2023-11-13_item_5.3_continued_discussion_from_october_9_2023_for_cup_23-08_spr_23-09_ashley_furniture_project — Lathrop City Council, November 13, 2023 (part 1 of 2)

ITEM 5. 3

CITY MANAGER' S REPORT
NOVEMBER 13, 2023 CITY COUNCIL REGULAR MEETING
ITEM: CONTINUED DISCUSSION FROM OCTOBER 9, 2023

REGULAR MEETING REGARDING CONDITIONAL USE
PERMIT NO. CUP- 23- 08 AND SITE PLAN REVIEW NO.

SPR- 23- 09 FOR THE ASHLEY FURNITURE PROJECT
RECOMMENDATION: Council to Consider the Following:

1. Testimony Presented During the Public Hearing
Held October 9, 2023;

2. Adopt a Resolution to Find the Project Exempt
from Further Environmental Review Pursuant to
Public Resources Code Section 21083. 3 and
California Environmental Quality Act ( CEQA)
Guidelines Section 15183; and

3. Adopt a Resolution to Approve a Conditional Use
Permit and Site Plan Review for the Ashley
Furniture Project to Allow for the Construction of
an Approximately 1. 5 Million Square Foot
Concrete Tilt- Up Building Located within the
Central Lathrop Specific Plan Phase 2 Area.

SUMMARY:

The applicant, Hodgdon Group Realty, Inc., is requesting a Conditional Use Permit and Site Plan Review to allow for the development of a 1, 486, 607 sq. ft. concrete tiltup building on an 89. 82- acre property located at the northwest corner of Dos Reis Road and Manthey Road and within the Central Lathrop Specific Plan Phase 2 area.

The proposed building will include a 24, 000 sq. ft. office, a 110, 260 sq. ft. retail outlet and showroom and a 1, 352, 347 sq. ft. warehouse distribution center.

The project includes related on- and off-site improvements, including but not limited to off- street parking, lighting, landscaping, solid wall and wrought iron fencing, outdoor employee break area, paving, and street improvements ( landscaping, curb, gutter, and sidewalk).

The Planning Commission and staff recommend that City Council consider all information provided and submitted, take and consider all public testimony and, if determined to be appropriate, adopt a Resolution to find the project exempt from further environmental review pursuant to Public Resources Code Section 21083. 3 and California Environmental Quality Act ( CEQA) Guidelines Section 15183 and adopt a Resolution to approve the Conditional Use Permit ( CUP- 23- 08) and Site Plan Review SPR- 23- 09) for the Ashley Furniture Project.

CITY MANAGERS REPORT PAGE 2
NOVEMBER 13, 2023 CITY COUNCIL REGULAR MEETING
ASHLEY FURNITURE PR07ECT
SITE DESCRIPTION:

The project site is located at the northwest corner of Dos Reis Road and Manthey Road, north of terminus of Golden Valley Parkway at Dos Reis Road. The property address is 14101 S. Manthey Road and has an Accessor Parcel Number ( APN) of 192- 020- 14). The project site is 89. 82- acres in size and is generally flat and historically been used for agricultural purposes. The site has been planned for urban development and is within the CLSP Phase 2 area. Planned infrastructure extensions will be constructed to the site for public water, sewer and stormwater. The City' s General Plan designates the project site for Light Industrial ( LI) land uses, and will be zoned IL- CL, Limited Industrial. The project site is bounded by agricultural properties to the north, Manthey Road and Interstate 5 ( I- 5) to the east, Dos Reis Road and ranchette properties to the south and agricultural properties to the west.

The table below depicts the surrounding land uses of the project site:

Land Use Zoning District General Plan ( GP)
Desi nation
North
Agricultural Properties, IL- CL, Limited LI- CL, Limited Industrial Cit of Lathro ond Industrial
Vacant Properties and CO/ DS- CL, OC- CL, Office
Ranchette Properties Commercial Office Commercial, and R/ MUSouth Dos Reis Road R/ MU/ DS- CL, CL, Residential Mixed
Residential/ Mixed Use
Use
Manthey Road and CC, Central CC, Central commercial
Interstate 5 Commercial, R- 1- 5 and LD, Low Density
One Family Residential ( across I- 5
East
Residential Highway)
R- 1- 5, R One
Family Residential
across I- 5
Hi hwa
West
Agricultural Properties IL- CL, Limited LI- CL, Limited Industrial Industrial
CITY MANAGERS REPORT PAGE 3
NOVEMBER 13, 2023 CITY COUNCIL REGULAR MEETING
ASHLEY FURNITURE PRO.IECT
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BACKGROU N D:

The existing Ashley Furniture Outlet and Distribution Warehouse facility is located within the Crossroads Industrial area at 18290 S. Harlan Road ( APN: 198- 130- 39), just north of the Home Depot Distribution Center. The 525, 000 sq. ft. sq. ft. concrete tilt- up building was constructed in 2018 and includes a 50, 000 sq. ft. retail outlet and distribution warehouse.

The Ashley Furniture Outlet and Warehouse serves as an Ashley Homestore and Outlet and distribution center. The facility will serve Northern California and adjacent States with regional offices and a call center. The applicant informed staff that Ashley Furniture' s business operation has outgrown its existing facility on S. Harlan Road, and it is expected that the facility will be unable to accommodate the future operations anticipated for the company. As such, the proposed project will support the expansion needs of the company. Upon completion of the proposed project and relocation of the company to the new site, it is anticipated that subject to market conditions, the S. Harlan Road site will be completely vacated and listed for lease or sale.

CITY MANAGERS REPORT PAGE 4
NOVEMBER 13, 2023 CITY COUNCIL REGULAR MEETING

ASHLEY FURNITURE PROJECT
The proposed project is located within the Central Lathrop Specific Plan ( CLSP) Phase 2 area. The CLSP was approved by the City Council on November 9, 2004. The project included certification of the Environmental Impact Report ( EIR) ( SCH# 2003072132), for the CLSP, adoption of the Specific Plan document, General Plan Land Use Map amendments, Zoning Map, and text amendments to the Lathrop Municipal Code ( LMC). The CLSP is separated into two ( 2) major phases of development. Phase 1 is generally located south of Dos Reis Road and includes a High School, development of a regional park ( adjacent to the High School), residential and commercial uses. Phase 2 is located north of Dos Reis Road and previously included development of residential and commercial uses, parks, and school sites ( K8).

The Lathrop General Plan Update in 2022 ( adopted by City Council on September 19, 2022) modified the Phase 2 area ( north of Dos Reis Road to the City limit boundary) of the CLSP from Residential and Commercial Land Use Designations to Limited Industrial. As a result of the newly adopted General Plan, the City is also initiating an update to the Lathrop Municipal Code and Zoning Map to bring both into consistency with the General Plan. An Amendment to the CLSP for Phase 2 is being processed by the City concurrently with the proposed Ashley Furniture Project. The Amendment would update the Specific Plan to provide development standards and design guidelines for the development of limited industrial uses to be consistent with the intent of the recently assigned Limited Industrial General Plan Land Use Designation.

As such, all aspects of the proposed project have been reviewed in relationship to the Central Lathrop Specific Plan Phase 2 design criteria illustrated in Chapter 7, " Design Guidelines" of the Specific Plan Amendment.

PLANNING COMMISSION:

On September 13, 2023, the Planning Commission held a public hearing on the proposed Conditional Use Permit ( CUP- 23- 08) and Site Plan Review ( SPR- 23- 09) for the Ashley Furniture Project. The Planning Commission received written correspondence from Mr. Michael R. Lozeau of Lozeau Drury, LLP, representing the Laborers' Union of North America, Local Union No. 73 ( LIUNA) regarding the Ashley Furniture Project. The comment letter incorrectly asserts that additional CEQA analysis must be completed for the project.

With respect to the use of the exemption provisions provided under Section 15183 of the CEQA Guidelines, the City has applied these correctly to this project. Public Resources Code Section 20183. 3 and corresponding State CEQA Guidelines Section 15183 allows a streamlined environmental review process for projects that are consistent with the densities established by existing zoning, community plan or general plan policies for which an EIR was certified.

CITY MANAGERS REPORT PAGE 5
NOVEMBER 13, 2023 CITY COUNCIL REGULAR MEETING

ASHLEY FURNITURE PRO) ECT
The Ashley Warehouse project is consistent with the uses and development intensities established for the site under the City' s General Plan and Land Use Map.

As such, the application of CEQA to the approval of development projects, such as the proposed Ashley Project, shall be limited to effects on the environment which are peculiar to the parcel or to the Project and which were not addressed as significant effects in the prior environmental impact report, or which substantial new information shows will be more significant than described in the prior environmental impact report. ( Pub. Res. Code § 21083. 3.) Further, an effect of a project on the environment is not considered peculiar to the parcel or the project, if uniformly applied development policies or standards have been adopted by the local agency with a finding that they will substantially mitigate that effect when applied to future projects.

State CEQA Guidelines § 15183( f).)
The lead agency must make a finding at a public hearing that any mitigation measures in the prior EIR that apply to the project' s specific effects, and that the lead agency found to be feasible, will be undertaken. ( Pub. Res. Code § 21083. 3( c); State CEQA Guidelines § 15183( e).) The City has done that here, by incorporating relevant policies, actions, standards, and other mitigating requirements as Conditions of Approval for the Ashley Warehouse project. These requirements and standards are specifically identified throughout the Environmental Analysis the City prepared for the Ashley Warehouse project. Such a finding is not required for potentially significant environmental effects that are not considered peculiar to the parcel or the project if uniformly applied development policies or standards were previously adopted by the agency with a finding that the policies or standards would substantially mitigate the environmental effect when applied to future projects.

State CEQA Guidelines § 15183( f).) When the agency has failed to make such a finding previously, it can do so when it approves the later project.

Often, such certified prior EIRs are Program EIRs and, in fact, the factual questions as to whether project impacts fall within the scope of the prior EIR are very similar.

