Elk Grove City Council
November 12, 2025

regarded as a single project. The construction of a
fast-food restaurant on Parcel 3 is not a crucial
functional element or integral part of the
development of Parcels 1 and 2 such that, without
it, the construction of the commercial buildings on
those parcels could not proceed.

In our view, the circumstances here are analogous
to cases rejecting piecemealing claims on the
ground that future actions were too speculative.
(See, e.g., Berkeley Keep Jets Over the Bay Com.
v. Board of Port Cmrs. (2001) 91 Cal.App.4th
1344, 1361, 111 Cal. Rptr. 2d 598 [airport EIR
could omit future projects that "existed only as
concepts in long-range plans that were subject to
constant revision"]; National Parks and
Conservation Assn. v. County of Riverside (1996)
42 Cal.App.4th 1505, 1518-1519, 50 Cal. Rptr. 2d
339 [landfill EIR could omit detailed analysis of
processing plants because "it is not known where
[the plants] will be situated and who will be
operating them"]; Del Mar Terrace Conservancy,
Inc. v. City Council (1992) 10 Cal.App.4th 712,
736-737, 12 Cal. Rptr. 2d 785 [highway EIR could
omit detailed analysis of "anticipated," but "still
contingent," expansion], disapproved on another
ground in Western States Petroleum Assn. v.

Superior Court, supra, 9 Cal.4th at p. 576, fn. 6.)
Plaintiffs, for their part, have not persuasively
articulated how and why the development of Parcel
3 cannot be implemented independently
from [*30] the development of Parcels 1 and 2. In
other words, plaintiffs have not shown why the
development of Parcels 1 and 2 may not properly
undergo separate environmental review under
CEQA.11 In any event, even assuming that the first
11 Contrary to plaintiffs' contention, Laurel Heights does not compel a finding that the future development of a fast-food restaurant on Parcel 3 is a reasonably foreseeable
consequence of the approved project. The circumstances
presented here are distinguishable from the situation in Laurel Heights. The project in Laurel Heights was defined in the EIR as "'mov[ing] the School of Pharmacy basic science research units from the [University of California, San Francisco (UCSF)] Parnassus campus to Laurel Heights.'" (Laurel Heights, supra, 47 Cal.3d at pp. 389, 393.) The building at Laurel Heights (purchased by the Regents of the University of California in 1985) consisted of approximately 354,000 square feet, of which only 100,000 was then available for relocation of the prong of the Laurel Heights piecemealing test has
been satisfied, plaintiffs, as we next explain, have
failed to demonstrate that the second prong has
been met.

Plaintiffs have made no effort to show that the
future development of Parcel 3 will be significant in
that it will likely change the scope or nature of the
development of Parcels 1 and 2 or the
environmental effects from that development.
(Laurel Heights, supra, 47 Cal.3d at p. 396.) In
their opening brief, plaintiffs do not provide any
legal analysis directly addressing this prong of the
Laurel Heights test, including any explanation as to
how the future development of Parcel 3 will likely
change the environmental effects of the initial
project, which is the development of Parcels 1 and

2.12 And, in any event, the record supports the
UCSF School of Pharmacy research units. The rest of the building was occupied by the California Department of
Transportation under a lease that was to expire in 1990, with an option for an additional five years. (Id. at p. 393.) The EIR did not discuss the additional environmental effects, if any, that would result from UCSF's use of the remaining 254,000 square feet when it becomes available. (Ibid.)
In Laurel Heights, evidence that future expansion was
"reasonably foreseeable" included an acknowledgment in the draft EIR that UCSF would occupy the entire facility when the remaining 254,000 square feet became available. (Laurel Heights, supra, 47 Cal.3d at p. 396, see also pp. 393, 397.) UCSF's plans were sufficiently definite that it estimated the number of faculty, staff, and students who would occupy the building before and after the expansion. (Id. at p. 396.) The final EIR also referred to the future expansion as a certainty, as did newsletters, minutes of the planning committee, and correspondence between the pharmacy dean and the
chancellor. These documents also described with specificity how the additional space would be used. (Id. at p. 397.) The Laurel Heights court concluded: "In short, there is telling evidence that [UCSF], by the time it prepared the EIR, had either made decisions, or formulated reasonably definite proposals as to future uses of the building. At a minimum, it is clear that the further expansion and the general types of future activity at the facility are reasonably foreseeable." (Ibid.) In reaching this conclusion, the court specifically noted that "[t]his is not the type of situation where it is unclear as to whether a parcel of land will be developed or as to whether activity will commence." (Id. at p. 396, italics added [explaining that there was "no doubt . . . there will be future use"].)
12 In the introduction section of their reply brief, plaintiffs assert, without further elaboration or explanation, as follows:
2025 Cal. App. Unpub. LEXIS 6219, *29

conclusion that any future commercial
development of Parcel 3 will not change the scope
or nature of the environmental effects from [*31]
the development of Parcels 1 and 2. As City staff
explained in response to the appeal of the planning
commission's decision to approve the project:
"Programmatic evaluation of site development
consistent with [community commercial zoning]
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."
Contrary to [*32] plaintiffs' suggestion, Citizens
Assn. for Sensible Development of Bishop Area v.

County of Inyo (1985) 172 Cal.App.3d 151, 217
Cal. Rptr. 893, does not support a different result.

There, the public agency approved a proposed
shopping center development by dividing two
related portions of the project—(1) a general plan
amendment and zone reclassification, and (2) a
tentative tract map approval and road
abandonment—into two projects. The agency then
environmentally reviewed the "'two projects'"
separately and adopted separate negative
declarations (no EIR required) for each. (Id. at pp.
"Contrary to Respondents' assertions and arguments the
development of Parcel 3 is a reasonably foreseeable
consequence of the initial project and the future development of Parcel 3 will likely change the scope and nature of the initial project and its environmental effects." (Italics added.) We need not and do not consider this undeveloped argument. (Keyes v.

Bowen (2010) 189 Cal.App.4th 647, 655-656, 117 Cal. Rptr. 3d 207 [arguments unsupported by legal authority and factual analysis may be deemed forfeited].)
165-166.) In reversing, the appellate court stated:
"This approach is inconsistent with the mandate of
CEQA that a large project shall not be divided into
little ones because such division can improperly
submerge the aggregate environmental
considerations of the total project." (Id. at p. 167
[concluding that the purposes of CEQA were
subverted because the lead agency never
considered whether the environmental effects of
the total shopping center project, properly defined,
were significantly adverse and thus required an
EIR].)
Here, by contrast, the record reflects that the City
environmentally reviewed one project. The mere
fact that the City contemplates further commercial
development at the project site is not sufficient to
conclude that a fast-food [*33] restaurant on
Parcel 3 is a "reasonably foreseeable"
consequence of the approved project.13 In short,
this is not the type of case that implicates the
concerns underlying CEQA's prohibition against
piecemealing of environmental review. The
commercial development project at issue here was
not segmented to avoid consideration of its
cumulative environmental impacts. Indeed, as
13 In support of their contention that improper piecemealing occurred, plaintiffs assert that the commercial development of Parcel 3 is a future phase of the approved project, since the planning commission's findings state that the project includes the grading and drainage required for the development of the parcels, which (in plaintiffs' view) includes grading and drainage of Parcels 1, 2, and 3. But the portions of the record plaintiffs rely upon do not clearly show that grading and drainage of Parcel 3 is part of the approved project. And, in any event, plaintiffs have failed to cite any authority convincing us that such work on Parcel 3 supports the conclusion that the construction of a fast-food restaurant on Parcel 3 is a reasonably foreseeable consequence of the initial project—the creation of three separate parcels at the project site and the commercial development of Parcels 1 and 2. (See Banning Ranch, supra, 211 Cal.App.4th at pp. 1223, 1225 [while
improper piecemealing may occur when the purpose of the activity at issue is to be the first step or to provide a catalyst toward future development, courts have distinguished these "first step" cases where the project under consideration is only a baby step toward another project]; see id. at pp. 1225-1226 [concluding that an access road to a park was "only a baby step toward [a housing] project" that would use the same access road and certainly "a much smaller step than the reviewed actions in the 'first step' cases"].)
2025 Cal. App. Unpub. LEXIS 6219, *30

explained by City staff in the proceedings below,
programmatic evaluation of site development
consistent with community commercial land use
designation was already completed as part of the
NRSP EIR, which analyzed the impacts of full
development of the entirety of the project site with
commercial uses. Plaintiffs, for their part, provide
no reasoned legal analysis, supported by citation
to pertinent authority, convincing us that a contrary
result is required.

We thus reject plaintiffs' contention that the City
inadequately described the project by failing to
account for future development that is a
reasonably foreseeable consequence of the
project—construction of a fast-food restaurant on
Parcel 3. We also reject plaintiffs' related
contention that improper segmentation or
piecemealing of environmental [*34] review
occurred because the City did not evaluate the
"whole of the action" by failing to consider the
future development of a fast-food restaurant
thereon.

II
In-fill Development Exemption
Next, plaintiffs argue the City erred in determining
that the project is categorically exempt from
CEQA's environmental review requirements under
the in-fill (or Class 32) development exemption.

They contend that because the project will result in
significant effects related to traffic safety in the
adjacent subdivision due to increased traffic on the
private road connecting the subdivision to the
project site, the City improperly found that the
project is exempt from CEQA. Plaintiffs add that
the City erred in determining the "unusual
circumstances" exception to the in-fill exemption
did not apply.

A. Relevant Legal Principles and Standard of
Review
To ensure that environmental considerations
inform a public agency's decisions, CEQA
establishes a three-tier environmental review
process. (Muzzy Ranch Co. v. Solano County
Airport Land Use Com., supra, 41 Cal.4th at pp.
379-380; Holden v. City of San Diego (2019) 43
Cal.App.5th 404, 409, 255 Cal. Rptr. 3d 873.) As
relevant here, at the second step, the agency must
decide whether the project falls under an
exemption that renders CEQA compliance
unnecessary. (See Holden, at p. 409.)
The categorical exemptions are set forth in section
21084, which mandates [*35] that the Guidelines
"shall include a list of classes of projects that have
been determined not to have a significant effect on
the environment." (§ 21084, subd. (a).) The
Guidelines include 33 such categorical
exemptions.

The in-fill (or Class 32) exemption is set forth in
Guidelines section 15332. It exempts "projects
characterized as in-fill development meeting the
conditions described in this section"; of the five
conditions set forth, only one is at issue here. That
condition, set forth in subdivision (d), requires that
"[a]pproval of the project would not result in any
significant effects relating to traffic, noise, air
quality, or water quality." (CEQA Guidelines, §
15332(d).)
A public agency's determination that a particular
project is exempt from compliance with CEQA's
environmental review requirements is subject to
judicial review under the abuse of discretion
standard in section 21168.5. (Protect Tustin Ranch
v. City of Tustin (2021) 70 Cal.App.5th 951, 960,
285 Cal. Rptr. 3d 775.) An abuse of discretion is
established if the agency has not proceeded in a
manner required by law or its determination or
decision is not supported by substantial evidence.
(§ 21168.5; Protecting Our Water, supra, 10
Cal.5th at p. 495.)
"When [a public] agency concludes an activity is
exempt based on factual considerations, a court
reviews for substantial evidence. If the agency's
determination 'involves pure questions of law, we
review those [*36] questions de novo.'" (Protecting
Our Water, supra, 10 Cal.5th at p. 495.) "The lead
agency has the burden to demonstrate that a
project falls within a categorical exemption and the
agency's determination must be supported by
substantial evidence. [Citation.] Once the agency
establishes that the project is exempt, the burden
2025 Cal. App. Unpub. LEXIS 6219, *33

shifts to the party challenging the exemption to
show that the project is not exempt because it falls
within one of the exceptions listed in Guidelines
section 15300.2." (Citizens for Environmental
Responsibility v. State ex rel. 14th Dist. Ag. Assn.
(2015) 242 Cal.App.4th 555, 568, 195 Cal. Rptr. 3d
168.)
A project that falls within one of the categorical
exemptions is deemed to be exempt from CEQA,
unless an exception set forth in the Guidelines
applies. (Guidelines, § 15061, subd. (b)(2).) One of
these exceptions, the "unusual-circumstances
exception," provides that "[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." (Guidelines, § 15300.2,
subd. (c).) The plain language of this provision
"requires that a potentially significant effect must
be 'due to unusual circumstances' for the exception
to apply. The requirement of unusual
circumstances recognizes and gives effect to the
Secretary's14 general finding that projects in the
exempt class typically do not have significant [*37]
impacts." (Berkeley Hillside, supra, 60 Cal.4th at p.
1105.)
"As to projects that meet the requirements of a
categorical exemption, a party challenging the
exemption has the burden of producing evidence
supporting an exception." (Berkeley Hillside, supra,
60 Cal.4th at p. 1105.) As relevant here, to
establish that the exception applies, the party has
the burden to show two elements: (1) "that the
project has some feature that distinguishes it from
others in the exempt class, such as its size or
location," and (2) that there is "a reasonable
possibility of a significant effect [on the
environment] due to that unusual circumstance."
(Ibid.) "This bifurcated approach . . . require[s]
findings of both unusual circumstances and a
potentially significant effect." (Id. at p. 1115.)
Evidence that a project may have a significant
effect is not enough to "remove it" from an exempt
class that the Secretary has found do not have a
significant effect on the environment. (Ibid.)
14 Secretary of the Natural Resources Agency.

