Fresno City Council
December 18, 2025

City of Fresno—Fresno Southeast Development Area Specific Plan Project Final Program EIR
FirstCarbon Solutions
Appendix A:

Full CLC-RCI and GSEJA Letters

THIS PAGE INTENTIONALLY LEFT BLANK
City of Fresno—Fresno Southeast Development Area Specific Plan Project Final Program EIR
FirstCarbon Solutions
A.1 - CLC-RCI Letter

THIS PAGE INTENTIONALLY LEFT BLANK

CLC/RCI

1 2

CLC/RCI

2 CONT
3 CLC/RCI

3 CONT
4 CLC/RCI

4 CONT

CLC/RCI

4 CONT
5 6

CLC/RCI

6 CONT
7 CLC/RCI

7 CONT
8 CLC/RCI

8 CONT
9 10

CLC/RCI

10 CONT
11 13
12 CLC/RCI

13 CONT

CLC/RCI

13 CONT
14 15

CLC/RCI

15 CONT
16 17

CLC/RCI

17 CONT
18 19

CLC/RCI

19 CONT
20 CLC/RCI

20 CONT
21 22
23 CLC/RCI

23 CONT

CLC/RCI

23 CONT
24 CLC/RCI

24 CONT
25 26

CLC/RCI

26 CONT

CLC/RCI

26 CONT
27 CLC/RCI

27 CONT
28 29

CLC/RCI

29 CONT
30 CLC/RCI

30 CONT

CLC/RCI

30 CONT
31 CLC/RCI

31 CONT
32 CLC/RCI

32 CONT

CLC/RCI

32 CONT
33 CLC/RCI

33 CONT
34 CLC/RCI

34 CONT
35 36
37 CLC/RCI

37 CONT
38 CLC/RCI

38 CONT

CLC/RCI

38 CONT
39 CLC/RCI

39 CONT
40 41
42 CLC/RCI

CLC/RCI

43 CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT
CLC/RCI Page 118 of 51743 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

CLC/RCI

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

CLC/RCI

CLC/RCI

CLC/RCI

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT
CLC/RCI Page 218 of 51743 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT
CLC/RCI Page 232 of 517
CLC/RCI Page 233 of 517
CLC/RCI Page 234 of 517
CLC/RCI Page 235 of 517
CLC/RCI Page 236 of 517
CLC/RCI Page 237 of 517

CLC/RCI

43 CONT

CLC/RCI

43 CONT
CLC/RCI Page 240 of 517

CLC/RCI

43 CONT

CLC/RCI

43 CONT
CLC/RCI Page 243 of 517
CLC/RCI Page 244 of 517

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT
CLC/RCI Page 299 of 51743 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT
CLC/RCI Page 309 of 51743 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT
CLC/RCI Page 508 of 51743 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

CLC/RCI

43 CONT

THIS PAGE INTENTIONALLY LEFT BLANK
City of Fresno—Fresno Southeast Development Area Specific Plan Project Final Program EIR
FirstCarbon Solutions
A.2 - GSEJA Letter

THIS PAGE INTENTIONALLY LEFT BLANK

BLUM, COLLINS & HO LLP ATTORNEYS AT LAW

AON CENTER
707 WILSHIRE BOULEVARD
SUITE 4880
LOS ANGELES, CALIFORNIA 90017
(213) 572-0400
March 21, 2025
Sophia Pagoulatos Via Email to:

Planning Manager [email protected]
City of Fresno
Planning and Development Department
2600 Fresno Street, Third Floor, Room 3043
Fresno, CA 93721
Subject: Comments on Recirculated Fresno Southeast Development Area Specific Plan Project EIR (SCH NO. 2022020486)
Dear Ms. Pagoulatos,
Thank you for the opportunity to comment on the Recirculated Program Environmental Impact Report (EIR) for the proposed Recirculated Fresno Southeast Development Area Specific Plan Project. Please accept and consider these comments on behalf of Golden State Environmental Justice Alliance. Also, Golden State Environmental Justice Alliance formally requests to be added to the public interest list regarding any subsequent environmental documents, public notices, public hearings, and notices of determination for this project. Send all communications to Golden State Environmental Justice Alliance P.O. Box 79222 Corona, CA 92877.

1.0 Summary
The proposed project is a Specific Plan (SP) for the Southeast Development Area (SEDA) formerly known as the Southeast Growth Area (SEGA). The mixed-use SEDA SP would permit residential, commercial, and employment generating uses. It has the potential to accommodate approximately 45,000 homes and 37,000 jobs within the nearly 9,000-acre planning area by the year 2050.

The EIR lists the following items as additional components of the project:

1. Phasing Plan: The Phasing Plan defines the required sequence of development for various areas within SEDA.

2. Infrastructure Financing Plan: The proposed project would include a Public Facilities Financing Plan to present a strategy and funding options for backbone infrastructure and public facilities, including roads, sewer, water, storm drainage, parks, and other public facilities.

GSEJA

1 Sophia Pagoulatos
March 21, 2025

Backbone infrastructure and public facilities required for development would be funded through a combination of public and private funding. The Public Facilities Financing Plan has been developed through a review of the SEDA Specific Plan, infrastructure studies, and coordination with the City.

3. Annexation: The proposed project requires annexation of Fresno County (County) lands into the City. LAFCo is a Responsible Agency under CEQA for the proposed project. LAFCo will consider the analysis contained in this EIR when considering the annexation of the project site into the City. Annexation will be strategic and proactive to facilitate infrastructure development by the City.

4. General Plan Amendment and Development Code Change: The proposed project would also amend the General Plan and Development Code to implement the land use and zoning described in the proposed project.

1.4 Documents Incorporated by Reference
The EIR states that the Southeast Development Area Specific Plan (SEDA SP) document itself (2023) is incorporated by reference. The SEDA SP is the proposed project and excluding it as an attachment for public review does not comply with CEQA’s requirements for meaningful disclosure. Incorporation by reference (CEQA § 15150 (f)) is not appropriate as the SEDA SP document contributes directly to analysis of the problem at hand. The EIR must be revised to include the SEDA SP document for review, analysis, and comment by the public and decision makers.

2.0 Project Description
The EIR is not clear regarding the proposed General Plan land use designations for the project site.

Specifically, the EIR only provides exhibits that depict the Existing General Plan land use designations and the proposed SEDA SP land use designations, leaving the reader to assume that the proposed SEDA land uses are the new General Plan land use designations. It must be noted that the City’s General Plan does not list any of the 10 proposed SEDA land use designations as existing land use designations. For example, SEDA’s employment-focused land use designations are “Office Center” and “Flexible Research and Development.” These land use designations do not exist in the City’s General Plan, and neither do any of the other eight proposed land use designations. The City’s General Plan also does not include a broad “Specific Plan” land use designation that would be applied to all parcels within any approved Specific Plan within the City.

Therefore, all 10 land use designations proposed in the SEDA SP will be new additions to the General Plan and the EIR must be revised to include all text and exhibits that will be part of the revised General Plan and Development Code in order to comply with CEQA’s requirements for meaningful disclosure and adequate informational documents (CEQA § 15121).

GSEJA

1 CONT
2 3
Sophia Pagoulatos
March 21, 2025

Further, the EIR impact analysis throughout the document relies on the notion that bus rapid transit (BRT) service will be expanded in Fresno to serve the project area (Kings Canyon), rendering several impact areas less than significant. However, the EIR does not provide any meaningful evidence to support the conclusion that the BRT expansion will actually be constructed. Most notably, the Fresno COG Long Range Transportation Plan1 (LRTP) (2019-2050) does not include service to the SEDA SP area as a specific project. Table 2 - LRTP Project List within the LRTP only includes, "Project 6: Extend the Kings Canyon BRT corridor to Fancher Creek,” and the Fancher Creek area is located north/west of the SEDA areas and not contiguous to it. Therefore, BRT service to the project area is not a funded commitment or project and is not planned to exist by 2050. The EIR must be revised to clarify this and update its impact analysis throughout the document.

Additionally, the EIR lists several items as “additional components” of the project that are not included for public review: Phasing Plan, Infrastructure Financing Plan, Annexation, and the above-mentioned General Plan Amendment and Development Code Change. These project components are necessary for the public to review as they directly inform the environmental analysis, such as Utilities and Service Systems, Hydrology and Water Quality, and Public Services.

Excluding these project components as attachments for public review does not comply with CEQA’s requirements for meaningful disclosure. Incorporation by reference (CEQA § 15150 (f)) is not appropriate as all project components contribute directly to analysis of the problem at hand.

The EIR must be revised to include all project components for review, analysis, and comment by the public and decision makers.

