

Based on the preceding, the proposed Project would not adversely affect LACoFD’s ability to provide adequate service and would not require new or expanded fire facilities that could result in adverse environmental impacts. Therefore, impacts would be less than significant, and no mitigation measures are necessary.

Police protection?
The Los Angeles County Sheriff’s Department (LASD) provides police protection to Industry, including the Project Site. The nearest LASD station to the Project Site is the Industry Station at 150 North Hudson Avenue in Industry, approximately one mile to the north.

Implementation of the proposed Project is not anticipated to result in an increased demand for police protection services. The proposed BESS facility on the Project Site includes security measures and features that would help prevent needing to call for police services. For example, the Project Site would be secured on all sides via the provision of walls, fences, and controlled-access vehicular gates, which are illustrated in Figure 4, Proposed Site Layout,

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and Figure 6, Substation Elevations, to prevent access from the public and secure the site.

As illustrated in the figures, the Project Stie would be secured on all sides by block walls with security wiring on top. 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.

Also, security lighting for the BESS facility on the Project Site would be provided from dusk until dawn. Permanent motion-sensitive, directional security lights would be installed onsite to provide adequate illumination around the substation area 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.

Additionally, the City involves LASD in the development review process in order to ensure that the necessary police protection features are incorporated into development projects.

All site and structural improvements proposed under the proposed Project would be subject to review and approval by LASD.

Project implementation would not result in an increase in calls for police protection service.

As described above, no new population would be located onsite daily, and the BESS facility includes various security measures, (e.g., fencing, cameras, lighting) to enhance public safety and secure the site. Considering the existing police resources available in and near Industry, project impacts on police services (including response times) are not expected to occur. LASD’s staffing and equipment levels could sufficiently respond to any additional calls and responses that could be generated by the proposed Project. Additionally, in the event of an emergency that required more resources than LASD could provide, LASD would request assistance from other nearby police or Sherriff departments. The Project Site and Substation Area are also infill sites already served by LASD; therefore, the proposed Project would not result in an expansion of their service area.

Based on the preceding, the proposed Project would not adversely affect LASD’s ability to provide adequate service and would not require new or expanded police facilities that could result in adverse environmental impacts. Therefore, impacts related to police services would be less than significant and no mitigation measures are necessary.

Schools?
The increase in student generation and the need for new or the expansion of existing school facilities is tied to population growth. The proposed Project is anticipated to have up to two employees on-site daily. This small increase in the daily employee population in the City would not result in a substantial increase in usage of local school facilities.

MARICI BATTERY ENERGY STORAGE SYSTEM FACILITY INITIAL STUDY / MITIGATED

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Therefore, no impact related to schools would occur and no mitigation measures are necessary.

Parks?
The need for new or the expansion of existing parks is tied to population growth. No residential development is proposed under the proposed Project, and Project development would not generate a need for new or additional parks. Therefore, no impact related to library services or facilities would occur and no mitigation measures are necessary.

Other public facilities?
The need for new or the expansion of existing library services and other public facilities is tied to population growth. No residential development is proposed under the proposed Project, and Project development would not generate a need for new or additional library services or other public facilities. Therefore, no impact related to library services or other public facilities would occur and no mitigation measures are necessary.

XVI. Recreation
Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Would the project increase the use of
existing neighborhood and regional parks
or other recreational facilities such that
substantial physical deterioration of the
facility would occur or be accelerated?
☐ ☐ ☐ ☒
b) Does the project include recreational
facilities or require the construction or
expansion of recreational facilities which
might have an adverse physical effect on
the environment?
☐ ☐ ☐ ☒

MARICI BATTERY ENERGY STORAGE SYSTEM FACILITY INITIAL STUDY / MITIGATED

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DISCUSSION
a) Would the project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated?
The increase in the use of existing parks and recreational facilities and the need for new or the construction or expansion of existing recreational facilities is tied to population growth. No residential development is proposed as a part of the proposed Project. Additionally, it is anticipated that up to two employees would be present on the Project Site on a daily basis. It is likely that employees would live locally and therefore would not increase the usage of nearby recreational facilities. Therefore, no population growth or increase in the use of existing parks or other recreational facilities would occur. Therefore, no impact would occur, and no mitigation measures are necessary.
b) Does the project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment? The proposed Project does not involve the development of recreational facilities; and Project development would not require construction of new or expanded recreational facilities, as noted in Section XVI.a, above. Therefore, no impact would occur, and no mitigation measures are necessary.

XVII. Transportation
Would the project:

Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Conflict with a program, plan, ordinance or
policy addressing the circulation system,
including transit, roadway, bicycle and
pedestrian facilities?
☐ ☐ ☒ ☐
b) Conflict or be inconsistent with CEQA
Guidelines § 15064.3, subdivision (b)? ☐ ☐ ☒ ☐
c) Substantially increase hazards due to a
geometric design feature (e.g., sharp
curves or dangerous intersections) or
incompatible uses (e.g., farm equipment)?
☐ ☐ ☒ ☐
d) Result in inadequate emergency access? ☐ ☐ ☒ ☐

MARICI BATTERY ENERGY STORAGE SYSTEM FACILITY INITIAL STUDY / MITIGATED

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The analysis in this section is based partly on the following technical study, which is included as Appendix R to this Initial Study:
 Transportation Study, Fehr & Peers, May 2025.

DISCUSSION
a) Conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities? Following is a discussion of the proposed Project’s potential impacts on a program, plan, ordinance, or policy addressing the circulation system and the evaluation was conducted by reviewing City documents related to transportation: the Industry General Plan Circulation Element and Title 17, Zoning, of the Industry Municipal Code.

Industry General Plan Circulation Element
The Industry General Plan Circulation Element outlines the City’s plans to provide a transportation network system that allows the movement of people, goods, and services easily and safely throughout Industry. As stated in the Circulation Element, to enhance the value of existing businesses, attract new businesses, and stimulate new investment, the City must continue to improve its circulation systems to ensure they accommodate the desired level of growth, are functional and safe, and further the professional appearance desired in Industry. As such, the proposed Project would be a new business occupying a former businesses’ site and would provide new investment to the City. Therefore, the proposed Project would not conflict with the City’s General Plan.

Industry Municipal Code
Title 17, Zoning, of the Industry Municipal Code includes the development and design standards and regulations that constitute the zoning regulations that govern development and use of the Project Site and help implement the Industry General Plan. The Industry Municipal Code is the guiding document that contains the City’s rules and regulations that apply to development.

Generally, transportation-specific ordinances, standards or regulations that apply to the proposed Project would pertain to minimum parking requirements. The proposed Project would comply with any municipal code requirements.

Roadway Facilities
As stated in the Circulation Element, Industry’s roadway system must provide convenient access and be safe, free-flowing, functional, and compatible with its surroundings. The roadway system must provide the necessary capacity to accommodate the traffic generated from future development. The street rights-of-way also need to accommodate pedestrians, bicyclists,

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landscaping, traffic control devices, and infrastructure in a manner that is safe and aesthetically pleasing.

As shown in Figure 4a, vehicular employee-only access to the Project Site would be provided from Gale Avenue via two driveways, which forms the Project Sites southern boundary, and via one driveway from Ward Way, which forms the Project Site’s western boundary. The three driveways would provide access to the internal aisles and parking area.

Project development would not impact the functionality or use of Gale Avenue or Ward Way.

Additionally, design and construction of the proposed driveways would be required to adhere to the City’s Public Works Department’s established standard plans and the standards outlined in the Industry Municipal Code, which are imposed on development projects during the City’s development review and building plan check process. For example, at intersections and project driveways, a substantially clear line of sight must be maintained between the driver of a vehicle waiting at the crossroad and the driver of an approaching vehicle. Sight distance is the continuous length of roadway visible to the driver. Based on a review of aerial photography and Google maps, there are no restrictions blocking views from the locations of the proposed driveways and traffic along Gale Avenue or Ward Way, and sufficient sight distance would be provided. Compliance with the established design standards would ensure that hazards due to design features would not occur and that the placement of the vehicular access and circulation improvements would not create a conflict for motorists, pedestrians, or bicyclists traveling along Gale Avenue or Ward Way.

Additionally, during the construction phase of the proposed Project, the number of trips that would be generated during the peak construction period, specifically during the demolition phase, would be 163 daily trips. The construction phase would be from February 2026 to early 2027 and any impact on roadway facilities due to additional vehicles on the road would be temporary and all work during the construction phase would be limited to the confines of the Project Site. The operation phase would include two employees daily to conduct maintenance of the proposed BESS facility that would operate on the Project Site. As such, the permanent number of trips to the Project Site for maintenance would be negligible and would not substantially impact the roadway facilities in the vicinity.

Transit, Pedestrian, and Bicycle Access and Facilities
Public transit in the City is provided by Foothill Transit. Foothill Transit provides public transportation in the form of bus services and includes buses that serve the San Gabriel Valley, Pomona Valley, and downtown Los Angeles. The project area is served by Line 281 and Line 285.

The nearest bus stops to the Project Site are Bus Stops 1393 and 2789 of Lines 281 and 285, located at the intersection of Hinnen Avenue and Gale Avenue, which is just south of the Project Site. The proposed improvements at the Project Site would not interfere with the existing public transit service or facilities as all improvements would occur within the confines of the Project Site.

Furthermore, safe access to the aforementioned bus stops to and from the Project Site would be

MARICI BATTERY ENERGY STORAGE SYSTEM FACILITY INITIAL STUDY / MITIGATED

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available to site maintenance employees (if needed) via the existing public sidewalk along Gale Avenue.

Under existing conditions there is no sidewalk along Ward Way, which forms the western site boundary; however, there is a public sidewalk along Gale Avenue, which forms the southern site boundary. Additionally, implementation of the proposed Project would not impact any bicycle facilities because no such facilities exist adjacent to or within the vicinity of the Project Site.

Conclusion
As demonstrated above, Project development would not conflict with any components of the Industry General Plan Circulation Element or the City’s Municipal Code, nor would it preclude the City from implementing adopted programs, plans, and policies addressing the circulation system.

Therefore, impacts would be less than significant, and no mitigation measures are necessary. b) Conflict or be inconsistent with CEQA Guidelines § 15064.3, subdivision (b)? The legislature found that with adoption of Senate Bill 375, the state had signaled its commitment to encourage land use and transportation planning decisions and investments that reduce vehicle miles traveled and thereby contribute to the reduction of GHG emissions, as required by the California Global Warming Solutions Act of 2006 (Assembly Bill (AB 32)). Additionally, AB 1358 (Complete Streets Act) requires local governments to plan for a balanced, multimodal transportation network that meets the needs of all users.

On September 27, 2013, SB 743 was signed into law. SB 743 started a process that would fundamentally change transportation impact analysis as part of CEQA compliance. These changes include the elimination of auto delay, level of service (LOS), and other similar measures of vehicular capacity or traffic congestion as a basis for determining significant impacts in many parts of California (if not statewide). As part of the updated CEQA Guidelines, the new criteria “shall promote the reduction of greenhouse gas emissions, the development of multimodal transportation networks, and a diversity of land uses” (Public Resources Code Section 21099(b)(1)). On January 20, 2016, the Office of Land Use and Climate Innovation (LCI), formerly the Office of Planning and Research (OPR), released revisions to its proposed CEQA guidelines for the implementation of SB 743. Final review and rulemaking for the new guidelines were completed on December 28, 2018, when the California Natural Resource Agency certified and adopted the CEQA Guidelines update package, including guidelines section implementing Senate Bill 743.

On June 25, 2020, the City adopted Resolution CC 2020-20, which established vehicle miles traveled (VMT) thresholds for the purpose of analyzing transportation impacts under CEQA. Per the City’s Transportation Guidelines, projects generating less than 110 (permanent) daily vehicle trips may be screened out of VMT analysis and would be presumed to have a less than significant impact on VMT.

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Proposed Project VMT
Development of the BESS facility on the Project Site would involve construction that would generate temporary construction-related traffic. The proposed Project’s construction phase would be consistent with typical construction activities in terms of the temporary nature of activities, trip generation characteristics, and the types of vehicles and equipment required.

While worker and vendor trips would generate VMT, once construction is completed, the construction-related traffic would cease and VMT would return to pre-construction conditions.

Impacts due to construction activities would be temporary and would not result in any meaningful long-term or permanent change in VMT. It is anticipated that most construction personnel would be from surrounding population centers. Measures to reduce the VMT generated by workers and trucks are limited, and there are no thresholds or significance criteria for temporary, construction-related VMT. The increase in VMT associated with the proposed Projects’ construction is expected to be temporary and would therefore not cause a significant VMT impact.

In addition, the operation phase of the proposed Project would include one or two staff members on-site, as needed. In addition to on-site staff, the proposed Project is expected to typically require a four- to six-person crew for maintenance visits, once every two to three months on average. As concluded in the Transportation Study prepared for the proposed Project, the proposed Project generated traffic would be negligible (Appendix R). Therefore, consistent with the City’s adopted Transportation Guidelines, the proposed Project screens out of VMT analysis and is presumed to have a less than significant impact on VMT. Impacts would be less than significant, and no mitigation measures are necessary.
c) Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? The proposed Project includes three existing driveways that would provide vehicular employeeonly access to the Project Site. The Project Site would also include internal drive aisles. See Figure 4a, Proposed Site Layout.

The City and LACoFD have adopted design standards that preclude the construction of any unsafe roadway, circulation, or access design features. Design and construction of the proposed driveways would be required to adhere to the City’s Public Works Department’s established standard plans, the standards outlined in the Industry Municipal Code, and LACoFD’s design standards, which are imposed on development projects during the City’s development review and building plan check process.

At intersections and project driveways in Industry, a substantially clear line of sight must be maintained between the driver of a vehicle waiting at the crossroad and the driver of an approaching vehicle. Sight distance is the continuous length of roadway visible to the driver.