In deciding whether the unusual-circumstances
exception applies to preclude a project from
qualifying as in-fill development exempt from
CEQA's environmental review requirements, we
apply different standards of review. (Berkeley
Hillside, supra, 60 Cal.4th at pp. 1114-1115.) We
assess the public agency's determination on the
first element—whether the project presents
unusual circumstances—by [*38] applying the
traditional substantial evidence standard. (Id. at p.
1114) As for the second element—whether there is
"a reasonable possibility of a significant effect [on
the environment] due to that unusual
circumstance"—our "function 'is to determine
whether substantial evidence support[s] the
agency's conclusion as to whether'" there is a fair
argument of a reasonable possibility that the
activity will have a significant effect on the
environment. (Id. at p. 1115.) If there is substantial
evidence of such a reasonable possibility, then the
public agency's determination that no fair argument
can be made constitutes an abuse of discretion
and cannot be upheld. (Ibid.)
Substantial evidence includes "fact, a reasonable
assumption predicated upon fact, or expert opinion
supported by fact." (§ 21080, subd. (e)(1); see also
Guidelines, § 15384, subd. (a).) It does not include
"[a]rgument, speculation, unsubstantiated opinion
or narrative, evidence that is clearly inaccurate or
erroneous, or evidence of social or economic
impacts that do not contribute to, or are not caused
by, physical impacts on the environment." (§
21080, subd. (e)(2); see also Guidelines, § 15384,
subd. (a).) The Guidelines define substantial
evidence as "enough relevant information and
reasonable inferences from this information that a
fair argument [*39] can be made to support a
conclusion, even though other conclusions might
also be reached." (Guidelines, § 15384, subd. (a).)
In other words, "[s]ubstantial evidence is evidence
of ponderable legal significance that is reasonable
in nature, credible, and of solid value." (Holden v.

City of San Diego, supra, 43 Cal.App.5th at p.
410.) This standard requires the court to resolve
"all conflicts in the evidence . . . in favor of the
prevailing party and all legitimate and reasonable
inferences are made to support the [public]
agency's decision." (Ibid.)
2025 Cal. App. Unpub. LEXIS 6219, *36

B. Analysis
As previously indicated, plaintiffs' challenge to the
project's initial qualification as an infill development is limited to the question of whether the approval of
the project will "result in any significant effects
relating to traffic, noise, air quality, or water
quality." (Guidelines, § 15332, subd. (d).) In
plaintiffs' view, the in-fill development exemption
does not apply here because there is substantial
evidence of a fair argument of a reasonable
possibility that the project will have significant
effects relating to traffic safety. As we have set
forth, ante, plaintiffs' concerns regarding traffic
safety were originally explained to the City as
predicated on the assumption that the construction
of a fast-food restaurant on Parcel [*40] 3 would
result in increased traffic through the subdivision
(via the private road—Camino Real Way), causing
significant effects relating to traffic/pedestrian
safety, and later the expressed concerns regarding
those effects were expanded to include the project
as a whole, even without the restaurant added. On
appeal, plaintiffs argue mainly that the non-resident
traffic coming and going from the project, i.e. the
"cut-thru traffic on Camino Real Way, a private
road" will lead to traffic safety concerns within the
development.

We see no basis for reversal. As an initial matter,
we concluded ante that the approved project does
not include the development of Parcel 3. It follows
that the approval does not include fast-food
restaurant on Parcel 3. And there is no substantial
evidence supporting a fair argument there is a
reasonable possibility that the project-development
of Parcels 1 and 2 and no development of Parcel
3—will have significant impacts relating to
transportation. The project was analyzed under the
VMT standard and found to be consistent with the
2035 General Plan, including the VMT analysis
included in the EIR. As set forth in the General
Plan Update EIR, a project that is [*41] consistent
with the 2035 General Plan (as here) does not
require any further VMT analysis.

Plaintiffs do not claim the City erred in determining
the project will not have significant transportation
impacts under a VMT analysis, which is generally
the most appropriate measure of transportation
impacts under CEQA.15 (See Citizens for Positive
Growth & Preservation v. City of Sacramento
(2019) 43 Cal.App.5th 609, 625-626, 255 Cal. Rptr.
3d 889 [describing legislative change in
transportation analysis from automobile delay (i.e.,
traffic congestion) or level of service (LOS) to VMT
criteria].) Instead, plaintiffs fault the City for failing to analyze the project's "potentially significant
impacts" related to pedestrian safety. (See §
21099, subd. (b)(3) ["This subdivision does not
relieve a public agency of the requirement to
analyze a project's potentially significant
transportation impacts related to air quality, noise,
safety, or any other impact associated with
transportation"].)
According to plaintiffs, the "unusual-circumstances"
exception applies, which provides that a
categorical exemption such as in-fill development
"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." (Guidelines, § 15300.2,
subd. (c).) We do not [*42] see that the exception
applies here, for the reasons that follow.

A public agency's decision that a project falls within
one of CEQA's categorical exemptions (e.g., in-fill
development exemption) includes an implied
finding that exceptions to the categorical
exemption are inapplicable. (Respect Life South
San Francisco v. City of South San Francisco
(2017) 15 Cal.App.5th 449, 457, 223 Cal. Rptr. 3d
202.) When (as here) "an [agency's] determination
that the unusual-circumstances exception is
inapplicable is implied, a court's ability to affirm is constrained. The court may affirm on the basis of
the first element—which . . . asks whether the
15 Guidelines section 15064.3 "describes specific
considerations for evaluating a project's transportation impacts" and provides that, "[g]enerally, vehicle miles traveled [VMT] is the most appropriate measure of transportation impacts." (Guidelines, § 15064.3, subd. (a).) The guideline defines VMT as "the amount and distance of automobile travel attributable to a project." (Ibid.) "Other relevant considerations" in determining the significance of a project's transportation impacts "may include the effects of the project on transit and non-motorized travel." (Ibid.)
2025 Cal. App. Unpub. LEXIS 6219, *39

project presents any unusual circumstances—only
if the court assumes that the [agency] found that
there were unusual circumstances and then
concludes that the record does not contain
substantial evidence of any such circumstances. A
court cannot, however, affirm on the basis of the
first element by simply concluding that the record
contains substantial evidence that there are not
unusual circumstances. This is because such an
approach fails to address the possibility that the
[agency] thought there were unusual
circumstances but concluded, under the second
element, that these circumstances did not support
a fair argument of a reasonable possibility of a
significant [*43] environmental effect." (Id. at p.
458.)
"In contrast, a court need not make any
assumption about what the [agency] found to affirm
on the basis of the second element—which . . .
asks whether there is a reasonable possibility of a
significant environmental effect due to any unusual
circumstances. This element presupposes the
existence of unusual circumstances, and a court
applies a nondeferential standard of review in
considering it. Under this nondeferential standard,
a court must affirm an [agency's] implied
determination that the unusual-circumstances
exception does not apply if it concludes that no
substantial evidence in the record supports a fair
argument that there is a reasonable possibility the
project will have a significant effect on the
environment as a result of any purported unusual
circumstances the petitioner identifies." (Respect
Life South San Francisco v. City of South San
Francisco, supra, 15 Cal.App.5th at p. 458.)
Here, we need not and do not consider the first
element of the unusual-circumstances test
because plaintiffs have failed to cite substantial
evidence that satisfies the second element of the
test. That is, evidence that supports a fair
argument of a reasonable possibility that the
purported unusual circumstances they identified in
the administrative proceedings—the [*44]
placement of a fast-food restaurant adjacent to the
subdivision—will have a significant effect on the
environment. In plaintiffs' view, the testimony of
area residents about traffic-related safety concerns
within the subdivision due to increased traffic from
the project is substantial evidence showing that the
unusual-circumstances exception applies. We are
unpersuaded, because no fast-food restaurant has
been approved.

Further, addressing plaintiffs' later arguments,
made in the trial court and now on appeal, and
assuming that the "unusual circumstance" at issue
here is the commercial development of Parcels 1
and 2 in close proximity to a residential
development with a private road that provides
access to the commercial development,16 there is
insufficient evidence to support a fair argument that
there is a reasonable possibility the approved
project would have a significant effect on the
environment. Although substantial evidence may
include relevant personal observations of area
residents on nontechnical subjects, such as
existing traffic conditions based upon personal
knowledge, argument, speculation,
unsubstantiated opinions, concerns, and
suspicions about a project do not rise to [*45] the
level of substantial evidence necessary to support
a fair argument that there is a reasonable
possibility a project will have a significant effect on the environment. (See Hilltop Group, Inc. v. County
of San Diego (2024) 99 Cal.App.5th 890, 919, 318
Cal. Rptr. 3d 336.) "[I]n the absence of a specific
factual foundation in the record, dire predictions by
nonexperts regarding the consequences of a
project do not constitute substantial evidence."
(Gentry v. City of Murrieta (1995) 36 Cal.App.4th
1369, 1417, italics added.) "Unsubstantiated
opinions, concerns, and suspicions about a project,
though sincere and deeply felt, do not rise to the
level of substantial evidence." (Leonoff v. Monterey
County Bd. of Supervisors, supra, 222 Cal.App.3d
at p. 1352.) Thus, to meet the fair argument
standard, "project opponents must produce some
evidence, other than their unsubstantiated
16 On appeal, the City argues that we lack jurisdiction to "entertain" the new theories plaintiffs raised for the first time before the trial court, arguing that plaintiffs failed to exhaust their administrative remedies as to those theories. The City did not raise this objection in the trial court and we decline to consider it. Instead, we address the merits of plaintiffs' appellate contentions, which track the arguments plaintiffs made in the trial court.
2025 Cal. App. Unpub. LEXIS 6219, *42

opinions, that a project will produce a particular
adverse effect." (Association for Protection etc.

Values v. City of Ukiah (1991) 2 Cal.App.4th 720,
735-736, 3 Cal. Rptr. 2d 488.) Here, the record
contains no factual foundation supporting the
proposition that the approved project will create
significant traffic-related safety issues for residents of the subdivision due to increased traffic on
Camino Real Way from non-residents.

There is, however, evidence supporting the
conclusion that the project will not result in a
significant increase in traffic within the subdivision
by non-residents. City planning and engineering
staff determined that Camino [*46] Real Way was
not a likely shortcut to the project (or commercial)
site due to the "circuitous route" of the road.

Therefore, it was not anticipated that non-resident
customers of the commercial site would use the
private road. Nevertheless, the City, in approving
the project, addressed the traffic-related safety
concerns of the area residents by requiring InterCal to install a speed bump on Camino Real Way at the western entry of the subdivision and post a
sign stating that the road was a private road that
could not be used by non-residents. These
conditions were added after City engineering staff
was apprised of the residents' concerns and
reviewed the traffic circulation.

On this record, we see no abuse of discretion in
the City's determination that the unusualcircumstances exception does not apply here to preclude application of the in-fill development
exemption. Given our conclusions, we need not
and do not address any of the other arguments
raised by the parties.

DISPOSITION
The judgment is affirmed. The City is entitled to
recover its costs on appeal. (Cal. Rules of Court,
rule 8.278(a).)
/s/ Duarte, J.

We concur:
/s/ Mauro, Acting P. J.
/s/ Renner, J.

End of Document
2025 Cal. App. Unpub. LEXIS 6219, *45
  






 







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SUPPLEMENTAL INFORMATION
AGENDA ITEM NO. 8.1
11-12-2025
1 November 10, 2025
Mayor Bobbie Singh Allen and Members of the Elk Grove City Council Elk Grove City Hall - Council Chambers
8400 Laguna Palms Way
Elk Grove, CA 95758
Transmitted via by email to: [email protected]
RE: CONFLICT OF INTEREST/BIAS CONCERNING CONSIDERATION OF

MAVERIK FUELING STATION PERMIT
Dear Mayor Singh Allen and Members of the City Council:

I represent a Protect Elk Grove, a group of residents in the City of Elk Grove (City) concerned about environmental and community issues. My client is concerned about the potential, unexamined impacts of the proposed Maverik Fueling Station in Elk Grove (“Elk Grove Maverik Project,” or “Project”) located on Grants Pass Road/Stockton Blvd. near Highway 99.

On behalf of my client, I request that Mayor Bobbie Singh Allen recuse herself from any attendance, deliberation or City Council vote on November 12, 2025 regarding my client’s appeal of the Elk Grove Planning Commission’s September 18, 2025 approval of the Maverik Fueling Station, due to conflicts with both: Fair Political Practice Commission (FPPC) Conflict of Interest Rules and FPPC and common law bias issues.

In brief, if Mayor Singh Allen involves herself in any way regarding Elk Grove’s consideration of the Maverik permits, she will be violating the Political Reform Act and Fair Political Practice Regulations by acting as a lobbyist and not disclosing that role where she indirectly benefits, and for not or recusing herself from said permitting decisions. Even if there was no direct or indirect financial interest, Mayor Singh Allen’s compensation as a lobbyist for gas stations and convenience stores provides the appearance of impropriety and suggests improper bias in any decision making regarding the Maverik fueling station, and therefore, violates the FPPC rules.

Law Office of Edward E. Yates
2060 Sutter St., #403
San Francisco, CA 94115
Ph: 415-990-4805
2 Background.

Government Code Section 87100 of the Political Reform Act (the “Act”) prohibits a public official at any level of state or local government from making, participating in making, or attempting to use the official’s position to influence a governmental decision in which the official knows or has reason to know the official has a financial interest.

