Att 17 - Public Comments — Special City Council, June 5, 2023

6.2.23 Dear Fort Bragg Council members,
On June 5, the council will hold another council meeting to review, discuss and take in public opinion regarding the Grocery Outlet's application.

My hope after all this time, that it passes and no one tries to challenge it.

Owning a restaurant, has had its challenges, especially during the pandemic. Now, we are facing rising food prices and some shortages. I also have my employees to consider. Living here is not always easy. I know this Grocery Outlet will be helpful to so many. I shop at all the stores in the area. This will not change. However, this store will benefit so many.

I am especially excited to hear more jobs will be created. Along with having the business district improved upon.

I know you have thought about this project along with the staff, and have put in many hours.

Thank you for all you do to continue to make Fort Bragg even more special than it already is.

Lastly, a yes vote would be appreciated.
z.;tL9fak
Cordelia Fortier
Home Style Cafe
790 S Main Street
Fort Bragg. CA
From: Clara Estelle Shook
To: City Clerk
Subject: Grocery Outlet Meeting - June 5th is not adequate notice of meeting Date: Sunday, May 28, 2023 5:13:35 PM
Attachments: screenshot.png
Hello,
I have attended several of the Planning Commission and City Council meetings on this topic.

Once again, I am having to take time away from my busy work schedule to advocate for affordable food in our community. This is feeling really ridiculous.

The City Council has approved this project before, but a few of the City Council members are new to this project, so I understand that we need to go through this all over again.

The public notification on how to participate in the June 5th City Council Grocery Outlet Meeting viz Zoom link has not been made available to the public within an adequate amount of time. The public who have signed up to be notified of this particular meeting agenda have not been notified by today's date (May 28, 2023).

There has been an extremely well-funded opposition to this project through the Fort Bragg California Local Business Matters Group. So far, whoever is funding this opposition has remained anonymous. The Fort Bragg public has a right to know who is funding the opposition to this project.

Per capita income in the past 12 months (in 2021 dollars), 2017-2021 $27,582, according to the 2022 Census (please see screenshot).

This is not an affluent community, and we need to be able to provide the basic necessities for welfare, which include affordable food. We cannot have employees to serve the tourism industry, which is Fort Bragg's largest source of revenue if the citizen of Fort Bragg cannot afford to eat.

This project is an opportunity to support Fort Bragg's welfare and its people. This is your opportunity to make an actual difference for the Fort Bragg residents who need your help.

Please help us move this project along, so that the people of Fort Bragg may come home in the evening and have enough food for their families to eat because right now many are going hungry unnoticed.

Thank you.

Best,
Clara Shook
PO Box 1626
Mendocino, CA 95460
6) U.S. Census Bureau QuickFacts X +
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0 Per capita income in past 12 months (in 2021 dollars), 2017-2021 Population
0 Population Estimates, July I, 2022, (V2022)
0 Population estimates base, April I, 2020, 0/20'22)
0 Population, percent change -April I, 2020 (estimates base) to July I, 2022, (V2022) 0 Population, CellSUs, April I, 2020
0 Population, CellSUs, April I, 2010
Age and Sex
0 Persons under 5 years, percent
0 Persons under 18 years, percent
0 Persons 65 year, and over, percent
0 Female persons, percent
Race and Hispanic Origin
0 White alone, percent
0 Black or African American alone, percent (a)
0 American Indian and Alaska Native alone, percent {a)
0 Asian alone, percent (a)
0 Native Hawaiian and Other Pacific blander alone, percent (a) 0 Two or More Races, percent
0 Hispanic or Latino, percent (b)
0 White alone, not Hispanic or Latino, percent
Population Characteristics
0 Veterans, 2017-2021
0 Foreign bom per,ons, percent, 2017-2021
Housing
0 Housing units, July 1, 2022, (V2022)
0 O,mer-occupied bowing unit rate, 2017-2021
0 Median value ofo"ner-occupied housing units, 2017-2021 0 Median selected monthly owner cost, -\\ith a mortgage, 2017-2021 0 Median selected monthly o\\ner costs -\\ithout a mortgage, 2017-2021 0 Mediangrossrent, 2017-2021
C) Building permits, 20'22
Families & Lhing Arrangements
0 Households, 2017-2021
•
Fort Bragg cliy,
Coliforni•
& 6,881
& 6,986
& -1.5%
6,983 ---7,273
& 9.4%
& 26.2%
& 23.3%
& 55.8%
& 75.2%
& 1.0%
& 2.0%
& l.1%
& 0.0%
& 14.3%
& 34.9%
& 55.9%
342

16.5%
X

39.3%
$393,300
$1,830
$792
$1,070
X
2,925
V oJ
5:07 PM
(j' c1,i) s128!2023 C
Hearing: June 5, 2023
Project: Grocery Outlet – Vote
YES
To the Fort Bragg City Council,
I am a local business owner of the hotel right across the street from the old Social Services office, which is the building site where the new Grocery Outlet will be built.

As a local business and a neighbor to the location, I support the Grocery Outlet’s application.

The Social Services building used to have employees and visitors. Now, it looks abandoned attracting those that are partaking in drug activity, and where local police are called to the site frequently. I have seen the needles left behind.

This New store would help our employees and guests. Right now, my guests have to witness the drug and other activity taking place at the dilapidated building. I worry more about the lawlessness at the old Social Services building. It is also health hazard. We end up picking up much of the trash that is left there and blows into our parking lot. It would better having a new clean store, than having a run-down building that attracts homeless, and is a magnet for drug activity and other police activity, just check the logs.

We will have hotel guests that can utilize the store for long term stays.

It would be a value to our hotel, our customers, and the local residents who could conveniently pick up food items. I am particularly excited there will be better lighting and legitimate business activity on this corner.

We work so hard to keep our building well maintained and to provide a quality place for people who want to visit the area. I feel, we are doing our part. I wish the city would do their part, and approve this building plan.

This has been discussed for so long. It would be so painful to see this applicant go away after years of planning to only be rejected. We need this and so much more in Fort Bragg.

Lastly, my hope is that there are no more lawsuits. A new store on that corner will bring more vitality, and versatility to Fort Bragg. Please vote Yes to the new store.

Sincerely,
Brittney Govind, Co-Owner, SeaBird Lodge
SeaBird Lodge -191 South Street, Fort Bragg, CA 95437- 707/964-8000 ---'-ff WtbO't, Lite---'-
LODGE
120 NORTH HARBOR DRIVE
FT . BRAGG , CALIFORNIA 95437
(707) 964-0221
~
May 31, 2023
Dear City Council Members,
I am writing this letter in su.pport
of the Grocery Outlet across the street from Harbor Lite Lodge. I believe this would be an asset to our community and would provide many job opportunities for our coast.

This business will offer affordable food for lower income residents within our community.

Thank you for your consideration of approval for this
project.

Sincerely,
Omie Behrns
General Manager
(707)964-0221
Dear City Development Department and City Clerk
5/31/23
I am a regular cyclist and one of the founding members of Seniors On Bikes Fort Bragg. I regularly
ride my bicycle from my home off Benson Lane down highway 20 towards Highway 1. I am a
consistent user of the both the South and North Coastal Trails.

The draft EIR analysis of traffic effects of the Grocery Outlet Store are definitely outdated and need
to be redone. That analysis is five years out of date (2019). The traffic in Fort Bragg has increased
greatly since the Covid outbreak in 2020. Many more people are driving their cars in the area. Also,
more people are riding bicycles due to being unemployed and the economic effect of Covid on the
economy.Many of these new cyclists are extremely inexperienced in riding in traffic with automobiles.

I am a very experienced bicyclist having worked for 6.5 years at a bicycle delivery business in
Santa Barbara, CA which has a higher population than all of Mendocino County. I have also ridden
a bicycle from Eugene Oregon to Santa Barbara CA. I have also participated in the Konocti
Challenge five times. The first two times i rode in the metric century option there.

It has already become too dangerous for me to ever attempt to attempt the entrance to the
Southern Coastal trail from Highway 1 just north of the Noyo River Bridge. I recently had an
accident while attempting to do so and had a head injury even though I was wearing a helmet. I
blacked out and had to be helicoptered to a hospital in Santa Rosa.

As a result, I never attempt to enter the trail at that point. I now always go to the Cypress
Street intersection with Highway 1. Traffic will increase there as well due to the Grocery Outlet
project as outlined in the draft EIR. This will make a trip to the Adventist Hospital more full of traffic
and will increase traffic and its pollution for many residents in the housing areas along the way
there.

The Grocery Outlet store will increase traffic on highway 20 and on the traffic coming from south
of the Hare Creek bridge as well. The bridge is already substandard for the existing traffic. It is so
dangerous for bicycles that I already avoid using it. Caltrans has no plans for improving that bridge
until 2025 at a cost of more than 23 and a half million dollars.

The Grocery Outlet project will increase automobile traffic in Fort Bragg in general. Especially
during the tourist season. This traffic has already increased due to global climate change making
the weather drier and hotter inland from our coast.

These factors make it necessary to reevaluate the Grocery Outlet project and its impact on the traffic
situation because of how it may effect the tourist trade in our area which is a main economic generator
here.

Edward M. Oberweiser
19244 Benson Lane
Fort Bragg, CA
707-964-7065
[email protected]
From: Jacob Patterson
To: City Clerk
Cc: cdd
Subject: Public Comment -- 6/5/2023 CC Special Meeting, GrocOut Special Conditions Date: Wednesday, May 31, 2023 2:27:41 PM
Attachments: Recommended Revisions to Special Conditions.docx Recommended Revisions to Special Conditions.pdf
City Council,
Please consider the following suggested revisions to the draft special conditions recommended by the Planning Commission for the Grocery Outlet project. I already commented about why I think these (or similar) revisions are justified in my prior comment but the specific language I recommend is attached in both Word and PDF. The blue italicized content represents the changes made by Marie and approved during the Planning Commission's public hearing. The redlines are my suggested revisions for your consideration based on the PC's resolution that will be in the published agenda materials for your public hearing.

9.l...Preserve and protect the existing Monterey Cypress ~ nd the Shore Pine trees on site, iUi-to the maximum extent feasible and employing BMPs .aMJ /including installing protective fencing around a tree protection zone for each existing tree established at five (5) feet out from the tree canopy dn·p line prior to and during any demolition or construction activities prohibit any material storage or heaw equipment storage or operation within the tree protection zones inside of which all work will be performed by hand tools or air spades to avoid damage to the root structures of the trees and prohibiting cutting or severing any root of the existing trees with a diameter of one (1) inch or more· <fje_j________B_eplace the proposed Monterey Cypress Trees in the Lan~;;caping Plan with a locally native tree species.~
fl_Comply with the California Model Water Efficient Landscape Ordinance (MWELO);_fil!Q
&½]) Require the ongoing maintenance and replacement of any existing retained or newly-planted trees in the Landscaping Plan that may die during project construction or thereafter such replacement planting is required within one (1) year of the tree's death with replacement tree(s) of the same or substantially similar species as the dead tree at a ratio that will replace the prior canopy coverage of the dead removed tree(s) within five (5) years based on the size of the canopy prior to the tree's death the standard predicted canopy growth rate of that species of tree and the initial planting size of the replacement tree(s). ~Special Condition 23: To the extent otherwise permitted by the CLUDC the windows on the south side of the building may be
obscured with murals or other films or coverings so long as they don't limit passive solar gain.

Optional Special Condition 24: The applicant shall replace/cover all smooth surface CMU block on the east and north elevation of the building as well as the northern-most portion of the west elevation of the building that is visible from Main Street through the Chevron property with one of the other higher-grade materials which are already proposed for the ~uth and West-west facade of the building.

GptioRal apesial CoRditioR 2a: TAe applisaRt sAall replaso lso••er all C~~I I 91osk OR tAo est faee ofthe t11:1il8iA€1 ilh har8iBoar8 eeA:i13esile 008 13aAeliA€j.

Special Condition 34: The applicant shall install either an all-way stop or a walker:
triggered flashing lights, as recommended by a traffic engineer, at the intersection of South Franklin St. and South St., including signage, striping , and pedestrian facilities (sidewalk, curb, and gutter) to provide protected crossing at all legs of the intersection.

The proposed intersection improvement would require the installation of sidewa lk curb and gutter to City Standard Specifications for a total length of 57 linear feet along the east side of South Franklin St. as well as a curb return to provide sufficient pedestrian landing facilities on the south-east comer of the intersection. Off-site improvements shall be completed prior to issuance of final certificate of occupancy .

Special Condition 1: The applicant shall resubmit the landscaping and parking plans for Community Development Director approval. The revised parking and landscaping plan shall:
a) Delete the two parking spaces on the southwest corner of the parking lot and replace this area with native plant landscaping;
b) Eliminate the excess RV parking space, and to the degree feasible replace a portion of it with native plant landscaping;
c) Contain drought tolerant native species;
d) Preserve and protect the existing Monterey Cypress and the Shore Pine trees on site, to the maximum extent feasible and employing BMPs, including installing protective fencing around a tree protection zone for each existing tree established at five (5) feet out from the tree canopy drip line prior to and during any demolition or construction activities, prohibit any material storage or heavy equipment storage or operation within the tree protection zones, inside of which all work will be performed by hand tools or air spades to avoid damage to the root structures of the trees, and prohibiting cutting or severing any root of the existing trees with a diameter of one (1) inch or more;
e) Replace the proposed Monterey Cypress Trees in the Landscaping Plan with a locally native tree species;
f) Comply with the California Model Water Efficient Landscape Ordinance (MWELO); and
g) Require the ongoing maintenance and replacement of any existing retained or newly-planted trees in the Landscaping Plan that may die during project construction or thereafter, such replacement planting is required within one (1) year of the tree’s death with replacement tree(s) of the same or substantially similar species as the dead tree at a ratio that will replace the prior canopy coverage of the dead removed tree(s) within five (5) years based on the size of the canopy prior to the tree’s death, the standard predicted canopy growth rate of that species of tree, and the initial planting size of the replacement tree(s).

Optional Special Condition 23: To the extent otherwise permitted by the CLUDC, the windows on the south side of the building may be
obscured with murals or other films or coverings so long as they don’t limit passive solar gain.

Optional Special Condition 24: The applicant shall replace/cover all smooth surface CMU block on the east and north elevation of the building, as well as the northern-most portion of the west elevation of the building that is visible from Main Street through the Chevron property with one of the other higher-grade materials which are already proposed for the south and west facade of the building.

Optional Special Condition 25: The applicant shall replace/cover all CMU block on the west face of the building with hardiboard composite wood paneling.

Special Condition 34: The applicant shall install either an all-way stop or a walkertriggered flashing lights, as recommended by a traffic engineer, at the intersection of South Franklin St. and South St., including signage, striping, and pedestrian facilities (sidewalk, curb, and gutter) to provide protected crossing at all legs of the intersection.

The proposed intersection improvement would require the installation of sidewalk curb and gutter to City Standard Specifications for a total length of 57 linear feet along the east side of South Franklin St. as well as a curb return to provide sufficient pedestrian landing facilities on the south-east corner of the intersection. Off-site improvements shall be completed prior to issuance of final certificate of occupancy.

I
Special Condition 1: The applicant shall resubmit the landscaping and parking plans for Community Development Director approval. The revised parking and landscaping plan shall:
a) Delete the two parking spaces on the southwest corner of the parking lot and replace this area with native plant landscaping.;
b) Eliminate the excess RV parking space, and to the degree feasible replace a portion of it with native plant landscaping.;
c) Contain drought tolerant native species;
d) Preserve and protect the existing Monterey Cypress Trees and the Shore Pine trees on site, as to the maximum extent feasible and employing BMPs, and rincluding installing protective fencing around a tree protection zone for each existing tree established at five (5) feet out from the tree canopy drip line prior to and during any demolition or construction activities, prohibit any material storage or heavy equipment storage or operation within the tree protection zones, inside of which all work will be performed by hand tools or air spades to avoid damage to the root structures of the trees, and prohibiting cutting or severing any root of the existing trees with a diameter of one (1) inch or more; d)e) Replace the proposed Monterey Cypress Trees in the Land Sscaping Plan with a locally native tree species.;
f) Comply with the California Model Water Efficient Landscape Ordinance (MWELO); and
e)g) Require the ongoing maintenance and replacement of any existing retained or newly-planted trees in the Landscaping Plan that may die during project construction or thereafter, such replacement planting is required within one (1) year of the tree’s death with replacement tree(s) of the same or substantially similar species as the dead tree at a ratio that will replace the prior canopy coverage of the dead removed tree(s) within five (5) years based on the size of the canopy prior to the tree’s death, the standard predicted canopy growth rate of that species of tree, and the initial planting size of the replacement tree(s).

Optional Special Condition 25: The applicant shall replace/cover all CMU block on the west face of the building with hardiboard composite wood paneling.

The proposed intersection improvement would require the installation of sidewalk curb and gutter to City Standard Specifications for a total length of 57 linear feet along the east side of South Franklin St. as well as a curb return to provide sufficient pedestrian landing facilities on the south-east corner of the intersection. Off-site improvements shall be completed prior to issuance of final certificate of occupancy.

From: Kaitlyn E. Conover
To: Lemos, June
Cc: Jim Moose; Casey A. Shorrock; Keith F. Collins; [email protected]; [email protected]; Terry Johnson; Carl Best ([email protected]); [email protected]; [email protected] Subject: Best Development Grocery Outlet Final EIR (SCH # 2022050308)—Letter to City Council with Responses to Comments on the Final EIR.

Date: Wednesday, May 31, 2023 4:47:13 PM
Attachments: Letter to Fort Bragg City Council re. Comments on FEIR (May 31 2023) (00672894xB0A85).PDF Good afternoon,
On behalf of Best Properties, the Applicant for the proposed Best Development Grocery Outlet project in the City of Fort Bragg, Remy Moose Manley submits the attached letter to City Council containing responses to select comments on the Final EIR that were submitted to the City on May 10, 2023.

Best regards,
Kaitlyn E. Conover
Paralegal/Legal Assistant to
James G. Moose, Sabrina Teller,
Elizabeth Pollock and Casey Shorrock
R E M Y | M O O S E | M A N L E Y LLP
555 Capitol Mall, Suite 800 | Sacramento, CA 95814
P (916) 443-2745 x 209 | F (916) 443-9017
[email protected] | www.rmmenvirolaw.com
CONFIDENTIALITY NOTICE: This electronic mail message and any attachments are intended only for the use of the addressee(s) named above and may contain information that is privileged, confidential and exempt from disclosure under applicable law. If you are not an intended recipient, or the employee or agent responsible for delivering this e-mail to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you received this e-mail message in error, please immediately notify the sender by replying to this message or by telephone. Thank you.

Please consider the environment before printing this email.

RMM
May 31, 2023
Via Electronic Mail
[email protected]
City Council
City of Fort Bragg
c/o City Clerk
416 N. Franklin St.

Fort Bragg, CA 95437
Re: Best Development Grocery Outlet Final EIR (SCH # 2022050308) – Responses to legal issues raised by five letters submitted on May 10, 2023, on the Final EIR
Dear City Councilmembers:

On behalf of Best Properties (Best), the Applicant for the proposed Best Development Grocery Outlet project (Project), Remy Moose Manley, LLP (RMM) submits the following responses to legal or factual claims raised in five written submissions to the Fort Bragg Planning Commission (Commission) prior to that body’s May 10, 2023, advisory deliberations with respect to the Project. These submissions claim to identify problems with the Final Environmental Impact Report (FEIR) for the Project and, in some instances, also raise issues with the underlying Draft EIR (DEIR) and/or the Project itself.

As you know, the Planning Commission recommended that your City Council certify the FEIR and approve the Project. We were obviously very pleased with those recommendations. We are writing to assure the Council that, despite these commenters’ protestations to the contrary, actions by your body certifying the FEIR and approving the Project would not run afoul of the California Environmental Quality Act (Pub. Resources Code, § 21000 et seq.) (CEQA), the CEQA Guidelines (Cal. Code Regs., tit. 14, § 15000 et seq.), or any other applicable provisions of law.

In the discussion below, we explain in detail why these five commenters are mistaken in arguing that Project approval would violate the law. These submissions come from: (1) Mark Wolfe, of M.R. Wolfe and Associates, P.C., on behalf of Fort Bragg James G. Moose
[email protected]
RMM

REMY MOOSE MANLEY LLP
555 Capitol Ma ll, Suite 800 Sacramento CA 95814 I Phone: (916) 443-2745 I Fax: (9 16) 443-90 17 I www.rmmenvirolaw.com City Councilmembers
May 31, 2023

Page 2 ends

Local Business Matters (FBLBM); (2) Leslie Kashiwada; (3) Annemarie Weibel; (4) Jacob Patterson; and (5) North Bay Labor Council. We address each submission individually, although we cross reference analysis where applicable to avoid duplication.

Notably, in contrast to these submissions, by far the vast majority of comments on the Project submitted just prior to the May 10th hearing expressed enthusiastic support for the Project, with many people repeating the sentiment that Fort Bragg very much needs this grocery store, which will sell food at prices substantially below those of existing local grocery operations.

We hope that the City Council finds the analysis in this letter useful as its members consider the Project’s many community and regional benefits, such as (i) providing a much-needed local affordable grocery option for the many residents, especially low-income individuals and families, who currently regularly drive to Willits to shop at the Grocery Outlet there, (ii) a commensurate regional reduction in vehicle-miles traveled (VMT) compared with existing levels, (iii) the beneficial reuse of an infill site on which an existing out-of-date office structure is currently going unused, and (iv) increased tax revenues for the City. We are hopeful that, in light of these many benefits and others, the Council will see fit to approve the Project.

I. RESPONSES TO COMMENTS FROM FORT BRAGG LOCAL BUSINESS

MATTERS (FMLBM)
FBLBM asserts that the FEIR violates CEQA because some of its air quality, noise, and traffic analyses are incorrect or inadequate and because some responses to comments are allegedly inadequate. FBLBM also argues that CEQA requires the FEIR be recirculated because of its reliance on an “urban decay” analysis prepared by ALH Urban & Regional Economics (see FEIR, Appendix B).

For reasons explained in detail below, FBLBM is mistaken on all of these points.

A. The FEIR’s Air Quality Analysis of Diesel Particulate Matter is Sufficient and its Responses to Related Comments are Appropriate.

1. The FEIR’s analysis of air quality as it relates to truck-generated diesel particulate matter is sufficient and presents no CEQA violation.

FBLBM asserts, without evidence, that the FEIR violates CEQA because its air quality analysis lacks detail on the potential health impacts of diesel particulate matter City Councilmembers
May 31, 2023

Page 3 ends

(DPM) emissions from the approximate eight weekly heavy-duty truck trips and approximate four to five daily medium-duty truck trips, and specifically claims that truck refrigeration elements were not analyzed. FBLBM also asserts that the FEIR does not properly analyze the air quality impact of these trucks as they travel on Highway 1.

FBLBM is mistaken on all of these points.

These issues must be placed in proper context. The Project is simply not a major source of air pollution. With only 16,157 square feet (sf) (DEIR, p. 2.0-2), the Project is too small, and the vehicle trips associated with it are too limited, to be the source of emissions that can give rise to measurable adverse health effects. In contrast, the leading CEQA case on the health effects of air pollution involved a project that included 2,500 housing units and 250,000 square feet of commercial space located within one of the most polluted air basins in California and that resulted in a significant and unavoidable impact on air quality. (See Sierra Club v. County of Fresno (2018) 6 Cal.5th 502, 508, 528519 [Fresno Count “suffers from the ‘most severe’ ozone problems in the state”].) Here, the relatively low amounts of air pollution attributable to the Project are evident from Table 3.2-8 (Operational Project Generated Emissions) on page 3.2-21 of the DEIR. This table identifies the CEQA thresholds of significance recommended by the Mendocino County Air Quality Management District (MBAQMD) and shows the Project’s projected emissions for the identified pollutants.1 In all instances, the anticipated emissions are far, far below the significance thresholds and therefore result in a less-than-significant impact on air quality. (DEIR, p. 3.2-22.) For example, the significance threshold for PM10 is 82 pounds per day, while the Project will emit only 2.7 pounds. Similarly, the threshold for PM2.5 is 54 pounds per day, while the Project will emit only 1.1 pounds.2 These emissions include emissions from trucks. (See DEIR, 1 “A threshold of significance is an identifiable quantitative, qualitative or performance level of a particular environmental effect, non-compliance with which means the effect will normally be determined to be significant by the agency and compliance with which means the effect normally will be determined to be less than significant.” (CEQA Guidelines, § 15064.7, subd. (a).)
2 “Respirable particulate matter (PM10) consists of small particles, less than 10 microns in diameter, of dust, smoke, or droplets of liquid which penetrate the human respiratory system and cause irritation by themselves, or in combination with other gases.” (DEIR, p. 3.2-5.) “PM2.5 consists of fine particles, which are less than 2.5 microns in size. Similar to PM10, these particles
City Councilmembers
May 31, 2023

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Appendix B.1, CalEEMod Outputs, p. 23 [Section 4.0 Operational Detail – Mobile:

Section 4.4 Fleet Mix, showing a mix of medium-duty [MHD] and heavy-duty [HHD] trucks].)
The DEIR appropriately discloses and analyzes the truck trips attributable to the Project and their contributions to Project emissions on pages 3.2-25 to 3.2-26, including emissions of toxic air contaminants (TACs) such as DPM. The text accurately states that “the frequency of heavy- and medium-duty truck trips generated by the proposed Project is very small, and therefore would not represent a significant risk of TACs from DPM.” (DEIR, p. 3.2-25.) This assessment accounts for the fact that approximately “half of these truck trips would be for refrigerated goods” (i.e., would include Transport Refrigeration Units (TRUs)). (See DEIR, p. 3.2-25.)
An important fact to consider here is that, as the DEIR explains, the Project will lead to a net decrease in overall VMT. “[A]s provided in the CEQA VMT Analysis prepared for the proposed Project by Fehr & Peers, the proposed Project would generate a net decrease in VMT, VMT, due to the effects of the trip redistribution from the Willits Grocery Outlet to the proposed Project.” (DEIR, p. 3.2-26.) Thus, air pollutant emissions from the Project, by and large, will not be new emissions but will be emissions occurring in different locations within the airshed than are occurring at present.

In short, the Project is simply too small in size and scope, and its truck deliveries are simply too few in number, to generate DPM TACs in amounts that come close to creating health risks for sensitive receptors living close to the Project site.

Even so, the DEIR candidly acknowledges that existing traffic in Highway 1 does generate some levels of DPM emissions, but describes them as comparatively limited. “[A]lthough the proposed Project itself does not represent a significant risk of TACs, existing TACs are present under baseline conditions. For example, relatively high traffic roads such as Highway 1 are located near the Project site. As previously stated, mobile sources are the largest overall contributors to the State’s air pollution problems, representing the greatest air pollution health risk to most Californians. This is not unique to the proposed Project. Moreover, TACs from mobile sources in Fort Bragg are not are primarily the result of combustion in motor vehicles, particularly diesel engines, as well as from industrial sources and residential/agricultural activities such as burning. It is also formed through the reaction of other pollutants.” (Ibid.) City Councilmembers
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particularly high, when compared to other parts of California that experience much higher traffic levels.” (Id., pp. 3.2-25 – 3.2-26, italics added.) In its response to FBLBM’s first DEIR comment on this issue, the FEIR makes clear that “projects would need to generate upwards of one hundred heavy-duty truck trips per day to have the possibility of generating enough TACs to exceed the MCAQMD thresholds3 for health risks (i.e., an increased cancer risk of greater than 10 in a million, or an increased non-cancer risk exceeding the Hazard Index of 1.0),” regardless of their “relatively close location of the nearest sensitive receptors.” (FEIR, pp. 2.0-183 to 2.0- 184; DEIR, pp. 3.2-24 to 3.2-25 [Table 3.2-10, CARB [California Air Rsources Board] Minimum Separation Recommendations on Siting Sensitive Land Uses], 7.0-1 to 7.0-2 [references to CARB documents used in analysis], 7.0-6 [references to MCAQMD thresholds]; see also CARB, Air Quality and Land Use Handbook: A Community Health Perspective (Apr. 2005), pp. 4 [Table 1-1], 15, available at http://www.aqmd.gov/docs/default-source/ceqa/handbook/california-air-resources-boardair-quality-and-land-use-handbook-a-community-health-perspective.pdf; MCAQMD, Adopted Air Quality CEQA Thresholds of Significance (Jun. 2. 2010), available at https://www.co.mendocino.ca.us/aqmd/pdf_files/
MCAQMDCEQARecomendations.pdf.) “Ultimately, even with topmounted refrigeration units on some of the heavy-duty and/or medium-duty vehicles, the heavyand medium-duty truck trips would not represent a significant risk of TACs on nearby sensitive receptors from DPM because there are so few truck trips.”4. (FEIR, p. 2.0-184.) 3 Lead agencies may “use thresholds on a case-by-case basis.” (CEQA Guidelines, § 15064.7, subd. (b); Save Cuyama Valley v. County of Santa Barbara (2013) 213 Cal.App.4th 1059, 1068 [“CEQA permits an agency to define its own project-specific thresholds...”]; Oakland Heritage Alliance v. City of Oakland (2011) 195 Cal.App.4th 884, 896 [CEQA “does not forbid an agency to rely on standards developed for a particular project”]; see also CEQA Guidelines, § 15064.7, subd. (c) [lead agencies may use significance thresholds adopted or recommended by other public agencies].) 4 For an illustrative comparison, we bring to your attention a Health Risk Assessment performed in 2020 by LSA Associates for an EIR for an industrial project in the City of Jurupa Valley, California. (Attachment B2 of the Agua Mansa Industrial Project Draft EIR [SCH# 2020010137], publicly available at the CEQAnet web portal, https://ceqanet.opr.ca.gov/2020010137/3, and included hereto as Attachment A.) That project, which would generate 281 daily truck trips consisting of “105 two-axle trucks, 51 three-axle trucks, and 125 four-plus-axle trucks” (p. 2), was found to have a maximum City Councilmembers
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“CEQA does not require technical perfection in an EIR, but rather adequacy, completeness, and a good-faith effort at full disclosure. A court does not pass upon the correctness of an EIR’s environmental conclusions, but only determines if the EIR is sufficient as an informational document. (Kings County Farm Bureau v. City of Hanford (1990) 221 Cal.App.3d 692).” (CEQA Guidelines, § 15003, subd. (i).) Here, the EIR discloses the number of Project-related truck trips (based on expert traffic modeling), their very modest air emissions (based on expert air emissions analysis), and their ultimate lack of any significant contribution toward a health. This level of disclosure and reasoned analysis is adequate and supported by substantial evidence. (See, e.g., Protect the Historic Amador Waterways v. Amador Water Agency (2004) 116 Cal.App.4th 1099, 1113 (Amador Waterways) [agency “assertion that riparian habitat will ‘“continue to thrive along local streamcourses if canal leakage is eliminated”’ constitutes a valid statement of reasons for the Agency’s significance determination”].) The existence of DPM emissions from Highway 1 traffic under existing baseline conditions does not alter the conclusion that the Project’s DPM emissions are less than significant. After acknowledging that existing highway traffic generates such emissions, the FEIR states that “the key concern of CEQA for TAC emissions is whether the proposed Project itself would generate TACs in excess of the applicable thresholds; as previously stated, the level of diesel truck traffic generated by the proposed Project is so small that it is not possible for the TACs generated from the proposed Project truck trips to cause an exceedance of the applicable TAC thresholds, as promulgated by the MCAQMD.” (See FEIR, p. 2.0-184.)
Reducing this negligible risk even further are California’s recent 2022 amendments to the Airborne Toxic Control Measure for In-Use Diesel-Fueled TRU and TRU Generator Sets, and Facilities Where TRUs Operate, which will lower TRU particulate matter emissions through various means, including a requirement for users to cancer risk of 0.12 in one million at the nearest residential receptor (p. 15) located 550 feet away (p. 2). This risk is far, far below MCAQMD’s “10 in a million” criteria of concern, even though that project’s number of operational truck trips substantially exceeded those of the proposed Grocery Outlet project (a maximum total of only 6.14 combined truck trips per day compared with 281). If a project with 281 daily truck trips does not come anywhere close to resulting in a significant health risk, the same is certainly true of a project with 6.14 daily truck trips.

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convert 15 percent of new TRU fleets to zero-emission technology annually, starting December 31, 2023. (See CARB, 2022 Amendments to the TRU ACTM (Mar. 17, 2022), available at https://ww2.arb.ca.gov/resources/fact-sheets/2022-amendments-truatcm.) The level of detail provided in the DEIR on these issues is legally sufficient. An EIR is not required to discuss in detail environmental impacts that are not significant. (See, e.g., CEQA Guidelines, § 15128 [“[a]n EIR shall contain a statement briefly indicating the reasons that various possible significant effects of a project were determined not to be significant and were therefore not discussed in detail in the EIR”] (italics added); Amador Waterways, supra, 116 Cal.App.4th at p. 1109.) Here, the FEIR (inclusive of the DEIR) appropriately discusses air quality impacts associated with truck traffic to and from the Project. It includes industry-standard emissions and traffic modeling, uses applicable air district thresholds, and addresses impacts associated with operational truck-related DPM at a level commensurate of the obvious less-thansignificant impact. No more is required.

Counsel for FBLBM criticizes the DEIR for its analysis of these issues but provides no actual evidence that the analysis is flawed. Instead, he only contends that DPM-related health risks are not adequately evaluated. This kind of unsupported assertion is not enough to show a flaw in the EIR. An attorney’s opinion does not rise to the level of substantial evidence of an un- or under-disclosed impact. (Pala Band of Mission Indians v. County of San Diego (1998) 68 Cal.App.4th 556, 578580 [arguments of legal counsel are not substantial evidence]; San Franciscans Upholding the Downtown Development Plan v. City and County of San Francisco (2002) 102 Cal.App.4th 656, 704 [petitioners cannot just cite their “own lay opinions” to undermine the substantial evidence relied on in an EIR]; Wollmer v. City of Berkeley (2011) 193 Cal.App.4th 1329, 1352 (Wollmer) [project opponent’s “hostility to the decision of the City and its experts … is nothing more than argument and unsubstantiated opinion”].)

2. The FEIR’s responses to comments on this issue are appropriate.

FBLBM asserts that the FEIR’s response to its DEIR comments on this issue did not provide “any further details relating to existing and potential future risks from cumulative exposure to DPM emissions” and that, as a result, the FEIR violates CEQA’s City Councilmembers
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requirement for “good-faith, reasoned analysis.” (CEQA Guidelines, § 15088, subd. (c).) FBLBM is incorrect.

