Desert Hot Springs City Council
April 21, 2026

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resources necessary for police protection services, which at the time of the EIR was $4.49 per square foot of commercial and office use development and $0.70 per square foot of industrial and manufacturing development. Implementation of Regulatory Requirements RR-20 through RR-23 would ensure that the City would continue to monitor population growth to ensure that the Police Department could provide adequate police protection in the DLVSP.

In addition, pursuant to City of Desert Hot Springs Municipal Code Section 5.50.040 which governs cannabis businesses, project applicants would be required to prepare a security plan and install security measures at each medical marijuana cultivation facility to ensure the safety of employees and patients.

Schools
The project site and surrounding area is located within the Palm Springs Unified School District (PSUSD). The 2018 EIR determined the DLVSP project would be required to pay the requisite PSUSD school impact fee for construction of new commercial and industrial facilities, which was $0.56 per square foot at the time. However, the EIR noted that some schools were operating at or beyond capacity, and new facilities would be needed to serve the student population for the entire City, including student generation derived from potential Specific Plan-related job creation. Regulatory Requirement RR-24 was set forth to ensure that potential adverse effects to public schools are reduced to less than significant levels.

Parks
The 2018 EIR deferred to Section 4-15, Recreation for its discussion of park impacts.

Other Public Facilities - Libraries
The County and City did not require non-residential developments to pay a development impact fee (DIF) in order to meet the need for public facilities and improvements. The DLVSP did not propose residential uses, and the 2018 EIR determined impacts to the City library would be less than significant.

Cumulative Impacts
The 2018 EIR determined that the payment of developer impact fees and implementation of Mitigation Measures PS-1 through PS-8 would assure cumulative impacts to public services and facilities remain less than significant.

Mitigation Measures
No mitigation were required because impacts were less than significant with implementation of Regulatory Requirements.

Regulatory Requirements
The following Regulatory Requirements are from pages 4.14-8 and -9 of the 2018 EIR.

Item Number: 1.

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Fire
RR-17 The project applicant(s) shall participate in the Development Impact Fee Program as adopted by the City of Desert Hot Springs for applicable development projects to compensate for the costs necessary to maintain an acceptable level of service to the project site.

RR-18 The City and Riverside County Fire Department shall continue to confer and coordinate with the City of DHS to ensure that facilities and services associated with the DLVSP are expanded in a timely manner.

RR-19 The Riverside County Fire Department shall continue to review and evaluate new development proposals and project plans associated with the DLVSP to ensure that it can provide adequate fire protection.

Police
RR-20 The project applicant(s) shall participate in the Development Impact Fee Program as adopted by the City of Desert Hot Springs for applicable development projects to compensate for the costs necessary to maintain an acceptable level of service.

RR-21 The project applicant(s) shall be subject to Police Department review for applicable development projects to assure that the Department can provide adequate police protection.

RR-22 Due to the size and nature of development, the project applicant(s) shall implement around the clock security, including video cameras and security personnel, to eliminate unnecessary response to the facilities.

RR-23 The City shall monitor population increases and Police Department staffing levels to ensure the provision of police protection services at sufficient levels.

Schools
RR-24 The project applicant(s) shall be assessed statutory school mitigation fees, in place at the time industrial and commercial projects are proposed.

Analysis of the Proposed Project
The proposed Specific Plan amendment and development project would decrease the development intensities previously proposed in the DLVSP. Buildout of the proposed development (1.16 million SF) would result in a 24.5 percent reduction in industrial space, and a 100 percent reduction in commercial space previously analyzed in the 2018 EIR. This change will also result in a corresponding reduction in population from potential employment growth, as discussed in Section 4.13, Population and Housing. These reductions will also reduce demand for Item Number: 1.

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fire and police services, since fewer incidents would occur due to reductions in density and elimination of the commercial component. Similarly, impacts associated with libraries, schools and parks would be reduced with buildout of the Project, due to reductions in new employment population growth requiring these services.

The proposed Project will be subject to the same Regulatory Requirements as the 2018 Project.

Overall, impacts are expected to be comparable to or less than those previously identified in the EIR due to the reduction in buildout intensity, elimination of commercial uses, and reduction in projected employment opportunities that could indirectly induce unplanned population growth.

Therefore, implementation of the Specific Plan amendment and buildout of the Project would not result in any new adverse impacts, cumulative impacts, or increase the severity of identified significant impacts in the 2018 EIR.

3.15. RECREATION
Summary of Findings in the 2018 EIR (Section 4.15, page 4.15-1 et.seq.) The 2018 EIR described the existing condition of recreational resources within the planning area and vicinity. In 2018, according to the Desert Hot Spring’s Final Parks and Recreation Master Plan, there were approximately 27.29 total acres of parkland including seven parks, recreational facilities including a skate park, two community centers, a Community Health & Wellness Center/Boys & Girls Club, Senior Center and the Cabot’s Pueblo Museum. None of these facilities were on or in close proximity to the project site. The nearest park to the project site was Mission Springs Park, located approximately 3.9 miles north of the project site, 0.2 miles east of Palm Drive and Park Lane.

The DLVSP had the potential to generate approximately 2,212 employees and it was assumed that many of the potential employees would be living in the City or the general surrounding area.

Based on a family of 3.12 persons per household, the 2018 EIR determined the DLVSP’s proposed mixed industrial and commercial development had the potential to increase the population of the city by approximately 6,901 residents and thus had the potential to increase demands on local recreation facilities. In accordance with City’s Final Park and Recreation Master Plan Policy 1, the addition of 6,901 residents to the City population of 29,111 (2018) would require a minimum acquisition of 7 acres of parkland at the parkland ratio of 1 acre to 1,000 residents, or 21 acres of parkland at the recommended parkland ratio of 3 acres to 1,000 residents.

Under Desert Hot Springs Municipal Code Section 16.16.40A, commercial and industrial use projects are not required to pay the Parkland Acquisition and Improvements Fee to the City because these types of projects are exempt from this development impact fee.

Section 4.13 – Population and Housing of the 2018 EIR concluded that the 2018 vacancy rate and the allocated 4,196 housing units for forecast population growth in the City was sufficient to accommodate the population increase resulting from implementation of the DLVSP. However, in the event that new housing was required in the City, residential developers would be required to pay the Parkland Acquisition and Improvements Fee, offsetting the impacts of new residents.

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Therefore, the City would have funding to ensure that substantial physical deterioration of park and recreation facilities would not occur and impacts would be less than significant. Therefore, the 2018 EIR concluded that development of the DLVSP would have no adverse physical effect on the environment.

Cumulative Impacts
The 2018 EIR determined the project would not create cumulative impacts to recreation resources because the project would not impact these resources at buildout. Cumulative impacts were found to be less than significant.

Mitigation Measures
No mitigation were required because impacts were found to be less than significant.

Analysis of the Proposed Project
The Project proposes a reduced maximum development potential that would thus reduce the severity of recreation resources impacts compared to the DLVSP and 2018 EIR, due to the reduction in employees and potential new residents. The Project does not propose any residential development and will not directly increase the City’s population. The proposed industrial development will not include any on-site recreational facilities, nor will it directly require the construction or expansion of additional recreational facilities. The Project may indirectly require the construction of new housing units for Project employees, if these employees are new to the City. Should this occur, the number of potential new households would be well within that anticipated by the General Plan for build out of the City. As was the case under the 2018 EIR, any construction required for these units will be required to pay the Parkland Acquisition and Improvements Fee for the impacts of new residential units which may be needed to house Project employees.

Overall, implementation of the proposed Project is consistent with the industrial land uses previously analyzed in the 2018 EIR, would result in less intense development, and would not result in any new adverse impacts, cumulative impacts, or increase the severity of previously identified significant impacts to recreational resources in the 2018 EIR

3.16. TRANSPORTATION AND TRAFFIC
This section of the 2018 EIR is based on information contained in the Desert Land Ventures III LLC Property Traffic Impact Analysis (TIA), prepared by Kunzman Associates, July 2017, and the City of Desert Hot Springs Comprehensive General Plan Circulation Element 2000. The TIA is included as Appendix I of the 2018 EIR.

The focus of transportation analysis under CEQA has shifted since the preparation of the 2018 EIR. As this Addendum compares the proposed Project’s impacts to those analyzed for build out of the DLVSP, however, the following discussion addresses those issues considered in 2018, as they relate to the City’s policies regarding transportation issues.

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Summary of Findings in the 2018 EIR (Section 4.16, page 4.16-1 et.seq.) Traffic analysis was conducted to determine whether the proposed project would impact Level of Service (LOS) on City roadways. Based on the City-approved scoping agreement, the following scenarios were analyzed in the 2018 EIR:

1. Existing Conditions,

2. Existing Plus Project Conditions,

3. Opening Year (2019) Without Project Conditions,

4. Opening Year (2019) With Project Conditions,

5. Year 2035 Without Project Conditions, and

6. Year 2035 With Project Conditions.

As described in the 2018 EIR Table 4.16-1, duplicated below, the study area comprised 18 intersections within three jurisdictions: the City of Desert Hot Springs, the City of Palm Springs, and the City of Cathedral City. The General Plan Circulation Elements of all three cities had established LOS D as the minimum acceptable LOS for their transportation system. Roadway facilities operating at Level of Service E or F were considered deficient.

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Trip Generation
As described in the 2018 EIR, development of future projects at the project site was forecast to generate a total of approximately 28,719 daily trips in passenger car equivalents (PCE), of which 2,138 PCE trips would occur during the morning peak hour and 2,973 passenger car equivalent trips would occur during the evening peak hour, as shown in EIR Table 4.15-5 below.

The 2018 EIR traffic analysis included an Existing Conditions, with and without Project scenario that was developed to establish the baseline for traffic conditions. Under that scenario, the intersection of Palm Drive/Camino Aventura, and Palm Drive/20th Avenue both operated at unacceptable levels without the project, while the addition of the project added unacceptable conditions at the intersection of Palm Drive/Two Bunch Palms Drive. This baseline was used to develop future scenarios, both at opening year, and in the long term General Plan build out.

Opening Year (2019) Without Project Level of Service
The 2018 EIR found that the study area intersections were projected to operate within acceptable LOS conditions (D or better) during the morning and evening peak hours for Opening Year Without Project traffic conditions, except for the following study area intersections:
• Palm Drive at:
o Two Bunch Palms Trail (#7)
o Camino Aventura (#9)
o 20th Avenue (#11)
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The 2018 EIR found these intersections were forecast to result in no significant traffic impacts, with incorporation of recommended intersection improvements shown in EIR Table 4.16-7 below (also see Mitigation Measures section below)
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Opening Year (2019) With Project Level of Service
When the project was added to this scenario, the 2018 EIR found that the same three study area intersections would be at unacceptable LOS, and that the Palm Drive/Varner Road intersection would also fall below acceptable LOS standards.

However, based on required improvements to these intersections, the 2018 EIR found that with incorporation of recommended intersection improvements shown in EIR Table 4.16-8 below, LOS at all four intersections would operate at acceptable LOS (also see Mitigation Measures section below).

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Year 2035 Without Project Level of Service
To consider the impacts of General Plan build out, based on the GPA that changed the land uses on the property, the 2018 EIR found that without the project, three intersections would operate at an unacceptable LOS, as shown in EIR Table 4.16-9, below:
• Palm Drive at:
o Camino Aventura (#9)
o 20th Avenue (#11)
• Gene Autry Trail at:
o Vista Chino (#15)
The 2018 EIR found these intersections were forecast to result in no significant traffic impacts, with incorporation of recommended intersection improvements shown in EIR Table 4.16-9 below (also see Mitigation Measures section below).

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Year 2035 With Project Level of Service
With the addition of the proposed project to 2035 conditions, the 2018 EIR found that these five intersections would operate at an unacceptable LOS without improvements, including two which were not degraded without the project:
• Palm Drive at:
o Two Bunch Palms Trail (#7)
o Camino Aventura (#9)
o 20th Avenue (#11)
o Varner Road (#12)
• Gene Autry Trail at Vista Chino (#15)
The 2018 EIR found these intersections were forecast to result in no significant traffic impacts, with incorporation of recommended intersection improvements shown in EIR Table 4.16-10 below (also see Mitigation Measures section below)
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In summary, although LOS deficiencies were identified in both Opening Year and Horizon Year conditions, without or with the project, the 2018 EIR identified specific improvements, which were imposed as mitigation measures CIR-1 through CIR-6 to which the project would contribute its fair share. By collecting fair share contributions on these improvements, the 2018 EIR determined that LOS impacts associated with the project would be reduced to less than significant levels.

Air Traffic Patterns
Given the distance from the project site to the nearest airports, 3.75 miles to Palm Springs International Airport and more than 16 miles to the Bermuda Dunes Airport, the 2018 EIR determined implementation of the project would not impact traffic patterns, and there would be no impact.

Design Hazards
The 2018 EIR stated that all future projects within the project site would be required to undergo discretionary review with the City to ensure that design features were consistent with General Plan Policies, City Ordinances, and the recommendations for intersection improvements set forth in the DLVSP TIA. The City’s review of the project would analyze design features and project access to ensure that they were consistent with City guidelines and did not pose hazards to the public. Therefore, once a proposed project had been approved by the City, the 2018 EIR concluded impacts would be less than significant.

Transit, Bicycle and Pedestrian Facilities
The 2018 EIR stated that mitigation implemented towards the redesigning of intersections with traffic signals, turn and through lanes, and overlap traffic signal phasing is consistent with the Circulation Element of the General Plan. Additionally, sidewalks would be developed along all project roadways to provide sufficient pedestrian circulation throughout the project site. The EIR concluded that the DLVSP would not conflict with City policies for public transit, bicycle, or pedestrian facilities.

Cumulative Impacts
The 2018 EIR referred to the cumulative analysis discussed in the Year 2035 with Project Level of Service impact discussion, reiterating that implementation of mitigation measures CIR-1 through CIR-13 would ensure adequate level of service and reduce potential cumulative impacts to less than significant levels.

Mitigation Measures
The following Mitigations Measures and Regulatory Requirements are from pages 4.16-26 through -28 of the 2018 EIR.

Off Site Intersection Improvements
The following offsite mitigation measures are recommendations to achieve acceptable Levels of Service during peak hours as per the City of Desert Hot Springs’s requirements for Year 2035 with Project traffic conditions. Future projects developed at the project site would be responsible for paying a fair share contribution to the intersection improvements. This would be calculated on Item Number: 1.

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a project by project basis as projects are proposed and project specific traffic studies are prepared for each new project. EIR Table 4.16-11 Project Fair Share Contribution, identifies the cost for intersection improvements that the DLVSP projects in the aggregate.

CIR-1 Palm Drive at Two Bunch Palms Trail (#7):
• Install an eastbound right turn overlap traffic signal phasing CIR-2 Palm Drive at Camino Aventura (#9):
• Install a traffic signal
CIR-3 Palm Drive at Camino Campanero (#8):
• Construct a northbound left turn lane
• Construct an eastbound shared left/through/right turn lane • Construct a westbound through lane
CIR-4 Palm Drive at 20th Avenue (#11):
• Install a traffic signal
CIR-5 Palm Drive at Varner Road (#12):
• Construct two additional northbound left turn lanes
• Construct three total outbound lanes on west leg of the intersection • Construct additional southbound through lane
• Construct additional outbound lane on southbound leg of the intersection • Construct an eastbound left turn lane
• Construct an eastbound free right turn lane
• Construct a westbound left turn lane
• Construct westbound right turn lane
• Install westbound right turn overlap traffic signal phasing CIR-6 Gene Autry Trail at Vista Chino (#15):
• Construct additional southbound through lane
• Construct additional northbound left turn lane
• Install a southbound right turn overlap traffic signal phasing Item Number: 1.

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Onsite Roadway Improvements
The following site-specific circulation and access mitigation measures are recommended and are shown in EIR Exhibit 4.16-2, On-Site Circulation Recommendations. The proposed project provides conceptual planning areas and has been analyzed as such. Detailed site plans for each planning area have not yet been designed by the project proponent. Focused traffic analyses shall be conducted for the planning areas once detailed site plans are provided by the project proponent and/or project applicant(s) in order to analyze all potential traffic and transportationrelated impacts. Therefore, as part of the site plan review for each planning area, the project proponent and/or project applicant(s) shall adhere to all applicable City Standards in order to achieve approval from the City. In addition, the following mitigation measures shall be implemented to reduce potentially significant impacts to circulation and access:

CIR-7 The project applicant(s) shall construct all site access related improvements, including travel lanes on Varner Road in each direction between the project site and the Palm Drive and Varner Road intersection. Timing of construction of these improvements shall be at the discretion of the City Engineer or his/her designee, as new development projects at the project site are proposed.

CIR-8 The project applicant(s) shall construct all onsite and site-adjacent improvements, including traffic signing/striping and project driveways, as approved by the City of Desert Hot Springs Public Works Department. Timing of construction of these improvements shall be at the discretion of the City Engineer or his/her designee, as new development projects at the project site are proposed.

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CIR-9 Varner Road along the project boundary shall be constructed at its ultimate crosssection width, including landscaping and parkway improvements in conjunction with development, or as otherwise approved by the City of Desert Hot Springs Public Works Department. Timing of construction of these improvements will be at the discretion of the City Engineer or his/her designee, as new development projects at the project site are proposed.

CIR-10 On-site parking shall be provided to the satisfaction of the City of Desert Hot Springs Planning Department
CIR-11 Sight distance at the project accesses shall comply with standard Caltrans and City of Desert Hot Springs sight distance standards. The final grading, landscaping, and street improvement plans shall demonstrate that sight distance standards are met. Such plans must be reviewed and approved as consistent with this measure prior to issuance of grading permits and shall be reviewed on a project by project basis.

CIR-12 All future proponents proposing projects within the project site shall participate in phased construction of off-site traffic signals through payment of traffic signal mitigation fees. At the discretion of the City Engineer or his/her designee, payment of fees sum may be required of the project proponent prior to development of the first new development project, or collected as each new development project is proposed. The traffic signals within the TIA study area at buildout should specifically include an interconnect of the traffic signals to function in a coordinated system.

CIR-13 The project proponent shall contribute on a fair share basis through the City’s Development Impact Fee Circulation Systems Streets, Traffic Signals, and Bridges Program, or in dollar equivalent in lieu mitigation contributions, in the implementation of the recommended improvements.

Analysis of the Proposed Project
A Project-specific Traffic Analysis (TA) was prepared by Urban Crossroads in March 2025 (Appendix I) that analyzed 1,500,000 square feet of high cube warehouse, consistent with the maximum buildout potential of the proposed Specific Plan amendment. Since completion of the TA, the proposed GPA has been revised to remove the segment of Mihalyo Road from Palm Drive to Varner Road from the General Plan. A supplemental Technical Memorandum was prepared by Urban Crossroads in March 2026 (see Appendix K) that evaluated future (2045) traffic conditions with this segment of Mihalyo removed from the City’s General Plan.

The estimated Project trip generation is 3,194 vehicle trip-ends per day with 183 AM peak vehicle hour trips and 248 PM peak hour vehicle trips, which is a substantial reduction in trips, due to the reduction in industrial square footage, and the elimination of commercial uses considered in the 2018 EIR. Refinements to the raw vehicle trip generation estimates for the Project were made to provide a more detailed breakdown of trips by vehicle type (passenger cars or trucks).

Passenger car equivalents (PCEs) allow the typical “real-world” mix of vehicle types to be Item Number: 1.

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represented as a single, standardized unit, such as the passenger car, to be used for the purposes of capacity and level of service analyses. The Project is anticipated to generate a total of 5,114 PCE trip-ends per day with 293 PCE AM peak vehicle hour trips and 398 PCE PM peak hour vehicle trips.

Access to the Project will be provided via full access intersections along Varner Road (2 driveways) and West Drive (2 driveways). It is anticipated that the Project will initially use Varner Road as its sole connection to Palm Drive.

For the purposes of the traffic study, potential deficiencies to traffic and circulation have been assessed for each of the following conditions:
• Existing (2025) Conditions
• Existing plus Ambient Growth plus Project (EAP) (2027) Conditions • Existing plus Ambient Growth plus Project plus Cumulative (EAPC) (2027) Conditions • General Plan buildout, Mihalyo Removed (Horizon Year 2045) With Desert Land Ventures SP • General Plan buildout, Mihalyo Removed (Horizon Year 2045) With Project The following study area intersections were selected for the TA and supplemental Technical Memorandum based on consultation with City of Desert Hot Springs.

Table 14
Intersection Analysis Locations
# Intersection # Intersection
1 Palm Dr. / I-10 EB Ramps 6 Project Access 1 / Varner Rd. 2 Palm Dr. / I-10 WB Ramps 7 Project Access 2 / Varner Rd. 3 Palm Dr. / Paul Rd. – Future Valley Center Bl. 8 West Dr. / Project Access 3 4 Palm Dr. / Varner Rd. 9 West Dr. / Project Access 4
5 West Dr. / Varner Rd. 10 Palm Dr. / Future Thornton Rd. (2045 Conditions Only) Source: Table 1-1 Traffic Analysis. For Intersection 10, Table 1 Supplemental Technical Memorandum.

Project Traffic Analysis Findings
Existing (2025) Conditions: The TA determined study area intersections are currently operating at an acceptable LOS (LOS “D” or better) during the peak hours under Existing (2025) traffic conditions.

Opening Year (2027 Conditions): For EAP (2027) and EAPC (2027) traffic conditions, study intersections were found to operate at an acceptable LOS (LOS “D” or better) during peak hours with access improvements that include improvements to Varner Road west of Palm Drive to provide 32 feet of new pavement width, as shown in Tables 15 and 16.

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Table 15
Intersection Analysis for EAP (2027)
# Intersection Traffic
Control1
Intersection Approach Lanes2 Delay3 Level of
Northbound Southbound Eastbound Westbound (secs.) Service

L T R L T R L T R L T R AM PM AM PM
1 Palm Dr./I-10 EB Ramps TS 0 3 1>> 0 3 1>> 1 1! 1 0 0 0 7.3 5.5 A A 2 Palm Dr./I-10 WB Ramps TS 0 3 1>> 0 3 1>> 0 0 0 1 1! 1 12.2 13.9 B B 3 Palm Dr./Paul Rd.-Future
Valley Center Bl. TS 1 2 0 1 2 0 1 1 0 0 1! 0 22.3 17.1 C B 4 Palm Dr./Varner Rd. TS 1 2 0 1 2 0 1 1 0 1 1 0 44.7 37.4 D D 5 West Dr./Varner Rd. CSS 0 1! 0 0 0 0 0 1 0 0.5 0.5 0 8.7 9.9 A A 6 Project Access 1/Varner Rd. CSS 0 1! 0 0 0 0 0 1 0 0.5 0.5 0 8.5 8.9 A A 7 Project Access 2/Varner Rd. CSS 0 1! 0 0 0 0 0 1 0 0.5 0.5 0 8.4 8.6 A A 8 West Dr./Project Access 3 CSS 0.5 0.5 0 0 1 0 0 1! 0 0 0 0 9.2 9.6 A A 9 West Dr./Project Access 4 CSS 0.5 0.5 0 0 1 0 0 1! 0 0 0 0 8.7 8.8 A A 10 Palm Dr./Thornton Rd. Future Intersection (Horizon Year 2045 Only) Source: Table 5-1 Traffic Analysis, modified to remove reference to future Mihalyo Road. 1 TS = Traffic Signal; CSS = Cross-Street Stop 2 When a right turn is designated, the lane can either be striped or unstriped. To function as a right turn lane there must be sufficient width for right turning vehicles to travel outside the through lanes.

L = Left; T = Through; R = Right; 0.5 = Shared Lane; 1! = Shared Left/Through/Right lane; >> = Free-Right Turn; 1 = Improvement 3 Per the Highway Capacity Manual (7th Edition), overall average intersection delay and level for service are shown for intersections with a traffic signal or all way stop control. For intersections with cross street stop control, the delay and level of service for the worst individual movement (or movements sharing a single lane) are shown.

Table 16
Intersection Analysis for EAPC (2027)
# Intersection
Traffic
Control1
Intersection Approach Lanes2 Delay3 Level of
Northbound Southbound Eastbound Westbound (secs.) Service

L T R L T R L T R L T R AM PM AM PM
1 Palm Dr./I-10 EB Ramps TS 0 3 1>> 0 3 1>> 1 1! 1 0 0 0 7.7 7.1 A A 2 Palm Dr./I-10 WB Ramps TS 0 3 1>> 0 3 1>> 0 0 0 1 1! 1 14.5 18.1 B B 3 Palm Dr./Paul Rd.-Future
Valley Center Bl.

TS 1 2 0 1 2 0 1 1 0 0 1! 0 30.9 21.8 C C
4 Palm Dr./Varner Rd. TS 1 2 0 1 2 0 1 1 0 1 1 0 50.7 47.8 D D 5 West Dr./Varner Rd. CSS 0 1! 0 0 0 0 0 1 0 0.5 0.5 0 8.7 9.9 A A 6 Project Access 1/Varner Rd. CSS 0 1! 0 0 0 0 0 1 0 0.5 0.5 0 8.5 9.9 A A 7 Project Access 2/Varner Rd. CSS 0 1! 0 0 0 0 0 1 0 0.5 0.5 0 8.4 8.6 A A 8 West Dr./Project Access 3 CSS 0.5 0.5 0 0 1 0 0 1! 0 0 0 0 9.2 9.6 A A 9 West Dr./Project Access 4 CSS 0.5 0.5 0 0 1 0 0 1! 0 0 0 0 8.7 8.8 A A 10 Palm Dr./Thornton Rd. Future Intersection (Horizon Year 2045 Only) Source: Table 6-1 Traffic Analysis, modified to remove reference to future Mihalyo Road. 1 TS = Traffic Signal; CSS = Cross-Street Stop 2 When a right turn is designated, the lane can either be striped or unstriped. To function as a right turn lane there must be sufficient width for right turning vehicles to travel outside the through lanes.

L = Left; T = Through; R = Right; 0.5 = Shared Lane; 1! = Shared Left/Through/Right lane; >> = Free-Right Turn; 1 = Improvement 3 Per the Highway Capacity Manual (7th Edition), overall average intersection delay and level for service are shown for intersections with a traffic signal or all way stop control. For intersections with cross street stop control, the delay and level of service for the worst individual movement (or movements sharing a single lane) are shown.

Horizon Year (2045) Conditions: The TA supplemental Technical Memorandum determined significant future improvements will be needed along Palm Drive to serve General Plan buildout conditions, with or without the Project, as shown in Table 17. It is anticipated that Varner Road will also be widened to four through travel lanes between West Drive and Palm Drive in conjunction with future development east of the Project site and south of Varner Road. Because these improvements are required with or without the Project, the Project would be required to contribute its fair share to these improvements to reduce its impacts to less than significant levels, as provided in Mitigation Measure TRA-2.

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Table 17
Intersection Analysis for Horizon Year 2045
# Intersection Traffic
Control1
Intersection Approach Lanes2 2045 with DLVSP 2045 with Project Delay3 Level of Delay3 Level of
Northbound Southbound Eastbound Westbound (secs.) Service (secs) Service

L T R L T R L T R L T R AM PM AM PM AM PM AM PM
1 Palm Dr./I-10 EB Ramps TS 0 3 1>> 0 3 1>> 1 1! 1 0 0 0 13.0 8.8 B A 8.5 7.8 A A 2 Palm Dr./I-10 WB Ramps TS 0 3 1>> 0 3 1>> 0 0 0 1 1! 1 41.1 36.0 D D 27.4 21.2 C C 3 Palm Dr./Paul Rd.-Future
Valley Center Bl. TS 1 2 0 1 2 0 1 1 0 0 1! 0 >80 >80 F F >80 >80 F F -with Improvements TS 1 3 1> 1 3 0 1 1 0 1 1 1> 45.5 54.6 D D 40.3 53.3 D D 4 Palm Dr./Varner Rd. TS 1 2 0 1 2 0 0 1! 0 0 1! 0 >80 >80 F F >80 >80 F F - 2045 with DLVSP Improvement TS 2 3 0 1 3 1 2 1 1> 1 1 0 54.5 51.2 D D - - - - - 2045 with Project Improvement TS 2 3 0 2 3 0 1 2 0 1 2 0 - - - - 39.6 41.1 D D 5 West Dr./Varner Rd.
-2045 with DLVSP Improvement TS 0 1! 0 0 0 0 0 2 0 1 2 0 16.1 27.0 B C - - - - -2045 with Project Improvement CSS 0 1! 0 0 0 0 0 1 0 1 1 0 - - - - 12.2 15.5 B C 6 Project Access 1/Varner Rd. CSS 0 1! 0 0 0 0 0 1 0 0 1 0 - - - - 12.1 12.7 B B 7 Project Access 2/Varner Rd. CSS 0 1! 0 0 0 0 0 1 0 0 1 0 - - - - 11.8 12.1 B B 8 West Dr./Project Access 3 CSS 0 1 0 0 1 0 0 1! 0 0 0 0 - - - - 9.2 9.6 A A 9 West Dr./Project Access 4
-2045 with DLVSP Improvement CSS 0 1! 0 0 1! 0 1 1 0 0 1! 0 34.4 31.5 D D - - - - -2045 with Project Improvement CSS 0 1 0 0 1 0 0 1! 0 0 0 0 - - - - 8.7 8.8 A A 10 Palm Dr./Thornton Rd.
-2045 with DLVSP Improvement - - - - - - - - - - - - - - - - - - - - - -2045 with Project Improvement TS 1 3 0 0 3 0 1 0 1 0 0 0 - - - - 5.0 7.4 A A Source: TA Technical Memorandum Table 1. 1 TS = Traffic Signal; CSS = Cross-Street Stop 2 When a right turn is designated, the lane can either be striped or unstriped. To function as a right turn lane there must be sufficient width for right turning vehicles to travel outside the through lanes.

L = Left; T = Through; R = Right; 0.5 = Shared Lane; 1! = Shared Left/Through/Right lane; >> = Free-Right Turn; 1 = Improvement 3 Per the Highway Capacity Manual (7th Edition), overall average intersection delay and level for service are shown for intersections with a traffic signal or all way stop control. For intersections with cross street stop control, the delay and level of service for the worst individual movement (or movements sharing a single lane) are shown.

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In comparison to the approved DLVSP, the proposed Project generates 23,605 fewer daily trips (with passenger car equivalents applied to truck activity associated with the Project). During the morning peak hour, the Project generates 1,845 fewer vehicle trips than the DLVSP land uses.

During the evening peak hour, the Project generates 2,430 fewer vehicle trips than the DLVSP land uses.

Access Improvements: Driveway connections to the Project will be provided via full access intersections along Varner Road (two driveways) and West Drive (two driveways). Roadway improvements necessary to provide site access and on-site circulation consist of the following:
• Construct new 32-foot pavement width (half section of Secondary II) along Varner Road from the Palm Drive intersection to the Project Access 2 intersection near the northwest site boundary.
• Construct new 26-foot pavement width (half section of Collector) along West Drive from the Varner Road intersection to the Project Access 4 intersection near the southeast site boundary.
• At the intersection of Palm Drive and Varner Road, provide separate 90-foot-long left turn lanes for the eastbound and westbound approaches.

Cross-street stop sign controls will adequately serve the Project driveway intersections on Varner Road and West Drive. Cross-street stop sign control will also adequately serve the West Drive intersection at Varner Road.

With implementation of the access improvements, as required by Mitigation Measures TRA-1, Project impacts would be less than significant.

Participation In Cumulative Future Improvements: The supplemental Technical Memorandum also recommends that the Project applicant participate in relevant City and subregional (CVAG’s TUMF program) fees. In some cases, separate fees based upon Project fair share calculations may be appropriate. The fair share calculations presented in Mitigation Measures TRA-2 provide a basis for discussion between the City and Project Applicant. For Horizon Year (2045) With Project traffic conditions, and without Mihalyo Road, study area intersection improvements (from EAPC) necessary to provide acceptable peak hour intersection LOS (LOS “D” or better) are as follows:
#3 – Palm Dr. / Paul Rd. – Valley Center Bl.
• Provide a 3rd NB through lane and a separate NB right turn lane with overlap phase. • Provide a 3rd SB through lane.
• Provide a separate WB left turn lane and one WB right turn lane with overlap phase. #4 – Palm Dr. / Varner Rd.
• Provide a 2nd NB left turn lane with a minimum of 200 ft. turn pocket length. • Provide a 3rd NB through lane.
• Provide a 2nd SB left turn lane with a minimum of 150 ft. turn pocket length. • Provide a 3rd SB through lane.