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Compliance with the City’s and LACoFD’s established design standards would ensure that hazards due to design features would not occur.

Based on a review of aerial photography and Google maps, there are no restrictions blocking views from the locations along Gale Avenue and Ward Way. Sufficient sight distance is provided because each of the existing driveways was previously approved by the City. Additionally, the Project Site does not include incompatible uses such as farm equipment. The Project Site is located in an industrialized area of the City and would be developed with an industrial-type use that is compatible with the surrounding uses. Therefore, impacts would be less than significant, and no mitigation measures are necessary.
d) Result in inadequate emergency access?
As outlined above, the proposed Project would introduce new on-site vehicular access circulation improvements that would connect to existing driveways located off Gale Avenue and Ward Way.

To address emergency and fire access needs, the improvements would be required to be designed and constructed in accordance with all applicable City and LACoFD design standards for emergency access (e.g., minimum lane width and turning radius). For example, the drive aisles would be designed to meet the minimum width requirements of LACoFD to allow the passing of emergency vehicles.

The Project Site is located in an established, developed area with sufficient access for emergency service providers. The internal drive aisle would serve as a fire access lane and would become part of the on-site fire access path of travel. These improvements would not hinder emergency access to the Project Site or the surrounding area.

Additionally, the proposed Project would be required to be designed and constructed in accordance with all applicable City and LACoFD design standards for emergency access (e.g., minimum lane width and turning radius). During the development review and building plan check process, the City would coordinate with LACoFD to ensure that the necessary fire prevention and emergency response features are incorporated into the Project Site and that adequate circulation and access (e.g., adequate turning radii for fire trucks) are provided within the access and circulation components of the Project Site.

The proposed Project would also be required to incorporate all applicable design and safety requirements as set forth in the most current adopted fire codes, building codes, and nationally recognized fire and life safety standards of the City and LACoFD. Compliance with these standards is ensured through the City’s and LACoFD’s development review and building plan check process.

Therefore, impacts on emergency access would be less than significant and no mitigation measures are necessary.

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XVIII. Tribal Cultural Resources
Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Would the project cause a substantial
adverse change in the significance of a
tribal cultural resource, defined in Public
Resources Code § 21074 as either a site,
feature, place, cultural landscape that is
geographically defined in terms of the size
and scope of the landscape, sacred place,
or object with cultural value to a California
Native American tribe, and that is:
☐ ☐ ☐ ☐
i) Listed or eligible for listing in the
California Register of Historical
Resources, or in a local register of
historical resources as defined in
Public Resources Code section
5020.1(k), or
☐ ☐ ☐ ☒
ii) A resource determined by the lead
agency, in its discretion and
supported by substantial evidence, to
be significant pursuant to criteria set
forth in subdivision (c) of Public
Resources Code § 5024.1. In applying
the criteria set forth in subdivision (c)
of Public Resource Code § 5024.1, the
lead agency shall consider the
significance of the resource to a
California Native American tribe.
☐ ☒ ☐ ☐

DISCUSSION
a) Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code § 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of

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the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
i) Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code section 5020.1(k), or
The Project Site does not contain a known tribal cultural resource that is listed in the California Register of Historical Resource or in a local register of historical resources (NPS 2024; OHP 2025). Public Resources Code Section 5020.1(k) defines local register of historical resources as a list of properties officially designated or recognized as historically significant by a local government pursuant to a local ordinance or resolution. There is also no local ordinance or resolution that identifies the Project Site containing a tribal cultural resource that also constitutes a historical resource. No impact related to tribal cultural resources that are listed or eligible for listing on the CRHR or local register would occur, and no mitigation measures are necessary.
ii) A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code § 5024.1. In applying the criteria set forth in subdivision (c) of Public Resource Code § 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe.

The provisions of CEQA, PRC Sections 21080.3.1 et seq. (also known as AB 52), require meaningful consultation with California Native American tribes on potential impacts to tribal cultural resources. As defined in PRC Section 21074, tribal cultural resources are sites, features, places, cultural landscapes, sacred places, and objects with cultural value to a California Native American tribe.

As part of the AB 52 process, a Native American tribe must submit a written request to the relevant lead agency if it wishes to be notified of projects that require CEQA public noticing and are within its traditionally and culturally affiliated geographical area. The lead agency must provide written, formal notification to the tribes that have requested it within 16 days of determining that a project application is complete or deciding to undertake a project. The tribe must respond to the lead agency within 30 days of receipt of the notification if it wishes to engage in consultation on the proposed Project, and the lead agency must begin the consultation process within 30 days of receiving the request for consultation. Consultation concludes when either 1): the parties agree to mitigation measures to avoid a significant effect, if one exists, on a tribal cultural resource, or 2) a party, acting in good faith and after reasonable effort, concludes that mutual agreement cannot be reached. AB 52 also addresses confidentiality during tribal consultation per PRC Section 21082.3(c).

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In accordance with the provisions of AB 52, on September 18, 2025, the City sent letters to the Gabrieleño Band of Mission Indians–Kizh Nation (Kizh Nation), Gabrielino Tongva Tribe, and Soboba Band of Luiseño Indians. The 30-day noticing requirement under AB 52 ended on October 20, 2025 (approximately 30 days from the date the tribes received the notification letter). Of the three notified tribes, Kizh Nation, responded via email and provided a list of mitigation measures that they requested be included in this Initial Study.

While not anticipated, there is a potential to encounter buried prehistoric deposits (which could qualify as tribal cultural resources) on the Project Site during site excavation and grading activities. The presence of unknown subsurface tribal cultural resources remains possible and could be affected by project-related, ground-disturbing activities associated with excavation and grading. It is possible that subsurface disturbance may uncover undiscovered tribal cultural resources at the Project Site. Therefore, impacts to tribal cultural resources are potentially significant.

To enable Kizh Nation to protect and preserve their tribal cultural resources and to reduce potential impacts to such resources (if encountered during ground-disturbing activities), mitigation is required. With implementation of Mitigation Measures TCR-1, TCR-2, and TCR3, which are based on input the City received from Kizh Nation during the consultation efforts, impacts to tribal cultural resources would be reduced to a level of less than significant.

Mitigation Measure TCR-1: Retain a Native American Monitor Prior to Commencement of Ground-Disturbing Activities. The Project applicant shall retain a Native American Monitor prior to the commencement of any “ground-disturbing activity” for the subject project at all project locations (i.e., both on-site and any off-site locations that are included in the project description/definition and/or required in connection with the project, such as public improvement work). “Ground-disturbing activity” shall include, but is not limited to, demolition, pavement removal, potholing, auguring, grubbing, tree removal, boring, grading, excavation, drilling, and trenching. A copy of the executed monitoring agreement shall be submitted to the City prior to the commencement of any ground-disturbing activity. The monitor will complete daily monitoring logs that will provide descriptions of the relevant ground-disturbing activities, the type of construction activities performed, locations of ground-disturbing activities, soil types, cultural-related materials, and any other facts, conditions, materials, or discoveries of significance to the Tribe. Monitor logs will identify and describe any discovered tribal cultural resources (TCR), as defined by Section 21074(a) of the Public Resources Code. Copies of monitor logs will be provided to the City upon written request to the Tribe. Upon discovery of any TCRs, all construction activities in the immediate vicinity of the discovery shall cease (i.e., not less than the surrounding 50 feet) and shall not resume until the discovered TCR has been fully assessed by the monitor and/or archeologist. The tribal monitor will recover and retain discovered

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TCRs in the form and/or manner they deem appropriate, and for any purpose the Tribe deems appropriate, including for educational, cultural, and/or historic purposes.

Mitigation Measure TCR-2: Unanticipated Discovery of Human Remains and Associated Funerary Objects. Native American human remains are defined in PRC 5097.98(d)(1) as an inhumation or cremation, and in any state of decomposition or skeletal completeness.

Funerary objects, called associated grave goods in Public Resources Code Section 5097.98, are also to be treated according to this statute. If Native American human remains and/or grave goods are discovered or recognized on the Project Site, then all construction activities shall immediately cease. Health and Safety Code Section 7050.5 dictates that any discoveries of human remains shall be immediately reported to the County Coroner, and all ground-disturbing activities shall immediately halt and shall remain halted until the coroner has determined the nature of the remains. If the coroner recognizes the human remains to be those of a Native American or has reason to believe they are Native American, he or she shall contact, by telephone within 24 hours, the Native American Heritage Commission, and Public Resources Code Section 5097.98 shall be followed.

Human remains and grave/burial goods shall be treated alike per California Public Resources Code section 5097.98(d)(1) and (2). Construction activities may resume in other parts of the Project Site at a minimum of 200 feet away from discovered human remains and/or burial goods, if the tribal monitor determines that resuming construction activities at that distance is acceptable and provides the project manager express consent of that determination (CEQA Guidelines Section 15064.5(f)). Preservation in place (i.e., avoidance) is the preferred manner of treatment for discovered human remains and/or burial goods. Any discovery of Native American human remains/burial goods shall be kept confidential to prevent further disturbance.

Mitigation Measure TCR-3: Procedures for Burials and Funerary Remains. To the Tribe, the term “human remains” encompasses more than human bones. In ancient as well as historic times, Tribal Traditions included, but were not limited to, the preparation of the soil for burial, the burial of funerary objects with the deceased, and the ceremonial burning of human remains. If the discovery of human remains includes four or more burials, the discovery location shall be treated as a cemetery and a separate treatment plan shall be created. The prepared soil and cremation soils are to be treated in the same manner as bone fragments that remain intact. Associated funerary objects are objects that, as part of the death rite or ceremony of a culture, are reasonably believed to have been placed with individual human remains either at the time of death or later; other items made exclusively for burial purposes or to contain human remains can also be considered associated funerary objects. Cremations will either be removed in bulk or by means as necessary to ensure complete recovery of all sacred materials. In the case where discovered human remains cannot be fully documented and recovered on the same day, the remains will be covered with muslin cloth and a steel plate that can be moved by

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heavy equipment placed over the excavation opening to protect the remains. If this type of steel plate is not available, a 24-hour guard should be posted outside of working hours.

The Tribe will make every effort to recommend diverting the project and keeping the remains in situ and protected. If the Project cannot be diverted, it may be determined that burials will be removed. In the event preservation in place is not possible despite good faith efforts by the Project applicant, before ground-disturbing activities may resume on the Project Site, the landowner shall arrange a designated site location within the footprint of the project for the respectful reburial of the human remains and/or ceremonial objects. Each occurrence of human remains and associated funerary objects will be stored using opaque cloth bags. All human remains, funerary objects, sacred objects, and objects of cultural patrimony will be removed to a secure container on-site if possible. These items should be retained and reburied within six months of recovery. The site of reburial/repatriation shall be on the Project Site but at a location agreed upon between the Tribe and the landowner at a site to be protected in perpetuity. There shall be no publicity regarding any cultural materials recovered. The Tribe will work closely with the Project’s qualified archaeologist to ensure that the excavation is treated carefully, ethically, and respectfully. If data recovery is approved by the Tribe, documentation shall be prepared and shall include (at a minimum) detailed descriptive notes and sketches. All data, recovery data, and recovery-related forms of documentation shall be approved in advance by the Tribe. If any data recovery is performed, once complete, a final report shall be submitted to the Tribe and the Native American Heritage Commission. The Tribe does not authorize any scientific study or the utilization of any invasive and/or destructive diagnostics on human remains.

XIX. Utilities and Service Systems
Would the project:

Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Require or result in the relocation or
construction of new or expanded water,
wastewater treatment or storm water
drainage, electric power, natural gas, or
telecommunications facilities, the
construction or relocation of which could
cause significant environmental effects?
☐ ☐ ☒ ☐

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b) Have sufficient water supplies available to
serve the project and reasonably
foreseeable future development during
normal, dry and multiple dry years?
☐ ☐ ☐ ☒
c) Result in a determination by the waste
water treatment provider, which serves or
may serve the project that it has adequate
capacity to serve the project’s projected
demand in addition to the provider’s
existing commitments?
☐ ☐ ☐ ☒
d) Generate solid waste in excess of state or
local standards, or in excess of the
capacity of local infrastructure, or
otherwise impair the attainment of solid
waste reduction goals?
☐ ☐ ☒ ☐
e) Comply with federal, state, and local
management and reduction statutes and
regulations related to solid waste?
☐ ☐ ☒ ☐

DISCUSSION
a) Require or result in the relocation or construction of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects?
Water and Wastewater
During construction activities, there would be a temporary, intermittent demand for water for such activities as soil watering for site preparation, fugitive dust control, concrete preparation, cleanup, and other short-term activities. Normal operation of the proposed BESS facility on the Project Site would result in water use for landscape irrigation and operation of the office building.

Outside of the office and storage building and landscaping, water use would be minimal and intermittent, associated with activities such as maintenance, and emergency fire suppression.

Suburban Water Systems (SWS) currently provides water to the Project Site and anticipates that water demands can be met during normal, single dry, and multiple dry years over the next 20 years (City of Industry 2025; SWS 2021). Within the SWS service area, the Project Site is in the San Jose Hills area of the service for SWS. In 2020, SWS had a water demand of 24,939 acre-feet (AF) and a water supply of 25,649 AF for the San Jose Hills area (SWS 2021). Due to the existing Project Site having more intensive water uses than what is proposed, SWS would be able to provide water to the Project Site.

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Wastewater generation associated with the operation of the proposed Project includes connections to the office and storage building which would contain six offices and a conference room for employees and for occasional use by contractors and vendors. The office and storage building would include a sink and a restroom. The restroom would be connected to sanitary sewer services. However, when compared to existing conditions on the Project Site which include 161,781 square feet of building space, the 1,200 square foot office building is minimal in nature and the existing sewer facilities would have adequate capacity to accommodate the proposed Project.

Therefore, the proposed Project would not require the relocation or expansion of any water or wastewater treatment facilities. Impacts would be less than significant, and no mitigation measures are necessary.