Contrary to this contention, the response does meet CEQA’s standards. Under CEQA, a lead agency need only respond to comments “raising significant environmental issues.” (CEQA Guidelines, § 15088, subd. (a).) Responses need not be exhaustive; they only need to demonstrate a “good-faith, reasoned analysis.” (CEQA Guidelines, § 15088, subd. (c); Gilroy Citizens for Responsible Planning v. City of Gilroy (2006) 140 Cal.App.4th 911, 937 (Gilroy Citizens); see generally City of Irvine v. County of Orange (2015) 238 Cal.App.4th 526, 546–553 (City of Irvine) [discussing CEQA’s requirements for responses to comments].) “A response can be sufficient if it refers to parts of the draft EIR that analyzes the environmental impacts raised by the comment.” (City of Irvine, supra, at p. 550, citing to Paulek v. Department of Water Resources (2014) 231 Cal.App.4th 35, 49, 179.) A reviewing court assesses whether, viewed “as a whole,” a lead agency’s responses to comments “evince good faith and a reasoned analysis” even if the responses may not be “exhaustive or thorough in some specific respects.” (Twain Harte Homeowners Assn. v. County of Tuolumne (1982) 138 Cal.App.3d 664, 686 (Twain Harte), italics added.) The key question is whether the responses “adequately serve the disclosure purpose which is central to the EIR process.” (Ibid.) In reviewing the adequacy of a lead agency’s responses, the court must presume the responses are adequate; the burden is on the petitioner to prove otherwise. (Gilroy Citizens, supra, 140 Cal.Ap.4th at p. 937.)
Here, the FEIR provides reasonable and good-faith responses to FBLBM’s airquality-related comments on the DEIR. In its original comments, FBLBM asks what the DEIR means when it states that the frequency of truck trips is “very small.” (FEIR, p.

2.0-52.) The FEIR’s response clarifies that the number of truck trips generated by the Project is small insofar as the number does not come anywhere near the number that would trigger MCAQMD criteria for assessing health risks associated with truck trip TACs (approximate eight weekly heavy-duty truck trips and approximate four to five daily medium-duty truck trips compared with one hundred heavy-duty truck trips per day). (FEIR, p. 2.0-184.)
In its original comments, FBLBM asked what the DEIR means when it states that “TACs from mobile sources in Fort Bragg are not particularly high, when compared to City Councilmembers
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other parts of California that experience much higher traffic levels.” (FEIR, p. 2.0-52.) The FEIR’s response points out that this comparative observation made in the DEIR is not necessarily relevant, insofar as emissions from existing traffic are part of baseline conditions and are not attributable to the Project. “[T]he key concern of CEQA for TAC emissions is whether the proposed Project itself would generate TACs in excess of the applicable thresholds; as previously stated, the level of diesel truck traffic generated by the proposed Project is so small that it is not possible for the TACs generated from the proposed Project truck trips to cause an exceedance of the applicable TAC thresholds, as promulgated by the MCAQMD.” (FEIR, p. 2.0-184.)
The response then goes on to note, however, that the physical setting for air quality in which the Project is located is far less polluted that other locations in the state in which new grocery stores are located. “[I]t is not uncommon for grocery stores to be located a similar distance (approximately 300 feet) from an existing active freeway, near freeways in other parts of California (such as Los Angeles or Oakland) that have dramatically higher traffic levels than the traffic along Highway 1 near to the Project site. (Ibid.)
Finally, FBLBM asked in its original comments what routes these trucks will take to the site, whether they will be idling, and how much DPM will result, and then requested a “quantitative study.” (FEIR, p. 2.0-52.) To these points, the FEIR reiterates that “as previously stated, the level of diesel truck traffic generated by the proposed Project is so small that it is not possible for the TACs generated from the proposed Project truck trips to cause an exceedance of the applicable TAC thresholds, as promulgated by the MCAQMD. No further response to this comment is warranted.” (FEIR, p. 2.0-184.)
We also note that section 2485 of Title 13 of the California Code of Regulations requires that drivers of diesel-fueled commercial motor vehicles with gross vehicle weight ratings greater than 10,000 pounds not idle their vehicle’s primary diesel engine longer than five minutes at any location, with the failure to comply subjecting the driver to the risk of significant fines. (See MCAQMD, Regulation 3, Section 9 (adopted Sept. 14, 2020), Rule 3.9-900, available at https://www.co.mendocino.ca.us/aqmd/districtregulation-3.html.) City Councilmembers
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FBLMB’s request for a “quantitative study” is unreasonable under the circumstances. As discussed above, the Project is far too small to warrant such an elaborate undertaking. “A project opponent … court can always imagine some additional study or analysis that might provide helpful information. It is not for them to design the EIR. That further study … might be helpful does not make it necessary.” (Laurel Heights Improvement Assn. v. Regents of University of California (1988) 47 Cal.3d 376, 415 (Laurel Heights I).) These pragmatic principles are not negated by the fact that additional study is requested through comments on a draft EIR. “[N]othing in CEQA Guidelines section 15088 … allows project opponents to use the comment-and-response process to wear down a lead agency, or delay a project, by the simple expedient of filing an onerous series of demands for information and setting up a series of hoops for the lead agency to jump through.” (City of Irvine, supra, 238 Cal.App.4th at p. 549.)5 The FEIR’s responses to these comments “evince good faith and a reasoned analysis,” even if the responses are not always “exhaustive or thorough in some specific respects.” (Twain Harte, supra, 138 Cal.App.3d at p. 686.) The burden is on FBLBM to disprove the legal presumption that the FEIR’s responses to comments are adequate, and that burden has not been met here. (Gilroy Citizens, supra, 140 Cal.Ap.4th at p. 937.) 6 5 See also Pub. Resources Code, § 21003, subd. (f) (“[a]ll persons and public agencies involved in the environmental review process be responsible for carrying out the process in the most efficient, expeditious manner in order to conserve the available financial, governmental, physical, and social resources with the objective that those resources may be better applied toward the mitigation of actual significant effects on the environment”). 6 FBLBM cites to Berkeley Keep Jets Over the Bay Committee v. Board of Port Com’rs (2001) 91 Cal.App.4th 1344, 1371, in support of its claim that the FEIR inadequately responds to comments, but that case is easily distinguishable because it involved a massive airport project with very substantial air pollutant emissions. In that case, which involved an airport development plan that contemplated increased capacity for both air cargo and passenger operations, the lead agency failed to properly respond to “significant conflicting information generated by the public” regarding TACs. (Ibid.) Here, FBLBM has not provided any information or evidence that conflicts with the DEIR, only opinion and requests for more data that the FEIR makes clear is not necessary. FBLBM also cites Santa Clarita Organization for Planning the Environment v. County of Los Angeles (2003) 106 Cal.App.4th 715, 723, which involved an EIR for development project with 2,545 housing units, 180,000 square feet of commercial retail space and 46 acres of community facilities. That precedent is also readily distinguishable. There, the court found that “the EIR does little more than dismiss project opponents concerns about water supply,” with the final EIR even acknowledging that there may be a water supply City Councilmembers
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B. The FEIR’s Noise Analysis is Sufficient and its Responses to Related Comments are Appropriate.

1. The FEIR’s analysis of noise as it relates to nearby lodging is sufficient and presents no CEQA violation.

FBLBM asserts that the FEIR violates CEQA because its noise analysis fails to adequately analyze impacts to nearby lodging land uses, namely, the Super 8 Motel to the west of the project site and the Seabird Lodge and Harbor Lite Lodge to the north and south. Specifically, FBLBM appears to claim that the Super 8 Motel was erroneously omitted from the DEIR’s sensitive receptor noise contour graphics and that the graphics indicate an impact at Super 8. FBLBM’s concerns are ill-founded. “The SoundPLAN noise prediction model was used to plot noise contours and to calculate noise levels at the sensitive receptors located around the Project site.” (DEIR, p.

3.6-10, italics added.) The City does not classify transient lodging, such as the Super 8 Motel, within its Coastal Zone as a sensitive noise receptor. Sensitive noise receptors within the City’s Coastal Zone include hospitals, schools, senior centers, churches, libraries, etc., but not hotels and motels. (See City of Fort Bragg, Coastal General Plan, Noise Element (Jul. 2008), pp. 8-5 [Table N-4, listing “Noise Sensitive” land uses], 8-7 [Map N-1 showing “Sensitive Noise Receptors”].) Accordingly, the sensitive receptor noise contours prepared by Saxelby Acoustics did not model noise impacts on the Super 8 Motel.7 (See DEIR, Figures 3.5-2 to 3.5-7.)
deficit. Conversely here, the FEIR’s response looks to air district guidelines and discusses issues specific to Highway 1. The response also reinforces the findings in the DEIR rather than contradicting them.

7 Some of the DEIR’s noise contour figures appear to show that the Project may generate excessive operational noise at the western property line with Super 8 (see DEIR, pp. 3.6- 21 to 3.6-31), but those graphics are misleading. As described just above, the purpose of those graphics is to visually demonstrate any Project-related decibel increases on nearby residences (i.e., sensitive receptors.) Inclusion of the noise contours extending toward the Super 8 was incidental to the depiction of contours extending towards sensitive receptors, and did not account for the Project’s design features intended to reduce operational noise. A new noise contour graphic was prepared for the Revised FEIR. It specifically looks at noise levels at the Super 8 Motel (discussed below). Nevertheless, the DEIR graphics clearly demonstrate that the Super 8 building itself serves as a near complete noise blocker for Project-related noise for the motel’s interior areas where guests and other receptors would be present (also discussed below).

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Moreover, the majority of the FEIR’s significance thresholds for operational noise impacts apply only to residential land uses not hotels and motels. Per the initial FEIR,8 as relevant here:

Generation of a temporary or permanent increase in ambient noise levels in the vicinity of the Project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies, as outlined below:
o Non-transportation noise that exceeds 55 dBA Leq / 75 dBA Lmax during daytime (7 A.M. to 10 P.M.) hours, excluding temporary construction noise. o Non-transportation noise that exceeds 45 dBA Leq / 65 dBA L max during daytime (7 A.M. to 10 P.M.) hours, excluding temporary construction noise.

Generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the Project in excess of ambient conditions, as outlined below; and/or
…

o A permanent increase in operational noise that would:
 cause the Ldn in existing residential areas to increase by 3 dB or more;  cause the Ldn in existing residential areas to increase by 2 dB or more if the Ldn would exceed 70 dB; or
 cause the L dn resulting exclusively from project-generated traffic to exceed an Ldn of 60 dB at any existing residence.
(FEIR, pp. 3.0-12 to 3.0-13.)
Both sets of thresholds are taken verbatim from the Coastal General Plan Noise Element and were adopted along with the Plan (see footnote 3, supra, on an agency’s discretion to develop its CEQA thresholds). The first set of thresholds derives from Table N-5 in Policy N-1.5, Non-Transportation Noise Generation, which states, in relevant part: “[f]or new non-transportation noise generators, Table N-5 describes the maximum noise level at the nearest residential property line:….” (Coastal General Plan, Noise Element, pp. 8-8 to 8-9, italics added.) The second set of thresholds derives from Policy 8 The initial FEIR revised the operational noise thresholds of significance from those presented in the DEIR to better encapsulate the DEIR’s analysis by including the nontransportation noise generation standards for “maximum noise level at the nearest residential property line.” (Coastal General Plan, Noise Element, pp, 8-8 to 8-9 [Policy N-1.5].) Operational noise thresholds of significance were further revised in the Revised FEIR to include thresholds for Project-generated noise on nearby hotels and motels. For more discussion on these revisions, please refer to Section II.B, infra. See also footnote 3, supra, on an agency’s discretion to develop its CEQA thresholds.

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N-1.2, Reduce Noise Impacts, and explicitly states that the indicated decibel increases apply only to “existing residential areas” or “at any residence.” (Id., pp. 8-7 to 8-8.) Consequently, the FEIR does not consider noise increases at or near a commercial use like a motel an impact under CEQA.

Indeed, the Coastal General Plan Noise Element does not appear to include a noise standard for the situation presented here—where a new commercial use is proposed aside an existing hotel/motel commercial use. The “Noise and Land Use Compatibility Standards” in Table N-4 of the Noise Element are intended for exterior noise levels of “new development” of the land uses indicated in the table (which include “Hotels and Motels”), not for potential impacts of new development on those land uses. (Coastal General Plan, Noise Element, pp. 8-5 to 8-6; see also Policy N-1.3, Noise and Land Use Compatibility Standards [“[e]nsure that all new noise sensitive development proposals be reviewed with respect to Table N-4: Noise and Land Use Compatibility Standards…”].) Other noise standards, such as those for “Acceptable Noise Environments,” apply to housing and sensitive receptors (which hotels and motels are not, as explained above) or, again, appear to apply only to development of that particular use. Policy N-1.4, likewise, establishes an indoor noise standard for “all new...hotels and motels.” (Id., p. 8-8.) It is, of course, fitting that a general plan would not have a noise standard for the potential effects of one commercial use upon another because commercial uses are not generally considered sensitive receptors, and because commercial uses like hotels and motels that provide sleeping accommodations are subject to state-regulated building standards intended to limit interior noise (discussed more below).

Nevertheless, in the revised FEIR, published on May 31, 2023, on the City’s webpage for the Project (Revised FEIR), the City conservatively opted to include new thresholds for impacts to nearby hotels and motels resulting from Project-generated noise.9 (Revised FEIR, pp. 3.0-16-5 to 3.0-16; see also footnote 3, supra.) As explained in the Revised FEIR, these new thresholds were adapted from Coastal General Plan standards established for “‘new’ proposed...hotel/motel uses” to regulate exterior and 9 The law is clear that, prior to certification, a lead agency can add more material to the (proposed) Final EIR as initially published. (See, e.g., Beverly Hills Unified School Dist. v. Los Angeles County Metropolitan Transportation Authority (2015) 241 Cal.App.4th 627, 664666.)
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interior noise levels (namely, Table N-4 Noise and Land Use Compatibility Standards for exterior noise levels and Policy N.1-4 standard for interior noise levels). The new thresholds are used in the Revised FEIR in order “to be conservative” and to “examine project-generated noise at hotel/motel uses....” (Id., p. 3.0-16.) Under these new thresholds, the Project would result in a significant impact if it creates operational “non-transportation noise, that causes exterior noise levels exceeding 75 dBA Ldn at hotel/motel uses or interior noise levels exceeding 45 dBA Ldn, at hotel/motel uses.” (Revised FEIR, p. 3.0-16.) The new analysis, inclusive of a new Figure

3.6-10 with modeled noise contouring focused specifically toward Super 8 Motel, demonstrates that the Project would not generate noise at the Super 8 Motel in exceedance of the newly established thresholds (id., pp. 3.0-20, 3.0-28):

Based upon Figure 3.6-10, the proposed Project would generate day/night average (Ldn) noise levels of up to 67 dBA Ldn at the rear area of the adjacent Super 8 motel. This area is not utilized by patrons for the motel. Noise levels on the entry side of the motel are predicted to be 42 dBA Ldn. These levels would comply with the City’s 60-75 dBA Ldn noise standard range for existing hotels and motels. Based upon the exterior noise level of 67 dBA Ldn, and the interior noise reduction calculations, interior noise levels within the Super 8 are predicted to be no greater than 41 dBA Ldn. This complies with the City’s 45 dBA Ldn interior noise standard for hotels/motels.

Thus, the Revised FEIR found that the Project would have a less-than-significant noise impact on the adjacent Super 8 Motel. (Revised FEIR, p. 3.0-21) This analysis is especially conservative because it “assumed that the proposed loading dock could operate at the full peak hour level of activity for every daytime (7:00 a.m. to 10:00 p.m.) hour”; however, “per Special Condition 37 for the Planning Permit, delivery hours would occur between 7:00 AM and 9:00 PM. As such, this analysis is considered conservative and provides a worst-case scenario for truck delivery noise.” (Id., p. 3.0-20.) This finding comports with the obvious—the Project would not generate significant decibel increases at the Super 8 Motel, or at the Seabird Lodge and Harbor Lite Lodge. The Seabird Lodge and Harbor Lite Lodge are located significant distances from the project site and are separated by well-traveled roadways (South Street and N.

Harbor Drive, respectively). Thus, Project noise would be attenuated well below the threshold used in the Revised FEIR. (See DEIR, p. 3.6-4 [“Stationary point sources of noise – including stationary mobile sources such as idling vehicles – attenuate (lessen) at City Councilmembers
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a rate of approximately 6 dB per doubling of distance from the source, depending on environmental conditions (i.e., atmospheric conditions and either vegetative or manufactured noise barriers, etc.)”].)
The Super 8 Motel, although immediately adjacent to the Project site, likewise would not be significantly impacted. The modeling prepared for the Revised FEIR provides substantial evidence that the Project would not exceed the thresholds for operational noise on hotels and motels being used by the City here. This conclusion makes perfect sense given existing conditions as well as Project design and conditions of approval.

For example, the motel structure is rear-facing, such that the two-story building itself will block or reduce Project-related noise from the motel’s front and interior areas, where guests park and enter, and where balconies and walkways exist.10 (See DEIR, p.

3.1-13 [Figure 3.1-1] [showing backside of Super 8 Motel in relation to parking lot portion of the Project].) The Super 8 also is subject to “Title 24, part 2 of the California Code of Regulations [CCR], Noise Insulation Standards, for multi-family attached dwellings, hotels, motels, etc.” (Coastal General Plan, Noise Element, p. 8-8), which include airborne sound transmission limitations and constraints on noise levels attributable to exterior sources for all rooms that must be tested in accordance with American Society for Testing and Materials (ASTM) standards (24 CCR 1206.2, 1206.4), and therefore would have been built according to these standards to stringently limit interior noise.

In addition, the Project includes a four-foot-high masonry block wall with metal railing surrounding the “Truck Dock,” which will significantly reduce loading dock noise, as well as a six-foot-high sound wall parallel to the western property line, with landscaping, which will further reduce noise. As explained below, this Truck Dock (or loading dock) was sited to minimize noise impacts on Super 8 occupants. (See DEIR, 10 A two-story building significantly reduces noise levels from adjacent noise sources. (See, e.g., S. Department of Transportation, Federal
Highway Administration, Audible Landscape: A Manual for Highway Noise and Land Use, Chapter 4. Physical Techniques to Reduce Noise Impacts, Section 4.1 (Jun. 7, 2017), available at https://www.fhwa.dot.gov/ENVIRONMENT/noise/noise_compatible _planning/federal_approach/audible_landscape/al04.cfm#bar [up to a 13 dBA reduction].)

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Figure 2.0-5 [Site Plan showing location of “truck well” adjacent to the proposed Grocery Outlet structure and therefore north of the backside of the Super 8 motel]; see also City of Fort Bragg, Planning Commission Meeting Agenda (May 10, 2023), p. 29 [“Backside (Internal) facing fence/gas station/Taco Bell Elevation”], available at https://cityfortbragg.legistar.com/View.ashx?M=PA&ID=1088590&GUID=9E1029D8- 95AD-486F-9EBC-72F47EE84A13.)
As explained by Project engineer Chris Schulze of TSD Engineering in a May 17, 2023, memorandum to Terry Johnson of Best Development (Schulze Memo), the location and operation of the Truck Dock and loading area were key factors considered early in the design process. Mr. Schulze notes that the possibility of the “Truck Dock being placed immediately adjacent to the existing Motel Use on the adjacent property to the east was a concern and was one of the factors that led to the Building Placement to be located adjacent to South Street and such the Truck Dock and Loading Area would be adjacent to a vacant property with commercial zoning.” (Schulze Memo, p. 2.)11 Thus, the loading dock area, from which delivery trucks will come and go, was designed and sited so as to minimize noise not only to residences along South Franklin Street but also to the Super 8 Motel.

Importantly, moreover, the above-described sound wall and landscaping must and will comply with section 17.36.110 (Loading Space Requirements), subdivision B.5 (Screening) of the City’s Coastal Land Use and Development Code, requiring “a combination of dense landscaping and solid masonry walls with a minimum height of six feet.” (See Planning Commission Meeting Agenda (May 10, 2023), supra, p. 14 [Consistency With The Coastal Land Use And Development Code: Parking and Circulation: CLUDC Regulations].)
Finally, the store’s hours of operation will be from 8:00 AM to 10:00 PM. (DEIR, p. 2.0-3.) These are hours when motel guests are not expected to be sleeping, so any noise from customer vehicle usage associated with Project operations should not interfere with those guests’ ability to sleep during normal nighttime hours. Nor will truck deliveries occur during nighttime hours. As discussed above, and noted in the Revised FEIR, a special condition will be included in the final Project conditions of approval, to be 11 A copy of the Schulze Memo is submitted with this letter as Attachment B.

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presented to City Council, that limits the hours of truck deliveries to the Project from 7:00 AM to 9:00 PM, to which the Applicant has already agreed. Thus, there is no danger that occupants of the Super 8 Motel will be awakened during the middle of the night by noisy truck deliveries.

In light of all of these safeguards, it is not surprising that the operator of the Super 8 Motel enthusiastically supports the Project and the many benefits it will bring. (See Attachment C, May 27, 2023, letter to Fort Bragg City Council and Planning Commission from Devon Patel, Manager of Super 8 Motel.)

2. The FEIR’s responses to comments on this issue are appropriate.

FBLBM asserts that the FEIR’s responses to its comments on this issue fail to demonstrate how noise standards were applied to nearby transient lodging and, therefore, violate CEQA’s requirement for “good-faith, reasoned analysis.” (CEQA Guidelines, § 15088, subd. (c).) Again, FBLBM is incorrect.

The FEIR provides reasonable and good-faith responses to FBLBM’s noiserelated comments on the DEIR. In its original comments, FBLBM claimed that a “single-day short-term measurement is not adequate to establish a meaningful baseline, as traffic levels and nearby activities will likely vary depending on the day of the week, etc. Measurements should be taken continuously over a multi-day period, ideally during different months.” (FEIR, p. 2.0-52 [Comment K-3].) The FEIR’s response reiterates that the DEIR in fact included continuous noise measurements, taken over the course of two days in January 2022 at one location, and another short-term measurement taken at another location. (FEIR, pp. 2.0-184 to 2.0-185.) FBLBM does not explain why it believes taking noise measurements during different months of the year is important; but, presumably, Luxe Saxelby, principal at Saxelby Acoustics, who is board-certified by the Institute of Noise Control Engineering and has more than 20 years’ experience preparing noise studies, used the appropriate industry standard when taking noise measurements for the DEIR’s noise study and making CEQA conclusions,12 and FBLBM provides no 12 Significance conclusions must be based on “substantial evidence” and “[s]ubstantial evidence shall include facts, reasonable assumptions predicated upon facts, and expert opinion supported by facts.” (Pub. Resources Code, § 21082.2, italics added; see also CEQA Guidelines, § 15384; City of Long Beach v. Los Angeles Unified School Dist. (2009) 176 Cal.App.4th 889, 917 [court upholding EIR consultant’s analysis]; City Councilmembers
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evidence to the contrary. (See Saxelby Acoustics, LLC, About Us (2023), available at http://www.saxnoise.com/about-us.html.)
In its original comments, FBLBM further claimed that the DEIR’s noise analysis “omitted consideration of receptors at the Super 8 Motel” and that the noise contours “suggest that Project-related noise levels xceeding [sic] applicable significance thresholds at this location.” (FEIR, p. 2.0-52.) The FEIR responds by reiterating the DEIR analysis that discusses the City’s noise standards and explains, again, how the Project would not exceed them at any location, including Super 8. This issue has been discussed above.

The FEIR’s response to these comments appropriately “refers to parts of the draft EIR that analyzes the environmental impacts raised by the comment” (City of Irvine, supra, 238 Cal.App.4th at p. 550) and further clarifies the previous analysis in a manner that “evince[s] good faith and a reasoned analysis,” even if reach response is not “exhaustive or thorough in some specific respects” (Twain Harte, supra, 138 Cal.App.3d at p. 686). The FEIR’s response explains that “[w]ith respect to the Super 8 Motel, as discussed in Section 3.6, Noise, of the Draft EIR, Policy N-1.4 of the City of Fort Bragg Coastal Region General Plan establishes a standard of 45 Ldn for indoor noise levels for all new residential development including hotels and motels and a standard of 60 Ldn for outdoor noise at residences. These limits shall be reduced by 5 dB for senior housing and residential care facilities. These thresholds and standards were used to analyze Project impacts to the Super 8 Motel. Noise impacts at existing receptors from increased traffic noise would be considered less-than-significant.” (FEIR, p. 2.0-185.) These thresholds were fine-tuned in the Revised FEIR with more explicit analysis of operational Project noise on the adjacent Super 8 Motel.

The burden is on FBLBM to disprove the legal presumption that the FEIR’s responses to comments are adequate, and that burden has not been met here. (Gilroy Citizens, supra, 140 Cal.Ap.4th at p. 937.)
Association of Irritated Residents v. County of Madera (2003) 107 Cal.App.4th 1383, 1396 1398 (Association of Irritated Residents) [same].) The data collection, modeling, and analysis performed by Saxelby Acoustics constitutes substantial evidence, as does similar work prepared by other consultants for the EIR.

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C. The FEIR’s Responses to Traffic-Related Comments Are Appropriate and FBLBM Provides no Evidence to the Contrary.

FBLBM asserts, generally, that the FEIR’s responses to other commenters’ concerns regarding Project impacts to traffic, emergency vehicles, and pedestrian safety violates CEQA’s requirement for “good-faith, reasoned analysis.” (CEQA Guidelines, § 15088, subd. (c).) FBLBM does not specify which comments it believes were given too little attention in the FEIR’s responses, making it impossible for us to respond to this claim with any specificity. The FEIR approached each response to each comment with the same “good-faith, reasoned analysis” that it approached responses to FBLBM’s comments, which, as demonstrated above, are entirely appropriate, and FBLBM provides no evidence to the contrary. (CEQA Guidelines, § 15088, subd. (c).) The burden is on FBLBM to disprove the legal presumption that the FEIR’s responses to comments are adequate. (Gilroy Citizens, supra, 140 Cal.Ap.4th at p. 937.) FBLBM has not met that burden here with its generalized statement about no- specified responses to non-specified comments.

D. The FEIR’s Supplemental Urban Decay Study Does Not Trigger Recirculation.

FBLBM claims that CEQA requires the FEIR be recirculated to the public for additional review because of its inclusion of, and references to, the study of potential “urban decay” from the Project by ALH Urban & Regional Economics (see FEIR, Appendix B). According to FBLBM, this new study is “significant new information” that, under CEQA Guidelines section 15088.5, subdivision (a), triggers document recirculation. FBLBM is incorrect.

The DEIR already included a discussion of the subject of urban decay, listing nine existing regional grocery stores and relying on fieldwork that looked for any regional evidence of potential indicators of decay, such as litter, graffiti, excessive weeds, etc., of which none were found (DEIR, pp. 3.5-30 to -31.) The DEIR then reasonably concludes, based on this evidence, that that the Project would not result in urban decay, and that any impact in this category would be less than significant.

In its comment on the DEIR, FBLBM requested additional analysis of the subject, and specifically included an example of a study prepared by ALH Urban & Regional Economics for another project as the type of study it said was necessary. (FEIR, p. 2.0- City Councilmembers
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53.) In response to this comment, out of an abundance of caution (despite the lack of evidence here for an exhaustive study), the Applicant had an Urban Decay Study prepared for the Project by FBLBM’s suggested consultant, ALH Urban & Regional Economics, which the City relied on for additional support in the FEIR. (See FEIR, pp.

3.0-9 to 3.0-12 [revised DEIR text], Appendix B [full Urban Decay Study].) FBLBM now claims that the EIR must be recirculated for public review and comment, without demonstrating any actual triggers for recirculation, because of the inclusion of an unnecessary study that it requested in the first place.

Recirculation is required where “significant new information” is added to the EIR after the close of public comment but prior to certification. (Pub. Resources Code, § 21092.1; CEQA Guidelines, § 15088.5.) “New information” is “significant” only if “the EIR is changed in a way that deprives the public of a meaningful opportunity to comment upon a substantial adverse environmental effect of the project or a feasible way to mitigate or avoid such an effect . . . that the project’s proponents have declined to implement.” (CEQA Guidelines, § 15088.5, subd. (a).) Such information must show “(1) [a] new significant environmental impact would result from the project or from a new mitigation measure proposed to be implemented[;] or (2) [a] substantial increase in the severity of an environmental impact would result unless mitigation measures are adopted. . . .” (CEQA Guidelines, § 15088.5, subds. (a)(1), (a)(2).) A lead agency’s decision on recirculation “is presumed [] correct” (Citizens for a Sustainable Treasure Island v. City and County of San Francisco (2014) 227 Cal.App.4th 1036, 1064 (Treasure Island), internal quotations omitted), and a challenger has the burden to prove that the agency did not rely on substantial evidence when making its decision (Laurel Heights Improvement Assn. v. Regents of Univ. of Cal. (1993) 6 Cal.4th 1112, 1135 (Laurel Heights II).)
The Urban Decay Study does not does not introduce a “new significant environmental impact” or a “substantial increase in the severity of an environmental impact.” Rather, nothing in the Study changed the impact conclusion in the DEIR that the impact would be less than significant. (Guidelines, § 15088.5, subd. (a)(1); FEIR, p.

3.0-12.) The Study does not propose mitigation or demonstrate that mitigation is City Councilmembers
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necessary. (CEQA Guidelines, § 15088.5, subd. (a)(2).) The Study merely expounds on the analysis that existed in the DEIR. The author summarized her conclusions as follows:

The study analysis does not suggest any retailers would be at risk of losing retail sales sufficient to result in store closure leading to increased commercial vacancy as a result of Grocery Outlet’s development, and thus there would likely be no risk for their properties to erode into conditions leading to urban decay. Yet, if such an event were to occur, there is no indication from the market that urban decay would result from such a store closure. Even properties that have been closed for longer periods of time, up to four years or more, continue to be maintained in reasonable condition and, most importantly, are not indicative of urban decay. Thus, real estate market conditions in Fort Bragg do not appear to be conducive to urban decay.

Therefore, pursuant to the existing market conditions, projected retail supply and demand conditions, and Grocery Outlet project orientation, ALH Economics concludes that there is no reason to consider that development of the proposed Grocery Outlet store would cause or contribute to urban decay.
(FEIR, Appendix B, p. 4.)13
Accordingly, the ALH Urban & Regional Economics Urban Decay Study and revised EIR text do not introduce any “significant new information,” by CEQA’s definition of that phrase, that would require recirculation. (Pub. Resources Code, § 21092.1; CEQA Guidelines, § 15088.5.) The City Council may therefore proceed without recirculating the EIR and be confident that its decision will be presumed correct by the court and upheld, should the Project and FEIR be challenged on this issue.

As stated just above, “nothing in CEQA Guidelines section 15088 … allows project opponents to use the comment-and-response process to wear down a lead agency, or delay a project, by the simple expedient of filing an onerous series of demands for information and setting up a series of hoops for the lead agency to jump through.” (City of Irvine, supra, 238 Cal.App.4th at p. 549.)
13 In fact, new evidence suggests that the Project would eliminate a current risk factor for urban decay on the Project site. Devon Patel, Manager of the adjacent Super 8 Motel, in his May 27, 2023, letter to Fort Bragg City Council and Planning Commission (included here as Attachment C), states that “[t]he current building on the site is neglected and has safety issues, as well as it is a magnet for homeless. I know other nearby owners frequently call the police regarding illegal activity on that site.” City Councilmembers
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FBLBM requested this unnecessary Urban Decay Study, the Applicant had it prepared (at considerable expense) by FBLBM’s suggested consultant. Even though the Study came to the exact same conclusion as the DEIR, FBLBM now demands the City jump through yet another unnecessary hoop of document recirculation. CEQA does not support FBLBM’s demand; indeed, courts warn against it. (See Citizens of Goleta Valley v. Board of Supervisors (1990) 52 Cal.3d 553, 576 [“we caution that rules regulating the protection of the environment must not be subverted into an instrument for the oppression and delay of social, economic, or recreational development and advancement”].)
Regardless, the ALH Urban & Regional Economics Study has been available for public comment for a considerable period of time, and nothing prevents interested persons from offering their substantive critiques. The City published the FEIR on April 4, 2023, which gave members of the public 34 full calendar days to review the Study and other material within the FEIR prior to the May 10, 2023, Planning Commission meeting. Nearly four weeks of additional time will transpire before the City Council convenes its own hearing on the Project on June 5, 2023.

II. RESPONSES TO COMMENTS FROM LESLIE KASHIWADA
In her May 10, 2023, comment submission, Leslie Kashiwada makes several critiques of the Project and FEIR, many of which are derivative of her comments on the DEIR, and only some of which implicate CEQA. In this letter, we respond to only those comments with CEQA implications relating to the FEIR.

Like FBLBM, Leslie Kashiwada questions Project-generated noise at the adjacent Super 8 Motel. Please refer to Section I.B above for a response to that comment. Also like FBLBM, Leslie Kashiwada indicates that the supplemental Urban Decay Study should be circulated for public review and comment. Please refer to Section I.D above for a response to that comment. Leslie Kashiwada likewise states, generally, that the FEIR does not substantially address comments on the DEIR, but does not point to any particular failing. Please refer to Sections I.A.2 and I.B.2 above for legal standards and other information related to the FEIR’s responses to comments.

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A. The FEIR’s Biological Resource Analysis and Studies are Sufficient.

In her comments on the FEIR, Leslie Kashiwada “concede[s] that [the project site [is not a special site in [] regard [to either biology and geology].” Ms. Kashiwada then proceeds to criticize the biological resources analysis and studies performed for the proposed Project. We address some of those criticisms below.

Ms. Kashiwada criticizes the bat survey performed and claims that it “was never redone, even though the California Department of Fish and Wildlife requested that such a study be completed before demolishing the old building.” Ms. Kashiwada, however, overlooks the fact that Mitigation Measure 3.3-2 requires that a new bat survey be performed “by a qualified biologist prior to demolition of the existing on-site building,” with various protectionary measures in place should bat roosts be discovered. This measure is consistent with CEQA case law, which has blessed the use of preconstruction surveys as means of identifying and mitigating impacts to any creatures that might have been absent earlier, but have moved into an area to be physically altered by a proposed project. (See, e.g., Save Panoche Valley v. San Benito County (2013) 217 Cal.App.4th 503, 524-527. Intuitively, this approach is particularly sensible for flying creatures, such as nesting birds and roosting bats.

Ms. Kashiwada then expresses concern that “[t]he mature evergreen trees on the northwest corner of the building will likely not survive the construction process given the proposed site of the new building, despite City policy to encourage existing mature trees be retained.” We address these trees in section IV.B of RMM’s December 6, 2022, letter (“RMM’s 2022 Letter”), available in Appendix A of the FEIR. As stated in our previous letter, these trees are ornamental and not protected species; therefore, their removal does not present a significant impact to biological resources under CEQA. Likewise, removal of these trees will not significantly impact aesthetics, as they are “not part of the natural scenic landscape” and will be replaced “with landscaping selected for the local climate, including the planting of 37 new trees.” (DEIR, p. 3.1-10.) Notwithstanding, the DEIR states that it is possible these trees can be preserved, and Ms. Kashiwada presents no evidence to the contrary. (DEIR, p. 2.0-3.)
Lastly, in the section entitled, “Biological Report,” in her comment submission, Ms. Kashiwada expresses doubt about the suitability of the currently proposed site drainage, based on her personal observations about “large puddles of water at the City Councilmembers
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southern end of the property....” Ms. Kashiwada need not be concerned. As the FEIR explains, site drainage will be engineered to comply with “standards and specifications of the City of Fort Bragg (i.e., City of Fort Bragg Design Specifications and Standards).

