Agenda — Indio City Council, September 16, 2026 (part 17 of 17)

3.6 Paving - 2024
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0444 0.0257 0.3114 1.0000e0030.1141 8.8000e0040.1150 0.0303 8.1000e0040.0311 99.5045 99.5045 2.4700e00399.5663 Total 0.0444 0.0257 0.3114 1.0000e0030.1141 8.8000e0040.1150 0.0303 8.1000e0040.0311 99.5045 99.5045 2.4700e00399.5663 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 0.9882 9.5246 14.6258 0.0228 0.4685 0.4685 0.4310 0.4310 0.0000 2,207.547 2 2,207.547
2 0.7140 2,225.396
3 Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.9882 9.5246 14.6258 0.0228 0.4685 0.4685 0.4310 0.4310 0.0000 2,207.547 2 2,207.547
2 0.7140 2,225.396
3 Mitigated Construction On-Site
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3.7 Architectural Coating - 2024
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Archit. Coating 236.4115 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.1808 1.2188 1.8101 2.9700e0030.0609 0.0609 0.0609 0.0609 281.4481 281.4481 0.0159 281.8443 Total 236.5923 1.2188 1.8101 2.9700e0030.0609 0.0609 0.0609 0.0609 281.4481 281.4481 0.0159 281.8443 Unmitigated Construction On-Site
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3.7 Architectural Coating - 2024
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.4734 0.2743 3.3220 0.0107 1.2171 9.4300e0031.2266 0.3229 8.6800e0030.3315 1,061.381 8 1,061.381
8 0.0264 1,062.041
0 Total 0.4734 0.2743 3.3220 0.0107 1.2171 9.4300e0031.2266 0.3229 8.6800e0030.3315 1,061.381 8 1,061.381
8 0.0264 1,062.041
0 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Archit. Coating 236.4115 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.1808 1.2188 1.8101 2.9700e0030.0609 0.0609 0.0609 0.0609 0.0000 281.4481 281.4481 0.0159 281.8443 Total 236.5923 1.2188 1.8101 2.9700e0030.0609 0.0609 0.0609 0.0609 0.0000 281.4481 281.4481 0.0159 281.8443 Mitigated Construction On-Site
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4.0 Operational Detail - Mobile

4.1 Mitigation Measures Mobile

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ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Mitigated 9.5233 45.9914 110.0422 0.4681 45.9592 0.3373 46.2965 12.2950 0.3132 12.6083 47,917.80 05 47,917.80
05 2.1953 47,972.68
39 Unmitigated 9.5233 45.9914 110.0422 0.4681 45.9592 0.3373 46.2965 12.2950 0.3132 12.6083 47,917.80 05 47,917.80
05 2.1953 47,972.68
39 4.2 Trip Summary Information

4.3 Trip Type Information
Average Daily Trip Rate Unmitigated Mitigated
Land Use Weekday Saturday Sunday Annual VMT Annual VMT
Apartments Low Rise 145.75 154.25 154.00 506,227 506,227 Apartments Mid Rise 4,026.75 3,773.25 4075.50 13,660,065 13,660,065 General Office Building 288.45 62.55 31.05 706,812 706,812 High Turnover (Sit Down Restaurant) 2,368.80 2,873.52 2817.72 3,413,937 3,413,937 Hotel 192.00 187.50 160.00 445,703 445,703
Quality Restaurant 501.12 511.92 461.20 707,488 707,488 Regional Shopping Center 528.08 601.44 357.84 1,112,221 1,112,221 Total 8,050.95 8,164.43 8,057.31 20,552,452 20,552,452
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Miles Trip % Trip Purpose %
Land Use H-W or C-W H-S or C-C H-O or C-NW H-W or C-W H-S or C-C H-O or C-NW Primary Diverted Pass-by Apartments Low Rise 14.70 5.90 8.70 40.20 19.20 40.60 86 11 3 Apartments Mid Rise 14.70 5.90 8.70 40.20 19.20 40.60 86 11 3 General Office Building 16.60 8.40 6.90 33.00 48.00 19.00 77 19 4 High Turnover (Sit Down
Restaurant)

16.60 8.40 6.90 8.50 72.50 19.00 37 20 43
Hotel 16.60 8.40 6.90 19.40 61.60 19.00 58 38 4
Quality Restaurant 16.60 8.40 6.90 12.00 69.00 19.00 38 18 44 Regional Shopping Center 16.60 8.40 6.90 16.30 64.70 19.00 54 35 11

