Indio City Council
September 16, 2026

Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 1683 of 2236 The Oasis at Indio Project Fiscal and Economic Impact Analysis DRAFT Report
20 I/O Modeling Considerations
The IMPLAN dataset utilized in this analysis relies on I/O relations derived using 2022 data that was inflation adjusted to 2024 dollars. All economic impacts depicted in this analysis reflect gross impacts. As such, they do not account for potential shifts in resources or consumer expenditures from other local alternatives. The I/O methodology assumes that an industry’s demand for goods and services results in a commensurate increase in supply and therefore employment. This implies that key industry suppliers can increase output rather than shift output from one set of consumers or products to another. This assumption may not hold in areas with tight labor or capital markets because companies may find it difficult to obtain these inputs or other resources necessary to expand production. In these cases, accommodating an establishment’s demand for labor and other inputs may come at the expense of other establishments in the same or related sectors or may need to be satisfied by increased imports from outside the study area. This phenomenon often is referred to as “crowding out” because the stimulated sector tends to crowd out other sectors, which can reduce the net economic gain.

Economic Analysis Results
Table 3 above summarizes the estimated one-time construction impacts and ongoing annual direct, indirect, and induced impacts generated by the Project in the City. As shown, construction of the Project is anticipated to generate between $613.3 million and $1.32 billion in one-time economic impacts, supporting between 5,326 and 11,831 job years in the City. Assuming a development timeline of approximately five and a half years, this is equivalent to 968 to 2,151 construction-related jobs annually. On an annual ongoing basis, Project operations are anticipated to support between 1,293 and 1,400 new jobs (including direct, indirect, and induced jobs) in the City, including 1,236 to 1,375 jobs associated with the non-residential land uses and 25 to 57 jobs associated with the residential land uses. The non-residential land uses are estimated to generate between $147 million and $159 million annually in total economic impacts in Indio. The economic model does not estimate economic impacts of jobs associated with the residential land uses.

Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 1684 of 2236 Economic & Planning Systems, Inc. (EPS)
21 Detailed Economic Analysis Findings
and Assumptions
The following section provides the detailed results of the Economic Impact Analysis, as well as the assumptions used to calculate each impact.

One-Time Construction Impacts
Impacts associated with construction of the Project through buildout are measured on a one-time basis. Construction activity generates a short-term burst of economic activity that dissipates once construction is complete. One-time impacts include the value of new construction, employment created, and income earned during Project construction. One-time economic impacts are calculated based on the anticipated Project hard construction cost. Soft costs and financing costs are excluded. Based on information provided by the Project Applicant, it is estimated that the Project will incur approximately $609.7 million to $1.31 billion in hard construction costs. Duration of one-time impacts is limited to the development period of the Project, which the Applicant indicated would be five and a half years.

Table 4 details the estimated one-time economic impacts associated with construction of the Project. The resulting impacts are described below:
• Annual Output: For Maximum Buildout Scenario, construction operations are estimated to generate approximately $1.31 billion in direct one-time industry output in the City. Local spending will result in $7.5 million in indirect and induced one-time impacts for a total one-time industry output impact of $1.32 billion. For Scenario 2, construction operations are estimated to generate approximately $609.7 million in direct one-time industry output in the City. Local spending will result in $3.6 million in indirect and induced onetime impacts for a total one-time industry output impact of $613.3 million. • Employee Compensation: Of the $609.7 million to $1.31 billion in direct industry output reported above, approximately $335 million to $745.4 million will be received by construction employees in the form of salary, wages, and benefits, respectively. Indirect and induced employee compensation impacts range from approximately $1.0 million to $2.1 million, for a total annual employee compensation impact ranging from approximately $336 million to $747.5 million, respectively.

Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 1685 of 2236 Sanderson Avenue Industrial Project Fiscal and Economic Impact Analysis 22 • Annual Employment: For Maximum Buildout Scenario, the 11,791 direct job years support approximately 40 indirect and induced job years for a total employment impact of approximately 11,831 job years. For Scenario 2, the 5,307 direct job years support approximately 19 indirect and induced job years for a total employment impact of approximately 5,326 job years. Employment includes both full-time and part-time workers. Job years refers to the number of jobs in each year summed over the entire estimated period of construction of the Project. Assuming a development timeline of approximately five and a half years, this is equivalent to an annual average of 968 to 2,151 jobs.

Table 4 Detailed One-Time Economic Impacts of Project Construction Activity/Impact Categories
Key Input
Maximum Buildout Scenario Project Construction Costs $1,309,350,835 Scenario 2 Project Construction Costs $609,724,943
Maximum Buildout Scenario - One-Time Construction Impacts Economic Output in City of Indio [2]
Industry Output (excl. Income) $563,920,000 $3,660,000 $1,720,000 $569,300,000 Income [3] $745,430,000 $1,467,402 $662,949 $747,560,351 Total Output $1,309,350,000 $5,127,402 $2,382,949 $1,316,860,351 nstruction Employment in City of Indio
ob years) [4] 11,791 26 14 11,831
Scenario 2 - One-Time Construction Impacts
Economic Output in City of Indio [2]
Industry Output (excl. Income) $274,710,000 $1,800,000 $780,000 $277,290,000 Income [3] $335,020,000 $720,000 $292,949 $336,032,949
Total Output $609,730,000 $2,520,000 $1,072,949 $613,322,949 nstruction Employment in City of Indio
ob years) [4] 5,307 12 7 5,326
[3] Includes employee compensation, proprietors income, and other income (industry profits, rents, and royalties).

Source: IMPLAN, 2022 Dataset; BH Properties; EPS.
[1] Note that total construction impacts include direct and indirect impacts only; induced Impacts were not estimated because construction activities are temporary and thus are not anticipated to generate net new household expenditures in the local economy. [2] Analysis based on City of Indio data. Output is the amount of business expenditures on goods and services retained within the local economy, defined as City of Indio.
[4] Job years refer to the number of jobs in each year summed over the entire construction period of the Project. For example, if the construction timeline was two years, a single worker employed for the entire construction period would equate to two job years.

No assumption has been made for the Project construction timeline in this table. Employment includes both full-time and part-time workers.

Impacts Type
Total
One Time
Impacts
Direct
(Project Construction)
Indirect
(Construction
Suppliers)
Induced [1]
(NA)

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23 Ongoing Operations Impacts
Ongoing economic impacts capture the direct, indirect, and induced impacts generated annually by the spending of residents and the operations businesses located in the Project. Impacts associated with these economic activities are estimated based on operating costs for residential land uses, household spending, occupied housing units, and employment estimates for the Project. Table 5 shows estimated total direct ongoing Full-Time Equivalent (FTEs) jobs generated by the two use scenarios.

Ongoing Jobs Created from Residential Uses
To estimate direct jobs associated with the Project’s residential land uses, EPS estimated average annual operating expenses for residential uses in the City of Indio using Riverside/Corona market data obtained from CoStar, and applied the most appropriate industry code to the associated jobs in order to estimate economic impacts. For Maximum Buildout Scenario, estimated annual residential operating expenses are associated with 40 direct on-site jobs. For Scenario 2, estimated annual residential operating expenses are associated with 18 direct onsite jobs. The model estimates that the number of indirect jobs associated with residential operations is less than one.

Ongoing Direct Jobs Created from Non-Residential Uses
EPS estimated the total employment at the Project based on information provided by the Applicant and industry standards for employment density for the proposed land use types (as described in the Fiscal Impact Analysis chapter), and applied the most appropriate industry codes to the associated jobs in order to estimate total economic impacts. For Maximum Buildout Scenario, 3 percent of the 1,232 estimated direct employees are assumed to be employed in retail jobs (IMPLAN Code 412 – Retail – Miscellaneous store retailers) and 97 percent of the 1,232 estimated direct employees are assumed to be employed in industrial jobs (IMPLAN Code 422 – Warehousing and Storage).

For Scenario 2, there is a mix of retail, hotel, and industrial employment, resulting in 133 workers employed directly in retail jobs (IMPLAN Code 412 – Retail – Miscellaneous store retailers), 43 workers in hotel jobs (IMPLAN Code 507 – Hotels and motels, including casino hotels), and 1,195 workers in industrial jobs (IMPLAN Code 422 – Warehousing and Storage), for a total of 1,371 nonresidential jobs.

Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 1687 of 2236 Sanderson Avenue Industrial Project Fiscal and Economic Impact Analysis 24 Table 5 Estimated Direct Project Employment
Land Use Category Employees [1]
Maximum Buildout Scenario
Residential 40
Retail 37
Industrial 1,195
Total 1,272
Scenario 2
Residential 18
Retail 133
Industrial 1,195
Hotel 43
Total 1,389
Source: BH Properties; EPS.
[1] Non-residential Employment estimates have
been provided by BH Properties. Residential
Employment estimates were determined by
using an I/O approach based on
annual operating expenses.

Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 1688 of 2236 Economic & Planning Systems, Inc. (EPS)
25 Ongoing Impacts from Project Uses
Table 6 summarizes the total estimated annual ongoing impacts associated with Project operations at the non-residential land uses for the two use scenarios. The resulting impacts are described below:

Maximum Buildout Scenario (Retail and Industrial Uses)
• Annual Output: Project operations are estimated to generate approximately $146.1 million in direct industry output annually. Local spending will result in approximately $680,000 in indirect industry output impacts and approximately $47,400 in induced impacts annually, for a total industry output impact of $147 million on an annual basis.
• Employee Compensation: Of the $146.1 million in direct industry output reported above, approximately $77 million will be received by employees employed in the Project in the form of salary, wages, and benefits. Indirect and induced employee compensation impacts total approximately $196,100, for a total annual employee compensation impact of approximately $77.2 million.
• Annual Employment: The 1,232 direct jobs for non-residential land uses will generate approximately 4 indirect jobs annually. Total employment impact will be approximately 1,236 jobs on an annual basis.

Scenario 2 (Retail, Hotel, and Industrial Uses)
• Annual Output: Project operations are estimated to generate approximately $157.8 million in direct industry output annually. Local spending will result in approximately $730,000 in indirect industry output impacts and $60,543 in induced impacts annually, for a total industry output impact of $158.6 million on an annual basis.
• Employee Compensation: Of the $157.8 billion in direct industry output reported above, approximately $81.9 million will be received by employees employed in the Project in the form of salary, wages, and benefits. Indirect and induced employee compensation impacts total approximately $217,000, for a total annual employee compensation impact of approximately $82.1 million.
• Annual Employment: The 1,371 direct jobs for non-residential land uses will generate approximately 4 indirect jobs annually. Total employment impact will be approximately 1,375 jobs on an annual basis.

Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 1689 of 2236 Sanderson Avenue Industrial Project Fiscal and Economic Impact Analysis 26 Table 6 Detailed Annual Economic Impacts of Ongoing Project Operations (NonResidential Land Uses) Table 7 summarizes total estimated ongoing jobs associated with the residential land uses for the two use scenarios. The estimate for direct jobs associated with the operations of the Project’s residential uses is shown above. To estimate induced jobs generated by household spending at the Project’s residential units, EPS estimated disposable household income per 100 units was using annual rents associated with each prototype for the two use scenarios and assuming households spend 30 percent of their income on rent (detailed in the Fiscal Impact Analysis). EPS then adjusted annual household income for annual rent and payroll taxes. The household income generated per 100 units was input to the IMPLAN model to estimate the jobs supported by new household spending. Using IMPLAN allows for a comprehensive analysis of residential spending patterns, including in traditional industries like housecleaning, home repair/maintenance, landscaping, and construction but also on services that may not require physical (i.e., “brick and mortar”) establishments. The industries with the most jobs include health care, retail trade; other services (except public administration); and accommodation and food services. The pattern of job generation depends on the household income level. In this analysis, 100 percent of households in Maximum Buildout Scenario and 39 percent of households in Scenario 2 have a Activity/Impact Categories
Key Input
Maximum Buildout Scenario
Ongoing Project Full Time Equivalent (FTE) Employees (Non-Residential Uses) 1,232 Scenario 2
Ongoing Project Full Time Equivalent (FTE) Employees (Non-Residential Uses) 1,371 Maximum Buildout Scenario - Annual Ongoing Operating Impact Economic Output in City of Indio [1]
Industry Output (excl. Income) $69,107,849 $497,234 $34,076 $69,639,159 Income [2] $77,020,000 $182,766 $13,321 $77,216,087
Total Output $146,127,849 $680,000 $47,397 $146,855,246 Annual Average Employment in City of Indio [3] 1,232 4 0 1,236 Scenario 2 - Annual Ongoing Operating Impact
Economic Output in City of Indio [1]
Industry Output (excl. Income) $75,880,617 $530,000 $43,552 $76,454,169 Income [2] $81,930,000 $200,000 $16,991 $82,146,991
Total Output $157,810,617 $730,000 $60,543 $158,601,160 Annual Average Employment in City of Indio [3] 1,371 4 0 1,375 [2] Includes employee compensation, proprietors income, and other income (profits, rents, and royalties).

Source: IMPLAN, 2022 Dataset; BH Properties; EPS.
[1] Analysis based on City of Indio data. Output is the amount of business expenditures on goods and services retained within the local economy.
[3] Reflects stabilized operational employment at Project. Indirect and Induced Employment includes both full-time and part-time workers. Induced jobs from project employee spending are less than one.

Impact Type
Total
Annual
Ongoing
Impacts
Direct
(Project
Operations)
Indirect
(Business to
Business Purchases
to Support
Operations)
Induced
(Household
Spending from
Project
Employees)

Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 1690 of 2236 Economic & Planning Systems, Inc. (EPS)
27 gross household income of $80,000 per year, while 61 percent of households in Scenario 2 have a gross household income of $100,000.

Using this analysis, EPS estimates that new household spending will generate approximately 17 induced jobs annually for the Maximum Buildout Scenario, and seven jobs annually for Scenario 2. Total employment impacts will be approximately 57 jobs annually for Maximum Buildout Scenario, and approximately 25 jobs annually for Scenario 2.

Table 7 Detailed Annual Jobs Impacts of Ongoing Project Operations (Residential Land Uses)
Activity/Impact Categories
Key Input
Maximum Buildout Scenario
Residential Land Use Operating Expenses $17,559,113
Household Spending per 100 Units (Wrap Units) $4,881,800 Total Occupied Units (Wrap Units) 3,029
Scenario 2
Residential Land Use Operating Expenses $8,042,239
Household Spending per 100 Units (Townhome Units) $6,008,104 Total Occupied Units (Townhome Units) 360
Household Spending per 100 Units (Tuck Under Units) 4,881,800 Total Occupied Units (Tuck Under Units) 877
Maximum Buildout Scenario - Annual Ongoing Operating Impact Annual Average Employment in City of Indio [1] 40 0 17 57 Scenario 2 - Annual Ongoing Operating Impact
Annual Average Employment in City of Indio [1] 18 0 7 25 Source: IMPLAN, 2022 Dataset; BH Properties; EPS.
[1] Reflects stabilized operational employment at Project. Indirect jobs associated with business to business purchases from residential uses are less than one. Induced jobs from residential uses are based on spending by new resident households.

Impact Type
Total
Annual
Ongoing
Impacts
Direct
(Project
Operations)
Indirect
(Business to
Business Purchases
to Support
Operations)
Induced
(Household
Spending from
Project Residents)

Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 1691 of 2236 APPENDICES:

Appendix A: General Fiscal Impact Assumptions
Appendix B: Revenue-Estimating Tables
Appendix C: Expenditure-Estimating Tables
Appendix D: Supporting Tables for
Revenue Estimates

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General Fiscal Impact Assumptions
Table A-1 General Assumptions ...................................................A-1 Table A-2.1 Maximum Buildout Scenario Detailed Land Use..................A-2 Table A-2.2 Scenario 2 Detailed Land Use.........................................A-3 Table A-3.1 Maximum Buildout Scenario Assumptions at Buildout .........A-4 Table A-3.2 Scenario 2 Assumptions at Buildout ................................A-5

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Table A-1
The Oasis in Indio Specific Plan Fiscal Impact Analysis General Assumptions
Item Assumption
General Assumptions
Base Fiscal Year [1] FY 2023-24
Dollars (2023$)
General Demographic Characteristics
City of Indio
Population [2] Per Capita 90,837
Employees [3] Per Employee 20,403
City of Indio Persons Served [4] Persons Served 98,386
Source: CA DOF; CA EDD; LEHD; BLS; City of Indio; EPS
[2] DOF Table 2: E-5 City of Indio population estimate as of January 2023. [3] Employee number is based on LEHD 2021 jobs estimate for Indio, adjusted upward by

10.7% to reflect overall jobs increase from Dec. 2020 to Dec. 2022 in Riverside County.

Number is further adjusted by an additional 5% to account for self-employed workers. [1] Reflects the City of Indio Fiscal Year 2023-24 Adopted Annual Budget.

Revenues and expenditures are in 2023 dollars. This analysis does not reflect changes in value resulting from inflation or appreciation.
[4] Defined as total population plus 50% of total employees, reflecting commute patterns in Indio.

Prepared by EPS. 234051-FIAmodelv5 3/22/2024

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Table A-2.1
The Oasis in Indio Specific Plan Fiscal Impact Analysis Maximum Buildout Scenario Detailed Land Use
Land Use
Avg. Sq. Ft. Per
Unit Value PSF [1]
TRA
Share of
Land Use
Planned Units
or Sq. Ft. Total Value [2]
Residential
4-story Wrap
TRA: 007-029 850 $349 54% 1,742 $516,830,146
TRA: 007-104 850 $349 46% 1,498 $444,315,854
Subtotal 3,240 $961,146,000
Commercial - Retail
Retail
TRA: 007-029 $275 54% 10,754 $2,957,476
TRA: 007-104 $275 46% 9,246 $2,542,524
Subtotal 20,000 $5,500,000
Industrial
Industrial
TRA: 007-029 $70 54% 971,283 $67,989,836
TRA: 007-104 $70 46% 835,007 $58,450,464
Subtotal 1,806,290 $126,440,300
lu data
Source: BH Properties; EPS
[2] Weighted average values per category rounded to nearest thousand. [1] The value for each land use is based on estimated construction costs from BH Properties.

Prepared by EPS. 234051-FIAmodelv5 3/22/2024

Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 1695 of 2236 DRAFT
Table A-2.2
The Oasis in Indio Specific Plan Fiscal Impact Analysis Scenario 2 Detailed Land Use
Land Use
Avg. Sq. Ft. Per
Unit
Value Per Sq.

Ft. [1]
TRA
Share of
Land Use
Planned Units
or Sq. Ft. Total Value [2]
Residential
Townhomes
TRA: 007-104 1,482 $175 100% 360 $93,366,000
Tuck-under
TRA: 007-029 829 $270 100% 877 $196,298,910
Subtotal 1,237 $289,664,910
Commercial
Retail
TRA: 007-029 $275 100% 71,600 $19,690,000
Subtotal 71,600 $19,690,000
Hotel per room
TRA: 007-029 $150,000 100% 128 $19,200,000
Subtotal 128 $19,200,000
Industrial
Industrial
TRA: 007-029 $70 54% 971,283 $67,989,836
TRA: 007-104 $70 46% 835,007 $58,450,464
Subtotal 1,806,290 $126,440,300
lu data
Source: BH Properties; EPS
[2] Weighted average values per category rounded to nearest thousand. [1] The value for each land use is based on estimated construction costs from BH Properties.

Prepared by EPS. 234051-FIAmodelv5 3/22/2024

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Table A-3.1
The Oasis in Indio Specific Plan Fiscal Impact Analysis Maximum Buildout Scenario Assumptions at Buildout
Land Use
Est. Average
Assessed
Value [2]
Vacancy
Rate [3]
Persons
per
HH/Sq.

Ft. per
Employee
[4]
Persons
Served
Factor
Units/Bldg.

Sq. Ft.

Occupied
Units/Bldg.

Sq. Ft.

Population/
Employees
Persons
Served
Formula A B C D E = D * (1 - A) F = E * B G = C * F
Residential Land Use Categories [1]
4-story Wrap
TRA: 007-029 $516,830,146 6.5% 2.3 1.0 1,742 1,629 3,714 3,714 TRA: 007-104 $444,315,854 6.5% 2.3 1.0 1,498 1,400 3,192 3,192 Subtotal 3,240 3,029 6,906 6,906
Commercial Land Use Categories
Retail
TRA: 007-029 $2,957,476 7.4% 500 0.5 10,754 9,959 20 10 TRA: 007-104 $2,542,524 7.4% 500 0.5 9,246 8,561 17 9
Subtotal 20,000 18,520 37 19
Industrial Land Use Categories
Industrial
TRA: 007-029 $67,989,836 0.8% 1500 0.5 971,283 963,513 642 321 TRA: 007-104 $58,450,464 0.8% 1500 0.5 835,007 828,327 552 276 Subtotal 1,806,290 1,791,840 1,195 597
Total 8,138 7,522
dev assumps
Source: CoStar; City of Indio; EPS
[2] Average assessed values rounded to the nearest thousand.

Assumptions Planned Land Uses
[4] 2022 American Community Survey data estimates an average persons per multifamily household of 2.3 persons.

Square feet per employee based on industry standards.
[1] Products included in each residential land use category are detailed in Table A-2. Average assessed value for each category is a weighted average of estimated assessed value for each product within the category. [3] Residential, Commercial and Industrial vacancy rates from CoStar. Residential vacancy accounts for units used as short-term rentals.

Hotel vacancy is accounted for in calculation of revenues in Table B-6.

Prepared by EPS. 234051-FIAmodelv5 3/22/2024

DRAFT
Table A-3.2
The Oasis in Indio Specific Plan Fiscal Impact Analysis Scenario 2 Assumptions at Buildout
Land Use
Est. Average
Assessed
Value [2]
Vacancy
Rate [3]
Persons
per HH
Or Sq. Ft.
per
Employee
[4]
Persons
Served
Factor
Units/Bldg.

Sq. Ft.

Occupied
Units/Bldg.

Sq. Ft.

Population/
Employees
Persons
Served
Formula A B C D E = D * (1 - A) F = E * B G = C * F
Residential Land Use Categories [1]
Townhomes
TRA: 007-104 $93,366,000 6.5% 2.3 1.0 360 337 768 768
Tuck-under
TRA: 007-029 $196,298,910 6.5% 2.3 1.0 877 820 1,870 1,870 Subtotal 1,237 1,157 2,638 3,081
Commercial Land Use Categories
Retail
TRA: 007-029 $19,690,000 7.4% 500 0.5 71,600 66,302 133 66 Subtotal 71,600 66,302 133 66
Hotel rooms/empl.

TRA: 007-029 $19,200,000 N/A 3 0.5 128 128 43 21
Subtotal 128 128 43 21
Industrial Land Use Categories
Industrial
TRA: 007-029 $67,989,836 0.8% 1500 0.5 971,283 963,513 642 321 TRA: 007-104 $58,450,464 0.8% 1500 0.5 835,007 828,327 552 276 Subtotal 1,806,290 1,791,840 1,195 597
Total 4,008 3,766
dev assumps
Source: CoStar; City of Indio; EPS
[2] Average assessed values rounded to the nearest thousand.

Assumptions Planned Land Uses
[4] 2022 American Community Survey data estimates an average persons per multifamily household of 2.3 persons. Square feet per employee based on industry standards.