Prior to the issuance of a building or grading permit, the Project applicant would be required to submit a drainage plan to the City of Fort Bragg for review and approval. The plan would be an engineered storm drainage plan that calculates the runoff volume and describes the volume reduction measures, if needed, and treatment controls used to reach attainment consistent with the Fort Bragg Storm Drain Master Plan and City of Fort Bragg Design Specifications and Standards. Overall, drainage impacts would be reduced to less than significant.” (FEIR, p. 3.0-33.) For more detail on project site drainage, please refer to section IX.B of RMM’s 2022 Letter (see FEIR, Appendix A).

B. The FEIR’s Noise Impact Thresholds Are Appropriate.

Leslie Kashiwada comments that “impacts on surrounding businesses were dismissed without using actual thresholds of significance.” In the DEIR, the CEQA thresholds of significance for operational Project noise impacts focus on noise increases at residential land uses. (See DEIR, p. 3.6-8.) These thresholds were taken verbatim from the Coastal General Plan Noise Element Policy N-1.2 and are appropriate for use (refer to footnote 3, supra, regarding an agency’s discretion to establish its own case-by-case CEQA thresholds of significance).

The DEIR analysis, however, is not limited to just incremental decibel increases in operational Project noise on nearby residences; the analysis also addresses the Project’s contribution to overall ambient noise levels at residential land uses, pursuant to “the City of Fort Bragg [] daytime and [] nighttime noise level standards.” (DEIR, p. 3.6-15.) Because of the scope of this analysis, and in response to some comments on the DEIR’s operational noise thresholds (e.g., FEIR, p. 2.0-274 to 2.0-275), the FEIR refines the DEIR’s thresholds by adding the City’s non-transportation noise standards for “maximum noise level at the nearest residential property line,” adopted as part of the Coastal General Plan, whereas an exceedance at a residence would constitute a significant impact. (Coastal General Plan, Noise Element, Policy N-1.5 [Table N-5]; FEIR, pp. 3.0-12 to 3.0-13; see also footnote 3, supra, and Treasure Island, supra, 227 Cal.App.4th at p. 1065 [“refinements that occurred in the EIR...do not constitute the City Councilmembers
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type of significant new information requiring recirculation”].) The Revised FEIR further refines operational noise thresholds of significance, adding one that explicitly applies to nearby hotels and motels (see Section I.B.1, supra, for more discussion on this new threshold). The DEIR’s less-than-significant impact conclusions remain unchanged, and new analysis in the FEIR likewise results in a less-than-significant operational noise impact on hotels and motels.

C. Backup Signal Sounds Emitted by Delivery Trucks at the Project Site Do Not Create a Significant Noise Impact under CEQA.

Leslie Kashiwada comments that the Project will result in “significant noise from backup signaling” of trucks. Ms. Kashiwada is mistaken—truck backup signal noise will not result in a significant impact under CEQA.

When determining loading dock noise generation for the DEIR, Saxelby Acoustics took noise level measurements at a Wal-Mart loading dock, which it considered to be “conservative” given that the specific “Wal-Mart loading dock supports a much larger store than the proposed Grocery Outlet.” (DEIR, p. 3.6-11.) The activities measured included “truck arrival/departures, truck idling, truck backing, air brake release, and operation of truck-mounted refrigeration units.” (Ibid., emphasis added.) The Revised FEIR clarifies that “truck backing” includes “backup alarms.” (Revised FEIR, p. 3.0-17.) Hence, noise modeling for the proposed Project included audible truck backup signals.

These measurements “were conducted at a distance of 100 feet from the center of the twobay loading dock and circulation area,” which is nearly a full 100 feet less than the approximately 200 feet between Project’s proposed loading dock (to be located on the opposite side of the Grocery Outlet building from residences) and the nearest residence to the east, on S. Franklin Street. Saxelby Acoustics found that the Project’s operation would have a less-than-significant impact on nearby residences in that it would not exceed the thresholds of significance used for the Project in its CEQA analysis (see Sections i.B.1 and II.B, supra). (DEIR, p. 3.6-15.) Notably also, per the Revised FEIR, “per Special Condition 37 for the Planning Permit, delivery hours would occur between 7:00 AM and 9:00 PM. As such, this analysis is considered conservative and provides a worst-case scenario for truck delivery noise.” (Revised FEIR, p. 3.0-17.) City Councilmembers
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Therefore, “backup signaling” from trucks would not result in a significant CEQA impact and, in all likelihood, will be inaudible to nearby residents given that backup signaling will occur at or near the loading dock, which will be blocked from nearby residences by the building itself. (See DEIR, Figure 2.0-5 [Site Plan], pp. 3.6-21 to 27 [noise contour figures].) For more information on the total number of truck trips associated with the Project, please refer to Section I.A.1 above. For a discussion on noise at nearby transient lodging, refer to Section I.B.1.

D. The FEIR’s Analysis of Emergency Services is Sufficient, and any Noise Associated with any Increased Use of Emergency Sirens Does Not Create a Significant CEQA Impact.

Leslie Kashiwada states that “emergency services were never consulted about potential impacts of this project on travel to and from ER” and then claims that an individual named “Davey Beak,” whom she describes as the “long-time manager of emergency transport at the hospital,” informed her in writing that the Project would cause “‘[a] significant change in the volume of traffic on South Street” and “‘will absolutely have an effect on our response and return times. Code 3 (lights and sirens) help but they will have an negative effect on the residential neighborhoods to the South and East of South Street...With the additional traffic created by this development we will need to switch to Code 3 several blocks earlier which will likely lead to angry public and reduced real estate values in the adjacent neighborhoods. Access to our Hospital will also be negatively affected. Thanks, Davey.’”
We have not seen, because Ms. Kashiwada did not supply the City with, the written communication to her from Mr. Beak. We note, though, that analysis in the DEIR, inclusive of its Initial Study, undermine the claims she attributes to him.

The DEIR finds that “[i]mplementation of the proposed Project would not create roadway and transportation facilities that impede access for emergency response vehicles.

All existing roadways and intersections, and internal transportation network is designed to maintain levels of accessibility for police and fire response times, which ensures vehicles have the necessary access when responding to an emergency. Therefore, this impact would be less than significant.” (DEIR, p. 3.7-46.) City Councilmembers
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This conclusion is reached, in large part, because the Project must comport with:
the numerous plans related to hazard management and mitigation, and emergency response, including but not limited to: the City of Fort Bragg Emergency Operations Plan (2010), the Mendocino County Community Wildfire Protection Plan (2005), Hazardous Waste Management Plan, Mendocino County Operational Area Emergency Operations Plan (2016), and Mendocino County Multi-Jurisdictional Hazard Mitigation Plan (2014), in which the City of Fort Bragg (City) is a participant. In addition, the Safety Element of the City of Fort Bragg Coastal General Plan aims at protecting people and property from natural hazards and other locally relevant safety issues.
(DEIR, Appendix A [Initial Study], p. 57.)

In particular, the Project will be informed by, and conform to, “the Mendocino County Operational Area Emergency Operations Plan (County EOP) [adopted] on September 13, 2016, under Resolution Number 16-119.” (Ibid.) The County EOP “complies with local ordinances, state law, and state and federal emergency planning guidance, serves as the primary guide for coordinating and responding to all emergencies and disasters within the County.” (Ibid.) Its purpose is to “‘facilitate multi-agency and multi-jurisdictional coordination during emergency operations, particularly between Mendocino County, local and tribal governments, special districts as well as state and federal agencies’ (MCOES – Plans and Publications, 2019).” (Ibid.) “The proposed development would be compatible with existing surrounding development and would be designed to current standards with suitable road widths and turn radii to accommodate emergency vehicles.[14] A less than significant impact would occur.” (Id., pp. 5758.) Additionally, the proposed Project would have a less-than-significant impact on fire services, inclusive of non-fire emergency services, pursuant to criteria in CEQA’s Appendix G Checklist. (See DEIR, Appendix A, pp. 7071.) Regarding traffic, the proposed Project will not create a significant traffic impact using current CEQA criteria for analyzing VMT. (DEIR, pp. 3.7-43 to 3.7-45.) Traffic volume (mentioned in the comment) implicates level of services (LOS), which is no longer an impact under CEQA. (See DEIR, p. 3.7-43; FEIR, Appendix A, pp. 6667.) Nevertheless, in its analysis of transportation and traffic impacts, the City included 14 “The proposed retail store would be constructed in accordance with state and local standards, including safety and emergency access requirements.” (DEIR, p. 4.0-33.) City Councilmembers
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discussions of LOS-related issues on a voluntary basis and not in order to satisfy any CEQA requirement. (See DEIR, p. 3.7-2.) The City determined that, in a cumulative scenario, City General Plan LOS standards would be exceeded; however, this concern would be ameliorated because “the Project would contribute their fair share to the cost of regional circulation improvements by paying [required] adopted fees and making [required] frontage improvements. In addition, the Project would contribute its fair share to the cost of cumulatively needed improvements to the SR 1 (Main Street) / South Street intersection.” (DEIR, p. 3.5-20.) With the required payment of these fair share fees, and required frontage improvements, the Project will relieve any incremental effects it might have on cumulative traffic volume.

As to ambulance siren noise, any theoretical increased siren usage that may result in intermittent increases in ambient noise levels as a consequence of Project-generated traffic is far too speculative of an effect to analyze in a CEQA document. CEQA does not require analysis of potential impacts, either direct or indirect, that are overly speculative.

This is particularly true of impacts that, by their nature, are temporary. (See, e.g., CEQA Guidelines, § 15064, subd. (d)(3) [“[a] change which is speculative or unlikely to occur is not reasonably foreseeable”].) Regardless, occasional sirens are part of living in an urban area. Siren sounds are an indication that highly-trained teams of professional emergencycare providers are on their way to help people who may be in danger of losing their lives.

Such sounds cannot credibly be treated as significant environmental effects to be avoided or discouraged where feasible.

In discussing this issue, Ms. Kashiwada (and Davey Beak, assuming that he is correctly quoted by Ms. Kashiwada) assumes that the Project will increase traffic in the area such that ambulances will be significantly and regularly waylaid, and then assumes that this condition will force ambulance drivers to use their sirens at a rate far greater than occurs now, and then assumes that this increase in siren usage will increase ambient noise levels such that they regularly exceed City noise standards. These assumptions pile speculation on top of speculation.
“Common sense leads us to conclude that these concerns are too ‘speculative or unlikely’ to be considered ‘reasonably foreseeable.’” (Union of Medical Marijuana Patients, Inc. v. City of Upland (2016) 245 Cal.App.4th 1265, 1276.) “Any analysis of [these] potential environmental impacts would be wholly speculative and essentially City Councilmembers
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meaningless.” (Concerned McCloud Citizens v. McCloud Community Services Dist. (2007) 147 Cal.App.4th 181, 197.)
As discussed above, the Project will have a less-than-significant effect on traffic, traffic volumes (although they are no longer a CEQA issue), and emergency response. It is, therefore, overly speculative (and entirely inaccurate) to assume that the Project would result in significant noise impacts associated with increased traffic and emergency response. Even if an increase in ambulance siren usage could somehow be tied to the Project, this increase would be sporadic, with absolutely no evidence suggesting that it would create a significant noise impact.

E. The FEIR’s Traffic Studies Are Appropriate.

Leslie Kashiwada states that the “traffic study” conducted for the Project in “late July 2019” is “incomplete and outdated.” Ms. Kashiwada, however, overlooks the two supplemental technical traffic studies that were performed for the Project. The 2019 traffic study was verified and supplemented by a nine-page June 2021 addendum, prepared by the same traffic consultant (KD Anderson & Associates, Inc.) (see DEIR, Appendix G), and a six-page June 2022 VMT analysis, prepared by a second traffic consultant (Fehr & Peers) (see DEIR, Appendix H). Together, these three traffic studies provide ample substantial evidence to support the FEIR’s conclusions (see footnote 11, supra, for legal standards related to “substantial evidence”).

Furthermore, Ms. Kashiwada does not support her cursory claim that these studies “should have included data collection on several school days and, as a tourist destination, the study should have included at least one holiday, like Paul Bunyan Days.” Presumably, the experts and registered professional engineers at KD Anderson & Associates and Fehr & Peers used the appropriate industry standard when modeling traffic data for the Project and reaching their conclusions, and Ms. Kashiwada provides no evidence to the contrary (see footnote 11, supra).

Moreover, the DEIR’s cumulative traffic analysis accounted for all planned and currently developed land uses within the area, including the nearby hospital and “Plateau” housing project mentioned by the commenter. The DEIR’s cumulative analysis employed the “summary of projection” approach, explicitly allowed by CEQA Guidelines section 15130, subdivision (b)(1)(B), by “[using] a summary of projections in City Councilmembers
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adopted General Plans or related planning documents to identify potential cumulative impacts.” (DEIR, p. 4.0-3.) These planning documents take all current and future planned land uses into account, including the aforementioned ones. For more explanation on this approach and its validity under CEQA, please refI mader to section X of RMM’s 2022 Letter (see FEIR, Appendix A).

Lastly, the “left turn from westbound N. Harbor Dr. onto Main St.” discussed by Ms. Kashiwada is not a City issue, as Main Street (Highway 1) is a Caltrans facility. In the past, Caltrans disallowed left turns at this intersection, but changed this policy prior to the release of the DEIR. (DEIR, p. 3.7-10.) In the future, as traffic increases under cumulative conditions, Caltrans may decide to consider whether or not to revert to the old policy by prohibiting left turns there. Before doing so, Caltrans must ensure all safety rules and regulations are met. (See, e.g., General Plan Policy C-2.1 [discussing that roadway improvements “to the local and regional road system” must be coordinated with Caltrans “to ensure that SR 1...will remain a scenic two-lane road consistent with Section 30254 of the Coastal Act”].) Regardless, there are laws in place to prevent vehicles from making roadway turns where they are prohibited, and it is presumed that all trucks make deliveries to the Project will adhere to those laws. Right now, however, nothing would prevent trucks from making left turns onto Highway 1 at North Harbor Drive. If drivers of delivery trucks determine that they are better off by driving north and using the signalized intersection at Highway 1 and Cypress Street to turn southward onto Highway 1, they may do so. Time will tell.

F. An Alternative that Repositions the Building to the South or Middle of the Project Site is Infeasible.

Leslie Kashiwada suggests an alternative where the Project’s building is sited on either the “south end of the adjoined properties” or “placed more in the middle of the property or where the currently [sic] building is located, with employee parking on one side and customer parking on the other.” This alternative siting, however, is neither required by CEQA nor feasible.

As explained in section II of RMM’s 2022 Letter (see FEIR, Appendix A), the DEIR need not consider additional Project alternatives because the City has discretion to determine the appropriate range of alternatives, and the City selected other alternatives City Councilmembers
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that, taken together, provided a sufficient variation of options to permit a reasoned choice under CEQA. (CEQA Guidelines, § 15126.6; In re Bay-Delta etc. (2008) 43 Cal.4th 1143, 1163.) The DEIR’s alternatives are not “manifestly unreasonable”; nor do they fail to “contribute to a reasoned range.” (Cal. Native Plant Society v. City of Santa Cruz (2009) 177 Cal.App.4th 957, 988.) Besides, Ms. Kashiwada has not presented any evidence that an alternative site layout would reduce the severity of any significant impacts of the Project or better fulfill Project objectives. Indeed, her proposed alternatives would actually create new problems (explained below).

From an engineering perspective, these alternate site layouts simply do not work.

As Project engineer Chris Schulze has explained in a technical memorandum (included herewith as Attachment B) , the Project’s building must be situated as currently proposed on the deep and narrow lot in order to: (i) comply with City setbacks, specifically a 20- foot building setback from North Harbor Drive; (ii) visibly shield the truck dock and loading area from neighboring residents and adjacent streets; (iii) minimize noise to neighboring residents from activity at the truck dock and loading area; (iv) minimize interference with the Super 8 Motel by placing the truck dock and loading area adjacent to a vacant property with commercial zoning; and (v) maximize the use of existing utility infrastructure (water, sewer, electricity, etc.) coming primarily from South Street, thereby avoiding the reconfiguration of infrastructure.

This last factor is especially meaningful from a CEQA perspective because any additional infrastructure reconfiguration would necessarily require elaborate construction begetting environmental impacts, all of which are avoidable under the proposed Project.

III. RESPONSES TO COMMENTS FROM ANNEMARIE WEIBEL
In her May 10, 2023, comment submission, Annemarie Weibel, like FBLBM, expresses that the FEIR does not adequately address DPM emissions. Please refer to Section I.A above for a response to that comment. Also, like FBLBM, Ms. Weibel indicates that the supplemental Urban Decay Study should be circulated for public review and comment. Please refer to Section I.D above for a response to that comment (as well as her comment insinuating that the Project may cause urban decay).

Like Leslie Kashiwada, Annemarie Weibel questions emergency response times and noise associated with a potential increase in the use of emergency vehicle sirens City Councilmembers
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resulting from Project traffic. Please refer to Section II.C above for a response to that comment. For a response to Ms. Weibel’s comments that the “traffic study did not take into consideration” traffic associated with summer months and holidays, and a change in traffic control at “SR 1/N. Harbor Drive intersection,” please refer to Section II.E above.

Below we respond to other comments made by Annemarie Weibel implicating CEQA or other laws and pertaining to the FEIR. The remainder of Ms. Weibel’s comments express general concerns about the Project (about noise, water supply, aesthetics, etc.) that we do not respond to in this letter, but which are addressed in some form or fashion in RMM’s 2022 Letter (see FEIR, Appendix A).

A. The 2019 Initial Study from the Previous Version of the Project Does Not Form the Basis for the DEIR or FEIR.

Annemarie Weibel incorrectly claims that the 2020 initial study prepared for the prior version of the Project “forms the basis” for the current Project’s EIR. This statement is not true. This most recent version of the proposed Project was analyzed in a completely new initial study in 2022, included as Appendix A of the DEIR, prepared by a completely new environmental consultant (DeNovo Planning Group versus LACO Associates). The DEIR and FEIR were informed by this 2022 initial study, and also by several new technical studies and reports prepared specifically for this version of the Project. See Section IV.A below for a discussion on the differences between the proposed Project and its prior iteration.

B. Information Associated with the Project is Available in Different Documents for Different Purposes—and This Approach does Not Violate CEQA.

Ms. Weibal takes umbrage with different pieces of Project information being made available in different formats and locations. Although it is somewhat difficult to follow her line of reasoning, it appears that she has concerns with the scattered nature of this Project information and some potential discrepancies between different sources. While we did not verify the accuracy of her claims as they relate to the many non-CEQA documents she cites, the CEQA analysis performed for the Project is based on the Project Description as it exists in the DEIR and FEIR. Any discrepancies between the EIR’s Project Description and the other non-CEQA documents referenced in the comment are City Councilmembers
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inconsequential to the environmental analysis performed for the Project and do not violate CEQA.

C. Although Solar Panels are not Currently Required on Commercial Projects in California, the Project will Include Solar Panels.

Annemarie Weibel asks why solar panels are “not shown or analyzed in the design” even though they are required by State law and suggests that the addition of solar panels to the Project would require review for the impact on visual resources.

Starting in January 1, 2023, California will indeed require solar power and batteries in all new commercial structures (with exceptions), pursuant to the recently updated 2022 Build Energy Efficiency Standards approved by the California Clean Energy Commission. When the EIR for the Project was first being prepared, this law was not in effect, which is why the EIR discloses only that “the proposed Project is required by the [prior version of the] California Building Energy Efficiency Standards (Energy Code) to be ‘solar ready”; specifically, the proposed Project includes a solar-ready area of 2,400 square feet.” (DEIR, pp. 3.4-37.) Although the DEIR goes on to state that “[t]he proposed Project would have to comply with all applicable federal, State, and local regulations regulating energy usage.” (Id., p. 3.4-40.) These updated standards are addressed in the recent staff report prepared for the May 10, 2023, Planning Commission meeting, in which it states that, although “[t]he proposed roof plan does not currently include solar panels...a location is reserved for them on the plans,” alongside a special condition of approval that would require the building permit application to “include solar panels on the roof.” (Planning Commission Meeting Agenda (May 10, 2023), supra, p. 32.) The Applicant has agreed to this special condition. Thus, the Project will include solar panels on its roof.

Installation of these environmentally beneficial solar panels, however, will not require additional CEQA review. Installation of solar panels require only a ministerial building permit, which does not trigger CEQA review. (See CEQA Guidelines, § 15268, subd. (a)(1) [“[i]ssuance of building permits”...are “presumed to be ministerial” and “[m]inisterial projects are exempt from the requirements of CEQA”].) City Councilmembers
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IV. RESPONSES TO COMMENTS FROM JACOB PATTERSON
A. Comments on a Prior CEQA Document Do Not Inform Decisionmakers on Another.

In one of his May 10, 2023, submissions, Jacob Patterson purports to submit (in bulk and as URLs, many of which are broken) to the Planning Commission a series of public comments made on a 2020 initial study prepared for a prior version of the Project, presumably to be applied to the proposed Project. This scattershot attempt to incorporate his prior comments into the current proceeding, however, is not proper. Indeed, this attempt seems more aimed at gumming up the works than contributing to an informed public process.

Comments intended for one project do not inform decisionmakers on another.

Every project, or every new project iteration, is a different undertaking that presents unique environmental issues at specific points in time upon which a separate application is submitted and a separate governmental approval is either granted or denied.15 (See Pub. Resources Code, §§ 21002.1, subds. (a), (d), 21065, 21065.3; CEQA Guidelines, § 15378, subds. (a), (c).) Put another way, the comment submissions made in 2020 on a prior version of the Project with a different environmental document do not present “significant environmental issues” warranting a response because they are not sufficiently specific to the currently proposed Project and, therefore, are “patently irrelevant.” (See Environmental Protection Information Center v. California Dept. of Forestry & Fire Protection (2008) 44 Cal.4th 459, 484, 487; CEQA Guidelines, § 15088 subd. (a).) This is particularly true when the commenter could not be troubled to specify exactly which prior comments he wishes to apply against a current project, as occurs here.

Accordingly, we do not respond to these comments here because they do not apply to the Project or the FEIR. Nevertheless, it is noteworthy that the vast majority of 15 The proposed Project and the project considered in the 2020 initial study differ (proposed Project has a shorter maximum height, proposed Project includes stalls for charging electric vehicles and dedicated parking spots for clean air vehicles, etc.), but even if they were identical in design, they still reflect different applications and timeframes with unique issues that require different approvals. The application for the proposed Project was submitted well after 2020, on March 14, 2022. (See Planning Commission Meeting Agenda (May 10, 2023), supra, p. 6 [“Application Date 3-14- 2022”].)
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the comment collections linked by Jacob Patterson express support and enthusiasm for development of a Grocery Outlet at the project site, much like the vast majority of the comments on the DEIR and the FEIR.

B. The Project Differs from a 2019 Auto Zone Retail Store Project, therefore, City Policies Protecting Ocean Views Apply Differently.

Jacob Patterson claims that the City’s past precedent in analyzing “the Coastal General Plan Policy that protects views along and TO the ocean” for a 2019 Auto Zone Retail Store project requires the City to analyze and interpret that same policy in the same manner for the proposed Project. This contention fails.

The policy referenced by Jacob Patterson is Coastal General Plan Policy CD-1.1, which provides, in full:

Permitted development shall be designed and sited to protect views to and along the ocean and scenic coastal areas, to minimize the alternation of natural landforms, to be visually compatible with the character of surrounding areas, and, where feasible, to restore and enhance views in visually degraded areas.

We address Project consistency with this policy in great detail in section III.A of RMM’s 2022 Letter (see FEIR, Appendix A). There, we demonstrate why and how the City’s interpretation of Policy CD-1.1 and its consistency determination of the Project with the policy is sound.

For the 2019 Auto Zone Retail Store project, to ensure compliance with Policy CD-1.1 (as well as Policies CD-1.4 to CD-1.6, CD-1.9, and CD-1.11), the City required mitigation to, in relevant part, create a “visual easement...as a deed restriction” that prohibits “[v]iew blocking development.” Jacob Patterson believes that this requirement for this different other project is evidence of “local precedent” and “actua; [sic] past practices” that must be applied to the proposed Project. Mr. Patterson is mistaken.

The two projects are easily distinguishable from one another. They are located in very different areas and exist under very different circumstances, despite the two sites both being zoned and designated as Highway Visitor Commercial. The 2019 Auto Zone Retail Store project is located immediately west of Highway 1, oceanside, with no commercial development between it and the ocean (in fact, little development at all – just a couple of homes – exists between the Auto Zone site and the ocean). Furthermore, the Auto Zone site is completely undeveloped and unpaved. Thus, any brand new City Councilmembers
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development on that site would in all likelihood block existing direct and unobstructed views from a scenic highway (Highway 1) to the ocean.

The proposed Project, conversely, is located east of Highway 1, not oceanside, with a two-story motel (Super 8) and a gas station (Chevron) between it and Highway 1, currently blocking and largely obstructing ocean views. (See FEIR, Appendix A, pp. 2123.) As well, the site itself is fully developed with a large building and paved parking lot, and it is completely surrounded by urban commercial and residential uses. (See id., pp. 2526.) Thus, the two projects have very different baseline conditions with different surrounding character.

It makes complete sense that the City would require preservation of an existing panoramic unobstructed direct ocean view from a scenic highway across a currently undeveloped lot to ensure compliance with Policy CD-1.1. It also makes perfect sense that the City would decide that a developed urban infill lot east of a scenic highway, with just a distant and mostly obstructed view of the ocean from only one marginal viewpoint does not require the same protections. (See FEIR, Appendix A, p. 22.) As we explain in RMM’s 2022 Letter (see FEIR, Appendix A, pp. 2324), the City is entitled to considerable deference in the interpretation of its own General Plan. (Gray v. County of Madera (2008) 167 Cal.App.4th 1099, 11291130.) The City Council has “broad discretion to construe its [general plan] policies in light of the plan’s purposes.” (Endangered Habitats League, Inc. v. County of Orange (2005) 131 Cal.App.4th 777, 782.) For both the Auto Zone project and the proposed Project, the City used its unique discretion as a subject matter expert when interpreting Policy CD1.1 and determining project consistency to ensure that the respective different developments are “visually compatible with the character of surrounding areas.” Lastly, in his comments inaccurately likening the proposed Project to the Auto Zone Retail Store, Jacob Patterson suggests shifting the Project’s building to the south portion of the site, much as Leslie Kashiwada has suggested. Please refer to Section II.E above for a response to that comment.

V. RESPONSE TO COMMENTS FROM NORTH BAY LABOR COUNCIL
In its May 10, 2023, submission, the North Bay Labor Council comments primarily on labor and employment issues that are not governed by CEQA, but it also City Councilmembers
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indicates, generally, that the Project has an “impact on traffic, emergency response and commute times, pollution (air, noise, light).” The generality of this comment makes it impossible to respond to with any specificity. Nevertheless, please take note that the DEIR found potential impacts associated with these issue areas to be less than significant without mitigation, save for construction noise, which will require standard-practice measures to mitigate impacts to a less-than-significant level. (See DEIR, Table ES-2 [Project Impacts and Proposed Mitigation Measures].) Please also refer to our above responses to other comments on air emissions, noise, and traffic, as well as Appendix A of the FEIR for RMM’s 2022 Letter addressing some or all of these concerns. * * *
We hope that City Council finds this letter helpful as it considers the Project for approval. As demonstrated, the FEIR does not violate CEQA in the manner indicated in these five submissions, or in any way for that matter. Many years and much expertise went into preparing this FEIR for a project that, in our legal opinion, could have been eligible for a CEQA Class 32 categorical exemption for infill development.16 We encourage City Council to rely on the legally sound analysis presented in this letter and not allow a relatively small number of project opponents with unreasonable analytical demands detract from the many benefits that this Project brings to the 16 We cannot help noting that our law firm recently prevailed in Monterey County Superior Court in defending a larger Grocery Outlet project approved by King City based on a categorical exemption. I point this out in order to emphasize that the proposed Fort Bragg Grocery Outlet project is comparatively modest in scope compared with other types of projects for which EIRs are typically prepared. The Class 32 exemption applies to qualifying infill projects that are on sites within cities that are not greater that five acres in size. (CEQA Guidelines, § 15332.) The City of Fort Bragg opted against pursuing this option before we got involved with the Project, but many courts have upheld agencies’ reliance on the Class 32 categorical exemption for projects far more intensive than the 16,157 square foot (sf) Project, which would replace an existing 16,436-sf former office building, for a net reduction of 279 square feet of physical space. (See, e.g., Banker’s Hill, Hillcrest, Park West Community Preservation Group v. City of San Diego (2006) 139 Cal.App.4th 249 [14-story multifamily residential building with underground parking]; Wollmer, supra, 193 Cal.App.4th [five-story mixed-use building with 98 residential units, 7,770 sf of commercial space, and 114 parking spaces]; Protect Tustin Ranch v. City of Tustin (2021) 70 Cal.App.5th 951 [16-pump (32-fuel position) gas station with a canopy, related equipment, landscaping, and 56 new parking stalls].) City Councilmembers
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community and broader region. Courts have long warned against unreasonable demands from project opponents intended to cause lead agencies to “jump through hoops.” (City of Irvine, supra, 238 Cal.App.4th at p. 558.) Indeed, “the comment-and-response process can … be abused. At its worst, it could become an end in itself, simply a means by which project opponents can subject a lead agency’s staff to an onerous series of busywork requests and ‘go fetch’ demands.” (Ibid.; see Long Beach Sav. & Loan Assn. v.

Long Beach Redevelopment Agency (1986) 188 Cal.App.3d 249, 263 [“[t]o allow the public review period to proceed ad nauseam would only serve to arm persons dead set against a project”]; Board of Supervisors v. Superior Court (1994) 23 Cal.App.4th 830, 837 [“CEQA was not to be ‘subverted into an instrument for the oppression and delay of social, economic, or recreational development and advancement’”].) The City need not and should not capitulate to the very few people who argue that that current process be extended long into the future. The CEQA document prepared for this much-needed Project is sufficient.

Very truly yours,
James G. Moose
Casey A. Shorrock
Cc: Keith Collins ([email protected])
Lisa Kranitz ([email protected])
Marie Jones ([email protected])
Terry Johnson ([email protected])
Carl Best ([email protected])
Scott Best ([email protected])
John Barney ([email protected])
Attachment A: Health Risk Assessment prepared by LSA Associates for the Agua Mansa Industrial Project Draft EIR (SCH# 2020010137), City of Jurupa Valley, California (Mar. 2020)
Attachment B: Memorandum from Chris Schulze to Terry Johnson (May 17. 2023) Attachment C: Letter from Devon Patel, Manager of Super 8 Motel to City Council (May 27 2023)
Attachment A: Health Risk Assessment prepared by
LSA Associates for the Agua Mansa Industrial Project
Draft EIR (SCH# 2020010137), City of Jurupa Valley,
California (Mar. 2020)
March 2020

HEALTH RISK ASSESSME NT

AGUA MANSA INDUSTRIAL PROJECT

CITY OF JURUPA VALLEY, CALIFORNIA
CASE NUMBER MA18008
LSA
March 2020

HEALTH RISK ASSESSMENT

AGUA MANSA INDUSTRIAL PROJECT

CITY OF JURUPA VALLEY, CALIFORNIA
CASE NUMBER MA18008
Submitted to:

Carson Companies
100 Bayview Circle, Suite 3500
Newport Beach, California 92660
Prepared by:

LSA
20 Executive Park, Suite 200
Irvine, California 92614-4731
(949) 553-0666
Project No. CRN1801
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TABLE OF CONTENTS
LIST OF ABBREVIATIONS AND ACRONYMS............................................................................................. ii

1.0 INTRODUCTION................................................................................................... 1

1.1 Background .......................................................................................................................... 1

1.1.1 California Air Resources Board Handbook and Technical Advisory....................................... 1

1.1.2 California Air Pollution Control Officers Association ............................................................. 1

1.1.3 South Coast Air Quality Management District....................................................................... 2

1.2 Project Location ................................................................................................................... 2

1.3 Project Description............................................................................................................... 2

1.4 Existing Sensitive Land Uses in the Project Area.................................................................. 2

2.0 SETTING .............................................................................................................. 6

2.1 Regional Air Quality.............................................................................................................. 6

2.1.1 Climate/Meteorology ............................................................................................................ 6

2.1.2 Toxic Air Contaminants.......................................................................................................... 7

3.0 THRESHOLDS....................................................................................................... 8

3.1 Health Risk Assessment Thresholds of Significance............................................................. 8

4.0 IMPACTS AND MITIGATION................................................................................. 9

4.1 Health Risk Assessment........................................................................................................ 9

4.1.1 Emission Sources.................................................................................................................10

4.1.2 American Meteorological Society/Environmental Protection Agency Regulatory Model Dispersion Modeling .............................................................................................................13

4.1.3 Hotspots Analysis and Reporting Program Modeling..........................................................14

4.1.4 Acute Project-Related Emission Impacts.............................................................................14

4.1.5 Carcinogenic and Chronic Project-Related Emission Impacts .............................................15

5.0 REFERENCES...................................................................................................... 17

FIGURES
Figure 1: Project Location....................................................................................................................... 3 Figure 2: Conceptual Site Plan................................................................................................................ 4 Figure 3: Sensitive Receptors ................................................................................................................. 5 Figure 4: Project Area Wind Patterns..................................................................................................... 6 Figure 5: Overall Modeling Layout ....................................................................................................... 11 Figure 6: 30 Year Cancer Risk Levels..................................................................................................... 16 TABLES
Table A: Agua Mansa Industrial Truck Idling Emission Rates............................................................... 13 Table B: Health Risk Levels for Existing Residents Near the Project Site ............................................. 15

APPENDICES
A: EMISSION FACTORS FOR VEHICLES AND HEALTH RISK ASSESSMENT EMISSION RATES B: AERMOD OUTPUT AND HARP RESULTS
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LIST OF ABBREVIATIONS AND ACRONYMS
AAQS ambient air quality standards
AB Assembly Bill
AERMOD American Meteorological Society/Environmental Protection Agency Regulatory Model
AMIC Agua Mansa Industrial Corridor
APU auxiliary power unit
Basin South Coast Air Basin
CalEPA California Environmental Protection Agency
CAPCOA California Air Pollution Control Officers Association CARB California Air Resources Board
CARB Handbook California Air Resources Board Air Quality and Land Use Handbook: A Community Health Perspective
CEQA California Environmental Quality Act
City City of Jurupa Valley
DPM diesel particulate matter
EMFAC2017 California Emissions Factor Model, Version 2017 EPA United States Environmental Protection Agency
HARP2 Hotspots Analysis and Reporting Program, Version 2 HI Hazard Index
HRA health risk assessment
I-10 Interstate 10
MEI maximum exposed individual
MICR maximum individual cancer risk
mph miles per hour
OEHHA Office of Environmental Health Hazard Assessment
PM particulate matter
PM10 particulate matter less than 10 microns in size
PM2.5 particulate matter less than 2.5 microns in size
project Agua Mansa Industrial development
ROG reactive organic gas
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SCAQMD South Coast Air Quality Management District
sf square foot/feet
SR-60 State Route 60
State State of California
TAC toxic air contaminant
T-BACT toxics best available control technology
μg/m3 millions per microgram per cubic meter
URF unit risk factor
USC United States Code
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1.0 INTRODUCTION
LSA Associates, Inc. (LSA) has prepared a health risk assessment (HRA) for the proposed Agua Mansa Industrial development (project) located in Jurupa Valley, California. The project involves the development of two buildings on an undeveloped site for industrial uses. The project is planned to be constructed starting in 2019 and is planned to begin operations in 2020.