As to reliance on a Program EIR, later activities are examined to determine whether an additional environmental document must be prepared. ( State CEQA Guidelines § 15168( c).) As the commenter notes, if a later activity would result in environmental effects that were not examined in the Program EIR, the agency must prepare an initial study to determine whether an EIR or negative declaration is required to address those effects. ( Id.) However, as is the case here, if a later activity would not have any effects that were not examined in the Program EIR ( including any new or more severe impacts), the agency can approve the activity as being within the scope of the project covered by the Program EIR, and no new environmental document would be required. ( Id.)
CITY MANAGERS REPORT PAGE 6
NOVEMBER 13, 2023 CITY COUNCIL REGULAR MEETING
ASHLEY FURNITURE PRO] ECT
Factors that an agency may consider in determining whether a later activity is within the scope of a Program EIR include " consistency of the later activity with the type of allowable land use, overall planned density and building intensity, geographic area analyzed for environmental impacts, and covered infrastructure as described in the program EIR." ( State CEQA Guidelines § 15168( c).) An agency must incorporate feasible mitigation measures and alternatives developed in the Program EIR into later activities in the program. ( Id.) " Where the later activities involve site specific operations, the agency should use a written checklist or similar device to document the evaluation of the site and the activity to determine whether the environmental effects of the operation were within the scope of the program EIR." ( Id.) The City' s Environmental Analysis complies with both Section 15183 and Section 15168 of the State CEQA Guidelines. The commenter claims that an EIR is required for the Project. While the applicability of the exemption provided by State CEQA Guidelines 15183 does not turn on whether the City completes some form of preliminary review, here the City did use an environmental checklist which identifies whether or not each CEQA Appendix G environmental checklist question, and its corresponding impacts, were adequately addressed in the Lathrop General Plan EIR, if there is a significant impact due to new information, or if the Project would result in a significant impact peculiar to the Project site that was not adequately addressed in the General Plan EIR. The Environmental Analysis identifies the applicable City of Lathrop development standards and policies that would apply to the proposed Project during both the construction and operational phases, identifies applicable state- level standards and requirements, and explains how the application of these uniformly applied standards and policies would ensure that no peculiar or site- specific environmental impacts would occur. As such, there are no significant impacts associated with the proposed project that would be different from, or exceed the level of severity of any significant impacts identified in the General Plan EIR. As such, there is no need for the City to adopt a Statement of Overriding Considerations for the proposed Ashley Warehouse project.

Written correspondence from LIUNA is attached to this Staff Report as Attachment

12. After review and consideration of all information provided, and after taking and considering all public testimony, the Planning Commission voted unanimously ( 4- 0) to adopt Resolution No. 23- 13, recommending the City Council find the project exempt from further environmental review pursuant to Public Resources Code Section 21083. 3 and California Environmental Quality Act ( CEQA) Guidelines Section 15183 and approve the Conditional Use Permit ( CUP- 23- 08) and Site Plan Review ( SPR- 23- 09) for the proposed Ashley Furniture Project. The Planning Commission Resolution is attached to this Staff Report as Attachment 11.

CITY MANAGERS REPORT PAGE 7
NOVEMBER 13, 2023 CITY COUNCIL REGULAR MEETING

ASHLEY FURNITURE PROJECT
CITY COUNCIL MEETING OF OCTOBER 9, 2023
On October 9, 2023, the City Council held a public hearing on the proposed Conditional Use Permit ( CUP- 23- 08) and Site Plan Review ( SPR- 23- 09) for the Ashley Furniture Project. The City Council received written correspondence from Mr. Michael R. Lozeau of Lozeau Drury, LLP, representing the Laborers' Union of North America, Local Union No. 73 ( LIUNA) and from Manteca Unified School District ( MUSD). The LIUNA letter is attached to this Staff Report as Attachment 13 and a written response is attached to this Staff Report as Attachment 15. The MUSD letter is attached to this Staff Report as Attachment 14.

ANALYSIS:

Site Plan Review
As stated above, the proposed project includes the construction of a new 1, 486, 607 sq. ft. concrete tilt- up building on an 89. 82- acre site located at the northwest corner of Dos Reis Road and Manthey Road. The building will include the following uses:

Use S uare Foota e s . ft.

Office 24, 000
Retail Outlet 110, 260
Warehouse Distribution 1, 352, 347
Facilit
Total 1, 486, 607
The building is generally located in the center of the subject parcel with a drive aisle providing access to all sides of the building. Off-street parking is provided both for passenger vehicles ( employee parking and customer/ public parking) and for commercial trucks and trailers.

Additionally, a customer pick- up area is located at the southeastern portion of the building, north of the Dos Reis automobile driveway. Customers will be guided to the customer pick up area office and directed to the specific pick- up bay.

CITY MANAGERS REPORT PAGE 8
NOVEMBER 13, 2023 CITY COUNCIL REGULAR MEETING

ASHLEY FURNITURE PROJECT
Square
Automobile
Automobile Commercial
Use Footage Parking parking Spaces Truck and
sq. ft.)
Spaces
provided Trailer Spaces
Re uired
Office 24, 000 1 per 400 sq. ft.
g42 total 1, 104
Retail 110, 260 1 per 600 sq ft.

Employee stalls ( 12' x 30' = 46)
Outlet 184 s aces
462) 12 x 40 ) = 261)
Warehouse 1, 352, 347 1 per 2, 000 sq.

Public stalls = ( 12 x 53 = 797)
480)
Total 920 S aces 942 1, 104
Automobile parking spaces are nine ( 9) by eighteen ( 18) feet in size, meeting the dimension requirements pursuant to Section 17. 76. 030, Standards for off-street and on- street parking facilities. Of the 942 automobile parking spaces provided, twenty 20) are handicap accessible ( including four ( 4) van accessible), 188 are Electric Vehicle ( EV) capable parking spaces, and twelve ( 12) are EV parking spaces pursuant to California building Code ( CBC) requirements.

As noted in the table above, the commercial truck and trailer spaces include a variety of sizes to accommodate single trailers and the commercial truck cab and tailer.

Commercial truck and trailer parking is located primarily on the eastern portion of the Site Plan and along the northern and southern property line.

Architecture
The proposed building is designed as a concrete tilt- up structure with colored wall accents and glass treatments near the outlet/ showroom entrance and employee entrances. The elevation facing S. Manthey Road and Interstate 5 ( I- 5) will convey a high- quality office/ retail appearance while maintaining key functions, including customer pick- up area along the southeast elevation. The appearance is achieved with glazing to indicate an office appearance and clerestory windows along the upper potions of the fa ade. The building also includes accent shading features, variations in parapet height and colors. Collectively, these provide for enhanced visual interest and varied building massing, to create distinctive points of entry for users. The following is a portion of the east elevation and a rendering looking at the building from S. Manthey Road.

CITY MANAGERS REPORT PAGE 9
NOVEMBER 13, 2023 CITY COUNCIL REGULAR MEETING

ASHLEY FURNITURE PROJECT
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The building varies in height from 46 feet to 60 feet. The tallest height of the building is located at the entrance, facing S. Manthey Road ( illustrated above). The distribution warehouse portion of the building is 46 feet to the parapet. The height fluctuates between 43 feet to 46 feet for the majority of the building. The maximum height allowed under the Limited Industrial Zoning District in the CLSP Phase 2 Amendment is 76 feet.

CITY MANAGERS REPORT PAGE 10
NOVEMBER 13, 2023 CITY COUNCIL REGULAR MEETING

ASHLEY FURNITURE PROJECT
Floor Plan
As noted above, the proposed building will include a three- story, 24, 000 sq. ft. office, two- story 110, 260 sq. ft. retail outlet and showroom, and a 1, 352, 347 sq. ft. warehouse distribution center. The office is located within the northeastern portion of the building and will include a variety of offices, conference rooms, restrooms, and breakroom for each floor. The retail outlet and showroom will have an open floor plan, similar to the existing Ashley Furniture Outlet on S. Harlan Road. An escalator will provide access to the second floor retail outlet and showroom.

Lighting
Lighting is proposed to be shielded and directed towards the parking and access areas only. As illustrated on the Photometric Plan ( Attachment 6), lighting levels beyond the property line are at 0 candle power. Specific lighting detail, beyond the photometric plan will be refined as part of the Building Permit process.

Landscaping
Landscaping is provided throughout the project area and represents 10. 4% ( 388, 479 sq. ft.) of the entire project area ( excluding stormwater detention basins). Landscape treatment along Dos Reis Road and S. Manthey Road include a variety of large trees, screening trees ( discussed further below), medium trees, shrubs and ground cover.

Shade trees are proposed throughout the parking lot ( public and employee parking areas) and at maturity, 73% of the parking area will be shaded, exceeding the City' s requirement of 50%. The Preliminary Landscape Plan is attached to this Staff Report as Attachment 8.

Fencing and Walls
Proposed fencing and walls for the project are illustrated in the Screen Wall and Fencing Plan ( Attachment 6). The proposed project will include three ( 3) fence types:
wrought iron fencing, steel gate and solid tilt- up screen all. The wrought iron fencing will be utilized within the interior of the project, particularly to secure the employee parking area and along the northern and western property line. A steel sliding gate will be utilized at the access points to the employee parking area and the off-street parking area for trucks/ trailers. A solid tilt- up screen wall will be utilized along a portion of the northern property line ( along the commercial truck driveway) and the southern property line to screen the project from uses to the south.

CITY MANAGERS REPORT PAGE 11
NOVEMBER 13, 2023 CITY COUNCIL REGULAR MEETING
ASHLEY FURNITURE PRO] ECT
The following is a detail of the screen wall and metal gate:
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Screening along Dos Reis Road
The proposed project includes a variety of strategies to screen the building and offstreet parking of commercial vehicles and trailers from Dos Reis Road and adjacent properties to the south. These strategies include the following:

1. Installation of an 8- foot tall solid screen wall at the southern property line.

2. Planting of a mixture of deciduous shade trees and large evergreen trees for purposes of screening. As illustrated in the Preliminary Landscape Plan Attachment 8), Deodar Cedar trees will be planted along Dos Reis Road at a maximum spacing of 40 feet. Deodar Cedar trees are a type of evergreen tree that keep its foliage year- round.

Chinese Flame Trees will also be planted along Dos Reis Road to assist in screening. The trees and landscaping will be installed between the 8 foot sidewalk and the 8' wall along Dos Reis Road.