3.3 Air Quality, 3.6 Energy, and 3.8 Greenhouse Gas Emissions The EIR does not include for analysis relevant environmental justice issues in reviewing potential impacts, including cumulative impacts from the proposed project. The EIR provides general information about the census tract’s CalEnviroScreen scores but does not provide meaningful analysis regarding the health impacts and effects of severe pollution rates. This is in conflict with CEQA Guidelines Section 15131 (c), which requires that “Economic, social, and particularly housing factors shall be considered by public agencies together with technological and environmental factors in deciding whether changes in a project are feasible to reduce or avoid the significant effects on the environment identified in the EIR. If information on these factors is not contained in the EIR, the information must be added to the record in some other manner to allow the agency to consider the factors in reaching a decision on the project.” 1 https://www.fresnocog.org/wp-content/uploads/2021/10/Fresno-County-Regional-Long-Range-TransitPlan-050519-RL-34.pdf GSEJA

5 4
3 CONT
Sophia Pagoulatos
March 21, 2025

This is especially significant as the surrounding community is highly burdened by pollution.

According to CalEnviroScreen 4.02, CalEPA’s screening tool that ranks each census tract in the state for pollution and socioeconomic vulnerability, the proposed project spans multiple census tracts ((6019005904 (Temperance south of Church Street extending east to McCall); 6019001413 (Temperance north of Church Street extending north to Belmont); and 6019001500 (Temperance between Jensen and North extending west to Peach)) that rank significantly worse than the rest of the state in overall pollution burden and specific factors that directly contribute to pollution applied to the socioeconomic factors of the population. Census tract 6019005904 ranks in the 77th percentile for overall pollution burden, census tract 6019001413 ranks in the 57th percentile, and census tract 6019001500 ranks in the 100th percentile, meaning that it is among the most highly polluted census tracts in the state.

The project census tracts rank highly for ozone burden (6019005904 and 6019001413: 89th percentile; 6019001500: 85th percentile), particulate matter (PM) 2.5 burden (6019005904: 95th percentile; 6019001413 and 6019001500: 96th percentile), and diesel PM burden (6019001500:
65th percentile). All of these environmental factors are typically attributed to heavy truck activity in the area. Ozone can cause lung irritation, inflammation, and worsening of existing chronic health conditions, even at low levels of exposure3. The very small particles of diesel PM can reach deep into the lung, where they can contribute to a range of health problems. These include irritation to the eyes, throat and nose, heart and lung disease, and lung cancer4.

The census tracts also bear more impacts from cleanup sites compared to the rest of the state (6019005904: 89th percentile; 6019001500: 98th percentile). Chemicals in the buildings, soil, or water at cleanup sites can move into nearby communities through the air or movement of water5.

The census tracts also rank highly for impacts from toxic releases (6019005904: 70th percentile; 6019001413: 74th percentile; 6019001500: 95th percentile). People living near facilities that emit toxic releases may breathe contaminated air regularly or if contaminants are released during an accident6.

The census tracts rank among the most severely impacted in several areas that impact water quality.

Census tract 6019001500 rank in the 94th percentile for groundwater threats. People who live near contaminated groundwater may be exposed to chemicals moving from the soil into the air 2 CalEnviroScreen 4.0 https://oehha.ca.gov/calenviroscreen/report/calenviroscreen-40 3 OEHHA Ozone https://oehha.ca.gov/calenviroscreen/indicator/air-quality-ozone 4 OEHHA Diesel Particulate Matter https://oehha.ca.gov/calenviroscreen/indicator/diesel-particulatematter 5 OEHHA Cleanup Sites https://oehha.ca.gov/calenviroscreen/indicator/cleanup-sites 6 OEHHA Toxic Releases https://oehha.ca.gov/calenviroscreen/indicator/toxic-releases-facilities GSEJA

5 CONT
Sophia Pagoulatos
March 21, 2025

inside their homes7. Additionally, the project census tracts rank highly for drinking water impacts (6019005904: 99th percentile; 6019001413: 94th percentile; 6019001500: 100th percentile), which indicates that the project site ranks with the worst quality drinking water in the state. Poor communities and people in rural areas are exposed to contaminants in their drinking water more often than people in other parts of the state8.

The census tracts also rank highly for solid waste facility impacts (6019005904: 70th percentile; 6019001500: 100th percentile), which can expose people to hazardous chemicals, release toxic gases into the air (even after these facilites are closed), and chemicals can leach into soil around the facility and pose a health risk to nearby populations9. Census tract 6019001500 ranks in the 100th percentile for hazardous waste impacts. Hazardous waste generators and facilities contribute to the contamination of air, water and soil near waste generators and facilities can harm the environment as well as people10.

Further, the census tract is a diverse community including many Hispanic residents (6019005904:
32%; 6019001413: 46%; 6019001500: 75%), Asian-American residents (6019005904: 24%; 6019001413: 25%; 6019001500: 3%), and African-American residents (6019005904: 2%; 6019001413: 2%; 6019001500: 1%), whom are especially vulnerable to the impacts of pollution. The communities have a high rate of low educational attainment, meaning significant portions of the census tracts over age 25 has not attained a high school diploma (6019005904:
56%; 6019001413: 54%; 6019001500: 95%). The community also has a high rate of poverty, meaning significant portions of the households in the census tract have a total income before taxes that is less than the poverty level (6019001500: 94%). Income can affect health when people cannot afford healthy living and working conditions, nutritious food and necessary medical care11.

Poor communities are often located in areas with high levels of pollution12. Poverty can cause stress that weakens the immune system and causes people to become ill from pollution13. Living in poverty and low education levels are also an indication that residents may lack health insurance or access to medical care. Medical care is vital for the project census tracts as they rank significantly for the incidence of cardiovascular disease (6019001413: 55th percentile; 7 OEHHA Groundwater Threats https://oehha.ca.gov/calenviroscreen/indicator/groundwater-threats 8 OEHHA Drinking Water https://oehha.ca.gov/calenviroscreen/drinking-water 9 OEHHA Solid Waste Facilities https://oehha.ca.gov/calenviroscreen/indicator/solid-waste-sites-andfacilities 10 OEHHA Hazardous Waste Generators and Facilities
https://oehha.ca.gov/calenviroscreen/indicator/hazardous-waste-generators-and-facilities 11 OEHHA Poverty https://oehha.ca.gov/calenviroscreen/indicator/poverty 12 Ibid.
13 Ibid.

GSEJA

5 CONT
Sophia Pagoulatos
March 21, 2025

6019001500: 71st percentile) and the incidence of asthma (6019001413: 55th percentile; 6019001500: 93rd percentile). The communities also have a high rate of linguistic isolation, meaning significant portions of residents in the census tracts speak little to no English and faces further inequities as a result (6019005904: 49%; 6019001413: 50%; 6019001500: 70%).

Additionally, the proposed project’s census tracts (6019001413 and 6019001500) are identified as SB 535 Disadvantaged Communities14. This indicates that cumulative impacts of development and environmental impacts in the area are disproportionately impacting these communities. The EIR does not discuss that the project site and surrounding area are disadvantaged communities and does not utilize this information in its analysis. The EIR has not considered the project’s significant and unavoidable cumulatively considerable environmental impacts in relation to the SB 535 status of the project census tracts and surrounding area. The negative environmental, health, and quality of life impacts in the City have become distinctly inequitable. The severity of environmental impacts particularly on these Disadvantaged Communities must be included for analysis as part of a revised EIR.

The State of California lists three approved compliance modeling softwares15 for non-residential buildings: CBECC-Com, EnergyPro, and IES VE. CalEEMod and EMFAC are not listed as approved softwares. The CalEEMod/EMFAC and spreadsheet-based modeling does not comply with the 2022 Building Energy Efficiency Standards and under-reports the project’s significant Energy impacts and fuel consumption to the public and decision makers. Since the EIR did not accurately or adequately model the energy impacts in compliance with Title 24, a finding of significance must be made. A revised EIR with modeling using one of the approved software types must be prepared and circulated for public review in order to adequately analyze the project’s significant environmental impacts. This is vital as the EIR utilizes CalEEMod/EMFAC as sources in its methodology and analysis, which are clearly not approved softwares.

3.9 Hazards and Hazardous Materials
The EIR states that, “According to the Fresno Yosemite International Airport Safety Compatibility Zones Map, a small portion of the Plan Area is located within the 60 dB CNEL contour. A Larger portion of the Plan Area is located within the Traffic Pattern Zone.” The EIR concludes that, “The ALUC found the proposed project to be consistent with the ALUCP on August 7, 2023. Therefore, at the programmatic level, impacts to the Plan Area would be less than significant. Consistent with the General Plan and SEDA Specific Plan policies, individual development projects would be 14 OEHHA SB 535 Census Tracts https://oehha.ca.gov/calenviroscreen/sb535 15 California Energy Commission 2022 Energy Code Compliance Software https://www.energy.ca.gov/programs-and-topics/programs/building-energy-efficiency-standards/2022- building-energy-efficiency-1
GSEJA

5 CONT
6 7
Sophia Pagoulatos
March 21, 2025

required to undergo project-specific environmental review, which may require additional sitespecific or project-specific airport land use compatibility measures to reduce any potential impacts and ensure that impacts remain less than significant.”
However, the EIR has not provided any meaningful evidence or analysis to support the claim that the impacts are less than significant. Notably, the Fresno County Airport Land Use Commission (FC ALUC) review document is not included as an attachment for public review in compliance with CEQA’s requirements for meaningful disclosure. Incorporation by reference (CEQA § 15150 (f)) is not appropriate as the FC ALUC review document contributes directly to analysis of the problem at hand. The EIR must be revised to include the FC ALUC review document for review, analysis, and comment by the public and decision makers.

Additionally, based on the August 7, 2023 FC ALUC meeting agenda16, attachments17/ 18, and
minutes19 of the meeting, the FC ALUC only reviewed the SEDA Specific Plan. The FC ALUC did not explicitly review or take action on all aspects of the project, including the required General Plan Amendment and Development Code Change required to implement the proposed project.

The California Airport Land Use Planning Handbook20 states that Airport Land Use Commission review is required “Prior to the amendment of a general plan or specific plan, or the adoption of a zoning ordinance or building regulation within the ALUCP planning boundary, the ALUC shall review the plan, ordinance, or regulation for consistency with the ALUCP (PUC Section 21676(b)).” Given that the proposed project includes General Plan Amendment and Development Code Change to proceed, FC ALUC review of all associated actions is required. As stated above in the Project Description analysis, the EIR has not provided the new text or exhibits to be included in the revised General Plan associated with the 10 new land use designations created by the proposed project, or the new text of the development code. Therefore, the FC ALUC has not reviewed the required General Plan Amendment and a revised EIR must be prepared to include a finding of significance.
16 August 7, 2023 FC ALUC meeting agenda https://agendas2011-24.fresnocog.org/agenda/read/785 17 August 7, 2023 FC ALUC attachment for SEDA project https://agendas2011-

24.fresnocog.org/itemAttachments/785/SEDA_-_ALUC_Submittal_-_7.24_.23_.pdf 18 August 7, 2023 FC ALUC attachment for SEDA project https://agendas2011-

24.fresnocog.org/itemAttachments/785/SEDA_-_FAT_Influence_Areas.pdf 19 August 7, 2023 FC ALUC meeting minutes https://agendas2011-

24.fresnocog.org/itemAttachments/794/080723_ALUC_Action_Summary.pdf 20 California Airport Land Use Planning Handbook https://dot.ca.gov/-/media/dotmedia/programs/aeronautics/documents/californiaairportlanduseplanninghandbook-a11y.pdf GSEJA

7 CONT
Sophia Pagoulatos
March 21, 2025

3.11 Land Use and Planning
It must be noted that the EIR does not accurately characterize or analyze the permitted use types within each land use designation of the SEDA SP21. For example, SEDA SP Policy EO-2.1 states, “Promote industry clusters that build on Fresno’s local strengths. The SEDA Plan presents opportunities for each of the following clusters: Advanced Manufacturing, Clean Energy, Construction, Food Processing, Healthcare, Information Processing, Logistics & Distribution, Software Development, Tourism, and Water Technology. This list may evolve as Fresno grows and changes.” The EIR does not discuss or analyze the possibility of logistics and distribution uses in any of the proposed land use designations. The EIR is inadequate as an informational document and must be revised to accurately list all permitted/conditionally permitted uses within each land use designation and update all associated impact analysis.

The EIR is not clear regarding the proposed General Plan land use designations for the project site.

Specifically, the EIR only provides exhibits that depict the Existing General Plan land use designations and the proposed SEDA SP land use designations, leaving the reader to assume that the proposed SEDA land uses are the new General Plan land use designations. It must be noted that the City’s General Plan does not list any of the 10 proposed SEDA land use designations as existing land use designations. For example, SEDA’s employment-focused land use designations are “Office Center” and “Flexible Research and Development.” These land use designations do not exist in the City’s General Plan, and neither do any of the other eight proposed land use designations. The City’s General Plan also does not include a broad “Specific Plan” land use designation that would be applied to all parcels within any approved Specific Plan within the City.

Therefore, all 10 land use designations proposed in the SEDA SP will be new additions to the General Plan and the EIR must be revised to include all text and exhibits that will be part of the revised General Plan and Development Code in order to comply with CEQA’s requirements for meaningful disclosure and adequate informational documents (CEQA § 15121).

Additionally, the EIR does not provide adequate information to determine the project’s compliance or noncompliance with statutory requirements of the Housing Crisis Act (HCA) of 2019/Senate Bill (SB) 33022/SB 823. The HCA/SB 330/SB 8 require replacement housing sites when land designated for housing development experience land use changes to ensure no net loss of housing capacity.
21 SEDA SP https://www.fresno.gov/wp-content/uploads/2023/07/Draft-SEDA-Specific-Plan.pdf 22 Housing Crisis Act of 2019/SB 330
https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=201920200SB330 23 SB 8 https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=202120220SB8 GSEJA

8 9
Sophia Pagoulatos
March 21, 2025

Government Code Section 66300(b)(1)(A) requires that agencies shall not “change the general plan land use designation, specific plan land use designation, or zoning to a less intensive use below what was allowed under the land use designation and zoning ordinances in effect at the time of the proposed change.” Under Government Code Section 66300(b)(1)(A), a “less intensive use” includes, but is not limited to, reductions to height, density, or floor area ratio, new or increased open space or lot size requirements, or new or increased setback requirements, minimum frontage requirements, or maximum lot coverage limitations, or any other action that would individually or cumulatively reduce residential development capacity. Pursuant to SB 330, replacement capacity for any displaced residential units must be provided concurrently at the time of project approval.

Government Code Section 66300 (h)(i)(1) states that, “this section does not prohibit an affected county or an affected city, including the local electorate acting through the initiative process, from changing a land use designation or zoning ordinance to a less intensive use, or reducing the intensity of land use, if the city or county concurrently changes the development standards, policies, and conditions applicable to other parcels within the jurisdiction to ensure that there is no net loss in residential capacity.” The EIR is inadequate in that it does not provide the acreage of each existing General Plan land use designation within the project area. The total acreage for each existing General Plan land use designation is necessary to calculate the existing total residential development capacity to ensure there is no net loss of capacity. The EIR must be revised to include this information for analysis.

3.14 Population and Housing
The EIR states that, “According to General Plan Tables 1-3 (Residential Development Capacity at General Plan Horizon) and 1-4 (Residential Development Capacity at General Plan Buildout, the proposed project would generate up to 14,900 dwelling units at General Plan Horizon and an additional 25,000 at buildout occurring sometime after 2050, for a total of 45,000 new dwelling units, comprising approximately 31 percent of the total planned capacity for the City. Buildout of the proposed project is considered planned growth and would provide housing to meet the demand for new residential units.” However, this statement does not accurately reflect General Plan Tables 1-3 and 1-4. According to the General Plan, the project site is located within Development Areas (DA) DA-3 Southeast and DA-4 East. General Plan Tables 1-3 and 1-4 provide the following buildout information for DA-3 and DA-4:

Table 1-3: Residential Development Capacity Under General Plan Horizon (2035) DA-3 Southeast
Type of Dwelling Unit (DU)
Multi-Family/Townhouse: 2,500 DU
SFD: 3,500 DU
GSEJA

9 CONT
10 11
Sophia Pagoulatos
March 21, 2025

Total: 6,000 DU
Location
City Limits: 0
Development on Sites in Growth Areas Requiring Annexation: 6,000 DU DA-4 East
Type of DU
MF/Townhouse: 5,100 DU
SFD: 3,800 DU
Location
City Limits: 0
Development on Sites in Growth Areas Requiring Annexation: 8,900 DU Total General Plan Horizon (2035) = 14,900 DU
Table 1-4: Residential Development Capacity Under Buildout (2056) DA-3 Southeast
Location
City Limits: 0
Development on Sites in Growth Areas Requiring Annexation: 9,092 DU DA-4 East
Location
City Limits: 0
Development on Sites in Growth Areas Requiring Annexation: 35,008 DU Total General Plan Buildout (2056) = 44,100 DU
The EIR states that the General Plan provides for, “up to 14,900 dwelling units at General Plan Horizon and an additional 25,000 at buildout occurring sometime after 2050, for a total of 45,000 new dwelling units.” However, the sum of 14,900 DU and 25,000 DU is 39,900 DU, which is 5,100 DU fewer than the proposed project. It must be noted that the General Plan excludes the specific date of total buildout, but the 2019 EIR for the General Plan Update24 clearly identifies the total buildout year as 2056.

As shown above, the General Plan accommodates a cumulative total of 44,100 DU on the project site from General Plan adoption through 2056. This is 900 DU fewer than the 45,000 DU proposed by the project. The proposed project exceeds the cumulative General Plan buildout scenario through 2056 and the EIR must be revised to disclose this with a finding of significance. 24 https://www.fresno.gov/wp-content/uploads/2023/03/Fresno-GP-Public-Review-Draft-ProgramEIR.pdf GSEJA

11 CONT
Sophia Pagoulatos
March 21, 2025

A revised EIR must also provide a cumulative analysis of projects approved and “in the pipeline” to provide an adequate and accurate analysis to determine if the project will exceed Fresno COG’s employment and population growth forecasts, and all projects approved since 2014 and projects “in the pipeline” to provide an adequate and accurate analysis to determine if the project will exceed the City’s General Plan employment and population growth forecasts. For example, the General Plan includes Table 1-5: Population Estimate Under Horizon and Buildout that depicts the City will add 226,000 residents by horizon year 2035 and a cumulative total of 425,000 residents by General Plan buildout in 2056. The EIR’s estimated 134,550 residents accounts for

59.5% of horizon population buildout (2035), 31.6% of total General Plan population buildout (2056), and 67.5% of the population increase from 2035 to 2056. This is a significant amount of growth attributable to a single project. The EIR has not prepared an adequate cumulative analysis to determine the City’s progress towards these buildout scenarios and a revised EIR must be prepared with this information in order to provide an adequate and accurate environmental analysis.

The EIR states that, “new development would be required to address potential environmental impacts as part of individual project review. As such, cumulative development would not induce substantial unplanned population growth, either directly or indirectly. Because cumulative projects would comply with all applicable land use plans to provide adequate development within a jurisdiction, cumulative impacts would be less than significant.” This statement is misleading and erroneous as CEQA provides several options to exempt future projects from environmental review.

New development would not be required to address potential environmental impacts as part of individual project review. New residential development proposed pursuant to the SEDA SP is statutorily exempt from CEQA due to the adoption of a Program EIR. Specifically, CEQA Guidelines Section 15168 (c)(2) states regarding later activities that, “If the agency finds that pursuant to Section 15162, no subsequent EIR would be required, the agency can approve the activity as being within the scope of the project covered by the program EIR, and no new environmental document would be required.” CEQA Guidelines Section 15182 exempts “residential, commercial and mixed-use projects that are consistent with a specific plan.” CEQA Guidelines Section 15182 (c) exempts residential projects so long as no new information has been presented pursuant to Section 15162. Additionally, CEQA Guidelines Section 15168 (b)(2) provides a list of advantages for developing a Program EIR as, “Ensure consideration of cumulative impacts that might be slighted in a case-by-case analysis.” Therefore, the EIR’s reliance upon delayed/future CEQA review as part of individual project review is not adequate or accurate and does not support a less than significant finding. The EIR must be revised to remove these statements and provide a finding of significance.

GSEJA

12 Sophia Pagoulatos
March 21, 2025

3.17 Transportation and Traffic
The EIR has not provided any consistency analysis with the Fresno Council of Governments (COG) 2022 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS)25. Due to errors in modeling, modeling without supporting evidence, and the EIR’s conclusion the project will result in significant and unavoidable cumulatively considerable impacts to Air Quality, the proposed project has signifiant potential for inconsistency with Goal 2: Vibrant communities that are accessible by sustainable transportation options, Policy 4: Encourage alternatives to singleoccupancy vehicles that reduce vehicle miles traveled (VMT) and greenhouse gas emissions, and Policy 6: Encourage sustainable development that focuses growth near activity centers and mobility options that achieve greater location efficiency. Portions of the project site is also identified as an Environmental Justice area26 in Fresno COG’s 2022 RTP/SCS. Since the project requires a General Plan Amendment to the land use designations on the project site to proceed, it was clearly not accounted for or analyzed by the 2022 RTP/SCS. A revised EIR must be prepared to accurately analyze and disclose the inconsistency with the 2022 RTP/SCS document with a finding of significance.

Further, the EIR impact analysis relies on the notion that bus rapid transit (BRT) service will be expanded in Fresno to serve the project area (Kings Canyon), rendering several impact areas less than significant. However, the EIR does not provide any meaningful evidence to support the conclusion that the BRT expansion will actually be constructed. Most notably, the Fresno COG Long Range Transportation Plan27 (LRTP) (2019-2050) does not include service to the SEDA SP area as a specific project. Table 2 - LRTP Project List within the LRTP only includes, "Project 6:

Extend the Kings Canyon BRT corridor to Fancher Creek,” and the Fancher Creek area is located north/west of the SEDA areas and not contiguous to it. Therefore, BRT service to the project area is not a funded commitment or project and is not planned to exist by 2050. The EIR must be revised to clarify this and update its impact analysis throughout the document.

4.2 Growth-Inducing Impacts
The EIR has excluded for discussion for the precedence setting action that approval of the required General Plan Amendment and Development Code Change set for future changes in the City. The EIR must be revised to include a finding of significance as the required GPA/Development Code Change to implement the project will result in significant and unavoidable cumulatively 25 Fresno COG 2022 RTP/SCS https://www.planfresno.com/sustainable-communities-strategies-falloutreach/ 26 Environmental Justice Chapter of 2022 Fresno COG RTP/SCS https://www.planfresno.com/planfresno/uploads/2022/06/Chapter-7-Environmental-Justice-Final-Draft.pdf 27 https://www.fresnocog.org/wp-content/uploads/2021/10/Fresno-County-Regional-Long-Range-TransitPlan-050519-RL-34.pdf GSEJA

13 14
15 Sophia Pagoulatos
March 21, 2025

considerable impacts to Aesthetics, Agricultural Resources, Air Quality, and Noise, and approval of the proposed project will set precedent for approval of other projects with significant and unavoidable impacts that require changes in land use designations and will encourage and facilitate other activities that will have significant negative impacts to the environment. The EIR must be revised to disclose this information and provide a finding of significance.

The EIR has excluded discussion of the precedence setting action that approval of the required General Plan Amendment and Development Code Change set for future changes in the City. The EIR does not analyze that the project will create 10 new General Plan land use designations that can be applied to any property in the City. The EIR must be revised to disclose this information and provide a finding of significance.

The EIR states that, “According to General Plan Tables 1-3 (Residential Development Capacity at General Plan Horizon) and 1-4 (Residential Development Capacity at General Plan Buildout, the proposed project would generate up to 14,900 dwelling units at General Plan Horizon and an additional 25,000 at buildout occurring sometime after 2050, for a total of 45,000 new dwelling units, comprising approximately 31 percent of the total planned capacity for the City. Buildout of the proposed project is considered planned growth and would provide housing to meet the demand for new residential units.” However, this statement does not accurately reflect General Plan Tables 1-3 and 1-4. According to the General Plan, the project site is located within Development Areas (DA) DA-3 Southeast and DA-4 East. General Plan Tables 1-3 and 1-4 provide the following buildout information for DA-3 and DA-4:

Table 1-3: Residential Development Capacity Under General Plan Horizon (2035) DA-3 Southeast
Type of Dwelling Unit (DU)
Multi-Family/Townhouse: 2,500 DU
SFD: 3,500 DU
Total: 6,000 DU
Location
City Limits: 0
Development on Sites in Growth Areas Requiring Annexation: 6,000 DU DA-4 East
Type of DU
MF/Townhouse: 5,100 DU
SFD: 3,800 DU
Location
City Limits: 0
Development on Sites in Growth Areas Requiring Annexation: 8,900 DU GSEJA

15 CONT
Sophia Pagoulatos
March 21, 2025

Total General Plan Horizon (2035) = 14,900 DU
Table 1-4: Residential Development Capacity Under Buildout (2056) DA-3 Southeast
Location
City Limits: 0
Development on Sites in Growth Areas Requiring Annexation: 9,092 DU DA-4 East
Location
City Limits: 0
Development on Sites in Growth Areas Requiring Annexation: 35,008 DU Total General Plan Buildout (2056) = 44,100 DU
The EIR states that the General Plan provides for, “up to 14,900 dwelling units at General Plan Horizon and an additional 25,000 at buildout occurring sometime after 2050, for a total of 45,000 new dwelling units.” However, the sum of 14,900 DU and 25,000 DU is 39,900 DU, which is 5,100 DU fewer than the proposed project. It must be noted that the General Plan excludes the specific date of total buildout, but the 2019 EIR for the General Plan Update28 clearly identifies the total buildout year as 2056.

As shown above, the General Plan accommodates a cumulative total of 44,100 DU on the project site from General Plan adoption through 2056. This is 900 DU fewer than the 45,000 DU proposed by the project. The proposed project exceeds the cumulative General Plan buildout scenario through 2056 and the EIR must be revised to disclose this with a finding of significance.

The EIR must also be
A revised EIR must also provide a cumulative analysis of projects approved and “in the pipeline” to provide an adequate and accurate analysis to determine if the project will exceed Fresno COG’s employment and population growth forecasts, and all projects approved since 2014 and projects “in the pipeline” to provide an adequate and accurate analysis to determine if the project will exceed the City’s General Plan employment and population growth forecasts. For example, the General Plan includes Table 1-5: Population Estimate Under Horizon and Buildout that depicts the City will add 226,000 residents by horizon year 2035 and a cumulative total of 425,000 residents by General Plan buildout in 2056. The EIR’s estimated 134,550 residents accounts for

59.5% of horizon population buildout (2035), 31.6% of total General Plan population buildout 28 https://www.fresno.gov/wp-content/uploads/2023/03/Fresno-GP-Public-Review-Draft-ProgramEIR.pdf GSEJA

15 CONT
16 Sophia Pagoulatos
March 21, 2025

(2056), and 67.5% of the population increase from 2035 to 2056. This is a significant amount of growth attributable to a single project. The EIR has not prepared an adequate cumulative analysis to determine the City’s progress towards these buildout scenarios and a revised EIR must be prepared with this information in order to provide an adequate and accurate environmental analysis.