5.0 Energy Detail

5.1 Mitigation Measures Energy

4.4 Fleet Mix
Land Use LDA LDT1 LDT2 MDV LHD1 LHD2 MHD HHD OBUS UBUS MCY SBUS MH Apartments Low Rise 0.543088 0.044216 0.209971 0.116369 0.014033 0.006332 0.021166 0.033577 0.002613 0.001817 0.005285 0.000712 0.000821 Apartments Mid Rise 0.543088 0.044216 0.209971 0.116369 0.014033 0.006332 0.021166 0.033577 0.002613 0.001817 0.005285 0.000712 0.000821 General Office Building 0.543088 0.044216 0.209971 0.116369 0.014033 0.006332 0.021166 0.033577 0.002613 0.001817 0.005285 0.000712 0.000821 High Turnover (Sit Down
Restaurant)

0.543088 0.044216 0.209971 0.116369 0.014033 0.006332 0.021166 0.033577 0.002613 0.001817 0.005285 0.000712 0.000821 Hotel 0.543088 0.044216 0.209971 0.116369 0.014033 0.006332 0.021166 0.033577 0.002613 0.001817 0.005285 0.000712 0.000821 Quality Restaurant 0.543088 0.044216 0.209971 0.116369 0.014033 0.006332 0.021166 0.033577 0.002613 0.001817 0.005285 0.000712 0.000821 Regional Shopping Center 0.543088 0.044216 0.209971 0.116369 0.014033 0.006332 0.021166 0.033577 0.002613 0.001817 0.005285 0.000712 0.000821 Historical Energy Use: N
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ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
NaturalGas
Mitigated

0.7660 6.7462 4.2573 0.0418 0.5292 0.5292 0.5292 0.5292 8,355.983 2 8,355.983
2 0.1602 0.1532 8,405.638
7 NaturalGas
Unmitigated

0.7660 6.7462 4.2573 0.0418 0.5292 0.5292 0.5292 0.5292 8,355.983 2 8,355.983
2 0.1602 0.1532 8,405.638
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5.2 Energy by Land Use - NaturalGas
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr lb/day lb/day
Apartments Low
Rise
1119.16 0.0121 0.1031 0.0439 6.6000e0048.3400e0038.3400e0038.3400e0038.3400e003131.6662 131.6662 2.5200e0032.4100e003132.4486 Apartments Mid
Rise
35784.3 0.3859 3.2978 1.4033 0.0211 0.2666 0.2666 0.2666 0.2666 4,209.916 4 4,209.916
4 0.0807 0.0772 4,234.933
9 General Office
Building
1283.42 0.0138 0.1258 0.1057 7.5000e0049.5600e0039.5600e0039.5600e0039.5600e003150.9911 150.9911 2.8900e0032.7700e003151.8884 High Turnover (Sit
Down Restaurant)
22759.9 0.2455 2.2314 1.8743 0.0134 0.1696 0.1696 0.1696 0.1696 2,677.634 2 2,677.634
2 0.0513 0.0491 2,693.546
0 Hotel 4769.72 0.0514 0.4676 0.3928 2.8100e0030.0355 0.0355 0.0355 0.0355 561.1436 561.1436 0.0108 0.0103 564.4782 Quality
Restaurant
5057.75 0.0545 0.4959 0.4165 2.9800e0030.0377 0.0377 0.0377 0.0377 595.0298 595.0298 0.0114 0.0109 598.5658 Regional
Shopping Center
251.616 2.7100e0030.0247 0.0207 1.5000e0041.8700e0031.8700e0031.8700e0031.8700e00329.6019 29.6019 5.7000e0045.4000e00429.7778 Total 0.7660 6.7463 4.2573 0.0418 0.5292 0.5292 0.5292 0.5292 8,355.983 2 8,355.983
2 0.1602 0.1532 8,405.638
7 Unmitigated
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6.1 Mitigation Measures Area

6.0 Area Detail

1.11916 0.0121 0.1031 0.0439 6.6000e0048.3400e0038.3400e0038.3400e0038.3400e003131.6662 131.6662 2.5200e0032.4100e003132.4486 Apartments Mid
Rise

35.7843 0.3859 3.2978 1.4033 0.0211 0.2666 0.2666 0.2666 0.2666 4,209.916 4 4,209.916
4 0.0807 0.0772 4,234.933
9 General Office
Building

1.28342 0.0138 0.1258 0.1057 7.5000e0049.5600e0039.5600e0039.5600e0039.5600e003150.9911 150.9911 2.8900e0032.7700e003151.8884 High Turnover (Sit
Down Restaurant)

22.7599 0.2455 2.2314 1.8743 0.0134 0.1696 0.1696 0.1696 0.1696 2,677.634 2 2,677.634
2 0.0513 0.0491 2,693.546
0 Hotel 4.76972 0.0514 0.4676 0.3928 2.8100e0030.0355 0.0355 0.0355 0.0355 561.1436 561.1436 0.0108 0.0103 564.4782 Quality
Restaurant

5.05775 0.0545 0.4959 0.4165 2.9800e0030.0377 0.0377 0.0377 0.0377 595.0298 595.0298 0.0114 0.0109 598.5658 Regional
Shopping Center

0.251616 2.7100e0030.0247 0.0207 1.5000e0041.8700e0031.8700e0031.8700e0031.8700e00329.6019 29.6019 5.7000e0045.4000e00429.7778 Total 0.7660 6.7463 4.2573 0.0418 0.5292 0.5292 0.5292 0.5292 8,355.983 2 8,355.983
2 0.1602 0.1532 8,405.638
7 Mitigated
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ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Mitigated 30.5020 15.0496 88.4430 0.0944 1.5974 1.5974 1.5974 1.5974 0.0000 18,148.59 50 18,148.59
50 0.4874 0.3300 18,259.11
92 Unmitigated 30.5020 15.0496 88.4430 0.0944 1.5974 1.5974 1.5974 1.5974 0.0000 18,148.59 50 18,148.59
50 0.4874 0.3300 18,259.11
92 6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory lb/day lb/day
Architectural
Coating

2.2670 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products

24.1085 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Hearth 1.6500 14.1000 6.0000 0.0900 1.1400 1.1400 1.1400 1.1400 0.0000 18,000.00 00 18,000.00
00 0.3450 0.3300 18,106.96
50 Landscaping 2.4766 0.9496 82.4430 4.3600e0030.4574 0.4574 0.4574 0.4574 148.5950 148.5950 0.1424 152.1542 Total 30.5020 15.0496 88.4430 0.0944 1.5974 1.5974 1.5974 1.5974 0.0000 18,148.59 50 18,148.59
50 0.4874 0.3300 18,259.11
92 Unmitigated
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8.1 Mitigation Measures Waste

7.1 Mitigation Measures Water

7.0 Water Detail

8.0 Waste Detail

6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory lb/day lb/day
Architectural
Coating

2.2670 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products

9.0 Operational Offroad
Equipment Type Number Hours/Day Days/Year Horse Power Load Factor Fuel Type

10.0 Stationary Equipment
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11.0 Vegetation
Fire Pumps and Emergency Generators
Equipment Type Number Hours/Day Hours/Year Horse Power Load Factor Fuel Type Boilers
Equipment Type Number Heat Input/Day Heat Input/Year Boiler Rating Fuel Type User Defined Equipment
Equipment Type Number
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Total Construction GHG Emissions (MT CO2e) 3,623
Amortized (MT CO2e/year) 120.77
Total Construction GHG Emissions (MT CO2e) 3,024
Amortized (MT CO2e/year) 100.80
% Decrease in Construction-related GHG Emissions 17%
Local Hire Provision Net Change
With Local Hire Provision
Without Local Hire Provision
Attachment C Page 1076 of 1229 AGENDA ITEM #12.2
Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 2083 of 2236

EXHIBIT B

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SOIL WATER AIR PROTECTION ENTERPRISE
2656 29th Street, Suite 201
Santa Monica, California 90405
Attn: Paul Rosenfeld, Ph.D.

Mobil: (310) 795-2335
Office: (310) 452-5555
Fax: (310) 452-5550
Email: [email protected]

Paul E. Rosenfeld, Ph.D. Page 1 of 10 June 2019
Paul Rosenfeld, Ph.D. Chemical Fate and Transport & Air Dispersion Modeling Principal Environmental Chemist Risk Assessment & Remediation Specialist Education
Ph.D. Soil Chemistry, University of Washington, 1999. Dissertation on volatile organic compound filtration.

M.S. Environmental Science, U.C. Berkeley, 1995. Thesis on organic waste economics.

B.A. Environmental Studies, U.C. Santa Barbara, 1991. Thesis on wastewater treatment.

Professional Experience

Dr. Rosenfeld has over 25 years’ experience conducting environmental investigations and risk assessments for evaluating impacts to human health, property, and ecological receptors. His expertise focuses on the fate and transport of environmental contaminants, human health risk, exposure assessment, and ecological restoration. Dr.

Rosenfeld has evaluated and modeled emissions from unconventional oil drilling operations, oil spills, landfills, boilers and incinerators, process stacks, storage tanks, confined animal feeding operations, and many other industrial and agricultural sources. His project experience ranges from monitoring and modeling of pollution sources to evaluating impacts of pollution on workers at industrial facilities and residents in surrounding communities.

Dr. Rosenfeld has investigated and designed remediation programs and risk assessments for contaminated sites containing lead, heavy metals, mold, bacteria, particulate matter, petroleum hydrocarbons, chlorinated solvents, pesticides, radioactive waste, dioxins and furans, semi- and volatile organic compounds, PCBs, PAHs, perchlorate, asbestos, per- and poly-fluoroalkyl substances (PFOA/PFOS), unusual polymers, fuel oxygenates (MTBE), among other pollutants. Dr. Rosenfeld also has experience evaluating greenhouse gas emissions from various projects and is an expert on the assessment of odors from industrial and agricultural sites, as well as the evaluation of odor nuisance impacts and technologies for abatement of odorous emissions. As a principal scientist at SWAPE, Dr. Rosenfeld directs air dispersion modeling and exposure assessments. He has served as an expert witness and testified about pollution sources causing nuisance and/or personal injury at dozens of sites and has testified as an expert witness on more than ten cases involving exposure to air contaminants from industrial sources.

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Paul E. Rosenfeld, Ph.D. Page 2 of 10 June 2019
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:

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.

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.

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Paul E. Rosenfeld, Ph.D. Page 3 of 10 June 2019
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.

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.

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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., 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.

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.

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Rosenfeld, P. E. (October 15-18, 2007). Somerville Community Exposure To Contaminants From Wood Treatment Facility Emissions. The 23rd Annual International Conferences on Soils Sediment and Water. Lecture conducted from University of Massachusetts, Amherst MA.

Rosenfeld P. E. (March 2007). Production, Chemical Properties, Toxicology, & Treatment Case Studies of 1,2,3- Trichloropropane (TCP). The Association for Environmental Health and Sciences (AEHS) Annual Meeting. Lecture conducted from San Diego, CA.

Rosenfeld P. E. (March 2007). Blood and Attic Sampling for Dioxin/Furan, PAH, and Metal Exposure in Florala, Alabama. The AEHS Annual Meeting. Lecture conducted from San Diego, CA.

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

Hensley A.R., Scott, A., Rosenfeld P.E., Clark, J.J.J. (November 4-8, 2006). Dioxin Containing Attic Dust And Human Blood Samples Collected Near A Former Wood Treatment Facility. APHA 134 Annual Meeting & Exposition. Lecture conducted from Boston Massachusetts.

Paul Rosenfeld Ph.D. (October 24-25, 2005). Fate, Transport and Persistence of PFOA and Related Chemicals.

Mealey’s C8/PFOA. Science, Risk & Litigation Conference. Lecture conducted from The Rittenhouse Hotel, Philadelphia, PA.

Paul Rosenfeld Ph.D. (September 19, 2005). Brominated Flame Retardants in Groundwater: Pathways to Human Ingestion, Toxicology and Remediation PEMA Emerging Contaminant Conference. Lecture conducted from Hilton Hotel, Irvine California.

Paul Rosenfeld Ph.D. (September 19, 2005). Fate, Transport, Toxicity, And Persistence of 1,2,3-TCP. PEMA Emerging Contaminant Conference. Lecture conducted from Hilton Hotel in Irvine, California.

Paul Rosenfeld Ph.D. (September 26-27, 2005). Fate, Transport and Persistence of PDBEs. Mealey’s Groundwater Conference. Lecture conducted from Ritz Carlton Hotel, Marina Del Ray, California.

Paul Rosenfeld Ph.D. (June 7-8, 2005). Fate, Transport and Persistence of PFOA and Related Chemicals.

International Society of Environmental Forensics: Focus On Emerging Contaminants. Lecture conducted from Sheraton Oceanfront Hotel, Virginia Beach, Virginia.

Paul Rosenfeld Ph.D. (July 21-22, 2005). Fate Transport, Persistence and Toxicology of PFOA and Related Perfluorochemicals. 2005 National Groundwater Association Ground Water And Environmental Law Conference.

Lecture conducted from Wyndham Baltimore Inner Harbor, Baltimore Maryland.

Paul Rosenfeld Ph.D. (July 21-22, 2005). Brominated Flame Retardants in Groundwater: Pathways to Human Ingestion, Toxicology and Remediation. 2005 National Groundwater Association Ground Water and Environmental Law Conference. Lecture conducted from Wyndham Baltimore Inner Harbor, Baltimore Maryland.

Paul Rosenfeld, Ph.D. and James Clark Ph.D. and Rob Hesse R.G. (May 5-6, 2004). Tert-butyl Alcohol Liability and Toxicology, A National Problem and Unquantified Liability. National Groundwater Association. Environmental Law Conference. Lecture conducted from Congress Plaza Hotel, Chicago Illinois.

Paul 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.

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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.

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.

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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.

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

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Deposition and/or Trial Testimony:

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, Plaintiffs, 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.: 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.: No. BC646857
Rosenfeld Deposition, 10-6-2018; Trial 3-7-19

In United States District Court For The District of Colorado Bells et al. Plaintiff 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., Plaintiffs 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 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 Number: 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.: 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 Iowa District Court For Wapello County
Jerry Dovico, et al., Plaintiffs vs. Valley View Sine LLC, et al., Defendants Law No,: LALA105144 - Division A
Rosenfeld Deposition, August 2015
In The Iowa District Court For Wapello County
Doug Pauls, et al.,, et al., Plaintiffs vs. Richard Warren, et al., Defendants Law No,: LALA105144 - Division A
Rosenfeld Deposition, August 2015
In The Circuit Court of Ohio County, West Virginia
Robert Andrews, et al. v. Antero, et al.

Civil Action N0. 14-C-30000
Rosenfeld Deposition, June 2015
In The Third Judicial District County of Dona Ana, New Mexico Betty Gonzalez, et al. Plaintiffs vs. Del Oro Dairy, Del Oro Real Estate LLC, Jerry Settles and Deward DeRuyter, Defendants
Rosenfeld Deposition: July 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 Number CACE07030358 (26)
Rosenfeld Deposition: December 2014
In the United States District Court Western District of Oklahoma Tommy McCarty, et al., Plaintiffs, v. Oklahoma City Landfill, LLC d/b/a Southeast Oklahoma City Landfill, et al. Defendants.

Case No. 5:12-cv-01152-C
Rosenfeld Deposition: July 2014

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In the County Court of Dallas County Texas
Lisa Parr et al, Plaintiff, vs. Aruba et al, Defendant.

Case Number 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 Number: 2008 CT 10 0741 (Cons. w/ 2009 CV 10 0987) Rosenfeld Deposition: October 2012
In the United States District Court of Southern District of Texas Galveston Division Kyle Cannon, Eugene Donovan, Genaro Ramirez, Carol Sassler, and Harvey Walton, each Individually and on behalf of those similarly situated, Plaintiffs, vs. BP Products North America, Inc., Defendant.

Case 3:10-cv-00622
Rosenfeld Deposition: February 2012
Rosenfeld Trial: April 2013
In the Circuit Court of Baltimore County Maryland
Philip E. Cvach, II et al., Plaintiffs vs. Two Farms, Inc. d/b/a Royal Farms, Defendants Case Number: 03-C-12-012487 OT
Rosenfeld Deposition: September 2013

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EXHIBIT C

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Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 2095 of 2236 1640 5th St.., Suite 204 Santa
Santa Monica, California 90401
Tel: (949) 887‐9013
Email: [email protected]
Matthew F. Hagemann, P.G., C.Hg., QSD, QSP
Geologic and Hydrogeologic Characterization
Industrial Stormwater Compliance
Investigation and Remediation Strategies
Litigation Support and Testifying Expert
CEQA Review
Education:

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

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

Professional Certifications:

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

Matt has 25 years of experience in environmental policy, assessment and remediation. 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) while also working with permit holders to improve hydrogeologic characterization and water quality monitoring.

Matt has worked closely with U.S. EPA legal counsel and the technical staff of several states in the application and enforcement of RCRA, Safe Drinking Water Act and Clean Water Act regulations. Matt has trained the technical staff in the States of California, Hawaii, Nevada, Arizona and the Territory of Guam in the conduct of investigations, groundwater fundamentals, and sampling techniques.

Positions Matt has held include:
• Founding Partner, Soil/Water/Air Protection Enterprise (SWAPE) (2003 – present); • Geology Instructor, Golden West College, 2010 – 2014; • Senior Environmental Analyst, Komex H2O Science, Inc. (2000 ‐‐ 2003);

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• 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 100 environmental impact reports since 2003 under CEQA that identify significant issues with regard to hazardous waste, water resources, water quality, air quality, Valley Fever, 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 industrial facilities. • Manager of a project to provide technical assistance to a community adjacent to a former Naval shipyard under a grant from the U.S. EPA.
• Technical assistance and litigation support for vapor intrusion concerns. • Lead analyst and testifying expert in the review of environmental issues in license applications for large 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.
• Expert witness on two cases involving MTBE litigation. • Expert witness and litigation support on the impact of air toxins and hazards at a school. • Expert witness in litigation at a former plywood plant.

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. • Senior researcher in the development of a comprehensive, electronically interactive chronology of MTBE use, research, and regulation.
• Senior researcher 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.
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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 hearings, and responded to public comments from residents who were very concerned about the impact of designation.
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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 principles into the policy‐making process.
• Established national protocol for the peer review of scientific documents. 5

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Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 2100 of 2236 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 taught physical geology (lecture and lab and introductory geology at Golden West College in Huntington Beach, California from 2010 to 2014.

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).

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

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Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 2101 of 2236 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.

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

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Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 2102 of 2236 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 Water 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 Characterization and Cleanup 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. 8

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Other Experience:

Selected as subject matter expert for the California Professional Geologist licensing examination, 2009‐ 2011.
9

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Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 2105 of 2236 June 3, 2026
Indio Planning Commission
c/o Community Development Department, Planning Division 100 Civic Center Drive
Indio, CA 92201
Submitted via [email protected] and for the record
Dear Chair and Members of the Planning Commission:

I write to express my deep concern about the significant and unavoidable environmental impacts disclosed in the Environmental Impact Report for the Oasis at Indio project, and to urge the Commission not to recommend certification of the EIR, adoption of the CEQA findings, or adoption of the proposed statement of overriding considerations as presently drafted.

The EIR acknowledges that the Oasis at Indio project will result in impacts to air quality and greenhouse gas emissions that cannot be mitigated to a level below significance. These are not minor or technical conclusions. Under CEQA, a finding that impacts are “significant and unavoidable” is a serious admission that the project, as designed, will cause lasting harm to the health and environment of this community—harm that no proposed condition fully cures.

My specific concerns are as follows:

First, the adequacy of mitigation. Before the Commission accepts that these impacts are truly unavoidable, the record should demonstrate that every feasible mitigation measure has been required and made enforceable—not merely encouraged or deferred. I ask the Commission to confirm that the proposed mitigation measures are mandatory, fully funded, monitored, and reportable, rather than aspirational.

Second, the feasibility of alternatives. CEQA requires that decision-makers reject project alternatives only upon substantial evidence that they are infeasible. I am concerned that a reduced-intensity or reconfigured alternative could lessen the air quality and greenhouse gas impacts while still meeting most project objectives. The Commission should not recommend approval until the record contains specific, evidence-based findings explaining why each environmentally superior alternative was rejected.

Third, the standard for overriding considerations. A statement of overriding considerations is permissible only where the lead agency identifies specific economic, legal, social, or other benefits that genuinely outweigh the unavoidable environmental harms, supported by substantial evidence. Given the scale of the disclosed air quality and greenhouse gas impacts, and their direct bearing on public health in a region already burdened by poor air quality, I do not believe the benefits asserted are sufficient to override these harms. At

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I recognize that the Commission’s role is to make a recommendation to the City Council. For that reason, the recommendation you forward carries real weight, and the concerns raised on this record will frame the Council’s eventual decision. I respectfully ask that you decline to recommend the findings as drafted, and instead direct staff and the applicant to strengthen enforceable mitigation and to more rigorously evaluate feasible, lower-impact alternatives.

Thank you for your service to our community and for considering these comments.

Respectfully,
Barry Fisher
, Indio, CA 92203
Sent from my iPhone

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Concerned citizen
Christiane Glasner
Sent from my Galaxy

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Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 2114 of 2236 quality due to its proximity to the freeway. With the addition of this immense project, my community and many others in the area will face even greater environmental impacts with the increased traffic from the housing and warehouses these project includes.

On top of the environmental impacts, this project includes other concerning economic issues:

Market rate housing As costs continue to rise, the people of Indio would be priced out of our own neighborhoods if we tried to buy today. The median value of a home is $458,000 according to Census data. Market rate housing, especially as those market rates drastically increase, will exacerbate the City’s and Valley’s desperate need for affordable housing.

Service and other working class jobs The project promises jobs. However, as with other projects in Indio and across the Valley, these jobs are primarily focused in the service industry or other working class jobs that use residents’ working power to run these projects with minimum pay. This leads to more and more residents being priced out of their own communities. In Indio, the median household income is about $77,000 and the median per capita income is about $35,000 also according to the Census. The median cost of a home is almost SIX times that of the median household income and almost 13 times that of the median per capita income. We need jobs that offer opportunities for growth and improved economic positions. We do not need more jobs that use the people as servants for the wealthy.