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• Provide a separate EB left turn lane with a minimum of 200 ft. turn pocket length. • Provide a 2nd EB through lane.
• Provide a separate WB left turn lane with a minimum of 200ft. turn pocket length. • Provide a 2nd WB through lane.
#10 – Palm Dr. / Thornton Rd.
• Install traffic signal
• Provide a separate NB left turn lane and a 3rd NB through lane. • Provide a 3rd SB through lane.
• Provide a separate WB left turn lane and one WB right turn lane.

With implementation of the fair share improvements, as required by Mitigation Measures TRA2, Project impacts would be less than significant.

Air Traffic Patterns
The Project site is 3.75 miles to Palm Springs International Airport and more than 16 miles to the Bermuda Dunes Airport. Consistent with the findings of the 2018 EIR, implementation of the Project would not impact traffic patterns, consistent with the findings of the 2018 EIR.

Design Hazards
The Project is required to undergo discretionary review with the City to ensure that design features are consistent with General Plan Policies, City Ordinances, and the recommendations for intersection improvements set forth in the Project-specific Traffic Analysis. The City’s review of the Project would analyze design features and project access to ensure that they are consistent with City guidelines and do not pose hazards to the public. Impacts would be less than significant and consistent with the 2018 EIR.

Transit, Bicycle and Pedestrian Facilities
As with the 2018 EIR, mitigation implemented towards the redesigning of intersections with traffic signals, turn and through lanes, and overlap traffic signal phasing is consistent with the Mobility Element of the General Plan. Additionally, sidewalks will be developed along all Project roadways to provide sufficient pedestrian circulation throughout the project site. The Project would not conflict with City policies for public transit, bicycle, or pedestrian facilities, as was the case with the 2018 EIR.

Cumulative Impacts
Adherence to regulatory requirements and mitigation measures imposed on the Project, as discussed above, and provided in mitigation measures TRA-1 and TRA-3 would reduce potential Project-related impacts to Level of Service, and as demonstrated in Table 16, would have no cumulative impacts on the area’s roadway system.

Summary
Like the 2018 EIR, the regulatory requirements and mitigation measures imposed on the Project address impacts from the Project and would reduce these impacts to less than significant levels.

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Overall, the proposed Project will substantially reduce trips and lower impacts to regional roadways, when compared to the 2018 EIR. The Project will therefore not result in any new significant impacts or increase the severity of impacts already identified in the EIR. Development conducted pursuant to the mitigation measures set forth below, and in adherence to existing federal, state, and City regulations will ensure potential impacts associated with traffic are reduced to less than significant levels.

Mitigation Measures
TRA-1 Per the Project-specific Traffic Analysis, the Project shall install the following access improvements:
• Construct new 32-foot pavement width (half section of Secondary II) along Varner Road from the Palm Drive intersection to the Project Access 2 intersection near the northwest site boundary.
• Construct new 26-foot pavement width (half section of Collector) along West Drive from the Varner Road intersection to the Project Access 4 intersection near the southeast site boundary.
• At the intersection of Palm Drive and Varner Road, provide separate 90-foot-long left turn lanes for the eastbound and westbound approaches.

Cross-street stop sign controls will adequately serve the Project driveway intersections on Varner Road and West Road. Cross-street stop sign control will also adequately serve the West Drive intersection at Varner Road.

West Dr. / Varner Rd. (#5)
• Provide a cross-street stop for the northbound approach. • Provide a shared northbound left/right lane.

Project Access 1 / Varner Road (#6)
• Install a cross-street stop control on the northbound approach. • Provide one northbound shared left-right lane.

Project Access 2 / Varner Road (#7)
• Install a cross-street stop control on the northbound approach. • Provide one northbound shared left-right lane.

West Drive / Project Access 3 (#8)
• Install a cross-street stop control on the eastbound approach. • Provide one eastbound shared left-right lane.

West Drive / Project Access 4 (#9)
• Install a cross-street stop control on the eastbound approach. • Provide one eastbound shared left-right lane.

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TRA-2 The Project applicant shall participate in relevant City and subregional (CVAG’s TUMF program) fees. In some cases, separate fees based upon Project fair share calculations may be appropriate. The fair share calculations in the tables below provide a basis for discussion between the City and Project Applicant. For Horizon Year (2045) With Project traffic conditions, and without Mihalyo Road, study area intersection improvements (from EAPC) necessary to provide acceptable peak hour intersection LOS (LOS “D” or better) are as follows:
#3 – Palm Dr. / Paul Rd. – Valley Center Bl.
• Provide a 3rd NB through lane and a separate NB right turn lane with overlap phase.
• Provide a 3rd SB through lane.
• Provide a separate WB left turn lane and one WB right turn lane with overlap phase.
#4 – Palm Dr. / Varner Rd.
• Provide a 2nd NB left turn lane with a minimum of 200 ft. turn pocket length. • Provide a 3rd NB through lane.
• Provide a 2nd SB left turn lane with a minimum of 150 ft. turn pocket length. • Provide a 3rd SB through lane.
• Provide a separate EB left turn lane with a minimum of 200 ft. turn pocket length.
• Provide a 2nd EB through lane.
• Provide a separate WB left turn lane with a minimum of 200ft. turn pocket length.
• Provide a 2nd WB through lane.
#10 – Palm Dr. / Thornton Rd.
• Install traffic signal
• Provide a separate NB left turn lane and a 3rd NB through lane. • Provide a 3rd SB through lane.
• Provide a separate WB left turn lane and one WB right turn lane.

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Fair Share Calculations for Study Area Intersections
# Intersection Existing
Traffic
2045WP
Traffic3
Project
Only Traffic
TotalNew
Traffic1
Project
Fair Share (%)2
3 Palm Dr. / Paul Rd. - Future Valley Center Bl.
• AM Peak Hour
• PM Peak Hour
2,824 4,866 267 2,042 13.1%
3,331 5,629 363 2,298 15.8%
4 Palm Dr. / Varner Rd.
• AM Peak Hour
• PM Peak Hour
2,634 4,895 292 2,261 12.9%
3,079 5,797 398 2,718 14.6%
10 Palm Dr. / Thornton Rd.
• AM Peak Hour
• PM Peak Hour
2,581 4,190 267 1,609 16.6%
3,023 4,860 363 1,837 19.8%
Source: Table 4 Technical Memorandum to TA. 1 Total New Traffic = (2045 with Project - Existing Traffic) 2 Project Fair Share % = (Project Only Traffic / Total New Traffic) 3 General Plan Buildout (Horizon Year 2045) With Project Fair Share Calculations for Study Area Roadway Segments Roadway Segment Existing
Traffic
2045WP
Traffic3
Project
Only Traffic
Total New
Traffic1
Project
Fair Share (%)2
Varner Road, west of Palm Drive
• Construct 4-lane roadway 100 16,600 5,100 16,500 30.9% Palm Drive, north of Varner Road
• Widen to six lanes 36,000 50,300 300 14,300 2.1%
PalmDrive, between Varner Road and Thornton Road
• Widen to six lanes 37,500 54,700 4,700 17,200 27.3%
Palm Drive, between Paul Rd. and Thornton Road
• Widen to six lanes 37,500 54,700 4,700 17,200 27.3%
Palm Drive,south of Paul Road
• Widen to six lanes 38,700 57,600 4,700 18,900 24.9%
Palm Drive, South Railroad Tracks
• Widen to six lanes 29,600 41,900 300 12,300 2.4%
Source: Table 5 Technical Memorandum to TA. 1 Total New Traffic = (2045 with Project - Existing Traffic) 2 Project Fair Share % = (Project Only Traffic / Total New Traffic) 3 General Plan Buildout (Horizon Year 2045) With Project

3.17. TRIBAL CULTURAL RESOURCES
Summary of Findings in the 2018 EIR (Section 4.17, page 4.17-1 et.seq.) As described in the 2018 EIR, and in compliance with AB 52 and SB 18, the City of DHS sent tribal consultation letters to ten Native American tribes on October 16, 2017. The letter included a project description and an explanation of entitlements associated with the proposed project. The following Tribes were contacted:

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• Agua Caliente Band of Cahuilla Indians
• Augustine Band of Cahuilla Indians
• Cabazon Band of Mission Indians
• Morongo Band of Mission Indians
• Ramona Band of Cahuilla Indians
• Santa Rosa Band of Mission Indians
• Soboba Band of Luiseno Indians
• Torres-Martinez Desert Cahuilla Indians
• Twenty-Nine Palms Band of Mission Indians
Tribes were given thirty days to request consultation under AB 52 and 90 days under SB 18. The 2018 EIR asserted that SB 18 did not apply to CEQA and the discussion would only include results of AB 52 consultation.

Impacts to Historic Resources
The 2018 EIR referred to the discussion of Historic Resources in Section 4.5.4.a.

Impacts to Tribal Resources
During the 30-day response period for AB 52 consultation, the City of Desert Hot Springs received two response letters from Native American Tribes, including the Agua Caliente Band of Cahuilla Indians and Soboba Band of Luiseno Indians. The Tribes requested the following:

Aqua Caliente Band of Cahuilla Indians
• A copy of the records search with associated survey reports and site records from the information center.
• A cultural resources inventory of the project area by a qualified archaeologist prior to any development activities in the area.
• Copies of any cultural resource documentation (report and site records) generated in connection with this project
Soboba Band of Luiseno Indians
• Government to Government Consultation in accordance with SB 18 (not applicable to CEQA)
• Tribe to continue to be a consulting entity for this project • Working in and around traditional use areas intensifies the possibility of encountering cultural resources during the construction/excavation phase. For this reason the Soboba Band of Luiseño Indians requests that Native American Monitor(s) from the Soboba Band of Luiseño Indians Cultural Resource Department to be present during any ground disturbing proceedings, including surveys and archaeological testing.

Although no Tribal Cultural Resources were identified within the project site during AB 52 consultation, the 2018 EIR determined project applicant(s) proposing development within the project site must hire a Native American Monitor to be present during any ground disturbing activities, including surveys and archaeological testing (implemented with Mitigation Measure Item Number: 1.

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TCR-1), to ensure that no unknown subsurface TCRs were impacted during development of the proposed project. Should buried tribal cultural resource deposits be encountered, the monitor could request that construction be halted and notify a qualified archaeologist to investigate the resource. The 2018 EIR concluded that impacts to TCRs from implementation of the DLVSP would be less than significant with implementation of mitigation measure TCR-1.

Cumulative Impacts
The 2018 EIR determined development within the DLVSP project site would result in less than significant cumulative impacts because Mitigation Measure TCR-1 ensures that any unknown TCRs uncovered during construction activities will be adequately protected and preserved.

Mitigation Measures
The following Mitigation Measure is from pages 4.17-6 of the 2018 EIR.

TCR-1 An approved Native American Cultural Resource Monitor shall be present during ground-disturbing activities (including archaeological testing and surveys). Should buried tribal cultural resources deposits be encountered, the monitor may request that construction be halted, and the monitor shall notify a qualified archaeologist, meeting the Secretary of Interior’s Standards and Guidelines for Professional Qualifications, to investigate and, if necessary, prepare a mitigation plan for submission to the State Historic Preservation Officer (SHPO) and the Agua Caliente Tribal Historical Preservation Office (THPO).

Analysis of the Proposed Project
In compliance with AB 52 and SB 18, the City of DHS sent tribal consultation letters to 14 Native American tribes on February 25, 2025. The letter included a project description, and an explanation of entitlements associated with the proposed project. The following Tribes were contacted:
• Agua Caliente Band of Cahuilla Indians
• Augustine Band of Cahuilla Mission Indians
• Cabazon Band of Mission Indians
• Cahuilla Band of Indians
• Los Coyotes Band of Cahuilla and Cupeno Indians
• Morongo Band of Mission Indians
• Quechan Tribe of the Fort Yuma Reservation
• Ramona Band of Cahuilla Indians
• San Manuel Band of Mission Indians
• Santa Rosa Band of Cahuilla Indians
• Serrano Nation of Mission Indian
• Soboba Band of Luiseno Indians
• Torres Martinez Desert Cahuilla Indians
• Twenty-Nine Palms Band of Mission Indians
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The City requested the Tribes respond by May 26, 2025 (90 day review period). To date (March 2025), only one Tribe, ACBCI, responded to the City in a letter dated March 12 2025. The letter stated a records check of the ACBCI registry identified previous surveys in the area that were positive for the presence of cultural resources. The ACBCI THPO requested consultation. To further protect potential tribal cultural resources, the Project is subject to Mitigation Measure TCR-1 of the 2018 EIR, which requires a tribal monitor be present during all ground-disturbing activities, which would reduce the impacts to Tribal Resources to less than significant levels.

Should other Tribes request consultation before the 90-day review period has ended (May 26, 2025), results of the consultation shall be incorporated as conditions of approval, if applicable.

Summary
Overall, the proposed Project will not result in any new significant impacts, cumulative impacts, or increase the severity of impacts already identified in the 2018 EIR. Development conducted pursuant to the mitigation measure set forth in the EIR, and in consultation with ACBCI in conformance with AB 52 and SB 18, will ensure potential impacts associated with tribal resources are reduced to less than significant levels.

3.18. UTILITIES AND SERVICE SYSTEMS
Summary of Findings in the 2018 EIR (Section 4.18, page 4.18-1 et.seq.) As described in the 2018 EIR, domestic water for the majority of the City of Desert Hot Spring was provided by Mission Springs Water District (MSWD) and a limited portion of the City, including the project site, was located within the service area of CVWD.

CVWD delivers irrigation and domestic (drinking) water, collects and recycles wastewater, provides regional storm water protection, replenishes the groundwater basin, and promotes water conservation within a large portion of the Coachella Valley. The project site is located in the CVWD service area for wastewater; however, CVWD had neither the infrastructure nor immediate plans to provide potable water service to the project site. Sanitary sewer collection and treatment facilities for the majority of the City of Desert Hot Spring were provided by MSWD.

The City has a franchise agreement with Desert Valley Disposal Inc. (DVD) for the provision of complete residential, commercial and roll-off trash disposal.

The project site’s electric power service is provided by Southern California Edison Company (SCE).

Overhead power lines on wooden power poles run along the entire stretch of the southern boundary of the project site—similar power lines traverse the central portion of the project site along the southern end of Varner Road.

Exceedance of Water Quality Requirements
The 2018 EIR states that with implementation of Regulatory Requirement RR-8 and RR-12, all proponents proposing developments within the project site that disturb one acre or more would be required to prepare and implement a SWPPP during construction and prepare and implement Item Number: 1.

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a WQMP for post construction at each site. This would ensure that a project’s impact to water quality would be reduced to less than significant levels with the proper operation and maintenance of structural BMPs, continued use of non-structural BMPs such as education programs for local residents, property owners, operators, tenants, occupants, or employees, and continued inspection of low impact development/treatment BMPs such as inspection of infiltration basins.

Construction or Expansion of Wastewater Treatment Facilities As described in the 2018 EIR, ultimate wastewater service to the project site would be provided from the MSWD Regional Wastewater Treatment Plant, generally located at the northwest corner of Little Morongo Road and 20th Avenue. Connection to the Regional Wastewater Treatment Plant would be provided via a proposed 8-inch force-main sewer pipeline extending from the approximately 1.0-acre proposed wastewater facility to be located in the project’s southeast corner. The wastewater facility site would also provide a sewer lift station to pump wastewater from the project site to the MSWD Regional Wastewater Treatment Plant.

The 2018 EIR described two potential alignment options to connect the project site to MSWD’s Regional Wastewater Treatment Plant. The preferred option (Option A) was to connect from the DLVSP’s wastewater facility site north in West Drive, west in Varner Road, north from Varner Road through the Willow Hole Conservation Area within a public utility easement, then west within 20th Avenue right-of-way to the point of connection near the intersection of Little Morongo Road and 20th Avenue. The second option (Option B) was to connect from the DLVSP’s wastewater facility site north in West Drive, east in Varner Road right-of-way, north in Palm Drive right-of-way, and then west in 20th Avenue right-of-way, to the point of connection near the intersection of Little Morongo Road and 20th Avenue. Other onsite sewer facilities would include 8-inch sewer pipelines, within the internal roadway system, connecting the development areas to an onsite wastewater facility site and sewer lift station.

As described in the 2018 EIR, before the MSWD Regional Wastewater Treatment Plant was operational or during early development with minimal wastewater from marijuana cultivation, interim underground storage facilities could be used, with wastewater periodically trucked to a regional treatment plant. These storage facilities, located either at the onsite wastewater facility or within development parking areas, would eventually connect to the MSWD system, and those in parking areas would also store recycled water from cultivation irrigation, unsuitable for standard treatment plants, until the regional system was ready.

Regarding the cannabis cultivation buildings with the DLVSP, the 2018 EIR described the potential wastewater systems as being either reverse osmosis (RO) or hydroponics. The bi-product of RO is the accumulation of concentrated levels of total dissolved solids (TDS) and brine solutions in filter, which can be hazardous to the groundwater supply if not treated and disposed of properly by a third party licensed hazardous waste hauler. Additionally, if RO was utilized, the EIR stated that documentation of how concentrated levels of TDS and brine solutions would be disposed of and the licensed entity that would receive the TDS waste must be provided to the City.

Hydroponics is a method of growing plants in a water-based, nutrient rich solution. Prior to issuance of a Certificate of Occupancy, the 2018 EIR stated that any proponent that proposed to Item Number: 1.

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recycle and discharge onsite wastewater involving the use of a hydroponic grow system would be required to notify the City prior to initial discharge of hydroponic water media, and that testing would be performed at the time of discharge by a licensed wastewater testing firm. If testing revealed an exceedance in the maximum allowable threshold for dissolved solids, the facility would halt any further discharge until appropriate filtering methods had been replaced/installed and re-tested by the wastewater testing firm until discharge levels of dissolved solids fell below the maximum allowable threshold.

The 2018 EIR concluded that in order for the project site to be served by MSWD, CVWD and MSWD would enter into an agreement whereby CVWD relinquished the right to serve the project site in favor of MSWD. Therefore, development of interim wastewater underground storage facilities onsite could serve early project operations until the offsite sewer line could be constructed to connect to the proposed MSWD Regional Wastewater Treatment Plant, which would supply long-term wastewater services to the project site. Impacts were found to be less than significant
Construction or Expansion of Storm Water Drainage Facilities As mapped by FEMA in 2018, the project site and its surrounding area were constrained by flooding and drainage conditions and the 100-year flood plain with no base flood elevations determined. The DLVSP site would be developed with nine (9) onsite storm water infiltration basins that would comply with the Stormwater Management and Discharge Controls stipulated in Chapter 13.08 of the Desert Hot Springs Municipal Code (Ordinance 1997-02). The basin capacities proposed in 2018 were sized to contain the 100-year, 24-hour duration storm event and therefore meet the City’s requirements for Stormwater Management and Discharge Controls and minimize the discharge and transport of storm flows to natural drainage facilities south of the project site where historic flows from the site were deposited. Impacts were found to be less than significant.

Sufficient Water Supplies to Serve the Project
A Water Supply Assessment (WSA) was prepared for the DLVSP to provide the projected water demand and supply conditions associated with build out of the DLVSP. The 2018 EIR considered two options for water supply sources: connection to MSWD’s existing water facilities or drilling an onsite groundwater well to be located at the northwest corner of Planning Area 1 to provide onsite treatment, a ground storage reservoir, a pump station, a hydropneumatic tank, and water pipelines. Because the project site was in CVWD’s Water Service Area, a Water Service Agreement would need to be finalized between CVWD and MSWD in order to address roles of both agencies in providing potable water to the project site.

As described in the 2018 EIR, the DLVSP projected total indoor and outdoor domestic water demand was expected to be approximately 405.44 acre-feet of water per year (AFY), or 0.35 percent of the total water supply (114,600 acre-feet per year) for the CVWD service area in 2020 and would represent 0.20 percent of the total water supply (194,300 AFY) for the CVWD service area in 2040 as identified in the CVWD 2015 UWMP for the period from 2020 to 2040, and as shown in EIR Table 4.18-2, duplicated below.

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Based on the information, analysis, and findings documented in the DLVSP WSA, there was substantial evidence to support a determination that there would be sufficient water supplies to meet the demands of the project and future demands of the project plus all forecasted demands in the next 20 years.

The 2018 EIR concluded that if either Option 1 (connecting to MSWD’s supply) or Option 2 (a well) was implemented, a Replenishment Assessment would need to be processed in accordance with the State Water Code prior to development. If approved by the State Water Resources Control Board (SWRCB), all water wells (under Option 2) would be required to be equipped with a water measuring device to be maintained by CVWD. Under Option 1, the project would also require a water measuring device to be maintained by MSWD. With implementation of State requirements and CVWD and MSWD monitoring of the project’s water supply source, the 2018 EIR determined full build-out of the DLVSP would have a less than significant impact on groundwater resources.

Adequate Capacity for Wastewater Treatment Provider
During the writing of the 2018 EIR, the MSWD Regional Wastewater Treatment Plant was being designed with an anticipated construction date of late 2019. See discussion under Construction or Expansion of Wastewater Treatment Facilities, above, for description of proposed wastewater treatment options. The MSWD Regional Wastewater Treatment Plant was anticipated to have adequate capacity considering it was being developed to support growing demand, thus the 2018 EIR concluded that MSWD would have sufficient capacity to provide the project site with wastewater services.

Sufficient Landfill Capacity
According to the 2018 EIR, the DLVSP had potential to generate 17,480.28 tons/year of solid waste that could need disposal in a county landfill, which accounted for 0.86 percent of the solid waste generation in the County of Riverside, reducing the overall landfill capacity by approximately 0.22 percent. The 2018 EIR concluded that County landfills had sufficient capacity to serve the DLVSP, and impacts would be less than significant.

Regulations Related to Solid Waste
As described in the 2018 EIR, consistent with the City’s Municipal Code, the project applicant(s) were required to submit a construction and demolition waste plan, implemented with Regulatory Requirement RR-25, to ensure that construction waste was adequately handled and result in a less than significant impact during construction activities.

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During operation of future projects within the project site, operators would require solid waste services that would be provided by DVD. In conformance with AB939, each development within the DLVSP would be supplied with a container for recyclable items that is separate from the solid waste container. The EIR concluded that the DLVSP would have a less than significant impact with regard to federal, State, and local statutes pertaining to solid waste.

Energy Resources
The 2018 EIR considered electrical load calculations for two separate options: 100 percent cultivation within the industrial area and 60 percent cultivation within the industrial area. Since cannabis cultivation has a high electrical energy demand, the 100 percent cultivation option was considered the worst case scenario for the project, and it was the option analyzed in the EIR.

The calculated total build out load was 78.5 MVA for the 100 percent cultivation option. This option would result in 1,334 Amps on the 33KV which would equate to 3 fully loaded 33KV circuits required to serve the site. According to the 2018 EIR, SCE might choose to install a 115KV distribution station on the project site to supply power to development within the DLVSP, for which an acre of land within the DLVSP site was set aside to allow SCE to develop a substation to meet a portion of the project demand. The DLVSP also included roof top solar panels and some covered areas of parking lots to assist with meeting a portion of the project’s needs.

Cumulative Impacts
The 2018 EIR determined that cumulative impacts associated with water supply, wastewater treatment, stormwater and drainage control, landfill capacity and diversion, and electrical use would be less than significant with adherence to standard regulatory requirements and appropriate site design that conforms to City requirements.

Mitigation Measures
No mitigation measures were required.

Regulatory Requirements
The following Regulatory Requirements are from pages 4.18-16 and -17 of the 2018 EIR.

RR-25 Prior to issuance of construction permits, contractors shall prepare and implement Construction and Demolition Waste Reduction/Recycling Plans, for review and approval by the City Engineer or his/her designee.

The following regulatory requirements from Section 4.8, Hazards and Hazardous Materials and Section 4.9, Hydrology and Water Quality, apply to Utilities and Service Systems as well:

RR-8 Prior to issuance of building permits on vacant or undeveloped parcels that will be developed within the project site, the project applicant(s) shall prepare a Storm Water Pollution Prevention Plan (SWPPP) for all developments within the project site that disturb one acre or more. The SWPPP shall provide a list of Best Management Practices (BMPs) for the control and treatment of runoff from the project site.

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RR-12 Prior to issuance of building permits on vacant parcels within the DLVSP, the project applicant(s) shall prepare a WQMP for post construction conditions which shall include a list of appropriate Best Management Practices (BMPs) for the control and treatment of runoff from the project site.

Analysis of the Proposed Project
The proposed Specific Plan amendment and development project would decrease the development intensities previously proposed in the DLVSP. Buildout of the proposed development (1.16 million SF) would result in a 24.5 percent reduction in industrial space, and a 100 percent reduction in commercial space previously analyzed in the 2018 EIR. Therefore, it can be assumed that demands for water, wastewater, telecommunication facilities, energy infrastructure, and solid waste disposal would be less than those previously analyzed in the EIR under maximum buildout conditions, as detailed below.

Wastewater
As with the 2018 DLVSP, in order for the project site to be served by MSWD, CVWD and MSWD would enter into an agreement whereby CVWD relinquishes the right to serve the project site in favor of MSWD. The Project is able to extend offsite sewer lines to connect to the MSWD Regional Wastewater Treatment Plant (RWTP), which is now in operation and able to supply long-term wastewater services to the project site. The MSWD RWTP was developed to support growing demand; therefore, consistent with the findings of the 2018 EIR, MSWD would have sufficient capacity to provide the project site with wastewater services, although demand would be substantially reduced because of the reduction in type of use and overall square footage of the currently proposed Project.

Buildout of the proposed development (1.16 million SF) would result in a 24.5 percent reduction in industrial space, and a 100 percent reduction in commercial space previously analyzed in the 2018 EIR. Therefore, buildout of the Project would be less intense than that previously analyzed in the EIR due to the reduction in building square footage, and would represent a less than significant impact on wastewater and sanitary sewer services.

Stormwater
The Project would provide three (3) on-site stormwater infiltration basins that during the life of the project will comply with the Stormwater Management and Discharge Controls stipulated in Chapter 13.08 of the Desert Hot Springs Municipal Code. The provided basin capacities are sized to contain the 100-year, 24-hour duration storm event and therefore meet the City’s requirements on Stormwater Management and Discharge Controls and minimize the discharge and transport of pollutants associated with the new developments. Impacts would be less than significant. (Also see Section 3.9 Hydrology and Water Quality).

Water
A connection to the Desert Hot Springs Pressure Zone will be required to provide water service to the site; this will require the construction of an 8-inch water line within Varner Road from the eastern end of the site to Palm Drive, which will connect to an 8-inch water line to be installed Item Number: 1.

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within Palm Drive that will travel north where it will connect to an existing 18-inch water line just south of the Dillon Road/Palm Drive intersection. From the Dillon Road/Palm Drive intersection, there is an existing 8-inch pipeline that travels west along Dillon Road and connects to a 24-inch pipeline at the intersection of Dillon Road and Atlantic Avenue.

As discussed in Section 3.9 Hydrology and Water Quality, the total projected water demand for the Project is 72.96 AFY, or 0.591 acre-feet per acre. The 2018 DLVSP project was projected to generate a demand of 405.44 AFY, meaning the proposed Project’s water demand of 72.96 AFY represents an 82 percent reduction in projected water demands previously analyzed in the 2018 EIR. Therefore, buildout of the Project would be less intense than what was previously analyzed in the EIR, and impacts to water supply would be substantially reduced, and less than significant.

Solid Waste
According to Jurisdiction Landfill Tonnage Reports from the Department of Waste Resources10, 2,725,457 total tons of solid waste was hauled to County landfills in 2023. The 2018 EIR estimated that Industrial development generates approximately 0.0108 tons/SF/year of solid waste. Using the same waste generation factor, maximum buildout of the proposed Project (1.5 million SF) would generate 16,200 tons/year. The 2018 DLVSP was anticipated to generate approximately 17,480 tons/year of solid waste, therefore the Project reduces anticipated solid waste generation by 1,280 tons/year. Therefore, buildout of the Project would be less intense than that previously analyzed in the 2018 EIR due to the reduction in building square footage, and impacts would remain less than significant.

Energy
The 2018 EIR considered electrical load calculations based on maximum buildout potential of the DLVSP, and assuming cannabis cultivation which has high electrical energy demand. According to the DLVSP CalEEMod outputs (DLVSP EIR Appendix B), the 2018 project was estimated to demand 15,887,430 kWh annually (mitigated). The proposed Specific Plan amendment and development project would decrease the development intensities previously proposed in the DLVSP. According to the CalEEMod outputs for the proposed Project (Appendix A), the Project would generate a demand of 7,842,510 kWh annually (mitigated), which is a 50 percent energy demand reduction compared to the 2018 DLVSP project. Therefore, buildout of the Project would be less intense than that previously analyzed in the 2018 EIR due to the reduction in building square footage and type of use, and impacts would remain less than significant. 10 RDRS Report 1: Overall Jurisdiction Tons for Disposal and Disposal Related Uses. CalRecyle. https://www2.calrecycle.ca.gov/RecyclingDisposalReporting/Reports/OverallJurisdictionTonsForDisposal Item Number: 1.

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Summary
Implementation of proposed Project would not result in any new impacts, cumulative impacts, or increase the severity of a previously identified significant impact as previously analyzed in the 2018 EIR. The proposed Project will be subject to the same Regulatory Requirements as the 2018 project. Overall, impacts are expected to be comparable to or less than those previously identified in the EIR due to the reduction in buildout intensity, and the elimination of cannabis cultivation and commercial uses. Therefore, implementation of the Specific Plan amendment and buildout of the Project would not result in any new adverse impacts or increase the severity of previously identified significant impacts associated with utilities and service systems in the 2018 EIR.

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A
Appendix A
Air Quality and Greenhouse Gas Report
Item Number: 1.

Air Quality and Greenhouse Gas Report
DHS Varner Road Specific Plan
Desert Hot Springs, Riverside County, CA
Prepared by:

Terra Nova Planning & Research, Inc.®
42635 Melanie Place, Suite #101
Palm Desert, California 92211
December 2025
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Air Quality and Greenhouse Gas Report – December 2025
DHS Varner Road Specific Plan
2 Table of Contents
ES EXECUTIVE SUMMARY .................................................................................................................................... 4 ES.1 AIR QUALITY ........................................................................................................................................................ 4 ES.2 GREENHOUSE GASES.............................................................................................................................................. 5 1 INTRODUCTION ................................................................................................................................................ 6

1.1SITE LOCATION........................................................................................................................................................ 6

1.22018 PROJECT........................................................................................................................................................ 6

1.3PROPOSED PROJECT ................................................................................................................................................. 7 2 AIR QUALITY SETTING ..................................................................................................................................... 12

2.1 ATMOSPHERIC SETTING.......................................................................................................................................... 12

2.2 CRITERIA POLLUTANTS ........................................................................................................................................... 13

2.2.1 Toxic Air Contaminants .............................................................................................................................14

2.3 CURRENT CONDITIONS ........................................................................................................................................... 15

2.3.1 Regional Air Quality – Air Basin.................................................................................................................16

2.3.2 Local Air Quality – Source Receptor Area..................................................................................................17

2.4 REGULATORY BACKGROUND.................................................................................................................................... 19

2.4.1 Federal Regulations...................................................................................................................................20

2.4.2 State Regulations......................................................................................................................................20

2.4.3 Local Regulations ......................................................................................................................................22

2.4.4 Air Quality Management Planning............................................................................................................23 3 PROJECT AIR QUALITY IMPACT........................................................................................................................ 27

3.1 INTRODUCTION..................................................................................................................................................... 27

3.2 STANDARDS OF SIGNIFICANCE.................................................................................................................................. 27

3.3 METHODOLOGY.................................................................................................................................................... 27

3.4 CONSTRUCTION EMISSIONS..................................................................................................................................... 32

3.5 OPERATIONAL EMISSIONS ....................................................................................................................................... 33

3.6 SENSITIVE RECEPTOR IMPACTS................................................................................................................................. 34

3.7 AIR QUALITY MANAGEMENT PLANNING .................................................................................................................... 35

3.8 ODORS................................................................................................................................................................ 36

3.10 CEQA DETERMINATION....................................................................................................................................... 36 4 CLIMATE CHANGE SETTING............................................................................................................................. 40

4.1 INTRODUCTION TO GREENHOUSE GASES AND CLIMATE CHANGE .................................................................................... 40

4.1.1 Greenhouse Gases.....................................................................................................................................40

4.1.2 Climate Change in California.....................................................................................................................42

4.1.3 GHGs and Health Impacts.........................................................................................................................45

4.2 REGULATORY SETTING............................................................................................................................................ 45

4.2.1 International..............................................................................................................................................45

4.2.2 Federal ......................................................................................................................................................46

4.2.3 State ..........................................................................................................................................................47

4.2.4 Local ..........................................................................................................................................................49 5 PROJECT GREENHOUSE GAS IMPACT............................................................................................................... 51

5.1 INTRODUCTION..................................................................................................................................................... 51

5.2 STANDARDS OF SIGNIFICANCE.................................................................................................................................. 51

5.3 METHODOLOGY.................................................................................................................................................... 51

5.4 CONSTRUCTION EMISSIONS..................................................................................................................................... 51

5.5 OPERATIONAL EMISSIONS ....................................................................................................................................... 52

5.7 CEQA DETERMINATION ......................................................................................................................................... 53 6 REFERENCES.................................................................................................................................................... 55 Item Number: 1.