[1] Products included in each residential land use category are detailed in Table A-2. Average assessed value for each category is a weighted average of estimated assessed value for each product within the category. [3] Residential, Commercial and Industrial vacancy rates from CoStar. Residential vacancy accounts for units used as short-term rentals.

Hotel vacancy is accounted for in calculation of revenues in Table B-6.

Prepared by EPS. 234051-FIAmodelv5 3/22/2024

APPENDIX B:

Revenue-Estimating Tables
Table B-1 Revenue-Estimating Procedures .....................................B-1 Table B-2 Estimated Project Revenues at Buildout...........................B-2 Table B-3 Estimated Property Tax Revenues...................................B-3 Table B-4.1 Maximum Buildout Scenario Real Property Transfer Tax Revenue at Buildout.....................................................B-4 Table B-4.2 Scenario 2 Real Property Transfer Tax Revenue at Buildout ............................................................................…..B-5 Table B-5 Estimated Taxable Sales and Use Tax Revenue .................B-6 Table B-5A Estimated Annual Taxable Sales, Hybrid Market Support Method ..........................................................B-7 Table B-5B Estimated Annual Taxable Sales Generated from On-Site Retail Development..............................................................B-8 Table B-5C Estimated Annual Taxable Sales Generated from Industrial Business-to-Business Activities ......................................B-9 Table B-6 Estimated Annual Transient Occupancy Tax .................... B-10 Table B-6A Estimated Annual Transient Occupancy Tax from Hotel Use .............................................................................. B-11 Table B-6B Estimated Annual Transient Occupancy Tax from Short-term Rentals.................................................................... B-12

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Table B-1
The Oasis in Indio Specific Plan Fiscal Impact Analysis Revenue-Estimating Procedures Based on City of Indio FY 2022-23 Budget (2023$) FY 2022-23
Estimating Case Study Budgeted Service Revenue
General Fund Revenues Procedure Reference Revenues Population Multiplier Taxes:

Property Taxes $23,600,000
Property Tax In-Lieu of VLF Case Study Table B-3 $12,500,000 N/A - County Allocated and Homeowner Property Tax Case Study Table B-3 $11,100,000 N/A - Real Property Transfer Tax Case Study Table B-4.2 $450,000 N/A - Sales Tax Case Study $36,500,000 N/A -
Bradley Burns Tax Case Study Table B-5 $18,500,000 N/A - Measure X Case Study Table B-5 $18,000,000 N/A
Transient Occupancy Tax $15,150,000 N/A -
Hotel/STR-Generated Transient Occupancy Tax [1] Case Study Resident-Associated Transient Occupancy Tax [2] Per Capita 90,837 $116.75 Business License Tax Per Employee $650,000 20,403 $31.86 Utility Users' Tax Persons Served $9,800,000 98,386 $99.61 Licenses and Permits $4,170,000
Business Licenses Per Employee $350,000 20,403 $17.15
Building and Planning Permits [2] $2,400,000 N/A
Short-term rental Permits Per Capita $1,000,000 90,837 $11.01 Other Licenses and Permits [2] $420,000 N/A -
Fees and Charges for Current Services $12,489,500
Music-Festival Events [2] $6,500,000 N/A -
Ambulance Services [2] $2,500,000 N/A -
Other Fees and Charges [2] $3,489,500 N/A -
Fines and Forfeitures Persons Served $600,000 98,386 $6.10 Use of Money and Property [3] $7,116,496 N/A -
Intergovernmental [3] $155,000 N/A -
Other Revenues [3] $150,000 N/A -
Subtotal General Fund Revenues $110,830,996
Transfers In from Special Revenue Funds [4] [2] $4,505,000 - Subtotal General Fund Operating Resources $115,335,996
Less Offsetting Revenues [5] $15,309,500
Net General Fund Operating Revenues $100,026,496
Source: City of Indio FY 2023-24 Adopted Annual Budget; EPS. [3] Not expected to be affected by the Project and therefore no revenue multipliers are estimated in this analysis. [4] Transfers from restricted funds that can only be used for specific purposes. These revenues are included in the offsetting revenues calculations.

See Table C-3.
[5] Sum of offsetting revenues dedicated to specific General Fund department functions. These revenues are budget neutral and are netted out of both total revenues and total costs. See Table C-1.
[2] This analysis assumes that all or part of these revenues are fully dedicated to specific General Fund departmental costs (Offsetting Revenues). [1] Hotel/STR-Generated Transient Occupancy Tax revenues are revenues that generated directly from the project site upon buildout.

Resident-Associated Transitent Occupancy Tax revenues are revenues generated by visitors associated with new residents at the Project.

Prepared by EPS. 234051-FIAmodelv5 3/22/2024

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Table B-2
The Oasis in Indio Specific Plan Fiscal Impact Analysis Estimated Project Revenues at Buildout (2023$)
General Fund Revenues Source
Maximum
Buildout
Scenario Scenario 2
(Rounded) (Rounded)
Taxes:

Property Taxes
Property Tax In-Lieu of VLF Table B-3 $1,135,306 $472,600 County Allocated and Homeowner Property Tax Table B-3 $1,218,900 $551,200 Real Property Transfer Tax Table B-4 $30,060 $15,200
Sales Tax
Bradley Burns Tax Table B-5 $545,600 $359,600
Measure X Table B-5 $545,600 $359,600
Transient Occupancy Tax
Hotel/STR-Generated Transient Occupancy Tax Table B-6 $646,000 $546,000 Resident-Associated Transient Occupancy Tax Table B-1 $806,300 $359,700 Business License Tax Table B-1 $39,200 $43,600
Utility Users' Tax Table B-1 $749,200 $375,100
Licenses and Permits
Business Licenses Table B-1 $21,100 $23,500
Short-term rental Permits Table B-1 $76,000 $33,900
Fines and Forfeitures Table B-1 $45,900 $23,000
Total Annual General Fund Revenues $5,859,166 $3,163,000 Source: City of Indio FY 2023-24 Adopted Annual Budget; EPS.

Note: Values are rounded to the nearest 100.

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Table B-3
The Oasis in Indio Specific Plan Fiscal Impact Analysis Estimated Property Tax Revenues (2023$)
Item Assumptions Formula
Maximum
Buildout
Scenario Scenario 2
1-Percent Property Tax
Total Assessed Value of Project [1]a $1,093,086,300 $454,995,210 TRA: 007-029 Total Assessed Valueb $488,051,622 $292,810,061 TRA: 007-104 Total Assessed Valuec $577,408,773 $134,559,244 Property Tax Revenue (1% of Assessed Value) 1.00% d = a * 1.00% $10,930,863 $4,549,952 TRA: 007-029 Property Tax Revenue (1% of Assessed Value) 1.00% e = b * 1.00% $4,880,516 $2,928,101 TRA: 007-104 Property Tax Revenue (1% of Assessed Value) 1.00% f = c * 1.00% $5,774,088 $1,345,592 Estimated Property Tax Allocation: 007-029
City of Indio 14.92% g = e * 14.92% $728,157 $436,863
Other Agencies 85.08% h = e * 85.08% $4,152,359 $2,491,237 Estimated Property Tax Allocation: 007-104
City of Indio 8.50% i = f * 8.50% $490,721 $114,358
Other Agencies 91.50% i = f * 91.50% $5,283,366 $1,231,235 Property Tax In Lieu of Motor Vehicle In-Lieu Fee Revenue (VLF) Total Existing Citywide Assessed Value [2]j $12,035,150,566 $12,035,150,566 Est. Total Assessed Value of Project k = a $1,093,086,300 $454,995,210 Est. Total New Assessed Value l = j + k $13,128,236,866 $12,490,145,776 Percent Change in AV m = k / j 9.08% 3.78%
Net New Property Tax In Lieu of VLF $12,500,000 n = m * $12,500,000 $1,135,306.01 $472,569.09 prop tax
Source: City of Indio FY 2023-24 Adopted Annual Budget; EPS. [1] For assumptions and calculation of assessed value, refer to Table D-2. [2] County of Riverside 2023 Assessed Value.

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DRAFT
Table B-4.1
The Oasis in Indio Specific Plan Fiscal Impact Analysis Maximum Buildout Scenario Real Property Transfer Tax Revenue at Buildout (2023$) Description Assessed Value
Annual Transfer
Tax Revenue
Assumptions
Rate per $1,000 of AV [1] $0.55
Turnover Rate
Renter-Occupied Homes [2] 5.0%
Nonresidential Sq. Ft. 5.0%
Assessed Value [3]
Residential
4-story Wrap
TRA: 007-029 $516,830,146 $14,213
TRA: 007-104 $444,315,854 $12,219
Subtotal $961,146,000 $26,432
Commercial
Retail
TRA: 007-029 $2,957,476 $81
TRA: 007-104 $2,542,524 $70
Subtotal $5,500,000 $151
Industrial
Industrial
TRA: 007-029 $67,989,836 $1,870
TRA: 007-104 $58,450,464 $1,607
Subtotal $126,440,300 $3,477
Total $1,093,086,300 $30,060
Source: City of Indio; BH Properties; EPS.
[1] City of Indio FY 2023-2024 Adopted Annual Budget.

Source/
Assumption
Planned Land Uses
[3] Assessed Values (AV) derived in Table D-2.1. Note that assessed values are expressed in (2023$) and include no real AV growth.
[2] Turnover rate for rental units indicates the rate at which the residential buildings are sold and reassessed, not the rate of tenant turnover in individual units.

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Table B-4.2
The Oasis in Indio Specific Plan Fiscal Impact Analysis Scenario 2 Real Property Transfer Tax at Buildout (2023$) Description Assessed Value
Annual Transfer
Tax Revenue
Assumptions
Rate per $1,000 of AV [1] $0.55
Turnover Rate
Renter-Occupied Homes [2] 6.7%
Nonresidential Sq. Ft. 5.0%
Assessed Value [3]
Residential
Townhomes
TRA: 007-104 $93,366,000 $3,423
Tuck-under
TRA: 007-029 $196,298,910 $7,198
Subtotal $289,664,910 $10,621
Commercial
Retail
TRA: 007-029 $19,690,000 $541
Subtotal $19,690,000 $541
Hotel
TRA: 007-029 $19,200,000 $528
Subtotal $19,200,000 $528
Industrial
Industrial
TRA: 007-029 $67,989,836 $1,870
TRA: 007-104 $58,450,464 $1,607
Subtotal $126,440,300 $3,477
Total $454,995,210 $15,168
Source: City of Indio; BH Properties; EPS.
[1] City of Indio FY 2023-2024 Adopted Annual Budget.

Source/
Assumption
Planned Land Uses
[2] Turnover rate for rental units indicates the rate at which the residential buildings are sold and reassessed, not the rate of tenant turnover in individual units. [3] Assessed Values (AV) derived in Table D-2.2. Note that assessed values are expressed in (2023$) and include no real AV growth.

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Table B-5
The Oasis in Indio Specific Plan Fiscal Impact Analysis Estimated Taxable Sales and Use Tax Revenue (2023$)
Item Assumptions Formula
Estimated Annual Taxable Sales (Rounded)
Annual Taxable Sales from New Market Support Table B-5.A $47,700,460 $19,677,057 Net Annual Taxable Sales from Onsite Retail Use Table B-5.B $1,486,000 $10,906,000 Annual Taxable Sales from Onsite Industrial Use Table B-6 $5,375,520 $5,375,520 Total Annual Taxable Sales a $54,561,980 $35,958,577
Annual Sales Tax Revenue
Bradley Burns Local Sales Tax 1.0% b = 1.0% * a $545,620 $359,586 Measure X Sales Tax 1.0% c = 1.0% * a $545,620 $359,586 Subtotal $1,091,240 $719,172
sales tax
Source: EPS
Scenario 2
Maximum
Buildout Scenario
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DRAFT
Table B-5.A
The Oasis in Indio Specific Plan Fiscal Impact Analysis Estimated Annual Taxable Sales, Hybrid Market Support Method (2023$) Item Description
Annual Taxable Sales from New Occupied Households
Taxable Retail Expenditures [1]
4-story Wrap
TRA: 007-029 $21,800 $35,512,200
TRA: 007-104 $21,800 $30,520,000
Townhomes
TRA: 007-104 $23,400 $7,885,800
Tuck-under
TRA: 007-029 $21,800 $17,876,000
Subtotal $66,032,200 $25,761,800
Taxable Sales from New Households
Taxable Sales Captured by the City 70% $46,222,540 $18,033,260 Maximum Buildout Scenario
Estimated Taxable Sales inside Project Area [2] 5% $2,311,127 Estimated Taxable Sales outside Project Area [2] 95% $43,911,413 Scenario 2
Estimated Taxable Sales inside Project Area [2] 15% $2,704,989 Estimated Taxable Sales outside Project Area [2] 85% $15,328,271 Annual Taxable Sales from New Employees
New Employees Table A-3 1,232 1,370
Average Work Day Taxable Sales per New Employee $10.00
Work Days per Year 240
Total City Taxable Sales from New Employees $2,955,840 $3,287,594 Taxable Sales Captured by City [3] 50% $1,477,920 $1,643,797 Maximum Buildout Scenario
Estimated Taxable Sales inside Project Area [2] 5% $73,896 Estimated Taxable Sales outside Project Area [2] 95% $1,404,024 Scenario 2
Estimated Taxable Sales inside Project Area [2] 15% $246,570 Estimated Taxable Sales outside Project Area [2] 85% $1,397,227 Total Annual City Taxable Sales from Market Support $47,700,460 $19,677,057 Taxable City Sales inside Project Area $2,385,023 $2,951,559 Taxable City Sales outside Project Area $45,315,437 $16,725,498 sales tax a
Source: BLS; Consumer Expenditure Survey; EPS.

Assumption Scenario 2
[2] EPS estimate of resident/employee spending split between retail stores in the Project and stores outside the Project. The proportion of new household spending at the Project is assumed to be higher in Scenario 2 given the greater amount of retail space in that scenario. [3] Discounted by 50% to avoid double-counting employees who are also residents and to account for taxable sales from new employees that occur outside the City.

Maximum
Buildout Scenario
[1] The calculation of retail expenditures is based on assumptions regarding household expenditures shown on D-3, and the development program shown on A-3. Rounded to the nearest $500.

Annual Expenditures
Per HH
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Table B-5.B
The Oasis in Indio Specific Plan Fiscal Impact Analysis Estimated Annual Taxable Sales Generated from On-Site Retail Development (2023$) On-Site Retail Development Assumption Formula
Maximum
Buildout Scenario Scenario 2
Retail Use
Taxable Sales per Sq. Ft. [1] $220 a
Occupied Building Sq. Ft. [2] b 18,520 66,302
Annual Taxable Sales from On-Site Retail Dev. [3] c = a * b $4,074,400 $14,586,440 Less On-Site Market Support [4] d $2,385,023 $2,951,559 Subtotal Annual Sales less Market Support e = c - d $1,689,377 $11,634,881 Less Shift of Sales from Existing Retail Stores to the Project [5] 5% f = c * 0.05 $203,720 $729,322 Net Annual On-Site Retail Taxable Sales g = e - f $1,485,657 $10,905,559 sales tax b
Source: Urban Land Institute & ICSC, Dollars & Cents of Shopping Centers/The SCORE 2008 ; BOE; EPS. [3] Refers to new sales in the Project from customers other than new Project residents and employees. [4] Derived in Table B-5A.
[1] Derived from ULI's Dollars & Cents of Shopping Centers: 2008. Values inflated to 2023 dollars using the CPI for the Riverside Area, All Urban Consumers. Taxable Retail Sales Factor based on taxable sales information from the CA Board of Equalization. [5] Represents a discount factor to account for taxable sales transactions that may shift from existing City retail to those inside the Project. [2] Assumed vacancy rate for retail use is detailed in Table A-3.

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Sanderson Avenue San Jacinto Project Fiscal Impact Analysis Estimated Annual Taxable Sales Generated from Industrial B2B Activities (2023$) On-Site Industrial Development Formula
Occupied Building Sq. Ft. [1] a 1,791,840
Proportion Generating Sales Tax [2] 30%
Taxable Sales per Sq. Ft. [3] b $10.00
Annual Taxable Sales from On-Site Industrial Dev. c = a * b $5,375,520 Source: EPS.
[1] Assumed vacancy rate for industrial use is detailed in Table A-3. [4] As both scenarios have the same amount of industrial space, estimated sales tax from industrial uses is assumed to be the same for both scenarios Amount [4]
[2] Accounts for industrial building uses that are not expected to generate onsite business-to-business sales activities, including e-commerce, warehousing, and logistics.
[3] A taxable sales per square foot assumption representing onsite business-to-business sales activity, based on research of similar industrial development. This assumptions take into account use tax, which is paid to the State by in-state businesses on purchases made from out-of-state businesses.

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DRAFT
Table B-6
The Oasis in Indio Specific Plan Fiscal Impact Analysis Estimated Annual Transient Occupancy Tax (2023$)
Item Assumptions
Estimated Annual Transient Occupancy Tax Revenue (Rounded) Annual Transient Occupancy Tax from Hotel Use Table B-6.A $299,000 Annual Transient Occupancy Tax from Short-term Rentals Table B-6.B $646,000 $247,000 Total Annual Revenue $646,000 $546,000
sales tax
Source: EPS
Maximum
Buildout Scenario Scenario 2
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DRAFT
Table B-6.A
The Oasis in Indio Specific Plan Fiscal Impact Analysis Estimated Annual Transient Occupancy Tax from Hotel Use (2023$) Item
Scenario 2 [1]
RevPAR [2] a $64
# of Rooms b 128
# of Days c 365
Annual Hotel Revenue Generated d = a * b * c $2,990,080 Transient Occupancy Tax (TOT) Rate [3] e 10.00%
Annual Transient Occupancy Tax f = d * e $299,008
Source: CoStar; City of Indio; BH Properties; EPS
[2] RevPAR, or revenue per available room, is calculated as annual daily rate (ADR) multiplied by occupancy. This assumption reflects 2023 RevPAR for City of Indio hotels.
[3] Based on City of Indio's TOT rate for hotels with 50 or more rooms. [1] TOT from hotel use is only calculated for Scenario 2, as the Maximum Buildout Scenario does not include a hotel use.

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Table B-6.B
The Oasis in Indio Specific Plan Fiscal Impact Analysis Estimated Annual Transient Occupancy Tax from Short-term Rentals (2023$) Item
General Assumptions
Share of Residential Units Used for Short-term Rentals [1] 2.0% Average Daily Rate [2] $350
Average Occupancy Rate [2] 60%
Maximum Buildout Scenario
Total Residential Units a 3,240
Number of Units Used for Short-term Rentals b 65
# of Days c 219
Average Daily Rate d $350
Annual Hotel Revenue Generated e = b * c * d $4,966,920 Transient Occupancy Tax (TOT) Rate [4] f 13.00%
Annual Transient Occupancy Tax g = e * f $645,700
Scenario 2
Total Residential Units h 1,237
Number of Units Used for Short-term Rentals i 25
# of Days j 219
Average Daily Rate k $350
Annual Hotel Revenue Generated l = i * j * k $1,896,321 Transient Occupancy Tax (TOT) Rate [4] m 13.00%
Annual Transient Occupancy Tax n = l * m $246,522
Source: Airbtics; City of Indio; BH Properties; EPS
[1] Informed by current percentage of Indio housing units registered as short-term rentals, as reported by the City, and feedback from Applicant and City. [3] Based on City of Indio's TOT rate for STRs.
[2] Based on average daily rate and occupancy rate data obtained from Airbtics.

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Expenditure-Estimating Tables
Table C-1 Expenditure-Estimating Procedures.................................C-1 Table C-2 Estimated Annual Project Expenditures............................C-2 Table C-3 City of Indio Offsetting General Fund Revenue .................C-3

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Table C-1
The Oasis in Indio Specific Plan Fiscal Impact Analysis Expenditure-Estimating Procedures Based on City of Indio FY 2023-24 Budget Less
FY 2023-24 Offsetting FY 2023-24
Estimating Budgeted Revenue Net City Persons Cost Per Variable Net Cost Per Item Procedure Expenditures [1] Expenditures Served Persons Served Factor [2] Persons Served General Administration Per Capita $12,466,207 $0 $12,466,207 90,837 $137.24 50% $68.62 Economic Development Persons Served $1,389,879 $0 $1,389,879 98,386 $14.13 50% $7.06 Community Development Persons Served $3,656,278 $2,820,000 $836,278 98,386 $8.50 50% $4.25 Police Persons Served $41,918,995 $9,989,500 $31,929,495 98,386 $324.53 90% $292.08 Fire and Ambulance Persons Served $21,123,220 $2,500,000 $18,623,220 98,386 $189.29 90% $170.36 Public Works Persons Served $8,877,866 $0 $8,877,866 98,386 $90.24 90% $81.21 Total Annual General Fund Expenditures $89,432,445 $15,309,500 $74,122,945 exp pro
Source: City of Indio FY 2023-24 Adopted Annual Budget; EPS. [1] Represents departmental revenues identified for specific General Fund department functions in the City's fiscal budget. See Table C-3. [2] Variable factor recognizes some department costs are fixed and would increase on a one-to-one basis with new growth in persons served.

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DRAFT
Table C-2
The Oasis in Indio Specific Plan Fiscal Impact Analysis Estimated Annual Project Expenditures (2023$)
Expenditures Source
General Fund
General Administration Table C-1 $473,900 10.2% $211,400 9.2% Economic Development Table C-1 $53,100 1.1% $26,600 1.2% Community Development Table C-1 $32,000 0.7% $16,000 0.7% Police Table C-1 $2,197,000 47.3% $1,099,900 47.8%
Fire and Ambulance Table C-1 $1,281,400 27.6% $641,600 27.9% Public Works Table C-1 $610,900 13.1% $305,800 13.3%
Total Annual General Fund Expenditures $4,648,300 100.0% $2,301,300 100.0% Source: City of Indio FY 2023-24 Adopted Annual Budget; EPS.

Note: Values are rounded to the nearest $100.

Scenario 2
Amount
(Rounded)
Percent of
Total
Maximum Buildout Scenario
Amount (Rounded)
Percent of
Total
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Table C-3
The Oasis in Indio Specific Plan Fiscal Impact Analysis City of Indio Offsetting General Fund Revenue FY 23-24
General Fund Department Offsetting Revenue Source Revenue (FY 23-24) Community Development $2,820,000
Building and Planning Permits $2,400,000
Other Licenses and Permits $420,000
Police $9,989,500
Music-Festival Events $6,500,000
Other Fees and Charges $3,489,500
Fire and Ambulance $2,500,000
Ambulance Services $2,500,000
TOTAL $15,309,500
offset rev
Source: City of Indio FY 2023-24 Adopted Annual Budget; EPS.