An HRA is a process used to estimate the increased health risk levels for people living and/or working near a project that emits toxic air contaminants (TACs). An HRA combines the results of studies on the health effects of various animal and human exposure to TACs with the results of studies that estimate exposure levels at different distances from pollutant sources. The purpose of this HRA is to determine the increased cancer and noncancer health risks from project-related emissions of TACs in the exhaust of diesel-powered trucks on existing nearby sensitive receptors, including residents and workers.

The City of Jurupa Valley (City) recommends the preparation of an HRA in accordance with policies and procedures of the state Office of Environmental Health Hazard Assessment (OEHHA) and the South Coast Air Quality Management District (SCAQMD). This HRA evaluates the project against the significance criteria established by the SCAQMD and is in compliance with all other applicable requirements.

1.1 BACKGROUND
This section provides a discussion of regulatory guidance from the California Air Resources Board (CARB), the California Air Pollution Control Officers Association (CAPCOA), and the SCAQMD.

1.1.1 California Air Resources Board Handbook and Technical Advisory CARB has developed an Air Quality and Land Use Handbook (CARB Handbook; 2005) and a supplement, Strategies to Reduce Air Pollution Exposure Near High-Volume Roadways: Technical Advisory (CARB 2017), that are intended to serve as general reference guides for evaluating and reducing air pollution impacts associated with new projects that are part of the land use decisionmaking process. According to the CARB Handbook, recent air pollution studies have shown an association between both respiratory and other noncancer health effects and proximity to hightraffic roadways. Other studies have shown that diesel exhaust and other cancer-causing chemicals emitted from cars and trucks are responsible for much of the overall cancer risk from airborne toxics in California. The CARB Handbook recommends that planning agencies recognize that the configuration of warehouse and distribution centers can reduce population exposure and risk. For example, locating the main entry and exit points away from sensitive land uses helps to reduce cancer risks and other health impacts.

1.1.2 California Air Pollution Control Officers Association In 2009, the CAPCOA published guidance (CAPCOA 2009) on assessing the health risk impacts from and to proposed land use projects, focusing on the acute, chronic, and cancer impacts of sources affected by the California Environmental Quality Act (CEQA) and recommending procedures to identify when a project should undergo further risk evaluation, how to conduct the HRA, how to LSA

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1.1.3 South Coast Air Quality Management District
The SCAQMD has its own risk assessment guidelines and required assumptions, Supplemental Guidelines for Preparing Risk Assessments for the Air Toxics “Hot Spots” Information and Assessment Act (2015). These guidelines incorporate the OEHHA guidance and the options to be used when using the CARB’s Hotspots Analysis and Reporting Program Version 2 (HARP 2) program for risk assessment calculations.

1.2 PROJECT LOCATION
The project site is located at 12340 Agua Mansa Road in the Agua Mansa Industrial Corridor (AMIC) of Jurupa Valley, as shown on Figure 1, Project Location. The project site is located approximately 2 miles north of the State Route 60 (SR-60) freeway and 3.5 miles south of the Interstate 10 (I-10) freeway.

1.3 PROJECT DESCRIPTION
The project would develop two separate buildings on the project site for industrial uses. Building A would be 140,198 square feet (sf) on an 8.94-acre lot, and Building B would be 194,804 sf on a

14.49-acre lot. The project would also include 234 parking spaces. See Figure 2, Conceptual Site Plan. The main freight truck entrance/exits to the proposed warehouse buildings will be on Hall Avenue with separate passenger vehicle entrances also on Hall Avenue. The project trucks would travel south on Rubidoux Boulevard to the SR-60 freeway and north on Riverside Avenue to the I-10 freeway. The project includes loading bays along the west side of Building A and the south side of Building B, as shown in Figure 3, Sensitive Receptors. The project would generate a daily trip rate of 1,035 cars, 105 two-axle trucks, 51 three-axle trucks, and 125 four-plus-axle trucks.

This HRA focuses on the potential health risks to residents and workers near the site, following the CARB Handbook, CAPCOA, and SCAQMD guidance and recommendations. It examines the shortterm and long-term potential health effects from emissions of TACs from project operations, primarily the exhaust from trucks hauling materials to and from the project site.

1.4 EXISTING SENSITIVE LAND USES IN THE PROJECT AREA
Sensitive receptors include residences, schools, hospitals, and similar uses sensitive to air quality.

The project site is surrounded primarily by industrial and residential development, as shown on Figure 3, Sensitive Receptors. The areas adjacent to the project site include the following uses:
• North: Industrial and residential development in the AMIC in Jurupa Valley. The closest residential building is located approximately 550 feet north of the project’s loading docks and the closest worker location is located approximately 450 feet north of the project’s loading docks. • Northeast: Residential development in the AMIC in unincorporated San Bernardino County. • East: Industrial development in the AMIC in San Bernardino County. • South: Industrial development in the AMIC in Jurupa Valley. • West: Industrial development and undeveloped land in the AMIC in Jurupa Valley.

LSA
Service Layer Credits: Copyright:© 2014 Esri
© 2020 Microsoft Corporation © 2020
SOURCE: Bing (2018); Agua Mansa (07/1986)
I:\CRN1801\GIS\MXD\ProjLoc_Noise.mxd (3/16/2020)
FIGURE 1
Agua Mansa Industrial Project
Project Location
0 1000 2000
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Project Location
Agua Mansa Industrial Corridor Specific Plan Area
Riverside County/San Bernardino County Boundary
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Ã60
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Existing Block Wall
I:\CRN1801\G\Site_Plan.cdr (5/7/2019)
Proposed 7 ft Block Wall
LEGEND FIGURE 2
Conceptual Site Plan
Agua Mansa Industrial Project
SOURCE RGA, 4/19:

FEET
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Agua Mansa Rd Hall Ave
Brown Ave
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Holly St N
Nearest ResidentsNearest WorkersLoading Docks
LEGEND
Project Site
FIGURE 3
Sensitive Receptors
Agua Mansa Industrial Project
SOURCE Google Earth (Aerial, 2018), Carson Companies (Site Plan) :

FEET
0 225 450
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2.0 SETTING

2.1 REGIONAL AIR QUALITY
The project site is located in Jurupa Valley, California, which is part of the South Coast Air Basin (Basin) and is under the jurisdiction of the SCAQMD.

2.1.1 Climate/Meteorology
Air quality in the planning area is not only affected by various emission sources (e.g., mobile and industrial), but also by atmospheric conditions (e.g., wind speed, wind direction, temperature, and rainfall). The combination of topography, low mixing height, abundant sunshine, and emissions from the second-largest urban area in the United States gives the Basin some of the worst air pollution problems in the nation.

The nearest representative meteorological station that provides the American Meteorological Society/Environmental Protection Agency Regulatory Model (AERMOD) ready meteorological data is the Riverside Airport Meteorological Station, about 6.4 miles from the project site. Figure 4, Project Area Wind Patterns, below, shows the windrose from data measured at this station and the wind patterns for the project area.

Figure 4: Project Area Wind Patterns
:NORTH
. __ ... ··,:, 32.5%
__ .-·"26%
_.·"19.5%
_/ 13%
9% \ : : : ......... ! ........... ; ............. . EAST:
: :
isouTH .. ----
V\/lt-OSA:ED
(mis)
- >= 11.10
- 8.80- 11.10
D 5.10 - 8.80
D 3.60-5 .10

2.10 - 3.60
- 0.50-2.10
Calms: 2.37%
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2.1.2 Toxic Air Contaminants
The public’s exposure to TACs is a significant environmental health issue in the State of California.

In 1983, the California Legislature enacted a program to identify the health effects of TACs and to reduce exposure to these contaminants to protect the public health. The Health and Safety Code defines a TAC as “an air pollutant which may cause or contribute to an increase in mortality or in serious illness, or which may pose a present or potential hazard to human health.” A substance that is listed as a hazardous air pollutant pursuant to subsection (b) of Section 112 of the Federal Act (42 United States Code [USC] Section 7412[b]) is a TAC. Under State law, the California Environmental Protection Agency (CalEPA), acting through CARB, is authorized to identify a substance as a TAC if it determines the substance is an air pollutant that may cause or contribute to an increase in mortality or an increase in serious illness, or which may pose a present or potential hazard to human health.

California regulates TACs primarily through Assembly Bill (AB) 1807 (Tanner Air Toxics Act), AB 2588 (Air Toxics “Hot Spot” Information and Assessment Act of 1987), and Senate Bill (SB) 25, the Children's Environmental Health Protection Act. The Tanner Air Toxics Act sets forth a formal procedure for CARB to designate substances as TACs. Once TACs are identified, CARB adopts an “airborne toxics control measure” for sources that emit designated TACs. If there is a safe threshold for a substance at which there is no toxic effect, the control measure must reduce exposure to below that threshold. If there is no safe threshold, the measure must incorporate toxics best available control technology (T-BACT) to minimize emissions.

Air toxics from stationary sources are also regulated in California under the Air Toxics “Hot Spot” Information and Assessment Act of 1987 (AB 2588). Under AB 2588, TAC emissions from individual facilities are quantified and prioritized by the designated air quality management district or air pollution control district. High priority facilities are required to perform an HRA and, if specific thresholds are exceeded, are required to communicate the results to the public in the form of notices and public meetings.

To date, CARB has designated nearly 200 compounds as TACs. Additionally, CARB has implemented control measures for a number of compounds that pose high risks and show potential for effective control. The majority of the estimated health risks from TACs can be attributed to relatively few compounds, the most important being particulate matter from diesel-fueled engines (diesel particulate matter [DPM]).

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3.0 THRESHOLDS

3.1 HEALTH RISK ASSESSMENT THRESHOLDS OF SIGNIFICANCE
Both the State and federal governments have established health-based ambient air quality standards (AAQS) for seven air pollutants. For other air pollutants without defined significance standards, the definition of substantial pollutant concentrations varies. For TACs, “substantial” is taken to mean that the individual health risk exceeds a threshold considered to be a prudent risk management level.

The following limits for maximum individual cancer risk (MICR) and noncancer acute and chronic Hazard Index (HI) from project emissions of TACs are considered appropriate for use in determining the health risk for projects in the Basin:
• MICR: MICR is the estimated probability of a maximum exposed individual (MEI) contracting cancer as a result of exposure to TACs over a period of 30 years for adults and 9 years for children in residential locations and over a period of 25 years for workers. The MICR calculations include multi-pathway consideration, when applicable.

The cumulative increase in MICR that is the sum of the calculated MICR values for all TACs would be considered significant if it would result in an increased MICR greater than 10 in 1 million (1.0 x 10-5) at any receptor location.
• Chronic HI: Chronic HI is the ratio of the estimated long-term level of exposure to a TAC for a potential MEI to its chronic reference exposure level. The chronic HI calculations include multipathway consideration, when applicable.

The project would be considered significant if the cumulative increase in total chronic HI for any target organ system would exceed 1.0 at any receptor location. • Acute HI: Acute HI is the ratio of the estimated maximum 1-hour concentration of a TAC for a potential MEI to its acute reference exposure level.

The project would be considered significant if the cumulative increase in total acute HI for any target organ system would exceed 1.0 at any receptor location.

The SCAQMD CEQA Air Quality Handbook (1993, currently under revision) states that emissions of TACs are considered significant if an HRA shows an increased risk of greater than 10 in 1 million.

Based on guidance from SCAQMD in the document Health Risk Assessment Guidance for Analyzing Cancer Risks from Mobile Source Diesel Idling Emissions for CEQA Air Quality Analysis (2003), for the purposes of this analysis, the threshold of 10 in 1 million was used as the cancer risk threshold for the proposed project.

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4.0 IMPACTS AND MITIGATION

4.1 HEALTH RISK ASSESSMENT
For the purposes of an HRA, short-term emissions are of concern for analyzing acute health impacts, and long-term emissions are of concern for analyzing chronic and carcinogenic health impacts. A screening-level multi-pathway assessment has been conducted. This technique was chosen as recommended in the OEHHA Air Toxic Hot Spots Program Risk Assessment Guidelines (March 2015).

This HRA has been conducted using three models: the CARB’s California Emissions Factor Model, Version 2017 (EMFAC2017) for vehicle emissions factors and percentages of fuel type within the overall vehicle fleet, the United States Environmental Protection Agency’s (EPA) AERMOD air dispersion model to determine how the TACs would move through the atmosphere after release from sources both on site and on surrounding roadways, and the CARB’s Hotspots Analysis and Reporting Program (HARP2) model to translate the pollutant concentrations from AERMOD into individual health risks at any sensitive receptor locations surrounding the project site.

This HRA includes analyzing the inhalation, dermal soil, mother’s milk, and homegrown produce pathways. This technique was chosen as prescribed in SCAQMD’s Supplemental Guidelines for Preparing Risk Assessments for the Air Toxics “Hot Spots” Information and Assessment Act (June 2015).

The OEHHA has determined that long-term exposure to diesel exhaust particulates poses the highest cancer risk of any TAC it has evaluated. Exposure to diesel exhaust can also have immediate health effects. Diesel exhaust can irritate the eyes, nose, throat, and lungs, and it can cause coughs, headaches, lightheadedness, and nausea. In studies with human volunteers, DPM made people with allergies more susceptible to the materials to which they are allergic, such as dust and pollen.

Exposure to DPM also causes inflammation in the lungs, which may aggravate chronic respiratory symptoms and increase the frequency or intensity of asthma attacks. For risk assessment procedures, the OEHHA specifies that the surrogate for whole diesel exhaust is DPM.

The conservative nature of this analysis is due primarily to the following three factors:
• The CARB-adopted diesel exhaust unit risk factor (URF) of 300 in 1 million per microgram per cubic meter (μg/m3
) is based on the upper 95th percentile of estimated risk for each of the epidemiological studies used to develop the URF. Therefore, the risk factor is already representative of the conservative risk posed by DPM.
• The risk estimates assume sensitive receptors will be subject to DPM for 24 hours per day, 350 days per year. As a conservative measure, SCAQMD does not recognize indoor adjustments for LSA

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\\vcorp12\projects\CRN1801\HRA\Products\HRA-RTC-RLSO.docx «03/19/20» 10 residents. However, typical people spend the majority of their time indoors versus remaining outdoors for 24 hours per day, 350 days per year.1
• The exposure to DPM is assumed to be constant for the given period analyzed (i.e., 30 years).

However, emissions from DPM are expected to substantially decrease in the future with the implementation of standard regulatory requirements and technological advancement to reduce DPM.

Improvements over the last 40 years to diesel fuel and diesel engines have resulted in lower emissions of some of these contaminants. These improvements have resulted in a 75 percent reduction in particle emissions from diesel-powered trucks and other equipment as compared to 2000 levels, and by 2020, when fully implemented, will result in an 85 percent reduction.2 These improvements are anticipated to continue into the foreseeable future.

4.1.1 Emission Sources
The first step of an HRA is to characterize the project-related emissions of TACs. According to the Agua Mansa Industrial Traffic Impact Analysis (LSA 2020), the project would generate a daily trip rate of 1,035 cars, 105 two-axle trucks, 51 three-axle trucks, and 125 four-plus-axle trucks. The traffic study also characterized the routes and percentages of the car and truck traffic that would travel to and from the project site. While the TAC emissions from gasoline-powered vehicles have a small health effect compared to DPM, this HRA includes all the traffic information described and both gasoline- and diesel-powered vehicle emissions. For the diesel exhaust emissions, it is sufficient to only consider the DPM (particulate matter less than 10 microns in diameter [PM10] and particulate matter less than 2.5 microns in size [PM2.5]) portions of the exhaust; all the TACs for the gasoline exhaust emissions are contained in the reactive organic gas (ROG) emissions. Using speciation data from CARB, the emission rates of the TAC components are derived from the total ROG emissions.

The vehicles associated with the project were assumed to operate 24 hours per day, 7 days per week, and 52 weeks per year. The project trucks operate in two modes: stationary idling and moving on and off the site. The emissions from trucks while idling result in a much higher concentration of TACs at nearby sensitive receptors compared to the emissions from moving trucks. This is due to the dispersion of emissions that occurs with distance and with travel of the vehicle. For this HRA, the truck travel emissions were modeled as a series of volume sources along on-site buildings and driveways and along truck routes to the I-10 and SR-60 freeways. These sources cover the anticipated primary truck routes as shown on Figure 5, Overall Modeling Layout, with the dark blue

1 In May 1991, the CARB Research Division, in association with the University of California, Berkeley, published research findings titled Activity Patterns of California Residents. The findings of that study indicate that on average, adults and adolescents in California spent almost 15 hours per day inside their homes and 6 hours in other indoor locations, for a total of 21 hours (87 percent of the day). About 2 hours per day were spent in transit, and just over 1 hour per day was spent in outdoor locations. 2 California Environmental Protection Agency (CalEPA), Office of Environmental Health Hazard Assessment (OEHHA), and American Lung Association of California. 2001. Health Effects of Diesel Exhaust. May 21, 2001. Website: oehha.ca.gov/air/health-effects-diesel-exhaust, accessed May 2018.

LSA
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\\vcorp12\projects\CRN1801\HRA\Products\HRA-RTC-RLSO.docx «03/19/20» 12 line. While it is possible that a few trucks could take other routes, the small number of trucks going on any routes other than those identified as the main routes would not add substantial amounts of TACs along those routes. LSA assumed vehicles traveling on site would maneuver slowly, averaging approximately 5 miles per hour (mph), and that vehicles traveling on roadways would average 35 mph.

The idling emissions of trucks operating on the project site were modeled as individual point sources at idling locations along the planned loading docks for both buildings, shown on Figure 5 as red dots.

While the idling times of the trucks are regulated to be no more than 5 minutes, it is possible the trucks will stop at the loading dock and one or two other areas on site during a single delivery. For the purposes of this HRA, the idling times per delivery were conservatively assumed to be 15 minutes per delivery.

EMFAC2017 was used to determine the emissions factors of idling and operating diesel trucks to determine the total emissions of PM10. While the TAC of concern from diesel trucks is DPM, EMFAC2017 does not include emissions factors for this TAC. DPM is a component of the overall exhaust from the project-related trucks. This HRA conservatively assumes the DPM emissions are equal to the PM10 emissions when actually the DPM is only a portion of the overall PM10 in the truck exhaust. While it is expected that the truck emissions rate will continue to reduce over time, an HRA only allows for a single emission rate to represent the entire 25- or 30-year exposure period. The use of emissions factors for the year 2025 was selected for this HRA to be conservative. For instance, based on operations starting in 2020, using emissions factors for a 2026 vehicle fleet (the midpoint of the 9-year exposure period) or using emissions for a 2036 vehicle fleet (the midpoint of the 30- year exposure period) could be used; however, either of these would be less conservative.

The tables in Appendix A show the development of the exhaust emission rates for the trucks while operating both on the project site and on the roadways as described in the project traffic study. The tables show the average daily traffic for the entire project on each stretch of road by vehicle category. The percentage within each vehicle category that is diesel powered (from EMFAC2017) and the PM10, PM2.5, and ROG emissions factors for each vehicle category at the average vehicle speed of 5 mph on site and 35 mph on roadways are also shown. Because the AERMOD dispersion model cannot use emissions in grams per mile, emissions are converted to grams per second. The same derivation is repeated for ROG emissions from gasoline-powered vehicles (all TAC emissions from gasoline exhaust are contained in the ROG emissions).

Table A shows the development of the exhaust emission rates for the trucks while idling on the project site. These emissions are equally divided among the 11 point sources located at all the loading dock areas for the two project buildings. These are depicted on Figures 5 and 6 as red circles next to the project buildings. Emissions data results are shown in Table A using the idling emissions factors from EMFAC2017 for these trucks, combined with the total truck count, and assuming 15 minutes of idling per trip.

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\\vcorp12\projects\CRN1801\HRA\Products\HRA-RTC-RLSO.docx «03/19/20» 13 Table A: Agua Mansa Industrial Truck Idling Emission Rates Facility Hours/
Day
Trucks/
Day1
Trucks/
Hour
Diesel Idle Exhaust per
Vehicle (g/hr)2 Idle Time
(min/trip)3
Idle Exhaust Diesel
(g/hr)
PM10 PM2.5 PM10 PM2.5
Loading Dock 24 282 11.7 0.00010 0.00010 15 0.0003 0.0003 Source: LSA Associates, Inc. (March 2020). 1 Agua Mansa Industrial Traffic Impact Analysis (LSA 2020). Note that each truck visit comprises two trips, one to arrive and one to depart. 2 CARB EMFAC2017 idling emissions factors for 2020 MHDT & HHDT diesel trucks. 3 This table assumes each truck idles for 15 minutes per trip to account for multiple stops (i.e., at an entry check-in, loading/unloading, and miscellaneous on-site activities).

CARB = California Air Resources Board
EMFAC2017 = California Emissions Factor Model, Version 2017 g/hr = grams per hour
HHDT = Heavy-Heavy-Duty Truck
min/trip = minutes per trip
MHDT = Medium heavy-duty truck
mph = miles per hour
PM10 = particulate matter less than 10 microns in diameter PM2.5 = particulate matter less than 2.5 microns in diameter It was assumed the trucks would idle using their main engines rather than an auxiliary power unit (APU) or plugging in to shore power throughout their time at the project site. This is a very conservative assumption, as the loading docks are required to have electrical hookups and the trucks to have the ability to run their accessories from that electricity, so it is likely that the trucks would only be operating on their own power when arriving or departing. CARB has developed plans (CARB 2017) to transition to near-zero-emission technologies and ultimately zero-emission technologies. These will be phased in over time, possibly beginning in the 2020 decade and extending out to 2050.

4.1.2 American Meteorological Society/Environmental Protection Agency Regulatory Model Dispersion Modeling
In order to assess the dispersion of emissions associated with the project, air dispersion modeling was performed using AERMOD. The model is approved by the EPA when estimating the air quality impacts associated with point and fugitive sources in simple and complex terrain. The model was used to calculate the annual average and short duration (e.g., 1-hour) pollutant concentrations associated with each emitting source. Inputs for each emitting source were based on the characterizations described above. Details of these inputs are shown in Appendix B.

For the volume sources used to represent on-road mobile source activity, vertical (sigma z) dispersion parameters were developed as described in the EPA guidance for trucks. Horizontal (sigma y) dispersion parameters were generated by dividing the source separation distance by a standard deviation of 2.15, as described in the EPA guidance. For the truck idling locations, individual point sources represent the idling at all the loading docks by points spread along all loading dock locations and the total idling emissions spread equally. For all the idling sources, the release height was set to the approximate truck exhaust stack height of 12 feet, a temperature of 200°F, a flow rate of 50 meters per second, and an exhaust pipe diameter of 4 inches. Because building wake effects (building downwash) influences can significantly increase concentrations for receptors located downwind of the building close to the emissions source, the proposed new buildings were included with a building height of 45 feet for Building A and 44 feet for Building B.

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\\vcorp12\projects\CRN1801\HRA\Products\HRA-RTC-RLSO.docx «03/19/20» 14 The model requires additional input parameters, including local meteorology. Due to the model’s sensitivity to individual parameters (e.g., wind speed, temperature, and direction), the EPA recommends meteorological data used as input into dispersion models be selected on the basis of relative spatial and temporal conditions that exist in the area of concern. As such, 5 years of meteorological data from SCAQMD’s Riverside-Rubidoux Monitoring Station1 (the nearest available) was used to represent local weather conditions and prevailing winds.

Receptors were placed in an approximately 2.5- by 5-mile grid, as shown on Figure 5, from west of Linden Avenue to east of Market Street, and from north of the I-10 to south of the SR-60 to characterize the regional risk levels. Additionally, discrete receptors were places at the location of all sensitive receptors surrounding the proposed project site.

4.1.3 Hotspots Analysis and Reporting Program Modeling
CARB’s HARP2 model is a tool that assists with the programmatic requirements of the Air Toxics “Hot Spots” Program (AB 2588). HARP2 was used to translate the TAC concentrations from AERMOD into long-term carcinogenic and chronic, and short-term acute health risk levels following the guidance in the SCAQMD risk assessment guidelines (2015) for residents and workers. These guidelines specify a minimum set of TAC pathways and HARP2 modeling options for the carcinogenic assessment. To estimate chronic noncancer risks at residential receptors, the “OEHHA-Derived Method” risk-calculation option was used. Following the OEHHA guidance (2015), an 8-hour chronic noncancer risk was calculated for residential receptors because the project would operate more than 8 hours per day and 5 days per week.

The dose-response relationship for a specific pollutant describes the association between exposure and the observed response (health effect). In other words, the relationship estimates how different levels of exposure to a pollutant change the likelihood and severity of health effects. The doseresponse relationship (the response occurring with increasing doses) varies with each pollutant, individual sensitivity, and type of health effect. Combining the results of the emission characterization and dispersion modeling described above with the dose-response assessment gives an estimate of the increased health risk for an individual exposed to the maximum predicted longterm concentrations of TACs.

4.1.4 Acute Project-Related Emission Impacts
Exposure to TACs from vehicle exhaust can result in immediate health effects. However, according to the rulemaking in CARB’s Identifying Particulate Emissions from Diesel-Fueled Engines as a Toxic Air Contaminant (1998), the available data from studies of humans exposed to diesel exhaust are not sufficient for deriving an acute noncancer health risk guidance value.

Emissions from gasoline-powered vehicles do contain TACs with short-term acute health effects. The acute health risks from the project’s on-site truck activity and roadway traffic are shown in Table B.

1 South Coast Air Quality Management District (SCAQMD). Meteorological Data for AERMOD. Website:
http://www.aqmd.gov/home/library/air-quality-data-studies/meteorological-data/data-for-aermod, accessed November 2017.

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\\vcorp12\projects\CRN1801\HRA\Products\HRA-RTC-RLSO.docx «03/19/20» 15 Table B: Health Risk Levels for Existing Residents Near the Project Site Location
Maximum Cancer
Risk
(risk per million)
Maximum Noncancer
Chronic Risk
(Hazard Index)
Maximum Noncancer
Acute Risk
(Hazard Index)
Residential Risks 0.12 in 1 million 0.00011 0.0003
Worker Risks 0.03 in 1 million 0.0003 0.0004
SCAQMD Significance Threshold 10 1.0 1.0
Significant? No No No
Source: Compiled by LSA Associates, Inc. (March 2020).

SCAQMD = South Coast Air Quality Management District
The Acute HI for the residential MEI would be 0.0003, and for the worker, the MEI would be 0.0004; both are less than the threshold of 1.0.

4.1.5 Carcinogenic and Chronic Project-Related Emission Impacts The carcinogenic and chronic health risks from the proposed project are also shown in Table B. The residential risk incorporates both the risk for a child living in a nearby residence for 9 years (the standard period of time for child risk) and an adult living in a nearby residence for 30 years (considered a conservative period of time for an individual to live in any one residence). The maximum cancer risk for the residential MEI would be 0.12 in 1 million, less than the threshold of 10 in 1 million. Figure 6, 30 Year Cancer Risk Levels, shows the extent of the 0.3 in 1 million cancer risk level. The maximum cancer risk for the worker MEI would be 0.03 in 1 million, also less than the threshold of 10 in 1 million. The chronic health risks from the project’s on-site and roadway traffic are shown in Table B.

As these results show, all health risk levels to nearby residents and workers from project-related emissions of TAC would be well below SCAQMD’s HRA thresholds. No significant health risk would occur from project-related truck traffic, and no mitigation is necessary. Appendix B provides the HARP modeling reports and AERMOD information.

LSA
LEGEND
- Volume Sources Along Roads and Driveways
- Truck Idling Locations
- Receptors Around Project Site
FIGURE 6
I:\CRN1801\G\30-Year Cancer Risk Levels.cdr (11/15/2018) 30-Year Cancer Risk Levels FEET
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\\vcorp12\projects\CRN1801\HRA\Products\HRA-RTC-RLSO.docx «03/19/20» 17

5.0 REFERENCES
California Air Pollution Control Officers Association. 2009. Health Risk Assessments for Proposed Land Use Projects. July. Website: www.capcoa.org/wp-content/uploads/2012/03/ CAPCOA_HRA_LU_Guidelines_8-6-09.pdf, accessed November 2018.

California Air Resources Board (CARB). 1998. Identifying Particulate Emissions from Diesel-Fueled Engines as a Toxic Air Contaminant.
_____. 2003. Air Resources Board Recommended Interim Risk Management Policy for InhalationBased Residential Cancer Risk. October 9. Website: www.arb.ca.gov/toxics/harp/docs/ rmpolicy.pdf, accessed November 2018.
_____. 2005. Air Quality and Land Use Handbook: A Community Health Perspective (CARB Handbook). April. Website: www.arb.ca.gov/ch/handbook.pdf, accessed November 2018. _____. 2015. Consolidated Table of OEHHA/CARB Approved Risk Assessment Health Values. Table last updated February 23, 2017. Website: www.arb.ca.gov/toxics/healthval/contable.pdf, accessed November 2018.
_____. 2017. Strategies to Reduce Air Pollution Exposure Near High-Volume Roadways: Technical Advisory. April. Website: www.arb.ca.gov/ch/ rd_technical_analysis_fact_sheet.pdf, accessed November 2018.
_____. 2017. Truck and Bus Regulation Compliance Requirements Summary. December 18. Website:
www.arb.ca.gov/msprog/onrdiesel/documents/fsregsum.pdf, accessed November 2018. _____. California Emissions Factor Model, Version 2017 (EMFAC2017). Webpage last updated by CARB on August 23, 2018. Website: www.arb.ca.gov/msei/categories.htm, accessed November 2018.
_____. HARP. HARP Overview. Webpage last reviewed by CARB on July 11, 2018. Website:
www.arb.ca.gov/toxics/harp/harp.htm, accessed November 2018. _____. Particulate Emissions from Diesel-Fueled Engines as a Toxic Air Contaminant. Webpage last reviewed by CARB on July 29, 2008. Website: www.arb.ca.gov/toxics/dieseltac/ dieseltac.htm, accessed November 2018.
_____. Statewide Truck and Bus Regulations. Webpage last reviewed by CARB on January 8, 2014.

Website: www.arb.ca.gov/regact/2008/truckbus08/truckbus08.htm, accessed November 2018.
_____. Toxic Air Contaminant Identification List. Webpage last reviewed by CARB on July 18, 2011.

Website: www.arb.ca.gov/toxics/id/taclist.htm, accessed November 2018.

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\\vcorp12\projects\CRN1801\HRA\Products\HRA-RTC-RLSO.docx «03/19/20» 18 California Environmental Protection Agency (CalEPA) Office of Environmental Health Hazard Assessment (OEHHA). 2015. Air Toxics Hot Spots Program Guidance Manual for Preparation of Health Risk Assessments. March. Website: oehha.ca.gov/air/air-toxics-hot-spots, accessed November 2018.

California Environmental Protection Agency (CalEPA) Office of Environmental Health Hazard Assessment and the American Lung Association of California. 2001. Health Effects of Diesel Exhaust. May 21, 2001. Website: https://oehha.ca.gov/air/health-effects-diesel-exhaust, accessed November 2018.

LSA Associates, Inc. (LSA). 2020. Traffic Impact Analysis for the Agua Mansa Industrial Project.

February.

South Coast Air Quality Management District (SCAQMD). 1993. CEQA Air Quality Handbook (currently under revision).
_____. 2003. Health Risk Assessment Guidance for Analyzing Cancer Risks from Mobile Source Diesel Idling Emissions for CEQA Air Quality Analysis.
_____. 2015. Supplemental Guidelines for Preparing Risk Assessments for the Air Toxics “Hot Spots” Information and Assessment Act (AB 2588). June 5. Website: www.aqmd.gov/docs/defaultsource/planning/risk-assessment/ab2588_guidelines.pdf, accessed November 2018. _____. SCAQMD Meteorological Data for AERMOD. Website: www.aqmd.gov/home/air-quality/airquality-data-studies/meteorological-data/data-for-aermod, accessed November 2018.

United States Environmental Protection Agency (EPA). 1991. Risk Assessment for Toxic Air Pollutants: A Citizen’s Guide, EPA No. 450/3-90-024. March. Website: www.epa.gov/ttn/ atw/3_90_024.html, accessed November 2018.
_____. 1999. Integrated Urban Air Toxics Strategy. July. Website: www.federalregister.gov/ documents/1999/07/19/99-17774/national-air-toxics-program-the-integrated-urbanstrategy, accessed November 2018. _____. AERMOD Modeling System. Website: www.epa.gov/scram/air-quality-dispersion-modelingpreferred-and-recommended-models, accessed November 2018.

Western Regional Climate Center. Website: www.wrcc.dri.edu, accessed November 2018.