Air Quality and Greenhouse Gas Report – December 2025
DHS Varner Road Specific Plan
3 7 APPENDICES.................................................................................................................................................... 57 Appendix A Desert Hot Springs Varner Road Specific Plan Detailed Report, CalEEMod Version 2022.1, prepared by Terra Nova Planning & Research, Inc. September 11, 2025. ...................................................................58

APPENDIX B DESERT HOT SPRINGS VARNER ROAD SPECIFIC PLAN- HRA ELECTRIC VEHICLE MITIGATION DETAILED REPORT, CALEEMOD VERSION 2022.1, PREPARED BY TERRA NOVA PLANNING & RESEARCH, INC. SEPTEMBER 11, 2025. .......................... 59

APPENDIX C DHS VARNER ROAD OPERATIONAL HEALTH RISK ASSESSMENT (HRA) ANALYSIS, PREPARED BY KW AIR QUALITY & NOISE LLC. OCTOBER 2, 2025................................................................................................................................ 60 Table List
TABLE 1-1 2018 PROJECT LAND USE DEVELOPMENT SUMMARY ................................................................................................ 6 TABLE 1-2 PROJECT LAND USE DEVELOPMENT SUMMARY......................................................................................................... 8 TABLE 2-1 CRITERIA POLLUTANTS AND HEALTH IMPACTS ........................................................................................................ 14 TABLE 2-2 AMBIENT AIR QUALITY STANDARDS ..................................................................................................................... 15 TABLE 2-3 REGIONAL ATTAINMENT STATUS – COACHELLA VALLEY............................................................................................ 16 TABLE 2-4 OZONE MONITORING DATA ............................................................................................................................... 18 TABLE 2-5 PARTICULATE MATTER 10 MONITORING DATA ...................................................................................................... 19 TABLE 2-6 SCAQMD AIR QUALITY MASS DAILY THRESHOLDS ................................................................................................ 24 TABLE 3-1 PROJECT DEVELOPMENT ASSUMPTIONS ................................................................................................................ 28 TABLE 3-2 MAXIMUM DAILY CONSTRUCTION-RELATED EMISSIONS SUMMARY ........................................................................... 32 TABLE 3-3 MAXIMUM DAILY OPERATIONAL-RELATED EMISSIONS SUMMARY (POUNDS PER DAY) .................................................... 34 TABLE 4-1 SOURCES OF GHGS FROM HUMAN ACTIVITIES ....................................................................................................... 41 TABLE 5-1 PROJECTED GHG EMISSIONS SUMMARY WITH MITIGATION...................................................................................... 53 Exhibit List
EXHIBIT 1-1 REGIONAL LOCATION MAP ................................................................................................................................ 9 EXHIBIT 1-2 PROJECT VICINITY MAP................................................................................................................................... 10 EXHIBIT 1-3 CONCEPTUAL SITE PLAN.................................................................................................................................. 11 Figure List
FIGURE 2-1: BOUNDARIES OF THE SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT............................................................... 12 FIGURE 2-2: SCAQMD MONITORING STATIONS IN THE COACHELLA VALLEY .............................................................................. 17 FIGURE 4-1: ANNUAL STATEWIDE GHG EMISSIONS COMPARED TO THE 2020 GHG LIMIT ........................................................... 43 FIGURE 4-2: 2023 GHG EMISSIONS BY ECONOMIC SECTOR (% OF TOTAL CALIFORNIA EMISSIONS) .................................................. 43 Item Number: 1.

Air Quality and Greenhouse Gas Report – December 2025
DHS Varner Road Specific Plan
4 ES EXECUTIVE SUMMARY
This Air Quality and Greenhouse Gas Report was prepared to accompany the Addendum to the 2018 Desert Land Ventures Environmental Impact Report (EIR). In accordance with the California Environmental Quality Act (CEQA), the Addendum is being prepared to evaluate the potential environmental impacts of revising the 2018 Desert Land Ventures Specific Plan (DLVSP), now titled DHS Varner Road Specific Plan. The purpose of this Report is to analyze potential air quality and greenhouse gas (GHG) impacts of the proposed Project as compared to those previously identified in the 2018 Desert Land Ventures EIR.

The project site consists of 123± acres of vacant land located in the northwest portion of the Coachella Valley within the incorporated area of the City of Desert Hot Springs in Riverside County, California. The 2018 DLVSP allowed ±1.5 million square feet of Mixed Use (Industrial) development, ±359,000 square feet of Mixed Use (Commercial) development and 150 hotel rooms, herein referred to as the “2018 Project”. The 2018 Project was cannabis-centric, and was analyzed as such, including substantial cultivation square footage. The Project revises the 2018 land use plan to allow up to 1,500,000 square feet of industrial space only and proposes distribution warehouse uses, herein referred to as the proposed “Project”.

Section 1 of this report introduces the proposed Project. Sections 2 and 4 provide background information on air quality and climate change. Sections 3 and 5 analyze the potential impacts of the Project on air quality and greenhouse gas emissions, respectively.

ES.1 Air Quality
The Project is located in the Coachella Valley portion of the Salton Sea Air Basin, within the jurisdictional boundary of the South Coast Air Quality Management District (SCAQMD). The Project would comply with the strategies and rules established in SCAQMD’s applicable air quality plans.

The emissions of criteria air pollutants projected to result from the Project were calculated using the California Emissions Estimator Model (CalEEMod) Version 2022.1. The analysis in this report found that daily construction emissions will not exceed SCAQMD’s thresholds for controlled air pollutants. However, daily operational emissions will exceed NOx thresholds established by SCAQMD for the duration of the Project. Exceedance of NOx is directly related to the site’s high traffic volume as a distribution/storage facility with office space. To reduce impacts and follow air quality standards, mitigation measures were applied to control and reduce emissions from construction and operation. Construction emissions were reduced to below significance. Operational emissions were reduced but NOx emissions continued to exceed SCAQMD significance thresholds.

Similar to findings in the 2018 EIR, buildout of the proposed Project would exceed the SCAQMD criteria thresholds for long-term operations, even with mitigation, and therefore would result in significant and unavoidable cumulative impacts. However, the proposed Project would reduce emission impacts when compared to the 2018 Project and therefore would not result in any new adverse cumulative impacts or increase the severity of cumulative impacts described in the 2018 EIR.

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Air Quality and Greenhouse Gas Report – December 2025
DHS Varner Road Specific Plan
5 ES.2 Greenhouse Gases
The Project’s greenhouse gas (GHG) emissions are subject to federal, state and the SCAQMD regulations pertaining to GHG emission reductions and reduction targets. CalEEMod was used to project the GHG emissions expected to result from construction and operation of the proposed Project. Based on the development review process provided in SCAQMD’s 2008 Interim CEQA GHG Significance Threshold for Stationary Sources, Rules and Plans, a tier system approach was taken to evaluate the Project’s potential for direct and indirect environmental impact.

Based on outputs from the Project-specific CalEEMod run, the Project is estimated to exceed SCAQMD annual threshold of significance (3,000 MTCO2e) during operation with feasible mitigation measures incorporated. Given the Project would substantially emit GHGs during operation, beyond acceptable levels, the development would be in direct violation of SCAQMD 2022 AQMP and AB 32 for GHG reduction goals. However, implementation of the proposed Project would not result in any new impacts or increase the severity of a previously identified significant impact as analyzed in the 2018 EIR. Overall impacts are expected to be less than those previously identified in the EIR due to the reduction in overall development intensity and square footage proposed in the Specific Plan and proposed development project.

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Air Quality and Greenhouse Gas Report – December 2025
DHS Varner Road Specific Plan
6 1 INTRODUCTION

1.1 Site Location
The DHS Varner Road Specific Plan (Project) proposes the buildout of 83.3±-acres for industrial use and

11.6±-acres for stormwater control, as well as the conservation of 28.5±-acres for open space/habitat preservation in the southernmost region of Desert Hot Springs in Riverside County, California (Exhibit 1- 1). The site is bounded by I-10 to the south and west, the Willow Hole Conservation Area created as part of the Coachella Valley Multiple Species Habitat Conservation Plan (CVMSHCP) to the north, and West Drive and undeveloped desert land to the east, as shown in Exhibit 1-2. The planning area is within the boundaries of the existing Desert Land Ventures Specific Plan (DLVSP). The Project is accessible from the north by Varner Road and the east by West Drive.

Surrounding properties are primarily undeveloped and unoccupied with the exception of the residential structure near the southeastern end of the site.

1.2 2018 Project
The 2018 Project consisted of 123.4 acres north and south of Varner Road and was divided into two planning areas. Planning Area 1 consisted of the southern/southeastern 62.9 acres and Planning Area 2 consisted of the northern/northwestern 38.7 acres. The remaining acreage (21.8 acres) would be set aside for development of the backbone infrastructure system including public roads and water, wastewater, and drainage infrastructure that would serve the project site.

Planning Area 1 comprised the Mixed-Use land use district and would accommodate a mix of industrial and commercial uses and up to 150 hotel rooms/keys. Planning Area 2 of the DLVSP included the preservation of 38.7 acres to be dedicated for open space conservation as part of the CVMSHCP’s Willow Hole Conservation Area, of which 35.6 acres was located at the northern portion of the project site and

3.1 acres is located at the northwestern end of the project site.

Table 1-1 provides a summary of the permitted land uses and the 2018 Project’s proposal for land use buildout.

Table 1-1
2018 Project Land Use Development Summary
Planning Area Specific Plan/Land Use Designation Land Use (acres)
Max. Gross
Square Feet
Max. Hotel
Room/Key
1 Mixed Use (Industrial) 64.9 1,538,757 150
Mixed Use (Commercial) 359,042
2 Open Space/ Conservation 38.7 -- --
Backbone Infrastructure 19.8 19.8 --
TOTAL 123.4 1,500,000 1,897,799
Source: Table 1-1 Land Use Development Summary, DLVSP DEIR, page 1-2.

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Air Quality and Greenhouse Gas Report – December 2025
DHS Varner Road Specific Plan
7 1.3 Proposed Project
As shown in Exhibit 1-3 and 1-4, Project encompasses approximately 123.4-acres of undeveloped desert land, the same area as the 2018 Project, of which 83.3±-acres is designated for industrial use, 11.6±- acres is for stormwater control, and 28.5±-acres is for open space/conservation. Off-site improvement areas include the segment of Varner Road west of the intersection with Palm Drive and the western segment of West Drive, immediately adjacent to the property. At the time of this Report a finalized Project site plan with specifications on project design has not been drafted. However, the DHS Varner Road Specific Plan establishes development guidelines that any proposed development, including the Project, must adhere to.

The following project description, consistent with the DHS Varner Road Specific Plan guidelines and development standards, assumes the maximum development capacity for each land use/planning area to analyze the site at capacity.

Planning Area 1A (PA-1A) is 83.3±-acres and zoned “Industrial.” The Project is allowed to build up to 1,500,000 sf of industrial space which may be used for warehousing and distribution, light manufacturing facilities, and/or mixed-use office/industrial. Supporting on-site improvements (i.e., parking, internal driveway system, sidewalks, drainage) are also permitted to allow for operational activities to occur in accordance with the City’s building and development code.

Planning Area 1B (PA-1B) is 11.6±-acres and zoned “Stormwater Control.” Located north of Varner Road, Planning Area 1B allows for the development of drainage and flood control channels to manage stormwater runoff in service of Planning Area 1A. No development besides flood control features are permitted.

Planning Area 2 (PA-2) is 28.5±-acres and zoned “Open Space.” PA-2 consists of two separate but contiguous areas, the larger area located north of Varner Road is 25.7±-acres and the smaller area, south of Varner Road in the northwest region of the Specific Planning Area, is 2.8±-acres. No development or modifications related to the property’s industrial land use is permitted. PA-2 will remain in its existing natural state, allowing for the site to be preserved and dedicated for open space conservation as part of the Coachella Valley Multiple Species Habitat Conservation Plan (CVMSHCP) Willow Hole Conservation Area, managed by the Coachella Valley Conservation Commission.

The DHS Varner Road Specific Plan includes a mobility plan for road improvements on Varner Road (approximately 1.07 miles) and West Drive (approximately 0.3 miles), given their partially paved and unpaved state, respectively. Other supporting infrastructure also includes the extension of sewer and water lines to connect the property to the local service system for wastewater collection and potable water. The utility lines will be routed underground and along adjacent corridor’s right-of-way as permitted. The sewer line will connect to the on-site wastewater facility consisting of a sewer lift station to pump wastewater from the property to the Mission Springs Water District’s (MSWD’s) Regional Wastewater Treatment Plant (RWTP). The Project’s water system will be connected to the Coachella Valley Water District (CVWD) existing water system which will require the construction of an 8-inch Item Number: 1.

Air Quality and Greenhouse Gas Report – December 2025
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8 water line within Varner Road from the eastern end of the site to Palm Drive, which will connect to an 8-inch water line to be installed within Palm Drive that will travel north where it will connect to an existing 18-inch water line just south of the Dillon Road/Palm Drive intersection. From the Dillon Road/Palm Drive intersection, there is an existing 8-inch pipeline that travels west along Dillon Road and connects to a 24-inch pipeline at the intersection of Dillon Road and Atlantic Avenue. Approximately 5.5 miles of roadway improvements are required in association with the proposed sewer and water utility extensions.

Table 1-2 provides a summary of the permitted land uses, consistent with the revised DHS Varner Road Specific Plan, and the Project’s proposal for land use buildout.

Table 1-2
Project Land Use Development Summary
Planning Area Specific Plan/Land Use Designation Land Use (acres)
Building Area
(square feet)
1A Industrial 83.3 1,500,000
1B Stormwater Control 11.6 N/A
2 Open Space/Conservation 28.7 N/A
TOTAL 123.4 1,500,000
Source: Desert Hot Springs Varner Road Specific Plan, February 2025; City of Desert Hot Springs General Plan, May 2020.

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Air Quality and Greenhouse Gas Report – December 2025
DHS Varner Road Specific Plan
12 2 AIR QUALITY SETTING

2.1 Atmospheric Setting
The Project site is within the Riverside County portion of the Salton Sea Air Basin (referred to as Coachella Valley Planning Area or Coachella Valley), under the jurisdiction of the South Coast Air Quality Management District (SCAQMD). The SCAQMD encompasses portions of Los Angeles, Orange, Riverside, and San Bernardino counties.

Figure 2-1: Boundaries of the South Coast Air Quality Management District Source: South Coast Air Quality Management District, Draft Final 2022 AQMP Figure 2-1 shows the location of the Coachella Valley within the boundaries of the Salton Sea Air Basin and the SCAQMD jurisdiction. The Coachella Valley Planning Area covers approximately 2,500 square miles. The area is bound by the San Jacinto and Santa Rosa Mountains to the west, the Little San Bernardino Mountains to the east, and spans from the San Gorgonio Pass in the north to the Salton Sea in the south. Elevations range from approximately 500 feet above sea level in the northern portion of the valley to above 150 feet below sea level near the Salton Sea.1 1 Final 2003 Coachella Valley PM10 State Implementation Plan.

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13 The Coachella Valley has a desert climate with hot summers, mild winters, and very little precipitation.

For four months each year, average temperatures are above 100 degrees Fahrenheit, and daily highs of approximately 110 degrees Fahrenheit in July and August. There is typically less than six inches of precipitation annually, most of which occurs in winter months or from late summer thunderstorms.2 The area is subject to frequent gusty winds. Wind conditions vary across the geography of the Valley, with the strongest and most consistent winds in the portion of the area closest to the San Gorgonio Pass.

Otherwise, stronger winds tend to occur in the middle of the Valley, with lighter winds in areas closer to the foothills. Strong winds can generate PM10 in the Coachella Valley, both through the natural distribution of blowsand, and by blowing sand and dust produced by human activity. Blowsand is a natural sand migration process, but when blown onto roadways can be further ground by moving vehicles and redistributed as fine particles.3 Strong winds can sweep up, suspend and transport large quantities of sand and dust, reducing visibility, and producing potentially significant health risks.

Wind also contributes to ozone levels in the Coachella Valley. While some ozone is formed in the Valley, the majority is formed photochemically from precursor chemicals emitted upwind in the western South Coast Air Basin and blown inland by the prevailing sea breeze. Concentrations of ozone are worst in the late spring and summer months when the heat increases the rate of reactions that form ozone and accelerates the evaporation of precursor chemicals.4

2.2 Criteria Pollutants
Criteria air pollutants are air pollutants for which acceptable levels of exposure have been determined and are regulated by Ambient Air Quality Standards (AAQS). The AAQS were established through the federal Clean Air Act (first enacted in 1963) and the California Clean Air Act (1988). The current criteria air pollutants are: ozone (O3), carbon monoxide (CO), particulate matter (PM10), fine particulate matter (PM2.5), nitrogen dioxide (NO2), lead (Pb), sulfur dioxide (SO2), and hydrogen sulfide (H2S).

Air pollution contributes to a wide variety of health impacts, including heart and lung illnesses, chronic health conditions, increased cancer rates, and premature death. For example, PM2.5 pollution is linked with hundreds of emergency room visits for respiratory and cardiovascular disease annually, as well as brain health and adverse birth outcomes. Elevated ozone levels in California are also associated with hospitalizations, lost school days, and premature death. 5 These health impacts disproportionately impact residents of low-income and disadvantaged communities.

Table 2-1 below outlines the primary human-caused emissions sources of criteria pollutants, as well as the effects of these pollutants on human health.
2 Final 2003 Coachella Valley PM10 State Implementation Plan. 3 Ibid. 4
Coachella Valley Extreme Area Plan for 1997 8-Hour Ozone Standard. 5 California Air Resources Board Proposed 2022 State SIP Strategy (August 2022).

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Air Quality and Greenhouse Gas Report – December 2025
DHS Varner Road Specific Plan
14 Table 2-1
Criteria Pollutants and Health Impacts
Criteria Pollutant Source Health Effects
Ozone (O3) A secondary pollutant resulting from
hydrocarbons and oxides of nitrogen,
emitted by cars, solvents, factories and
pesticides, reacting in the presence of
sunlight.

Difficulty breathing, chest pains,
aggravation of lung diseases such as
asthma, emphysema, and chronic
bronchitis. Shortness of breath,
coughing, and lung damage with
prolonged and chronic exposure.

Carbon Monoxide (CO) Fossil fuel combustion by vehicles, as well as household sources such as
some appliances, fireplaces, portable
generators, charcoal grills.

Headaches, dizziness, vomiting, and
nausea. Risk of loss of unconsciousness
or death.

Particulate Matter (PM10)
and Fine Particulate
Matter (PM2.5)
Fugitive dust from construction
projects and vehicles on unpaved
roads. Industrial smokestacks and
wildfires. Atmospheric formation from
SO2 and NOx.

Coughs, asthma, cancer, lung damage,
heart attacks, and premature death.

Nitrogen Dioxide (NO2) Fossil fuel combustion by vehicles, off road equipment, power generation,
and household appliances such as
furnaces, clothes dryers, ovens,
fireplaces.

Lung damage and irritation.

Lead (Pb) Lead smelters, ore and metals
processing, combustion of leaded
aviation fuel, waste incinerators,
utilities, and lead-acid battery
manufacturing facilities.

Damage to nervous system, kidney
function, immune system, reproductive
and developmental systems, and
cardiovascular systems.

Sulfur Dioxide (SO2) Combustion of fossil fuels by power plants and industries, refineries, and
diesel engines.

Irritates the nose, throat, and airways.

Coughing, shortness of breath,
tightness of chest. Individuals with
asthma at high risk for developing
issues.

Hydrogen Sulfide (H2S) Geothermal power plants, petroleum production, sewer gas.

Rotten egg smell, headache, skin
complications, respiratory damage.

Sources: CARB 2022 Scoping Plan Update, Environmental and Regulatory Setting, Table 3; SCAQMD Final 2022 Air Quality Management Plan, Appendix 1: Health Effects (November 2022).

2.2.1 Toxic Air Contaminants
According to §39655 of the California Health and Safety Code, a toxic air contaminant (TAC) is “an air pollutant which may cause or contribute to an increase in mortality or in serious illness, or which may pose a present or potential hazard to human health.” The Health and Safety Code definition of TACs also covers substances listed as hazardous air pollutants pursuant to §7412 of Title 42 of the United States Code. TACs are identified and controlled by the California Air Resources Board (CARB) in conjunction with the Office of Environmental Health Hazard Assessment (OEHHA). As an exception, TACs used in pesticides are regulated by the Department of Pesticide Regulation.

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15 Notable TACs include asbestos, benzene, chloroform, as well as inorganic lead and arsenic. The particulate matter emitted by diesel-fueled engines, known as diesel particulate matter (DPM), is also identified by CARB as a TAC.6 To reduce exposure to TACs, CARB recommends minimum separation distances between new sensitive land uses, such as residences, and eight categories of existing sources:
high-traffic freeways and roads, distribution centers, rail yards, ports, refineries, chrome plating facilities, perchloroethylene dry cleaners, and large gas stations.7

2.3 Current Conditions
The National Ambient Air Quality Standards (NAAQS) and California Ambient Air Quality Standards (CAAQS) establish thresholds to determine whether the contaminant levels in the air are considered unhealthy. The current federal and state standards are shown in Table 2-2:

Table 2-2
Ambient Air Quality Standards
Pollutant Averaging Time California Standards National Standards Concentrations1 Primary Secondary
Ozone (O3) 1 Hour 0.09 ppm --
8 Hour 0.070 ppm 0.070 ppm
Particulate Matter
(PM10)
24 Hour 50 μg/m3 150 μg/m3
AAM2 20 μg/m3 --
Fine Particulate
Matter (PM2.5)
24 Hour -- 35 μg/m3
AAM 12 μg/m3 9.0 μg/m3 15 μg/m3
Carbon Monoxide 1 Hour 20 ppm 35 ppm --
8 Hour 9.0 ppm 9 ppm --
Nitrogen Dioxide
(NO2)
1 Hour 0.18 ppm 100 ppb --
AAM 0.030 ppm 53 ppb
Sulfur Dioxide
(SO2)
1 Hour 0.25 ppm 75 ppb --
3 Hour -- -- 0.5 ppm
24 Hour 0.04 ppm 0.14 ppm --
AAM -- 0.030 ppm --
Lead
30 Day Average 1.5 μg/m3 -- --
Calendar Quarter -- 1.5 μg/m3
Rolling 3-Month
Average -- 0.15 μg/m3
Visibility Reducing
Particles 8 Hour -- No
National
Standards
Sulfates 24 Hour 25 μg/m3
Hydrogen Sulfide 1 Hour 0.03 ppm (42 μg/m3)
Vinyl Chloride 24 Hour 0.01 ppm (26 μg/m3) 1 μg/m3 = micrograms per cubic meter of air 2 AAM = Annual Arithmetic Mean Source: California Air Resources Board, Ambient Air Quality Standards (July 2024) https://ww2.arb.ca.gov/sites/default/files/2024-08/AAQS%20Table_ADA_FINAL_07222024.pdf (accessed November 2025). 6 California Air Resources Board, Toxic Air Contaminant Identification Reports https://ww2.arb.ca.gov/resources/documents/toxic-air-contaminant-identification-reports (accessed November 2025). 7 CalEPA and CARB, Air Quality and Land Use Handbook: A Community Health Perspective (April 2005).

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Air Quality and Greenhouse Gas Report – December 2025
DHS Varner Road Specific Plan
16 The air quality of an area is in attainment if the measure ambient air pollutant levels, for the pollutants in the above table, are not exceeded and all other standards are not exceeded at any time in any consecutive three-year period. Attainment also assumes the national standards (other than O3, PM10, and those based on annual averages or arithmetic mean) are not exceeded more than once per year.

The ozone standard is in attainment when the fourth highest 8-hour concentration in a year, averaged over three years, is equal to or less than the standard. For PM10, the 24-hour standard is attained when 99% of the daily concentrations, averaged over three years, are equal to or less than the standard.

Pursuant to the Federal Clean Air Act, areas that do not meet these standards must prepare State Implementation Plans (SIPs) establishing strategies and deadlines for attainment of the NAAQS and CAAQS. Additionally, air quality districts with non-attainment areas under their jurisdiction must prepare attainment plans providing steps for the implementation, maintenance, and enforcement of the air quality standard within the required timeframe.

2.3.1 Regional Air Quality – Air Basin
The Project is located in the Coachella Valley Planning Area within the Salton Sea Air Basin (SSAB). The SSAB is under the jurisdiction of the South Coast Air Quality Management District (SCAQMD) and the Imperial County Air Pollution Control District (ICAPCO).

Table 2-3 shows the Coachella Valley’s attainment status for the criteria air pollutants, as designated by the EPA. The Coachella Valley is designated as being in nonattainment for regional levels of particulate matter (PM10) and ozone (O3).

Table 2-3
Regional Attainment Status – Coachella Valley
Criteria Pollutant Attainment Status
Ozone (O3) Nonattainment (Severe-15 (2015); Extreme (2008)) Carbon Monoxide (CO) Attainment
Fine Particulate Matter (PM2.5) Attainment
Particulate Matter (PM10) Nonattainment (Serious)
Nitrogen Dioxide (NO2) Attainment
Lead (Pb) Attainment
Sulfur Dioxide (SO2) Attainment
Source: EPA Green Book (Updated October 31, 2025).

Ozone (O3): Ozone is formed through the reaction of precursor chemicals reacting under sunlight. Given the dispersing nature of air pollutants, the Coachella Valley is subject to the aggregate impacts of densely populated neighboring jurisdictions in the South Coast Air Basin (SCAB). Nitrogen Oxides (NOx) and Volatile Organic Compounds (VOCs) emitted in the SCAB react and form ozone. These precursors, as well as ozone, are transported by wind to the Coachella Valley. Ozone levels in the Coachella Valley are therefore primarily a result of emissions blown inland from the SCAB by the prevailing sea breeze, resulting in high concentrations in the San Fernando Valley, San Gabriel Valley, and Coachella Valleys.8 8 South Coast Air Quality Management District, Draft Final 2022 Air Quality Management Plan, Desert Nonattainment Areas SIP.

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17 Particulate Matter (PM10): PM10 is produced by fugitive dust generated by high winds. Fugitive dust in the Coachella Valley is primarily the result of local wind-blown sand and dust resulting from construction activities, re-entrained dust from vehicles on paved and un-paved roads, as well as natural sources such as blow sand.9

2.3.2 Local Air Quality – Source Receptor Area
Air quality is measured at monitoring stations operated by the air quality management district. The SCAQMD operates three air monitoring stations in Source Receptor Area (SRA) 30 (Coachella Valley):

Palms Springs, Mecca, and Indio. The stations have been operational since 1971, 2011, and 2024, respectively.10
Ozone is regularly measured at the Palm Springs and Indio monitoring stations. PM10 and PM2.5 are measured at the Palm Springs, Indio, and Mecca stations. The Palm Springs station is the nearest to the Project, located approximately 3.06 miles southwest of the Project site.

Figure 2-2: SCAQMD Monitoring Stations in the Coachella Valley Source: South Coast Air Quality Management District, Draft Final 2022 AQMP The following tables show the maximum concentration and number of days annually that ambient air quality measured at Coachella Valley monitoring stations exceeded state and national standards for ozone and particulate matter (PM10) from 2016 to 2024.
9 Ibid. 10 South Coast Air Quality Management District, 2024 Annual Air Quality Monitoring Network Plan, Table 1.

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18 Table 2-4 shows the ozone monitoring data for the Palm Springs and Indio monitoring stations.

Compared to the Indio, Palm Springs consistently had more days per year exceeding the state and federal standards for ozone.

Table 2-4
Ozone Monitoring Data
Monitoring
Station Year Maximum Concentration Number of Days Standard Exceeded National State
1 Hour ppm 8 Hour ppm1 8 Hour2 1 Hour 8 Hour
Palm Springs
2016 0.103 0.092 46 6 48
2017 0.113 0.097 57 18 63
2018 0.111 0.099 56 11 58
2019 0.100 0.084 34 5 39
2020 0.119 0.094 49 9 53
2021 0.110 0.092 35 10 38
2022 0.106 0.089 39 7 43
2023 0.116 0.093 38 8 39
2024 0.105 0.091 55 8 56
Indio
2016 0.099 0.089 27 3 29
2017 0.107 0.093 44 8 47
2018 0.106 0.091 49 4 52
2019 0.103 0.087 43 4 47
2020 0.097 0.084 42 2 44
2021 0.099 0.078 18 2 24
2022 0.072 0.069 0 0 0
2023 * * * * *
2024 0.098 0.080 27 2 31
Source: iAdam: Air Quality Data Statistics, California Air Resources Board; www.arb.ca.gov/adam (accessed November 2025). 1
8-Hour Average National 0.07 ppm Standard Maximum 2 Days Exceeding National 0.070 ppm Standard 3 * = There was insufficient (or no) data available to determine the value.

Table 2-5 shows the PM10 data for the Palm Springs, Indio, and Mecca monitoring stations. The Mecca and Indio stations haven’t reported data the past three and two years, respectively. The Palm Springs station hasn’t reported for 2024 and partially reported for 2023. On average, over the last nine years the Indio and Mecca stations exceeded national and state standards more frequently than the Palm Springs station. In recent reporting years the Mecca station experienced the highest maximum concentrations for the national standard (2021) and the Palm Springs station experienced the highest maximum concentrations for the national standard (2023). The annual arithmetic mean national standard of less than 50 μg/m3 was not exceeded at any of the monitoring stations from 2016 to 2025.

Item Number: 1.

Air Quality and Greenhouse Gas Report – December 2025
DHS Varner Road Specific Plan
19 Table 2-5
Particulate Matter 10 Monitoring Data
Monitoring
Station Year
Maximum Concentration
(μg/m3/24 hours)
Number of Days
Standard Exceeded
Annual
Arithmetic
Mean3 National State2
National State
Palm Springs
2016 447.2 113.1 1.1 * 23.1
2017 105.6 60.5 0 * 22.1
2018 442.3 37.4 2.0 0 22.9
2019 75.6 51.8 0 6.0 20.7
2020 129.8 40.8 * * 23.2
2021 35.2 34.5 0 0 18.4
2022 159.5 156.3 * * 21.1
2023 173.6 170.1 * * 23.1
2024 * * * * *
Indio
2016 393.2 261.2 * 135.7 37.0
2017 198.6 143.1 1.0 * 34.8
2018 336.0 149.6 2.2 88.4 34.8
2019 141.9 80.3 0 25.7 28.5
2020 145.2 53.8 0 * 31.6
2021 100.4 100.6 0 29.3 28.6
2022 160.0 160.3 * * 19.8
2023 * * * * *
2024 * * * * *
Mecca
2016 468.9 183.1 * * 41.1
2017 477.6 198.8 * 81.5 47.5
2018 275.2 59.8 6.3 * 40.8
2019 232.9 213.7 * 49.2 35.0
2020 680.6 62.6 10.0 * 45.5
2021 334.5 118.3 3.0 * 41.5
2022 * * * * *
2023 * * * * *
2024 * * * * *
Source: iAdam: Air Quality Data Statistics, California Air Resources Board; www.arb.ca.gov/adam (accessed February 2025). 1 Note: National maximum concentration is based on the highest standard-conditions 24-hour PM10 average observed within a year. State maximum concentration is based on the highest local-condition 24-hour PM10 average. 2 * = There was insufficient (or no) data available to determine the value. 3 National Annual Average Standard AAM exceeding 50 μg/m3

2.4 Regulatory Background
The primary contributor to air pollution in California is the burning of fossil fuels for transportation, power and heat generation, and industrial processes. Mobile sources such as heavy-duty trucks, airplanes, and construction equipment are similarly the primary contributors to air pollution in the Item Number: 1.