3. Providing an additional landscape buffer along Dos Reis Road. As illustrated in the cross- section of Dos Reis Road below, the project includes an additional 43 foot on- site landscape buffer adjacent to the public right- of- way. In addition to the landscape buffer north of Dos Reis Road within the public rightof- way, there is a total of 73 feet between the roadway and the off-street parking of commercial trucks/ trailers.

CITY MANAGERS REPORT PAGE 12
NOVEMBER 13, 2023 CITY COUNCIL REGULAR MEETING
ASHLEY FURNITURE PRO] ECT
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4. The building is setback 279 feet from the property line, which assists in limiting the sight line from Dos Reis Road. As illustrated in the Sight Line Exhibit below, the building is screened from view from the northern sidewalk along Dos Reis Road.

The applicant has prepared renderings of the proposed screening along Dos Reis Road, with mature trees and associated landscaping. The images below illustrate the proposed landscaping and screening strategies along Dos Reis Road. The full set of renderings are attached to this Staff Report as Attachment 9. z
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CITY MANAGERS REPORT PAGE 13
NOVEMBER 13, 2023 CITY COUNCIL REGULAR MEETING
ASHLEY FURNITURE PRO] ECT
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Traffic and Circulation
Passenger vehicle access to the project is provided via Dos Reis Road and S. Manthey Road. As noted above, the proposed project includes two ( 2) driveways from passenger vehicles, one ( 1) along Dos Reis Road, east of Golden Valley Parkway and the other along S. Manthey Road. An Emergency Vehicle Access ( EVA) driveway is located on Dos Reis Road, west of Golden Valley Parkway.

A Traffic Impact Analysis ( TIA) was prepared for the proposed project by TJKM Transportation Consultants. The Traffic Impact Analysis analyzed the following scenarios:

Existing Conditions - Intersection Level of Service
Existing Conditions - Freeway Mainline Level of Service Baseline Conditions - Intersection Level of Service
Baseline Conditions - Freeway Mainline Level of Service Baseline plus Project Conditions - Intersection Level of Service Baseline plus Project Conditions - Freeway Mainline Level of Service Cumulative Conditions - Intersection level of Service
Cumulative plus Project Conditions - Intersection Level of Service In addition to the Level of Service scenarios analyzed above, the Traffic Impact Analysis included a Vehicle Miles Traveled ( VMT) Analysis, consistent with California Environmental Quality Act ( CEQA) Guidelines and Senate Bill 743.

CITY MANAGERS REPORT PAGE 14
NOVEMBER 13, 2023 CITY COUNCIL REGULAR MEETING
ASHLEY FURNITURE PRO] ECT
Trip Generation
To determine the amount of peak hour and daily trips generated by the project, TJKM conducted a 24- hour count at the existing Ashley Furniture facility located on S.

Harlan Road. The approximate square footage of the existing Ashley Furniture facility is 525, 000 sq. ft. and with this information and data collected from the 24- hour count, TJKM developed trip rates for the proposed project for passenger vehicles and heavy trucks. The following tables illustrate the trip generation for the proposed project.

Table 13: Project Trip Generation for Passenger Vehicles Daity A. M. Peak P.M. Peak
Size
Rate Trips Rate tn: Dut tn Out Tota( Rate tn: 0ut / n Oat Totat Propased t) ses
Ashley
1, 5€SO ksf t.87 2, 798 0. 135 61: 39 124 79 203 0. 170 43: 57 11Q 145 255 Furnikure
Net Trips 2, 798 124 79 203 1 f0 J45 255
Table 14: Project Trip Generation for Heavy Trucks
Qcity A. M. Peak RM. Peak
Land Use Size
Rote Trips Rate / n:0ut / n Out Tatat Rote ln:0ut ! n Oot Totat Praposed Uses
Ashley
1, 50Q ksf 0.453 68C? 0.063 15: 85 14 81 95 O. q34 6931 31 14 45 Furniture
Net Trips 680 14 8i 95 31 f4 45
As shown in the table above, the proposed project is projected to generate 2, 798 daily passenger vehicles, 203 a. m. peak hour passenger vehicles, and 255 p. m. peak hour passenger vehicles. For heavy trucks, the proposed project is projected to generate 680 daily heavy trucks, 95 a. m. peak hour trucks, and 45 p. m. peak hour trucks.

Trip Distribution
Pursuant to General Plan Implementation Action Lu- 5. f and the Central Lathrop Specific Plan Amendment for Phase 2, truck traffic within the Limited Industrial area of the Specific Plan shall be limited to De Lima Road, and any future roadways north of Dos Reis Road, to connect to Manthey Road, Roth Road, and Interstate 5.

Additionally, truck dependent development projects shall be prohibited from providing driveway access points off of Dos Reis Road, west of Golden Valley Parkway, other than Emergency Vehicle Access ( EVA) ( Implementation Action LU- 5. f ( b)( iii).

The proposed project includes one ( 1) driveway dedicated to commercial trucks and is located on S. Manthey Road, within the northeastern portion of the project.

CITY MANAGERS REPORT PAGE 15
NOVEMBER 13, 2023 CITY COUNCIL REGULAR MEETING
ASHLEY FURNITURE PRO] ECT
Signage is proposed that will direct traffic north on 5. Manthey Road and prohibit trucks from turning right on to S. Manthey Road toward Dos Reis Road and Golden Valley Parkway.
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Traffic Impact Analysis Results
The intersection level of service analysis for Baseline plus Project Conditions results in three ( 3) intersections operating at unacceptable service levels during the a. m. and p. m. peak hour. It is important to note that the following intersection already operates at unacceptable level of service without the addition of project traffic:

Lathrop Road/ I- 5 Northbound Ramps degrades to LOS F in the p. m. peak hour, with an increase in average delay of 19. 1 seconds.

The following two ( 2) intersections would degrade from acceptable to unacceptable level of service with the addition of project trafFic:

Lathrop Road- Spartan Way/ I- 5 Southbound Ramps would degrade from LOS D to LOS E in the a. m. and p. m. peak hour, a substantial degradation.

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Spartan Way/ Golden Valley Parkway intersection would degrade from LOS C to LOS E in the a. m. peak hour and LOS D to LOS F in the p. m. peak hour, a substantial degradation.

To improve the traffic flow for the three ( 3) above noted intersections, the Traffic Impact Analysis recommends the following improvements:

A separate right- turn lane added to the Lathrop Road/ I- 5 Northbound off- ramp as well as signal timing to improve the intersection operation to LOS C in the a. m. and p. m. peak hours. The new lane should provide at least 400 ft. of vehicle storage.

For the Lathrop Road/ I- 5 Southbound off-ramp, adjusting the signal timing of the existing traffic lights will improve the intersection operate to LOS D in the a. m. and p. m. peak hour. Widening is not necessary for the Baseline plus Project Conditions at the southbound off- ramp.

For Spartan Way/ Golden Valley parkway, the TIA recommends making adjustments to the lane geometry ( number of turn lanes, through lanes, and right-turn lanes) to improve the efficiency of the intersection.

These improvements have been incorporated into the proposed project' s Conditions of Approval. The TIA is attached to this Staff Report as Attachment 10.

Utilities
Potable water will be supplied to the proposed project by the City of Lathrop via connection to an existing 12" water line in Golden Valley Parkway, south of Dos Reis Road. The CLSP Phase 2 Amendment states that water supply to the plan area will be provided from the City' s existing groundwater wells and potable surface water from the South County Surface Water Supply Program ( SCSWSP) by the South San Joaquin Irrigation District ( SSJID).

Wastewater generated by the project will be treated by the City' s Consolidated Treatment Facility ( CTF) along Christopher Way, southeast of the project site. The project will connect to an existing 24" sanitary sewer line in Golden Valley parkway, south of Dos Reis Road. As part of the project' s Conditions of Approval, the applicant is required to secure sufficient sewer treatment capacity, including treatment at the City' s CTF.

Per the CLSP Phase 2 Amendment, stormwater runoff from the plan area is designed to discharge into the San Joaquin River through an existing outfall located near the southwest corner of the CLSP Phase 2 Amendment Plan Area at the end of Dos Reis Road and the existing outfall within the Phase 1 area.

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The CLSP Phase 2 Amendment Plan Area consists of two ( 2) major drainage sheds with underground storage pipes to reduce the peak discharge from the plan area to the San Joaquin River. The project site is located within Watershed 4, which includes both CLSP Phase 1 and the CLSP Phase 2 Amendment areas. The proposed project will connect to the existing 54" Stormdrain line in Golden Valley Parkway, south of Dos Reis Road. Stormwater will be treated on- site with Best Management Practices BMPs) through a series of bio- detention basins prior to entering the City system.

The Civil Plans are attached to this Staff Report as Attachment 7.

Zoning Consistencx
The project site will be located within the IL- CL, Limited Industrial Zoning District in which a Zoning Map and Municipal Code Amendment is also being processed by the City for consistency with the recently adopted General Plan. Chapter 17. 62, Article 6, and Article 12 will provide guidance and development requirements for projects located within this District. Section 17. 62. 061 of the Zoning Ordinance will be amended as part of the General Plan consistency effort to state the following: the IL- CL district is intended to provide opportunities for certain types of limited industrial uses; provide adequate space to meet the needs of modern industrial development, including off- street parking and truck loading areas; and to provide industrial employment opportunities for residents of the city and region." Principal uses include but are not limited to assembly of small electrical equipment and appliances, various manufacturing uses, lumber yards, public utility and public service structures, public buildings and grounds, business parks and incubator spaces, research development industry and business support services and warehouse and distribution facilities.

The proposed project is considered a principal use.

Table 17. 62. 120( B), Central Lathrop Specific Plan: Industrial Development Standards provides the development standards required of the IL- CL District, and the table below depicts the conformance determination between the Zoning Ordinance and the proposed project.

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Develo ment Standard IL- CL Zone District Pro osed Pro" ect Lot Dimensions
Lot Size ( Minimum) No Minimum or Maximum 89. 82- acres Re uirement
Setbacks Minimum
Front/ Rear/ Side 15 feet / 0 feet / 0 feet Front: Approximately 418- feet from S. Manthey
Road
Side: Approximately 279-
feet from Dos Reis Road
and 220- feet from then
northern property line.