LSA

HEALTH RISK ASSESSMENT
MARCH 2020

A GUA MANSA INDUSTRIAL P ROJECT

C ITY OF JURUPA V ALLEY , C ALIFORNIA
\\vcorp12\projects\CRN1801\HRA\Products\HRA-RTC-RLSO.docx «03/19/20»

APPENDIX A

EMISSION FACTORS FOR VEHICLES AND HEALTH RISK ASSESSMENT

EMISSION RATES
LSA
EMFAC2017 Model Output Used to Determine I-405 Vehicle Emissions Factors EMFAC2017 Emission Rates
Region Type: Air Basin
Region: South Coast
Calendar Year: 2025
Season: Annual
Vehicle Classification: EMFAC2011 Categories
Speed VMT ROG PM10 PM2.5
Region CalYr Season Veh_Class Fuel (miles/hr) (miles/day) (gms/mile) (gms/mile) (gms/mile) South Coast 2025 Annual Aggreg Light Veh GAS 5 609,734 0.0282453 0.003441528 0.003170399 South Coast 2025 Annual Aggreg Light Veh GAS 10 2,354,892 0.0702159 0.00848296 0.00781666 South Coast 2025 Annual Aggreg Light Veh GAS 15 6,138,317 0.1229777 0.014865289 0.013701105 South Coast 2025 Annual Aggreg Light Veh GAS 20 17,975,593 0.2554581 0.030939222 0.028522789 South Coast 2025 Annual Aggreg Light Veh GAS 25 37,943,884 0.40454 0.048874928 0.045067373 South Coast 2025 Annual Aggreg Light Veh GAS 30 42,386,143 0.35588 0.042945839 0.039608695 South Coast 2025 Annual Aggreg Light Veh GAS 35 24,294,293 0.1682376 0.020317148 0.018742252 South Coast 2025 Annual Aggreg Light Veh GAS 40 17,638,182 0.1061959 0.012774432 0.011786486 South Coast 2025 Annual Aggreg Light Veh GAS 45 14,559,106 0.080448 0.009657383 0.008911701 South Coast 2025 Annual Aggreg Light Veh GAS 50 13,420,136 0.0713631 0.008583337 0.007921483 South Coast 2025 Annual Aggreg Light Veh GAS 55 12,158,383 0.065127 0.00788884 0.007281377 South Coast 2025 Annual Aggreg Light Veh GAS 60 16,430,118 0.0930489 0.011475649 0.010593579 South Coast 2025 Annual Aggreg Light Veh GAS 65 7,870,401 0.049098 0.006129221 0.005661521 South Coast 2025 Annual Aggreg Light Veh GAS 70 3,176 2.115E-05 2.71478E-06 2.51756E-06 South Coast 2025 Annual Aggreg Light Veh DSL 5 11,228 0.0159524 0.001816548 0.001676366 South Coast 2025 Annual Aggreg Light Veh DSL 10 41,160 0.0415848 0.004715827 0.004353099 South Coast 2025 Annual Aggreg Light Veh DSL 15 105,827 0.0732741 0.008405098 0.00776133 South Coast 2025 Annual Aggreg Light Veh DSL 20 291,214 0.1588381 0.018528452 0.017111023 South Coast 2025 Annual Aggreg Light Veh DSL 25 589,945 0.2598252 0.030382967 0.028061769 South Coast 2025 Annual Aggreg Light Veh DSL 30 706,340 0.2162245 0.02538164 0.02346202 South Coast 2025 Annual Aggreg Light Veh DSL 35 470,404 0.0914935 0.010850687 0.010047225 South Coast 2025 Annual Aggreg Light Veh DSL 40 392,308 0.0534989 0.006383952 0.005924427 South Coast 2025 Annual Aggreg Light Veh DSL 45 337,107 0.0399876 0.004788173 0.004447886 South Coast 2025 Annual Aggreg Light Veh DSL 50 352,016 0.0338104 0.004155 0.003870194 South Coast 2025 Annual Aggreg Light Veh DSL 55 403,156 0.029006 0.00380194 0.003559836 South Coast 2025 Annual Aggreg Light Veh DSL 60 772,849 0.0422317 0.00648029 0.006117955 South Coast 2025 Annual Aggreg Light Veh DSL 65 559,769 0.0288086 0.004720715 0.004483835 South Coast 2025 Annual Aggreg Light Veh DSL 70 435 0.0108844 0.001768174 0.001690621 South Coast 2025 Annual T6 instate heavy DSL 5 1737.717415 0.0008786 4.48394E-05 4.28996E-05 South Coast 2025 Annual T6 instate heavy DSL 10 5618.263428 0.0022859 0.000129686 0.000124075 South Coast 2025 Annual T6 instate heavy DSL 15 15055.375 0.0042134 0.000292264 0.000279621 South Coast 2025 Annual T6 instate heavy DSL 20 41478.83604 0.0082155 0.000702124 0.00067175 South Coast 2025 Annual T6 instate heavy DSL 25 86368.19684 0.0125563 0.001322217 0.001265019 South Coast 2025 Annual T6 instate heavy DSL 30 110863.9038 0.0119551 0.001566145 0.001498394 South Coast 2025 Annual T6 instate heavy DSL 35 82998.737 0.0066467 0.001096945 0.001049492 South Coast 2025 Annual T6 instate heavy DSL 40 87592.10819 0.0052193 0.001097332 0.001049861 South Coast 2025 Annual T6 instate heavy DSL 45 87310.97611 0.0038836 0.001050297 0.001004862 South Coast 2025 Annual T6 instate heavy DSL 50 90153.34364 0.00301 0.001054838 0.001009206 South Coast 2025 Annual T6 instate heavy DSL 55 95700.46321 0.0024206 0.001103089 0.001055369 South Coast 2025 Annual T6 instate heavy DSL 60 128037.0397 0.0028333 0.001471674 0.00140801 South Coast 2025 Annual T6 instate heavy DSL 65 101270.2946 0.002241 0.001164013 0.001113659 South Coast 2025 Annual T6 instate heavy DSL 70 72.0864118 1.595E-06 8.2857E-07 7.92727E-07 South Coast 2025 Annual T6 instate small DSL 5 4432.107009 0.0045735 0.000354771 0.000339423 South Coast 2025 Annual T6 instate small DSL 10 14329.57079 0.0113523 0.001086015 0.001039035 South Coast 2025 Annual T6 instate small DSL 15 38399.24288 0.0172267 0.002629636 0.002515879 South Coast 2025 Annual T6 instate small DSL 20 105793.1735 0.0270124 0.006557341 0.006273674 South Coast 2025 Annual T6 instate small DSL 25 220285.0056 0.0427509 0.012821012 0.01226638 South Coast 2025 Annual T6 instate small DSL 30 282762.1344 0.0445048 0.016160013 0.015460938 South Coast 2025 Annual T6 instate small DSL 35 211691.0844 0.0272116 0.012325024 0.011791849 South Coast 2025 Annual T6 instate small DSL 40 223406.6329 0.0236648 0.013712961 0.013119744 South Coast 2025 Annual T6 instate small DSL 45 222689.596 0.0196782 0.014832792 0.014191132 South Coast 2025 Annual T6 instate small DSL 50 229939.1505 0.0172443 0.016989389 0.016254436 South Coast 2025 Annual T6 instate small DSL 55 244087.2665 0.0159082 0.020310059 0.019431455 South Coast 2025 Annual T6 instate small DSL 60 326562.798 0.020065 0.028944159 0.027692047 South Coast 2025 Annual T6 instate small DSL 65 258293.3098 0.0158703 0.022893246 0.021902894 South Coast 2025 Annual T6 instate small DSL 70 183.8588301 1.13E-05 1.62959E-05 1.5591E-05 South Coast 2025 Annual T6TS GAS 5 1489.485939 0.000857 1.0733E-05 9.8686E-06 South Coast 2025 Annual T6TS GAS 10 5208.249519 0.0019017 2.37113E-05 2.18016E-05 South Coast 2025 Annual T6TS GAS 15 13650.12523 0.00334 4.14218E-05 3.80858E-05 South Coast 2025 Annual T6TS GAS 20 35294.34488 0.0061053 7.53097E-05 6.92445E-05 These EFs are
derived by
factoring EFs for
LDA, LDT1,
LDT2, LHD1,
LHD2, MDV,
MH, Motorcoach,
and SBUS by
VMT for each to
get a weighted
aggregate set of
EFs.

These EFs are
derived by
factoring EFs for
LDA, LDT1,
LDT2, LHD1,
LHD2, MDV,
MH, Motorcoach,
and SBUS by
VMT for each to
get a weighted
aggregate set of
EFs.

Page 1 of 2 ends

EMFAC2017 Model Output Used to Determine I-405 Vehicle Emissions Factors South Coast 2025 Annual T6TS GAS 25 69211.70176 0.0089272 0.00010954 0.000100718 South Coast 2025 Annual T6TS GAS 30 82333.11034 0.0083441 0.000101947 9.37362E-05 South Coast 2025 Annual T6TS GAS 35 60150.22701 0.0050494 6.14572E-05 5.65076E-05 South Coast 2025 Annual T6TS GAS 40 62342.38084 0.004583 5.54312E-05 5.09669E-05 South Coast 2025 Annual T6TS GAS 45 60070.42004 0.0040718 4.90157E-05 4.50682E-05 South Coast 2025 Annual T6TS GAS 50 60151.79737 0.0039557 4.74975E-05 4.36722E-05 South Coast 2025 Annual T6TS GAS 55 60122.29822 0.004035 4.84421E-05 4.45407E-05 South Coast 2025 Annual T6TS GAS 60 65375.06349 0.0046923 5.66716E-05 5.21074E-05 South Coast 2025 Annual T6TS GAS 65 52861.89038 0.0043077 5.19814E-05 4.7795E-05 South Coast 2025 Annual T6TS GAS 70 44.84573404 3.97E-06 4.79092E-08 4.40508E-08 South Coast 2025 Annual T7 Public DSL 5 168.1561358 0.0001507 2.99088E-05 2.8615E-05 South Coast 2025 Annual T7 Public DSL 10 555.5933951 0.0003916 8.42319E-05 8.05881E-05 South Coast 2025 Annual T7 Public DSL 15 1499.417292 0.0006278 0.000163507 0.000156434 South Coast 2025 Annual T7 Public DSL 20 4225.223358 0.0009996 0.00033407 0.000319619 South Coast 2025 Annual T7 Public DSL 25 8890.206371 0.0015228 0.00059103 0.000565463 South Coast 2025 Annual T7 Public DSL 30 12047.08902 0.0016321 0.000709582 0.000678886 South Coast 2025 Annual T7 Public DSL 35 9335.875447 0.0010105 0.000496484 0.000475006 South Coast 2025 Annual T7 Public DSL 40 8993.022623 0.0007927 0.000443456 0.000424272 South Coast 2025 Annual T7 Public DSL 45 8594.868525 0.000637 0.000406545 0.000388958 South Coast 2025 Annual T7 Public DSL 50 9255.951429 0.0006047 0.000436614 0.000417726 South Coast 2025 Annual T7 Public DSL 55 11025.72615 0.000674 0.00053977 0.00051642 South Coast 2025 Annual T7 Public DSL 60 19325.8825 0.0011741 0.000975936 0.000933718 South Coast 2025 Annual T7 Public DSL 65 15317.28834 0.0009306 0.000773507 0.000740045 South Coast 2025 Annual T7 Public DSL 70 11.16065494 6.78E-07 5.63601E-07 5.3922E-07 South Coast 2025 Annual T7IS GAS 5 161.1567311 0.0004807 9.43486E-07 8.67894E-07 South Coast 2025 Annual T7IS GAS 10 563.5128504 0.00106 2.08427E-06 1.91736E-06 South Coast 2025 Annual T7IS GAS 15 1476.891794 0.0018501 3.64093E-06 3.34953E-06 South Coast 2025 Annual T7IS GAS 20 3818.714294 0.0033609 6.61939E-06 6.0899E-06 South Coast 2025 Annual T7IS GAS 25 7488.443709 0.0048848 9.62773E-06 8.85799E-06 South Coast 2025 Annual T7IS GAS 30 8908.130366 0.00454 8.96006E-06 8.24405E-06 South Coast 2025 Annual T7IS GAS 35 6508.026498 0.002733 5.40128E-06 4.96986E-06 South Coast 2025 Annual T7IS GAS 40 6745.209231 0.0024681 4.87154E-06 4.48259E-06 South Coast 2025 Annual T7IS GAS 45 6499.391687 0.0021833 4.30761E-06 3.96382E-06 South Coast 2025 Annual T7IS GAS 50 6508.196405 0.0021135 4.1741E-06 3.84106E-06 South Coast 2025 Annual T7IS GAS 55 6505.004709 0.0021503 4.25704E-06 3.91747E-06 South Coast 2025 Annual T7IS GAS 60 7073.333995 0.0024976 4.98018E-06 4.583E-06 South Coast 2025 Annual T7IS GAS 65 5719.456109 0.0022901 4.56798E-06 4.20371E-06 South Coast 2025 Annual T7IS GAS 70 4.852138387 2.11E-06 4.21012E-09 3.8744E-09 Idling Emissions Factors PM10 PM2.5
Region CalYr Season Veh_Class Fuel (gms/hr) (gms/hr)
South Coast 2025 Annual T6 Instate Small DSL 5.61E-05 5.37E-05 South Coast 2025 Annual T7 DSL 1.47E-04 1.41E-04
These Efs are the IDLEX daily regional
tons/day rates divided by the truck population
and 24 hrs/day.

Page 2 of 2 ends

L S A A S S O C I A T E S , I N C .

Agua Mansa Industrial
Building A
Manufacturing 140.2 TSF
Trips/Unit (Cars) 3.089
Trips/Unit (2‐Axle Trucks) 0.314
Trips/Unit (3‐Axle Trucks) 0.153
Trips/Unit (4+ Axle Trucks) 0.374
Trips/Unit (Total) 3.930
Trip Generation (Cars) 433
Trip Generation (2‐Axle Trucks) 44
Trip Generation (3‐Axle Trucks) 21
Trip Generation (4+ Axle Trucks) 52
Trip Generation (Total) 551
Building B
Manufacturing 194.8 TSF
Trips/Unit (Cars) 3.089
Trips/Unit (2‐Axle Trucks) 0.314
Trips/Unit (3‐Axle Trucks) 0.153
Trips/Unit (4+ Axle Trucks) 0.374
Trips/Unit (Total) 3.930
Trip Generation (Cars) 602
Trip Generation (2‐Axle Trucks) 61
Trip Generation (3‐Axle Trucks) 30
Trip Generation (4+ Axle Trucks) 73
Trip Generation (Total) 766
Summary
Trip Generation (Cars) 1,035
Trip Generation (2-Axle Trucks) 105
Trip Generation (3-Axle Trucks) 51
Trip Generation (4+ Axle Trucks) 125
Trip Generation (Total) 1,317
Note: From Traffic Study (November 2018)
TSF = Thousand Square-Feet
Project Trip Generation
Land Uses Units Daily
The trip generation was developed using rates from the Institute of Transportation Engineers (ITE) Trip Generation Manual (10th Edition) for Land Use 140 – “Manufacturing.” The resulting trips were converted to trucks and passenger vehicles based on the vehicle mix from the City of Fontana's Truck Trip Generation Study (August 2003). As such, 78.6% of project traffic will be passenger vehicles and 21.4% of project traffic will be trucks. All truck trips were converted to passenger car equivalents (PCEs) using a 1.5 PCE factor for 2-axle trucks, 2.0 for 3-axle trucks, and 3.0 for 4- and more axle trucks.

P:\CRN1801\HRA\Background\HRA Coords & EmRates.xlsx\TripGen (11/20/2018) LSA Associates, Inc. Vehicle Exhaust Worksheet CRN1801
Agua Mansa Industrial
LDV2 2-Axle3 3-Axle4 4+-Axle5
434 45 22 53
lb/yr lb/hr
Average 2.6% 73% 73% 99% diesel part. -- 3.07E-04 3.50E-08 Speed PM2.5 -- 2.87E-04 3.28E-08
5 mph PM10 0.0018 3.55E-04 4.48E-05 2.99E-05 1,3-butadiene 0.0055 5.89E-04 6.72E-08 PM2.5 0.0017 3.39E-04 4.29E-05 2.86E-05 benzene 0.02636 2.82E-03 3.22E-07 ethylbenzene 0.01072 1.15E-03 1.31E-07
97% 27% 27% 0.9% MEK 0.00019 2.03E-05 2.32E-09
Number naphthalene 0.00048 5.14E-05 5.86E-09
ROG 0.028 8.57E-04 8.57E-04 4.81E-04 of propylene 0.03127998 3.35E-03 3.82E-07 Sources g/s lb/hr lb/yr styrene 0.00126 1.35E-04 1.54E-08 PM10 5.73E-08 3.32E-08 2.05E-09 4.45E-09 22 4.4E-09 3.5E-08 0.0003 toluene 0.05879998 6.29E-03 7.18E-07 PM2.5 5.29E-08 3.18E-08 1.96E-09 4.25E-09 22 4.1E-09 3.3E-08 0.0003 m & p-xylene 0.03639998 3.90E-03 4.44E-07 ROG 3.38E-05 2.89E-08 1.41E-08 6.50E-10 22 1.5E-06 1.2E-05 0.1070 1 AADT from project traffic study2 LDV assumed to LDA (Passenger Cars) 3 2 axle trucks are assumed to be MDV (Medium-Duty Truck GVW=5,574-8,500 lbs.)4 3 axle trucks are assumed to be MHDT (Medium-Heavy Duty Truck GVW=14,001-33,000 lbs.)5 4+ axle trucks are assumed to be HHDT (Heavy-Heavy Duty Truck GVW=33,001-60,000 lbs.) 6 Source: EMFAC2017 fleet populations.7 Source: EMFAC2017 emission factors for 2025 (model year aggregate).

Onsite travel - AADT by Truck Category1
along
394 meters
Diesel Exhaust PM10 & PM2.5 Emissions at 5 mph (g/mi)7
Total distance
covered by
Onsite travel -
driveway
sources
% of Vehicles That Are Gasoline-Powered6
Gasoline Exhaust ROG Emissions at 5 mph (g/mi)7
Speciated Emissions Rates
Bldg A
% of Vehicles That Are Diesel-Powered6
Emission Rates per source
PM10, PM2.5 & ROG Exhaust Emissions (g/s)
LSA Associates, Inc. Vehicle Exhaust Worksheet CRN1801
Agua Mansa Industrial
LDV2 2-Axle3 3-Axle4 4+-Axle5
602 62 30 73
lb/yr lb/hr
Average 2.6% 73% 73% 99% diesel part. -- 3.80E-04 4.33E-08 Speed PM2.5 -- 3.56E-04 4.06E-08
5 mph PM10 0.0018 3.55E-04 4.48E-05 2.99E-05 1,3-butadiene 0.0055 7.31E-04 8.34E-08 PM2.5 0.0017 3.39E-04 4.29E-05 2.86E-05 benzene 0.02636 3.50E-03 4.00E-07 ethylbenzene 0.01072 1.42E-03 1.63E-07
97% 27% 27% 0.9% MEK 0.00019 2.53E-05 2.88E-09
Number naphthalene 0.00048 6.38E-05 7.28E-09
ROG 0.028 8.57E-04 8.57E-04 4.81E-04 of propylene 0.03127998 4.16E-03 4.74E-07 Sources g/s lb/hr lb/yr styrene 0.00126 1.67E-04 1.91E-08 PM10 2.91E-08 1.68E-08 1.02E-09 2.24E-09 9 5.5E-09 4.3E-08 0.0004 toluene 0.05879998 7.82E-03 8.92E-07 PM2.5 2.69E-08 1.60E-08 9.80E-10 2.15E-09 9 5.1E-09 4.1E-08 0.0004 m & p-xylene 0.03639998 4.84E-03 5.52E-07 ROG 1.72E-05 1.46E-08 7.07E-09 3.28E-10 9 1.9E-06 1.5E-05 0.1329 1 AADT from project traffic study2 LDV assumed to LDA (Passenger Cars) 3 2 axle trucks are assumed to be MDV (Medium-Duty Truck GVW=5,574-8,500 lbs.)4 3 axle trucks are assumed to be MHDT (Medium-Heavy Duty Truck GVW=14,001-33,000 lbs.)5 4+ axle trucks are assumed to be HHDT (Heavy-Heavy Duty Truck GVW=33,001-60,000 lbs.)6 Source: EMFAC2017 fleet populations.7 Source: EMFAC2017 emission factors for 2025 (model year aggregate).

Onsite travel - AADT by Truck Category1
along
144 meters
Diesel Exhaust PM10 & PM2.5 Emissions at 5 mph (g/mi)7
Total distance
covered by
Onsite travel -
driveway
sources
% of Vehicles That Are Gasoline-Powered6
Gasoline Exhaust ROG Emissions at 5 mph (g/mi)7
Speciated Emissions Rates
Bldg B
% of Vehicles That Are Diesel-Powered6
Emission Rates per source
PM10, PM2.5 & ROG Exhaust Emissions (g/s)
LSA Associates, Inc. Vehicle Exhaust Worksheet CRN1801
Agua Manza Industrial
Percent of truck traffic on this road
LDV2 2-Axle3 3-Axle4 4+-Axle5 50%
217 23 11 27
lb/yr lb/hr
Average 2.6% 73% 73% 99% diesel part. -- 2.21E-03 2.52E-07 Speed PM2.5 -- 2.10E-03 2.39E-07
35 mph PM10 0.0109 1.23E-02 1.10E-03 4.96E-04 1,3-butadiene 0.0055 1.49E-03 1.70E-07 PM2.5 0.0100 1.18E-02 1.05E-03 4.75E-04 benzene 0.02636 7.12E-03 8.13E-07 ethylbenzene 0.01072 2.90E-03 3.30E-07
97% 27% 27% 0.9% MEK 0.00019 5.13E-05 5.86E-09
Number naphthalene 0.00048 1.30E-04 1.48E-08
ROG 0.168 5.05E-03 5.05E-03 2.73E-03 of propylene 0.03127998 8.45E-03 9.64E-07 Sources g/s lb/hr lb/yr styrene 0.00126 3.41E-04 3.88E-08 PM10 3.30E-08 1.14E-07 4.84E-09 7.24E-09 5 3.2E-08 2.5E-07 0.0022 toluene 0.05879998 1.59E-02 1.81E-06 PM2.5 3.05E-08 1.09E-07 4.63E-09 6.93E-09 5 3.0E-08 2.4E-07 0.0021 m & p-xylene 0.03639998 9.84E-03 1.12E-06 ROG 1.94E-05 1.68E-08 8.03E-09 3.63E-10 5 3.9E-06 3.1E-05 0.2702 1 AADT from project traffic study2 LDV assumed to LDA (Passenger Cars) 3 2 axle trucks are assumed to be MDV (Medium-Duty Truck GVW=5,574-8,500 lbs.)4 3 axle trucks are assumed to be MHDT (Medium-Heavy Duty Truck GVW=14,001-33,000 lbs.)5 4+ axle trucks are assumed to be HHDT (Heavy-Heavy Duty Truck GVW=33,001-60,000 lbs.)6 Source: EMFAC2017 fleet populations.7 Source: EMFAC2017 emission factors for 2025 (model year aggregate).

Hall Ave. from AADT by Truck Category1
Project Driveway 1
76 meters
Diesel Exhaust PM10 & PM2.5 Emissions at 35 mph (g/mi)7 % of Vehicles That Are Gasoline-Powered6
Total distance
covered by
Hall Ave. from
sources
Gasoline Exhaust ROG Emissions at 35 mph (g/mi)7
Speciated Emissions Rates
east to Proj. Drwy. 2
% of Vehicles That Are Diesel-Powered6
Emission Rates per source
PM10, PM2.5 & ROG Exhaust Emissions (g/s)
LSA Associates, Inc. Vehicle Exhaust Worksheet CRN1801
Agua Manza Industrial
Percent of truck traffic on this road
LDV2 2-Axle3 3-Axle4 4+-Axle5 15%
156 16 8 19
lb/yr lb/hr
Average 2.6% 73% 73% 99% diesel part. -- 1.77E-03 2.02E-07 Speed PM2.5 -- 1.68E-03 1.92E-07
35 mph PM10 0.0109 1.23E-02 1.10E-03 4.96E-04 1,3-butadiene 0.0055 1.22E-03 1.39E-07 PM2.5 0.0100 1.18E-02 1.05E-03 4.75E-04 benzene 0.02636 5.84E-03 6.66E-07 ethylbenzene 0.01072 2.38E-03 2.71E-07
97% 27% 27% 0.9% MEK 0.00019 4.21E-05 4.80E-09
Number naphthalene 0.00048 1.06E-04 1.21E-08
ROG 0.168 5.05E-03 5.05E-03 2.73E-03 of propylene 0.03127998 6.93E-03 7.91E-07 Sources g/s lb/hr lb/yr styrene 0.00126 2.79E-04 3.19E-08 PM10 7.57E-08 2.52E-07 1.12E-08 1.63E-08 14 2.5E-08 2.0E-07 0.0018 toluene 0.05879998 1.30E-02 1.49E-06 PM2.5 7.01E-08 2.41E-07 1.07E-08 1.56E-08 14 2.4E-08 1.9E-07 0.0017 m & p-xylene 0.03639998 8.07E-03 9.20E-07 ROG 4.45E-05 3.73E-08 1.87E-08 8.15E-10 14 3.2E-06 2.5E-05 0.2216 1 AADT from project traffic study2 LDV assumed to LDA (Passenger Cars) 3 2 axle trucks are assumed to be MDV (Medium-Duty Truck GVW=5,574-8,500 lbs.)4 3 axle trucks are assumed to be MHDT (Medium-Heavy Duty Truck GVW=14,001-33,000 lbs.)5 4+ axle trucks are assumed to be HHDT (Heavy-Heavy Duty Truck GVW=33,001-60,000 lbs.)6 Source: EMFAC2017 fleet populations.7 Source: EMFAC2017 emission factors for 2025 (model year aggregate).

Hall Ave. from AADT by Truck Category1
Project Driveway 2
242 meters
Diesel Exhaust PM10 & PM2.5 Emissions at 35 mph (g/mi)7 % of Vehicles That Are Gasoline-Powered6
Total distance
covered by
Hall Ave. from
sources
Gasoline Exhaust ROG Emissions at 35 mph (g/mi)7
Speciated Emissions Rates
east to Agua Manza Rd.
% of Vehicles That Are Diesel-Powered6
Emission Rates per source
PM10, PM2.5 & ROG Exhaust Emissions (g/s)
LSA Associates, Inc. Vehicle Exhaust Worksheet CRN1801
Agua Manza Industrial
Percent of truck traffic on this road
LDV2 2-Axle3 3-Axle4 4+-Axle5 85%
880 90 44 107
lb/yr lb/hr
Average 2.6% 73% 73% 99% diesel part. -- 7.08E-03 8.08E-07 Speed PM2.5 -- 6.73E-03 7.68E-07
35 mph PM10 0.0109 1.23E-02 1.10E-03 4.96E-04 1,3-butadiene 0.0055 4.90E-03 5.59E-07 PM2.5 0.0100 1.18E-02 1.05E-03 4.75E-04 benzene 0.02636 2.35E-02 2.68E-06 ethylbenzene 0.01072 9.55E-03 1.09E-06
97% 27% 27% 0.9% MEK 0.00019 1.69E-04 1.93E-08
Number naphthalene 0.00048 4.28E-04 4.88E-08
ROG 0.168 5.05E-03 5.05E-03 2.73E-03 of propylene 0.03127998 2.79E-02 3.18E-06 Sources g/s lb/hr lb/yr styrene 0.00126 1.12E-03 1.28E-07 PM10 8.48E-07 2.82E-06 1.23E-07 1.82E-07 39 1.0E-07 8.1E-07 0.0071 toluene 0.05879998 5.24E-02 5.98E-06 PM2.5 7.85E-07 2.70E-06 1.17E-07 1.74E-07 39 9.7E-08 7.7E-07 0.0067 m & p-xylene 0.03639998 3.24E-02 3.70E-06 ROG 4.99E-04 4.17E-07 2.04E-07 9.12E-09 39 1.3E-05 1.0E-04 0.8910 1 AADT from project traffic study2 LDV assumed to LDA (Passenger Cars) 3 2 axle trucks are assumed to be MDV (Medium-Duty Truck GVW=5,574-8,500 lbs.)4 3 axle trucks are assumed to be MHDT (Medium-Heavy Duty Truck GVW=14,001-33,000 lbs.)5 4+ axle trucks are assumed to be HHDT (Heavy-Heavy Duty Truck GVW=33,001-60,000 lbs.)6 Source: EMFAC2017 fleet populations.7 Source: EMFAC2017 emission factors for 2025 (model year aggregate).

Brown Ave. from AADT by Truck Category1
Hall Ave. to
481 meters
Diesel Exhaust PM10 & PM2.5 Emissions at 35 mph (g/mi)7 % of Vehicles That Are Gasoline-Powered6
Total distance
covered by
Brown Ave.
from sources
Gasoline Exhaust ROG Emissions at 35 mph (g/mi)7
Speciated Emissions Rates
Agua Mansa Rd.
% of Vehicles That Are Diesel-Powered6
Emission Rates per source
PM10, PM2.5 & ROG Exhaust Emissions (g/s)
LSA Associates, Inc. Vehicle Exhaust Worksheet CRN1801
Agua Manza Industrial
Percent of truck traffic on this road
LDV2 2-Axle3 3-Axle4 4+-Axle5 70%
725 74 36 88
lb/yr lb/hr
Average 2.6% 73% 73% 99% diesel part. -- 9.06E-03 1.03E-06 Speed PM2.5 -- 8.61E-03 9.82E-07
35 mph PM10 0.0109 1.23E-02 1.10E-03 4.96E-04 1,3-butadiene 0.0055 6.28E-03 7.16E-07 PM2.5 0.0100 1.18E-02 1.05E-03 4.75E-04 benzene 0.02636 3.01E-02 3.43E-06 ethylbenzene 0.01072 1.22E-02 1.40E-06
97% 27% 27% 0.9% MEK 0.00019 2.17E-04 2.47E-08
Number naphthalene 0.00048 5.48E-04 6.25E-08
ROG 0.168 5.05E-03 5.05E-03 2.73E-03 of propylene 0.03127998 3.57E-02 4.07E-06 Sources g/s lb/hr lb/yr styrene 0.00126 1.44E-03 1.64E-07 PM10 4.68E-06 1.55E-05 6.72E-07 1.00E-06 168 1.3E-07 1.0E-06 0.0091 toluene 0.05879998 6.71E-02 7.66E-06 PM2.5 4.33E-06 1.49E-05 6.43E-07 9.60E-07 168 1.2E-07 9.8E-07 0.0086 m & p-xylene 0.03639998 4.15E-02 4.74E-06 ROG 2.75E-03 2.29E-06 1.12E-06 5.02E-08 168 1.6E-05 1.3E-04 1.1414 1 AADT from project traffic study2 LDV assumed to LDA (Passenger Cars) 3 2 axle trucks are assumed to be MDV (Medium-Duty Truck GVW=5,574-8,500 lbs.)4 3 axle trucks are assumed to be MHDT (Medium-Heavy Duty Truck GVW=14,001-33,000 lbs.)5 4+ axle trucks are assumed to be HHDT (Heavy-Heavy Duty Truck GVW=33,001-60,000 lbs.)6 Source: EMFAC2017 fleet populations.7 Source: EMFAC2017 emission factors for 2025 (model year aggregate).

Agua Manza Rd. AADT by Truck Category1
from Brown Ave.
3,221 meters
Diesel Exhaust PM10 & PM2.5 Emissions at 35 mph (g/mi)7 % of Vehicles That Are Gasoline-Powered6
Total distance
covered by
Agua Manza
Rd. sources
Gasoline Exhaust ROG Emissions at 35 mph (g/mi)7
Speciated Emissions Rates
south to SR-60
% of Vehicles That Are Diesel-Powered6
Emission Rates per source
PM10, PM2.5 & ROG Exhaust Emissions (g/s)
LSA Associates, Inc. Vehicle Exhaust Worksheet CRN1801
Agua Manza Industrial
Percent of truck traffic on this road
LDV2 2-Axle3 3-Axle4 4+-Axle5 30%
311 32 16 38
lb/yr lb/hr
Average 2.6% 73% 73% 99% diesel part. -- 3.88E-03 4.43E-07 Speed PM2.5 -- 3.69E-03 4.21E-07
35 mph PM10 0.0109 1.23E-02 1.10E-03 4.96E-04 1,3-butadiene 0.0055 2.67E-03 3.05E-07 PM2.5 0.0100 1.18E-02 1.05E-03 4.75E-04 benzene 0.02636 1.28E-02 1.46E-06 ethylbenzene 0.01072 5.20E-03 5.94E-07
97% 27% 27% 0.9% MEK 0.00019 9.22E-05 1.05E-08
Number naphthalene 0.00048 2.33E-04 2.66E-08
ROG 0.168 5.05E-03 5.05E-03 2.73E-03 of propylene 0.03127998 1.52E-02 1.73E-06 Sources g/s lb/hr lb/yr styrene 0.00126 6.12E-04 6.98E-08 PM10 9.95E-07 3.33E-06 1.48E-07 2.15E-07 84 5.6E-08 4.4E-07 0.0039 toluene 0.05879998 2.85E-02 3.26E-06 PM2.5 9.21E-07 3.18E-06 1.42E-07 2.05E-07 84 5.3E-08 4.2E-07 0.0037 m & p-xylene 0.03639998 1.77E-02 2.02E-06 ROG 5.85E-04 4.92E-07 2.46E-07 1.08E-08 84 7.0E-06 5.5E-05 0.4855 1 AADT from project traffic study2 LDV assumed to LDA (Passenger Cars) 3 2 axle trucks are assumed to be MDV (Medium-Duty Truck GVW=5,574-8,500 lbs.)4 3 axle trucks are assumed to be MHDT (Medium-Heavy Duty Truck GVW=14,001-33,000 lbs.)5 4+ axle trucks are assumed to be HHDT (Heavy-Heavy Duty Truck GVW=33,001-60,000 lbs.)6 Source: EMFAC2017 fleet populations.7 Source: EMFAC2017 emission factors for 2025 (model year aggregate). 1,597 meters
Agua Manza Rd. AADT by Truck Category1
from Brown Ave. Speciated Emissions Rates
% of Vehicles That Are Diesel-Powered6
Diesel Exhaust PM10 & PM2.5 Emissions at 35 mph (g/mi)7 % of Vehicles That Are Gasoline-Powered6
Total distance
covered by
Agua Manza
Rd. sources
Gasoline Exhaust ROG Emissions at 35 mph (g/mi)7
Emission Rates per source
PM10, PM2.5 & ROG Exhaust Emissions (g/s)
north to Riverside Ave.

LSA Associates, Inc. Vehicle Exhaust Worksheet CRN1801
Agua Manza Industrial
Percent of truck traffic on this road
LDV2 2-Axle3 3-Axle4 4+-Axle5 30%
to I-10 311 32 16 38
lb/yr lb/hr
Average 2.6% 73% 73% 99% diesel part. -- 3.92E-03 4.47E-07 Speed PM2.5 -- 3.72E-03 4.24E-07
35 mph PM10 0.0109 1.23E-02 1.10E-03 4.96E-04 1,3-butadiene 0.0055 2.69E-03 3.07E-07 PM2.5 0.0100 1.18E-02 1.05E-03 4.75E-04 benzene 0.02636 1.29E-02 1.47E-06 ethylbenzene 0.01072 5.25E-03 5.99E-07
97% 27% 27% 0.9% MEK 0.00019 9.31E-05 1.06E-08
Number naphthalene 0.00048 2.35E-04 2.68E-08
ROG 0.168 5.05E-03 5.05E-03 2.73E-03 of propylene 0.03127998 1.53E-02 1.75E-06 Sources g/s lb/hr lb/yr styrene 0.00126 6.17E-04 7.04E-08 PM10 2.09E-06 7.00E-06 3.11E-07 4.51E-07 175 5.6E-08 4.5E-07 0.0039 toluene 0.05879998 2.88E-02 3.29E-06 PM2.5 1.94E-06 6.69E-06 2.98E-07 4.32E-07 175 5.3E-08 4.2E-07 0.0037 m & p-xylene 0.03639998 1.78E-02 2.03E-06 ROG 1.23E-03 1.03E-06 5.17E-07 2.26E-08 175 7.0E-06 5.6E-05 0.4898 1 AADT from project traffic study2 LDV assumed to LDA (Passenger Cars) 3 2 axle trucks are assumed to be MDV (Medium-Duty Truck GVW=5,574-8,500 lbs.)4 3 axle trucks are assumed to be MHDT (Medium-Heavy Duty Truck GVW=14,001-33,000 lbs.)5 4+ axle trucks are assumed to be HHDT (Heavy-Heavy Duty Truck GVW=33,001-60,000 lbs.)6 Source: EMFAC2017 fleet populations.7 Source: EMFAC2017 emission factors for 2025 (model year aggregate). 3,356 meters
Riverside Ave. AADT by Truck Category1
from Agua Manza Rd. Speciated Emissions Rates
% of Vehicles That Are Diesel-Powered6
Diesel Exhaust PM10 & PM2.5 Emissions at 35 mph (g/mi)7 % of Vehicles That Are Gasoline-Powered6
Total distance
covered by
Riverside Ave.
sources
Gasoline Exhaust ROG Emissions at 35 mph (g/mi)7
Emission Rates per source
PM10, PM2.5 & ROG Exhaust Emissions (g/s)
LSA Associates, Inc. Idling Truck Exhaust Worksheet CRN1801 Agua Mansa Industrial
Facility
Hour
per day
Deliveries
per day1
Trips
per
Hour
Diesel Idle
Exhaust PM10
(gm/vh-hr)2
Diesel Idle
Exhaust PM2.5
(gm/vh-hr)2
Idle Time
(min/trip)3
Idle Exhaust
Diesel PM10
(gm/hr)
Idle Exhaust
Diesel PM2.5
(gm/hr)
Number of
Sources
Diesel
PM10 lb/hr
Diesel
PM10
lb/yr
Diesel
PM2.5
lb/hr
Diesel
PM2.5 lb/yr
Loading docks 24 282 11.7 0.00010 0.00010 15 0.0003 0.0003 11 5.8E-08 0.0005 5.6E-08 0.0005 1 AADT from project traffic study. Note that each truck visit comprises two trips, one to arrive and one to leave. 2 Source: EMFAC2017 idling emission factors for 2025 MHDT & HHDT diesel trucks.3 It is assumed that each truck idles for 15 minute per trip to account for multiple stops, i.e. at an entry check-in, loading/unloading and miscellaneous tasks.