4.3 Mandatory Findings of Significance
The EIR concludes that the proposed project will have a less than significant impact regarding Mandatory Finding of Significance Threshold 3: “The environmental effects of a project will cause substantial adverse effects on human beings, either directly or indirectly.” The EIR states that, “Compliance with and implementation of mitigation measures, existing regulations, and the City’s standard permit conditions would ensure that the proposed project, and future development consistent with the proposed project, would not result in substantial adverse effects on human beings, including effects related to air pollution, seismic and geologic hazards, hazardous materials, flooding and natural disasters, or noise and vibration. Therefore, impacts associated with the proposed project would be less than significant.”
However, this analysis fails to account for the project’s significant and unavoidable cumulatively considerable impact for Threshold AIR-3: Project-level Sensitive Receptors Exposure to Pollutant Concentrations. Regarding this signifiant impact, the EIR states that proposed mitigation would reduce impacts to the extent feasible, but, “the proposed project would result in the future development of numerous projects, each contributing incrementally to air emissions affecting sensitive receptors. Thus, it is possible that the proposed project would result in cumulatively significant impacts to sensitive receptors, even if individual projects were each less than significant. This is particularly likely since none of the measures herein would prevent multiple development projects from being constructed concurrently within close proximity to sensitive receptors in such a manner as to cause substantial concentrations within the area. Further, neither the amount of construction occurring nor the exact location within the Plan Area is foreseeable and, as such, it cannot be determined whether the resultant construction emissions could be adequately controlled or reduced to below regulatory thresholds. Without such information, it is not possible to conclude that air pollutant emissions resulting from construction activities would be adequately reduced to the point that sensitive receptors are not exposed to substantial concentrations of air pollutants, and thus a significant and unavoidable impact may result.” The EIR is internally inconsistent as it does not acknowledge this impact in the Mandatory Findings.

The EIR must be revised to include this information for analysis and provide a finding of significance.

GSEJA

16 CONT
17 Sophia Pagoulatos
March 21, 2025

5.0 Alternatives
The EIR is required to evaluate a reasonable range of alternatives to the proposed project which will avoid or substantially lessen any of the significant effects of the project (CEQA § 15126.6.) The alternatives chosen for analysis include the CEQA required “No Project/No Build” alternative and only two others - Consolidated Business Park Alternative and Farmland Conservation Alternative. The EIR does not evaluate a reasonable range of alternatives as only two alternatives beyond the required No Project alternative are analyzed. The EIR does not include an alternative eliminates any of the project’s significant and unavoidable impacts. The EIR must be revised to include analysis of a reasonable range of alternatives and foster informed decision making (CEQA § 15126.6). This could include alternatives such as development of the site with a project that eliminates all of the proposed project’s significant and unavoidable impacts to less than significant levels while meeting all project objectives. The EIR must be revised to include analysis of a reasonable range of alternatives and foster informed decision making (CEQA § 15126.6).

Conclusion
For the foregoing reasons, GSEJA believes the EIR is flawed and a revised EIR must be prepared for the proposed project and circulated for public review. Golden State Environmental Justice Alliance requests to be added to the public interest list regarding any subsequent environmental documents, public notices, public hearings, and notices of determination for this project. Send all communications to Golden State Environmental Justice Alliance P.O. Box 79222 Corona, CA 92877.

Sincerely,
Vashon Simien
Blum, Collins & Ho, LLP
Attachments:

1. SWAPE Technical Analysis
GSEJA

18 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]
March 18, 2025
Gary Ho
Blum, Collins & Ho LLP
707 Wilshire Blvd, Ste. 4880
Los Angeles, CA 90017
Subject: Comments on the Fresno Southeast Development Area Specific Plan Project (SCH No. 2022020486)
Dear Mr. Ho,
We have reviewed the February 2025 Recirculated Draft Program Environmental Impact Report (“RDPEIR”) for the Fresno Southeast Development Area Specific Plan Project (“Specific Plan”) located in the City of Fresno. The Project proposes constructing complete communities and mixed-use centers, including up to 45,000 dwelling units, over a 9,000-acre plan area.

In our opinion, the RDPEIR does not sufficiently evaluate the Project’s air quality and greenhouse gas (“GHG”) impacts. Emissions associated with construction and operation of the proposed Project may therefore be inadequately addressed. A revised Environmental Impact Report (“EIR”) should be prepared to adequately assess and mitigate the potential air quality and greenhouse gas impacts that the project may have on the environment.

Air Quality
Failure to Implement All Feasible Mitigation Measures to Reduce ConstructionRelated and Operational Criteria Air Pollutant Emissions The RDPEIR relies on California Emissions Estimator Model (“CalEEMod”) to estimate emissions from construction and operation of future projects under the Specific Plan. Despite incorporating Mitigation Measures (“MM”) AIR-1a through AIR-1d, the RDPEIR concludes that construction-related and operational emissions of volatile organic compounds (“VOC”), nitrogen oxide (“NOx), carbon oxide (“CO”), particulate matter 10 (“PM₁₀”), and particulate matter 2.5 (“PM2.5”) would remain significant and unavoidable (pp. 3.3-48–51, Table 3.3-8, Table 3.3-9).

GSEJA

19 2
The RDPEIR, however, does not implement all feasible mitigation for reducing these emissions. The California Environmental Quality Act (“CEQA”) requires lead agencies to implement all feasible mitigation to reduce significant impacts to the maximum extent feasible. 1 The RDPEIR fails to evaluate
or adopt additional measures that could further reduce emissions. As outlined in the “Feasible Mitigation Measures Available to Reduce Emissions” section of this letter, we suggest further mitigation measures to be considered; a revised EIR should be prepared to further assess and incorporate all available mitigation before concluding that impacts are significant and unavoidable.

Greenhouse Gas
Failure to Implement All Feasible Mitigation Measures to Reduce Greenhouse Gas Impacts
The RDPEIR estimates that Project construction and operation would generate 2,316,578 and 510,791 metric tons of carbon dioxide equivalents per year (“MT CO2e/year”), respectively (p. 3.8-42–43, Table

3.8-2, 2.8-3). The RDPEIR concludes that the Project’s GHG emissions would be less than significant based on consistency with the 2022 ARB Scoping Plan and the Fresno 2022 Regional Transportation Plant (“RTP”) and the Sustainable Communities Strategy (“SCS”) (p. 3.8-56).

In our opinion, however, the RDPEIR’s significant and unavoidable conclusion lacks sufficient support.

CEQA requires the RDPEIR to implement all feasible mitigation to minimize impacts to the maximum extent feasible.
2 An impact can only be deemed significant and unavoidable after considering all available feasible mitigation. The RDPEIR does not incorporate all feasible mitigation measures despite declaring compliance with the RTP and SCS plans.

A revised EIR should be prepared to include and provide evidence for the implementation of additional feasible mitigation measures which we recommend below in the section titled, “Feasible Mitigation Measures Available to Reduce Emissions.”
Mitigation
Feasible Mitigation Measures Available to Reduce Emissions The RDPEIR concludes that the construction and operation of future projects under the Specific Plan would lead to significant air quality and GHG impacts. Under CEQA, the RDPEIR is required to implement all feasible mitigation. We have provided a list of additional mitigation measures below for the Project Applicant to consider implementing as formal mitigation measures in a future EIR. 1 “Guidance on Frequently Questioned Topics in Roadway Analysis for the California Environmental Quality Act (CEQA).” CEQA, February 2018, available at: https://www.aqmd.gov/docs/defaultsource/ceqa/handbook/roadway-ceqa-guidance_v10.pdf, p. 2. 2 Ibid.

GSEJA

19 CONT
3 To reduce the VOC emissions associated with the construction and operation of future projects, we recommend the RDPEIR consider incorporating the following mitigation measures used by other land use development projects to address VOC emissions: 3
• Recycle leftover paint. Take any leftover paint to a household hazardous waste center; do not mix leftover water-based and oil-based paints.
• Keep lids closed on all paint containers when not in use to prevent VOC emissions and excessive odors.
• For water-based paints, clean up with water only. Whenever possible, do not rinse the cleanup water down the drain or pour it directly into the ground or the storm drain • Use compliant low-VOC cleaning solvents to clean paint application equipment. • Keep all paint- and solvent-laden rags in sealed containers to prevent VOC emissions.

The United States Environmental Protection Agency recommends conducting calculations for coverage area and thinning ratios prior to purchasing paints. By applying these calculations, the appropriate quantity of paint can be acquired, helping to minimize waste and optimize resource use.4 To reduce construction VOC emissions, the California Department of Public Health (“CDPH”) recommends the use of:5

• Composite wood products that comply with the California Air Resources Board's (“CARB”) Airborne Toxic Control Measure for formaldehyde.
• Interior paints, coatings, adhesives, and sealants that comply with South Coast AQMD Rule 1168 or CARB’s Suggested Control Measure for Architectural Coatings. • Flooring materials that are certified as low emitting under the CDPH Standard Method v1.2 or equivalent.
• Sealer on the surface of spray-on fireproofing to reduce adsorption of VOCs using a low-VOC sealer, if necessary.