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Supporting Tables for Revenue Estimates
Table D-1 Property Tax Allocations ...............................................D-1 Table D-2.1 Maximum Buildout Scenario Estimated Assessed Valuation at Buildout.....................................................................D-2 Table D-2.2 Scenario 2 Estimated Assessed Valuation at Buildout..........D-3 Table D-3 Estimated Project Household Incomes .............................D-4

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Table D-1
The Oasis in Indio Specific Plan Fiscal Impact Analysis Preliminary Property Tax Allocations
Fund/ Agency 007-029 007-104
City of Indio 14.92% 8.50%
All Other Taxing Agencies
Riverside County General 12.12% 11.41%
County Library 1.22% 1.47%
Desert Sands Unified School District 30.72% 37.13%
Desert Community College 6.38% 7.72%
Riverside County Office of Education 3.47% 4.20%
Coachella Valley Recreation and Parks 1.00% 1.21%
Coachella Valley Mosquito and Vector Control 0.83% 1.00% Coachella Valley Water District State WTR Proj 2.32% 2.81% Coachella Valley Public Cemetary 0.19% 0.24%
Coachella Valley Resource Conser 0.03% 0.04%
Coachella Valley WD IMP DIST 1 DS 1.08% 1.31%
Coachella Valley WD Storm Water Unit 2.94% 3.55%
ERAF 22.77% 19.04%
Riverside County Regional Park and Open Space -- 0.36%
Coachella Valley Sanitary -- 0.03%
Subtotal for Other Taxing Agencies 85.0803% 91.5013%
Total Gross Property Tax 100% 100%
Source: Riverside County Auditor-Controller; EPS.
[1] Represents the percentage allocation of the 1% ad valorem property tax by Tax Rate Area (TRA).

Distribution of Tax Increment [1]
Tax Rate Areas
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DRAFT
Table D-2.1
The Oasis in Indio Specific Plan Fiscal Impact Analysis Maximum Buildout Scenario Estimated Assessed Valuation at Buildout (2023$) [1] Item
Residential
4-story Wrap per unit
TRA: 007-029 1,742 $296,650 $516,830,146
TRA: 007-104 1,498 $296,650 $444,315,854
Subtotal 3,240 $961,146,000
Commercial - Retail per bldg. sq. ft.

Retail
TRA: 007-029 10,754 $275.00 $2,957,476
TRA: 007-104 9,246 $275.00 $2,542,524
Subtotal 20,000 $5,500,000
Industrial per bldg. sq. ft.

Industrial
TRA: 007-029 971,283 $70.00 $67,989,836
TRA: 007-104 835,007 $70.00 $58,450,464
Subtotal 1,806,290 $126,440,300
Total Assessed Value at Buildout for TRA: 007-029 $587,777,458 Total Assessed Value at Buildout for TRA: 007-104 $505,308,842 (minus) 2023 Curent Assessed Value for TRA: 007-029 ($10,368,685) (minus) 2023 Current Assessed Value for TRA: 007-104 ($17,257,220) Net New Assessed Value for TRA: 007-029 $577,408,773
Net New Assessed Value for TRA: 007-104 $488,051,622
Total Net New Assessed Value $1,093,086,300
Source: BH Properties; EPS.
[1] Note that assessed values (AV)s are expressed in 2023$ and include no real AV growth. [2] Assessed values are rounded to the nearest thousand.

Total Units
Assessed Value
Per Unit or
Sq. Ft. [2] Total Assessed Value
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Table D-2.2
The Oasis in Indio Specific Plan Fiscal Impact Analysis Scenario 2 Estimated Assessed Valuation at Buildout (2023$) [1] Item
Residential
Townhomes
TRA: 007-104 360 $259,350 $93,366,000
Tuck-under
TRA: 007-029 877 $223,830 $196,298,910
Subtotal 1,237 $289,664,910
Commercial
Retail per bldg. sq. ft.

TRA: 007-029 71,600 $275.00 $19,690,000
Subtotal 71,600 $19,690,000
Hotel per room
TRA: 007-029 128 $150,000 $19,200,000
Subtotal 128 $19,200,000
Industrial
Industrial per bldg. sq. ft.

TRA: 007-029 971,283 $70.00 $67,989,836
TRA: 007-104 835,007 $70.00 $58,450,464
Subtotal 1,806,290 $126,440,300
Total Assessed Value at Buildout for TRA: 007-029 $303,178,746 Total Assessed Value at Buildout for TRA: 007-104 $151,816,464 (minus) 2023 Curent Assessed Value for TRA: 007-029 ($10,368,685) (minus) 2023 Current Assessed Value for TRA: 007-104 ($17,257,220) Net New Assessed Value for TRA: 007-029 $292,810,061
Net New Assessed Value for TRA: 007-104 $134,559,244
Total Net New Assessed Value $454,995,210
Source: BH Properties; EPS.
[1] Note that assessed values (AV)s are expressed in 2023$ and include no real AV growth. [2] Assessed values are rounded to the nearest thousand.

Assessed Value
Per Unit [2]
Total Assessed
Total Units Value
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Table D-3
The Oasis in Indio Specific Plan Fiscal Impact Analysis Estimated Project Household Incomes (2023$)
Estimated
Estimated Estimated Household
Unit Annual Housing Income
Residential Land Use Type Rents [2] Costs (Rounded) [3] Rental Occupied - Maximum Buildout Scenario Annual Rent 4-story Wrap
TRA: 007-029 1,629 $2,000 $24,000 $80,000 27.3% $21,800 TRA: 007-104 1,400 $2,000 $24,000 $80,000 27.3% $21,800 Weighted Average/Total 3,029 $21,800
Rental Occupied - Scenario 2
Townhomes
TRA: 007-104 337 $2,500 $30,000 $100,000 23.4% $23,400
Tuck-under
TRA: 007-029 820 $2,000 $24,000 $80,000 27.3% $21,800
Weighted Average/Total 1,157 $22,266
hh income
Source: Bureau of Labor Statistics (BLS), Consumer Expenditure Survey; CoStar; EPS. [1] See Table A-3 for calculation of the number of occupied households. [2] Renter-occupied rent assumptions based on market data from CoStar, and rounded to the nearest thousand. [3] Calculated using assumption that 30% of income is dedicated to rent payments. Incomes rounded to the nearest $1,000. [4] Taxable expenditures as a percentage of income derived from the BLS Consumer Expenditure Survey. [5] Average retail expenditures per household used to estimate annual sales tax revenues, as shown in Table B-5.A.

Occupied Number
of Households [1]
Taxable
Expenditures
as a %
of Income [4]
Average Annual
Household Taxable
Retail Exp.
(Rounded) [5]
Prepared by EPS. 234051-FIAmodelv5 3/22/2024

RESOLUTION NO. 2141

A RESOLUTION OF THE PLANNING COMMISSION OF THE CITY OF

INDIO, CALIFORNIA, RECOMMENDING THAT THE CITY COUNCIL DENY

THE OASIS AT INDIO PROJECT AS PRESENTED TO THE PLANNING

COMMISSION
WHEREAS, the City of Indio (“City”) is a general law city organized and existing under the laws of the State of California; and WHEREAS, the Oasis at Indio Project is a proposed mixed-use development project encompassing approximately 183 acres generally located at the southwest corner of Avenue 42 and Monroe Street and north of Interstate 10, consisting of various requested discretionary entitlements to be considered by the City Council, including: (1) certification of a Final Environmental Impact Report (“EIR”) (SCH No. 2024050578), adoption of CEQA findings, adoption of a statement of overriding considerations, and approval of a mitigation monitoring and reporting program; (2) General Plan Amendments (GP 23-0001 and GP 26-0005); (3) rescission of the Gateway Specific Plan and Clinton Street Business Park Project Master Plan, and adoption of the Oasis at Indio Specific Plan (SP-23-0001); (4) Zone Map Amendment (ZMA-23-0001); (5) Development Agreement (DA-23-0001); and (6) Financing Tentative Parcel Map No. 38799 (TPM-23-0001) (collectively, the “Project”); and WHEREAS, the Project as presented to the Planning Commission included industrial residential, commercial, and related mixed-use development; and WHEREAS, notice of the public hearing for the Project was provided as required by law; and
WHEREAS, on May 27, 2026, the Planning Commission conducted a duly noticed public hearing to consider the Project, the related staff report, the Final EIR, written and oral public comments, applicant materials and presentations, and all other documents and testimony submitted to the Planning Commission; and WHEREAS, after receiving public testimony, considering the staff presentation and applicant presentation, and deliberating on the Project as presented, the Planning Commission by a vote of three to two (3-2) recommended that the City Council deny the Project as presented to the Planning Commission; and WHEREAS, the Planning Commission directed that a resolution be returned to the Commission to memorialize the basis for the Commission’s recommendation; and WHEREAS, the Planning Commission’s recommendation is advisory to the City Council, and nothing in this Resolution is intended to limit the City Council’s independent review and consideration of the Project, the Final EIR, any modified or reduced project description, any additional or revised conditions of approval, any revised development agreement terms, or any other information presented to the City Council before final action; and
Docusign Envelope ID: 38276103-8ABC-8A41-815E-94D81C7EB403

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NOW, THEREFORE, THE PLANNING COMMISSION OF THE CITY OF
INDIO DOES RESOLVE, DECLARE, DETERMINE, AND ORDER AS FOLLOWS:

Section 1. Recitals.

The foregoing recitals are true and correct and are incorporated herein by this reference.

Section 2. Planning Commission Recommendation.

The Planning Commission recommends that the City Council deny the Project as presented to the Planning Commission, including the requested General Plan Amendments, Zone Map Amendment, Specific Plan, Development Agreement, Financing Tentative Parcel Map, and related discretionary approvals.

Section 3. CEQA Recommendation.

The Planning Commission recommends that, if the City Council denies the Project as presented, the City Council determine that CEQA does not require certification of the Final EIR or adoption of CEQA findings, a statement of overriding considerations, or a mitigation monitoring and reporting program because CEQA does not apply to projects that a public agency rejects or disapproves.

The Planning Commission further recommends that, if the City Council elects to consider approval of the Project as presented or as modified, the City Council independently review the Final EIR and administrative record and determine whether the Final EIR should be certified and whether appropriate CEQA findings, mitigation measures, and any required statement of overriding considerations should be adopted.

The Planning Commission’s recommendation not to approve the Project as presented is based, in part, on the Commission’s concern that the Project would result in significant and unavoidable air quality and greenhouse gas impacts (including diesel fuel emissions) and that the Project’s environmental impacts, when considered together with the scale, intensity, and location of the proposed development, do not support approval of the Project as presented.

Section 4. General Plan Amendment and Zone Map Amendment Findings.

The Planning Commission recommends denial of the requested General Plan Amendments and Zone Map Amendment for the Project as presented based on the following findings:

A. The Planning Commission could not find that the Project as presented would be consistent with the overall vision, goals, and policies of the City of Indio General Plan 2040. Although the Project includes employment-generating uses, residential uses, commercial uses, and potential public and community benefits, the Planning Commission found that the scale and intensity of the proposed industrial component, consisting of approximately 1,806,290 square feet of industrial uses, raised Docusign Envelope ID: 38276103-8ABC-8A41-815E-94D81C7EB403

Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 1722 of 2236 substantial land use compatibility, environmental, circulation, and community impact concerns.

B. The Planning Commission found that the Project as presented raised concerns regarding consistency with General Plan policies related to land use compatibility, parks and open space, circulation, and the promotion of the public health, safety, and welfare.

C. The Planning Commission found that the Project as presented would place a substantial industrial development component at a highly visible gateway location near Interstate 10 and Monroe Street, and that the proposed scale and character of the industrial component may not adequately reflect the City’s long-term planning objectives for that area.

D. The Planning Commission found that the proposed amendments to the General Plan land use designations and circulation network were not warranted based on the Project as presented, particularly given concerns regarding the proposed intensity of industrial development, vehicular and truck circulation, and compatibility with surrounding and planned land uses.

E. The Planning Commission found that the Project as presented did not provide sufficient certainty that the proposed community benefits, public facilities, park/open space improvements, and public-serving components would adequately offset or address the Project’s land use, circulation, environmental, and infrastructure impacts.

Section 5. Specific Plan Findings.

The Planning Commission recommends denial of the proposed Oasis at Indio Specific Plan as presented based on the following findings:

A. The Planning Commission could not find that the proposed Specific Plan, as presented, provides an adequate and acceptable framework for the coordinated development of the plan area due to unresolved concerns regarding land use intensity, circulation, public facilities, public benefits, and compatibility with the City’s gateway planning objectives.

B. The Planning Commission found that the proposed industrial development component, consisting of approximately 1,806,290 square feet of industrial uses, is of a scale, height, and intensity that raises substantial concerns regarding the character of the plan area at a highly visible gateway location.

C. The Planning Commission found that the Project as presented raised unresolved concerns regarding vehicular and truck circulation, access, buffering, aesthetics, and integration of the Project with surrounding streets and existing and planned development.

D. The Planning Commission found that certain public-serving components discussed in connection with the Project, including potential public facility, medical, or similar community-serving uses, were not sufficiently assured to support approval of the Specific Plan as presented.

Docusign Envelope ID: 38276103-8ABC-8A41-815E-94D81C7EB403

Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 1723 of 2236 E. The Planning Commission found that, based on the totality of the record before it, the Specific Plan as presented would not adequately promote the public health, safety, and general welfare.

Section 6. Development Agreement Findings.

The Planning Commission recommends denial of the proposed Development Agreement as presented based on the following findings:

A. Because the Planning Commission recommends denial of the legislative land use approvals necessary to implement the Project as presented, the Planning Commission could not find that the Development Agreement is consistent with the General Plan, applicable planning documents, or the public health, safety, and welfare.

B. The Planning Commission found that the public benefits proposed in the Development Agreement, as presented, were not sufficient to justify the long-term vesting of development rights contemplated by the Agreement, particularly given the scale and intensity of the proposed industrial component and the Project’s identified environmental, circulation, infrastructure, and land use compatibility concerns.

C. The Planning Commission found that the Development Agreement should not be recommended for approval unless and until the City Council determines that the Project, whether as presented or as modified, is consistent with the General Plan, supported by appropriate CEQA findings, and provides public benefits sufficient to justify the proposed vested rights.

Section 7. Financing Tentative Parcel Map Findings.

The Planning Commission recommends denial of Financing Tentative Parcel Map No. 38799 as presented based on the following findings:

A. Because the Planning Commission recommends denial of the General Plan Amendments, Zone Map Amendment, Specific Plan, and Development Agreement necessary to implement the Project as presented, the Planning Commission could not find that the proposed Financing Tentative Parcel Map is consistent with the General Plan, applicable zoning, or the proposed Specific Plan.

B. The Planning Commission found that the proposed subdivision should not be recommended for approval in the absence of approval of the underlying land use entitlements necessary to establish the development framework for the Project.

C. The Planning Commission further incorporates by reference the findings in Sections 4 and 5 of this Resolution regarding land use compatibility, circulation, infrastructure, and public facilities concerns.

Docusign Envelope ID: 38276103-8ABC-8A41-815E-94D81C7EB403

Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 1724 of 2236 Section 8. Recommendation to City Council.

Based on the foregoing, the Planning Commission hereby recommends that the City Council take the following actions with respect to the Project as presented to the Planning Commission:
• Decline to certify the Final Environmental Impact Report (SCH No. 2024050578) if the City Council denies the Project as presented; • Deny General Plan Amendments GP-23-0001 and GP-26-0005; • Deny Zone Map Amendment ZMA-23-0001;
• Deny the Oasis at Indio Specific Plan SP-23-0001 and related rescission of applicable existing specific plan and master plan provisions; • Deny Financing Tentative Parcel Map No. 38799 / TPM-23-0001; • Deny Development Agreement DA-23-0001; and
• Deny all related discretionary approvals necessary to implement the Project as presented.

Section 9. No Limitation on City Council Authority.

This Resolution reflects the Planning Commission’s recommendation on the Project as presented to the Planning Commission. Nothing in this Resolution shall be construed to limit, prejudge, or otherwise constrain the City Council’s independent legislative and adjudicatory discretion to approve, conditionally approve, modify, reduce, remand, or deny the Project or any revised version of the Project based on the record before the City Council.

PASSED, APPROVED, AND ADOPTED this 10 day of June 2026, by the following vote:

AYES: Franz, Ortiz, Santos, Slater, Scarborough-Eckel
NOES: None
ABSTAIN: None
ABSENT: None

GLORIA FRANZ

PLANNING COMMISSION CHAIRPERSON
ATTEST:

PAULINA MENDOZA

PLANNING COMMISSION SECRETARY
Docusign Envelope ID: 38276103-8ABC-8A41-815E-94D81C7EB403

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Community Outreach & Stakeholder Engagement Summary
2023 – 2026

Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 1726 of 2236 2 Executive Summary
The Oasis at Indio development team has undertaken a multi-year community outreach and stakeholder engagement effort beginning in 2023 and continuing throughout the entitlement process.

The outreach strategy has focused on transparency, accessibility, responsiveness, and ongoing dialogue with residents, neighborhood organizations, business leaders, public agencies, community stakeholders, and City leadership.

Outreach efforts have occurred during multiple phases of the project’s evolution and prior to formal public hearings in order to provide opportunities for early community awareness and dialogue.

Since retaining CV Strategies in February 2024 to lead community outreach and engagement efforts, the team has implemented a comprehensive communications and stakeholder engagement program that includes:
• Dedicated project website and
digital communications
• Community meetings and public
town halls
• HOA and neighborhood outreach
• Stakeholder briefings and agency
coordination
• Participation in local business and
civic events
• Ongoing media engagement and
public information efforts
• Email notifications and public
meeting notices
• Continuous availability of project
consultants and technical experts
The development team has hosted multiple community meetings and open houses attended by hundreds of residents and stakeholders. These meetings have included participation from the developer, planning consultants, environmental consultants, traffic engineers, legal counsel, and community engagement professionals to ensure community members had direct access to project information and subject matter experts.

The Oasis at Indio team remains committed to continued communication and engagement throughout the public review and development process.

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May 2023
Location: Shadow Hills High School
The project participated in the environmental
scoping process and early public engagement
activities associated with the project review
process.

February 2024
• CV Strategies retained to lead
Community Outreach and Stakeholder
Engagement
• Launch of dedicated project website:
www.theoasisatindio.com
• Development of ongoing
communications and stakeholder
engagement strategy
March 2024
• Individual introductory meetings
conducted with members of the Indio
City Council to introduce the project
team and provide a project overview
• Joined the Greater Coachella Valley
Chamber of Commerce (GCVCC)
• Planning Commission Study Session
conducted regarding the project
Planning Commission Study Session
Date: March 27, 2024
Project Team Present:
• Corey Harpole, BH Properties
• David Um, BH Properties
• Sean Matzler, Cox Castle
• Beatrice Eslamboly, CV Strategies
April 2024
Introductory Meeting with Sun City Shadow
Hills
Date: May 9, 2024
Location: College of the Desert, Indio Campus
The development team hosted an introductory
community meeting to present the project
overview and answer community questions.

Representatives from the development,
planning, legal, environmental, traffic, and
community outreach teams were available to
speak directly with attendees.

May 2024
Community Meeting #1
Date: May 9, 2024
Location: College of the Desert, Indio Campus
The development team hosted an introductory
community meeting to present the project
overview and answer community questions.

Representatives from the development,
planning, legal, environmental, traffic, and
community outreach teams were available to
speak directly with attendees.

Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 1728 of 2236 4 July 2024
Community Town Hall Meeting
Date: July 22, 2024
Location: Sun City Shadow Hills, Montecito
Ballroom
Attendance: 400+ attendees
A large-scale community town hall meeting
was hosted for residents and neighboring HOA
communities in North Indio.

The development team provided a formal
presentation regarding the project and
answered questions from attendees. Technical
experts and consultants were available to
address project-specific questions related to
planning, environmental review, traffic, and
community impacts.

October 2024
Community Town Hall Meeting
Date: October 24, 2024
Location: College of the Desert, Indio Campus
and via Zoom
Attendance: Approximately 300 attendees
A second large-scale public town hall meeting
was conducted to provide project updates and
continue community dialogue.

The meeting included both in-person and virtual
participation options to improve accessibility
and encourage broader public participation.

Meeting video and project materials were made
available through the project website.

April 2026
Sun City Shadow Hills Community
Development Committee Meeting
Date: April 21, 2026
CV Strategies met with the Sun City Shadow
Hills Community Development Committee to
provide project updates, answer questions, and
inform the committee regarding the anticipated
Planning Commission schedule and upcoming
outreach opportunities.

May 2026
Community Open House
Date: May 20, 2026
Time: 1:00 p.m. – 2:30 p.m.

Location: Fantasy Springs Resort Casino, Hunal
Meeting Room
The project team hosted a community open
house designed to provide residents with
an opportunity to meet directly with the
development team and consultants in a more
informal setting.

Project stations included representatives from
planning, environmental, traffic, legal, and
community outreach teams to answer questions
and provide information regarding the project.

Outreach Timeline

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Website: www.theoasisatindio.com
The project website was created as a centralized public information hub designed to provide continuous access to project information and planning materials.

The website includes:
• Project descriptions and updates
• Community benefits information
• Project timeline and milestones
• Development team biographies and
contact information
• Meeting notices and outreach updates
• Conceptual plans and renderings
• Links to planning and environmental
documents
• Access to the City of Indio development
dashboard
• Public resource materials and project
FAQs
The website also includes an interested parties sign-up feature allowing residents and stakeholders to receive ongoing project updates and meeting notifications.

The website has been continuously maintained and updated throughout the entitlement process to reflect the most current project information available.

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To date, the development team has hosted:
• Three community meetings/town halls
• One community open house
• Multiple HOA and stakeholder meetings
• Combined attendance at public meetings
has exceeded 700 attendees
Meetings have included participation from:
• BH Properties
• Planning consultants
• Traffic engineers
• Environmental consultants
• Legal counsel
• Community outreach professionals
These meetings were intended to provide community members with direct access to technical experts and opportunities to ask questions and share feedback.

HOA & Neighborhood Outreach
The project team has maintained ongoing communication with Sun City Shadow Hills leadership and neighboring community representatives throughout the entitlement process.

Outreach activities included:
• Introductory meetings
• Community Development Committee meetings
• Town hall presentations
• Project update discussions
• Community open house invitations
The development team has continued to provide updates and maintain communication with HOA leadership regarding project milestones and upcoming public hearings.

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The development team and outreach consultants have conducted meetings and coordination efforts with the following organizations and stakeholders:
• Desert Healthcare District (DHCD)
• Visit Greater Palm Springs (VGPS)
• Coachella Valley Economic Partnership
(CVEP)
• Greater Coachella Valley Chamber of
Commerce (GCVCC)
• Coachella Valley Association of
Governments (CVAG)
• College of the Desert
• Desert Sands Unified School District
• Buzzbox Cocktails
• Indio Business Alliance
Stakeholder discussions have included:
• Economic development opportunities
• Healthcare and community service needs
• Traffic and transportation considerations
• Environmental review process
• Tourism and hospitality opportunities
• Business community engagement
• Educational and workforce
considerations
Email Communications &
Public Notices
Individuals who subscribed through the
project website received ongoing project
updates and meeting notifications through
email communications.