HEALTH RISK ASSESSMENT
MARCH 2020

A GUA MANSA INDUSTRIAL P ROJECT

C ITY OF JURUPA V ALLEY , C ALIFORNIA
\\vcorp12\projects\CRN1801\HRA\Products\HRA-RTC-RLSO.docx «03/19/20»

APPENDIX B

AERMOD OUTPUT AND HARP RESULTS
LSA
*** AERMOD - VERSION 19191 *** *** Agua Mansa Industrial HRA *** 03/12/20 *** AERMET - VERSION 16216 *** *** *** 12:15:11 PAGE 1 *** MODELOPTs: RegDFAULT CONC ELEV URBAN ADJ_U* *** MODEL SETUP OPTIONS SUMMARY *** - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - **Model Is Setup For Calculation of Average CONCentration Values. -- DEPOSITION LOGIC -- **NO GAS DEPOSITION Data Provided. **NO PARTICLE DEPOSITION Data Provided. **Model Uses NO DRY DEPLETION. DRYDPLT = F **Model Uses NO WET DEPLETION. WETDPLT = F **Model Uses URBAN Dispersion Algorithm for the SBL for 527 Source(s), for Total of 1 Urban Area(s): Urban Population = 101315.0 ; Urban Roughness Length = 1.000 m **Model Uses Regulatory DEFAULT Options: 1. Stack-tip Downwash. 2. Model Accounts for ELEVated Terrain Effects. 3. Use Calms Processing Routine. 4. Use Missing Data Processing Routine. 5. No Exponential Decay. 6. Urban Roughness Length of 1.0 Meter Assumed. **Other Options Specified: ADJ_U* - Use ADJ_U* option for SBL in AERMET CCVR_Sub - Meteorological data includes CCVR substitutions TEMP_Sub - Meteorological data includes TEMP substitutions **Model Assumes No FLAGPOLE Receptor Heights. **The User Specified a Pollutant Type of: TOXICS **Model Calculates 1 Short Term Average(s) of: 1-HR and Calculates PERIOD Averages **This Run Includes: 527 Source(s); 527 Source Group(s); and 876 Receptor(s) with: 11 POINT(s), including 0 POINTCAP(s) and 0 POINTHOR(s) and: 516 VOLUME source(s) and: 0 AREA type source(s) and: 0 LINE source(s) and: 0 RLINE/RLINEXT source(s) and: 0 OPENPIT source(s) and: 0 BUOYANT LINE source(s) with 0 line(s) **Model Set To Continue RUNning After the Setup Testing. **The AERMET Input Meteorological Data Version Date: 16216 **Output Options Selected: Model Outputs Tables of PERIOD Averages by Receptor Model Outputs Tables of Highest Short Term Values by Receptor (RECTABLE Keyword) Model Outputs External File(s) of High Values for Plotting (PLOTFILE Keyword) Model Outputs Separate Summary File of High Ranked Values (SUMMFILE Keyword) **NOTE: The Following Flags May Appear Following CONC Values: c for Calm Hours m for Missing Hours b for Both Calm and Missing Hours **Misc. Inputs: Base Elev. for Pot. Temp. Profile (m MSL) = 397.00 ; Decay Coef. = 0.000 ; Rot. Angle = 0.0 Emission Units = GRAMS/SEC ; Emission Rate Unit Factor = 0.10000E+07 Output Units = MICROGRAMS/M**3 **Approximate Storage Requirements of Model = 26.0 MB of RAM. **Input Runstream File: aermod.inp **Output Print File: aermod.out **File for Summary of Results: P:\CFN1601\BACKGROUND\HRA\AERMOD\CFN1601.SUM *** AERMOD - VERSION 19191 *** *** Agua Mansa Industrial HRA *** 03/12/20 *** AERMET - VERSION 16216 *** *** *** 12:15:11 PAGE 2 *** MODELOPTs: RegDFAULT CONC ELEV URBAN ADJ_U* *** POINT SOURCE DATA *** NUMBER EMISSION RATE BASE STACK STACK STACK STACK BLDG URBAN CAP/ EMIS RATE SOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT TEMP. EXIT VEL. DIAMETER EXISTS SOURCE HOR SCALAR ID CATS. (METERS) (METERS) (METERS) (METERS) (DEG.K) (M/SEC) (METERS) VARY BY - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - IDLE01 0 0.10000E+01 465113.5 3765732.1 286.1 3.80 366.00 50.00 0.10 YES YES NO IDLE02 0 0.10000E+01 465107.2 3765717.2 285.9 3.80 366.00 50.00 0.10 YES YES NO IDLE03 0 0.10000E+01 465097.4 3765701.4 285.8 3.80 366.00 50.00 0.10 YES YES NO IDLE04 0 0.10000E+01 465089.0 3765688.9 285.7 3.80 366.00 50.00 0.10 YES YES NO IDLE05 0 0.10000E+01 465079.3 3765673.7 285.7 3.80 366.00 50.00 0.10 YES YES NO IDLE06 0 0.10000E+01 465202.4 3765563.8 284.6 3.80 366.00 50.00 0.10 YES YES NO IDLE07 0 0.10000E+01 465216.2 3765554.5 284.2 3.80 366.00 50.00 0.10 YES YES NO IDLE08 0 0.10000E+01 465229.6 3765546.7 284.0 3.80 366.00 50.00 0.10 YES YES NO IDLE09 0 0.10000E+01 465247.4 3765538.3 283.7 3.80 366.00 50.00 0.10 YES YES NO IDLE10 0 0.10000E+01 465263.9 3765530.0 283.4 3.80 366.00 50.00 0.10 YES YES NO IDLE11 0 0.10000E+01 465281.4 3765521.3 287.1 3.80 366.00 50.00 0.10 YES YES NO *** AERMOD - VERSION 19191 *** *** Agua Mansa Industrial HRA *** 03/12/20 *** AERMET - VERSION 16216 *** *** *** 12:15:11 PAGE 3 *** MODELOPTs: RegDFAULT CONC ELEV URBAN ADJ_U* *** VOLUME SOURCE DATA *** NUMBER EMISSION RATE BASE RELEASE INIT. INIT. URBAN EMISSION RATE SOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT SY SZ SOURCE SCALAR VARY ID CATS. (METERS) (METERS) (METERS) (METERS) (METERS) (METERS) BY - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - HALLA1 0 0.10000E+01 465036.4 3765617.3 285.0 3.11 8.82 2.89 YES HALLA2 0 0.10000E+01 465051.7 3765606.1 284.9 3.11 8.82 2.89 YES HALLA3 0 0.10000E+01 465067.0 3765595.0 284.7 3.11 8.82 2.89 YES HALLA4 0 0.10000E+01 465082.4 3765583.9 284.6 3.11 8.82 2.89 YES HALLA5 0 0.10000E+01 465097.7 3765572.7 284.4 3.11 8.82 2.89 YES HALLB01 0 0.10000E+01 465111.5 3765561.4 284.3 3.11 8.66 2.89 YES HALLB02 0 0.10000E+01 465127.2 3765551.4 284.1 3.11 8.66 2.89 YES HALLB03 0 0.10000E+01 465142.8 3765541.3 284.1 3.11 8.66 2.89 YES HALLB04 0 0.10000E+01 465158.5 3765531.2 283.9 3.11 8.66 2.89 YES HALLB05 0 0.10000E+01 465174.2 3765521.2 283.8 3.11 8.66 2.89 YES HALLB06 0 0.10000E+01 465189.9 3765511.1 283.6 3.11 8.66 2.89 YES HALLB07 0 0.10000E+01 465205.5 3765501.0 283.5 3.11 8.66 2.89 YES HALLB08 0 0.10000E+01 465221.2 3765491.0 283.3 3.11 8.66 2.89 YES HALLB09 0 0.10000E+01 465236.9 3765480.9 283.1 3.11 8.66 2.89 YES HALLB10 0 0.10000E+01 465252.5 3765470.8 282.9 3.11 8.66 2.89 YES HALLB11 0 0.10000E+01 465268.2 3765460.8 282.8 3.11 8.66 2.89 YES HALLB12 0 0.10000E+01 465283.9 3765450.7 282.9 3.11 8.66 2.89 YES HALLB13 0 0.10000E+01 465299.6 3765440.6 283.4 3.11 8.66 2.89 YES HALLB14 0 0.10000E+01 465315.2 3765430.5 284.1 3.11 8.66 2.89 YES AMS_001 0 0.10000E+01 465156.5 3765169.3 277.5 3.11 8.97 2.89 YES AMS_002 0 0.10000E+01 465145.9 3765153.2 277.4 3.11 8.97 2.89 YES AMS_003 0 0.10000E+01 465135.2 3765137.1 277.1 3.11 8.97 2.89 YES AMS_004 0 0.10000E+01 465124.6 3765121.0 276.9 3.11 8.97 2.89 YES AMS_005 0 0.10000E+01 465114.0 3765104.9 276.7 3.11 8.97 2.89 YES AMS_006 0 0.10000E+01 465103.4 3765088.8 276.4 3.11 8.97 2.89 YES AMS_007 0 0.10000E+01 465092.7 3765072.7 276.3 3.11 8.97 2.89 YES AMS_008 0 0.10000E+01 465082.1 3765056.6 276.1 3.11 8.97 2.89 YES AMS_009 0 0.10000E+01 465071.5 3765040.5 275.9 3.11 8.97 2.89 YES AMS_010 0 0.10000E+01 465059.4 3765025.8 275.6 3.11 8.97 2.89 YES AMS_011 0 0.10000E+01 465043.9 3765014.3 275.4 3.11 8.97 2.89 YES AMS_012 0 0.10000E+01 465028.4 3765002.9 275.3 3.11 8.97 2.89 YES AMS_013 0 0.10000E+01 465012.8 3764991.5 275.0 3.11 8.97 2.89 YES AMS_014 0 0.10000E+01 464997.3 3764980.0 274.7 3.11 8.97 2.89 YES AMS_015 0 0.10000E+01 464981.8 3764968.6 274.4 3.11 8.97 2.89 YES AMS_016 0 0.10000E+01 464966.3 3764957.1 274.3 3.11 8.97 2.89 YES AMS_017 0 0.10000E+01 464950.7 3764945.7 274.0 3.11 8.97 2.89 YES AMS_018 0 0.10000E+01 464935.2 3764934.3 272.8 3.11 8.97 2.89 YES AMS_019 0 0.10000E+01 464919.7 3764922.8 272.4 3.11 8.97 2.89 YES AMS_020 0 0.10000E+01 464904.1 3764911.4 272.4 3.11 8.97 2.89 YES AMS_021 0 0.10000E+01 464888.6 3764899.9 272.2 3.11 8.97 2.89 YES *** AERMOD - VERSION 19191 *** *** Agua Mansa Industrial HRA *** 03/12/20 *** AERMET - VERSION 16216 *** *** *** 12:15:11 PAGE 4 *** MODELOPTs: RegDFAULT CONC ELEV URBAN ADJ_U* *** VOLUME SOURCE DATA *** NUMBER EMISSION RATE BASE RELEASE INIT. INIT. URBAN EMISSION RATE SOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT SY SZ SOURCE SCALAR VARY ID CATS. (METERS) (METERS) (METERS) (METERS) (METERS) (METERS) BY - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - AMS_022 0 0.10000E+01 464873.1 3764888.5 272.5 3.11 8.97 2.89 YES AMS_023 0 0.10000E+01 464857.6 3764877.1 272.7 3.11 8.97 2.89 YES AMS_024 0 0.10000E+01 464842.0 3764865.6 272.7 3.11 8.97 2.89 YES AMS_025 0 0.10000E+01 464826.5 3764854.2 272.8 3.11 8.97 2.89 YES AMS_026 0 0.10000E+01 464811.0 3764842.7 272.8 3.11 8.97 2.89 YES AMS_027 0 0.10000E+01 464795.5 3764831.3 272.6 3.11 8.97 2.89 YES AMS_028 0 0.10000E+01 464779.9 3764819.8 272.7 3.11 8.97 2.89 YES AMS_029 0 0.10000E+01 464764.4 3764808.4 272.8 3.11 8.97 2.89 YES AMS_030 0 0.10000E+01 464748.9 3764797.0 272.7 3.11 8.97 2.89 YES AMS_031 0 0.10000E+01 464733.3 3764785.5 272.6 3.11 8.97 2.89 YES AMS_032 0 0.10000E+01 464717.8 3764774.1 272.6 3.11 8.97 2.89 YES AMS_033 0 0.10000E+01 464702.3 3764762.6 272.4 3.11 8.97 2.89 YES AMS_034 0 0.10000E+01 464686.8 3764751.2 272.5 3.11 8.97 2.89 YES AMS_035 0 0.10000E+01 464671.2 3764739.8 272.5 3.11 8.97 2.89 YES AMS_036 0 0.10000E+01 464655.7 3764728.3 272.4 3.11 8.97 2.89 YES AMS_037 0 0.10000E+01 464640.2 3764716.9 272.4 3.11 8.97 2.89 YES AMS_038 0 0.10000E+01 464624.7 3764705.4 272.4 3.11 8.97 2.89 YES AMS_039 0 0.10000E+01 464609.1 3764694.0 272.3 3.11 8.97 2.89 YES AMS_040 0 0.10000E+01 464593.6 3764682.5 272.3 3.11 8.97 2.89 YES AMS_041 0 0.10000E+01 464578.1 3764671.1 272.2 3.11 8.97 2.89 YES AMS_042 0 0.10000E+01 464562.5 3764659.7 272.2 3.11 8.97 2.89 YES AMS_043 0 0.10000E+01 464547.0 3764648.2 272.1 3.11 8.97 2.89 YES AMS_044 0 0.10000E+01 464531.5 3764636.8 272.1 3.11 8.97 2.89 YES AMS_045 0 0.10000E+01 464516.0 3764625.3 272.0 3.11 8.97 2.89 YES AMS_046 0 0.10000E+01 464500.4 3764613.9 272.0 3.11 8.97 2.89 YES AMS_047 0 0.10000E+01 464484.9 3764602.5 272.0 3.11 8.97 2.89 YES AMS_048 0 0.10000E+01 464469.4 3764591.0 272.0 3.11 8.97 2.89 YES AMS_049 0 0.10000E+01 464453.8 3764579.6 272.0 3.11 8.97 2.89 YES AMS_050 0 0.10000E+01 464438.3 3764568.1 271.7 3.11 8.97 2.89 YES AMS_051 0 0.10000E+01 464425.4 3764554.0 271.0 3.11 8.97 2.89 YES AMS_052 0 0.10000E+01 464413.6 3764538.8 270.5 3.11 8.97 2.89 YES AMS_053 0 0.10000E+01 464401.8 3764523.5 269.8 3.11 8.97 2.89 YES AMS_054 0 0.10000E+01 464390.0 3764508.3 268.8 3.11 8.97 2.89 YES AMS_055 0 0.10000E+01 464378.2 3764493.0 268.3 3.11 8.97 2.89 YES AMS_056 0 0.10000E+01 464366.3 3764477.8 267.8 3.11 8.97 2.89 YES AMS_057 0 0.10000E+01 464354.5 3764462.5 267.4 3.11 8.97 2.89 YES AMS_058 0 0.10000E+01 464342.7 3764447.3 266.8 3.11 8.97 2.89 YES AMS_059 0 0.10000E+01 464330.9 3764432.0 266.0 3.11 8.97 2.89 YES AMS_060 0 0.10000E+01 464319.1 3764416.8 265.0 3.11 8.97 2.89 YES AMS_061 0 0.10000E+01 464307.3 3764401.5 264.2 3.11 8.97 2.89 YES *** AERMOD - VERSION 19191 *** *** Agua Mansa Industrial HRA *** 03/12/20 *** AERMET - VERSION 16216 *** *** *** 12:15:11 PAGE 5 *** MODELOPTs: RegDFAULT CONC ELEV URBAN ADJ_U* *** VOLUME SOURCE DATA *** NUMBER EMISSION RATE BASE RELEASE INIT. INIT. URBAN EMISSION RATE SOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT SY SZ SOURCE SCALAR VARY ID CATS. (METERS) (METERS) (METERS) (METERS) (METERS) (METERS) BY - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - AMS_062 0 0.10000E+01 464295.5 3764386.3 263.6 3.11 8.97 2.89 YES AMS_063 0 0.10000E+01 464283.7 3764371.0 263.3 3.11 8.97 2.89 YES AMS_064 0 0.10000E+01 464271.9 3764355.8 263.0 3.11 8.97 2.89 YES AMS_065 0 0.10000E+01 464260.0 3764340.6 262.9 3.11 8.97 2.89 YES AMS_066 0 0.10000E+01 464248.2 3764325.3 262.8 3.11 8.97 2.89 YES AMS_067 0 0.10000E+01 464236.4 3764310.1 262.5 3.11 8.97 2.89 YES AMS_068 0 0.10000E+01 464224.6 3764294.8 262.4 3.11 8.97 2.89 YES AMS_069 0 0.10000E+01 464212.8 3764279.6 262.3 3.11 8.97 2.89 YES AMS_070 0 0.10000E+01 464201.0 3764264.3 262.9 3.11 8.97 2.89 YES AMS_071 0 0.10000E+01 464189.2 3764249.1 261.6 3.11 8.97 2.89 YES AMS_072 0 0.10000E+01 464177.4 3764233.8 260.0 3.11 8.97 2.89 YES AMS_073 0 0.10000E+01 464165.6 3764218.6 258.7 3.11 8.97 2.89 YES AMS_074 0 0.10000E+01 464153.8 3764203.3 258.1 3.11 8.97 2.89 YES AMS_075 0 0.10000E+01 464141.9 3764188.1 257.8 3.11 8.97 2.89 YES AMS_076 0 0.10000E+01 464130.1 3764172.8 257.7 3.11 8.97 2.89 YES AMS_077 0 0.10000E+01 464118.3 3764157.6 257.5 3.11 8.97 2.89 YES AMS_078 0 0.10000E+01 464106.5 3764142.3 257.5 3.11 8.97 2.89 YES AMS_079 0 0.10000E+01 464094.7 3764127.1 257.4 3.11 8.97 2.89 YES AMS_080 0 0.10000E+01 464082.9 3764111.8 257.4 3.11 8.97 2.89 YES AMS_081 0 0.10000E+01 464071.1 3764096.6 257.4 3.11 8.97 2.89 YES AMS_082 0 0.10000E+01 464059.3 3764081.3 257.3 3.11 8.97 2.89 YES AMS_083 0 0.10000E+01 464047.5 3764066.1 257.3 3.11 8.97 2.89 YES AMS_084 0 0.10000E+01 464035.6 3764050.8 257.3 3.11 8.97 2.89 YES AMS_085 0 0.10000E+01 464023.8 3764035.6 257.4 3.11 8.97 2.89 YES AMS_086 0 0.10000E+01 464012.0 3764020.3 257.7 3.11 8.97 2.89 YES AMS_087 0 0.10000E+01 464000.2 3764005.1 257.9 3.11 8.97 2.89 YES AMS_088 0 0.10000E+01 463988.4 3763989.8 257.9 3.11 8.97 2.89 YES AMS_089 0 0.10000E+01 463976.6 3763974.6 257.9 3.11 8.97 2.89 YES AMS_090 0 0.10000E+01 463964.8 3763959.3 257.8 3.11 8.97 2.89 YES AMS_091 0 0.10000E+01 463953.0 3763944.1 257.9 3.11 8.97 2.89 YES AMS_092 0 0.10000E+01 463941.1 3763928.8 257.9 3.11 8.97 2.89 YES AMS_093 0 0.10000E+01 463929.3 3763913.6 258.2 3.11 8.97 2.89 YES AMS_094 0 0.10000E+01 463917.5 3763898.4 258.4 3.11 8.97 2.89 YES AMS_095 0 0.10000E+01 463905.7 3763883.1 258.8 3.11 8.97 2.89 YES AMS_096 0 0.10000E+01 463893.9 3763867.9 259.0 3.11 8.97 2.89 YES AMS_097 0 0.10000E+01 463882.1 3763852.6 259.2 3.11 8.97 2.89 YES AMS_098 0 0.10000E+01 463870.3 3763837.4 259.5 3.11 8.97 2.89 YES AMS_099 0 0.10000E+01 463858.5 3763822.1 259.7 3.11 8.97 2.89 YES AMS_100 0 0.10000E+01 463846.7 3763806.9 259.9 3.11 8.97 2.89 YES AMS_101 0 0.10000E+01 463834.8 3763791.6 260.0 3.11 8.97 2.89 YES *** AERMOD - VERSION 19191 *** *** Agua Mansa Industrial HRA *** 03/12/20 *** AERMET - VERSION 16216 *** *** *** 12:15:11 PAGE 6 *** MODELOPTs: RegDFAULT CONC ELEV URBAN ADJ_U* *** VOLUME SOURCE DATA *** NUMBER EMISSION RATE BASE RELEASE INIT. INIT. URBAN EMISSION RATE SOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT SY SZ SOURCE SCALAR VARY ID CATS. (METERS) (METERS) (METERS) (METERS) (METERS) (METERS) BY - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - AMS_102 0 0.10000E+01 463823.0 3763776.4 260.2 3.11 8.97 2.89 YES AMS_103 0 0.10000E+01 463811.2 3763761.1 260.4 3.11 8.97 2.89 YES AMS_104 0 0.10000E+01 463799.4 3763745.9 260.5 3.11 8.97 2.89 YES AMS_105 0 0.10000E+01 463787.6 3763730.6 260.7 3.11 8.97 2.89 YES AMS_106 0 0.10000E+01 463775.8 3763715.4 260.9 3.11 8.97 2.89 YES AMS_107 0 0.10000E+01 463764.0 3763700.1 261.1 3.11 8.97 2.89 YES AMS_108 0 0.10000E+01 463752.2 3763684.9 261.2 3.11 8.97 2.89 YES AMS_109 0 0.10000E+01 463740.4 3763669.6 261.5 3.11 8.97 2.89 YES AMS_110 0 0.10000E+01 463728.5 3763654.4 261.8 3.11 8.97 2.89 YES AMS_111 0 0.10000E+01 463716.7 3763639.1 262.2 3.11 8.97 2.89 YES AMS_112 0 0.10000E+01 463704.9 3763623.9 262.6 3.11 8.97 2.89 YES AMS_113 0 0.10000E+01 463693.1 3763608.6 263.1 3.11 8.97 2.89 YES AMS_114 0 0.10000E+01 463681.3 3763593.4 263.9 3.11 8.97 2.89 YES AMS_115 0 0.10000E+01 463669.5 3763578.1 264.3 3.11 8.97 2.89 YES AMS_116 0 0.10000E+01 463657.7 3763562.9 264.7 3.11 8.97 2.89 YES AMS_117 0 0.10000E+01 463645.9 3763547.6 264.8 3.11 8.97 2.89 YES AMS_118 0 0.10000E+01 463634.1 3763532.4 264.7 3.11 8.97 2.89 YES AMS_119 0 0.10000E+01 463622.2 3763517.1 264.7 3.11 8.97 2.89 YES AMS_120 0 0.10000E+01 463610.4 3763501.9 264.5 3.11 8.97 2.89 YES AMS_121 0 0.10000E+01 463598.6 3763486.6 264.4 3.11 8.97 2.89 YES AMS_122 0 0.10000E+01 463586.8 3763471.4 264.2 3.11 8.97 2.89 YES AMS_123 0 0.10000E+01 463575.0 3763456.2 263.9 3.11 8.97 2.89 YES AMS_124 0 0.10000E+01 463563.2 3763440.9 263.8 3.11 8.97 2.89 YES AMS_125 0 0.10000E+01 463551.4 3763425.7 263.6 3.11 8.97 2.89 YES AMS_126 0 0.10000E+01 463539.6 3763410.4 263.3 3.11 8.97 2.89 YES AMS_127 0 0.10000E+01 463527.8 3763395.2 263.2 3.11 8.97 2.89 YES AMS_128 0 0.10000E+01 463515.9 3763379.9 262.9 3.11 8.97 2.89 YES AMS_129 0 0.10000E+01 463504.1 3763364.7 262.6 3.11 8.97 2.89 YES AMS_130 0 0.10000E+01 463492.3 3763349.4 262.4 3.11 8.97 2.89 YES AMS_131 0 0.10000E+01 463480.5 3763334.2 262.1 3.11 8.97 2.89 YES AMS_132 0 0.10000E+01 463468.7 3763318.9 261.8 3.11 8.97 2.89 YES AMS_133 0 0.10000E+01 463456.9 3763303.7 261.6 3.11 8.97 2.89 YES AMS_134 0 0.10000E+01 463445.1 3763288.4 261.4 3.11 8.97 2.89 YES AMS_135 0 0.10000E+01 463433.3 3763273.2 261.2 3.11 8.97 2.89 YES AMS_136 0 0.10000E+01 463421.5 3763257.9 261.1 3.11 8.97 2.89 YES AMS_137 0 0.10000E+01 463409.6 3763242.7 260.9 3.11 8.97 2.89 YES AMS_138 0 0.10000E+01 463397.8 3763227.4 260.8 3.11 8.97 2.89 YES AMS_139 0 0.10000E+01 463386.0 3763212.2 260.6 3.11 8.97 2.89 YES AMS_140 0 0.10000E+01 463374.2 3763196.9 260.5 3.11 8.97 2.89 YES AMS_141 0 0.10000E+01 463362.4 3763181.7 260.4 3.11 8.97 2.89 YES *** AERMOD - VERSION 19191 *** *** Agua Mansa Industrial HRA *** 03/12/20 *** AERMET - VERSION 16216 *** *** *** 12:15:11 PAGE 7 *** MODELOPTs: RegDFAULT CONC ELEV URBAN ADJ_U* *** VOLUME SOURCE DATA *** NUMBER EMISSION RATE BASE RELEASE INIT. INIT. URBAN EMISSION RATE SOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT SY SZ SOURCE SCALAR VARY ID CATS. (METERS) (METERS) (METERS) (METERS) (METERS) (METERS) BY - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - AMS_142 0 0.10000E+01 463350.6 3763166.4 260.2 3.11 8.97 2.89 YES AMS_143 0 0.10000E+01 463338.8 3763151.2 260.0 3.11 8.97 2.89 YES AMS_144 0 0.10000E+01 463327.0 3763135.9 259.9 3.11 8.97 2.89 YES AMS_145 0 0.10000E+01 463315.2 3763120.7 259.7 3.11 8.97 2.89 YES AMS_146 0 0.10000E+01 463303.3 3763105.4 259.5 3.11 8.97 2.89 YES AMS_147 0 0.10000E+01 463291.5 3763090.2 259.4 3.11 8.97 2.89 YES AMS_148 0 0.10000E+01 463279.7 3763074.9 259.2 3.11 8.97 2.89 YES AMS_149 0 0.10000E+01 463267.9 3763059.7 259.0 3.11 8.97 2.89 YES AMS_150 0 0.10000E+01 463256.1 3763044.5 258.8 3.11 8.97 2.89 YES AMS_151 0 0.10000E+01 463244.3 3763029.2 258.7 3.11 8.97 2.89 YES AMS_152 0 0.10000E+01 463232.5 3763014.0 258.6 3.11 8.97 2.89 YES AMS_153 0 0.10000E+01 463220.7 3762998.7 258.4 3.11 8.97 2.89 YES AMS_154 0 0.10000E+01 463208.8 3762983.5 258.2 3.11 8.97 2.89 YES AMS_155 0 0.10000E+01 463197.0 3762968.2 257.9 3.11 8.97 2.89 YES AMS_156 0 0.10000E+01 463185.2 3762953.0 257.6 3.11 8.97 2.89 YES AMS_157 0 0.10000E+01 463173.4 3762937.7 257.4 3.11 8.97 2.89 YES AMS_158 0 0.10000E+01 463161.6 3762922.5 257.2 3.11 8.97 2.89 YES AMS_159 0 0.10000E+01 463149.8 3762907.2 257.0 3.11 8.97 2.89 YES AMS_160 0 0.10000E+01 463138.0 3762892.0 256.8 3.11 8.97 2.89 YES AMS_161 0 0.10000E+01 463126.2 3762876.7 256.1 3.11 8.97 2.89 YES AMS_162 0 0.10000E+01 463114.4 3762861.5 255.4 3.11 8.97 2.89 YES AMS_163 0 0.10000E+01 463102.5 3762846.2 254.4 3.11 8.97 2.89 YES AMS_164 0 0.10000E+01 463090.7 3762831.0 253.5 3.11 8.97 2.89 YES AMS_165 0 0.10000E+01 463078.9 3762815.7 252.8 3.11 8.97 2.89 YES AMS_166 0 0.10000E+01 463067.1 3762800.5 252.3 3.11 8.97 2.89 YES AMS_167 0 0.10000E+01 463055.3 3762785.2 251.9 3.11 8.97 2.89 YES AMS_168 0 0.10000E+01 463043.5 3762770.0 251.4 3.11 8.97 2.89 YES AMN_001 0 0.10000E+01 465167.1 3765185.4 277.8 3.11 8.97 2.89 YES AMN_002 0 0.10000E+01 465177.8 3765201.5 278.1 3.11 8.97 2.89 YES AMN_003 0 0.10000E+01 465188.4 3765217.6 278.5 3.11 8.97 2.89 YES AMN_004 0 0.10000E+01 465199.0 3765233.7 279.1 3.11 8.97 2.89 YES AMN_005 0 0.10000E+01 465209.7 3765249.8 279.8 3.11 8.97 2.89 YES AMN_006 0 0.10000E+01 465220.3 3765265.9 280.6 3.11 8.97 2.89 YES AMN_007 0 0.10000E+01 465230.9 3765281.9 281.3 3.11 8.97 2.89 YES AMN_008 0 0.10000E+01 465241.6 3765298.0 281.9 3.11 8.97 2.89 YES AMN_009 0 0.10000E+01 465252.2 3765314.1 282.4 3.11 8.97 2.89 YES AMN_010 0 0.10000E+01 465262.8 3765330.2 282.8 3.11 8.97 2.89 YES AMN_011 0 0.10000E+01 465273.5 3765346.3 283.2 3.11 8.97 2.89 YES AMN_012 0 0.10000E+01 465284.1 3765362.4 283.4 3.11 8.97 2.89 YES AMN_013 0 0.10000E+01 465294.7 3765378.5 283.6 3.11 8.97 2.89 YES *** AERMOD - VERSION 19191 *** *** Agua Mansa Industrial HRA *** 03/12/20 *** AERMET - VERSION 16216 *** *** *** 12:15:11 PAGE 8 *** MODELOPTs: RegDFAULT CONC ELEV URBAN ADJ_U* *** VOLUME SOURCE DATA *** NUMBER EMISSION RATE BASE RELEASE INIT. INIT. URBAN EMISSION RATE SOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT SY SZ SOURCE SCALAR VARY ID CATS. (METERS) (METERS) (METERS) (METERS) (METERS) (METERS) BY - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - AMN_014 0 0.10000E+01 465305.3 3765394.6 283.9 3.11 8.97 2.89 YES AMN_015 0 0.10000E+01 465316.0 3765410.7 284.1 3.11 8.97 2.89 YES AMN_016 0 0.10000E+01 465326.6 3765426.8 284.4 3.11 8.97 2.89 YES AMN_017 0 0.10000E+01 465335.2 3765442.5 284.6 3.11 8.97 2.89 YES AMN_018 0 0.10000E+01 465342.9 3765457.0 284.8 3.11 8.97 2.89 YES AMN_019 0 0.10000E+01 465353.3 3765473.3 285.2 3.11 8.97 2.89 YES AMN_020 0 0.10000E+01 465363.6 3765489.5 285.7 3.11 8.97 2.89 YES AMN_021 0 0.10000E+01 465374.0 3765505.8 286.2 3.11 8.97 2.89 YES AMN_022 0 0.10000E+01 465384.4 3765522.1 286.6 3.11 8.97 2.89 YES AMN_023 0 0.10000E+01 465394.7 3765538.4 286.9 3.11 8.97 2.89 YES AMN_024 0 0.10000E+01 465405.1 3765554.6 287.2 3.11 8.97 2.89 YES AMN_025 0 0.10000E+01 465415.5 3765570.9 287.3 3.11 8.97 2.89 YES AMN_026 0 0.10000E+01 465425.8 3765587.2 287.4 3.11 8.97 2.89 YES AMN_027 0 0.10000E+01 465436.2 3765603.4 287.3 3.11 8.97 2.89 YES AMN_028 0 0.10000E+01 465446.5 3765619.7 287.2 3.11 8.97 2.89 YES AMN_029 0 0.10000E+01 465456.9 3765636.0 287.0 3.11 8.97 2.89 YES AMN_030 0 0.10000E+01 465467.3 3765652.3 286.8 3.11 8.97 2.89 YES AMN_031 0 0.10000E+01 465477.6 3765668.5 286.4 3.11 8.97 2.89 YES AMN_032 0 0.10000E+01 465488.0 3765684.8 286.3 3.11 8.97 2.89 YES AMN_033 0 0.10000E+01 465498.3 3765701.1 286.1 3.11 8.97 2.89 YES AMN_034 0 0.10000E+01 465508.7 3765717.4 286.0 3.11 8.97 2.89 YES AMN_035 0 0.10000E+01 465519.1 3765733.6 285.9 3.11 8.97 2.89 YES AMN_036 0 0.10000E+01 465529.4 3765749.9 285.9 3.11 8.97 2.89 YES AMN_037 0 0.10000E+01 465539.8 3765766.2 285.8 3.11 8.97 2.89 YES AMN_038 0 0.10000E+01 465550.2 3765782.4 285.7 3.11 8.97 2.89 YES AMN_039 0 0.10000E+01 465560.5 3765798.7 285.7 3.11 8.97 2.89 YES AMN_040 0 0.10000E+01 465570.9 3765815.0 285.6 3.11 8.97 2.89 YES AMN_041 0 0.10000E+01 465581.2 3765831.3 285.5 3.11 8.97 2.89 YES AMN_042 0 0.10000E+01 465591.6 3765847.5 285.4 3.11 8.97 2.89 YES AMN_043 0 0.10000E+01 465602.0 3765863.8 285.2 3.11 8.97 2.89 YES AMN_044 0 0.10000E+01 465612.3 3765880.1 285.0 3.11 8.97 2.89 YES AMN_045 0 0.10000E+01 465622.7 3765896.3 284.8 3.11 8.97 2.89 YES AMN_046 0 0.10000E+01 465633.1 3765912.6 284.5 3.11 8.97 2.89 YES AMN_047 0 0.10000E+01 465643.4 3765928.9 284.2 3.11 8.97 2.89 YES AMN_048 0 0.10000E+01 465653.8 3765945.2 284.0 3.11 8.97 2.89 YES AMN_049 0 0.10000E+01 465664.1 3765961.4 283.6 3.11 8.97 2.89 YES AMN_050 0 0.10000E+01 465674.5 3765977.7 283.2 3.11 8.97 2.89 YES AMN_051 0 0.10000E+01 465684.9 3765994.0 282.8 3.11 8.97 2.89 YES AMN_052 0 0.10000E+01 465695.2 3766010.2 282.0 3.11 8.97 2.89 YES AMN_053 0 0.10000E+01 465705.6 3766026.5 281.2 3.11 8.97 2.89 YES *** AERMOD - VERSION 19191 *** *** Agua Mansa Industrial HRA *** 03/12/20 *** AERMET - VERSION 16216 *** *** *** 12:15:11 PAGE 9 *** MODELOPTs: RegDFAULT CONC ELEV URBAN ADJ_U* *** VOLUME SOURCE DATA *** NUMBER EMISSION RATE BASE RELEASE INIT. INIT. URBAN EMISSION RATE SOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT SY SZ SOURCE SCALAR VARY ID CATS. (METERS) (METERS) (METERS) (METERS) (METERS) (METERS) BY - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - AMN_054 0 0.10000E+01 465716.0 3766042.8 280.3 3.11 8.97 2.89 YES AMN_055 0 0.10000E+01 465726.3 3766059.1 279.5 3.11 8.97 2.89 YES AMN_056 0 0.10000E+01 465736.7 3766075.3 278.6 3.11 8.97 2.89 YES AMN_057 0 0.10000E+01 465747.0 3766091.6 277.5 3.11 8.97 2.89 YES AMN_058 0 0.10000E+01 465757.4 3766107.9 276.2 3.11 8.97 2.89 YES AMN_059 0 0.10000E+01 465767.8 3766124.1 275.3 3.11 8.97 2.89 YES AMN_060 0 0.10000E+01 465778.1 3766140.4 274.4 3.11 8.97 2.89 YES AMN_061 0 0.10000E+01 465788.5 3766156.7 274.0 3.11 8.97 2.89 YES AMN_062 0 0.10000E+01 465798.8 3766173.0 273.2 3.11 8.97 2.89 YES AMN_063 0 0.10000E+01 465809.2 3766189.2 272.6 3.11 8.97 2.89 YES AMN_064 0 0.10000E+01 465822.5 3766203.0 272.1 3.11 8.97 2.89 YES AMN_065 0 0.10000E+01 465836.9 3766215.8 271.8 3.11 8.97 2.89 YES AMN_066 0 0.10000E+01 465851.3 3766228.7 271.7 3.11 8.97 2.89 YES AMN_067 0 0.10000E+01 465865.7 3766241.5 271.3 3.11 8.97 2.89 YES AMN_068 0 0.10000E+01 465880.1 3766254.3 271.1 3.11 8.97 2.89 YES AMN_069 0 0.10000E+01 465894.5 3766267.1 271.4 3.11 8.97 2.89 YES AMN_070 0 0.10000E+01 465909.0 3766280.0 271.7 3.11 8.97 2.89 YES AMN_071 0 0.10000E+01 465923.4 3766292.8 271.6 3.11 8.97 2.89 YES AMN_072 0 0.10000E+01 465937.8 3766305.6 271.5 3.11 8.97 2.89 YES AMN_073 0 0.10000E+01 465952.2 3766318.5 271.6 3.11 8.97 2.89 YES AMN_074 0 0.10000E+01 465966.6 3766331.3 271.6 3.11 8.97 2.89 YES AMN_075 0 0.10000E+01 465981.0 3766344.1 271.4 3.11 8.97 2.89 YES AMN_076 0 0.10000E+01 465995.4 3766356.9 271.4 3.11 8.97 2.89 YES AMN_077 0 0.10000E+01 466009.8 3766369.8 271.5 3.11 8.97 2.89 YES AMN_078 0 0.10000E+01 466024.2 3766382.6 271.7 3.11 8.97 2.89 YES AMN_079 0 0.10000E+01 466038.6 3766395.4 271.8 3.11 8.97 2.89 YES AMN_080 0 0.10000E+01 466053.0 3766408.2 271.9 3.11 8.97 2.89 YES AMN_081 0 0.10000E+01 466067.5 3766421.1 271.9 3.11 8.97 2.89 YES AMN_082 0 0.10000E+01 466081.9 3766433.9 272.1 3.11 8.97 2.89 YES AMN_083 0 0.10000E+01 466096.3 3766446.7 272.1 3.11 8.97 2.89 YES AMN_084 0 0.10000E+01 466110.7 3766459.6 272.4 3.11 8.97 2.89 YES RVSD001 0 0.10000E+01 466109.5 3766496.0 273.0 3.11 8.97 2.89 YES RVSD002 0 0.10000E+01 466105.0 3766514.8 273.3 3.11 8.97 2.89 YES RVSD003 0 0.10000E+01 466100.5 3766533.5 273.6 3.11 8.97 2.89 YES RVSD004 0 0.10000E+01 466096.0 3766552.3 273.8 3.11 8.97 2.89 YES RVSD005 0 0.10000E+01 466091.5 3766571.0 274.1 3.11 8.97 2.89 YES RVSD006 0 0.10000E+01 466087.0 3766589.8 274.3 3.11 8.97 2.89 YES RVSD007 0 0.10000E+01 466082.5 3766608.5 274.8 3.11 8.97 2.89 YES RVSD008 0 0.10000E+01 466077.9 3766627.3 274.9 3.11 8.97 2.89 YES RVSD009 0 0.10000E+01 466073.4 3766646.1 275.2 3.11 8.97 2.89 YES *** AERMOD - VERSION 19191 *** *** Agua Mansa Industrial HRA *** 03/12/20 *** AERMET - VERSION 16216 *** *** *** 12:15:11 PAGE 10 *** MODELOPTs: RegDFAULT CONC ELEV URBAN ADJ_U* *** VOLUME SOURCE DATA *** NUMBER EMISSION RATE BASE RELEASE INIT. INIT. URBAN EMISSION RATE SOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT SY SZ SOURCE SCALAR VARY ID CATS. (METERS) (METERS) (METERS) (METERS) (METERS) (METERS) BY - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - RVSD010 0 0.10000E+01 466068.9 3766664.8 275.4 3.11 8.97 2.89 YES RVSD011 0 0.10000E+01 466064.4 3766683.6 275.7 3.11 8.97 2.89 YES RVSD012 0 0.10000E+01 466059.9 3766702.3 276.1 