Air Quality and Greenhouse Gas Report – December 2025
DHS Varner Road Specific Plan
20 SCAQMD.11 Fine particulate matter and ozone, two of the pollutants that have the greatest potential public health impacts, are also emitted by fuel and wood combustion, as well as indirectly by chemical reactions resulting from motor vehicle and industrial activity.12 While there have been significant efforts to reduce the historically high levels of air pollution in the SCAQMD, levels of ozone and particulate matter remain elevated.

Federal, state, and local policies aim to reduce air pollution by regulating air quality and the sources of pollution emissions. The following section describes relevant air quality policies and regulations.

2.4.1 Federal Regulations
Federal Clean Air Act (FCAA) - 42 U.S.C. §7401 et seq.

The Federal Clean Air Act, which was first enacted in 1970 and last amended in 1990, remains the federal government’s primary air quality law regulating air emissions from stationary and mobile sources. There are several regulatory programs bought about by FCAA amendments, including National Ambient Air Quality Standards (NAAQS), National Emissions Standards for Hazardous Air Pollutants (NESHAPs), New Source Performance Standards (NSPS), the Acid Rain Program (APP), and the CAA ozone program consistent with the Montreal Protocol. Notably, the FCAA gives the Environmental Protection Agency (EPA) that authority to establish the National Air Quality Standards.

National Ambient Air Quality Standards (NAAQS)
The FCAA authorizes the EPA to establish National Ambient Air Quality Standards (40 CFR Part 50) for six criteria air pollutants which are potentially harmful to the public and to the environment. The NAAQS define what qualifies as clean air by identifying the maximum amount of a pollutant, averaged over a specified timeframe, that can be present without harming public health.13 The EPA reviews the NAAQS at five-year intervals, and makes revisions as needed. The six criteria air pollutants currently covered by the NAAQS are: particulate matter (PM10 and PM2.5), ozone (O3), nitrogen oxides (NOX), sulfur oxides (SOX), carbon monoxide (CO), and lead. Under the FCAA, nonattainment areas (areas that exceed that maximum standard for one or more of the criteria pollutants) must prepare State Implementation Plans (SIPs) describing the actions the area will take to meet the NAAQS by the applicable attainment deadlines.

2.4.2 State Regulations
California Clean Air Act
The California Clean Air Act (CCAA) was passed into law in 1988, establishing ambient air quality standards for the State of California that exceed NAAQS, as well as accelerated attainment dates for criteria pollutants established in the FCAA. The CCAA establishes requirements for district air quality plans to ensure that the state standards for criteria pollutants are met. 11 South Coast Air Quality Management District, Draft Final 2022 Air Quality Management Plan. 12 California Air Resources Board, Sources of Air Pollution, https://ww2.arb.ca.gov/resources/sources-air-pollution (Accessed February 2025). 13 California Air Resources Board, National Ambient Air Quality Standards https://ww2.arb.ca.gov/resources/nationalambient-air-quality-standards (Accessed February 2025).

Item Number: 1.

Air Quality and Greenhouse Gas Report – December 2025
DHS Varner Road Specific Plan
21 Title 24 Energy Efficiency Standards & California Green Building Standards Title 24 of the California Code of Regulations was established in 1978 and serves to enhance and regulate California’s building standards. The Building Energy Efficiency Standards, Parts 6 and 11 of Title 24, are updated by the California Energy Commission (CEC) every three years. The 2022 Energy Code (Part 6), effective as of January 1, 2023, includes regulations encouraging efficient electric heat pumps, establishing electric-ready requirements for appliances and mechanical systems in new homes, strengthening ventilation standards, as well as expanding solar photovoltaic and battery storage standards. The 2022 update to Part 11, the California Green Building Standards Code (CALGreen), includes mandatory minimum environmental performance standards for all new construction of commercial, residential, and State-owned buildings, as well as schools and hospitals.

CALGreen Section 4.106 requires that all new single family and multifamily dwellings, as well as hotels, are built with EV Capable parking spaces. One and two-family dwellings must include one EV capable space per dwelling unit, and multifamily buildings and hotels must build a proportion of all provided parking to be either EV Capable or EV Ready.14 In accordance with Section 5.106, all new non-residential developments must provide both a portion of parking spaces are that EV Capable, as well as a portion of spaces with EV charging stations.

California Health and Safety Code §39655 Toxic Air Contaminants (TACs) The California Health and Safety Code §39655 defines a TAC as “an air pollutant which may cause or contribute to an increase in mortality or an increase in serious illness, or which may pose a present or potential hazard to human health.” Assembly Bill 1807, the Tanner Air Toxics Act of 1983, and the Air Toxics Hot Spots Information and Assessment Act of 1987 provide the procedures for CARB to identify and regulate TACs.
13 CCR § 2485 Airborne Toxic Control Measure
California Code of Regulations (CCR), Title 13, Section 2485 establishes the Airborne Toxic Control Measure to limit idling of diesel-powered commercial motor vehicles (over 14,000 pounds GVWR). The regulation generally prohibits idling for more than 5 consecutive minutes or idling when the vehicle is parked for more than 5 minutes within 100 feet of a restricted area (homes or schools), with limited exceptions queuing, passenger boarding, safety, and certain other operational needs. This regulation applies to both California- and out-of-state-registered vehicles operating in the state, requires drivers to manually shut off engines when idling is prohibited, and imposes record-keeping and reporting requirements on fleet operators for compliance verification. 13 CCR § 2025 Truck and Bus Regulation
13 CCR § 2025 requires nearly all heavy-duty diesel trucks and buses operating in California to upgrade or retrofit older engines with diesel particulate filters (DPFs) and, in later phases, replace or repower older engines to meet progressively stricter 2010-or-newer engine emission standards. The rule is based on the vehicle’s model year and gross vehicle weight rating, mandates annual reporting and labeling, 14 EV Capable refers to parking spaces which have electrical panel capacity, a dedicated branch circuit, and a raceway to support future installation of a charging station. EV Ready refers to the same conditions as EV Capable, with the addition of other electrical components as well as a receptable or blank cover to support future installation of a charging station.

Item Number: 1.

Air Quality and Greenhouse Gas Report – December 2025
DHS Varner Road Specific Plan
22 and aims to reduce diesel PM and NOx emissions by over 90% from the pre-regulation fleet. Compliance deadlines were fully implemented by January 1, 2023, with limited exemptions and extensions for lowmileage or specialty vehicles.

California Health and Safety Code Section 41700 Nuisance Complaint Program This code is also referred to as the Nuisance Complaint Program and states that with exceptions provided in Section 41705, a person shall not discharge from any source quantities of air contaminants or other material that cause injury, detriment, nuisance, or annoyance to any considerable number of persons or to the public.” The Code further includes that a person shall not discharge any air contaminants that endangers the comfort, repose, health, or safety of any people or the public, or causes injury or damage to business and property.

Assembly Bill 617
Codified primarily in Health & Safety Code §§ 44391.2 and 42705.5, the purpose of AB 617 is to address non-vehicular sources of TACs and criteria pollutants in disproportionately impacted neighborhoods. It requires CARB and local air districts to select disadvantaged communities for enhanced air monitoring, develop community emissions reduction programs (CERPs) with enforceable measures targeting stationary sources (e.g., refineries, factories, railyards), and impose expedited best available retrofit control technology (BARCT) requirements on certain industrial facilities in those areas. The program mandates community steering committees, public transparency, and faster implementation of TAC controls, resulting in dozens of adopted CERPs with binding emission limits and penalties for noncompliance.

2.4.3 Local Regulations
Desert Hot Springs General Plan 2020
The City’s 2020 General Plan address air quality in the following elements: Open Space and Natural Resources, Land Use and Community Design, and Mobility and Infrastructure. The following policies regulate air quality and are relevant to the proposed Project:

Open Space and Natural Resources
GOAL OS-2: Air quality that is healthy for residents and the environment OS-2.1: Air Pollution Reduction: Seek to reduce air pollution through the implementation of existing regulations and the creation of new regulations where needed.

OS-2.3: Minimize Air Quality Impacts. Minimize the air quality impacts of new development projects on established uses.

OS-2.6 Alternative Fuels. Prioritize alternative fuel vehicles for City use. Incorporate alternative fuel charging stations into public and private development projects.

Item Number: 1.

Air Quality and Greenhouse Gas Report – December 2025
DHS Varner Road Specific Plan
23 OS-2.8 Air Quality and Climate Change Analyses. Require detailed air quality and climate change analyses and mitigation plans for all applications that have the potential to adversely affect air quality.

Land Use and Community Design
LU 1.5 Coordinate land use patterns with the Mobility and Infrastructure Element to improve and protect air quality, reduce vehicle trips, and promote active transportation modes and transit use.

Mobility and Infrastructure
GOAL MI-5 Reduction in total vehicle miles traveled to help improve local air quality and reduce greenhouse gas emissions.

MI 5.3 Clean Vehicles: Support the development of a network of public and private clean and/or carbon-neutral fuel vehicle charging and fueling stations.

2.4.4 Air Quality Management Planning
California Air Resources Board
The California Air Resources Board (CARB) is part of the California Environmental Protection Agency and is responsible for preparation the SIP for submission to the EPA, as well as for overseeing air quality districts and approving district air quality plans. Established in 1967, the CARB regulates vehicle emissions standards and sets area designation for criteria pollutants.

South Coast Air Quality Management District (SCAQMD)
The California Air Resources Board is responsible for regulating mobile emissions sources, while quality management districts, such as SCAQMD, are responsible for controlling stationary sources and enforcing regulations. The SCAQMD is responsible for preparing the local portion of the State Implementation Plan, through which it is the primary authority for regulating stationary emissions sources.

The SCAQMD jurisdiction covers approximately 10,743 square miles including the South Coast Air Basin as well as the Riverside County portions of the Salton Sea Air Basin (SSAB) and Mojave Desert Air Basin (MDAB). The Coachella Valley Planning Area is within the Riverside County portion of the SSAB.

In accordance with the federal Clean Air Act, areas that do not attain the NAAQS are required to develop and implement plans to attain healthy air quality in reasonable timeframe. Likewise, areas that do not attain the CAAQS are required to apply and enforce measures in order to meet the State standard by the earliest practicable date. Areas under the SCAQMD have historically been nonattainment areas for particulate matter (PM10) as well as ozone (O3). The SCAQMD regulates air quality through air quality management plans (AQMPs) as well as the adoption of rules targeting specific sources of emissions.

Final 2022 Air Quality Management Plan: The SCAQMD has developed six air quality management plans (AQMPs) since the 1990s. The District’s 2022 AQMP focuses on implementing provisions to bring the Coachella Valley Planning Area in compliance with the federal 8-hour ozone standard by August 3, 2033.

Item Number: 1.

Air Quality and Greenhouse Gas Report – December 2025
DHS Varner Road Specific Plan
24 Final 2003 Coachella Valley PM10 State Implementation Plan: The 2003 Coachella Valley PM10 State Implementation Plan (CVSIP) builds on the 2002 CVSIP which provided a comprehensive strategy to meet the NAAQS for PM10 by 2006. The 2003 CVSIP update is based on updated motor vehicle emissions modeling and assumptions from CARB, and thus includes updated emissions inventories, mobile source budgets and attainment demonstration.

Final 2024 Coachella Valley Attainment Plan for 2008 8-Hour Ozone Standard: The Coachella Valley was reclassified from "severe" to "extreme" nonattainment effective April 7, 2023 with a new attainment date of July 20, 2032. The Coachella Valley Attainment Plan for the 2008 8-Hour Ozone Standard was developed to address the "extreme" nonattainment area requirements.

The SCAQMD has also established construction and operation thresholds for criteria air pollutants, as shown in Table 2-6. If exceeded, these thresholds indicate that a project has significant impacts to air quality:

Table 2-6
SCAQMD Air Quality Mass Daily Thresholds
Criteria Pollutant Daily Thresholds (pounds/day)
Construction Operation
Oxides of Nitrogen (NOx) 100 55
Reactive Organic Gases (ROG) 75 55
Particulate Matter (PM10) 150 150
Particulate Matter (PM2.5) 55 55
Oxides of Sulfur (SOx) 150 150
Carbon Monoxide (CO) 550 550
Lead (Pb) 3 3
Source: South Coast AQMD Air Quality Significance Thresholds (March 2023).

Assembly Bill 98 (AB 98)
Signed into law in September 2024 and commencing in January 2026, AB 98 establishes warehouse design and building standards for new and expanding “logistic centers” that increase total building square footage by more than 20 percent. A “logistic center” is defined as “a building in which cargo, goods, or products are moved or stored for later distribution to business or retail customers, or both, that does not predominantly serve retail customers for onsite purchase, and heavy-duty trucks are primarily involved in the movement of the cargo, goods, or products.” Dependent on the size of the proposed project and the project’s current zoning, different standards may apply as to address and reduce the logic center’s relative risk for impact on sensitive receptors (i.e., residences, schools, developed parkland, nursing homes, hospitals).

AB regulatory tier system includes:
• Tier 1 “21st Century Warehouse Design Standards”: Applies to logistic facilities with a total building area greater than 250,000 square feet in a district zoned for industrial or non-industrial use. Standards also apply to logistic facilities with a total building area less than 250,000 square feet in a zoned for non-industrial use or would otherwise require rezoning.

Item Number: 1.

Air Quality and Greenhouse Gas Report – December 2025
DHS Varner Road Specific Plan
25 • Tier 2 “Base Standards”: Applies to logistic facilities with a total building area less than 250,000 square feet, located in a district for industrial use.

In addition, AB 98 mandates cities and counties within the SCAQMD jurisdictional area to update their circulation element to include truck routes in non-sensitive land use districts. AB 98 also mandates SCAQMD to submit report updates in 2028 and 2033 regarding air pollutant concentration at various distances from logistic facilities in Riverside and San Bernardino County so as to assess the effectiveness of the regulatory standards proscribed in AB 98.

Assembly Bill 1000 (AB 1000)
Amended in January 2024, AB 1000 reinforces air quality standards established by CEQA and Climate Action Plans by regulating the review and approval process for “qualifying logistics use” projects. A “qualifying logistics use” project is defined as “a building with 100,000 or more square feet of building space, including, but not limited to, warehouses.” AB 1000 prohibits local jurisdictions from approving a “qualifying logistics use” project within 1,000 feet of a sensitive receptor. A project nonetheless may be approved up to 750 feet from a sensitive receptor if a cumulative air quality assessment is prepared, in which compliance with regional environmental criteria is determined or otherwise addressed through feasible mitigation measures.

2.4.3.1 Air Basin Regulations
The SCAQMD has adopted rules and regulations to improve and maintain air quality in the district. The rules and regulations also implement state and federal policies, such as the Clean Air Act. The current SCAQMD rule book contains 28 regulations and associated rules. Excerpts of applicable regulations to the Project are listed below. The complete list and full text of the current rule book is available on the SCAQMD website.15
Regulation II – Permits
Rule 201: Permits to Construct: A person shall not build, erect, install, alter or replace any equipment or agricultural permit unit, the use of which may cause the issuance of air contaminants or the use of which may eliminate, reduce or control the issuance of air contaminants without first obtaining written authorization for such construction from the Executive Officer. A permit to construct shall remain in effect until the permit to operate the equipment or agricultural permit unit for which the application was filed is granted or denied, or the application is canceled.

Rule 203: Permit to Operate: A person shall not operate or use any equipment or agriculture permit unit, the use of which may cause the issuance of air contaminants, or the use of which may reduce or control the issuance of air contaminates, without first obtaining a written permit to operate from the Executive Officer or except as provided in Rule 202. 15 South Coast AQMD Rule Book, http://www.aqmd.gov/home/rules-compliance/rules/scaqmd-rule-book (accessed February 2025).

Item Number: 1.

Air Quality and Greenhouse Gas Report – December 2025
DHS Varner Road Specific Plan
26 Regulation IV – Prohibitions
Rule 402: Nuisance: A person shall not discharge from any source whatsoever such quantities of air contaminants or other material which cause injury, detriment, nuisance or annoyance to any considerable number of persons or to the public, or which endanger the comfort, repose, health or safety of any such persons or the public, or which cause, or have a natural tendency to cause, injury or damage to business or property.

Rule 403: Fugitive Dust Control: The purpose of this rule is to reduce the amount of particulate matter entrained in the ambient air as a result of anthropogenic (man-made) fugitive dust sources by requiring actions to prevent, reduce or mitigate fugitive dust emissions Rule 404: Particulate Matter Concentration: A person shall not discharge into the atmosphere from any source, particulate matter except liquid sulfur compounds, in excess of the concentration at standard conditions, shown in Table 404(a). Where the volume discharged is between figures listed in the table, the exact concentration permitted to be discharged shall be determined by linear interpolation.

Regulation XI – Source Specific Standards
Rule 1113: Architectural Coatings: This rule is applicable to any person who supplies, sells, markets, offers for sale, or manufactures any architectural coating that is intended to be field applied within the District to stationary structures or their appurtenances, and to fields and lawns; as well as any person who applies, stores at a worksite, or solicits the application of any architectural coating within the District. The purpose of this rule is to limit the VOC content of architectural coatings used in the District.

Regulation XIII – New Source Review
Rule 1300: New Source Review General: This regulation sets forth pre-construction review requirements for new, modified, or relocated facilities, to ensure that the operation of such facilities does not interfere with progress in attainment of the national ambient air quality standards, and that future economic growth within the South Coast Air Quality Management District (District) is not unnecessarily restricted. The specific air quality goal of this regulation is to achieve no net increases from new or modified permitted sources of nonattainment air contaminants or their precursors.

Regulation XXIII: Facility Based Mobile Source Measures Rule 2305: Warehouse Indirect Source Rule—Warehouse Actions and Investments to Reduce Emissions (WAIRE) Program: The purpose of this rule is to reduce local and regional emissions of nitrogen oxides and particulate matter, and to facilitate local and regional emissions reductions associated with warehouses and the mobile sources attracted to warehouses in order to assist in meeting state and federal air quality standards for ozone and fine particulate matter.

Item Number: 1.

Air Quality and Greenhouse Gas Report – December 2025
DHS Varner Road Specific Plan
27 3 PROJECT AIR QUALITY IMPACT

3.1 Introduction
In accordance with CEQA, this following analyzes the proposed Project and demonstrates that all potential air quality impacts associated with the Project at buildout would be within the envelope of impacts already evaluated in the approved 2018 EIR.

3.2 Standards of Significance
The following thresholds are from the significance criteria listed in the CEQA Environmental Checklist included in Appendix G of the CEQA Guidelines. The Project would have a significant effect on air quality if the proposed Project were to:
a) Conflict with or obstruct implementation of the applicable air quality plan? b) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard? c) Expose sensitive receptors to substantial pollutant concentrations? d) Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
According to the SCAQMD CEQA Handbook, any project that has the potential to expose the public to toxic air contaminants in excess of the following thresholds would be considered to have a significant air quality impact:
• If the Maximum Incremental Cancer Risk (MICR) is 10 in one million or greater; or • Toxic air contaminants from the proposed project would result in a Hazard Index increase of 1 or greater.

3.3 Methodology
On-site improvements encompass approximately 123.4-acres of undeveloped desert land within a relatively rural and undeveloped portion of the City’s southernmost region. Pursuant to the DHS Varner Road Specific Plan, the property includes 83.3± acres of industrial land to include 1.5 million SF of industrial warehouse space, 11.6±-acres of stormwater control, and 28.5± acres of open space/conservation. The open space is intended for habitat conservation and therefore, the associated

28.5±-acres will not be developed or modified in relation to the Project buildout. Additionally, the Specific Plan includes 1.37 miles of off-site roadway widening along Varner Road and West Drive, and

5.5 miles of sewer and water utility extensions combined.

As shown in Table 3-1, a total of 115.68 acres would be disturbed as part of the Project including on- and off-site improvements.

Item Number: 1.

Table 3-1
Project Development Assumptions
Land Use (Proposed) Land Use (CalEEMod) Acres1 Building Area (sf)2
Landscaping
Area (sf)3 Other4 Daily Trips5 Trip Length6
Non Res H-W Non Res W-O
On-Site Development
Office Space Industrial Park 18.73 75,000 107,147 -- 2,234 13.8 6.2 Distribution & Storage Unrefrigerated
Warehouse-No Retail 56.18 1,425,000 321,441 -- 960 -- 40 Parking Lot Parking Lot 20.00 -- -- -- -- -- --
Utility Extension Road Construction 6.67 -- -- 5.50 miles -- -- -- Road Improvement Road Widening 14.11 -- -- 1.37 miles -- -- -- Total Area for On- and Off-Site Improvements 115.681 1,500,000 428,588 -- 3,194 Total trips --
1 Total disturbed area is 115.68 AC; 83.3 AC for Industrial uses (including 20 AC for parking lot), 11.6 acres for storm water/drainage improvements, and 14.11 for roadway improvements. 2 Specific Plan allows up to 1.5 million sf of industrial space. For analysis purposes, it is assumed that 5 percent (75,000 SF) of the total industrial space would be associated office space ("Industrial Park"), and the remainder (1,425,000 SF) would be "Unrefrigerated Warehouse - No Rail." 3 Landscaping: Square footage (428,588 SF) based on Project Water Supply Assessment; includes onsite landscaping and off-site roadway landscaped median areas, split 25/75 among Industrial and Warehouse acreage, respectively. 4 Off-site utility extensions for sewer and water combined total 5.5 miles, assuming a 10 foot wide disturbance area would result in 290,400 sf (6.67 AC) of off-site disturbed area for installation of sewer and water lines. Roadway improvements (14.11AC): Varner Road = 1.07 miles with 92 foot ROW (11.93 AC); West Drive = 0.3 miles with 60ft ROW (2.18AC)
5 Daily trips are based on Varner Road/ West Drive Logistics Traffic Analysis, prepared by Urban Crossroads (March 2025), Table 4-1. Assumes vehicle fleet mix generated by the Industrial Park will primarily consist of passenger cars (62%) and the remaining (38%) is divided between light-duty trucks, LDT2 with a 21% and LDT1 with 4%. These vehicle trips account for the 2,234 daily vehicle trips generated by the office space. The percentages are based on the Morongo Valley Trade Center (Warehouse Scenario) Air Quality, GHG & HRA Evaluation prepared by UXR (October 2020). Assumes vehicle fleet mix generated by the Unrefrigerated Warehouse-No Retail will primarily consist of heavy-heavy duty trucks (60%), medium-heavy-duty trucks (23%), and light heavy-heavy-duty trucks (17%). These truck trips account for the 960 daily vehicle trips generated by the operation of a distribution/storage warehouse. The percentages are based on the Morongo Valley Trade Center (Warehouse Scenario) Air Quality, GHG & HRA Evaluation prepared by UXR (October 2020). 6 Trip length for Industrial Park is consistent with the 2017 Desert Land Venture III LLC Property Air Quality and Global Climate Change Impact Analysis; 40 miles for W-O for Unrefrigerated Warehouse-No Retail accounts for long-haul distribution trips, based on the average truck trip length from the SCAG 2016 Regional Transportation Plan.

Item Number: 1.

Air Quality and Greenhouse Gas Report – April 2025
DHS Varner Road Specific Plan
29 CalEEMod Modeling
The proposed Project will emit criteria air pollutants during both the construction and the operational phases. Construction and operational emissions were projected using California Emissions Estimator Model (CalEEMod) Version 2022.1. CalEEMod is a Statewide land use emission computer model developed for the California Air Pollution Officers Association (CAPCOA) in collaboration with the California Air Districts, including the SCAQMD, that provides a uniform platform to quantify potential criteria pollutant and greenhouse emissions associated with construction and operation of land development projects. CalEEMod utilizes widely accepted methodologies for estimating emissions from several sources, including studies commissioned by the California Energy Commission (CEC). CalEEMod Version 2022.1 analyzes operational emissions from natural gas and electricity usage for residential and non-residential uses, and models Title 24 energy conservation standards applicable to all residential and nonresidential buildings throughout California. For electricity, Title 24 uses include the major building envelope systems covered by Part 6 (California Energy Code) of Title 24 such as space heating, space cooling, water heating, and ventilation. For natural gas, Title 24 uses include building heating and hot water end uses. CalEEMod calculates criteria air pollutants, including CO, PM10, PM2.5, and the ozone precursors ROG and NOx. CalEEMod output tables are provided in Appendix A and B of this report.

Land use parameters and traffic trip information used for analysis purposes was based on data provided in the Traffic Impact Analysis (TIA) prepared for the Project by Urban Crossroads, Inc.

Due to limitations in the land use options available in CalEEMod, not all uses proposed by the Project had corresponding categories in the model. Where the land use as proposed in the Specific Plan was not available, a similar use was used in its place, and trip rates and other inputs were adjusted as needed. Table 3-1 compares the proposed land uses with the land use parameters entered to CalEEMod. For analysis purposes, where the proposed land use was replaced with a similar CalEEMod category, adjustments were made in the model to represent the intended use more accurately. For example, where “Industrial Park” was used in place of the proposed office space, trip rates were adjusted per daily passenger trips estimated by the Project-specific TIA. The “Unrefrigerated Warehouse” land use in CalEEMod was used to represent the proposed warehouse total distribution and storage space. The corresponding trip rates were adjusted based on traffic count data to reflect truck trips. According to the TIA, the 1,500,000± square foot industrial warehouse would generate 3,194 daily trips, of which 2,234 weekday trips are passenger vehicles and 960 weekday trips are hauling trucks. The same trip generation is assumed for weekend trips.

It is also assumed that the Project will comply with the mitigation measures previously established in the 2017 air quality report prepared for the Desert Land Venture Specific Plan EIR16, of which DHS Varner Road Specific Plan is an addendum to. The Project is therefore subject to these mitigations that include but are not limited to a photovoltaic system that provides at least 16 Desert Land Ventures III LLC Property Air Quality and Global Climate Change Impact Analysis Revised, prepared by Kunzman Associates, Inc. (November 2017), Section 10.

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Air Quality and Greenhouse Gas Report – December 2025
DHS Varner Road Specific Plan
30 10 percent of the total electricity demand, recycling program to divert 75 percent of solid waste from local landfills, and a vanpool/rideshare program that provides at least 80 percent of on-site employees with an alternative to single-vehicle use.

The following summarizes the primary construction, operation, and mitigation assumptions applied to CalEEMod, as previously shown in Table 3-1. These general assumptions allow for the air quality assessment to evaluate the Project’s maximum emissions at buildout, consistent with the DHS Varner Road Specific Plan.
• Total Disturbed Acreage: 115.68 AC (includes road improvement and off-site utility extensions)
• Industrial Park: 75,000 SF
• Unrefrigerated Warehouse-No Retail: 1,425,000 SF
• Parking Lot: 20 AC (95% asphalt for vehicle and truck parking and internal driveways) • Road Widening: 1.37 miles, 14.11 AC disturbed (95% asphalt for Varner and West Drive) • Road Construction: 5.50 miles, 6.67 AC disturbed (20% asphalt for trenching/roadway repair)
• On-Site Construction: 24-months buildout, starting May 2026 to 2028 o Grading: 70 days
o Building Construction: 400 days
o Paving: 45 days
o Arch coating: 60 days
• Off-Site Construction: 4-months buildout, starting August 2026 to December 2026 o Grading & Excavation: 60 days
o Drainage, Utilities, & Sub-grade: 60 days
o Paving: 60 days
• Net Export in Grading Phase: 88,400 CY
• Daily Vehicle Trips: 3,194 daily trips (2,234 passenger vehicle trips, 960 trucks/distribution trips)
• Annual VMT: 19,273,363
• Trip Length: H-W: 13.8 miles (consistent with 2017 Desert Land Venture air quality report); W-O: 6.2 miles for industrial park workers (consistent with 2017 air quality report), and 40 miles for long-haul truck trips.
• Off-Road Vehicle and Equipment Operations (Not accounted for in 2017 Project) o Assumes warehouse would operate 30 forklifts17 and 6 holsters/yard goats18, each piece operating approximately 4 hours per day.
17 Forklifts: Based on the SCAQMD White Paper presented above, you can assume 0.02 pallet jacks/forklifts per TSF of building area. 18 Hostlers: 2014 SCAQMD High Cube Warehouse Truck Trip Study White Paper Summary Of Business Survey Results (https://www.aqmd.gov/docs/default-source/ceqa/handbook/high-cube-warehouse-trip-rate-studyfor-air-quality-analysis/business-survey-summary.pdf), the average usage was 3.6 hostlers (yard goats) per million square feet of building area.

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31 o Assumes 2 fire pumps, average 450 horsepower operating 10 hours per year, including non-emergency testing and maintenance.
o Assumes diesel emergency generator with an average of 2000 horsepower operating a max. of 100 hours per year, including non-emergency testing and maintenance.
• Mitigation Measures (consistent with 2017 Project plus additional measures for DPM reductions)
o Water exposed areas
o Arch coating VOC content lowered to 10 g/L for buildings and 100 g/L for parking area
o Oxidation catalyst on construction equipment with reduction of 20% o Tier 4 final engines of equipment
o Level 3 Diesel Particulate Filters on construction equipment o 10% of operational energy demand produced with on-site solar o All electric yard equipment (forklifts and hostlers)
o Assumes 350 of the 960 truck trips would be from electric trucks, with the remaining 610 trucks being diesel.
2018 Project Emissions Comparison
Air pollutant emissions in the 2018 EIR were calculated using CalEEMod Version 2016.3.2. The following summarizes the primary construction, operation and mitigation assumptions applied to CalEEMod in the 2018 EIR analysis:
• Total Site Acreage: 88.57 AC (Offsite utility extensions not included) • General Light Industry: 1,538,757 SF
• Regional Shopping Center: 359,042 SF
• Asphalt Paving: 21.34 AC
• Other Non-Asphalt: 23.67 AC
• 24-month buildout (building, paving and arch coating phases have some overlap) o Grading: 70 days
o Building: 400 days
o Paving: 45 days
o Arch coating: 60 days
• 196,440 CY import
• 25,833 daily trips
• Annual vehicle miles traveled (VMT): 51,273,973 unmitigated; 30,959,64 mitigated with carpool/shuttle program
• Trip Lengths: H-W/C-W: 13.8 miles; H-S/C-C/H-O/C-NW: 6.2 miles • Mitigation Measures:
o Water exposed areas
o Arch coating VOC content lowered to 10 g/L for buildings and 100 g/L for parking area
o Oxidation catalyst on construction equipment with reduction of 20% Item Number: 1.

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32 o Tier 4 final engines on equipment
o Level 3 Diesel Particulate Filters on construction equipment o Assumed approximately 10% of energy demand provided by onsite renewables.

Emissions from the proposed Project are compared to the emissions provided in the 2018 EIR in the following sections to determine whether impacts associated with the Project at buildout would be within the envelope of impacts already evaluated in the approved 2018 EIR.

3.4 Construction Emissions
Construction of the proposed Project and related infrastructure improvements would generate criteria pollutant emissions over a 2-year period, beginning May 2026 and concluding in 2028.

The construction phase would include site preparation, excavation and grading, paving, building construction, utility extension trenching and paving, and application of architectural coatings.

Worker and vendor trips would be required throughout the construction phase.

The following construction mitigation measures were selected in CalEEMod:
• Construction contractors use construction equipment that have a Tier 4 engines • Use a level 3 diesel particulate filter (DPF)
• Use oxidation catalyst that have a 20 percent reduction in emissions • Apply architectural coating to project buildings with a limited content of 10 grams per liter VOC and traffic pains with a limit of 100g/L VOC content • Riverside County and SCAQMD will require future development projects implement standard dust control measures per SCAQMD Rule 403.1, which will further reduce emissions of PM10 and PM2.5. CalEEMod assumes watering unpaved surfaces twice a day, and the emissions reduction is captured in the unmitigated outputs.

Table 3-2 shows the emissions generated by construction of the Project compared to the 2018 Project. The proposed Project will not exceed any of SCAQMD’s daily threshold with mitigation, while the 2018 Project exceeded the NOx threshold.

Table 3-2
Maximum Daily Construction-Related Emissions Summary
(pounds per day)
Scenario CO ROG NOx SO2 PM10 PM2.5
2018 Project, Mitigated 185.93 66.32 115.65 0.93 35.86 10.33 Proposed Project, Unmitigated 201 240 133 0.35 23.1 8.42 Proposed Project, Mitigated 217 30.4 83.1 0.35 20.6 6.23 SCAQMD Threshold 550 75 100 150 150 55
Exceeds Threshold, Mitigated?
(2018/2025) No/No No/No Yes/No No/No No/No No/No
Source: DLVSP 2018 EIR; CalEEMod detailed reports, Appendix A.

