Cities Index.
Communications 11-12-25

Elk Grove City Council
November 12, 2025

Document
Communications 11-12-25
Meeting
November 12, 2025
Body
Elk Grove City Council
Pages
32
Original file
70.5 MB
Text extracted from the city's file for reading and search. Open the original on elkgrove.granicus.com. That file is the official record.

COMMUNICATIONS

IN RELATION TO THE

CITY OF ELK GROVE
NOVEMBER 12, 2025

REGULAR MEETING
11/ 10/25, 8:0 1 AM lnbox - Jason Lindqren - Outlook
Outlook
Re: November 12 Appeal Hearing
From Edward Yates
Date Sat 11/8/2025 3:16 PM
To Jason Lindgren <[email protected]>
Cc Kyra Killingsworth <[email protected]>; EG City Clerk <[email protected]>; Timothy Kassouni II 3 attachments (11 MB)
Maverick Fueling Elk Grove Detailed Report_AQ and Toxics.pd/; Clark Comments Maverick Fuel Class 32 Letter.pd/; Elk Grove - Maverik TBrohard Traffic Comments 11 07 2025.pdt [EXTERNAL EMAIL]
Mr. Lindgren,
I am attaching reports from two technical experts that I retained on behalf of my client, Protect Elk Grove, regarding my client's appeal on Nov. 12. These reports are incorporated by reference into the already submitted appeal.

I will address both the Staff Report and these attached studies in a letter to the Council as soon as I am able.

Ed Yates
Thank you for the quick helpful response.

EdY
On Fri, Nov 7, 2025 at 12:06 PM Jason Lindgren <jlindgreo@Jllkgu:ootgall.> wrote:

Good Afternoon,
The City of Elk Grove does require physical attendance for speakers.

As the appellant, you will have the opportunity to speak both at the start of the item, and you will have an opportunity after the close of general public comment. There is no timer for your opportunities to speak as appellant (general public comment speakers have a 3-minute speaker limit), but overall the allotted time would be at the discretion of the City Council.

Note that the applicant will have the similar opportunity to speak both at the start of the item, and will have an opportunity after the close of general public comment.

Noted on the materials, those are anticipated to post today, and I will send you the link to the agenda and to the item staff report.

If you have any questions or concerns regarding this matter, feel free to contact me by phone at 1-916-478-2286, or email at jlindg�g(Jlllf.gall. .

Jason Lindgren (he/him}
City Clerk
Office of the City Clerk
City of Elk Grove

CITY OF
LK
https://outlook.office.com/mail/inbox/id/AAkALqAAAAAAHYQDEapmEc2byACQAC%2FEWq0AMfAZIHIIQEWH1oeiOuF8dwAGRQL%2Bil:IAA?nativeV... 1/2

SUPPLEMENTAL INFORMATION
AGENDA ITEM NO. 8.1
11-12-2025








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Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 1 / 46
Maverick Fueling Elk Grove v2 Detailed Report
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

2.4. Operations Emissions Compared Against Thresholds

2.5. Operations Emissions by Sector, Unmitigated

3. Construction Emissions Details

3.1. Demolition (2025) - Unmitigated

3.3. Site Preparation (2025) - Unmitigated

3.5. Grading (2025) - Unmitigated

3.7. Building Construction (2025) - Unmitigated

3.9. Paving (2025) - Unmitigated
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 2 / 46

3.11. Architectural Coating (2025) - Unmitigated

4. Operations Emissions Details

4.1. Mobile Emissions by Land Use

4.1.1. Unmitigated

4.2. Energy

4.2.1. Electricity Emissions By Land Use - Unmitigated

4.2.3. Natural Gas Emissions By Land Use - Unmitigated

4.3. Area Emissions by Source

4.3.1. Unmitigated

4.4. Water Emissions by Land Use

4.4.1. Unmitigated

4.5. Waste Emissions by Land Use

4.5.1. Unmitigated

4.6. Refrigerant Emissions by Land Use

4.6.1. Unmitigated

4.7. Offroad Emissions By Equipment Type

4.7.1. Unmitigated

4.8. Stationary Emissions By Equipment Type
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 3 / 46

4.8.1. Unmitigated

4.9. User Defined Emissions By Equipment Type

4.9.1. Unmitigated

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

5. Activity Data

5.1. Construction Schedule

5.2. Off-Road Equipment

5.2.1. Unmitigated

5.3. Construction Vehicles

5.3.1. Unmitigated

5.4. Vehicles

5.4.1. Construction Vehicle Control Strategies

5.5. Architectural Coatings

5.6. Dust Mitigation

5.6.1. Construction Earthmoving Activities
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 4 / 46

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

5.10. Operational Area Sources

5.10.1. Hearths

5.10.2. Architectural Coatings

5.10.3. Landscape Equipment

5.11. Operational Energy Consumption

5.11.1. Unmitigated

5.12. Operational Water and Wastewater Consumption

5.12.1. Unmitigated

5.13. Operational Waste Generation

5.13.1. Unmitigated

5.14. Operational Refrigeration and Air Conditioning Equipment

5.14.1. Unmitigated

5.15. Operational Off-Road Equipment
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 5 / 46

5.15.1. Unmitigated

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. Biomass Cover Type

5.18.1.1. Unmitigated

5.18.2. Sequestration

5.18.2.1. Unmitigated

6. Climate Risk Detailed Report

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
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 6 / 46

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

8.1. Justifications
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 7 / 46

1. Basic Project Information

1.1. Basic Project Information
Data Field Value
Project Name Maverick Fueling Elk Grove v2
Construction Start Date 7/1/2025
Operational Year 2026
Lead Agency —
Land Use Scale Project/site
Analysis Level for Defaults County
Windspeed (m/s) 3.0
Precipitation (days) 37
Location 10490 E Stockton Blvd, Elk Grove, CA 95624, USA County Sacramento
City Elk Grove
Air District Sacramento Metropolitan AQMD
Air Basin Sacramento Valley
TAZ 737
EDFZ 13
Electric Utility Sacramento Municipal Utility District
Gas Utility Pacific Gas & Electric
App Version 2022.1.1.31

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
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 8 / 46
Convenience 6.0 1000sqft 2.6 2.6 27,364 — — —
Market with Gas
Pumps

1.3. User-Selected Emission Reduction Measures by Emissions Sector No measures selected

2. Emissions Summary

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. TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 3.3 2.8 25 27 0.05 1.0 7.2 8.2 0.96 3.4 4.4 — 5,281 5,281 0.36 0.44 6.1 5,428 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 1.9 1.7 11 12 0.02 0.40 0.15 0.42 0.37 0.04 0.37 — 2,201 2,201 0.09 0.02 0.02 2,209 Average
Daily
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 0.51 0.42 3.6 4.0 0.01 0.14 0.15 0.29 0.13 0.04 0.16 — 790 790 0.04 0.02 0.08 796 Annual
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 0.09 0.08 0.66 0.73 < 0.005 0.02 0.03 0.05 0.02 0.01 0.03 — 131 131 0.01 < 0.005 0.01 132 Exceeds
(Daily
Max)
— — — — — — — — — — — — — — — — — —
Threshol
d
— — 85 — — — — 80 — — 82 — — — — — — —
Unmit. — — No — — — — No — — No — — — — — — —
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 9 / 46
Exceeds
(Average
Daily)
— — — — — — — — — — — — — — — — — —
Threshol
d
— — 85 — — — — 80 — — 82 — — — — — — —
Unmit. — — No — — — — No — — No — — — — — — —
Exceeds
(Annual)
— — — — — — — — — — — — — — — — — —
Threshol
d
— — — — — — — — — — — — — — — — — —
Unmit. — — 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 TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily -
Summer
(Max)
— — — — — — — — — — — — — — — — — —
2025 3.3 2.8 25 27 0.05 1.0 7.2 8.2 0.96 3.4 4.4 — 5,281 5,281 0.36 0.44 6.1 5,428 Daily -
Winter
(Max)
— — — — — — — — — — — — — — — — — —
2025 1.9 1.7 11 12 0.02 0.40 0.15 0.42 0.37 0.04 0.37 — 2,201 2,201 0.09 0.02 0.02 2,209 Average
Daily
— — — — — — — — — — — — — — — — — —
2025 0.51 0.42 3.6 4.0 0.01 0.14 0.15 0.29 0.13 0.04 0.16 — 790 790 0.04 0.02 0.08 796 Annual — — — — — — — — — — — — — — — — — —
2025 0.09 0.08 0.66 0.73 < 0.005 0.02 0.03 0.05 0.02 0.01 0.03 — 131 131 0.01 < 0.005 0.01 132

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) Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 10 / 46
Un/Mit. TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 18 17 15 154 0.34 0.25 28 29 0.23 7.2 7.5 11 34,606 34,617 2.4 1.4 120 35,212 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 17 15 18 129 0.31 0.25 28 29 0.23 7.2 7.5 11 31,615 31,626 2.6 1.5 3.7 32,150 Average
Daily
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 14 13 9.1 69 0.14 0.11 12 12 0.11 3.0 3.1 11 13,942 13,953 2.0 0.78 22 14,256 Annual
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 2.5 2.3 1.7 13 0.02 0.02 2.1 2.1 0.02 0.54 0.56 1.8 2,308 2,310 0.33 0.13 3.7 2,360

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 TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Mobile 18 17 15 154 0.34 0.25 28 29 0.23 7.2 7.5 — 34,604 34,604 1.4 1.4 120 35,174 Area < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 Energy < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 0.15 0.15 < 0.005 < 0.005 — 0.15 Water — — — — — — — — — — — 0.95 1.9 2.8 < 0.005 < 0.005 — 3.5 Waste — — — — — — — — — — — 9.7 0.00 9.7 0.97 0.00 — 34 Refrig. — — — — — — — — — — — — — — — — 0.55 0.55
Total 18 17 15 154 0.34 0.25 28 29 0.23 7.2 7.5 11 34,606 34,617 2.4 1.4 120 35,212 Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 11 / 46
Daily, — — — — — — — — — — — — — — — — — —
Winter
(Max)
Mobile 17 15 18 129 0.31 0.25 28 29 0.23 7.2 7.5 — 31,613 31,613 1.6 1.5 3.1 32,112 Area < 0.005 < 0.005 — — — — — — — — — — — — — — — —
Energy < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 0.15 0.15 < 0.005 < 0.005 — 0.15 Water — — — — — — — — — — — 0.95 1.9 2.8 < 0.005 < 0.005 — 3.5 Waste — — — — — — — — — — — 9.7 0.00 9.7 0.97 0.00 — 34 Refrig. — — — — — — — — — — — — — — — — 0.55 0.55
Total 17 15 18 129 0.31 0.25 28 29 0.23 7.2 7.5 11 31,615 31,626 2.6 1.5 3.7 32,150 Average
Daily
— — — — — — — — — — — — — — — — — —
Mobile 14 13 9.1 69 0.14 0.11 12 12 0.11 3.0 3.1 — 13,940 13,940 1.00 0.77 22 14,218 Area < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 Energy < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 0.15 0.15 < 0.005 < 0.005 — 0.15 Water — — — — — — — — — — — 0.95 1.9 2.8 < 0.005 < 0.005 — 3.5 Waste — — — — — — — — — — — 9.7 0.00 9.7 0.97 0.00 — 34 Refrig. — — — — — — — — — — — — — — — — 0.55 0.55
Total 14 13 9.1 69 0.14 0.11 12 12 0.11 3.0 3.1 11 13,942 13,953 2.0 0.78 22 14,256 Annual — — — — — — — — — — — — — — — — — —
Mobile 2.5 2.3 1.7 13 0.02 0.02 2.1 2.1 0.02 0.54 0.56 — 2,308 2,308 0.16 0.13 3.6 2,354 Area < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 Energy < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 0.02 0.02 < 0.005 < 0.005 — 0.02 Water — — — — — — — — — — — 0.16 0.31 0.47 < 0.005 < 0.005 — 0.58 Waste — — — — — — — — — — — 1.6 0.00 1.6 0.16 0.00 — 5.6 Refrig. — — — — — — — — — — — — — — — — 0.09 0.09
Total 2.5 2.3 1.7 13 0.02 0.02 2.1 2.1 0.02 0.54 0.56 1.8 2,308 2,310 0.33 0.13 3.7 2,360

3. Construction Emissions Details
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 12 / 46

3.1. Demolition (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

1.8 1.5 14 15 0.02 0.57 — 0.57 0.52 — 0.52 — 2,494 2,494 0.10 0.02 — 2,502 Demoliti
on
— — — — — — 3.1 3.1 — 0.47 0.47 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.05 0.04 0.38 0.41 < 0.005 0.02 — 0.02 0.01 — 0.01 — 68 68 < 0.005 < 0.005 — 69 Demoliti
on
— — — — — — 0.09 0.09 — 0.01 0.01 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.01 0.01 0.07 0.08 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 11 11 < 0.005 < 0.005 — 11 Demoliti
on
— — — — — — 0.02 0.02 — < 0.005 < 0.005 — — — — — — —
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 13 / 46
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.06 0.05 0.04 0.75 0.00 0.00 0.13 0.13 0.00 0.03 0.03 — 142 142 < 0.005 0.01 0.54 144 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.33 0.07 4.8 1.9 0.02 0.05 0.68 0.73 0.05 0.18 0.23 — 2,645 2,645 0.25 0.42 5.6 2,782 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 3.5 3.5 < 0.005 < 0.005 0.01 3.6 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.01 < 0.005 0.14 0.05 < 0.005 < 0.005 0.02 0.02 < 0.005 < 0.005 0.01 — 72 72 0.01 0.01 0.07 76 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.59 0.59 < 0.005 < 0.005 < 0.005 0.59 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling < 0.005 < 0.005 0.03 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 12 12 < 0.005 < 0.005 0.01 13

3.3. Site Preparation (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 14 / 46
Off-Roa 1.4 1.2 11 11 0.03 0.47 — 0.47 0.43 — 0.43 — 2,717 2,717 0.11 0.02 — 2,726 d
Equipm
ent
Dust
From
Material
Movement
— — — — — — 1.6 1.6 — 0.17 0.17 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent
< 0.005 < 0.005 0.03 0.03 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 7.4 7.4 < 0.005 < 0.005 — 7.5 Dust
From
Material
Movement
— — — — — — < 0.005 < 0.005 — < 0.005 < 0.005 — — — — — — — Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent
< 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 1.2 1.2 < 0.005 < 0.005 — 1.2 Dust
From
Material
Movement
— — — — — — < 0.005 < 0.005 — < 0.005 < 0.005 — — — — — — — Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 15 / 46
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.03 0.03 0.02 0.45 0.00 0.00 0.08 0.08 0.00 0.02 0.02 — 85 85 < 0.005 < 0.005 0.33 86 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.21 0.21 < 0.005 < 0.005 < 0.005 0.22 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.04 0.04 < 0.005 < 0.005 < 0.005 0.04 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.5. Grading (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

1.8 1.5 14 15 0.02 0.64 — 0.64 0.59 — 0.59 — 2,455 2,455 0.10 0.02 — 2,463 Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 16 / 46
Dust — — — — — — 7.1 7.1 — 3.4 3.4 — — — — — — —
From
Material
Movement
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.01 0.01 0.08 0.08 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 13 13 < 0.005 < 0.005 — 13 Dust
From
Material
Movement
— — — — — — 0.04 0.04 — 0.02 0.02 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent
< 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 2.2 2.2 < 0.005 < 0.005 — 2.2 Dust
From
Material
Movement
— — — — — — 0.01 0.01 — < 0.005 < 0.005 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.05 0.04 0.03 0.60 0.00 0.00 0.10 0.10 0.00 0.02 0.02 — 114 114 < 0.005 < 0.005 0.44 115 Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 17 / 46
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.57 0.57 < 0.005 < 0.005 < 0.005 0.57 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.09 0.09 < 0.005 < 0.005 < 0.005 0.10 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.7. Building Construction (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

1.5 1.2 11 12 0.02 0.40 — 0.40 0.37 — 0.37 — 2,201 2,201 0.09 0.02 — 2,209 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 18 / 46
Off-Roa 1.5 1.2 11 12 0.02 0.40 — 0.40 0.37 — 0.37 — 2,201 2,201 0.09 0.02 — 2,209 d
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.41 0.34 2.9 3.2 0.01 0.11 — 0.11 0.10 — 0.10 — 603 603 0.02 < 0.005 — 605 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.07 0.06 0.53 0.59 < 0.005 0.02 — 0.02 0.02 — 0.02 — 100 100 < 0.005 < 0.005 — 100 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.01 0.01 < 0.005 < 0.005 < 0.005 0.01 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 0.01 0.01 < 0.005 < 0.005 < 0.005 0.01 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.01 0.01 < 0.005 < 0.005 < 0.005 0.01 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 0.01 0.01 < 0.005 < 0.005 < 0.005 0.01 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 19 / 46
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.9. Paving (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.83 0.70 6.1 8.2 0.01 0.27 — 0.27 0.25 — 0.25 — 1,244 1,244 0.05 0.01 — 1,248 Paving 0.99 0.99 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.01 0.01 0.08 0.11 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 17 17 < 0.005 < 0.005 — 17 Paving 0.01 0.01 — — — — — — — — — — — — — — — —
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 20 / 46
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent
< 0.005 < 0.005 0.02 0.02 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 2.8 2.8 < 0.005 < 0.005 — 2.8 Paving < 0.005 < 0.005 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.06 0.06 0.06 0.67 0.00 0.00 0.15 0.15 0.00 0.04 0.04 — 151 151 < 0.005 0.01 0.02 153 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 2.1 2.1 < 0.005 < 0.005 < 0.005 2.2 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.35 0.35 < 0.005 < 0.005 < 0.005 0.36 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.11. Architectural Coating (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 21 / 46
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.15 0.13 0.88 1.1 < 0.005 0.03 — 0.03 0.03 — 0.03 — 134 134 0.01 < 0.005 — 134 Architect
ural
Coating
s
< 0.005 < 0.005 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent
< 0.005 < 0.005 0.01 0.02 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 1.8 1.8 < 0.005 < 0.005 — 1.8 Architect
ural
Coating
s
< 0.005 < 0.005 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent
< 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 0.30 0.30 < 0.005 < 0.005 — 0.30 Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 22 / 46
Architect < 0.005 < 0.005 — — — — — — — — — — — — — — — — ural
Coating
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

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) Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 23 / 46
Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Conveni
ence
Market
with Gas
Pumps
18 17 15 154 0.34 0.25 28 29 0.23 7.2 7.5 — 34,604 34,604 1.4 1.4 120 35,174 Total 18 17 15 154 0.34 0.25 28 29 0.23 7.2 7.5 — 34,604 34,604 1.4 1.4 120 35,174 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Conveni
ence
Market
with Gas
Pumps
17 15 18 129 0.31 0.25 28 29 0.23 7.2 7.5 — 31,613 31,613 1.6 1.5 3.1 32,112 Total 17 15 18 129 0.31 0.25 28 29 0.23 7.2 7.5 — 31,613 31,613 1.6 1.5 3.1 32,112 Annual — — — — — — — — — — — — — — — — — —
Conveni
ence
Market
with Gas
Pumps

2.5 2.3 1.7 13 0.02 0.02 2.1 2.1 0.02 0.54 0.56 — 2,308 2,308 0.16 0.13 3.6 2,354 Total 2.5 2.3 1.7 13 0.02 0.02 2.1 2.1 0.02 0.54 0.56 — 2,308 2,308 0.16 0.13 3.6 2,354

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
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 24 / 46
Daily, — — — — — — — — — — — — — — — — — —
Summer
(Max)
Conveni
ence
Market
with Gas
Pumps
— — — — — — — — — — — — 0.13 0.13 < 0.005 < 0.005 — 0.13 Total — — — — — — — — — — — — 0.13 0.13 < 0.005 < 0.005 — 0.13 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Conveni
ence
Market
with Gas
Pumps
— — — — — — — — — — — — 0.13 0.13 < 0.005 < 0.005 — 0.13 Total — — — — — — — — — — — — 0.13 0.13 < 0.005 < 0.005 — 0.13 Annual — — — — — — — — — — — — — — — — — —
Conveni
ence
Market
with Gas
Pumps
— — — — — — — — — — — — 0.02 0.02 < 0.005 < 0.005 — 0.02 Total — — — — — — — — — — — — 0.02 0.02 < 0.005 < 0.005 — 0.02

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
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 25 / 46
Conveni < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 0.02 0.02 < 0.005 < 0.005 — 0.02 ence
Market
with Gas
Pumps
Total < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 0.02 0.02 < 0.005 < 0.005 — 0.02 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Conveni
ence
Market
with Gas
Pumps
< 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 0.02 0.02 < 0.005 < 0.005 — 0.02 Total < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 0.02 0.02 < 0.005 < 0.005 — 0.02 Annual — — — — — — — — — — — — — — — — — —
Conveni
ence
Market
with Gas
Pumps
< 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 Total < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005

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 TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Consum
er
Product
s
< 0.005 < 0.005 — — — — — — — — — — — — — — — —
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 26 / 46
Architect
Coatings
< 0.005 < 0.005 — — — — — — — — — — — — — — — —
Landsca
pe
Equipm
ent
< 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 Total < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Consum
er
Product
s
< 0.005 < 0.005 — — — — — — — — — — — — — — — —
Architect
ural
Coating
s
< 0.005 < 0.005 — — — — — — — — — — — — — — — —
Total < 0.005 < 0.005 — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Consum
er
Product
s
< 0.005 < 0.005 — — — — — — — — — — — — — — — —
Architect
ural
Coating
s
< 0.005 < 0.005 — — — — — — — — — — — — — — — —
Landsca
pe
Equipm
ent
< 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 Total < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005

4.4. Water Emissions by Land Use
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 27 / 46

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
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Conveni
ence
Market
with Gas
Pumps
— — — — — — — — — — — 0.95 1.9 2.8 < 0.005 < 0.005 — 3.5 Total — — — — — — — — — — — 0.95 1.9 2.8 < 0.005 < 0.005 — 3.5 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Conveni
ence
Market
with Gas
Pumps
— — — — — — — — — — — 0.95 1.9 2.8 < 0.005 < 0.005 — 3.5 Total — — — — — — — — — — — 0.95 1.9 2.8 < 0.005 < 0.005 — 3.5 Annual — — — — — — — — — — — — — — — — — —
Conveni
ence
Market
with Gas
Pumps
— — — — — — — — — — — 0.16 0.31 0.47 < 0.005 < 0.005 — 0.58 Total — — — — — — — — — — — 0.16 0.31 0.47 < 0.005 < 0.005 — 0.58

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) Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 28 / 46
Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Conveni
ence
Market
with Gas
Pumps
— — — — — — — — — — — 9.7 0.00 9.7 0.97 0.00 — 34
Total — — — — — — — — — — — 9.7 0.00 9.7 0.97 0.00 — 34 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Conveni
ence
Market
with Gas
Pumps
— — — — — — — — — — — 9.7 0.00 9.7 0.97 0.00 — 34
Total — — — — — — — — — — — 9.7 0.00 9.7 0.97 0.00 — 34 Annual — — — — — — — — — — — — — — — — — —
Conveni
ence
Market
with Gas
Pumps
— — — — — — — — — — — 1.6 0.00 1.6 0.16 0.00 — 5.6
Total — — — — — — — — — — — 1.6 0.00 1.6 0.16 0.00 — 5.6

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
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 29 / 46
Daily, — — — — — — — — — — — — — — — — — —
Summer
(Max)
Conveni
ence
Market
with Gas
Pumps
— — — — — — — — — — — — — — — — 0.55 0.55
Total — — — — — — — — — — — — — — — — 0.55 0.55
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Conveni
ence
Market
with Gas
Pumps
— — — — — — — — — — — — — — — — 0.55 0.55
Total — — — — — — — — — — — — — — — — 0.55 0.55
Annual — — — — — — — — — — — — — — — — — —
Conveni
ence
Market
with Gas
Pumps
— — — — — — — — — — — — — — — — 0.09 0.09
Total — — — — — — — — — — — — — — — — 0.09 0.09

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) Equipm
ent
Type
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 30 / 46
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

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) Equipm
ent
Type
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

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) Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 31 / 46
Equipm TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e ent
Type
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
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) Vegetati
on
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 32 / 46
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R 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) Species TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Sequest
ered
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Remove
d
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
— — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 33 / 46
Avoided — — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Sequest
ered
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Remove
d
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
— — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Sequest
ered
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Remove
d
— — — — — — — — — — — — — — — — — —
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 Demolition Demolition 7/1/2025 7/14/2025 5.0 10.0 —
Site Preparation Site Preparation 7/16/2025 7/16/2025 5.0 1.00 — Grading Grading 7/18/2025 7/21/2025 5.0 2.0 —
Building Construction Building Construction 7/21/2025 12/5/2025 5.0 100 — Paving Paving 12/9/2025 12/15/2025 5.0 5.0 —
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 34 / 46
Architectural Coating Architectural Coating 12/17/2025 12/23/2025 5.0 5.0 —

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 Demolition Tractors/Loaders/Back
hoes
Diesel Average 3.0 8.0 84 0.37
Demolition Rubber Tired Dozers Diesel Average 1.00 8.0 367 0.40 Demolition Concrete/Industrial
Saws
Diesel Average 1.00 8.0 33 0.73
Site Preparation Graders Diesel Average 1.00 8.0 148 0.41 Site Preparation Scrapers Diesel Average 1.00 8.0 423 0.48 Site Preparation Tractors/Loaders/Back
hoes
Diesel Average 1.00 7.0 84 0.37
Grading Graders Diesel Average 1.00 8.0 148 0.41
Grading Rubber Tired Dozers Diesel Average 1.00 8.0 367 0.40 Grading Tractors/Loaders/Back
hoes
Diesel Average 2.0 7.0 84 0.37
Building Construction Cranes Diesel Average 1.00 8.0 367 0.29 Building Construction Forklifts Diesel Average 2.0 7.0 82 0.20 Building Construction Generator Sets Diesel Average 1.00 8.0 14 0.74 Building Construction Tractors/Loaders/Back
hoes
Diesel Average 1.00 6.0 84 0.37
Building Construction Welders Diesel Average 3.0 8.0 46 0.45 Paving Tractors/Loaders/Back
hoes
Diesel Average 1.00 8.0 84 0.37
Paving Pavers Diesel Average 1.00 8.0 81 0.42
Paving Paving Equipment Diesel Average 1.00 8.0 89 0.36 Paving Rollers Diesel Average 2.0 8.0 36 0.38
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 35 / 46
Paving Cement and Mortar
Mixers
Diesel Average 1.00 8.0 10.0 0.56
Architectural Coating Air Compressors Diesel Average 1.00 6.0 37 0.48

5.3. Construction Vehicles

5.3.1. Unmitigated
Phase Name Trip Type One-Way Trips per Day Miles per Trip Vehicle Mix Demolition Worker 13 14 LDA,LDT1,LDT2
Demolition Vendor — 8.8 HHDT,MHDT
Demolition Hauling 36 20 HHDT
Demolition Onsite truck — — HHDT
Site Preparation Worker 7.5 14 LDA,LDT1,LDT2
Site Preparation Vendor — 8.8 HHDT,MHDT
Site Preparation Hauling 0.00 20 HHDT
Site Preparation Onsite truck — — HHDT
Grading Worker 10.0 14 LDA,LDT1,LDT2
Grading Vendor — 8.8 HHDT,MHDT
Grading Hauling 0.00 20 HHDT
Grading Onsite truck — — HHDT
Building Construction Worker < 0.005 14 LDA,LDT1,LDT2
Building Construction Vendor < 0.005 8.8 HHDT,MHDT
Building Construction Hauling 0.00 20 HHDT
Building Construction Onsite truck — — HHDT
Paving Worker 15 14 LDA,LDT1,LDT2
Paving Vendor — 8.8 HHDT,MHDT
Paving Hauling 0.00 20 HHDT
Paving Onsite truck — — HHDT
Architectural Coating Worker < 0.005 14 LDA,LDT1,LDT2
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 36 / 46
Architectural Coating Vendor — 8.8 HHDT,MHDT
Architectural Coating Hauling 0.00 20 HHDT
Architectural Coating Onsite truck — — HHDT