3.11 8.97 2.89 YES RVSD013 0 0.10000E+01 466055.4 3766721.1 276.3 3.11 8.97 2.89 YES RVSD014 0 0.10000E+01 466050.9 3766739.8 276.9 3.11 8.97 2.89 YES RVSD015 0 0.10000E+01 466046.4 3766758.6 277.2 3.11 8.97 2.89 YES RVSD016 0 0.10000E+01 466041.9 3766777.3 278.0 3.11 8.97 2.89 YES RVSD017 0 0.10000E+01 466037.4 3766796.1 278.2 3.11 8.97 2.89 YES RVSD018 0 0.10000E+01 466032.9 3766814.8 278.9 3.11 8.97 2.89 YES RVSD019 0 0.10000E+01 466028.4 3766833.6 279.5 3.11 8.97 2.89 YES RVSD020 0 0.10000E+01 466023.9 3766852.4 280.4 3.11 8.97 2.89 YES RVSD021 0 0.10000E+01 466019.4 3766871.1 281.1 3.11 8.97 2.89 YES RVSD022 0 0.10000E+01 466014.9 3766889.9 282.0 3.11 8.97 2.89 YES RVSD023 0 0.10000E+01 466010.4 3766908.6 282.7 3.11 8.97 2.89 YES RVSD024 0 0.10000E+01 466005.9 3766927.4 283.6 3.11 8.97 2.89 YES RVSD025 0 0.10000E+01 466001.4 3766946.1 284.4 3.11 8.97 2.89 YES RVSD026 0 0.10000E+01 465996.9 3766964.9 285.2 3.11 8.97 2.89 YES RVSD027 0 0.10000E+01 465992.3 3766983.6 285.9 3.11 8.97 2.89 YES RVSD028 0 0.10000E+01 465987.8 3767002.4 286.7 3.11 8.97 2.89 YES RVSD029 0 0.10000E+01 465983.3 3767021.1 287.4 3.11 8.97 2.89 YES RVSD030 0 0.10000E+01 465978.8 3767039.9 288.0 3.11 8.97 2.89 YES RVSD031 0 0.10000E+01 465974.3 3767058.6 288.6 3.11 8.97 2.89 YES RVSD032 0 0.10000E+01 465969.8 3767077.4 289.2 3.11 8.97 2.89 YES RVSD033 0 0.10000E+01 465965.3 3767096.2 289.8 3.11 8.97 2.89 YES RVSD034 0 0.10000E+01 465960.8 3767114.9 290.3 3.11 8.97 2.89 YES RVSD035 0 0.10000E+01 465956.3 3767133.7 290.8 3.11 8.97 2.89 YES RVSD036 0 0.10000E+01 465951.8 3767152.4 291.3 3.11 8.97 2.89 YES RVSD037 0 0.10000E+01 465947.3 3767171.2 291.9 3.11 8.97 2.89 YES RVSD038 0 0.10000E+01 465942.8 3767189.9 292.2 3.11 8.97 2.89 YES RVSD039 0 0.10000E+01 465938.3 3767208.7 292.6 3.11 8.97 2.89 YES RVSD040 0 0.10000E+01 465933.8 3767227.4 292.9 3.11 8.97 2.89 YES RVSD041 0 0.10000E+01 465929.3 3767246.2 293.1 3.11 8.97 2.89 YES RVSD042 0 0.10000E+01 465924.8 3767264.9 293.4 3.11 8.97 2.89 YES RVSD043 0 0.10000E+01 465920.3 3767283.7 293.5 3.11 8.97 2.89 YES RVSD044 0 0.10000E+01 465915.8 3767302.5 293.7 3.11 8.97 2.89 YES RVSD045 0 0.10000E+01 465911.3 3767321.2 293.8 3.11 8.97 2.89 YES RVSD046 0 0.10000E+01 465906.8 3767340.0 294.0 3.11 8.97 2.89 YES RVSD047 0 0.10000E+01 465902.3 3767358.7 294.1 3.11 8.97 2.89 YES RVSD048 0 0.10000E+01 465897.8 3767377.5 294.2 3.11 8.97 2.89 YES RVSD049 0 0.10000E+01 465893.2 3767396.2 294.4 3.11 8.97 2.89 YES *** AERMOD - VERSION 19191 *** *** Agua Mansa Industrial HRA *** 03/12/20 *** AERMET - VERSION 16216 *** *** *** 12:15:11 PAGE 11 *** MODELOPTs: RegDFAULT CONC ELEV URBAN ADJ_U* *** VOLUME SOURCE DATA *** NUMBER EMISSION RATE BASE RELEASE INIT. INIT. URBAN EMISSION RATE SOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT SY SZ SOURCE SCALAR VARY ID CATS. (METERS) (METERS) (METERS) (METERS) (METERS) (METERS) BY - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - RVSD050 0 0.10000E+01 465888.8 3767415.0 294.5 3.11 8.97 2.89 YES RVSD051 0 0.10000E+01 465884.2 3767433.7 294.6 3.11 8.97 2.89 YES RVSD052 0 0.10000E+01 465879.7 3767452.5 294.8 3.11 8.97 2.89 YES RVSD053 0 0.10000E+01 465875.2 3767471.2 294.9 3.11 8.97 2.89 YES RVSD054 0 0.10000E+01 465870.7 3767490.0 295.1 3.11 8.97 2.89 YES RVSD055 0 0.10000E+01 465866.2 3767508.8 295.3 3.11 8.97 2.89 YES RVSD056 0 0.10000E+01 465861.7 3767527.5 295.5 3.11 8.97 2.89 YES RVSD057 0 0.10000E+01 465857.2 3767546.3 295.7 3.11 8.97 2.89 YES RVSD058 0 0.10000E+01 465852.7 3767565.0 295.9 3.11 8.97 2.89 YES RVSD059 0 0.10000E+01 465848.2 3767583.8 296.1 3.11 8.97 2.89 YES RVSD060 0 0.10000E+01 465843.7 3767602.5 296.2 3.11 8.97 2.89 YES RVSD061 0 0.10000E+01 465839.7 3767621.3 296.5 3.11 8.97 2.89 YES RVSD062 0 0.10000E+01 465839.6 3767640.6 296.6 3.11 8.97 2.89 YES RVSD063 0 0.10000E+01 465839.5 3767659.9 296.8 3.11 8.97 2.89 YES RVSD064 0 0.10000E+01 465839.4 3767679.2 296.9 3.11 8.97 2.89 YES RVSD065 0 0.10000E+01 465839.3 3767698.5 297.1 3.11 8.97 2.89 YES RVSD066 0 0.10000E+01 465839.2 3767717.8 297.2 3.11 8.97 2.89 YES RVSD067 0 0.10000E+01 465839.1 3767737.1 297.4 3.11 8.97 2.89 YES RVSD068 0 0.10000E+01 465839.0 3767756.3 297.5 3.11 8.97 2.89 YES RVSD069 0 0.10000E+01 465838.9 3767775.6 297.7 3.11 8.97 2.89 YES RVSD070 0 0.10000E+01 465838.8 3767794.9 297.9 3.11 8.97 2.89 YES RVSD071 0 0.10000E+01 465838.7 3767814.2 298.1 3.11 8.97 2.89 YES RVSD072 0 0.10000E+01 465838.6 3767833.5 298.3 3.11 8.97 2.89 YES RVSD073 0 0.10000E+01 465838.5 3767852.8 298.5 3.11 8.97 2.89 YES RVSD074 0 0.10000E+01 465838.5 3767872.1 298.8 3.11 8.97 2.89 YES RVSD075 0 0.10000E+01 465838.3 3767891.4 299.0 3.11 8.97 2.89 YES RVSD076 0 0.10000E+01 465838.2 3767910.6 299.2 3.11 8.97 2.89 YES RVSD077 0 0.10000E+01 465838.2 3767929.9 299.5 3.11 8.97 2.89 YES RVSD078 0 0.10000E+01 465838.1 3767949.2 299.7 3.11 8.97 2.89 YES RVSD079 0 0.10000E+01 465838.0 3767968.5 299.9 3.11 8.97 2.89 YES RVSD080 0 0.10000E+01 465837.9 3767987.8 300.1 3.11 8.97 2.89 YES RVSD081 0 0.10000E+01 465837.8 3768007.1 300.3 3.11 8.97 2.89 YES RVSD082 0 0.10000E+01 465837.7 3768026.4 300.6 3.11 8.97 2.89 YES RVSD083 0 0.10000E+01 465837.6 3768045.7 300.8 3.11 8.97 2.89 YES RVSD084 0 0.10000E+01 465837.5 3768064.9 301.2 3.11 8.97 2.89 YES RVSD085 0 0.10000E+01 465837.4 3768084.2 301.6 3.11 8.97 2.89 YES RVSD086 0 0.10000E+01 465837.3 3768103.5 302.1 3.11 8.97 2.89 YES RVSD087 0 0.10000E+01 465837.2 3768122.8 302.6 3.11 8.97 2.89 YES RVSD088 0 0.10000E+01 465837.1 3768142.1 303.2 3.11 8.97 2.89 YES RVSD089 0 0.10000E+01 465837.0 3768161.4 303.8 3.11 8.97 2.89 YES *** AERMOD - VERSION 19191 *** *** Agua Mansa Industrial HRA *** 03/12/20 *** AERMET - VERSION 16216 *** *** *** 12:15:11 PAGE 12 *** MODELOPTs: RegDFAULT CONC ELEV URBAN ADJ_U* *** VOLUME SOURCE DATA *** NUMBER EMISSION RATE BASE RELEASE INIT. INIT. URBAN EMISSION RATE SOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT SY SZ SOURCE SCALAR VARY ID CATS. (METERS) (METERS) (METERS) (METERS) (METERS) (METERS) BY - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - RVSD090 0 0.10000E+01 465836.9 3768180.7 304.4 3.11 8.97 2.89 YES RVSD091 0 0.10000E+01 465836.8 3768200.0 304.8 3.11 8.97 2.89 YES RVSD092 0 0.10000E+01 465836.7 3768219.2 305.3 3.11 8.97 2.89 YES RVSD093 0 0.10000E+01 465836.6 3768238.5 305.6 3.11 8.97 2.89 YES RVSD094 0 0.10000E+01 465836.5 3768257.8 305.9 3.11 8.97 2.89 YES RVSD095 0 0.10000E+01 465836.4 3768277.1 306.1 3.11 8.97 2.89 YES RVSD096 0 0.10000E+01 465836.3 3768296.4 306.2 3.11 8.97 2.89 YES RVSD097 0 0.10000E+01 465836.2 3768315.7 306.3 3.11 8.97 2.89 YES RVSD098 0 0.10000E+01 465836.1 3768335.0 306.2 3.11 8.97 2.89 YES RVSD099 0 0.10000E+01 465836.0 3768354.2 306.2 3.11 8.97 2.89 YES RVSD100 0 0.10000E+01 465835.9 3768373.5 306.0 3.11 8.97 2.89 YES RVSD101 0 0.10000E+01 465835.8 3768392.8 305.9 3.11 8.97 2.89 YES RVSD102 0 0.10000E+01 465835.7 3768412.1 305.7 3.11 8.97 2.89 YES RVSD103 0 0.10000E+01 465835.6 3768431.4 305.3 3.11 8.97 2.89 YES RVSD104 0 0.10000E+01 465835.5 3768450.7 304.9 3.11 8.97 2.89 YES RVSD105 0 0.10000E+01 465835.5 3768470.0 304.4 3.11 8.97 2.89 YES RVSD106 0 0.10000E+01 465835.3 3768489.3 303.9 3.11 8.97 2.89 YES RVSD107 0 0.10000E+01 465835.3 3768508.5 303.4 3.11 8.97 2.89 YES RVSD108 0 0.10000E+01 465835.2 3768527.8 302.9 3.11 8.97 2.89 YES RVSD109 0 0.10000E+01 465835.1 3768547.1 302.5 3.11 8.97 2.89 YES RVSD110 0 0.10000E+01 465835.0 3768566.4 302.2 3.11 8.97 2.89 YES RVSD111 0 0.10000E+01 465834.9 3768585.7 302.0 3.11 8.97 2.89 YES RVSD112 0 0.10000E+01 465834.8 3768605.0 301.9 3.11 8.97 2.89 YES RVSD113 0 0.10000E+01 465834.7 3768624.3 301.9 3.11 8.97 2.89 YES RVSD114 0 0.10000E+01 465834.6 3768643.6 301.9 3.11 8.97 2.89 YES RVSD115 0 0.10000E+01 465834.5 3768662.8 302.1 3.11 8.97 2.89 YES RVSD116 0 0.10000E+01 465834.4 3768682.1 302.3 3.11 8.97 2.89 YES RVSD117 0 0.10000E+01 465834.3 3768701.4 302.6 3.11 8.97 2.89 YES RVSD118 0 0.10000E+01 465834.2 3768720.7 302.9 3.11 8.97 2.89 YES RVSD119 0 0.10000E+01 465834.1 3768740.0 303.1 3.11 8.97 2.89 YES RVSD120 0 0.10000E+01 465834.0 3768759.3 303.4 3.11 8.97 2.89 YES RVSD121 0 0.10000E+01 465833.9 3768778.6 303.7 3.11 8.97 2.89 YES RVSD122 0 0.10000E+01 465833.8 3768797.9 304.0 3.11 8.97 2.89 YES RVSD123 0 0.10000E+01 465833.7 3768817.1 304.3 3.11 8.97 2.89 YES RVSD124 0 0.10000E+01 465833.6 3768836.4 304.6 3.11 8.97 2.89 YES RVSD125 0 0.10000E+01 465833.5 3768855.7 304.9 3.11 8.97 2.89 YES RVSD126 0 0.10000E+01 465833.4 3768875.0 305.2 3.11 8.97 2.89 YES RVSD127 0 0.10000E+01 465833.3 3768894.3 305.5 3.11 8.97 2.89 YES RVSD128 0 0.10000E+01 465833.2 3768913.6 305.8 3.11 8.97 2.89 YES RVSD129 0 0.10000E+01 465833.1 3768932.9 306.1 3.11 8.97 2.89 YES *** AERMOD - VERSION 19191 *** *** Agua Mansa Industrial HRA *** 03/12/20 *** AERMET - VERSION 16216 *** *** *** 12:15:11 PAGE 13 *** MODELOPTs: RegDFAULT CONC ELEV URBAN ADJ_U* *** VOLUME SOURCE DATA *** NUMBER EMISSION RATE BASE RELEASE INIT. INIT. URBAN EMISSION RATE SOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT SY SZ SOURCE SCALAR VARY ID CATS. (METERS) (METERS) (METERS) (METERS) (METERS) (METERS) BY - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - RVSD130 0 0.10000E+01 465833.0 3768952.2 306.4 3.11 8.97 2.89 YES RVSD131 0 0.10000E+01 465832.9 3768971.4 306.7 3.11 8.97 2.89 YES RVSD132 0 0.10000E+01 465832.8 3768990.7 306.9 3.11 8.97 2.89 YES RVSD133 0 0.10000E+01 465832.7 3769010.0 307.2 3.11 8.97 2.89 YES RVSD134 0 0.10000E+01 465832.6 3769029.3 307.5 3.11 8.97 2.89 YES RVSD135 0 0.10000E+01 465832.5 3769048.6 307.7 3.11 8.97 2.89 YES RVSD136 0 0.10000E+01 465832.5 3769067.9 307.9 3.11 8.97 2.89 YES RVSD137 0 0.10000E+01 465832.4 3769087.2 308.2 3.11 8.97 2.89 YES RVSD138 0 0.10000E+01 465832.3 3769106.5 308.5 3.11 8.97 2.89 YES RVSD139 0 0.10000E+01 465832.2 3769125.8 308.7 3.11 8.97 2.89 YES RVSD140 0 0.10000E+01 465832.1 3769145.0 309.0 3.11 8.97 2.89 YES RVSD141 0 0.10000E+01 465832.0 3769164.3 309.3 3.11 8.97 2.89 YES RVSD142 0 0.10000E+01 465831.9 3769183.6 309.6 3.11 8.97 2.89 YES RVSD143 0 0.10000E+01 465831.8 3769202.9 309.8 3.11 8.97 2.89 YES RVSD144 0 0.10000E+01 465831.7 3769222.2 310.0 3.11 8.97 2.89 YES RVSD145 0 0.10000E+01 465831.6 3769241.5 310.3 3.11 8.97 2.89 YES RVSD146 0 0.10000E+01 465831.5 3769260.8 310.6 3.11 8.97 2.89 YES RVSD147 0 0.10000E+01 465831.4 3769280.0 310.8 3.11 8.97 2.89 YES RVSD148 0 0.10000E+01 465831.3 3769299.3 311.1 3.11 8.97 2.89 YES RVSD149 0 0.10000E+01 465831.2 3769318.6 311.4 3.11 8.97 2.89 YES RVSD150 0 0.10000E+01 465831.1 3769337.9 311.6 3.11 8.97 2.89 YES RVSD151 0 0.10000E+01 465831.0 3769357.2 311.9 3.11 8.97 2.89 YES RVSD152 0 0.10000E+01 465830.9 3769376.5 312.5 3.11 8.97 2.89 YES RVSD153 0 0.10000E+01 465830.8 3769395.8 313.2 3.11 8.97 2.89 YES RVSD154 0 0.10000E+01 465830.7 3769415.1 314.2 3.11 8.97 2.89 YES RVSD155 0 0.10000E+01 465830.6 3769434.3 315.5 3.11 8.97 2.89 YES RVSD156 0 0.10000E+01 465830.5 3769453.6 316.9 3.11 8.97 2.89 YES RVSD157 0 0.10000E+01 465830.4 3769472.9 318.3 3.11 8.97 2.89 YES RVSD158 0 0.10000E+01 465830.3 3769492.2 319.8 3.11 8.97 2.89 YES RVSD159 0 0.10000E+01 465830.2 3769511.5 321.2 3.11 8.97 2.89 YES RVSD160 0 0.10000E+01 465830.1 3769530.8 322.5 3.11 8.97 2.89 YES RVSD161 0 0.10000E+01 465830.0 3769550.1 323.7 3.11 8.97 2.89 YES RVSD162 0 0.10000E+01 465829.9 3769569.3 324.9 3.11 8.97 2.89 YES RVSD163 0 0.10000E+01 465829.8 3769588.6 325.8 3.11 8.97 2.89 YES RVSD164 0 0.10000E+01 465829.8 3769607.9 326.7 3.11 8.97 2.89 YES RVSD165 0 0.10000E+01 465829.6 3769627.2 327.5 3.11 8.97 2.89 YES RVSD166 0 0.10000E+01 465829.5 3769646.5 321.3 3.11 8.97 2.89 YES RVSD167 0 0.10000E+01 465829.5 3769665.8 319.7 3.11 8.97 2.89 YES RVSD168 0 0.10000E+01 465829.4 3769685.1 320.2 3.11 8.97 2.89 YES RVSD169 0 0.10000E+01 465829.3 3769704.4 320.6 3.11 8.97 2.89 YES *** AERMOD - VERSION 19191 *** *** Agua Mansa Industrial HRA *** 03/12/20 *** AERMET - VERSION 16216 *** *** *** 12:15:11 PAGE 14 *** MODELOPTs: RegDFAULT CONC ELEV URBAN ADJ_U* *** VOLUME SOURCE DATA *** NUMBER EMISSION RATE BASE RELEASE INIT. INIT. URBAN EMISSION RATE SOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT SY SZ SOURCE SCALAR VARY ID CATS. (METERS) (METERS) (METERS) (METERS) (METERS) (METERS) BY - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - RVSD170 0 0.10000E+01 465829.2 3769723.6 320.8 3.11 8.97 2.89 YES RVSD171 0 0.10000E+01 465829.1 3769742.9 320.8 3.11 8.97 2.89 YES RVSD172 0 0.10000E+01 465829.0 3769762.2 320.7 3.11 8.97 2.89 YES RVSD173 0 0.10000E+01 465828.9 3769781.5 324.0 3.11 8.97 2.89 YES RVSD174 0 0.10000E+01 465828.8 3769800.8 330.0 3.11 8.97 2.89 YES RVSD175 0 0.10000E+01 465828.7 3769820.1 328.5 3.11 8.97 2.89 YES OS2_01 0 0.10000E+01 465269.5 3765505.2 285.5 3.11 8.41 2.89 YES OS2_02 0 0.10000E+01 465253.5 3765513.7 283.5 3.11 8.41 2.89 YES OS2_03 0 0.10000E+01 465237.5 3765522.2 283.4 3.11 8.41 2.89 YES OS2_04 0 0.10000E+01 465221.6 3765530.7 283.8 3.11 8.41 2.89 YES OS2_05 0 0.10000E+01 465205.6 3765539.2 284.1 3.11 8.41 2.89 YES OS2_06 0 0.10000E+01 465189.7 3765547.7 284.4 3.11 8.41 2.89 YES OS2_07 0 0.10000E+01 465173.7 3765556.2 284.5 3.11 8.41 2.89 YES OS2_08 0 0.10000E+01 465157.7 3765563.2 284.6 3.11 8.41 2.89 YES OS2_09 0 0.10000E+01 465140.9 3765556.4 284.2 3.11 8.41 2.89 YES OS1_01 0 0.10000E+01 465021.5 3765632.8 285.1 3.11 8.95 2.89 YES OS1_02 0 0.10000E+01 465033.3 3765648.0 285.5 3.11 8.95 2.89 YES OS1_03 0 0.10000E+01 465045.1 3765663.2 285.6 3.11 8.95 2.89 YES OS1_04 0 0.10000E+01 465056.9 3765678.4 285.9 3.11 8.95 2.89 YES OS1_05 0 0.10000E+01 465068.7 3765693.6 285.9 3.11 8.95 2.89 YES OS1_06 0 0.10000E+01 465080.5 3765708.8 286.0 3.11 8.95 2.89 YES OS1_07 0 0.10000E+01 465092.3 3765724.0 286.1 3.11 8.95 2.89 YES OS1_08 0 0.10000E+01 465104.1 3765739.2 286.1 3.11 8.95 2.89 YES OS1_09 0 0.10000E+01 465118.3 3765742.3 286.2 3.11 8.95 2.89 YES OS1_10 0 0.10000E+01 465135.1 3765733.0 286.2 3.11 8.95 2.89 YES OS1_11 0 0.10000E+01 465151.9 3765723.6 286.4 3.11 8.95 2.89 YES OS1_12 0 0.10000E+01 465168.7 3765714.2 289.6 3.11 8.95 2.89 YES OS1_13 0 0.10000E+01 465185.5 3765704.8 289.8 3.11 8.95 2.89 YES OS1_14 0 0.10000E+01 465202.3 3765695.5 289.6 3.11 8.95 2.89 YES OS1_15 0 0.10000E+01 465206.4 3765682.6 289.5 3.11 8.95 2.89 YES OS1_16 0 0.10000E+01 465196.8 3765665.9 289.5 3.11 8.95 2.89 YES OS1_17 0 0.10000E+01 465187.2 3765649.2 286.7 3.11 8.95 2.89 YES OS1_18 0 0.10000E+01 465177.7 3765632.5 285.8 3.11 8.95 2.89 YES OS1_19 0 0.10000E+01 465168.1 3765615.8 285.4 3.11 8.95 2.89 YES OS1_20 0 0.10000E+01 465158.6 3765599.1 285.0 3.11 8.95 2.89 YES OS1_21 0 0.10000E+01 465149.0 3765582.4 284.6 3.11 8.95 2.89 YES OS1_22 0 0.10000E+01 465139.5 3765565.8 284.5 3.11 8.95 2.89 YES BRWN_01 0 0.10000E+01 465126.0 3765539.2 284.0 3.11 5.91 2.89 YES BRWN_02 0 0.10000E+01 465119.2 3765528.5 283.8 3.11 5.91 2.89 YES BRWN_03 0 0.10000E+01 465112.4 3765517.8 283.5 3.11 5.91 2.89 YES *** AERMOD - VERSION 19191 *** *** Agua Mansa Industrial HRA *** 03/12/20 *** AERMET - VERSION 16216 *** *** *** 12:15:11 PAGE 15 *** MODELOPTs: RegDFAULT CONC ELEV URBAN ADJ_U* *** VOLUME SOURCE DATA *** NUMBER EMISSION RATE BASE RELEASE INIT. INIT. URBAN EMISSION RATE SOURCE PART. (GRAMS/SEC) X Y ELEV. HEIGHT SY SZ SOURCE SCALAR VARY ID CATS. (METERS) (METERS) (METERS) (METERS) (METERS) (METERS) BY - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - BRWN_04 0 0.10000E+01 465105.6 3765507.0 283.2 3.11 5.91 2.89 YES BRWN_05 0 0.10000E+01 465098.8 3765496.3 283.0 3.11 5.91 2.89 YES BRWN_06 0 0.10000E+01 465092.0 3765485.6 282.8 3.11 5.91 2.89 YES BRWN_07 0 0.10000E+01 465085.2 3765474.9 282.6 3.11 5.91 2.89 YES BRWN_08 0 0.10000E+01 465078.4 3765464.1 282.4 3.11 5.91 2.89 YES BRWN_09 0 0.10000E+01 465071.6 3765453.4 282.2 3.11 5.91 2.89 YES BRWN_10 0 0.10000E+01 465064.8 3765442.7 282.0 3.11 5.91 2.89 YES BRWN_11 0 0.10000E+01 465058.0 3765431.9 281.8 3.11 5.91 2.89 YES BRWN_12 0 0.10000E+01 465051.2 3765421.2 281.6 3.11 5.91 2.89 YES BRWN_13 0 0.10000E+01 465044.4 3765410.5 281.4 3.11 5.91 2.89 YES BRWN_14 0 0.10000E+01 465037.6 3765399.7 281.2 3.11 5.91 2.89 YES BRWN_15 0 0.10000E+01 465030.8 3765389.0 280.9 3.11 5.91 2.89 YES BRWN_16 0 0.10000E+01 465024.0 3765378.3 280.8 3.11 5.91 2.89 YES BRWN_17 0 0.10000E+01 465017.2 3765367.5 280.5 3.11 5.91 2.89 YES BRWN_18 0 0.10000E+01 465010.4 3765356.8 280.3 3.11 5.91 2.89 YES BRWN_19 0 0.10000E+01 465003.6 3765346.1 280.1 3.11 5.91 2.89 YES BRWN_20 0 0.10000E+01 464996.8 3765335.3 279.9 3.11 5.91 2.89 YES BRWN_21 0 0.10000E+01 464990.0 3765324.6 279.7 3.11 5.91 2.89 YES BRWN_22 0 0.10000E+01 464983.2 3765313.9 279.6 3.11 5.91 2.89 YES BRWN_23 0 0.10000E+01 464990.5 3765306.1 279.4 3.11 5.91 2.89 YES BRWN_24 0 0.10000E+01 465001.0 3765298.9 279.2 3.11 5.91 2.89 YES BRWN_25 0 0.10000E+01 465011.5 3765291.7 279.0 3.11 5.91 2.89 YES BRWN_26 0 0.10000E+01 465022.0 3765284.6 278.7 3.11 5.91 2.89 YES BRWN_27 0 0.10000E+01 465032.5 3765277.4 278.6 3.11 5.91 2.89 YES BRWN_28 0 0.10000E+01 465043.0 3765270.3 278.3 3.11 5.91 2.89 YES BRWN_29 0 0.10000E+01 465053.5 3765263.1 278.1 3.11 5.91 2.89 YES BRWN_30 0 0.10000E+01 465064.0 3765255.9 277.9 3.11 5.91 2.89 YES BRWN_31 0 0.10000E+01 465074.5 3765248.8 277.7 3.11 5.91 2.89 YES BRWN_32 0 0.10000E+01 465085.0 3765241.6 277.5 3.11 5.91 2.89 YES BRWN_33 0 0.10000E+01 465095.5 3765234.4 277.3 3.11 5.91 2.89 YES BRWN_34 0 0.10000E+01 465106.0 3765227.3 277.2 3.11 5.91 2.89 YES BRWN_35 0 0.10000E+01 465116.5 3765220.1 277.0 3.11 5.91 2.89 YES BRWN_36 0 0.10000E+01 465127.0 3765213.0 277.0 3.11 5.91 2.89 YES BRWN_37 0 0.10000E+01 465137.5 3765205.8 277.2 3.11 5.91 2.89 YES BRWN_38 0 0.10000E+01 465148.0 3765198.6 277.3 3.11 5.91 2.89 YES BRWN_39 0 0.10000E+01 465158.5 3765191.5 277.6 3.11 5.91 2.89 YES *** AERMOD - VERSION 19191 *** *** Agua Mansa Industrial HRA *** 03/12/20 *** AERMET - VERSION 16216 *** *** *** 12:15:11 PAGE 50 *** MODELOPTs: RegDFAULT CONC ELEV URBAN ADJ_U* *** GRIDDED RECEPTOR NETWORK SUMMARY *** *** NETWORK ID: UCART1 ; NETWORK TYPE: GRIDCART *** *** X-COORDINATES OF GRID *** (METERS) 462761.4, 462961.4, 463161.4, 463361.4, 463561.4, 463761.4, 463961.4, 464161.4, 464361.4, 464561.4, 464761.4, 464961.4, 465161.4, 465361.4, 465561.4, 465761.4, 465961.4, 466161.4, 466361.4, 466561.4, 466761.4, *** Y-COORDINATES OF GRID *** (METERS) 3762278.8, 3762478.8, 3762678.8, 3762878.8, 3763078.8, 3763278.8, 3763478.8, 3763678.8, 3763878.8, 3764078.8, 3764278.8, 3764478.8, 3764678.8, 3764878.8, 3765078.8, 3765278.8, 3765478.8, 3765678.8, 3765878.8, 3766078.8, 3766278.8, 3766478.8, 3766678.8, 3766878.8, 3767078.8, 3767278.8, 3767478.8, 3767678.8, 3767878.8, 3768078.8, 3768278.8, 3768478.8, 3768678.8, 3768878.8, 3769078.8, 3769278.8, 3769478.8, 3769678.8, 3769878.8, 3770078.8, 3770278.8, *** AERMOD - VERSION 19191 *** *** Agua Mansa Industrial HRA *** 03/12/20 *** AERMET - VERSION 16216 *** *** *** 12:15:11 PAGE 63 *** MODELOPTs: RegDFAULT CONC ELEV URBAN ADJ_U* *** DISCRETE CARTESIAN RECEPTORS *** (X-COORD, Y-COORD, ZELEV, ZHILL, ZFLAG) (METERS) ( 464999.3, 3765575.9, 284.0, 365.1, 0.0); ( 465077.6, 3765525.9, 283.7, 365.1, 0.0); ( 465150.9, 3765487.6, 282.9, 365.1, 0.0); ( 465257.5, 3765419.4, 281.9, 365.1, 0.0); ( 465037.5, 3765934.7, 285.5, 285.5, 0.0); ( 465091.3, 3765945.8, 285.3, 285.3, 0.0); ( 465151.8, 3765942.5, 285.6, 285.6, 0.0); ( 465175.6, 3765936.4, 285.7, 285.7, 0.0); ( 465149.0, 3765915.3, 285.4, 285.4, 0.0); ( 465211.1, 3765939.1, 285.5, 285.5, 0.0); ( 465251.6, 3765943.6, 285.9, 285.9, 0.0); ( 465340.9, 3765932.5, 287.8, 287.8, 0.0); ( 465292.1, 3765933.6, 286.8, 286.8, 0.0); ( 465103.0, 3765882.6, 285.6, 285.6, 0.0); ( 465035.3, 3765902.0, 285.7, 285.7, 0.0); *** AERMOD - VERSION 19191 *** *** Agua Mansa Industrial HRA *** 03/12/20 *** AERMET - VERSION 16216 *** *** *** 12:15:11 PAGE 66 *** MODELOPTs: RegDFAULT CONC ELEV URBAN ADJ_U* *** UP TO THE FIRST 24 HOURS OF METEOROLOGICAL DATA *** Surface file: KRAL_v9.SFC Met Version: 16216 Profile file: KRAL_v9.PFL Surface format: FREE Profile format: FREE Surface station no.: 3171 Upper air station no.: 3190 Name: RIVERSIDE_AIRPORT Name: MIRAMAR_AIR_STATION Year: 2012 Year: 2012 First 24 hours of scalar data YR MO DY JDY HR H0 U* W* DT/DZ ZICNV ZIMCH M-O LEN Z0 BOWEN ALBEDO REF WS WD HT REF TA HT- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 12 01 01 1 01 -25.6 0.266 -9.000 -9.000 -999. 330. 77.9 0.15 2.40 1.00 2.93 55. 10.1 288.1 2.0 12 01 01 1 02 -26.8 0.277 -9.000 -9.000 -999. 351. 84.7 0.15 2.40 1.00 3.05 55. 10.1 287.0 2.0 12 01 01 1 03 -21.5 0.221 -9.000 -9.000 -999. 250. 53.5 0.15 2.40 1.00 2.45 74. 10.1 284.2 2.0 12 01 01 1 04 -22.0 0.227 -9.000 -9.000 -999. 260. 56.8 0.15 2.40 1.00 2.52 77. 10.1 285.9 2.0 12 01 01 1 05 -20.0 0.206 -9.000 -9.000 -999. 225. 46.8 0.15 2.40 1.00 2.30 80. 10.1 285.4 2.0 12 01 01 1 06 -14.4 0.171 -9.000 -9.000 -999. 170. 32.1 0.15 2.40 1.00 1.93 79. 10.1 287.0 2.0 12 01 01 1 07 -14.9 0.174 -9.000 -9.000 -999. 174. 33.2 0.15 2.40 1.00 1.96 77. 10.1 284.2 2.0 12 01 01 1 08 -11.9 0.169 -9.000 -9.000 -999. 167. 36.1 0.15 2.40 0.53 1.89 77. 10.1 288.1 2.0 12 01 01 1 09 40.4 0.234 0.359 0.006 40. 272. -28.1 0.15 2.40 0.31 2.10 81. 10.1 289.2 2.0 12 01 01 1 10 112.6 0.246 0.742 0.005 129. 293. -11.8 0.15 2.40 0.24 1.99 101. 10.1 296.4 2.0 12 01 01 1 11 161.0 0.402 1.188 0.005 369. 611. -35.6 0.15 2.40 0.21 3.68 78. 10.1 298.8 2.0 12 01 01 1 12 184.7 0.337 1.516 0.005 668. 473. -18.4 0.15 2.40 0.20 2.89 68. 10.1 300.4 2.0 12 01 01 1 13 183.9 0.310 1.809 0.005 1139. 414. -14.2 0.15 2.40 0.20 2.57 64. 10.1 302.5 2.0 12 01 01 1 14 156.6 0.374 1.852 0.005 1434. 549. -29.5 0.15 2.40 0.22 3.37 63. 10.1 303.1 2.0 12 01 01 1 15 104.3 0.382 1.658 0.005 1546. 567. -47.2 0.15 2.40 0.25 3.59 62. 10.1 302.5 2.0 12 01 01 1 16 31.8 0.374 1.123 0.005 1573. 550. -145.8 0.15 2.40 0.34 3.76 69. 10.1 300.9 2.0 12 01 01 1 17 -23.3 0.276 -9.000 -9.000 -999. 354. 84.0 0.15 2.40 0.62 3.03 59. 10.1 297.5 2.0 12 01 01 1 18 -21.5 0.229 -9.000 -9.000 -999. 264. 57.8 0.15 2.40 1.00 2.54 54. 10.1 295.4 2.0 12 01 01 1 19 -19.3 0.204 -9.000 -9.000 -999. 221. 45.6 0.15 2.40 1.00 2.27 79. 10.1 292.0 2.0 12 01 01 1 20 -20.7 0.218 -9.000 -9.000 -999. 244. 52.2 0.15 2.40 1.00 2.42 79. 10.1 292.5 2.0 12 01 01 1 21 -19.7 0.206 -9.000 -9.000 -999. 225. 46.9 0.15 2.40 1.00 2.30 95. 10.1 290.9 2.0 12 01 01 1 22 -17.6 0.190 -9.000 -9.000 -999. 199. 39.8 0.15 2.40 1.00 2.13 78. 10.1 290.4 2.0 12 01 01 1 23 -20.3 0.211 -9.000 -9.000 -999. 233. 49.0 0.15 2.40 1.00 2.35 52. 10.1 289.2 2.0 12 01 01 1 24 -16.4 0.183 -9.000 -9.000 -999. 189. 37.0 0.15 2.40 1.00 2.06 75. 10.1 288.8 2.0 First hour of profile data YR MO DY HR HEIGHT F WDIR WSPD AMB_TMP sigmaA sigmaW sigmaV 12 01 01 01 10.1 1 55. 2.93 288.2 99.0 -99.00 -99.00 F indicates top of profile (=1) or below (=0) *** AERMOD - VERSION 19191 *** *** Agua Mansa Industrial HRA *** 03/12/20 *** AERMET - VERSION 16216 *** *** *** 12:15:11
PAGE 9707
*** MODELOPTs: RegDFAULT CONC ELEV URBAN ADJ_U* *** Message Summary : AERMOD Model Execution *** --------- Summary of Total Messages -------- A Total of 0 Fatal Error Message(s) A Total of 986 Warning Message(s) A Total of 1638 Informational Message(s) A Total of 43848 Hours Were Processed A Total of 1039 Calm Hours Identified A Total of 599 Missing Hours Identified ( 1.37 Percent) ******** FATAL ERROR MESSAGES ******** *** NONE ***
******** WARNING MESSAGES ******** ME W186 2373 MEOPEN: THRESH_1MIN 1-min ASOS wind speed threshold used 0.50 ME W187 2373 MEOPEN: ADJ_U* Option for Stable Low Winds used in AERMET OU W565 2454 OUPLOT: Possible Conflict With Dynamically Allocated FUNIT PLOTFILE OU W565 2455 OUPLOT: Possible Conflict With Dynamically Allocated FUNIT PLOTFILE OU W565 2456 OUPLOT: Possible Conflict With Dynamically Allocated FUNIT PLOTFILE OU W565 2457 OUPLOT: Possible Conflict With Dynamically Allocated FUNIT PLOTFILE OU W565 2458 OUPLOT: Possible Conflict With Dynamically Allocated FUNIT PLOTFILE OU W565 2459 OUPLOT: Possible Conflict With Dynamically Allocated FUNIT PLOTFILE OU W565 2460 OUPLOT: Possible Conflict With Dynamically Allocated FUNIT PLOTFILE OU W565 2461 OUPLOT: Possible Conflict With Dynamically Allocated FUNIT PLOTFILE OU W565 2462 OUPLOT: Possible Conflict With Dynamically Allocated FUNIT PLOTFILE OU W565 2463 OUPLOT: Possible Conflict With Dynamically Allocated FUNIT PLOTFILE OU W565 2464 OUPLOT: Possible Conflict With Dynamically Allocated FUNIT PLOTFILE OU W565 2465 OUPLOT: Possible Conflict With Dynamically Allocated FUNIT PLOTFILE OU W565 OU W565 3421 PERPLT: Possible Conflict With Dynamically OU W565 OU W565 3422 PERPLT: Possible Conflict With Dynamically OU W565 OU W565 3423 PERPLT: Possible Conflict With Dynamically OU W565 OU W565 3424 PERPLT: Possible Conflict With Dynamically OU W565 OU W565 3425 PERPLT: Possible Conflict With Dynamically OU W565 OU W565 3426 PERPLT: Possible Conflict With Dynamically OU W565 OU W565 3427 PERPLT: Possible Conflict With Dynamically OU W565 OU W565 3428 PERPLT: Possible Conflict With Dynamically OU W565 OU W565 3429 PERPLT: Possible Conflict With Dynamically OU W565 OU W565 3430 PERPLT: Possible Conflict With Dynamically OU W565 OU W565 3431 PERPLT: Possible Conflict With Dynamically OU W565 OU W565 3432 PERPLT: Possible Conflict With Dynamically OU W565 OU W565 3433 PERPLT: Possible Conflict With Dynamically OU W565 OU W565 3434 PERPLT: Possible Conflict With Dynamically OU W565 OU W565 3435 PERPLT: Possible Conflict With Dynamically OU W565 OU W565 3436 PERPLT: Possible Conflict With Dynamically OU W565 OU W565 3437 PERPLT: Possible Conflict With Dynamically ************************************ *** AERMOD Finishes Successfully *** ************************************ HARP Project Summary Report 3/12/2020 10:06:12 AM
***PROJECT INFORMATION***
HARP Version: 19121
Project Name: HARP2
Project Output Directory: P:\CRN1801\HRA\Modeling\HARP2 HARP Database: NA
***POLLUTANT HEALTH INFORMATION***
Health Database: C:\HARP2\Tables\HEALTH17320.mdb
Health Table Version: HEALTH19252
Official: True
PolID PolAbbrev InhCancer OralCancer AcuteREL InhChronicREL OralChronicREL InhChronic8HRREL
___________________________________________________________________________________________________________________ _____________
9901 DieselExhPM 1.1 5
88101 PM25
106990 1,3-Butadiene 0.6 660 2 9
71432 Benzene 0.1 27 3 3
100414 Ethyl Benzene 0.0087 2000
78933 MEK 13000
91203 Naphthalene 0.12 9
115071 Propylene 3000
100425 Styrene 21000 900
108883 Toluene 37000 300
1330207 Xylenes 22000 700
HARP2 - HRACalc (dated 19044) 3/13/2020 11:30:21 AM - Output Log GLCs loaded successfully
Pollutants loaded successfully
Pathway receptors loaded successfully
**********************************

RISK SCENARIO SETTINGS
Receptor Type: Resident
Scenario: All
Calculation Method: Derived
**********************************

EXPOSURE DURATION PARAMETERS FOR CANCER
Start Age: -0.25
Total Exposure Duration: 30
Exposure Duration Bin Distribution
3rd Trimester Bin: 0.25
0<2 Years Bin: 2
2<9 Years Bin: 0
2<16 Years Bin: 14
16<30 Years Bin: 14
16 to 70 Years Bin: 0
**********************************

PATHWAYS ENABLED
NOTE: Inhalation is always enabled and used for all assessments. The remaining pathways are only used for cancer and noncancer chronic assessments.

Inhalation: True
Soil: True
Dermal: True
Mother's milk: True
Water: False
Fish: False
Homegrown crops: True
Beef: False
Dairy: False
Pig: False
Chicken: False
Egg: False
**********************************

INHALATION
Daily breathing rate: RMP
**Worker Adjustment Factors**
Worker adjustment factors enabled: NO
**Fraction at time at home**
3rd Trimester to 16 years: OFF
16 years to 70 years: OFF
**********************************

SOIL & DERMAL PATHWAY SETTINGS
Deposition rate (m/s): 0.02
Soil mixing depth (m): 0.01
Dermal climate: Warm
**********************************

HOMEGROWN CROP PATHWAY SETTINGS
Household type: HouseholdsthatGarden
Fraction leafy: 0.137
Fraction exposed: 0.137
Fraction protected: 0.137
Fraction root: 0.137
**********************************
TIER 2 SETTINGS
Tier2 not used.
**********************************
Calculating cancer risk
HRA ran successfully
HARP2 - HRACalc (dated 19044) 3/13/2020 1:44:48 PM - Output Log GLCs loaded successfully
Pollutants loaded successfully
Pathway receptors loaded successfully
**********************************

RISK SCENARIO SETTINGS
Receptor Type: Resident
Scenario: NCChronic8HR
Calculation Method: Derived
**********************************

EXPOSURE DURATION PARAMETERS FOR CANCER
**Exposure duration are only adjusted for cancer assessments** **********************************

PATHWAYS ENABLED
NOTE: Inhalation is always enabled and used for all assessments. The remaining pathways are only used for cancer and noncancer chronic assessments.

Inhalation: True
Soil: False
Dermal: False
Mother's milk: False
Water: False
Fish: False
Homegrown crops: False
Beef: False
Dairy: False
Pig: False
Chicken: False
Egg: False
**********************************

INHALATION
Daily breathing rate: RMP
**Worker Adjustment Factors**
Worker adjustment factors enabled: NO
**Fraction at time at home**
NOTE: Exposure duration (i.e., start age, end age, ED, & FAH) are only adjusted for cancer assessments.
**********************************
TIER 2 SETTINGS
Tier2 not used.
**********************************
Calculating chronic 8hr risk
Chronic 8-hr risk breakdown by pollutant and receptor saved to:

P:\CRN1801\HRA\Modeling\HARP2\hra\8 Hr - NCChronic8HrRisk.csv Chronic 8-hr risk total by receptor saved to: P:\CRN1801\HRA\Modeling\HARP2\hra\8 Hr - NCChronic8HrRiskSumByRec.csv
HRA ran successfully
HARP2 - HRACalc (dated 19044) 3/13/2020 11:26:56 AM - Output Log GLCs loaded successfully
Pollutants loaded successfully
Pathway receptors loaded successfully
**********************************

RISK SCENARIO SETTINGS
Receptor Type: Worker
Scenario: All
Calculation Method: Derived
**********************************

EXPOSURE DURATION PARAMETERS FOR CANCER
Start Age: 16
Total Exposure Duration: 25
Exposure Duration Bin Distribution
3rd Trimester Bin: 0
0<2 Years Bin: 0
2<9 Years Bin: 0
2<16 Years Bin: 0
16<30 Years Bin: 0
16 to 70 Years Bin: 25
**********************************

PATHWAYS ENABLED
NOTE: Inhalation is always enabled and used for all assessments. The remaining pathways are only used for cancer and noncancer chronic assessments.

SOIL & DERMAL PATHWAY SETTINGS
Deposition rate (m/s): 0.02
Soil mixing depth (m): 0.01
Dermal climate: Warm
**********************************

HOMEGROWN CROP PATHWAY SETTINGS
Household type: HouseholdsthatGarden
Fraction leafy: 0.137
Fraction exposed: 0.137
Fraction protected: 0.137
Fraction root: 0.137
**********************************
TIER 2 SETTINGS
Tier2 not used.
**********************************
Calculating cancer risk
HRA ran successfully
Attachment B: Memorandum from Chris Schulze to
Terry Johnson (May 17. 2023)
Memo To: Terry Johnson, Best Development Group
From: Chris Schulze – President, TSD Engineering, Inc.

CC: Jim Moose, RMM Environmental Law
Date: May 17, 2023
Re: Grocery Outlet – Fort Bragg CA – Design Development and Programing for Site Lotting Study
TSD has been involved in the subject project and the development of the site starting in January 2019. With the development of the Grocery Outlet and the current site plan layout, including building placement and parking lot orientation, several factors have been evaluated prior to final design decisions in developing a site plan. The process of the early conceptual planning phase is typically what TSD identifies as Design Development and Programming phase and below is a short list of factors that influenced the development of the site plan.  Tenant Specifications and Requirements
 General Plan & Zoning Code Requirements
 Surrounding Zoning
 Surrounding existing and proposed land use.
 California Building Code
 Surveying information to include easements and/or development restrictions.  Physical features of the property
 Utility Infrastructure
 Pre-Application Meetings with City
TSD has revisited our design notes, as applicable to the civil engineering elements, in the design development and programming process and has summarized our findings that support the iterations of the site plan that have led to the current site layout.  Subject Property has a relatively deep and narrow lot configuration and does not meet Grocery Outlet Prototypes. Modification to the Grocery Outlet Building Prototype was required.
 Ensure Setbacks are identified and satisfied.
 Key factor that was considered early on was the location/operation of the Truck Dock and loading area.
o Truck Dock/Loading Area needed to be placed in location as not visible from the adjacent streets and most specifically from the residential property to the east…requires the truck dock to be placed on western edge of property TSO ENGINEERING, INC.
expect more.
785 Orchard Drive, Suite 110, Folsom, CA 95630 P 916.608.0707 F 916.608.0701 I expect more.
 Page 2
and use building to screen the truck dock and loading areas to minimize visibility and acoustical factors.
o Truck Dock being placed immediately adjacent to the existing Motel Use on the adjacent property to the east was a concern and was one of the factors that led to the Building Placement to be located adjacent to South Street and such the Truck Dock and Loading Area would be adjacent to a vacant property with commercial zoning.
 Subject Property is currently developed, and existing utility infrastructure (water, sewer, electricity, telephone, and communications) is all served and located within South Street. With most of the utility infrastructure to serve Grocery Outlet coming from South Street this was also a factor in the Building Placement to be located adjacent to South Street.
 South Franklin Street and North Harbor Street have an acute angle at the intersection. Based on the non-perpendicular acute angle of street alignments this would require building placement on North Harbor Drive to setback further into the property to maintain the required 20-foot building setback.

Attachment C: Letter from Devon Patel, Manager of
Super 8 Motel to City Council (May 27, 2023)
Dear Fort Bragg City Council and Planning Commission,
I manage the Super 8 Hotel on Main Street.

I understand that a vote will be taken on the Grocery Outlet application on the June 5,2023.

At the Super 8, I have a front row window to what happens here in Fort Bragg. As you know, we are located on Main Street/Hwy 1, we expect noise. We are surrounded by businesses of all kinds, other hotels, gas station, pizza place, a huge Safeway is down the road and more. We are a mixeduse area. I do not expect the traffic or the noise to be any different when a Grocery Outlet is here.

We are a small town with a small population base. I do think it would be much safer and nicer to have a clean, new Grocery Outlet where my guests can conveniently shop. The current building on the site is neglected and has safety issues, as well as it is a magnet for homeless. I know other nearby owners frequently call the police regarding illegal activity on that site. I want to help the homeless in town, however, I would rather my guests who are here on vacation could be spared seeing some of the irregular activity, or safety concerns.

There have been complaints from locals about the trucks that park occasionally on the applicant's lot. Many of those drivers sleep at my Hotel. They bring food to the City of Fort Bragg, which I think is essential. Moreover, many of the houses on S. Franklin are across from commercial buildings.

They understand there will always be some level of noise and activity. I do not think it will be as extreme as some describe.

We are working hard to remodel our Super 8 hotel. I am grateful to serve out-of-towners who contribute so much to the local economy and to those who may be temporarily in need of a clean room due to unforeseen circumstances. We think it will be a better experience for our guests and will help to beautify the area. A new Grocery Outlet store would give this part· of Fort Bragg a visual and safety boost. It may also mean less driving to Willits or Ukiah to shop for food for my family and the hotel.

Lastly, I understand an accommodation has been made and a cement wall will go up between our Super 8 and the new Grocery Outlet store. Thank you for making that accommodation. Please approve this project/application. Thank you for your consideration.

Devon Patel, General Manager ~
Super 8 Fort Bragg California
888 S. Main Street, Fort Bragg, CA 95437 • 707-964-4003 \
f
l
From: Jacob Patterson
To: City Clerk
Cc: cdd
Subject: Another comment for the GrocOut public hearing on the 5th Date: Wednesday, May 31, 2023 10:04:25 AM
City Council,
I recommend one or more of you have someone on the City's legal team provide advice on the following procedural concerns:

It appears the City didn't have the school district review the DEIR as a responsible agency (and there might even be a requirement to do so).

It appears that Davey Beak/AH wasn't consulted concerning the project's potential impacts on the ambulance service.

It appears that Caltrans wasn't consulted concerning the traffic analysis even though it was explicitly changed from the earlier approved but cancelled application to reflect allegedly permissible left turns off of N. Harbor Drive. However, it is not clear that Caltrans actually authorized left turns at N. Harbor Drive and there is some evidence to suggest they did not authorize them and someone else removed the sign at some point.

Doing these entitlement reviews for what is a fairly significant project by Fort Bragg standards should involve truly-informed decision making and when we forget to seek the input of community stakeholders like the school district or the emergency services at our nearby hospital we undermine that critical piece of every review.

Regards,
--Jacob
•
•
•
From: Jacob Patterson
To: City Clerk
Cc: cdd
Subject: Comment for 6/5/2023 PC Public Hearing on Grocery Outlet Project Date: Tuesday, May 30, 2023 12:54:03 PM
City Council,
The Planning Commission recommended approval of the Grocery Outlet project and incorporated many special conditions to try to make this project consistent with our certified LCP. I want to suggest some additional language for the City Council's consideration for the meeting on the 5th.

Specifically, I want to be sure the new special condition requiring preservation of the existing healthy mature trees along the northern segment of the west side of the project site. I want to ensure that it not only preserves the trees but that they are explicitly protected from damage during demolition and construction activities with best management practices (BMPs) like creating a root protection zone that prohibits any heavy equipment or materials storage within the protection zones (usually the tree canopy drip line plus 5 feet out), only permitting hand excavations or air spades that keep the root structures intact within the protection zone. It should explicitly prohibit severing roots bigger than one (1) inch in diameter as well. I also want to be sure that any trees (either new ones planted as part of the project or the existing trees along the northern portion of the western boundary of the project site facing Chevron) are not only planted and retained but that if any trees die, they have the affirmative duty to not only install and maintain the landscaping as approved but they also need to replace anything that dies within a year of the plant's death and for replacement trees to be planted at a rate that ensures the existing canopy cover is effectively replaced within 5 years of replanting, which might mean a greater number of replacement trees than the one(s) that may die.

The other special condition I want to suggest revising is the one that addresses the east and north facades. Staff originally recommended a second special condition addressing the west facade too but it wasn't adopted because the PC mistakenly thought the west facade was blocked already by the motel, which is only true for about 2/3rds of the west facade. That special condition should be revised to include the west facade (at the same location where the trees are) because it will actually be visually prominent from Main Street. I recommend extending the hardie board over the CMU on just that visible portion of the west elevation in addition to the east and north facades. (Interestingly, the west facade was left out of any of the visual analysis simulated depictions and I think a visual simulation of the west facade, including the existing boundary trees to be retained, should be created and presented on the 5th along with the other three facades that were already simulated.

You might want to consider another new special condition as well as revising the two special conditions mentioned above. Last time, the PC added a unique special condition that required any future sign requests to be presented back to the PC rather than staff over the counter because many people thought the real reason that GrocOut wants to be at the far north of the project site is so that west facade is visible from Main Street and they may want to add another sign up there so drivers on Main can see that there is a GrocOut when they drive down Main Street. We don't want a bait-and-switch or bifurcated review situation where the applicant suggests they only want the parking lot freestanding sign and one over the Franklin Street entrance when they likely want another (ugly and formulaic) sign on the visually prominent west facade. I would add a special condition prohibiting any future signs other than the two approved as part of this application, which wouldn't actually prohibit such signs but it would require GrocOut to apply for a CDP amendment and sign permit if they want to add another sign at a future date that would happen in a public context rather than over-the-counter. Last time the PC just required that it would come to them so the public and the PC would be able to know and potentially say no to a visually offensive sign on the west facade, which is the same basic result either way it is drafted.

Best,
--Jacob
From: Emerald Dolphin
To: City Clerk
Subject: Grocery Outlet coming to Fort Bragg
Date: Sunday, May 28, 2023 3:55:28 PM
Dear City Clerk,
As a long time business of this community, we at Emerald Dolphin Inn & Mini Golf would very much like to see a Grocery Outlet in Fort Bragg. This would be a great asset to our community in so many ways. It would bring many long term jobs for locals as well as many temporary jobs while it's being built. We don't believe it will impact traffic because any of the patrons will be locals and visiting tourists that will already be in Fort Bragg. Another positive thing about Grocery Outlet is that it not only has less expensive food and beverages but also offers many household goods and sundries. We are all for a Grocery Outlet in beautiful Fort Bragg!
Kind Regards,
Emerald Dolphin Inn & Mini Golf
1211 S Main Street, Fort Bragg, CA. 95437
tele: 707.964.6699 fax: 707.962.0338
www.emeralddolphin.com
[email protected]
From: Sherry Fischer
To: City Clerk
Subject: Grocery outlet
Date: Friday, May 26, 2023 9:05:32 AM
I want to voice my support for the Grocery Outlet , we need this in our community.

Sherry Fischer
Fort Bragg Ca.

Sent from my iPad
From: Paul Clark
To: Lemos, June
Cc: Paul Clark
Subject: June 5 City Council Grocery Outlet
Date: Saturday, May 27, 2023 9:30:27 AM
Please count me as a supporter of this project. As I have spoken several times before, this company has tried to come to Fort Bragg for years and years, and should be welcomed in to the community. A few folks that don’t want any new development should not outweigh the needs of the community in general.

This old building has the chance to be demolished and start a new asset to the community.

Thank you.

Paul Clark
DRE 00640014
809 North Main Street
Fort Bragg, CA 95437
707-964-0811
[email protected]
From: Edward Oberweiser
To: cdd; City Clerk
Subject: Re: Letter re:The Grocery Outlet proposal
Date: Wednesday, May 31, 2023 7:30:30 AM
Dear folk
Here is a better version of my letter re: the Grocery Outlet project.

Ed Oberweiser
Dear City Development Department and City Clerk 5/31/23 I am a regular cyclist and one of the founding members of Seniors On Bikes Fort Bragg. I regularly
ride my bicycle from my home off Benson Lane down highway 20 towards Highway 1. I am a consistent user of the both the South and North Coastal Trails.

Also,
more people are riding bicycles due to being unemployed and the economic effect of Covid on the
economy.Many of these new cyclists are extremely inexperienced in riding in traffic with automobiles.

I am a very experienced bicyclist having worked for 6.5 years at a bicycle delivery business in Santa Barbara, CA which has a higher population than all of Mendocino County. I have also ridden
a bicycle from Eugene Oregon to Santa Barbara CA. I have also participated in the Konocti Challenge five times. The first two times i rode in the metric century option there.

It has already become too dangerous for me to ever attempt to attempt the entrance to the Southern Coastal trail from Highway 1 just north of the Noyo River Bridge. I recently had an accident while attempting to do so and had a head injury even though I was wearing a helmet.

I
blacked out and had to be helicoptered to a hospital in Santa Rosa.

As a result, I never attempt to enter the trail at that point. I now always go to the Cypress Street intersection with Highway 1. Traffic will increase there as well due to the Grocery Outlet
project as outlined in the draft EIR. This will make a trip to the Adventist Hospital more full of traffic
and will increase traffic and its pollution for many residents in the housing areas along the way there.

The Grocery Outlet project will increase automobile traffic in Fort Bragg in general.

Especially
during the tourist season. This traffic has already increased due to global climate change making
the weather drier and hotter inland from our coast.

Edward M. Oberweiser
19244 Benson Lane
Fort Bragg, CA
707-964-7065
On Wed, May 31, 2023 at 7:26 AM Edward Oberweiser <[email protected]> wrote:

From: Jacob Patterson
To: City Clerk
Subject: Re: Public Comment -- 6/5/2023 CC Special Meeting, GrocOut Special Conditions Date: Wednesday, May 31, 2023 2:53:30 PM
City Council,
I forgot to include the Planning Commission's special condition about the signage from the last review. I think you should consider adding a similar special condition to this potential approval as well.

Last time the Planning Commission included the following as Special Condition 20: "A separate sign permit from the City of Fort Bragg will be required for this project. This sign and any future sign permits for this site shall be reviewed and approved by the Planning Commission."
I recommend a shortened version because I think the two proposed signs are part of the review and potential approval this time, which is proper since concurrent processing by the same review authority of all necessary permits for the entire project is required by our code. The shortened version would read "Any future sign permits for this site shall be reviewed and potentially approved by the Planning Commission" or "Additional signs besides the single free-standing monument sign in the parking lot area and a wall-mounted sign above the building entrance are prohibited and any additional signs will require a CDP amendment and sign permit, which shall be reviewed and potentially approved by the Planning Commission".

The reason for this special condition is to avoid the possibility of additional, potentially objectionable signs being added to this project without any public notice or hearings because simple sign permits are handled administratively by staff over-the-counter. This special condition would avoid the applicant holding off and trying to process additional sign permit applications at the staff level without public notice or the opportunity to be heard.

Best,
--Jacob
On Wed, May 31, 2023 at 2:27 PM Jacob Patterson <[email protected]> wrote:

City Council,
Please consider the following suggested revisions to the draft special conditions recommended by the Planning Commission for the Grocery Outlet project. I already commented about why I think these (or similar) revisions are justified in my prior comment but the specific language I recommend is attached in both Word and PDF. The blue italicized content represents the changes made by Marie and approved during the Planning Commission's public hearing. The redlines are my suggested revisions for your consideration based on the PC's resolution that will be in the published agenda materials for your public hearing.

Best,
--Jacob
______________________________________________________________________ Special Condition 1: The applicant shall resubmit the landscaping and parking plans for Community Development Director approval. The revised parking and landscaping plan shall:
a) Delete the two parking spaces on the southwest corner of the parking lot and replace this area with native plant landscaping.,.~ b) Eliminate the excess RV parking space, and to the degree feasible replace a portion of it with native plant landscaping.,.~
c) Contain drought tolerant native species;
s:!l_Preserve and protect the existing Monterey Cypress +F&66-and the Shore Pine trees on site, as-to the maximum extent feasible and employing BMPs -aRd /including installing protective fencing around a tree protection zone for each existing tree established at five (5) feet out from the tree canopy drip line prior to and during any demolition or construction activities prohibit any material storage or heaw equipment storage or operation within the tree protection zones inside of which all work will be performed by hand tools or air spades to avoid damage to the root structures of the trees and prohibiting cutting or severing any root of the existing trees with a diameter of one (1J inch or more· G)e...l.._____B_eplace the proposed Monterey Cypress Trees in the Lanci-,i;§i'aping Plan with a locally native tree species.,.~
n_comply with the California Model Water Efficient Landscape Ordinance (MWELO);_fil]Q
e¾J) Require the ongoing maintenance and replacement of any existing retained or newly-planted trees in the Landscaping Plan that may die during project construction or thereafter such replacement planting is required within one (1) year of the tree's death with replacement tree(s) of the same or substantially similar species as the dead tree at a ratio that will replace the prior canopy coverage of the dead removed tree(s) within five (5) years based on the size of the canopy prior to the tree's death the standard predicted canopy growth rate of that species of tree and the initial planting size of the replacement tree(s). ~Special Condition 23: To the extent otherwise permitted by the CLUDC the windows on the south side of the building may be
obscured with murals or other films or coverings so long as they don't limit passive solar gain.

GptioRal Spasial CoRBitiOR 25: Tho appliGaRt shall F8plaGB~8"8F all GMI, Blasl< OR the west fase sf the 81:1iletiR§ ..,ith har8il3saFet ssm13ssite "'998 13aReliR!l Special Condition 34: The applicant shall install either an all-way stop or a walker:
triggered flashing lights, as recommended by a traffic engineer, at the intersection of South Franklin St. and South St., including signage, striping , and pedestrian facilities (sidewalk, curb, and gutter) to provide protected crossing at all legs of the intersection.

The proposed intersection improvement would require the installation of sidewalk curb and gutter to City Standard Specifications for a total length of 57 linear feet along the east side of South Franklin St. as well as a curb return to provide sufficient pedestrian landing facilities on the south-east comer of the intersection. Off-site improvements shall be completed prior to issuance of final certificate of occupancy .

From: Greg Burke
To: Lemos, June
Subject: Vote yes for Grocery Outlet
Date: Friday, May 26, 2023 12:07:33 PM
Dear City Council Members;
Over 2 years ago I wrote a letter in support of Grocery Outlet. My feelings have not changed but I will provide a shorter version of that same letter:

We need more affordable shopping options for seniors and younger families with children along with many others.

Promote affordable living needs, as they go hand in hand with affordable housing.

Having another store will help our area when the next rolling blackout, pandemic or natural disaster happens. Essentially we are an island and will need more resources for our community in any challenging time.
2 years ago my letter said prices will continue to grow higher and higher, and that sure happened. Having options helps promote healthy competition, which in turn helps those most in need.

It’s time to think of what’s best for the many, whose voices may not be heard, and not for just the few.

Thank you for your consideration.

Greg Burke

Special City CouncilJune 5, 2023

Special City Council
June 5, 2023