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33 3.5 Operational Emissions
Operational emissions refer to the ongoing emissions over the life of a project. They include area source emissions )architectural coatings, consumer products, landscape equipment), emissions from energy demand (e.g., electricity and natural gas) and mobile source emissions (e.g. vehicle trips, off-road equipment). According to the Traffic Impact Analysis (TIA) prepared by Urban Crossroads, the Project’s 1.5-million SF distribution center is estimated to generate 3,194 weekday trips. Saturday and Sunday trips assume the same traffic volume (3,194 trips). Operation of sewer and water lines, as well as roadway improvements, would not directly generate new stationary sources of criteria pollutant emissions.

The following operational mitigation measures were selected in CalEEMod to reduce both criteria pollutant and TACs:
• Provide employer-sponsored vanpool service to at least 80% of the work force. • Require energy efficiency appliances for commercial refrigerators in the Industrial Park • Require an on-site photosynthetic energy system to offset at least 10 percent of the proposed Industrial Park and Unrefrigerated Warehouse space projected energy demand. • Public street and area lighting shall use high efficiency lighting, such as LED lighting. • Require all faucets, toilets, and showers to utilize low-flow fixtures to reduce indoor water demand by 20%. This measure is required by CalGreen Building Standards Code. • Employ water efficient landscaping practices on-site. • Implement solid waste reduction plan to diverge at least 75 percent of all generated waste.
• Require the paint for architectural coating to consist of a VOC content percentage of 10g/L for interior and exterior use of nonresidential use and 100g/L for parking. • To reduce cancer-related health impacts from the project to the residential dwelling located to the southeast of the project site, it is required that all on-site offroad equipment (forklifts and holsters/yard goats) shall be electric and that 350 of delivery trucks utilizing the project site shall be electric trucks. The project shall install electrical charging infrastructure to accommodate the electric vehicles.

Table 3-3 shows the operational emissions generated by the proposed Project compared to the 2018 Project. The proposed Project will not exceed SCAQMD thresholds for CO, ROG, SO2, PM10 and PM2.5. However, daily emissions of criteria pollutants during Project operations will exceed the SCAQMD thresholds for nitrogen oxides (NOx). The 2018 EIR results show that DLVSP operations at buildout would exceed SCAQMD regional thresholds for both ROG and NOx.

Compared to the 2018 Project, the proposed Project would reduce the emissions of all criteria pollutants and would reduce the significance impact of ROG emissions from Significant to Less than Significant.

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34 Table 3-3
Maximum Daily Operational-Related Emissions Summary (pounds per day) Scenario CO ROG NOx SO2 PM10 PM2.5
2018 Project, Mitigated 350.83 90.19 373.25 1.32 69.01 20.29 Proposed Project, Unmitigated 198 55.9 119 1.24 56.2 16.9 Proposed Project, Mitigated 167 47.8 71.2 0.82 42.8 12.5 2018 SCAQMD Threshold1 550 75 100 150 150 55
2025 SCAQMD Threshold 550 55 55 150 150 55
Exceeds Threshold, Mitigated?
(2018/2025) No/No Yes/No Yes/Yes No/No No/No No/No
Source: CalEEMod detailed reports, Appendix A for unmitigated emissions, Appendix B for mitigated emissions.

1. At the time the 2018 EIR was prepared the SCAQMD significance thresholds for operational ROG and NOx emissions in the Coachella Valley were increased to match the more lenient construction-level thresholds, reflecting efforts to address the region’s air quality challenges. However, the Coachella Valley exceptions to operational thresholds are no longer in place, and the Coachella Valley now adheres to the same operational ROG and NOx thresholds as the rest of the South Coast Air Basin.

3.6 Sensitive Receptor Impacts
The Project site is located within a largely undeveloped, rural part of the City of Desert Hot Springs where desert lands expand to the north and east. The nearest sensitive receptor is a single-family residence located immediately south of the industrial parcel and approximately 900 feet from the proposed distribution warehouse.

According to the 2018 EIR, Mitigation Measure AQ-11 (2017 DEIR p. 4.3-35):

If a distribution center with more than 100 daily truck trips is constructed within the project site within 1,000 feet from the property lines of existing single-family detached residential dwelling units located to the southeast of the project site, then the project proponent will require that the individual applicant proposing development prepare a Health Risk Assessment (HRA) to ensure that the cancer risk to existing sensitive uses does not exceed the SCAQMD MICR TAC threshold of 10 in 1 million. If the SCAQMD MICR TAC threshold of 10 in 1 million is exceeded, then the proposed distribution center shall be redesigned to ensure MICR TAC levels are below the threshold.

An operational Health Risk Assessment (HRA) was prepared for the Project in October 2025 and is provided in Appendix C of this report. The HRA was prepared following the Risk Assessment Guidelines: Guidance Manual for Preparation of Health Risk Assessments, formally adopted by the Office of Environmental Health Hazard Assessment (OEHHA) in March 2015. The HRA utilized the USEPA AERMOD Model, which is the air dispersion model accepted by the SCAQMD for performing air quality impact analyses. AERMOD predicts pollutant concentrations from point, area, volume, line, and flare sources with variable emissions in terrain from flat to complex with Item Number: 1.

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35 the inclusion of building downwash effects from buildings on pollutant dispersion. It captures the essential atmospheric physical processes and provides reasonable estimates over a wide range of meteorological conditions and modeling scenarios.

The HRA analyzed both cancer risks and non-cancer risks to sensitive populations measured at the sensitive receptor approximately 900 feet south of the proposed warehouse. Without mitigation, the HRA determined that no infants, children or adults, within their age brackets, would be exposed to cancer risks in excess of 10 in a million. The highest cancer risk corresponds to children 2-16 years (HRA, Table 6), with a maximum risk of 7.67 in one million. However, the HRA determined that the cumulative carcinogenic health risk to an individual born during the opening year of the project and located in the project vicinity for the entire 30-year duration, is a maximum of 15.78 in a million. Therefore, as the maximum incremental cancer risk (MICR) exceeds 10 in a million at the closest sensitive receptor location, the residence adjacent to the southeastern portion of the project site, mitigation measures are required.

Mitigation measures to reduce the DPM emissions from the project include the use of 350 electric trucks, reducing the total number of diesel trucks down from 960 to 610. Regarding on-site DPM emissions reductions, it is assumed that the warehouse would operate 30 electric forklifts and 6 electric holsters/yard goats. Under mitigated conditions the MICR was reduced to a maximum of

6.11 in a million and no longer exceeds the threshold.

For non-cancer risks, the criterion for significance is a Hazard Index increase of 1.0 or greater.

Using the maximum DPM concentration from opening year (2028) emissions under unmitigated conditions, the HRA determined that the resulting hazard index is 0.0042. Therefore, the ongoing operations of the proposed Project would result in a less than significant impact due to the non-cancer risk from diesel emissions from the project.

3.7 Air Quality Management Planning
The Project site is located within the Riverside County portion of the Salton Sea Air Basin, also known as the Coachella Valley planning area. The Coachella Valley is within the jurisdiction of the SCAQMD, which is responsible for monitoring criteria air pollutant concentrations and establishing management policies for the South Coast Air Basin as well as the Coachella Valley.

All development within the Coachella Valley, including the proposed Project, is subject to the provisions of the 2022 Air Quality Management Plan (2022 AQMP) as well as the 2003 Coachella Valley PM10 State Implementation Plan (2003 CV PM10 SIP). The 2022 AQMP describes the District’s plan to achieve Federal and State air quality standards set forth in the Federal and State Clean Air Acts. The 2003 CV PM10 SIP was prepared by SCAQMD in conjunction with the Coachella Valley Association of Governments (CVAG), Riverside County and other local jurisdictions. The plan includes PM10 control program enhancements and requests an extension of the region’s PM10 attainment date. The Coachella Valley is designated as a serious nonattainment area for PM10 and thus subject to the regulations in the 2003 SIP as well as the rules and regulations imposed by the SCAQMD, including Rule 403.1, which governs fugitive dust emissions from construction within the Coachella Valley.

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36 Southern California Association of Governments 2024 RTP/SCS SCAQMD works in conjunction with the Southern California Association of Governments (SCAG), county transportation commissions, and local governments. SCAG adopted the 2024-2050 Regional Transportation Plan / Sustainable Communities Strategy (2024 RTP/SCS) in April of 2024 to comply with metropolitan planning organization (MPO) requirements under the Sustainable Communities and Climate Protection Act. The Growth Management chapter of the RTP/SCS forms the basis of land use and transportation controls of air quality plans. Projects that are consistent with the projections of population forecasts are considered consistent with the AQMP.

The growth forecasts in the 2024 RTP/SCS are based in part on local jurisdiction land use plans in effect at the time of its development, including the City of Desert Hot Springs General Plan (adopted 2020) and the 2018 DLVSP (approved 2018). The revised Specific Plan proposed by the Project would reduce the maximum gross square footage by 397,799 SF and removes hotels as a permitted use. For the City of Desert Hot Springs, the 2024 RTP/SCS projects a household inventory of 24,600 by 2050 and an employment size of 9,400 by the same year (2050).

Residential development is not proposed as part of the Project buildout nor is rezoning an existing land use from nonresidential to residential. The Project would create new job opportunities related to construction and daily warehouse operations, however future employes are expected to be existing residents of the city and region. Overall, the proposed Project is consistent with the City’s land use designations and would not induce an unplanned population growth not accounted for in the 2024 RTP/SCS.

3.8 Odors
Some land uses can be sources of odors that, while not necessarily physically harmful, may be unpleasant and distressing to the public. The SCAQMD identifies land uses such as agriculture, chemical plants, composting operations, dairies, fiberglass molding, landfills, refineries, rendering plants, rail yards, and wastewater treatment plants as more likely to generate odors.

Development facilitated by the proposed Project, an industrial warehouse distribution facility, does not propose the operation of any development which typically emits objective odors, resulting in community complaints and health impacts. However, the Project proposes a sewer lift station on the southeast corner. The potential for the lift station to become a source of odor on-site is limited considering its location underground and development, in accordance with industry standards which include odor control measures. Therefore, the Project proposal to operate a distribution center and a lift station on-site would not emit objective odors which would otherwise affect nearby receptors. Less than significant impact from odor is anticipated.

3.10 CEQA Determination
a) Conflict with or obstruct implementation of the applicable air quality plan? As discussed in Section 3.7, the proposed Project is consistent with the land use designations for the site in the approved 2018 DLVSP and City’s General Plan and would not induce unplanned population growth outside the growth projections in the 2024 RTP/SCS. In addition, all Item Number: 1.

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37 development within the Coachella Valley, including the proposed Project, is subject to the provisions of the 2022 AQMP as well as the 2003 CV PM10 SIP.

Despite compliance with all applicable SCAQMD rules and regulations and application of projectspecific mitigation measures, operational NOx emissions from the proposed Project would still exceed the SCAQMD’s regional significance threshold during operation, primarily due to the Project’s high truck traffic volume. This exceedance would conflict with certain implementation measures in the 2022 AQMP, primarily the goal of reducing regional ozone concentrations.

However, as shown in Table 3-3, the proposed Project would generate substantially lower operational emissions of all criteria pollutants compared to the 2018 Project analyzed in the certified 2018 EIR. Notably, ROG emissions would be reduced to a less-than-significant level, which were previously identified as significant in the 2018 EIR. Therefore, operational air quality impacts of the proposed Project fall well within the envelope of impacts disclosed and analyzed in the previously certified 2018 EIR and would not result in any new or substantially more severe significant impacts.
b) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard?
Given the dispersing nature of pollutant emissions and aggregate impacts from nearby jurisdictions, cumulative air quality is evaluated on a regional scale. As previously described, the Coachella Valley portion of the Salton Sea Air Basin is a designated nonattainment region for PM10 and ozone. Any development resulting in emissions of PM10, ozone, or ozone precursors will, to some extent, contribute to existing regional nonattainment.

The SCAQMD does not currently provide thresholds of significance for the cumulative emissions of multiple projects. Instead, a project’s potential cumulative contributions can be analyzed using the criteria for project-specific impacts, assuming that if an individual development generates less than significant construction and operation emissions, then it would not generate a cumulatively considerable increase in nonattainment criteria pollutants.

The Project is located in a nonattainment area for PM10, as well ozone, for which precursors include CO, NOx, and ROG.

Construction Emissions
Emissions associated with on- and off-site construction (i.e., industrial, roadway improvements, utility, and flood control) will primarily consist of mobile sources emissions due to heavy equipment use including, but not limited to tractors, rollers, excavators, pavers, and forklifts which release exhaust from engine combustion while in use. Mitigations were selected in CalEEMod to reduce construction emission to below threshold standards. As shown in Table 3-2, the Project construction will not exceed SCAQMD daily maximum emissions during the highest daily emissions with mitigation. As such, construction emissions will not result in a net increase in the SSAB nonattainment for NOx or ozone. No federal or state ambient air quality standards Item Number: 1.

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38 will be violated by the Project’s temporary construction emission. For these reasons, construction emissions will result in less than significant impact with mitigation, in addition to air quality standards pursuant to SCAQMD Rule Book, as well as the City’s General Plan and DHS Municipal Code.

Operational Emissions
Operation of the Project will not exceed SCAQMD thresholds for CO, ROG, SOx, PM10, or PM2.5.

However, daily emissions during Project operations will exceed the SCAQMD threshold for NOx, as shown in Table 3-3. The subject site is located in a nonattainment area for PM10 and ozone, for which precursors include CO, NOx, and ROG. Given that the Project will exceed the SCAQMD threshold for NOx, it could make substantial contributions to the region’s existing air quality violation for ozone.

The majority of operational NOx emissions would result from mobile sources including employee trips and long-haul truck trips. Accordingly, project-generated traffic (and associated emissions) would be constant and occur throughout the life of the Project. Mitigation measures were applied to reduce mobile source emissions, nonetheless the Project would still exceed NOx emissions for SCAQMD operational daily maximum emissions. The use of public transit, carpooling, electric vehicles, and bicycle facilities would reduce Project-related vehicle trips, thereby reducing the Project’s NOx emissions. However, the selective use of alternative modes of transportation by on-site employees cannot be confidently quantified and applied as mitigation measures in a way that ensures operational NOx emissions will not exceed the SCAQMD’s maximum thresholds.

However, as shown in Table 3-3, the proposed Project would generate substantially lower operational emissions of all criteria pollutants compared to the 2018 Project analyzed in the certified 2018 EIR. Notably, ROG emissions would be reduced to a less-than-significant level, which were previously identified as significant in the 2018 EIR. Therefore, cumulative operational air quality impacts of the proposed Project fall well within the envelope of impacts disclosed and analyzed in the previously certified 2018 EIR and would not result in any new or substantially more severe significant impacts.
c) Expose sensitive receptors to substantial pollutant concentrations? The Project site is located within a rural region of the City planning area and bound by Interstate10 Freeway to the west and south. No development has occurred to the north, east, and west beyond the I-10. However, there is a residential parcel abutting the site immediately south and located within 1,000 feet from the proposed warehouse facility.

As discussed in Section 3.6, an operational HRA was prepared to evaluate the potential cancer and non-cancer risks the Project would pose to the nearby sensitive receptor. The HRA concluded that with mitigation (Mitigation Measure AQ-1), Project emissions would not exceed the maximum incremental cancer risk (MICR) threshold of 10 in a million nor would it exceed the non-cancer criterion of a Hazard Index increase of 1.0 or greater. Therefore, Project impacts to sensitive receptors would be less than significant with mitigation.

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39 d) Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
The Project does not propose land uses that typically generate objectionable odor, as discussed in Section 3.8. A sewer lift station is proposed at the site’s southeast corner, however potential odors are anticipated to be negligible considering its location underground and built to industry standards including odor control measures such as ventilation. The lift station will be subject to review by the City of Desert Hot Springs Building and Safety Department, ensuring that potential odors and resulting impacts are less than significant.

Development in accordance with management practices, especially for lift stations, ensures that the emission of odors from the Project will not adversely affect a substantial number of people, impacts are expected to be less than significant.

Mitigation Measures
AQ-1 To reduce cancer-related health impacts from the project to the residential dwelling located to the southeast of the project site, it is required that all on-site offroad equipment (forklifts and holsters/yard goats) shall be electric and that 350 of delivery trucks utilizing the project site shall be electric trucks. The project shall install electrical charging infrastructure to accommodate the electric vehicles.

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40 4 CLIMATE CHANGE SETTING

4.1 Introduction to Greenhouse Gases and Climate Change Greenhouse gases, or GHG, are gases that absorb infrared radiation in the atmosphere. They are named after their role in the greenhouse effect, which refers to the trapping of heat in the atmosphere, near the earth’s surface. Like the function of the walls of a greenhouse, as heat flows towards space from the earth’s surface, GHGs absorb it and re-radiate it back towards the earth’s surface.19 Greenhouse gases play an essential role in insulating the earth and thereby maintaining climatic conditions amenable to life as we know it.

While GHGs are vital, maintaining balance in the system is also crucial. Over the last two centuries, human activity, such as the burning of fossil fuels, industrial activity, deforestation, and land use changes, began to intensify the natural greenhouse effect. While the combustion of fossil fuels produces and emits greenhouse gases into the atmosphere at levels elevated far beyond the natural production of these gases, the removal of trees and other vegetation reduce the earth’s ability to sequester CO2.
20 As the concentrations of these gases increase, so too does the amount of heat that they trap in the atmosphere and the oceans. The resulting warming of the earth’s climate is known as climate change.

4.1.1 Greenhouse Gases
According to the Intergovernmental Panel on Climate Change (IPCC) Sixth Assessment Report (AR6), atmospheric concentrations of CO2 have increased by 50 percent since the industrial revolution and continue to increase at a rate of two parts per million each year. At this rate, the world will likely exceed 1.5°C above pre-industrial levels between 2030 and 2052.21 This level of global warming is associated with global mean sea level rise as well as regional climatic changes such as extreme temperatures, increases in the frequency and intensity of heavy precipitation in some regions, and increases in the intensity and frequency of droughts in some regions.22 Greenhouse gas is a broad term referring to chemicals and substances found to cause changes in the atmosphere and the changing of the earth’s climate. While these are not the only greenhouse gases, the California Air Resources Board is required to monitor and regulate seven GHGs: carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), sulfur hexafluoride (SF6), nitrogen trifluoride 19 United Nations Framework Convention on Climate Change – GHG Inventories. 20 California Air Resources Board 2022 Scoping Plan, Environmental and Regulatory Setting. 21 IPCC, 2018: Global Warming of 1.5°C. An IPCC Special Report on the impacts of global warming of 1.5°C above pre-industrial levels and related global greenhouse gas emission pathways, in the context of strengthening the global response to the threat of climate change, sustainable development, and efforts to eradicate poverty [Masson-Delmotte, V., P. Zhai, H.-O. Pörtner, D. Roberts, J. Skea, P.R. Shukla, A. Pirani, W. Moufouma-Okia, C.

Péan, R. Pidcock, S. Connors, J.B.R. Matthews, Y. Chen, X. Zhou, M.I. Gomis, E. Lonnoy, T. Maycock, M. Tignor, and T. Waterfield (eds.)]. Cambridge University Press, Cambridge, UK and New York, NY, USA, 616 pp. https://doi.org/ 10.1017/9781009157940. 22 Ibid.

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41 (NF3), perfluorocarbons (PFCs), and hydrofluorocarbons (HFCs).23 The latter four gases, all of which contain fluorine, are sometimes collectively referred to as high global warming potential greenhouse gases (high-GWP gases).

Global warming potential (GWP) is a metric used to convert all GHGs into carbon dioxide equivalents. Carbon dioxide equivalents (CO2e), and specifically metric tons of carbon dioxide equivalents (MTCO2e), are units of measure used to compare emissions of various greenhouse gases. Carbon equivalent refers to the mass of carbon dioxide that would produce the same estimated radiative force as that of another greenhouse gas. 24 These metrics facilitate the development of multi-gas frameworks and policies which are crucial to action addressing climate change.

Table 4-1 describes the primary GHGs, the contribution of each gas to California’s total GHG emissions, and the main sources of emissions. The transportation sector is the largest emitter of GHGs in California, followed by the generation of electricity.25 Table 4-1
Sources of GHGs from Human Activities
GHG
% of
California’s
2020 GHG
emissions 1
Description Sources2
Carbon
Dioxide
(CO2)

80.2%
Odorless and colorless gas that is
naturally emitted by the
decomposition of dead organic
matter, oceans, and volcanoes, as
well as the respiration of plants,
animals and fungus.

CO2 is naturally sequestered in
trees and other vegetation,
oceans, soils, and ice caps.

Fossil fuel combustion for
transportation, electricity, and
industry.

Other sources include burning solid
waste, trees and other biological
materials, as well specific chemical
processes for the industrial
production of materials such as
cement.

Methane
(CH4) 10.5%3
A natural byproduct of biological
processes in low oxygen
environments such as bogs or at
the roots of rice crops, as well as
in cattle raising.

CH4 absorbs more radiation than
CO2 but has a lower atmospheric
concentration.

Fugitive emissions from fossil fuel
operations and transport.

Off-gassing from agricultural
practices and landfills.
23 California Health and Safety Code § 38505 (g). 24 California Air Resources Board. 25 California Air Resources Board 2022 Scoping Plan Update, Environmental and Regulatory Setting.

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42 Table 4-1
Sources of GHGs from Human Activities
GHG
% of
California’s
2020 GHG
emissions 1
Description Sources2
Nitrous
Oxide
(N2O)

3.5%3
Colloquially known as laughing
gas, a colorless gas that can
cause dizziness and euphoria in
small doses.

Agricultural practices, particularly
nitrogen-base fertilizers.

Soil management, wastewater
treatment, and solid waste from land
use and industrial activity.

High-GWP
gases

5.8%3
Hydrofluorocarbons (HFCs):

Synthetic gases that have the
highest GWP of all GHGs, though
they represent a small proportion
of emissions.

Perfluorocarbons (PFCs):

Synthetic gases stable molecular
structures and very long lifetimes
in the atmosphere.

PFCs and HFCs: Used as substitutes
for chlorofluorocarbons (CFCs),
ozone-depleting substances used in
refrigeration, air conditioning,
solvents, and aerosol products.

Sulfur Hexafluoride (SF6): A
synthetic, odorless, colorless,
nontoxic and nonflammable gas.

SF6: Electricity transmission and
distribution and in semiconductor
manufacturing.

Nitrogen trifluoride (NF3): A
synthetic, colorless, toxic gas
with a musty odor.

NF3: Semiconductor manufacturing.
1 Source: California Air Resources Board.
2 Sources: California Air Resources Board 2022 Scoping Plan Update, Environmental and Regulatory Setting; U.S. EPA, Overview of Greenhouse Gases, https://www.epa.gov/ghgemissions/overview-greenhouse-gases (accessed October 2025). 3 In carbon dioxide equivalent units.

4.1.2 Climate Change in California
California is the second largest greenhouse gas producing state in the U.S., and the 16th largest contributor in the world; it is also the fifth largest economy in the world. In 2022, emissions from GHG emitting activities in California were 371.1 MMTCO2e, 9.3 MMTCO2e below 2021 levels and

59.9 MMTCO2e below the 2020 GHG Limit. The 2023 emissions of 360.4 MMTCO2e demonstrates that the State of California is continuing its established long-term trend of GHG emissions declines, despite the anomalous emissions trends from 2019 through 2021, due in large part to the impacts of the COVID-19 pandemic. Figure 4.1 shows that the state’s success in reducing GHG emissions since 2000 and Figure 4-2 breaks down 2023 emissions by economic sector.

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43 Figure 4-1: Annual Statewide GHG Emissions Compared to the 2020 GHG Limit Source: California Greenhouse Gas 2000-2022 Emissions Trends and Indicators Report Figure 4-2: 2023 GHG emissions by economic sector (% of total California emissions) Source: California Air Resources Board, Current California GHG Emission Inventory Data.

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44 Carbon dioxide is the primary greenhouse gas emitted in California. Transportation, particularly on-road travel, is the predominant source of carbon dioxide emissions in California, and as shown in Figure 4-2, accounted for 38% of MMT CO2e in the state in 2023.

While research into the effects of climate change continues to evolve, such as determining the severity of impacts at specific temperature increases, current and emerging impacts are becoming increasingly evident in climatic events globally. The impacts of climate change are apparent in California in effects such as the increasing frequency and severity of wildfires, droughts, and extreme heat.

Extreme Heat: California’s daily maximum average temperature, an indicator of extreme temperature trends, is expected to increase 4.4°F - 5.8°F by 2050 and 5.6°F - 8.8°F by 2100.26 Many regions in the state broke their previous records for hottest measured temperature, and as a whole California had its hottest summer on record in 2021.27 Heat waves are occurring more frequently and are enduring longer, resulting in deadly public health crises, particularly in cities, across the state. Like many other effects of climate change and air pollution, the adverse impacts of heat waves are felt most acutely by vulnerable communities, including people with sensitive health conditions and low-income populations. Higher temperatures can also exacerbate natural disasters such as storms, heat waves, floods, and droughts.

Drought: According to CARB, 87% of California was in severe drought, and 100% of California was in at least moderate drought, as of March 2022. While droughts are a natural phenomenon, it is estimated that human-caused climate change accounts for 19% of drought severity and 42% of the soil moisture deficit in the state since 2000.28 Severe and enduring drought is harmful to both wildlife and California’s agricultural industry, which is responsible for growing more than half of the country’s produce.29 Combined, drought and extreme heat contribute to worsening wildfires in California.

Wildfires: Large wildfires are occurring more frequently in California: of the twenty largest wildfires recorded in the state’s history, almost half of them occurred in 2020 and 2021.30 In addition to the damage and lives lost directly from these fires, wildfire impacts compound with other impacts and causes of climate change. For example, wildfires in California result in severe air quality hazards and substantially harm wildlife populations, and the fires also result in the further emission of massive quantities of CO2 into the atmosphere.

Beyond these three hazards, climate change is expected to have wide ranging effects to California’s water and energy supply, sea level, and ecosystems. Coastal flooding is expected to occur because of rising sea levels paired with severe wind and rains. Inland flooding is expected 26 California Air Resources Board, 2022 Scoping Plan for Achieving Carbon Neutrality (November 2022), p.5. 27 Ibid. 28 Ibid. 29 Ibid. 30 Ibid.

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45 to occur in areas where levees are at risk, for example because of the sinking of the SacramentoSan Joaquin Delta.31

4.1.3 GHGs and Health Impacts
While some greenhouse gases are hazardous to human health if encountered in high concentrations in confined areas, the public health impacts associated with GHGs are primarily those associated with their combined influence on climate change. Climate change and its effects are responsible for a wide range of potential hazards to public health, both direct and indirect.

Direct health impacts resulting from climate change include heat-related illnesses, such as heat stroke, as well as injuries and death from natural disasters and extreme weather, such as wildfires.

Climate change is also associated with indirect adverse health impacts, such as:
• Exacerbation of cardiovascular and respiratory disease due to increased smog and wildfire smoke.
• Increased rates and expanding geographic ranges of vector-borne and fungal diseases. • Nutrition consequences associated with food insecurity worsened by decreased agricultural production.
• Mental trauma related to extreme weather disasters and other mental health impacts due to climate change-related unemployment, income loss, home loss, or displacement.32
According to the California Air Resources Board, while climate change is one of the greatest public health threats of the twenty-first century, action to address climate change presents one of the most significant opportunities to improve public health, both globally and in California.33

4.2 Regulatory Setting
The following section outlines regulatory actions being taken to address climate change and reduce GHG emissions at the international, federal, state, and regional levels.

4.2.1 International
Intergovernmental Panel on Climate Change (IPCC)
The IPCC was founded in 1988 by the World Meteorological Organization (WMO) and the United Nations Environment Programme (UNEP). The organization is comprised of member governments of the WMO and UN. The mission of the IPCC is to provide scientific research to governments in order to inform climate policies.
31 California Air Resources Board, Draft 2022 Scoping Plan Update, Environmental and Regulatory Setting. 32 California Air Resources Board, Draft 2022 Scoping Plan Update (May 2022), p.127. 33 California Air Resources Board, Draft 2022 Scoping Plan Update Appendix G: Public Health.

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46 United Nation’s Framework Convention on Climate Change (UNFCCC) The UNFCCC was signed by 154 member nations in 1992 and now has 198 members. The Convention guides the global response to climate change with the objective of stabilizing greenhouse gas concentrations at a level that would mitigate the dangerous consequences of climate change. The UNFCCC defines climate change as: “a change of climate which is attributed directly or indirectly to human activity that alters the composition of the global atmosphere, and which is in addition to natural climate variability observed over comparable time periods.”34 The UNFCCC is the parent treaty of the Kyoto Protocol and Paris Agreement. While the UNFCC sets targets for GHG concentrations, the 1997 Kyoto Protocol established binding targets for the 192 signatory parties. The Paris Agreement was adopted in 2015 as a legally binding international treaty signed by 196 parties. It aims to limit global warming to less than 2 degrees Celsius above pre-industrial levels by setting nationally determined contributions (NDCs) of increasingly ambitious climate action on 5-year cycles.35

4.2.2 Federal
GHG Endangerment Finding
Under section 202(a) of the Clean Air Act, the EPA determined that GHGs threaten public health and welfare, and that GHG emissions from motor vehicles contribute to this threat. The two distinct findings, signed by the EPA Administrator in December 2009, found that:

1. The Endangerment Finding: Concentrations of six greenhouse gases (carbon dioxide, methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride) in atmosphere constitute air pollution and threaten the health and welfare of the public.

2. The Cause or Contribute Finding: Emissions from new motor vehicles and motor vehicle emissions contribute to GHG concentrations in the atmosphere and thus to climate change.36
Mandatory Reporting of GHGs (40 CFR Parts 86, 87, 89 et al.) The Mandatory Reporting of Greenhouses Gases rule requires reporting of greenhouse gas emissions from major fossil fuel suppliers, industrial gas suppliers, direct greenhouse gas emitters and manufacturers of heavy-duty and off-road vehicles and engines. The rule requires facilities that emit 25,000 tons or more per year (MT/yr) of GHGs to submit annual reports to the EPA.37 New Source Review (NSR)
The New Source Review Permitting program was established by Congress in 1977 as part of the Clean Air Act Amendments. The program requires new industrial facilities, or facilities making changes that will increase emissions significantly, to obtain permits limiting air emissions prior to construction. Permits are issues by state or local air pollution control agencies, and sometimes 34 United Nations Framework Convention on Climate Change, Article 1 (2). 35 United Nations Climate Change, UNFCCC Process, The Paris Agreement https://unfccc.int/process-andmeetings/the-paris-agreement/the-paris-agreement (Accessed February 2025). 36 United States Environmental Protection Agency, EPA’s Endangerment Finding. 37 Federal Register, Part II Environmental Protection Agency (October 30, 2009).

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47 the EPA. The program requires that new sources meet the requirements for one or more of the following permits: Prevention of Significant Deterioration (PSD) permits, Nonattainment NSR permits, and minor source permits.

4.2.3 State
Assembly Bill 32 (AB 32)
The California Global Warming Solutions Act of 2006 (AB 32) required California to adopt regulations in order to reduce their GHG emissions to 1990 levels by 2020. This represents reductions of approximately 15 percent below the emissions projected in a “business as usual” scenario. The California Air Resources Board (CARB) prepared a Scoping Plan (2008) and Update (2014) to establish the state’s strategy to meet the targets set forth by AB 32. CARB reported that 1990 GHG emissions totaled 431 million metric tons (MMT) for the state of California. In 2020, statewide GHG emissions totaled 369.2 MMT of CO2e, which is 61.8 MMTCO2e below the 2020 GHG limit pursuant to AB 32. 38 Moving forward, AB 32 requires California to maintain and continue reductions beyond 2020 and continues to require CARB to update the Scoping Plan every 5 years.

Senate Bill 32 (SB 32)
The California Global Warming Solutions Act of 2016: emissions limit (SB 32) builds on AB 32 by establishing a new goal for California’s greenhouse gas reductions. SB 32 requires California to reduce GHG emissions to 40% below 1990 levels by 2030, and to reduce emissions to 80% below 1990 levels by 2050.

CARB 2022 Scoping Plan Update
The 2022 Scoping Plan provides CARB’s update to the 2017 Plan. Pursuant to SB 32, the plan sets forth the state’s plan to stay on track towards reducing GHG emission by at least 40% below 1990 levels by 2030. The 2022 Plan Update expands on earlier targets, establishing a new goal of reducing GHG emissions to 85% below 1990 levels by 2045. Additionally, the 2022 Plan Update establishes a path for the state to achieve carbon neutrality by 2045 through technologically feasible, cost-effective means.39
Senate Bill 375 (SB 375)
SB 375 directs CARB to set regional GHG emissions reduction targets. The intent of the bill is to ensure local and regional governments are involved in efforts to meet the reduction targets set forth by AB 32 and SB 32. Alignment between state and local emission reduction efforts is important particularly because regional transportation planning and housing needs allocation, factors that have a major impact on GHG emissions in California, are overseen by local elected officials. The bill encourages an integrated approach by requiring the inclusion of Sustainable Communities Strategies in regional transportation plans, synchronizing the General Plan Housing Elements update schedule to align with regional transportation planning cycles, and adding CEQA incentives for projects that align with regional plans and reduce GHG emissions. 38 California Air Resources Board, California Greenhouse Gas Emissions for 2000 to 2020 (October 2022). 39 California Air Resources Board, 2022 Scoping Plan for Achieving Carbon Neutrality (November 2022).

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48 Clean Energy and Pollution Reduction Act of 2015 (SB 350) SB 350 establishes a state renewable energy procurement goal, increasing from 33% by 2020 to 50% by 2030. It is implemented by the California Energy Commission in conjunction with state agencies including the Public Utilities Commission and CARB. The bill also requires large utilities companies to prepare integrated resource plans (IRPs) that establish how the utilities will meet customer demands while reducing GHG emissions and increasing the use of clean energy sources.

Title 24 of the California Code of Regulations
Title 24 of the California Code of Regulations was established in 1978 and serves to enhance and regulate California’s building standards. The Building Energy Efficiency Standards, Parts 6 and 11 of Title 24, are updated by the California Energy Commission (CEC) every three years.

The 2022 California Energy Code (Title 24, Part 6), which became effective on January 1, 2023, provides measures to continue reducing energy consumption in California. The 2022 Update includes regulations encouraging efficient electric heat pumps, establishing electric-ready requirements for appliances and mechanical systems in new homes, strengthening ventilation standards, as well as expanding solar photovoltaic and battery storage standards. According to the Energy Code, all single-family residential buildings, low-rise and high-rise multifamily buildings, as well as non-residential buildings such as grocery stores, offices, retail, hotels, and restaurants, must have a newly installed photovoltaic (PV) system. Additionally, all high-rise residential and non-residential buildings required to have PV systems must also have a battery storage system that meets the requirements provided in Section 140.10 of the Energy Code.

Title 24 also includes Part 11, the California Green Building Standards Code (CALGreen). The California Building Standards Commission first developed “green” standards in 2007 to meet the greenhouse gas reduction targets established by AB 32. The 2022 CALGreen standards, effective as of January 1, 2023, institute mandatory minimum environmental performance standards for all new construction of commercial, residential, and State-owned buildings, as well as schools and hospitals. According to CALGreen Section 4.106, all new single family and multifamily dwellings, as well as hotels, must be built with EV capable parking spaces. One and two-family dwellings must include one EV capable space per dwelling unit, and multifamily buildings and hotels must build a proportion of all provided parking to be either EV Capable or EV Ready.40 In accordance with Section 5.106, all new non-residential developments must provide both a portion of parking spaces are that EV capable, as well as a portion of spaces with EV charging stations.

Senate Bill 97 (SB 97)
SB 97 recognized the need for state agencies to analyze GHG emissions as part of the California Environmental Quality Act project review process. The bill updated CEQA to require the Office of 40 EV Capable refers to parking spaces which have electrical panel capacity, a dedicated branch circuit, and a raceway to support future installation of a charging station. EV Ready refers to the same conditions as EV Capable, with the addition of other electrical components as well as a receptable or blank cover to support future installation of a charging station.

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49 Planning and Research (OPR) to develop guidelines for the feasible mitigation of GHG emissions, of the effects of GHG emissions, to be transmitted to the California Air Resources Board for approval. The adopted guidelines apply to effects associated with transportation and energy consumption.

Assembly Bill 1493 – The Pavley Bill
California was the first state to establish regulations that require the reduction of emissions of GHGs from motor vehicles. On September 24, 2004, the California legislature adopted the Pavley Bill that requires all motor vehicles of 2009 vintage or later to reduce their greenhouse gas emissions by about 30% by the year 2016. The second phase of the implementation for the Pavley bill was incorporated into Amendments to the Low-Emission Vehicle Program (LEV III) or the Advanced Clean Cars program. The Advanced Clean Car program combines the control of smogcausing pollutants and GHG emissions into a single coordinated package of requirements for model years 2017 through 2025. The regulation will reduce GHG emissions from new cars by 34% from 2016 levels by 2025.

Approved in November 2022, the Advanced Clean Cars II (ACC II) regulations require that all new passenger cars, trucks, and SUVs sold in California are zero emission vehicles by 2035.

4.2.4 Local
SCAQMD GHG Significance Thresholds
On December 5, 2008, the SCAQMD formally adopted a greenhouse gas significance threshold for stationary sources of 10,000 MTCO2e per year for industrial projects and 3,000 MTCO2e per year for residential and commercial projects where SCAQMD is the lead agency (SCAQMD Resolution No. 08-31). This threshold was adopted based upon a December 2008 staff report and draft interim guidance document that also recommended thresholds for all projects using a tiered approach.41
It was recommended by SCAQMD staff that a project’s greenhouse gas emissions would be considered significant if it could not comply with at least one of the following “tiered” tests:
• Tier 1: Is there an applicable exemption?
• Tier 2: Is the project compliant with a greenhouse gas reduction plan that is, at a minimum, consistent with the goals of AB 32?
• Tier 3: Is the project below an absolute threshold (10,000 MTCO2e/yr for industrial projects; 3,000 MTCO2e/yr for residential and commercial projects)? • Tier 4: Is the project below a (yet to be set) performance threshold? • Tier 5: Would the project achieve a screening level with off-site mitigation? 41 SCAQMD, Interim CEQA GHG Significance Threshold for Stationary Sources, Rules and Plans (December 2008).

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50 Desert Hot Springs General Plan
The City General Plan incorporates a greenhouse gas emission reduction section to set forth policies promoting pollution control, as well as land use and transportation measures to reduce greenhouse gas emissions. The following policies from the subsections are relevant to the proposed Project:

Open Space and Natural Resources
GOAL OS-2 Air quality that is healthy for residents and the environment OS-2.8: Air Quality and Climate Change Analyses. Require detailed air quality and climate change analyses and mitigation plans for all applications that have the potential to adversely affect air quality
GOAL OS-4 Increased energy efficiency and conservation
OS-4.4 Solar Energy Systems. Encourage the use of solar energy systems or any other technologies that similarly reduce the use of power from the grid in residential and commercial uses.

GOAL OS-6 Sustainable development approaches
OS-6.1 Sustainable Construction. Encourage sustainable construction practices and the use of energy-saving technology within buildings. Consider establishing a green building program that draws from the LEED (Leadership in Energy & Environmental Design) standards.

Mobility and Infrastructure Element
MI 5.1 Implement development and transportation improvements that help reduce greenhouse gas emissions by reducing per capita Vehicle Miles Traveled (VMT), reducing impacts on the City’s transportation network, and maintaining the desired service levels for all modes of transportation.

MI 5.2 Implement sustainable transportation and land use strategies that can effectively reduce vehicle miles traveled. Consider using vehicle daily trips as the benchmark demand for determining potential level of parking and vehicular congestion.

MI 5.3 Support the development of a network of public and private clean and/or carbon-neutral fuel vehicle charging and fueling stations.

MI 5.6 Consider the use of sustainable and carbon-neutral material when repaving, repairing, or constructing streets and other transportation facilities.

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51 5 PROJECT GREENHOUSE GAS IMPACT

5.1 Introduction
In accordance with CEQA, this following analyzes the proposed Project and demonstrates that all potential GHG impacts associated with the Project at buildout would be within the envelope of impacts already evaluated in the approved 2018 EIR.

5.2 Standards of Significance
According to the 2022 CEQA Guidelines (Appendix G: Environmental Checklist), the project would have a significant effect on greenhouse gases if the Project were to:
a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment.
b) Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases.

5.3 Methodology
The Project will generate GHG emissions during both the construction and the operational phases.

As described in Section 3.3, construction and operational emissions, including GHGs, were projected using California Emissions Estimator Model (CalEEMod) Version 2022.1. CalEEMod is a computer program that can be used to estimate future air quality and GHG emissions associated with land development projects in California. The model projects the generation of GHG emissions based on land use factors.

Please see Section 3.3 for a detailed description of the modeling assumptions used for this report.

CalEEMod output tables are provided in Appendix A and B.

The Project’s GHG emissions are analyzed using SCAQMD tier system which sets a GHG threshold at 3,000 MT CO2e per year.

5.4 Construction Emissions
Construction activities will result in short-term GHG emissions associated with the operation of construction equipment, vehicle emissions from construction employee commutes, material hauling, and other ground disturbing activities.

For analysis purposes, it is assumed that Project construction would occur over a 24-month period, with an operational year of 2028.42 Construction would be phased as follows:
42 For analysis purposes, CalEEMod was run for the Project assuming a seven-year buildout and an operational year of 2032 based on the estimated buildout year provided in the approved Traffic Impact Analysis (TIA), prepared for the Project by Urban Crossroads, Inc.

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52 ● Grading: 5/1/2026 to 8/6/2026; 70 days
● Building Construction: 8/7/2026 to 2/17/2028; 400 days ● Paving: 2/18/2026 to 4/21/2026; 45 days
● Architectural: 2/8/2028 to 5/1/2028; 60 days
● Linear, Grading & Excavation: 8/7/2026 to 10/29/2026; 60 days ● Linear, Drainage, Utilities, & Sub-Grade: 9/1/2026 to 11/23/2026; 60 days ● Linear, Paving: 10/1/2026 to 12/23/2026; 60 days
There are currently no construction-related GHG emissions thresholds for projects of this nature.

Therefore, construction-related GHG emissions were amortized over a 30-year period and added to the annual operational emissions, consistent with SCAQMD’s methodology. For an assumed buildout in 2028, the Project is projected to generate 4,997 metric tons of CO2e over the 24- month construction.

5.5 Operational Emissions
Once the Project reaches the operational phase, eight categories of emissions will contribute to its annual GHG emissions either directly or indirectly: area emissions (i.e., pavement, landscape equipment, and architectural coating), energy use (i.e., electricity and natural gas), mobile source emissions (i.e., passenger vehicles and delivery trucks), solid waste disposal, water use, refrigerant use, stationary sources (i.e., emergency generators, fire pumps), and off-road equipment (i.e., forklifts, yard goats).

The following operational mitigation measures were selected in CalEEMod:
● Provide employer-sponsored vanpool service to at least 80% of the workforce. ● Require energy efficiency appliances for commercial refrigerators in the Industrial Park ● Require an on-site photosynthetic energy system to offset at least 10 percent of the proposed Industrial Park and Unrefrigerated Warehouse space projected energy demand. ● Public street and area lighting shall use high efficiency lighting, such as LED lighting. ● Require all faucets, toilets, and showers to utilize low-flow fixtures to reduce indoor water demand by 20%. This measure is required by CalGreen Building Standards Code. ● Employ water efficient landscaping practices on-site. ● Implement a solid waste reduction plan to diverge at least 75 percent of all generated waste.
● Require the paint for architectural coating to consist of a VOC content percentage of 10g/L for interior and exterior use of nonresidential use and 100g/L for parking. ● All on-site offroad equipment (forklifts and holsters/yard goats) shall be electric and that 350 of delivery trucks utilizing the project site shall be electric trucks. The project shall install electrical charging infrastructure to accommodate the electric vehicles.

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53 As stated above, GHG emissions from construction of the Project were amortized over a 30-year period and added to the total operational emissions. Table 5-1 shows a summary of the total annual construction and operational GHG emissions projected for buildout of the Project in 2028 compared to the emissions reported in the 2018 EIR.

As shown in Table 5-1 below, the Project would generate 19,038.53 MTCO2e per year with mitigation, which is a 36.4 percent reduction in emissions compared to 2018 Project emissions.

Table 5-1
Projected GHG Emissions Summary with Mitigation
Phase Unmitigated Mitigated 2018 Project
Mitigated
MTCO2e (MT/YR)
Construction
2026 2,425 2,425 --
2027 2,235 2,235 --
2028 337 337 --
Construction Total: 4,997 4,997 --
Operation
Area 22 22 0.4
Energy 2,921 4,412 1,806.70
Mobile 20,513 14,139 19,986.15
Waste 447 112 287.29
Water 30.1 27.7 1,748.19
Refrigerants 3.23 3.23 --
Off-Road 374 0 --
Stationary 156 156 --
Sequestration from Trees -- -- -15.47
Construction: 30-years amortized 166.6 166.6 141,63
Total Operational 24,632.93 19,038.53 29,954.52
Net Reduction with Mitigation 10,915.99 MTCO2e reduction compared to 2018 Project Source: CalEEMod detailed reports, Appendix A for unmitigated emissions, Appendix B for mitigated emissions.

5.7 CEQA Determination
a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment.

The Project would emit CO2e during the temporary construction period and long-term operation.

The SCAQMD ‘tier’ test was used to determine the Project’s potential for significant environmental impacts from CO2e emissions. The Tier 3 threshold (3,000 MTCO2e) is used as the primary tier in evaluating the Project’s significance, consistent with the 2018 EIR analysis.

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54 A CalEEMod run for GHG emissions was modeled for the Project, assuming a construction period of 24-months starting in May 2026 with a full buildout by 2028. A description of the modeling methodology and list of CalEEMod inputs are provided in Section 3.3 and CalEEMod emission outputs are provided in Appendix A and B. Results indicate that construction activities and use of heavy equipment would release 4,997 metric tons of CO2e over the 24-month construction with mitigation. These emissions would occur only once and cease after the construction period has ended. Considering that SCAQMD does not have a GHG emission threshold for construction, the Project’s total construction emissions were amortized over 30-year and added to the total annual operation emissions, consistent with the 2018 EIR analysis.

Operational emissions stem from eight primary sources including mobile, area, energy, water, waste, refrigerants, stationary, and off-road equipment. As shown in Table 5-1, the combination of operational emission sources, in addition with the Project’s construction amortized emissions over a 30-year period, the total GHG emissions during operation is estimated at 19,038.53 metric tons of CO2e per year under mitigation conditions. Annual emissions levels from the proposed Project substantially exceed SCAQMD annual maximum threshold of significance set at 3,000 MTCO2e/yr. However, the proposed Project would result in 10,915.99 MTCO₂e fewer emissions than the 2018 Project. Therefore, GHG emission-related impacts of the proposed Project fall well within the envelope of impacts disclosed and analyzed in the previously certified 2018 EIR and would not result in any new or substantially more severe significant impacts. b) Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases.

The Project would be required to comply with all development standards set by California Code of Regulation, CalGreen Building Code, Title 24, City General Plan, and City Municipal Code of which require energy efficiency, water conservation, solid waste diversion during construction and operation so as to reduce GHG emissions. Project mitigation also requires that all on-site offroad equipment (forklifts and holsters/yard goats) be electric and that 350 of delivery trucks utilizing the project site shall be electric trucks, further reducing mobile-related GHG emissions.

Furthermore, the Project would comply with SCAQMD rules and regulation for emission control measures. Although adherence to regulatory standards and application of mitigation measures would not reduce GHG emissions below the SCAQMD tiered thresholds, GHG emission-related impacts of the proposed Project fall well within the envelope of impacts disclosed and analyzed in the previously certified 2018 EIR and would not result in any new or substantially more severe significant impacts.

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55 6 REFERENCES
American Farmland Trust, A New Comparison of Greenhouse Gas Emissions from California Agricultural and Urban Land Uses (2015).

California Air Resources Board, National Ambient Air Quality Standards https://ww2.arb.ca.gov/resources/national-ambient-air-quality-standards (Accessed May 2024).

California Air Resources Board Proposed 2022 State SIP Strategy (August 2022).

California Air Resources Board, 2022 Scoping Plan for Achieving Carbon Neutrality (November 2022).

California Air Resources Board 2022 Scoping Plan, Environmental and Regulatory Setting.

California Air Resources Board, Sources of Air Pollution, https://ww2.arb.ca.gov/resources/sources-air-pollution (Accessed May 2024).

California Air Resources Board, Toxic Air Contaminant Identification Reports https://ww2.arb.ca.gov/resources/documents/toxic-air-contaminant-identificationreports (accessed May 2024).

California Health and Safety Code § 38505 (g).

Coachella Valley Extreme Area Plan for 1997 8-Hour Ozone Standard.

County of Riverside, Climate Action Plan Update (November 2019).

Federal Register, Part II Environmental Protection Agency (October 30, 2009).

Final 2002 Coachella Valley PM10 State Implementation Plan.

Final 2003 Coachella Valley PM10 State Implementation Plan. iAdam: Air Quality Data Statistics, California Air Resources Board; www.arb.ca.gov/adam.

IPCC Climate Change 2021: The Physical Science Basis. Contribution of Working Group 1 to the Sixth Assessment Report of the IPCC (2021).

IPCC Special Report: Global Warming of 1.5°C – Summary for Policymakers (2018).

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56 South Coast Air Quality Management District, Air Quality Significance Thresholds (April 2019) South Coast Air Quality Management District, Fact Sheet for Applying CalEEMod to Localized Significance Thresholds, http://www.aqmd.gov/docs/defaultsource/ceqa/handbook/localized-significance-thresholds/caleemod-guidance.pdf (accessed May 2024).

South Coast Air Quality Management District, Final 2022 Air Quality Management Plan.

South Coast Air Quality Management District, Final 2022 Air Quality Management Plan, Appendix 1: Health Effects (November 2022).

South Coast Air Quality Management District, Interim CEQA GHG Significance Threshold for Stationary Sources, Rules and Plans (December 2008).

United Nations Framework Convention on Climate Change – GHG Inventories.

United Nations Climate Change, UNFCCC Process, The Paris Agreement https://unfccc.int/process-and-meetings/the-paris-agreement/the-paris-agreement (Accessed May 2024).

United States Environmental Protection Agency, EPA’s Endangerment Finding.

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57 7 APPENDICES
Appendix A: Desert Hot Springs Varner Road Specific Plan Detailed Report, CalEEMod Version 2022.1, prepared by Terra Nova Planning & Research, Inc. September 11, 2025.

Appendix B: Desert Hot Springs Varner Road Specific Plan- HRA Electric Vehicle Mitigation Detailed Report, CalEEMod Version 2022.1, prepared by Terra Nova Planning & Research, Inc.

September 11, 2025.

Appendix C: DHS Varner Road Operational Health Risk Assessment (HRA) Analysis, prepared by KW Air Quality & Noise LLC. October 2, 2025.

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B
Appendix A
Desert Hot Springs Varner Road Specific Plan Detailed Report, CalEEMod Version 2022.1, prepared by Terra Nova Planning & Research, Inc. September 11, 2025.

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Table of Contents

1. Basic Project Information

1.1. Basic Project Information

1.2. Land Use Types

1.3. User-Selected Emission Reduction Measures by Emissions Sector

2. Emissions Summary

2.1. Construction Emissions Compared Against Thresholds

2.2. Construction Emissions by Year, Unmitigated

2.3. Construction Emissions by Year, Mitigated

2.4. Operations Emissions Compared Against Thresholds

2.5. Operations Emissions by Sector, Unmitigated

2.6. Operations Emissions by Sector, Mitigated

3. Construction Emissions Details

3.1. Linear, Grading & Excavation (2026) - Unmitigated

3.2. Linear, Grading & Excavation (2026) - Mitigated

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3.4. Linear, Drainage, Utilities, & Sub-Grade (2026) - Mitigated

3.5. Linear, Paving (2026) - Unmitigated

3.6. Linear, Paving (2026) - Mitigated

3.7. Grading (2026) - Unmitigated

3.8. Grading (2026) - Mitigated

3.9. Building Construction (2026) - Unmitigated

3.10. Building Construction (2026) - Mitigated

3.11. Building Construction (2027) - Unmitigated

3.12. Building Construction (2027) - Mitigated

3.13. Building Construction (2028) - Unmitigated

3.14. Building Construction (2028) - Mitigated

3.15. Paving (2026) - Unmitigated

3.16. Paving (2026) - Mitigated

3.17. Architectural (2028) - Unmitigated

3.18. Architectural (2028) - Mitigated

4. Operations Emissions Details

4.1. Mobile Emissions by Land Use

4.1.1. Unmitigated
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4.1.2. Mitigated

4.2. Energy

4.2.1. Electricity Emissions By Land Use - Unmitigated

4.2.2. Electricity Emissions By Land Use - Mitigated

4.2.3. Natural Gas Emissions By Land Use - Unmitigated

4.2.4. Natural Gas Emissions By Land Use - Mitigated

4.3. Area Emissions by Source

4.3.1. Unmitigated

4.3.2. Mitigated

4.4. Water Emissions by Land Use

4.4.1. Unmitigated

4.4.2. Mitigated

4.5. Waste Emissions by Land Use

4.5.1. Unmitigated

4.5.2. Mitigated

4.6. Refrigerant Emissions by Land Use

4.6.1. Unmitigated

4.6.2. Mitigated
Item Number: 1.

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4.7. Offroad Emissions By Equipment Type

4.7.1. Unmitigated

4.7.2. Mitigated

4.8. Stationary Emissions By Equipment Type

4.8.1. Unmitigated

4.8.2. Mitigated

4.9. User Defined Emissions By Equipment Type

4.9.1. Unmitigated

4.9.2. Mitigated

4.10. Soil Carbon Accumulation By Vegetation Type

4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated

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

4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated

4.10.4. Soil Carbon Accumulation By Vegetation Type - Mitigated

4.10.5. Above and Belowground Carbon Accumulation by Land Use Type - Mitigated

4.10.6. Avoided and Sequestered Emissions by Species - Mitigated

5. Activity Data

5.1. Construction Schedule Item Number: 1.

DHS Varner Road Specific Plan Detailed Report, 9/11/2025 5 / 80

5.2. Off-Road Equipment

5.2.1. Unmitigated

5.2.2. Mitigated

5.3. Construction Vehicles

5.3.1. Unmitigated

5.3.2. Mitigated

5.4. Vehicles

5.4.1. Construction Vehicle Control Strategies

5.5. Architectural Coatings

5.6. Dust Mitigation

5.6.1. Construction Earthmoving Activities

5.6.2. Construction Earthmoving Control Strategies

5.7. Construction Paving

5.8. Construction Electricity Consumption and Emissions Factors

5.9. Operational Mobile Sources

5.9.1. Unmitigated

5.9.2. Mitigated

5.10. Operational Area Sources Item Number: 1.

DHS Varner Road Specific Plan Detailed Report, 9/11/2025 6 / 80

5.10.1. Hearths

5.10.1.1. Unmitigated

5.10.1.2. Mitigated

5.10.2. Architectural Coatings

5.10.3. Landscape Equipment

5.10.4. Landscape Equipment - Mitigated

5.11. Operational Energy Consumption

5.11.1. Unmitigated

5.11.2. Mitigated

5.12. Operational Water and Wastewater Consumption

5.12.1. Unmitigated

5.12.2. Mitigated

5.13. Operational Waste Generation

5.13.1. Unmitigated

5.13.2. Mitigated

5.14. Operational Refrigeration and Air Conditioning Equipment

5.14.1. Unmitigated

5.14.2. Mitigated
Item Number: 1.

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5.15. Operational Off-Road Equipment

5.15.1. Unmitigated

5.15.2. Mitigated

5.16. Stationary Sources

5.16.1. Emergency Generators and Fire Pumps

5.16.2. Process Boilers

5.17. User Defined

5.18. Vegetation

5.18.1. Land Use Change

5.18.1.1. Unmitigated

5.18.1.2. Mitigated

5.18.1. Biomass Cover Type

5.18.1.1. Unmitigated

5.18.1.2. Mitigated

5.18.2. Sequestration

5.18.2.1. Unmitigated

5.18.2.2. Mitigated

6. Climate Risk Detailed Report Item Number: 1. Page 346 of 2902 DHS Varner Road Specific Plan Detailed Report, 9/11/2025 8 / 80

6.1. Climate Risk Summary

6.2. Initial Climate Risk Scores

6.3. Adjusted Climate Risk Scores

6.4. Climate Risk Reduction Measures

7. Health and Equity Details

7.1. CalEnviroScreen 4.0 Scores

7.2. Healthy Places Index Scores

7.3. Overall Health & Equity Scores

7.4. Health & Equity Measures

7.5. Evaluation Scorecard

7.6. Health & Equity Custom Measures

8. User Changes to Default Data Item Number: 1. Page 347 of 2902 DHS Varner Road Specific Plan Detailed Report, 9/11/2025 9 / 80

1. Basic Project Information

1.1. Basic Project Information
Data Field Value
Project Name DHS Varner Road Specific Plan
Construction Start Date 5/1/2026
Operational Year 2028
Lead Agency —
Land Use Scale Project/site
Analysis Level for Defaults County
Windspeed (m/s) 3.30
Precipitation (days) 11.2
Location 33.892796234658945, -116.51442456367914
County Riverside-Salton Sea
City Desert Hot Springs
Air District South Coast AQMD
Air Basin Salton Sea
TAZ 5638
EDFZ 11
Electric Utility Southern California Edison
Gas Utility Southern California Gas
App 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 Landscape
Area (sq ft)
Population Description
Industrial Park 75.0 1000sqft 18.7 75,000 — 0.00 — Office Space Item Number: 1. Page 348 of 2902 DHS Varner Road Specific Plan Detailed Report, 9/11/2025 10 / 80
Unrefrigerated
Warehouse-No Rail
1,425 1000sqft 56.2 1,425,000 — 0.00 — Distribution and Storage Space
Parking Lot 1,297 Space 20.0 0.00 0.00 0.00 — —
Road Widening 1.37 Mile 14.1 0.00 0.00 — — Road improvements Road Construction 5.50 Mile 6.70 0.00 0.00 — — Utility Extensions

1.3. User-Selected Emission Reduction Measures by Emissions Sector Sector # Measure Title
Construction C-2* Limit Heavy-Duty Diesel Vehicle Idling Construction C-5 Use Advanced Engine Tiers
Construction C-6 Use Diesel Particulate Filters
Construction C-7 Use Oxidation Catalyst
Construction C-13 Use Low-VOC Paints for Construction
Transportation T-11* Provide Employer-Sponsored Vanpool Transportation T-30* Use Cleaner-Fuel Vehicles
Energy E-2 Require Energy Efficient Appliances
Energy E-7* Require Higher Efficacy Public Street and Area Lighting Energy E-10-B Establish Onsite Renewable Energy Systems: Solar Power Water W-4 Require Low-Flow Water Fixtures
Water W-5 Design Water-Efficient Landscapes
Waste S-1/S-2 Implement Waste Reduction Plan
Area Sources AS-1 Use Low-VOC Cleaning Supplies
Area Sources AS-2 Use Low-VOC Paints
Miscellaneous M-6* Off-Road Equipment Efficiency
* Qualitative or supporting measure. Emission reductions not included in the mitigated emissions results.

2. Emissions Summary Item Number: 1. Page 349 of 2902
DHS Varner Road Specific Plan Detailed Report, 9/11/2025 11 / 80

2.1. Construction Emissions Compared Against Thresholds Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Un/Mit. ROG NOx CO SO2 PM10T PM2.5T CO2e
Daily, Summer (Max) — — — — — — —
Unmit. 236 116 201 0.32 21.6 7.66 47,125
Mit. 27.8 72.4 217 0.32 19.4 5.71 47,125
% Reduced 88% 38% -8% — 10% 25% —
Daily, Winter (Max) — — — — — — —
Unmit. 240 133 196 0.35 23.1 8.42 49,552
Mit. 30.4 83.1 213 0.35 20.6 6.23 49,552
% Reduced 87% 37% -9% — 10% 26% —
Average Daily (Max) — — — — — — —
Unmit. 39.2 33.6 49.3 0.10 7.71 2.50 14,650
Mit. 4.82 19.1 54.0 0.10 7.45 1.90 14,650
% Reduced 88% 43% -10% — 3% 24% —
Annual (Max) — — — — — — —
Unmit. 7.16 6.13 8.99 0.02 1.41 0.46 2,425
Mit. 0.88 3.49 9.85 0.02 1.36 0.35 2,425
% Reduced 88% 43% -10% — 3% 24% —
Exceeds (Daily Max) — — — — — — —
Threshold 75.0 100 550 150 150 55.0 —
Unmit. Yes Yes No No No No —
Mit. No No No No No No —
Exceeds (Average
Daily)
— — — — — — —
Threshold 75.0 100 550 150 150 55.0 —
Unmit. No No No No No No —
Mit. No No No No No No — Item Number: 1. Page 350 of 2902 DHS Varner Road Specific Plan Detailed Report, 9/11/2025 12 / 80
Exceeds (Annual) — — — — — — —
Threshold — — — — — — —
Unmit. — — — — — — Yes
Mit. — — — — — — Yes

2.2. Construction Emissions by Year, Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Year ROG NOx CO SO2 PM10T PM2.5T CO2e
Daily - Summer (Max) — — — — — — —
2026 16.0 116 201 0.32 21.6 7.66 47,125
2027 4.20 21.1 70.8 0.08 10.9 3.00 19,726
2028 236 1.30 10.8 < 0.005 1.66 0.40 1,918
Daily - Winter (Max) — — — — — — —
2026 17.2 133 196 0.35 23.1 8.42 49,552
2027 3.72 22.0 48.4 0.09 10.9 3.00 18,359
2028 240 22.2 52.7 0.09 12.5 3.37 19,692
Average Daily — — — — — — —
2026 4.38 33.6 49.3 0.10 6.82 2.50 14,650
2027 2.75 15.3 39.8 0.06 7.71 2.13 13,498
2028 39.2 2.12 6.29 0.01 1.28 0.34 2,033
Annual — — — — — — —
2026 0.80 6.13 8.99 0.02 1.24 0.46 2,425
2027 0.50 2.80 7.27 0.01 1.41 0.39 2,235
2028 7.16 0.39 1.15 < 0.005 0.23 0.06 337

2.3. Construction Emissions by Year, Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Year ROG NOx CO SO2 PM10T PM2.5T CO2e Item Number: 1. Page 351 of 2902 DHS Varner Road Specific Plan Detailed Report, 9/11/2025 13 / 80
Daily - Summer (Max) — — — — — — —
2026 11.1 72.4 217 0.32 19.4 5.71 47,125
2027 3.36 13.3 73.1 0.08 10.5 2.68 19,726
2028 27.8 1.13 10.7 < 0.005 1.65 0.39 1,918
Daily - Winter (Max) — — — — — — —
2026 11.7 83.1 213 0.35 20.6 6.23 49,552
2027 2.88 14.1 50.7 0.09 10.5 2.68 18,359
2028 30.4 14.7 54.9 0.09 12.2 3.07 19,692
Average Daily — — — — — — —
2026 2.80 19.1 54.0 0.10 6.13 1.87 14,650
2027 2.16 9.70 41.5 0.06 7.45 1.90 13,498
2028 4.82 1.41 6.49 0.01 1.25 0.31 2,033
Annual — — — — — — —
2026 0.51 3.49 9.85 0.02 1.12 0.34 2,425
2027 0.39 1.77 7.57 0.01 1.36 0.35 2,235
2028 0.88 0.26 1.18 < 0.005 0.23 0.06 337

2.4. Operations Emissions Compared Against Thresholds
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Un/Mit. ROG NOx CO SO2 PM10T PM2.5T CO2e
Daily, Summer (Max) — — — — — — —
Unmit. 55.9 113 198 1.24 56.2 16.9 149,790
Mit. 50.1 113 198 1.24 56.2 16.9 146,501
% Reduced 10% — — — — — 2%
Daily, Winter (Max) — — — — — — —
Unmit. 44.2 119 101 1.20 56.0 16.8 146,370
Mit. 38.3 119 101 1.20 56.0 16.8 143,081
% Reduced 13% — — — — — 2% Item Number: 1. Page 352 of 2902 DHS Varner Road Specific Plan Detailed Report, 9/11/2025 14 / 80
Average Daily (Max) — — — — — — —
Unmit. 51.1 122 142 1.22 55.9 16.9 147,775
Mit. 45.3 122 142 1.22 55.9 16.9 144,486
% Reduced 11% — — — — — 2%
Annual (Max) — — — — — — —
Unmit. 9.33 22.2 25.9 0.22 10.2 3.08 24,466
Mit. 8.27 22.2 25.9 0.22 10.2 3.08 23,921
% Reduced 11% — — — — — 2%
Exceeds (Daily Max) — — — — — — —
Threshold 55.0 55.0 550 150 150 55.0 —
Unmit. Yes Yes No No No No —
Mit. No Yes No No No No —
Exceeds (Average
Daily)
— — — — — — —
Threshold 55.0 55.0 550 150 150 55.0 —
Unmit. No Yes No No No No —
Mit. No Yes No No No No —
Exceeds (Annual) — — — — — — —
Threshold — — — — — — 3,000
Unmit. — — — — — — Yes
Mit. — — — — — — Yes

2.5. Operations Emissions by Sector, Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Sector ROG NOx CO SO2 PM10T PM2.5T CO2e
Daily, Summer (Max) — — — — — — —
Mobile 7.21 90.7 104 1.16 54.8 15.7 125,809
Area 46.8 0.55 65.2 < 0.005 0.12 0.09 269 Item Number: 1. Page 353 of 2902 DHS Varner Road Specific Plan Detailed Report, 9/11/2025 15 / 80
Energy 0.43 7.86 6.61 0.05 0.60 0.60 17,641
Water—————— 182
Waste—————— 2,701
Refrig.—————— 19.5
Off-Road 1.49 13.5 21.8 0.03 0.60 0.55 3,168
Stationary 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Total 55.9 113 198 1.24 56.2 16.9 149,790
Daily, Winter (Max)———————
Mobile 6.20 97.6 72.9 1.13 54.8 15.7 122,658
Area 36.0——————
Energy 0.43 7.86 6.61 0.05 0.60 0.60 17,641
Water—————— 182
Waste—————— 2,701
Refrig.—————— 19.5
Off-Road 1.49 13.5 21.8 0.03 0.60 0.55 3,168
Stationary 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Total 44.2 119 101 1.20 56.0 16.8 146,370
Average Daily———————
Mobile 6.48 95.6 82.7 1.14 54.5 15.6 123,897
Area 41.3 0.27 32.2 < 0.005 0.06 0.04 133
Energy 0.43 7.86 6.61 0.05 0.60 0.60 17,641
Water—————— 182
Waste—————— 2,701
Refrig.—————— 19.5
Off-Road 1.06 9.62 15.5 0.02 0.43 0.39 2,257
Stationary 1.84 8.16 4.69 0.01 0.27 0.27 944
Total 51.1 122 142 1.22 55.9 16.9 147,775
Annual———————
Item Number: 1.

DHS Varner Road Specific Plan Detailed Report, 9/11/2025 16 / 80
Mobile 1.18 17.5 15.1 0.21 9.95 2.84 20,513
Area 7.54 0.05 5.87 < 0.005 0.01 0.01 22.0
Energy 0.08 1.44 1.21 0.01 0.11 0.11 2,921
Water — — — — — — 30.1
Waste — — — — — — 447
Refrig. — — — — — — 3.23
Off-Road 0.19 1.75 2.83 < 0.005 0.08 0.07 374
Stationary 0.34 1.49 0.86 < 0.005 0.05 0.05 156
Total 9.33 22.2 25.9 0.22 10.2 3.08 24,466

2.6. Operations Emissions by Sector, Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Sector ROG NOx CO SO2 PM10T PM2.5T CO2e
Daily, Summer (Max) — — — — — — —
Mobile 7.21 90.7 104 1.16 54.8 15.7 125,809
Area 40.9 0.55 65.2 < 0.005 0.12 0.09 269
Energy 0.43 7.86 6.61 0.05 0.60 0.60 16,393
Water — — — — — — 167
Waste — — — — — — 675
Refrig. — — — — — — 19.5
Off-Road 1.49 13.5 21.8 0.03 0.60 0.55 3,168
Stationary 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Total 50.1 113 198 1.24 56.2 16.9 146,501
Daily, Winter (Max) — — — — — — —
Mobile 6.20 97.6 72.9 1.13 54.8 15.7 122,658
Area 30.2 — — — — — —
Energy 0.43 7.86 6.61 0.05 0.60 0.60 16,393
Water — — — — — — 167 Item Number: 1. Page 355 of 2902
DHS Varner Road Specific Plan Detailed Report, 9/11/2025 17 / 80
Waste — — — — — — 675
Refrig. — — — — — — 19.5
Off-Road 1.49 13.5 21.8 0.03 0.60 0.55 3,168
Stationary 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Total 38.3 119 101 1.20 56.0 16.8 143,081
Average Daily — — — — — — —
Mobile 6.48 95.6 82.7 1.14 54.5 15.6 123,897
Area 35.5 0.27 32.2 < 0.005 0.06 0.04 133
Energy 0.43 7.86 6.61 0.05 0.60 0.60 16,393
Water — — — — — — 167
Waste — — — — — — 675
Refrig. — — — — — — 19.5
Off-Road 1.06 9.62 15.5 0.02 0.43 0.39 2,257
Stationary 1.84 8.16 4.69 0.01 0.27 0.27 944
Total 45.3 122 142 1.22 55.9 16.9 144,486
Annual — — — — — — —
Mobile 1.18 17.5 15.1 0.21 9.95 2.84 20,513
Area 6.48 0.05 5.87 < 0.005 0.01 0.01 22.0
Energy 0.08 1.44 1.21 0.01 0.11 0.11 2,714
Water — — — — — — 27.7
Waste — — — — — — 112
Refrig. — — — — — — 3.23
Off-Road 0.19 1.75 2.83 < 0.005 0.08 0.07 374
Stationary 0.34 1.49 0.86 < 0.005 0.05 0.05 156
Total 8.27 22.2 25.9 0.22 10.2 3.08 23,921

3. Construction Emissions Details Item Number: 1. Page 356 of 2902 DHS Varner Road Specific Plan Detailed Report, 9/11/2025 18 / 80

3.1. Linear, Grading & Excavation (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10T PM2.5T CO2e
Onsite — — — — — — —
Daily, Summer (Max) — — — — — — —
Off-Road Equipment 6.55 55.9 67.0 0.13 2.43 2.24 14,407 Dust From Material
Movement
— — — — 2.69 0.29 —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Daily, Winter (Max) — — — — — — —
Off-Road Equipment 6.55 55.9 67.0 0.13 2.43 2.24 14,407 Dust From Material
Movement
— — — — 2.69 0.29 —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Average Daily — — — — — — —
Off-Road Equipment 1.08 9.20 11.0 0.02 0.40 0.37 2,368
Dust From Material
Movement
— — — — 0.44 0.05 —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — —
Off-Road Equipment 0.20 1.68 2.01 < 0.005 0.07 0.07 392 Dust From Material
Movement
— — — — 0.08 0.01 —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Offsite — — — — — — —
Daily, Summer (Max) — — — — — — —
Worker 0.47 0.49 9.09 0.00 1.34 0.31 1,512
Vendor < 0.005 0.06 0.03 < 0.005 0.02 0.01 64.9
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Item Number: 1. Page 357 of 2902 DHS Varner Road Specific Plan Detailed Report, 9/11/2025 19 / 80
Daily, Winter (Max) — — — — — — —
Worker 0.38 0.53 5.15 0.00 1.34 0.31 1,284
Vendor < 0.005 0.07 0.03 < 0.005 0.02 0.01 64.8
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Average Daily — — — — — — —
Worker 0.07 0.08 1.06 0.00 0.22 0.05 226
Vendor < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 10.7 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — —
Worker 0.01 0.01 0.19 0.00 0.04 0.01 37.4
Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 1.76 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00

3.2. Linear, Grading & Excavation (2026) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10T PM2.5T CO2e
Onsite — — — — — — —
Daily, Summer (Max) — — — — — — —
Off-Road Equipment 3.75 32.0 76.2 0.13 1.23 1.15 14,407 Dust From Material
Movement
— — — — 2.69 0.29 —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Daily, Winter (Max) — — — — — — —
Off-Road Equipment 3.75 32.0 76.2 0.13 1.23 1.15 14,407 Dust From Material
Movement
— — — — 2.69 0.29 —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Average Daily — — — — — — —
Off-Road Equipment 0.62 5.26 12.5 0.02 0.20 0.19 2,368 Item Number: 1. Page 358 of 2902 DHS Varner Road Specific Plan Detailed Report, 9/11/2025 20 / 80
Dust From Material
Movement
— — — — 0.44 0.05 —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — —
Off-Road Equipment 0.11 0.96 2.29 < 0.005 0.04 0.03 392 Dust From Material
Movement
— — — — 0.08 0.01 —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Offsite — — — — — — —
Daily, Summer (Max) — — — — — — —
Worker 0.47 0.49 9.09 0.00 1.34 0.31 1,512
Vendor < 0.005 0.06 0.03 < 0.005 0.02 0.01 64.9
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Daily, Winter (Max) — — — — — — —
Worker 0.38 0.53 5.15 0.00 1.34 0.31 1,284
Vendor < 0.005 0.07 0.03 < 0.005 0.02 0.01 64.8
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Average Daily — — — — — — —
Worker 0.07 0.08 1.06 0.00 0.22 0.05 226
Vendor < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 10.7 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — —
Worker 0.01 0.01 0.19 0.00 0.04 0.01 37.4
Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 1.76 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00

3.3. Linear, Drainage, Utilities, & Sub-Grade (2026) - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10T PM2.5T CO2e Item Number: 1. Page 359 of 2902 DHS Varner Road Specific Plan Detailed Report, 9/11/2025 21 / 80
Onsite———————
Daily, Summer (Max)———————
Off-Road Equipment 4.18 37.1 43.1 0.09 1.44 1.33 9,815
Dust From Material
Movement
———— 1.65 0.18—
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Daily, Winter (Max)———————
Off-Road Equipment 4.18 37.1 43.1 0.09 1.44 1.33 9,815
Dust From Material
Movement
———— 1.65 0.18—
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Average Daily———————
Off-Road Equipment 0.69 6.10 7.08 0.02 0.24 0.22 1,613
Dust From Material
Movement
———— 0.27 0.03—
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Annual———————
Off-Road Equipment 0.13 1.11 1.29 < 0.005 0.04 0.04 267 Dust From Material
Movement
———— 0.05 0.01—
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Offsite———————
Daily, Summer (Max)———————
Worker 0.37 0.39 7.31 0.00 1.08 0.25 1,217
Vendor 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
Daily, Winter (Max)———————
Worker 0.31 0.43 4.14 0.00 1.08 0.25 1,034
Vendor 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 Item Number: 1. Page 360 of 2902 DHS Varner Road Specific Plan Detailed Report, 9/11/2025 22 / 80
Average Daily — — — — — — —
Worker 0.05 0.06 0.85 0.00 0.18 0.04 182
Vendor 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
Annual — — — — — — —
Worker 0.01 0.01 0.16 0.00 0.03 0.01 30.1
Vendor 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

3.4. Linear, Drainage, Utilities, & Sub-Grade (2026) - Mitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10T PM2.5T CO2e
Onsite — — — — — — —
Daily, Summer (Max) — — — — — — —
Off-Road Equipment 2.98 25.5 47.6 0.09 0.91 0.84 9,815
Dust From Material
Movement
— — — — 1.65 0.18 —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Daily, Winter (Max) — — — — — — —
Off-Road Equipment 2.98 25.5 47.6 0.09 0.91 0.84 9,815
Dust From Material
Movement
— — — — 1.65 0.18 —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Average Daily — — — — — — —
Off-Road Equipment 0.49 4.19 7.83 0.02 0.15 0.14 1,613
Dust From Material
Movement
— — — — 0.27 0.03 —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — — Item Number: 1. Page 361 of 2902
DHS Varner Road Specific Plan Detailed Report, 9/11/2025 23 / 80
Off-Road Equipment 0.09 0.76 1.43 < 0.005 0.03 0.03 267 Dust From Material
Movement
— — — — 0.05 0.01 —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Offsite — — — — — — —
Daily, Summer (Max) — — — — — — —
Worker 0.37 0.39 7.31 0.00 1.08 0.25 1,217
Vendor 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
Daily, Winter (Max) — — — — — — —
Worker 0.31 0.43 4.14 0.00 1.08 0.25 1,034
Vendor 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
Average Daily — — — — — — —
Worker 0.05 0.06 0.85 0.00 0.18 0.04 182
Vendor 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
Annual — — — — — — —
Worker 0.01 0.01 0.16 0.00 0.03 0.01 30.1
Vendor 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

3.5. Linear, Paving (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10T PM2.5T CO2e
Onsite — — — — — — —
Daily, Summer (Max) — — — — — — —
Daily, Winter (Max) — — — — — — — Item Number: 1. Page 362 of 2902 DHS Varner Road Specific Plan Detailed Report, 9/11/2025 24 / 80
Off-Road Equipment 1.66 14.9 22.4 0.03 0.61 0.56 3,399
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Average Daily — — — — — — —
Off-Road Equipment 0.27 2.45 3.69 0.01 0.10 0.09 559
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — —
Off-Road Equipment 0.05 0.45 0.67 < 0.005 0.02 0.02 92.5 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Offsite — — — — — — —
Daily, Summer (Max) — — — — — — —
Daily, Winter (Max) — — — — — — —
Worker 0.25 0.35 3.39 0.00 0.88 0.21 846
Vendor 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
Average Daily — — — — — — —
Worker 0.04 0.05 0.70 0.00 0.14 0.03 149
Vendor 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
Annual — — — — — — —
Worker 0.01 0.01 0.13 0.00 0.03 0.01 24.6
Vendor 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

3.6. Linear, Paving (2026) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10T PM2.5T CO2e
Onsite — — — — — — —
Daily, Summer (Max) — — — — — — — Item Number: 1. Page 363 of 2902 DHS Varner Road Specific Plan Detailed Report, 9/11/2025 25 / 80
Daily, Winter (Max) — — — — — — —
Off-Road Equipment 1.03 9.43 23.1 0.03 0.34 0.31 3,399
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Average Daily — — — — — — —
Off-Road Equipment 0.17 1.55 3.80 0.01 0.06 0.05 559
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — —
Off-Road Equipment 0.03 0.28 0.69 < 0.005 0.01 0.01 92.5 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Offsite — — — — — — —
Daily, Summer (Max) — — — — — — —
Daily, Winter (Max) — — — — — — —
Worker 0.25 0.35 3.39 0.00 0.88 0.21 846
Vendor 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
Average Daily — — — — — — —
Worker 0.04 0.05 0.70 0.00 0.14 0.03 149
Vendor 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
Annual — — — — — — —
Worker 0.01 0.01 0.13 0.00 0.03 0.01 24.6
Vendor 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

3.7. Grading (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10T PM2.5T CO2e
Onsite — — — — — — — Item Number: 1. Page 364 of 2902
DHS Varner Road Specific Plan Detailed Report, 9/11/2025 26 / 80
Daily, Summer (Max)———————
Off-Road Equipment 3.23 28.9 30.2 0.06 1.21 1.11 7,062
Dust From Material
Movement
———— 3.63 1.43—
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Daily, Winter (Max)———————
Average Daily———————
Off-Road Equipment 0.62 5.53 5.79 0.01 0.23 0.21 1,354
Dust From Material
Movement
———— 0.70 0.27—
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Annual———————
Off-Road Equipment 0.11 1.01 1.06 < 0.005 0.04 0.04 224 Dust From Material
Movement
———— 0.13 0.05—
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Offsite———————
Daily, Summer (Max)———————
Worker 0.11 0.12 2.22 0.00 0.33 0.08 369
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.22 11.7 2.71 0.07 3.07 0.94 11,039
Daily, Winter (Max)———————
Average Daily———————
Worker 0.02 0.02 0.30 0.00 0.06 0.01 64.2
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.04 2.36 0.53 0.01 0.58 0.18 2,115
Annual———————
Worker < 0.005 < 0.005 0.05 0.00 0.01 < 0.005 10.6
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Item Number: 1. Page 365 of 2902 DHS Varner Road Specific Plan Detailed Report, 9/11/2025 27 / 80
Hauling 0.01 0.43 0.10 < 0.005 0.11 0.03 350

3.8. Grading (2026) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10T PM2.5T CO2e
Onsite — — — — — — —
Daily, Summer (Max) — — — — — — —
Off-Road Equipment 0.68 4.64 38.4 0.06 0.13 0.13 7,062
Dust From Material
Movement
— — — — 3.63 1.43 —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Daily, Winter (Max) — — — — — — —
Average Daily — — — — — — —
Off-Road Equipment 0.13 0.89 7.37 0.01 0.03 0.03 1,354
Dust From Material
Movement
— — — — 0.70 0.27 —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — —
Off-Road Equipment 0.02 0.16 1.35 < 0.005 < 0.005 < 0.005 224 Dust From Material
Movement
— — — — 0.13 0.05 —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Offsite — — — — — — —
Daily, Summer (Max) — — — — — — —
Worker 0.11 0.12 2.22 0.00 0.33 0.08 369
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.22 11.7 2.71 0.07 3.07 0.94 11,039
Daily, Winter (Max) — — — — — — —
Average Daily — — — — — — — Item Number: 1. Page 366 of 2902 DHS Varner Road Specific Plan Detailed Report, 9/11/2025 28 / 80
Worker 0.02 0.02 0.30 0.00 0.06 0.01 64.2
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.04 2.36 0.53 0.01 0.58 0.18 2,115
Annual — — — — — — —
Worker < 0.005 < 0.005 0.05 0.00 0.01 < 0.005 10.6
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.01 0.43 0.10 < 0.005 0.11 0.03 350

3.9. Building Construction (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10T PM2.5T CO2e
Onsite — — — — — — —
Daily, Summer (Max) — — — — — — —
Off-Road Equipment 1.26 11.5 15.6 0.03 0.46 0.43 2,846
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Daily, Winter (Max) — — — — — — —
Off-Road Equipment 1.26 11.5 15.6 0.03 0.46 0.43 2,846
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Average Daily — — — — — — —
Off-Road Equipment 0.36 3.30 4.48 0.01 0.13 0.12 819
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — —
Off-Road Equipment 0.07 0.60 0.82 < 0.005 0.02 0.02 136 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Offsite — — — — — — —
Daily, Summer (Max) — — — — — — —
Worker 2.86 3.01 55.8 0.00 8.23 1.93 9,290
Vendor 0.29 7.86 3.40 0.06 2.21 0.69 7,972 Item Number: 1. Page 367 of 2902 DHS Varner Road Specific Plan Detailed Report, 9/11/2025 29 / 80
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Daily, Winter (Max) — — — — — — —
Worker 2.36 3.27 31.6 0.00 8.23 1.93 7,894
Vendor 0.26 8.47 3.53 0.06 2.21 0.69 7,961
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Average Daily — — — — — — —
Worker 0.72 0.86 11.4 0.00 2.35 0.55 2,427
Vendor 0.08 2.38 0.99 0.02 0.63 0.20 2,291
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — —
Worker 0.13 0.16 2.08 0.00 0.43 0.10 402
Vendor 0.01 0.43 0.18 < 0.005 0.12 0.04 379
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00

3.10. Building Construction (2026) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10T PM2.5T CO2e
Onsite — — — — — — —
Daily, Summer (Max) — — — — — — —
Off-Road Equipment 0.37 3.04 17.9 0.03 0.06 0.06 2,846
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Daily, Winter (Max) — — — — — — —
Off-Road Equipment 0.37 3.04 17.9 0.03 0.06 0.06 2,846
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Average Daily — — — — — — —
Off-Road Equipment 0.11 0.87 5.15 0.01 0.02 0.02 819
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — — Item Number: 1. Page 368 of 2902
DHS Varner Road Specific Plan Detailed Report, 9/11/2025 30 / 80
Off-Road Equipment 0.02 0.16 0.94 < 0.005 < 0.005 < 0.005 136 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Offsite — — — — — — —
Daily, Summer (Max) — — — — — — —
Worker 2.86 3.01 55.8 0.00 8.23 1.93 9,290
Vendor 0.29 7.86 3.40 0.06 2.21 0.69 7,972
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Daily, Winter (Max) — — — — — — —
Worker 2.36 3.27 31.6 0.00 8.23 1.93 7,894
Vendor 0.26 8.47 3.53 0.06 2.21 0.69 7,961
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Average Daily — — — — — — —
Worker 0.72 0.86 11.4 0.00 2.35 0.55 2,427
Vendor 0.08 2.38 0.99 0.02 0.63 0.20 2,291
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — —
Worker 0.13 0.16 2.08 0.00 0.43 0.10 402
Vendor 0.01 0.43 0.18 < 0.005 0.12 0.04 379
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00

3.11. Building Construction (2027) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10T PM2.5T CO2e
Onsite — — — — — — —
Daily, Summer (Max) — — — — — — —
Off-Road Equipment 1.21 10.9 15.6 0.03 0.42 0.38 2,847
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Daily, Winter (Max) — — — — — — — Item Number: 1. Page 369 of 2902 DHS Varner Road Specific Plan Detailed Report, 9/11/2025 31 / 80
Off-Road Equipment 1.21 10.9 15.6 0.03 0.42 0.38 2,847
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Average Daily — — — — — — —
Off-Road Equipment 0.86 7.80 11.1 0.02 0.30 0.27 2,033
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — —
Off-Road Equipment 0.16 1.42 2.03 < 0.005 0.05 0.05 337 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Offsite — — — — — — —
Daily, Summer (Max) — — — — — — —
Worker 2.71 2.73 51.9 0.00 8.23 1.93 9,095
Vendor 0.28 7.50 3.28 0.06 2.21 0.69 7,784
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Daily, Winter (Max) — — — — — — —
Worker 2.25 2.99 29.5 0.00 8.23 1.93 7,738
Vendor 0.26 8.06 3.34 0.06 2.21 0.69 7,774
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Average Daily — — — — — — —
Worker 1.70 1.93 26.4 0.00 5.84 1.37 5,909
Vendor 0.20 5.61 2.33 0.04 1.57 0.49 5,555
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — —
Worker 0.31 0.35 4.81 0.00 1.07 0.25 978
Vendor 0.04 1.02 0.43 0.01 0.29 0.09 920
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00

3.12. Building Construction (2027) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Item Number: 1. Page 370 of 2902 DHS Varner Road Specific Plan Detailed Report, 9/11/2025 32 / 80
Location ROG NOx CO SO2 PM10T PM2.5T CO2e
Onsite———————
Daily, Summer (Max)———————
Off-Road Equipment 0.37 3.03 17.9 0.03 0.06 0.06 2,847
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Daily, Winter (Max)———————
Off-Road Equipment 0.37 3.03 17.9 0.03 0.06 0.06 2,847
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Average Daily———————
Off-Road Equipment 0.26 2.17 12.8 0.02 0.04 0.04 2,033
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Annual———————
Off-Road Equipment 0.05 0.40 2.33 < 0.005 0.01 0.01 337 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Offsite———————
Daily, Summer (Max)———————
Worker 2.71 2.73 51.9 0.00 8.23 1.93 9,095
Vendor 0.28 7.50 3.28 0.06 2.21 0.69 7,784
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Daily, Winter (Max)———————
Worker 2.25 2.99 29.5 0.00 8.23 1.93 7,738
Vendor 0.26 8.06 3.34 0.06 2.21 0.69 7,774
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Average Daily———————
Worker 1.70 1.93 26.4 0.00 5.84 1.37 5,909
Vendor 0.20 5.61 2.33 0.04 1.57 0.49 5,555
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Annual———————
Item Number: 1.

DHS Varner Road Specific Plan Detailed Report, 9/11/2025 33 / 80
Worker 0.31 0.35 4.81 0.00 1.07 0.25 978
Vendor 0.04 1.02 0.43 0.01 0.29 0.09 920
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00

3.13. Building Construction (2028) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10T PM2.5T CO2e
Onsite — — — — — — —
Daily, Summer (Max) — — — — — — —
Daily, Winter (Max) — — — — — — —
Off-Road Equipment 1.17 10.4 15.6 0.03 0.38 0.35 2,846
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Average Daily — — — — — — —
Off-Road Equipment 0.11 0.98 1.46 < 0.005 0.04 0.03 267 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — —
Off-Road Equipment 0.02 0.18 0.27 < 0.005 0.01 0.01 44.3 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Offsite — — — — — — —
Daily, Summer (Max) — — — — — — —
Daily, Winter (Max) — — — — — — —
Worker 2.17 2.72 27.3 0.00 8.23 1.93 7,597
Vendor 0.20 7.75 3.21 0.06 2.21 0.69 7,596
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Average Daily — — — — — — —
Worker 0.21 0.23 3.22 0.00 0.77 0.18 763
Vendor 0.02 0.71 0.29 0.01 0.21 0.06 714
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Item Number: 1. Page 372 of 2902 DHS Varner Road Specific Plan Detailed Report, 9/11/2025 34 / 80
Annual — — — — — — —
Worker 0.04 0.04 0.59 0.00 0.14 0.03 126
Vendor < 0.005 0.13 0.05 < 0.005 0.04 0.01 118
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00

3.14. Building Construction (2028) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10T PM2.5T CO2e
Onsite — — — — — — —
Daily, Summer (Max) — — — — — — —
Daily, Winter (Max) — — — — — — —
Off-Road Equipment 0.37 3.03 17.9 0.03 0.06 0.06 2,846
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Average Daily — — — — — — —
Off-Road Equipment 0.03 0.28 1.68 < 0.005 0.01 0.01 267 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — —
Off-Road Equipment 0.01 0.05 0.31 < 0.005 < 0.005 < 0.005 44.3 Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Offsite — — — — — — —
Daily, Summer (Max) — — — — — — —
Daily, Winter (Max) — — — — — — —
Worker 2.17 2.72 27.3 0.00 8.23 1.93 7,597
Vendor 0.20 7.75 3.21 0.06 2.21 0.69 7,596
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Average Daily — — — — — — —
Worker 0.21 0.23 3.22 0.00 0.77 0.18 763
Vendor 0.02 0.71 0.29 0.01 0.21 0.06 714 Item Number: 1. Page 373 of 2902 DHS Varner Road Specific Plan Detailed Report, 9/11/2025 35 / 80
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — —
Worker 0.04 0.04 0.59 0.00 0.14 0.03 126
Vendor < 0.005 0.13 0.05 < 0.005 0.04 0.01 118
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00

3.15. Paving (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10T PM2.5T CO2e
Onsite — — — — — — —
Daily, Summer (Max) — — — — — — —
Off-Road Equipment 0.76 7.12 9.94 0.01 0.32 0.29 1,516
Paving 1.96 — — — — — —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Daily, Winter (Max) — — — — — — —
Off-Road Equipment 0.76 7.12 9.94 0.01 0.32 0.29 1,516
Paving 1.96 — — — — — —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Average Daily — — — — — — —
Off-Road Equipment 0.09 0.88 1.23 < 0.005 0.04 0.04 187 Paving 0.24 — — — — — —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — —
Off-Road Equipment 0.02 0.16 0.22 < 0.005 0.01 0.01 30.9 Paving 0.04 — — — — — —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Offsite — — — — — — —
Daily, Summer (Max) — — — — — — — Item Number: 1. Page 374 of 2902 DHS Varner Road Specific Plan Detailed Report, 9/11/2025 36 / 80
Worker 0.07 0.07 1.33 0.00 0.20 0.05 221
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.04 2.23 0.52 0.01 0.58 0.18 2,098
Daily, Winter (Max) — — — — — — —
Worker 0.06 0.08 0.75 0.00 0.20 0.05 188
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.04 2.38 0.53 0.01 0.58 0.18 2,096
Average Daily — — — — — — —
Worker 0.01 0.01 0.12 0.00 0.02 0.01 24.8
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 0.29 0.06 < 0.005 0.07 0.02 258
Annual — — — — — — —
Worker < 0.005 < 0.005 0.02 0.00 < 0.005 < 0.005 4.10
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 0.05 0.01 < 0.005 0.01 < 0.005 42.8

3.16. Paving (2026) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10T PM2.5T CO2e
Onsite — — — — — — —
Daily, Summer (Max) — — — — — — —
Off-Road Equipment 0.16 1.93 10.6 0.01 0.03 0.03 1,516
Paving 1.96 — — — — — —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Daily, Winter (Max) — — — — — — —
Off-Road Equipment 0.16 1.93 10.6 0.01 0.03 0.03 1,516
Paving 1.96 — — — — — —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Item Number: 1. Page 375 of 2902 DHS Varner Road Specific Plan Detailed Report, 9/11/2025 37 / 80
Average Daily — — — — — — —
Off-Road Equipment 0.02 0.24 1.31 < 0.005 < 0.005 < 0.005 187 Paving 0.24 — — — — — —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — —
Off-Road Equipment < 0.005 0.04 0.24 < 0.005 < 0.005 < 0.005 30.9 Paving 0.04 — — — — — —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Offsite — — — — — — —
Daily, Summer (Max) — — — — — — —
Worker 0.07 0.07 1.33 0.00 0.20 0.05 221
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.04 2.23 0.52 0.01 0.58 0.18 2,098
Daily, Winter (Max) — — — — — — —
Worker 0.06 0.08 0.75 0.00 0.20 0.05 188
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.04 2.38 0.53 0.01 0.58 0.18 2,096
Average Daily — — — — — — —
Worker 0.01 0.01 0.12 0.00 0.02 0.01 24.8
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 0.29 0.06 < 0.005 0.07 0.02 258
Annual — — — — — — —
Worker < 0.005 < 0.005 0.02 0.00 < 0.005 < 0.005 4.10
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 0.05 0.01 < 0.005 0.01 < 0.005 42.8

3.17. Architectural (2028) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Item Number: 1. Page 376 of 2902 DHS Varner Road Specific Plan Detailed Report, 9/11/2025 38 / 80
Location ROG NOx CO SO2 PM10T PM2.5T CO2e
Onsite———————
Daily, Summer (Max)———————
Off-Road Equipment 0.11 0.81 1.12 < 0.005 0.02 0.01 134 Architectural Coatings 236——————
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Daily, Winter (Max)———————
Off-Road Equipment 0.11 0.81 1.12 < 0.005 0.02 0.01 134 Architectural Coatings 236——————
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Average Daily———————
Off-Road Equipment 0.02 0.13 0.18 < 0.005 < 0.005 < 0.005 22.0 Architectural Coatings 38.8——————
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Annual———————
Off-Road Equipment < 0.005 0.02 0.03 < 0.005 < 0.005 < 0.005 3.65 Architectural Coatings 7.08——————
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Offsite———————
Daily, Summer (Max)———————
Worker 0.52 0.49 9.71 0.00 1.65 0.39 1,784
Vendor 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
Daily, Winter (Max)———————
Worker 0.43 0.54 5.46 0.00 1.65 0.39 1,519
Vendor 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
Average Daily———————
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Worker 0.07 0.08 1.13 0.00 0.27 0.06 267
Vendor 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
Annual — — — — — — —
Worker 0.01 0.01 0.21 0.00 0.05 0.01 44.2
Vendor 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

3.18. Architectural (2028) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10T PM2.5T CO2e
Onsite — — — — — — —
Daily, Summer (Max) — — — — — — —
Off-Road Equipment 0.02 0.65 0.96 < 0.005 < 0.005 < 0.005 134 Architectural Coatings 27.2 — — — — — —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Daily, Winter (Max) — — — — — — —
Off-Road Equipment 0.02 0.65 0.96 < 0.005 < 0.005 < 0.005 134 Architectural Coatings 27.2 — — — — — —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Average Daily — — — — — — —
Off-Road Equipment < 0.005 0.11 0.16 < 0.005 < 0.005 < 0.005 22.0 Architectural Coatings 4.47 — — — — — —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — —
Off-Road Equipment < 0.005 0.02 0.03 < 0.005 < 0.005 < 0.005 3.65 Architectural Coatings 0.82 — — — — — —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Item Number: 1. Page 378 of 2902 DHS Varner Road Specific Plan Detailed Report, 9/11/2025 40 / 80
Offsite — — — — — — —
Daily, Summer (Max) — — — — — — —
Worker 0.52 0.49 9.71 0.00 1.65 0.39 1,784
Vendor 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
Daily, Winter (Max) — — — — — — —
Worker 0.43 0.54 5.46 0.00 1.65 0.39 1,519
Vendor 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
Average Daily — — — — — — —
Worker 0.07 0.08 1.13 0.00 0.27 0.06 267
Vendor 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
Annual — — — — — — —
Worker 0.01 0.01 0.21 0.00 0.05 0.01 44.2
Vendor 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