Government Code Section 87103 provides that an official has a “financial interest” within the meaning of Section 87100 if it is reasonably foreseeable that the decision will have a material financial effect on one or more of the official’s interests as identified and distinguishable from the decision’s effect on the public generally.

Under the Act, a public official has a disqualifying conflict of interest in a governmental decision if it is foreseeable that the decision will have a financial impact on his or her personal finances or other financial interests. In such cases, there is a risk of biased decision-making that could sacrifice the public’s interest in favor of the official’s private financial interests. To avoid actual bias or the appearance of possible improprieties, the public official is prohibited from participating in the decision.

FPPC Conflict of Interest rules (Title 2, Division 6, Sections 18104-18998 of the California Code of Regulations) regarding personal and or business income, prohibit involvement where “an individual or an entity from whom the official has received income or promised income aggregating to $500 or more in the previous 12 months, including the official's community property interest in the income of his or her spouse or registered domestic partner.” CCR Title 2 § 18700, 18700.1 (See Gov’t Code Sections 87100, 87101, & 87103.) Specifically, FPPC regulations at CCR Title 2 § 18702.3 prohibit involvement where there is income from a party appearing before the legislative body. Further, § 18703.3(b) states that the: “Financial Interest Not [be] Explicitly Involved in Decision: A financial effect need not be likely to be considered reasonably foreseeable. In general, if the financial effect can be recognized as a realistic possibility and more than hypothetical or theoretical, it is reasonably foreseeable.” Mayor Singh Allen’s Potential Violations, Conflicts and Bias.

Mayor Singh Allen is the President of the American Petroleum and Convenience Store Association (APCA.) (See https://www.apca.us › leadership.) The APCA conducts “legislative advocacy” for “gasoline and convenience store owners across the USA” including 20% of gas stations in California. (https://www.apca.us/en/about-us.) The Mayor’s compensation from APCA – which is in conflict with her government agency role – is at least $100,000.00, according to her April 22, 2025 filed FPPC Form 700.

Such a sum not only qualifies as triggering FPPC rules, but it is also such a substantial sum as to obviously trigger common sense concerns that the Mayor cannot fairly adjudicate an appeal regarding an entity, Maverik, that benefits from her lobbying. This is true whether or not Maverik is a member of the APCA. 3 Mayor Singh Allen’s work on behalf of gas station and convenience stores and deliberating on such a development, would be "attempting to use his or her official position to influence" (id. at § 18700.1, subd. (a). See Hamilton v. Town of Los Gatos, 213 Cal. App. 3d 1050, 1056 (1989). Also, one FPPC opinion suggests that a disqualified official should not even be present at a hearing in which the official has a conflict. In the Matter of Hudson (1978) 4 FPPC Opinions 13. Mayor Singh Allen is a paid lobbyist for gas stations and convenience stores in California. Since Mayor Singh Allen is paid to lobby for these stations, she has a direct and/or indirect financial interest in the Maverik application.

Similarly, regarding common law bias concerns, given May Singh Allen’s championing of gas station and convenience stores, there is a probability of bias. The generally accepted linguistic formation of the rule against bias has been framed in terms of probabilities, not certainties. The law does not require the complainant to prove actual bias. Rather, there must not be “an unacceptable probability of actual bias” on the part of the municipal decision maker. (Nasha v. City of L.A., 125 Cal. App. 4th 470, 483 (2004); see BreakZone Billiards v. City of Torrance, 81 Cal. App. 4th 1205, 1236 (2000).

Thus bias—either actual or an “unacceptable probability” of it—alone is enough on the part of a municipal decision maker to show a violation of the due process right to fair procedure. (E.g., Cohan v. City of Thousand Oaks, 30 Cal. App. 4th 547, 559 (1994) [“A biased decision maker is constitutionally unacceptable.”]. Here, Mayor Singh Allen is essentially a lobbyist and, therefore, the very nature of her businesses and her intertwined relationship with the industry demonstrates unacceptable bias over any decision where she is representing the voters and taxpayers of Elk Grove.1 We suggest that Mayor Singh Allen and the City of Elk Grove contact the FPPC to determine what the rules are regarding the conduct. Persons may directly contact the FPPC on its website (www.fppc.ca.gov), or on its toll-free telephone advice line (1-866- 275-3772). Until that time, Mayor Bobbie Singh Allen should recuse herself from any attendance, deliberation or City Council vote on November 12, 2025 regarding the Maverik Fueling Station.

Sincerely,
/s/ Edward E. Yates
1 It is not clear if Mayor Singh Allen has other investments in companies that profit off of gas station/convenience stores. She should file periodic complete disclosure reports pursuant to Government Code Sections 86108(a) and 86109.1. See In the Matter of Morrisey, 2 FPPC Opinions 121,In the Matter of Stern (1975) 1 FPPC Ops. 59 75-040 where school lobbyists must report under Section 86108(b).  




 



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1 November 11, 2025
VIA E-MAIL ONLY [email protected]
City of Elk Grove City Council
8401 Laguna Palms Way
Elk Grove, CA 5758
Re: PLNG24-031 Maverik Fueling Station and Convenience Store – Conditional Use Permit and Minor Design Review
Elk Grove City Council, November 12, 2025
Dear Members of the City Council:

I represent a Protect Elk Grove, a group of residents in the City of Elk Grove (City) concerned about environmental and community issues. My client is concerned about the potential, unexamined impacts of the proposed Maverik Fueling Station in Elk Grove (“Elk Grove Maverik Project,” or “Project”) located on Grants Pass Road/Stockton Blvd. near Highway 99.

This letter serves as an addendum to Protect Elk Grove’s September 29, 2025 appeal and responds to the City’s November 12, 2025 Staff Report (Staff Report).

I have attached technical studies from two technical experts, James Clark, air quality and hazardous waste specialist, and Tom Brohard, transportation and traffic specialist. Those letters and reports are incorporated by reference into this appeal. In summary:
• The City and the Applicant, Maverik, continue to withhold information and blindside the public during this process. This includes Maverik waiting 41 days to submit its comments on this appeal at the last minute, in a brazen attempt to prevent any scrutiny of its comments.
• The City contends that the area was “urbanized” because it was rezoned is contradicted by CEQA caselaw and common sense.

Law Office of Edward E. Yates
2060 Sutter St., #403
San Francisco, CA 94115
Addendum to Protect Elk Grove’s Appeal of Maverik Fueling Station

• The City and Maverik’s conclusions on water quality and toxics completely ignore available baseline information on State of California Water Resources Control Board databases including designation of the property as containing toxic waste contamination. This missing data renders the City’s conclusions regarding potential water quality impacts as unsupported and baseless.
• The City failed to: quantify the concentration and levels of inherent toxicity of the Toxic Air Contaminants (TACs) 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.
• The trip generation numbers used in the traffic study were hugely underestimated. Even with the daily trip generation for the Maverik Project at about 25% of what will occur, the traffic consultant’s data indicates that the intersection of Grant Line Road at East Stockton Boulevard would experience delays that significantly exceed the City’s signalized intersection performance target.
• The City and Maverik’s claims that there are no cumulative projects related to the proposed fueling station are demonstrably false. The property owner Mr. Gillam stated at the Planning Commission that he is "planning for complementary uses" and that he has prepared a preliminary site plan for "restaurants, a hotel, and coffee shops. The City’s own staff at the Planning Commission hearing confirmed that “there are future development” assumptions.

Regulation and approval of an enormous fueling station/truck stop is a serious and technical undertaking. This is because such facilities emit and discharge toxic pollutants into the City of Elk Grove’s environment. The City of Elk Grove should take its role in regulating the facility and its pollutants and traffic generation much more seriously. The City should require both review of standard State of California pollutant databases and preparation of industry standard assessments of the potential impacts of the facility on Elk Grove residents’ health.

1. The City Has Continued to Hide Information from the Public.

At the Planning Commission hearing, the City withheld information from the public until it was the subject of the public’s demand, and refused to allow Elk Grove residents to speak. The City and the Applicant, Maverik, continue to Addendum to Protect Elk Grove’s Appeal of Maverik Fueling Station

withhold information and blindside the public during this process. Protect Elk Grove’s appeal was made on September 29, 2025, yet Maverik’s attorney has chosen to wait 41 days - until the very last minute - to respond. Maverik and its attorneys have plenty of resources; this last minute letter was obviously intended to withhold arguments so that the appellant had no time to respond.

The City’s Staff Report continues to mislead the Council and the public by inaccurately minimizing the Maverik Projects impacts. Protect Elk Grove’s technical experts have shown that Maverick and the City have repeatedly withheld data, modeling, information and other baseline evidence that might question their conclusions that there are no impacts from the Project.

Our opinion remains that the City violated the Brown Open Meetings Act at the Planning Commission Hearing by: a) not allowing residents to speak during the agenda item comment period; and b) by not providing meaningful opportunity to review several critical documents which were not made available with the agenda packet that was provided to the Planning Commission.

Even if the City did not expressly violate the Brown Act, the City has blatantly violated the spirit of the law. The City’s management of the Planning Commission hearing disenfranchised Elk Grove residents who wanted an opportunity to speak and to review documents the City produced to support the application. Many Elk Grove residents went home without speaking and no one received all the Agenda materials and technical reports before the meeting because the City refused to post them.

2. Maverik’s Property is Not Substantially Surrounded by Urban Uses.

We continue to take the position that the City improperly relied on CEQA exemption, Class 32 for infill development projects. (Calif. Code Regulations, Title 14, Section 15332.) To qualify for the Class 32 exemption, the Project must be “substantially surrounded by urban uses.”
The Staff Report goes to great length to argue that “substantially surrounded” is not what it means. That instead, any urban project, with any adjacent urban uses or nearby urban zoning (as my first letter predicted) exempts an applicant from the requirement to be surrounded by urban uses. However, the Project is bordered by non-urban uses –on two full sides. Whether the property is characterized as open space or not, it is currently undeveloped and the baseline is that there are currently Addendum to Protect Elk Grove’s Appeal of Maverik Fueling Station

no urban uses on two full sides. CEQA authority is clear; a project with two sides of non-urban uses does not qualify for the Class 32 exemption.

Again, the Court in Friends of Mammoth v. Town of Mammoth Lakes Redevelopment Agency, 82 Cal. App. 4th 511, 546 (2000) dismissed the Town of Mammoth’s – and here, the City of Elk Grove’s - contention that the area was urbanized because it was rezoned or partly developed land.1 “The vacant acreage is not to be counted as urbanized merely because it is part of a parcel that has been partially developed consistent with zoning.”2 (Ibid.) See also Banker's Hill, Hillcrest, Park W. Cmty. Pres. Grp. v. City of San Diego, 139 Cal. App. 4th 249, 270-71 (2006)

3. The City and Maverik Have Ignored State Toxic Materials Databases Showing Groundwater Contamination at the Site.

CEQA Guidelines Section 15332 allows for an exemption from environmental review for in-fill development projects only if approval “would not result in any significant effects relating to traffic, noise, air quality, or water quality.” The City relies on air quality and traffic studies that are flawed and did not bother to assess on site toxics and water quality issues. As such the City and Maverik’s Staff Report and other reports do not adequately assess the Project’s direct and cumulative impacts to air quality, water quality, and traffic.

The attached letter by Jim Clark makes it clear that the City has ignored numerous publicly available documents that clearly demonstrate problems with toxics and on site water quality issues. The City’s Staff Report and Categorical Exclusion justifications, fail to include any 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 does not contain any hazardous materials and is not any active hazardous material site lists pursuant to 1 In my September 29, 2025 letter, I mistakenly said the City of Galt, instead of the City of Elk Grove.

In an email of November 4 to the City Clerk I corrected this typo. That this was a typo, was clear, yet Maverik has tried to make hay about this meaningless error. 2 The Mammoth court further clarified by holding that: The statute's language does not support the Town's interpretation. Subdivision (c) is not concerned with the extent of development. It says nothing of deeming a partially developed parcel to be a fully developed parcel. Thus, subdivision (c) does not permit us to deem the undeveloped portions of a parcel to be "land . . . developed for urban uses. (At 543)
Addendum to Protect Elk Grove’s Appeal of Maverik Fueling Station

Government Code Section 65962.5. But this is demonstrably false. Mr. Clark states that:

Even a cursory Phase I Environmental Site Assessment (ESA) would have noted properties 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. (Emphasis added.)
The City and Maverik’s conclusions completely ignore this and other such baseline information, thereby rendering the City’s conclusions regarding potential water quality impacts as unsupported and baseless. It is not that Mr. Clark simply disagrees with Maverik’s consultants, but instead that Maverik’s consultants, ignored, buried or failed to address public information about the site’s water quality. He states that:

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.

4. The City Failed To Perform An Accurate Impact Analysis On Air Quality Due to Lack of Consideration of Other Sources.

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.” Bakersfield Citizens for Local Control v.

City of Bakersfield, 124 Cal. App. 4th 1184, 1214 (2004) (quoting Communities for a Better Environment v. California Resources Agency 103 Cal.App.4th at 116).

Addendum to Protect Elk Grove’s Appeal of Maverik Fueling Station

The Staff Report has claimed that the City is not obligated by CEQA to address cumulative impacts except for those projects related to the Maverik facility. But that contention does not relate to the basic requirements for an agency to use the class 32 categorical exemption. The Class 32 CEQA exemption allows for in-fill development projects only if approval “would not result in any significant effects relating to traffic, noise, air quality, or water quality.” The City, though, makes this conclusion based on an air quality study that is flawed because it does not assess the toxics emissions from truck diesel engines. Mr. Clark writes that:

TACs, including diesel particulate matter (DPM) , contribute 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.