Notifications included:
• Environmental review notices
• Community meeting announcements
• Planning Commission notifications
• Open house invitations
• Project milestone updates
Examples include:
• July 2024 – EIR Notice
• May 2026 – Planning Commission and
Community Open House Notice

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The Oasis at Indio team has actively participated in and supported local civic, business, and community events throughout the Coachella Valley.
2024
March 14, 2024
Taste of Indio & Business Awards at Fantasy
Springs
• Community Sponsor
• Project team attendance
June 2024
GCVCC Annual Board Installation & Awards
Ceremony
• Community Sponsor
• Project team attendance
September 2024
GCVCC All Valley Mayors & Tribal Luncheon
• Community Sponsor
• Project team attendance
October 2024
City of Indio State of the City
• Community Sponsor
• Project team attendance
2025
January 2025
Coachella Valley Journalism Foundation
• Community Sponsor
• Table donated to College of the Desert
journalism students
October 21, 2025
Indio State of the City
• Community Sponsor
• Project team attendance
October 30, 2025
Indio Night at Firebirds Game
• Sponsorship participation
• Project team attendance
2026
March 19, 2026
Coachella Valley Rescue Mission Gala
• Bronze Sponsor
May 1, 2026
GCVCC State of Education
• Community Sponsor

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The Oasis at Indio project has received ongoing regional media coverage throughout the entitlement process.

Project representatives and communications consultants have participated in interviews and provided information to local and regional media outlets to support accurate public information and transparency.

Media Coverage
Desert Sun
2024 Article:
https://www.desertsun.com/story/news/
local/indio/2024/06/28/developmentcould-bring-thousands-of-homes-tonorth-indio/74065160007/ 2026 Article:
https://www.desertsun.com/story/
news/local/indio/2026/05/10/northindio-oasis-new-homes-hotelwarehouse/89996030007/ NBC Palm Springs
June 28, 2024
Zoom interview with Beatrice Eslamboly,
CV Strategies
KESQ News Channel 3
May 7, 2026
Interview with Beatrice Eslamboly,
CV Strategies
https://kesq.com/news/2026/05/07/
residents-sound-alarm-on-proposedindustrial-space-in-north-indio/ Coachella Valley Independent
May 6, 2026
https://cvindependent.com/2026/05/theoasis-at-indio-an-inside-look/ Some projects arrive with renderings. Others arrive with opinions.

The Oasis at Indio has become the latter. Before most people have seen a site plan, they have already heard what it is supposed to be. A warehouse. A traffic problem.

Something too big for where it sits.

That kind of narrative tends to move faster than facts.

At the center of the noise is a familiar mix of questions. Is it a massive data center? Will traffic choke the Monroe interchange? What exactly is being built out there along the freeway? And maybe the bigger question: what does this project actually mean for Indio? So instead of guessing, we went straight to the source. We asked BH Properties, the developer behind Oasis at Indio, to walk us through the facts, the unknowns, and the vision.

Author: Let’s start with the
headline concern. People hear
“1.8 million square feet” and
immediately picture a giant warehouse.

Is that what this is?
BH Properties: We understand
why that perception exists. It’s a big
number, and when people hear a
number like that, they often jump to
a single image. But that is not what
this project is.

What’s proposed is a mixed-use plan
across 75.5 acres that allows for a range
of complementary uses. That includes
up to 3,240 multi-family residential
units, 20,000 square feet of commercial
space, or an equivalent level of
intensity, along with approximately
1,806,000 square feet designated for
light industrial use.

But “light industrial” can mean many
things beyond what people typically
picture as warehouse development.

We are exploring possibilities such as
medical facilities, large-format sports
and recreation venues, recording
studios or soundstages, and other
active uses that create jobs and bring
people to the site.

The exact mix is still being finalized,
but the vision is for a flexible campus
that supports a broader live-work-play
environment, not a project defined by
trucks and loading docks.

Author: Traffic is another major
concern, especially around the Monroe
Street interchange. Critics say the
infrastructure can’t handle it.

BH Properties: That’s a valid
concern, and one we take seriously.

The Monroe Street interchange
needs improvements, and we are
contributing to those upgrades
as part of the project. We are also
working with local agencies to make
sure infrastructure keeps pace with
development. The site itself is wellpositioned for that kind of planning.

It is bounded by Avenue 42 to the
north, Monroe Street to the east,
the Thousand Palms Storm Channel
to the west, and the I-10 Freeway
to the south. Because it sits directly
adjacent to the freeway, the location
allows traffic to move on and off the
highway system more efficiently, rather
than forcing the bulk of circulation
through surrounding city streets.

Author: So, you’re saying
the project won’t overwhelm
local roads?
BH Properties: The goal is to
reduce that impact as much as
possible. No project is without
traffic, but thoughtful planning
makes a difference. By aligning
access with the freeway and
investing in infrastructure
improvements, we are addressing
those concerns early.

Author: Let’s talk about what
the Oasis at Indio is. What
kind of experience are you
trying to create?
BH Properties: We see this
as one of the first true livework-play environments in the Coachella Valley. That means
bringing together hospitality,
commercial uses, and recreation
in a cohesive way, while also
supporting how people actually
live day-to-day. The plan includes
up to 3,240 residential units,
which helps the City of
Indio meet growing housing
demand while creating a more
balanced community.

Beyond housing, this is about
opportunity. The project is
expected to generate around
1,300 permanent jobs across
retail, commercial, and related
uses, along with as many as 2,100
construction jobs annually during
build-out. At the same time, we
are investing in infrastructure,
including a new 2.4-acre IID
substation that will improve
electrical reliability for nearby
residents and businesses.

From a lifestyle perspective, you could
have a hotel, walkable retail, wellnessfocused businesses, and spaces for entertainment or sports all in one
place. It also contributes to shaping the
Avenue 42 corridor into something
more connected, with new options to
shop, dine, and live. The goal is to create
a place where people can spend time,
build community, and access what they
need without having to leave the area.

Author: There’s been mention of
restaurants and retail. What will that
look like?
BH Properties: It will be intentional.

We are not planning to include drivethrough fast food. That is a conscious decision. We want a more walkable
environment that supports a healthier
and more community-oriented
experience. The focus is on quality,
variety, and creating places where
people gather.

Author: Final question.

For residents who are still skeptical,
what would you say?
BH Properties: Stay engaged.

This project is still evolving, and
community input matters. There is a
lot of information out there, and we
want people to have accurate details.

We believe this is an opportunity
to create something meaningful
for Indio and the Coachella Valley,
and we are committed to being part
of that conversation.

The Oasis at Indio

AN INSIDE LOOK
Learn More
For updates and more information
about the Oasis at Indio, visit
www.theoasisatindio.com
MAY 2026
Author: Megan George

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Throughout the outreach process, the development team has engaged in discussions related to:
• Traffic and circulation
• Environmental review
• Land use compatibility
• Infrastructure and utilities
• Economic development
• Hospitality and tourism opportunities
• Community character and quality of life
• Public safety and emergency access
Technical experts and consultants have been made available during public meetings and stakeholder discussions to answer questions directly and provide additional information regarding project studies and planning documents.

The project team has continued to refine communications and outreach efforts in response to community questions and feedback received throughout the process.

Commitment to Continued Engagement
The Oasis at Indio team remains committed to ongoing communication, transparency, and community engagement throughout the planning and development process. The team will continue to:
• Maintain and update the project website
• Provide public meeting notices and
project updates
• Participate in stakeholder and
community discussions
• Remain available to residents and
community organizations
• Coordinate with City staff and regional
partners
• Provide opportunities for continued
public engagement as the project moves
through the public review process

Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 1735 of 2236

BLUM, COLLINS & HO LLP

ATTORNEYS AT LAW

AON CENTER
707 WILSHIRE BOULEVARD
SUITE 4880
LOS ANGELES, CALIFORNIA 90017
(213) 572-0400
August 5, 2024
Kendra Reif Via Email to:

Principal Planner [email protected]
City of Indio
100 Civic Center Mall
Indio, California 92201
Subject: Comments on the Oasis at Indio EIR EIR (SCH NO. 2024050578) Dear Ms. Reif,
Thank you for the opportunity to comment on the Environmental Impact Report (EIR) for the proposed The Oasis at Indio 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 project proposes the construction and operation of a mixed-use project (residential, commercial, and industrial uses) on approximately 183 acres of vacant land, separated into four planning areas. The EIR evaluates potential environmental impacts with the development of two buildoutscenarios: (1) Maximum Buildout Scenario (MBS), which assumes buildout of the project resulting in 3,240 dwelling units, 20,000 square feet of retail commercial uses, and 1,806,290 square feet of industrial development; and (2) Scenario #2, which assumes lesser buildout than the MBS but within the maximum intensities permitted. Scenario #2 would result in 1,237 dwelling units, 71,600 square feet of retail commercial uses, a 128 key hotel/motel, and 1,806,290 square feet of industrial uses.

The following discretionary actions are required to implement the proposed project:

1. General Plan Amendment (GPA 23-0001) to amend the current General Plan land use designations from Mixed-Use Neighborhood (MUN) and Regional Commercial (RC) to Specific Plan (SP) and revise the Mobility Element Figure 4.3 “Circulation Plan” to remove Clinton

Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 1736 of 2236 Kendra Reif
August 5, 2024

Street south of Avenue 42.

2. Zone Change (ZC 23-0001) to revise the existing zoning designation of Mixed Use Neighborhood (MUN) and Regional Commercial (RC) to SP to permit the implementation of the proposed project.

3. The Oasis at Indio Specific Plan (SP 23-0001) to act the master plan governing the allowable land uses, development standards and design guidelines for the project.

4. Tentative Parcel Map (TPM 23-0001). The TPM subdivides the property into four distinct parcels. The TPM will indicate Planning Areas 1 through 4 permitted in the Specific Plan.

5. Development Agreement (DA 23-0001). The proposed Development Agreement would vest the applicant’s right to develop The Oasis at Indio Specific Plan area pursuant to the entitlements described above and ensure the timely completion of infrastructure to serve the project and surrounding area, and ensure that the project design features and mitigation measures identified in this EIR are enforceable by the City as project requirements.

3.0 Project Description
The EIR does not include a floor plan, detailed building elevations, detailed site plan, or a conceptual grading plan. The basic components of a Planning Application include a detailed site plan, floor plan, conceptual grading plan, written narrative, and detailed elevations. For example, the site plan provided in Exhibit 4.16-2: MBS Scenario Site Plan and Exhibit 4.16-3: Scenario 2 Conceptual Site Plan are extremely blurry and illegible, and a revised EIR must be published that provides a clear and complete site plan for each development scenario. Notably, it appears that both exhibits have been edited for public review to remove meaningful information such as the legend, general notes, key notes, parking requirements, floor area ratio, and site coverage. All of these basic items are necessary to conduct any type of analysis, and the EIR is inadequate as an informational document as it is not possible to ascertain any meaningful analysis based upon the information provided.

There are also no building elevations or grading plans provided and the EIR does not provide any information regarding the required quantity of cut/fill material during the grading phase of construction. Providing the complete grading plan to verify the earthwork quantities is vital as this directly informs the quantity of necessary truck hauling trips due to soil import/export during the grading phase of construction. A revised EIR must be prepared to include wholly accurate and unedited detailed floor plan, grading plan, site plan, building elevations, and project narrative for public review.

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Additionally, it must be noted that the EIR posted on the State of California Clearinghouse1 excluded all of the EIR Appendices, meaning that the document posted was incomplete for public and state agency review. The EIR must be recirculated on the State of California Clearinghouse with the Appendices in order to comply with CEQA Guidelines Sections 15205 and 15206.

4.3 Air Quality, 4.6 Energy Resources, and 4.8 Greenhouse Gas Emissions Please refer to attachments from SWAPE for a complete technical commentary and analysis.

The State of California lists three approved compliance modeling softwares2for non-residential buildings: CBECC-Com, EnergyPro, and IES VE. CalEEMod is not listed as an approved software. The CalEEMod 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, it cannot conclude the project will generate less than significant impacts and 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 as a source in its methodology and analysis, which is clearly not an approved software. This is also especially notable as the proposed project requires the construction of a new onsite electricity substation in order to accommodate its power supply.

4.9 Hazards and Hazardous Materials
The EIR has not provided any analysis with “Threshold E: For a project located within an airport land use plan or, where such a plan has not been adopted within two miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area?” The project site is located within Compatibility Zones C, D, and E of the Bermuda Dunes Airport Influence Area. The Land Use and Planning Section of the EIR states that, “The Riverside County Airport Land Use Commission held a public hearing and issued a Finding of Consistency for the project on February 8, 2023, in which they determined the project to be consistent with the Bermuda Dunes Airport Land Use Compatibility Plan. ALUC Conditions of approval have been fully incorporated into the Specific Plan (Appendix A of this Draft EIR).” However, Appendix A does not include ALUC Conditions of Approval. It only includes a letter 1 https://ceqanet.opr.ca.gov/2024050578/2
2 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

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from the RC ALUC dated February 13, 2024 stating that a hearing was held. This does not comply with CEQA’s requirements for adequate informational documents and meaningful disclosure (CEQA § 15121 and 21003(b)). Incorporation by reference (CEQA § 15150 (f)) is not appropriate as the RC ALUC Conditions of Approval contribute directly to analysis of the problem at hand.

A revised EIR must be prepared to include the RC ALUC Conditions of Approval for review, analysis, and comment by the public and decision makers. The EIR is also inadequate as an informational document as it has excluded analysis with Threshold 4.9-E and must be revised to provide a complete analysis with this threshold.

4.11 Land Use and Planning
The EIR does not meaningfully discuss or analyze the project’s compliance with the General Plan’s Land Use Buildout Scenario. Table 9-2: Comparison of Land Uses and Development Between the Adopted General Plan and GPU within the General Plan EIR3analyzes a buildout of 9,152,549 square feet of commercial (all non-residential) building area. The MBS Scenario is 1,826,290 sf of non-residential building area, which accounts for 19.95% of all non-residential building area for the General Plan buildout through 2040. Scenario 2 is 2,063,746 sf of nonresidential building area, which accounts for 22.5% of all non-residential building area for the General Plan buildout through 2040. The completion of General Plan buildout scenario increases exponentially when other non-residential development activity is added to the calculation. The EIR has not provided evidence that the growth generated by the proposed project was anticipated by the General Plan, RTP/SCS, or AQMP. The EIR must be revised to provide an accurate buildout scenario of the City’s General Plan.

Table 4.11-6 City of Indio General Plan Consistency Analysis does not provide a consistency analysis with all land use plans, policies, or regulations adopted for the purpose of avoiding or mitigating an environmental effect. The project has significant potential to conflict with many of these items, including but not limited to the following from the General Plan:

1. Policy LU 1.1: Creating mixed-use corridors along Highway 111, Monroe Street, Avenue 42, and Avenue 44 that contain a mix of retail, service, office, and residential uses. Corridors should have defined nodes that provide a mix of local- and regional-serving uses; Creating mixed-use corridors along Highway 111, Monroe Street, Avenue 42, and Avenue 44 that contain a mix of retail, service, office, and residential uses. Corridors should have defined nodes that provide a mix of local- and regional-serving uses. 3 https://www.indio.org/home/showpublisheddocument/3681/638174340014770000

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2. Goal LU-7: New Neighborhoods. Neighborhoods that provide a variety of housing types, densities, designs and mix of uses and services that support healthy and active lifestyles.

3. Policy LU-7.1 Complete neighborhoods. Through the development entitlement process, ensure that all new Neighborhoods (areas with a Neighborhood” General Plan Designation) are complete and well structured such that the physical layout and land use mix promote walking to services, biking and transit use, are family friendly, and address the needs of multiple ages and physical abilities. New neighborhoods should have the following characteristics: Contain short, walkable block lengths. Contain a high level of connectivity for pedestrians, bicycles and vehicles where practicable. Organize around a central focal point such as a park, school, civic building or neighborhood retail such that most homes are no more than one quarter-mile from this focal point. Have goods and services within a short walking distance. Contain a diversity of housing types, where possible. Have homes with entries and windows facing the street. Have a grid or modified grid street network (except where topography necessitates another street network layout). Provide a diversity of architectural styles

4. Policy LU-7.2 Balanced neighborhoods. Within the allowed densities and housing types, promote and allow for a range of housing and price levels within each neighborhood in order to accommodate diverse ages and incomes. For development projects larger than five acres, require that a diversity of housing types be provided and that these housing types be mixed rather than segregated by unit type.

5. Policy LU-7.3 Housing affordability. Ensure affordable housing is distributed throughout the City to avoid concentrations of poverty and to be accessible to jobs. LU-7.4 Block size.

Require new neighborhoods to be designed with blocks length ranging from 400 or less to 800 feet consistent with the General Plan place type. Exceptions can be made if mid-block pedestrian and bicycle connections are provided.

6. Policy LU-7.5 Provision of sidewalks. Except within designated Rural Estate areas, require sidewalks of at least five feet in width on at least one side of private and both sides of public streets in neighborhoods and prohibit obstructions,such as utility boxes, telephone poles,street signs, etc. that would impede sidewalk use.

7. Policy LU-7.6 Tree-lined streets. Require trees on both sides of at least 60 percent of new and existing streets within the project and on the project s side of bordering streets, between the vehicle travel way and walkway at intervals averaging no more than 50-100 feet (excluding driveways and utility vaults). This standard shall apply whenever new streets are constructed

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or when existing streets and sidewalks are significantly rehabilitated with existing neighborhoods. Ensuring the appropriate revenue stream to provide long-term maintenance.

8. Policy LU-7.7 Shaded sidewalks. Require shade over at least 50 percent of the length of sidewalks on streets within a project. Trees must provide shade within five-years of landscape installation and should be as water efficient as possible.

9. Policy LU-7.8 Gated communities. Discourage the construction of new gated communities.

When gated communities are allowed, require frequent pedestrian and bicycle connections between the gated community and surrounding areas at distances no more than 600 feet apart.

10. Policy LU-7.9 Soundwalls. Allow the use of soundwalls to buffer new neighborhoods from existing sources of noise pollution, such as railroads and limited-access roadways. Prohibit the use of soundwalls to buffer residential areas from arterial, boulevard, connector, Downtown, and local streets. Instead design approaches such as building setbacks, landscaping, and other techniques shall be used. In the case where soundwalls might be acceptable, require regular pedestrian access points at intervals less than 600 feet to improve access from the neighborhoods.

11. Policy LU-7.10 Subdivision gateways. Strive for neighborhoods to blend seamlessly with one another and discourage distinguishing one residential project from another.

12. Policy LU-7.11 Connections to key destinations. Require direct pedestrian and bicycle connections between residential areas and nearby commercial and public and institutional areas as well as other residential areas.

13. Policy LU-7.12 Access to parks and open spaces. Require the design of new neighborhoods and, where feasible, retrofit existing neighborhoods, so that the majority of dwelling units are within a half-mile walking distance of a usable open space such as a tot-lot, neighborhood park, community park, or plaza/ green.

14. Policy LU-11.3 Development projects. Require development projects provide public artwork or contribute to an Art in Public Places fund.

15. Policy LU-11.4 Public art. Continue to require art in public places to be located in an area that either highlights the design of the building or center or is incorporated within an on-site pedestrian plaza.

16. Policy ED-2.6 Attract livable wages. Continue to purse and attract companies and industries who offer livable wages and medical benefits for employees in Indio.

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17. Goal HE-2: Healthy Neighborhood Design. Neighborhoods designed to encourage a healthy lifestyle for people of all ages, income levels, and cultural backgrounds.

18. Policy HE-2.1 Neighborhood design. Design neighborhoods to promote pedestrian and bicycle activity as alternatives to driving. This policy is implemented through the Land Use and Community Design Element.

19. Policy HE-2.3 Universal park access. Increase access to existing and proposed parks and open spaces. Apply universal design principles to ensure that people of any culture, age, size, weight, race, gender, and ability can experience an environment that promotes their health, safety, and welfare. This policy is implemented through the Parks, Recreation, and Open Space Element.

20. Policy HE-2.4 Sidewalk network. Design neighborhoods to facilitate social connectivity and walkability. This policy is implemented through the Mobility and the Land Use and Community Design Elements.

21. Goal HE-3: Environmental Quality. A City designed to improve the quality of the built and natural environments to reduce disparate health and environmental impacts

22. Policy HE-3.4 Sensitive-receptor uses. Discourage development of sensitive land uses – defined as schools, hospitals, residences, and elder and childcare facilities – near air pollution sources that pose health risks – including freeways and polluting industrial sites. HE-3.5 Truck routes. Designate truck routes to avoid sensitive land uses, where feasible.

23. Goal CE-1: Greenhouse Gas Emissions. Indio maintains a leadership role in the Coachella Valley by reducing greenhouse gas emission to support a resilient community.

24. Policy CE-1.1 Reduction targets. Establish greenhouse gas emission reduction targets in line with those of the State that call for reducing greenhouse gas emissions as follows: 1990 levels by 2020 40 percent below 1990 levels by 2030 60 percent below 1990 levels by 2040

25. Policy CE-1.2 Reduction measures. Implement greenhouse gas reduction measures consistent with the Climate Action Plan to achieve greenhouse gas reduction targets.

26. Policy CE-1.6 Green jobs. Promote greenhouse gas reduction measures that support local job training and placement in green industries focused on environmental sustainability, renewable energy, renewable-related technologies, and bioremediation.

27. Policy CE-1.7 Sustainable communities strategy. Collaborate with regional and State partners to implement the Sustainable Communities Strategy to reduce greenhouse gas emissions,

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balance jobs and housing, and develop transportation systems that support all modes of circulation.

Further, the consistency analysis provided within the table is misleading and erroneous as it excludes analysis of the project’s required construction of a new electricity substation to accommodate the project’s quantity of energy consumption, the required GPA/ZC, and the project’s significant and unavoidable cumulatively considerable impacts to Air Quality and GHG emissions. For example, the EIR concludes the project is consistent with “Policy IE-4.2: Require the appropriate environmental review and clearance of electricity and natural gas infrastructure projects including solar generation, cogeneration facilities, wind energy systems, and similar developments to ensure proper siting and operation,” because “The project will comply with the most recent California Build Code and City ordinances regarding the construction of any electricity or natural gas infrastructure projects.” There is no discussion or analysis of the required electricity substation and specific statements regarding how it does or does not comply with these requirements. The EIR must be revised to include an adequate and accurate environmental analysis with all General Plan goals and policies.

Table 4.11-8 SCAG 2020-2045 RTP/SCS Goals Consistency Analysis provides a misleading and erroneous consistency analysis with SCAG’s 2020-2045 Connect SoCal RTP/SCS. Due to errors in modeling, modeling without supporting evidence, and the EIR’s conclusion that the proposed project will result in significant and unavoidable cumulatively considerable impacts to Air Quality and GHG emissions, the proposed project is directly inconsistent with Goal 5 to reduce greenhouse gas emissions and improve air quality, Goal 6 to support healthy and equitable communities, and Goal 7 to adapt to a changing climate. Further, since the proposed project requires a GPA/ZC to proceed, it was not accounted for by the RTP/SCS and is therefore further inconsistent with the document. The EIR must be revised to include revised, accurate modeling and consistency analysis with all goals of SCAG’s 2020-2045 Connect SoCal RTP/SCS that states the project is not consistent with the goals of Connect SoCal.

The project site is located within Compatibility Zones C, D, and E of the Bermuda Dunes Airport Influence Area. The EIR states that, “The Riverside County Airport Land Use Commission held a public hearing and issued a Finding of Consistency for the project on February 8, 2023, in which they determined the project to be consistent with the Bermuda Dunes Airport Land Use Compatibility Plan. ALUC Conditions of approval have been fully incorporated into the Specific Plan (Appendix A of this Draft EIR).” The EIR is erroneous as the date of the RC ALUC hearing was stated to be February 8, 2024 in the Hazards and Hazardous Materials section. Additionally, Appendix A does not include ALUC Conditions of Approval. It only includes a letter from the RC ALUC dated February 13, 2024 stating that a hearing was held. This does not comply with

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CEQA’s requirements for adequate informational documents and meaningful disclosure (CEQA § 15121 and 21003(b)). Incorporation by reference (CEQA § 15150 (f)) is not appropriate as the RC ALUC Conditions of Approval contribute directly to analysis of the problem at hand. A revised EIR must be prepared to include the RC ALUC Conditions of Approval for review, analysis, and comment by the public and decision makers.