An additional mitigation measure that may reduce the impact from operational VOC emissions is to implement a mechanical ventilation system meeting the American Society of Heating, Refrigerating and Air-Conditioning Engineers Standards 62.1 and 62.2. 6 HVAC systems should include MERV 13 or higher filters to reduce indoor pollutant exposure. Prior to occupancy, the building should undergo a flush-out 3 “Banning Commerce Center Project.” Kimley-Horn and Associates, Inc., June 2024, available at:
https://ceqanet.opr.ca.gov/2022090102/2; Draft Environmental Impact Report, p. 1-7. 4 “Methods for Estimating Air Emissions from Paint, Ink, and Other Coating Manufacturing Facilities.” Emissions Inventory Improvement Program, February 2005, available at: https://www.epa.gov/sites/default/files/2015- 08/documents/ii08_feb2005.pdf, Volume II, Chapter 8, p. 8.3-1. 5 “Reducing occupant exposure to volatile organic compounds (VOCs) from indoor sources: Guidelines for building occupants.” California Department of Public Health, July 1996, available at:
https://www.cdph.ca.gov/Programs/CCDPHP/DEODC/EHLB/IAQ/CDPH%20Document%20Library/reducing_occupa nt_exposure_vocs_guidelines_ADA.pdf. 6 Ibid., p. xii.

GSEJA

19 CONT
4 period with HVAC systems operating at full capacity for at least 48 hours to remove residual VOCs and improve indoor air quality.

To reduce the NOx, PM10, and PM2.5 emissions from the construction and operation of future project, which commonly originate from mobile source engines and road dust, we recommend the DPEIR consider incorporating several mitigation measures (see list below).7,8 The Southern California Association of Governments (“SCAG”)’s 2020 RTP/SCS Program Environmental Impact Report recommends the followingAir Quality Project Level Mitigation Measures, which are applicable to future projects: 9
• Minimize land disturbance.
• Cover trucks when hauling dirt.
• Limit vehicular paths on unpaved surfaces and stabilize any temporary roads. • Minimize unnecessary vehicular and machinery activities. • Provide an operational water truck on-site at all times. Use watering trucks to minimize dust; watering should be sufficient to confine dust plumes to the project work areas. Sweep paved streets at least once per day where there is evidence of dirt that has been carried on to the roadway.
• Develop a traffic plan to minimize community impacts as a result of traffic flow interference from construction activities. The plan may include advance public notice of routing, use of public transportation, and satellite parking areas with a shuttle service. Schedule operations affecting traffic for off-peak hours. Minimize obstruction of through-traffic lanes. Provide a flag person to guide traffic properly and ensure safety at construction sites. Project sponsors should consider developing a goal for the minimization of community impacts. • Require contractors to assemble a comprehensive inventory list (i.e., make, model, engine year, horsepower, emission rates) of all heavy-duty off-road (portable and mobile) equipment (50 horsepower and greater) that could be used an aggregate of 40 or more hours for the construction project.
• Require residential area parking permit.

To reduce the CO emissions associated with the construction and operation of future projects under the Specific Plan, the Bay Area Air Quality Management District recommends implementing “reduction programs to reduce vehicle miles traveled (“VMT”), improving bicycle and pedestrian infrastructure and access; improving public transit service and access; designating truck routes and limiting heavy-duty 7 “Proposed Revisions to the National Ambient Air Quality Standards for Nitrogen Dioxide.” EPA, July 2009, available at: https://www.gpo.gov/fdsys/pkg/FR-2009-07-15/pdf/E9-15944.pdf. 8 “Particle Pollution and your Health.” EPA, September 2003, available at:
https://www.airnow.gov/publications/air-quality-andyour-health/partical-pollution-and-your-health/. 9 “4.0 Mitigation Measures.” Connect SoCal Program Environmental Impact Report Addendum #1, September 2020, available at: https://scag.ca.gov/sites/main/files/fileattachments/fpeir_connectsocal_addendum_4_mitigationmeasures.pdf?1606004420, p. 4.0-2 – 4.0-10; 4.0-19 –

4.0-23; See also: “Certified Final Connect SoCal Program Environmental Impact Report.” SCAG, May 2020, available at: https://scag.ca.gov/peir.

GSEJA

19 CONT
5 truck traffic during peak hours, and encouraging the use of cleaner fuel vehicles.”10 We recommend the following mitigation measures used by other land use development projects:
• All construction equipment shall be properly tuned and maintained in accordance with manufacturer specifications.
• The use of electrical or natural-gas-powered construction equipment shall be employed where feasible, including forklifts and other comparable equipment types.

To reduce the GHG emissions associated with future projects, we suggest several mitigation measures (see list below).

The SCAG’s 2020 RTP/SCS Program Environmental Impact Report Greenhouse Gas Project Level Mitigation Measures recommends:
• Incorporate bicycle and pedestrian facilities into project designs, maintaining these facilities, and providing amenities incentivizing their use; and planning for and building local bicycle projects that connect with the regional network.
• Improving transit access to rail and bus routes by incentives for construction and transit facilities within developments, and/or providing dedicated shuttle service to transit stations. • Designate a percentage of parking spaces for ride-sharing vehicles or high-occupancy vehicles, and provide adequate passenger loading and unloading for those vehicles.

In their 2022 Scoping Plan, CARB recommends that new residential projects “[use] all-electric appliances without any natural gas connections and [do] not use propane or other fossil fuels for space heating, water heating, or indoor cooking” in order to reduce Project-related GHG emissions. 11 CEQA Guidelines 15126.4 (c)(3) include “[o]ffsite measures, including offsets that are not otherwise required, to mitigate a project’s emissions” as viable options for GHG mitigation.12 While the use of local carbon offset programs to reduce a project's GHG impacts should be considered as a measure of last resort, around 5% of project have implemented such strategies to mitigate residual emissions.13 There are many instances of projects implementing similar strategies, one example is the Otay Ranch Village 10 “Mitigating Air Quality and Climate Impacts.” BAAQMD, 2022, available at:
https://www.baaqmd.gov/~/media/files/planning-and-research/ceqa/ceqa-guidelines-2022/ceqa-guidelineschapter-8-mitigation_final-pdf.pdf?rev=5a4aa8d31c394498b8b4de4e9eb46edc, p. 8-2 and 3. 11 “2022 Scoping Plan For Achieving Carbon Neutrality” CARB, November 2022, available at:
https://ww2.arb.ca.gov/sites/default/files/2022-11/2022-sp-appendix-d-local-actions.pdf, Appendix D, p. 23, Table

3. 12 “Cal. Code Regs. tit. 14 § 15126.4.” CEQA Guidelines, May 2024, available at:
https://casetext.com/regulation/california-code-of-regulations/title-14-natural-resources/division-6-resourcesagency/chapter-3-guidelines-for-implementation-of-the-california-environmental-quality-act/article-9-contents-ofenvironmental-impact-reports/section-151264-consideration-and-discussion-of-mitigation-measures-proposed-tominimize-significant-effects. 13 “Local CEQA Mitigation Best Practices and Lessons Learned.” CARB and California EPA, September 2023, available at: https://ww2.arb.ca.gov/sites/default/files/2023-11/CARB%2021STC001%20White%20Paper.pdf, p. ix,

46. GSEJA

19 CONT
6 13 Project in San Diego County which proposed the use of carbon offsets to mitigate its GHG emissions.14 Another example of this was in the case of the Oakland Sports and Mixed-Use Project, where off-site reduction measures in the neighboring communities were recommended.15 The California Air Pollution Control Officers Association recommends the establishment of community gardens as a method of mitigation for greenhouse gas.16 Community gardens can provide local food sources, potentially reducing VMT for grocery shopping and displacing carbon-intensive food production practices. The reduced VMT could minimize CO, NOx, PM10, and PM2.5 emissions from the operations of future projects under the Specific Plan.

The measures provided offer feasible ways to incorporate lower-emitting design features into the proposed Project, which can subsequently reduce emissions released during the construction and operation of the future projects.

We recommend a revised EIR be prepared to include all feasible mitigation measures, as well as updated air quality and GHG analyses to ensure that the necessary mitigation measures are implemented. The revised EIR should also demonstrate a commitment to the implementation of these measures prior to Specific Plan approval to ensure that the potentially significant emissions from future projects are reduced to the maximum extent possible.

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.
14 “List Of Mitigation Measures and Environmental Design Considerations.” Otay Ranch Resort Village FEIR, County of San Diego, September 2020, available at:
https://www.sandiegocounty.gov/content/dam/sdc/pds/ceqa/OtayRanchVillage13Resort/PreBoard/DFEIR/7.0%20 List%20of%20Mitigation%20Measures%20.pdf, Chapter 7.0, p. 7-50. 15 “Cal. Pub. Resources Code § 21168.6.7.” 2024, available at: https://casetext.com/statute/californiacodes/california-public-resources-code/division-13-environmental-quality/chapter-6-limitations/section-2116867- oakland-sports-and-mixed-use-project-conditions-for-approval-certification-of-project-for-streamlining. 16 “Quantifying Greenhouse Gas Mitigation Measures.” CAPCOA, August 2010, available at:
https://www.aqmd.gov/docs/default-source/ceqa/handbook/capcoa-quantifying-greenhouse-gas-mitigationmeasures.pdf, p. 448.

GSEJA

19 CONT
7 Sincerely,
Matt Hagemann, P.G., C.Hg.

Paul E. Rosenfeld, Ph.D.

Attachment A: Matt Hagemann CV
Attachment B: Paul Rosenfeld CV
GSEJA

19 CONT
2656 29th Street, Suite 201
Santa Monica, CA 90405
Matt Hagemann, P.G, C.Hg.
(949) 887-9013
[email protected]
Matthew F. Hagemann, P.G., C.Hg., QSD, QSP
Geologic and Hydrogeologic Characterization
Investigationand RemediationStrategies
LitigationSupport and Testifying Expert
IndustrialStormwaterCompliance
CEQAReview
Education:

M.S. Degree, Geology, California State University Los Angeles, Los Angeles, CA, 1984.

B.A. Degree, Geology, Humboldt State University, Arcata, CA, 1982.

ProfessionalCertifications:

California Professional Geologist
California Certified Hydrogeologist
Qualified SWPPP Developer and Practitioner
ProfessionalExperience:

Matt has 30 years of experience in environmental policy, contaminant assessment and remediation, stormwater compliance, and CEQA review. He spent nine years with the U.S. EPA in the RCRA and Superfund programs and served as EPA’s Senior Science Policy Advisor in the Western Regional Office where he identified emerging threats to groundwater from perchlorate and MTBE. While with EPA, Matt also served as a Senior Hydrogeologist in the oversight of the assessment of seven major military facilities undergoing base closure. He led numerous enforcement actions under provisions of the Resource Conservation and Recovery Act (RCRA) and directed efforts to improve hydrogeologic characterization and water quality monitoring. For the past 15 years, as a founding partner with SWAPE, Matt has developed extensive client relationships and has managed complex projects that include consultation as an expert witness and a regulatory specialist, and a manager of projects ranging from industrial stormwater compliance to CEQA review of impacts from hazardous waste, air quality and greenhouse gas emissions.

Positions Matt has held include:
• Founding Partner, Soil/Water/Air Protection Enterprise (SWAPE) (2003 – present); • Geology Instructor, Golden West College, 2010 – 2104, 2017; • Senior Environmental Analyst, Komex H2O Science, Inc. (2000 ‐‐ 2003); Attachment A
GSEJA

19 CONT
2 • Executive Director, Orange Coast Watch (2001 – 2004); • Senior Science Policy Advisor and Hydrogeologist, U.S. Environmental Protection Agency (1989– 1998);
• Hydrogeologist, National Park Service, Water Resources Division (1998 – 2000); • Adjunct Faculty Member, San Francisco State University, Department of Geosciences (1993 – 1998);
• Instructor, College of Marin, Department of Science (1990 – 1995); • Geologist, U.S. Forest Service (1986 – 1998); and
• Geologist, Dames & Moore (1984 – 1986).

Senior Regulatory and Litigation Support Analyst:

With SWAPE, Matt’s responsibilities have included:
• Lead analyst and testifying expert in the review of over 300 environmental impact reports and negative declarations since 2003 under CEQA that identify significant issues with regard to hazardous waste, water resources, water quality, air quality, greenhouse gas emissions, and geologic hazards. Make recommendations for additional mitigation measures to lead agencies at the local and county level to include additional characterization of health risks and implementation of protective measures to reduce worker exposure to hazards from toxins and Valley Fever.
• Stormwater analysis, sampling and best management practice evaluation at more than 100 industrial facilities.
• Expert witness on numerous cases including, for example, perfluorooctanoic acid (PFOA) contamination of groundwater, MTBE litigation, air toxins at hazards at a school, CERCLA compliance in assessment and remediation, and industrial stormwater contamination. • Technical assistance and litigation support for vaporintrusion concerns. • Lead analyst and testifying expert in the review of environmental issues in license applications forlarge solar power plants before the California Energy Commission. • Manager of a project to evaluate numerous formerly used military sites in the western U.S. • Manager of a comprehensive evaluation of potential sources of perchlorate contamination in Southern California drinking water wells.
• Manager and designated expert for litigation support under provisions of Proposition 65 in the review of releases of gasoline to sources drinking water at major refineries and hundreds of gas stations throughout California.

With Komex H2O Science Inc., Matt’s duties included the following:
• Senior author of a report on the extent of perchlorate contamination that was used in testimony by the former U.S. EPA Administrator and General Counsel. • Seniorresearcher in the development of a comprehensive, electronically interactive chronology of MTBE use, research, and regulation.
• Seniorresearcher in the development of a comprehensive, electronically interactive chronology of perchlorate use, research, and regulation.
• Senior researcher in a study that estimates nationwide costs for MTBE remediation and drinking water treatment, results of which were published in newspapers nationwide and in testimony against provisions of an energy bill that would limit liability for oil companies. • Research to support litigation to restore drinking water supplies that have been contaminated by MTBE in California and New York.

GSEJA

19 CONT
3 • Expert witness testimony in a case of oil production‐related contamination in Mississippi. • Lead author for a multi‐volume remedial investigation report for an operating school in Los Angeles that met strict regulatory requirements and rigorous deadlines. • Development of strategic approaches for cleanup of contaminated sites in consultation with clients and regulators.

Executive Director:

As Executive Director with Orange Coast Watch, Matt led efforts to restore water quality at Orange County beaches from multiple sources of contamination including urban runoff and the discharge of wastewater. In reporting to a Board of Directors that included representatives from leading Orange County universities and businesses, Matt prepared issue papers in the areas of treatment and disinfection of wastewater and control of the discharge of grease to sewer systems. Matt actively participated in the development of countywide water quality permits for the control of urban runoff and permits for the discharge of wastewater. Matt worked with other nonprofits to protect and restore water quality, including Surfrider, Natural Resources Defense Council and Orange County CoastKeeper as well as with business institutions including the Orange County Business Council.

Hydrogeology:

As a Senior Hydrogeologist with the U.S. Environmental Protection Agency, Matt led investigations to characterize and cleanup closing military bases, including Mare Island Naval Shipyard, Hunters Point Naval Shipyard, Treasure Island Naval Station, Alameda Naval Station, Moffett Field, Mather Army Airfield, and Sacramento Army Depot. Specific activities were as follows:
• Led efforts to model groundwater flow and contaminant transport, ensured adequacy of monitoring networks, and assessed cleanup alternatives for contaminated sediment, soil, and groundwater.
• Initiated a regional program for evaluation of groundwater sampling practices and laboratory analysis at military bases.
• Identified emerging issues, wrote technical guidance, and assisted in policy and regulation development through work on four national U.S. EPA workgroups, including the Superfund Groundwater Technical Forum and the Federal Facilities Forum.

At the request of the State of Hawaii, Matt developed a methodology to determine the vulnerability of groundwater to contamination on the islands of Maui and Oahu. He used analytical models and a GIS to show zones of vulnerability, and the results were adopted and published by the State of Hawaii and County of Maui.

As a hydrogeologist with the EPA Groundwater Protection Section, Matt worked with provisions of the Safe Drinking Water Act and NEPA to prevent drinking water contamination. Specific activities included the following:
• Received an EPA Bronze Medal for his contribution to the development of national guidance for the protection of drinking water.
• Managed the Sole Source Aquifer Program and protected the drinking water of two communities through designation under the Safe Drinking Water Act. He prepared geologic reports, conducted GSEJA

19 CONT
4 public hearings, and responded to public comments from residents who were very concerned about the impact of designation.
• Reviewed a number of Environmental Impact Statements for planned major developments, including large hazardous and solid waste disposal facilities, mine reclamation, and water transfer.

Matt served as a hydrogeologist with the RCRA Hazardous Waste program. Duties were as follows:
• Supervised the hydrogeologic investigation of hazardous waste sites to determine compliance with Subtitle C requirements.
• Reviewed and wrote ʺpart Bʺ permits for the disposal of hazardous waste. • Conducted RCRA Corrective Action investigations of waste sites and led inspections that formed the basis for significant enforcement actions that were developed in close coordination with U.S.

EPA legal counsel.
• Wrote contract specifications and supervised contractor’s investigations of waste sites.

With the National Park Service, Matt directed service‐wide investigations of contaminant sources to prevent degradation of water quality, including the following tasks:
• Applied pertinent laws and regulations including CERCLA, RCRA, NEPA, NRDA, and the Clean Water Act to control military, mining, and landfill contaminants. • Conducted watershed‐scale investigations of contaminants at parks, including Yellowstone and Olympic National Park.
• Identified high‐levels of perchlorate in soil adjacent to a national park in New Mexico and advised park superintendent on appropriate response actions under CERCLA. • Served as a Park Service representative on the Interagency Perchlorate Steering Committee, a national workgroup.
• Developed a program to conduct environmental compliance audits of all National Parks while serving on a national workgroup.
• Co‐authored two papers on the potential for water contamination from the operation of personal watercraft and snowmobiles, these papers serving as the basis for the development of nation‐ wide policy on the use of these vehicles in National Parks. • Contributed to the Federal Multi‐Agency Source Water Agreement under the Clean Water Action Plan.

Policy:

Served senior management as the Senior Science Policy Advisor with the U.S. Environmental Protection Agency, Region 9.

Activities included the following:
• Advised the Regional Administrator and senior management on emerging issues such as the potential for the gasoline additive MTBE and ammonium perchlorate to contaminate drinking water supplies.
• Shaped EPA’s national response to these threats by serving on workgroups and by contributing to guidance, including the Office of Research and Development publication, Oxygenates in Water: Critical Information and Research Needs.
• Improved the technical training of EPAʹs scientific and engineering staff. • Earned an EPA Bronze Medal for representing the region’s 300 scientists and engineers in negotiations with the Administrator and senior management to better integrate scientific GSEJA

19 CONT
5 principles into the policy‐making process.
• Established national protocol for the peerreview of scientific documents.

Geology:

With the U.S. Forest Service, Matt led investigations to determine hillslope stability of areas proposed for timber harvest in the central Oregon Coast Range. Specific activities were as follows:
• Mapped geology in the field, and used aerial photographic interpretation and mathematical models to determine slope stability.
• Coordinated his research with community members who were concerned with natural resource protection.
• Characterized the geology of an aquifer that serves as the sole source of drinking water for the city of Medford, Oregon.

As a consultant with Dames and Moore, Matt led geologic investigations of two contaminated sites (later listed on the Superfund NPL) in the Portland, Oregon, area and a large hazardous waste site in eastern Oregon. Duties included the following:
• Supervised year‐long effort for soil and groundwater sampling. • Conducted aquifer tests.
• Investigated active faults beneath sites proposed for hazardous waste disposal.

Teaching:

From 1990 to 1998, Matt taught at least one course per semester at the community college and university levels:
• At San Francisco State University, held an adjunct faculty position and taught courses in environmental geology, oceanography (lab and lecture), hydrogeology, and groundwater contamination.
• Served as a committee member for graduate and undergraduate students. • Taught courses in environmental geology and oceanography at the College of Marin.

Matt is currently a part time geology instructor at Golden West College in Huntington Beach, California where he taught from 2010 to 2014 and in 2017.

Invited Testimony, Reports, Papers and Presentations:

Hagemann, M.F., 2008. Disclosure of Hazardous Waste Issues under CEQA. Presentation to the Public Environmental Law Conference, Eugene, Oregon.

Hagemann, M.F., 2008. Disclosure of Hazardous Waste Issues under CEQA. Invited presentation to U.S.

EPA Region 9, San Francisco, California.

Hagemann, M.F., 2005. Use of Electronic Databases in Environmental Regulation, Policy Making and Public Participation. Brownfields 2005, Denver, Coloradao.

Hagemann, M.F., 2004. Perchlorate Contamination of the Colorado River and Impacts to Drinking Water in Nevada and the Southwestern U.S. Presentation to a meeting of the American Groundwater Trust, Las Vegas, NV (served on conference organizing committee).

GSEJA

19 CONT
6 Hagemann, M.F., 2004. Invited testimony to a California Senate committee hearing on air toxins at schools in Southern California, Los Angeles.

Brown, A., Farrow, J., Gray, A. and Hagemann, M., 2004. An Estimate of Costs to Address MTBE Releases from Underground Storage Tanks and the Resulting Impact to Drinking Water Wells.

Presentation to the Ground Water and Environmental Law Conference, National Groundwater Association.

Hagemann, M.F., 2004. Perchlorate Contamination of the Colorado River and Impacts to Drinking Water in Arizona and the Southwestern U.S. Presentation to a meeting of the American Groundwater Trust, Phoenix, AZ (served on conference organizing committee).

Hagemann, M.F., 2003. Perchlorate Contamination of the Colorado River and Impacts to Drinking Water in the Southwestern U.S. Invited presentation to a special committee meeting of the National Academy of Sciences, Irvine, CA.

Hagemann, M.F., 2003. Perchlorate Contamination of the Colorado River. Invited presentation to a tribal EPA meeting, Pechanga, CA.

Hagemann, M.F., 2003. Perchlorate Contamination of the Colorado River. Invited presentation to a meeting of tribal repesentatives, Parker, AZ.

Hagemann, M.F., 2003. Impact of Perchlorate on the Colorado River and Associated Drinking Water Supplies. Invited presentation to the Inter‐Tribal Meeting, Torres Martinez Tribe.

Hagemann, M.F., 2003. The Emergence of Perchlorate as a Widespread Drinking Water Contaminant.

Invited presentation to the U.S. EPA Region 9.

Hagemann, M.F., 2003. A Deductive Approach to the Assessment of Perchlorate Contamination. Invited presentation to the California Assembly Natural Resources Committee.

Hagemann, M.F., 2003. Perchlorate: A Cold War Legacy in Drinking Water. Presentation to a meeting of the National Groundwater Association.

Hagemann, M.F., 2002. From Tank to Tap: A Chronology of MTBE in Groundwater. Presentation to a meeting of the National Groundwater Association.

Hagemann, M.F., 2002. A Chronology of MTBE in Groundwater and an Estimate of Costs to Address Impacts to Groundwater. Presentation to the annual meeting of the Society of Environmental Journalists.

Hagemann, M.F., 2002. An Estimate of the Cost to Address MTBE Contamination in Groundwater (and Who Will Pay). Presentation to a meeting of the National Groundwater Association.

Hagemann, M.F., 2002. An Estimate of Costs to Address MTBE Releases from Underground Storage Tanks and the Resulting Impact to Drinking Water Wells. Presentation to a meeting of the U.S. EPA and State Underground Storage Tank Program managers.

GSEJA

19 CONT
7 Hagemann, M.F., 2001. From Tank to Tap: A Chronology of MTBE in Groundwater. Unpublished report.

Hagemann, M.F., 2001. Estimated Cleanup Cost for MTBE in Groundwater Used as Drinking Water.

Unpublished report.

Hagemann, M.F., 2001. Estimated Costs to Address MTBE Releases from Leaking Underground Storage Tanks. Unpublished report.

Hagemann, M.F., and VanMouwerik, M., 1999. Potential W a t e r Quality Concerns Related to Snowmobile Usage. Water Resources Division, National Park Service, Technical Report.

VanMouwerik, M. and Hagemann, M.F. 1999, Water Quality Concerns Related to Personal Watercraft Usage. Water Resources Division, National Park Service, Technical Report.

Hagemann, M.F., 1999, Is Dilution the Solution to Pollution in National Parks? The George Wright Society Biannual Meeting, Asheville, North Carolina.

Hagemann, M.F., 1997, The Potential for MTBE to Contaminate Groundwater. U.S. EPA Superfund Groundwater Technical Forum Annual Meeting, Las Vegas, Nevada.

Hagemann, M.F., and Gill, M., 1996, Impediments to Intrinsic Remediation, Moffett Field Naval Air Station, Conference on Intrinsic Remediation of Chlorinated Hydrocarbons, Salt Lake City.

Hagemann, M.F., Fukunaga, G.L., 1996, The Vulnerability of Groundwater to Anthropogenic Contaminants on the Island of Maui, Hawaii. Hawaii Water Works Association Annual Meeting, Maui, October 1996.

Hagemann, M. F., Fukanaga, G. L., 1996, Ranking Groundwater Vulnerability in Central Oahu, Hawaii. Proceedings, Geographic Information Systems in Environmental Resources Management, Air and Waste Management Association Publication VIP‐61.

Hagemann, M.F., 1994. Groundwater Ch ar ac te r i z a t i o n and Cl ean up a t Closing Military Bases in California. Proceedings, California Groundwater Resources Association Meeting.

Hagemann, M.F. and Sabol, M.A., 1993. Role of the U.S. EPA in the High Plains States Groundwater Recharge Demonstration Program. Proceedings, Sixth Biennial Symposium on the Artificial Recharge of Groundwater.

Hagemann, M.F., 1993. U.S. EPA Policy on the Technical Impracticability of the Cleanup of DNAPL‐ contaminated Groundwater. California Groundwater Resources Association Meeting.

GSEJA

19 CONT
8 Hagemann, M.F., 1992. Dense Nonaqueous Phase Liquid Contamination of Groundwater: An Ounce of Prevention... Proceedings, Association of Engineering Geologists Annual Meeting, v. 35.

Other Experience:

Selected as subject matter expert for the California Professional Geologist licensing examinations, 2009‐2011.

GSEJA

19 CONT

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 B
GSEJA

19 CONT
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.

GSEJA

19 CONT
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.

GSEJA

19 CONT
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.

GSEJA

19 CONT
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.

GSEJA

19 CONT
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.

GSEJA

19 CONT
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.

GSEJA

19 CONT
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
GSEJA

19 CONT
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
GSEJA

19 CONT
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
GSEJA

19 CONT
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
GSEJA

19 CONT
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
GSEJA

19 CONT

THIS PAGE INTENTIONALLY LEFT BLANK