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.

5. The City Cannot Use the Class 32 CEQA Exemption Because its Traffic Conclusions Were Based on Erroneous Baseline Assumptions.

Similar to its Water Quality and Air Quality reports and conclusions, the City has either intentionally misstated or mistakenly used erroneous baseline numbers and assumptions. Traffic expert Tom Brohard explains what these errors were and why they are important.

Table 2 in the LTA provides a trip generation forecast for the future CMD Court Commercial Project described above. However, this forecast includes a significant error (circled in blue ink) showing only 1,503 daily trips to and from the Maverik Project. As disclosed in Table 1 in the August 15, 2025 Project Conditioning Report, the Maverik Project will actually generate 6,010 daily trips, four times higher than reported in the LTA.

Addendum to Protect Elk Grove’s Appeal of Maverik Fueling Station

Even with the erroneous daily trip generation for the Maverik Project at about 25% of what will occur, Table 3 in the LTA indicates that the intersection of Grant Line Road at East Stockton Boulevard would experience delays that significantly exceed the City’s signalized intersection performance target.

Therefore, whether or not the LOS is not used as a primary significance criteria as the City Staff Report claims, by approving this project without any adequate traffic mitigation, the City is violating its own standards. Those standards are incorporated into CEQA. (See CEQA Guidelines Section 15125(d), 15126; Chaparral Greens v. City of Chula Vista. (1996) 50 Cal.App.4th 1134, 1145 n2.

Mr. Brohard also specifically examined the City’s claim that measures would mitigate the traffic. Again, the City and Maverik’s consultants were basing their conclusion on faulty assumptions.

From my review of the available documents, the reasonably foreseeable projects including those that may be developed in the balance of the CMD Court Commercial Project, their cumulative impacts, and potential mitigation measures were not fully considered. Before approving the Maverik Project and finalizing the designs, further study and evaluation together with coordination and communication with Caltrans are required.

Mr. Brohard also pointed out that the City and Maverik’s consultants were contradicted by experienced truck drivers speaking at the Planning Commission and that he agreed:

Trucks must be able to smoothly travel within and in and out the Maverik site. It appears that some of the required turns cannot be made by large trucks without backing up and causing considerable delay and congestion on East Stockton Boulevard and within the development site. As part of the design review at this point, large truck turning templates must be overlaid at each of the required truck turns to validate that turns can be smoothly negotiated, or how larger radii can be implemented on paper before they are built and then must be rebuilt in the field. Such considerable delays have not been addressed in the traffic studies for the Maverik Project and so, it appears that such delay and congestion would be significant.

Addendum to Protect Elk Grove’s Appeal of Maverik Fueling Station

6. The City improperly relied on CEQA exemption, Class 32 for infill development projects. (Calif. Code Regulations, Title 14, Section 15332) because there was evidence at the time that there were cumulative impacts and foreseeable projects.

The Staff Report and a November 10, 2025 letter from Maverik’s attorney Casey Shorrock, claim that no applications have been filed with the City regarding future projects at the Project site, and therefore, the City is not required to examine any cumulative impacts of future projects. The Planning Commission Staff Report identifies probable future projects at the site. Further, at the September Planning Commission Hearing, (at minute 36:23) the property owner, Jim Gillam, stated that he is "planning for complementary uses" and that (contrary to no active applications see above), he has prepared a preliminary site plan for "restaurants, a hotel, and coffee shops." The City’s own staff at the Planning Commission hearing admitted that “there are future development” assumptions (at minute 10:45.) The foregoing establishes at a minimum the "probability" of future projects, especially in light of the required dedication for street widening and the abandonment of the public easement. See CCR 15065(a)(3) and 15355(b).

CEQA Guideline Section 15065(a)(3) provides:
(a) A lead agency shall find that a project may have a significant effect on the environment and thereby require an EIR to be prepared for the project where there is substantial evidence, in light of the whole record, that any of the following conditions may occur:...(3)The project has possible environmental effects that are individually limited but cumulatively considerable. "Cumulatively considerable" means that the incremental effects of an individual project are significant when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects. (Emphasis added.)3 3 See also CEQA Guidelines Section 15355(b), which provides:
"Cumulative impacts" refer to two or more individual effects which, when considered together, are considerable or which compound or increase other environmental impacts. (a) The individual effects may be changes resulting from a single project or a number of separate projects.

Addendum to Protect Elk Grove’s Appeal of Maverik Fueling Station

It is not simply that the City did not bother to query the property owner about other probable projects and developments at the Maverik and commercial center site, it appears that the City is refusing to do so, based on a narrow legal view that it does not have to. But the City is wrong – the City has a duty to reasonably research any reasonably foreseeable projects.

Conclusion
For the foregoing reasons and as set out below, the City Council should grant Protect Elk Grove’s appeal and deny the application for the Maverik Project. In the alternative, the City Council should require Maverik to review the numerous errors made by its consultants, address them, and provide mitigation measures for the project’s probable impacts to air quality, water quality, and traffic.

Sincerely,
/s/ Edward E. Yates
Cc: Kyra Killingsworth
(b) The cumulative impact from several projects is the change in the environment which results from the incremental impact of the project when added to other closely related past, present, and reasonably foreseeable probable future projects. Cumulative impacts can result from individually minor but collectively significant projects taking place over a period of time.” Emphasis Added.

CURRICULUM VITAE OF JAMES J. J. CLARK; 1 | Page
James J. J. Clark, Ph.D.

Principal Toxicologist
Toxicology/Exposure Assessment Modeling/Environmental Health Risk Assessment/Analysis/Dispersion Modeling
Education:

Ph.D., Environmental Health Science, University of California, 1995 M.S., Environmental Health Science, University of California, 1993 B.S., Biophysical and Biochemical Sciences, University of Houston, 1987 Professional Experience:

Dr. Clark is a well-recognized environmental health scientist, toxicologist, air modeler, and health scientist specializing in exposure and safety analysis. He has 30 years of experience in developing health and safety programs to comply with state and federal regulations, and tying together environmental contaminants measurements to human health impacts.

SELECTED HEALTH AND SAFETY PROJECTS
Client: Soil, Water, Air Protection Enterprise (SWAPE), Santa Monica, California Dr. Clark developed and managed the health and safety program for a consulting firm specializing in complex environmental assessments of commercial, industrial and governmental projects. In addition to developing the corporate health and safety program, James wrote and oversaw all of the site specific health and safety programs (HASPs), medical monitoring, blood borne pathogen, and ergonomic compliance protocols.

Client: Komex H2O Science, Huntington Beach, California Dr. Clark served as the corporate health and safety office for a US based division of a Canadian/UK based environmental science and engineering corporation. James developed all of the health and safety documentation necessary for compliance with State, Federal, and international investigations performed by the company. In addition to developing the corporate health and safety program, James oversaw the medical monitoring and HAZWOPER training of all U.S. based employees.

Clark & Associates
Environmental Consulting, Inc
Office
12405 Venice Blvd.

Suite 331
Los Angeles, CA 90066
Phone
310-907-6165
Email
[email protected]
CURRICULUM VITAE OF JAMES J. J. CLARK; 2 | Page
Client: Various Clients with location throughout the U.S.

Dr. Clark developed HASPs for industrial and commercial clients throughout the U.S. for site specific projects involving construction, investigation, and remediation projects. Depending on the clients’ operations the HASPs include project specific protocols for work flow and safety operations.

SELECTED AIR MODELING RESEARCH/PROJECTS
Client(s) – Multiple
Indoor Air Evaluations, California: Performed multiple indoor air screening evaluations and risk characterizations consistent with California Environmental Protection Agency’s (Cal/EPA) Department of Toxic Substances Control (DTSC) and Regional Water Quality Control Board (RWQCB) methodologies. Characterizations included the use of DTSC’s modified Johnson & Ettinger Model and USEPA models, as well as the attenuation factor model currently advocated by Cal/EPA’s Office of Environmental Health and Hazard Assessment (OEHHA).

Client – Confidential
Dr. Clark performed a comprehensive evaluation of criteria pollutants, air toxins, and particulate matter emissions from a carbon black production facility to determine the impacts on the surrounding communities. The results of the dispersion model were used to estimate acute and chronic exposure concentrations to multiple contaminants and were be incorporated into a comprehensive risk evaluation.

Client – Confidential
Dr. Clark performed a comprehensive evaluation of air toxins and particulate matter emissions from a railroad tie manufacturing facility to determine the impacts on the surrounding communities. The results of the dispersion model have been used to estimate acute and chronic exposure concentrations to multiple contaminants and have been incorporated into a comprehensive risk evaluation.

EMERGING/PERSISTENT CONTAMINANT RESEARCH/PROJECTS
Client: City of Santa Clarita, Santa Clarita, California Dr. Clark managed the oversight of the characterization, remediation and development activities of a former 1,000 acre munitions manufacturing facility for the City of Santa Clarita. The site is impacted with a number of contaminants including perchlorate, unexploded ordinance, and volatile organic compounds (VOCs). The site is currently under a number of regulatory consent orders, including an Immanent and Substantial Endangerment Order. Dr. Clark assisted the impacted municipality with the development of remediation strategies, interaction with the responsible parties and stakeholders, as well as interfacing with the regulatory agency responsible for oversight of the site cleanup.

CURRICULUM VITAE OF JAMES J. J. CLARK; 3 | Page
Client – Confidential, Los Angeles, California
Dr. Clark is performing a comprehensive review of the potential for pharmaceuticals and their by-products to impact groundwater and surface water supplies. This evaluation will include a review if available data on the history of pharmaceutical production in the United States; the chemical characteristics of various pharmaceuticals; environmental fate and transport; uptake by xenobiotics; the potential effects of pharmaceuticals on water treatment systems; and the potential threat to public health. The results of the evaluation may be used as a briefing tool for nonpublic health professionals.

PUBLIC HEALTH/TOXICOLOGY
Client: Brayton Purcell, Novato, California
Dr. Clark performed a toxicological assessment of residents exposed to methyl-tertiary butyl ether (MTBE) from leaking underground storage tanks (LUSTs) adjacent to the subject property. The symptomology of residents and guests of the subject property were evaluated against the known outcomes in published literature to exposure to MTBE. The study found that residents had been exposed to MTBE in their drinking water; that concentrations of MTBE detected at the site were above regulatory guidelines; and, that the symptoms and outcomes expressed by residents and guests were consistent with symptoms and outcomes documented in published literature.

Client: Covanta Energy, Westwood, California
Evaluated health risk from metals in biosolids applied as soil amendment on agricultural lands. The biosolids were created at a forest waste cogeneration facility using 96% whole tree wood chips and 4 percent green waste. Mass loading calculations were used to estimate Cr(VI) concentrations in agricultural soils based on a maximum loading rate of 40 tons of biomass per acre of agricultural soil. The results of the study were used by the Regulatory agency to determine that the application of biosolids did not constitute a health risk to workers applying the biosolids or to residences near the agricultural lands.

Client: Kaiser Venture Incorporated, Fontana, California Prepared PBPK assessment of lead risk of receptors at a 1,100-acre former steel mill. This evaluation was used as the basis for granting closure of the site by lead regulatory agency.

CURRICULUM VITAE OF JAMES J. J. CLARK; 4 | Page

RISK ASSESSMENTS/REMEDIAL INVESTIGATIONS
Kaiser Ventures Incorporated, Fontana, California
Prepared health risk assessment of semi-volatile organic chemicals and metals for a fifty-year old wastewater treatment facility used at a 1,100-acre former steel mill. This evaluation was used as the basis for granting closure of the site by lead regulatory agency.

ANR Freight - Los Angeles, California
Prepared a comprehensive Preliminary Endangerment Assessment (PEA) of petroleum hydrocarbon and metal contamination of a former freight depot. This evaluation was as the basis for reaching closure of the site with lead regulatory agency.

Kaiser Ventures Incorporated, Fontana, California
Prepared comprehensive health risk assessment of semi-volatile organic chemicals and metals for 23-acre parcel of a 1,100-acre former steel mill. The health risk assessment was used to determine clean up goals and as the basis for granting closure of the site by lead regulatory agency. Air dispersion modeling using ISCST3 was performed to determine downwind exposure point concentrations at sensitive receptors within a 1 kilometer radius of the site. The results of the health risk assessment were presented at a public meeting sponsored by the Department of Toxic Substances Control (DTSC) in the community potentially affected by the site.

Unocal Corporation - Los Angeles, California
Prepared comprehensive assessment of petroleum hydrocarbons and metals for a former petroleum service station located next to sensitive population center (elementary school). The assessment used a probabilistic approach to estimate risks to the community and was used as the basis for granting closure of the site by lead regulatory agency.

Client: Confidential, Los Angeles, California
Managed oversight of remedial investigation most contaminated heavy metal site in California. Lead concentrations in soil excess of 68,000,000 parts per billion (ppb) have been measured at the site. This State Superfund Site was a former hard chrome plating operation that operated for approximately 40-years.

CURRICULUM VITAE OF JAMES J. J. CLARK; 5 | Page
Client: Confidential, San Francisco, California
Coordinator of regional monitoring program to determine background concentrations of metals in air. Acted as liaison with SCAQMD and CARB to perform co-location sampling and comparison of accepted regulatory method with ASTM methodology.