Rear: Approximately 704-
feet from the rear
ro ert line.

Maximum Buildin Hei ht Sevent - six 76 feet 60- feet
Off- Street Parking Office - 1 per 400 square 942 total feet = 60 spaces Employee stalls = 462)
Retail - 1 per 600 square Public stalls = 480)
feet = 184 spaces
Warehouse - 1 per 2, 000 1, 104 truck and trailer
square feet = 676 spaces spaces ( 12' x 30', 40',
Total re uired: 920 and 53'
Landscaping 10% of Site shall be 10. 4% ( 388, 618 square landsca ed feet of landsca in
Hours of Operation No Specific Limit Retail - 9: 00 am to 9: OOpm
Office - TBD
Distribution - TBD
Based on Staff' s review, the proposed project is consistent with the requirements of the IL- CL Zoning District.

Design Guidelines
The Central Lathrop Specific Plan ( CLSP) Phase 2 Amendment includes a variety of principles and standards related to land use, site design, and architecture. Staff has reviewed the proposed project Site Plan, Building Elevations, Landscape Plans, and Architecture ( Attachments 6 through 8) and has determined that overall compliance with the Design Guidelines listed in the CLSP Phase 2 Amendment has been achieved.

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Where applicable, Conditions of Approval have been incorporated to the proposed project to address the following improvements: perimeter wall treatment, on- site lighting, screening of exterior building equipment ( e. g., mechanical equipment, A/ C, etc.), screening of commercial truck and trailer storage, and landscape buffer requirements and treatment.

General Plan
The project site has a General Plan Land Use Designation of LI, Limited Industrial.

The intent of the IL land use designation is to, ' accommodate a wide range of jobsgenerating uses, including business parks; clean light industrial; research and development ( R& D); science, technology, engineering, and math ( STEM); tech/ biotech manufacturing; high- tech services that incorporate some combination of assembly, warehousing, and/ or sales, hospitals and other health care- related uses, warehouses and distribution centers."
The Ashley Furniture Project has been reviewed by Staff for consistency with the General Plan and finds that the proposed project is consistent with the following General Plan Policies and Implementation Actions ( consistency statements are in italics):

LU- 5. 1 Require new development to be compatible and complementary to existing development. Where appropriate and feasible, promote connections between neighborhoods and services and facilities.

As noted above, the subject property has a General Plan Land Use Designation of LI, Limited Industrial and will be located within the Central Lathrop Specific Plan ( CLSP) Phase 2 Amendment area IL, Limited Industrial Zoning District. The proposed project would improve and extend Golden Valley Parkway and construct a roundabout at the intersection of Dos Reis Road and Golden Valley Parkway which would provide connection to the CLSP Phase 1 area for passenger vehicles. The proposed use is compatible with the IL, Limited Industrial Zoning District and the CLSP Phase 2 Amendment.

LU- 5. 4
In industrial areas located within 1, 000 feet of existing or planned sensitive receptors, promote industrial uses that are environmentally sustainable with limited potential to create nuisances such as noise and odors.

An Environmental Noise Assessment, prepared by Saxelby Acoustics and a Health Risk Assessment ( HRA), prepared by De Novo Planning Group were prepared to analyze the noise and health risks impacts associated with the proposed project, respectively.

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As noted in the Environmental Noise Assessment, the City' s General Plan limits stationary noise increases to 3 dBA, or the City' s noise standards ( daytime ( 7: 00 am to 10: 00 pm) maximum of 55 d8A and nighttime ( 10: 00 pm to 7: 00 am) maximum of 45 d8A). The average ambient noise level during nighttime hours at the closest sensitive receptors to the southwest is 54 d8A LeQ. At the sensitive receptors to the southwest, a project-generated noise level of 51 d8A Leq would result in a total noise level of 54 d8A Le4, resulting in a 3d8A increase. Therefore, the nighttime noise level standard applicable to the proposed project is 51 d8A Leq.

The primary noise source associated with operation of the proposed project is truck and automobile circulation and loading docks. Single family residential land uses are located to the north, west, and south of the project, Lathrop High School is located to the west of the project, and Interstate 5 is located directly east of the project.

Saxelby Acoustics conducted noise measurements at the existing Ashley Facility located on 5. Harlan Road. Measurements were conducted in the loading dock area during a weekday peak hour of use. Activities during the peak hour include truck arrival/ departures, truck idling, truck backing, air brake re/ ease, passenger vehicle trips to and from docks, and operation of forklifts. Loading dock activity was found to generate continuous average noise levels of approximately 57 d8A LeQ at the edge of the truck maneuvering lanes, approximately 120 feet from the fa ade of the building at the center of the loading area. Saxelby Acoustics took these measurements and utilized SoundPLAN to predict noise levels for the proposed project.

The proposed project is predicted to generate noise levels up to 45 dBA LeQ at the nearest residences to the southwest and 39 d8A Leq at the residences to the northeast, resulting in a maximum increase of 0. 9 dBA at nearby residences. This complies with the adjusted nighttime noise level standard of 51 d8A LeQ and limit of 3 d8A increase. Therefore, the Environmental Noise Assessment did not recommend any additional noise control measures to achieve compliance with the City' s noise level standards.

Although not specifically required to achieve noise level standards, the proposed project includes an 8- foot tall solid wall along the southern property line and a portion of the northern property as required by the Lathrop Municipal Code when an industrial use is adjacent to a residential use and for screening purposes along Dos Reis Road.

This will assist in reducing noise exposure from the operation of the Ashley Furniture project. Additionally, the project is required to adhere to California Air Resources Board ( CARB) rules and regulations for use of diesel fueled fleets, including limiting the idling time for heavy trucks to five ( 5) minutes.

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The HRA was prepared to evaluate whether or not the estimated construction and operational toxic air contaminant ( TAC) emissions generated from the proposed project will cause significant impacts to the local air resources in the project area, in particular, sensitive receptors such as residences located in proximity to the project.

The results of the risk analysis indicate that cancer risks vary depending on the exposure scenario ( residential or worker) and on location. Locations nearest the project site have the greatest exposure and the associated risks are considerably lower as distance from the project site increases. None of the exposure levels at any of the nearby sensitive receptors exceed any of the thresholds of significance established by the San Joaquin Valley Air Pollution Control District ( SJVAPCD) for residents or workers. This finding applies to both cancer risks and non- cancer chronic long term exposure to diesel particulate matter (DPM).

LU- 5. 5 Ensure that industrial development projects, including warehouse, distribution, logistics, and fulfillment projects, mitigate adverse impacts including health risks and nuisances) to nearby residential land uses and other existing and planned sensitive receptors.

As noted above, a Health Risk Assessment, prepared by De Novo Planning Group has been prepared as part of the Environmental Checklist. The HRA findings are described above. The HRA concluded that the project would not exceed any of the applicable thresholds of significance related to toxic air contaminants and health risks.

LU- 5a Through the development review process, screen development proposals for land use and transportation network compatibility with existing surrounding or abutting development or neighborhoods.

As noted above, a Traffic Impact Analysis ( TIA) was prepared for the proposed project by TJKM Transportation Consultants to evaluate the impacts of the transportation infrastructure due to the addition of traffic from the proposed project. The report also evaluates project site access and on- site circulation for vehicles, bicycles, and pedestrians. The proposed project includes a dedicated truck driveway located at the northeastern portion of the project site with full access to S. Manthey Road.

This driveway is approximately 488- feet in length and provides double- stacking for trucks entering the site and a single lane exiting the site. As required by the City's General Plan, trucks are prohibited from utilizing Golden Valley Parkway, Dos Reis Road west of Golden Valley Parkway, Spartan Way, and Lathrop Road. As such, trucks entering and exiting the site will utilize Roth Road and S. Manthey Road.

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LU- 5. b Through the development review process, analyze land use compatibility and require adequate buffers and/ or architectural enhancements to protect sensitive receptors from intrusion of development activities that may cause unwanted nuisances and health risks.

The proposed project includes a landscape buffer and screening along Dos Reis Road.

The buffer includes a 43 feet of on- site landscaping in addition to the 30 feet of landscaping within the public right- of-way adjacent to Dos Reis Road. Landscaping will include a mixture of deciduous shade trees and large evergreen trees for the purpose of screening.

LU- 5. c When industrial projects, including warehouse projects, fulfillment centers, and other projects that may generate high volumes of truck trips and/ or air quality emissions are proposed within 1, 000 feet of existing or planned residential sues or other sensitive receptors, the City shall require the preparation of a Health Risk Assessment ( HRA) that meets the standards established by the Office of Environmental Hazard Assessment ( OEHHA), and the San Joaquin Valley Air Pollution Control District ( SJVAPCD). Projects shall not be approved until it can be demonstrated that the project would not result in an exceedance of the established threshold of significance for public health risks at nearby sensitive receptors.

As noted above, an HRA, prepared by De Novo Planning Group, has been prepared as part of the Initial Study Checklist. The HRA was prepared in accordance with the standards established by OEHHA and SJVAPCD. The HRA findings are presented above.

LU- 5. d When industrial projects, including warehouse projects, fulfillment centers, and other projects that may generate high volumes of truck trips and/ or air quality emissions are proposed within 1, 000 feet of existing or planned residential uses or other sensitive receptors, the City shall require the implementation of best management practices ( BMPs) to reduce pollution exposure to sensitive receptors, particularly diesel particulate matter ( DPM). The appropriate BMPs shall be established on a case- by- case basis, and should consider the following tools, methods, and approaches:

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Creating physical, structural, and/ or vegetative buffers that adequately prevent or substantially reduce pollutant dispersal between warehouses and any areas where sensitive receptors are likely to be present, such as homes, schools, daycare centers, hospitals, community centers, and parks.

Providing adequate areas for on- site parking, on- site queueing and truck check- in that prevent trucks and other vehicles from parking or idling on public streets.

Placing facility entry and exit points from the public street away from sensitive receptors, e. g., placing these points on the north side of the facility if sensitive receptors are adjacent to the south side of the facility. Exceptions can be made for emergency vehicle access ( EVA) points.

Locating warehouse dock doors and other onsite areas with significant truck traffic and noise away from sensitive receptors.

Screening dock doors and onsite areas with significant truck traffic and noise with physical, structural, and/ or vegetative barriers that adequately prevent or substantially reduce pollutant dispersal from the facility towards sensitive receptors.

Posting signs clearly showing the designated entry and exit points from the public street for trucks and service vehicles.

Posting signs indicating that all parking and maintenance of trucks must be conducted within designated on- site areas and not within the surrounding community or public streets.

The proposed project is consistent with Implementation Action LU- S. d as follows:

As noted above, the proposed project includes the construction of an 8 foot tall solid wall along the majority of the southern property line and a portion of the northern property line. Additionally, the proposed project includes a onsite landscape buffer along Dos Reis Road approximately 43- feet in width and 30 feet of landscaping within the public right- of-way.

Off- street parking is provided for passenger vehicles ( employee parking and customer/ public parking) and for commercial trucks and trailers. As noted above, the amount of off-street parking provided exceeds the minimum required pursuant to the Lathrop Municipal Code.

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The proposed project includes one ( 1) dedicated driveway for trucks, located along S. Manthey Road at the northeastern portion of the project site. The driveway allows stacking of approximately 488- feet with two ( 2) entry lanes and one ( 1) exit lane. Automobile driveways are located along S. Manthey Road ( primary entry/ exit) and Dos Reis Road. An additional Emergency Vehicle Access ( EVA) driveway is located on Dos Reis Road, west of Golden Valley Parkway.

As noted above, the warehouse dock doors are located on the north and south sides of the proposed building,
As noted above, the proposed project includes screening via an 8 foot solid wall and landscaping along the majority of the southern property line.

Additionally, an 8 foot solid wall will be constructed along a portion of the northern property line, screening the truck entrance/ exit drive aisle.

The proposed project will be required to place on- site and off-site signage indicating that trucks must adhere to the City's Truck Route Ordinance.

LU- 5. f Update the Central Lathrop Specific Plan ( CLSP) to accomplish the following objectives:
a. Bring the Specific Plan' s land use map into consistency with the General Plan Land Use Map ( Figure LU- 1)
b. Establish a circulation network that keeps future truck trips as far from existing and planned sensitive receptors as feasible; this includes, but not limited to, the following requirements, which shall be incorporated into the Specific Plan:
i. Trucks shall be prohibited on Dos Reis Road west and east of Golden Valley Parkway, on Golden Valley Parkway south of Dos Reis Road to Lathrop Road, and on Lathrop Road
east of Golden Valley Parkway to Interstate 5 southbound off- ramp.
ii. Future truck dependent development projects shall be prohibited from providing driveway access points off of Dos Reis Road, west of Golden Valley Parkway, other than
emergency vehicle access ( EVA).

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iii. Truck traffic within the Limited Industrial Area of the Central Lathrop Specific Plan shall be limited to De Lima Road, and any future roadways north of Dos Reis Road, to connect to Manthey Road, Roth Road, and Interstate 5.
c. Establish site design standards for new industrial projects; d. Identify financing and cost- recovery methods to fund roadway and infrastructure improvements.
e. Circulation design standards that promote safe transportation routes that limit impacts to developed areas to the south, and connectivity enhancements to provide better connectivity to I- 5. f. Infrastructure improvements to improve roadway operations. g. Opportunities to provide employee- serving amenities onsite, such as parks and plazas, outdoor seating areas, fitness facilities, and daycare centers as a means to reduce vehicle trips, while supporting air quality, public health, and sustainability goals. h. Include provisions that all development projects proposed north of Dos Reis Road and south of De Lima Road be required to obtain a Conditional Use Permit ( CUP), which shall be subject to discretionary review by the City Council.

The proposed project is consistent with the CLSP Phase 2 Amendment design guidelines, policies, and land uses. The City is processing the CLSP Phase 2 Amendment concurrently with the Zoning Consistency Update and the Ashley Furniture Project. The CLSP Phase 2 Amendment has been prepared consistent with the requirements established by this General Plan Action.

Conditional Use Permit
The General Plan and Central Lathrop Specific Plan ( CLSP) Phase 2 Amendment requires all development projects proposed between Dos Reis Road and De Lima Road to obtain a Conditional Use Permit ( CUP) subject to discretionary review by the Planning Commission and the City Council.

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The Planning Commission and City Council must make certain findings when approving a Conditional Use Permit:

1. That there are circumstances or conditions applicable to the land, structure, or use which makes the granting of a use permit necessary for the preservation and enjoyment of a substantial property right;

2. That the proposed location of the conditional use is in accordance with the objectives of the zoning code and the purposes of the district in which the site is located;

3. That the proposed use will comply with each of the applicable provisions of this the LMC.

Staff has reviewed each of the findings presented above and suggests that the proposed project location is consistent with the City' s zoning code and is a permitted use within the zoning district in which the site is located.

Site Plan Review
In accordance with Chapter 17. 100, Site Plan Review, of the Lathrop Municipal Code LMC), the Planning Commission must make the following findings when approving a Site Plan:

1. That the site plan complies with all applicable provisions of this chapter;

2. That the site improvements listed ( a. through i.) are so arranged that traffic congestion is avoided and that pedestrian and vehicular safety and welfare are protected, and there will not be adverse effect on surrounding property;

3. Proposed lighting is so arranged as to deflect the light away from adjoining properties;

4. Proposed signs will comply with all of the applicable provisions of Section

17. 16. 010 and Chapters 17. 64 through 17. 72, 17. 80 and 17. 84;

5. That adequate provision is made to reduce adverse or potentially adverse environmental impacts to acceptable levels.

Staff has reviewed each of the findings presented above and suggests that the proposed project has been designed so that the use is compatible with the surrounding land uses and will not be detrimental to the health, safety, or general welfare of the City.

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Conditions of A proval
Planning staff routed the project plans on February 14, 2023 and May 17, 2023 to the Building Division, Public Works Department, Lathrop- Manteca Fire District, Lathrop Police Department for review and to ensure compliance with applicable codes and requirements. Planning staff also routed the project plans on June 1, 2023 to various non- City agencies. The City received comments from the following agencies:

Caltrans
San Joaquin Council of Governments
San Joaquin County Environmental Health Department
San Joaquin Valley Air Pollution Control District
South San Joaquin Irrigation District
Pacific Gas & Electric
The Caltrans letter stated that the project has the potential to significantly impact the interchange and requested that a Traffic Impact Study be submitted to Caltrans for review and comment prior to project approval.

As noted above, City staff routed the Traffic Impact Analysis, prepared by TJKM to Caltrans on July 12, 2023. The City received a letter from Caltrans on August 9, 2023 with comments on the Traffic Impact Study. The majority of the comments were associated with the technical aspects of the Traffic Impact Study, such utilizing Caltran' s Three County Travel Demand Model, trip count year, and request for an explanation why Lathrop Interchange is not being utilized by trucks. TJKM will continue to work with Caltrans to refine the Traffic Impact Study. As noted above, the applicant will be required to construct a separate right- turn lane to the Lathrop Road/ I- 5 Northbound off- ramp ( 400 ft. of vehicle storage) which will require an Encroachment Permit from Caltrans. The applicant is working with Caltran' s to address their concerns.

S) COG provided information regarding the project' s participation in the San Joaquin County Multi- Species Habitat Conservation and Open Space Plan ( SJMSCP) and that the project is located within the Airport Influence Zone pursuant to the Airport Land Use Compatibility Plan ( ALUC). Additional review has been completed by SJCOG and the project was found to be compatible with the ALUC.

The San Joaquin County Environmental Health Department provided requirements for geotechnical drilling and process for abandonment and destruction of any wells or septic systems on the property.

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San Joaquin Valley Air Pollution Control District ( SJVAPCD) provided comments on measures to reduce air quality impacts associated with diesel vehicles and industrial projects, instructions for preparation of a Health Risk Screening/ Assessment and the District' s Rules and Regulations.

The Pacific Gas & Electric ( PGE) letter provided requirements for planting trees and shrubs along S. Manthey Road and underneath existing PG& E overhead pole line and that any planting in this area must comply with PG& E' s guide to Trees and Shrubs for Power Line- Friendly Landscaping.

As a result, staff developed a consolidated list of conditions ( Attachment 3). Staff finds that the proposed project has been properly conditioned to meet the City' s standards and requirements.

Public Notice
A Notice of Public Hearing was advertised in the Manteca Bulletin on September 29, 2023. Staff also mailed the public hearing notice to notify property owners located within a 300- foot radius from the project site boundary. In addition, the Public Notice was emailed to the City' s Public Hearing subscribers and interested parties and posted at three ( 3) locations accessible to the public and the City website.

CEQA REVIEW:

California Public Resources Code Section 21083. 3 and California Environmental Quality Act ( CEQA) Guidelines Section 15183 allows for a streamlined environmental review process for projects which are consistent with the development density established by existing zoning, community plan, or general plan policies for which an Environmental Impact Report ( EIR) was certified, except as might be necessary to examine whether there are project- specific significant effects which are peculiar to the project or its site.

If the above qualifications are met, as stated in Section 15183( b), a public agency shall limit its examination of environmental effects to those which the agency determines, in an initial study or other analysis:

1. Are peculiar to the project or the parcel on which the project would be located;

2. Were not analyzed as significant effects in a prior EIR on the zoning action, general plan or community plan with which the project is consistent;

3. Are potentially significant off-site impacts and cumulative impacts which were not discussed in the prior EIR prepared for the general plan, community plan or zoning action; or
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4. Are previously identified significant effects which, as a result of substantial new information which was not known at the time the EIR was certified, are determined to have a more severe impact than discussed in the prior EIR.

A detailed environmental analysis, prepared in the form of an Environmental Checklist with supporting technical analysis, has been prepared by De Novo Planning Group, to provide analysis of three distinct, yet closely related actions being contemplated by the City. These include an update to the Lathrop Municipal Code ( LMC) and Zoning Map ( Zoning Consistency Update), and update to the Phase 2 ( CLSP Phase 2 Amendment) and the proposed Ashley Furniture Project. The three ( 3) projects are being implemented as a result of the City' s comprehensive General Plan update, which was adopted on September 19, 2022. The General Plan Update provides a framework for future growth and projects the development reasonably expected during the build- out of the City. The Lathrop General Plan Update EIR analyzed the environmental impacts associated with adoption and implementation of the General Plan. All three of the actions analyzed in the Environmental Checklist are consistent with the General Plan, and were analyzed and accounted for in the General Plan EIR.

Biological Resources Analysis Report;
Preliminary Geotechnical Engineering Report;
Phase 1 Environmental Site Assessment Report;
Shallow Soil Investigation Report;
The CLSP Phase 2 Document;
Acoustical Assessment;
Air Quality- Health Risk Assessment Technical Report;
Traffic Impact Analysis; and
Ashley Furniture Project CaIEEMod output file.

The Environmental Analysis includes a discussion and analysis of any peculiar or sitespecific environmental impacts associated with adoption of the Municipal Code and Zoning Map Update, adoption of the CLSP Phase 2 Amendment, and construction and operation of the proposed Ashley Furniture Project.

The Environmental Analysis identifies whether or not each CEQA Appendix G environmental checklist question, and its corresponding impacts, were adequately addressed in the 2022 Lathrop General Plan EIR, if there is a significant impact due to new information, or if the project would result in a significant impact peculiar to the project site that was not adequately addressed in the General Plan EIR.

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The Environmental Analysis identifies the applicable City of Lathrop development standards and policies that would apply to the proposed project during both the construction and operational phases, identifies applicable minimization measures from the General Plan EIR that must be implemented, identifies applicable state- level standards and policies that would ensure that no peculiar or site- specific environmental impacts would occur.

The Environmental Analysis concluded that the proposed project is consistent with the land uses and development intensities assigned to the project site by the General Plan.

Impacts from buildout of the General Plan including cumulative impacts associated with development and buildout of the CLSP Phase 2 plan area and the Ashley Furniture Project, as proposed, were fully addressed in the General Plan EIR ( State Clearinghouse No. 2021100139), and implementation of the proposed project would not result in any new or altered impacts beyond those addressed in the General Plan EIR.

All project requirements identified in the Environmental Checklist are incorporated in project Consolidated Conditions of Approval ( Attachment 3). The Environmental Checklist is attached to this Staff Report as Attachment 10.

RECOMMENDATION:

The Planning Commission and staff recommend that the City Council consider all information provided and submitted, take and consider all public testimony and, if determined to be appropriate, adopt a Resolution to Find the Project Exempt from Further Environmental Review Pursuant to Public Resources Code Section 21083. 3 and California Environmental Quality Act ( CEQA) Guidelines Section 15183 and Adopt a Resolution to Approve a Conditional Use Permit and Site Plan Review for the Ashley Furniture Project.

FISCAL IMPACT:

All application processing fees and costs are charged to the applicant. The request has no fiscal impact to the City.

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APPROVALS:
w i
David Niskanen ate
Contract Planner
t 311 2 7
Jo n B. Anderson Date
Contract Planner
0 3 2
Rick C iat Da e
Com nity Development Director
Zot3
Salvador Navarrete Date
City Attorney
t• Z3
Step J. Salvatore Date
City Manager
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ATTACH M ENTS:

1. City Council Resolution to Find the Project Exempt from Further Environmental Review Pursuant to Public Resources Code Section 21083. 3 and California Environmental Quality Act ( CEQA) Guidelines Section 15183

2. City Council Resolution to Approve a Conditional Use Permit and Site Plan Review for the Ashley Furniture Project

3. Consolidated Conditions of Approval, dated September 13, 2023

4. Vicinity Map

5. Project Description

6. Architectural Plans

7. Preliminary Civil Plans

8. Preliminary Landscape Plan

9. Perspective Views/ Renderings

10. Environmental Checklist, prepared by De Novo Planning Group, dated August, 2023 with Appendices

11. Planning Commission Resolution No. 23- 13 Recommending City Council Approval

12. Comment Letter, dated September 13, 2023, from Lozeau Drury LLP regarding the Ashley Furniture Project

13. Comment Letter, dated October 6, 2023, from Lozeau Drury LLP regarding the Ashley Furniture Project

14. Comment Letter, dated September 28, 2023, from Manteca Unified School District MUSD) regarding the Ashley Furniture Project

15. Response to Lozeau Drury LLP letter dated October 6, 2023 regarding the Ashley Furniture Project
RESOLUTION NO. 23-

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF LATHROP FINDING

THE PROJECT EXEMPTION FROM FURTHER ENVIRONMENTAL REVIEW PURSUANT TO PUBLIC RESOURCES CODE SECTION 21083. 3 AND CEQA GUIDELINES SECTION 15183 ( CUP- 23- 08 AND SPR- 23- 09) WHEREAS, the City of Lathrop City Council held a duly noticed public hearing to consider the Conditional Use Permit and Site Plan Review pursuant to the General Plan and Lathrop Municipal Code; and
WHEREAS, the request is for approval of a Conditional Use Permit and Site Plan Review to allow the construction of an approximately 1. 5 million square foot concrete tilt- up building and all necessary supporting infrastructure on a property located within the Central Lathrop Specific Plan Phase 2 Amendment area as further defined below in the third recital ( the proposed Project or the Project); and WHEREAS, the property is located at 14101 S. Manthey Road ( APN: 192- 020- 14) ( the property); and
WHEREAS, prior to the City' s approval of the 2022 General Plan Update, the City prepared an Environmental Impact Report ( EIR) which analyzed the environmental impacts of buildout under the General Plan Update pursuant to the California Environmental Quality Act ( CEQA) ( Public Resources Code Section 21000, et. seq.), and the City of Lathrop City Council certified the Final EIR on September 19, 2022 ( State Clearinghouse # 2021100139); and
WHEREAS, the analysis in the General Plan Update EIR allows the use of CEQA exemption/ streamlining provisions for projects under the General Plan Update, including the proposed Project; and
WHEREAS, an Environmental Checklist has been prepared for the proposed Project, which is attached to the City Council Staff Report as Attachment 9 and can also be found in the Planning Division project files located at 390 Towne Centre Drive, Lathrop, CA 95330; and
WHEREAS, the City Council finds that the proposed Project is consistent with the Limited Industrial land use goals and policies of the City of Lathrop General Plan and is also consistent with the development standards for the IL- CL, Limited Industrial Zoning District and the Central Lathrop Specific Plan Phase 2 Amendment as further implemented through the Zoning Code Text Amendment; and WHEREAS, the City of Lathrop Planning Commission held a duly noticed public hearing on September 13, 2023, to consider the proposed Project and after reviewing and considering all information provided and submitted, and after taking and considering all public testimony adopted Resolution No. 23- 13 recommending City Council find the Project exempt from further environmental review pursuant to Public Resources Code Section 21083. 3 and California Environmental Quality Act CEQA) Guidelines Section 15183; and
Resolution No. 23-
WHEREAS, proper notice of this public hearing was given in all respects as required by law including the publishing of a legal notice of the hearing in the Manteca Bulletin on or about September 29, 2023 and mailed out to property owners located within a 300- foot radius from the project site boundary on September 29, 2023, emailed to the City' s Public Hearing subscribers and interested parties and posted at three ( 3) locations accessible to the public and the City website; and
WHEREAS, the City Council has utilized its own independent judgement in adopting this Resolution.

NOW THEREFORE, BE IT RESOLVED that the City Council of the City of Lathrop does hereby make the following findings:

Section 1. California Environmental Quality Act ( CEQA) Findings. Pursuant to Public Resources Code section 21083. 3 and CEQA Guidelines section 15183, the City Council finds and determines as follows:
a. The project complies with CEQA based on the CEQA
exemption/ streamlining provisions contained in Public Resources Code section 21083. 3 and CEQA Guidelines section 15183;
b. Pursuant to the City Council Staff Report and the attachments and exhibits thereto, including but not limited to, the CEQA Environmental Checklist, which are incorporated herein by reference, the proposed Project will not result in any significant impacts that: 1) are peculiar to the project or project site; 2) were not identified as significant projectlevel, cumulative, or off- site effects in the General Plan Update EIR; or 3) were previously identified significant effects, which as a result of substantial new information that was not known at the time that the General Plan Update EIR was certified, are determined to have a more severe adverse impact than discussed in the General Plan Update EIR.

As a result, pursuant to Public Resources Code section 21083. 3 and CEQA Guidelines section 15183, the proposed Project is exempt from further environmental review under CEQA.
c. All applicable General Plan Update policy and implementation actions and uniformly applied development policies, standards and/ or regulations are, hereby imposed on the proposed Project and must be adhered to by the Project applicant.

Resolution No. 23-
To the extent the City has not previously made findings regarding any/ all of these referenced General Plan policy and implementation actions and uniformly applied development policies, standards and/ or regulations, the City Council finds that all of those General Plan Update policy and implementation actions and uniformly applied development policies, standards and/ or regulations, were adopted, in whole or in part, to substantially mitigate the potential environmental effects to which they pertain ( i. e., aesthetics, agricultural and forest resources, air quality, biological resources, cultural and tribal resources, geology and soils, greenhouse gases, climate change, and energy, hazards and hazardous materials, hydrology and water quality, land use, population, and housing, mineral resources, noise, public services and recreation, circulation, utilities and service systems, and wildfire).

Section 2. Based on the findings set forth in this Resolution and the evidence in the Staff Report, the City Council hereby find the Project Exempt from Further Environmental Review Pursuant to Public Resources Code Section 21083. 3 and California Environmental Quality Act ( CEQA) Guidelines Section 15183 as illustrated and incorporated by reference as Attachment 10 of the City Council Staff Report.

Resolution No. 23-
The foregoing resolution was passed and adopted this 13t'' day of November 2023 by the following vote of the City Council, to wit:

AYES:

NOES:

ABSTAIN:

ABSENT:

SIGNED:

Sonny Dhaliwal, Mayor
ATTEST: APPROVED AS TO FORM:

Teresa Vargas, City Clerk Salvador Navarrete, City Attorney Resolution No. 23-
RESOLUTION NO. 23-

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF LATHROP

APPROVING A CONDITIONAL USE PERMIT AND SITE PLAN REVIEW FOR THE ASHLEY FURNITURE PROJECT ( CUP- 23- 08 AND SPR- 23- 09) WHEREAS, the City of Lathrop City Council held a duly noticed public hearing to consider the Conditional Use Permit and Site Plan Review pursuant to the General Plan and Lathrop Municipal Code; and
WHEREAS, the request is for approval of a Conditional Use Permit and Site Plan Review to allow the construction of an approximately 1. 5 million square foot concrete tilt- up building and all necessary supporting infrastructure on a property located within the Central Lathrop Specific Plan Phase 2 Amendment area as further defined below in the third recital ( the proposed Project or the Project); and WHEREAS, the property is located at 14101 S. Manthey Road ( APN: 192- 020- 14) ( the property); and
WHEREAS, prior to the City' s approval of the 2022 General Plan Update, the City prepared an Environmental Impact Report ( EIR) which analyzed the environmental impacts of buildout under the General Plan Update pursuant to the California Environmental Quality Act ( CEQA) ( Public Resources Code Section 21000, et. seq.), and the City of Lathrop City Council certified the Final EIR on September 19, 2022 ( State Clearinghouse # 2021100139); and
WHEREAS, the analysis in the General Plan Update EIR allows the use of CEQA exemption/ streamlining provisions for projects under the General Plan Update, including the proposed Project; and
WHEREAS, an Environmental Checklist has been prepared for the proposed Project, which is attached to the City Council Staff Report as Attachment 10 and can also be found in the Planning Division project files located at 390 Towne Centre Drive, Lathrop, CA 95330; and
WHEREAS, prior to approval of the Project, the City Council adopted a Resolution to find the Project exempt from further environmental review pursuant to Public Resources Code Section 21083. 3 and California Environmental Quality Act CEQA) Guidelines Section 15183; and
WHEREAS, the City Council finds that the proposed Project is consistent with the Limited Industrial land use goals and policies of the City of Lathrop General Plan and is also consistent with the development standards for the IL- CL, Limited Industrial Zoning District and the Central Lathrop Specific Plan Phase 2 Amendment as further implemented through the Zoning Code Text Amendment; and Resolution No. 23-
WHEREAS, the City of Lathrop Planning Commission held a duly noticed public hearing on September 13, 2023, to consider the proposed Project and after reviewing and considering all information provided and submitted, and after taking and considering all public testimony adopted Resolution No. 23- 13 recommending City Council approval of the proposed Project; and
WHEREAS, proper notice of this public hearing was given in all respects as required by law including the publishing of a legal notice of the hearing in the Manteca Bulletin on or about September 29, 2023 and mailed out to property owners located within a 300- foot radius from the project site boundary on September 29, 2023, emailed to the City' s Public Hearing subscribers and interested parties and posted at three ( 3) locations accessible to the public and the City website; and
WHEREAS, the City Council has utilized its own independent judgement in adopting this Resolution.

NOW THEREFORE, BE IT RESOLVED that the City Council of the City of Lathrop does hereby make the following findings:

Section 1. Conditional Use Permit Findings. Pursuant to Section 17. 112. 060 of the Lathrop Municipal Code ( LMC), the City Council finds as follows:
a. That there are circumstances or conditions applicable to the land, structure or use which makes the granting of a use permit necessary for the preservation and enjoyment of a substantial property right.

The proposed Project represents a major expansion of the existing Ashley Furniture Distribution Center and Retail Outlet located on S.

Harlan Road. The proposed Project is consistent with the City's development standards for Limited Industrial.
b. That the proposed location of the conditional use is in accordance with the objectives of the zoning code and the purposes of the district in which the site is located. The proposed Project is located in the IL- CL, Limited Industrial Zoning District and the Central Lathrop Specific Plan Phase 2 Amendment area and is a permitted use within the zoning district for which it is located as further established in the Zoning Code Text Amendment.
c. That the proposed use will comply with each of the applicable provisions of the LMC, as amended. As noted above and as described in the Staff Report, the proposed Project is a permitted use in the ILCL, Limited Industrial Zoning District and is consistent with the applicable provisions in the LMC, including screening requirements pursuant to the Central Lathrop Specific P/an Phase 2 Amendment.

Additionally, the General Plan requires updates to the LMC and Central Lathrop Specific Plan Phase 2 in order to ensure that new development is compatible with existing development ( Goal LU- 5).

Resolution No. 23-
The proposed Project is consistent with the LMC, Policies and Implementation Actions of the General Plan as it relates to truck traffic impacts and land use compatibility.

Section 2. Site Plan Review Findings. Pursuant to Section 17. 100. 050 of the Lathrop Municipal Code ( LMC), the City Council finds as follows:
a. The proposed Site Plan Review complies with all applicable provisions of Chapter 17. 100;
b. The proposed Site Plan Review is consistent with the site improvements listed in Chapter 17. 100 ( a. through i.) and improvements are such that traffic congestion is avoided and pedestrian and vehicular safety and welfare are protected and there will not be adverse effects on surrounding properties;
c. Proposed lighting for the project area is so arranged as to deflect away from adjoining properties; and
d. The proposed Site Plan Review is compatible with surrounding land uses and will not be detrimental to the health, safety and general welfare of the City as further evaluated in the Environmental Checklist.

Section 3. Based on the findings set forth in this Resolution and the evidence in the Staff Report, the City Council hereby approve Conditional Use Permit No.

CUP- 23- 08 and Site Plan Review No. SPR- 23- 09 subject to the Consolidated Conditions of Approval as illustrated and incorporated by reference as Attachment 3 of the City Council Staff Report.

BE IT FURTHER RESOLVED that the City Council of the City of Lathrop, based on substantial evidence in the administrative record of proceedings, its above findings, including the staff report and associated attachments, pursuant to its independent review and consideration, does hereby approve Conditional Use Permit No. CUP- 23- 08 and Site Plan Review No. SPR- 23- 09, subject to the Consolidated Conditions of Approval listed in Attachment 3 of the November 13, 2023 City Council Staff Report and incorporated by reference herein Resolution No. 23-
The foregoing resolution was passed and adopted this 13t" day of November 2023 by the following vote of the City Council, to wit:

AYES:

NOES:

ABSTAIN:

ABSENT:

SIGNED:

Sonny Dhaliwal, Mayor
ATTEST: APPROVED AS TO FORM:

Teresa Vargas, City Clerk Salvador Navarrete, City Attorney Resolution No. 23-
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Community Development Department — Planning Division
Amended Consolidated Conditions of Approval
September 13, 2023
Project Name: Ashley Furniture Project
File Number: Conditional Use Permit No. CUP- 23- 08 and Site Plan Review No. SPR- 23- 09 Project Address: 14101 S. Manthey Road ( APN: 192- 020- 14) The following list of conditions shall be incorporated into the fznal constritction plans and development phases of the project. The list of conditions are not intended to be all- inclusive or a comprehensive listing of all Ciry or district regulations. Please note that additional comments and/ or conditions may be added pending the response to the comments noted below and/or changes to the proposed project. The following comments and conditions ofapproval are based on the application and diagrams dated May, 2023.

PROJECT DESCRIPTION
Approval of this project authorizes the construction of a 1, 486, 607 sq. ft. concrete tilt-up building on a

89. 82- acre property located at the northwest corner of Dos Reis Road and Manthey Road and within the Central Lathrop Specific Plan Phase 2 Amendment area. The proposed building will include an up to three- story, 24, 000 sq. ft. office, an up to two- story 110, 260 sq. ft. retail outlet and showroom and a 1, 352, 347 sq. ft. warehouse distribution center. The project includes related on- and off-site improvements, including but not limited to off-street parking, lighting, landscaping, solid wall and wrought iron fencing, outdoor employee break area, paving, and street improvements ( landscaping, curb, gutter, and sidewalk

CEQA DETERMINATION
Exempt in accordance with Section 21083. 3 of the Public Resources Code and Section 15183 of the California Environmental Quality Act( CEQA) Guidelines.

PLANNING
l. The project is subject to and shall comply with the Project Requirements resulting from the Environmental Checklist prepared by De Novo Planning Group. The Project Requirements are incorporated by reference into this list of conditions ( attached).

2. The Conditional Use Permit and Site Plan Review shall not be in effect until the Rezone that is part of the City' s Zoning Consistency Project and Central Lathrop Specific Plan ( CLSP) Phase 2 Amendment are approved and in effect.

3. Signs ( Directional Signs) shall be placed on- site directing trucks north on S. Manthey Road towards Roth Road from the site. Signage shall be maintained by the applicant/property owner and replaced if damaged, destroyed or otherwise unreadable. Signage shall be reviewed and approved by the Planning Division.

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4. Sign( s) shall be placed in the drivers' lounge and/or breakroom associated with the project building directing trucks north on S. Manthey Road toward Roth Road from the site. The sign shall illustrate the Truck Route to and from the site, the City' s Truck Route Map and a reference to Chapter 10. 16, Truck Routes and Commercial Vehicles of the Lathrop Municipal Code ( LMC).

5. Evergreen trees planted along Dos Reis Road for the purposes of screening sha(I be in compliance with the CLSP Phase 2 Amendment.

6. Outdoor employee break area( s) shall include trash receptacles, shade structure( s), and seating areas. The final design and location of employee break area( s) shall be subject to review and approval by the Planning Division.

7. Passenger vehicle entryways shall include enhanced paving materials, such as herringbone design or stamped concrete. The extent of the enhanced paving materials shall be subject to review and approval by the Planning Division.

8. Interior truck operator lounge( s) and/ or employee break area( s) shall include on- site amenities, such as restrooms, vending machines, air conditioning, seating areas, etc. The truck operator lounge( s) and/ or employee break area( s) shall be subject to review and approval by the Planning Division.

9. With the exception of parking and storage of truck cabs and truck trailers, storage containers, and temporary load transfers, outdoor storage is prohibited, unless otherwise reviewed and approved by the Planning Division.

10. Installation of driveway entry/ security gates or interior site fencing shall subject to review and approval by the Planning Division, Building Department and Lathrop Manteca Fire District prior to installation. All driveway entry/ security gates shall provide truck queuing in front of the gate of at least seventy-five ( 75) feet in order to allow trucks with trailers to pull onto the site without blocking adjacent street rights-of-ways.

11. The security gate building ( guard shack) shall be architecturally compatible with the primary building as it relates to color, aesthetic, and material.