5.4. Vehicles

5.4.1. Construction Vehicle Control Strategies
Control Strategies Applied PM10 Reduction PM2.5 Reduction Water unpaved roads twice daily 55% 55%

5.5. Architectural Coatings
Phase Name Residential Interior Area
Coated (sq ft)
Residential Exterior Area
Coated (sq ft)
Non-Residential Interior Area
Coated (sq ft)
Non-Residential Exterior Area
Coated (sq ft)
Parking Area Coated (sq ft)
Architectural Coating 0.00 0.00 4.0 1.3 —

5.6. Dust Mitigation

5.6.1. Construction Earthmoving Activities
Phase Name Material Imported (cy) Material Exported (cy) Acres Graded (acres) Material Demolished (Building Square Footage)
Acres Paved (acres)
Demolition 0.00 0.00 0.00 31,000 0.00
Site Preparation — — 1.5 0.00 0.00
Grading — — 2.0 0.00 0.00
Paving 0.00 0.00 0.00 0.00 1.9

5.6.2. Construction Earthmoving Control Strategies
Non-applicable. No control strategies activated by user.

5.7. Construction Paving
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 37 / 46
Phase Name Land Use Area Paved (acres) % Asphalt
Paving Convenience Market with Gas Pumps 1.9 100%

5.8. Construction Electricity Consumption and Emissions Factors kWh per Year and Emission Factor (lb/MWh)
Year kWh per Year CO2 CH4 N2O
2025 0.00 375 0.01 < 0.005

5.9. Operational Mobile Sources

5.9.1. Unmitigated
Land Use Type Trips/Weekday Trips/Saturday Trips/Sunday Trips/Year VMT/Weekday VMT/Saturday VMT/Sunday VMT/Year Convenience
Market with Gas
Pumps
3,734 3,734 3,734 1,362,897 7,537 40,085 40,085 6,145,175

5.10. Operational Area Sources

5.10.1. Hearths
Land Use Hearth Type Unmitigated (number) Mitigated (number) Convenience Market with Gas Pumps Wood Fireplaces 0 0
Convenience Market with Gas Pumps Gas Fireplaces 0 0
Convenience Market with Gas Pumps Propane Fireplaces 0 0 Convenience Market with Gas Pumps Electric Fireplaces 0 0 Convenience Market with Gas Pumps No Fireplaces 0 0
Convenience Market with Gas Pumps Conventional Wood Stoves 0 0 Convenience Market with Gas Pumps Catalytic Wood Stoves 0 0 Convenience Market with Gas Pumps Non-Catalytic Wood Stoves 0 0 Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 38 / 46
Convenience Market with Gas Pumps Pellet Wood Stoves 0 0

5.10.2. Architectural Coatings
— Residential Interior Area
Coated (sq ft)
Residential Exterior Area
Coated (sq ft)
Non-Residential Interior Area
Coated (sq ft)
Non-Residential Exterior Area
Coated (sq ft)
Parking Area Coated (sq ft)
undefined 0.00 0.00 4.0 1.3 —

5.10.3. Landscape Equipment
Season Unit Value
Snow Days day/yr 0.00
Summer Days day/yr 250

5.11. Operational Energy Consumption

5.11.1. Unmitigated
Electricity (kWh/yr) and CO2 and CH4 and N2O and Natural Gas (kBTU/yr) Land Use Electricity (kWh/yr) CO2 CH4 N2O Natural Gas (kBTU/yr) Convenience Market with Gas
Pumps
126 375 0.0129 0.0017 53

5.12. Operational Water and Wastewater Consumption

5.12.1. Unmitigated
Land Use Indoor Water (gal/year) Outdoor Water (gal/year) Convenience Market with Gas Pumps 443,102 382,175

5.13. Operational Waste Generation
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 39 / 46

5.13.1. Unmitigated
Land Use Waste (ton/year) Cogeneration (kWh/year)
Convenience Market with Gas Pumps 18 0.00

5.14. Operational Refrigeration and Air Conditioning Equipment

5.14.1. Unmitigated
Land Use Equipment Type Refrigerant GWP Quantity (kg) Operations Leak Rate Service Leak Rate Times Serviced Convenience Market
with Gas Pumps
Other commercial A/C
and heat pumps
R-410A 2,088 < 0.005 4.0 4.0 18
Convenience Market
with Gas Pumps
Supermarket
refrigeration and
condensing units
R-404A 3,922 27 17 17 18

5.15. Operational Off-Road Equipment

5.15.1. Unmitigated

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
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 40 / 46
Vegetation Land Use Type Vegetation Soil Type Initial Acres Final Acres

5.18.1. Biomass Cover Type

5.18.1.1. Unmitigated
Biomass Cover Type Initial Acres Final Acres

5.18.2. Sequestration

5.18.2.1. Unmitigated
Tree Type Number Electricity Saved (kWh/year) Natural Gas Saved (btu/year)

6. Climate Risk Detailed Report

6.1. Climate Risk Summary
Cal-Adapt midcentury 2040–2059 average projections for four hazards are reported below for your project location. These are under Representation Concentration Pathway (RCP) 8.5 which assumes GHG emissions will continue to rise strongly through 2050 and then plateau around 2100.

Climate Hazard Result for Project Location Unit
Temperature and Extreme Heat 20 annual days of extreme heat Extreme Precipitation 4.8 annual days with precipitation above 20 mm Sea Level Rise — meters of inundation depth
Wildfire 0.00 annual hectares burned
Temperature and Extreme Heat data are for grid cell in which your project are located. The projection is based on the 98th historical percentile of daily maximum/minimum temperatures from observed historical data (32 climate model ensemble from Cal-Adapt, 2040–2059 average under RCP 8.5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.

Extreme Precipitation data are for the grid cell in which your project are located. The threshold of 20 mm is equivalent to about ¾ an inch of rain, which would be light to moderate rainfall if received over a full day or heavy rain if received over a period of 2 to 4 hours. Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.

Sea Level Rise data are for the grid cell in which your project are located. The projections are from Radke et al. (2017), as reported in Cal-Adapt (Radke et al., 2017, CEC-500-2017-008), and consider inundation location and depth for the San Francisco Bay, the Sacramento-San Joaquin River Delta and California coast resulting different increments of sea level rise coupled with extreme storm events. Users may select from four scenarios to view the range in potential inundation depth for the grid cell. The four scenarios are: No rise, 0.5 meter, 1.0 meter, 1.41 meters Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 41 / 46
Wildfire data are for the grid cell in which your project are located. The projections are from UC Davis, as reported in Cal-Adapt (2040–2059 average under RCP 8.5), and consider historical data of climate, vegetation, population density, and large (> 400 ha) fire history. Users may select from four model simulations to view the range in potential wildfire probabilities for the grid cell. The four simulations make different assumptions about expected rainfall and temperature are: Warmer/drier (HadGEM2-ES), Cooler/wetter (CNRM-CM5), Average conditions (CanESM2), Range of different rainfall and temperature possibilities (MIROC5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.

6.2. Initial Climate Risk Scores
Climate Hazard Exposure Score Sensitivity Score Adaptive Capacity Score Vulnerability Score Temperature and Extreme Heat 1 0 0 N/A
Extreme Precipitation 1 0 0 N/A
Sea Level Rise N/A N/A N/A N/A
Wildfire 1 0 0 N/A
Flooding 0 0 0 N/A
Drought 0 0 0 N/A
Snowpack Reduction N/A N/A N/A N/A
Air Quality Degradation 0 0 0 N/A
The sensitivity score reflects the extent to which a project would be adversely affected by exposure to a climate hazard. Exposure is rated on a scale of 1 to 5, with a score of 5 representing the greatest exposure.

The adaptive capacity of a project refers to its ability to manage and reduce vulnerabilities from projected climate hazards. Adaptive capacity is rated on a scale of 1 to 5, with a score of 5 representing the greatest ability to adapt.

The overall vulnerability scores are calculated based on the potential impacts and adaptive capacity assessments for each hazard. Scores do not include implementation of climate risk reduction measures.

6.3. Adjusted Climate Risk Scores
Climate Hazard Exposure Score Sensitivity Score Adaptive Capacity Score Vulnerability Score Temperature and Extreme Heat 1 1 1 2
Extreme Precipitation 1 1 1 2
Sea Level Rise N/A N/A N/A N/A
Wildfire 1 1 1 2
Flooding 1 1 1 2
Drought 1 1 1 2
Snowpack Reduction N/A N/A N/A N/A
Air Quality Degradation 1 1 1 2
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 42 / 46
The sensitivity score reflects the extent to which a project would be adversely affected by exposure to a climate hazard. Exposure is rated on a scale of 1 to 5, with a score of 5 representing the greatest exposure.

The adaptive capacity of a project refers to its ability to manage and reduce vulnerabilities from projected climate hazards. Adaptive capacity is rated on a scale of 1 to 5, with a score of 5 representing the greatest ability to adapt.

The overall vulnerability scores are calculated based on the potential impacts and adaptive capacity assessments for each hazard. Scores include implementation of climate risk reduction measures.

6.4. Climate Risk Reduction Measures

7. Health and Equity Details

7.1. CalEnviroScreen 4.0 Scores
The maximum CalEnviroScreen score is 100. A high score (i.e., greater than 50) reflects a higher pollution burden compared to other census tracts in the state.

Indicator Result for Project Census Tract
Exposure Indicators —
AQ-Ozone 47
AQ-PM 35
AQ-DPM 47
Drinking Water 42
Lead Risk Housing 43
Pesticides 55
Toxic Releases 20
Traffic 65
Effect Indicators —
CleanUp Sites 4.1
Groundwater 22
Haz Waste Facilities/Generators 85
Impaired Water Bodies 12
Solid Waste 36
Sensitive Population —
Asthma 46
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 43 / 46
Cardio-vascular 79
Low Birth Weights 60
Socioeconomic Factor Indicators —
Education 37
Housing 40
Linguistic 8.5
Poverty 55
Unemployment 12

7.2. Healthy Places Index Scores
The maximum Health Places Index score is 100. A high score (i.e., greater than 50) reflects healthier community conditions compared to other census tracts in the state.

Indicator Result for Project Census Tract
Economic —
Above Poverty 65.31502631
Employed 83.80597973
Median HI 56.69190299
Education —
Bachelor's or higher 34.96727833
High school enrollment 100
Preschool enrollment 13.49929424
Transportation —
Auto Access 46.0284871
Active commuting 66.46990889
Social —
2-parent households 68.29205697
Voting 78.13422302
Neighborhood —
Alcohol availability 64.32696009
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 44 / 46
Park access 59.96407032
Retail density 38.5730784
Supermarket access 18.65776979
Tree canopy 84.11394842
Housing —
Homeownership 59.50211728
Housing habitability 72.71910689
Low-inc homeowner severe housing cost burden 38.86821506 Low-inc renter severe housing cost burden 84.02412421
Uncrowded housing 42.30719877
Health Outcomes —
Insured adults 60.5800077
Arthritis 28.3
Asthma ER Admissions 47.5
High Blood Pressure 40.5
Cancer (excluding skin) 27.6
Asthma 32.2
Coronary Heart Disease 47.4
Chronic Obstructive Pulmonary Disease 35.3
Diagnosed Diabetes 68.9
Life Expectancy at Birth 23.5
Cognitively Disabled 30.7
Physically Disabled 22.7
Heart Attack ER Admissions 28.3
Mental Health Not Good 47.3
Chronic Kidney Disease 64.9
Obesity 44.9
Pedestrian Injuries 19.6
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 45 / 46
Physical Health Not Good 54.5
Stroke 58.2
Health Risk Behaviors —
Binge Drinking 15.4
Current Smoker 32.2
No Leisure Time for Physical Activity 68.6
Climate Change Exposures —
Wildfire Risk 0.0
SLR Inundation Area 0.0
Children 37.8
Elderly 42.6
English Speaking 71.1
Foreign-born 17.6
Outdoor Workers 45.5
Climate Change Adaptive Capacity —
Impervious Surface Cover 60.3
Traffic Density 49.1
Traffic Access 23.0
Other Indices —
Hardship 48.5
Other Decision Support —
2016 Voting 66.5

7.3. Overall Health & Equity Scores
Metric Result for Project Census Tract
CalEnviroScreen 4.0 Score for Project Location (a) 45
Healthy Places Index Score for Project Location (b) 63
Project Located in a Designated Disadvantaged Community (Senate Bill 535) No Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 46 / 46
Project Located in a Low-Income Community (Assembly Bill 1550) No Project Located in a Community Air Protection Program Community (Assembly Bill 617) No a: The maximum CalEnviroScreen score is 100. A high score (i.e., greater than 50) reflects a higher pollution burden compared to other census tracts in the state. b: The maximum Health Places Index score is 100. A high score (i.e., greater than 50) reflects healthier community conditions compared to other census tracts in the state.

7.4. Health & Equity Measures
No Health & Equity Measures selected.

7.5. Evaluation Scorecard
Health & Equity Evaluation Scorecard not completed.

7.6. Health & Equity Custom Measures
No Health & Equity Custom Measures created.

8. User Changes to Default Data

8.1. Justifications
Screen Justification
Land Use Based on project description
Construction: Construction Phases Per model output from Ascent Construction: Paving Based on site plans
1 November 7, 2025

Law Office of Edward E. Yates
2060 Sutter St. #403
San Francisco, CA 94115
Attn: Mr. Edward Yates
Subject: Comments On CEQA Categorical Exemption 15332 For Maverick Fueling Station And Convenience Store
Located At 10490 East Stockton Boulevard, City of Elk
Grove, California, PLNG24-031, SCH Number
2025090957
At the request of Law Office of Edward E. Yates (Yates), Clark and Associates (Clark) has reviewed the Planning Commission Staff Report Requesting A Conditional Use Permit and Minor Design Review for the Project (dated September 18, 2025); the September 9, 2024 Memo from Ascent Environmental to Kyra Killingworth, Project Planner regarding Application PLNG24-031 for the Maverick Elk Grove and CEQA Process Recommendation; as well as the January 17, 2025 Memo from Ascent Environmental to Rick Magness, AWA.

Clark’s review does not constitute validation or endorsement of the conclusions or content presented in the documents reviewed. Any lack of comment on specific items should not be interpreted as acceptance or approval of those items.

According to the CEQANet summary of the project (which is taken directly from the City of Elk Grove Notice Of Exemption), “The Maverik Fueling Station and Convenience Store Project (“Project”) consists of a Conditional Use Permit to allow a fueling station use on the Project site and Minor Design Review for the proposed fueling station and convenience store. The proposed development includes a ±5,951 square foot convenience store, two fuel canopies with a total of 25 pumps and associated site improvements (i.e. landscaping, parking, and lighting). The Project shall comply with the City’s Climate Action Plan Clark & Associates
Environmental Consulting, Inc.

OFFICE
12405 Venice Blvd
Suite 331
Los Angeles, CA 90066
PHONE
310-907-6165
EMAIL
[email protected]
2 (CAP) for non-residential development.”
The City of Elk Grove provided a Categorical Exemption (CE) under Section 15332 (In-Fill Development) for the Project based on its review of the materials submitted by the Proponent.

According to the City’s analysis, the State CEQA guidelines section 15332 consists of projects characterized as in fill development that meet the following conditions: a) The project is consistent with the applicable general plan designation and all applicable general plan policies as well as with applicable zoning designation and regulations. b) The proposed development occurs within city limits on a project site of no more than five acres substantially surrounded by urban uses. c) The project site has no value as habitat for endangered, rare, or threatened species. d) Approval of the project would not result in any significant effects relating to traffic, noise, air quality, or water quality. e) The site can be adequately served by all required utilities and public services.

The Project consists of a Minor Design Review and a Conditional Use Permit for the construction of a fueling station with a convenience store; two fueling canopies; and associated parking, landscaping and lighting improvements. The property currently has an existing building that will be demolished with this application, which will also require a building permit with the City’s Building Division. The Project was reviewed by the City and found to be consistent with the applicable General Plan designation and all applicable General Plan policies as well as with the applicable zoning designation and regulations.

The Project site is within an urban area that is less than five acres in size and surrounded by other industrial and commercial businesses. The Project site does not contain any habitat for endangered, rare, or threatened species as the site is graded, does not have vegetation, and there has been a building on site since the early 1980’s. According to the City’s review approval of the Project would not result in any significant effects relating to traffic, noise, air quality, or water quality as it would be subject to the Elk Grove Municipal Code (EGMC) Chapter 16.44 related to Land Grading and Erosion Control and EGMC 6.32 related to Noise Control. The Project would also be subject to the City’s water efficient landscape ordinance.

The Applicant provided an Air Quality Assessment for the Project dated January 17, 2025, by Ascent and peer-reviewed by AECOM. It was determined that the Project would be below the construction and operational air quality screening levels set forth in the Sacramento Metropolitan Air Quality Management District CEQA Guide and would not result in significant impacts related to air quality.
3 Specific Comments

1. The City Failed To Assess The Potential For Historic Hazardous Waste Contamination On Site.

The City’s CE fails to include an analysis of the potential for hazardous waste to exist in the subsurface soils and or groundwater of the Project Site. According to the September 9, 2024 Ascent Memo “The site is not does not contain any hazardous materials and is not any active hazardous material site lists pursuant to Government Code Section 65962.5. A search of the State Water Resources Control Board and California Department of Toxic Substance Control databases was conducted on September 09, 2024.”
Figure 1: Geotracker Map Of Impacted Sites In Vicinity of Project Site Even a cursory Phase I Environmental Site Assessment (ESA) would have noted properties 4 with historic contamination. The property at 10473 Stockton Blvd (property next door) historically had a gasoline dispensing facility and mini mart (Chuck’s Mini Mart or Flying “V” Service Station).

The Property is listed in the State Water Resources Control Board’s (SWRCB’s) Geotracker website as Regional Board Case Number 340411 and is identified as a leaking underground storage tank (LUST) clean up site. According to the Quarterly Monitoring report in the Geotracker website, the investigation at Chuck's Mini Mart focused on assessing soil and groundwater contamination due to gasoline leakage from underground fuel tanks. Delta Environmental Consultants conducted initial soil borings in February 1990, revealing petroleum hydrocarbons in soil samples near the tanks, with concentrations of Total Petroleum Hydrocarbons as Gasoline (TPH G) ranging from 15 ppm to 2,800 ppm. Groundwater monitoring well MW-1 was installed in March 1990, detecting TPH G at 4,000 ppb and benzene at 220 ppb.

The soil contamination was primarily concentrated within the upper 40 feet around the underground tanks, with significant TPH G levels detected. Groundwater contamination was confirmed in 1990 but could not be reassessed in 1991 due to the dry state of MW-1. Further investigation, including the installation of a deeper monitoring well, was necessary to verify groundwater contamination and guide remediation efforts.

Additionally, the Geotracker website shows that ARCO #5752, located at 10466 Grand Line Road (the southern end of the current Project Site) also was aa LUST site. In 2003, URS reported that the site was investigated due to petroleum hydrocarbon contamination detected during February 2003 sampling activities. Hydrocarbon-impacted soil was primarily found near dispenser island samples DI-1 and DI-4, with other impacted areas near DI-2, DI-3, LS-2, LS-3, LS-4, LS-5, and LS-6. Total petroleum hydrocarbons as gasoline (TPHg) were reported at concentrations up to 3,400 mg/kg, while benzene was below detection limits. Methyl tert-butyl ether (MtBE) and tert-amyl methyl ether (TAME) were detected at concentrations up to 29 mg/kg and 2.8 mg/kg, respectively.

The site investigation included the installation of a groundwater monitoring well (MW-1) and soil borings to assess contamination. Subsurface conditions revealed layers of sandy silt, poorly graded sand, sandy gravel, and sandy clay. Groundwater was encountered at approximately 91 feet below ground surface (bgs). Analytical results showed no significant detection of petroleum hydrocarbons or fuel additives in soil samples, while groundwater samples revealed low concentrations of toluene (0.64 µg/L) and total xylenes (0.76 µg/L). A quarterly monitoring program was initiated to further evaluate groundwater conditions. 5 Since the City has failed to address the concerns of historic hazardous waste contamination in the area of the Project Site, it is clear that they have not actually assessed the potential hazards associated with the Project Site. At a minimum the City should require the completion of a Phase I ESA for the Project Site and should also require a Phase II ESA in which the site is assessed for residual contamination in the subsurface. Issuance of a CE for the Project is not warranted and an environmental impact report (EIR) should be required before the Project is allowed to proceed.

2. The CE Fails To Perform An Accurate Cumulative Impact Analysis On Air Quality.

A proper cumulative impact analysis is vital for an environmental analysis “because the full environmental impact of a proposed project cannot be gauged in a vacuum. One of the most important environmental lessons that has been learned is that the environmental damage often occurs incrementally from a variety of small sources with which they interact.”1 The CSEA’s conclusion is flawed for the following reasons.

First, the discussion in the comments above indicates that the Project would contribute to an existing significant impact, i.e. degraded air quality in the air basin as evidenced by frequent violations of PM10, PM2.5 and ozone ambient air quality standards. The Project would increase the emissions of PM10, PM2.5, and ozone precursors and thus would contribute to these existing exceedances of ambient air quality standards. Thus, the Project’s contribution is per se cumulatively significant.

Second, a cumulative impacts analysis must consider past projects, the effects of other current projects, and the effects of probable future projects.”2 The CE did not identify any other closely related, past, present, or reasonably foreseeable probable future projects let alone attempt to quantify their emissions and, thus, to evaluate them cumulatively with the Project.

The City’s air quality cumulative analysis is clearly deficient and must be supported by the preparation of an CE.
1 Bakersfield Citizens (2004) 124 Cal. App. 4th at 1214 (quoting Communities for a Better Environment v. California Resources Agency 103 Cal.App.4th at 116).
2 CEQA Guidelines §15355(b)
6 3. The Air Quality Analysis Utilizes An Older Version of CalEEMod And Underestimates The NOx Emissions By At Least Fifty Percent
According to the January 17, 2025 Ascent Memo regarding Air Quality Assessment for the Maverick Elk Grove Gas Station Project, “Criteria air pollutant and precursor emissions from the construction and operation of the project were estimated using the California Emissions Estimator Model (CalEEMod) version 2022.1, which is the latest model tool available at the time of the analysis.

Modeling inputs included project-specific land use types and size.” Model defaults were utilized for the construction phases and equipment activities.

Figure 2: Summary of CalEEMod Analysis For Construction Of Project Using the latest version of CalEEMOD, version 2022.1.1.31, I have reconstructed the CalEEMod analysis for the project (attached as an exhibit to this letter) and found that original version which was submitted (but not included in the attachments to the Memo) produced NOx emissions that were 250% higher (25 lbs per day versus 10 lbs per day) than those calculated by Ascent. As Ascent noted, NOx emissions are primarily a result of exhaust from construction equipment, and PM10 emissions are a result of airborne dust earth-moving activities and exhaust emissions. Reactive organic gas (ROG) emissions are primarily a result of volatile organic gases from architectural coatings. 7 Figure 3: CalEEMod Analysis Using Latest Model Version Additionally, the model estimated calculated the number of daily trips associated with the Project to be 3,734 trips per day rather than the 1,919 trips per day assumed in the Ascent memo.

Figure 4: Operational Traffic Estimate
This near doubling of the traffic associated with the Project will result in a doubling of the regional impacts associated with the Project that have not been accounted for by the City in the CE.

4. The City’s Air Quality Analysis Fails To Include A Quantitative Health Risk Analysis Of The Impacts Of Toxic Air Contaminants From The Construction Phase And Operational Phase Of The Project For The Nearest Sensitive Receptor(s) The City has failed to conduct a numerical health risk analysis (HRA) for operational phase of the Project that includes all of the chemicals of concern that will be emitted from the Project Site. For the operational phase of the Project, since the emissions calculated were below the SMAQMD’s regional thresholds, a risk assessment was not warranted. The determination of a significance 8 threshold is based on a quantitative risk analysis that requires the City to perform a multistep, quantitative health risk analysis.

The Proponent has utilized a screening health risk assessment tool from the California Air Resources Board (CARB) that focuses on emissions of one group of toxic air contaminants (TACs) associated with the fueling operations of the Project. Excluded in the analysis are emissions of other TACs associated with the Project Site, and most specifically diesel particulate matter (DPM) 3 . It has
been well established that DPM contributes to a host of respiratory impacts and may lead to the development of various cancers. Failing to quantify those impacts places the community at risk for unwanted adverse health impacts. Even brief exposures to the TACs could lead to the development of adverse health impacts over the life of an individual.

Diesel exhaust contains nearly 40 toxic substances, including TACs and may pose a serious public health risk for residents in the vicinity of the facility. TACs are airborne substances that are capable of causing short-term (acute) and/or long-term (chronic or carcinogenic, i.e., cancer causing) adverse human health effects (i.e., injury or illness). TACs include both organic and inorganic chemical substances. The current California list of TACs includes approximately 200 compounds, including particulate emissions from diesel-fueled engines.

Diesel exhaust has been linked to a range of serious health problems including an increase in respiratory disease, lung damage, cancer, and premature death. 4,5,6 Fine DPM is deposited deep in the
lungs in the smallest airways and can result in increased respiratory symptoms and disease; decreased lung function, particularly in children and individuals with asthma; alterations in lung tissue and 3 Because DPM is a TAC, it is a different air pollutant than criteria particulate matter (PM) emissions such as PM10, PM2.5, and fugitive dust. DPM exposure causes acute health effects that are different from the effects of exposure to PM alone.
4 California Air Resources Board, Initial Statement of Reasons for Rulemaking, Proposed Identification of Diesel Exhaust as a Toxic Air Contaminant, Staff Report, June 1998; see also California Air Resources Board, Overview:

Diesel Exhaust & Health, https://ww2.arb.ca.gov/resources/overview-diesel-exhaust-andhealth#:~:text=Diesel%20Particulate%20Matter%20and%20Health&text=In%201998%2C%20CARB%20identified%2 0DPM,and%20other%20adverse%20health%20effects.
5 U.S. EPA, Health Assessment Document for Diesel Engine Exhaust, Report EPA/600/8-90/057F, May 2002. 6 Environmental Defense Fund, Cleaner Diesel Handbook, Bring Cleaner Fuel and Diesel Retrofits into Your Neighborhood, April 2005; http://www.edf.org/documents/4941_cleanerdieselhandbook.pdf, accessed July 5, 2020. 9 respiratory tract defense mechanisms; and premature death.7 Exposure to DPM increases the risk of
lung cancer. It also causes non-cancer effects including chronic bronchitis, inflammation of lung tissue, thickening of the alveolar walls, immunological allergic reactions, and airway constriction.8 DPM is a TAC that is recognized by state and federal agencies as causing severe health risk because it contains toxic materials, unlike PM2.5 and PM10.
9 The inherent toxicity of the TACs requires the City to first quantify the concentration released into the environment at each of the sensitive receptor locations through air dispersion modeling, calculate the dose of each TAC at that location, and quantify the cancer risk and hazard index for each of the chemicals of concern. Following that analysis, then the City can make a determination of the relative significance of the emissions. The City’s current analysis is therefore incomplete and must be corrected in an EIR for the Project.

Conclusion
The facts presented in this comment letter lead me to reasonably conclude that the Project could result in significant impacts if allowed to proceed based on the CE. An EIR is necessary to address these substantial concerns fully and transparently.

Sincerely,
7 California Air Resources Board, Initial Statement of Reasons for Rulemaking, Proposed Identification of Diesel Exhaust as a Toxic Air Contaminant, Staff Report, June 1998. 8 Findings of the Scientific Review Panel on The Report on Diesel Exhaust as adopted at the Panel’s April 22, 1998 Meeting.
9 Health & Safety Code § 39655(a) (defining “toxic air contaminant” as air pollutants “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. A substance that is listed as a hazardous air pollutant pursuant to subsection (b) of Section 112 of the federal act (42 U.S.C.