Stormwater Drainage
As detailed in the proposed Project’s Hydrology Study and Stormwater Quality Management Plan (Appendix P), the proposed Project would result in a decrease of 4.54 acres of impervious surfaces at the Project Site when compared to existing conditions. Therefore, the proposed Project would not require the expansion or relocation of stormwater drainage facilities and impacts would be less than significant. No mitigation measures are necessary.

Electricity and Natural Gas
The proposed Project represents an improvement to the existing electrical power system as its function would be to receive, store, and deliver electricity for the SCE regional electric grid. The proposed Project is itself a project that expands the capacity of existing electric facilities and the impacts of its construction and operation are analyzed throughout this Initial Study. Therefore, the proposed Project would have less than significant impacts related to electric power and no mitigation measures are necessary.

The proposed Project would not require new natural gas services connections and would not result in the need for new natural gas supplies or infrastructure. Therefore, the proposed Project would have no impact with regard to natural gas, and no mitigation measures are necessary.

Telecommunications
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. These telecommunications facilities are considered part of the proposed Project and the environmental impacts of constructing and operating these facilities

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are analyzed throughout this Initial Study. The proposed Project would not require new or expanded telecommunications facilities beyond those identified in Section 2.3.6, Project Description, of this Initial Study. Therefore, impacts related to telecommunications facilities would be less than significant and no mitigation measures are necessary. b) Have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years? As discussed in Section XIX.a, the proposed Project would use minimal water to support the construction of the BESS facility and would decrease the demand for water during the operational phase when compared to existing conditions. SWS currently provides water to the Project Site and anticipates that water demands can be met during normal, single dry, and multiple dry years over the next 20 years (SWS 2021). Therefore, no impact would occur, and no mitigation measures are necessary.
c) Result in a determination by the waste water treatment provider, which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments?
As noted above, the proposed Project would generate less wastewater compared to existing conditions. Due to the wastewater provider already treating wastewater from the Project Site at a larger volume than what is proposed, the proposed Project would not require construction of new or expanded wastewater treatment facilities. Therefore, no impact would occur, and no mitigation measures are necessary.
d) Generate solid waste in excess of state or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals? Valley Vista Services provides solid waste services in Industry. In 2019, approximately 89 percent of the municipal solid waste landfilled from the City was disposed of at the Antelope Valley Public Landfill, Azusa Land Reclamation Co. Landfill, and Badlands Sanitary Landfill (CalRecycle 2019).

Very small amounts of solid waste would be generated from the proposed Project when compared to existing conditions at the Project Site.

Construction of the proposed Project would result in the demolition of the existing on-site buildings, covered storage area, and hardscape. These activities would result in the generation of construction and demolition debris such as metal scrap, lumber, concrete, and asphalt, which would be collected and diverted to a construction and demolition debris facility for materials to be recycled and/or discarded. However, in compliance with CALGreen, development of the proposed Project’s improvements would be required to divert a minimum of 65 percent of construction and demolition waste from landfills. Residual waste, such as trash packing materials, and plastics could require disposal at a landfill.

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The proposed BESS facility would be designed to be in operation for 35 years. After completion of the BESS facility operations, if not repowered with then-current technology, most of the electrical equipment (breakers, transformers, inverters) would be removed and recycled or disposed of. Project batteries shipped off-site to be recycled or disposed of at an appropriately licensed disposal facility. A collection and recycling program would be implemented to promote recycling of the proposed Project components and minimize disposal in landfills.

All collection, transportation, and disposal of any solid waste generated by the proposed Project during construction and operation would comply with all applicable federal, state, and local statutes and regulations. In particular, AB 939 requires that at least 50 percent of solid waste generated by a jurisdiction be diverted from landfill disposal through source reduction, recycling, or composting. Cities, counties, and regional agencies are required to develop a waste management plan that would achieve a 50 percent diversion from landfills (Public Resources Code Section 40000 et seq.). Furthermore, as required by existing regulations, any hazardous materials collected on the Project Site during demolition, construction, or operational activities would be transported and disposed of by a permitted and licensed hazardous materials service provider at a facility permitted to accept such hazardous materials.

As such, the proposed Project’s improvements are not anticipated to generate solid waste in excess of state or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals. Therefore, impacts would be less than significant, and no mitigation measures are necessary.
e) Comply with federal, state, and local management and reduction statutes and regulations related to solid waste?
The following federal and state laws and regulations govern solid waste disposal:
 AB 939 (Chapter 1095, Statutes of 1989), the California Integrated Waste Management Act of 1989 required each city, county, and regional agency to develop a source reduction and recycling element of an integrated waste management plan that contained specified components, including a source reduction component, a recycling component, and a composting component. With certain exceptions, the source reduction and recycling components were required to divert 50 percent of all solid waste from landfill disposal or transformation by January 1, 2000, through source reduction, recycling, and composting activities.
 AB 32 (Chapter 488, Statutes of 2006), the California Global Warming Solutions Act established mandatory recycling as one of the measures to reduce GHG emissions adopted in the Scoping Plan by CARB.

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 AB 341 (Chapter 476, Statutes of 2011), requires that all “commercial” generators of solid waste (businesses, institutions, and multifamily dwellings) establish recycling and/or composting programs. AB 341 goes beyond AB 939 and establishes the new recycling goal of 75 percent by 2020.

Project-related construction and operation phases would be implemented in accordance with all applicable federal, state, and local laws and regulations that govern solid waste disposal.

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

XX. Wildfire
If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project:

Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Substantially impair an adopted
emergency response plan or emergency
evacuation plan?
☐ ☐ ☐ ☒
b) Due to slope, prevailing winds, and other
factors, exacerbate wildfire risks, and
thereby expose project occupants to
pollutant concentrations from a wildfire or
the uncontrolled spread of a wildfire?
☐ ☐ ☐ ☒
c) Require the installation or maintenance of
associated infrastructure (such as roads,
fuel breaks, emergency water sources,
power lines or other utilities) that may
exacerbate fire risk or that may result in
temporary or ongoing impacts to the
environment?
☐ ☐ ☐ ☒
d) Expose people or structures to significant
risks, including downslope or downstream
flooding or landslides, as a result of runoff,
post-fire slope instability, or drainage
changes?
☐ ☐ ☐ ☒
Wildland fire protection in California is the responsibility of either the state, local government, or the federal government. State Responsibility Areas (SRA) are the areas where the State of

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California has the primary financial responsibility for the prevention and suppression of wildland fires. The SRA forms one large area over 31 million acres, for which the California Department of Forestry and Fire Protection (CAL FIRE) provides a basic level of wildland fire prevention and protection services.

Local Responsibility Areas (LRA) include incorporated cities, cultivated agriculture lands, and portions of the desert. LRA fire protection is typically provided by city fire departments, fire protection districts, counties, and by CAL FIRE under contract to local government. CAL FIRE uses an extension of the SRA Fire Hazard Severity Zone model as the basis for evaluating fire hazard in LRA. The LRA hazard rating reflects flame and ember intrusion from adjacent wildlands and from flammable vegetation in the urban area. The Los Angeles County Fire Department currently provides fire protection and emergency medical services to Industry.

Fire Hazard Severity Zones (FHSZ) are identified by Moderate, High and Very High in an SRA, and Very High in an LRA.

If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project:

DISCUSSION
a) Substantially impair an adopted emergency response plan or emergency evacuation plan? The proposed Project is located in a developed, urbanized area of the City of Industry and is not within a state responsibility area (SRA) or a very high fire hazard severity zone, as mapped by CAL FIRE (CAL FIRE 2025). Potential impacts related to fire hazards are addressed in Section 3.IX, Hazards and Hazardous Materials. The nearest FHSZ in an SRA and LRA is a Very High FHSZ two miles southwest of the Project Site, where open space interfaces with the urban edge west of Vallecito Drive. Land between the edge of the FHSZ and the Project Site is dense urban development and includes SR-60.

The emergency response plan in effect in Los Angeles County is the Los Angeles County OAEOP maintained by the County Office of Emergency Management (OAEOP 2023) Project construction and operation would not block access to the Project Site or to surrounding properties, and would not impede the evacuation program. Notification of emergency personnel of impending blockages, detour signs, and a construction plan for traffic would ensure that there would be no impact in the case of emergency evacuation.

Therefore, the proposed Project would not impair implementation of or physically interfere with an adopted emergency response or evacuation plan. No impact would occur, and no mitigation measures are necessary.

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b) Due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire?
Based on the review of the topographic map, the Project Site is flat and developed and does not contain vegetated hillsides or other wildfire-prone terrain. The proposed Project is not located within or near a very high fire hazard severity zone, and the surrounding area consists of industrial, commercial, and residential uses. Although prevailing wind patterns flow in the direction of the Project Site, due to intervening development and the level topography north of the very high FHSZ, Project development is not anticipated to exacerbate wildfire risk. The proposed Project would not include residential uses or structures regularly occupied by large groups of people. Therefore, the proposed Project would not exacerbate wildfire risk or expose occupants to pollutant concentrations from a wildfire. No impact would occur, and no mitigation measures are necessary.
c) Require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment? The proposed Project involves redevelopment of an existing industrial site with a battery energy storage facility and supporting infrastructure. No new off-site utilities, overhead electrical lines, roads, or fuel breaks are proposed. Electrical connections would be made to the adjacent Southern California Edison substation. The proposed Project does not include infrastructure that would exacerbate fire risk or require activities that would impact sensitive environmental resources. No impact would occur, and no mitigation measures are necessary. d) Expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes? As noted above, the Project Site and off-site improvement areas are not located in a state responsibility area or land classified as a very high fire hazard severity zone, as identified in the latest Los Angeles County Fire Hazard Severity Zone Map (CAL FIRE 2025). The proposed Project would not expose people or structures to risks related to post-fire slope instability or landslides, as the Project Site is generally flat and is not located in or near hillside areas. The proposed Project would also not result in downstream flooding or adverse drainage changes. Stormwater under existing conditions flows to a public storm drain in Gale Avenue that connects to a system in South Stimson Avenue and ultimately discharges to the San Jose Creek channel. The proposed Project would retain this existing flow path and include surface grading, drop inlets, and underground piping to maintain drainage patterns. Peak runoff volumes would be reduced compared to existing conditions because the amount of impermeable surface area would decrease (from 92 percent to 88 percent). However, biofiltration systems would be incorporated to remove pollutants prior to discharge. Therefore, the proposed Project would not result in significant risks

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associated with runoff, drainage changes, or post-fire instability. No impact would occur, and no mitigation measures are necessary.

XXI. Mandatory Findings of Significance
Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Does the project have the potential to
substantially degrade the quality of the
environment, substantially reduce the
habitat of a fish or wildlife species, cause a
fish or wildlife population to drop below
self-sustaining levels, threaten to
eliminate a plant or animal community,
substantially reduce the number or restrict
the range of a rare or endangered plant or
animal or eliminate important examples of
the major periods of California history or
prehistory?
☐ ☒ ☐ ☐
b) Does the project have impacts that are
individually limited, but cumulatively
considerable? (“Cumulatively
considerable” means that the incremental
effects of a project are considerable when
viewed in connection with the effects of
past projects, the effects of other current
projects, and the effects of probable
future projects.)
☐ ☐ ☒ ☐
c) Does the project have environmental
effects which will cause substantial
adverse effects on human beings, either
directly or indirectly?
☐ ☒ ☐ ☐

DISCUSSION
a) Does the project have the potential to substantially degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, substantially reduce the number or restrict the range of a rare or

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endangered plant or animal or eliminate important examples of the major periods of California history or prehistory?
As shown in Figure 3, Aerial Photograph, the Project Site is heavily disturbed and is in a highly urbanized area of the City; it is mainly surrounded by industrial and warehouse uses.

As substantiated in Section IV, Biological Resources, implementation of the proposed Project would not result in the reduction of the habitat of fish or wildlife species; cause a fish or wildlife population to drop below self-sustaining levels; threaten to eliminate a plant or animal community; or reduce the number or restrict the range of a rare or endangered plant or animal.

As substantiated in Section V, Cultural Resources, no historic resources were identified on the Project Site. However, Project related ground-disturbing activities (e.g., grading and excavation) have the potential to reveal unknown buried deposits. With implementation of Mitigation Measures CUL-1 and CUL-2, impacts to archaeological resources would be reduced to a less than significant level.

Furthermore, Project related ground-disturbing activities (e.g., grading and excavation) have the potential to reveal unknown buried paleontological resources. However, as substantiated in Section VII, Geology and Soils, impacts to paleontological resources were deemed to be less than significant with implementation of Mitigation Measure GEO-1.

Finally, as stated in Section XVIII, Tribal Cultural Resources, the presence of unknown subsurface tribal cultural resources on the site remains possible and could be affected by Project-related, ground-disturbing activities associated with excavation and grading at the Project Site. Therefore, the Kizh Nation provided the City with mitigation measures (TCR-1, TCR-2, and TCR-3) to reduce the potential impact to tribal cultural resources to a less than significant level. b) Does the project have impacts that are individually limited, but cumulatively considerable? (“Cumulatively considerable” means that the incremental effects of a project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects.) The issues relevant to the proposed Project development are confined to the immediate Project Site and surrounding area. Additionally, the Project Site is in a highly urbanized, disturbed area of the City where supporting utility infrastructure (e.g., electricity, natural gas, and drainage) and services (e.g., solid waste collection) currently exist. Project implementation would not require the construction of new or expansion of utility infrastructure for water, sewer, or natural gas.

Improvements to the SCE Walnut Substation would be required but they would only be needed to accommodate and support the proposed BESS facility’s interconnection.

Furthermore, impacts related to other topical areas such as air quality, GHG, hydrology and water quality, and traffic would not be cumulatively considerable with development of the proposed

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Project in conjunction with other cumulative projects (including the proposed development of another similar, but smaller BESS facility approximately 0.2 mile west of the Project Site), as analyzed in this Initial Study.

In consideration of the preceding factors, the proposed Project’s contribution to cumulative impacts would be rendered less than significant; therefore, project impacts would not be cumulatively considerable.
c) Does the project have environmental effects which will cause substantial adverse effects on human beings, either directly or indirectly?
As substantiated in the respective topical sections of this Initial Study, implementation of the proposed Project would not result in significant impacts in the areas of air quality, GHG, geology and soils, hazards and hazardous materials, hydrology and water quality, or wildfire, which may cause adverse effects on human beings. Additionally, as outlined in Section XIII, Noise, construction-related noise impacts would be reduced to a level of less than significant with implementation of mitigation. Therefore, impacts related to these environmental effects were deemed to be less than significant with mitigation incorporated.

DECEMBER 2025 185

4. REFERENCES
Bay Area Air District. 2023, May. California Environmental Quality Act Air Quality Guidelines. https://www.baaqmd.gov/plans-and-climate/california-environmental-quality-act -ceqa/updated-ceqa-guidelines.

California Air Resources Board (CARB). 2022. 2022 Scoping Plan for Achieving Carbon Neutrality. https://ww2.arb.ca.gov/sites/default/files/2022-12/2022-sp.pdf.

California Department of Conservation (DOC). 2022. California Important Farmland Finder. https://maps.conservation.ca.gov/DLRP/CIFF/.
––––––. 2016. Division of Mine Reclamation. https://maps.conservation.ca.gov/mol/.

California Department of Forestry and Fire Protection (CAL FIRE). 2023. Fire Hazard Severity Zones. https://osfm.fire.ca.gov/what-we-do/community-wildfire-preparedness-andmitigation/fire-hazard-severity-zones.

California Department of Resources Recycling and Recovery (CalRecycle). 2019a. Jurisdiction Disposal and Alternative Daily Cover (ADC) Tons by Facility. https://www2.calrecycle .ca.gov/LGCentral/DisposalReporting/Destination/DisposalByFacility.

California Department of Transportation (Caltrans). 2020, April. Construction Vibration Guidance Manual. https://dot.ca.gov/-/media/dot-media/programs/environmental -analysis/documents/env/tcvgm-apr2020-a11y.pdf.

California Geologic Energy Management Division (CalGEM). 2022. Well Finder. https://maps.conservation.ca.gov/doggr/wellfinder/.

California Geological Survey (CGS). 2010. Mineral Land Classifications. https://maps.conservation.ca.gov/cgs/minerals/?page=Mineral-Land-Classification# data_s=id%3AdataSource_335-18a47b5b8e5-layer-10-192c08351d6-layer-28%3A35.

California Office of Historic Preservation (OHP). 2025. California Historical Resources. https://ohp.parks.ca.gov/listedresources/.

California State Water Resources Control Board (CSWRCB). September 2022. National Pollutant Discharge Elimination System (NPDES) General Permit for Stormwater Discharges Associated With Construction And Land Disturbance Activities. ORDER WQ 2022-0057- DWQ NPDES NO. CAS000002.

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California Stormwater Quality Association (CASQA). 2019, December. Stormwater Pollution Prevention Plan Template for Traditional Construction Sites.

City of Industry. 2014. 2014 General Plan.
https://www.cityofindustry.org/DocumentCenter/View/180/General-Plan-PDF. ––––––. February 2025. Water Purveyor Service Area. https://gis-industry.hub.arcgis.com/ maps/5fccb0ac81a24f8f9e671f9418e31064/explore?location=33.967458%2C -117.963120%2C11.73.

County of Los Angeles Department of Public Works (LADPW). February 2014. Low Impact Development Standards Manual. https://pw.lacounty.gov/ldd/lddservices/docs/Los %20Angeles%20County%20Low%20Impact%20Development%20(LID)%20Manual.pdf. ––––––. 2025 (accessed). Spreading Grounds Facilities. https://pw.lacounty.gov/core-service -areas/uploads/2024/10/SpreadingGroundMap.pdf.

Department of Water Resources (DWR). 2025 (accessed). SGMA Basin Prioritization Dashboard. https://gis.water.ca.gov/app/bp-dashboard/final/#.

Division of Mine Reclamation (DMR). 2022. Mines Online. California Department of Conservation. http://maps.conservation.ca.gov/mol/.

Federal Emergency Management Agency (FEMA). 2008. National Flood Hazard Layer FIRMette 06037C1700F. https://msc.fema.gov/arcgis/rest/directories/arcgisjobs/nfhl_print/ mscprintb_gpserver/j7eea1edc02a6490a929d3a4ef34c0143/scratch/FIRMETTE_99cfd55 a-0087-4bb3-a511-bbd521ff7423.pdfhttps://msc.fema.gov/portal/home.

Federal Highway Administration (FHWA). 2006. Roadway Construction Noise Model (RCNM) Version 1.0. Accessed September 2025.
www.fhwa.dot.gov/environment/noise/construction_noise/rcnm2/.

La Puente Valley County Water District (LPVCWD). May 2017. 2017 Water Master Plan Update. https://lapuentewater.com/wp-content/uploads/2022/02/2017-05-15-FINAL-2017 -LPVCWD-WMP.pdf.

Los Angeles, County of. 2014, June. Los Angeles County General Plan Update Draft Environmental Impact Report (SCH No. 2011081042). https://planning.lacounty.gov/ wp-content/uploads/2022/11/gp_2035_deir.pdf.
––––––. 2007. San Gabriel Watershed.
http://www.ladpw.org/wmd/watershed/SG/docs/SanGabrielRiver_wtrshed.pdf.

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National Fire Protection Association (NFPA). 2022. Energy Storage Systems (ESS) and Solar Safety. https://www.nfpa.org/News-and-Research/Resources/Emergency -Responders/High-risk-hazards/Energy-Storage-Systems.

National Park Service (NPS). 2024. National Register of Historic Places. https://www.nps.gov/subjects/nationalregister/database-research.htm.

Office of Environmental Health Hazard Assessment (OEHHA). 2015, February. Air Toxics Hot Spots Program Risk Assessment Guidelines. Guidance Manual for Preparation of Health Risk Assessments. http://oehha.ca.gov/air/hot_spots/2015/2015GuidanceManual.pdf.

South Coast Air Quality Management District (South Coast AQMD). 1993. California Environmental Quality Act Air Quality Handbook.
––––––. 2010, September 28. Minutes for the GHG CEQA Significance Threshold Stakeholder Working Group #15. http://www.aqmd.gov/docs/default-source/ceqa/handbook/ greenhouse-gases-(ghg)-ceqa-significance-thresholds/year-2008-2009/ghg-meeting -15/ghg-meeting-15-minutes.pdf.

Southern California Association of Governments (SCAG). 2024. Connect SoCal Plan: The 2024– 2050 Regional Transportation Plan / Sustainable Communities Strategy of the Southern California Association of Governments. https://scag.ca.gov/connect-socal.

State Water Resources Control Board (SWRCB). 2024. San Gabriel River Watershed. https://www.waterboards.ca.gov/rwqcb4/water_issues/programs/regional_program/W ater_Quality_and_Watersheds/san_gabriel_river_watershed/summary.shtml#:~:text=W atershed%20Description,habitats%20in%20its%20upper%20reaches.

Suburban Water Systems (SWS). 2021, June. 2020 Urban Water Management Plan. https://wuedata.water.ca.gov/getfile?filename=/public%2Fuwmp_attachments%2F3851 880729%2FSuburban%20Final%202020%20UWMP_2021-06-30.pdf.

TRC. 2024, June. Cultural Records Search Results Memorandum.

US Environmental Protection Agency (EPA). May 2021. San Gabriel Valley Superfund Sites Progress Update. https://semspub.epa.gov/work/09/100023871.pdf.

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5. LIST OF PREPARERS

LEAD AGENCY
Kathy Tai, Development Services Manager
Eduardo Manriquez, Contract Associate Planner
Mike Poland, Contract Senior Project Manager

PLACEWORKS
Addie Farrell, Principal (Principal-in-Charge)
Jorge Estrada, Senior Associate (Project Manager)
Lance Park, Senior Associate, Air Quality and GHG
Steve Bush, Senior Engineer, Health Risk Assessment and Air Toxics Chris Shields, Senior Associate, Noise and Vibration
Dina El Chammas, Senior Engineer, Hydrology and Water Quality Emily Park, Associate, Air Quality and GHG
Jared Bradford, Associate
Justine Garner, Associate
Madeline Miller, Associate
Cary Nakama, Graphic Artist

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APPENDIX
DECEMBER 2025

APPENDIX A

AIR QUALITY AND GREENHOUSE GAS

EMISSIONS REPORT

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Rev. 9/16/25
Attachment H
Marici Energy Storage Project
Air Quality and Greenhouse Gas Emissions Report
Revised 9/16/2025
Introduction
TRC Solutions, Inc. (TRC) utilized the California Emissions Estimator Model (CalEEMod) to evaluate potential criteria pollutant and greenhouse gas (GHG) emissions associated with the proposed Marici Energy Storage Project (the Project). The Project will consist of the construction and operation of an electric energy storage facility that will utilize lithium-ion batteries and ancillary equipment to store energy received from the electric grid and return it to the grid when needed. The Project will include an operations and maintenance support building containing six offices and a conference room. The Project is located in the City of Industry in the South Coast Air Quality Management District (SCAQMD).

The Project site is zoned industrial and is surrounded by commercial properties to the west, a railroad right-of-way and rail yard to the north, and the Southern California Edison Walnut electric substation to the east. The Project includes installation of a 220 kV overhead electric tie-line that will cross over the eastern site boundary directly into the Southern California Edison Walnut Substation where it will interconnect to the power grid. The nearest sensitive receptor locations to the Project are the residences located on the south side of Gale Avenue, where the closest residence is approximately 100 feet south of the Project.

Regulatory Setting
Los Angeles County continually exceeds federal and state ambient air quality standards for ozone, and particulate matter. The United States Environmental Protection Agency (USEPA) Region 9 is responsible for enforcement of federal air pollution control requirements. The SOCAB is currently classified by the US EPA as “extreme” nonattainment for the 2015 8-hour ozone National Ambient Air Quality Standard (NAAQS), and serious non-attainment for the 2012 PM2.5 NAAQS.

The SCAQMD is responsible for monitoring air quality and planning, implementing, and enforcing programs designed to attain and maintain state and federal ambient air quality standards in the district.

Programs developed include air quality rules and regulations that regulate stationary source emissions, including area and point sources and certain mobile source emissions. The SCAQMD is also responsible for establishing permitting requirements and issuing permits for stationary sources and ensuring that new, modified, or relocated stationary sources do not create net emissions increases. The SCAQMD enforces air quality rules and regulations through a variety of means, including inspections, educational and training programs, and fines (SCAQMD, 2005).

The SCAQMD Air Quality Significance Thresholds provide project emissions thresholds as guidance for determining whether the project will have a significant impact on communities surrounding the Project.

The thresholds were updated in March 2023 to reflect the EPA’s ozone redesignation. Neither SCAQMD nor any other jurisdictional agency have a Significance Threshold for construction project GHG emissions.

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Project Impacts
The Project operation will not have direct emissions and will have up to two employees on-site daily which will result in negligible impacts from worker trips as the Project is designed for remote operation.

The Project’s operational air quality impacts and greenhouse gas emissions will primarily consist of emissions from the relatively low number of worker trips and other vehicles used for occasional deliveries and other site visits. Overall, given the role of energy storage in State and regional planning for reduced pollutant and GHG emissions, the emission reductions that can be achieved with the Project’s additional storage capacity for renewable energy can be expected to exceed Project operating emissions. Therefore, only emissions associated with construction of the 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, Project operations can be expected to result in an overall reduction in pollutant and greenhouse gas 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.

Construction impacts were evaluated using the California Emissions Estimator Model (CalEEMod) Version 2022.1.1.30. 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 Project construction schedule provided in Attachment 1 was used for estimating emissions associated with the Project construction. This data included construction phase duration, equipment utilized, and daily equipment operating hours. A five-day construction workweek was assumed.

Emissions from 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. Limiting onsite vehicle speeds on unpaved roads to 25 miles per 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 SCAQMD 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.

Emissions that will occur from decommissioning at the end of the 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.

Regional Impacts
The CalEEMod predicted emissions do not exceed any of the current SCAQMD Air Quality Significance Thresholds for construction as indicated in Table 1 below. Therefore, the Project will not result in significant adverse air quality impacts to the regional air quality in the SCAQMD.

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Table 1 – Project Construction Regional Air Quality Impact Summary Pollutant SCAQMD Significance
Threshold (lbs/day)*
Maximum Project Construction
Emissions (lbs/day)**
Oxides of Nitrogen (NOx) 100 21.5
Volatile Organic Chemicals (VOCs) 75 3.13
Particulate Matter (PM10) 150 3.86
Particulate Matter (PM2.5) 55 1.33
Sulfur Dioxide (SO2) 150 0.05
Carbon Monoxide (CO) 550 26.9
*SCAQMD, 2023
**With a Project site 25 mile per hour speed limit and watering of disturbed areas, unpaved onsite hauling routes, and active demolition sites twice daily.

The CalEEMod predicted total GHG emissions from the Project construction is 484 metric tonnes of carbon dioxide equivalent emissions (MTCO2e) As previously stated, there is no official significance threshold for GHG emissions from construction projects. It should be noted that there is an interim SCAQMD GHG significance threshold of 3,000 MTCO2e/yr for construction projects and the GHG impact for the Project is below this threshold even if both construction and decommissioning (968 MTCO2e) are included. Long-term reduction in regional GHG emissions that would be expected from Project operations are expected to more than offset construction and decommissioning emissions, resulting in an overall net benefit in terms of GHG emission reduction.