Market rate housing paired with service industry and other working class jobs as cost of living in general increases is not what the current average residents of Indio need. The Oasis at Indio project is not geared toward the betterment of the people of Indio. It will bring undeniable environmental impacts as stated in its own environmental report. It will contribute to the lack of affordable housing the City of Indio desperately needs. It will continue to contribute to the lack of jobs with opportunity for growth and professional level jobs that pay a livable wage. All of which will place a heavier burden on current residents that, like myself, have lived our whole or much of our lives in the City of Indio, but must consider the prospect of moving out of the city because the lack of affordability.

I love Indio, and I want an Indio that is built with me and my loved ones in mind. For these reasons and many others, I urge the Planning Commission to reject this project, and instead focus on projects that benefit the current needs of the community and are designed with the current residents of Indio in mind. It is what the community here now deserves.

Appreciatively,
Allyson Jeffredo

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Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 2116 of 2236 area impacts commuters, families, and emergency response times. Adding heavy warehouse traffic without first addressing infrastructure capacity is irresponsible planning.

Second, this project will increase pollution and negatively impact air quality in our community. The expected increase in semi-truck traffic will bring more diesel emissions, noise, and environmental impacts to nearby neighborhoods, schools, and parks. Residents should not have to bear additional health and quality-of-life burdens from industrial expansion.

Third, the project fails to reflect the needs and priorities of working families in Indio. For years, residents have asked city leaders for more family-friendly amenities, recreational spaces, entertainment options, and community-serving development. Instead, this proposal prioritizes another industrial warehouse project that does not improve daily life for local families or children.

Finally, the public deserves transparency regarding this development. Who will be the tenant occupying this warehouse space? If the project is beneficial to the community, there should be no reason to withhold that information. Residents have a right to know which company will operate this facility and what long-term impacts it may bring to Indio.

I urge the City to delay or reject approval of this project until traffic infrastructure is adequately addressed, environmental concerns are fully evaluated, and the community’s priorities are genuinely considered.

Thank You,
Nicole Arciga
Sent from my iPhone

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Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 2118 of 2236 Second, this project will increase pollution and negatively impact air quality in our community. The expected increase in semi-truck traffic will bring more diesel emissions, noise, and environmental impacts to nearby neighborhoods, schools, and parks. Residents should not have to bear additional health and quality-of-life burdens from industrial expansion.

Sincerely,
Jose Arciga
Concerned Indio Resident

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Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 2134 of 2236 To the Indio Planning Commission,
My name is Nancy Reyes, and I am an Indio resident and homeowner living near Richard Oliphant Elementary School, which is located nearly across from the proposed Oasis at Indio development site. I am writing to express both my support and concerns regarding this project.

First, I want to acknowledge that our region urgently needs additional housing, especially multi-family and more affordable housing opportunities. I strongly support the residential component of this project, including the proposed 3,240 multi-family residential units. Housing affordability and availability continue to be major challenges throughout the Coachella Valley, and I appreciate efforts to address those needs.

However, I am deeply concerned about the proposal for approximately 1.8 million square feet of light industrial development and the long-term impacts this could have on our infrastructure, environment, public health, and overall quality of life.

As someone who regularly uses the Monroe Street and Jackson Street freeway interchanges, I can confidently say that the surrounding infrastructure already does not meet the current needs of our growing community. During peak evening commute hours, it is common to wait through multiple light cycles simply to exit the freeway or make a left turn at Monroe Street. Jackson Street experiences similar congestion issues. These are not future concerns; they are existing daily realities for residents.

While I understand there are plans to widen the Monroe Street bridge and improve infrastructure, those improvements are still years away and, in my opinion, will still struggle to adequately support current traffic demand, let alone the substantial increase that would result from adding 1.8 million square feet of industrial uses.

Even if described as “light industrial,” development at this scale has the potential to dramatically increase:
• Truck traffic and freight movement
• Diesel emissions and air pollution
• Noise pollution
• Traffic congestion
• Heat island effects
• Strain on roads and public infrastructure
• Safety concerns for surrounding neighborhoods
I am particularly concerned that industrial uses could eventually evolve into warehouse, logistics, or distribution-oriented operations that generate high levels of truck traffic near residential neighborhoods and schools.