Sec. 7412 (b)) is a toxic air contaminant.”)
10 Exhibit A:

CalEEMod Analysis Of Project
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 1 / 46
Maverick Fueling Elk Grove v2 Detailed Report
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

2.4. Operations Emissions Compared Against Thresholds

2.5. Operations Emissions by Sector, Unmitigated

3. Construction Emissions Details

3.1. Demolition (2025) - Unmitigated

3.3. Site Preparation (2025) - Unmitigated

3.5. Grading (2025) - Unmitigated

3.7. Building Construction (2025) - Unmitigated

3.9. Paving (2025) - Unmitigated
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 2 / 46

3.11. Architectural Coating (2025) - Unmitigated

4. Operations Emissions Details

4.1. Mobile Emissions by Land Use

4.1.1. Unmitigated

4.2. Energy

4.2.1. Electricity Emissions By Land Use - Unmitigated

4.2.3. Natural Gas Emissions By Land Use - Unmitigated

4.3. Area Emissions by Source

4.3.1. Unmitigated

4.4. Water Emissions by Land Use

4.4.1. Unmitigated

4.5. Waste Emissions by Land Use

4.5.1. Unmitigated

4.6. Refrigerant Emissions by Land Use

4.6.1. Unmitigated

4.7. Offroad Emissions By Equipment Type

4.7.1. Unmitigated

4.8. Stationary Emissions By Equipment Type
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 3 / 46

4.8.1. Unmitigated

4.9. User Defined Emissions By Equipment Type

4.9.1. Unmitigated

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

5. Activity Data

5.1. Construction Schedule

5.2. Off-Road Equipment

5.2.1. Unmitigated

5.3. Construction Vehicles

5.3.1. Unmitigated

5.4. Vehicles

5.4.1. Construction Vehicle Control Strategies

5.5. Architectural Coatings

5.6. Dust Mitigation

5.6.1. Construction Earthmoving Activities
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 4 / 46

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

5.10. Operational Area Sources

5.10.1. Hearths

5.10.2. Architectural Coatings

5.10.3. Landscape Equipment

5.11. Operational Energy Consumption

5.11.1. Unmitigated

5.12. Operational Water and Wastewater Consumption

5.12.1. Unmitigated

5.13. Operational Waste Generation

5.13.1. Unmitigated

5.14. Operational Refrigeration and Air Conditioning Equipment

5.14.1. Unmitigated

5.15. Operational Off-Road Equipment
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 5 / 46

5.15.1. Unmitigated

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. Biomass Cover Type

5.18.1.1. Unmitigated

5.18.2. Sequestration

5.18.2.1. Unmitigated

6. Climate Risk Detailed Report

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
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 6 / 46

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

8.1. Justifications
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 7 / 46

1. Basic Project Information

1.1. Basic Project Information
Data Field Value
Project Name Maverick Fueling Elk Grove v2
Construction Start Date 7/1/2025
Operational Year 2026
Lead Agency —
Land Use Scale Project/site
Analysis Level for Defaults County
Windspeed (m/s) 3.0
Precipitation (days) 37
Location 10490 E Stockton Blvd, Elk Grove, CA 95624, USA County Sacramento
City Elk Grove
Air District Sacramento Metropolitan AQMD
Air Basin Sacramento Valley
TAZ 737
EDFZ 13
Electric Utility Sacramento Municipal Utility District
Gas Utility Pacific Gas & Electric
App Version 2022.1.1.31

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
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 8 / 46
Convenience 6.0 1000sqft 2.6 2.6 27,364 — — —
Market with Gas
Pumps

1.3. User-Selected Emission Reduction Measures by Emissions Sector No measures selected

2. Emissions Summary

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. TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 3.3 2.8 25 27 0.05 1.0 7.2 8.2 0.96 3.4 4.4 — 5,281 5,281 0.36 0.44 6.1 5,428 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 1.9 1.7 11 12 0.02 0.40 0.15 0.42 0.37 0.04 0.37 — 2,201 2,201 0.09 0.02 0.02 2,209 Average
Daily
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 0.51 0.42 3.6 4.0 0.01 0.14 0.15 0.29 0.13 0.04 0.16 — 790 790 0.04 0.02 0.08 796 Annual
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 0.09 0.08 0.66 0.73 < 0.005 0.02 0.03 0.05 0.02 0.01 0.03 — 131 131 0.01 < 0.005 0.01 132 Exceeds
(Daily
Max)
— — — — — — — — — — — — — — — — — —
Threshol
d
— — 85 — — — — 80 — — 82 — — — — — — —
Unmit. — — No — — — — No — — No — — — — — — —
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 9 / 46
Exceeds
(Average
Daily)
— — — — — — — — — — — — — — — — — —
Threshol
d
— — 85 — — — — 80 — — 82 — — — — — — —
Unmit. — — No — — — — No — — No — — — — — — —
Exceeds
(Annual)
— — — — — — — — — — — — — — — — — —
Threshol
d
— — — — — — — — — — — — — — — — — —
Unmit. — — 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 TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily -
Summer
(Max)
— — — — — — — — — — — — — — — — — —
2025 3.3 2.8 25 27 0.05 1.0 7.2 8.2 0.96 3.4 4.4 — 5,281 5,281 0.36 0.44 6.1 5,428 Daily -
Winter
(Max)
— — — — — — — — — — — — — — — — — —
2025 1.9 1.7 11 12 0.02 0.40 0.15 0.42 0.37 0.04 0.37 — 2,201 2,201 0.09 0.02 0.02 2,209 Average
Daily
— — — — — — — — — — — — — — — — — —
2025 0.51 0.42 3.6 4.0 0.01 0.14 0.15 0.29 0.13 0.04 0.16 — 790 790 0.04 0.02 0.08 796 Annual — — — — — — — — — — — — — — — — — —
2025 0.09 0.08 0.66 0.73 < 0.005 0.02 0.03 0.05 0.02 0.01 0.03 — 131 131 0.01 < 0.005 0.01 132

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) Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 10 / 46
Un/Mit. TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 18 17 15 154 0.34 0.25 28 29 0.23 7.2 7.5 11 34,606 34,617 2.4 1.4 120 35,212 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 17 15 18 129 0.31 0.25 28 29 0.23 7.2 7.5 11 31,615 31,626 2.6 1.5 3.7 32,150 Average
Daily
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 14 13 9.1 69 0.14 0.11 12 12 0.11 3.0 3.1 11 13,942 13,953 2.0 0.78 22 14,256 Annual
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 2.5 2.3 1.7 13 0.02 0.02 2.1 2.1 0.02 0.54 0.56 1.8 2,308 2,310 0.33 0.13 3.7 2,360

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 TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Mobile 18 17 15 154 0.34 0.25 28 29 0.23 7.2 7.5 — 34,604 34,604 1.4 1.4 120 35,174 Area < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 Energy < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 0.15 0.15 < 0.005 < 0.005 — 0.15 Water — — — — — — — — — — — 0.95 1.9 2.8 < 0.005 < 0.005 — 3.5 Waste — — — — — — — — — — — 9.7 0.00 9.7 0.97 0.00 — 34 Refrig. — — — — — — — — — — — — — — — — 0.55 0.55
Total 18 17 15 154 0.34 0.25 28 29 0.23 7.2 7.5 11 34,606 34,617 2.4 1.4 120 35,212 Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 11 / 46
Daily, — — — — — — — — — — — — — — — — — —
Winter
(Max)
Mobile 17 15 18 129 0.31 0.25 28 29 0.23 7.2 7.5 — 31,613 31,613 1.6 1.5 3.1 32,112 Area < 0.005 < 0.005 — — — — — — — — — — — — — — — —
Energy < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 0.15 0.15 < 0.005 < 0.005 — 0.15 Water — — — — — — — — — — — 0.95 1.9 2.8 < 0.005 < 0.005 — 3.5 Waste — — — — — — — — — — — 9.7 0.00 9.7 0.97 0.00 — 34 Refrig. — — — — — — — — — — — — — — — — 0.55 0.55
Total 17 15 18 129 0.31 0.25 28 29 0.23 7.2 7.5 11 31,615 31,626 2.6 1.5 3.7 32,150 Average
Daily
— — — — — — — — — — — — — — — — — —
Mobile 14 13 9.1 69 0.14 0.11 12 12 0.11 3.0 3.1 — 13,940 13,940 1.00 0.77 22 14,218 Area < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 Energy < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 0.15 0.15 < 0.005 < 0.005 — 0.15 Water — — — — — — — — — — — 0.95 1.9 2.8 < 0.005 < 0.005 — 3.5 Waste — — — — — — — — — — — 9.7 0.00 9.7 0.97 0.00 — 34 Refrig. — — — — — — — — — — — — — — — — 0.55 0.55
Total 14 13 9.1 69 0.14 0.11 12 12 0.11 3.0 3.1 11 13,942 13,953 2.0 0.78 22 14,256 Annual — — — — — — — — — — — — — — — — — —
Mobile 2.5 2.3 1.7 13 0.02 0.02 2.1 2.1 0.02 0.54 0.56 — 2,308 2,308 0.16 0.13 3.6 2,354 Area < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 Energy < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 0.02 0.02 < 0.005 < 0.005 — 0.02 Water — — — — — — — — — — — 0.16 0.31 0.47 < 0.005 < 0.005 — 0.58 Waste — — — — — — — — — — — 1.6 0.00 1.6 0.16 0.00 — 5.6 Refrig. — — — — — — — — — — — — — — — — 0.09 0.09
Total 2.5 2.3 1.7 13 0.02 0.02 2.1 2.1 0.02 0.54 0.56 1.8 2,308 2,310 0.33 0.13 3.7 2,360

3. Construction Emissions Details
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 12 / 46

3.1. Demolition (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

1.8 1.5 14 15 0.02 0.57 — 0.57 0.52 — 0.52 — 2,494 2,494 0.10 0.02 — 2,502 Demoliti
on
— — — — — — 3.1 3.1 — 0.47 0.47 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.05 0.04 0.38 0.41 < 0.005 0.02 — 0.02 0.01 — 0.01 — 68 68 < 0.005 < 0.005 — 69 Demoliti
on
— — — — — — 0.09 0.09 — 0.01 0.01 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.01 0.01 0.07 0.08 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 11 11 < 0.005 < 0.005 — 11 Demoliti
on
— — — — — — 0.02 0.02 — < 0.005 < 0.005 — — — — — — —
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 13 / 46
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.06 0.05 0.04 0.75 0.00 0.00 0.13 0.13 0.00 0.03 0.03 — 142 142 < 0.005 0.01 0.54 144 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.33 0.07 4.8 1.9 0.02 0.05 0.68 0.73 0.05 0.18 0.23 — 2,645 2,645 0.25 0.42 5.6 2,782 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 3.5 3.5 < 0.005 < 0.005 0.01 3.6 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.01 < 0.005 0.14 0.05 < 0.005 < 0.005 0.02 0.02 < 0.005 < 0.005 0.01 — 72 72 0.01 0.01 0.07 76 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.59 0.59 < 0.005 < 0.005 < 0.005 0.59 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling < 0.005 < 0.005 0.03 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 12 12 < 0.005 < 0.005 0.01 13

3.3. Site Preparation (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 14 / 46
Off-Roa 1.4 1.2 11 11 0.03 0.47 — 0.47 0.43 — 0.43 — 2,717 2,717 0.11 0.02 — 2,726 d
Equipm
ent
Dust
From
Material
Movement
— — — — — — 1.6 1.6 — 0.17 0.17 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent
< 0.005 < 0.005 0.03 0.03 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 7.4 7.4 < 0.005 < 0.005 — 7.5 Dust
From
Material
Movement
— — — — — — < 0.005 < 0.005 — < 0.005 < 0.005 — — — — — — — Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent
< 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 1.2 1.2 < 0.005 < 0.005 — 1.2 Dust
From
Material
Movement
— — — — — — < 0.005 < 0.005 — < 0.005 < 0.005 — — — — — — — Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 15 / 46
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.03 0.03 0.02 0.45 0.00 0.00 0.08 0.08 0.00 0.02 0.02 — 85 85 < 0.005 < 0.005 0.33 86 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.21 0.21 < 0.005 < 0.005 < 0.005 0.22 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.04 0.04 < 0.005 < 0.005 < 0.005 0.04 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.5. Grading (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

1.8 1.5 14 15 0.02 0.64 — 0.64 0.59 — 0.59 — 2,455 2,455 0.10 0.02 — 2,463 Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 16 / 46
Dust — — — — — — 7.1 7.1 — 3.4 3.4 — — — — — — —
From
Material
Movement
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.01 0.01 0.08 0.08 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 13 13 < 0.005 < 0.005 — 13 Dust
From
Material
Movement
— — — — — — 0.04 0.04 — 0.02 0.02 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent
< 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 2.2 2.2 < 0.005 < 0.005 — 2.2 Dust
From
Material
Movement
— — — — — — 0.01 0.01 — < 0.005 < 0.005 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.05 0.04 0.03 0.60 0.00 0.00 0.10 0.10 0.00 0.02 0.02 — 114 114 < 0.005 < 0.005 0.44 115 Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 17 / 46
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.57 0.57 < 0.005 < 0.005 < 0.005 0.57 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.09 0.09 < 0.005 < 0.005 < 0.005 0.10 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.7. Building Construction (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

1.5 1.2 11 12 0.02 0.40 — 0.40 0.37 — 0.37 — 2,201 2,201 0.09 0.02 — 2,209 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 18 / 46
Off-Roa 1.5 1.2 11 12 0.02 0.40 — 0.40 0.37 — 0.37 — 2,201 2,201 0.09 0.02 — 2,209 d
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.41 0.34 2.9 3.2 0.01 0.11 — 0.11 0.10 — 0.10 — 603 603 0.02 < 0.005 — 605 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.07 0.06 0.53 0.59 < 0.005 0.02 — 0.02 0.02 — 0.02 — 100 100 < 0.005 < 0.005 — 100 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.01 0.01 < 0.005 < 0.005 < 0.005 0.01 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 0.01 0.01 < 0.005 < 0.005 < 0.005 0.01 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.01 0.01 < 0.005 < 0.005 < 0.005 0.01 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 0.01 0.01 < 0.005 < 0.005 < 0.005 0.01 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 19 / 46
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.9. Paving (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.83 0.70 6.1 8.2 0.01 0.27 — 0.27 0.25 — 0.25 — 1,244 1,244 0.05 0.01 — 1,248 Paving 0.99 0.99 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.01 0.01 0.08 0.11 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 17 17 < 0.005 < 0.005 — 17 Paving 0.01 0.01 — — — — — — — — — — — — — — — —
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 20 / 46
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent
< 0.005 < 0.005 0.02 0.02 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 2.8 2.8 < 0.005 < 0.005 — 2.8 Paving < 0.005 < 0.005 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.06 0.06 0.06 0.67 0.00 0.00 0.15 0.15 0.00 0.04 0.04 — 151 151 < 0.005 0.01 0.02 153 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 2.1 2.1 < 0.005 < 0.005 < 0.005 2.2 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.35 0.35 < 0.005 < 0.005 < 0.005 0.36 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.11. Architectural Coating (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 21 / 46
Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.15 0.13 0.88 1.1 < 0.005 0.03 — 0.03 0.03 — 0.03 — 134 134 0.01 < 0.005 — 134 Architect
ural
Coating
s
< 0.005 < 0.005 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent
< 0.005 < 0.005 0.01 0.02 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 1.8 1.8 < 0.005 < 0.005 — 1.8 Architect
ural
Coating
s
< 0.005 < 0.005 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent
< 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 0.30 0.30 < 0.005 < 0.005 — 0.30 Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 22 / 46
Architect < 0.005 < 0.005 — — — — — — — — — — — — — — — — ural
Coating
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

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) Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 23 / 46
Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Conveni
ence
Market
with Gas
Pumps
18 17 15 154 0.34 0.25 28 29 0.23 7.2 7.5 — 34,604 34,604 1.4 1.4 120 35,174 Total 18 17 15 154 0.34 0.25 28 29 0.23 7.2 7.5 — 34,604 34,604 1.4 1.4 120 35,174 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Conveni
ence
Market
with Gas
Pumps
17 15 18 129 0.31 0.25 28 29 0.23 7.2 7.5 — 31,613 31,613 1.6 1.5 3.1 32,112 Total 17 15 18 129 0.31 0.25 28 29 0.23 7.2 7.5 — 31,613 31,613 1.6 1.5 3.1 32,112 Annual — — — — — — — — — — — — — — — — — —
Conveni
ence
Market
with Gas
Pumps

2.5 2.3 1.7 13 0.02 0.02 2.1 2.1 0.02 0.54 0.56 — 2,308 2,308 0.16 0.13 3.6 2,354 Total 2.5 2.3 1.7 13 0.02 0.02 2.1 2.1 0.02 0.54 0.56 — 2,308 2,308 0.16 0.13 3.6 2,354

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
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 24 / 46
Daily, — — — — — — — — — — — — — — — — — —
Summer
(Max)
Conveni
ence
Market
with Gas
Pumps
— — — — — — — — — — — — 0.13 0.13 < 0.005 < 0.005 — 0.13 Total — — — — — — — — — — — — 0.13 0.13 < 0.005 < 0.005 — 0.13 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Conveni
ence
Market
with Gas
Pumps
— — — — — — — — — — — — 0.13 0.13 < 0.005 < 0.005 — 0.13 Total — — — — — — — — — — — — 0.13 0.13 < 0.005 < 0.005 — 0.13 Annual — — — — — — — — — — — — — — — — — —
Conveni
ence
Market
with Gas
Pumps
— — — — — — — — — — — — 0.02 0.02 < 0.005 < 0.005 — 0.02 Total — — — — — — — — — — — — 0.02 0.02 < 0.005 < 0.005 — 0.02

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
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 25 / 46
Conveni < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 0.02 0.02 < 0.005 < 0.005 — 0.02 ence
Market
with Gas
Pumps
Total < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 0.02 0.02 < 0.005 < 0.005 — 0.02 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Conveni
ence
Market
with Gas
Pumps
< 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 0.02 0.02 < 0.005 < 0.005 — 0.02 Total < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 0.02 0.02 < 0.005 < 0.005 — 0.02 Annual — — — — — — — — — — — — — — — — — —
Conveni
ence
Market
with Gas
Pumps
< 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 Total < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005

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 TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Consum
er
Product
s
< 0.005 < 0.005 — — — — — — — — — — — — — — — —
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 26 / 46
Architect
Coatings
< 0.005 < 0.005 — — — — — — — — — — — — — — — —
Landsca
pe
Equipm
ent
< 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 Total < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Consum
er
Product
s
< 0.005 < 0.005 — — — — — — — — — — — — — — — —
Architect
ural
Coating
s
< 0.005 < 0.005 — — — — — — — — — — — — — — — —
Total < 0.005 < 0.005 — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Consum
er
Product
s
< 0.005 < 0.005 — — — — — — — — — — — — — — — —
Architect
ural
Coating
s
< 0.005 < 0.005 — — — — — — — — — — — — — — — —
Landsca
pe
Equipm
ent
< 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 Total < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005

4.4. Water Emissions by Land Use
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 27 / 46

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
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Conveni
ence
Market
with Gas
Pumps
— — — — — — — — — — — 0.95 1.9 2.8 < 0.005 < 0.005 — 3.5 Total — — — — — — — — — — — 0.95 1.9 2.8 < 0.005 < 0.005 — 3.5 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Conveni
ence
Market
with Gas
Pumps
— — — — — — — — — — — 0.95 1.9 2.8 < 0.005 < 0.005 — 3.5 Total — — — — — — — — — — — 0.95 1.9 2.8 < 0.005 < 0.005 — 3.5 Annual — — — — — — — — — — — — — — — — — —
Conveni
ence
Market
with Gas
Pumps
— — — — — — — — — — — 0.16 0.31 0.47 < 0.005 < 0.005 — 0.58 Total — — — — — — — — — — — 0.16 0.31 0.47 < 0.005 < 0.005 — 0.58

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) Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 28 / 46
Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Conveni
ence
Market
with Gas
Pumps
— — — — — — — — — — — 9.7 0.00 9.7 0.97 0.00 — 34
Total — — — — — — — — — — — 9.7 0.00 9.7 0.97 0.00 — 34 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Conveni
ence
Market
with Gas
Pumps
— — — — — — — — — — — 9.7 0.00 9.7 0.97 0.00 — 34
Total — — — — — — — — — — — 9.7 0.00 9.7 0.97 0.00 — 34 Annual — — — — — — — — — — — — — — — — — —
Conveni
ence
Market
with Gas
Pumps
— — — — — — — — — — — 1.6 0.00 1.6 0.16 0.00 — 5.6
Total — — — — — — — — — — — 1.6 0.00 1.6 0.16 0.00 — 5.6

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
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 29 / 46
Daily, — — — — — — — — — — — — — — — — — —
Summer
(Max)
Conveni
ence
Market
with Gas
Pumps
— — — — — — — — — — — — — — — — 0.55 0.55
Total — — — — — — — — — — — — — — — — 0.55 0.55
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Conveni
ence
Market
with Gas
Pumps
— — — — — — — — — — — — — — — — 0.55 0.55
Total — — — — — — — — — — — — — — — — 0.55 0.55
Annual — — — — — — — — — — — — — — — — — —
Conveni
ence
Market
with Gas
Pumps
— — — — — — — — — — — — — — — — 0.09 0.09
Total — — — — — — — — — — — — — — — — 0.09 0.09

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) Equipm
ent
Type
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 30 / 46
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

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) Equipm
ent
Type
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

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) Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 31 / 46
Equipm TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e ent
Type
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
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) Vegetati
on
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 32 / 46
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R 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) Species TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Sequest
ered
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Remove
d
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
— — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 33 / 46
Avoided — — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Sequest
ered
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Remove
d
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
— — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Sequest
ered
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Remove
d
— — — — — — — — — — — — — — — — — —
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 Demolition Demolition 7/1/2025 7/14/2025 5.0 10.0 —
Site Preparation Site Preparation 7/16/2025 7/16/2025 5.0 1.00 — Grading Grading 7/18/2025 7/21/2025 5.0 2.0 —
Building Construction Building Construction 7/21/2025 12/5/2025 5.0 100 — Paving Paving 12/9/2025 12/15/2025 5.0 5.0 —
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 34 / 46
Architectural Coating Architectural Coating 12/17/2025 12/23/2025 5.0 5.0 —

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 Demolition Tractors/Loaders/Back
hoes
Diesel Average 3.0 8.0 84 0.37
Demolition Rubber Tired Dozers Diesel Average 1.00 8.0 367 0.40 Demolition Concrete/Industrial
Saws
Diesel Average 1.00 8.0 33 0.73
Site Preparation Graders Diesel Average 1.00 8.0 148 0.41 Site Preparation Scrapers Diesel Average 1.00 8.0 423 0.48 Site Preparation Tractors/Loaders/Back
hoes
Diesel Average 1.00 7.0 84 0.37
Grading Graders Diesel Average 1.00 8.0 148 0.41
Grading Rubber Tired Dozers Diesel Average 1.00 8.0 367 0.40 Grading Tractors/Loaders/Back
hoes
Diesel Average 2.0 7.0 84 0.37
Building Construction Cranes Diesel Average 1.00 8.0 367 0.29 Building Construction Forklifts Diesel Average 2.0 7.0 82 0.20 Building Construction Generator Sets Diesel Average 1.00 8.0 14 0.74 Building Construction Tractors/Loaders/Back
hoes
Diesel Average 1.00 6.0 84 0.37
Building Construction Welders Diesel Average 3.0 8.0 46 0.45 Paving Tractors/Loaders/Back
hoes
Diesel Average 1.00 8.0 84 0.37
Paving Pavers Diesel Average 1.00 8.0 81 0.42
Paving Paving Equipment Diesel Average 1.00 8.0 89 0.36 Paving Rollers Diesel Average 2.0 8.0 36 0.38
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 35 / 46
Paving Cement and Mortar
Mixers
Diesel Average 1.00 8.0 10.0 0.56
Architectural Coating Air Compressors Diesel Average 1.00 6.0 37 0.48

5.3. Construction Vehicles

5.3.1. Unmitigated
Phase Name Trip Type One-Way Trips per Day Miles per Trip Vehicle Mix Demolition Worker 13 14 LDA,LDT1,LDT2
Demolition Vendor — 8.8 HHDT,MHDT
Demolition Hauling 36 20 HHDT
Demolition Onsite truck — — HHDT
Site Preparation Worker 7.5 14 LDA,LDT1,LDT2
Site Preparation Vendor — 8.8 HHDT,MHDT
Site Preparation Hauling 0.00 20 HHDT
Site Preparation Onsite truck — — HHDT
Grading Worker 10.0 14 LDA,LDT1,LDT2
Grading Vendor — 8.8 HHDT,MHDT
Grading Hauling 0.00 20 HHDT
Grading Onsite truck — — HHDT
Building Construction Worker < 0.005 14 LDA,LDT1,LDT2
Building Construction Vendor < 0.005 8.8 HHDT,MHDT
Building Construction Hauling 0.00 20 HHDT
Building Construction Onsite truck — — HHDT
Paving Worker 15 14 LDA,LDT1,LDT2
Paving Vendor — 8.8 HHDT,MHDT
Paving Hauling 0.00 20 HHDT
Paving Onsite truck — — HHDT
Architectural Coating Worker < 0.005 14 LDA,LDT1,LDT2
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 36 / 46
Architectural Coating Vendor — 8.8 HHDT,MHDT
Architectural Coating Hauling 0.00 20 HHDT
Architectural Coating Onsite truck — — HHDT

5.4. Vehicles

5.4.1. Construction Vehicle Control Strategies
Control Strategies Applied PM10 Reduction PM2.5 Reduction Water unpaved roads twice daily 55% 55%

5.5. Architectural Coatings
Phase Name Residential Interior Area
Coated (sq ft)
Residential Exterior Area
Coated (sq ft)
Non-Residential Interior Area
Coated (sq ft)
Non-Residential Exterior Area
Coated (sq ft)
Parking Area Coated (sq ft)
Architectural Coating 0.00 0.00 4.0 1.3 —

5.6. Dust Mitigation

5.6.1. Construction Earthmoving Activities
Phase Name Material Imported (cy) Material Exported (cy) Acres Graded (acres) Material Demolished (Building Square Footage)
Acres Paved (acres)
Demolition 0.00 0.00 0.00 31,000 0.00
Site Preparation — — 1.5 0.00 0.00
Grading — — 2.0 0.00 0.00
Paving 0.00 0.00 0.00 0.00 1.9

5.6.2. Construction Earthmoving Control Strategies
Non-applicable. No control strategies activated by user.

5.7. Construction Paving
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 37 / 46
Phase Name Land Use Area Paved (acres) % Asphalt
Paving Convenience Market with Gas Pumps 1.9 100%

5.8. Construction Electricity Consumption and Emissions Factors kWh per Year and Emission Factor (lb/MWh)
Year kWh per Year CO2 CH4 N2O
2025 0.00 375 0.01 < 0.005

5.9. Operational Mobile Sources

5.9.1. Unmitigated
Land Use Type Trips/Weekday Trips/Saturday Trips/Sunday Trips/Year VMT/Weekday VMT/Saturday VMT/Sunday VMT/Year Convenience
Market with Gas
Pumps
3,734 3,734 3,734 1,362,897 7,537 40,085 40,085 6,145,175

5.10. Operational Area Sources

5.10.1. Hearths
Land Use Hearth Type Unmitigated (number) Mitigated (number) Convenience Market with Gas Pumps Wood Fireplaces 0 0
Convenience Market with Gas Pumps Gas Fireplaces 0 0
Convenience Market with Gas Pumps Propane Fireplaces 0 0 Convenience Market with Gas Pumps Electric Fireplaces 0 0 Convenience Market with Gas Pumps No Fireplaces 0 0
Convenience Market with Gas Pumps Conventional Wood Stoves 0 0 Convenience Market with Gas Pumps Catalytic Wood Stoves 0 0 Convenience Market with Gas Pumps Non-Catalytic Wood Stoves 0 0 Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 38 / 46
Convenience Market with Gas Pumps Pellet Wood Stoves 0 0

5.10.2. Architectural Coatings
— Residential Interior Area
Coated (sq ft)
Residential Exterior Area
Coated (sq ft)
Non-Residential Interior Area
Coated (sq ft)
Non-Residential Exterior Area
Coated (sq ft)
Parking Area Coated (sq ft)
undefined 0.00 0.00 4.0 1.3 —

5.10.3. Landscape Equipment
Season Unit Value
Snow Days day/yr 0.00
Summer Days day/yr 250

5.11. Operational Energy Consumption

5.11.1. Unmitigated
Electricity (kWh/yr) and CO2 and CH4 and N2O and Natural Gas (kBTU/yr) Land Use Electricity (kWh/yr) CO2 CH4 N2O Natural Gas (kBTU/yr) Convenience Market with Gas
Pumps
126 375 0.0129 0.0017 53

5.12. Operational Water and Wastewater Consumption

5.12.1. Unmitigated
Land Use Indoor Water (gal/year) Outdoor Water (gal/year) Convenience Market with Gas Pumps 443,102 382,175

5.13. Operational Waste Generation
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 39 / 46

5.13.1. Unmitigated
Land Use Waste (ton/year) Cogeneration (kWh/year)
Convenience Market with Gas Pumps 18 0.00

5.14. Operational Refrigeration and Air Conditioning Equipment

5.14.1. Unmitigated
Land Use Equipment Type Refrigerant GWP Quantity (kg) Operations Leak Rate Service Leak Rate Times Serviced Convenience Market
with Gas Pumps
Other commercial A/C
and heat pumps
R-410A 2,088 < 0.005 4.0 4.0 18
Convenience Market
with Gas Pumps
Supermarket
refrigeration and
condensing units
R-404A 3,922 27 17 17 18

5.15. Operational Off-Road Equipment

5.15.1. Unmitigated

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
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 40 / 46
Vegetation Land Use Type Vegetation Soil Type Initial Acres Final Acres

5.18.1. Biomass Cover Type

5.18.1.1. Unmitigated
Biomass Cover Type Initial Acres Final Acres

5.18.2. Sequestration

5.18.2.1. Unmitigated
Tree Type Number Electricity Saved (kWh/year) Natural Gas Saved (btu/year)

6. Climate Risk Detailed Report

6.1. Climate Risk Summary
Cal-Adapt midcentury 2040–2059 average projections for four hazards are reported below for your project location. These are under Representation Concentration Pathway (RCP) 8.5 which assumes GHG emissions will continue to rise strongly through 2050 and then plateau around 2100.

Climate Hazard Result for Project Location Unit
Temperature and Extreme Heat 20 annual days of extreme heat Extreme Precipitation 4.8 annual days with precipitation above 20 mm Sea Level Rise — meters of inundation depth
Wildfire 0.00 annual hectares burned
Temperature and Extreme Heat data are for grid cell in which your project are located. The projection is based on the 98th historical percentile of daily maximum/minimum temperatures from observed historical data (32 climate model ensemble from Cal-Adapt, 2040–2059 average under RCP 8.5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.

Extreme Precipitation data are for the grid cell in which your project are located. The threshold of 20 mm is equivalent to about ¾ an inch of rain, which would be light to moderate rainfall if received over a full day or heavy rain if received over a period of 2 to 4 hours. Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.

Sea Level Rise data are for the grid cell in which your project are located. The projections are from Radke et al. (2017), as reported in Cal-Adapt (Radke et al., 2017, CEC-500-2017-008), and consider inundation location and depth for the San Francisco Bay, the Sacramento-San Joaquin River Delta and California coast resulting different increments of sea level rise coupled with extreme storm events. Users may select from four scenarios to view the range in potential inundation depth for the grid cell. The four scenarios are: No rise, 0.5 meter, 1.0 meter, 1.41 meters Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 41 / 46
Wildfire data are for the grid cell in which your project are located. The projections are from UC Davis, as reported in Cal-Adapt (2040–2059 average under RCP 8.5), and consider historical data of climate, vegetation, population density, and large (> 400 ha) fire history. Users may select from four model simulations to view the range in potential wildfire probabilities for the grid cell. The four simulations make different assumptions about expected rainfall and temperature are: Warmer/drier (HadGEM2-ES), Cooler/wetter (CNRM-CM5), Average conditions (CanESM2), Range of different rainfall and temperature possibilities (MIROC5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.

6.2. Initial Climate Risk Scores
Climate Hazard Exposure Score Sensitivity Score Adaptive Capacity Score Vulnerability Score Temperature and Extreme Heat 1 0 0 N/A
Extreme Precipitation 1 0 0 N/A
Sea Level Rise N/A N/A N/A N/A
Wildfire 1 0 0 N/A
Flooding 0 0 0 N/A
Drought 0 0 0 N/A
Snowpack Reduction N/A N/A N/A N/A
Air Quality Degradation 0 0 0 N/A
The sensitivity score reflects the extent to which a project would be adversely affected by exposure to a climate hazard. Exposure is rated on a scale of 1 to 5, with a score of 5 representing the greatest exposure.

The adaptive capacity of a project refers to its ability to manage and reduce vulnerabilities from projected climate hazards. Adaptive capacity is rated on a scale of 1 to 5, with a score of 5 representing the greatest ability to adapt.

The overall vulnerability scores are calculated based on the potential impacts and adaptive capacity assessments for each hazard. Scores do not include implementation of climate risk reduction measures.

6.3. Adjusted Climate Risk Scores
Climate Hazard Exposure Score Sensitivity Score Adaptive Capacity Score Vulnerability Score Temperature and Extreme Heat 1 1 1 2
Extreme Precipitation 1 1 1 2
Sea Level Rise N/A N/A N/A N/A
Wildfire 1 1 1 2
Flooding 1 1 1 2
Drought 1 1 1 2
Snowpack Reduction N/A N/A N/A N/A
Air Quality Degradation 1 1 1 2
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 42 / 46
The sensitivity score reflects the extent to which a project would be adversely affected by exposure to a climate hazard. Exposure is rated on a scale of 1 to 5, with a score of 5 representing the greatest exposure.

The adaptive capacity of a project refers to its ability to manage and reduce vulnerabilities from projected climate hazards. Adaptive capacity is rated on a scale of 1 to 5, with a score of 5 representing the greatest ability to adapt.

The overall vulnerability scores are calculated based on the potential impacts and adaptive capacity assessments for each hazard. Scores include implementation of climate risk reduction measures.

6.4. Climate Risk Reduction Measures

7. Health and Equity Details

7.1. CalEnviroScreen 4.0 Scores
The maximum CalEnviroScreen score is 100. A high score (i.e., greater than 50) reflects a higher pollution burden compared to other census tracts in the state.

Indicator Result for Project Census Tract
Exposure Indicators —
AQ-Ozone 47
AQ-PM 35
AQ-DPM 47
Drinking Water 42
Lead Risk Housing 43
Pesticides 55
Toxic Releases 20
Traffic 65
Effect Indicators —
CleanUp Sites 4.1
Groundwater 22
Haz Waste Facilities/Generators 85
Impaired Water Bodies 12
Solid Waste 36
Sensitive Population —
Asthma 46
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 43 / 46
Cardio-vascular 79
Low Birth Weights 60
Socioeconomic Factor Indicators —
Education 37
Housing 40
Linguistic 8.5
Poverty 55
Unemployment 12

7.2. Healthy Places Index Scores
The maximum Health Places Index score is 100. A high score (i.e., greater than 50) reflects healthier community conditions compared to other census tracts in the state.

Indicator Result for Project Census Tract
Economic —
Above Poverty 65.31502631
Employed 83.80597973
Median HI 56.69190299
Education —
Bachelor's or higher 34.96727833
High school enrollment 100
Preschool enrollment 13.49929424
Transportation —
Auto Access 46.0284871
Active commuting 66.46990889
Social —
2-parent households 68.29205697
Voting 78.13422302
Neighborhood —
Alcohol availability 64.32696009
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 44 / 46
Park access 59.96407032
Retail density 38.5730784
Supermarket access 18.65776979
Tree canopy 84.11394842
Housing —
Homeownership 59.50211728
Housing habitability 72.71910689
Low-inc homeowner severe housing cost burden 38.86821506 Low-inc renter severe housing cost burden 84.02412421
Uncrowded housing 42.30719877
Health Outcomes —
Insured adults 60.5800077
Arthritis 28.3
Asthma ER Admissions 47.5
High Blood Pressure 40.5
Cancer (excluding skin) 27.6
Asthma 32.2
Coronary Heart Disease 47.4
Chronic Obstructive Pulmonary Disease 35.3
Diagnosed Diabetes 68.9
Life Expectancy at Birth 23.5
Cognitively Disabled 30.7
Physically Disabled 22.7
Heart Attack ER Admissions 28.3
Mental Health Not Good 47.3
Chronic Kidney Disease 64.9
Obesity 44.9
Pedestrian Injuries 19.6
Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 45 / 46
Physical Health Not Good 54.5
Stroke 58.2
Health Risk Behaviors —
Binge Drinking 15.4
Current Smoker 32.2
No Leisure Time for Physical Activity 68.6
Climate Change Exposures —
Wildfire Risk 0.0
SLR Inundation Area 0.0
Children 37.8
Elderly 42.6
English Speaking 71.1
Foreign-born 17.6
Outdoor Workers 45.5
Climate Change Adaptive Capacity —
Impervious Surface Cover 60.3
Traffic Density 49.1
Traffic Access 23.0
Other Indices —
Hardship 48.5
Other Decision Support —
2016 Voting 66.5

7.3. Overall Health & Equity Scores
Metric Result for Project Census Tract
CalEnviroScreen 4.0 Score for Project Location (a) 45
Healthy Places Index Score for Project Location (b) 63
Project Located in a Designated Disadvantaged Community (Senate Bill 535) No Maverick Fueling Elk Grove v2 Detailed Report, 11/6/2025 46 / 46
Project Located in a Low-Income Community (Assembly Bill 1550) No Project Located in a Community Air Protection Program Community (Assembly Bill 617) No a: The maximum CalEnviroScreen score is 100. A high score (i.e., greater than 50) reflects a higher pollution burden compared to other census tracts in the state. b: The maximum Health Places Index score is 100. A high score (i.e., greater than 50) reflects healthier community conditions compared to other census tracts in the state.

7.4. Health & Equity Measures
No Health & Equity Measures selected.

7.5. Evaluation Scorecard
Health & Equity Evaluation Scorecard not completed.

7.6. Health & Equity Custom Measures
No Health & Equity Custom Measures created.

8. User Changes to Default Data

8.1. Justifications
Screen Justification
Land Use Based on project description
Construction: Construction Phases Per model output from Ascent Construction: Paving Based on site plans

 














 














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SUPPLEMENTAL INFORMATION
AGENDA ITEM NO. 8.1
11-12-2025
500 CAPITOL MALL, SUITE 1000, SACRAMENTO, CA 95814
OFFICE: 916-446-7979 FAX: 916-446-8199
SOMACHLAW.COM
November 10, 2025
Via Electronic Mail Only
City Council
City of Elk Grove
Community Development Department
c/o Jason Lindgren, City Clerk
8401 Laguna Palms Way
Elk Grove, CA 95758
[email protected]
[email protected]
Re: Response to Appeal of Planning Commission Approval of Maverik Fueling Station (PLNG 24-031)
Dear Mayor Singh-Allen, Vice Mayor Robles, and Councilmembers Suen, Brewer, and Spease:

On behalf of Maverik Inc. and FJ Management Inc., Maverik’s parent company (collectively here “Maverik”)—Proponent for the Maverik Fueling Station (PLNG 24-031) (Project) approved by the City of Elk Grove (City) Planning Commission on September 18, 2025—we submit the following response to Protect Elk Grove’s (Appellant) appeal of the Planning Commission’s action. This letter is intended to supplement the responses to the appeal and other analysis, information, and determinations provided in the Planning Department’s Staff Report to City Council (CC Staff Report), published on the City’s website on November 7, 2025. Substantial evidence relied on by the City includes, but is not limited to: the January 17, 2025, Air Quality Assessment for the Maverik Elk Grove Gas Station Memorandum prepared by Ascent Environmental, Inc.1 (Ascent); the April 2, 2025, Maverik Elk Grove Fueling Station (PLNG 24-031) – VMT [vehicle miles traveled] Analysis Memorandum prepared by Fehr & Peers;2 the March 15, 2025, Cultural Resources Memorandum – Maverik Elk Grove Gas Station Project Memorandum; the November 3, 2025, Application PLNG 24-031 Maverik Elk Grove, CEQA Biological Resources Memorandum prepared by Ascent (Ascent Bio Memo); the November 3, 2025, PLNG 24-031, Maverik Elk Grove, Review of Protect Elk Grove Comments Dated September 29, 2025 1 https://ascent.inc/.
2 https://www.fehrandpeers.com/.

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Memorandum prepared by Ascent (Ascent Response Memo); and expert peer review of some of this analysis.

Maverik appreciates City staff’s hard work in preparing a thorough Staff Report and concurs with the City’s analyses, determinations, findings, and responses to the appeal.

Maverik submits this letter for consideration by both City staff and City Council regarding the appeal. The letter addresses: (i) Appellant’s mischaracterization of the Project; (ii) the City’s adherence to the Brown Act3 before and during the September 18 Planning Commission hearing; (iii) the City’s proper application of the Class 32 exemption4 from environmental review under the California Environmental Quality Act (CEQA);5 and the Project’s consistency with the General Plan and its 2018 Environmental Impact Report (EIR) and thereby its further exemption from review. This letter also addresses certain comments made by members of the public before or during the Planning Commission hearing.

It is our understanding that the Appellant submitted additional material to the City on or around November 10, 2025. Maverik will review that material and may prepare a supplemental response letter.

Maverik appreciates any consideration that the City can give this and any supplemental letter. We understand that the timing is imperfect. If the City agrees with the information and analysis contained in this letter, we welcome the City’s acknowledgment of and concurrence with the letter at or before the November 12, 2025, City Council hearing.

I. APPELLANT MISCHARACTERIZES THE PROJECT
A. The Project Is Not a Truck Stop
On its website,
6 Facebook page,7 and in Maverik’s communication with its legal counsel, Appellant has repeatedly referred to the Project as a “truck stop.”8 Maverik is not aware of any governing definition of a truck stop that might apply here, but the common understanding is that truck stops provide overnight parking and other associated facilities (like showers). This common understanding is supported by a definition found in the California Civil Code that defines “truck stop” as “a privately owned and operated facility that provides 3 Gov. Code, § 54950 et seq.
4 Cal. Code Regs., tit. 14, § 15000 et seq. (CEQA Guidelines), § 15332. 5 Pub. Resources Code, § 21000 et seq.
6 https://protectelkgroveca.com/, attached hereto as Exhibit A. 7 https://www.facebook.com/protectelkgroveca/.
8 https://protectelkgroveca.com/community-concerns/. Indeed it appears Appellant’s counsel has made it a practice to oppose Maverik fueling stations in this region; see Exhibit B, attached hereto, for an opposition letter from Appellant’s counsel regarding a proposed Maverik fueling station in Galt. The proposed “Galt Maverik” was mentioned in the appeal as the “case at hand,” perhaps as a copy-and-paste snafu.

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food, fuel, shower or other sanitary facilities, and lawful overnight truck parking.”9 The
Project does not include any lawful overnight parking or showers or any other amenity that would encourage long-term stops and is conditioned by the City with a requirement to limit vehicle parking to 90 minutes.10 The Project, in fact, does not even include parking spaces for trucks. The Project is a fueling station that will accommodate trucks and is allowable within the existing land use designation and zoning for the Project site with a conditional use permit (CUP),11 which was approved by the Planning Commission. The Project also includes a convenience store and other standard amenities, like an air station for tires, similar to the two nearest fueling stations—ARCO on Grant Line Road across the street from the Project site and Chevron on Kammerer Road on the other side of State Route (SR) 99—which also include convenience stores and standard fueling station amenities. The ARCO across the street further includes a drive-through car wash.

B. Appellant Is Distributing an Inaccurate Project Site Plan and Description Appellant’s website12 depicts an inaccurate and misleading site plan for the Project.

The Staff Report prepared for the Planning Commission, made available to the public prior to the September 18 hearing, includes accurate site plans for the Project. The site plan on Appellant’s website shows a heavily distorted development with Maverik consuming approximately 14 acres instead of the accurate 2.93-acre Project site. Appellant’s site plan also shows truck parking in the east/northeast portion of the Project site. However, that area primarily will be comprised of a stormwater basin, as described and shown in the previous and current Staff Report.13 Appellant’s version of the site plan omits the fueling stations and inaccurately locates the convenience store toward the middle of the site instead of near Grant Line Road.
14 Appellant’s website then represents that “[f]amilies driving to practice” and “neighborhoods near Grant Line and East Stockton will all face heavier traffic” and the Project will “worsen air quality near neighborhoods,” however, there are no neighborhoods or parks near the Project site. The nearest residential neighborhood is located approximately 3,500 feet north of the Project site, as mentioned in the previous and current Staff Reports,15 separated by commercial and industrial land uses. The nearest neighborhood to the east is approximately 5,000 feet away, separated by train tracks and industrial uses. The nearest park (Elk Grove Regional Park) is more than 4,650 feet to the north/northwest, also separated by 9 Civ. Code, § 52.2(a)(6) [code provision pertaining to civil rights that may be instructive here]. 10 CC Staff Report, pp. 4, 36, 62 (Condition of Approval [COA] No. 10]; see also PC Hearing Video at 1:33:25- 34:40 [discussion of COA].
11 Elk Grove Municipal Code, § 23.27.020; CC Staff Report, pp. 1-2, 8. 12 https://protectelkgroveca.com/the-proposal/.
13 CC Staff Report, pp. 14, 43-48; Planning Commission (PC) Staff Report, pp. 6-8, 28-33. 14 See fn. 11.
15 CC Staff Report, pp. 32; PC Staff Report, p. 13.

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industrial and commercial uses. The nearest school (Pleasant Grove High School) is approximately 8,300 feet to the north/northeast, separated by industrial, commercial, and residential land uses. In any event, the City has determined, based on substantial evidence, that the Project will not result in significant impacts to transportation or air quality.16 II. CITY ADHERED TO THE BROWN ACT
A. All Documents Required to be Disclosed Were Made Available with the Agenda Packet
Appellant argues the City failed to disclose certain documents cited in its appeal to the public, alleging a violation of the Brown Act. The Brown Act requires public agencies to disclose writings that are distributed to all, or a majority of the members of the legislative body in connection with a matter subject to discussion or consideration at an open meeting.17 If a writing has been provided to all or a majority of the members of a legislative body less than 72 hours prior to the meeting when the matter will be discussed, the writing is to be made available to the public at the same time it is distributed to the legislative body.18 As explained in the most recent Staff Report,19 prior to consideration of the Project at the September 18, 2025 hearing, Planning Commissioners were provided only the Staff Report that was listed on the posted agenda with a link to enable access via the internet for members of the public. At no time prior to that hearing were the additional documents mentioned in the appeal distributed to all or a majority of the Planning Commissioners. Accordingly, there was no required Brown Act disclosure and no Brown Act violation regarding these documents.

It should be noted, however, that in response to concerns raised in public comments received prior to the Planning Commission hearing, City Staff did provide copies of these additional documents to the Planning Commission at the meeting. At the same time, these documents were made available to the public as noted by Staff during the meeting.20 Copies were placed on tables in the back of the meeting room and Staff also offered to provide electronic copies if needed. City staff also noted that noted that these documents would have been made available at any time to any member of the public who requested them.21 B. The Public Was Allowed to Comment During the Agenda Item Comment Period Appellant claims that the City “prohibited residents from speaking during the agenda item comment period,” but this is patently false. A review of the video from the September 18 Planning Commission hearing clearly demonstrates that both the Clerk and 16 CC Staff Report, pp. 11-13.
17 Gov. Code, § 54957.5(a); Sierra Watch v. Placer County (2021) 69 Cal.App.5th 1, 9. 18 Gov. Code, § 54957.5(b).
19 CC Staff Report, pp. 5-7.
20 PC Hearing Video at 43:00-44:50.
21 Ibid.

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Planning Commission Chair noted several times the Commission’s rules related to public comment.22 The Clerk read such rules aloud just after the meeting was called to order. The rules are also clearly displayed on the agenda. The Chair again reminded attendees of the need to fill out a speaker card as well as the three-minute time limit after the Maverick Fuel Station agenda item was called and again prior to beginning the public comment period.

Moreover, before the public comment period was closed, the Chair asked if there were any other members of the public who had requested to speak, recalled one speaker who had completed a speaker card but did not respond when first called to speak (speaker was still nonresponsive), and hearing no additional speakers, closed the public comment period.23 Later, after the public comment period had been closed and during the Commission’s consideration of the item, someone from the public asked, “Can I make an observation?”24 At that time, the Chair rightfully informed the person that the public comment period was closed.25
The Brown Act requires that public agencies provide an opportunity for the public to directly address the legislative body on any item of interest to the public before or during the legislative body’s consideration of the item.26 The Brown Act allows local agencies to adopt reasonable regulations that limit the total amount of time allocated for public testimony and for each individual speaker.27 Here, members of the public were informed both before and several times during the meeting of the Commission’s rules for the public comment period.

Ample time was provided for public comment and the Chair even inquired whether any late speaker cards had been submitted prior to closing the public comment period. Only one person attempted to speak after the public comment period was closed and was informed of such. There is no evidence that the Commission “prohibited” any member of the public from commenting.

Accordingly, the City complied with the Brown Act, and Appellant’s allegations are unfounded.

III. PROJECT QUALIFIES FOR THE CLASS 32 EXEMPTION
A. All Class 32 Criteria Are Met
The Class 32 categorical exemption to CEQA review includes five criteria that must be met for a project to qualify for the exemption:
22 Id., e.g., 4:12-5:14, 22:15-23:23, 40:00-15, 1:19:24-44. 23 Id., 1:16:40-1:17:20.
24 Id., 1:30:32-40.
25 Ibid.
26 Gov. Code, § 54954.3(a).
27 Id., § 54954.3(b).

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(a) The project is consistent with the applicable general plan designation and all applicable general plan policies as well as with applicable zoning designation and regulations.
(b) The proposed development occurs within city limits on a project site of no more than five acres substantially surrounded by urban uses. (c) The project site has no value, as habitat for endangered, rare or threatened species.
(d) Approval of the project would not result in any significant effects relating to traffic, noise, air quality, or water quality.
(e) The site can be adequately served by all required utilities and public services.28
As explained in the Staff Report,29 the Project meets all five criteria. Below we examine how and why the Project is consistent with the first four criteria as Appellant has not claimed that the Project cannot be adequately served by all required utilities and public services, and the City is clear that it can and will be.
30 1. The Project Is Consistent with the City General Plan Designation, Applicable General Policies, and Zoning
The Project is consistent with the General Plan land use designation and zoning. As explained in the Staff Report, the Project site is designated as a Special Planning Area (SPA) and zoned for Regional Commercial (RC) development.31 The Project site and entire SPA was redesignated from industrial in 2008 to allow commercial development, including fueling stations, which are allowed in this designation and zone with a CUP, as approved by the Planning Commission. The Staff Report also explains that the Project is consistent with applicable General Plan policies.32 Regarding the specific policies mentioned in the appeal, per the Staff Report and supporting evidence prepared by expert consultants, the Project complies with General Plan Policies NR 1-2, 1-4, and 1-9 advocating impact avoidance to wetlands, habitat, and riparian areas because it will have no impact on these resources. As explained by Ascent in its responses to the Appeal, and in other prior assessment of the Project site and area, there are no wetlands, habitat, or riparian areas onsite, and no offsite resources will be affected by the Project.33 The Staff Report explains that the Project complies with Policy LU-2-4 requiring infill development to be “compatible with the 28 CEQA Guidelines, § 15332.
29 CC Staff Report, pp. 7-15.
30 Id., p. 15.
31 CC Staff Report, p. 3.
32 Id., pp. 7-8, 19-24.
33 CC Staff Report, pp. 11, 21, 33, 35, 375 [Ascent Response Memo], 382-383 [Ascent Bio Memo]; see also fn. 62.

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character of the surrounding areas” because it is compatible with the surrounding area, which includes gas stations, and to “support increased transit use [and] promote pedestrian and bicycle mobility” because the Project includes construction of bicycle and pedestrian lanes consistent with the City’s Bicycle, Pedestrian, and Trails Master Plan. 34 Lastly, the Staff
Report explains that the City complied with General Plan Policy ED-1-5 because approving the Project supports the policy directive to “support existing and prospective businesses” (emphasis added).35
“It is well settled that [an agency] is entitled to considerable deference in the interpretation of its own General Plan.”36 Here, the City reasonably interpreted its General Plan policies, in part in reliance on substantial evidence prepared by expert consultants, to determine that the Project is consistent with applicable policies.37 No more is required.

2. The Project Occurs Within City Limits on a Site No More than Five Acres and Is Substantially Surrounded by Urban Uses
To qualify for the Class 32 exemption, a project must occur “within city limits on a project site of no more than five acres substantially surrounded by urban uses.”38 The Project is located within City limits, and the Project site consists of only 2.93 acres. 39 These facts are
uncontested. Further, the Project site is substantially surrounded by urban uses, as explained by the City in both of its Staff Reports and directly to the Planning Commission.40 The Project site and the areas immediately to the north and west are designated as an SPA and zoned for RC development. Prior to that designation and zoning, the Project site and these 34 CC Staff Report, pp. 21-22.
35 Id., p. 22.
36 Gray v. County of Madera (2008) 167 Cal.App.4th 1099, 1129-1130; see also Friends of Davis v. City of Davis (2000) 83 Cal.App.4th 1004, 1015 [“an agency’s view of the meaning and scope of its own ordinance is entitled to great weight”]; San Diego Citizenry Group v. County of San Diego (2013) 219 Cal.App.4th 1, 26 [“[a] reviewing court accords ‘great deference’ to an agency’s determination that a project is consistent with its own general plan, recognizing that ‘the body which adopted the general plan policies in its legislative capacity has unique competence to interpret those policies when applying them in its adjudicatory capacity’ ”]; Pfeiffer v.

City of Sunnyvale City Council (2011) 200 Cal.App.4th 1552, 1563. 37 Unless “ ‘no reasonable person could have reached the same conclusion on the evidence before it,’ ” a court must “defer to an agency’s factual findings of consistency.” (California Native Plant Society v. City of Rancho Cordova (2009) 172 Cal.App.4th 603, 637, quoting Endangered Habitats League, Inc. v. County of Orange (2005) 131 Cal.App.4th 777, 782; see also No Oil, Inc. v. City of Los Angeles (1987) 196 Cal.App.3d 223, 243.) An agency’s “broad discretion to construe its [general plan] policies in light of the plan’s purposes” (Endangered Habitats League, Inc., at p. 782) “stems from the well-settled principles of court respect for the [constitutional] separation of powers” (San Francisco Tomorrow v. City and County of San Francisco (2014) 229 Cal.App.4th 498, 515; Cal. Const., art. III, § 3).
38 CEQA Guidelines, § 15332(b).
39 CC Staff Report, p. 8.
40 CC Staff Report, pp. 3, 9-10; PC Staff Report, pp. 1-3, 14; PC Hearing Video at 8:00-07.

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SPA areas were designated and zoned for industrial use.41 The area immediately east of the Project site, across East Stockton Boulevard, is designated and zoned for Heavy Industrial and is developed with a variety of urban uses, including a printing shop and electrical and hardware supply stores.42 The area immediately south of the Project site, across Grant Line Road, is designated and zoned for Light and Heavy Industrial and as Industrial Office Park and is likewise developed with a variety of urban uses, including a healthcare facility, tool supply store, window tinting operation, and physical fitness centers.43 Immediately to the southeast of the Project site, across Grant Line Road, is an ARCO gas station with a car wash and a convenience store. Another gas station with a convenience store—a Chevron—is also situated on Grant Line Road on the other side of SR 99. Beyond these uses, the Project site is surrounded to the north/northeast/east, across East Stockton Boulevard, by industrial and commercial uses, notably several vehicle-oriented uses like Elite Truck Repair and Wash, Konko Truck Wash, Aujla Freight Carrier, Prime Truck Parking, and On The Spot RV and Trailer Repair, to name a few, as well as a propane facility, train tracks, and a paper company.

Appellant argues that the areas immediately to the north and west of the Project site are currently undeveloped and therefore the Project does not meet this Class 32 criterion.

That is incorrect. First and foremost, the City has considerable discretion when making factual determinations and courts will resolve all reasonable doubts in favor of the agency’s decisions.44 Whether or not the Project site is surrounded by urban uses is a factual determination based on the City’s understanding of its land uses. The City has been clear, multiple times (see, e.g., fn. 41), that the area surrounding the Project site consists of urban uses. It made this determination because of the General Plan land use designation that allows urban uses, like commercial development, and the developed nature of the area including commercial and industrial uses along Grant Line Road that “substantially surround” the Project site.

Notably, as explained in the Staff Report, appellant incorrectly labels these vacant areas surrounding the Project sites as “open space” and “agriculture,” but these areas are designated and zoned for neither use.45 In fact, some of the currently vacant space around the Project site was previously developed with commercial uses—including an ARCO gas station that was located just west of the Project site within the SPA, north of and adjacent to Grant Line Road and immediately east of the onramp to SR 99.46 That ARCO gas station was 41 CC Staff Report, p. 9; see also 2018 General Plan Update Environmental Impact Report (EIR) (SCH No. 2017062058), Figure 4.0-1, Existing General Plan Land, attached hereto as Exhibit C. 42 CC Staff Report, pp. 9-10.
43 Ibid.
44 See, e.g., Sierra Club v. County of Fresno (2018) 6 Cal.5th 502, 515; Working Families of Monterey County v.

King City Planning Com. (2024) 106 Cal.App.5th 833, 852 (Working Families), citing Protect Tustin Ranch v.

City of Tustin (2021) 70 Cal.App.5th 951, 960 (Protect Tustin Ranch); see also CC Staff Report, p. 10. 45 CC Staff Report, p. 9.
46 See current and historic aerial photographs of the Project site, attached hereto as Exhibit D, some of which show previous development on portions of the areas surrounding the Project site that are currently vacant. In City Council
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removed in 2007 (along with other surrounding development) at the City’s request in anticipation of the Grant Line Road/Kammerer Road Interchange project,47 which was approved and constructed to accommodate urban growth in the surrounding area and ultimately provide for the completion of the Capital Southeast Connector48 (Grant Line Road49)—a major regional thoroughfare.

Furthermore, the plain language of this Class 32 criterion does not support Appellant’s claims. The criterion includes the phrase “urban uses” but omits any requirement that urban uses need be developed. It also omits any qualifier to the phrase “substantially surrounded” that would constrain consideration to land adjacent to a Project site. Had the Secretary for the California Natural Resources Agency—which promulgates the CEQA Guidelines—intended to constrain the phrase “urban uses” with the word “developed,” especially given the earlier use of the term “development” in the criterion when describing the subject project and the use of the term “developed” elsewhere in the categorical exemptions,50 they could have.

Likewise for the phrase “substantially surrounding.” The term “adjacent” shows up in more than one categorical exemption when describing property and project locations51 yet was omitted from Class 32. The Legislature expressly directs that the CEQA statute and Guidelines are not to be interpreted to impose procedural or substantive requirements beyond those explicitly stated.52
The court in Working Families, supra, citing heavily to Protect Tustin Ranch, supra, and discussed in the Staff Report,53 agreed that not all land surrounding a project site need be developed for a project to qualify for a Class 32 exemption. Working Families described the subject project’s “surrounding vicinity” to include “commercial buildings, parking lots, a cemetery, vacant land, and the Monterey County Sheriff’s Office.”54 Opponents there argued that the proposed project did not meet this Class 32 criterion because it was not surrounded by “ ‘qualified urban uses.’ ”55 The court found “no merit in [opponents’] contentions” and particular, the photograph from 2004 shows the ARCO gas station that was previously situated just west of the Project site and the auto repair business that was located immediately south/southeast of the Portuguese Hall.

That same photograph also shows a previous Chevron station that was located farther west from the Project site, across Grant Line Road, and east of SR 99. See also CC Staff Report, p. 7. 47 CC Staff Report, pp. 9, 375 [Ascent Response Memo].
48 https://connectorjpa.com/.
49 https://connectorjpa.com/project-overview.
50 CEQA Guidelines, § 15319(a).
51 Id., §§ 15312(b)(3), 15328(c).
52 Pub. Resources Code, § 21083.1; see also Palmer v. GTE California, Inc. (2003) 30 Cal.4th 1265, 1279 [“additional unwritten requirements” shall not be inserted into statutes]; Conservatorship of K.P. (2021) 11 Cal.5th 695, 717 [“additional element not found in the statutory definition” shall not be required]; CC Staff Report, p. 9.
53 CC Staff Report, p. 10.
54 Id., at p. 840.
55 Id., at p. 852.

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upheld the lead agency’s decision to approve a Class 32 exemption, without expressing qualms about the neighboring vacant lot.56 The court also noted the proximity of Highway 101 to the project site,57 not dissimilar to the proximity of SR 99 to the Project site here.

Additionally, as explained in the Staff Report,58 cases cited by Appellant are inapposite and/or unhelpful to its appeal. Friends of Mammoth v. Town of Mammoth Lakes Redevelopment Agency (2000) 82 Cal.App.4th 511, involved the issue of whether a 74-acre golf course within a 1,100 acre redevelopment plan satisfied the requirement of being located in a “predominantly urbanized” area pursuant to Health and Safety Code section 33030(b)(1), not whether it qualified for a Class 32 exemption.59 The court in Banker’s Hill, Hillcrest, Park West Community Preservation Group v. City of San Diego (2006) 139 Cal.App.4th 249, relied on the Friends of Mammoth definition of urban uses despite its inapplicability to CEQA exemptions, ultimately finding that the Class 32 exemption applied because the large public park that bordered one side of the proposed developed was an urban use, in part, as it was “landscaped” and in “a densely populated area.”60 Here, the Project site and surrounding areas are landscaped or regularly maintained61 and are located within a well-populated municipality.

The cases cited by Appellant are between 19 and 25 years old and relied on an inapplicable definition, and, in any event, Banker’s Hill—the only case that actually dealt with a Class 32 exemption—upheld its use. The court in the more current Working Families instructs that any “reliance on these decisions is misplaced, since Friends of Mammoth “did not construe [the Class 32 exemption]” and did not rely on the lead agency’s determinations because the lead agency made none.62 Whereas here, the City has made specific determinations and findings supported by substantial evidence on this Class 32 criterion.63 56 Id., at pp. 852-853. The project site in the Working Families case is located at 1023 Broadway Street, King City, California. (Id., at p. 840.) An aerial photograph of that site as it currently exists, still undeveloped with surrounding vacant land, is attached hereto as Exhibit E. Compare with photograph in Exhibit D showing similar vacant areas surrounding the Project site.
57 Id., at pp. 853.
58 CC Staff Report, p. 10.
59 Id., at p. 538.
60 Id., at p. 271.
61 CC Staff Report, p. 382 [Ascent Bio Memo, noting that vacant land surrounding the Project site “shows signs of regular maintenance”].
62 Working Families, supra, 106 Cal.App.5th at p. 851, fn. 10; see also CC Staff Report, p. 10. 63 See, e.g., Pacific Palisades Residents Assn., Inc. v. City of Los Angeles (2023) 88 Cal.App.5th 1338, 1367 [“argument fails because substantial evidence supports the City’s [Class 21 exemption] finding”].

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Accordingly, the Project is consistent with this Class 32 criterion, and Appellant has not provided any evidence or legal authority to the contrary.64

3. The Project Site Has No Value as Habitat for Endangered, Rare, or Threatened Species
As explained in the Staff Report, and at the Planning Commission hearing,65 the City’s CEQA consultant, Ascent, performed a site survey and database searches to determine that the site has no value as habitat for any special-status species. 66 Per Ascent, the Project site “is
developed” and “paved,” “does not contain natural habitat suitable for special-status or common species,” “does not contain any riparian habitat or other sensitive natural community,” and “does not contain any state or federally protected wetlands.”67 Appellant claims riverine habitat exists adjacent to the Project site in conflict with this criterion but provides no supporting evidence.68 Appellant also appears to misunderstand this criterion’s requirements. This criterion does not ask whether adjacent property has any value as habitat, it asks whether the Project site itself has such value. Substantial evidence demonstrates that it does not. Accordingly, the Project is consistent with this Class 32 criterion.

4. Approval of the Project Would Not Result in Significant Effects Relating to Traffic, Noise, Air Quality, or Water Quality
As explained in the Staff Report,69 supported by substantial evidence provided by Ascent and Fehr & Peers, the Project would not result in significant effects to traffic, noise, air quality, or water quality. For traffic,70 Fehr & Peers analyzed transportation impacts by comparing the Project’s estimated VMT against the City’s VMT limit standards, and found that the Project did not exceed any known threshold of significance.71 Regarding noise, the nearest sensitive receptor to the Project site is approximately 1,400 feet west of the site, 64 Federation of Hillside & Canyon Assns. v. City of Los Angeles (2000) 83 Cal.App.4th 1252, 1265 [court rejecting challenge citing “no evidence or meaningful legal authority”]. 65 PC Hearing Video at 1:18:16-19:12.
66 CC Staff Report, p. 382 et seq. [Ascent Bio Memo].
67 Id., p. 383 [Ascent Bio Memo]; see also 2007 jurisdictional wetland delineation prepared for the SPA by Gibson & Skordal, attached hereto as Exhibit F, finding no “waters/wetlands” on the site. 68 Federation of Hillside & Canyon Assns., supra, 83 Cal.App.4th at p. 1265. 69 CC Staff Report, pp. 11-15, 376-377 [Ascent Response Memo]. 70 Any traffic analysis for a Class 32 exemption should focus on VMT, as occurs here, because level of service (including congestion) is no longer an issue that should be analyzed under CEQA. For more detail, please refer to the Governor’s Office of Land Use and Climate Innovation’s (formerly the Office of Planning and Research) webpage for frequently asked questions about Senate Bill (SB) 743 (2013) (https://lci.ca.gov/ceqa/sb743/faq.html), which changed how lead agencies analyze transportation impacts, an excerpt of which is attached hereto as Exhibit G. See also the discussion on the role of VMT in Class 32 infill exemptions in the unpublished Third Appellate District opinion Protect Neighborhoods v. City of Roseville (Sept. 29, 20205, Case no. C101428), attached hereto as Exhibit H.
71 CC Staff Report, p. 376 [Ascent Response Memo].

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adjacent to and across SR 99, and there would be no perceptible change in noise at this sensitive receptor, or elsewhere, as a result of Project operation, and Project construction would be temporary and adhere to City noise requirements for construction.72 Air quality analysis for the Project was prepared in accordance with Sacramento Metropolitan Air Quality Management District CEQA guidelines,73 and a water quality analysis showed that the Project does not have any direct connectivity to the Consumnes River, which is 1.5 miles southeast of the site, and includes design features that meet water quality requirements for stormwater runoff, including an onsite retention pond, that would significantly improve the site’s current drainage and any existing effects on water quality.74 Accordingly, the Project is consistent with this Class 32 criterion.

B. No Exceptions to the Exemption Apply
CEQA Guidelines include six exceptions to exemptions that preclude an exemption from applying if any one exception is met.75 Appellant appears to believe that two of these exceptions apply—the “Cumulative Impact” exception mandating that “[a]ll exemptions for these classes are inapplicable when the cumulative impact of successive projects of the same type in the same place, over time is significant” and the “Significant Effect” exception, also referred to as the “Unusual Circumstances” exception, directing “[a] categorical exemption shall not be used for an activity where there is a reasonable possibility that the activity will have a significant effect on the environment due to unusual circumstances.”76 After reviewing ample substantial evidence, City staff properly concluded that these exceptions do not apply.77 Our analysis is consistent with and supports the City’s conclusion.

1. The Project Does Not Contribute to a Significant Cumulative Impact of Successive Projects of the Same Type in the Same Place
As explained in the Staff Report, the Project would not contribute to any significant cumulative impacts.78 Specifically of concern to Appellant, the Project would not result in any cumulatively considerable impacts to air quality or VMT.79 Analyses performed for these resource areas by Ascent and Fehr & Peers accounted for cumulative conditions using regional cumulative assumptions included in the guidelines and standards under which the 72 Ibid.
73 Ibid.
74 Id., pp. 376-377.
75 CEQA Guidelines, § 15300.2.
76 Id., § 15300.2(b), (c).
77 CC Staff Report, pp. 16-19. Importantly, a lead agency need not make express findings that no exceptions to an exemption apply—the declaration that an exemption applies includes an implied finding that no exception barred the exemption. (See, e.g., Arcadians for Environmental Preservation v. City of Arcadia (2023) 88 Cal.App.5th 418, 438.)
78 CC Staff Report, pp 16-17; CEQA Guidelines, § 15300.2(b). 79 CC Staff Report, p. 376 [Ascent Response Memo].

City Council
RE: Response to Appeal of PC Approval of Maverik Fueling Station November 10, 2025

Page 13 ends

Project was assessed.80 As explained in the Staff Report,81 there are no known or reasonably foreseeable future tenants in the SPA area surrounding the Project site. Separate and apart from the Project, the property owners of both the Project site and SPA analyzed certain components of potential future development that would be allowable under existing land use designation and zoning, like ingress and egress, in an effort to effectively market the SPA property to potential future tenants and respond to City inquiries. No specific tenants or businesses have been secured, and no applications have been filed with the City. It has taken nearly 17 years since the SPA was established to secure just one new tenant—Maverik. It is unknown how long it may take to secure additional tenants willing to develop the area. So any additional cumulative assessment, although entirely unwarranted here, that might consider any such future development would be speculative and discouraged by CEQA. 82 Certainly, there will be no future fueling stations located adjacent to the Project site as they are disallowed under a development agreement executed between Maverik and the property owner.83 And, the development of future fueling stations, or comparable development, near the Project site would be the “successive projects of the same type in the same place” with which this exception is concerned.84 Accordingly, this exception does not apply.

2. There Are No Unusual Circumstances that Would Result in Significant Effects on the Environment
As explained in the Staff Report, the Project does not present any unusual circumstances and therefore there is no reasonable possibility that the Project would have a significant effect on the environment due to unusual circumstances.85 Indeed, as explained above, a gas station formerly operated adjacent to and just west of the Project site in the SPA 80 Ibid.
81 CC Staff Report, p. 16.
82 CEQA Guidelines, §§ 15064(d), 15358; Laurel Heights Improvement Assn. v. Regents of University of California (1988) 47 Cal.3d 376, 396 [“future action…not considered” at the same time as current action to be “discussed in subsequent [CEQA review]”]; Arcadians for Environmental Preservation, supra, 88 Cal.App.5th at p. 439, quoting Aptos Residents Assn. v. County of Santa Cruz (2018) 20 Cal.App.5th 1039, 1051 [“speculation that other projects, when approved and considered together with [the project], would create the significant environmental effects was pure speculation” and “ ‘not sufficient to negate a categorical exemption’ ”].
83 CC Staff Report, pp. 16-17.
84 Id., p. 16; see also, e.g., Assoc. for Protection etc. Values v. City of Ukiah (1991) 2 Cal.App.4th 720, 733-734 [for project claiming Class 1 exemption for an addition to an existing facility, “successive projects of the same type in the same place” under this cumulative exception are future planned additions to the same structure]; Robinson v. City & County of San Francisco (2012) 208 Cal.App.4th 950, 957 [constraining the “same place” element to ensure the exception does not “swallow the rule”]; North Coast Rivers Alliance v. Westlands Water Dist. (2014) 227 Cal. App. 4th 832, 876-877 [constraining the “same type” element to future short-term water contracts like the project and not future long-term contracts]. 85 CC Staff Report, pp. 17-19; CEQA Guidelines, § 15300.2(c); see also Exh. H [Third Appellate District explaining the court’s unusual circumstances review]; Protect Tustin Ranch, supra, 70 Cal.App.5th at p. 964 [the same].

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(ARCO) at the same time that another gas station was operating slightly farther west and across Grant Line Road (Chevron).86 A comparable gas station with a convenience store and car wash currently operates just across Grant Line Road (ARCO) from the Project site. 87 A
primary purpose of a gas station within city limits is to conveniently serve surrounding urban development. So, it is difficult to imagine how operating a gas station at the Project site could be considered an unusual circumstance in the context of the Class 32 infill exemption. As well, City staff and two environmental consulting firms have determined that the Project will not have a significant effect on the environment. Accordingly, this exception does not apply.

IV. PROJECT IS CONSISTENT WITH GENERAL PLAN AND ITS EIR In addition to qualifying for the Class 32 exemption, as explained in the Staff Report,88 the Project comports with CEQA Guidelines section 15183, which “mandates that projects which are consistent with the development density established by existing zoning … or general plan policies for which an EIR was certified shall not require additional environmental review,” as explained and demonstrated in the Staff Report. 89 City staff determined that the Project is consistent with zoning, the General Plan, and the General Plan EIR and no additional environmental review is required because there would be no potentially significant effects resulting from the Project that are peculiar to the parcel or Project and therefore, prior environmental review is “sufficient to support the proposed action and pursuant to State CEQA Guidelines sections 15183 and 15162, no further environmental review is required.”90 Nevertheless, environmental review was performed, including for air quality, biological resources, cultural resources, noise, transportation, and cumulative impacts, that would fulfill any requirement under the streamlining provisions of CEQA Guidelines section 15183 for additional analysis.
91 V. OTHER COMMENTER CONCERNS ARE UNFOUNDED

AND DO NOT PRESENT CEQA ISSUES
A. There Is No Evidence that the Project Would Affect Property Values; Notwithstanding, CEQA Does Not Require Consideration of Property Values At least one commenter expressed a concern that the Project would lower residential property values within the City. As noted above and in the Staff Report, the Project site is not 86 See Exh. D.
87 CC Staff Report, p. 18.
88 CC Staff Report, pp. 24-28.
89 See also Pub. Resources Code, § 21083.3.
90 CC Staff Report, pp. 27-28, 377-381 [Ascent Response Memo]; CEQA Guidelines, § 15183(c), (d), (f)-(h); Pub. Resources Code, § 21083.3(b), (d); see also Muzzy Ranch Co. v. Solano County Airport Land Use Com. (2007) 41 Cal.4th 372, 388, fn. 7.
91 CEQA Guidelines, § 15183(b); see also Lucas v. City of Pomona (2023) 92 Cal.App.5th 508, 546.

City Council
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Page 15 ends

located near any residential neighborhoods.92 Nor has any evidence been provided that property values would decrease as a result of the Project.93 Even if any such evidence were provided, CEQA does not require this type of economic consideration. “Effects analyzed under CEQA must be related to a physical change” and economic changes resulting from a project, in and of themselves, “shall not be treated as significant effects on the environment.”94
B. There Is No Evidence that the Project Would Increase Crime; Notwithstanding, CEQA Does Not Require Consideration of Crime Here
A few commenters were concerned that the Project would increase crime, although no evidence was provided to support this concern. There is no reason to believe that the Project would substantively increase crime in the area. Maverik gas stations are designed to ensure the safety and security of its customers and the operation. Maverik installs between 50 and 80 security cameras at its stations. It designs its convenience store fronts with large windows along the face of the building so that employees can monitor activity at the fuel stations.

Maverik convenience stores are well lit with clear entrances and with restroom entrances inside the building so they can be continuously monitored. Maverik is a great collaborator with local law enforcement and has assisted in several investigations leading to arrests for crimes not related to Maverik stations, such as credit card fraud and identify theft, domestic disputes, stolen property, vehicle accidents, missing persons, and more. Maverik’s safety policies and procedures are so exemplary that it was awarded the Workplace Safety Award by WCF Insurance in 2017.

Notwithstanding the lack of evidence linking the Project with crime, CEQA does not require that a lead agency analyze potential crime associated with a project unless crime would increase such that it would result in an increase of services requiring an expansion of law enforcement facilities, the construction of which requires environmental review under CEQA.95 There is zero evidence that the Project would result in any substantive increase in crime and therefore no evidence that the Project would result in the construction of law enforcement facilities requiring CEQA review.

VI. CONCLUSION
Maverik is confident that its modern, clean, and conveniently located fueling station will be beneficial to the City and its residents. On Yelp.com, the West Sacramento Maverik fueling station overwhelmingly receives 4-star and above ratings, with predominant 5-star 92 CC Staff Report, p. 91.
93 Federation of Hillside & Canyon Assns, supra, 83 Cal.App.4th at p. 1265. 94 CEQA Guidelines, §§ 15064(e), 15131, 15358(b); see also Gray v. County of Madera (2008) 167 Cal.App.4th 1099, 1121 [a decline in property values as a result of a project need not be addressed because “no evidence [was presented] that any significant physical changes to the environment will result”]. 95 See, e.g., CEQA Guidelines, appen. G, § XV; see also § 15358 [defining indirect effects].

City Council
RE: Response to Appeal of PC Approval of Maverik Fueling Station November 10, 2025

Page 16 ends

reviews. Likewise, for the Maverik station in Rocklin. Reviewers repeatedly remark positively about the clean and spacious restrooms, great fuel pricing, safety, large selection of drinks and snacks, fresh food, and use of modern technology.96 Appellant’s criticisms of Maverik on its website97 and in its appeal appear to be based largely on misleading and untrue information of unknown origin and not on verified facts and analysis. Maverik encourages the City Council to trust in its staff’s findings and deny the appeal.

Maverik thanks the City for its consideration of the information and analysis provided in this letter. I am happy to answer any questions the City may have. Please feel free to contact me at
Sincerely,
Casey A. Shorrock
Attachments
Exhibit A: Appellant’s Website for Project, last accessed 11/07/25 Exhibit B: Comment Letter from Ed E. Yates Representing No More Gas in Galt on Maverik Project in Galt (03/10/25)
Exhibit C: General Plan Update EIR Figure 4.0-1
Exhibit D: Current and Historic Aerial Photos of the Project Site Exhibit E: Project Site Aerial Photo from Working Families Case Exhibit F: Wetland Delineation Covering the Project Site Exhibit G: Excerpt from Governor’s Office of Land Use and Climate Innovation Webpage on SB 743
Exhibit H: Protect Neighborhoods v. City of Roseville (Sept. 29, 2025, Case No. C101428, unpublished opinion)
cc: Kyra Killingsworth, Senior City Planner
Jonathan Hobbs, City Attorney
Chelsea Mejia, Senior Deputy City Attorney
96 https://www.yelp.com/biz/maverik-adventures-first-stop-west-sacramento?rr=5#reviews. 97 See Exh. A.

EXHIBIT EXHIBIT EXHIBIT AA
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SUPPORT THE APPEAL
Tell the
Elk Grove City Council to
deny Maverik
The Planning Commission approved it. The City Council has the final say.

They need to hear from us now!
The Planning Commission approved a 24/7 truck-scale fueling center at Grant Line and E. Stockton without a full review. But the City Council has the power to stop it. Tell them to support the appeal and deny Maverik before it’s too late.

Send the City Council an email today! (/letters/)
(https://protectelkgroveca.com)

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(HTTPS://PROTECTELKGROVECA.COM/LETTERS/)

SIGN THE PE
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ELK-GROVE-SAY-NO

MAVERIK-DIESEL-SUP

GRANT-LIN
Home The Proposal What’s at Risk
10/26/25, 4:58 PM ProtectElkGrove – Protecting What Makes Elk Grove Home. https://protectelkgroveca.com 1/4
A Massive
Project Pushed
Through as ‘InFill’
Maverik was approved
using a loophole —
calling it an “in-fill”
project to avoid a full
development review.

But this is no small infill site. It’s mostly open
land, and the
developer admitted
Maverik is just the first
piece of the larger
Grant Line Village
project. Approving this
project in pieces hides
the true impacts and
denies residents a fair
look at what’s really
coming.
(/theproposal/)
Traffic, Safety,
and Community
Risks
East Stockton
Boulevard is already
one of the most
congested corridors in
Elk Grove. Maverik
hasn’t submitted final
plans for required road
work, yet the City
pushed it forward
anyway. Elk Grove
Police did not provide
a call data report or
real safety review in
the staff report.

Approving a 24/7
fueling center here
means more truck
traffic, more
congestion, and more
safety risks for
families, schools, and
local businesses.
(/communityconcerns/)
Not Needed —
16+ Stations
Already Nearby
Within three miles of
this site, there are
already more than 16
fueling stations,
including diesel
providers like CFN,
InterState Oil, and
Clean Energy. Elk
Grove does not need
another massive
fueling hub. A 25-
pump, 24/7 dieselheavy station doesn’t
serve our
neighborhoods — it
only adds traffic and
crime while duplicating
services we already
have.
(/theproposal/)

Support the
Appeal — Tell
City Council to
Deny Maverik
The Planning
Commission approved
Maverik, but the City
Council has the final
say. Now is the time to
act. Support Protect
Elk Grove’s appeal
and tell the Council to
deny this project
before it reshapes our
southern gateway into
a 24/7 fueling hub.

Click below to send
your message today.
(/letters/)
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The Proposal: Round-theClock Diesel Traffic Next to
Our Families and
Community Spaces
What’s Being Planned — and Why You Haven’t Heard About It Maverik Stores, Inc., a Utah-based corporation, has quietly submitted a proposal to the City of Elk Grove to build a 24/7 fueling station with a nearly 6,000 square foot convenience store and 25 pumps — including high-volume diesel fueling — at the corner of East Stockton Blvd and Grant Line Road.

The project requires a Conditional Use Permit and Minor Design Review and is currently listed on the City’s Private Development Projects page (https://elkgrove.gov/sites/default/files/city-files/City%20Government/commissions-committees/planning/2025/phn-maverik-plng24- 031.pdf). Despite its scale and potential impacts, most Elk Grove residents are unaware of the proposal. (https://protectelkgroveca.com)

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MAVERIK-DIESEL-SUPER-ST
GRANT-LINE-99)
Home The Proposal What’s at Risk
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(https://elkmap.maps.arcgis.com/apps/MapTour/index.html?appid=3c40052d00c34da6a10af32f609decb5) 10/26/25, 4:57 PM The Proposal – ProtectElkGrove
https://protectelkgroveca.com/the-proposal/ 2/5

WHAT WE KNOW NOW
Developer: Maverik Stores,
Inc. (Utah-based corporation)
Location: NW corner of East
Stockton Blvd & Grant Line
Rd
Size: 5,951 sq. ft.
convenience store
Features: 25 fueling pumps
under two canopies, including
high-volume diesel fueling for
trucks
Hours: 24/7 operation
Nearby: SES Portuguese
Hall (community venue), Sky
River Casino (across Hwy
99), Amazon distribution
center, and surrounding
neighborhoods

WHY IT MATTERS
A fueling station of this scale at Elk
Grove’s southern gateway could
fundamentally change the
character of the area, and once it’s
built, it cannot be undone.

This proposal isn’t just about fuel.

It’s about bringing:

Heavy diesel traffic onto
roads already burdened by
Amazon’s distribution center
24/7 fueling hub activity
directly next to the SES
Portuguese Hall and across
from Sky River Casino
Public safety risks,
pollution, and nonstop
disruption in a location
better suited for higher-value
development that benefits Elk
Grove families

STOP IT BEFORE IT'S
BUILT
The project is early in the City’s
review process — which means
there’s still time to raise concerns.

But once approved, it will be nearly
impossible to reverse.

Help make sure this project doesn’t
move forward quietly. Make your
voice heard.

SIGN THE PET
(HTTPS://WWW.CHANGE.ORG/P/PROTECT-ELK-GROVE-SAY-NO-TO-T RECRUITER=1374013079&RECRUITED_BY
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WHAT THEY'RE NOT TELLING YOU
The developers are presenting this project as a simple fueling station, but the plans reveal much more: a nearly 6,000-square-foot convenience store with two canopies covering 25 fueling pumps, including high-volume diesel fueling for trucks. This facility is designed to operate 24/7, bringing significant traffic, noise, and pollution to Elk Grove’s southern gateway.

Residents also deserve full transparency about the long-term plans for this site. Once a project of this scale is approved, additional phases or expansions can be proposed, locking the community into even greater impacts for decades.

Protect what matters. Be the change for the Elk Grove we love.