4.13 Population and Housing
The EIR utilizes uncertain language and does not provide any meaningful analysis or supporting evidence to substantiate the conclusion that there will be no significant impact to population and housing. The EIR states that “it is anticipated that project employees will come from the City of Indio and surrounding cities and would be within commuting distance.” The EIR states that the unemployment rate in Indio is “nearly 5%,” but an unemployment rate below 5% is considered full employment and does not substantiate the EIR’s claims that impacts will be less than significant. Additionally, the EIR relies upon the unemployed workforce in the Coachella Valley region to fill the project’s operational jobs, but does not provide any meaningful evidence that the specific workforce listed is qualified for or interested in industrial work to substantiate this claim.

The “commuting distance” of the project site is undefined, and relying on the unemployed workforce population of the surrounding Inland Empire region will increase project related VMT and emissions during all phases of construction and operations and a revised EIR must be prepared to account for longer worker trip distances.

SCAG’s Connect SoCal Demographics and Growth Forecast4 notes that the City will add 11,700 jobs between 2016 - 2045. Utilizing the EIR’s calculation of 1,244 employees, the project represents 10.6% of the City s employment growth from 2016 - 2045. The City’s General Plan EIR accounted for 9,520 jobs in the City from 2018-2040. The project represents 13% of the City s employment growth through the General Plan horizon year. A single project accounting for this amount of the projected employment growth represents a significant amount of growth. Since the project requires a GPA/ZC to implement the proposed project on the site, it was not included for analysis by the City or SCAG and represents a 10.6% increase in growth that was not accounted for by either agency. A revised EIR must be prepared to include this analysis, and also provide a cumulative analysis discussion of projects approved since General Plan adoption, 2016 (SCAG), and projects “in the pipeline” to determine if the project will exceed SCAG’s employment growth forecast for the City.
4 SCAG Connect SoCal Demographics and Growth Forecast adopted September 3, 2020 https://scag.ca.gov/sites/main/files/file-attachments/0903fconnectsocal_demographics-and-growthforecast.pdf?1606001579

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4.16 Transportation
The EIR concludes that project employee VMT (Office/Industrial/Commercial) under Scenario 2 will be 19.49 VMT, which exceeds the threshold of 18.30 VMT per employee by 6.11%. The EIR implements Mitigation Measure TRA-1 and project design features (PDF) T-7 and T-8 to allegedly achieve a 10% reduction in employee vehicle trips and result in less than significant impacts.

Mitigation Measure TRA-1/PDF T-7 and T-8 state the following:
“MM TRA-1: Any future use subject to IMC Chapter 160 shall implement, as part of its TDM program, (1) commute trip reduction marketing and (2) a ridesharing program, among the other measures that may be required to achieve a 10% reduction in overall employee trips.

T-7 Implement Commute Trip Reduction Marketing. This measure will include the implementation of a marketing strategy that promotes the site employer s Commute Trip Reduction (CTR) Marketing program. The program includes information sharing and marketing to promote travel choices beyond driving that are available to employees such as taking transit, carpooling, walking and biking. These measures help to reduce VMT and GHG emissions. 100% of the total industrial employment will be eligible for the program. Other uses will be determined by future development.

T-8 Provide Ride Sharing Program This measure will include the implementation of a ride sharing program as well as the establishment of a permanent transportation management association. This association will have a funding requirement for employment. Ridesharing promotes carpooled vehicle trips in place of single-occupancy vehicle trips. These measures help to reduce VMT and GHG emissions. 100% of the total industrial employment will be eligible for the program. Other uses will be determined by future development.”
However, the EIR has not provided meaningful evidence to support the conclusion that Project Design Features T-7 and T-8 and/or Mitigation Measure TRA-1 will reduce project generated VMT per employee to below the significance threshold of 18.30 VMT per employee continuously for the life of the project. Since future building tenants are unknown, implementation of trip reduction measures cannot be guaranteed to reduce Project generated VMT to a level of less than significant. It is not possible for the City to ensure that Project Design Features T-7 and T-8 and/or Mitigation Measure TRA-1 will result in reduced VMT by project employees and be implemented continuously, at all times, throughout the life of the project and maintain a VMT reduction to less than significant levels at all times. The efficacy of the proposed mitigation measures and reduction of VMT impacts below the applicable thresholds cannot be assured and the project’s VMT impact is therefore considered significant and unavoidable. A revised EIR must be prepared to include a finding of significance because there is no possible assurance of the percentage of project

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employees that would utilize non-automobile travel associated with implementation of Project Design Features T-7 and T-8 and/or Mitigation Measure TRA-1 and mitigation of the project’s VMT impact to less than significant is not feasible.

Further, the EIR has underreported the quantity VMT generated by the proposed project operations and the conclusion that the MBS Scenario will generate VMT below the threshold is not supported by meaningful evidence based on project operations. The operational nature of industrial/warehouse uses involves high rates of truck/trailer/delivery van VMT due to traveling from large import hubs to regional distribution centers to smaller industrial parks and then to their final delivery destinations. Once employees arrive at work at the proposed project, they will conduct their jobs by driving delivery vans across the region as part of the daily operations as a fulfillment center, which will drastically increase project-generated VMT. The project’s truck/trailer and delivery van activity is unable to utilize public transit or active transportation and it is misleading to the public and decision makers to exclude this activity from VMT analysis. The project’s total operational VMT generated is not consistent with the significance threshold and legislative intent of SB 743 to reduce greenhouse gas emissions by reducing VMT. A revised EIR must be prepared to reflect a quantified VMT analysis that includes all truck/trailer and delivery van activity.

Additionally, Appendix L2: VMT Memo5excludes the modeling input parameters and output screens generated by the RIVCOM model to support the EIR’s claims that the project will have less than significant impacts. This does not comply with CEQA’s requirements for adequate informational documents and meaningful disclosure (CEQA § 15121 and 21003(b)). The VMT input/output modeling information contributes directly to analysis of the problem at hand. A revised EIR must be prepared to include these items for review by the public and decision makers in order to provide an adequate informational document.

The EIR has not adequately analyzed the project’s potential to substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses; or the project’s potential to result in inadequate emergency access. The EIR has excluded any specific truck/trailer turning exhibits from public review. There are no exhibits adequately depicting the available maneuvering and queueing space for trucks/trailers at the intersection of the project driveways and the adjacent streets. There are also no exhibits adequately depicting the onsite turning radius available for trucks maneuvering throughout the site.

It must first be noted that Exhibit 4.16-2: MBS Scenario Site Plan is extremely blurry and illegible, and a revised EIR must be published that provides a clear and complete site plan for each 5 https://www.indio.org/home/showpublisheddocument/4907/638549293103270000

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development scenario. The proposed New Street “A” that bisects the project site provides access for both the residential and industrial uses. Table 5-2: Project Option A Trip Generation Forecast indicates that the MBS Scenario will generate 1,720 daily truck trips to the industrial portion of the project. Several areas of potential conflicts between trucks/trailers and passenger cars exist at the streets adjacent to the project site and throughout the site itself. For example, truck/trailer parking stalls are located immediately adjacent to the truck/trailer loading dock courts on each side of both buildings. These parking stalls may be in use at any time and further restrict truck/trailer movement on the site and present a safety hazard with potential for conflicts between passenger cars and trucks/trailers. The overall site design presents several potential conflicts in maneuvering area for both passenger cars and trucks/trailers that have not been analyzed. A revised EIR must be prepared to include a finding of significance as the EIR has not provided any meaningful evidence to support a less than significant finding.

Further, Table 16-2: Project Option B Trip Generation Forecast indicates that Scenario 2 will also generate 1,720 daily truck trips to the industrial portion of the project. Figure 16-1: Option B Site Plan within Appendix L
6 depicts a similar overall building layout as the MBS Scenario, therefore the same conflicts noted above exist in Scenario 2. Further, since this figure is legible, it can be seen that the truck/trailer parking stall configuration presents several areas of conflict as shown below. For example, the parking stalls in corners and on angles are not demonstrated to have adequate maneuvering and backup space to enter/exit the parking space. Additionally, the 190 foot dimension from head of parking stall to head of parking stall will not provide adequate backup space. A standard WB-67 truck/trailer is 66 feet long, meaning that the available backup space between these parking stalls is only 58 feet. The overall site design presents several potential conflicts in maneuvering area for both passenger cars and trucks/trailers that have not been 6 https://www.indio.org/home/showpublisheddocument/4903/638549293050130000

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informational documents and meaningful disclosure (CEQA § 15121 and 21003(b)). The EIR has not provided any details regarding the City of Indio standards for road development, stacking distances, or lines of sight, or meaningful analysis of the project’s compliance or noncompliance with these requirements. Deferring this environmental analysis required by CEQA to the construction permitting phase is improper mitigation and does not comply with CEQA’s requirement for meaningful disclosure and adequate informational documents. A revised EIR must be prepared to include a finding of significance as the EIR has not provided any meaningful evidence to support a less than significant finding.

The EIR states regarding emergency access that, “City staff, including Police and Fire Department staff, would review site plans and provide conditions of approval that are specific to the provision of emergency access on a project‐by‐project basis. The development of the roads is not anticipated to impact the evacuation plan and routes within the region.” This does not comply with CEQA’s requirements for adequate informational documents and meaningful disclosure (CEQA § 15121 and 21003(b)). The EIR has not provided any details regarding the requirements for emergency access or meaningful analysis of the project’s compliance or noncompliance with these requirements. Deferring this environmental analysis required by CEQA to the construction permitting phase is improper mitigation and does not comply with CEQA’s requirement for meaningful disclosure and adequate informational documents. A revised EIR must be prepared to include a finding of significance as the EIR has not provided any meaningful evidence to support a less than significant finding.

5.3 Significant Irreversible Environmental Changes and 5.4 Growth-Inducing Impacts The EIR does not provide any meaningful analysis of the proposed project components, construction, or operations. For example, the EIR states that, “Electricity consumption during construction of the site is anticipated to be minimal. However, the project proposes to develop a substation to provide power to the project.” This is not a quantified response and does not meaningfully discuss the requirement of a new onsite electricity substation to accommodate the electricity consumption needs resulting from the project. Further, the EIR relies upon erroneous Energy modeling to determine that the project will meet sustainability requirements. As noted above, the EIR did not model the project’s energy consumption in compliance with Title 24 modeling software. The EIR must be revised to include a finding of significance as it has not adequately or accurately analyzed the project’s commitment of resources.

The EIR does not adequately discuss or and analyze the commitment of resources is not consistent with regional and local growth forecasts. As noted throughout this comment letter, the project represents a significant amount of growth in the City and accounts for a significant amount of the City’s employment growth over 29 years (SCAG) and through the City’s General Plan horizon

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year of 2040. The EIR has not provided an adequate or accurate cumulative analysis discussion here to demonstrate the impact of the proposed project in a cumulative setting. The EIR must be revised to include this information for analysis and also include a cumulative development analysis of projects approved since General Plan adoption, 2016 (SCAG), and projects in the pipeline” to determine if the proposed project exceeds the General Plan buildout scenario and/or SCAG’s growth forecasts.

The EIR does not meaningfully discuss or analyze the project’s compliance with the General Plan’s Land Use Buildout Scenario. Table 9-2: Comparison of Land Uses and Development Between the Adopted General Plan and GPU within the General Plan EIR7analyzes a buildout of 9,152,549 square feet of commercial (all non-residential) building area. The MBS Scenario is 1,826,290 sf of non-residential building area, which accounts for 19.95% of all non-residential building area for the General Plan buildout through 2040. Scenario 2 is 2,063,746 sf of nonresidential building area, which accounts for 22.5% of all non-residential building area for the General Plan buildout through 2040. The completion of General Plan buildout scenario increases exponentially when other non-residential development activity is added to the calculation. The EIR has not provided evidence that the growth generated by the proposed project was anticipated by the General Plan, RTP/SCS, or AQMP. The EIR must be revised to provide an accurate buildout scenario of the City’s General Plan.

7.0 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” alternative and only three others - General Plan Buildout, Zoning Buildout, and No Commercial (MBS). The EIR does not evaluate a reasonable range of alternatives as only three alternatives beyond the required No Project alternative are analyzed. The EIR does not include an alternative that meets the project objectives and also eliminates all 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 reduces all of the proposed project’s significant and unavoidable impacts to less than significant levels while meeting all project objectives, and/or a mixed-use project that provides affordable housing and local-serving commercial uses that may reduce VMT, GHG emissions, and improve Air Quality.
7 https://www.indio.org/home/showpublisheddocument/3681/638174340014770000

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Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 1751 of 2236 2656 29th Street, Suite 201
Santa Monica, CA 90405
Matt Hagemann, P.G, C.Hg.

Paul E. Rosenfeld, PhD
August 2, 2024
Gary Ho
Blum, Collins & Ho LLP
707 Wilshire Blvd, Ste. 4880
Los Angeles, CA 90017
Subject: Comments on The Oasis at Indio Project (SCH No. 2024050578) Dear Mr. Ho,
We have reviewed the June 2024 Draft Environmental Impact Report (“DEIR”) for The Oasis at Indio Project (“Project”) located in the City of Indio (“City”). The Project proposes to construct either one of two scenarios. The first scenario proposes to construct 1,806,290-square-feet (“SF”) of residential space, including 3,240 dwelling units and 20,000-SF of commercial space. The second scenario proposes to construct 1,806,290-SF of residential space, consisting of 1,237 dwelling units, 128 hotel units, and 71,600-SF of commercial use on the 183-acre site.

Our review concludes that the DEIR fails to adequately evaluate the Project’s greenhouse gas impacts.

As a result, emissions associated with construction and operation of the proposed Project may be underestimated and inadequately addressed. A revised Environmental Impact Report (“EIR”) should be prepared to adequately assess and mitigate the potential greenhouse gas impacts that the project may have on the environment.

Greenhouse Gas
Failure to Adequately Evaluate Greenhouse Gas Impacts
The DEIR estimates that the proposed Maximum Buildout Scenario and Scenario 2 would result in net annual greenhouse gas (“GHG”) emissions of 4.2-and 9.0- metric tons of carbon dioxide equivalents per service population per year (“MT CO2e/SP/year”), respectively, which exceed the City’s Climate Action Plan (“CAP”) 2040 threshold of 2.6 MT CO2e/SP/year (“MT CO2e/year”) (see excerpts below) (p. 4.8 - 27, Table 4.8-6; p. 4.8-28, Table 4.8-7).

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Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 1753 of 2236 3 the project’s building energy and mobile sources by 2033 and beyond, the actual reductions that would occur with the implementation of these measures and the ability of future actions to achieve State goals cannot be known at this time and, therefore, is uncertain. Thus, although substantial GHG emissions reductions may occur, the timing and certainty of such reductions cannot be guaranteed. Therefore, the proposed project’s GHG emissions could have the potential to result in a cumulatively considerable contribution to the adverse effects of global climate change, even with the incorporation of feasible mitigation measures. Therefore, the project’s GHG emissions would be potentially significant” (p. 4.8-29).

While we agree that the Project would result in a significant GHG impact, the DEIR’s assertion that this impact is significant-and-unavoidable is unreliable. As previously discussed, according to CEQA Guidelines § 15096(g)(2):
“When an updated EIR has been prepared for a project, the Responsible Agency shall not approve the project as proposed if the agency finds any feasible alternative or feasible mitigation measures within its powers that would substantially lessen or avoid any significant effect the project would have on the environment.”
An impact can only be labeled as significant-and-unavoidable after all available, feasible mitigation measures are considered. While the DEIR incorporates GHG Mitigation Measure (“MM”)-1 through GHG MM-3, there are additional measures that the DEIR fails to consider (p. 4.8-28). To reduce the Project’s GHG impacts to the maximum extent possible, additional feasible mitigation measures should be incorporated, such as those suggested in the section of this letter titled “Feasible Mitigation Measures Available to Reduce Emissions.” The Project should not be approved until a revised EIR is prepared, incorporating all feasible mitigation to reduce emissions to less-than-significant levels.

Mitigation
Feasible Mitigation Measures Available to Reduce Emissions The DEIR is consequently required under CEQA to implement all feasible mitigation to reduce the Project’s potential impacts. As demonstrated in the sections above, the Project would result in potentially significant air quality, health risk, and GHG impacts that should be mitigated further. In order to reduce the GHG emissions associated with the Project, we recommend several mitigation measures.

The Southern California Association of Governments (“SCAG”)’s 2020 RTP/SCS Program Environmental Impact Report (“PEIR”) recommends the following Greenhouse Gas Project Level Mitigation Measures (“PMM-GHG-1”), which are applicable to the Project and are as follows:
• Measures that encourage transit use, carpooling, bike-share and car-share programs, active transportation, and parking strategies, including, but not limited to the following:
o Promote transit-active transportation coordinated strategies, o Improve or increase access to transit,
o Increase access to common goods and services, such as groceries, schools, and day care, o Limit or eliminate park supply,

Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 1754 of 2236 4 o Provide parking cash-out programs, and
o Implement or provide access to commute reduction program; • 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; • Implement preferential parking permit program; and
• Encourage telecommuting and alternative work schedules, such as:
o Staggered starting times,
o Flexible schedules, and
o Compressed work weeks;
• Implement commute trip reduction marketing, such as:
o New employee orientation of trip reduction and alternative mode options, o Event promotions, and
o Publications;
• Price workplace parking, such as:
o Explicitly charging for parking for its employees,
o Implementing above market rate pricing,
o Validating parking only for invited guests,
o Not providing employee parking and transportation allowances, and o Educating employees about available alternatives;
• Adopting employer trip reduction measures to reduce employee trips such as vanpool and carpool programs, providing end-of-trip facilities, and telecommuting programs including but not limited to measures that:
o Provide car-sharing, bike sharing, and ride-sharing programs, o Provide transit passes,
o Shift single occupancy vehicle trips to carpooling or vanpooling, for example providing ride-matching services,
o Provide incentives or subsidies that increase that use of modes other than singleoccupancy vehicle, and o Provide on-site amenities at places of work, such as priority parking for carpools and vanpools, secure bike parking, and showers and locker rooms.

CEQA Guidelines 15126.4 (c)(3) include “[o]ffsite measures, including offsets that are not otherwise required, to mitigate a project’s emissions” as an option for GHG mitigation. 1 An example of this was in
the case of the Oakland Sports and Mixed-Use Project, where off-site reduction measures in the 1 “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.

Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 1755 of 2236 5 neighboring communities were recommended.2 We recommend consideration of local carbon offset programs to reduce the Project’s GHG impacts as a measure of last result.

As demonstrated above, we have provided several mitigation measures that would reduce Projectrelated GHG emissions. These measures offer a cost-effective, feasible way to incorporate loweremitting design features into the proposed Project, which subsequently reduce emissions released during Project construction and operation.

A revised EIR should be prepared that includes all feasible mitigation measures, as well as an updated GHG analysis to ensure that the necessary mitigation measures are implemented to reduce emissions to the maximum extent feasible. The revised EIR should also demonstrate a commitment to the implementation of these measures prior to Project approval, to ensure that the Project’s potentially significant emissions are reduced to the maximum extent possible.

Disclaimer
SWAPE has received limited discovery regarding this project. Additional information may become available in the future; thus, we retain the right to revise or amend this report when additional information becomes available. Our professional services have been performed using that degree of care and skill ordinarily exercised, under similar circumstances, by reputable environmental consultants practicing in this or similar localities at the time of service. No other warranty, expressed or implied, is made as to the scope of work, work methodologies and protocols, site conditions, analytical testing results, and findings presented. This report reflects efforts which were limited to information that was reasonably accessible at the time of the work, and may contain informational gaps, inconsistencies, or otherwise be incomplete due to the unavailability or uncertainty of information obtained or provided by third parties.

Sincerely,
Matt Hagemann, P.G., C.Hg.

Paul E. Rosenfeld, Ph.D.
2 “Cal. Pub. Resources Code § 21168.6.7.” 2023, 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.

Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 1756 of 2236 Attachment A: Matt Hagemann CV
Attachment B: Paul Rosenfeld CV

Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 1757 of 2236 2656 29th Street, Suite 201
Santa Monica, CA 90405
Matt Hagemann, P.G, C.Hg.

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

Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 1758 of 2236 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.

Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 1759 of 2236 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

Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 1760 of 2236 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

Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 1761 of 2236 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).

Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 1762 of 2236 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.

Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 1763 of 2236 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.

Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 1764 of 2236 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.

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Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 1766 of 2236 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.

Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 1767 of 2236 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.

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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.

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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.

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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.

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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.

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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

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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

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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

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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

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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

Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 1777 of 2236 Green Jobs & Clean Communities
26 May 2026
Planning Commission
City of Indio
100 Civic Center Mall
Indio, CA 92201
Delivered via email to: [email protected]
[email protected]
Re: Supplemental Comments on The Oasis at Indio Project Final Environmental Impact Report (SCH No. 2024050578)
Commissioners,
Golden State Environmental Justice Alliance (GSEJA) has previously submitted comments on the Draft Environmental Impact Report (DEIR) for the proposed Oasis at Indio Project by way of a Comment Letter dated 5 August 2024, which documented significant and systematic deficiencies in the EIR's environmental analysis. Those deficiencies included an inadequate and incomplete project description, deficient air quality and greenhouse gas emissions modeling that failed to comply with Title 24 energy modeling requirements, an incomplete hazards and hazardous materials analysis with respect to the project site's location within the Bermuda Dunes Airport Influence Area, an erroneous and misleading land use and planning consistency analysis, unsupported and speculative population and housing impact conclusions, and an inadequate transportation and VMT analysis that excluded substantial truck, trailer, and delivery van activity from its modeling.

GSEJA also provided technical review comments prepared by Soil Water Air Protection Enterprise (SWAPE), concluding that the project's greenhouse gas impacts were underestimated, that not all feasible mitigation measures were incorporated prior to the significant-andunavoidable determination, and that a revised EIR was necessary before the project could be approved.

The City of Indio published its Final EIR in April 2026 and has scheduled a Planning Commission public hearing for 27 May 2026, to consider certification of the Final EIR and approval of the associated project entitlements. GSEJA has reviewed the City's responses to Comment Letter No. 13 and submits this Supplemental Comment Letter to reiterate its opposition to the project and to note that the City's responses do not adequately resolve the deficiencies identified in GSEJA's prior submissions. The City's responses largely fail to

Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 1778 of 2236 2 constitute the good-faith, reasoned analysis required by CEQA Guidelines Section 15088, and in several instances substitute procedural assertions and generalized denials for the substantive environmental analysis that CEQA demands. Unrefuted technical evidence submitted by SWAPE stands as fact in the administrative record.