Client: Confidential, San Francisco, California
Analyzed historical air monitoring data for South Coast Air Basin in Southern California and potential health risks related to ambient concentrations of carcinogenic metals and volatile organic compounds. Identified and reviewed the available literature and calculated risks from toxins in South Coast Air Basin.

IT Corporation, North Carolina
Prepared comprehensive evaluation of potential exposure of workers to air-borne VOCs at hazardous waste storage facility under SUPERFUND cleanup decree. Assessment used in developing health based clean-up levels.

Past Professional Associations
American Public Health Association (APHA)
Association for Environmental Health and Sciences (AEHS) American Chemical Society (ACS)
International Society of Environmental Forensics (ISEF) Society of Environmental Toxicology and Chemistry (SETAC) Publications and Presentations:

Books and Book Chapters
Sullivan, P., J.J. J. Clark, F.J. Agardy, and P.E. Rosenfeld. (2007). Synthetic Toxins In The Food, Water and Air of American Cities. Elsevier, Inc. Burlington, MA.

Sullivan, P. and J.J. J. Clark. 2006. Choosing Safer Foods, A Guide To Minimizing Synthetic Chemicals In Your Diet. Elsevier, Inc. Burlington, MA.

Sullivan, P., Agardy, F.J., and J.J.J. Clark. 2005. The Environmental Science of Drinking Water. Elsevier, Inc.

Burlington, MA.

Sullivan, P.J., Agardy, F.J., Clark, J.J.J. 2002. America’s Threatened Drinking Water: Hazards and Solutions.

Trafford Publishing, Victoria B.C.

Clark, J.J.J. 2001. “TBA: Chemical Properties, Production & Use, Fate and Transport, Toxicology, Detection in Groundwater, and Regulatory Standards” in Oxygenates in the Environment. Art Diaz, Ed.. Oxford University Press: New York.

CURRICULUM VITAE OF JAMES J. J. CLARK; 6 | Page
Clark, J.J.J. 2000. “Toxicology of Perchlorate” in Perchlorate in the Environment. Edward Urbansky, Ed.

Kluwer/Plenum: New York.

Clark, J.J.J. 1995. Probabilistic Forecasting of Volatile Organic Compound Concentrations At The Soil Surface From Contaminated Groundwater. UMI.

Baker, J.; Clark, J.J.J.; Stanford, J.T. 1994. Ex Situ Remediation of Diesel Contaminated Railroad Sand by Soil Washing. Principles and Practices for Diesel Contaminated Soils, Volume III. P.T. Kostecki, E.J. Calabrese, and C.P.L. Barkan, eds. Amherst Scientific Publishers, Amherst, MA. pp 89-96.

Journal and Proceeding Articles
Tam L. K.., Wu C. D., Clark J. J. and Rosenfeld, P.E. (2008) A Statistical Analysis Of Attic Dust And Blood Lipid Concentrations Of Tetrachloro-p-Dibenzodioxin (TCDD) Toxicity Equialency Quotients (TEQ) In Two Populations Near Wood Treatment Facilities. Organohalogen Compounds, Volume 70 (2008) page 002254.

Tam L. K.., Wu C. D., Clark J. J. and Rosenfeld, P.E. (2008) Methods For Collect Samples For Assessing Dioxins And Other Environmental Contaminants In Attic Dust: A Review. Organohalogen Compounds, Volume 70 (2008) page 000527
Hensley A.R., Scott, A., Rosenfeld P.E., Clark, J.J.J. (2007). “Attic Dust And Human Blood Samples Collected Near A Former Wood Treatment Facility.” Environmental Research. 105:194-199.

Rosenfeld, P.E., Clark, J. J., Hensley, A.R., and Suffet, I.H. 2007. “The Use Of An Odor Wheel Classification For The Evaluation of Human Health Risk Criteria For Compost Facilities” Water Science & Technology. 55(5):
345-357.

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

Rosenfeld, P.E., Clark, J. J. and Suffet, I.H. 2005. “The Value Of An Odor Quality Classification Scheme For Compost Facility Evaluations” The U.S. Composting Council’s 13th Annual Conference January 23 - 26, 2005, Crowne Plaza Riverwalk, San Antonio, TX.

Rosenfeld, P.E., Clark, J. J. and Suffet, I.H. 2004. “The Value Of An Odor Quality Classification Scheme For Urban Odor” WEFTEC 2004. 77th Annual Technical Exhibition & Conference October 2 - 6, 2004, Ernest N. Morial Convention Center, New Orleans, Louisiana.

Clark, J.J.J. 2003. “Manufacturing, Use, Regulation, and Occurrence of a Known Endocrine Disrupting Chemical (EDC), 2,4-Dichlorophnoxyacetic Acid (2,4-D) in California Drinking Water Supplies.” National Groundwater Association Southwest Focus Conference: Water Supply and Emerging Contaminants. Minneapolis, MN. March 20, 2003.

Rosenfeld, P. and J.J.J. Clark. 2003. “Understanding Historical Use, Chemical Properties, Toxicity, and Regulatory Guidance” National Groundwater Association Southwest Focus Conference: Water Supply and Emerging Contaminants. Phoenix, AZ. February 21, 2003.

CURRICULUM VITAE OF JAMES J. J. CLARK; 7 | Page
Clark, J.J.J., Brown A. 1999. Perchlorate Contamination: Fate in the Environment and Treatment Options. In Situ and On-Site Bioremediation, Fifth International Symposium. San Diego, CA, April, 1999.

Clark, J.J.J. 1998. Health Effects of Perchlorate and the New Reference Dose (RfD). Proceedings From the Groundwater Resource Association Seventh Annual Meeting, Walnut Creek, CA, October 23, 1998.

Browne, T., Clark, J.J.J. 1998. Treatment Options For Perchlorate In Drinking Water. Proceedings From the Groundwater Resource Association Seventh Annual Meeting, Walnut Creek, CA, October 23, 1998.

Clark, J.J.J., Brown, A., Rodriguez, R. 1998. The Public Health Implications of MtBE and Perchlorate in Water:

Risk Management Decisions for Water Purveyors. Proceedings of the National Ground Water Association, Anaheim, CA, June 3-4, 1998.

Clark J.J.J., Brown, A., Ulrey, A. 1997. Impacts of Perchlorate On Drinking Water In The Western United States.

U.S. EPA Symposium on Biological and Chemical Reduction of Chlorate and Perchlorate, Cincinnati, OH, December 5, 1997.

Clark, J.J.J.; Corbett, G.E.; Kerger, B.D.; Finley, B.L.; Paustenbach, D.J. 1996. Dermal Uptake of Hexavalent Chromium In Human Volunteers: Measures of Systemic Uptake From Immersion in Water At 22 PPM.

Toxicologist. 30(1):14.

Dodge, D.G.; Clark, J.J.J.; Kerger, B.D.; Richter, R.O.; Finley, B.L.; Paustenbach, D.J. 1996. Assessment of Airborne Hexavalent Chromium In The Home Following Use of Contaminated Tapwater. Toxicologist. 30(1):117-118.

Paulo, M.T.; Gong, H., Jr.; Clark, J.J.J. (1992). Effects of Pretreatment with Ipratroprium Bromide in COPD Patients Exposed to Ozone. American Review of Respiratory Disease. 145(4):A96.

Harber, P.H.; Gong, H., Jr.; Lachenbruch, A.; Clark, J.; Hsu, P. (1992). Respiratory Pattern Effect of Acute Sulfur Dioxide Exposure in Asthmatics. American Review of Respiratory Disease. 145(4):A88.

McManus, M.S.; Gong, H., Jr.; Clements, P.; Clark, J.J.J. (1991). Respiratory Response of Patients With Interstitial Lung Disease To Inhaled Ozone. American Review of Respiratory Disease. 143(4):A91.

Gong, H., Jr.; Simmons, M.S.; McManus, M.S.; Tashkin, D.P.; Clark, V.A.; Detels, R.; Clark, J.J. (1990).

Relationship Between Responses to Chronic Oxidant and Acute Ozone Exposures in Residents of Los Angeles County. American Review of Respiratory Disease. 141(4):A70.

Tierney, D.F. and J.J.J. Clark. (1990). Lung Polyamine Content Can Be Increased By Spermidine Infusions Into Hyperoxic Rats. American Review of Respiratory Disease. 139(4):A41. 1 November 11, 2025
VIA E-MAIL ONLY [email protected]
City of Elk Grove City Council
8401 Laguna Palms Way
Elk Grove, CA 5758
Re: PLNG24-031 Maverik Fueling Station and Convenience Store – Conditional Use Permit and Minor Design Review
Elk Grove City Council, November 12, 2025
Dear Members of the City Council:

I represent a Protect Elk Grove, a group of residents in the City of Elk Grove (City) concerned about environmental and community issues. My client is concerned about the potential, unexamined impacts of the proposed Maverik Fueling Station in Elk Grove (“Elk Grove Maverik Project,” or “Project”) located on Grants Pass Road/Stockton Blvd. near Highway 99.

This letter serves as an addendum to Protect Elk Grove’s September 29, 2025 appeal and responds to the City’s November 12, 2025 Staff Report (Staff Report).

I have attached technical studies from two technical experts, James Clark, air quality and hazardous waste specialist, and Tom Brohard, transportation and traffic specialist. Those letters and reports are incorporated by reference into this appeal. In summary:
• The City and the Applicant, Maverik, continue to withhold information and blindside the public during this process. This includes Maverik waiting 41 days to submit its comments on this appeal at the last minute, in a brazen attempt to prevent any scrutiny of its comments.
• The City contends that the area was “urbanized” because it was rezoned is contradicted by CEQA caselaw and common sense.

Law Office of Edward E. Yates
2060 Sutter St., #403
San Francisco, CA 94115
Addendum to Protect Elk Grove’s Appeal of Maverik Fueling Station

• The City and Maverik’s conclusions on water quality and toxics completely ignore available baseline information on State of California Water Resources Control Board databases including designation of the property as containing toxic waste contamination. This missing data renders the City’s conclusions regarding potential water quality impacts as unsupported and baseless.
• The City failed to: quantify the concentration and levels of inherent toxicity of the Toxic Air Contaminants (TACs) 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.
• The trip generation numbers used in the traffic study were hugely underestimated. Even with the daily trip generation for the Maverik Project at about 25% of what will occur, the traffic consultant’s data indicates that the intersection of Grant Line Road at East Stockton Boulevard would experience delays that significantly exceed the City’s signalized intersection performance target.
• The City and Maverik’s claims that there are no cumulative projects related to the proposed fueling station are demonstrably false. The property owner Mr. Gillam stated at the Planning Commission that he is "planning for complementary uses" and that he has prepared a preliminary site plan for "restaurants, a hotel, and coffee shops. The City’s own staff at the Planning Commission hearing confirmed that “there are future development” assumptions.

Regulation and approval of an enormous fueling station/truck stop is a serious and technical undertaking. This is because such facilities emit and discharge toxic pollutants into the City of Elk Grove’s environment. The City of Elk Grove should take its role in regulating the facility and its pollutants and traffic generation much more seriously. The City should require both review of standard State of California pollutant databases and preparation of industry standard assessments of the potential impacts of the facility on Elk Grove residents’ health.

1. The City Has Continued to Hide Information from the Public.

At the Planning Commission hearing, the City withheld information from the public until it was the subject of the public’s demand, and refused to allow Elk Grove residents to speak. The City and the Applicant, Maverik, continue to Addendum to Protect Elk Grove’s Appeal of Maverik Fueling Station

withhold information and blindside the public during this process. Protect Elk Grove’s appeal was made on September 29, 2025, yet Maverik’s attorney has chosen to wait 41 days - until the very last minute - to respond. Maverik and its attorneys have plenty of resources; this last minute letter was obviously intended to withhold arguments so that the appellant had no time to respond.

The City’s Staff Report continues to mislead the Council and the public by inaccurately minimizing the Maverik Projects impacts. Protect Elk Grove’s technical experts have shown that Maverick and the City have repeatedly withheld data, modeling, information and other baseline evidence that might question their conclusions that there are no impacts from the Project.

Our opinion remains that the City violated the Brown Open Meetings Act at the Planning Commission Hearing by: a) not allowing residents to speak during the agenda item comment period; and b) by not providing meaningful opportunity to review several critical documents which were not made available with the agenda packet that was provided to the Planning Commission.

Even if the City did not expressly violate the Brown Act, the City has blatantly violated the spirit of the law. The City’s management of the Planning Commission hearing disenfranchised Elk Grove residents who wanted an opportunity to speak and to review documents the City produced to support the application. Many Elk Grove residents went home without speaking and no one received all the Agenda materials and technical reports before the meeting because the City refused to post them.

2. Maverik’s Property is Not Substantially Surrounded by Urban Uses.

We continue to take the position that the City improperly relied on CEQA exemption, Class 32 for infill development projects. (Calif. Code Regulations, Title 14, Section 15332.) To qualify for the Class 32 exemption, the Project must be “substantially surrounded by urban uses.”
The Staff Report goes to great length to argue that “substantially surrounded” is not what it means. That instead, any urban project, with any adjacent urban uses or nearby urban zoning (as my first letter predicted) exempts an applicant from the requirement to be surrounded by urban uses. However, the Project is bordered by non-urban uses –on two full sides. Whether the property is characterized as open space or not, it is currently undeveloped and the baseline is that there are currently Addendum to Protect Elk Grove’s Appeal of Maverik Fueling Station

no urban uses on two full sides. CEQA authority is clear; a project with two sides of non-urban uses does not qualify for the Class 32 exemption.