A community-led initiative to raise awareness about proposed industrial development near our homes, schools, and parks.

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What’s at Risk for Elk Grove
A 24/7 diesel fueling station with 25 pumps and a nearly 6,000-square-foot store has been proposed at Elk Grove’s southern gateway, next to the SES Portuguese Hall and across from Sky River Casino. While the developers frame it as just another commercial project, the reality is far bigger. It brings serious risks — from traffic and diesel emissions, to public safety concerns, to lasting impacts on the character of our community. (https://protectelkgroveca.com)

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MAVERIK-DIESEL-SUP

GRANT-LIN
Home The Proposal What’s at Risk
10/26/25, 4:58 PM Community Concerns – ProtectElkGrove
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More Diesel Trucks. More
Danger on Our Streets.

A 24/7 diesel fueling hub at Elk
Grove’s southern gateway means
more than just inconvenience — it
means industrial truck traffic on
roads already strained by
Amazon’s distribution center.

Families driving to practice,
seniors navigating local
intersections, and neighborhoods
near Grant Line and East
Stockton will all face heavier,
faster, and more dangerous traffic
every day.

TRUCKS. CONGESTION.

ACCIDENTS.

Toxic Emissions Where
Families Breathe.

Diesel fueling stations bring toxic
emissions that settle into the air
our families breathe. The
proposed 25-pump fueling hub
threatens to worsen air quality
near neighborhoods, community
gathering spaces like the SES
Portuguese Hall, and Elk Grove’s
southern gateway. Kids, seniors,
and anyone with respiratory
conditions will be at greater risk.

Elk Grove families deserve clean
air, not a cloud of diesel exhaust.

POLLUTION. EXHAUST.

ASTHMA.
24-Hour Operations Invite
Unwanted Activity.

Truck stops across the country
have been linked to increased
crime, including drug activity,
prostitution, and human
trafficking. Placing a 24-hour
fueling hub with high-volume
diesel traffic next to the SES
Portuguese Hall, across from Sky
River Casino, and near Elk Grove
neighborhoods exposes our
community to risks that do not
belong in this location.

CRIME. DRUGS. DANGER.
10/26/25, 4:58 PM Community Concerns – ProtectElkGrove
https://protectelkgroveca.com/community-concerns/ 2/5
This Isn’t Just a Gas
Station — It Never Sleeps.

This isn’t just a gas station — it’s
a nonstop operation. A 25-pump,
24-hour fueling hub means big
rigs idling, bright canopy lights,
and constant traffic at all hours.

What should remain a safe,
community-centered corner of Elk
Grove could instead become a
zone of noise, light pollution, and
sleepless nights for nearby
families.

IDLING. LIGHTS. NO REST.

Elk Grove’s FamilyFriendly Vision —
Undermined.

A truck stop at Elk Grove’s
southern gateway goes against
everything our city has invested
in: youth, families, cultural
spaces, and smart growth. This
location deserves development
that enhances our community —
not a project that endangers it.

Once built, it cannot be undone.

WRONG PROJECT. WRONG
PLACE.

A Decision That Could
Shape Our City — Without
Us.

This proposal isn’t coming from a
local business. It’s backed by
Maverik Stores, Inc., a Utahbased corporation owned by an out-of-state investment company.

Big decisions about Elk Grove’s
future should reflect the voices of
the people who live here — not
absentee developers. Approving
a 24/7 fueling hub of this scale
sets a dangerous precedent. If
this goes through, what comes
next?
THEIR PROJECT. OUR CITY.
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EXHIBIT EXHIBIT EXHIBIT BB
Law Office of Edward E. Yates
2060 Sutter St., # 403
San Francisco, CA 94115
Ph: 415-990-4805
[email protected]
March 10, 2025
Amie Mendes
Economic Development Director
City of Galt
Galt California
By email: [email protected]
RE: proposed Maverik Gas Station and Convenience Store in Galt.

Dear Ms. Mendes:

I represent No More Gas in Galt (NMGG) regarding the proposed Maverik Gas Station and Convenience Store in Galt. (“Project”). My client members include community residents and small businesses and members who object to adding more gas stations to the relatively small City of Galt.

The proposed Project site is located at the corner of Crystal Way and Locust and A Street and includes a 5,900 S.F. Maverik convenience store with fuel sale uses. In brief, an approval of the project relying on an addendum would potentially result in the following violations of the California Environmental Quality Act (CEQA) (Pub.

Resources Code, § 21000 et seq.) (“CEQA”), state Planning and Zoning Law (Government Code § 65000 et seq., “PZL”), and the Galt Municipal Code:
e Fora project of this scale with potential traffic, infrastructure and air quality impacts, CEQA requires that the City prepare an Environmental Impact Report.

City attorney communications to me and City and consultant staff communications show that the City plans to prepare an “Addendum” to the Simmerhorn Ranch Initial Study/Negative Declaration and/or Conceptual Simmerhorn Commercial Shopping Center Initial Study (“Neg Dec”) to ostensibly comply with CEQA.

However, an addendum or any other subsequent CEQA document must regard the same project as was previously examined. This is not the case here: the project description and site plans in the previous negative declarations do not appear to include the Maverik station, and there is no mention of the Maverik gas station (which is in reality a truck stop). Therefore, separate and lawful CEQA compliance for the Maverik Project is required.
e The records obtained in Public Record Act requests demonstrate that the City is not only aware but also strongly advocating and planning for extensive, related development in Galt Ranch and on the property/parcels on which Maverik is proposed. As such it is clear that developers can and will request future development of easily foreseeable additional commercial uses. CEQA requires that agencies assess the impacts of cumulative and reasonably foreseeable related future projects. Thus, any addendum to the existing Neg Dec would be legally inadequate because the City does not appear to be considering the cumulative environmental impacts from the reasonably foreseeable commercial developments planned for the same commercial area where the Maverik station will be. e The City has so far refused to release any traffic or air quality studies for the Maverik Project and therefore, is potentially still in violation of the Public Records Act. Additionally, the public will not have an opportunity to read, review or critique these studies on a large scale project with potentially significant environmental impacts. This is not common practice by California state and local agencies, which routinely ensure transparency by providing such documents to the public well in advance of public hearings. The City’s behavior appears to suggest that the City is hiding something by not releasing these reports.

Additionally, the language used by City staff in its communications strongly promotes the Maverik Project and Galt Ranch commercial projects and thus, potentially demonstrates a lack of impartiality regarding review and deliberation over any decision to prepare an addendum instead of an EIR or negative declaration.

Given these issues, I urge the City of Galt to prepare an Environmental Impact Report for the Project, including the reasonably foreseeable and cumulative impacts of the proposed development projects in the Galt Ranch development area.

CEQA LEGAL REQUIREMENTS AND MAVERIK PROJECT APPLICATION

1. An EIR or Negative Declaration, Not an Addendum Must be Prepared of the Maverik Project.

CEQA provides for Subsequent or Supplemental analysis for the same project which has been the subject of a previous CEQA document. (Pub. Res. Code 21166, CEQA Guidelines 40 CCR §§ 15162, 15164.) However, the Maverik gas station and related commercial development is a new, different project, not mentioned or considered in the previous Neg Decs. Instead, CEQA requires the City of Galt to prepare an environmental impact report (EIR) before approving a new project that “may have a significant effect on the environment.” (Friends of Coll. of San Mateo Gardens v. San Mateo Cnty. Cmty.

Coll. Dist., 1 Cal. 5th 937, 943 (2016); 14 CCR § 21065, § 21151(a).

Here, neither the Maverik Project nor its potential impacts are mentioned in the previous negative declarations. Therefore, the City may not rely on the previous CEQA documents for the new Maverik Project, a different project.

Second, Section 15164 states that “An addendum to an adopted negative declaration may be prepared if only minor technical changes or additions are necessary” (Cal. Code Regs. tit. 14 § 15164...” The Resources Agency's discussion of Guidelines section 15164 states it was “designed to provide clear authority for an addendum as a way of making minor corrections in EIRs without recirculating the EIR. (Emphasis Added.) Save Our Heritage Organization v. City of San Diego, 28 Cal. App. Sth 656, 664 (2018). Here, the large Maverik Project and enormous related large commercial development, and their potential impacts to air quality and traffic resources are not “minor technical changes.” Third, Sections 15162 and 15164(b) further restrict use of addendums where there are substantial project changes or new circumstances potentially resulting in new impacts.

Here, the Project Description for the previous negative declarations only describe general impacts for the Galt Ranch commercial project and do not address specific impacts of the Maverik gas station/truck stop. Obviously, such analysis in the Nec Dec will not be adequate to consider the huge increase in traffic and emissions caused by the Maverik Project and the other reasonably foreseeable commercial development.

Thus, relying on an addendum to the previous negative declaration conflicts with the plain language of Section 21166 and case law where substantial changes in acreage and intensity of use and impacts require a new Negative declaration or EIR. See Concerned Citizens of Costa Mesa, Inc. v. 32nd Dist. Agric. Ass'n, 42 Cal. 3d 929, 937 (1986). See also Save Berkeley's Neighborhoods v. Regents of Univ. of Cal., 51 Cal. App. 5th 226, 237 (2020). Simply put, CEQA requires a new EIR or negative declaration and does not allow the commercial and industrial Maverik Project to be the subject of an addendum.

2. The City Must Assess Impacts from Reasonably Foreseeable Future Projects at Galt Ranch.

CEQA (Public Resources Code § 21000 et seq.) requires assessment of reasonably foreseeable related future impacts from foreseeable future development. Laurel Heights Improvement Assn. v. Regents of University of California (1988) 47 Cal. 3d 376, 396 concludes that a CEQA document:
must include an analysis of the environmental effects of future expansion or other action if: (1) it is a reasonably foreseeable consequence of the initial project; and (2) the future expansion or action will be significant in that it will likely change the scope or nature of the initial project or its environmental effects.

CEQA documents must include some degree of forecasting in evaluating a project’s environmental impacts. (CEQA Guidelines § 15144.) The principle that CEQA requires foreseeable forecasts is well established in case law. (CEB, Practice Under the CEQA, §

11.32., citing San Francisco Ecology Center v. City and County of San Francisco. (1975) 48 CA 3d 584, 595.)
Lead Agencies must use their best efforts to find out and disclose all that they reasonably can. (CEQA Guidelines § 15144.) Ifa precise technical analysis of an environmental impact is not practical, the agency must make a reasonable effort to pursue a less exacting analysis. Citizens to Preserve the Ojai v. County of Ventura (1985) 176 CA 3d 421, 432.

Agencies have alternatives such as tiered analysis but they cannot ignore the requirements to assess reasonably foreseeable projects in the first level CEQA review.

Santa Teresa Action Group v. City of San Jose (2003) 114 CA 4" 689, 696.

The City of Galt has more recent proposals, data and analyes regarding additional commercial development at Galt Ranch. Therefore, CEQA requires that this mew information, including assessment of any cumulative impacts, be included in any CEQA compliance documents for the Maverik Project. (14 CCR § 15355.)

3. The City Has Not Released any Traffic or Air Quality Studies for the Maverik Project.

The October 1, 2024 Raney Planning and Management (“Raney”) “Scope of Work for the Maverik Gas Station CEQA Addendum” details the required air quality traffic, and GHG studies that must be prepared for the Project. Despite my efforts for the last seven months to gain access to such technical documents, the City still has not released them.

Without the public having access to these technical documents, the public has no way to know what the impacts will be until right before any Planning Commission deliberations.

CONCLUSION
If the City chooses to continue on it path to using an addendum to previous negative declarations, my client will consider its legal options, which include filing a Petition for Writ of Mandate to overturn any Maverik approval based on such an addendum.

I am happy to discuss these issues at any time.

Sincerely,
2 Lye
Edward Yates

EXHIBIT EXHIBIT EXHIBIT CC
Figure 4.0-1
Existing General Plan Land Use Designations
City of Elk Grove
Development Services
AÎE !"^$
East Study Area
South Study Area
West Study Area
North
Study Area Sheldon Rd Excelsior Rd
Elk Grove Blvd
Bond Rd
Elk Grove Blvd
Laguna Blvd
Bilby Rd
Waterman Rd
Elk Grove Florin Rd
Bradshaw Rd
Eschinger Rd
Bruceville Rd
Kammerer Rd
Bruceville Rd
Franklin Blvd
Grant Line Rd
Core Rd
Big Horn Blvd
E Stockton Blvd
Whitelock Pkwy
T:\_GIS\Elk_Grove\MXDs\General_Plan_Update\EIR\Figure 4.0-1 Existing General Plan.mxd (1/30/2018) Source: City of Elk Grove; ESRI.

Legend
Elk Grove City Limits
Planning Area Boundary
Existing Elk Grove General Plan

RESIDENTIAL
Rural Residential (0.1 to 0.5 du/acre)
Estate Residential (0.6 to 4.0 du/acre)
Low Density Residential (4.1 to 7.0 du/acre)
Medium Density Residential (7.1 to 15.0 du/acre)
High Density Residential (15.1 to 30.0 du/acre)

MIXED USE
Commercial/Office/Multi-family
Office/Multi-family
Commercial/Office

NON-RESIDENTIAL
Commercial
Office
Public Schools
Institutional
Public/Quasi-public
Light Industry
Heavy Industry
Private Streets

POLICY AREA
Southeast Policy Area
Elk Grove Triangle Policy Area

OPEN LAND
Public Parks
Public Open Space/Recreation
Private Open Space/Recreation
´ 0 0.5 1
MILES

EXHIBIT EXHIBIT EXHIBIT DD
Aerial Photographs Showing Current and Fomer Commercial Development Surrounding the Project Site (2025, 2006, 2004, 1993)
(Google Earth Pro, 2025, accessed Oct. 21, 2025)

f t ‘
S - * e a LOACoOmsi Me "La ? 9 -—* ’ 4
y : f t ‘
S - * e a LOACoOmsi Me "La ? 9 -—* ’ 4
y :
ogle Eart

EXHIBIT EXHIBIT EXHIBIT EE
Aerial Photograph Showing Project Site from
Working Families of Monterey County v. King City Planning Com. (2024) 106 Cal. App. 5th 833 (1203 Broadway Street, King City CA 93930)
(Google Maps, accessed Oct. 28, 2025)

EXHIBIT EXHIBIT EXHIBIT FF

REVISED JURISDICTIONAL

DELINEATION

AND SPECIAL STATUS SPECIES

EVALUATION

REYNOLDS & BROWN

CMD COURT PROPERTY

SACRAMENTO COUNTY,

CALIFORNIA
June 2007
Revised July 2007
Prepared For: Prepared By:

Reynolds & Brown GIBSON & SKORDAL, LLC
1200 Concord Avenue, Suite 200 Wetland Consultants
Concord, California 94520 2277 Fair Oaks Blvd., Suite 105 Sacramento, California 95825

INTRODUCTION
This report presents the results of a special status species assessment and a delineation of waters of the United States, including wetlands, which may be regulated by the U.S. Army Corps of Engineers under the authority of Section 404 of the Federal Clean Water Act. The special status species assessment and delineation of waters of the United States were conducted within the study area for the below described Reynolds & Brown CMD Court project.

LOCATION
The approximately 12.25-acre study area is located in Sections 7 and 18; Township 6 North; Range 6 East; MDB&M; Sacramento County; California. The parcel can be found at North

38.378,854°; West 121.360,340° and is portrayed on the Elk Grove, California 7. 5 Minute Series Quadrangle. Figure 1 is a vicinity map.

To access the site from Sacramento, drive south on State Highway 99 and exit at Grant Line Road. The study area is situated east of the frontage road north and east of Highway 99 and Grant Line Road.

METHODOLOGY
This delineation was performed in accordance with the 1987 "Corps of Engineers Wetlands Delineation Manual," the “Interim Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Arid West Region,” and Sacramento District’s “Minimum Standards for Acceptance of Preliminary Wetlands Delineations” dated November 30, 2001.

Corps' regulations (33 CFR 328) were used to determine the presence of waters of the United States other than wetlands. The "National List of Plant Species That Occur in Wetlands:

California (Region 0)'"> was used to determine the wetland indicator status of plants observed in the study area.

' Environmental Laboratory. 1987. Corps of Engineers Wetlands Delineation Manual. Technical Report Y-87-1, U.S. Army Engineer Waterways Experiment Station. Vicksburg, Miss.
> Wetlands Regulatory Assistance Program. December 2006. Interim Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Arid West Region. U.S. Army Engineer Research and Development Center, Vicksburg, Miss. > Reed, P.B. 1988. National List of Plant Species That Occur In Wetlands: California (Region 0). Biological Report 88(26.10). May

1988. National Ecology Research Center, National Wetlands Inventory, U.S. Fish & Wildlife Service, St. Petersburg, Florida.

Reynolds & Brown CMD Court Property l
Jurisdictional Delineation and
Special Status Species Evaluation
Revised July 2007
=a
J
FIGURE 1
Study

Area Vicinity Map

wld wees!

“ESCHINGER

ae oe 5 a Nid a3 At a Bf Ne ;

oy)
Source: USGS Florin, Bruceville, Elk Grove, and Galt,
California 7.5 Minute Quadrangles.

Sections 7 & 18, Township 6 North, Range 6 East, MDB&M; North 38.378,854 degrees, West 121.360,340 degrees

Field surveys were conducted on April 18, 2007, within the study area to delineate water features, including wetlands that are potentially regulated under Section 404 of the Federal Clean Water Act. Data point locations were surveyed utilizing a Trimble ProXR GPS unit equipped with sub-meter accuracy. The delineation map was prepared by digitizing and layering the GPS survey data over May 2002 aerial photography. Detailed data on vegetation, soils, and hydrology were taken in the field. Data sheets documenting the basis for determining which areas are wetland or upland are provided in Appendix A. Appendix B contains a delineation map of the study area.

The study area was assessed for the potential presence of special status species. Initially, a record search of the California Natural Diversity Database (CNDDB) was conducted for the Bruceville, Galt, Florin, and Elk Grove USGS quadrangles to identify all documented sightings of special status species in the vicinity of the site. In addition to species identified in the CNDDB search, we included other special status species that may be present based on historical range data. Appendix D includes a CNDDB occurrence map with GPS information provided by the California Department of Fish and Game.

GENERAL SITE CONDITIONS AND HABITAT
Existing Field Conditions
The study area is a historically leveled parcel located south of Elk Grove, north of the Highway 99 frontage road, and west of Grant Line Road. It is situated on flat terrain at an average elevation of approximately 40 feet, and the immediately surrounding properties are composed of undeveloped lots, light industrial operations, and retail outlets. The site presently contains a large empty field, a vehicle salvage/repair facility with parking lots, and a large soil stockpile area.

Plant Communities and Habitat Types
The majority of the study area contains ruderal plant communities composed of soft chess (Bromus mollis), perennial rye (Lolium perenne), Mediterranean barley (Hordeum hystrix), winter vetch (Vicia villosa), barley (Hordeum leporinum), and wild oats (Avena fatua). The site’s few trees are located in the western half and consist of black walnut (Juglans nigra) and valley oak (Quercus lobata).

Reynolds

& Brown CMD Court Property 2
Jurisdictional Delineation and
Special Status Species Evaluation
Revised July 2007
Hydrology
The site is relatively flat and contains no drainage patterns or depressional wetlands.

Soils
According to the April 1993, "Soil Survey of Sacramento County, California," three soil map units occur within the study area. The first unit is Galt clay, leveled, 0-1 percent slopes (151). It is a moderately deep and moderately well drained soil, and an underlying calcareous hardpan is situated about 32 inches below the surface. This soil is derived from fine textured alluvium formed from granitic rock sources and includes small areas of Clear Lake and San Joaquin soils as well as Urban land. The second unit is San Joaquin silt loam, leveled, 0 to 1 percent slopes (213), which is a moderately deep and moderately well drained soil that is mainly derived from mixed granitic rocks in alluvium. It has an underlying claypan typically at a depth of 23 inches.

An approximately 26-inch indurated hardpan is found beneath the claypan. Permeability for this soil unit is very slow resulting in pooled water for short periods after heavy winter/spring rains or over-irrigation. This unit contains inclusions of the following soils: Bruella, Durixeralfs, Galt, Hedge, Kimball, and Xerarents. The final soil is San Joaquin-Galt Complex, 0-1 percent slopes (217). This unit is composed of approximately 45 percent San Joaquin soil and 40 percent Galt Soil, and they are classified as an abruptic durixeralf and a typic chromoxerert, respectively.

Both are moderately deep and moderately well drained. The San Joaquin soil includes a clay pan about five inches thick, which overlays a 26 inch indurated hardpan. The claypan typically begins at a depth of 12 to 30 inches and may result in pooled surface water after rains or overirrigation. The Galt soil may possess a calcareous hardpan with weakly cemented silica about 38 inches below the surface. Included in the complex are small areas of Clear Lake, Durixeralfs, and Kimball soils and Xerarents.

None of the above soil map units are listed in the June 1991, "Hydric Soils of the United States", or the Natural Resources Conservation Service’s "Field Office Official List of Hydric Soil Map Units for Sacramento County, California" (county list) dated March 17, 1992. The following are classified as hydric on the county list when found within certain landforms (listed in parentheses): the Clear Lake inclusions in 151 and 217 (basin floor) and the Galt component in 217 (depressions). Figure 2 is a soils map.

FINDINGS
We

did not locate any waters/wetlands within the study area.

Reynolds & Brown CMD Court Property 3
Jurisdictional Delineation and
Special Status Species Evaluation
Revised July 2007

213
217
FIGURE 2
Study Area Soils Map

Ma Unit Subgroup __

Drainage Class
Galt clay, leveled,
0-1% slopes
San Joaquin silt loam,
leveled, 0-1% slopes
San Joaquin-Galt Complex
loam, 0-1% slopes
Typic Chromoxerert
Abruptic Durixeralf
Abruptic Durixeralf/
Typic Chromoxerert
Moderately well drained
Moderately well drained
Moderately well drained/
Moderately well drained
Source: USDA, Soil Conservation Service. April 1993. Soil Survey of Sacramento County, California.

APPENDIX A

DATA FORMS

APPENDIX A

DATA FORMS
WETLAND DETERMINATION DATA FORM - Arid West Region

Project/Site: Reynolds & Brown CMD Court City/County: Sacramento Sampling Date: 4/18/2007 Applicant/Owner: Reynolds & Brown State: CA Sampling Point: 01 Investigator(s): Jim Gibson / Matt Hirkala Section, Township, Range: S 18, T6N, R6E Landform (hillslope, terrace, etc.): __ Toe of Slope Local relief (concave, convex, none): None Slope (%): _0 Subregion (LRR): Cc Lat) 38.378,070°N Long: 121.361,055° W Datum: WGS 84 Soil Map Unit Name: San Joaquin - Galt Complex loam, 0-1% slopes NWI classification: NIA Are climatic / hydrologic conditions on the site typical for this time of year? Yes & No | (If no, explain in Remarks.) Are Vegetation 1 Soil O or Hydrology C1] significantly disturbed? Are "Normal Circumstances" present? Yes K} Nol] Are Vegetation (] Soil 1 or Hydrology [] naturally problematic? (lf needed, explain any answers in Remarks.) SUMMARY OF FINDINGS - Attach site map showing sampling point locations, transects, important features, etc.

Hydrophytic Vegetation Present? Y No
siete haat ° vee 5 No ls the Sampled Area , - within a Wetland? Yes OJ No & Wetland Hydrology Present? Yes No
Remarks:

EGETATION
| ott Absolute Dominant indicator | Dominance Test worksheet: Tree Stratum (Use scientific names.) % Cover Species? Status —- —_—. __ = Number of Dominant Species That

2. ——- — = Are OBL, FACW, or FAC: 4 (A)
| 3. _ — Total Number of Dominant Species

4. — A Across All Strata: 3 (B)
Total Cover: 0% Percent of Dominant Species That
Are OBL, FACW, or FAC: 0.33 (A/B)
| sa ling/Shrub Stratum Prevalence Index worksheet:
z. ——s __ <a Total % Cover of: Multiply by:

S. = = OBL species x1= QO
| 4, — __ FACW species = 0
ve — eer —_ — FAC species 30 x3= 90
Total Cover: 0% FACU species 61 x4= 244
UPL species — xo= 0
| Herb Stratum Column Totals: 91 (A) 334 (B)
'. Hordeum leporinum 30 Yes UPL
2, Lolium perenne 30 Yes FAC Prevalence Index = B/A = 3.67

3. Silybum marianum 30 Yes UPL Hydrophytic Vegetation Indicators:
| 4. Hypochaeris glabra 4 No UPL No Dominance Test is > 50%

5. —"s No. Prevalence Index is < 3.0
a —__ — = Morphological Adaptations (Provide supporting | /. — — —- data in Remarks or on a separate sheet)

8.___ — — Problematic Hydrophytic Vegetation (Explain)
Total Cover: 91%
Woody Vine Stratum Indicators of hydric soil and wetland hydrology must

1. —— — be present.
0% _ .s Hydrophytic
Total Cover: ae Vegetation
| % Bare Ground in Herb Stratum 9% % Cover of Biotic Crust Present? Yes 0 No & Remarks:

SOILS

Sampling Point: 01
Profile Description: (Describe to the depth needed to document the indicator or confirm the absence of indicators.)

Depth Matrix Redox Features
| (inches) Color (moist So Color (moist % Type Loc Texture Remarks 0-12 10YR3/4 100%
Loam

HII}
HII

NTT
TUT
|
Type: C=Concentration, D=Depletion, RM=Reduced Matrix. Location; PL=Pore Lining, RC=Root Channel, M=Matrix.

‘Hydric Soil Indicators: (Applicable to all LRRs, unless otherwise noted.) Indicators for Problematic Hydric Soils:

CJ Histosol (A1) (CJ Sandy Redox (S5) C1 1 cm Muck (A9) (LRR C) C1 Histic Epipedon (A2) OO Stripped Matrix (S6) (1 2.cm Muck (A10) (LRR B) CO Black Histic (A3) (J Loamy Mucky Mineral (F1) Cd Reduced Vertic (F18) CJ Hydrogen Sulfide (A4) (C1 Loamy Gleyed Matrix (F2) CI Red Parent Material (TF2) | CJ Stratified Layers (A5) (LRR C) C1 Depleted Matrix (F3) (J Other (Explain in Remarks) ‘(C1 cm Muck (AQ) (LRR D) (1 Redox Dark Surface (F6)
(J Depleted Below Dark Surface (A11) ( Depleted Dark Surace (F7) | 0 Thick Dark Surface (A12) C] Redox Depressions (F8)
1D Sandy Mucky Mineral (S1) (J Vernal Pools (F9) ; ;
(J Sandy Gleyed Matrix (S4) peony Geant haat Ea Dnesane | Restrictive Layer (if present):

Type:

Depth (inches): Hydric Soil Present? Yes C] No &]
Remarks:

L

HYDROLOGY
Wetland Hydrology Indicators: Secondary Indicators (2 or more required Primary Indicators (any one indicator is sufficient (J Water Marks (B1) (Riverine) Surface Water (A1) (1 Salt Crust (B11) CJ Sediment Deposits (B2) (Riverine) T] High Water Table (A2) (C Biotic Crust (B12) (1 Drift Deposits (B3) (Riverine) _] Saturation (A3) C1 Aquatic Invertebrates (B13) ( Drainage Patterns (B10) (1 Water Marks (B1) (Nonriverine) (J Hydrogen Sulfide Odor (C1) (1 Dry-Season Water Table (C2) [] Sediment Deposits (B2) (Nonriverine) 1] Oxidized Rhizospheres along Living Roots (C3) (J Thin Muck Surface (C7) (J Drift Deposits (B3) (Nonriverine) (Presence of Reduced Iron (C4) C Crayfish Burrows (C8) | CJ Surface Soil Cracks (B6) C] Recent Iron Reduction in Plowed Soils (C6) C Saturation Visible on Aerial Imagery (C9) —] inundation Visible on Aerial Imagery (B7) ( Other (Explain in Remarks) CJ Shallow Aquitard (D3) _] Water-Stained Leaves (B9)

(1 FAC-Neutral Test (D5)
Sield Observations
Surface Water Present? Yes 1] No & Depth (inches):
| Water Table Present? Yes No & Depth (inches):

Saturation Present? Yes] No Depth (inches): Wetland Hydrology Present? Yes (1 No &

‘includes capillary fringe)
Describe

Recorded Data (stream gauge, monitoring well. aerial photos, previous inspections), if available:

Remarks:

WETLAND DETERMINATION DATA FORM - Arid West Region

Project/Site: Reynolds & Brown CMD Court City/County: Sacramento Sampling Date: 4/18/2007 ‘Applicant/Owner: Reynolds & Brown State: CA Sampling Point: 02 Investigator(s): Jim Gibson / Matt Hirkala Section, Township, Range: S 18, T6N, R6E Landform (hillslope, terrace, etc.): Toe of Slope Local relief (concave, convex, none): None Slope (%): 0 Subregion (LRR); _© Lat: _ 38.378,985° N Long: _121.362,377° W Datum: _WGS 84 Soil Map Unit Name: San Joaquin - Galt Complex loam, 0-1% slopes NWI classification: N/A Are climatic / hydrologic conditions on the site typical for this time of year? Yes No O (If no, explain in Remarks.) Are Vegetation [J Soil [10 = orHydrology OJ significantly disturbed? Are "Normal Circumstances" present? Yes Nol] Are Vegetation (J Soil 1 or Hydrology (J naturally problematic? (If needed, explain any answers in Remarks.) SUMMARY OF FINDINGS - Attach site map showing sampling point locations, transects, important features, etc.