The proposed project would construct a mixed-use development on approximately 183 acres of currently vacant land in the City of Indio, including up to 3,240 residential dwelling units, 1,806,290 ft2 of industrial uses, and retail commercial space. The project's industrial component alone is expected to generate 1,720 daily truck trips. The project site is in the Coachella Valley, a region that already bears a disproportionate share of the state's air quality and environmental health burden. The cumulative significance of a development of this scale in this setting demands a level of rigorous environmental review that the DEIR and the City's Final EIR responses have not provided.

I. Energy Modeling and the IID Substation (Comments 13-e and 13-q) GSEJA's 5 August 2024 comment letter identified that the DEIR relied on CalEEMod (a tool not listed among the California Energy Commission's approved compliance modeling software for non-residential buildings) to evaluate the project's energy impacts, and that this reliance resulted in an underestimation of the project's significant energy consumption. In Response 13-e, the City contends that the approved compliance software identified by GSEJA and SWAPE is designed for building performance compliance rather than CEQA emissions modeling, and that CalEEMod is the most used and well-accepted tool for CEQA air quality, greenhouse gas, and energy analysis.

GSEJA acknowledges the distinction between Title 24 performance compliance and CEQA emissions modeling. However, the City's response does not adequately explain why CalEEMod provides a sufficient basis for a less-than-significant energy finding for a project of this scale, one whose energy demands are significant enough to require the construction of an entirely new onsite electricity substation in coordination with the Imperial Irrigation District (IID). The requirement for a dedicated IID substation is itself a meaningful indicator of the project's extraordinary energy footprint, and the DEIR's treatment of this infrastructure as an incidental project feature, rather than a subject warranting independent and rigorous environmental analysis, which is inadequate. In Response 13-q, the City discloses that the project is anticipated to consume between 104.22 and 113.01 GWh of electricity annually, representing 2.2 to 2.4 percent of IID's total estimated energy consumption in 2031. That is a substantial share of regional electrical capacity attributable to a single project, and the DEIR's conclusion that energy impacts are less than significant is not supported by the level of analysis the record requires.

GSEJA maintains that the energy analysis is deficient and that a revised EIR should be prepared utilizing appropriate and defensible modeling methodology.

Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 1779 of 2236 3 II. Project Description and Adequacy of Site Plans (Comments 13-c, 13-o, and 13-p) GSEJA's original comment letter identified that the DEIR failed to include a legible and complete site plan, floor plan, building elevations, or grading plan, and that the exhibits provided for public review were blurry, illegible, and had been edited to remove meaningful information including legends, general notes, parking requirements, and floor area ratio data. In Response 13- c, the City characterized the requested information as unnecessary given the programmatic nature of the Specific Plan, citing CEQA Guidelines Section 15146 for the principle that the degree of specificity required in an EIR corresponds to the degree of specificity of the underlying activity.

GSEJA acknowledges that program-level EIRs are not required to include construction-level design documents. However, the level of detail provided in the DEIR falls materially short of what is necessary to enable meaningful public review and informed decision-making, the central purpose of CEQA under Section 21003(b). Exhibit 4.16-2, the MBS Scenario Site Plan, was acknowledged by multiple commenters to be blurry and illegible. A site plan that cannot be read by the public or by decision makers cannot serve as the foundation for environmental findings on transportation, circulation, or hazards.

The City's responses to Comments 13-o and 13-p further rely on the programmatic nature of the project to defer analysis of truck turning movements, sight distance at project driveways, and emergency access to future permitting stages. GSEJA maintains that this deferral is improper. A project expected to generate 1,720 daily truck trips to its industrial component, operating on a site bisected by a new internal street serving both residential and industrial uses, presents foreseeable and significant circulation and safety concerns that cannot be responsibly deferred.

The City's assurance that future projects will be required to comply with applicable design and safety standards does not substitute for the environmental analysis CEQA requires at the time of project approval.

III. Greenhouse Gas Emissions (Comments 13-h and 13-v)
GSEJA and SWAPE identified that the project would result in significant and unavoidable greenhouse gas emissions exceeding the City's Climate Action Plan 2040 threshold of 2.6 MT CO2e/SP/year under both the Maximum Buildout Scenario, which would generate 4.2 MT CO2e/SP/year, and Scenario 2, which would generate 9.0 MT CO2e/SP/year. The City's Final EIR acknowledges these exceedances but maintains that the significant-and-unavoidable determination is appropriate because the effectiveness of additional mitigation measures cannot be known at this time and future state actions supporting carbon-free electricity generation remain uncertain.

GSEJA maintains that the City has not demonstrated that all feasible mitigation measures were fully considered and exhausted prior to making a finding of significance and unavoidability, as CEQA requires. The SCAG 2020 RTP/SCS Program EIR identifies numerous project-level GHG mitigation measures that are applicable to this type of development (including transit incentive

Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 1780 of 2236 4 programs, employer-based commute trip reduction marketing, carpool and vanpool programs, telecommuting incentives, and parking pricing strategies) that the City has not adequately evaluated for applicability, feasibility, or quantified mitigative effect. In Response 13-v, the City dismisses these measures primarily on the grounds that the project is a Specific Plan rather than a project-level development and that specific uses and tenants are not yet known. While GSEJA acknowledges the programmatic nature of the analysis, this rationale cannot justify the wholesale omission of mitigation measures that are plainly applicable to the industrial and commercial uses the Specific Plan expressly contemplates.

Tables 4.8-6 and 4.8-7: Maximum Buildout Scenario and Scenario 2 Mitigated Operational GHG Emissions (Year 2033).

Source: The Oasis at Indio Draft EIR, June 2024, as reproduced in SWAPE Technical Analysis, prepared by Matt Hagemann, P.G., C.Hg. and Paul E. Rosenfeld, Ph.D., Soil Water Air Protection Enterprise (SWAPE), August 2, 2024.

Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 1781 of 2236 5 Furthermore, the City's response to Comment 13-h simultaneously acknowledges that the project's GHG impacts are significant and unavoidable while concluding that the project is consistent with General Plan Goals CE-1, CE-1.1, and CE-1.2, which establish GHG reduction targets aligned with statewide climate goals. This conclusion is internally inconsistent. A project that exceeds the City's own CAP 2040 threshold by more than three times under Scenario 2 cannot credibly be found to advance the City's stated commitment to greenhouse gas reduction leadership in the Coachella Valley.

IV. Land Use and General Plan Consistency (Comments 13-g, 13-h, and 13-i) GSEJA's original letter identified that the DEIR failed to meaningfully analyze the project's consistency with the City's General Plan Land Use Buildout Scenario and did not provide evidence that the growth generated by the project was anticipated by the General Plan, the SCAG RTP/SCS, or the AQMP. The City's responses to Comments 13-g and 13-h largely assert that the concurrent General Plan Amendment will bring the project into conformance with the General Plan and that the programmatic nature of the DEIR excuses a more detailed consistency analysis.

GSEJA maintains that a General Plan Amendment does not retroactively resolve the question of whether the environmental analysis adequately captures the growth implications of departing from the existing land use framework. The MBS Scenario alone accounts for approximately

19.95 percent of all non-residential building area contemplated under the City's General Plan buildout through 2040, and Scenario 2 accounts for approximately 22.5 percent. A single project accounting for nearly one-quarter of the City's planned non-residential growth over a multidecade planning horizon warrants more rigorous analysis of growth-inducing impacts and cumulative development context than the DEIR provides. The City's response to Comment 13-i similarly disposes of GSEJA's concern regarding the IID substation by asserting that it was included in the project description and therefore subsumed within the DEIR's consistency analysis — without providing any project-specific discussion of how this significant piece of electrical infrastructure satisfies the applicable policy requirements.

V. Transportation and VMT (Comments 13-m and 13-n)
GSEJA's original letter identified that the DEIR's VMT analysis was deficient in two material respects: first, that the mitigation measures relied upon to reduce Scenario 2's VMT per employee below the significance threshold lacked evidentiary support for their long-term effectiveness and enforceability; and second, that the analysis excluded substantial truck, trailer, and delivery van VMT associated with the operational nature of the project's industrial uses.

In Response 13-m, the City defends its reliance on a 6.68% VMT reduction attributable to Mitigation Measures T-7 and T-8 (commute trip reduction marketing and a ridesharing program) to bring Scenario 2's baseline VMT per employee of 19.49 below the County of Riverside significance threshold of 18.30 by 6.11%.

Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 1782 of 2236 6 VMT Calculation Table: Project Option B — Baseline Project-Generated VMT per Employee. Source: The Oasis at Indio Final Environmental Impact Report, Response to Comment 13-m, City of Indio, April 2026.

The City references the CAPCOA Handbook as supporting this reduction estimate and states that the project will be conditioned to ensure implementation. GSEJA maintains that the long-term enforceability and sustained effectiveness of these behavioral mitigation measures cannot be assured for a project whose future tenants are entirely unknown at the time of approval. Project conditioning does not guarantee a sustained 6.68% VMT reduction across all future industrial and commercial tenants over the life of the project, and this level of speculation does not satisfy CEQA's requirement that mitigation be feasible, enforceable, and supported by substantial evidence in the record.

In Response 13-n, the City asserts that the proposed industrial buildings are not last-mile facilities and therefore the VMT analysis need not account for sprinter van and delivery vehicle activity. GSEJA notes that the City's own characterization of the project's industrial uses as regional distribution operations does not eliminate the concern: regional distribution facilities generate substantial truck and trailer VMT that is not captured by a per-employee analysis methodology. The exclusion of this activity from the VMT analysis results in a material underestimation of the project's transportation-related environmental impacts.

VI. Population, Housing, and Employment Growth (Comments 13-l and 13-r) The DEIR concludes that project employees will be drawn from existing unemployed workers within the City of Indio and the surrounding Coachella Valley, and that population and housing impacts will therefore be less than significant. GSEJA's original letter identified that this conclusion was unsupported, noting that Indio's unemployment rate of approximately 5% reflects conditions broadly considered to represent full employment, and that the DEIR provides no meaningful evidence that the local and regional workforce has the qualifications or interest to fill the specific types of industrial jobs the project would generate.

Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 1783 of 2236 7 The City's response refers GSEJA back to its general discussion of General Plan growth consistency without directly addressing these concerns. GSEJA reiterates that a project requiring a General Plan Amendment and Zone Change to proceed, precisely because it was not contemplated under the existing land use framework, which cannot simultaneously claim that its growth and employment impacts were fully anticipated by the planning documents it seeks to amend. To the extent that workers are drawn from more distant areas of the Inland Empire or beyond, project-related VMT and associated air quality and greenhouse gas emissions during both construction and operations would be materially higher than analyzed in the DEIR.

VII. Alternatives Analysis (Comment 13-s)
GSEJA's original letter identified that the DEIR failed to evaluate a reasonable range of alternatives capable of avoiding or substantially lessening the project's significant and unavoidable impacts, as required by CEQA Guidelines Section 15126.6. The four alternatives analyzed, being No Project, General Plan Buildout, Zoning Buildout, and No Commercial (MBS), do not include any alternative that reduces air quality and greenhouse gas impacts to less-than-significant levels while meeting the project's stated objectives.

In Response 13-s, the City asserts that the alternatives analyzed represent sufficient variation to allow informed decision-making, and notes that Government Code Section 66300 restricts the ability to reduce residential density below levels permitted as of January 2018. GSEJA acknowledges this legal constraint with respect to the residential component of the project.

However, it does not preclude the analysis of alternatives that reconfigure or reduce the scale of the project's industrial component: the primary driver of the project's air quality, greenhouse gas, and heavy truck traffic impacts. No such alternative was analyzed, and the alternatives chapter of the DEIR has therefore not fulfilled its core statutory purpose.

VIII. Conclusion
For the foregoing reasons, GSEJA reiterates its opposition to the proposed Oasis at Indio Project and maintains that the Final EIR does not adequately remedy the deficiencies identified in GSEJA's 5 August 2024 Comment Letter and SWAPE's accompanying technical analysis. The City's responses, while noted, do not constitute the substantive, evidence-based analysis that CEQA demands, and in several key areas substitute conclusory procedural assertions for the rigorous environmental review the statute requires.

Certifying the Final EIR and approving the project under these circumstances would be inconsistent with the City's obligations under CEQA and would expose the City's actions to legal challenge.

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Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 1785 of 2236 May 26, 2026
Via Email
Gloria Franz, Chair
Felipe Ortiz, Vice-Chair
Michael Slater, Commissioner
Megan Scarborough-Eckel, Commissioner
Jose Santos, Commissioner
Planning Commission
City of Indio
100 Civic Center Drive
Indio CA 92201
[email protected]
Brian Halvorson, Director
Community Development Department
City of Indio
100 Civic Center Drive
Indio, CA 92201
[email protected]
Re: SAFER Comment – Oasis at Indio Project
Environmental Impact Report (SCH No. 2024050578)
Planning Commission Agenda Item 5.2 (May 27, 2026)
Dear Chair Franz, Vice-Chair Ortiz, Honorable Commissioners, and Mr. Halvorson:

This comment is submitted on behalf of Supporters Alliance for Environmental Responsibility (“SAFER”) regarding the Environmental Impact Report (“EIR”) prepared for the Oasis at Indio Project (SCH No. 2024050578), which proposes two potential buildout scenarios at the crossroads of Avenue 42 and Monroe Street: (1) Maximum Building Scenario, which includes buildout of 3,240 dwelling units, 20,000 square feet of retail commercial uses, and 1,806,290 square feet of industrial development; and (2) Scenario #2, which assumes lesser buildout than the MBS including 1,320 dwelling units, 71,600 square feet of retail commercial uses, a 128 key hotel/motel, and 1,806,290 square feet of industrial uses.

SAFER is concerned that the EIR fails as an informational document and fails to impose all feasible mitigation measures to reduce the Project’s impacts. SAFER joins in the comments submitted by CARE CA, Golden State Environmental Justice Alliance, and the California Department of Fish and Wildlife. SAFER requests that the City address the shortcomings raised in those comments in a revised and recirculated EIR prior to further consideration of the Project.

Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 1786 of 2236 SAFER Comment
Oasis at Indio EIR
PC Agenda Item 5.2 (May 27, 2026)
May 26, 2026

SAFER reserves the right to supplement these comments during the administrative process. (Galante Vineyards v. Monterey Peninsula Water Management Dist. (1997) 60 Cal.App.4th 1109, 1121.)

Sincerely,

Brian B. Flynn
Lozeau Drury LLP

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Vivian Zimmerman #

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Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 1794 of 2236 While the projected financial benefits to the city are clear, the current plan places a number of burdens on nearby residents in several critical areas:

1. Traffic and Public Safety: The influx of activity from this development will severely impact local traffic flow for years to come, specifically along key corridors that our residents rely on daily. I am deeply concerned about increased transit delays, intersection safety, and potential obstructions to emergency vehicle access for our community's residents.

I also have concerns about the safety of residents and the area where housing is put adjacent to an industrial complex. I have seen this negatively effect other areas in California in Hayward, Bloomington, Tulare, Wilmington, Long Beach etc. All of these areas had safety and crime related issues after similar projects had been developed.

Especially with so many seniors moving here because of the safety of the community this gives me and my wife great concern.

2. Infrastructure Strain: A project of this magnitude risks overextending local infrastructure and public resources. I urge the council to thoroughly examine whether our current utility frameworks and public safety teams are equipped to handle this expansion without diminishing services to existing and pending new neighborhoods.

3. Community Character and Quality of Life: The scale and operational nature of the Oasis project risk creating significant light, noise, and environmental disruptions that clash with the established quiet enjoyment of our residential zone.

I firmly believe that economic development and the protection of existing residential communities do not have to be mutually exclusive. Therefore, I respectfully ask that the City Council withhold approval of the current proposal until the developer agrees to rigorous mitigation strategies. Specifically, I urge you to require additional work on:
* Comprehensive, independent traffic and safety impact studies with mandatory developer-funded roadway improvements.
* Increased buffer zones, structural setbacks, and enhanced sound/light barriers to shield adjacent neighborhoods. * Strict limitations on operational hours or specific high-impact uses that directly threaten our quality of life.

Thank you for your time, your hard work, and your continued dedication to balancing the growth of Indio with the well-being of the constituents who live here. I look forward to your response and to seeing how the council intends to address these community concerns at the upcoming public hearings.

Sincerely,
David & Deirdre Galen

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Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 1801 of 2236 Mark & Linda Galletta

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3. How many of those voting on whether the project will move forward or not, live in North Indio (north of Interstate 10)?
I really hope you take the time to respond.

Thank you.

Nancy Trillo
Sent from my iPad

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Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 1817 of 2236 Subject: Public Comment Regarding Oasis at Indio Project -- May 27 Planning Commission Hearing
Dear Members of the Indio Planning Commission,
I am writing to express serious concerns regarding the proposed Oasis at Indio Project, which is scheduled for public hearing before the Planning Commission on May 27.

While I recognize the importance of economic development and responsible growth in the City of Indio, I urge the Commission to carefully evaluate whether this project, particularly the construction of a large-scale warehouse/distribution facility, is compatible with the surrounding community and long-term planning goals of our city.

My concerns include the following:

1. Traffic Congestion and Public Safety
A warehouse project of this magnitude will inevitably generate substantial truck traffic, employee vehicle traffic, and increased congestion on already impacted local roads. Residents deserve a clear understanding of:

The projected daily volume of truck traffic
Traffic impacts on nearby residential neighborhoods
Increased wear and tear on local streets
Potential delays for emergency vehicles
Pedestrian and cyclist safety concerns
Without meaningful infrastructure improvements and traffic mitigation

Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 1818 of 2236 measures, this project could significantly degrade the quality of life for nearby residents.

2. Environmental Impacts
The environmental consequences of a large warehouse operation should be closely scrutinized. These concerns include:

Increased air pollution from diesel truck traffic
Noise pollution from round-the-clock operations
Light pollution affecting nearby neighborhoods
Dust and construction-related impacts
Potential stormwater runoff concerns
Loss of open space and habitat impacts
Given the Coachella Valley's ongoing air quality challenges, any project that substantially increases heavy truck activity should be evaluated very carefully.

3. Compatibility with Surrounding Land Uses
Indio continues to grow as a residential, tourism, and community-oriented city. A massive industrial warehouse facility may be inconsistent with nearby residential development and may negatively affect property values and neighborhood character.

Residents should not bear the burden of poorly placed industrial expansion.

4. Water Usage and Sustainability Concerns
In a desert community that faces long-term water sustainability challenges, the Commission should examine:

Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 1819 of 2236 Construction-related water demands
Ongoing operational water usage
Landscaping requirements
Overall sustainability practices
Responsible development must reflect the realities of living in an arid region.

5. Economic Benefits vs. Community Costs
While warehouse projects often promise jobs and tax revenue, these benefits should be weighed against:

Increased infrastructure costs
Environmental degradation
Traffic burdens
Public safety concerns
Potential decline in nearby residential desirability
The community deserves transparency regarding whether the long-term benefits truly outweigh the costs.

6. Need for Full Public Transparency
Residents should have access to all environmental studies, traffic studies, mitigation plans, and operational details before major decisions are made.

Public participation should be meaningful--not merely procedural.

I respectfully urge the Planning Commission to carefully evaluate this proposal, require comprehensive mitigation measures, and consider whether

Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 1820 of 2236 this project is truly in the best interests of Indio residents.

Growth is important--but smart growth is essential.

Thank you for your time and consideration.

Sincerely,
Barry A. J. Fisher
Indio Resident

Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 1821 of 2236 P: (626) 314-3821
F: (626) 389-5414
E: [email protected]
Mitchell M. Tsai
Law Firm
139 South Hudson Avenue
Suite 200
Pasadena, California 91101

VIA E-MAIL
June 10, 2026
Planning Commission
City of Indio
100 Civic Center Drive
Council Chamber, 3rd floor
Indio, CA 92201
Ph: (760) 391-4086
Em: [email protected]
Em: [email protected]
Brian Halvorson, AICP
Community Development Director
Community Development Department
City of Indio
100 Civic Center Mall
Indio, CA 92201
Ph: (760) 391-4086
Em: [email protected]
RE: City’s June 10, 2026, Planning Commission Meeting – Agenda Item 5.1 – The Oasis at Indio Specific Plan Project, Final Environmental Impact Report [ER-23-0001; SCH# 2024050578] Dear Chair Franz, Honorable Commissioners, and Brian Halvorson, On behalf of the Western States Regional Council of Carpenters (“Western States Carpenters” or “WSRCC”), our firm is submitting these comments to the City of Indio (“City”) in connection with the City’s June 10, 2026, Planning Commission hearing on The Oasis at Indio Specific Plan Project (“Project”) and the Final Environmental Impact Report (“FEIR”) associated therewith.

The Project proposes the development of a mixed-use community on approximately 183 acres of vacant land within the City north of the I-10 freeway and south of Avenue 42, bounded on the east by Monroe Street and on the west by Madison Street. The mixed-use Project will consist of residential, commercial, and industrial uses separated into four planning areas. The EIR evaluates potential environmental impacts associated with the development of two buildout scenarios for the Project: (1) a Maximum Buildout Scenario (“MBS”), which assumes buildout of the project resulting in 3,240 dwelling units, 20,000 square feet of retail commercial uses, and 1,806,290 square feet of industrial development; and (2) Scenario #2, which assumes lesser buildout than the MBS but within the maximum intensities permitted. Scenario

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#2 would result in 1,237 dwelling units, 71,600 square feet of retail commercial uses, a 128 key hotel/motel, and 1,806,290 square feet of industrial uses.

The Western States Carpenters hereby reiterates its prior comments submitted regarding the Project, its FEIR, and its Draft Environmental Impact Report (“DEIR”). The FEIR’s responses to comments on the Project’s DEIR do not meet the requirement under CEQA Guidelines Section 15088 that such responses set forth a good-faith, reasoned analysis. WSRCC hereby expresses its support for the Planning Commission’s recommendation that the City Council deny the Project as proposed based on its significant and unavoidable air quality and greenhouse gas emissions impacts noted in the Project’s FEIR, its inconsistency with the goals and policies of the City’s General Plan, and the noted deficiencies in its proposed Specific Plan and Development Agreement.

The Western States Carpenters is a labor union representing nearly 90,000 union carpenters in ten states, including California, and has a strong interest in well-ordered land use planning and in addressing the environmental impacts of development projects. Individual members of the Western States Carpenters live, work, and recreate in the City and surrounding communities and would be directly affected by the Project’s environmental impacts.

The Western States Carpenters expressly reserves the right to supplement these comments at or prior to hearings on the Project, and at any later hearing and proceeding related to this Project. Gov. Code, § 65009, subd. (b); Pub. Res. Code, § 21177, subd. (a); see Bakersfield Citizens for Local Control v. Bakersfield (2004) 124 Cal.App.4th 1184, 1199-1203; see also Galante Vineyards v. Monterey Water Dist. (1997) 60 Cal.App.4th 1109, 1121.

The Western States Carpenters incorporates by reference all comments raising issues regarding the Environmental Impact Report (EIR) submitted prior to certification of the EIR for the Project. See Citizens for Clean Energy v City of Woodland (2014) 225 Cal.App.4th 173, 191 (finding that any party who has objected to the project’s environmental documentation may assert any issue timely raised by other parties).

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I. THE CITY SHOULD REQUIRE THE USE OF A LOCAL
WORKFORCE TO BENEFIT THE COMMUNITY’S ECONOMIC

DEVELOPMENT AND ENVIRONMENT
The City should require the Project to be built using a local workers who have graduated from a Joint Labor-Management Apprenticeship Program approved by the State of California, have at least as many hours of on-the-job experience in the applicable craft which would be required to graduate from such a state-approved apprenticeship training program, or who are registered apprentices in a state-approved apprenticeship training program.