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Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 2135 of 2236 The Coachella Valley already struggles with poor air quality and extreme heat conditions, and additional industrial activity could further worsen environmental and public health impacts for residents. This concern becomes even more significant considering the project’s proximity to future housing. It is difficult to reconcile the vision of creating a walkable, community-oriented environment while simultaneously introducing an industrial footprint of this magnitude directly adjacent to residential development.

I am also concerned about the cumulative environmental impacts associated with this proposal, including:
• Increased greenhouse gas emissions
• Reduced air quality
• Additional stress on water resources during ongoing drought conditions • Increased pavement and reduced natural cooling areas in a desert climate already vulnerable to extreme heat
• Potential impacts on vulnerable populations, including children, seniors, and working-class families who may live nearby
Water usage is another major concern that I do not believe should be overlooked. Large-scale industrial development in the desert raises serious questions about long-term sustainability and resource management, especially as California continues to face drought concerns and increasing pressure on water infrastructure. Future growth in Indio should prioritize sustainable land uses that align with the environmental realities of living in the desert.

I am also deeply concerned about public safety and emergency access. Traffic congestion at the Monroe and Jackson interchanges is already severe during normal commuting hours. In the event of a wildfire, major traffic collision, extreme weather event, or other emergency requiring evacuation or rapid emergency response, additional industrial traffic could create dangerous bottlenecks and significantly impact emergency access for residents and first responders.

Infrastructure improvements should be proactive, not reactive. Major transportation and roadway improvements should be fully addressed before approving industrial development at this scale, not years afterward once residents are already dealing with worsening congestion and environmental impacts.

I strongly encourage the Planning Commission and City Council to reconsider or significantly reduce the industrial component of this project and instead prioritize development that better aligns with the longterm needs of our community, including:
• Additional housing
• Mixed-use and neighborhood-serving commercial development • Open space and landscaping

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Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 2136 of 2236 • Community amenities
• Walkability and bike connectivity
• Sustainable and environmentally responsible planning
The Coachella Valley is growing rapidly, and growth itself is not the issue. The issue is ensuring that development is balanced, sustainable, and compatible with the infrastructure and environmental realities of our region.

I respectfully ask the City to prioritize housing and community-focused development over large-scale industrial expansion at this location and to carefully consider the long-term consequences this project could have on residents, traffic, air quality, public safety, water resources, and quality of life for years to come.

Thank you for your time and consideration.

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Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 2138 of 2236 the site daily. There are no limits on the hours of operation for industrial and commercial uses. Diesel emissions are a major contributor to the formation of ozone, which can be significantly harmful to public health.

Health care, virtually all of which is located south of the Interstate 10 Freeway, is already inadequate for North Indio. As it is, we only have one small Urgent Care, one small Firehouse and no Police Station. It is frightening and alarming to speculate how much our community will be severely impacted by the added congestion, respiratory related problems, and poor emergency access to facilities.

I am not against growth, but this project needs to be curtailed dramatically to address the adverse environmental and health-related impact to the community.

Sincerely,
Janet Boland

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Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 2146 of 2236 Please do not change the existing zoning and do reflect upon the continuation of building a bright Indio.

The proposed Oasis development is far from being an “oasis” for our overall Indio community.

Sincerely
Jim and Colleen Spahr

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Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 2153 of 2236 proposed project also states it would include space for businesses. What would actually happen is the space wouldn't be built and they would make the warehouse too big. A developer offering false promises and breaking them is all too familiar. Think of the people that live in this beautiful city and how we need more housing to lower the cost of living. You could double the housing on the site with a different developer and keep the air clean. So, please don't approve this project.

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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

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August 5, 2024

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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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August 5, 2024

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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 2172 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 2174 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,

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Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 2175 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.

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Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 2176 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.

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Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 2177 of 2236 Attachment A: Matt Hagemann CV
Attachment B: Paul Rosenfeld CV

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Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 2178 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

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Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 2179 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.

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Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 2180 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:

Hydrogeology:

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Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 2181 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.

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

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

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Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 2182 of 2236 5 principles into the policy‐making process.
• Established national protocol for the peerreview of scientific documents.

Geology:

Teaching:

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.

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Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 2183 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., 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.

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Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 2184 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., 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., 1993. U.S. EPA Policy on the Technical Impracticability of the Cleanup of DNAPL‐ contaminated Groundwater. California Groundwater Resources Association Meeting.

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Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 2185 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 2187 of 2236 Paul E. Rosenfeld, Ph.D. Page 2 of 12 October 2022
Professional History:

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.

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.

Procedia Environmental Sciences. 113–125.

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.

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Public Hearing to Consider Denial or Approval of the Oasis at Indio Proj... Page 2188 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.