Hydrophytic Vegetation Present? Yes No &X
Bes rescent? Yes 5 No S 1s Sha Sampled Area y within a Wetland? Yes O No &] Wetland Hydrology Present? Yes FJ No ‘Remarks:

EGETATION
| 45 Absolute Dominant indicator | Dominance Test worksheet: Tree Stratum (Use scientific names.) % Cover Species? Status — _—_ ~<= Number of Dominant Species That
i —— __ i _: Are OBL, FACW, or FAC: 2 (A)
| 3. ca3 | Total Number of Dominant Species 4 -s 4 Across All Strata: 4 (B) Total Cover: 0% Percent of Dominant Species That
Are OBL, FACW, or FAC: __0.50 (A/B)
| 2 ing/Shnib Stratum Prevalence Index worksheet:

2. — = _ Total % Cover of: Multiply by:

3. os — OBL species x= Oo
| a mt a = —. FACW species —— x2= O
es roe —y __ FAC species 40 x3= 120
Total Cover: 0% FACU species 35 x4= 140
UPL species 29 x= 145
Herb Stratum Column Totals: 104 (A) 405 (B)

1. Lolium perenne 20 Yes FAC

2. Hordeum hystrix 20 Yes FAC Prevalence Index = B/A = 3.89

3. Bromus mollis 35 Yes FAC Hydrophytic Vegetation Indicators:

4. Erodium botrys 2 No UPL No __ Dominance Test is > 50%

5. Convolvulus arvensis 20 Yes UPL No __ Prevalence Index is < 3.0

5. Bromus diandrus E] No UPL Morphological Adaptations (Provide supporting | 7. Geranium dissectum 2 No UPL data in Remarks or on a separate sheet)

8. — Problematic Hydrophytic Vegetation (Explain)
Total Cover: 104%
| Woody Vine Stratum Indicators of hydric soil and wetland hydrology must 1 <=: = = be present.
= = = 0% Hydrophytic
Total Cover: = Vegetation
% Bare Ground in Herb Stratum 0% % Cover of Biotic Crust Present? Yes O No XJ

Remarks:
ovILo

Sampling Font. UZ
Profile Description: (Describe to the depth needed to document the indicator or confirm the absence of indicators.) Depth Matrix
| (inches) Color (moist % Color (moist
1-12 10YR3/2 100%

en:

HII |

| Type: C=Concentration, D=Depletion, RM=Reduced Matrix.

Redox Features

% Type

— OQ ~ x e io
Remarks
° © 3

I
TT

Location: PL=Pore Lining, RC=Root Channel, M=Matrix.
dydric Soil Indicators: (Applicable to all LRRs, unless otherwise noted.) {J Sandy Redox (S5)
C1 Stripped Matrix (S6)
(-] Loamy Mucky Mineral (F1)
C1 Loamy Gleyed Matrix (F2)
Depleted Matrix (F3)
(C0 Redox Dark Surface (F6)
CD Depleted Dark Surace (F7)
(1 Redox Depressions (F8)
C1 Vernat Pools (F9)
~] Histosol (A1)
| CD Histic Epipedon (A2)
7] Black Histic (A3)
_] Hydrogen Sulfide (A4)
CJ Stratified Layers (A5) (LRR C)
7] 1 cm Muck (A9) (LRR D)
_] Depleted Below Dark Surface (A11)
(J Thick Dark Surface (A12)
T] Sandy Mucky Mineral (S1)
_] Sandy Gleyed Matrix (S4)
Indicators for Problematic Hydric Soils:
(11 cm Muck (A9) (LRR C)
(71 2. cm Muck (A10) (LRR B)
(CJ Reduced Vertic (F18)
(1 Red Parent Material (TF2)
(J Other (Explain in Remarks)
Indicators of hydraphytic vegetation and

wetland hydrology must be present.
| Restrictive Layer (if present):

Type:

Depth (inches):

Hydric Soil Present? Yes (] No XX]

Remarks:

HYDROLOGY
Netland Hydrology Indicators:
mary Indicators (any one indicator is sufficient)
= Surface Water (A1)
-] High Water Table (A2)
~] Saturation (A3)
| (J Water Marks (B1) (Nonriverine)
-] Sediment Deposits (B2) (Nonriverine)
"J Drift Deposits (B3) (Nonriverine)
CJ Surface Soil Cracks (B6)
7] Inundation Visible on Aerial imagery (B7)
_] Water-Stained Leaves (B9)
C1 Salt Crust (B11)
(1 Biotic Crust (B12)
(J Aquatic Invertebrates (B13)
(J Hydrogen Sulfide Odor (C1)
(] Oxidized Rhizospheres along Living Roots (C3) (1 Thin Muck Surface (C7) (C1 Presence of Reduced Iron (C4)
CJ Recent Iron Reduction in Plowed Soils (C6)
( Other (Explain in Remarks)
Secondary Indicators (2 or more required
(Water Marks (B1) (Riverine)
C1 Sediment Deposits (B2) (Riverine)
(J Drift Deposits (B3) (Riverine)
(C1 Drainage Patterns (B10)
(1 Dry-Season Water Table (C2)
(1 Crayfish Burrows (C8)
(2 Saturation Visible on Aerial Imagery (C9)
(1 Shallow Aquitard (D3)

(J FAC-Neutral Test (D5)
| exer Observations
jurface Water Present? Yes
| Water Table Present? Yes
;aturation Present? Yes]
ncludes capillary fringe)
No &]
No &J
No &
Depth (inches):

Depth (inches): ___—_
Depth (inches):

Wetland Hydrology Present? Yes] No J
| Describe

Recorded Data (stream gauge, monitoring well, aerial photos, previous inspections), if available:
| emarks:

WETLAND DETERMINATION DATA FORM - Arid West Region

Project/Site: Reynolds & Brown CMD Court City/County: Sacramento Sampling Date: 4/18/2007 Applicant/Owner: Reynolds & Brown State: CA Sampling Point: 03 \nvestigator(s): Jim Gibson / Matt Hirkala Section, Township, Range: S18, T6N, R6E Landform (hillslope, terrace, etc.); _ Toe of Slope Local relief (concave, convex, none): Concave Slope (%): _ <2 Subregion (LRR): Cc Lat; 38.378,752°N Long: 121.361,900° W Datum: WGS 84 Soil Map Unit Name: San Joaquin - Galt Complex loam, 0-1% slopes NWI classification: N/A Are climatic / hydrologic conditions on the site typical for this time of year? Yes & No O (if no, explain in Remarks.) ‘Are Vegetation Sol [1 ~~ orHydrology significantly disturbed? Are “Normal Circumstances" present? Yes &] Nol]

Are Vegetation C] Soil or Hydrology C) naturally problematic? (If needed, explain any answers in Remarks.)

SUMMARY

OF FINDINGS - Attach site map showing sampling point locations, transects, important features, etc.

4ydrophytic Vegetation Present? Yes No LJ
Aydric Soil Present? Yes 0 No Is the:Sampled Area k within a Wetland? Yes 1 No &) | Wetland Hydrology Present? Yes Kl No [J
Remarks:
_EGETATION
| F Absolute Dominant Indicator | Dominance Test worksheet: Tree Stratum (Use scientific names.) % Cover Species? Statu 1 2 _ Number of Dominant Species That

2. == Are OBL, FACW, or FAC: 4 (A)
| a oe =m Total Number of Dominant Species
} _ _ Across All Strata: 4 (B)
Total Cover: 0% Percent of Dominant Species That
Are OBL, FACW, or FAC: 1.00 (A/B)
| sane Prevalence Index worksheet:
2, = 2 Total % Cover of: Multiply by:

8. ——— _ a OBL species 20 x1= 20
| 4. ne = FACW species = fo
5 — = FAC species 412 x3= 36
Total Cover: 0% FACU species 10 x4= 40
UPL species 20 = 100
| Herb Stratum Column Totals: 62 (A) 196 (B)
|. Psilocarphus oregonus 20 —_ OBL

2. Salsola kali 10 __ FACU Prevalence Index = B/A = 3.16

3. Convolvulus arvensis 45 - UPL Hydrophytic Vegetation Indicators:

4. Lolium perenne 410 = FAC Yes _ Dominance Test is > 50%

5. Picris echioides 2 ——_ FAC No __ Prevalence Index is = 3.0

3. Silyoum marianum 8 — UPL Morphological Adaptations (Provide supporting | rn —— —s — data in Remarks or on a separate sheet)
——— i = Problematic Hydrophytic Vegetation (Explain)
Total Cover: 62%
| Woody Vine Stratum Indicators of hydric soil and wetland hydrology must

1. —= =. be present.
a a a
0% Hydrophytic
Total Cover: Be Vegetation
| % Bare Ground in Herb Stratum 38% % Cover of Biotic Crust Present? Yes & NoT]

Remarks:

Sampling Point: 03
Color (moist %
Redox Features

Type Loc

SOILS
Profile Description: (Describe to the depth needed to do Depth Matrix
| (inches) Color (moist) %
0-4 10YR3/3 100%

>4-12
10YR3/2

100%

| Type: C=Concentration, D=Depletion, RM=Reduced Matrix. cument the indicator or confirm the absence of indicators.) Remarks

NIV
Location: PL=Pore Lining, RC=Root Channel, M=Matrix.

Hydric Soil Indicators: (Applicable to all LRRs, unless otherwise noted.) C1 Histosol (A1)
| C1 Histic Epipedon (A2)
(J Black Histic (A3)
(1 Hydrogen Sulfide (A4)
| (1 Stratified Layers (AS) (LRR C)
(1 1. cm Muck (AQ) (LRR D)
(J Depleted Below Dark Surface (A11)
(J Thick Dark Surface (A12)
(1 Sandy Mucky Mineral (S1)
C1 Sandy Gleyed Matrix (S4)
(1 Sandy Redox (S5)
C1 Stripped Matrix (S6)
(J Loamy Mucky Mineral (F1)
(J Loamy Gleyed Matrix (F2)
CJ] Depleted Matrix (F3)
(7 Redox Dark Surface (F6)
(1 Depleted Dark Surace (F7)
(1 Redox Depressions (F8)
C1 Vernal Pools (F9)
Indicators for Problematic Hydric Soils:
(1 1. cm Muck (A9) (LRR C)
(1 2 cm Muck (A10) (LRR B)
(1 Reduced Vertic (F18)
(J Red Parent Material (TF2)
(J Other (Explain in Remarks)
Indicators of hydrophytic vegetation and

wetland hydrology must be. present.
| Restrictive Layer (if present):

Type:

Depth (inches):

Hydric Soil Present? Yes J No &
|

Remarks:
l HYDROLOGY
Wetland Hydrology Indicators:
| Primary Indicators (any one indicator is sufficient)
(1 Surface Water (A1)
[] High Water Table (A2)
| ‘CO Saturation (A3)
(1 Water Marks (B1) (Nonriverine)
7] Sediment Deposits (B2) (Nonriverine)
| (Drift Deposits (B3) (Nonriverine)
(1 Surface Soil Cracks (B6)
T] Inundation Visible on Aerial Imagery (B7)
(C Water-Stained Leaves (B9)
(J Salt Crust (B11)
&I Biotic Crust (B12)
C0 Aquatic Invertebrates (B13)
(J Hydrogen Sulfide Odor (C1)
(1 Oxidized Rhizospheres along Living Roots (C3)
CO Presence of Reduced Iron (C4)
1 Recent Iron Reduction in Plowed Soils (C6)
(CJ Other (Explain in Remarks)
Secondary Indicators (2 or more required)
(1 Water Marks (B1) (Riverine)
( Sediment Deposits (B2) (Riverine)
(J Drift Deposits (B3) (Riverine)
(1 Drainage Patterns (B10)
(J Dry-Season Water Table (C2)
(J Thin Muck Surface (C7)
( Crayfish Burrows (C8)
CO Saturation Visible on Aerial Imagery (C9)
CI Shallow Aquitard (D3)

(1 FAC-Neutral Test (D5)
Field Observations
Surface Water Present? Yes CO]
| Water Table Present? YesO
Saturation Present? Yes]
tincludes capillary fringe)
No Depth (inches):

No &J Depth (inches):

No Depth (inches):

Wetland Hydrology Present? Yes No]
l
|

Describe Recorded Data (stream gauge, monitoring well, aerial photos, previous inspections), if available:
| Remarks:

APPENDIX B

WETLAND DELINEATION MAP

APPENDIX B

WETLAND DELINEATION MAP

EXHIBIT EXHIBIT EXHIBIT GG
Home ! CEQA ! SB 743 Frequently Asked Questions
SB 743 Frequently Asked Questions
Questions
Background and Purpose
What is SB 7 43?
Why was the change needed?
What are the benefits of moving to a VMT metric?
Does SB 7 43 only benefit coastal communities or dense urban areas? How will SB 743 reduce housing costs throughout California? Will significant VMT impacts prevent housing projects from being approved? Won't reducing the amount of driving limit economic growth? Does SB 7 43 still make sense given COVID-19?
Will SB 743 result in new fees and taxes for California residents? Implementation
When do lead agencies need to begin using VMT for land use projects? Are lead agencies required to formally adopt VMT thresholds to begin using VMT? What about draft documents that still use LOS? Do they need to be redone with a VMT analysis? Can I still tier from or rely on an environmental document that uses LOS? Does SB 743 impact general plans that contain LOS standards? Does SB 743 impact any other part of CEQA?
OPR recommends presuming residential development that is 100 percent affordable to have a less than significant transportation impact. What about development that is partially affordable? In the VMT Technical Advisory, does the term "regional" refer to the MPO/RTPA? OPR's Technical Advisory provides a list of transportation project types that would not likely result in a substantial or measurable increase in vehicle travel, and therefore generally should not require an induced travel analysis. Is there another advisory document that lead agencies can also consider? Could adding tolling to an existing lane increase VMT?
the analysis of the general plan EIR; agencies should review the conditions in Public Resources Code section 20194 and Guidelines section 15152 to determine whether additional limited environmental analysis would be required. Please see CEQA Guidelines Appendix J for examples of using tiering in EIRs.

Additionally, there may be circumstances when public agencies are considering changes to already approved projects that were analyzed using LOS. When determining whether subsequent and supplemental analyses are required under Public Resources Code section 21166, the agency should focus the inquiry on whether there are substantial changes in the project or circumstances that would require major revisions of the document, or if new information, which was not known and could not have been known at the time of becomes available. (Pub. Resources Code,§ 21166; CEQA Guidelines, §§ 15162-15163.) Agencies should review other streamlining provisions governing the bases for those analyses (see, e.g., CEQA Guidelines,§ 15164 [addendum to an EIR or negative declaration]).

In reviewing the applicability of these conditions, an agency may use its discretion to determine that a VMT analysis is not required for later-prepared documents. (See, e.g., CREED v. San Diego (2011) 196 Cal.App.4th 515; Concerned Dublin Citizens v. City of Dublin (2013) 214 Cal.App.4th 1301, 1320.) But note that the agency's determination should be supported by substantial evidence and should be guided by the circumstances of the project. back to top
Does SB 743 impact general plans that contain LOS standards? SB 743 "does not preclude the application of local general plan policies, zoning codes, conditions of approval, thresholds, or any other planning requirements pursuant to the police power or any other authority." (See Pub. Resources Code, § 21099(b)(4).) However, OPR has previously provided guidance on why LOS standards should not be included within general plans. (See OPR's General Plan Guidelines, Appendix B □ .) Even if a general plan contains an LOS standard and a project is found to exceed that standard, that conflict should not be analyzed under CEQA. CEQA is focused on planning conflicts that lead to environmental impacts. (The Highway 68 Coalition v. County of Monterey (2017) 14 Cal.App.5th 883; see, e.g., Appendix G, IX(b) [asking whether the project will "Cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect?").) Auto delay, on its own, is no longer an environmental impact under CEQA. (See Pub. Resources Code,§ 21099(b)(2).) back to top
Does SB 743 impact any other part of CEQA?
SB 743 will make it easier to use two CEQA exemptions for infill projects that can only be used when a project will not have significant transportation/traffic impacts. These are Public Resources Code section 21159.25's statutory exemption for housing projects in unincorporated areas and the Class 32 categorical exemption for infill projects within city limits. (See Pub. Resources Code,§ 21159.25,subd. (b)(5), CEQA Guidelines,§ 15332, subd. (d).) After July 1st, these analyses should be conducted using the VMT metric. Infill projects are much less likely to have transportation impacts under a VMT metric as opposed to an LOS metric.

Additionally, note that SB 743 also discusses impacts from parking, stating that "the adequacy of parking for a project shall not support a finding of significance." (See Pub. Resources Code,§ 21099(b)(3).) back to top

EXHIBIT EXHIBIT EXHIBIT HH
Protect Roseville Neighborhoods v. City of Roseville
Court of Appeal of California, Third Appellate District September 29, 2025, Opinion Filed
C101428
Reporter
2025 Cal. App. Unpub. LEXIS 6219 *; 2025 LX 407378; 2025 WL 2753821 PROTECT ROSEVILLE NEIGHBORHOODS et al.,
Plaintiffs and Appellants, v. CITY OF ROSEVILLE
et al, Defendants and Respondents; INTER-CAL
REAL ESTATE CORPORATION, Real Party in
Interest and Respondent.

Notice: NOT TO BE PUBLISHED IN OFFICIAL
REPORTS. CALIFORNIA RULES OF COURT,
RULE 8.1115(a), PROHIBITS COURTS AND

PARTIES FROM CITING OR RELYING ON

OPINIONS NOT CERTIFIED FOR PUBLICATION

OR ORDERED PUBLISHED, EXCEPT AS
SPECIFIED BY RULE 8.1115(b). THIS OPINION

HAS NOT BEEN CERTIFIED FOR PUBLICATION

OR ORDERED PUBLISHED FOR THE
PURPOSES OF RULE 8.1115.

Prior History: [*1] Superior Court of Placer
County, No. SCV0051108.

Counsel: Law Offices of Donald B. Mooney,
Donald B. Mooney, for Protect Roseville
Neighborhoods et al. Plaintiff and Appellant.

City of Roseville, Joseph Timothy Speaker, for City
of Roseville et al. Defendant and Respondent.

Remy Moose Manley, LLP, James G. Moose and
Christina Lee Berglund, for Inter-Cal Real Estate
Corporation : Real Party in Interest and
Respondent.

Judges: Duarte, J.; Mauro, Acting P. J., Renner, J.
concurred.

Opinion by: Duarte, J.

Opinion
This case involves the California Environmental
Quality Act (CEQA) (Pub. Resources Code, §
21000 et seq.),1 which seeks to ensure that public
agencies consider the environmental
consequences of the discretionary projects they
propose to carry out or approve. (Stockton Citizens
for Sensible Planning v. City of Stockton (2010) 48
Cal.4th 481, 488, 106 Cal. Rptr. 3d 858, 227 P.3d
416.) For policy reasons, the Legislature has
expressly exempted several categories of projects
from environmental review under CEQA, including
"Class 32," which comprises "in-fill" projects, i.e.,
development projects that occur within city limits
on no more than five acres substantially
surrounded by urban uses and that meet other
specified conditions. (Berkeley Hillside
Preservation v. City of Berkeley (2015) 60 Cal.4th
1086, 1092, 184 Cal. Rptr. 3d 643, 343 P.3d 834
(Berkeley Hillside); see Muzzy Ranch Co. v.

Solano County Airport Land Use Com. (2007) 41
Cal.4th 372, 380-381, 60 Cal. Rptr. 3d 247, 160
P.3d 116 [if a project is exempt from CEQA, no
further environmental review is necessary; the
public agency need only prepare and file a notice
of exemption].)
Protect Roseville Neighborhoods (Protect [*2]
Roseville) and Paseo Del Norte Homeowners
Association (collectively, plaintiffs)2 appeal from
the denial of their verified petition for a writ of
mandate, which challenged the approval of a
1 Undesignated statutory references are to the Public
Resources Code.
2 Protect Roseville is an unincorporated association with the "mission" to protect and enhance the environment and
community in the City of Roseville. Paseo Del Norte
Homeowners Association is a non-profit mutual benefit,
common interest development corporation. The members of these entities live, work, and/or recreate in the areas that will be impacted by the project at issue in this case.

Page 2 of 17 ends

commercial development project in northeast
Roseville that includes (among other things) the
construction of a 16,000 square foot Grocery
Outlet store and a tentative parcel map subdividing
an existing parcel into three separate lots (or
parcels). Plaintiffs contend the City of Roseville
and the City Council of the City of Roseville
(collectively, the City)3 failed to evaluate the entire project and provide an adequate project
description regarding the future development of
"Parcel 3," which, in the original project application, included the construction of a fast-food restaurant
with a drive-through.4 Plaintiffs argue that reversal
is required because although the immediate
commercial development of Parcel 3 was "omitted"
from the project, the subdivision of Parcel 3 was a
part of the approved project and "the whole of the
action," and therefore the City improperly
segmented environmental review for this
foreseeable use in violation of CEQA's prohibition
against "piecemealing." Plaintiffs further [*3]
contend the City erred in determining the project
was categorically exempt from CEQA under the infill (or Class 32) development exemption set forth in the CEQA Guidelines,5 which required (among
other things) a finding that the project would not
3 The defendants in this case are the City of Roseville and the City Council of the City of Roseville. The City of Roseville is the "lead agency" for purposes of the project. (See § 21067 [defining "lead agency" to mean "the public agency which has the principal responsibility for carrying out or approving a project which may have a significant effect upon the
environment"].) The city council was the legislative body responsible for approving or denying the project.
4 This restaurant is sometimes referred to as a quick-service restaurant (or QSR) with a drive-through. In this opinion, we refer to it as the fast-food restaurant. All references to a fastfood restaurant are to a fast-food restaurant with a drivethrough. 5 All references to "Guidelines" are to the CEQA Guidelines in title 14 of the California Code of Regulations, which implement the provisions of CEQA. (Cal. Code Regs., tit. 14, § 15000 et seq.) The Guidelines specify "classes" of projects that are categorically exempt from CEQA review, including Class 32, which consists of projects characterized as in-fill development meeting certain conditions. (Guidelines, § 15332; Pacific Palisades Residents Assn., Inc. v. City of Los Angeles (2023) 88 Cal.App.5th 1338, 1364, 305 Cal. Rptr. 3d 564 [the Class 32 categorical exemption is sometimes called "the in-fill development projects exemption"].)
result in any significant effects relating to traffic,
noise, air quality, or water quality. According to
plaintiffs, the project is subject to CEQA review
because it will have significant traffic-related safety impacts affecting area residents.

As we will explain, we disagree with plaintiffs'
contentions. Accordingly, we affirm the judgment.

FACTUAL AND PROCEDURAL BACKGROUND
The Project
The project involves the construction of a 16,000
square-foot Grocery Outlet store and a 4,600
square-foot freestanding pad building for retail
stores. The project also includes a tentative parcel
map to subdivide the existing parcel into three
separate lots, known as Parcels 1, 2, and 3. The
Grocery Outlet will be located on Parcel 1 and the
freestanding pad building will be located on Parcel

2. Although the owner of the project—real party in
interest, Inter-Cal Real Estate Corporation (InterCal)—originally proposed to build a fast-food restaurant on Parcel 3, [*4] that proposal was
withdrawn (via a modified permit application) after
City staff determined that the findings required to
approve permits for such use (including a
conditional use permit) could not be made and the
project would not qualify for the in-fill development
exemption with that proposed use. As a result, the
proposed project included an undeveloped parcel
(Parcel 3), which could ultimately be developed for
a variety of commercial uses (e.g., food and
beverage retail sales, bar, pet store) in accordance
with the applicable community commercial zoning
designation. However, any future development of
Parcel 3 would require a new design review permit
that evaluated the site plan and building elevations.

If that future development included the construction
of a fast-food restaurant, a conditional use permit
would also be required "due to the proximity [of the
restaurant] to residential uses." Neither of these
permits can be issued without further CEQA
review.

The Project Site
2025 Cal. App. Unpub. LEXIS 6219, *2

Page 3 of 17 ends

The North Roseville Specific Plan (NRSP) was
adopted in 1997 and consists of a three-phase,
comprehensive specific plan spanning more than
1,500 acres of land. It includes five distinct
neighborhoods (A, B, C, [*5] D, E), with a mix of
residential neighborhoods, schools, parks, and
supporting land uses. An EIR was prepared for the
NRSP in 1997 for Phase 1. It was subsequently
augmented in 1999 and 2000 with EIRs for Phases
2 and 3.

The project site—1751 Pleasant Grove
Boulevard—is located on the northern boundary of
neighborhood D. The site is approximately 3.1
acres on a parcel known as WW-40, which has a
land-use designation of community commercial.

The NRSP's intended uses for WW-40 are "smaller
retail shops and services targeted to the
surrounding neighborhoods" and/or professional
and service office uses, such as travel, insurance
and real estate services. Section 19.12.020 of the
Roseville Municipal Code lists the various
permitted land uses for areas zoned as community
commercial. Among the more than 50 allowable
land uses are a fast-food restaurant, food and
beverage retail sales, full service eating and
drinking establishments, retail sales and services,
and lodging services. (Roseville Municipal Code §

19.12.020.)6
The neighboring parcel to the east of the project
site, parcel WW-41, includes a single-family
residential subdivision, the 125-unit Paseo Del
Norte development, which has a land-use
designation of medium-density residential.7
The
proposed project includes several [*6] pedestrian
pathways and connections, including a pathway
that connects parcel WW-41 (the subdivision) to
6 We granted the City and real party in interest's (Inter-Cal) request to take judicial notice of this ordinance.
7 In 2006, the land-use map and text of the NRSP was
amended to change the zoning of parcel WW-41 (the Paseo subdivision) from a land-use designation of community
commercial to medium-density residential. In approving these changes, the city council found that medium-density
residential use was "consistent with the adopted City of Roseville General Plan" and was "conducive to public health, safety, and welfare and consistent with the land use practices of the City."
parcel WW-40 (the project site), as it was expected
that residents of the subdivision would use the
goods and services provided by the commercial
development of the site.

As for the other area surrounding the project site,
there are open space parcels containing the
Western Area Power Administration power line
corridor to the south, an existing CVS Pharmacy to
the west, and an undeveloped community
commercial parcel across Pleasant Grove
Boulevard to the north.