Again, the Court in Friends of Mammoth v. Town of Mammoth Lakes Redevelopment Agency, 82 Cal. App. 4th 511, 546 (2000) dismissed the Town of Mammoth’s – and here, the City of Elk Grove’s - contention that the area was urbanized because it was rezoned or partly developed land.1 “The vacant acreage is not to be counted as urbanized merely because it is part of a parcel that has been partially developed consistent with zoning.”2 (Ibid.) See also Banker's Hill, Hillcrest, Park W. Cmty. Pres. Grp. v. City of San Diego, 139 Cal. App. 4th 249, 270-71 (2006)

3. The City and Maverik Have Ignored State Toxic Materials Databases Showing Groundwater Contamination at the Site.

CEQA Guidelines Section 15332 allows for an exemption from environmental review for in-fill development projects only if approval “would not result in any significant effects relating to traffic, noise, air quality, or water quality.” The City relies on air quality and traffic studies that are flawed and did not bother to assess on site toxics and water quality issues. As such the City and Maverik’s Staff Report and other reports do not adequately assess the Project’s direct and cumulative impacts to air quality, water quality, and traffic.

The attached letter by Jim Clark makes it clear that the City has ignored numerous publicly available documents that clearly demonstrate problems with toxics and on site water quality issues. The City’s Staff Report and Categorical Exclusion justifications, fail to include any 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 does not contain any hazardous materials and is not any active hazardous material site lists pursuant to 1 In my September 29, 2025 letter, I mistakenly said the City of Galt, instead of the City of Elk Grove.

In an email of November 4 to the City Clerk I corrected this typo. That this was a typo, was clear, yet Maverik has tried to make hay about this meaningless error. 2 The Mammoth court further clarified by holding that: The statute's language does not support the Town's interpretation. Subdivision (c) is not concerned with the extent of development. It says nothing of deeming a partially developed parcel to be a fully developed parcel. Thus, subdivision (c) does not permit us to deem the undeveloped portions of a parcel to be "land . . . developed for urban uses. (At 543)
Addendum to Protect Elk Grove’s Appeal of Maverik Fueling Station

Government Code Section 65962.5. But this is demonstrably false. Mr. Clark states that:

Even a cursory Phase I Environmental Site Assessment (ESA) would have noted properties 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. (Emphasis added.)
The City and Maverik’s conclusions completely ignore this and other such baseline information, thereby rendering the City’s conclusions regarding potential water quality impacts as unsupported and baseless. It is not that Mr. Clark simply disagrees with Maverik’s consultants, but instead that Maverik’s consultants, ignored, buried or failed to address public information about the site’s water quality. He states that:

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.

4. The City Failed To Perform An Accurate Impact Analysis On Air Quality Due to Lack of Consideration of Other Sources.

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.” Bakersfield Citizens for Local Control v.

City of Bakersfield, 124 Cal. App. 4th 1184, 1214 (2004) (quoting Communities for a Better Environment v. California Resources Agency 103 Cal.App.4th at 116).

Addendum to Protect Elk Grove’s Appeal of Maverik Fueling Station

The Staff Report has claimed that the City is not obligated by CEQA to address cumulative impacts except for those projects related to the Maverik facility. But that contention does not relate to the basic requirements for an agency to use the class 32 categorical exemption. The Class 32 CEQA exemption allows for in-fill development projects only if approval “would not result in any significant effects relating to traffic, noise, air quality, or water quality.” The City, though, makes this conclusion based on an air quality study that is flawed because it does not assess the toxics emissions from truck diesel engines. Mr. Clark writes that:

TACs, including diesel particulate matter (DPM) , contribute 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.

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.

5. The City Cannot Use the Class 32 CEQA Exemption Because its Traffic Conclusions Were Based on Erroneous Baseline Assumptions.

Similar to its Water Quality and Air Quality reports and conclusions, the City has either intentionally misstated or mistakenly used erroneous baseline numbers and assumptions. Traffic expert Tom Brohard explains what these errors were and why they are important.

Table 2 in the LTA provides a trip generation forecast for the future CMD Court Commercial Project described above. However, this forecast includes a significant error (circled in blue ink) showing only 1,503 daily trips to and from the Maverik Project. As disclosed in Table 1 in the August 15, 2025 Project Conditioning Report, the Maverik Project will actually generate 6,010 daily trips, four times higher than reported in the LTA.

Addendum to Protect Elk Grove’s Appeal of Maverik Fueling Station

Even with the erroneous daily trip generation for the Maverik Project at about 25% of what will occur, Table 3 in the LTA indicates that the intersection of Grant Line Road at East Stockton Boulevard would experience delays that significantly exceed the City’s signalized intersection performance target.

Therefore, whether or not the LOS is not used as a primary significance criteria as the City Staff Report claims, by approving this project without any adequate traffic mitigation, the City is violating its own standards. Those standards are incorporated into CEQA. (See CEQA Guidelines Section 15125(d), 15126; Chaparral Greens v. City of Chula Vista. (1996) 50 Cal.App.4th 1134, 1145 n2.

Mr. Brohard also specifically examined the City’s claim that measures would mitigate the traffic. Again, the City and Maverik’s consultants were basing their conclusion on faulty assumptions.

From my review of the available documents, the reasonably foreseeable projects including those that may be developed in the balance of the CMD Court Commercial Project, their cumulative impacts, and potential mitigation measures were not fully considered. Before approving the Maverik Project and finalizing the designs, further study and evaluation together with coordination and communication with Caltrans are required.

Mr. Brohard also pointed out that the City and Maverik’s consultants were contradicted by experienced truck drivers speaking at the Planning Commission and that he agreed:

Trucks must be able to smoothly travel within and in and out the Maverik site. It appears that some of the required turns cannot be made by large trucks without backing up and causing considerable delay and congestion on East Stockton Boulevard and within the development site. As part of the design review at this point, large truck turning templates must be overlaid at each of the required truck turns to validate that turns can be smoothly negotiated, or how larger radii can be implemented on paper before they are built and then must be rebuilt in the field. Such considerable delays have not been addressed in the traffic studies for the Maverik Project and so, it appears that such delay and congestion would be significant.

Addendum to Protect Elk Grove’s Appeal of Maverik Fueling Station

6. The City improperly relied on CEQA exemption, Class 32 for infill development projects. (Calif. Code Regulations, Title 14, Section 15332) because there was evidence at the time that there were cumulative impacts and foreseeable projects.

The Staff Report and a November 10, 2025 letter from Maverik’s attorney Casey Shorrock, claim that no applications have been filed with the City regarding future projects at the Project site, and therefore, the City is not required to examine any cumulative impacts of future projects. The Planning Commission Staff Report identifies probable future projects at the site. Further, at the September Planning Commission Hearing, (at minute 36:23) the property owner, Jim Gillam, stated that he is "planning for complementary uses" and that (contrary to no active applications see above), he has prepared a preliminary site plan for "restaurants, a hotel, and coffee shops." The City’s own staff at the Planning Commission hearing admitted that “there are future development” assumptions (at minute 10:45.) The foregoing establishes at a minimum the "probability" of future projects, especially in light of the required dedication for street widening and the abandonment of the public easement. See CCR 15065(a)(3) and 15355(b).

CEQA Guideline Section 15065(a)(3) provides:
(a) A lead agency shall find that a project may have a significant effect on the environment and thereby require an EIR to be prepared for the project where there is substantial evidence, in light of the whole record, that any of the following conditions may occur:...(3)The project has possible environmental effects that are individually limited but cumulatively considerable. "Cumulatively considerable" means that the incremental effects of an individual project are significant when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects. (Emphasis added.)3 3 See also CEQA Guidelines Section 15355(b), which provides:
"Cumulative impacts" refer to two or more individual effects which, when considered together, are considerable or which compound or increase other environmental impacts. (a) The individual effects may be changes resulting from a single project or a number of separate projects.

Addendum to Protect Elk Grove’s Appeal of Maverik Fueling Station

It is not simply that the City did not bother to query the property owner about other probable projects and developments at the Maverik and commercial center site, it appears that the City is refusing to do so, based on a narrow legal view that it does not have to. But the City is wrong – the City has a duty to reasonably research any reasonably foreseeable projects.

Conclusion
For the foregoing reasons and as set out below, the City Council should grant Protect Elk Grove’s appeal and deny the application for the Maverik Project. In the alternative, the City Council should require Maverik to review the numerous errors made by its consultants, address them, and provide mitigation measures for the project’s probable impacts to air quality, water quality, and traffic.

Sincerely,
/s/ Edward E. Yates
Cc: Kyra Killingsworth
(b) The cumulative impact from several projects is the change in the environment which results from the incremental impact of the project when added to other closely related past, present, and reasonably foreseeable probable future projects. Cumulative impacts can result from individually minor but collectively significant projects taking place over a period of time.” Emphasis Added.

CURRICULUM VITAE OF JAMES J. J. CLARK; 1 | Page
James J. J. Clark, Ph.D.

Principal Toxicologist
Toxicology/Exposure Assessment Modeling/Environmental Health Risk Assessment/Analysis/Dispersion Modeling
Education:

Ph.D., Environmental Health Science, University of California, 1995 M.S., Environmental Health Science, University of California, 1993 B.S., Biophysical and Biochemical Sciences, University of Houston, 1987 Professional Experience:

Dr. Clark is a well-recognized environmental health scientist, toxicologist, air modeler, and health scientist specializing in exposure and safety analysis. He has 30 years of experience in developing health and safety programs to comply with state and federal regulations, and tying together environmental contaminants measurements to human health impacts.

SELECTED HEALTH AND SAFETY PROJECTS
Client: Soil, Water, Air Protection Enterprise (SWAPE), Santa Monica, California Dr. Clark developed and managed the health and safety program for a consulting firm specializing in complex environmental assessments of commercial, industrial and governmental projects. In addition to developing the corporate health and safety program, James wrote and oversaw all of the site specific health and safety programs (HASPs), medical monitoring, blood borne pathogen, and ergonomic compliance protocols.

Client: Komex H2O Science, Huntington Beach, California Dr. Clark served as the corporate health and safety office for a US based division of a Canadian/UK based environmental science and engineering corporation. James developed all of the health and safety documentation necessary for compliance with State, Federal, and international investigations performed by the company. In addition to developing the corporate health and safety program, James oversaw the medical monitoring and HAZWOPER training of all U.S. based employees.

Clark & Associates
Environmental Consulting, Inc
Office
12405 Venice Blvd.

Suite 331
Los Angeles, CA 90066
Phone
310-907-6165
Email
[email protected]
CURRICULUM VITAE OF JAMES J. J. CLARK; 2 | Page
Client: Various Clients with location throughout the U.S.

Dr. Clark developed HASPs for industrial and commercial clients throughout the U.S. for site specific projects involving construction, investigation, and remediation projects. Depending on the clients’ operations the HASPs include project specific protocols for work flow and safety operations.

SELECTED AIR MODELING RESEARCH/PROJECTS
Client(s) – Multiple
Indoor Air Evaluations, California: Performed multiple indoor air screening evaluations and risk characterizations consistent with California Environmental Protection Agency’s (Cal/EPA) Department of Toxic Substances Control (DTSC) and Regional Water Quality Control Board (RWQCB) methodologies. Characterizations included the use of DTSC’s modified Johnson & Ettinger Model and USEPA models, as well as the attenuation factor model currently advocated by Cal/EPA’s Office of Environmental Health and Hazard Assessment (OEHHA).

Client – Confidential
Dr. Clark performed a comprehensive evaluation of criteria pollutants, air toxins, and particulate matter emissions from a carbon black production facility to determine the impacts on the surrounding communities. The results of the dispersion model were used to estimate acute and chronic exposure concentrations to multiple contaminants and were be incorporated into a comprehensive risk evaluation.

Client – Confidential
Dr. Clark performed a comprehensive evaluation of air toxins and particulate matter emissions from a railroad tie manufacturing facility to determine the impacts on the surrounding communities. The results of the dispersion model have been used to estimate acute and chronic exposure concentrations to multiple contaminants and have been incorporated into a comprehensive risk evaluation.

EMERGING/PERSISTENT CONTAMINANT RESEARCH/PROJECTS
Client: City of Santa Clarita, Santa Clarita, California Dr. Clark managed the oversight of the characterization, remediation and development activities of a former 1,000 acre munitions manufacturing facility for the City of Santa Clarita. The site is impacted with a number of contaminants including perchlorate, unexploded ordinance, and volatile organic compounds (VOCs). The site is currently under a number of regulatory consent orders, including an Immanent and Substantial Endangerment Order. Dr. Clark assisted the impacted municipality with the development of remediation strategies, interaction with the responsible parties and stakeholders, as well as interfacing with the regulatory agency responsible for oversight of the site cleanup.

CURRICULUM VITAE OF JAMES J. J. CLARK; 3 | Page
Client – Confidential, Los Angeles, California
Dr. Clark is performing a comprehensive review of the potential for pharmaceuticals and their by-products to impact groundwater and surface water supplies. This evaluation will include a review if available data on the history of pharmaceutical production in the United States; the chemical characteristics of various pharmaceuticals; environmental fate and transport; uptake by xenobiotics; the potential effects of pharmaceuticals on water treatment systems; and the potential threat to public health. The results of the evaluation may be used as a briefing tool for nonpublic health professionals.

PUBLIC HEALTH/TOXICOLOGY
Client: Brayton Purcell, Novato, California
Dr. Clark performed a toxicological assessment of residents exposed to methyl-tertiary butyl ether (MTBE) from leaking underground storage tanks (LUSTs) adjacent to the subject property. The symptomology of residents and guests of the subject property were evaluated against the known outcomes in published literature to exposure to MTBE. The study found that residents had been exposed to MTBE in their drinking water; that concentrations of MTBE detected at the site were above regulatory guidelines; and, that the symptoms and outcomes expressed by residents and guests were consistent with symptoms and outcomes documented in published literature.

Client: Covanta Energy, Westwood, California
Evaluated health risk from metals in biosolids applied as soil amendment on agricultural lands. The biosolids were created at a forest waste cogeneration facility using 96% whole tree wood chips and 4 percent green waste. Mass loading calculations were used to estimate Cr(VI) concentrations in agricultural soils based on a maximum loading rate of 40 tons of biomass per acre of agricultural soil. The results of the study were used by the Regulatory agency to determine that the application of biosolids did not constitute a health risk to workers applying the biosolids or to residences near the agricultural lands.

Client: Kaiser Venture Incorporated, Fontana, California Prepared PBPK assessment of lead risk of receptors at a 1,100-acre former steel mill. This evaluation was used as the basis for granting closure of the site by lead regulatory agency.

CURRICULUM VITAE OF JAMES J. J. CLARK; 4 | Page

RISK ASSESSMENTS/REMEDIAL INVESTIGATIONS
Kaiser Ventures Incorporated, Fontana, California
Prepared health risk assessment of semi-volatile organic chemicals and metals for a fifty-year old wastewater treatment facility used at a 1,100-acre former steel mill. This evaluation was used as the basis for granting closure of the site by lead regulatory agency.

ANR Freight - Los Angeles, California
Prepared a comprehensive Preliminary Endangerment Assessment (PEA) of petroleum hydrocarbon and metal contamination of a former freight depot. This evaluation was as the basis for reaching closure of the site with lead regulatory agency.

Kaiser Ventures Incorporated, Fontana, California
Prepared comprehensive health risk assessment of semi-volatile organic chemicals and metals for 23-acre parcel of a 1,100-acre former steel mill. The health risk assessment was used to determine clean up goals and as the basis for granting closure of the site by lead regulatory agency. Air dispersion modeling using ISCST3 was performed to determine downwind exposure point concentrations at sensitive receptors within a 1 kilometer radius of the site. The results of the health risk assessment were presented at a public meeting sponsored by the Department of Toxic Substances Control (DTSC) in the community potentially affected by the site.

Unocal Corporation - Los Angeles, California
Prepared comprehensive assessment of petroleum hydrocarbons and metals for a former petroleum service station located next to sensitive population center (elementary school). The assessment used a probabilistic approach to estimate risks to the community and was used as the basis for granting closure of the site by lead regulatory agency.

Client: Confidential, Los Angeles, California
Managed oversight of remedial investigation most contaminated heavy metal site in California. Lead concentrations in soil excess of 68,000,000 parts per billion (ppb) have been measured at the site. This State Superfund Site was a former hard chrome plating operation that operated for approximately 40-years.

CURRICULUM VITAE OF JAMES J. J. CLARK; 5 | Page
Client: Confidential, San Francisco, California
Coordinator of regional monitoring program to determine background concentrations of metals in air. Acted as liaison with SCAQMD and CARB to perform co-location sampling and comparison of accepted regulatory method with ASTM methodology.

Client: Confidential, San Francisco, California
Analyzed historical air monitoring data for South Coast Air Basin in Southern California and potential health risks related to ambient concentrations of carcinogenic metals and volatile organic compounds. Identified and reviewed the available literature and calculated risks from toxins in South Coast Air Basin.

IT Corporation, North Carolina
Prepared comprehensive evaluation of potential exposure of workers to air-borne VOCs at hazardous waste storage facility under SUPERFUND cleanup decree. Assessment used in developing health based clean-up levels.

Past Professional Associations
American Public Health Association (APHA)
Association for Environmental Health and Sciences (AEHS) American Chemical Society (ACS)
International Society of Environmental Forensics (ISEF) Society of Environmental Toxicology and Chemistry (SETAC) Publications and Presentations:

Books and Book Chapters
Sullivan, P., J.J. J. Clark, F.J. Agardy, and P.E. Rosenfeld. (2007). Synthetic Toxins In The Food, Water and Air of American Cities. Elsevier, Inc. Burlington, MA.

Sullivan, P. and J.J. J. Clark. 2006. Choosing Safer Foods, A Guide To Minimizing Synthetic Chemicals In Your Diet. Elsevier, Inc. Burlington, MA.

Sullivan, P., Agardy, F.J., and J.J.J. Clark. 2005. The Environmental Science of Drinking Water. Elsevier, Inc.

Burlington, MA.

Sullivan, P.J., Agardy, F.J., Clark, J.J.J. 2002. America’s Threatened Drinking Water: Hazards and Solutions.

Trafford Publishing, Victoria B.C.

Clark, J.J.J. 2001. “TBA: Chemical Properties, Production & Use, Fate and Transport, Toxicology, Detection in Groundwater, and Regulatory Standards” in Oxygenates in the Environment. Art Diaz, Ed.. Oxford University Press: New York.

CURRICULUM VITAE OF JAMES J. J. CLARK; 6 | Page
Clark, J.J.J. 2000. “Toxicology of Perchlorate” in Perchlorate in the Environment. Edward Urbansky, Ed.

Kluwer/Plenum: New York.

Clark, J.J.J. 1995. Probabilistic Forecasting of Volatile Organic Compound Concentrations At The Soil Surface From Contaminated Groundwater. UMI.

Baker, J.; Clark, J.J.J.; Stanford, J.T. 1994. Ex Situ Remediation of Diesel Contaminated Railroad Sand by Soil Washing. Principles and Practices for Diesel Contaminated Soils, Volume III. P.T. Kostecki, E.J. Calabrese, and C.P.L. Barkan, eds. Amherst Scientific Publishers, Amherst, MA. pp 89-96.

Journal and Proceeding Articles
Tam L. K.., Wu C. D., Clark J. J. and Rosenfeld, P.E. (2008) A Statistical Analysis Of Attic Dust And Blood Lipid Concentrations Of Tetrachloro-p-Dibenzodioxin (TCDD) Toxicity Equialency Quotients (TEQ) In Two Populations Near Wood Treatment Facilities. Organohalogen Compounds, Volume 70 (2008) page 002254.

Tam L. K.., Wu C. D., Clark J. J. and Rosenfeld, P.E. (2008) Methods For Collect Samples For Assessing Dioxins And Other Environmental Contaminants In Attic Dust: A Review. Organohalogen Compounds, Volume 70 (2008) page 000527
Hensley A.R., Scott, A., Rosenfeld P.E., Clark, J.J.J. (2007). “Attic Dust And Human Blood Samples Collected Near A Former Wood Treatment Facility.” Environmental Research. 105:194-199.

Rosenfeld, P.E., Clark, J. J., Hensley, A.R., and Suffet, I.H. 2007. “The Use Of An Odor Wheel Classification For The Evaluation of Human Health Risk Criteria For Compost Facilities” Water Science & Technology. 55(5):
345-357.

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

Rosenfeld, P.E., Clark, J. J. and Suffet, I.H. 2005. “The Value Of An Odor Quality Classification Scheme For Compost Facility Evaluations” The U.S. Composting Council’s 13th Annual Conference January 23 - 26, 2005, Crowne Plaza Riverwalk, San Antonio, TX.

Rosenfeld, P.E., Clark, J. J. and Suffet, I.H. 2004. “The Value Of An Odor Quality Classification Scheme For Urban Odor” WEFTEC 2004. 77th Annual Technical Exhibition & Conference October 2 - 6, 2004, Ernest N. Morial Convention Center, New Orleans, Louisiana.

Clark, J.J.J. 2003. “Manufacturing, Use, Regulation, and Occurrence of a Known Endocrine Disrupting Chemical (EDC), 2,4-Dichlorophnoxyacetic Acid (2,4-D) in California Drinking Water Supplies.” National Groundwater Association Southwest Focus Conference: Water Supply and Emerging Contaminants. Minneapolis, MN. March 20, 2003.

Rosenfeld, P. and J.J.J. Clark. 2003. “Understanding Historical Use, Chemical Properties, Toxicity, and Regulatory Guidance” National Groundwater Association Southwest Focus Conference: Water Supply and Emerging Contaminants. Phoenix, AZ. February 21, 2003.

CURRICULUM VITAE OF JAMES J. J. CLARK; 7 | Page
Clark, J.J.J., Brown A. 1999. Perchlorate Contamination: Fate in the Environment and Treatment Options. In Situ and On-Site Bioremediation, Fifth International Symposium. San Diego, CA, April, 1999.

Clark, J.J.J. 1998. Health Effects of Perchlorate and the New Reference Dose (RfD). Proceedings From the Groundwater Resource Association Seventh Annual Meeting, Walnut Creek, CA, October 23, 1998.

Browne, T., Clark, J.J.J. 1998. Treatment Options For Perchlorate In Drinking Water. Proceedings From the Groundwater Resource Association Seventh Annual Meeting, Walnut Creek, CA, October 23, 1998.

Clark, J.J.J., Brown, A., Rodriguez, R. 1998. The Public Health Implications of MtBE and Perchlorate in Water:

Risk Management Decisions for Water Purveyors. Proceedings of the National Ground Water Association, Anaheim, CA, June 3-4, 1998.

Clark J.J.J., Brown, A., Ulrey, A. 1997. Impacts of Perchlorate On Drinking Water In The Western United States.

U.S. EPA Symposium on Biological and Chemical Reduction of Chlorate and Perchlorate, Cincinnati, OH, December 5, 1997.

Clark, J.J.J.; Corbett, G.E.; Kerger, B.D.; Finley, B.L.; Paustenbach, D.J. 1996. Dermal Uptake of Hexavalent Chromium In Human Volunteers: Measures of Systemic Uptake From Immersion in Water At 22 PPM.

Toxicologist. 30(1):14.

Dodge, D.G.; Clark, J.J.J.; Kerger, B.D.; Richter, R.O.; Finley, B.L.; Paustenbach, D.J. 1996. Assessment of Airborne Hexavalent Chromium In The Home Following Use of Contaminated Tapwater. Toxicologist. 30(1):117-118.

Paulo, M.T.; Gong, H., Jr.; Clark, J.J.J. (1992). Effects of Pretreatment with Ipratroprium Bromide in COPD Patients Exposed to Ozone. American Review of Respiratory Disease. 145(4):A96.

Harber, P.H.; Gong, H., Jr.; Lachenbruch, A.; Clark, J.; Hsu, P. (1992). Respiratory Pattern Effect of Acute Sulfur Dioxide Exposure in Asthmatics. American Review of Respiratory Disease. 145(4):A88.

McManus, M.S.; Gong, H., Jr.; Clements, P.; Clark, J.J.J. (1991). Respiratory Response of Patients With Interstitial Lung Disease To Inhaled Ozone. American Review of Respiratory Disease. 143(4):A91.

Gong, H., Jr.; Simmons, M.S.; McManus, M.S.; Tashkin, D.P.; Clark, V.A.; Detels, R.; Clark, J.J. (1990).

Relationship Between Responses to Chronic Oxidant and Acute Ozone Exposures in Residents of Los Angeles County. American Review of Respiratory Disease. 141(4):A70.

Tierney, D.F. and J.J.J. Clark. (1990). Lung Polyamine Content Can Be Increased By Spermidine Infusions Into Hyperoxic Rats. American Review of Respiratory Disease. 139(4):A41.

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
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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
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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
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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
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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
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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 — — — — — — —
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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
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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 — — — — — — —
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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)
— — — — — — — — — — — — — — — — — —
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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 — — — — — — — — — — — — — — — — — —
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
P (801) 521-8529 AWAEngineering.net PO BOX 16747, Salt Lake City, UT 84116 Civil Engineering • Land Surveying • Landscape Architecture • Transportation Engineering • Land Use Planning November 11, 2025
Project Name: Maverik – Elk Grove
Project Address: 10490 East Stockton Boulevard, Elk Grove, CA 95624 To Whom it May Concern,
The intent of this memorandum is to address the concerns articulated by Mr. Tom Brohard under “Review of the Maverik Project in the City of Elk Grove – Transportation and Circulation Issues”, dated November 7, 2025. That letter was prepared on behalf of Protect Elk Grove, the appellant of the City of Elk Grove Planning Commission’s September 18, 2025, approval of the Maverik Fueling Station (PLNG-24-031).

Mr. Brohard lists item no. 2, Free Right Turn From Southbound East Stockton Boulevard as an area needing further evaluation. This free right turn has been designed and detailed to the satisfaction of the City and is on display in the exhibits attached to this memorandum as an appendix. The free-right design was coordinated with the City and additional detail was provided per recommendations of the Planning Commission. The design satisfies the City’s performance standard of less than 55.1 seconds of delay without requiring any significant roadway widening along East Stockton Boulevard or Grant Line Road, as Mr. Brohard suggested.