4. Operations Emissions Details

4.1. Mobile Emissions by Land Use

4.1.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx CO SO2 PM10T PM2.5T CO2e
Daily, Summer (Max) — — — — — — —
Industrial Park 5.08 3.42 78.5 0.20 19.8 5.03 20,098
Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Item Number: 1. Page 379 of 2902 DHS Varner Road Specific Plan Detailed Report, 9/11/2025 41 / 80
Unrefrigerated
Warehouse-No Rail

2.13 87.3 25.9 0.96 35.1 10.6 105,711
Total 7.21 90.7 104 1.16 54.8 15.7 125,809
Daily, Winter (Max) — — — — — — —
Industrial Park 4.19 3.71 47.0 0.17 19.8 5.03 17,151
Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Unrefrigerated
Warehouse-No Rail

2.01 93.9 25.9 0.96 35.1 10.6 105,506
Total 6.20 97.6 72.9 1.13 54.8 15.7 122,658
Annual — — — — — — —
Industrial Park 0.81 0.63 10.4 0.03 3.58 0.91 3,032
Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Unrefrigerated
Warehouse-No Rail

0.38 16.8 4.73 0.17 6.36 1.93 17,481
Total 1.18 17.5 15.1 0.21 9.95 2.84 20,513

4.1.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx CO SO2 PM10T PM2.5T CO2e
Daily, Summer (Max) — — — — — — —
Industrial Park 5.08 3.42 78.5 0.20 19.8 5.03 20,098
Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Unrefrigerated
Warehouse-No Rail

2.13 87.3 25.9 0.96 35.1 10.6 105,711
Total 7.21 90.7 104 1.16 54.8 15.7 125,809
Daily, Winter (Max) — — — — — — —
Industrial Park 4.19 3.71 47.0 0.17 19.8 5.03 17,151
Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Unrefrigerated
Warehouse-No Rail

2.01 93.9 25.9 0.96 35.1 10.6 105,506
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Total 6.20 97.6 72.9 1.13 54.8 15.7 122,658
Annual — — — — — — —
Industrial Park 0.81 0.63 10.4 0.03 3.58 0.91 3,032
Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Unrefrigerated
Warehouse-No Rail

0.38 16.8 4.73 0.17 6.36 1.93 17,481
Total 1.18 17.5 15.1 0.21 9.95 2.84 20,513

4.2. Energy

4.2.1. Electricity Emissions By Land Use - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx CO SO2 PM10T PM2.5T CO2e
Daily, Summer (Max) — — — — — — —
Industrial Park — — — — — — 1,248
Parking Lot — — — — — — 728
Unrefrigerated
Warehouse-No Rail
— — — — — — 6,257
Total — — — — — — 8,233
Daily, Winter (Max) — — — — — — —
Industrial Park — — — — — — 1,248
Parking Lot — — — — — — 728
Unrefrigerated
Warehouse-No Rail
— — — — — — 6,257
Total — — — — — — 8,233
Annual — — — — — — —
Industrial Park — — — — — — 207
Parking Lot — — — — — — 121
Unrefrigerated
Warehouse-No Rail
— — — — — — 1,036
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Total — — — — — — 1,363

4.2.2. Electricity Emissions By Land Use - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx CO SO2 PM10T PM2.5T CO2e
Daily, Summer (Max) — — — — — — —
Industrial Park — — — — — — 0.00
Parking Lot — — — — — — 728
Unrefrigerated
Warehouse-No Rail
— — — — — — 6,257
Total — — — — — — 6,985
Daily, Winter (Max) — — — — — — —
Industrial Park — — — — — — 0.00
Parking Lot — — — — — — 728
Unrefrigerated
Warehouse-No Rail
— — — — — — 6,257
Total — — — — — — 6,985
Annual — — — — — — —
Industrial Park — — — — — — 0.00
Parking Lot — — — — — — 121
Unrefrigerated
Warehouse-No Rail
— — — — — — 1,036
Total — — — — — — 1,156

4.2.3. Natural Gas Emissions By Land Use - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx CO SO2 PM10T PM2.5T CO2e
Daily, Summer (Max) — — — — — — —
Industrial Park 0.03 0.56 0.47 < 0.005 0.04 0.04 665 Item Number: 1. Page 382 of 2902 DHS Varner Road Specific Plan Detailed Report, 9/11/2025 44 / 80
Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Unrefrigerated
Warehouse-No Rail

0.40 7.31 6.14 0.04 0.56 0.56 8,743
Total 0.43 7.86 6.61 0.05 0.60 0.60 9,408
Daily, Winter (Max) — — — — — — —
Industrial Park 0.03 0.56 0.47 < 0.005 0.04 0.04 665
Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Unrefrigerated
Warehouse-No Rail

0.40 7.31 6.14 0.04 0.56 0.56 8,743
Total 0.43 7.86 6.61 0.05 0.60 0.60 9,408
Annual — — — — — — —
Industrial Park 0.01 0.10 0.09 < 0.005 0.01 0.01 110
Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Unrefrigerated
Warehouse-No Rail

0.07 1.33 1.12 0.01 0.10 0.10 1,448
Total 0.08 1.44 1.21 0.01 0.11 0.11 1,558

4.2.4. Natural Gas Emissions By Land Use - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx CO SO2 PM10T PM2.5T CO2e
Daily, Summer (Max) — — — — — — —
Industrial Park 0.03 0.56 0.47 < 0.005 0.04 0.04 665
Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Unrefrigerated
Warehouse-No Rail

0.40 7.31 6.14 0.04 0.56 0.56 8,743
Total 0.43 7.86 6.61 0.05 0.60 0.60 9,408
Daily, Winter (Max) — — — — — — —
Industrial Park 0.03 0.56 0.47 < 0.005 0.04 0.04 665
Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Item Number: 1. Page 383 of 2902 DHS Varner Road Specific Plan Detailed Report, 9/11/2025 45 / 80
Unrefrigerated 0.40 7.31 6.14 0.04 0.56 0.56 8,743
Warehouse-No Rail
Total 0.43 7.86 6.61 0.05 0.60 0.60 9,408
Annual — — — — — — —
Industrial Park 0.01 0.10 0.09 < 0.005 0.01 0.01 110
Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Unrefrigerated
Warehouse-No Rail

0.07 1.33 1.12 0.01 0.10 0.10 1,448
Total 0.08 1.44 1.21 0.01 0.11 0.11 1,558

4.3. Area Emissions by Source

4.3.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Source ROG NOx CO SO2 PM10T PM2.5T CO2e
Daily, Summer (Max) — — — — — — —
Consumer Products 32.2 — — — — — —
Architectural Coatings 3.88 — — — — — —
Landscape Equipment 10.7 0.55 65.2 < 0.005 0.12 0.09 269 Total 46.8 0.55 65.2 < 0.005 0.12 0.09 269
Daily, Winter (Max) — — — — — — —
Consumer Products 32.2 — — — — — —
Architectural Coatings 3.88 — — — — — —
Total 36.0 — — — — — —
Annual — — — — — — —
Consumer Products 5.87 — — — — — —
Architectural Coatings 0.71 — — — — — —
Landscape Equipment 0.96 0.05 5.87 < 0.005 0.01 0.01 22.0 Total 7.54 0.05 5.87 < 0.005 0.01 0.01 22.0 Item Number: 1. Page 384 of 2902 DHS Varner Road Specific Plan Detailed Report, 9/11/2025 46 / 80

4.3.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Source ROG NOx CO SO2 PM10T PM2.5T CO2e
Daily, Summer (Max) — — — — — — —
Consumer Products 29.8 — — — — — —
Architectural Coatings 0.45 — — — — — —
Landscape Equipment 10.7 0.55 65.2 < 0.005 0.12 0.09 269 Total 40.9 0.55 65.2 < 0.005 0.12 0.09 269
Daily, Winter (Max) — — — — — — —
Consumer Products 29.8 — — — — — —
Architectural Coatings 0.45 — — — — — —
Total 30.2 — — — — — —
Annual — — — — — — —
Consumer Products 5.43 — — — — — —
Architectural Coatings 0.08 — — — — — —
Landscape Equipment 0.96 0.05 5.87 < 0.005 0.01 0.01 22.0 Total 6.48 0.05 5.87 < 0.005 0.01 0.01 22.0

4.4. Water Emissions by Land Use

4.4.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx CO SO2 PM10T PM2.5T CO2e
Daily, Summer (Max) — — — — — — —
Industrial Park — — — — — — 45.5
Parking Lot — — — — — — 0.00
Unrefrigerated
Warehouse-No Rail
— — — — — — 136
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Total — — — — — — 182
Daily, Winter (Max) — — — — — — —
Industrial Park — — — — — — 45.5
Parking Lot — — — — — — 0.00
Unrefrigerated
Warehouse-No Rail
— — — — — — 136
Total — — — — — — 182
Annual — — — — — — —
Industrial Park — — — — — — 7.53
Parking Lot — — — — — — 0.00
Unrefrigerated
Warehouse-No Rail
— — — — — — 22.6
Total — — — — — — 30.1

4.4.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx CO SO2 PM10T PM2.5T CO2e
Daily, Summer (Max) — — — — — — —
Industrial Park — — — — — — 41.8
Parking Lot — — — — — — 0.00
Unrefrigerated
Warehouse-No Rail
— — — — — — 125
Total — — — — — — 167
Daily, Winter (Max) — — — — — — —
Industrial Park — — — — — — 41.8
Parking Lot — — — — — — 0.00
Unrefrigerated
Warehouse-No Rail
— — — — — — 125
Total — — — — — — 167
Annual — — — — — — — Item Number: 1. Page 386 of 2902
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Industrial Park — — — — — — 6.91
Parking Lot — — — — — — 0.00
Unrefrigerated
Warehouse-No Rail
— — — — — — 20.7
Total — — — — — — 27.7

4.5. Waste Emissions by Land Use

4.5.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx CO SO2 PM10T PM2.5T CO2e
Daily, Summer (Max) — — — — — — —
Industrial Park — — — — — — 175
Parking Lot — — — — — — 0.00
Unrefrigerated
Warehouse-No Rail
— — — — — — 2,526
Total — — — — — — 2,701
Daily, Winter (Max) — — — — — — —
Industrial Park — — — — — — 175
Parking Lot — — — — — — 0.00
Unrefrigerated
Warehouse-No Rail
— — — — — — 2,526
Total — — — — — — 2,701
Annual — — — — — — —
Industrial Park — — — — — — 29.0
Parking Lot — — — — — — 0.00
Unrefrigerated
Warehouse-No Rail
— — — — — — 418
Total — — — — — — 447 Item Number: 1. Page 387 of 2902
DHS Varner Road Specific Plan Detailed Report, 9/11/2025 49 / 80

4.5.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx CO SO2 PM10T PM2.5T CO2e
Daily, Summer (Max) — — — — — — —
Industrial Park — — — — — — 43.8
Parking Lot — — — — — — 0.00
Unrefrigerated
Warehouse-No Rail
— — — — — — 631
Total — — — — — — 675
Daily, Winter (Max) — — — — — — —
Industrial Park — — — — — — 43.8
Parking Lot — — — — — — 0.00
Unrefrigerated
Warehouse-No Rail
— — — — — — 631
Total — — — — — — 675
Annual — — — — — — —
Industrial Park — — — — — — 7.26
Parking Lot — — — — — — 0.00
Unrefrigerated
Warehouse-No Rail
— — — — — — 105
Total — — — — — — 112

4.6. Refrigerant Emissions by Land Use

4.6.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx CO SO2 PM10T PM2.5T CO2e
Daily, Summer (Max) — — — — — — —
Industrial Park — — — — — — 19.5 Item Number: 1. Page 388 of 2902 DHS Varner Road Specific Plan Detailed Report, 9/11/2025 50 / 80
Total — — — — — — 19.5
Daily, Winter (Max) — — — — — — —
Industrial Park — — — — — — 19.5
Total — — — — — — 19.5
Annual — — — — — — —
Industrial Park — — — — — — 3.23
Total — — — — — — 3.23

4.6.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx CO SO2 PM10T PM2.5T CO2e
Daily, Summer (Max) — — — — — — —
Industrial Park — — — — — — 19.5
Total — — — — — — 19.5
Daily, Winter (Max) — — — — — — —
Industrial Park — — — — — — 19.5
Total — — — — — — 19.5
Annual — — — — — — —
Industrial Park — — — — — — 3.23
Total — — — — — — 3.23

4.7. Offroad Emissions By Equipment Type

4.7.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipment Type ROG NOx CO SO2 PM10T PM2.5T CO2e
Daily, Summer (Max) — — — — — — —
Forklifts 0.94 8.82 15.5 0.02 0.34 0.31 2,294 Item Number: 1. Page 389 of 2902 DHS Varner Road Specific Plan Detailed Report, 9/11/2025 51 / 80
Other General
Industrial Equipment

0.55 4.68 6.29 0.01 0.26 0.24 874
Total 1.49 13.5 21.8 0.03 0.60 0.55 3,168
Daily, Winter (Max) — — — — — — —
Forklifts 0.94 8.82 15.5 0.02 0.34 0.31 2,294
Other General
Industrial Equipment

0.55 4.68 6.29 0.01 0.26 0.24 874
Total 1.49 13.5 21.8 0.03 0.60 0.55 3,168
Annual — — — — — — —
Forklifts 0.12 1.15 2.01 < 0.005 0.04 0.04 271
Other General
Industrial Equipment

0.07 0.61 0.82 < 0.005 0.03 0.03 103
Total 0.19 1.75 2.83 < 0.005 0.08 0.07 374

4.7.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipment Type ROG NOx CO SO2 PM10T PM2.5T CO2e
Daily, Summer (Max) — — — — — — —
Forklifts 0.94 8.82 15.5 0.02 0.34 0.31 2,294
Other General
Industrial Equipment

0.55 4.68 6.29 0.01 0.26 0.24 874
Total 1.49 13.5 21.8 0.03 0.60 0.55 3,168
Daily, Winter (Max) — — — — — — —
Forklifts 0.94 8.82 15.5 0.02 0.34 0.31 2,294
Other General
Industrial Equipment

0.55 4.68 6.29 0.01 0.26 0.24 874
Total 1.49 13.5 21.8 0.03 0.60 0.55 3,168
Annual — — — — — — —
Forklifts 0.12 1.15 2.01 < 0.005 0.04 0.04 271 Item Number: 1. Page 390 of 2902 DHS Varner Road Specific Plan Detailed Report, 9/11/2025 52 / 80
Other General 0.07 0.61 0.82 < 0.005 0.03 0.03 103
Industrial Equipment
Total 0.19 1.75 2.83 < 0.005 0.08 0.07 374

4.8. Stationary Emissions By Equipment Type

4.8.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipment Type ROG NOx CO SO2 PM10T PM2.5T CO2e
Daily, Summer (Max) — — — — — — —
Fire Pump 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Emergency Generator 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Total 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Daily, Winter (Max) — — — — — — —
Fire Pump 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Emergency Generator 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Total 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — —
Fire Pump 0.01 0.02 0.02 < 0.005 < 0.005 < 0.005 3.44
Emergency Generator 0.33 1.47 0.84 < 0.005 0.05 0.05 153 Total 0.34 1.49 0.86 < 0.005 0.05 0.05 156

4.8.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipment Type ROG NOx CO SO2 PM10T PM2.5T CO2e
Daily, Summer (Max) — — — — — — —
Fire Pump 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Emergency Generator 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Item Number: 1. Page 391 of 2902 DHS Varner Road Specific Plan Detailed Report, 9/11/2025 53 / 80
Total 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Daily, Winter (Max) — — — — — — —
Fire Pump 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Emergency Generator 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Total 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — —
Fire Pump 0.01 0.02 0.02 < 0.005 < 0.005 < 0.005 3.44
Emergency Generator 0.33 1.47 0.84 < 0.005 0.05 0.05 153 Total 0.34 1.49 0.86 < 0.005 0.05 0.05 156

4.9. User Defined Emissions By Equipment Type

4.9.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipment Type ROG NOx CO SO2 PM10T PM2.5T CO2e
Daily, Summer (Max) — — — — — — —
Total — — — — — — —
Daily, Winter (Max) — — — — — — —
Total — — — — — — —
Annual — — — — — — —
Total — — — — — — —

4.9.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipment Type ROG NOx CO SO2 PM10T PM2.5T CO2e
Daily, Summer (Max) — — — — — — —
Total — — — — — — —
Daily, Winter (Max) — — — — — — — Item Number: 1. Page 392 of 2902 DHS Varner Road Specific Plan Detailed Report, 9/11/2025 54 / 80
Total — — — — — — —
Annual — — — — — — —
Total — — — — — — —

4.10. Soil Carbon Accumulation By Vegetation Type

4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Vegetation ROG NOx CO SO2 PM10T PM2.5T CO2e
Daily, Summer (Max) — — — — — — —
Total — — — — — — —
Daily, Winter (Max) — — — — — — —
Total — — — — — — —
Annual — — — — — — —
Total — — — — — — —

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

4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Item Number: 1. Page 393 of 2902 DHS Varner Road Specific Plan Detailed Report, 9/11/2025 55 / 80
Species ROG NOx CO SO2 PM10T PM2.5T CO2e
Daily, Summer (Max) — — — — — — —
Avoided — — — — — — —
Subtotal — — — — — — —
Sequestered — — — — — — —
Subtotal — — — — — — —
Removed — — — — — — —
Subtotal — — — — — — —
— — — — — — — —
Daily, Winter (Max) — — — — — — —
Avoided — — — — — — —
Subtotal — — — — — — —
Sequestered — — — — — — —
Subtotal — — — — — — —
Removed — — — — — — —
Subtotal — — — — — — —
— — — — — — — —
Annual — — — — — — —
Avoided — — — — — — —
Subtotal — — — — — — —
Sequestered — — — — — — —
Subtotal — — — — — — —
Removed — — — — — — —
Subtotal — — — — — — —
— — — — — — — —

4.10.4. Soil Carbon Accumulation By Vegetation Type - Mitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Item Number: 1. Page 394 of 2902 DHS Varner Road Specific Plan Detailed Report, 9/11/2025 56 / 80
Vegetation ROG NOx CO SO2 PM10T PM2.5T CO2e
Daily, Summer (Max) — — — — — — —
Total — — — — — — —
Daily, Winter (Max) — — — — — — —
Total — — — — — — —
Annual — — — — — — —
Total — — — — — — —

4.10.5. Above and Belowground Carbon Accumulation by Land Use Type - Mitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx CO SO2 PM10T PM2.5T CO2e
Daily, Summer (Max) — — — — — — —
Total — — — — — — —
Daily, Winter (Max) — — — — — — —
Total — — — — — — —
Annual — — — — — — —
Total — — — — — — —

4.10.6. Avoided and Sequestered Emissions by Species - Mitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Species ROG NOx CO SO2 PM10T PM2.5T CO2e
Daily, Summer (Max) — — — — — — —
Avoided — — — — — — —
Subtotal — — — — — — —
Sequestered — — — — — — —
Subtotal — — — — — — —
Removed — — — — — — —
Subtotal — — — — — — — Item Number: 1. Page 395 of 2902 DHS Varner Road Specific Plan Detailed Report, 9/11/2025 57 / 80
— — — — — — — —
Daily, Winter (Max) — — — — — — —
Avoided — — — — — — —
Subtotal — — — — — — —
Sequestered — — — — — — —
Subtotal — — — — — — —
Removed — — — — — — —
Subtotal — — — — — — —
— — — — — — — —
Annual — — — — — — —
Avoided — — — — — — —
Subtotal — — — — — — —
Sequestered — — — — — — —
Subtotal — — — — — — —
Removed — — — — — — —
Subtotal — — — — — — —
— — — — — — — —

5. Activity Data

5.1. Construction Schedule
Phase Name Phase Type Start Date End Date Days Per Week Work Days per Phase Phase Description Linear, Grading &
Excavation
Linear, Grading &
Excavation
8/7/2026 10/29/2026 5.00 60.0 —
Linear, Drainage, Utilities,
& Sub-Grade
Linear, Drainage, Utilities,
& Sub-Grade
9/1/2026 11/23/2026 5.00 60.0 —
Linear, Paving Linear, Paving 10/1/2026 12/23/2026 5.00 60.0 — Grading Grading 5/1/2026 8/6/2026 5.00 70.0 —
Building Construction Building Construction 8/7/2026 2/17/2028 5.00 400 — Item Number: 1. Page 396 of 2902 DHS Varner Road Specific Plan Detailed Report, 9/11/2025 58 / 80
Paving Paving 2/18/2026 4/21/2026 5.00 45.0 —
Architectural Architectural Coating 2/8/2028 5/1/2028 5.00 60.0 —

5.2. Off-Road Equipment

5.2.1. Unmitigated
Phase Name Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor Linear, Grading &
Excavation
Crawler Tractors Diesel Average 2.00 8.00 87.0 0.43
Linear, Grading &
Excavation
Excavators Diesel Average 6.00 8.00 36.0 0.38
Linear, Grading &
Excavation
Graders Diesel Average 3.00 8.00 148 0.41
Linear, Grading &
Excavation
Rollers Diesel Average 4.00 8.00 36.0 0.38
Linear, Grading &
Excavation
Rubber Tired Loaders Diesel Average 2.00 8.00 150 0.36
Linear, Grading &
Excavation
Scrapers Diesel Average 4.00 8.00 423 0.48
Linear, Grading &
Excavation
Signal Boards Electric Average 13.0 8.00 6.00 0.82
Linear, Grading &
Excavation
Tractors/Loaders/Back
hoes
Diesel Average 6.00 8.00 84.0 0.37
Linear, Grading &
Excavation
Other Construction
Equipment
Diesel Average 1.00 3.00 150 0.42
Linear, Drainage,
Utilities, & Sub-Grade
Air Compressors Diesel Average 2.00 8.00 37.0 0.48
Linear, Drainage,
Utilities, & Sub-Grade
Generator Sets Diesel Average 2.00 8.00 14.0 0.74
Linear, Drainage,
Utilities, & Sub-Grade
Graders Diesel Average 2.00 8.00 148 0.41
Linear, Drainage,
Utilities, & Sub-Grade
Plate Compactors Diesel Average 2.00 8.00 8.00 0.43
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Linear, Drainage,
Utilities, & Sub-Grade
Pumps Diesel Average 2.00 8.00 11.0 0.74
Linear, Drainage,
Utilities, & Sub-Grade
Rough Terrain Forklifts Diesel Average 2.00 8.00 96.0 0.40 Linear, Drainage,
Utilities, & Sub-Grade
Scrapers Diesel Average 3.00 8.00 423 0.48
Linear, Drainage,
Utilities, & Sub-Grade
Signal Boards Electric Average 13.0 8.00 6.00 0.82
Linear, Drainage,
Utilities, & Sub-Grade
Tractors/Loaders/Back
hoes
Diesel Average 5.00 8.00 84.0 0.37
Linear, Paving Pavers Diesel Average 2.00 8.00 81.0 0.42 Linear, Paving Paving Equipment Diesel Average 2.00 8.00 89.0 0.36 Linear, Paving Rollers Diesel Average 5.00 8.00 36.0 0.38 Linear, Paving Signal Boards Electric Average 13.0 8.00 6.00 0.82 Linear, Paving Tractors/Loaders/Back
hoes
Diesel Average 5.00 8.00 84.0 0.37
Grading Tractors/Loaders/Back
hoes
Diesel Average 2.00 8.00 84.0 0.37
Grading Excavators Diesel Average 2.00 8.00 36.0 0.38
Grading Graders Diesel Average 1.00 8.00 148 0.41
Grading Rubber Tired Dozers Diesel Average 1.00 8.00 367 0.40 Grading Scrapers Diesel Average 2.00 8.00 423 0.48
Grading Other Construction
Equipment
Diesel Average 2.00 3.00 150 0.42
Building Construction Cranes Diesel Average 1.00 7.00 367 0.29 Building Construction Forklifts Diesel Average 3.00 8.00 82.0 0.20 Building Construction Generator Sets Diesel Average 1.00 8.00 14.0 0.74 Building Construction Tractors/Loaders/Back
hoes
Diesel Average 3.00 7.00 84.0 0.37
Building Construction Welders Diesel Average 1.00 8.00 46.0 0.45 Building Construction Other Construction
Equipment
Diesel Average 2.00 3.00 150 0.42
Item Number: 1.

DHS Varner Road Specific Plan Detailed Report, 9/11/2025 60 / 80
Paving Pavers Diesel Average 2.00 8.00 81.0 0.42
Paving Paving Equipment Diesel Average 2.00 8.00 89.0 0.36 Paving Rollers Diesel Average 2.00 8.00 36.0 0.38
Architectural Air Compressors Diesel Average 1.00 6.00 37.0 0.48

5.2.2. Mitigated
Phase Name Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor Linear, Grading &
Excavation
Crawler Tractors Diesel Average 1.00 8.00 87.0 0.43
Linear, Grading &
Excavation
Crawler Tractors Diesel Tier 4 Final 1.00 8.00 87.0 0.43 Linear, Grading &
Excavation
Excavators Diesel Average 3.00 8.00 36.0 0.38
Linear, Grading &
Excavation
Excavators Diesel Tier 4 Final 3.00 8.00 36.0 0.38
Linear, Grading &
Excavation
Graders Diesel Average 1.00 8.00 148 0.41
Linear, Grading &
Excavation
Graders Diesel Tier 4 Final 2.00 8.00 148 0.41
Linear, Grading &
Excavation
Rollers Diesel Average 2.00 8.00 36.0 0.38
Linear, Grading &
Excavation
Rollers Diesel Tier 4 Final 2.00 8.00 36.0 0.38
Linear, Grading &
Excavation
Rubber Tired Loaders Diesel Average 1.00 8.00 150 0.36
Linear, Grading &
Excavation
Rubber Tired Loaders Diesel Tier 4 Final 1.00 8.00 150 0.36 Linear, Grading &
Excavation
Scrapers Diesel Average 2.00 8.00 423 0.48
Linear, Grading &
Excavation
Scrapers Diesel Tier 4 Final 2.00 8.00 423 0.48
Linear, Grading &
Excavation
Signal Boards Electric Average 13.0 8.00 6.00 0.82
Item Number: 1.

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Linear, Grading &
Excavation
Tractors/Loaders/Back Diesel Average 2.00 8.00 84.0 0.37 Linear, Grading &
Excavation
Tractors/Loaders/Back
hoes
Diesel Tier 4 Final 4.00 8.00 84.0 0.37
Linear, Grading &
Excavation
Other Construction
Equipment
Diesel Tier 4 Final 1.00 3.00 150 0.42
Linear, Drainage,
Utilities, & Sub-Grade
Air Compressors Diesel Average 1.00 8.00 37.0 0.48
Linear, Drainage,
Utilities, & Sub-Grade
Air Compressors Diesel Tier 4 Final 1.00 8.00 37.0 0.48 Linear, Drainage,
Utilities, & Sub-Grade
Generator Sets Diesel Average 2.00 8.00 14.0 0.74
Linear, Drainage,
Utilities, & Sub-Grade
Graders Diesel Average 1.00 8.00 148 0.41
Linear, Drainage,
Utilities, & Sub-Grade
Graders Diesel Tier 4 Final 1.00 8.00 148 0.41
Linear, Drainage,
Utilities, & Sub-Grade
Plate Compactors Diesel Average 2.00 8.00 8.00 0.43
Linear, Drainage,
Utilities, & Sub-Grade
Pumps Diesel Average 2.00 8.00 11.0 0.74
Linear, Drainage,
Utilities, & Sub-Grade
Rough Terrain Forklifts Diesel Average 1.00 8.00 96.0 0.40 Linear, Drainage,
Utilities, & Sub-Grade
Rough Terrain Forklifts Diesel Tier 4 Final 1.00 8.00 96.0 0.40 Linear, Drainage,
Utilities, & Sub-Grade
Scrapers Diesel Average 2.00 8.00 423 0.48
Linear, Drainage,
Utilities, & Sub-Grade
Scrapers Diesel Tier 4 Final 1.00 8.00 423 0.48
Linear, Drainage,
Utilities, & Sub-Grade
Signal Boards Electric Average 13.0 8.00 6.00 0.82
Linear, Drainage,
Utilities, & Sub-Grade
Tractors/Loaders/Back
hoes
Diesel Average 2.00 8.00 84.0 0.37
Linear, Drainage,
Utilities, & Sub-Grade
Tractors/Loaders/Back
hoes
Diesel Tier 4 Final 3.00 8.00 84.0 0.37
Linear, Paving Pavers Diesel Average 1.00 8.00 81.0 0.42 Item Number: 1. Page 400 of 2902 DHS Varner Road Specific Plan Detailed Report, 9/11/2025 62 / 80
Linear, Paving Pavers Diesel Tier 4 Final 1.00 8.00 81.0 0.42 Linear, Paving Paving Equipment Diesel Average 1.00 8.00 89.0 0.36 Linear, Paving Paving Equipment Diesel Tier 4 Final 1.00 8.00 89.0 0.36 Linear, Paving Rollers Diesel Average 3.00 8.00 36.0 0.38 Linear, Paving Rollers Diesel Tier 4 Final 2.00 8.00 36.0 0.38 Linear, Paving Signal Boards Electric Average 13.0 8.00 6.00 0.82 Linear, Paving Tractors/Loaders/Back
hoes
Diesel Average 2.00 8.00 84.0 0.37
Linear, Paving Tractors/Loaders/Back
hoes
Diesel Tier 4 Final 3.00 8.00 84.0 0.37
Grading Tractors/Loaders/Back
hoes
Diesel Tier 4 Final 2.00 8.00 84.0 0.37
Grading Excavators Diesel Tier 4 Final 2.00 8.00 36.0 0.38 Grading Graders Diesel Tier 4 Final 1.00 8.00 148 0.41
Grading Rubber Tired Dozers Diesel Tier 4 Final 1.00 8.00 367 0.40 Grading Scrapers Diesel Tier 4 Final 2.00 8.00 423 0.48 Grading Other Construction
Equipment
Diesel Tier 4 Final 2.00 3.00 150 0.42
Building Construction Cranes Diesel Tier 4 Final 1.00 7.00 367 0.29 Building Construction Forklifts Diesel Tier 4 Final 3.00 8.00 82.0 0.20 Building Construction Generator Sets Diesel Average 1.00 8.00 14.0 0.74 Building Construction Tractors/Loaders/Back
hoes
Diesel Tier 4 Final 3.00 7.00 84.0 0.37
Building Construction Welders Diesel Tier 4 Final 1.00 8.00 46.0 0.45 Building Construction Other Construction
Equipment
Diesel Tier 4 Final 2.00 3.00 150 0.42
Paving Pavers Diesel Tier 4 Final 2.00 8.00 81.0 0.42
Paving Paving Equipment Diesel Tier 4 Final 2.00 8.00 89.0 0.36 Paving Rollers Diesel Tier 4 Final 2.00 8.00 36.0 0.38
Architectural Air Compressors Diesel Tier 4 Final 1.00 6.00 37.0 0.48 Item Number: 1. Page 401 of 2902 DHS Varner Road Specific Plan Detailed Report, 9/11/2025 63 / 80

5.3. Construction Vehicles

5.3.1. Unmitigated
Phase Name Trip Type One-Way Trips per Day Miles per Trip Vehicle Mix Grading — — — —
Grading Worker 25.0 18.5 LDA,LDT1,LDT2
Grading Vendor — 10.2 HHDT,MHDT
Grading Hauling 158 20.0 HHDT
Grading Onsite truck — — HHDT
Building Construction — — — —
Building Construction Worker 630 18.5 LDA,LDT1,LDT2
Building Construction Vendor 246 10.2 HHDT,MHDT
Building Construction Hauling 0.00 20.0 HHDT
Building Construction Onsite truck — — HHDT
Paving — — — —
Paving Worker 15.0 18.5 LDA,LDT1,LDT2
Paving Vendor — 10.2 HHDT,MHDT
Paving Hauling 30.0 20.0 HHDT
Paving Onsite truck — — HHDT
Linear, Grading & Excavation — — — —
Linear, Grading & Excavation Worker 103 18.5 LDA,LDT1,LDT2 Linear, Grading & Excavation Vendor 2.00 10.2 HHDT,MHDT Linear, Grading & Excavation Hauling 0.00 20.0 HHDT
Linear, Grading & Excavation Onsite truck — — HHDT
Linear, Drainage, Utilities, &
Sub-Grade
— — — —
Linear, Drainage, Utilities, &
Sub-Grade
Worker 82.5 18.5 LDA,LDT1,LDT2
Item Number: 1.