Community benefits such as local hire can also be helpful to reduce environmental impacts and improve the positive economic impact of the Project. Local hire provisions requiring that a certain percentage of workers reside within 10 miles or less of the Project site can reduce the length of vendor trips, reduce greenhouse gas emissions, and provide localized economic benefits. As environmental consultants Matt Hagemann and Paul E. Rosenfeld note:
[A]ny local hire requirement that results in a decreased worker trip length from the default value has the potential to result in a reduction of construction-related GHG emissions, though the significance of the reduction would vary based on the location and urbanization level of the project site.

March 8, 2021 SWAPE Letter to Mitchell M. Tsai re Local Hire Requirements and Considerations for Greenhouse Gas Modeling.

Workforce requirements promote the development of skilled trades that yield sustainable economic development. As the California Workforce Development Board and the University of California, Berkeley Center for Labor Research and Education concluded:
[L]abor should be considered an investment rather than a cost—and investments in growing, diversifying, and upskilling California’s workforce can positively affect returns on climate mitigation efforts. In other words,

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well-trained workers are key to delivering emissions reductions and moving California closer to its climate targets.1
Furthermore, workforce policies have significant environmental benefits given that they improve an area’s jobs-housing balance, decreasing the amount and length of job commutes and the associated greenhouse gas (GHG) emissions. In fact, on May 7, 2021, the South Coast Air Quality Management District found that that the “[u]se of a local state-certified apprenticeship program” can result in air pollutant reductions.2 Locating jobs closer to residential areas can have significant environmental benefits.

As the California Planning Roundtable noted in 2008:

People who live and work in the same jurisdiction would be more likely to take transit, walk, or bicycle to work than residents of less balanced communities and their vehicle trips would be shorter. Benefits would include potential reductions in both vehicle miles traveled and vehicle hours traveled.3
Moreover, local hire mandates and skill-training are critical facets of a strategy to reduce vehicle miles traveled (VMT). As planning experts Robert Cervero and Michael Duncan have noted, simply placing jobs near housing stock is insufficient to achieve VMT reductions given that the skill requirements of available local jobs must match those held by local residents.4 Some municipalities have even tied local hire and 1 California Workforce Development Board (2020) Putting California on the High Road: A Jobs and Climate Action Plan for 2030 at p. ii, available at https://laborcenter.berkeley.edu/ wp-content/uploads/2020/09/Putting-California-on-the-High-Road.pdf. 2 South Coast Air Quality Management District (May 7, 2021) Certify Final Environmental Assessment and Adopt Proposed Rule 2305 – Warehouse Indirect Source Rule – Warehouse Actions and Investments to Reduce Emissions Program, and Proposed Rule 316 – Fees for Rule 2305, Submit Rule 2305 for Inclusion Into the SIP, and Approve Supporting Budget Actions, available at http://www.aqmd.gov/docs/defaultsource/Agendas/Governing-Board/2021/2021-May7-027.pdf?sfvrsn=10. 3 California Planning Roundtable (2008) Deconstructing Jobs-Housing Balance at p. 6, available at https://cproundtable.org/static/media/uploads/publications/cpr-jobshousing.pdf 4 Cervero, Robert and Duncan, Michael (2006) Which Reduces Vehicle Travel More: JobsHousing Balance or Retail-Housing Mixing? Journal of the American Planning Association 72 (4), 475-490, 482, available at http://reconnectingamerica.org/assets/Uploads/UTCT825.pdf.

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other workforce policies to local development permits to address transportation issues. Cervero and Duncan note that:

In nearly built-out Berkeley, CA, the approach to balancing jobs and housing is to create local jobs rather than to develop new housing. The city’s First Source program encourages businesses to hire local residents, especially for entry- and intermediate-level jobs, and sponsors vocational training to ensure residents are employment-ready. While the program is voluntary, some 300 businesses have used it to date, placing more than 3,000 city residents in local jobs since it was launched in 1986. When needed, these carrots are matched by sticks, since the city is not shy about negotiating corporate participation in First Source as a condition of approval for development permits.

Recently, the State of California verified its commitment towards workforce development through the Affordable Housing and High Road Jobs Act of 2022, otherwise known as Assembly Bill No. 2011 (“AB2011”). AB2011 amended the Planning and Zoning Law to allow ministerial, by-right approval for projects being built alongside commercial corridors that meet affordability and labor requirements.

The City should consider utilizing local workforce policies and requirements to benefit the local area economically and to mitigate greenhouse gas, improve air quality, and reduce transportation impacts.

II. THE CITY SHOULD IMPOSE TRAINING REQUIREMENTS FOR
THE PROJECT’S CONSTRUCTION ACTIVITIES TO PREVENT
COMMUNITY SPREAD OF COVID-19 AND OTHER INFECTIOUS

DISEASES
Construction work has been defined as a Lower to High-risk activity for COVID-19 spread by the Occupations Safety and Health Administration. Recently, several construction sites have been identified as sources of community spread of COVID19.5

5 Santa Clara County Public Health (June 12, 2020) COVID-19 CASES AT

CONSTRUCTION SITES HIGHLIGHT NEED FOR CONTINUED VIGILANCE IN SECTORS THAT HAVE REOPENED, available at https://www.sccgov.org/sites/ covid19/Pages/press-release-06-12-2020-cases-at-construction-sites.aspx.

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The Western States Carpenters recommend that the City adopt additional requirements to mitigate public health risks from the Project’s construction activities.

The Western States Carpenters requests that the City require safe on-site construction work practices as well as training and certification for any construction workers on the Project Site.

In particular, based upon the Western States Carpenters’ experience with safe construction site work practices, the Western States Carpenters recommends that the City require that while construction activities are being conducted at the Project Site:

Construction Site Design:
• The Project Site will be limited to two controlled entry points.
• Entry points will have temperature screening technicians taking temperature readings when the entry point is open. • The Temperature Screening Site Plan shows details
regarding access to the Project Site and Project Site logistics for conducting temperature screening.
• A 48-hour advance notice will be provided to all trades prior to the first day of temperature screening.
• The perimeter fence directly adjacent to the entry points will be clearly marked indicating the appropriate 6-foot social distancing position for when you approach the screening area. Please reference the Apex temperature screening site map for additional details.
• There will be clear signage posted at the project site directing you through temperature screening.
• Provide hand washing stations throughout the construction site.

Testing Procedures:
• The temperature screening being used are non-contact
devices.
• Temperature readings will not be recorded.

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• Personnel will be screened upon entering the testing center and should only take 1-2 seconds per individual.
• Hard hats, head coverings, sweat, dirt, sunscreen or any other cosmetics must be removed on the forehead before
temperature screening.
• Anyone who refuses to submit to a temperature screening or does not answer the health screening questions will be
refused access to the Project Site.
• Screening will be performed at both entrances from 5:30 am to 7:30 am.; main gate [ZONE 1] and personnel gate
[ZONE 2]
• After 7:30 am only the main gate entrance [ZONE 1] will continue to be used for temperature testing for anybody gaining entry to the project site such as returning personnel, deliveries, and visitors.
• If the digital thermometer displays a temperature reading above 100.0 degrees Fahrenheit, a second reading will be taken to verify an accurate reading.
• If the second reading confirms an elevated temperature, DHS will instruct the individual that he/she will not be allowed to enter the Project Site. DHS will also instruct the individual to promptly notify his/her supervisor and his/her human resources (HR) representative and provide them with a copy of Annex A.

Planning
• Require the development of an Infectious Disease
Preparedness and Response Plan that will include basic
infection prevention measures (requiring the use of personal protection equipment), policies and procedures for prompt identification and isolation of sick individuals, social distancing (prohibiting gatherings of no more than 10
people including all-hands meetings and all-hands lunches)

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communication and training and workplace controls that
meet standards that may be promulgated by the Center for Disease Control, Occupational Safety and Health
Administration, Cal/OSHA, California Department of
Public Health or applicable local public health agencies.6 The United Brotherhood of Carpenters and Carpenters International Training Fund has developed COVID-19 Training and Certification to ensure that Carpenter union members and apprentices conduct safe work practices. The Agency should require that all construction workers undergo COVID-19 Training and Certification before being allowed to conduct construction activities at the Project Site.

The Western States Carpenters has also developed a rigorous Infection Control Risk Assessment (“ICRA”) training program to ensure it delivers a workforce that understands how to identify and control infection risks by implementing protocols to protect themselves and all others during renovation and construction projects in healthcare environments.7
ICRA protocols are intended to contain pathogens, control airflow, and protect patients during the construction, maintenance and renovation of healthcare facilities.

ICRA protocols prevent cross contamination, minimizing the risk of secondary infections in patients at hospital facilities.

The City should require the Project to be built using a workforce trained in ICRA protocols.

III. THE CITY MUST REVISE AND RECIRCULATE THE EIR FOR

THE PROJECT
CEQA is a California statute designed to inform decision makers and the public about the potential, significant environmental effects of a project. 14 California Code of 6 See also The Center for Construction Research and Training, North America’s Building Trades Unions (April 27 2020) NABTU and CPWR COVIC-19 Standards for U.S Constructions Sites, available at https://www.cpwr.com/sites/default/files/NABTU_ CPWR_Standards_COVID-19.pdf; Los Angeles County Department of Public Works (2020) Guidelines for Construction Sites During COVID-19 Pandemic, available at https://dpw.lacounty.gov/building-and-safety/docs/pw_guidelines-construction-sites.pdf. 7 For details concerning the Western States Carpenters’ ICRA training program, see https://icrahealthcare.com/.

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Regulations (“CEQA Guidelines”) § 15002(a)(1).8 At its core, “[i]ts purpose is to inform the public and its responsible officials of the environmental consequences of their decisions before they are made.” Citizens of Goleta Valley v. Board of Supervisors (1990) 52 Cal. 3d 553, 564.

To achieve this purpose, CEQA mandates preparation of an Environmental Impact Report (“EIR”) for projects so that the foreseeable impacts of pursuing the project can be understood and weighed. Communities for a Better Environment v. Richmond (2010) 184 Cal. App. 4th 70, 80. The EIR requirement “is the heart of CEQA.” CEQA Guidelines, § 15003(a).

The preparation and circulation of an EIR is more than a set of technical hurdles for agencies and developers to overcome. The EIR’s function is to ensure that government officials who decide to build or approve a project do so with a full understanding of the environmental consequences and, equally important, that the public is assured those consequences have been considered. For the EIR to serve these goals it must present information so that the foreseeable impacts of pursuing the project can be understood and weighed, and the public must be given an adequate opportunity to comment on that presentation before the decision to go forward is made. Communities for a Better Environment v. Richmond (2010) 184 Cal. App. 4th 70, 80 (quoting Vineyard Area Citizens for Responsible Growth, Inc. v. City of Rancho Cordova (2007) 40 Cal. 4th 412, 449–450).

Section 15088.5(a) of the CEQA Guidelines provides that an EIR must be recirculated whenever there is disclosure of significant new information. Significant new information includes: (1) disclosure of a new significant environmental impact resulting from the project or from a new proposed mitigation measure; (2) disclosure of a substantial increase in the severity of an environmental impact unless mitigation measures are adopted that reduce the impact to a level of insignificance; and (3) disclosure of a feasible project alternative or mitigation measure considerably different from others previously analyzed which would clearly lessen the significant 8 The CEQA Guidelines, codified in Title 14 of the California Code of Regulations, section 15000 et seq, are regulatory guidelines promulgated by the state Natural Resources Agency for the implementation of CEQA. (Cal. Pub. Res. Code § 21083.) The CEQA Guidelines are given “great weight in interpreting CEQA except when . . . clearly unauthorized or erroneous.” Center for Biological Diversity v. Department of Fish & Wildlife (2015) 62 Cal. 4th 204, 217.

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environmental impacts of the project which the project proponents decline to adopt.

Id.

Additionally, an EIR must be recirculated when it is so fundamentally inadequate and conclusory in nature that meaningful public review and comment is precluded. Id. [citing Mountain Lion Coalition v. Fish & Game Com. (1989) 214 Cal.App.3d 1043].

Here, as discussed below, the Project’s FEIR fails to substantiate all of its conclusions to allow meaningful public review and comment, provide adequate mitigation measures, and fully assess all pertinent environmental factors. Accordingly, this comment letter discloses significant new information, necessitating revision and recirculation of the FEIR.

A. The FEIR’s Mitigation Measures Remain Insufficient
A fundamental purpose of an EIR is to identify ways in which a proposed project's significant environmental impacts can be mitigated or avoided. Pub. Res. Code §§ 21002.1(a), 21061. To implement this statutory purpose, an EIR must describe any feasible mitigation measures that can minimize the project's significant environmental effects. PRC §§ 21002.1(a), 21100(b)(3); CEQA Guidelines §§ 15121(a), 15126.4(a).

If the project has a significant effect on the environment, the agency may approve the project only upon finding that it has “eliminated or substantially lessened all significant effects on the environment where feasible” PRC §§ 21002; 21002.1, 21081; CEQA Guidelines §§ 15091, 15092(b)(2)(A); and find that ‘specific overriding economic, legal, social, technology or other benefits of the project outweigh the significant effects on the environment.” PRC §§ 21002; 21002.1, 21081; CEQA Guidelines §§ 15091, 15092(b)(2)(B). “A gloomy forecast of environmental degradation is of little or no value without pragmatic, concrete means to minimize the impacts and restore ecological equilibrium.” Environmental Council of Sacramento v. City of Sacramento (2006) 142 Cal.App.4th 1018, 1039.

CEQA mitigation measures proposed and adopted are required to describe what actions will be taken to reduce or avoid an environmental impact. (CEQA Guidelines § 15126.4(a)(1)(B) [providing “[f]ormulation of mitigation measures should not be deferred until some future time.”].) While the same Guidelines section 15126.5(a)(1)(B) acknowledges an exception to the rule against deferrals, such exception is narrowly proscribed to situations where it is impractical or infeasible to include those details during the project's environmental review.

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According to CEQA Guidelines, “[w]hen an EIR has been prepared for a project, the Responsible Agency shall not approve the project as proposed if the agency finds any feasible alternative or feasible mitigation measures within its powers that would substantially lessen or avoid any significant effect the project would have on the environment.” CEQA Guidelines Section 15096(g)(2).

Here, the FEIR’s mitigation measures perpetuate the failures evident in the Project’s DEIR to adequately mitigate the Project’s impacts as follows:
i. Greenhouse Gas Emissions
The Project’s DEIR found that the Project greenhouse gas (“GHG”) impacts will be significant and unavoidable. DEIR at 1-25 – 1-26. Highlighting the significance of those impacts, the FEIR and DEIR indicate that the Project will significantly exceed the City's Climate Action Plan 2040 GHG emissions threshold of 2.6 MT CO2e/SP/year, irrespective of whether the Project proceeds under the MBS (calculated at 4.2 MT CO2e/SP/year) or Scenario 2 (calculated at 9.0 MT CO2e/SP/year). Based on the Project’s significant and unavoidable GHG impacts, the DEIR and FEIR impose several measures in attempt to mitigate such impacts, GHG-1 – GHG-3.

As stated in the Office of Planning Research’s (“OPR”) technical advisory in 2018:

VMT and Greenhouse Gas Emissions Reduction. Senate Bill 32 (Pavley, 2016) requires California to reduce greenhouse gas (GHG) emissions 40 percent below 1990 levels by 2030, and Executive Order B-16-12 provides a target of 80 percent below 1990 emissions levels for the transportation sector by 2050.

Despite the Project’s clear GHG emissions impacts in direct contravention of SB 32’s GHG reduction goals, and the concerns raised by WSRCC and other commenting parties regarding Project’s GHG impacts, the EIR still does not make an adequate effort to otherwise reduce the Project’s GHG impacts through other specific project design features aimed at reducing GHG emissions.

Moreover, the Project is not consistent with the CARB 2022 Scoping Plan. Indeed, the first action item in the Scoping Plan is reduce GHG emissions “40% below 1990 levels by 2030.”9 The CARB Scoping Plan also sets forth the action item that new 9 California Air Resources Board 2022 Scoping Plan at p. 72;

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residential and commercial buildings will have “[a]ll electric appliances beginning 2026 (residential) and 2029 (commercial), contributing to 6 million heat pumps installed statewide by 2030.”10
Despite the clear path presented by the CARB Scoping Plan for reducing GHG emissions, the FEIR continues to decline to hold the Project to that standard, and instead deflects the City’s responsibility to mitigate significant GHG emissions impacts to the greatest degree possible, pursuant to CEQA’s mandate. Moreover, the SCAG 2020 RTP/SCS Program EIR identifies numerous project-level GHG mitigation measures that would be applicable to the Project, including, but not limited to, transit incentive programs, employer-based commute trip reduction marketing, carpool and vanpool programs, telecommuting incentives, and parking pricing strategies. However, the Project’s EIR fails to adequately evaluate and incorporate, where feasible and applicable, mitigation measures of this sort to the maximum extent possible, and fails to sufficiently analyze and quantify the mitigating effect on the Project that would be presented by such measures.

While the Project’s FEIR acknowledges the Project’s contravention of the City’s CAP, it still declines to make further commitments toward mitigating the significant-andunavoidable GHG impacts on the specious basis that the effectiveness of additional mitigation measures remain unknown at this time and future state actions supporting carbon-free electricity generation have yet to be determined.

The City must demonstrate, as the Project’s lead agency under CEQA, that all feasible mitigation measures for the Project have been fully considered and exhausted prior to adopting findings of significant and unavoidable GHG impacts. Indeed, it is the City’s obligation, as lead agency, to ensure that the Project’s environmental impacts have first been properly analyzed and then mitigated to a less than significant level wherever possible. WSRCC reiterates that the Project’s implementation of the additional potential mitigation measures set forth below (where applicable), as delineated by the California Air Pollution Control Officers Association’s Quantifying Greenhouse Gas Mitigation Measures, would contribute toward the goal of reducing the Project’s GHG emission impacts to the maximum extent possible:
https://ww2.arb.ca.gov/sites/default/files/2023-04/2022-sp.pdf 10 Id. at p. 75

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(See Quantifying Greenhouse Gas Mitigation Measures, Tables 6-1 to 6-9, California Air Pollution Control Officers Association (CAPCOA), August 2010.11) It is entirely feasible for the Project’s EIR to incorporate a substantial proportion of the foregoing measures for the Project as mandatory forms of mitigation against the Project’s significant and unavoidable greenhouse gas impacts (many with co-benefits to 11 Available at: http://www.aqmd.gov/docs/default-source/ceqa/handbook/capcoaquantifying-greenhouse-gas-mitigation-measures.pdf

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the Project’s significant and unavoidable air quality impacts as well). In particular, despite the comments raised regarding the DEIR’s inadequate efforts to mitigate the Project’s significant and unavoidable GHG impacts, the FEIR failed and refused to add additional mitigation measures on those impacts, including declining to incorporate any mitigation measures aimed at ensuring that an adequate percentage of the Project’s total roof area be dedicated for photovoltaic installation to meet the Project’s energy needs, to the maximum extent feasible, or to otherwise commit the Project to meeting an applicable and significant percentage of its energy needs via onsite solar energy (or other renewable energy) generation. The FEIR’s contention that the energy demands of the Project remain speculative based on the ultimate uses and development in the Project’s Specific Plan area remaining yet undetermined does not preclude the City from requiring that the Project set standards to ensure the mitigation of its operational GHG impacts to the maximum extent feasible via on-site renewable energy generation, among other things.

Additionally, the FEIR has summarily rejected as infeasible the notion of incorporating the purchase of carbon offsets as a form of further mitigation of the Project’s significant and unavoidable GHG impacts. While the FEIR sets forth a litany of excuses as to why the purchase of carbon offsets may not be practical (see FEIR, pp. 2-108 – 2-109), this limited discussion of the purported pitfalls of pursuing carbon offsets falls far from providing substantial evidence that carbon offsets would make for an infeasible form of mitigation against GHG impacts that have otherwise been deemed significant and unavoidable for the Project. Indeed, the FEIR fails to set forth with any specificity that it investigated the existence and availability of “sufficient, reliable offsets” for the Project’s GHG emissions impacts before concluding that such offsets would be infeasible to obtain. CEQA requires that the FEIR supply greater detail, analysis, and overall effort to demonstrate that such a viable proposed mitigation option is infeasible before adopting the conclusion that carbon offsets are not a worthy form of mitigation for the Project.

Thus, FEIR’s analysis and mitigation of the Project’s significant GHG impacts remains inadequate and continues to violate CEQA, such that the City cannot permissibly certify the FEIR in its present form, and the Project’s EIR must be revised and recirculated to incorporate all feasible forms of mitigation of the Project’s GHG impacts, either to the point that the impacts can cognizably deemed less than significant, or otherwise to the maximum extent feasible.

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ii. Air Quality
A fundamental purpose of an EIR is to identify ways in which a proposed project's significant environmental impacts can be mitigated or avoided. Pub. Res. Code §§ 21002.1(a), 21061. To implement this statutory purpose, an EIR must describe any feasible mitigation measures that can minimize the project's significant environmental effects. PRC §§ 21002.1(a), 21100(b)(3); CEQA Guidelines §§ 15121(a), 15126.4(a).

If the project has a significant effect on the environment, the agency may approve the project only upon finding that it has “eliminated or substantially lessened all significant effects on the environment where feasible” PRC §§ 21002; 21002.1, 21081; CEQA Guidelines §§ 15091, 15092(b)(2)(A); and find that ‘specific overriding economic, legal, social, technology or other benefits of the project outweigh the significant effects on the environment.” PRC §§ 21002; 21002.1, 21081; CEQA Guidelines §§ 15091, 15092(b)(2)(B). “A gloomy forecast of environmental degradation is of little or no value without pragmatic, concrete means to minimize the impacts and restore ecological equilibrium.” Environmental Council of Sacramento v. City of Sacramento (2006) 142 Cal.App.4th 1018, 1039.

According to CEQA Guidelines, “[w]hen an EIR has been prepared for a project, the Responsible Agency shall not approve the project as proposed if the agency finds any feasible alternative or feasible mitigation measures within its powers that would substantially lessen or avoid any significant effect the project would have on the environment.” CEQA Guidelines Section 15096(g)(2). The DEIR concluded that the Project will have significant Air Quality impacts in numerous respects. DEIR, p. 1-10 – 1-17; 4.3-25 – 4.3-71. As such, the Project has proposed to follow certain regulatory requirements and proposes mitigation measures MM-AQ-1 to MM-AQ-7 to further reduce construction and operational air quality impacts. Id. Notwithstanding, the DEIR concluded the Project’s air quality impacts associated are “significant and unavoidable” in a variety of respects, a determination that remained unchanged in the Project’s FEIR. Id.