Mr. Brohard also lists item no. 3, Off-Street Trail On The North Side Of Grant Line Road as an area needing further evaluation. The proposed multi-use trail was reviewed and approved by the City’s Trail Committee during a meeting on January 27th, 2025. The typical 36’-wide landscape corridor section includes a multi-use trail, an equestrian tread, and a varying number and styles of landscaping buffers, however, the Trail Committee decided to replace the equestrian tread with additional landscape buffering (see attached meeting minutes dated March 17, 2025). The Trail Committee’s decision is reflected in the plans submitted for PLNG-24-031. Mr.

Brohard’s suggestion to alter Grant Line Road striping is not supported by the City’s review.

Thank you,
James Copeland, Project Manager
C-STORE 50_L_XR_2102 5,951 SF FF = 47.50'
2010 North Redwood Road, Salt Lake City, Utah 84116
(801) 521-8529 - AWAengineering.net
C-STORE 50_L_XR_2102 5,951 SF FF = 47.50'

NO PARKING
2010 North Redwood Road, Salt Lake City, Utah 84116
(801) 521-8529 - AWAengineering.net
C-STORE 50_L_XR_2102 5,951 SF FF = 47.50'

NO PARKING
2010 North Redwood Road, Salt Lake City, Utah 84116
(801) 521-8529 - AWAengineering.net

CITY OF ELK GROVE TRAILS COMMITTEE
Mark Mendenhall, Chair
Sharon Anderson, Vice Chair
Mark Doty  Christopher Neumann  Sheri Noblett
Incorporated July 1, 2000 Web: www.elkgrovecity.org

ELK GROVE TRAILS COMMITTEE REGULAR MEETING
Monday, March 17, 2025 at 6:00 p.m.

Elk Grove City Hall
8400 Laguna Palms Way, Elk Grove, CA 95758
City Council Chambers
AGENDA

1. CALL TO ORDER / ROLL CALL

2. APPROVAL OF AGENDA

3. PUBLIC COMMENT
Members of the public may comment on matters that are not included on the agenda that the Trails Committee has jurisdiction over. Each speaker will be limited to one (1) three (3) minute comment opportunity.

4. APPROVAL OF MINUTES

4.1 REGULAR MEETING MINUTES OF JANUARY 27, 2025.

5. DEVELOPMENT PROJECT/CAPITAL IMPROVEMENT PROJECT REVIEW None.

6. PROJECT UPDATES, INFORMATIONAL ITEMS AND PRESENTATIONS

6.1 TRAIL BOLLARD DISCUSSION
Staff will provide an update on the City’s approach to bollards at trail entrances and seek feedback from the Committee.

6.2 MAY IS BIKE MONTH & BIKE RIDE WITH CITY STAFF
The Committee will discuss ideas for promoting May is Bike Month and provide feedback. As part of May is Bike Month, there will be a Trails Committee bike ride scheduled with City Staff. The Committee will discuss potential routes and key items to highlight while on the ride.

6.3 TRAILS COMMITTEE ANNUAL REPORT TO CITY COUNCIL
The Committee will review and discuss the draft Annual Trails Committee update, scheduled for the April 23, 2025, City Council meeting.

7. FUTURE AGENDA ITEMS
The Trails Committee may provide direction to staff for future agenda items.

8. ADJOURNMENT

ADA COMPLIANCE STATEMENT
In compliance with the Americans with Disabilities Act, if you need special assistance to participate in this meeting, please contact the Secretary at (916) 478-3620 / TTY 888-435-6092. Notification 48 hours prior to the meeting will enable the City to make reasonable arrangements to ensure accessibility to this meeting. Information on the Elk Grove Trails Committee is available on the internet at http://elkgrovecity.org/trails-committee/index.asp

CITY OF ELK GROVE TRAILS COMMITTEE

REGULAR MEETING MINUTES
MONDAY, JANUARY 27, 2025
The meeting was called to order by the Chair at 6:02 p.m. with the following participants:

Trails Committee Members Present: Chair Mark Mendenhall, Vice Chair Sharon Anderson, Committee Members Mark Doty, Sheri Noblett, Chris Neumann (arrived at 6:05 p.m.)
Trails Committee Members Absent:

City Staff/Consultants/Advisory
Members:

Kaley Lyons, Senior Transportation Planner
Christina Castro, CIP Division Manager
Kyra Killingsworth, Senior Planner
Jason Hone, Assistant Director, Community Development
Kaylah Ball, CivicSpark Fellow
Todd Meyers, Maverik Senior Site Development Manager
Rick Magnus, AWA Engineering

APPROVAL OF AGENDA
MOTION: M/S Doty/Anderson to approve the agenda as presented. The motion passed by the following vote: Ayes: 4 (Mendenhall, Noblett, Anderson, Doty); Noes: 0; Absent: 1 (Neumann).

PUBLIC COMMENT
There was no public comment.

APPROVAL OF MINUTES
None.

DEVELOPMENT/CAPITAL IMPROVEMENT PROJECT REVIEW
ITEM 5.1 PLNG24-031 MAVERIK FUELING STATION
The proposed Project site is located at the corner of East Stockton Boulevard and Grant Line Road on three parcels at 10490 Grant Line Road. The Applicant is requesting a Major Design Review, Conditional Use Permit and Boundary Line Adjustment for a new fueling station and convenience store with on site improvements.

Kyra Killingsworth, Senior Planner, presented the item. Todd Meyers, the Maverik Senior Site Development Manager, was present. Rick Magnus, a Consulting Engineer with AWA Engineering, was also present.

Vice Chair Anderson opened comment to discuss the addition of a trail. She noted the proposed trail included an equestrian component and said due to the lack of other equestrian facilities along westbound Grant Line/Kammerer Rd, the equestrian trail may not be necessary. The Committee agreed.

Chair Mendenhall pointed out that other Maverik locations have large truck traffic. Ms. Killingsworth showed where vehicles would move through the gas station area.

Vice Chair Anderson asked if there was an existing sidewalk along E Stockton Blvd. The Project Applicant confirmed that there is a 4 ft. sidewalk.

Vice Chair Anderson expressed concern about bikes coming down E Stockton Blvd.

Chair Mendenhall said that he anticipates a bike route connecting the Grant Line trail over SR99 and past Promenade Pkwy. He said it was difficult to bike through the E Stockton Blvd/Grant Line Rd intersection. He requested particular attention to this intersection going forward. The Committee Elk Grove Trails Committee
Regular Meeting Minutes
Monday, January 27, 2025 Page | 2
agreed.

Christina Castro said impacts would be analyzed.

Vice Chair Anderson expressed concern with the increase of big rig trucks in the area. Chair Mendenhall concurred that the truck radius looked tight.

Rick Magnus and Todd Meyers, representing the Project Applicant, said the traffic study was under review.

Member Noblett suggested using the unused 5 feet of equestrian trail to add more space to the pedestrian path for a wider buffer from Grant Line Rd.

Chair Mendenhall suggested widening the sidewalk enough to make it a multi-use trail.

ITEM 5.2 WTL016 LAGUNA CREEK INTER-REGIONAL TRAIL CROSSING AT STATE ROUTE 99 Christina Castro presented the item.

Ms. Castro presented three designs: Baseline (matches the current Sheldon overcrossing), “Traditional Truss,” and “Creek & Trees,” in order of cost and said Caltrans must approve the final design.

Chair Mendenhall and Member Noblett agreed the smaller decorative trees were unnecessary for the “Creek & Trees” design. Member Neumann suggested keeping the creek without the trees.

Vice Chair Anderson suggested attaching decorations, like the bird designs decorating I-5, for a lower cost option.

Chair Mendenhall said it should be some combination of “Traditional Truss” and “Creek & Trees.” Member Noblett suggested having the arches only where the trees are, or placing two arches where they convene at the tree motif.

Member Neumann concurred with Member Noblett, the green tree shape on the arches was excessive.

He supported the idea of a combination of “Traditional Truss” and “Creek & Trees.” Member Doty said that a cheaper, decent design is preferable to a more expensive design that would take longer to construct.

Chair Mendenhall recommended installing the lighting on top of the fence like the existing overcrossing, but with a more fluid lighting design.

Vice Chair Anderson said the decorative trees should resemble oaks, not palm trees.

Kaley Lyons pointed out the painted blue “creek” on the overcrossing walkway, which may be slippery.

The Committee agreed there should be no confusing colors or potentially slippery details on the bridge.

Member Noblett said the blue paint was too minimalistic for a creek design. However, Ms. Castro said the adjacent Creekside Church supported the creek design.

Vice Chair Anderson asked if there would be flat areas on the inclines similar to other overcrossings. Ms.

Castro said they weren’t included in the proposal because the incline is 5% or less.

Chair Mendenhall concluded that the current “Creek & Trees” design is too busy.

The Committee came to consensus that construction timing was more important than an elaborate design that would cost more and take longer to implement.

ITEM 5.3 CAPITAL IMPROVEMENT PROGRAM UPDATE
Christina Castro presented the item, including seven new Rectangular Rapid Flashing Beacons, funded through HSIP grant, and WTL041 for trail system maintenance, similar to the pavement maintenance program. She said she was proposing to increase the annual budget for trail maintenance.

Vice Chair Anderson said there was often development money but no maintenance money. She added that the north area of Elk Grove was not well-funded.

Elk Grove Trails Committee
Regular Meeting Minutes
Monday, January 27, 2025 Page | 3
Ms. Castro said that Operations & Maintenance (O&M) performs trail rehabilitation annually. She said they were looking at new bollards standards and proposing to have O&M replace bollards as part of the regular trail maintenance program.

Chair Mendenhall said the bollards should be removed completely, especially where they pose a hazard. He gave an example on the trail down to Bartholomew Park and said users didn’t expect the post to be there. Ms. Lyons confirmed that the City was looking at a policy around bollard placement.

Chair Mendenhall asked if there were any curb ramp projects. Ms. Castro said there were spot repairs throughout the City.

Vice Chair Anderson asked about a project that was supposed to bring sidewalk improvements from the Camden neighborhood and northward along Elk Grove-Florin Rd. Ms. Castro said that sidewalk improvements were made on the east side of W Camden Dr and some curb ramps were installed. Vice Chair Anderson pointed out the traffic from pedestrians and kids on bikes up to Sheldon Rd.

Vice Chair Anderson brought up the area south of E Stockton Blvd/Elk Grove-Florin Rd intersection being repaved. She said there was no bike lane, only gravel, south to Grant Line Rd. Ms. Castro said the City was looking at a project for future grants to install a class 4 bike lane on the west side of E Stockton Blvd, 10 feet wide and bidirectional. However, it would need to be reconfigured when the Whitelock interchange is built.

Member Doty brought up the CIP community meeting. He said there was no trailhead sign for Laguna Creek Trail at Waterman/Bond Rd, so people don’t know the entrance is there. Ms. Castro said it would be included in the trail wayfinding project to identify all facilities, and Laguna Creek Trail was going to be prioritized for new signage.

PROJECT UPDATES, INFORMATIONAL ITEMS, AND PRESENTATIONS ITEM 6.1 TRAILS COMMITTEE BIENNIAL REORGANIZATION
Chair Mendenhall said the Trails Committee holds elections for Chair and Vice Chair on the Mayoral election cycle and announced it was time to select Chair and Vice Chair for the upcoming term.

Chair Mendenhall was nominated to continue to serve as Chair and he accepted the nomination.

MOTION: M/S Doty/Noblett to approve Mark Mendenhall as Trails Committee Chair. The motion passed by the following vote: Ayes: 5 (Anderson, Doty, Mendenhall, Neumann, Noblett); Noes: 0; Absent: 0.

Vice Chair Anderson was nominated to continue to serve as Vice Chair and she accepted the nomination.

MOTION: M/S Mendenhall/Neumann to approve Sharon Anderson as Trails Committee Vice Chair. The motion passed by the following vote: Ayes: 5 (Anderson, Doty, Mendenhall, Neumann, Noblett); Noes:
0; Absent: 0.

TRAILS COMMITTEE MATTERS/FUTURE AGENDA ITEMS
Chair Mendenhall noted there hadn't been an ethics item in a while. Ms. Lyons said she may organize an ethics training at a future meeting.

Ms. Lyons mentioned activities for the City of Elk Grove’s 25th birthday from July through December.

Chair Mendenhall agreed to design a bike route forming a 2 and 5 on a map.

There will be no meeting in February. The next meeting will be March 17, 2025.

Elk Grove Trails Committee
Regular Meeting Minutes
Monday, January 27, 2025 Page | 4

ADJOURNMENT
The Elk Grove Trails Committee Regular Meeting of January 27, 2025, was adjourned at 7:22 p.m.

Prepared by Kaley Lyons
APPROVED:
 



 










 








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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 11, 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: Supplemental 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 supplemental response to Protect Elk Grove’s (Appellant) appeal of the Planning Commission’s action. This letter responds to material prepared by Clark & Associates and Tom Brohard and Associates dated November 7, 2025.

Maverik appreciates any consideration that the City can give this supplemental response letter. 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. PROJECT IS EXEMPT FROM CEQA REVIEW
A. Appellant Acknowledges that the Project Is Substantially Surrounded by Urban Uses and Contains No Sensitive Habitat
As explained in Maverik’s November 10, 2025, response letter, the Class 32 categorical exemption to review under the California Environmental Quality Act (CEQA) City Council
RE: Supplemental Response to Appeal of PC Approval of Maverik Fueling Station November 11, 2025