In 2020, the City of Roseville adopted the 2035
General Plan. Of relevance here, the transportation
section analyzed the effects to the transportation
system, which included an updated traffic analysis
that considered a vehicle miles traveled (VMT)
metric in accordance with newly enacted legislation
surrounding traffic impacts on CEQA review. (See
Guidelines, § 15064.3, subd. (a) [VMT, which
"refers to the amount and distance of automobile
travel attributable to a project," is generally "the
most appropriate measure of transportation
impacts"].) The portion of the transportation section
addressing VMT explained that future projects
consistent with the 2035 [*7] General Plan would
not require further VMT analysis, "pursuant to the
tiering provisions of CEQA."
Project Application
In June 2022, Inter-Cal applied for a design review
permit and a tentative parcel map subdividing WW40 into three lots (or parcels).8 Inter-Cal proposed
that Parcel 1 (1.9 acres) would be a 16,000
square-foot Grocery Outlet store, Parcel 2 (0.6
acres) would be a 4,600 square-foot freestanding
pad building for retail stores, and Parcel 3 (0.6
acres) would be a 2,600 square foot fast-food
restaurant. Inter-Cal's application included traffic
study and a noise study. The traffic study,
completed by Fehr & Peers (a national consulting
firm specializing in transportation planning and
engineering), analyzed the proposed project's
impacts on turning movements and traffic queueing
8 The application was submitted by Norr Architects on behalf of Inter-Cal.
2025 Cal. App. Unpub. LEXIS 6219, *4

Page 4 of 17 ends

on the existing roadways. While the traffic study
considered the existence of a fast-food restaurant
on Parcel 3, the analysis was undertaken with the
understanding that the construction of such a
restaurant was not part of Inter-Cal's application for
a design review permit. Thus, it was understood
that a supplemental analysis of the layout and
traffic circulation would be required if Inter-Cal
applied [*8] for a permit to build a fast-food
restaurant on Parcel 3. The study provided three
recommendations to assist with project access and
on-site circulation, but it did not independently
analyze VMT. Because the noise study is not
relevant to the issues raised on appeal, we note
only that its analysis considered a fast-food
restaurant and concluded that the resulting noise
levels would comply with the "City of Roseville
noise level standards."
In February and March 2023, public meetings were
held for the purpose of allowing community
members to provide feedback about the proposed
project. At these meetings, residents of the
subdivision expressed concerns about traffic safety
related to additional vehicles using Camino Real
Way—a private road that bisects the subdivision
and connects it to the adjacent project site.

Further, during the time period between the public
meetings, it was discovered that there was an
easement that allowed residents of the subdivision
to access the project site but would not allow nonresidents to use the easement to enter the subdivision via Camino Real Way.

In early May 2023, City staff issued a report
addressing the project application and the trafficrelated [*9] safety concerns raised by area residents during the public meetings. Although the
report expressly stated that there would be no
development of Parcel 3, it also included language
in Condition of Approval #4 indicating that a fastfood restaurant would be built on that parcel. City staff also prepared a memorandum for the
planning commission that responded to a letter
submitted by Protect Roseville, which relied on the
traffic and noise studies to argue that the City
could not rely on in-fill development exemption due
to significant effects to traffic and noise that would
be caused by the "unusual circumstance" of
placing a fast-food restaurant adjacent to an
existing neighborhood. The City staff memorandum
explained that the traffic study prepared by Fehr &
Peers contemplated a "worst case scenario"
because it was conducted before the construction
of a fast-food restaurant on Parcel 3 was
withdrawn from the project application, and only
analyzed short-term effects, such as turning
movements and queuing, which are not impacts
under CEQA. The memorandum further explained
that VMT was the required transportation analysis
under CEQA, and that no further environmental
review of VMT was [*10] necessary because the
proposed project was consistent with the 2035
General Plan land-use designation (community
commercial), and therefore consistent with the
citywide analysis of VMT included in the EIR for
the 2035 General Plan.

On the same day as the City staff report and
memorandum were issued, the planning
commission held a public hearing on the proposed
project. During that hearing, there was evidence
that no development was currently planned for
Parcel 3, as the proposal to build a fast-food
restaurant was withdrawn from the project
application, and that the construction of any such
restaurant in the future would require a conditional
use permit. In addition, residents of the subdivision
raised concerns about traffic safety, parking, noise,
and emergency access related to an increase in
vehicles using Camino Real Way as a result of the
project. Traffic safety concerns related to an
increase in use of the access easement were also
raised.

Planning Commission and City Council Review
At the conclusion of the hearing, the planning
commission unanimously approved the project,
subject to numerous conditions, including a
requirement that Inter-Cal install a speed bump on
Camino Real [*11] Way and a sign indicating that
the road was private and could only be used by
residents of the subdivision. In approving the
project, the planning commission determined that it
was categorically exempt from CEQA's
environmental review requirements under
2025 Cal. App. Unpub. LEXIS 6219, *7

Page 5 of 17 ends

Guidelines section 15332, which concerns the
development of in-fill projects. As noted ante, "infill" refers to construction in areas that are already largely developed. (See Guidelines, § 15332, subd.
(b) [among other requirements, projects subject to
the in-fill exemption must be "substantially
surrounded by urban uses"].) Here, it is not
disputed that the project site is located in an area
surrounded by urban uses.

In mid-May 2023, Protect Roseville appealed the
planning commission's decision to the city council,
which focused on concerns related to the
development of a fast-food restaurant on Parcel 3.

Among other things, Protect Roseville again
argued that the in-fill development exemption did
not apply due to "unusual circumstances" because
there would be significant transportation impacts
from increased traffic as a result of the
development of a fast-food restaurant on Parcel 3.

In July 2023, plaintiffs sent a letter to the city
council highlighting their specific concerns
with [*12] the proposed project. Among other
things, they claimed environmental review under
CEQA was improperly piecemealed because there
was no analysis of the future development of
Parcel 3, the project description was inadequate
because Parcel 3 was part of the project but City
staff claimed it was removed from the project, and
the project did not qualify for the in-fill development exemption because the construction of a fast-food
restaurant adjacent to an existing residential
subdivision constituted an "unusual circumstance"
precluding application of the exemption.

City staff prepared a written response to the
appeal; it stated that while it was not reasonably
foreseeable Parcel 3 would be developed with a
fast-food restaurant because "staff could not
support such a proposal," it was reasonably
foreseeable that the parcel could be developed
with "other use types" allowed for a parcel zoned
as community commercial. City staff explained that
because the project application did not include a
specific proposal for the development of Parcel 3,
discussion of this parcel was included as part of
the tentative parcel map evaluation rather that the
design review permit evaluation, which (in the
City's [*13] view) did not result in improper
piecemealing of environmental review.

City staff went on to explain as follows:
"Programmatic evaluation of site development
consistent with [community commercial] land use
designation was already completed as part of the
[NRSP EIR]. The project is located on Specific
Plan Parcel WW-40 in the [NRSP]. The [EIR]
analyzed the impacts of full development of the
entirety of Parcel WW-40 with commercial uses,
including the project site. The creation of an
additional parcel within the same site does not
require further CEQA review, as there are no
specific or peculiar project-level effects of a
commercial parcel map. Furthermore, the EIR
assumed Community Commercial parcels would
develop at a Floor Area Ratio of 0.30, which for
this 3.1-acre project site would be approximately
40,500 square feet of building area. The proposed
project includes approximately 20,600 square feet
of building area, and thus is significantly less
intensive than the assumptions of the
programmatic analysis.
"Development of commercial parcels commonly
happens in phases over time, and often includes
remainder parcels. In 2010, as part of the
application for the CVS developed on the
western [*14] portion of parcel WW-40, the CVS
project included a parcel map which created an
undeveloped eastern parcel. Like the current
project, the CEQA review for the CVS project
focused on the potential effects of developing the
CVS and did not provide further discussion of the
remainder parcel because there was no projectlevel proposal to evaluate. Thirteen years later, the Grocery Outlet is proposed and CEQA review has
been completed for the project. Parcel 3 is a
remainder parcel with no specific development
proposal at this time, and therefore no project
specific analysis is possible for Parcel 3; the
programmatic CEQA analysis of the EIR is
sufficient. It is certainly not prudent to analyze
Parcel 3 as a future drive-through restaurant,
which staff explicitly told the applicant they could
not support."
As for whether there were "unusual circumstances"
precluding application of the in-fill development
exemption, the City staff memorandum stated:
2025 Cal. App. Unpub. LEXIS 6219, *11

Page 6 of 17 ends

"The appellant [claims] that there is an unusual
circumstance in the project that does not allow for
a CEQA infill exemption. They allege that '[i]n the
present case, the unusual circumstance is the
placement of a fast-food restaurant adjacent [*15]
to an existing neighborhood.' As discussed above,
there is clearly no fast-food restaurant proposed or
a reasonable possibility that one is proposed, given
that there is no Conditional Use Permit associated
with the project and no drive-through is shown on
any of the project plans. There are no unusual
circumstances as described by the appellant
associated with this Project."
As for the purported inconsistent (or inadequate)
project description, City staff acknowledged that its
May 2023 staff report (prepared for the hearing
before the planning commission) erroneously
indicated in Condition of Approval #4 that a fastfood restaurant would be built on Parcel 3. City staff explained that this error did not create an
unstable project description, as "[t]he commission
staff report, project plans, memo to planning
commission, planning commission presentation
and city council staff report are clear on the scope
of the project," which includes a request for a
design review permit to construct two buildings—a
16,000 square-foot grocery store (Grocery Outlet)
and a 4,600 square-foot freestanding pad
building—and a request for a tentative parcel map
to subdivide the existing parcel into three [*16] lots
(or parcels).

Prior to the appeal hearing, City staff prepared a
memorandum for the city council, which
recommended denying plaintiffs' appeal, adopting
various findings of fact, and imposing numerous
conditions of approval. As for the traffic-related
safety concerns raised by area residents, the City
staff memorandum stated: "Residents' concerns in
relation to traffic were largely around access to the
Paseo del Norte site from the commercial site. The
concern was that additional vehicles will use the
private road, Camino Real Way, that bisects the
community and will have safety impacts to children
in the area as well as parking impacts. These
concerns were also brought up at the two
neighborhood meetings held for the project. While
staff does not believe that Camino Real Way is a
likely egress route for customers of the commercial
center, conditions of approval 10a and 28 were
added before the Planning Commission meeting to
address these concerns and further deter use of
the private road by non-residents of the
[homeowners association]." The conditions of
approval referenced in the memorandum included
the requirement that Inter-Cal install a speed bump
on Camino Real Way and a [*17] sign indicating
that the road is private and cannot be used by nonresidents.

Project Approval and Notice of Exemption
In July 2023, after a hearing in which area
residents raised concerns related to traffic, the city
council unanimously adopted Resolution No. 23-
309, denying the appeal submitted by Protect
Roseville and approving the project with numerous
conditions of approval. The approval was subject
to several amendments, including (as relevant
here) an amendment clarifying that any future
development of Parcel 3 would require a new
design review permit, and an amendment
removing the reference to a fast-food restaurant
that appeared in Condition of Approval #4.9
The next day, the City of Roseville filed a notice of
exemption under section 21152, stating that the
project was categorically exempt from CEQA's
environmental review requirements pursuant to the
in-fill development exemption under Guidelines
section 15332. The notice of exemption described
the project as follows: "On July 19, 2023, the City
Council denied the appeal of the Planning
Commission's decision and approved [*18] a
Design Review Permit to construct a 16,000
9 Condition of Approval #4 stated: "The project shall be addressed as 1751 Pleasant Grove Bl. The address for
proposed Parcel 3, and building 'QSR' [(i.e., fast-food restaurant)] on said parcel, shall be addressed 1741 Pleasant Grove Dr. Parcel 2, and the building 'SHOPS' on said parcel, shall be addressed as 1749 Pleasant Grove Bl. The address for Parcel l, and the GROCERY OUTLET building on said
parcel, shall be 1755 Pleasant Grove Bl. All projects with multi-tenants or buildings must submit a site plan with building footprint(s) to the Development Services Department
(Business Services-Addressing) for building/suite addressing. (Business Services)." (Italics added.)
2025 Cal. App. Unpub. LEXIS 6219, *14

Page 7 of 17 ends

square-foot grocery building and a 4,600 squarefoot freestanding pad building. The request also included a Tentative Parcel Map to subdivide the
existing parcel into three (3) lots."
After identifying the five criteria that must be met in order for the in-fill development exemption to
apply, the notice of exemption stated: "The project
meets these criteria for the following reasons and
is therefore exempt. (a) The General Plan land use
designation of Community Commercial and the
Zoning designation of Community Commercial
allows for this commercial development. (b) The
total project site is 3.1 acres and is substantially
surrounded with urban development, including a
commercial use to west and a residential
community to the east. (c) The project site has
been previously disturbed including, discing and
paving, and does not contain habitat for
endangered, rare or threatened species. (d) The
proposed use will not have significant effects on
traffic (as provided in the traffic study), noise (as
provided in the noise study), air quality (due to
minimum screening thresholds per the PCAPCD),
or water quality. (e) Based on a review by the
City's [*19] utility departments, the site can be
adequately served by all required utilities and
public services allocated to the site."
Verified Petition for Writ of Mandate and Complaint
In August 2023, plaintiffs filed a verified petition for writ of mandate and complaint for declaratory and
injunctive relief against the City, which sought
(among other things) an order vacating the City's
approval of the project. Plaintiffs alleged one cause
of action under CEQA, which was predicated on
the City's impermissible piecemeal environmental
review (i.e., the City's failure to evaluate the "whole of the action" by failing to conduct environmental
review for the development of Parcel 3 and the
reasonably foreseeable uses of that parcel), the
City's failure to adequately describe the proposed
project by providing an inconsistent and incomplete
project description regarding Parcel 3, and the
City's erroneous determination that the project was
categorically exempt from CEQA under the in-fill
development exemption.

As for the in-fill development exemption, plaintiffs
asserted that it did not apply due to the "unusual
circumstances" exception because the proposed
project would result in "significant effects [*20] to
noise and traffic," "[g]iven the piecemeal
environmental review and the ambiguous and
uncertain Project description regarding whether a
[fast-food restaurant] is part of the Project." In this regard, the theory expressed in the petition differed
from that expressed during the administrative
proceedings, during which, as outlined ante,
plaintiffs asserted that the unusual circumstances
were the placement of a fast-food restaurant
adjacent to a residential subdivision. In their
briefing in the trial court, plaintiffs suggested that
the unusual circumstance was the "significant
impact to traffic safety on the private road that
passes through Paseo del Norte" and argued that
"[t]he project also involves unusual circumstances
as the City states that Parcel 3 is not part of the
Project but then includes approvals that benefit the
development of Parcel 3." In their reply brief,
plaintiffs offered that "[a] subdivision with a private road that provides ingress and egress to the
commercial center constitutes an unusual
circumstance in this Project."
Trial Court's Ruling and Appeal
In May 2024, after a hearing, the trial court issued
a detailed written order denying plaintiffs' verified
petition [*21] for writ of mandate. Plaintiffs timely
appealed. The matter was fully briefed and
assigned to this panel in April 2025.

DISCUSSION
I
Description of the Project and Piecemeal
Environmental Review
Plaintiffs argue the City inadequately described the
project by failing to account for future development
that is a reasonably foreseeable consequence
thereof-construction of a fast-food restaurant on
Parcel 3. As a result, plaintiffs claim the City
2025 Cal. App. Unpub. LEXIS 6219, *18

Page 8 of 17 ends

improperly segmented environmental review of the
project by not evaluating "the whole of the action,"
which (in their view) includes the future
development of Parcel 3. In other words, plaintiffs
argue the City impermissibly piecemealed the
approval of the project by failing to analyze the
reasonably foreseeable future development that
would occur as a consequence of the project.

A. Relevant Legal Principles and Standard of
Review
"CEQA is a comprehensive scheme designed to
provide long-term protection to the environment."
(Mountain Lion Foundation v. Fish & Game Com.
(1997) 16 Cal.4th 105, 112, 65 Cal. Rptr. 2d 580,
939 P.2d 1280.) It "was enacted to advance four
related purposes: to (1) inform the government and
public about a proposed activity's potential
environmental impacts; (2) identify ways to reduce,
or avoid, environmental damage; (3) prevent
environmental [*22] damage by requiring project
changes via alternatives or mitigation measures
when feasible; and (4) disclose to the public the
rationale for governmental approval of a project
that may significantly impact the environment."
(California Building Industry Assn. v. Bay Area Air
Quality Management Dist. (2015) 62 Cal.4th 369,
382, 196 Cal. Rptr. 3d 94, 362 P.3d 792; see also
Tomlinson v. County of Alameda (2012) 54 Cal.4th
281, 285-286, 142 Cal. Rptr. 3d 539, 278 P.3d
803.)
"In enacting CEQA, the Legislature declared its
intention that all public agencies responsible for
regulating activities affecting the environment give
prime consideration to preventing environmental
damage when carrying out their duties. [Citations.]
CEQA is to be interpreted 'to afford the fullest
possible protection to the environment within the
reasonable scope of the statutory language.'"
(Mountain Lion Foundation v. Fish & Game Com.,
supra, 16 Cal.4th at p. 112; see Friends of the Eel
River v. North Coast Railroad Authority (2017) 3
Cal.5th 677, 711, 220 Cal. Rptr. 3d 812, 399 P.3d
37 ["CEQA embodies a central state policy to
require state and local governmental entities to
perform their duties 'so that major consideration is
given to preventing environmental damage'"].)
"CEQA prescribes how governmental decisions will
be made whenever an agency undertakes,
approves, or funds a project." (Protecting Our
Water and Environmental Resources v. County of
Stanislaus (2020) 10 Cal.5th 479, 488, 268 Cal.

Rptr. 3d 148, 472 P.3d 459 (Protecting Our
Water).) With narrow exceptions, CEQA requires
an Environmental Impact Report (EIR) whenever
"a public agency proposes to approve or to carry
out a project that may have a significant effect on
the environment." (Laurel Heights Improvement
Assn. v. Regents of Univ. of Cal. (1988) 47 Cal.3d
376, 390 (Laurel Heightsal.3d 376, 390, 253 Cal.

Rptr. 426, 764 P.2d 278 (Laurel Heights); see id. at
pp. 390, 392 [at the "heart of CEQA" is the
requirement [*23] that public agencies prepare an
EIR for any "project" that "may have a significant
effect on the environment"].) "The purpose of an
EIR is to inform the agency and the public, in
detail, about the effect the project is likely to have
on the environment and the ways available to
minimize that impact." (Friends of Sierra Madre v.

City of Sierra Madre (2001) 25 Cal.4th 165, 184-
185, 105 Cal. Rptr. 2d 214, 19 P.3d 567; see
Neighbors for Smart Rail v. Exposition Metro Line
Construction Authority (2013) 57 Cal.4th 439, 447,
160 Cal. Rptr. 3d 1, 304 P.3d 499 ["The
fundamental goal of an EIR is to inform decision
makers and the public of any significant adverse
effects a project is likely to have on the physical
environment"].)10
"'Project' is a term of art. 'CEQA broadly defines a
"project" as "an activity which may cause either a
direct physical change in the environment, or a
reasonably foreseeable indirect physical change in
the environment, and . . . [¶] . . . [¶] . . . that
involves the issuance to a person of a lease,
10 An EIR "'must include a description of the proposed project and its environmental setting and discussions of (1) the possible environmental effects of the project, (2) feasible measures to mitigate any significant, adverse environmental effects of the project, (3) the comparative environmental effects of a range of reasonable alternatives to the proposed project, including a 'no project' alternative, and (4) the cumulative impact of the project's various environmental effects.'" (County of Butte v. Department of Water Resources (2022) 13 Cal.5th 612, 627, 296 Cal. Rptr. 3d 649, 514 P.3d 234.)
2025 Cal. App. Unpub. LEXIS 6219, *21

Page 9 of 17 ends

permit, license, certificate, or other entitlement for
use by one or more public agencies." [Citation.] [¶]
The statutory definition is augmented by the
Guidelines [citation], which define a "project' as
"the whole of an action, which has a potential for
resulting in either a direct physical change in the
environment, or a reasonably foreseeable indirect
physical change in the environment . . . ."'"
(Banning Ranch Conservancy v. City of Newport
Beach (2012) 211 Cal.App.4th 1209, 1220, 150
Cal. Rptr. 3d 591 (Banning Ranch); Aptos Council
v. County of Santa Cruz (2017) 10 Cal.App.5th
266, 277, 216 Cal. Rptr. 3d 142; see County of
Amador v. City of Plymouth (2007) 149
Cal.App.4th 1089, 1099, 1104, 1100, 57 Cal. Rptr.
3d 704 & fn. 10 [the [*24] term "project" refers to
"'the whole of an action'" affecting the environment
and "'is given a broad interpretation in order to
maximize protection of the environment'"].)
Environmental review of a project under CEQA
must encompass the whole of an action affecting
the environment. (Guidelines, § 15378, subd. (a);
Rio Vista Farm Bureau Center v. County of Solano
(1992) 5 Cal.App.4th 351, 369-370, 7 Cal. Rptr. 2d
307.) "'CEQA forbids "piecemeal" review of the
significant environmental impacts of a project.'"
(Banning Ranch, supra, 211 Cal.App.4th at p.
1222; Planning & Conservation League v.

Department of Water Resources (2024) 98
Cal.App.5th 726, 751, 317 Cal. Rptr. 3d 53; see
also McCann v. City of San Diego (2021) 70
Cal.App.5th 51, 84, 285 Cal. Rptr. 3d 175
[improper piecemealing occurs when "an agency . .
. split[s] a project into separate segments to avoid
consideration of the cumulative environmental
impacts of a project"].) Our Supreme Court
established a piecemealing test in Laurel Heights
as follows: A public agency must include an
analysis of the environmental effects of future
expansion or other action if: "(1) it is a reasonably
foreseeable consequence of the initial project; and
(2) the future expansion or action will be significant
in that it will likely change the scope or nature of
the initial project or its environmental effects."
(Laurel Heights, supra, 47 Cal.3d at p. 396 [absent
these two circumstances, the future expansion
need not be considered].) As explained by our high
court: "This standard is consistent with the principle
that 'environmental considerations do not
become [*25] submerged by chopping a large
project into many little ones — each with a minimal
potential impact on the environment — which
cumulatively may have disastrous consequences.'
[Citation.] The standard also gives due deference
to the fact that premature environmental analysis
may be meaningless and financially wasteful."
(Ibid.)
"The project definition is the starting point of a
piecemealing challenge, not the finish line. The
whole question is whether the project definition is
correct." (Banning Ranch, supra, 211 Cal.App.4th
at p. 1223.) A project description must be accurate,
stable, and finite. (City of Santee v. County of San
Diego (1989) 214 Cal.App.3d 1438, 1454, 263 Cal.

Rptr. 340.) If the project description is inadequate,
the environmental impact analysis likely will be
inadequate, too. (San Joaquin Raptor/Wildlife
Rescue Center v. County of Stanislaus (1994) 27
Cal.App.4th 713, 734, 32 Cal. Rptr. 2d 704; see
McQueen v. Board of Directors (1988) 202
Cal.App.3d 1136, 1143, 249 Cal. Rptr. 439 ["An
accurate project description is necessary for an
intelligent evaluation of the potential environmental
effects of a proposed activity"], disapproved of on
other grounds in Western States Petroleum Assn.
v. Superior Court (1995) 9 Cal.4th 559, 570, 38
Cal. Rptr. 2d 139, 888 P.2d 1268 & fn. 2;
McQueen, at p. 1144 ["A narrow view of a project
could result in the fallacy of division [citation], that is, overlooking its cumulative impact by separately
focusing on isolated parts of the whole"].)
Improper piecemealing occurs when the purpose
of the proposed project is to be the first step
toward future development but the public agency
fails to conduct environmental [*26] review for that
development/expansion. (Banning Ranch, supra,
211 Cal.App.4th at p. 1223; see, e.g., Laurel
Heights, supra, 47 Cal.3d at p. 398 [EIR set aside
for failing to analyze impacts of second phase of
multi-phased project where university planned to
occupy entire building eventually]; City of Carmelby-the-Sea v. Board of Supervisors (1986) 183 Cal.App.3d 229, 244, 227 Cal. Rptr. 899 [county
rezoned land as "a necessary first step to approval
of a specific development project"]; City of Antioch
2025 Cal. App. Unpub. LEXIS 6219, *23

Page 10 of 17 ends

v. City Council (1986) 187 Cal.App.3d 1325, 1337,
232 Cal. Rptr. 507 [negative declaration wrongly
issued; "the sole reason" city approved road and
sewer construction was "to provide a catalyst for
further development"].) There may also be
improper piecemealing when the proposed project
legally compels or practically presumes completion
of another action. (Banning Ranch, at p. 1223; see,
e.g., Nelson v. County of Kern (2010) 190
Cal.App.4th 252, 272, 118 Cal. Rptr. 3d 736 [EIR
for reclamation plan should have included mining
operations that necessitated it]; San Joaquin
Raptor/Wildlife Rescue Center v. County of
Stanislaus, supra, 27 Cal.App.4th at p. 732 [EIR for
residential development should have included
sewer expansion that was a "crucial element[ ]" of
development]; Plan for Arcadia, Inc. v. City Council
of Arcadia (1974) 42 Cal.App.3d 712, 726, 117
Cal. Rptr. 96 [shopping center, parking lot, and
adjacent road widening "should be regarded as a
single project"].)
By contrast, no improper piecemealing occurs,
meaning two projects may properly undergo
separate environmental review by a public agency,
"when the projects have different proponents,
serve different purposes, or can be implemented
independently." (Banning Ranch, at p. 1223; see,
e.g., Communities for a Better Environment v. City
of Richmond (2010) 184 Cal.App.4th 70, 99, 108
Cal. Rptr. 3d 478 [the upgrade of a refinery [*27]
and construction of pipeline exporting excess
hydrogen were "independently justified separate
projects with different project proponents"];
Planning & Conservation League v. Castaic Lake
Water Agency (2009) 180 Cal.App.4th 210, 237,
103 Cal. Rptr. 3d 124 [water transfer had
"significant independent or local utility" from a
broader water supply agreement, and would be
implemented with or without the supply
agreement]; Sierra Club v. West Side Irrigation
Dist. (2005) 128 Cal.App.4th 690, 699-700, 27 Cal.

Rptr. 3d 223 [two water rights assignments to city
were "approved by different independent agencies"
and "could be implemented independently of each
other"]; Plan for Arcadia, Inc. v. City Council of
Arcadia, supra, 42 Cal.App.3d at p. 724 [shopping
center EIR could exclude road work which the city
had "long before" decided would be needed due to
the construction of a new freeway].)
We independently determine whether a public
agency reviewed a proposed project in piecemeal
fashion. (Banning Ranch, supra, 211 Cal.App.4th
at p. 1224.)
B. Analysis
We see no improper segmentation, or
piecemealing, of environmental review in violation
of CEQA here. Our first question is whether the
construction of a fast-food restaurant on Parcel 3
of the project site is "a reasonably foreseeable
consequence of the initial project." (Laurel Heights,
supra, 47 Cal.3d at p. 396, italics added.) As we
have discussed, the approved project includes the
subdivision of an existing parcel (with a land-use
designation of community commercial) into three
separate lots (or parcels), and the
construction [*28] of a 16,000 square-foot Grocery
Outlet store on Parcel 1, the construction of a
4,600 square-foot freestanding pad building for
retail stores on Parcel 2, and no development on
Parcel 3. Although it is anticipated that Parcel 3 will be developed in the future for some commercial
use, it is not clear that any development would
involve the construction of a fast-food restaurant.

On this record, the construction of this type of
restaurant on Parcel 3 is entirely speculative.

Indeed, the proposal to build such a restaurant was
withdrawn by the owner of the project after City
staff determined that the findings required to
approve such use could not be made.

We find unpersuasive plaintiffs' contention that the
City's failure to conduct environmental review for a
fast-food restaurant on Parcel 3 violated CEQA's
prohibition against piecemealing. The record does
not support the conclusion that this use of Parcel 3
is a reasonably foreseeable consequence of the
project under review. The development of Parcels
1 and 2 are not the first step towards the
development of Parcel 3, let alone the construction
of a fast-food restaurant on that parcel. Nor does
the approved development of Parcels 1 and [*29]
2 "legally compel" or "practically presume" the
development of a fast-food restaurant or any other
commercial establishment on Parcel 3, such that
the development of all three parcels should be
2025 Cal. App. Unpub. LEXIS 6219, *26

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