However, an impact can only be labeled as significant-and-unavoidable after all available, feasible mitigation is considered and the EIR lacks substantial evidence to support a finding that no other feasible mitigation existed to mitigate Project’s significant impacts. Here, the EIR fails to incorporate any and all feasible mitigation measures associated with the Project’s significant and unavoidable Air Quality impacts. A mitigation measure must be enforceable through conditions of approval,

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contracts or other means that are legally binding. (PRC § 21081.6; CEQA Guidelines § 15126.4(a)(2).) Mitigation measures should be implemented, not adopted and ignored (Federation of Hillside & Canyon Ass’ns v. City of Los Angeles (2000) 83 Cal.App.4th 1252, 1261.)
Indeed, the FEIR does not incorporate, for example, all feasible mitigation measures delineated in the foregoing CAPCOA Greenhouse Gas Mitigation Measures, or the other measures pertaining to the Project’s reliance on renewable energy (see above).

For example, the Project’s implementation of CAPCOA Mitigation Measure Nos.

BE-1, BE-2, and BE-3 would demonstrably impact the amount of natural gas used/combusted during the Project’s operation, which in turn, would lessen the Project’s air quality impacts. Meanwhile, the Project’s EIR admits that natural gas combustion is a contributor to Air Quality impacts.

Moreover, the FEIR perpetuates the failure and refusal to commit the Project to limiting its use of gas- and/or diesel-powered equipment to the maximum extent feasible. In this regard, the Project’s mitigation measure AIR-3 still only contains the inadequate requirement that, in connection with potential emissions generated by landscaping equipment servicing the Project, the Applicant provide the residential, commercial, and industrial property managers and owners/occupants with informational materials concerning SCAQMD’s rebate, incentive, and voucher programs associated with such types of equipment. The FEIR can clearly go further, in that it could require that the Project be operated using reduced emission and/or electrified landscaping equipment to the maximum extent feasible. As currently framed, mitigation measure AIR-3 does not commit to any quantifiable reduction to the Project’s otherwise significant and unavoidable air quality impacts, thereby undermining the CEQA requirement that such significant and unavoidable impacts be mitigated to the maximum extent feasible.

Accordingly, the EIR should be revised to, at a minimum, incorporate any of the CAPCOA Greenhouse Gas Mitigation Measures that are potentially feasible for the Project that have not already been included. Given that the City falls in a region that remains in non-attainment for multiple state and national air quality standards, WSRCC continues to concur with the FEIR’s conclusion that the air quality impacts of the Project will be significant and unavoidable regardless of the mitigation measures ultimately undertaken. However, WSRCC maintains that, under CEQA, the City has an obligation via the Project’s EIR to reduce the significant air quality

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impacts presented by the Project to the greatest extent feasible via appropriately crafted mitigation measures.

IV. CONCLUSION
In sum, WSRCC concurs with the Planning Commission’s recommendation that the City Council deny the Project as proposed based on the Project’s failure to mitigate its significant and unavoidable air quality and greenhouse gas emissions impacts to the maximum extent feasible, its current inconsistency with the goals and policies of the City’s General Plan, and the noted deficiencies in its proposed Specific Plan and Development Agreement. WSRCC further reiterates its requests that the City require a local workforce, that the City impose training requirements for the Project’s construction activities to prevent community spread of COVID-19 and other infectious diseases, and that the City revise and recirculate the EIR for the Project to address the aforementioned concerns. If the City has any questions, please do not hesitate to contact this office.

Sincerely,
______________________
Jeremy Herwitt
Attorneys for Western States Regional
Council of Carpenters
Attached:

March 8, 2021 SWAPE Letter to Mitchell M. Tsai re Local Hire Requirements and Considerations for Greenhouse Gas Modeling (Exhibit A); Air Quality and GHG Expert Paul Rosenfeld CV (Exhibit B); and Air Quality and GHG Expert Matt Hagemann CV (Exhibit C).

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EXHIBIT A

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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 8, 2021
Mitchell M. Tsai
155 South El Molino, Suite 104
Pasadena, CA 91101
Subject: Local Hire Requirements and Considerations for Greenhouse Gas Modeling Dear Mr. Tsai,
Soil Water Air Protection Enterprise (“SWAPE”) is pleased to provide the following draft technical report explaining the significance of worker trips required for construction of land use development projects with respect to the estimation of greenhouse gas (“GHG”) emissions. The report will also discuss the potential for local hire requirements to reduce the length of worker trips, and consequently, reduced or mitigate the potential GHG impacts.

Worker Trips and Greenhouse Gas Calculations
The California Emissions Estimator Model (“CalEEMod”) is a “statewide land use emissions computer model designed to provide a uniform platform for government agencies, land use planners, and environmental professionals to quantify potential criteria pollutant and greenhouse gas (GHG) emissions associated with both construction and operations from a variety of land use projects.”1 CalEEMod quantifies construction-related emissions associated with land use projects resulting from off-road construction equipment; on-road mobile equipment associated with workers, vendors, and hauling; fugitive dust associated with grading, demolition, truck loading, and on-road vehicles traveling along paved and unpaved roads; and architectural coating activities; and paving.2
The number, length, and vehicle class of worker trips are utilized by CalEEMod to calculate emissions associated with the on-road vehicle trips required to transport workers to and from the Project site during construction.3 1 “California Emissions Estimator Model.” CAPCOA, 2017, available at: http://www.aqmd.gov/caleemod/home. 2 “California Emissions Estimator Model.” CAPCOA, 2017, available at: http://www.aqmd.gov/caleemod/home. 3 “CalEEMod User’s Guide.” CAPCOA, November 2017, available at: http://www.aqmd.gov/docs/defaultsource/caleemod/01_user-39-s-guide2016-3-2_15november2017.pdf?sfvrsn=4, p. 34.

Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 1846 of 2236 2 Specifically, the number and length of vehicle trips is utilized to estimate the vehicle miles travelled (“VMT”) associated with construction. Then, utilizing vehicle-class specific EMFAC 2014 emission factors, CalEEMod calculates the vehicle exhaust, evaporative, and dust emissions resulting from construction-related VMT, including personal vehicles for worker commuting.4
Specifically, in order to calculate VMT, CalEEMod multiplies the average daily trip rate by the average overall trip length (see excerpt below):
“VMTd = Σ(Average Daily Trip Rate i * Average Overall Trip Length i) n Where:
n = Number of land uses being modeled.”5
Furthermore, to calculate the on-road emissions associated with worker trips, CalEEMod utilizes the following equation (see excerpt below):
“Emissionspollutant = VMT * EFrunning,pollutant
Where:

Emissionspollutant = emissions from vehicle running for each pollutant VMT = vehicle miles traveled
EFrunning,pollutant = emission factor for running emissions.” 6 Thus, there is a direct relationship between trip length and VMT, as well as a direct relationship between VMT and vehicle running emissions. In other words, when the trip length is increased, the VMT and vehicle running emissions increase as a result. Thus, vehicle running emissions can be reduced by decreasing the average overall trip length, by way of a local hire requirement or otherwise.

Default Worker Trip Parameters and Potential Local Hire Requirements As previously discussed, the number, length, and vehicle class of worker trips are utilized by CalEEMod to calculate emissions associated with the on-road vehicle trips required to transport workers to and from the Project site during construction.7In order to understand how local hire requirements and associated worker trip length reductions impact GHG emissions calculations, it is important to consider the CalEEMod default worker trip parameters. CalEEMod provides recommended default values based on site-specific information, such as land use type, meteorological data, total lot acreage, project type and typical equipment associated with project type. If more specific project information is known, the user can change the default values and input projectspecific values, but the California Environmental Quality Act (“CEQA”) requires that such changes be justified by substantial evidence.8 The default number of construction-related worker trips is calculated by multiplying the 4 “Appendix A Calculation Details for CalEEMod.” CAPCOA, October 2017, available at: http://www.aqmd.gov/docs/defaultsource/caleemod/02_appendix-a2016-3-2.pdf?sfvrsn=6, p. 14-15. 5 “Appendix A Calculation Details for CalEEMod.” CAPCOA, October 2017, available at: http://www.aqmd.gov/docs/defaultsource/caleemod/02_appendix-a2016-3-2.pdf?sfvrsn=6, p. 23. 6 “Appendix A Calculation Details for CalEEMod.” CAPCOA, October 2017, available at: http://www.aqmd.gov/docs/defaultsource/caleemod/02_appendix-a2016-3-2.pdf?sfvrsn=6, p. 15. 7 “CalEEMod User’s Guide.” CAPCOA, November 2017, available at: http://www.aqmd.gov/docs/defaultsource/caleemod/01_user-39-s-guide2016-3-2_15november2017.pdf?sfvrsn=4, p. 34. 8 CalEEMod User Guide, available at: http://www.caleemod.com/, p. 1, 9.

Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 1847 of 2236 3 number of pieces of equipment for all phases by 1.25, with the exception of worker trips required for the building construction and architectural coating phases.9Furthermore, the worker trip vehicle class is a 50/25/25 percent mix of light duty autos, light duty truck class 1 and light duty truck class 2, respectively.”10 Finally, the default worker trip length is consistent with the length of the operational home-to-work vehicle trips.11 The operational home-to-work vehicle trip lengths are:
“[B]ased on the location and urbanization selected on the project characteristic screen. These values were supplied by the air districts or use a default average for the state. Each district (or county) also assigns trip lengths for urban and rural settings” (emphasis added). 12 Thus, the default worker trip length is based on the location and urbanization level selected by the User when modeling emissions. The below table shows the CalEEMod default rural and urban worker trip lengths by air basin (see excerpt below and Attachment A).13
Worker Trip Length by Air Basin
Air Basin Rural (miles) Urban (miles)
Great Basin Valleys 16.8 10.8
Lake County 16.8 10.8
Lake Tahoe 16.8 10.8
Mojave Desert 16.8 10.8
Mountain Counties 16.8 10.8
North Central Coast 17.1 12.3
North Coast 16.8 10.8
Northeast Plateau 16.8 10.8
Sacramento Valley 16.8 10.8
Salton Sea 14.6 11
San Diego 16.8 10.8
San Francisco Bay Area 10.8 10.8
San Joaquin Valley 16.8 10.8
South Central Coast 16.8 10.8
South Coast 19.8 14.7
Average 16.47 11.17
Minimum 10.80 10.80
Maximum 19.80 14.70
Range 9.00 3.90
9 “CalEEMod User’s Guide.” CAPCOA, November 2017, available at: http://www.aqmd.gov/docs/defaultsource/caleemod/01_user-39-s-guide2016-3-2_15november2017.pdf?sfvrsn=4, p. 34. 10 “Appendix A Calculation Details for CalEEMod.” CAPCOA, October 2017, available at:
http://www.aqmd.gov/docs/default-source/caleemod/02_appendix-a2016-3-2.pdf?sfvrsn=6, p. 15. 11 “Appendix A Calculation Details for CalEEMod.” CAPCOA, October 2017, available at:
http://www.aqmd.gov/docs/default-source/caleemod/02_appendix-a2016-3-2.pdf?sfvrsn=6, p. 14. 12 “Appendix A Calculation Details for CalEEMod.” CAPCOA, October 2017, available at:
http://www.aqmd.gov/docs/default-source/caleemod/02_appendix-a2016-3-2.pdf?sfvrsn=6, p. 21. 13 “Appendix D Default Data Tables.” CAPCOA, October 2017, available at: http://www.aqmd.gov/docs/defaultsource/caleemod/05_appendix-d2016-3-2.pdf?sfvrsn=4, p. D-84 – D-86.

Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 1848 of 2236 4 As demonstrated above, default rural worker trip lengths for air basins in California vary from 10.8- to 19.8- miles, with an average of 16.47 miles. Furthermore, default urban worker trip lengths vary from 10.8- to 14.7- miles, with an average of 11.17 miles. Thus, while default worker trip lengths vary by location, default urban worker trip lengths tend to be shorter in length. Based on these trends evident in the CalEEMod default worker trip lengths, we can reasonably assume that the efficacy of a local hire requirement is especially dependent upon the urbanization of the project site, as well as the project location.

Practical Application of a Local Hire Requirement and Associated Impact To provide an example of the potential impact of a local hire provision on construction-related GHG emissions, we estimated the significance of a local hire provision for the Village South Specific Plan (“Project”) located in the City of Claremont (“City”). The Project proposed to construct 1,000 residential units, 100,000-SF of retail space, 45,000-SF of office space, as well as a 50-room hotel, on the 24-acre site. The Project location is classified as Urban and lies within the Los Angeles-South Coast County. As a result, the Project has a default worker trip length of 14.7 miles.14 In an effort to evaluate the potential for a local hire provision to reduce the Project’s construction-related GHG emissions, we prepared an updated model, reducing all worker trip lengths to 10 miles (see Attachment B). Our analysis estimates that if a local hire provision with a 10-mile radius were to be implemented, the GHG emissions associated with Project construction would decrease by approximately 17% (see table below and Attachment C).

Local Hire Provision Net Change
Without Local Hire Provision
Total Construction GHG Emissions (MT CO2e) 3,623
Amortized Construction GHG Emissions (MT CO2e/year) 120.77 With Local Hire Provision
Total Construction GHG Emissions (MT CO2e) 3,024
Amortized Construction GHG Emissions (MT CO2e/year) 100.80 % Decrease in Construction-related GHG Emissions 17%
As demonstrated above, by implementing a local hire provision requiring 10 mile worker trip lengths, the Project could reduce potential GHG emissions associated with construction worker trips. More broadly, any local hire requirement that results in a decreased worker trip length from the default value has the potential to result in a reduction of construction-related GHG emissions, though the significance of the reduction would vary based on the location and urbanization level of the project site.

This serves as an example of the potential impacts of local hire requirements on estimated project-level GHG emissions, though it does not indicate that local hire requirements would result in reduced construction-related GHG emission for all projects. As previously described, the significance of a local hire requirement depends on the worker trip length enforced and the default worker trip length for the project’s urbanization level and location.
14 “Appendix D Default Data Tables.” CAPCOA, October 2017, available at: http://www.aqmd.gov/docs/defaultsource/caleemod/05_appendix-d2016-3-2.pdf?sfvrsn=4, p. D-85.

Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 1849 of 2236 5 Disclaimer
SWAPE has received limited discovery. Additional information may become available in the future; thus, we retain the right to revise or amend this report when additional information becomes available. Our professional services have been performed using that degree of care and skill ordinarily exercised, under similar circumstances, by reputable environmental consultants practicing in this or similar localities at the time of service. No other warranty, expressed or implied, is made as to the scope of work, work methodologies and protocols, site conditions, analytical testing results, and findings presented. This report reflects efforts which were limited to information that was reasonably accessible at the time of the work, and may contain informational gaps, inconsistencies, or otherwise be incomplete due to the unavailability or uncertainty of information obtained or provided by third parties.

Sincerely,
Matt Hagemann, P.G., C.Hg.

Paul E. Rosenfeld, Ph.D.

Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 1850 of 2236 Location Type Location Name Rural H-W
(miles)
Urban H-W
(miles)
Air Basin Great Basin 16.8 10.8
Air Basin Lake County 16.8 10.8
Air Basin Lake Tahoe 16.8 10.8
Air Basin Mojave Desert 16.8 10.8
Air Basin Mountain 16.8 10.8
Air Basin North Central 17.1 12.3
Air Basin North Coast 16.8 10.8
Air Basin Northeast 16.8 10.8
Air Basin Sacramento 16.8 10.8
Air Basin Salton Sea 14.6 11
Air Basin San Diego 16.8 10.8
Air Basin San Francisco 10.8 10.8
Air Basin San Joaquin 16.8 10.8
Air Basin South Central 16.8 10.8
Air Basin South Coast 19.8 14.7
Air District Amador County 16.8 10.8
Air District Antelope Valley 16.8 10.8
Air District Bay Area AQMD 10.8 10.8
Air District Butte County 12.54 12.54
Air District Calaveras 16.8 10.8
Air District Colusa County 16.8 10.8
Air District El Dorado 16.8 10.8
Air District Feather River 16.8 10.8
Air District Glenn County 16.8 10.8
Air District Great Basin 16.8 10.8
Air District Imperial County 10.2 7.3
Air District Kern County 16.8 10.8
Air District Lake County 16.8 10.8
Air District Lassen County 16.8 10.8
Air District Mariposa 16.8 10.8
Air District Mendocino 16.8 10.8
Air District Modoc County 16.8 10.8
Air District Mojave Desert 16.8 10.8
Air District Monterey Bay 16.8 10.8
Air District North Coast 16.8 10.8
Air District Northern Sierra 16.8 10.8
Air District Northern

16.8 10.8
Air District Placer County 16.8 10.8
Air District Sacramento 15 10
Attachment A

Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 1851 of 2236 Air District San Diego 16.8 10.8
Air District San Joaquin

16.8 10.8
Air District San Luis Obispo 13 13
Air District Santa Barbara 8.3 8.3
Air District Shasta County 16.8 10.8
Air District Siskiyou County 16.8 10.8
Air District South Coast 19.8 14.7
Air District Tehama County 16.8 10.8
Air District Tuolumne 16.8 10.8
Air District Ventura County 16.8 10.8
Air District Yolo/Solano 15 10
County Alameda 10.8 10.8
County Alpine 16.8 10.8
County Amador 16.8 10.8
County Butte 12.54 12.54
County Calaveras 16.8 10.8
County Colusa 16.8 10.8
County Contra Costa 10.8 10.8
County Del Norte 16.8 10.8
County El Dorado-Lake 16.8 10.8
County El Dorado- 16.8 10.8
County Fresno 16.8 10.8
County Glenn 16.8 10.8
County Humboldt 16.8 10.8
County Imperial 10.2 7.3
County Inyo 16.8 10.8
County Kern-Mojave 16.8 10.8
County Kern-San 16.8 10.8
County Kings 16.8 10.8
County Lake 16.8 10.8
County Lassen 16.8 10.8
County Los Angeles- 16.8 10.8
County Los Angeles- 19.8 14.7
County Madera 16.8 10.8
County Marin 10.8 10.8
County Mariposa 16.8 10.8
County Mendocino- 16.8 10.8
County Mendocino- 16.8 10.8
County Mendocino- 16.8 10.8
County Mendocino- 16.8 10.8
County Merced 16.8 10.8
County Modoc 16.8 10.8
County Mono 16.8 10.8
County Monterey 16.8 10.8
County Napa 10.8 10.8

Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 1852 of 2236 County Nevada 16.8 10.8
County Orange 19.8 14.7
County Placer-Lake 16.8 10.8
County Placer-Mountain 16.8 10.8
County Placer- 16.8 10.8
County Plumas 16.8 10.8
County Riverside- 16.8 10.8
County Riverside-

19.8 14.7
County Riverside-Salton 14.6 11
County Riverside-South 19.8 14.7
County Sacramento 15 10
County San Benito 16.8 10.8
County San Bernardino- 16.8 10.8
County San Bernardino- 19.8 14.7
County San Diego 16.8 10.8
County San Francisco 10.8 10.8
County San Joaquin 16.8 10.8
County San Luis Obispo 13 13
County San Mateo 10.8 10.8
County Santa Barbara-

8.3 8.3
County Santa Barbara-

8.3 8.3
County Santa Clara 10.8 10.8
County Santa Cruz 16.8 10.8
County Shasta 16.8 10.8
County Sierra 16.8 10.8
County Siskiyou 16.8 10.8
County Solano- 15 10
County Solano-San 16.8 10.8
County Sonoma-North 16.8 10.8
County Sonoma-San 10.8 10.8
County Stanislaus 16.8 10.8
County Sutter 16.8 10.8
County Tehama 16.8 10.8
County Trinity 16.8 10.8
County Tulare 16.8 10.8
County Tuolumne 16.8 10.8
County Ventura 16.8 10.8
County Yolo 15 10
County Yuba 16.8 10.8
Statewide Statewide 16.8 10.8

Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 1853 of 2236 Air Basin Rural (miles) Urban (miles)
Great Basin Valleys 16.8 10.8
Lake County 16.8 10.8
Lake Tahoe 16.8 10.8
Mojave Desert 16.8 10.8
Mountain Counties 16.8 10.8
North Central Coast 17.1 12.3
North Coast 16.8 10.8
Northeast Plateau 16.8 10.8
Sacramento Valley 16.8 10.8
Salton Sea 14.6 11
San Diego 16.8 10.8
San Francisco Bay Area 10.8 10.8
San Joaquin Valley 16.8 10.8
South Central Coast 16.8 10.8
South Coast 19.8 14.7
Average 16.47 11.17
Mininum 10.80 10.80
Maximum 19.80 14.70
Range 9.00 3.90
Worker Trip Length by Air Basin

Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 1854 of 2236

1.1 Land Usage
Land Uses Size Metric Lot Acreage Floor Surface Area Population General Office Building 45.00 1000sqft 1.03 45,000.00 0 High Turnover (Sit Down Restaurant) 36.00 1000sqft 0.83 36,000.00 0 Hotel 50.00 Room 1.67 72,600.00 0
Quality Restaurant 8.00 1000sqft 0.18 8,000.00 0
Apartments Low Rise 25.00 Dwelling Unit 1.56 25,000.00 72 Apartments Mid Rise 975.00 Dwelling Unit 25.66 975,000.00 2789 Regional Shopping Center 56.00 1000sqft 1.29 56,000.00 0

1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
9 Wind Speed (m/s) 2.2 Precipitation Freq (Days) 33

1.3 User Entered Comments & Non-Default Data

1.0 Project Characteristics
Utility Company Southern California Edison
Operational Year 2028
CO2 Intensity
(lb/MWhr)
702.44 CH4 Intensity 0.029
(lb/MWhr)
N2O Intensity 0.006
(lb/MWhr)
Village South Specific Plan (Proposed)
Los Angeles-South Coast County, Annual
CalEEMod Version: CalEEMod.2016.3.2 Page 1 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual Attachment B

Project Characteristics - Consistent with the DEIR's model.

Land Use - See SWAPE comment regarding residential and retail land uses.

Construction Phase - See SWAPE comment regarding individual construction phase lengths.

Demolition - Consistent with the DEIR's model. See SWAPE comment regarding demolition.

Vehicle Trips - Saturday trips consistent with the DEIR's model. See SWAPE comment regarding weekday and Sunday trips.

Woodstoves - Woodstoves and wood-burning fireplaces consistent with the DEIR's model. See SWAPE comment regarding gas fireplaces.

Energy Use -
Construction Off-road Equipment Mitigation - See SWAPE comment on construction-related mitigation.

Area Mitigation - See SWAPE comment regarding operational mitigation measures.

Water Mitigation - See SWAPE comment regarding operational mitigation measures.

Table Name Column Name Default Value New Value
tblFireplaces FireplaceWoodMass 1,019.20 0.00
tblFireplaces FireplaceWoodMass 1,019.20 0.00
tblFireplaces NumberWood 1.25 0.00
tblFireplaces NumberWood 48.75 0.00
tblVehicleTrips ST_TR 7.16 6.17
tblVehicleTrips ST_TR 6.39 3.87
tblVehicleTrips ST_TR 2.46 1.39
tblVehicleTrips ST_TR 158.37 79.82
tblVehicleTrips ST_TR 8.19 3.75
tblVehicleTrips ST_TR 94.36 63.99
tblVehicleTrips ST_TR 49.97 10.74
tblVehicleTrips SU_TR 6.07 6.16
tblVehicleTrips SU_TR 5.86 4.18
tblVehicleTrips SU_TR 1.05 0.69
tblVehicleTrips SU_TR 131.84 78.27
CalEEMod Version: CalEEMod.2016.3.2 Page 2 of 44 Date: 1/6/2021 1:52 PM Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual