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The City’s reliance on a CEQA Checklist to exempt the Project from further CEQA review under CEQA Guidelines 15183 and 15162 is improper and not supported by substantial evidence because the Project has significant project- specific impacts that are peculiar to the Project, were not analyzed in the General Plan EIR, were not know and could not have been known when the 2011 General Plan EIR was certified, and are more severe than previously analyzed. These impacts are not fully mitigated by the General Plan EIR mitigation measures or the City’s Standard Development Requirements (“SDRs”) and therefore require disclosure and additional mitigation in a project-level EIR.
The Response to Appeal provided by the Applicant purports to respond to EBRRD’s issues raised on appeal. The Applicant’s conclusion that “the CEQA document is both valid and supported by substantial evidence” is incorrect.37 EBRRD’s comments on Appeal and to the Zoning Administrator stand and are supplemented herein with the following supplemental comments. EBRRD’s comments on Appeal and to the Zoning Administrator demonstrate that substantial evidence supports preparation of a project-level EIR in this instance. East Bay Residents urges the Planning Commission to uphold its Appeal, reverse the Zoning Administrator’s approval of the Project, and require staff to prepare an EIR to address the adverse environmental effects of the Project which were not adequately examined in the prior EIR.
V. THE PROJECT RESULTS IN SIGNIFICANT, UNMITIGATED
WATER SUPPLY IMPACTS
The CEQA Checklist’s Water Supply and Treatment Section fails to adequately disclose, analyze, and mitigate the Project’s potentially significant impacts to water supply. The City did not prepare a water supply assessment, nor has the ACWD provided a “will-serve” letter demonstrating the quantity and availability of water for the Project. Rather the District has indicated that “additional requirements, including preparation of a Water Supply Assessment (WSA), may be necessary.”
38 East Bay Residents submitted a Public Records Act request to ACWD. The District provided no documentation showing that the Project will be adequately served by District resources, nor is any such evidence in the CEQA Checklist or City records. The record before the Commission therefore lacks substantial evidence or any affirmative commitment from the District that the Project can be adequately served by the District’s water supply. This lack of analysis and supporting
37 Appeal Response Letter, p. 1.
38 See Exhibit A, p. 2, citing 10/12/2021 email from District to City staff re Project water supply.
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documentation violates both CEQA and related provisions in the California Water Code.39
When an agency determines that a project is subject to CEQA, it must comply with the provisions of California Water Code, sections 10910 to 10915, concerning water supply assessments.40 The CEQA Guidelines, section 15155 contain additional, specific requirements for “water demand projects.” Per CEQA Guidelines, section 15155(a)(1)(A)-(D) “A ‘water-demand project’ means … [a] shopping center or business establishment employing more than 1,000 persons or having more than 500,000 square feet of floor space … [a] commercial office building employing more than 1,000 persons or having more than 250,000 square feet of floor space…[or a] hotel or motel, or both, having more than 500 rooms.
41 If a project meets the criteria for a “water demand project,” the lead agency must take the following steps: identify the water system that will supply the water; request that the agency identify if the project was included in a recent Urban Water Management Plan (“UMP”) and if so, analyze the project under that plan; and depending on the circumstances, either the lead agency or the water district must prepare an water supply assessment consistent with the requirements of the Water Code, section 10910 to 10915.42
Regarding the sufficiency and specificity required for a water supply assessment, the CEQA Guidelines, section 15155(f) states that:
(f) [the] degree of certainty regarding the availability of water supplies will vary depending on the stage of project approval. A lead agency should have greater confidence in the availability of water supplies for a specific project than might be required for a conceptual plan (i.e. general plan, specific plan). An analysis of water supply in an environmental document may incorporate by reference information in a water supply assessment, urban water management plan, or other publicly available sources. The analysis shall include the following:
(1) Sufficient information regarding the project's proposed water demand and proposed water supplies to permit the lead agency to
39 See generally, CEQA Guidelines, § 15155; Wat. Code, § 10910 et seq. 40 Pub. Resources Code, § 21151.9 (“projects” under CEQA are subject to the provisions of the Wat.
Code, §§ 10910-10915); Wat. Code, § 10910(a) (same).
41 CEQA Guidelines, § 15155 (a)(1), (a)(1)(B)- (D) (emphasis added). 42 See generally, CEQA Guidelines, § 15155 ; see also Wat. Code, § 10910 et seq.
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evaluate the pros and cons of supplying the amount of water that the project will need.
(2) An analysis of the reasonably foreseeable environmental impacts of supplying water throughout all phases of the project. (3) An analysis of circumstances affecting the likelihood of the water's availability, as well as the degree of uncertainty involved.
Relevant factors may include but are not limited to, drought, salt- water intrusion, regulatory or contractual curtailments, and other reasonably foreseeable demands on the water supply.
43 In addition, Water Code Sections 10910(b), (c), (d) outline the specific requirements for the contents and sufficiency of a water supply assessment. A compliant water supply assessment must include, inter alia, an assessment of water supply during normal, single dry and multiple dry years and “proof” of legal entitlement to the water required for the project under all scenarios.44 Further data and analysis is required if the project will use groundwater.45 A. The Project Requires a Water Supply Assessment
The Project fulfills the criteria for a “water demand” project under CEQA and the Water Code provisions apply. The Project is a “industrial, manufacturing, or processing plant, or industrial park planned to house more than 1,000 persons, occupying more than 40 acres of land, or having more than 650,000 square feet of floor area.”
46 Because of its proposed use as a “research and development manufacturing/office campus totaling approximately 450,420 square feet of building area,”47 the Project also qualifies as a “commercial office building employing more than 1,000 persons or having more than 250,000 square feet of floor space.”48
A total of 1,379 vehicle parking spaces would be provided for the Project.49 The Project would generate approximately 4,512 average daily trips according to the CEQA Checklist and Transportation Demand Management Plan.50 The City
43 CEQA Guidelines, § 15155(f) (emphasis added) ; see also see also Vineyard Area Citizens for Responsible Growth, Inc. v. City of Rancho Cordova (2007) 40 Cal.4th 412. 44 See generally, Wat. Code, § 10910(d).
45 Wat. Code, § 10910(f).
46 CEQA Guidelines, 15155(a)(1) .
47 CEQA Checklist, p. 10 (emphasis added).
48 CEQA Guidelines, § 15155 (a)(1), (a)(1)(B)- (D) (emphasis added). 49 CEQA Checklist, p. 16.
50 Ardenwood R&D Industrial Development Transportation Demand Management Plan Prepared for: The City of Fremont (March 3, 2023) .
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required the Project Applicant to utilize the industrial parking standard, which provides one stall per 450 SF of building area, or one space per every two employees.51 If the Project provides 1,379 spaces at a rate of one space for every two employees, that constitutes 2,758 employees that will utilize the Project site.
The Project will therefore reasonably exceed the 1,000-employee minimum requirement for preparation of a Water Supply Assessment, and exceeds the 250,000 SF threshold for office buildings.
The CEQA Checklist does not clarify how many employees will be employed on the Project site because the Project is being built on a speculative basis.
However, since the Project is being built to facilitate over 1000 employees, the City must analyze the Project’s reasonably foreseeable impacts based on the Project’s proposed design.
At the October 15, 2024 Zoning Administrator hearing, the Applicant did not provide evidence that fewer than 1000 employees would be housed onsite, nor does the Project include a condition of approval restricting use to less than 1000 employees. 52 The Zoning Administrator contemplated that a water supply assessment may be required at a later date given the Project’s speculative end user and lack of certainty regarding the maximum employees onsite. The Zoning Administrator discussed requiring the Applicant to comply with a consent decree to keep the number of employees under 1,000, but the record before the Commission contains no such consent decree or minimum employee requirement to ensure fewer than 1,000 employees will be located onsite. There is no evidence in the record before the Commission supporting the Applicant’s claim that the Project will have less than 1,000 employees, and there is substantial evidence demonstrating that Project operations are likely to exceed 1,000 employees. Given that the Project may exceed 1,000 employees and exceeds 250,000 SF, a water supply assessment must be prepared.
The 2011 General Plan Public Facilities Element provides that there is substantial uncertainty in the ongoing reliability of ACWD’s water supply sources.
The Public Facilities Element provides that “Local Supplies will also see reliability impacts from operational and facility modifications to accommodate on-going Alameda Creek fishery restoration efforts. Upstream land use, flood control and water supply projects in the Alameda Creek Watershed may also impact this supply. Similarly, efforts to develop groundwater supplies by agencies in the South East Bay Plain (north of ACWD) may also impact ACWD’s groundwater supply
51 See Exhibit D - Letter from Evan Sockalosky, ARC TEC to City of Fremont (Dec. 18, 2023). 52 City of Fremont Zoning Administrator Hearing, Development Services Center, Niles Conference Room (Oct. 15, 2024 at 3:00 PM).
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availability. However, the extent of these impacts on ACWD’s local supplies, if any, is not currently known.”53 Given the General Plan’s recognition that there remains substantial uncertainty as to available water supply, the City must prepare an EIR to analyze the current water supply impacts of the Project. As part of that analysis, a water supply assessment must be prepared to confirm whether ACWD has adequate water supply to support the Project, and if not, to identify and secure alternative water supply resources. The City must work with ACWD to prepare a Water Supply Assessment before the Project is approved, in order to ensure that the Project complies with CEQA and the Water Code.
Juniet Rotter, the Development Services Manager of the Alameda County Water District provided the following comments to the Project Planner Mark Hungerford on October 12, 202154:
• The notice indicates the project calls for a six-building campus for R&D manufacturing and office buildings and the renovation of an existing one- story high bay manufacturing building. Prior to approving/providing water service, ACWD requests the applicant provide a description of the type of R&D manufacturing anticipated, number of employees proposed and the anticipated water demand for the operation at the buildings. Depending on the type of manufacturing, occupancy number and water demand, additional requirements, including preparation of a Water Supply Assessment (WSA), may be necessary…
• It is not clear from the plans if the parcels for Buildings 2,3,4 and 5 will be combined into one parcel. If these parcels will be combined into one parcel, the proposed is acceptable for the private fire hydrants. If the parcels will not be combined into one parcel and will remain individual parcels, ACWD advises that the proposed buildings have their own fire hydrants from a new service, not connected to the private fire line serving the private fire hydrants on the other parcels. This will eliminate any issues in the future if the lots/parcels are owned individually. If not, the CC&R’s should address the fire hydrants to the parcels being off the same private looped fire service and responsibility for any and all service charges and usage costs. The private fire hydrant layout for Building 6 is acceptable as it only services this lot.
53 City of Fremont General Plan Public Facilities Element ( Adopted December 2011 ) p. 9-18. 54 See Exhibit C – Email from Juniet Rotter Development Services Manager Alameda County Water District to Mark Hungerford City of Fremont, FW: PRP2022 -00014 Ardenwood @ Paseo (Oct. 12, 2021 11:50 PM) (hereinafter (“AWCD Comments”) .
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• Each building shall have a separate individual fire service from the public main located in the street fronting the building, not off the private fire line feeding the fire hydrants.
• Each non-residential, irrigation and dedicated fire services to each building and the service line for on-site private fire hydrants will require above- ground reduced pressure backflow prevention device(s). Backflow prevention devices must be located in accordance with District Standard Drawings BP-1- 08 through BP-3-08. The location and screening of these above-ground devices should be considered in the site design to address both District installation standards as well as aesthetic concerns of the development.
Backflows located within buildings are not acceptable.
The CEQA Checklist asserts that “[t]he Alameda County Water District has reviewed the project and has not indicated any issues with meeting the project’s water demands without significantly impacting its supplies or its distribution system.”
55 There is no substantial evidence supporting the claim that ACWD “has not indicated any issues.” Rather, as ACWD’s comments state, “prior to approving/providing water service, ACWD requests… the anticipated water demand for the operation of the buildings… [and] additional requirements, including preparation of a Water Supply Assessment (WSA), may be necessary.”56
Furthermore, ACWD’s comments specifically provide that the District “encourage[s] the project proponents to meet with District staff early… to review these and other issues.”57 The Staff Report and Appeal Response letter do not resolve these issues and do not provide substantial evidence that the ACWD has verified the adequacy of available water supply. The record before the Commission therefore lacks substantial evidence demonstrating that the issues raised by ACWD have been resolved or that the Project has adequate water supply. Rather, it is clear from the record that the local water district has neither approved the water service nor verified the adequacy of the available supply, as required by CEQA and the Water Code.58 Absent a water supply assessment, the Commission lacks substantial evidence to approve the Project.
55 CEQA Checklist, p. 59.
56 AWCD Comments, p. 1.
57 AWCD Comments, p. 1.
58 Burtt Comments, p. 2.
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B. The Project Site Lacks Adequate Fire Flow, Resulting in Significant, Unmitigated Water Supply and Public Services/Fire Safety Impacts
The record before the Commission lacks substantial evidence demonstrating that the water demand and fire flow demand have been determined for the Project.59 As detailed in Robert Burtt’s report, there is substantial evidence demonstrating that the Project’s water demand and fire flow demand would not be adequately served by ACWD’s existing water supply system.60 An EIR is required to address these impacts.
East Bay Residents consulted Fire Protection Engineer Robert Burtt of Burtt Engineering to review the Project and publicly available information to determine whether the Project is adequately served by water supply to support fire flow. Mr.
Burtt’s comments provide substantial evidence that the Project does not have adequate water supply from ACWD to support the Project’s “3,250 GPM or more of fire flow demand… required for several buildings for the Project.”61 Rather, Mr. Burtt explains that “the existing water supply will only support up to approximately 2,040 GPM of fire flow – significantly less than the water supply that may be required to provide fire flow demands.”62
Pursuant to California Fire Code Section B105 and Fremont Municipal Code Section 15.35.040, each building's construction type and square footage is necessary to adequately calculate the anticipated fire flow of each building. Considering the anticipated construction type of light industrial buildings, the size, and intended use of each building, Mr. Burtt calculated that up to 3,250 GPM or more of fire flow demand may be required for several Project buildings.63 Substantial evidence demonstrates that the existing water supply will only support up to approximately 2,040 GPM of fire flow – significantly less than the water supply that may be required to provide fire flow demands.64 The CEQA Checklist failed to disclose, analyze, or mitigate this impact.
Further, Mr. Burtt provided substantial evidence that the existing water supply and existing infrastructure may be inadequate to support the Project’s fire flow demands.65 Alameda County Fire Flow test data provided indicates that
59 Burtt Comments, p. 1.
60 Burtt Comments, p. 2.
61 Id.
62 Id.
63 Id.
64 Id.
65 Burtt Comments, p. 3.
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existing infrastructure can provide 78 PSI of static pressure and 1,180 GPM of flow at 57 PSI.66 According to Mr. Burtt’s analysis of available fire flow information, existing infrastructure would support up to approximately 2,040 GPM at 20 PSI of fire flow before substantial infrastructure improvements throughout the local area and roads would likely be required.67
Mr. Burtt cited the Alameda County Fire Flow test data which demonstrates that existing infrastructure can only provide 78 PSI of static pressure and 1,180 GPM of flow at 57 PSI.68 Analysis of this fire flow information indicates that existing infrastructure would support up to approximately 2,040 GPM at 20 PSI of fire flow (approximately 1,210 GPM less water flow than may be required for the Project).69 Substantial infrastructure improvements would therefore be required to increase the available water supply.70
The General Plan’s Public Facilities Element provides that “Older portions of the distribution system, particularly residential areas developed prior to 1960 are more likely to require upgrades in order to meet new water service and fire flow requirements.”
71 The CEQA Checklist failed to analyze whether additional upgrades are required to support the Project’s fire flow. This analysis must be performed before the City can approve the Project.
The CEQA Checklist provided no analysis of the required fire flow needed for each building.72 There is no substantial evidence that the available infrastructure and water supply will provide adequate fire-flow, as analysis of the fire-flow water demand has not been provided.73 In accordance with ACWD’s request, the fire flow demand for the Project must be analyzed to determine if the existing water supply requires substantial upgrade.
Mr. Burtt provided substantial evidence that additional infrastructure upgrades are required to provide the minimum required fire flow to the Project site.74 Pursuant to California Fire Code Section B105 and Fremont Municipal Code Section 15.35.040, the existing fire flow supply for the site is approximately 2,040
66 Id.
67 Id.
68 Burtt Comments, p. 5.
69 Id.
70 Id.
71 City of Fremont General Plan Public Facilities Element (Adopted December 2011) p. 9 -17. 72 Burtt Comments, p. 3.
73 Id.
74 Burtt Comments, p. 3.
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GPM.75 Mr. Burtt concluded that, up to 3,250 GPM or more of fire flow demand may be required for each of several buildings for the Project.76 Additional information from the Applicant is necessary to assess the building construction types and determine the fire flow requirements for each structure before the Project can be approved.77
Mr. Burtt’s analysis provides substantial evidence to support a determination that the existing water supply is insufficient to meet the Project’s fire flow demand and will require an estimated increase of at least 1,210 GPM beyond the currently available water supply.78
In order to provide an increase in the available water supply of this magnitude, substantial infrastructure improvements would be required throughout the area around the Project to provide minimum required fire flow.79 Mr. Burtt concluded that “[i]nfrastructure upgrades may require at least several thousand feet of water main along Paseo Padre Parkway and Ardenwood Boulevard.”80
Water infrastructure improvements would also have significant construction- related impacts on air quality, noise, traffic, local pedestrians and vehicles, and may require street excavation and subsequent repair to access water mains. Excavation would likely require demolition, disruption, and removal of portions of the street along the entire length of water main upgrade.81 New, upsized piping would likely be required, along with new trench backfill, soil, compaction, and new street asphalt work along the entire length of work.
82 The CEQA Checklist does not discuss any
of these impacts. Additional investigation, calculations, and review of the required infrastructure upgrades and severity of the impacts must be addressed in an EIR before the Project is approved, in order to comply with CEQA and ensure the adequacy of the minimum necessary fire flow for the Project.
Due to the demonstrated inadequacy of the fire flow for the Project, the Commission also cannot make the necessary findings to support Project approval.
The records does not contain substantial evidence demonstrating that the Project will “not be detrimental to the public health or safety [or] unreasonably interfere with the use and enjoyment of adjacent development nor be detrimental to the
75 Id.
76 Burtt Comments, p. 3.
77 Id.
78 Id.
79 Id.
80 Burtt Comments, p. 5.
81 Id.
82 Id.
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public health, safety, or welfare” as required by the Municipal Code for approval of the Discretionary Design Review Permit.83
VI. THE PROJECT RESULTS IN SIGNIFICANT AIR QUALITY
AND HEALTH RISK IMPACTS
Where a program EIR has been prepared that could apply to a later project, CEQA requires a lead agency to conduct a two-step process to examine the later project to determine whether additional environmental review is required.84 A public agency must consider whether the project will result in environmental effects that were not examined in the program EIR.85 If the agency finds the activity would have environmental effects that were not examined in the program EIR, it must then prepare an initial study to determine whether to prepare an EIR or negative declaration to address those effects.86 Second, if the agency determines the project is covered by the program EIR, it must then consider whether any new or more significant environmental effects could occur due to changes in circumstances or project scope, or new information that could not have been considered in the program EIR.
The Staff Report’s Response Letter provides that “CEQA Guidelines section 15183(f) provides that an effect of a project on the environment shall not be considered peculiar to the project . . . if uniformly applied the development policies or standards will substantially mitigate that environmental effect when applied to future projects… These provisions do not apply if substantial new information shows that the policies or standards will not substantially mitigate the environmental effect.”87
Here, substantial new information demonstrates that the City’s policies and standards will not substantially mitigate the air quality and health risk impacts associated with Project construction. As demonstrated in EBRRD’s prior comments to the City, the City cannot rely on a Community Plan Exemption to approve the Project because the Project results in significant air quality, diesel particulate matter, and health risk impacts which were not analyzed in the 2011 General Plan EIR. These impacts must be analyzed in a Project-level EIR. The EIR must include a more robust analysis of construction health risk
83 Fremont Municipal Code § 18.235.060(c).
84 See CEQA Guidelines, 15168(c); S. Kostka & M. Zischke, Practice Under the California Environmental Quality Act 2d, § 10.16 (Mar. 2018).
85 CEQA Guidelines, § 15168(c)(1).
86 CEQA Guidelines, § 15168(c)(1).
87 Appeal Response Letter, p. 6.
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impacts, and an operational health risk assessment to analyze the Project’s significant health risk impacts associated with diesel particulate matter emissions.
The CEQA Checklist states that the risk associated with project construction at the maximally exposed individual (MEI) would be 12.44 in one million, which would exceed the BAAQMD cancer risk of 10 in one million resulting in an admittedly significant impact which was not disclosed in the General Plan EIR. 88 The CEQA Checklist attempts to dismiss the impact by stating that “all health risks would be reduced with implementation of FCM Section 18.218.050(a)(2), and the reduced cancer risk at the MEI would be 2.17 in one million, which would not exceed the BAAQMD cancer risk of 10 in one million. Therefore, with implementation of the supplemental construction measures identified in FMC Section 18.218.050(a), construction of the proposed project would not exceed BAAQMD thresholds and would not expose nearby sensitive receptors to substantial pollutant concentrations.”
89 However, this statement is not supported
by substantial evidence, because the City did not quantify the health risk from all Project emissions, including DPM exposure during Project operation, and SWAPE determined that reliance on FMC mitigation would not reduce health risk impacts to below the level of significance.
90 SWAPE conducted a quantified health risk analysis (“HRA”) of the Project’s toxic air contaminant (“TAC”) emissions, including DPM, and identified health risk impacts which are more severe than analyzed in the 2011 General Plan EIR and in the CEQA Checklist. SWAPE identified the Child (2-6 years) excess cancer risk factor, over the course of the Project’s operation as 14.5 in one million.91 The total excess cancer risk for all populations, including 3rd Trimester pregnant individuals, Infants (0-2), Child (2-16), Adults (16-30) over the lifetime of the Project is 54.3 in one million excess cancer risk.92 The cancer risk associated with development of the Project so close to nearby sensitive receptors results in a significant cancer risk exceeding BAAQMD thresholds of 10 in one million.93
SWAPE’s comments, supported by a quantitative health risk analysis, constitute new information that was not available in 2011, demonstrating that the Project results in a significant health risk. This information was not previously
88 CEQA Checklist, p. 24.
89 Id.
90 EBRRD Zoning Administrator Comments , SWAPE Comments, p. 2. 91 EBRRD Zoning Administrator Comments , SWAPE Comments, p. 7. 92 Id.
93 Bay Area Air Quality Management District 2022 CEQA Guidelines , Thresholds of Significance, p. 3-4.
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available because the 2011 General Plan EIR did not conduct a quantitative health risk assessment. The Project’s health risk impacts must therefore be independently quantified by the City in an operational health risk assessment before the Project can be approved.
As demonstrated in SWAPE’s comments, the City’s failure to conduct an operational health risk assessment undermines the conclusions and renders the CEQA Checklist’s conclusions unsupported by substantial evidence. The City’s reliance on AERMOD modeling is not a substitute for operational health risk analysis because it only models construction emissions. The data from SWAPE’s quantitative health risk analysis is new information of the Project’s significant operational health risk impacts which was not and could not have been analyzed at the time of the General Plan EIR. These impacts must be analyzed and mitigated in a Project-level EIR before the Project can proceed.
The Appeal Response Letter provides that because operational emissions are not all occurring on the Project site, they should not have been counted in SWAPE’s calculation of total operational emissions.
94 This conclusion is incorrect. The trips
associated with the Project’s operation including offsite trips must be quantified in order to accurately calculate the Project’s entire operational impact. Moreover, the emissions associated with idling, cold starts, and on-site circulation must be quantified in order to accurately calculate the Project’s operational health risk impacts. SWAPE modeled these total emissions in order to quantify the full operational air quality and health risk impact of the Project’s operation. SWAPE’s calculations identified a significant health risk impact associated with DPM exposure associated with the Project’s operation.
SWAPE provided the following response to the Appeal Response Letter, stating:
While not all vehicle miles traveled occur on-site, significant emissions from idling, cold starts, and on-site circulation still contribute to localized air quality burdens. The use of AERSCREEN ensures that potential impacts from idling, cold starts, and on-site circulation are not overlooked in the environmental review process. As the U.S. Environmental Protection Agency describes, AERSCREEN is a screening-level air quality model that provides conservative estimates of air pollutant concentrations for a given source, assuming worst-case meteorological conditions.
95 94 Appeal Response Letter, p. 8.
95 SWAPE Comments, p. 3.
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The CEQA Checklist’s failure to analyze operational health risk impacts associated with idling, cold starts, and on-site and off-site circulation results in an underestimation of the Project’s significant operational diesel particulate matter emissions which constitute significant public health impacts, according to SWAPE.
Additionally, contrary to the Appeal Response Letter’s conclusion, diesel emissions from emergency generators and fire pumps are not the only sources of DPM relevant to health risk.
96 The primary source of DPM for the Project would
originate from vehicle activity, which remains unaccounted for in the Response’s analysis. SWAPE concludes that, by not preparing a quantified operational HRA, the CEQA Checklist is inconsistent with CEQA’s requirement to make a reasonable effort to substantively connect a project’s air quality impacts to likely health consequences.
Substantial evidence in SWAPE’s comments and EBRRD’s prior comments demonstrate that the Project results in a significant health risk which was not adequately analyzed in the 2011 General Plan EIR and is not adequately mitigated by the CEQA Checklist, Staff Report, nor by the City’s standard development conditions.
The Staff Report does not add mitigation which would adequately reduce the Project’s health risk impact to below significant. The Staff Report does not include changes to mitigation recommended by EBRRD to reduce emissions, like including Tier 4 Final Engines. EBRRD recommends the following mitigation to reduce the Project’s significant health risk impacts before the Project can lawfully be approved.
• Require projects to use Tier 4 Final equipment or better for all engines above 50 horsepower (hp).
• In the event that construction equipment cannot meet to Tier 4 Final engine certification, the Project representative or contractor must demonstrate through future study with written findings supported by substantial evidence that is approved by SCAG before using other technologies/strategies.
• Alternative applicable strategies may include, but would not be limited to, construction equipment with Tier 4 Interim or reduction in the number and/or horsepower rating of construction equipment and/or limiting the number of construction equipment operating at the same time.
96 See Appeal Response Letter , p. 8-9.
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• All equipment must be tuned and maintained in compliance with the manufacturer’s recommended maintenance schedule and
specifications.
• All maintenance records for each equipment and their contractor(s) should make available for inspection and remain on-site for a period of at least two years from completion of construction, unless the individual project can demonstrate that Tier 4 engines would not be required to mitigate emissions below significance thresholds. • Project sponsors should also consider including ZE/ZNE technologies where appropriate and feasible.
EBRRD recommends the Commission revise the Conditions of Approval to add the above measures to adequately mitigate the Project’s potentially significant health risk and air quality impacts before the Project can be approved.
VII. THE CITY CANNOT MAKE THE NECESSARY FINDINGS TO
APPROVE THE PROJECT’S ENTITLEMENTS
In order to approve a discretionary Design Review Permit, the Commission must make the following findings:
(a) The proposed project is consistent with the general plan, any applicable community or specific plan, planning and zoning regulations, and any adopted design rules and guidelines;
(b) When a proposed project is inconsistent with an adopted design rule, the purpose and intent of the design rule is met through alternative means; (c) The multifamily residential1 project’s architectural, site, and landscape design will not be detrimental to the public health or safety; or a nonmultifamily project’s architectural, site, and landscape design will not unreasonably interfere with the use and enjoyment of adjacent development nor be detrimental to the public health, safety, or welfare.97
As detailed herein, and in the expert consultant reports provided by EBRRD to the City, the Project will result in a detriment to the public health and safety, due to the Project’s significant, unmitigated health risk and cancer risk impacts to nearby sensitive receptors. The Planning Commission should grant this appeal and remand the Project to Staff to prepare a legally adequate EIR to analyze and mitigate the Project’s impacts because the Commission cannot make the necessary findings to approve the Project given the Projects significant detriment to the public health and safety and welfare.
97 Fremont Municipal Code § 18.235.060 (emphasis added).
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VIII. CONCLUSION
For the reasons stated herein, and detailed in our prior comments to the City, East Bay Residents urges the Planning Commission to reverse the Zoning Administrator’s approval of the Project, and require staff to prepare a project-level EIR. Thank you for your consideration.
Sincerely,
Kelilah D. Federman
Attachments
KDF:acp
EXHIBIT A
Ardenwood at Paseo Project Water Supply / Fire Flow Engineering Opinion Letter
BURTT ENGINEERING . 120 Village Square #150, Orinda CA. 94563 DIRECT 925-528-8081
February 8, 2025
Kelilah D. Federman
Adams Broadwell Joseph & Cardozo
601 G ateway B l vd. Ste 1000,
South San Francisco, CA 94080
RE: Ardenwood at Paseo Project
6200 Paseo Padre Parkway
Water Supply / Fire Flow Engineering Opinion Letter
Dear Ms. Federman:
Per your request, I have reviewed the Ardenwood at Paseo Project (the “Project”), the CEQA Environmental Consistency Checklist (the “CEQA Checklist”), Alameda County Water District (ACWD) comments, and Alameda County Fire Flow test data in relation to the water supply and fire flow requirements of the Project in the City of Fremont (the “City”).
The proposed Project includes the development of five new light industrial buildings totaling 407,250 square feet and renovation of an existing 43,172-square-foot light industrial building on the 24.2-acre site bounded by Paseo Padre Parkway, Ardenwood Boulevard, and Commerce Drive.
The southern portion of the site along Commerce Drive would be developed with two (2) two- story light industrial buildings, both measuring 75,112 square feet, and one (1) three-story, 91,162-square-foot light industrial building. The two-story buildings would stand 36’-6” in height and the three-story building would stand 51’-6” in height. The site’s Paseo Padre Parkway frontage would be developed with two (2) two- story light industrial buildings. The building proposed at the southern end of the frontage would measure 75,112 square feet in size and the building proposed at the northern end of the frontage would measure 90,750 square feet. Both buildings would measure 36’-6” in height. Situated between these two buildings is an existing one-story light industrial building measuring 43,172 square feet that would be renovated.
Given the Project information provided and the recommendations and requirements stated in the CEQA Checklist, the Project represents a unique and unusual construction development with significant fire water demand under California Code of Regulations and City of Fremont Municipal Code.
Overall, there are several outstanding items within the Project documentation and CEQA Checklist that appear to require further consideration. These items should be reviewed in accordance with the Alameda County Water District review comments, California Code of Regulations, and Fremont Municipal Code to ensure that the minimum fire hazard safety standards are met, and that sufficient water supplies are available to serve the Project.
Water / Fire Flow Demand
The Alameda County Water District Review Comment #1 indicates that ACWD has not approved the water service and requires additional analysis of the Project’s water demand and supporting evidence.
ACWD Comment #1 states that “prior to approving/providing water service, ACWD requests that the applicant provide… the anticipated water demand for the operation at the buildings … depending on the type of manufacturing, occupancy number and water demand, additional requirements, including preparation of a Water Supply Assessment (WSA), may be necessary” (Figure 1). Based on the information provided, there is no substantial evidence that the water demand (including fire flow demand) has been determined for the Project. This shows that the local water district has neither approved the water service nor verified the adequacy of the available supply.
Ardenwood at Paseo Project Water Supply / Fire Flow Engineering Opinion Letter
Figure 1. ACWD Comment #1 requesting the Project provide the water demand for the Project, and noting that additional requirements and evidence may be necessary to determine if the water supply is sufficient to serve the Project.
Additionally, there appears to be no substantial evidence that the Project meets the Project CEQA Checklist Items 1.10.2.a and 1.19.2.a.
CEQA Checklist Item 1.10.2.a states “The Alameda County Water District has reviewed the project and has not indicated any issues with meeting the project’s water demands without significantly impacting its supplies or its distribution system.” There is no substantial evidence supporting the claim that ACWD “has not indicated any issues”, as ACWD Comment #1 states “prior to approving/providing water service, ACWD requests… the anticipated water demand for the operation of the buildings… [and] additional requirements, including preparation of a Water Supply Assessment (WSA), may be necessary.” Furthermore, the ACWD commentary on the Project specifically states that they “encourage the project proponents to meet with District staff early… to review these and other issues.” (Figure 2) This provides substantial evidence that the ACWD has indicated multiple comments and issues with the Project that require resolution.
CEQA Checklist Item 1.19.2.a states that: “The development would be served by the Alameda County Water District (ACWD) utilizing the District’s existing water supply system. No issues with obtaining water supplies in normal, dry, and multiple dry years has been identified by ACWD, therefore the project would have a less than significant impact and no mitigation would be necessary.” However, there is no substantial evidence that demonstrates that the development water demand or fire flow demand would be able to be served by the ACWD existing water supply system. There is no substantial evidence that ACWD has approved the water service. The ACWD as specifically noted that the Project needs to provide additional Project water demand information, and that “prior to approving/providing water service, ACWD requests… the anticipated water demand for the operation of the buildings… [and] addit ional requirements, including preparation of a Water Supply Assessment (WSA), may be necessary.” As previously noted, the ACWD specifically states that they “encourage the project proponents to meet with District staff early… to review these and other issues.” This provides substantial evidence that the ACWD has indicated that there are issues with the Project, and additional information is required by the ACWD to determine if the water service is sufficient and if additional infrastructure improvements are required.
Ardenwood at Paseo Project Water Supply / Fire Flow Engineering Opinion Letter
Figure 2. ACWD statement that the Project may meet and discuss ACWD issues with the Project.
Furthermore, the ACWD fire flow data provides substantial evidence that the existing water supply and existing infrastructure may be inadequate to support the Project’s fire flow demands. Alameda County Fire Flow test data provided indicates that existing infrastructure can provide 78 PSI of static pressure and 1,180 GPM of flow at 57 PSI (Figure 3). Analysis of this fire flow information indicates that existing infrastructure would support up to approximately 2,040 GPM at 20 PSI of fire flow before substantial infrastructure improvements throughout the local area and roads would likely be required. The Project appears to have provided no analysis of the required fire flow needed for each building. There is no substantial evidence that the available infrastructure and water supply will provide adequate fire- flow, as analysis of the fire-flow water demand has not been provided. In accordance with the ACWD request, the fire flow demand for the Project should be analyzed to determine if the existing water supply requires substantial upgrade.
In accordance with California Fire Code Section B105 and Fremont Municipal Code Section 15.35.040, each building's construction type and square footage is required to determine the anticipated fire flow of each building. Considering the anticipated construction type of light industrial buildings, the size, and intended use of each building, it is likely that up to 3,250 GPM or more of fire flow demand may be required for several buildings for the Project. Substantial evidence provided by the ACWD indicates that the existing water supply will only support up to approximately 2,040 GPM of fire flow – significantly less than the water supply that may be required to provide fire flow demands.
Figure 3. ACWD Fire Flow Test Data Sheet indicating that existing infrastructure can provide up to 1,180 GPM at 57 PSI.
Potential Infrastructure Upgrades / Requirements
The Alameda County Water District (ACWD) comments and Alameda County Fire Flow test data constitute substantial evidence that the Project water main infrastructure will likely require significant and extensive improvement to provide the minimum required fire flow to the Project site. In accordance with California Fire Code Section B105 and Fremont Municipal Code Section 15.35.040, the existing fire flow supply for the site appears to be approximately 2,040 GPM. Based on Project building information, it is
Ardenwood at Paseo Project Water Supply / Fire Flow Engineering Opinion Letter
likely that up to 3,250 GPM or more of fire flow demand may be required for each of several buildings for the Project. Additional information from the Project is necessary to assess the building construction types and determine the fire flow requirements for each structure. However, this preliminary analysis suggests that the existing water supply is likely insufficient to meet the Project’s fire flow demand and will require an estimated increase of at least 1,210 GPM beyond the currently available water supply.
To provide such an increase in the available water supply, substantial infrastructure improvements would be required throughout the area around the Project to provide minimum required fire flow. While additional study is needed to determine the full extent of the improvements required for this specific project, infrastructure upgrades may require at least several thousand feet of water main along Paseo Padre Parkway and Ardenwood Boulevard. Any such improvements would likely have significant impacts to the environment, traffic, local pedestrians and vehicles, and require street excavation and subsequent repair to access water mains. Excavation would likely require demolition, disruption, and removal of portions of the street along the entire length of water main upgrade. This would entail excavation and removal asphalt, soils, and trench backfill materials. New, upsized piping would likely be required, along with new trench backfill, soil, compaction, and new street asphalt work along the entire length of work.
Traffic control would be required for the duration of the infrastructure improvement project, with careful protection and control to prevent congestion or accidents due to street lane closures. We would suggest further investigation, calculations, and review of the required infrastructure upgrades and severity of the impacts that would occur from construction and installation of the upgrades to achieve the minimum necessary fire flow for the Project.
Conclusion
Fire flow is a critical piece of infrastructure that represents the minimum required amount of water needed during an emergency fire event to safely assist with extinguishing a fire and achieving public safety. There is no substantial evidence that water demand (including fire flow demand) has been adequately analyzed to determine if the existing water supply can support the Project. Substantial evidence indicates that 3,250 GPM or more of fire flow may be required for the Project, exceeding the currently available water supply by approximately 1,210 GPM. Inadequate fire flow can result in a hazard and danger to public safety, occupant safety, firefighter safety, and the safety of adjoining properties and the community. If inadequate fire flow is present, significant hazards that may arise, including but not limited to:
- Increased Fire Severity: Deficiencies in available firefighter water may result in the potential for extended fire growth and fire spread as less water is available to suppress the fire, posing an immediate threat to the safety of occupants and neighboring properties. - Limited Firefighting Capabilities: Firefighters rely on adequate fire flow to combat fires. Deficit fire flow may hinder firefighting efforts to contain and extinguish fires promptly. - Increased Loss of Life and Property: Inadequate fire flow may result in decreased effectiveness of firefighting efforts, increasing the risk of greater loss of life and property in the event of a fire emergency.
- Increased Risk of Fire Spread: Inadequate fire flow may increase the likelihood of fire spreading to adjacent properties, increasing fire risks for the area and community.
The Alameda County Water District (ACWD) comments clearly state that “prior to approving/providing water service, ACWD requests that the applicant provide… the anticipated water demand for the operation at the buildings… depending on the type of manufacturing, occupancy number and water demand, additional requirements, including preparation of a Water Supply Assessment (WSA), may be necessary”. Furthermore, the ACWD stated that they “encourage the project proponents to meet with District staff early… to review these and other issues.” The Alameda County Water District (ACWD) comments provide substantial evidence that multiple comments and issues exist regarding the Project’s water supply.
The Alameda County Fire Flow test data supports this conclusion, and provides substantial evidence that existing infrastructure can only provide 78 PSI of static pressure and 1,180 GPM of flow at 57 PSI (Figure 3). Analysis of this fire flow information indicates that existing infrastructure would support up to Ardenwood at Paseo Project Water Supply / Fire Flow Engineering Opinion Letter
approximately 2,040 GPM at 20 PSI of fire flow (approximately 1,210 GPM less water flow than may be required for the Project). Substantial infrastructure improvements would be required to increase the available water supply.
In accordance with the ACWD comments, the Project should provide a comprehensive fire flow analysis and address ACWD’s concerns regarding water supply sufficiency and required infrastructure upgrades.
To achieve the estimated additional fire flow required to the project site, it is likely that at least a thousand to several thousands of linear feet of water main may require upgrade. These improvements should be carefully reviewed, as such work would require traffic control, road excavation, street trenching, backfill, asphalt replacement, and likely significantly impact the surrounding area.
Sincerely,
Robert E. Burtt, P.E.
Fire Protection Engineer
Robert Burtt, P.E., GC, PMP [email protected]
Expert – Professional Engineer
Licenses/Registrations/Designations
• California (Fire Protection ) Engineer No. 2225
• California (Mechanical) Engineer No. 39163
• California (Civil) Engineer No. 93149
• Hawaii Professional Engineer No. 19910
California Contractor License No. 1024599
• Class A Licensed Engineering Contractor
• Class B Licensed General Contractor
• Class C10 Licensed Electrical Contractor
• Class C36 Licensed Plumbing Contractor
• Class C16 Licensed Fire Protection Contractor
Areas of Focus
• Civil
• Fire Protection
• Plumbing
• High-rise Residential
• Apartments
• Hotels
• Mechanical
• Code Consulting / Building Code
Project Expertise
• Restaurants
• Industrial Plants
• Educational & Training Facilities
• Retail Stores • Warehouse / Storage Facilities
• Office Buildings • Churches
• Computer Rooms • Public Developments
Areas of Expertise
• Engineering Judgements / Opinion
Reports
• Design and Plan Review
• Forensic Investigation
• Document Analysis
• Building Code and Materials Research
• Standard of Care
• Contract Conformance
• Quality Control
• On-Site Supervision
• Project Management
• Regulatory Compliance
• Change Order and Cost Management
• Operational Oversight
Education
• Bachelor of Science, Mechanical Engineering, California Poly technic State Univer sity, San Luis Obispo
120 Village Sq. #150, Orinda, CA 94563 925-528-8081
EXHIBIT B
1 2656 29th Street, Suite 201
Santa Monica, CA 90405
Matt Hagemann, P.G, C.Hg.
(949) 887-9013
[email protected]
Paul E. Rosenfeld, PhD
(310) 795-2335
[email protected]
February 13, 2025
Kelilah Federman
Adams Broadwell Joseph & Cardozo
601 Gateway Blvd #1000
South San Francisco, CA 94080
Subject: Comments on the Ardenwood Warehouse RTC
Dear Ms. Federman,
We have reviewed the December 2024 Lamphier-Gregory Response to Appeal (“Response”) as well as the February 2024 Air Quality, Energy, and Greenhouse Gas Emissions Analysis Memorandum (“Memo”) for the Ardenwood Warehouse Project (“Project”) located in the City of Fremont.
Our review concludes that the Response fails to adequately characterize or respond to the health risk comments made in our October 14, 2024 letter. We maintain our determination that the IS/MND does not properly evaluate the Project’s potential health risks and that a full CEQA analysis should prepared to sufficiently assess and mitigate these potential environmental impacts.
Air Quality
Diesel Particulate Matter Emissions Inadequately Evaluated In our October 14, 2024 comment letter, we address the fact that the Memo fails to address the diesel particulate matter (“DPM”) impacts or evaluate the health risks associated with Project operation. Our screening-level analysis of the Project’s operational health risk impacts identified a potentially significant cancer risk, warranting, in our opinion, further analysis and the use of more developed modeling.1 In response, the Response claims that a refined health risk assessment (“HRA”) was conducted using the AERMOD dispersion model and California Air Resources Board exposure methodology (p. 7). However, despite the Response’s claims, the Memo fails to present an operational HRA quantifying the health risks associated with Project-generated DPM emissions from mobile sources. The Response restates the
1 See Attachment A for health risk calculations and Attachment B for AERSCREEN output files.
2 Memo’s claim that the Project’s operational DPM would not pose a significant health risk to nearby sensitive receptors, stating:
“The environmental setting for the CEQA Checklist Air Quality section (page 16) further specifies that the Project does not propose operational use of diesel emergency generators or diesel fire pumps, which are two sources of operational diesel emissions that can sometimes be proposed in development projects of this type but are not proposed for the Project” (p. 8).
This argument lacks basis because diesel emissions from emergency generators and fire pumps are not the only sources of DPM relevant to health risk. The primary source of DPM for the Project would originate from vehicle activity, which remains unaccounted for in the Response’s analysis. We therefore maintain our previous conclusion that by not preparing a quantified operational HRA, the Memo is inconsistent with the California Environmental Quality Act (“CEQA”)’s requirement to make “a reasonable effort to substantively connect a project’s air quality impacts to likely health consequences.”2
Furthermore, the Response attempts to discredit our screening-level analysis by stating:
“Screening level analyses are more conservative than the more complex and refined detailed analysis. This means that a screening level analysis is fully expected to show greater impacts than a more refined analysis” (p. 7).
The purpose of a screening analysis, however, is to determine whether a refined analysis is warranted.
Our analysis identified a cancer risk exceeding the 10 in a million significance threshold, which indicates the need for further evaluation.
3 Rather than conducting a refined operational HRA, the Response dismisses our findings without providing an equivalent or more detailed analysis of operational DPM health risks.
The Response also asserts that the Project does not meet the definition of a warehouse and that operational vehicle emissions are overstated (p. 8). While we acknowledge that the Project is not classified as a warehouse, this does not negate the need for an operational HRA. Diesel emissions from vehicle activity—regardless of land use classification—can pose a significant health risk. The Response does not provide a quantitative assessment demonstrating that operational emissions are negligible, nor does it address the fact that similar R&D facilities can generate substantial mobile emissions.
Additionally, the Response suggests that our analysis overestimates on-site operational emissions by modeling all project-related vehicle trips as if they occur entirely within the Project site (p. 9). However, as previously mentioned, AERSCREEN is a worst-case, screening-level dispersion model which assumes emissions occur within a defined area. This is not an error in our calculations, but rather a reflection of the modeling methodology used to assess potential localized air quality impacts.
While not all vehicle
miles traveled occur on-site, significant emissions from idling, cold starts, and on-site circulation still
2 “Sierra Club v. County of Fresno.” Supreme Court of California, December 2018, a vailable at:
https://ceqaportal.org/decisions/1907/Sierra%20Club%20v.%20County%20of%20Fresno.pdf . 3 See Attachment A for health risk calculations and Attachment B for AERSCREEN output files. 3 contribute to localized air quality burdens. The use of AERSCREEN also ensures that potential impacts from idling, cold starts, and on-site circulation are not overlooked in the environmental review process.
As the U.S. Environmental Protection Agency describes, AERSCREEN is a screening-level air quality model that provides conservative estimates of air pollutant concentrations for a given source, assuming worst- case meteorological conditions.4
The Response fails to substantively address our concerns. We maintain our opinion from the October 14, 2024 comment letter that a full CEQA analysis should be prepared to include an updated and quantified refined HRA which evaluates health risk impacts associated with Project operation.
Disclaimer
SWAPE has received limited documentation regarding this project. Additional information may become available in the future; thus, we retain the right to revise or amend this report when additional information becomes available. Our professional services have been performed using that degree of care and skill ordinarily exercised, under similar circumstances, by reputable environmental consultants practicing in this or similar localities at the time of service. No other warranty, expressed or implied, is made as to the scope of work, work methodologies and protocols, site conditions, analytical testing results, and findings presented. This report reflects efforts which were limited to information that was reasonably accessible at the time of the work, and may contain informational gaps, inconsistencies, or otherwise be incomplete due to the unavailability or uncertainty of information obtained or provided by third parties.
Sincerely,
Matt Hagemann, P.G., C.Hg.
Paul E. Rosenfeld, Ph.D.
4 “Air Quality Dispersion Modeling - Screening Models.“ U.S. Environmental Protection Agency, November 2024, available at: http://www.aqmd.gov/docs/default-source/ceqa/handbook/localized-significance-thresholds/final- lst-methodology-document.pdf.
Annual Emissions (tons/year) 0.06 Total DPM (lbs) 266.6849315 Annual Emissions (tons/year) 0.04 Daily Emissions (lbs/day) 0.328767123 Total DPM (g) 120968.2849 Daily Emissions (lbs/day) 0.219178082 Construction Duration (days) 212 Emission Rate (g/s) 0.001912699 Total DPM (lbs) 80 Total DPM (lbs) 69.69863014 Release Height (meters) 3 Emission Rate (g/s) 0.001150685 Total DPM (g) 31615.29863 Total Acreage 24.2 Release Height (meters) 3 Start Date 6/3/2024 Max Horizontal (meters) 442.57 Total Acreage 24.2 End Date 1/1/2025 Min Horizontal (meters) 221.28 Max Horizontal (meters) 442.57 Construction Days 212 Initial Vertical Dimension (meters) 1.5 Min Horizontal (meters) 221.28 Setting Fremont Initial Vertical Dimension (meters) 1.5 Annual Emissions (tons/year) 0.09 Population 223,871 Setting Fremont Daily Emissions (lbs/day) 0.493150685 Start Date 6/3/2024 Population 223,871 Construction Duration (days) 365 End Date 6/5/2026
Total DPM (lbs) 180 Total Construction Days 732
Total DPM (g) 81648 Total Years of Construction 2.01
Start Date 1/1/2025 Total Years of Operation 27.99
End Date 1/1/2026
Construction Days 365
Annual Emissions (tons/year) 0.02
Daily Emissions (lbs/day) 0.109589041
Construction Duration (days) 155
Total DPM (lbs) 16.98630137
Total DPM (g) 7704.986301
Start Date 1/1/2026
End Date 6/5/2026
Construction Days 155
2023
Construction Operation
2021 Total Emission Rate
2022
Attachment A
Age Group Emissions Source Duration (years) Concentration (ug/m3) Cancer Risk
3 rd Trimester Construction 0.25 0.1392 1.61E-06
Construction 1.76 0.1392 3.41E-05
Operation 0.24 0.0555 1.89E-06
Infant (0 - 2) Total 2 3.60E-05
Child (2 - 16) Operation 14 0.0555 1.45E-05
Adult (16 - 30) Operation 14 0.0555 2.23E-06
Lifetime 30 5.43E-05
The Maximally Exposed Individual at an Existing Residential Receptor AERSCREEN 21112 / AERMOD 21112 10/09/24
16:22:26
TITLE: ArdenwoodWarehouse, Construction
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ ****************************** AREA PARAMETERS **************************** ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ SOURCE EMISSION RATE: 0.191E ‐02 g/s 0.152E‐01 lb/hr
AREA EMISSION RATE: 0.195E‐07 g/(s‐m2) 0.155E ‐06 lb/(hr‐m2) AREA HEIGHT: 3.00 meters 9.84 feet
AREA SOURCE LONG SIDE: 442.57 meters 1452.00 feet
AREA SOURCE SHORT SIDE: 221.28 meters 725.98 feet
INITIAL VERTICAL DIMENSION: 1.50 meters 4.92 feet
RURAL OR URBAN: URBAN
POPULATION: 223871
INITIAL PROBE DISTANCE = 5000. meters 16404. feet
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ *********************** BUILDING DOWNWASH PARAMETERS ********************** ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ BUILDING DOWNWASH NOT USED FOR NON‐POINT SOURCES
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ ************************** FLOW SECTOR ANALYSIS *************************** 25 meter receptor spacing: 1. meters ‐ 5000. meters
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ MAXIMUM IMPACT RECEPTOR
Zo SURFACE 1‐HR CONC RADIAL DIST TEMPORAL
SECTOR ROUGHNESS (ug/m3) (deg) (m) PERIOD
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐
1* 1.000 0.9256 10 225.0 WIN
* = worst case diagonal
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ Attachment B
********************** MAKEMET METEOROLOGY PARAMETERS ********************* ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ MIN/MAX TEMPERATURE: 250.0 / 310.0 (K)
MINIMUM WIND SPEED: 0.5 m/s
ANEMOMETER HEIGHT: 10.000 meters
SURFACE CHARACTERISTICS INPUT: AERMET SEASONAL TABLES
DOMINANT SURFACE PROFILE: Urban
DOMINANT CLIMATE TYPE: Average Moisture
DOMINANT SEASON: Winter
ALBEDO: 0.35
BOWEN RATIO: 1.50
ROUGHNESS LENGTH: 1.000 (meters)
SURFACE FRICTION VELOCITY (U*) NOT ADUSTED
METEOROLOGY CONDITIONS USED TO PREDICT OVERALL MAXIMUM IMPACT ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ ‐‐‐‐‐‐ YR MO DY JDY HR
‐‐ ‐‐ ‐‐ ‐‐‐ ‐‐
10 01 10 10 01
H0 U* W* DT/DZ ZICNV ZIMCH M‐O LEN Z0 BOWEN ALBEDO REF WS ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 HT REF TA HT
‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐
10.0 310.0 2.0
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ ************************ AERSCREEN AUTOMATED DISTANCES ********************** OVERALL MAXIMUM CONCENTRATIONS BY DISTANCE
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐
MAXIMUM MAXIMUM
DIST 1‐HR CONC DIST 1‐HR CONC
(m) (ug/m3) (m) (ug/m3)
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐
1.00 0.7153 2525.00 0.3673E‐01
25.00 0.7462 2550.00 0.3625E‐01
50.00 0.7756 2575.00 0.3578E‐01
75.00 0.8027 2600.00 0.3532E‐01 100.00 0.8277 2625.00 0.3486E‐01 125.00 0.8508 2650.00 0.3442E‐01 150.00 0.8722 2675.00 0.3399E‐01 175.00 0.8921 2700.00 0.3356E‐01 200.00 0.9107 2725.00 0.3315E‐01 225.00 0.9256 2750.00 0.3274E‐01 250.00 0.8595 2775.00 0.3234E‐01 275.00 0.6469 2800.00 0.3195E‐01 300.00 0.5544 2825.00 0.3157E‐01 325.00 0.4911 2850.00 0.3120E‐01 350.00 0.4459 2875.00 0.3083E‐01 375.00 0.4116 2900.00 0.3047E‐01 400.00 0.3826 2925.00 0.3012E‐01 425.00 0.3568 2950.00 0.2978E‐01 450.00 0.3340 2975.00 0.2945E‐01 475.00 0.3136 3000.00 0.2911E‐01 500.00 0.2951 3025.00 0.2879E‐01 525.00 0.2784 3050.00 0.2847E‐01 550.00 0.2633 3075.00 0.2816E‐01 575.00 0.2495 3100.00 0.2785E‐01 600.00 0.2369 3125.00 0.2755E‐01 625.00 0.2253 3150.00 0.2726E‐01 650.00 0.2148 3175.00 0.2697E‐01 675.00 0.2049 3200.00 0.2669E‐01 700.00 0.1959 3225.00 0.2641E‐01 725.00 0.1875 3250.00 0.2614E‐01 750.00 0.1796 3275.00 0.2587E‐01 775.00 0.1724 3300.00 0.2560E‐01 800.00 0.1657 3325.00 0.2535E‐01 825.00 0.1593 3350.00 0.2509E‐01 850.00 0.1533 3375.00 0.2484E‐01 875.00 0.1478 3400.00 0.2460E‐01 900.00 0.1426 3425.00 0.2435E‐01 925.00 0.1377 3450.00 0.2412E‐01 950.00 0.1331 3475.00 0.2389E‐01 975.00 0.1287 3500.00 0.2366E‐01 1000.00 0.1246 3525.00 0.2343E‐01 1025.00 0.1207 3550.00 0.2321E‐01 1050.00 0.1170 3575.00 0.2299E‐01 1075.00 0.1135 3600.00 0.2278E‐01 1100.00 0.1101 3625.00 0.2257E‐01 1125.00 0.1069 3650.00 0.2236E‐01 1150.00 0.1039 3675.00 0.2215E‐01 1175.00 0.1011 3700.00 0.2195E‐01 1200.00 0.9837E‐01 3725.00 0.2175E‐01 1225.00 0.9579E‐01 3750.00 0.2156E‐01 1250.00 0.9332E‐01 3775.00 0.2136E‐01 1275.00 0.9092E‐01 3800.00 0.2117E‐01 1300.00 0.8861E‐01 3825.00 0.2099E‐01 1325.00 0.8641E‐01 3850.00 0.2080E‐01 1350.00 0.8431E‐01 3875.00 0.2062E‐01 1375.00 0.8230E‐01 3900.00 0.2044E‐01 1400.00 0.8038E‐01 3925.00 0.2027E‐01 1425.00 0.7853E‐01 3950.00 0.2009E‐01 1450.00 0.7676E‐01 3975.00 0.1992E‐01 1475.00 0.7507E‐01 4000.00 0.1975E‐01 1500.00 0.7344E‐01 4025.00 0.1959E‐01 1525.00 0.7186E‐01 4050.00 0.1942E‐01 1550.00 0.7033E‐01 4075.00 0.1926E‐01 1575.00 0.6885E‐01 4100.00 0.1934E‐01 1600.00 0.6743E‐01 4125.00 0.1918E‐01 1625.00 0.6606E‐01 4150.00 0.1902E‐01 1650.00 0.6474E‐01 4175.00 0.1886E‐01 1675.00 0.6347E‐01 4200.00 0.1871E‐01 1700.00 0.6223E‐01 4225.00 0.1856E‐01 1725.00 0.6103E‐01 4250.00 0.1841E‐01 1750.00 0.5988E‐01 4275.00 0.1826E‐01 1775.00 0.5876E‐01 4300.00 0.1812E‐01 1800.00 0.5768E‐01 4325.00 0.1797E‐01 1825.00 0.5663E‐01 4350.00 0.1783E‐01 1850.00 0.5562E‐01 4375.00 0.1769E‐01 1875.00 0.5464E‐01 4400.00 0.1756E‐01 1900.00 0.5369E‐01 4425.00 0.1742E‐01 1925.00 0.5277E‐01 4450.00 0.1729E‐01 1950.00 0.5187E‐01 4475.00 0.1715E‐01 1975.00 0.5099E‐01 4500.00 0.1702E‐01 2000.00 0.5014E‐01 4525.00 0.1690E‐01 2025.00 0.4931E‐01 4550.00 0.1677E‐01 2050.00 0.4851E‐01 4575.00 0.1664E‐01 2075.00 0.4773E‐01 4600.00 0.1652E‐01 2100.00 0.4697E‐01 4625.00 0.1640E‐01 2125.00 0.4624E‐01 4650.00 0.1628E‐01 2150.00 0.4552E‐01 4675.00 0.1616E‐01 2175.00 0.4483E‐01 4700.00 0.1604E‐01 2200.00 0.4415E‐01 4725.00 0.1592E‐01 2225.00 0.4349E‐01 4750.00 0.1581E‐01 2250.00 0.4285E‐01 4775.00 0.1570E‐01 2275.00 0.4222E‐01 4800.00 0.1559E‐01 2300.00 0.4161E‐01 4825.00 0.1548E‐01 2325.00 0.4102E‐01 4850.00 0.1537E‐01 2350.00 0.4044E‐01 4875.00 0.1526E‐01 2375.00 0.3987E‐01 4900.00 0.1515E‐01 2400.00 0.3931E‐01 4925.00 0.1505E‐01 2425.00 0.3877E‐01 4950.00 0.1494E‐01 2450.00 0.3824E‐01 4975.00 0.1484E‐01 2475.00 0.3772E‐01 5000.00 0.1474E‐01 2500.00 0.3722E‐01
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ ********************** AERSCREEN MAXIMUM IMPACT SUMMARY ********************* ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ 3‐hour, 8‐hour, and 24‐hour scaled
concentrations are equal to the 1‐hour concentration as referenced in SCREENING PROCEDURES FOR ESTIMATING THE AIR QUALITY
IMPACT OF STATIONARY SOURCES, REVISED (Section 4.5.4)
Report number EPA‐454/R‐92‐019
http://www.epa.gov/scram001/guidance_permit.htm
under Screening Guidance
MAXIMUM SCALED SCALED SCALED SCALED 1‐HOUR 3‐HOUR 8‐HOUR 24‐HOUR ANNUAL
CALCULATION CONC CONC CONC CONC CONC
PROCEDURE (ug/m3) (ug/m3) (ug/m3) (ug/m3) (ug/m3) ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ ‐‐‐‐‐‐‐‐‐‐ ‐‐‐‐‐‐‐‐‐‐ ‐‐‐‐‐‐‐‐‐‐ ‐‐‐‐‐‐‐‐‐‐ ‐‐‐‐‐‐‐‐‐‐ FLAT TERRAIN 0.9256 0.9256 0.9256 0.9256 N/A DISTANCE FROM SOURCE 225.00 meters
IMPACT AT THE
AMBIENT BOUNDARY 0.7153 0.7153 0.7153 0.7153 N/A DISTANCE FROM SOURCE 1.00 meters
AERSCREEN 21112 / AERMOD 21112 10/09/24
16:25:55
TITLE: ArdenwoodWarehouse, Operational
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ ****************************** AREA PARAMETERS **************************** ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ SOURCE EMISSION RATE: 0.115E ‐02 g/s 0.913E‐02 lb/hr
AREA EMISSION RATE: 0.117E‐07 g/(s‐m2) 0.933E ‐07 lb/(hr‐m2) AREA HEIGHT: 3.00 meters 9.84 feet
AREA SOURCE LONG SIDE: 442.57 meters 1452.00 feet
AREA SOURCE SHORT SIDE: 221.28 meters 725.98 feet
INITIAL VERTICAL DIMENSION: 1.50 meters 4.92 feet
RURAL OR URBAN: URBAN
POPULATION: 223871
INITIAL PROBE DISTANCE = 5000. meters 16404. feet
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ *********************** BUILDING DOWNWASH PARAMETERS ********************** ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ BUILDING DOWNWASH NOT USED FOR NON‐POINT SOURCES
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ ************************** FLOW SECTOR ANALYSIS *************************** 25 meter receptor spacing: 1. meters ‐ 5000. meters
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ MAXIMUM IMPACT RECEPTOR
Zo SURFACE 1‐HR CONC RADIAL DIST TEMPORAL
SECTOR ROUGHNESS (ug/m3) (deg) (m) PERIOD
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐
1* 1.000 0.5569 10 225.0 WIN
* = worst case diagonal
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ ********************** MAKEMET METEOROLOGY PARAMETERS ********************* ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ MIN/MAX TEMPERATURE: 250.0 / 310.0 (K)
MINIMUM WIND SPEED: 0.5 m/s
ANEMOMETER HEIGHT: 10.000 meters
SURFACE CHARACTERISTICS INPUT: AERMET SEASONAL TABLES
DOMINANT SURFACE PROFILE: Urban
DOMINANT CLIMATE TYPE: Average Moisture
DOMINANT SEASON: Winter
ALBEDO: 0.35
BOWEN RATIO: 1.50
ROUGHNESS LENGTH: 1.000 (meters)
SURFACE FRICTION VELOCITY (U*) NOT ADUSTED
METEOROLOGY CONDITIONS USED TO PREDICT OVERALL MAXIMUM IMPACT ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ ‐‐‐‐‐‐ YR MO DY JDY HR
‐‐ ‐‐ ‐‐ ‐‐‐ ‐‐
10 01 10 10 01
H0 U* W* DT/DZ ZICNV ZIMCH M‐O LEN Z0 BOWEN ALBEDO REF WS ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 HT
REF TA HT
‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐
10.0 310.0 2.0
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ ************************ AERSCREEN AUTOMATED DISTANCES ********************** OVERALL MAXIMUM CONCENTRATIONS BY DISTANCE
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ MAXIMUM MAXIMUM
DIST 1‐HR CONC DIST 1‐HR CONC
(m) (ug/m3) (m) (ug/m3)
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ ‐‐‐‐
1.00 0.4303 2525.00 0.2210E‐01
25.00 0.4489 2550.00 0.2181E‐01
50.00 0.4667 2575.00 0.2152E‐01
75.00 0.4830 2600.00 0.2125E‐01 100.00 0.4980 2625.00 0.2098E‐01 125.00 0.5118 2650.00 0.2071E‐01 150.00 0.5248 2675.00 0.2045E‐01 175.00 0.5367 2700.00 0.2019E‐01 200.00 0.5479 2725.00 0.1994E‐01 225.00 0.5569 2750.00 0.1970E‐01 250.00 0.5171 2775.00 0.1946E‐01 275.00 0.3892 2800.00 0.1922E‐01 300.00 0.3335 2825.00 0.1899E‐01 325.00 0.2955 2850.00 0.1877E‐01 350.00 0.2682 2875.00 0.1855E‐01 375.00 0.2477 2900.00 0.1833E‐01 400.00 0.2302 2925.00 0.1812E‐01 425.00 0.2147 2950.00 0.1792E‐01 450.00 0.2010 2975.00 0.1772E‐01 475.00 0.1886 3000.00 0.1752E‐01 500.00 0.1776 3025.00 0.1732E‐01 525.00 0.1675 3050.00 0.1713E‐01 550.00 0.1584 3075.00 0.1694E‐01 575.00 0.1501 3100.00 0.1676E‐01 600.00 0.1425 3125.00 0.1658E‐01 625.00 0.1356 3150.00 0.1640E‐01 650.00 0.1292 3175.00 0.1623E‐01 675.00 0.1233 3200.00 0.1606E‐01 700.00 0.1178 3225.00 0.1589E‐01 725.00 0.1128 3250.00 0.1572E‐01 750.00 0.1081 3275.00 0.1556E‐01 775.00 0.1037 3300.00 0.1540E‐01 800.00 0.9970E‐01 3325.00 0.1525E‐01 825.00 0.9584E‐01 3350.00 0.1510E‐01 850.00 0.9226E‐01 3375.00 0.1495E‐01 875.00 0.8892E‐01 3400.00 0.1480E‐01 900.00 0.8581E‐01 3425.00 0.1465E‐01 925.00 0.8284E‐01 3450.00 0.1451E‐01 950.00 0.8005E‐01 3475.00 0.1437E‐01 975.00 0.7743E‐01 3500.00 0.1423E‐01 1000.00 0.7495E‐01 3525.00 0.1410E‐01 1025.00 0.7261E‐01 3550.00 0.1396E‐01 1050.00 0.7040E‐01 3575.00 0.1383E‐01 1075.00 0.6827E‐01 3600.00 0.1370E‐01 1100.00 0.6625E‐01 3625.00 0.1358E‐01 1125.00 0.6434E‐01 3650.00 0.1345E‐01 1150.00 0.6253E‐01 3675.00 0.1333E‐01 1175.00 0.6081E‐01 3700.00 0.1321E‐01 1200.00 0.5918E‐01 3725.00 0.1309E‐01 1225.00 0.5763E‐01 3750.00 0.1297E‐01 1250.00 0.5614E‐01 3775.00 0.1285E‐01 1275.00 0.5470E‐01 3800.00 0.1274E‐01 1300.00 0.5331E‐01 3825.00 0.1263E‐01 1325.00 0.5199E‐01 3850.00 0.1252E‐01 1350.00 0.5073E‐01 3875.00 0.1241E‐01 1375.00 0.4952E‐01 3900.00 0.1230E‐01 1400.00 0.4836E‐01 3925.00 0.1219E‐01 1425.00 0.4725E‐01 3950.00 0.1209E‐01 1450.00 0.4618E‐01 3975.00 0.1199E‐01 1475.00 0.4516E‐01 4000.00 0.1188E‐01 1500.00 0.4418E‐01 4025.00 0.1178E‐01 1525.00 0.4323E‐01 4050.00 0.1168E‐01 1550.00 0.4231E‐01 4075.00 0.1159E‐01 1575.00 0.4142E‐01 4100.00 0.1163E‐01 1600.00 0.4057E‐01 4125.00 0.1154E‐01 1625.00 0.3975E‐01 4150.00 0.1144E‐01 1650.00 0.3895E‐01 4175.00 0.1135E‐01 1675.00 0.3819E‐01 4200.00 0.1126E‐01 1700.00 0.3744E‐01 4225.00 0.1117E‐01 1725.00 0.3672E‐01 4250.00 0.1108E‐01 1750.00 0.3602E‐01 4275.00 0.1099E‐01 1775.00 0.3535E‐01 4300.00 0.1090E‐01 1800.00 0.3470E‐01 4325.00 0.1081E‐01 1825.00 0.3407E‐01 4350.00 0.1073E‐01 1850.00 0.3346E‐01 4375.00 0.1064E‐01 1875.00 0.3287E‐01 4400.00 0.1056E‐01 1900.00 0.3230E‐01 4425.00 0.1048E‐01 1925.00 0.3175E‐01 4450.00 0.1040E‐01 1950.00 0.3121E‐01 4475.00 0.1032E‐01 1975.00 0.3068E‐01 4500.00 0.1024E‐01 2000.00 0.3017E‐01 4525.00 0.1017E‐01 2025.00 0.2967E‐01 4550.00 0.1009E‐01 2050.00 0.2919E‐01 4575.00 0.1001E‐01 2075.00 0.2872E‐01 4600.00 0.9939E‐02 2100.00 0.2826E‐01 4625.00 0.9866E‐02 2125.00 0.2782E‐01 4650.00 0.9793E‐02 2150.00 0.2739E‐01 4675.00 0.9722E‐02 2175.00 0.2697E‐01 4700.00 0.9651E‐02 2200.00 0.2656E‐01 4725.00 0.9581E‐02 2225.00 0.2616E‐01 4750.00 0.9512E‐02 2250.00 0.2578E‐01 4775.00 0.9444E‐02 2275.00 0.2540E‐01 4800.00 0.9377E‐02 2300.00 0.2503E‐01 4825.00 0.9311E‐02 2325.00 0.2468E‐01 4850.00 0.9245E‐02 2350.00 0.2433E‐01 4875.00 0.9180E‐02 2375.00 0.2399E‐01 4900.00 0.9116E‐02 2400.00 0.2365E‐01 4925.00 0.9053E‐02 2425.00 0.2333E‐01 4950.00 0.8990E‐02 2450.00 0.2301E‐01 4975.00 0.8929E‐02 2475.00 0.2270E‐01 5000.00 0.8868E‐02 2500.00 0.2239E‐01
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ ********************** AERSCREEN MAXIMUM IMPACT SUMMARY ********************* ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ 3‐hour, 8‐hour, and 24‐hour scaled
concentrations are equal to the 1‐hour concentration as referenced in SCREENING PROCEDURES FOR ESTIMATING THE AIR QUALITY
IMPACT OF STATIONARY SOURCES, REVISED (Section 4.5.4)
Report number EPA‐454/R‐92‐019
http://www.epa.gov/scram001/guidance_permit.htm
under Screening Guidance
MAXIMUM SCALED SCALED SCALED SCALED 1‐HOUR 3‐HOUR 8‐HOUR 24‐HOUR ANNUAL
CALCULATION CONC CONC CONC CONC CONC
PROCEDURE (ug/m3) (ug/m3) (ug/m3) (ug/m3) (ug/m3) ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ ‐‐‐‐‐‐‐‐‐‐ ‐‐‐‐‐‐‐‐‐‐ ‐‐‐‐‐‐‐‐‐‐ ‐‐‐‐‐‐‐‐‐‐ ‐‐‐‐‐‐‐‐‐‐ FLAT TERRAIN 0.5569 0.5569 0.5569 0.5569 N/A DISTANCE FROM SOURCE 225.00 meters
IMPACT AT THE
AMBIENT BOUNDARY 0.4303 0.4303 0.4303 0.4303 N/A DISTANCE FROM SOURCE 1.00 meters
SOIL WATER AIR PROTECTION ENTERPRISE
2656 29th Street, Suite 201
Santa Monica, California 90405
Attn: Paul Rosenfeld, Ph.D.
Mobil: (310) 795-2335
Office: (310) 452-5555
Fax: (310) 452-5550
Email: [email protected]
Paul E. Rosenfeld, Ph.D. Page 1 of 12 October 2022
Paul Rosenfeld, Ph.D. Chemical Fate and Transport & Air Dispersion Modeling Principal Environmental Chemist Risk Assessment & Remediation Specialist Education
Ph.D. Soil Chemistry, University of Washington, 1999. Dissertation on volatile organic compound filtration.
M.S. Environmental Science, U.C. Berkeley, 1995. Thesis on organic waste economics.
B.A. Environmental Studies, U.C. Santa Barbara, 1991. Focus on wastewater treatment.
Professional Experience
Dr. Rosenfeld has over 25 years of experience conducting environmental investigations and risk assessments for evaluating impacts to human health, property, and ecological receptors. His expertise focuses on the fate and transport of environmental contaminants, human health risk, exposure assessment, and ecological restoration. Dr.
Rosenfeld has evaluated and modeled emissions from oil spills, landfills, boilers and incinerators, process stacks, storage tanks, confined animal feeding operations, industrial, military and agricultural sources, unconventional oil drilling operations, and locomotive and construction engines. His project experience ranges from monitoring and modeling of pollution sources to evaluating impacts of pollution on workers at industrial facilities and residents in surrounding communities. Dr. Rosenfeld has also successfully modeled exposure to contaminants distributed by water systems and via vapor intrusion.
Dr. Rosenfeld has investigated and designed remediation programs and risk assessments for contaminated sites containing lead, heavy metals, mold, bacteria, particulate matter, petroleum hydrocarbons, chlorinated solvents, pesticides, radioactive waste, dioxins and furans, semi- and volatile organic compounds, PCBs, PAHs, creosote, perchlorate, asbestos, per- and poly-fluoroalkyl substances (PFOA/PFOS), unusual polymers, fuel oxygenates (MTBE), among other pollutants. Dr. Rosenfeld also has experience evaluating greenhouse gas emissions from various projects and is an expert on the assessment of odors from industrial and agricultural sites, as well as the evaluation of odor nuisance impacts and technologies for abatement of odorous emissions. As a principal scientist at SWAPE, Dr. Rosenfeld directs air dispersion modeling and exposure assessments. He has served as an expert witness and testified about pollution sources causing nuisance and/or personal injury at sites and has testified as an expert witness on numerous cases involving exposure to soil, water and air contaminants from industrial, railroad, agricultural, and military sources.
Attachment D
Paul E. Rosenfeld, Ph.D. Page 2 of 12 October 2022
Professional History:
Soil Water Air Protection Enterprise (SWAPE); 2003 to present; Principal and Founding Partner UCLA School of Public Health; 2007 to 2011; Lecturer (Assistant Researcher) UCLA School of Public Health; 2003 to 2006; Adjunct Professor UCLA Environmental Science and Engineering Program; 2002-2004; Doctoral Intern Coordinator UCLA Institute of the Environment, 2001-2002; Research Associate Komex H2O Science, 2001 to 2003; Senior Remediation Scientist National Groundwater Association, 2002-2004; Lecturer
San Diego State University, 1999-2001; Adjunct Professor Anteon Corp., San Diego, 2000-2001; Remediation Project Manager Ogden (now Amec), San Diego, 2000-2000; Remediation Project Manager Bechtel, San Diego, California, 1999 – 2000; Risk Assessor King County, Seattle, 1996 – 1999; Scientist
James River Corp., Washington, 1995-96; Scientist
Big Creek Lumber, Davenport, California, 1995; Scientist Plumas Corp., California and USFS, Tahoe 1993-1995; Scientist Peace Corps and World Wildlife Fund, St. Kitts, West Indies, 1991-1993; Scientist
Publications:
Rosenfeld P. E., Spaeth K., Hallman R., Bressler R., Smith, G., (2022) Cancer Risk and Diesel Exhaust Exposure Among Railroad Workers. Water Air Soil Pollution. 233, 171.
Remy, L.L., Clay T., Byers, V., Rosenfeld P. E. (2019) Hospital, Health, and Community Burden After Oil Refinery Fires, Richmond, California 2007 and 2012. Environmental Health. 18:48
Simons, R.A., Seo, Y. Rosenfeld, P., (2015) Modeling the Effect of Refinery Emission On Residential Property Value. Journal of Real Estate Research. 27(3):321-342
Chen, J. A, Zapata A. R., Sutherland A. J., Molmen, D.R., Chow, B. S., Wu, L. E., Rosenfeld, P. E., Hesse, R. C., (2012) Sulfur Dioxide and Volatile Organic Compound Exposure To A Community In Texas City Texas Evaluated Using Aermod and Empirical Data. American Journal of Environmental Science, 8(6), 622-632.
Rosenfeld, P.E. & Feng, L. (2011). The Risks of Hazardous Waste. Amsterdam: Elsevier Publishing.
Cheremisinoff, N.P., & Rosenfeld, P.E. (2011). Handbook of Pollution Prevention and Cleaner Production: Best Practices in the Agrochemical Industry, Amsterdam: Elsevier Publishing.
Gonzalez, J., Feng, L., Sutherland, A., Waller, C., Sok, H., Hesse, R., Rosenfeld, P. (2010). PCBs and Dioxins/Furans in Attic Dust Collected Near Former PCB Production and Secondary Copper Facilities in Sauget, IL.
Procedia Environmental Sciences. 113–125.
Feng, L., Wu, C., Tam, L., Sutherland, A.J., Clark, J.J., Rosenfeld, P.E. (2010). Dioxin and Furan Blood Lipid and Attic Dust Concentrations in Populations Living Near Four Wood Treatment Facilities in the United States. Journal of Environmental Health. 73(6), 34-46.
Cheremisinoff, N.P., & Rosenfeld, P.E. (2010). Handbook of Pollution Prevention and Cleaner Production: Best Practices in the Wood and Paper Industries. Amsterdam: Elsevier Publishing.
Cheremisinoff, N.P., & Rosenfeld, P.E. (2009). Handbook of Pollution Prevention and Cleaner Production: Best Practices in the Petroleum Industry. Amsterdam: Elsevier Publishing.
Paul E. Rosenfeld, Ph.D. Page 3 of 12 October 2022
Wu, C., Tam, L., Clark, J., Rosenfeld, P. (2009). Dioxin and furan blood lipid concentrations in populations living near four wood treatment facilities in the United States. WIT Transactions on Ecology and the Environment, Air Pollution, 123 (17), 319-327.
Tam L. K.., Wu C. D., Clark J. J. and Rosenfeld, P.E. (2008). A Statistical Analysis Of Attic Dust And Blood Lipid Concentrations Of Tetrachloro-p-Dibenzodioxin (TCDD) Toxicity Equivalency Quotients (TEQ) In Two Populations Near Wood Treatment Facilities. Organohalogen Compounds, 70, 002252-002255.
Tam L. K.., Wu C. D., Clark J. J. and Rosenfeld, P.E. (2008). Methods For Collect Samples For Assessing Dioxins And Other Environmental Contaminants In Attic Dust: A Review. Organohalogen Compounds, 70, 000527- 000530.
Hensley, A.R. A. Scott, J. J. J. Clark, Rosenfeld, P.E. (2007). Attic Dust and Human Blood Samples Collected near a Former Wood Treatment Facility. Environmental Research. 105, 194-197.
Rosenfeld, P.E., J. J. J. Clark, A. R. Hensley, M. Suffet. (2007). The Use of an Odor Wheel Classification for Evaluation of Human Health Risk Criteria for Compost Facilities. Water Science & Technology 55(5), 345-357.
Rosenfeld, P. E., M. Suffet. (2007). The Anatomy Of Odour Wheels For Odours Of Drinking Water, Wastewater, Compost And The Urban Environment. Water Science & Technology 55(5), 335-344.
Sullivan, P. J. Clark, J.J.J., Agardy, F. J., Rosenfeld, P.E. (2007). Toxic Legacy, Synthetic Toxins in the Food, Water, and Air in American Cities. Boston Massachusetts: Elsevier Publishing
Rosenfeld, P.E., and Suffet I.H. (2004). Control of Compost Odor Using High Carbon Wood Ash. Water Science and Technology. 49(9),171-178.
Rosenfeld P. E., J.J. Clark, I.H. (Mel) Suffet (2004). The Value of An Odor-Quality-Wheel Classification Scheme For The Urban Environment. Water Environment Federation’s Technical Exhibition and Conference (WEFTEC) 2004. New Orleans, October 2-6, 2004.
Rosenfeld, P.E., and Suffet, I.H. (2004). Understanding Odorants Associated With Compost, Biomass Facilities, and the Land Application of Biosolids. Water Science and Technology. 49(9), 193-199.
Rosenfeld, P.E., and Suffet I.H. (2004). Control of Compost Odor Using High Carbon Wood Ash, Water Science and Technology, 49( 9), 171-178.
Rosenfeld, P. E., Grey, M. A., Sellew, P. (2004). Measurement of Biosolids Odor and Odorant Emissions from Windrows, Static Pile and Biofilter. Water Environment Research. 76(4), 310-315.
Rosenfeld, P.E., Grey, M and Suffet, M. (2002). Compost Demonstration Project, Sacramento California Using High-Carbon Wood Ash to Control Odor at a Green Materials Composting Facility. Integrated Waste Management Board Public Affairs Office, Publications Clearinghouse (MS–6), Sacramento, CA Publication #442-02-008.
Rosenfeld, P.E., and C.L. Henry. (2001). Characterization of odor emissions from three different biosolids. Water Soil and Air Pollution. 127(1-4), 173-191.
Rosenfeld, P.E., and Henry C. L., (2000). Wood ash control of odor emissions from biosolids application. Journal of Environmental Quality. 29, 1662-1668.
Rosenfeld, P.E., C.L. Henry and D. Bennett. (2001). Wastewater dewatering polymer affect on biosolids odor emissions and microbial activity. Water Environment Research. 73(4), 363-367.
Rosenfeld, P.E., and C.L. Henry. (2001). Activated Carbon and Wood Ash Sorption of Wastewater, Compost, and Biosolids Odorants. Water Environment Research, 73, 388-393.
Paul E. Rosenfeld, Ph.D. Page 4 of 12 October 2022
Rosenfeld, P.E., and Henry C. L., (2001). High carbon wood ash effect on biosolids microbial activity and odor.
Water Environment Research. 131(1-4), 247-262.
Chollack, T. and P. Rosenfeld. ( 1998). Compost Amendment Handbook For Landscaping. Prepared for and distributed by the City of Redmond, Washington State.
Rosenfeld, P. E. (1992). The Mount Liamuiga Crater Trail. Heritage Magazine of St. Kitts, 3(2).
Rosenfeld, P. E. (1993). High School Biogas Project to Prevent Deforestation On St. Kitts. Biomass Users Network, 7(1).
Rosenfeld, P. E. ( 1998). Characterization, Quantification, and Control of Odor Emissions From Biosolids Application To Forest Soil. Doctoral Thesis. University of Washington College of Forest Resources.
Rosenfeld, P. E. (1994). Potential Utilization of Small Diameter Trees on Sierra County Public Land. Masters thesis reprinted by the Sierra County Economic Council. Sierra County, California.
Rosenfeld, P. E. (1991). How to Build a Small Rural Anaerobic Digester & Uses Of Biogas In The First And Third World. Bachelors Thesis. University of California.
Presentations:
Rosenfeld, P.E., "The science for Perfluorinated Chemicals (PFAS): What makes remediation so hard?" Law Seminars International, (May 9-10, 2018) 800 Fifth Avenue, Suite 101 Seattle, WA.
Rosenfeld, P.E., Sutherland, A; Hesse, R.; Zapata, A. (October 3-6, 2013). Air dispersion modeling of volatile organic emissions from multiple natural gas wells in Decatur, TX. 44th Western Regional Meeting, American Chemical Society. Lecture conducted from Santa Clara, CA.
Sok, H.L.; Waller, C.C.; Feng, L.; Gonzalez, J.; Sutherland, A.J.; Wisdom-Stack, T.; Sahai, R.K.; Hesse, R.C.; Rosenfeld, P.E. (June 20-23, 2010). Atrazine: A Persistent Pesticide in Urban Drinking Water .
Urban Environmental Pollution. Lecture conducted from Boston, MA.
Feng, L.; Gonzalez, J.; Sok, H.L.; Sutherland, A.J.; Waller, C.C.; Wisdom-Stack, T.; Sahai, R.K.; La, M.; Hesse, R.C.; Rosenfeld, P.E. (June 20-23, 2010). Bringing Environmental Justice to East St. Louis, Illinois. Urban Environmental Pollution. Lecture conducted from Boston, MA.
Rosenfeld, P.E . (April 19-23, 2009). Perfluoroctanoic Acid (PFOA) and Perfluoroactane Sulfonate (PFOS) Contamination in Drinking Water From the Use of Aqueous Film Forming Foams (AFFF) at Airports in the United States. 2009 Ground Water Summit and 2009 Ground Water Protection Council Spring Meeting , Lecture conducted from Tuscon, AZ.
Rosenfeld, P.E. (April 19-23, 2009). Cost to Filter Atrazine Contamination from Drinking Water in the United States” Contamination in Drinking Water From the Use of Aqueous Film Forming Foams (AFFF) at Airports in the United States. 2009 Ground Water Summit and 2009 Ground Water Protection Council Spring Meeting . Lecture conducted from Tuscon, AZ.
Wu, C., Tam, L., Clark, J., Rosenfeld, P . (20-22 July, 2009). Dioxin and furan blood lipid concentrations in populations living near four wood treatment facilities in the United States. Brebbia, C.A. and Popov, V., eds., Air Pollution XVII: Proceedings of the Seventeenth International Conference on Modeling, Monitoring and Management of Air Pollution. Lecture conducted from Tallinn, Estonia.
Rosenfeld, P. E. (October 15-18, 2007). Moss Point Community Exposure To Contaminants From A Releasing Facility. The 23rd Annual International Conferences on Soils Sediment and Water. Platform lecture conducted from University of Massachusetts, Amherst MA.
Paul E. Rosenfeld, Ph.D. Page 5 of 12 October 2022
Rosenfeld, P. E. (October 15-18, 2007). The Repeated Trespass of Tritium-Contaminated Water Into A Surrounding Community Form Repeated Waste Spills From A Nuclear Power Plant. The 23rd Annual International Conferences on Soils Sediment and Water. Platform lecture conducted from University of Massachusetts, Amherst MA.
Rosenfeld, P. E. (October 15-18, 2007). Somerville Community Exposure To Contaminants From Wood Treatment Facility Emissions. The 23rd Annual International Conferences on Soils Sediment and Water. Lecture conducted from University of Massachusetts, Amherst MA.
Rosenfeld P. E. (March 2007). Production, Chemical Properties, Toxicology, & Treatment Case Studies of 1,2,3- Trichloropropane (TCP). The Association for Environmental Health and Sciences (AEHS) Annual Meeting. Lecture conducted from San Diego, CA.
Rosenfeld P. E. (March 2007). Blood and Attic Sampling for Dioxin/Furan, PAH, and Metal Exposure in Florala, Alabama. The AEHS Annual Meeting. Lecture conducted from San Diego, CA.
Hensley A.R., Scott, A., Rosenfeld P.E., Clark, J.J.J. (August 21 – 25, 2006). Dioxin Containing Attic Dust And Human Blood Samples Collected Near A Former Wood Treatment Facility. The 26th International Symposium on Halogenated Persistent Organic Pollutants – DIOXIN2006. Lecture conducted from Radisson SAS Scandinavia Hotel in Oslo Norway.
Hensley A.R., Scott, A., Rosenfeld P.E., Clark, J.J.J. (November 4-8, 2006). Dioxin Containing Attic Dust And Human Blood Samples Collected Near A Former Wood Treatment Facility. APHA 134 Annual Meeting & Exposition. Lecture conducted from Boston Massachusetts.
Paul Rosenfeld Ph.D. (October 24-25, 2005). Fate, Transport and Persistence of PFOA and Related Chemicals.
Mealey’s C8/PFOA. Science, Risk & Litigation Conference. Lecture conducted from The Rittenhouse Hotel, Philadelphia, PA.
Paul Rosenfeld Ph.D. (September 19, 2005). Brominated Flame Retardants in Groundwater: Pathways to Human Ingestion, Toxicology and Remediation PEMA Emerging Contaminant Conference. Lecture conducted from Hilton Hotel, Irvine California.
Paul Rosenfeld Ph.D. (September 19, 2005). Fate, Transport, Toxicity, And Persistence of 1,2,3-TCP. PEMA Emerging Contaminant Conference. Lecture conducted from Hilton Hotel in Irvine, California.
Paul Rosenfeld Ph.D. (September 26-27, 2005). Fate, Transport and Persistence of PDBEs. Mealey’s Groundwater Conference. Lecture conducted from Ritz Carlton Hotel, Marina Del Ray, California.
Paul Rosenfeld Ph.D. (June 7-8, 2005). Fate, Transport and Persistence of PFOA and Related Chemicals.
International Society of Environmental Forensics: Focus On Emerging Contaminants. Lecture conducted from Sheraton Oceanfront Hotel, Virginia Beach, Virginia.
Paul Rosenfeld Ph.D. (July 21-22, 2005). Fate Transport, Persistence and Toxicology of PFOA and Related Perfluorochemicals. 2005 National Groundwater Association Ground Water And Environmental Law Conference.
Lecture conducted from Wyndham Baltimore Inner Harbor, Baltimore Maryland.
Paul Rosenfeld Ph.D. (July 21-22, 2005). Brominated Flame Retardants in Groundwater: Pathways to Human Ingestion, Toxicology and Remediation. 2005 National Groundwater Association Ground Water and Environmental Law Conference. Lecture conducted from Wyndham Baltimore Inner Harbor, Baltimore Maryland.
Paul Rosenfeld, Ph.D. and James Clark Ph.D. and Rob Hesse R.G. (May 5-6, 2004). Tert-butyl Alcohol Liability and Toxicology, A National Problem and Unquantified Liability. National Groundwater Association. Environmental Law Conference. Lecture conducted from Congress Plaza Hotel, Chicago Illinois.
Paul E. Rosenfeld, Ph.D. Page 6 of 12 October 2022
Paul Rosenfeld, Ph.D. (March 2004). Perchlorate Toxicology. Meeting of the American Groundwater Trust.
Lecture conducted from Phoenix Arizona.
Hagemann, M.F., Paul Rosenfeld, Ph.D. and Rob Hesse (2004). Perchlorate Contamination of the Colorado River.
Meeting of tribal representatives. Lecture conducted from Parker, AZ.
Paul Rosenfeld, Ph.D. (April 7, 2004). A National Damage Assessment Model For PCE and Dry Cleaners.
Drycleaner Symposium. California Ground Water Association. Lecture conducted from Radison Hotel, Sacramento, California.
Rosenfeld, P. E., Grey, M., (June 2003) Two stage biofilter for biosolids composting odor control. Seventh International In Situ And On Site Bioremediation Symposium Battelle Conference Orlando, FL.
Paul Rosenfeld, Ph.D. and James Clark Ph.D. (February 20-21, 2003) Understanding Historical Use, Chemical Properties, Toxicity and Regulatory Guidance of 1,4 Dioxane. National Groundwater Association. Southwest Focus Conference. Water Supply and Emerging Contaminants.. Lecture conducted from Hyatt Regency Phoenix Arizona.
Paul Rosenfeld, Ph.D. (February 6-7, 2003). Underground Storage Tank Litigation and Remediation. California CUPA Forum. Lecture conducted from Marriott Hotel, Anaheim California.
Paul Rosenfeld, Ph.D. (October 23, 2002) Underground Storage Tank Litigation and Remediation. EPA Underground Storage Tank Roundtable. Lecture conducted from Sacramento California.
Rosenfeld, P.E. and Suffet, M. (October 7- 10, 2002). Understanding Odor from Compost, Wastewater and Industrial Processes. Sixth Annual Symposium On Off Flavors in the Aquatic Environment. International Water Association. Lecture conducted from Barcelona Spain.
Rosenfeld, P.E. and Suffet, M. (October 7- 10, 2002). Using High Carbon Wood Ash to Control Compost Odor.
Sixth Annual Symposium On Off Flavors in the Aquatic Environment. International Water Association. Lecture conducted from Barcelona Spain.
Rosenfeld, P.E. and Grey, M. A. (September 22-24, 2002). Biocycle Composting For Coastal Sage Restoration.
Northwest Biosolids Management Association. Lecture conducted from Vancouver Washington..
Rosenfeld, P.E. and Grey, M. A. (November 11-14, 2002). Using High-Carbon Wood Ash to Control Odor at a Green Materials Composting Facility. Soil Science Society Annual Conference. Lecture conducted from Indianapolis, Maryland.
Rosenfeld. P.E. (September 16, 2000). Two stage biofilter for biosolids composting odor control. Water Environment Federation. Lecture conducted from Anaheim California.
Rosenfeld. P.E. (October 16, 2000). Wood ash and biofilter control of compost odor. Biofest. Lecture conducted from Ocean Shores, California.
Rosenfeld, P.E. (2000). Bioremediation Using Organic Soil Amendments. California Resource Recovery Association. Lecture conducted from Sacramento California.
Rosenfeld, P.E., C.L. Henry, R. Harrison. (1998). Oat and Grass Seed Germination and Nitrogen and Sulfur Emissions Following Biosolids Incorporation With High-Carbon Wood-Ash. Water Environment Federation 12th Annual Residuals and Biosolids Management Conference Proceedings. Lecture conducted from Bellevue Washington.
Rosenfeld, P.E., and C.L. Henry. (1999). An evaluation of ash incorporation with biosolids for odor reduction. Soil Science Society of America. Lecture conducted from Salt Lake City Utah.
Paul E. Rosenfeld, Ph.D. Page 7 of 12 October 2022
Rosenfeld, P.E., C.L. Henry, R. Harrison. (1998). Comparison of Microbial Activity and Odor Emissions from Three Different Biosolids Applied to Forest Soil. Brown and Caldwell. Lecture conducted from Seattle Washington.
Rosenfeld, P.E., C.L. Henry. (1998). Characterization, Quantification, and Control of Odor Emissions from Biosolids Application To Forest Soil. Biofest. Lecture conducted from Lake Chelan, Washington.
Rosenfeld, P.E, C.L. Henry, R. Harrison. (1998). Oat and Grass Seed Germination and Nitrogen and Sulfur Emissions Following Biosolids Incorporation With High-Carbon Wood-Ash. Water Environment Federation 12th Annual Residuals and Biosolids Management Conference Proceedings. Lecture conducted from Bellevue Washington.
Rosenfeld, P.E., C.L. Henry, R. B. Harrison, and R. Dills. (1997). Comparison of Odor Emissions From Three Different Biosolids Applied to Forest Soil. Soil Science Society of America. Lecture conducted from Anaheim California.
Teaching Experience:
UCLA Department of Environmental Health (Summer 2003 through 20010) Taught Environmental Health Science 100 to students, including undergrad, medical doctors, public health professionals and nurses. Course focused on the health effects of environmental contaminants.
National Ground Water Association, Successful Remediation Technologies. Custom Course in Sante Fe, New Mexico. May 21, 2002. Focused on fate and transport of fuel contaminants associated with underground storage tanks.
National Ground Water Association; Successful Remediation Technologies Course in Chicago Illinois. April 1, 2002. Focused on fate and transport of contaminants associated with Superfund and RCRA sites.
California Integrated Waste Management Board, April and May, 2001. Alternative Landfill Caps Seminar in San Diego, Ventura, and San Francisco. Focused on both prescriptive and innovative landfill cover design.
UCLA Department of Environmental Engineering, February 5, 2002. Seminar on Successful Remediation Technologies focusing on Groundwater Remediation.
University Of Washington, Soil Science Program, Teaching Assistant for several courses including: Soil Chemistry, Organic Soil Amendments, and Soil Stability.
U.C. Berkeley, Environmental Science Program Teaching Assistant for Environmental Science 10.
Academic Grants Awarded:
California Integrated Waste Management Board. $41,000 grant awarded to UCLA Institute of the Environment.
Goal: To investigate effect of high carbon wood ash on volatile organic emissions from compost. 2001.
Synagro Technologies, Corona California: $10,000 grant awarded to San Diego State University.
Goal: investigate effect of biosolids for restoration and remediation of degraded coastal sage soils. 2000.
King County, Department of Research and Technology, Washington State. $100,000 grant awarded to University of Washington: Goal: To investigate odor emissions from biosolids application and the effect of polymers and ash on VOC emissions. 1998.
Northwest Biosolids Management Association, Washington State. $20,000 grant awarded to investigate effect of polymers and ash on VOC emissions from biosolids. 1997.
Paul E. Rosenfeld, Ph.D. Page 8 of 12 October 2022
James River Corporation, Oregon: $10,000 grant was awarded to investigate the success of genetically engineered Poplar trees with resistance to round-up. 1996.
United State Forest Service, Tahoe National Forest: $15,000 grant was awarded to investigating fire ecology of the Tahoe National Forest. 1995.
Kellogg Foundation, Washington D.C. $500 grant was awarded to construct a large anaerobic digester on St. Kitts in West Indies. 1993
Deposition and/or Trial Testimony:
In the Superior Court of the State of California, County of San Bernardino Billy Wildrick, Plaintiff vs. BNSF Railway Company
Case No. CIVDS1711810
Rosenfeld Deposition 10-17-2022
In the State Court of Bibb County, State of Georgia
Richard Hutcherson, Plaintiff vs Norfolk Southern Railway Company Case No. 10-SCCV-092007
Rosenfeld Deposition 10-6-2022
In the Civil District Court of the Parish of Orleans, State of Louisiana Millard Clark, Plaintiff vs. Dixie Carriers, Inc. et al.
Case No. 2020-03891
Rosenfeld Deposition 9-15-2022
In The Circuit Court of Livingston County, State of Missouri, Circuit Civil Division Shirley Ralls, Plaintiff vs. Canadian Pacific Railway and Soo Line Railroad Case No. 18-LV-CC0020
Rosenfeld Deposition 9-7-2022
In The Circuit Court of the 13th Judicial Circuit Court, Hillsborough County, Florida Civil Division Jonny C. Daniels, Plaintiff vs. CSX Transportation Inc.
Case No. 20-CA-5502
Rosenfeld Deposition 9-1-2022
In The Circuit Court of St. Louis County, State of Missouri Kieth Luke et. al. Plaintiff vs. Monsanto Company et. al.
Case No. 19SL-CC03191
Rosenfeld Deposition 8-25-2022
In The Circuit Court of the 13th Judicial Circuit Court, Hillsborough County, Florida Civil Division Jeffery S. Lamotte, Plaintiff vs. CSX Transportation Inc.
Case No. NO. 20-CA-0049
Rosenfeld Deposition 8-22-2022
In State of Minnesota District Court, County of St. Louis Sixth Judicial District Greg Bean, Plaintiff vs. Soo Line Railroad Company
Case No. 69-DU-CV-21-760
Rosenfeld Deposition 8-17-2022
In United States District Court Western District of Washington at Tacoma, Washington John D. Fitzgerald Plaintiff vs. BNSF
Case No. 3:21-cv-05288-RJB
Rosenfeld Deposition 8-11-2022
Paul E. Rosenfeld, Ph.D. Page 9 of 12 October 2022
In Circuit Court of the Sixth Judicial Circuit, Macon Illinois Rocky Bennyhoff Plaintiff vs. Norfolk Southern
Case No. 20-L-56
Rosenfeld Deposition 8-3-2022
In Court of Common Pleas, Hamilton County Ohio
Joe Briggins Plaintiff vs. CSX
Case No. A2004464
Rosenfeld Deposition 6-17-2022
In the Superior Court of the State of California, County of Kern George LaFazia vs. BNSF Railway Company.
Case No. BCV-19-103087
Rosenfeld Deposition 5-17-2022
In the Circuit Court of Cook County Illinois
Bobby Earles vs. Penn Central et. al.
Case No. 2020-L-000550
Rosenfeld Deposition 4-16-2022
In United States District Court Easter District of Florida Albert Hartman Plaintiff vs. Illinois Central
Case No. 2:20-cv-1633
Rosenfeld Deposition 4-4-2022
In the Circuit Court of the 4th Judicial Circuit, in and For Duval County, Florida Barbara Steele vs. CSX Transportation
Case No.16-219-Ca-008796
Rosenfeld Deposition 3-15-2022
In United States District Court Easter District of New York Romano et al. vs. Northrup Grumman Corporation
Case No. 16-cv-5760
Rosenfeld Deposition 3-10-2022
In the Circuit Court of Cook County Illinois
Linda Benjamin vs. Illinois Central
Case No. No. 2019 L 007599
Rosenfeld Deposition 1-26-2022
In the Circuit Court of Cook County Illinois
Donald Smith vs. Illinois Central
Case No. No. 2019 L 003426
Rosenfeld Deposition 1-24-2022
In the Circuit Court of Cook County Illinois
Jan Holeman vs. BNSF
Case No. 2019 L 000675
Rosenfeld Deposition 1-18-2022
In the State Court of Bibb County State of Georgia
Dwayne B. Garrett vs. Norfolk Southern
Case No. 20-SCCV-091232
Rosenfeld Deposition 11-10-2021
Paul E. Rosenfeld, Ph.D. Page 10 of 12 October 2022
In the Circuit Court of Cook County Illinois
Joseph Ruepke vs. BNSF
Case No. 2019 L 007730
Rosenfeld Deposition 11-5-2021
In the United States District Court For the District of Nebraska Steven Gillett vs. BNSF
Case No. 4:20-cv-03120
Rosenfeld Deposition 10-28-2021
In the Montana Thirteenth District Court of Yellowstone County James Eadus vs. Soo Line Railroad and BNSF
Case No. DV 19-1056
Rosenfeld Deposition 10-21-2021
In the Circuit Court Of The Twentieth Judicial Circuit, St Clair County, Illinois Martha Custer et al.cvs. Cerro Flow Products, Inc.
Case No. 0i9-L-2295
Rosenfeld Deposition 5-14-2021
Trial October 8-4-2021
In the Circuit Court of Cook County Illinois
Joseph Rafferty vs. Consolidated Rail Corporation and National Railroad Passenger Corporation d/b/a
AMTRAK,
Case No. 18-L-6845
Rosenfeld Deposition 6-28-2021
In the United States District Court For the Northern District of Illinois Theresa Romcoe vs. Northeast Illinois Regional Commuter Railroad Corporation d/b/a METRA Rail Case No. 17-cv-8517
Rosenfeld Deposition 5-25-2021
In the Superior Court of the State of Arizona In and For the Cunty of Maricopa Mary Tryon et al. vs. The City of Pheonix v. Cox Cactus Farm, L.L.C., Utah Shelter Systems, Inc.
Case No. CV20127-094749
Rosenfeld Deposition 5-7-2021
In the United States District Court for the Eastern District of Texas Beaumont Division Robinson, Jeremy et al vs. CNA Insurance Company et al.
Case No. 1:17-cv-000508
Rosenfeld Deposition 3-25-2021
In the Superior Court of the State of California, County of San Bernardino Gary Garner, Personal Representative for the Estate of Melvin Garner vs. BNSF Railway Company.
Case No. 1720288
Rosenfeld Deposition 2-23-2021
In the Superior Court of the State of California, County of Los Angeles, Spring Street Courthouse Benny M Rodriguez vs. Union Pacific Railroad, A Corporation, et al.
Case No. 18STCV01162
Rosenfeld Deposition 12-23-2020
In the Circuit Court of Jackson County, Missouri
Karen Cornwell, Plaintiff, vs. Marathon Petroleum, LP, Defendant.
Case No. 1716-CV10006
Rosenfeld Deposition 8-30-2019
Paul E. Rosenfeld, Ph.D. Page 11 of 12 October 2022
In the United States District Court For The District of New Jersey Duarte et al, Plaintiffs, vs. United States Metals Refining Company et. al. Defendant.
Case No. 2:17-cv-01624-ES-SCM
Rosenfeld Deposition 6-7-2019
In the United States District Court of Southern District of Texas Galveston Division M/T Carla Maersk vs. Conti 168., Schiffahrts-GMBH & Co. Bulker KG MS “Conti Perdido” Defendant.
Case No. 3:15-CV-00106 consolidated with 3:15-CV-00237
Rosenfeld Deposition 5-9-2019
In The Superior Court of the State of California In And For The County Of Los Angeles – Santa Monica Carole-Taddeo-Bates et al., vs. Ifran Khan et al., Defendants Case No. BC615636
Rosenfeld Deposition 1-26-2019
In The Superior Court of the State of California In And For The County Of Los Angeles – Santa Monica The San Gabriel Valley Council of Governments et al. vs El Adobe Apts. Inc. et al., Defendants Case No. BC646857
Rosenfeld Deposition 10-6-2018; Trial 3-7-19
In United States District Court For The District of Colorado Bells et al. Plaintiffs vs. The 3M Company et al., Defendants Case No. 1:16-cv-02531-RBJ
Rosenfeld Deposition 3-15-2018 and 4-3-2018
In The District Court Of Regan County, Texas, 112th Judicial District Phillip Bales et al., Plaintiff vs. Dow Agrosciences, LLC, et al., Defendants Cause No. 1923
Rosenfeld Deposition 11-17-2017
In The Superior Court of the State of California In And For The County Of Contra Costa Simons et al., Plaintifs vs. Chevron Corporation, et al., Defendants Cause No. C12-01481
Rosenfeld Deposition 11-20-2017
In The Circuit Court Of The Twentieth Judicial Circuit, St Clair County, Illinois Martha Custer et al., Plaintiff vs. Cerro Flow Products, Inc., Defendants Case No.: No. 0i9-L-2295
Rosenfeld Deposition 8-23-2017
In United States District Court For The Southern District of Mississippi Guy Manuel vs. The BP Exploration et al., Defendants
Case No. 1:19-cv-00315-RHW
Rosenfeld Deposition 4-22-2020
In The Superior Court of the State of California, For The County of Los Angeles Warrn Gilbert and Penny Gilber, Plaintiff vs. BMW of North America LLC Case No. LC102019 (c/w BC582154)
Rosenfeld Deposition 8-16-2017, Trail 8-28-2018
In the Northern District Court of Mississippi, Greenville Division Brenda J. Cooper, et al., Plaintiffs, vs. Meritor Inc., et al., Defendants Case No. 4:16-cv-52-DMB-JVM
Rosenfeld Deposition July 2017
Paul E. Rosenfeld, Ph.D. Page 12 of 12 October 2022
In The Superior Court of the State of Washington, County of Snohomish Michael Davis and Julie Davis et al., Plaintiff vs. Cedar Grove Composting Inc., Defendants Case No. 13-2-03987-5
Rosenfeld Deposition, February 2017
Trial March 2017
In The Superior Court of the State of California, County of Alameda Charles Spain., Plaintiff vs. Thermo Fisher Scientific, et al., Defendants Case No. RG14711115
Rosenfeld Deposition September 2015
In The Iowa District Court In And For Poweshiek County
Russell D. Winburn, et al., Plaintiffs vs. Doug Hoksbergen, et al., Defendants Case No. LALA002187
Rosenfeld Deposition August 2015
In The Circuit Court of Ohio County, West Virginia
Robert Andrews, et al. v. Antero, et al.
Civil Action No. 14-C-30000
Rosenfeld Deposition June 2015
In The Iowa District Court for Muscatine County
Laurie Freeman et. al. Plaintiffs vs. Grain Processing Corporation, Defendant Case No. 4980
Rosenfeld Deposition May 2015
In the Circuit Court of the 17th Judicial Circuit, in and For Broward County, Florida Walter Hinton, et. al. Plaintiff, vs. City of Fort Lauderdale, Florida, a Municipality, Defendant.
Case No. CACE07030358 (26)
Rosenfeld Deposition December 2014
In the County Court of Dallas County Texas
Lisa Parr et al, Plaintiff, vs. Aruba et al, Defendant.
Case No. cc-11-01650-E
Rosenfeld Deposition: March and September 2013
Rosenfeld Trial April 2014
In the Court of Common Pleas of Tuscarawas County Ohio
John Michael Abicht, et al., Plaintiffs, vs. Republic Services, Inc., et al., Defendants Case No. 2008 CT 10 0741 (Cons. w/ 2009 CV 10 0987)
Rosenfeld Deposition October 2012
In the United States District Court for the Middle District of Alabama, Northern Division James K. Benefield, et al., Plaintiffs, vs. International Paper Company, Defendant.
Civil Action No. 2:09-cv-232-WHA-TFM
Rosenfeld Deposition July 2010, June 2011
In the Circuit Court of Jefferson County Alabama
Jaeanette Moss Anthony, et al., Plaintiffs, vs. Drummond Company Inc., et al., Defendants Civil Action No. CV 2008-2076
Rosenfeld Deposition September 2010
In the United States District Court, Western District Lafayette Division Ackle et al., Plaintiffs, vs. Citgo Petroleum Corporation, et al., Defendants.
Case No. 2:07CV1052
Rosenfeld Deposition July 2009
EXHIBIT C
From: Juniet Rotter
To: Mark Hungerford
Subject: FW: PRP2022-00014 Ardenwood @ Paseo
Date: Tuesday, October 12, 2021 4:50:53 PM
Attachments: PRP 20210924123311172.pdf
Hi Mark,
Alameda County Water District (District) Development Services has reviewed the planning application materials, received September 24th, for the Ardenwood @ Paseo Padre project located at 6200 Paseo Padre Parkway in Fremont. The District offers the following comments:
1. The notice indicates the project calls for a six-building campus for R&D manufacturing and office buildings and the renovation of an existing one-story high bay manufacturing building. Prior to approving/providing water service, ACWD requests the applicant provide a description of the type of R&D manufacturing anticipated, number of employees proposed and the anticipated water demand for the operation at the buildings. Depending on the type of manufacturing, occupancy number and water demand, additional requirements, including preparation of a Water Supply Assessment (WSA), may be necessary.
2. There is no irrigation service shown. A separate service line and meter is required for irrigation demands.
3. It is not clear from the plans if the parcels for Buildings 2,3,4 and 5 will be combined into one parcel. If these parcels will be combined into one parcel, the proposed is acceptable for the private fire hydrants. If the parcels will not be combined into one parcel and will remain individual parcels, ACWD advises that the proposed buildings have their own fire hydrants from a new service, not connected to the private fire line serving the private fire hydrants on the other parcels.
This will eliminate any issues in the future if the lots/parcels are owned individually. If not, the CC&R’s should address the fire hydrants to the parcels being off the same private looped fire service and responsibility for any and all service charges and usage costs. The private fire hydrant layout for Building 6 is acceptable as it only services this lot.
4. Each building shall have a separate individual fire service from the public main located in the street fronting the building, not off the private fire line feeding the fire hydrants.
5. Each non-residential, irrigation and dedicated fire services to each building and the service line for on-site private fire hydrants will require above-ground reduced pressure backflow prevention device(s). Backflow prevention devices must be located in accordance with District Standard Drawings BP-1-08 through BP-3-08. The location and screening of these above-ground devices should be considered in the site design to address both District installation standards as well as aesthetic concerns of the development. Backflows located within buildings are not acceptable.
6. The District requires that minimum clearance requirements are maintained between water meters, service lines, fire hydrants or mains and the nearest utilities, buildings, and trees. Reference District Standard Drawings CL-1-08 through CL-5-08.
7. Easements dedicated to the District shall be provided for all District-owned appurtenances located in private property and outside the public right-of-way. Easements dedicated to the District will require a plat and legal description, prepared by a licensed surveyor, to District standards, along with a current title report for any property or properties affected by the easement. The applicant should refer to the Development Specifications or contact the District Engineering Department for more information.
8. Copies of the District’s Standard Specifications for Water Main Installation and Development Specifications for Public Water System Extensions are available on the District's website at http://www.acwd.org.
9. For modifications of existing water facilities or to initiate new water service to the property, the developer should contact the District Engineering Department. Any existing water services which will not be used in the new development must be removed by the District at the developer's expense.
10. Project Proponent should contact the District’s Groundwater Department regarding requirements related to drilling, existing wells or elevator shaft construction.
We appreciate the opportunity to review the proposed development and encourage the project proponents to meet with District staff early in the project development process to review these and other issues. If you have any questions, please call me at (510) 668-4472.
Juni Rotter
Development Services Manager
Alameda County Water District
43885 S. Grimmer Blvd.
Fremont, CA 94538
Phone # (510) 668-4472
Fax # (510) 651-1760
e-mail: [email protected]
From: Crystal Flores <[email protected]>
Sent: Friday, September 24, 2021 2:48 PM
To: Juniet Rotter <[email protected]>
Cc: Anton Shorno <[email protected]>
Subject: PRP- Inbox
Hi Juni and Anton,
The following PRP came in the mail today. I dropped off the hard copy in your desk inbox. (Juni yours is the original)
Thank you,
Crystal Flores, Office Assistant I (TEMP)
[email protected]
Engineering Department
Alameda County Water District
Direct line: 510.668.4405
Engr Office: 510.668.4499
EXHIBIT D
December 18, 2023
City of Fremont
3300 Capitol Ave.
Fremont, CA 94538
Phone: (510) 494-44541
RE: 4th Submittal Review - PRP2022-00466ARC TEC #215334 Ardenwood @ Paseo
6200 Paseo Padre Pkwy, Fremont, CA
In reply to your correspondence dated December 5, 2023, please find our responses to your comments.
Item # Sheet # The comment
The response
Engineering Comments:
1. A-000 C4: (Repeat) Thanks for providing the soil report. However, the submittal of the geotechnical report via a separate TPR application is still pending. The peer review must be approved prior to approval of the entitlement.
C3 Comment Reminder: The soil report from Cornerstone Earth Group should be submitted with a separate TPR application. Please note the peer review must be approved prior to approval of the
entitlement.
Response: Separate TPR application # TPR2024-00008 has been submitted online.
2. C2.0 Informational: During building permit submittal, developer is required to submit a hydrology map and hydraulic calculations prepared, stamped, and signed by a licensed California Civil Engineer using a design storm of 15-year recurrence interval for primary facilities and 10- year recurrence interval for secondary facilities in accordance with the Alameda County Public Works Agency Hydrology and Hydraulics Criteria to ensure adequate conveyance of storm run-off from the project site. Off-site construction of storm drainage facilities s to mitigate projected flows may be required.
Response: Duly noted. Hydraulic calculations will be submitted during the building permit submittal process.
3. EX1 Informational: During building permit submittal, please furnish a letter from the owner which contains the following in addition to the submitted exhibits:
a. Request to waive the standard freeboard requirement. b. Hold harmless statement for the City of Fremont due to the granting of the waiver.
c. Acknowledgment that water may pond in the parking area. d. Acknowledgment that this information will be passed on to subsequent owners of the property.
Response: Duly noted.
Arizona
2960 E. Northern Avenue
Building C
Phoenix, AZ 85028
602.953.2355 t
480.562.6719 f
California
1731 Technology Drive
Suite 750
San Jose, CA 95110
408.496.0676 t
www.arctecinc.com
City of Fremont ARC TEC # 215334
December 18, 2023
Item # Sheet # The comment
The response
4. P1 Thanks for providing the soil report. However, the submittal of the geotechnical report via a separate TPR application is still pending. The peer review must be approved prior to approval of the entitlement.
Response: Geotechnical report has been submitted via separate TPR application # TPR2024-00008.
Planning Comments:
1. A-000 Application PLN2022-00466 is incomplete. Please provide the following items as part of your Cycle 2 submittal to complete the application:
•Environmental Impact Assessment application
•Lot Combination materials (plat map and legals) Title Report •Phase 1 ESA Draft TMD plan
•Geotechnical Study
CYCLE 2 - The above completeness items remain outstanding. Please provide all items listed above as part of the Cycle 3 resubmittal package to complete the application.
CYCLE 3 - The above completeness items remain outstanding. Please provide all items listed above as part of the Cycle 4 resubmittal package to complete the application.
CYCLE 4 - The application remains incomplete pending the filing of a Phase 1 ESA that covers the full extent of the project area. This is a key component of the project's CEQA analysis - please provide.
Response: Duly noted. Phase 1 ESA will be provided under separate cover.
2. A000 Since the project includes discretionary approval, it is subject to the California Environmental Quality Act (CEQA). Based on the scope of work an Initial Study will likely be required. Staff will identify which technical studies are necessary for the Initial Study upon application completeness.
CYCLE 2 - A request for proposals for CEQA services was released earlier this month. The scope of requested services includes Air Quality, Greenhouse Gas, and Energy assessments; a Noise/Vibration assessment; and a Cultural Resources assessment. The deadline for proposals is January 27, 2023. The applicant will be updated on proposals received shortly thereafter.
CYCLE 3 - Payment has not been received for LSA CEQA services outlined in an email sent 2/22/2023. Please provide payment in the amount of $26,460 per instructions contained in the email. LSA will commence preparation of the technical studies once payment is received.
CYCLE 4 - LSA is currently commencing technical studies for the project. A determination on the type of project CEQA analysis will be made once the studies have been received, reviewed, and finalized.
Response: Duly noted.
City of Fremont ARC TEC # 215334
December 18, 2023
Item # Sheet # The comment
The response
3. A000 (Kept as Advisory)
New non-residential construction triggers payment of capital facilities, fire facilities, traffic impact fees, and affordable housing fees. Please review this summary handout for more information:
https://www.fremont.gov/home/showpublisheddocument/371/637822692057470000
4. A000 (Kept as Advisory)
New development within the project site's P-81-15 (Ardenwood Research and Development Park) zoning district requires Community Development Director approval of a Planned District Major Amendment. Additionally, the requested floor area ratio increase (triggering a Modification of Zoning Standards finding) and the project's CEQA analysis will require discretionary actions.
5. A1-01 Short- and long-term bicycle parking provisions shall comply with the design recommendations and sizing/spacing requirements of the APBP Essentials of Bike Parking manual. Provide details of all fixture types, and dimension bicycle parking layouts.
CYCLE 4 - Bicycle parking infrastructure details cannot be located.
Response: Shown throughout the project area with callouts and dimensions on sheets L0.2 - L0.5 with detailed information on the upper center of sheet L0.3. With this resubmittal, all bike parking areas, notations, and dimensions that have been on the plans have been clouded and marked with delta 6 to make them stand out a little more clearly.
6. A-101 (Kept as Advisory)
All tenant and center identification signage shall be subject to a Master Sign Program. The Master Sign Program is to be processed as a separate item post- approval of the subject application.
City of Fremont ARC TEC # 215334
December 18, 2023
Item # Sheet # The comment
The response
7. A-101 Similar to FAR calculations, parking calculations should be on a per-parcel basis.
Calculations should be based on post-Lot Combination/Lot Line Adjustment conditions.
CYCLE 3 - Repeat comment. Parking requirements are for "on-site" parking, meaning parking spaces located on the same lot as the uses/buildings that's subject to the parking requirement. Plans/Tables need to clearly show how many parking spaces are provided on each lot and compare that figure with that lot's parking requirement based on the size of the buildings that sit upon it. More information is needed on the joint-use of parking spaces, like in a multi-lot campus environment, if that's the intent.
Additionally, please use the Planned District's "Industrial" parking rate (not the "Office" rate) for consistency with the project's VMT/LTA analysis, which uses industrial/R&D as the basis of analysis.
CYCLE 4 – The office rate is still being used. For VMT/LTA consistency, please revise to use the industrial parking standard (one stall per 450 SF of building area, or one space per every two employees). Note that this is a lower parking standard than the office rate.
Response: Refer to sheet A1.01 for revised parking analysis.
Solid Waste Comments:
1. A-101 Provide dimensions and details of existing trash enclosure. If it does not meet current standards, it may require an upgrade.
Response: Per conversation with Lori Marra on 12/15/2023 there are no outstanding solid waste comments. The trash enclosure complies.
2. A-110 Maximum height is 10' 0". Reduce the gap between the top of the wall and the bottom of the roof to 24" or less.
Response: Per conversation with Lori Marra on 12/15/2023 there are no outstanding solid waste comments. The trash enclosure complies.
3. A-110 Walls should be a maximum of 7' high.
Response: Per conversation with Lori Marra on 12/15/2023 there are no outstanding solid waste comments. The trash enclosure complies.
City of Fremont ARC TEC # 215334
December 18, 2023
Item # Sheet # The comment
The response
Stormwater Comments:
1. C5.0 Note that the project will need to meet the new stormwater treatment requirements set forth in in Municipal Regional NPDES Stormwater Permit 3.0 if the entitlements (final discretionary approval) are not received by July 1, 2023.
These new requirements require the project account for and treat/manage all offsite work being created or replaced in addition to onsite work. The Final Order of the permit is available for download at:
https://www.waterboards.ca.gov/sanfranciscobay/water_issues/programs/storm water/.
Response: Project meets the new stormwater treatment requirements, see sheet C5.0-C5.01, DMAs 43 and EQ-1. DMA 43 accounts for the offsite area that requires treatment. EQ-1 will be treated in-lieu of DMA 43. Additional information is provided on the Treatment Control Measure Summary Table on sheet C5.1.
2. C5.2 Based on the geotechnical report, the groundwater for the site is very shallow.
All systems where the bottom of excavation is within 5' of groundwater from will need to be lined. The perforated pipe in these systems will also need to be placed at the bottom.
Response: Duly noted. All treatment areas have been updated to be lined due to the proximity to the groundwater table. TCM table has been updated accordingly as well as the stormwater details, see sheets C5.0-C5.2.
Perforated pipe is designed to be at the bottom of the treatment system.
Transportation/Traffic Comments:
1. A-000 Information: City staff has been in contact with the applicant's Transportation Engineering consultant (Hexagon) regarding the scope of the Local Transportation Analysis (LTS) that is currently being prepared. Once received, any and all comments relating to the LTA will be communicated directly to the consultant.
2. A-000 Information: City staff will review and provide comments to the Transportation Demand Management (TDM) plan once it is received.
Please feel free to contact me if you have any additional questions. Thank you for your assistance.
Sincerely,
ARC TEC, Inc.
Evan Sockalosky, Principal