Localized Impacts
As part of SCAQMD’s environmental justice program there has been increased attention focused on localized effects of air quality. SCAQMD 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, SCAQMD 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. It should be noted that the CO and NOx LSTs are generally not more stringent than the SCAQMD significance thresholds, while the PM2.5 and PM10 LSTs are much more stringent, therefore TRC focused the LST evaluation on PM2.5 and PM10 emissions (SCAQMD, 2008). The CO and NOx LSTs are also included in Table 4. The LST methodology utilizes several key steps which are summarized below.

1. Determine maximum daily on-site total PM2.5 and PM10 emissions (dust and exhaust) in pounds per day (lb/day):

TRC reviewed the CalEEMod mitigated onsite emissions report provide as Attachment 2 and determined that the maximum onsite PM2.5 and PM10 emissions occur when the demolition and site preparation phases overlap. A summary of these emissions is provided in Table 2 below.

Table 2 – Maximum Daily Onsite PM2.5 and PM10 Emissions Phase Total PM2.5
(lb/day)
Total PM10
(lb/day)
Demolition 0.55 2.84
Site Preparation 0.27 0.57
Total 0.82 3.41
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2. Determine the SRA of the Project:

The SCAQMD is partitioned into smaller geographic areas called SRAs to help increase the accuracy of applicable LSTs by taking into consideration localized air quality characteristics. The Project is located in SRA number eleven (11) titled South San Gabriel Valley.

3. Estimate the receptor distance:

The nearest receptor to the Project fence line are the residences located approximately 30 meters to the south of the Project on Gale Avenue.

4. Determine the maximum number of acres disturbed on the peak emissions day using the construction equipment in operation on the peak emissions day according to the following table from the CalEEMod Appendix:

Table 3 – Maximum Disturbed Acres Per Equipment
Equipment Type Acres/8hr-day
Crawler Tractors 0.5
Graders 0.5
Rubber Tired Dozers 0.5
Scrapers (Tractors/Loaders/Backhoes)* 1
*Tractors/loaders/backhoes are not included in the SCAQMD LST guidance equipment categories but are conservatively assumed to disturb the same area as a scraper
During the demolition and site preparation phase there are a maximum of two (2) crawler tractors and two (2) tractor/loader/backhoes in use per 8-hour day which results in an estimated maximum of 3 disturbed acres per day. There are no graders, rubber-tired dozers, or scrapers in use during the demolition or site preparation phases. The equipment is estimated to operate 6 hours per day; therefore, the daily maximum number of disturbed acres is 75% of the LST default resulting in a total of 2.25 acres.

Using the SRA, receptor distance, and LST lookup tables, the applicable LSTs were determined and are compared to the maximum onsite PM2.5 and PM10 emissions in Table 4 below. The LST lookup tables are provided for 1, 2, and 5 maximum daily disturbed acres; therefore, the 2-acre lookup table was conservatively used.

Table 4 – Project Construction Localized Air Quality Impact Summary Pollutant SCAQMD LST
(lbs/day)
Maximum Daily Onsite Emissions*
(lbs/day)
PM10 7 3.41
PM2.5 5 0.82
NOx 121 21.5
CO 1,031 26.9
*Total Project daily maximums for NOx and CO were conservatively used.

As can be seen from Table 4 the maximum daily onsite PM2.5 and PM10 emissions are below the applicable SCAQMD LSTs, therefore no adverse localized air quality impacts are expected.

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CEQA Thresholds Review
Air Quality
The Project will not conflict with or obstruct implementation of the applicable air quality plan:

The Project will be consistent with existing rules and measures contained in the SCAQMD 2022 Air Quality Management Plan (the 2022 Plan) via compliance with all applicable SCAQMD rules and regulations. The purpose of the 2022 Plan is to regulate long term emissions in accordance with population and infrastructure growth in SCAQMD. During construction activities requiring the use of heavy construction equipment, the Project would be required to adhere to existing SCAQMD rules and measures 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 reducing emissions of NOx (the key pollutant that creates ozone) by 67 percent more than is required by the current SCAQMD 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 (SCAQMD 2022). Considering these factors, the Project will not conflict or obstruct implementation of the 2022 Plan and will support key goals of the Plan to support zero emission power generation in SCAQMD.

The Project will not result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or State ambient air quality standard:

The predicted emissions from the Project do not exceed any of the current SCAQMD Air Quality Significance Thresholds for construction as indicated in Table 1. Therefore, the Project will not result in a cumulatively considerable net increase of any criteria pollutant for which the project region is nonattainment under an applicable federal or State ambient air quality standard. Furthermore, the Project is expected to contribute to pollutant emission reductions by providing storage capacity for intermittent renewable energy which will have a beneficial impact on reducing criteria pollutants. Accordingly, the noproject alternative would have a significant adverse impact on criteria pollutant emissions.

The Project will not expose sensitive receptors to substantial pollutant concentrations:

The LST analysis results presented in Table indicate that localized Project impacts will not exceed any applicable SCAQMD LST thresholds; therefore, the Project will not result in exposure of sensitive receptors to substantial pollutant concentrations.

The Project will not result in other emissions (such as those leading to odors) adversely affecting a substantial number of people:

No other emissions such as those leading to odors are expected from the Project.

Greenhouse Gas Emissions
The Project will not conflict with an applicable plan, policy or regulation adopted for the purpose of reducing emissions of greenhouse gases:

The GHG emissions from the Project construction and decommissioning are temporary and minimal.

With decommissioning included the Project’s annual amortized GHG impact of 28 MTCO2e/yr over the A-5

Marici Energy Storage Project
Air Quality Impact Modeling

Rev. 9/16/25
35-year lifetime of the Project which is less than 1% of the current interim SCAQMD GHG significance threshold of 3,000 MTCO2e/yr. Additionally, long-term reductions in regional GHG emissions that would be expected from Project operations supporting zero emission power generation technology are expected to more than offset construction and decommissioning emissions, resulting an overall net benefit in terms of GHG emission reduction. Therefore, the Project will not conflict with any applicable plan, policy, or regulation adopted for the purpose of reducing emissions of greenhouse gases.

Furthermore, because the Project is expected to contribute to GHG emission reductions by providing storage capacity for intermittent renewable energy, the no-project alternative could have a significant adverse impact on GHG emissions.

References
Los Angeles County Planning Department (LACPD). 2024, June. General Plan 2035. https://planning.lacounty.gov/wp-content/uploads/2023/03/gp_final-general-plan.pdf South Coast Air Quality Management District (SCAQMD). 2022, December. 2022 Air Quality Management Plan. https://www.aqmd.gov/docs/default-source/clean-air-plans/air-quality-managementplans/2022-air-quality-management-plan/final-2022-aqmp/final-2022-aqmp.pdf?sfvrsn=edcebd61_16 South Coast Air Quality Management District (SCAQMD). 2005, May. Guidance Document for Addressing Air Quality Issues in General Plans and Local Planning. http://www.aqmd.gov/docs/defaultsource/planning/air-quality-guidance/complete-guidance-document.pdf South Coast Air Quality Management District (SCAQMD). 2008, July. Localized Significance Threshold Methodology. https://www.aqmd.gov/docs/default-source/ceqa/handbook/localized-significancethresholds/final-lst-methodology-document.pdf South Coast Air Quality Management District (SCAQMD). 2023, March. South Coast AQMD Air Quality Significance Thresholds. https://www.aqmd.gov/docs/default-source/ceqa/handbook/south-coast-aqmdair-quality-significance-thresholds.pdf South Coast Air Quality Management District (SCAQMD). Fact Sheet for Applying CalEEMod to Localized Significance Thresholds. https://www.aqmd.gov/docs/defaultsource/ceqa/handbook/localized-significance-thresholds/caleemod-guidance.pdf A-6

Attachment 1: Construction Schedule and Vehicle Trip
Project Data
A-7

Construction Phase Schedule Equipment Horsepower Number Hours/Day Aerial Lift 25 2 6
Generator Set 60 1 6
Water Truck1 180 1 2
Skid Steer Loader 70 1 4
Tractor/Loader/Backhoe 100 1 6
Crawler Tractor 150 1 6
Excavator 150 1 6
Generator Set 60 1 6
Water Truck1 180 1 2
Skid Steer Loader 70 1 4
Tractor/Loader/Backhoe 100 1 6
Crawler Tractor 150 1 6
Excavator 150 1 6
Generator Set 60 1 6
Water Truck1 180 1 2
Skid Steer Loader 70 1 4
Tractor/Loader/Backhoe 100 1 6
Crawler Tractor 150 1 6
Water Truck1 180 1 3
Rubber Tire Loader 150 1 6
Skid Steer Loader 70 1 4
Tractor/Loader/Backhoe 100 1 6
Crawler Tractor 150 1 6
Grader 140 1 6
Water Truck1 180 1 4
Skid Steer Loader 70 1 4
Tractor/Loader/Backhoe 100 1 4
Drilling Month 6.5 Bore/Drill Rig 160 1 6
Forklift 60 1 4
Generator Set 60 1 6
Water Truck1 180 1 4
Skid Steer Loader 70 1 4
Tractor/Loader/Backhoe 100 1 6
Aerial Lift 25 2 6
Forklift 60 1 4
Generator Set 60 1 6
Crane Work Month 8 Crane 150 1 4
Crane 150 1 6
Forklift 60 1 4
Generator Set 60 1 6
Water Truck1 180 1 2
Skid Steer Loader 70 1 4
Tractor/Loader/Backhoe 100 1 2
Pile Drivers3 75 2 6
Plate Compactor 5 2 6
Rubber Tire Loader 150 1 4
Tractor/Loader/Backhoe 100 1 6
Tie Line Install Month 12 Aerial Lift 25 2 4
Paving Equipment 150 1 6
Roller 50 1 6
Skid Steer Loader 70 1 6
Tractor/Loader/Backhoe 100 1 6 1
Modeled as "other construction equipment" 2
Modeled as "other material handling equipment" 3
Modeled as "bore/drill rigs"
Marici Energy Storage Project - Estimated Construction Schedule Grading Month 5
Demolition
Phase 2
Month 2
Demolition
Phase 3
Month 3
Demolition
Phase 1
Month 1
Site Prep Month 4
Foundations Month 6-9
Collector Substation Prep Month 7-12
Pave/Surface/Landscape Month 12
Equipment Installation Month 8-11
Trenching Month 9-10
A-8

Construction Phase Trip Type # One-Way Trips/day1,2
Worker 40
Vendor 12
Hauling 28
Onsite Truck 40
Worker 20
Vendor 2
Hauling 4
Onsite Truck 6
Worker 20
Vendor 6
Hauling 14
Onsite Truck 20
Worker 40
Vendor 2
Hauling 6
Onsite Truck 8
Worker 36
Vendor 2
Hauling 4
Onsite Truck 6
Worker 40
Vendor 6
Hauling 14
Onsite Truck 20
Worker 32
Vendor 2
Hauling 4
Onsite Truck 6
Worker 20
Vendor 2
Hauling 0
Onsite Truck 2
Worker 40
Vendor 16
Hauling 32
Onsite Truck 48
Marici Energy Storage Project - Vehicle Trip Estimates
Demolition (Phase 1-3)
Site Prep
Grading
Drilling and Foundations
Collector Substation Prep
Crane Work and Equipment
Installation
Trenching
Tie Line Install
2 Onsite truck trips were assumed to equal total vendor and hauling trips with trucks traveling half the approximate site or 0.07 miles per one way trip Pave/Surface/Landscape
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Attachment 2: CalEEMod Report
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Marici Custom Report
Table of Contents1. Basic Project Information

1.1. Basic Project Information1.2. Land Use Types1.3. User-Selected Emission Reduction Measures by Emissions Sector

2. Emissions Summary

2.1. Construction Emissions Compared Against Thresholds2.2. Construction Emissions by Year, Unmitigated2.3. Construction Emissions by Year, Mitigated

3. Construction Emissions Details

3.1. Phase 1 Demolition (2026) - Unmitigated3.2. Phase 1 Demolition (2026) - Mitigated3.3. Phase 2 Demolition (2026) - Unmitigated3.4. Phase 2 Demolition (2026) - Mitigated3.5. Phase 3 Demolition (2026) - Unmitigated3.6. Phase 3 Demolition (2026) - Mitigated A-11

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3.7. Site Preparation (2026) - Unmitigated3.8. Site Preparation (2026) - Mitigated3.9. Drilling (2026) - Unmitigated3.10. Drilling (2026) - Mitigated3.11. Grading (2026) - Unmitigated3.12. Grading (2026) - Mitigated3.13. Foundation (2026) - Unmitigated3.14. Foundation (2026) - Mitigated3.15. Substation Crane Work (2026) - Unmitigated3.16. Substation Crane Work (2026) - Mitigated3.17. Equipment Install (2026) - Unmitigated3.18. Equipment Install (2026) - Mitigated3.19. Tie Line Install (2027) - Unmitigated3.20. Tie Line Install (2027) - Mitigated3.21. Collector/SubStation Prep (2026) - Unmitigated3.22. Collector/SubStation Prep (2026) - Mitigated3.23. Collector/SubStation Prep (2027) - Unmitigated3.24. Collector/SubStation Prep (2027) - Mitigated A-12

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3.25. Pave/Surface/Landscape (2027) - Unmitigated3.26. Pave/Surface/Landscape (2027) - Mitigated3.27. Trenching (2026) - Unmitigated3.28. Trenching (2026) - Mitigated

5. Activity Data

5.1. Construction Schedule5.2. Off-Road Equipment

5.2.1. Unmitigated5.2.2. Mitigated

5.3. Construction Vehicles

5.3.1. Unmitigated5.3.2. Mitigated

5.4. Vehicles

5.4.1. Construction Vehicle Control Strategies

5.5. Architectural Coatings5.6. Dust Mitigation

5.6.1. Construction Earthmoving Activities5.6.2. Construction Earthmoving Control Strategies A-13

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5.7. Construction Paving5.8. Construction Electricity Consumption and Emissions Factors

8. User Changes to Default Data
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1. Basic Project Information1.1. Basic Project Information Data Field ValueProject Name MariciConstruction Start Date 2/1/2025Lead Agency —Land Use Scale Project/siteAnalysis Level for Defaults CountyWindspeed (m/s) 1.80Precipitation (days) 22.4Location 34.008968516234575, -117.95141714827392County Los Angeles-South CoastCity IndustryAir District South Coast AQMDAir Basin South CoastTAZ 6812EDFZ 7Electric Utility City of IndustryGas Utility Southern California GasApp Version 2022.1.1.30

1.2. Land Use Types
Land Use Subtype Size Unit Lot Acreage Building Area (sq ft) Landscape Area (sq ft)
Special LandscapeArea (sq ft)
Population Description
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General Heavy 395 1000sqft 9.07 0.00 64,284 0.00 —Industry Battery energystorage facilityconsisting of 472battery containers& 120 inverters

1.3. User-Selected Emission Reduction Measures by Emissions Sector Sector # Measure TitleConstruction C-10-A Water Exposed SurfacesConstruction C-10-B Water Active Demolition SitesConstruction C-10-C Water Unpaved Construction RoadsConstruction C-11 Limit Vehicle Speeds on Unpaved Roads

2. Emissions Summary2.1. Construction Emissions Compared Against ThresholdsCriteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Un/Mit. TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2eDaily,Summer(Max) ——————————————————
Unmit. 2.88 2.34 20.5 24.1 0.04 0.80 7.52 7.78 0.74 1.03 1.47 — 5,965 5,965 0.29 0.38 7.95 6,090Mit. 2.88 2.34 20.5 24.1 0.04 0.80 3.56 3.82 0.74 0.59 1.21 — 5,965 5,965 0.29 0.38 7.95 6,090%Reduced — — — — — — 53% 51% — 43% 18% — — — — — — —
Daily,Winter(Max)
——————————————————
Unmit. 3.13 2.53 21.5 26.9 0.05 0.82 7.77 7.92 0.75 1.07 1.64 — 6,863 6,863 0.35 0.52 0.25 7,001Mit. 3.13 2.53 21.5 26.9 0.05 0.82 3.72 3.86 0.75 0.61 1.33 — 6,863 6,863 0.35 0.52 0.25 7,001 A-16

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% — — — — — — 52% 51% — 43% 19% — — — — — — —Reduced
AverageDaily(Max)
——————————————————
Unmit. 1.05 0.84 7.65 9.49 0.02 0.28 2.88 3.16 0.26 0.41 0.66 — 2,607 2,607 0.13 0.18 1.55 2,667Mit. 1.05 0.84 7.65 9.49 0.02 0.28 1.39 1.67 0.26 0.25 0.51 — 2,607 2,607 0.13 0.18 1.55 2,667%Reduced — — — — — — 52% 47% — 39% 24% — — — — — — —
Annual(Max)
——————————————————
Unmit. 0.19 0.15 1.40 1.73 < 0.005 0.05 0.53 0.58 0.05 0.07 0.12 — 432 432 0.02 0.03 0.26 442Mit. 0.19 0.15 1.40 1.73 < 0.005 0.05 0.25 0.30 0.05 0.05 0.09 — 432 432 0.02 0.03 0.26 442%Reduced — — — — — — 52% 47% — 39% 24% — — — — — — —

2.2. Construction Emissions by Year, UnmitigatedCriteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Year TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2eDaily -Summer(Max) ——————————————————
2026 2.88 2.34 20.5 24.1 0.04 0.80 7.52 7.78 0.74 1.03 1.47 — 5,965 5,965 0.29 0.38 7.95 6,090Daily -Winter(Max) ——————————————————
2026 3.13 2.53 21.5 26.9 0.05 0.82 7.77 7.91 0.75 1.07 1.64 — 6,863 6,863 0.35 0.44 0.25 7,0012027 1.85 1.42 14.2 15.7 0.04 0.50 7.42 7.92 0.46 1.00 1.46 — 5,346 5,346 0.26 0.52 0.24 5,508AverageDaily ——————————————————
2026 1.05 0.84 7.65 9.49 0.02 0.28 2.88 3.16 0.26 0.41 0.66 — 2,607 2,607 0.13 0.18 1.55 2,6672027 0.11 0.08 0.83 0.93 < 0.005 0.03 0.41 0.44 0.03 0.06 0.08 — 312 312 0.01 0.03 0.23 321 A-17

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Annual — — — — — — — — — — — — — — — — — —
2026 0.19 0.15 1.40 1.73 < 0.005 0.05 0.53 0.58 0.05 0.07 0.12 — 432 432 0.02 0.03 0.26 4422027 0.02 0.02 0.15 0.17 < 0.005 0.01 0.07 0.08 < 0.005 0.01 0.01 — 51.6 51.6 < 0.005 < 0.005 0.04 53.2

2.3. Construction Emissions by Year, MitigatedCriteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Year TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2eDaily -Summer(Max) ——————————————————
2026 2.88 2.34 20.5 24.1 0.04 0.80 3.56 3.82 0.74 0.59 1.21 — 5,965 5,965 0.29 0.38 7.95 6,090Daily -Winter(Max) ——————————————————
2026 3.13 2.53 21.5 26.9 0.05 0.82 3.72 3.86 0.75 0.61 1.33 — 6,863 6,863 0.35 0.44 0.25 7,0012027 1.85 1.42 14.2 15.7 0.04 0.50 3.11 3.61 0.46 0.56 1.02 — 5,346 5,346 0.26 0.52 0.24 5,508AverageDaily ——————————————————
2026 1.05 0.84 7.65 9.49 0.02 0.28 1.39 1.67 0.26 0.25 0.51 — 2,607 2,607 0.13 0.18 1.55 2,6672027 0.11 0.08 0.83 0.93 < 0.005 0.03 0.17 0.20 0.03 0.03 0.06 — 312 312 0.01 0.03 0.23 321Annual — — — — — — — — — — — — — — — — — —2026 0.19 0.15 1.40 1.73 < 0.005 0.05 0.25 0.30 0.05 0.05 0.09 — 432 432 0.02 0.03 0.26 4422027 0.02 0.02 0.15 0.17 < 0.005 0.01 0.03 0.04 < 0.005 0.01 0.01 — 51.6 51.6 < 0.005 < 0.005 0.04 53.2

3. Construction Emissions Details3.1. Phase 1 Demolition (2026) - UnmitigatedCriteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e A-18

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Onsite — — — — — — — — — — — — — — — — — —
Daily,Summer(Max)
——————————————————
Daily,Winter(Max)
——————————————————
Off-RoadEquipment

0.49 0.40 4.20 5.54 0.01 0.12 — 0.12 0.11 — 0.11 — 1,009 1,009 0.04 0.01 — 1,012 Demolition
— — — — — — 2.69 2.69 — 0.41 0.41 — — — — — — —
Onsitetruck

0.05 0.02 0.59 0.44 < 0.005 < 0.005 4.12 4.12 < 0.005 0.41 0.41 — 77.4 77.4 0.03 0.01 < 0.005 81.9 AverageDaily
——————————————————
Off-RoadEquipment

0.03 0.02 0.23 0.30 < 0.005 0.01 — 0.01 0.01 — 0.01 — 55.3 55.3 < 0.005 < 0.005 — 55.5 Demolition
— — — — — — 0.15 0.15 — 0.02 0.02 — — — — — — —
Onsitetruck
< 0.005 < 0.005 0.03 0.02 < 0.005 < 0.005 0.21 0.21 < 0.005 0.02 0.02 — 4.20 4.20 < 0.005 < 0.005 < 0.005 4.45 Annual — — — — — — — — — — — — — — — — — —Off-RoadEquipment < 0.005 < 0.005 0.04 0.06 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 9.15 9.15 < 0.005 < 0.005 — 9.18 Demolition
— — — — — — 0.03 0.03 — < 0.005 < 0.005 — — — — — — —
Onsitetruck
< 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 0.04 0.04 < 0.005 < 0.005 < 0.005 — 0.70 0.70 < 0.005 < 0.005 < 0.005 0.74 Offsite ——————————————————
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Daily, — — — — — — — — — — — — — — — — — —Summer(Max)
Daily,Winter(Max)
——————————————————
Worker 0.15 0.14 0.13 1.61 0.00 0.00 0.36 0.36 0.00 0.08 0.08 — 353 353 0.02 0.01 0.03 357Vendor 0.02 0.01 0.36 0.18 < 0.005 < 0.005 0.08 0.08 < 0.005 0.02 0.02 — 287 287 0.01 0.04 0.02 300Hauling 0.14 0.03 2.38 0.91 0.01 0.02 0.52 0.54 0.02 0.14 0.17 — 1,905 1,905 0.11 0.30 0.11 1,999AverageDaily ——————————————————
Worker 0.01 0.01 0.01 0.09 0.00 0.00 0.02 0.02 0.00 < 0.005 < 0.005 — 19.6 19.6 < 0.005 < 0.005 0.03 19.9Vendor < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 15.7 15.7 < 0.005 < 0.005 0.02 16.5Hauling 0.01 < 0.005 0.13 0.05 < 0.005 < 0.005 0.03 0.03 < 0.005 0.01 0.01 — 104 104 0.01 0.02 0.10 110Annual — — — — — — — — — — — — — — — — — —Worker < 0.005 < 0.005 < 0.005 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 3.25 3.25 < 0.005 < 0.005 < 0.005 3.29Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 2.61 2.61 < 0.005 < 0.005 < 0.005 2.72Hauling < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 17.3 17.3 < 0.005 < 0.005 0.02 18.1

3.2. Phase 1 Demolition (2026) - MitigatedCriteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2eOnsite — — — — — — — — — — — — — — — — — —Daily,Summer(Max) ——————————————————
Daily,Winter(Max)
——————————————————
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Off-Roa 0.49 0.40 4.20 5.54 0.01 0.12 — 0.12 0.11 — 0.11 — 1,009 1,009 0.04 0.01 — 1,012dEquipment Demolition
— — — — — — 1.72 1.72 — 0.26 0.26 — — — — — — —
Onsitetruck

0.05 0.02 0.59 0.44 < 0.005 < 0.005 1.04 1.04 < 0.005 0.10 0.10 — 77.4 77.4 0.03 0.01 < 0.005 81.9 AverageDaily
——————————————————
Off-RoadEquipment

0.03 0.02 0.23 0.30 < 0.005 0.01 — 0.01 0.01 — 0.01 — 55.3 55.3 < 0.005 < 0.005 — 55.5 Demolition
— — — — — — 0.09 0.09 — 0.01 0.01 — — — — — — —
Onsitetruck
< 0.005 < 0.005 0.03 0.02 < 0.005 < 0.005 0.05 0.05 < 0.005 0.01 0.01 — 4.20 4.20 < 0.005 < 0.005 < 0.005 4.45 Annual — — — — — — — — — — — — — — — — — —Off-RoadEquipment < 0.005 < 0.005 0.04 0.06 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 9.15 9.15 < 0.005 < 0.005 — 9.18 Demolition
— — — — — — 0.02 0.02 — < 0.005 < 0.005 — — — — — — —
Onsitetruck
< 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 0.70 0.70 < 0.005 < 0.005 < 0.005 0.74 Offsite ——————————————————Daily,Summer(Max)
——————————————————
Daily,Winter(Max)
——————————————————
Worker 0.15 0.14 0.13 1.61 0.00 0.00 0.36 0.36 0.00 0.08 0.08 — 353 353 0.02 0.01 0.03 357Vendor 0.02 0.01 0.36 0.18 < 0.005 < 0.005 0.08 0.08 < 0.005 0.02 0.02 — 287 287 0.01 0.04 0.02 300 A-21

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Hauling 0.14 0.03 2.38 0.91 0.01 0.02 0.52 0.54 0.02 0.14 0.17 — 1,905 1,905 0.11 0.30 0.11 1,999 AverageDaily
——————————————————
Worker 0.01 0.01 0.01 0.09 0.00 0.00 0.02 0.02 0.00 < 0.005 < 0.005 — 19.6 19.6 < 0.005 < 0.005 0.03 19.9Vendor < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 15.7 15.7 < 0.005 < 0.005 0.02 16.5Hauling 0.01 < 0.005 0.13 0.05 < 0.005 < 0.005 0.03 0.03 < 0.005 0.01 0.01 — 104 104 0.01 0.02 0.10 110Annual — — — — — — — — — — — — — — — — — —Worker < 0.005 < 0.005 < 0.005 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 3.25 3.25 < 0.005 < 0.005 < 0.005 3.29Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 2.61 2.61 < 0.005 < 0.005 < 0.005 2.72Hauling < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 17.3 17.3 < 0.005 < 0.005 0.02 18.1

3.3. Phase 2 Demolition (2026) - UnmitigatedCriteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2eOnsite — — — — — — — — — — — — — — — — — —Daily,Summer(Max) ——————————————————
Daily,Winter(Max)
——————————————————
Off-RoadEquipment

0.86 0.72 6.45 9.96 0.02 0.26 — 0.26 0.24 — 0.24 — 1,736 1,736 0.07 0.01 — 1,742 Demolition
— — — — — — 2.45 2.45 — 0.37 0.37 — — — — — — —
Onsitetruck

0.05 0.02 0.59 0.44 < 0.005 < 0.005 4.12 4.12 < 0.005 0.41 0.41 — 77.4 77.4 0.03 0.01 < 0.005 81.9 AverageDaily
——————————————————
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Off-Roa 0.05 0.04 0.39 0.60 < 0.005 0.02 — 0.02 0.01 — 0.01 — 105 105 < 0.005 < 0.005 — 105d Demolition
— — — — — — 0.15 0.15 — 0.02 0.02 — — — — — — —
Onsitetruck
< 0.005 < 0.005 0.03 0.03 < 0.005 < 0.005 0.23 0.23 < 0.005 0.02 0.02 — 4.62 4.62 < 0.005 < 0.005 < 0.005 4.90 Annual — — — — — — — — — — — — — — — — — —Off-RoadEquipment

0.01 0.01 0.07 0.11 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 17.3 17.3 < 0.005 < 0.005 — 17.4 Demolition
— — — — — — 0.03 0.03 — < 0.005 < 0.005 — — — — — — —
Onsitetruck
< 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 0.04 0.04 < 0.005 < 0.005 < 0.005 — 0.77 0.77 < 0.005 < 0.005 < 0.005 0.81 Offsite ——————————————————Daily,Summer(Max)
——————————————————
Daily,Winter(Max)
——————————————————
Worker 0.15 0.14 0.13 1.61 0.00 0.00 0.36 0.36 0.00 0.08 0.08 — 353 353 0.02 0.01 0.03 357Vendor 0.02 0.01 0.36 0.18 < 0.005 < 0.005 0.08 0.08 < 0.005 0.02 0.02 — 287 287 0.01 0.04 0.02 300Hauling 0.14 0.03 2.38 0.91 0.01 0.02 0.52 0.54 0.02 0.14 0.17 — 1,905 1,905 0.11 0.30 0.11 1,999AverageDaily ——————————————————
Worker 0.01 0.01 0.01 0.10 0.00 0.00 0.02 0.02 0.00 < 0.005 < 0.005 — 21.6 21.6 < 0.005 < 0.005 0.03 21.9Vendor < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 17.3 17.3 < 0.005 < 0.005 0.02 18.1Hauling 0.01 < 0.005 0.15 0.05 < 0.005 < 0.005 0.03 0.03 < 0.005 0.01 0.01 — 115 115 0.01 0.02 0.11 121Annual — — — — — — — — — — — — — — — — — —Worker < 0.005 < 0.005 < 0.005 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 3.57 3.57 < 0.005 < 0.005 0.01 3.62Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 2.87 2.87 < 0.005 < 0.005 < 0.005 3.00 A-23

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Hauling < 0.005 < 0.005 0.03 0.01 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 19.0 19.0 < 0.005 < 0.005 0.02 20.0

3.4. Phase 2 Demolition (2026) - MitigatedCriteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2eOnsite — — — — — — — — — — — — — — — — — —Daily,Summer(Max) ——————————————————
Daily,Winter(Max)
——————————————————
Off-RoadEquipment

0.86 0.72 6.45 9.96 0.02 0.26 — 0.26 0.24 — 0.24 — 1,736 1,736 0.07 0.01 — 1,742 Demolition
— — — — — — 1.57 1.57 — 0.24 0.24 — — — — — — —
Onsitetruck

0.05 0.02 0.59 0.44 < 0.005 < 0.005 1.04 1.04 < 0.005 0.10 0.10 — 77.4 77.4 0.03 0.01 < 0.005 81.9 AverageDaily
——————————————————
Off-RoadEquipment

0.05 0.04 0.39 0.60 < 0.005 0.02 — 0.02 0.01 — 0.01 — 105 105 < 0.005 < 0.005 — 105 Demolition
— — — — — — 0.09 0.09 — 0.01 0.01 — — — — — — —
Onsitetruck
< 0.005 < 0.005 0.03 0.03 < 0.005 < 0.005 0.06 0.06 < 0.005 0.01 0.01 — 4.62 4.62 < 0.005 < 0.005 < 0.005 4.90 Annual — — — — — — — — — — — — — — — — — —Off-RoadEquipment

0.01 0.01 0.07 0.11 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 17.3 17.3 < 0.005 < 0.005 — 17.4 A-24

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Demoliti — — — — — — 0.02 0.02 — < 0.005 < 0.005 — — — — — — — Onsitetruck
< 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 0.77 0.77 < 0.005 < 0.005 < 0.005 0.81 Offsite ——————————————————Daily,Summer(Max)
——————————————————
Daily,Winter(Max)
——————————————————
Worker 0.15 0.14 0.13 1.61 0.00 0.00 0.36 0.36 0.00 0.08 0.08 — 353 353 0.02 0.01 0.03 357Vendor 0.02 0.01 0.36 0.18 < 0.005 < 0.005 0.08 0.08 < 0.005 0.02 0.02 — 287 287 0.01 0.04 0.02 300Hauling 0.14 0.03 2.38 0.91 0.01 0.02 0.52 0.54 0.02 0.14 0.17 — 1,905 1,905 0.11 0.30 0.11 1,999AverageDaily ——————————————————
Worker 0.01 0.01 0.01 0.10 0.00 0.00 0.02 0.02 0.00 < 0.005 < 0.005 — 21.6 21.6 < 0.005 < 0.005 0.03 21.9Vendor < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 17.3 17.3 < 0.005 < 0.005 0.02 18.1Hauling 0.01 < 0.005 0.15 0.05 < 0.005 < 0.005 0.03 0.03 < 0.005 0.01 0.01 — 115 115 0.01 0.02 0.11 121Annual — — — — — — — — — — — — — — — — — —Worker < 0.005 < 0.005 < 0.005 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 3.57 3.57 < 0.005 < 0.005 0.01 3.62Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 2.87 2.87 < 0.005 < 0.005 < 0.005 3.00Hauling < 0.005 < 0.005 0.03 0.01 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 19.0 19.0 < 0.005 < 0.005 0.02 20.0

3.5. Phase 3 Demolition (2026) - UnmitigatedCriteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2eOnsite — — — — — — — — — — — — — — — — — —Daily,Summer(Max) ——————————————————
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Off-Roa 0.70 0.59 5.13 8.50 0.01 0.23 — 0.23 0.21 — 0.21 — 1,514 1,514 0.06 0.01 — 1,519d Demolition
— — — — — — 2.45 2.45 — 0.37 0.37 — — — — — — —
Onsitetruck

0.06 0.03 0.57 0.43 < 0.005 < 0.005 4.12 4.12 < 0.005 0.41 0.41 — 76.2 76.2 0.03 0.01 0.02 80.8 Daily,Winter(Max)
——————————————————
AverageDaily
——————————————————
Off-RoadEquipment

0.04 0.04 0.31 0.51 < 0.005 0.01 — 0.01 0.01 — 0.01 — 91.2 91.2 < 0.005 < 0.005 — 91.6 Demolition
— — — — — — 0.15 0.15 — 0.02 0.02 — — — — — — —
Onsitetruck
< 0.005 < 0.005 0.03 0.03 < 0.005 < 0.005 0.23 0.23 < 0.005 0.02 0.02 — 4.62 4.62 < 0.005 < 0.005 < 0.005 4.90 Annual — — — — — — — — — — — — — — — — — —Off-RoadEquipment

0.01 0.01 0.06 0.09 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 15.1 15.1 < 0.005 < 0.005 — 15.2 Demolition
— — — — — — 0.03 0.03 — < 0.005 < 0.005 — — — — — — —
Onsitetruck
< 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 0.04 0.04 < 0.005 < 0.005 < 0.005 — 0.77 0.77 < 0.005 < 0.005 < 0.005 0.81 Offsite ——————————————————Daily,Summer(Max)
——————————————————
Worker 0.15 0.14 0.11 1.85 0.00 0.00 0.36 0.36 0.00 0.08 0.08 — 372 372 0.02 0.01 1.25 378Vendor 0.02 0.01 0.34 0.17 < 0.005 < 0.005 0.08 0.08 < 0.005 0.02 0.02 — 287 287 0.01 0.04 0.77 301Hauling 0.14 0.03 2.29 0.90 0.01 0.02 0.52 0.54 0.02 0.14 0.17 — 1,905 1,905 0.11 0.30 4.27 2,002 A-26

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Daily,Winter(Max)
——————————————————
AverageDaily
——————————————————
Worker 0.01 0.01 0.01 0.10 0.00 0.00 0.02 0.02 0.00 < 0.005 < 0.005 — 21.6 21.6 < 0.005 < 0.005 0.03 21.9Vendor < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 17.3 17.3 < 0.005 < 0.005 0.02 18.1Hauling 0.01 < 0.005 0.15 0.05 < 0.005 < 0.005 0.03 0.03 < 0.005 0.01 0.01 — 115 115 0.01 0.02 0.11 121Annual — — — — — — — — — — — — — — — — — —Worker < 0.005 < 0.005 < 0.005 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 3.57 3.57 < 0.005 < 0.005 0.01 3.62Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 2.87 2.87 < 0.005 < 0.005 < 0.005 3.00Hauling < 0.005 < 0.005 0.03 0.01 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 19.0 19.0 < 0.005 < 0.005 0.02 20.0

3.6. Phase 3 Demolition (2026) - MitigatedCriteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2eOnsite — — — — — — — — — — — — — — — — — —Daily,Summer(Max) ——————————————————
Off-RoadEquipment

0.70 0.59 5.13 8.50 0.01 0.23 — 0.23 0.21 — 0.21 — 1,514 1,514 0.06 0.01 — 1,519 Demolition
— — — — — — 1.57 1.57 — 0.24 0.24 — — — — — — —
Onsitetruck

0.06 0.03 0.57 0.43 < 0.005 < 0.005 1.04 1.04 < 0.005 0.10 0.10 — 76.2 76.2 0.03 0.01 0.02 80.8 Daily,Winter(Max)
——————————————————
AverageDaily
——————————————————
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Off-RoaEquipment

0.04 0.04 0.31 0.51 < 0.005 0.01 — 0.01 0.01 — 0.01 — 91.2 91.2 < 0.005 < 0.005 — 91.6 Demolition
— — — — — — 0.09 0.09 — 0.01 0.01 — — — — — — —
Onsitetruck
< 0.005 < 0.005 0.03 0.03 < 0.005 < 0.005 0.06 0.06 < 0.005 0.01 0.01 — 4.62 4.62 < 0.005 < 0.005 < 0.005 4.90 Annual — — — — — — — — — — — — — — — — — —Off-RoadEquipment

0.01 0.01 0.06 0.09 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 15.1 15.1 < 0.005 < 0.005 — 15.2 Demolition
— — — — — — 0.02 0.02 — < 0.005 < 0.005 — — — — — — —
Onsitetruck
< 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 0.77 0.77 < 0.005 < 0.005 < 0.005 0.81 Offsite ——————————————————Daily,Summer(Max)
——————————————————
Worker 0.15 0.14 0.11 1.85 0.00 0.00 0.36 0.36 0.00 0.08 0.08 — 372 372 0.02 0.01 1.25 378Vendor 0.02 0.01 0.34 0.17 < 0.005 < 0.005 0.08 0.08 < 0.005 0.02 0.02 — 287 287 0.01 0.04 0.77 301Hauling 0.14 0.03 2.29 0.90 0.01 0.02 0.52 0.54 0.02 0.14 0.17 — 1,905 1,905 0.11 0.30 4.27 2,002Daily,Winter(Max) ——————————————————
AverageDaily
——————————————————
Worker 0.01 0.01 0.01 0.10 0.00 0.00 0.02 0.02 0.00 < 0.005 < 0.005 — 21.6 21.6 < 0.005 < 0.005 0.03 21.9Vendor < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 17.3 17.3 < 0.005 < 0.005 0.02 18.1Hauling 0.01 < 0.005 0.15 0.05 < 0.005 < 0.005 0.03 0.03 < 0.005 0.01 0.01 — 115 115 0.01 0.02 0.11 121Annual — — — — — — — — — — — — — — — — — —Worker < 0.005 < 0.005 < 0.005 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 3.57 3.57 < 0.005 < 0.005 0.01 3.62Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 2.87 2.87 < 0.005 < 0.005 < 0.005 3.00 A-28

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Hauling < 0.005 < 0.005 0.03 0.01 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 19.0 19.0 < 0.005 < 0.005 0.02 20.0

3.7. Site Preparation (2026) - UnmitigatedCriteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2eOnsite — — — — — — — — — — — — — — — — — —Daily,Summer(Max) ——————————————————
Off-RoadEquipment

0.71 0.60 5.05 8.03 0.01 0.25 — 0.25 0.23 — 0.23 — 1,469 1,469 0.06 0.01 — 1,474 DustFromMaterialMovement
— — — — — — 0.40 0.40 — 0.04 0.04 — — — — — — —
Onsitetruck

0.01 < 0.005 0.08 0.06 < 0.005 < 0.005 0.62 0.62 < 0.005 0.06 0.06 — 11.4 11.4 < 0.005 < 0.005 < 0.005 12.1 Daily,Winter(Max)
——————————————————
AverageDaily
——————————————————
Off-RoadEquipment

0.04 0.03 0.29 0.46 < 0.005 0.01 — 0.01 0.01 — 0.01 — 84.5 84.5 < 0.005 < 0.005 — 84.8 DustFromMaterialMovement
— — — — — — 0.02 0.02 — < 0.005 < 0.005 — — — — — — —
Onsitetruck
< 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.03 0.03 < 0.005 < 0.005 < 0.005 — 0.66 0.66 < 0.005 < 0.005 < 0.005 0.70 Annual — — — — — — — — — — — — — — — — — —
A-29

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Off-RoaEquipment

0.01 0.01 0.05 0.08 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 14.0 14.0 < 0.005 < 0.005 — 14.0 DustFromMaterialMovement
— — — — — — < 0.005 < 0.005 — < 0.005 < 0.005 — — — — — — — Onsitetruck
< 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 0.11 0.11 < 0.005 < 0.005 < 0.005 0.12 Offsite ——————————————————Daily,Summer(Max)
——————————————————
Worker 0.08 0.07 0.06 0.93 0.00 0.00 0.18 0.18 0.00 0.04 0.04 — 186 186 0.01 0.01 0.63 189Vendor < 0.005 < 0.005 0.06 0.03 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 47.9 47.9 < 0.005 0.01 0.13 50.1Hauling 0.02 < 0.005 0.33 0.13 < 0.005 < 0.005 0.07 0.08 < 0.005 0.02 0.02 — 272 272 0.02 0.04 0.61 286Daily,Winter(Max) ——————————————————
AverageDaily
——————————————————
Worker < 0.005 < 0.005 < 0.005 0.05 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 — 10.3 10.3 < 0.005 < 0.005 0.02 10.4Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 2.76 2.76 < 0.005 < 0.005 < 0.005 2.88Hauling < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 15.7 15.7 < 0.005 < 0.005 0.02 16.4Annual — — — — — — — — — — — — — — — — — —Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 1.70 1.70 < 0.005 < 0.005 < 0.005 1.73Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 0.46 0.46 < 0.005 < 0.005 < 0.005 0.48Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 2.59 2.59 < 0.005 < 0.005 < 0.005 2.72

3.8. Site Preparation (2026) - MitigatedCriteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2eOnsite — — — — — — — — — — — — — — — — — — A-30

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Daily,Summer(Max)
——————————————————
Off-RoadEquipment

0.71 0.60 5.05 8.03 0.01 0.25 — 0.25 0.23 — 0.23 — 1,469 1,469 0.06 0.01 — 1,474 DustFromMaterialMovement
— — — — — — 0.16 0.16 — 0.02 0.02 — — — — — — —
Onsitetruck

0.01 < 0.005 0.08 0.06 < 0.005 < 0.005 0.16 0.16 < 0.005 0.02 0.02 — 11.4 11.4 < 0.005 < 0.005 < 0.005 12.1 Daily,Winter(Max)
——————————————————
AverageDaily
——————————————————
Off-RoadEquipment

0.04 0.03 0.29 0.46 < 0.005 0.01 — 0.01 0.01 — 0.01 — 84.5 84.5 < 0.005 < 0.005 — 84.8 DustFromMaterialMovement
— — — — — — 0.01 0.01 — < 0.005 < 0.005 — — — — — — —
Onsitetruck
< 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 0.66 0.66 < 0.005 < 0.005 < 0.005 0.70 Annual — — — — — — — — — — — — — — — — — —Off-RoadEquipment

0.01 0.01 0.05 0.08 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 14.0 14.0 < 0.005 < 0.005 — 14.0 DustFromMaterialMovement
— — — — — — < 0.005 < 0.005 — < 0.005 < 0.005 — — — — — — — A-31

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Onsite < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 0.11 0.11 < 0.005 < 0.005 < 0.005 0.12truck Offsite ——————————————————Daily,Summer(Max)
——————————————————
Worker 0.08 0.07 0.06 0.93 0.00 0.00 0.18 0.18 0.00 0.04 0.04 — 186 186 0.01 0.01 0.63 189Vendor < 0.005 < 0.005 0.06 0.03 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 47.9 47.9 < 0.005 0.01 0.13 50.1Hauling 0.02 < 0.005 0.33 0.13 < 0.005 < 0.005 0.07 0.08 < 0.005 0.02 0.02 — 272 272 0.02 0.04 0.61 286Daily,Winter(Max) ——————————————————
AverageDaily
——————————————————
Worker < 0.005 < 0.005 < 0.005 0.05 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 — 10.3 10.3 < 0.005 < 0.005 0.02 10.4Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 2.76 2.76 < 0.005 < 0.005 < 0.005 2.88Hauling < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 15.7 15.7 < 0.005 < 0.005 0.02 16.4Annual — — — — — — — — — — — — — — — — — —Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 1.70 1.70 < 0.005 < 0.005 < 0.005 1.73Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 0.46 0.46 < 0.005 < 0.005 < 0.005 0.48Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 2.59 2.59 < 0.005 < 0.005 < 0.005 2.72

3.9. Drilling (2026) - UnmitigatedCriteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2eOnsite — — — — — — — — — — — — — — — — — —Daily,Summer(Max) ——————————————————
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Off-Roa 0.12 0.10 0.75 2.50 < 0.005 0.03 — 0.03 0.03 — 0.03 — 449 449 0.02 < 0.005 — 450dEquipment DustFromMaterialMovement
— — — — — — 0.00 0.00 — 0.00 0.00 — — — — — — —
Onsitetruck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,Winter(Max)
——————————————————
AverageDaily
——————————————————
Off-RoadEquipment
< 0.005 < 0.005 0.03 0.09 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 16.0 16.0 < 0.005 < 0.005 — 16.0 DustFromMaterialMovement
— — — — — — 0.00 0.00 — 0.00 0.00 — — — — — — —
Onsitetruck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —Off-RoadEquipment < 0.005 < 0.005 < 0.005 0.02 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 2.64 2.64 < 0.005 < 0.005 — 2.65 DustFromMaterialMovement
— — — — — — 0.00 0.00 — 0.00 0.00 — — — — — — —
Onsitetruck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite ——————————————————
A-33

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Daily,Summer(Max)
——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00Daily,Winter(Max) ——————————————————
AverageDaily
——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00Annual — — — — — — — — — — — — — — — — — —Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.10. Drilling (2026) - MitigatedCriteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2eOnsite — — — — — — — — — — — — — — — — — —Daily,Summer(Max) ——————————————————
Off-RoadEquipment

0.12 0.10 0.75 2.50 < 0.005 0.03 — 0.03 0.03 — 0.03 — 449 449 0.02 < 0.005 — 450 A-34

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Dust — — — — — — 0.00 0.00 — 0.00 0.00 — — — — — — —FromMaterialMovement Onsitetruck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,Winter(Max)
——————————————————
AverageDaily
——————————————————
Off-RoadEquipment
< 0.005 < 0.005 0.03 0.09 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 16.0 16.0 < 0.005 < 0.005 — 16.0 DustFromMaterialMovement
— — — — — — 0.00 0.00 — 0.00 0.00 — — — — — — —
Onsitetruck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —Off-RoadEquipment < 0.005 < 0.005 < 0.005 0.02 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 2.64 2.64 < 0.005 < 0.005 — 2.65 DustFromMaterialMovement
— — — — — — 0.00 0.00 — 0.00 0.00 — — — — — — —
Onsitetruck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite ——————————————————Daily,Summer(Max)
——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 A-35

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Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00Daily,Winter(Max) ——————————————————
AverageDaily
——————————————————
Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00Annual — — — — — — — — — — — — — — — — — —Worker 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.11. Grading (2026) - UnmitigatedCriteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2eOnsite — — — — — — — — — — — — — — — — — —Daily,Summer(Max) ——————————————————
Off-RoadEquipment

0.82 0.69 6.13 7.98 0.01 0.31 — 0.31 0.28 — 0.28 — 1,498 1,498 0.06 0.01 — 1,503 DustFromMaterialMovement
— — — — — — 0.80 0.80 — 0.09 0.09 — — — — — — —
Onsitetruck

0.03 0.01 0.28 0.21 < 0.005 < 0.005 2.06 2.06 < 0.005 0.21 0.21 — 38.1 38.1 0.01 0.01 0.01 40.4 A-36

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Daily,Winter(Max)
——————————————————
AverageDaily
——————————————————
Off-RoadEquipment

0.05 0.04 0.37 0.48 < 0.005 0.02 — 0.02 0.02 — 0.02 — 90.3 90.3 < 0.005 < 0.005 — 90.6 DustFromMaterialMovement
— — — — — — 0.05 0.05 — 0.01 0.01 — — — — — — —
Onsitetruck
< 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 0.12 0.12 < 0.005 0.01 0.01 — 2.31 2.31 < 0.005 < 0.005 < 0.005 2.45 Annual — — — — — — — — — — — — — — — — — —Off-RoadEquipment

0.01 0.01 0.07 0.09 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 15.0 15.0 < 0.005 < 0.005 — 15.0 DustFromMaterialMovement
— — — — — — 0.01 0.01 — < 0.005 < 0.005 — — — — — — —
Onsitetruck
< 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.02 0.02 < 0.005 < 0.005 < 0.005 — 0.38 0.38 < 0.005 < 0.005 < 0.005 0.41 Offsite ——————————————————Daily,Summer(Max)
——————————————————
Worker 0.08 0.07 0.06 0.93 0.00 0.00 0.18 0.18 0.00 0.04 0.04 — 186 186 0.01 0.01 0.63 189Vendor 0.01 < 0.005 0.17 0.09 < 0.005 < 0.005 0.04 0.04 < 0.005 0.01 0.01 — 144 144 0.01 0.02 0.38 150Hauling 0.07 0.02 1.15 0.45 0.01 0.01 0.26 0.27 0.01 0.07 0.08 — 952 952 0.05 0.15 2.14 1,001Daily,Winter(Max) ——————————————————
A-37

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AverageDaily
——————————————————
Worker < 0.005 < 0.005 < 0.005 0.05 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 — 10.8 10.8 < 0.005 < 0.005 0.02 10.9Vendor < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 8.66 8.66 < 0.005 < 0.005 0.01 9.05Hauling < 0.005 < 0.005 0.07 0.03 < 0.005 < 0.005 0.02 0.02 < 0.005 < 0.005 < 0.005 — 57.4 57.4 < 0.005 0.01 0.06 60.3Annual — — — — — — — — — — — — — — — — — —Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 1.79 1.79 < 0.005 < 0.005 < 0.005 1.81Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 1.43 1.43 < 0.005 < 0.005 < 0.005 1.50Hauling < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 9.50 9.50 < 0.005 < 0.005 0.01 9.98

3.12. Grading (2026) - MitigatedCriteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2eOnsite — — — — — — — — — — — — — — — — — —Daily,Summer(Max) ——————————————————
Off-RoadEquipment

0.82 0.69 6.13 7.98 0.01 0.31 — 0.31 0.28 — 0.28 — 1,498 1,498 0.06 0.01 — 1,503 DustFromMaterialMovement
— — — — — — 0.31 0.31 — 0.03 0.03 — — — — — — —
Onsitetruck

0.03 0.01 0.28 0.21 < 0.005 < 0.005 0.52 0.52 < 0.005 0.05 0.05 — 38.1 38.1 0.01 0.01 0.01 40.4 Daily,Winter(Max)
——————————————————
AverageDaily
——————————————————
A-38

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Off-Roa 0.05 0.04 0.37 0.48 < 0.005 0.02 — 0.02 0.02 — 0.02 — 90.3 90.3 < 0.005 < 0.005 — 90.6d DustFromMaterialMovement
— — — — — — 0.02 0.02 — < 0.005 < 0.005 — — — — — — —
Onsitetruck
< 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 0.03 0.03 < 0.005 < 0.005 < 0.005 — 2.31 2.31 < 0.005 < 0.005 < 0.005 2.45 Annual — — — — — — — — — — — — — — — — — —Off-RoadEquipment

0.01 0.01 0.07 0.09 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 15.0 15.0 < 0.005 < 0.005 — 15.0 DustFromMaterialMovement
— — — — — — < 0.005 < 0.005 — < 0.005 < 0.005 — — — — — — — Onsitetruck
< 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 0.38 0.38 < 0.005 < 0.005 < 0.005 0.41 Offsite ——————————————————Daily,Summer(Max)
——————————————————
Worker 0.08 0.07 0.06 0.93 0.00 0.00 0.18 0.18 0.00 0.04 0.04 — 186 186 0.01 0.01 0.63 189Vendor 0.01 < 0.005 0.17 0.09 < 0.005 < 0.005 0.04 0.04 < 0.005 0.01 0.01 — 144 144 0.01 0.02 0.38 150Hauling 0.07 0.02 1.15 0.45 0.01 0.01 0.26 0.27 0.01 0.07 0.08 — 952 952 0.05 0.15 2.14 1,001Daily,Winter(Max) ——————————————————
AverageDaily
——————————————————
Worker < 0.005 < 0.005 < 0.005 0.05 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 — 10.8 10.8 < 0.005 < 0.005 0.02 10.9Vendor < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 8.66 8.66 < 0.005 < 0.005 0.01 9.05Hauling < 0.005 < 0.005 0.07 0.03 < 0.005 < 0.005 0.02 0.02 < 0.005 < 0.005 < 0.005 — 57.4 57.4 < 0.005 0.01 0.06 60.3Annual — — — — — — — — — — — — — — — — — — A-39

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Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 1.79 1.79 < 0.005 < 0.005 < 0.005 1.81 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 1.43 1.43 < 0.005 < 0.005 < 0.005 1.50Hauling < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 9.50 9.50 < 0.005 < 0.005 0.01 9.98

3.13. Foundation (2026) - UnmitigatedCriteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2eOnsite — — — — — — — — — — — — — — — — — —Daily,Summer(Max) ——————————————————
Off-RoadEquipment

0.80 0.67 5.98 6.32 0.01 0.26 — 0.26 0.24 — 0.24 — 1,162 1,162 0.05 0.01 — 1,166 Onsitetruck

0.01 0.01 0.11 0.09 < 0.005 < 0.005 0.82 0.82 < 0.005 0.08 0.08 — 15.2 15.2 0.01 < 0.005 < 0.005 16.2 Daily,Winter(Max)
——————————————————
Off-RoadEquipment

0.80 0.67 5.98 6.32 0.01 0.26 — 0.26 0.24 — 0.24 — 1,162 1,162 0.05 0.01 — 1,166 Onsitetruck

0.01 < 0.005 0.12 0.09 < 0.005 < 0.005 0.82 0.82 < 0.005 0.08 0.08 — 15.5 15.5 0.01 < 0.005 < 0.005 16.4 AverageDaily
——————————————————
Off-RoadEquipment

0.19 0.16 1.44 1.52 < 0.005 0.06 — 0.06 0.06 — 0.06 — 280 280 0.01 < 0.005 — 281 Onsitetruck
< 0.005 < 0.005 0.03 0.02 < 0.005 < 0.005 0.19 0.19 < 0.005 0.02 0.02 — 3.70 3.70 < 0.005 < 0.005 < 0.005 3.92 A-40