12. On- site fencing shall be maintained and in good working order for the life of the project. Damage and/ or wear- and- tear shall be repaired by the applicant/ property owner in a timely manner.

13. Prior to any ground disturbance, the project shall consult with the San Joaquin County MultiSpecies Habitat Conservation and Open Space Plan ( SJMSCP) for biological coverage, mitigation and participation in the plan. Participation in the SJMSCP satisfies requirements of both the State and Federal endangered species acts, and ensures that the impacts are mitigated below a level of significance in compliance with the California Environmental Quality Act ( CEQA).

14. The applicant shall coordinate with the San Joaquin Valley Air Pollution Control District to comply with District rules and regulation including but not limited to Rule 9510, Indirect Source Review. The applicant shall provide proof of compliance prior to building permit issuance.

15. The project shall comply with applicable site development provisions contained in the Central Lathrop Specific Plan Phase 2 Amendment Design Guidelines and Lathrop Municipal Code including but not limited to parking, lighting, landscaping, etc.

16. All areas not used for structures, parking, driveways, walkways, or other hardscape shall be landscaped and maintained by the property owner per Section 17. 92. 030( A)( 1) of the Lathrop Municipal Code to the satisfaction ofthe City.

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17. The applicant shall submit appropriate plans to the Community Development Department for plan check and building permit. Final site plan, elevation, landscaping and irrigation, exterior lighting and site improvement plans and details, etc. shall be reviewed and approved by the Planning Division. Any significant change or modification to the approved plan is subject to review and approval by the Community Development Director.

18. Landscaping and irrigation must be consistent with the City' s Water Conservation Requirements LMC 17. 92. 060) and the State Water Efficient Landscape Ordinance ( AB 1881). The applicant shall include with the landscape and irrigation plan a water efficient landscape worksheet with water budget calculations identifying the water allowance and estimated water use.

19. The applicant/ property owner shall ensure the entire site including landscaping areas shall be maintained in a healthy, weed free condition to the satisfaction of the City.

20. Trash enclosure( s) shall include but not be limited to a covered roof, metal gate and have three solid walls. Details and/ or alternative designs or location shall be subject to review and approval of the Planning, Building, and Public Works Department. The trash enclosure design, material and color shall match or compliment the main building.

21. It sha( 1 be the responsibility of the applicant/ property owner to ensure that any building or parking area lighting including security lighting associated with the project, be arranged so as to not cast light onto adjoining properties.

22. A final site lighting photometric plan with detailed specifications of all lighting fixtures, poles, and wall packs as well as a manufacture' s catalog sheet containing photometric data, shall be submitted with Building Permits for City review and approvaL Parking lots, driveways, trash enclosure/ areas shall be illuminated during the hours of darkness with a minimum maintained one foot- candle of light and an average not to exceed four foot- candles of light. The illumination shall not exceed ten ( 10) foot- candles in any one location.

23. No signs are approved for this project. A Master Sign Program for the project shall be prepared and submitted for review and approval by the Planning Division per Chapter 17. 84 of the Zoning Code. All signs shall require a Planning Division Sign Design application and a separate Building Permit application, subject to review and approval of the Planning and Building Divisions.

24. Bicycle parking shall be installed consistent with Chapter 17. 76. 120 of the LMC. In accordance with LMC Section 17. 76. 120( D), the proposed project shall provide changing facilities for employees/ workers utilizing bicycle to get to and from the use and bicycle lockers in a secure room equal to the minimum number of bicycle parking stalls required by Chapter 17. 76. Bicycle lockers should be in close proximity to the employee entrance. The final location( s) shall be subject to review and approval by the Planning Division. The secure room shall include electrical outlets for the purpose of charging electric bicycles ( e- bikes).

25. Roof-mounted mechanical equipment shall be screened and not visible from the public right- ofway. Screening materials shall be compatible with the architectural style, materials and color of the building upon which the equipment is located, subject to the approval of the Community Development Director or designee.

26. Ground- mounted equipment that is not required to be visible, shall be screened not visible from the public right-of-way using the most practical means of screening, such as landscaping, a freestanding wall/fence, matching paint, subject to approval of the Community Development Director or designee.

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27. Unless otherwise specified, all conditions of approval shall be complied with prior to the issuance of any Building Permits.

28. The Site Plan shall expire thirty- six ( 36) months from the date of approval unless a time extension is granted consistent with the policies and procedure of the Lathrop Municipal Code. Prior to the expiration date of August 30, 2026 a building permit must be issued and construction commenced and diligently pursued toward completion of the site or structures.

29. In the event clarification is required for an interpretation of these Conditions of Approval, the Community Development Director and City Engineer shall have the authority either to administratively clarify the intent and wording of these Conditions of Approval without the requirement of a public hearing or to refer questions regarding the interpretation of these Conditions of Approval to the Planning Commission. If the applicant take issue with the clarification provided administratively, the applicant shall have the right to appeal the administrative clarification to the Planning Commission. The Community Development Director and City Engineer shall also have the authority to make minor modifications to these conditions provided a request is made in writing by the applicant and it is determined such modifications are consistent with and in furtherance of the underlying intent of the condition being modified.

30. The City of Lathrop may conduct annual and or spot inspections to ensure that compliance with the required site improvements and conditions are being maintained.

31. The applicant shall install an eight ( 8) foot hi h chain link fence with vin privac slats black powder coated) alon the western property line to screen the outdoor stora e areas.

BUILDING

1. All construction associated with this project shall comply with the most recent adopted City and State building codes.

2. Special Inspections — As indicated by California Building Code Section 1704, the property owner/ developer shall employ one or more special inspectors who shall provide special inspections when required by CBC section 1704. The property owner/ developer shall contact the Building Department at time of plan submittal to obtain application for special inspections.

3. The Title Sheet of the plans shall include:

Occupancy Group Type of Construction
Occupant Load Height of Building
Description of Use Floor area of building( s) by occupancy group Area Analysis Code Used

4. The property owner/ developer shall be responsible for payment of school impact fees prior to the issuance of a building permit.

5. Dimensioned building setbacks and property lines, street centerlines and distances between buildings and structures shall be provided on the project site plan.

6. The project shall be designed to conform with energy conservation measures articulated in Title 24 of the California Code of Regulations and address measures to reduce energy consumption such as flow restrictors for toilets, low consumption light fixtures, and insulation and shall use to the extent feasible draught landscaping.

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7. All property lines and easements shall be shown on the site plan. A statement shall be provided that indicates such lines and easements are shown is required.

8. Public and private site improvements shall be designed in accordance with the Americans with Disabilities Act and Chapter 11 of the California Building Code. The site plan shall include a site accessibility plan identifying exterior routes of travel and detailing running slope, cross slope, width, pedestrian ramp, curb ramps, handrails, signage and truncated domes. The path of travel shall be provided from the public right of way and accessible parking to building. The design professional shall ensure that the site accessibility plan is in compliance with the latest Federal and State regulations. A site accessibility plan shall be required per the attached policy from the link below:
https:// www. ci. lathrop. ca. is/ sites/ default/ tiles/ fileattachments/ building division/ pa e/ 24708/ site accessibility plan_ requirements. pdf

9. At the time of building permit application submittal a design professional shall be required to prepare the formal construction plans for proposed improvements per the Business and Professions' Code.

10. Grading and Site Improvement permits from Public Works may be required separately from the accessibility plan in compliance with item 8.

PUBLIC WORKS
Land

1. The applicant shall dedicate all right- of-way ( ROW) necessary for the ultimate ROW width as represented in the approved Improvement Plans. A 10- foot public utility easement ( PUE) shall also be dedicated along all ROW frontages.

Public/ Fronta e Im rovements

1. The applicant shall submit an encroachment permit for all work within the public right- of-way and City owned or controlled property.

2. The applicant shall be required to install full street frontage improvements along all frontages of the parcel being developed or improved. Frontage improvements shall include but are not limited to curb, gutter, sidewalk, street lights, hydrants, asphalt concrete paving, striping, driveways, and landscaping. The extent of paving shall include one- half ultimate street width or as otherwise stated in the City of Lathrop Municipal Code. The applicant shall submit the off-site plans for approval along with the applicable plan check and inspection fees.

3. The applicant shall underground all existing and new overhead utilities on both sides of the frontage street in compliance with the Lathrop Municipal Code. Overhead power lines in excess of 34. 5 KVA are not required to be undergrounded.

4. As recommended in the TJKM Traffic Impact Analysis Report, the applicant shall complete the following improvements prior to issuance of a certificate of occupancy, including a temporary certificate of occupancy:
a. Lathrop Road/ I- 5 SB Ramps: Optimize signal timing to achieve an acceptable level of service. Align signal timing with coordination plan for the Lathrop Road corridor.

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b. Golden Valley Parkway & Spartan Way/ Lathrop Road Intersection: Grind existing striping, slurry seal extents of striping and restripe the following configuration to City Standards:
i. NB Approach: One left-turn lane, one through lane, two right- turn lanes ii. SB Approach: Two left-turn lanes, two through lanes, one right- turn lane iii. EB Approach: One left turn- lane, two through lanes, one right- turn lane iv. WB Approach: Two left- turn lanes, two through lanes, one right- turn lane

5. The TJKM Traffic Impact Analysis Report found that the Lathrop Road/ I- 5 NB Ramp will degrade from LOS E to LOS F with the Project in the Baseline plus Project condition, which will require the construction of a 400 foot separate right turn lane on the NB Ramp. The applicant shall conduct current traffic counts for the NB Ramp to confirm the baseline condition and complete a technical memorandum to document the findings of the traffic counts. If the results of the technical memorandum indicate that the impact is negligible or that the level of service does not degrade below LOS D in the Current Baseline plus Project condition, the project shall not be required to construct the 400 foot separate right turn lane on the NB Ramp. If the results of the traffic counts indicate that the project operations would cause the LOS to degrade below a LOS D with the Project, the applicant shall be required to construct the 400 foot separate right turn lane on the NB Ramp. If the improvements are required, applicant shall design, estimate construction cost and provide performance and labor & materials guarantee to the City for the improvements and enter into a deferred frontage improvement agreement with the City prior to issuance of a building permit for the Project. If required, the applicant shall work towards construction of the improvements in a timely manner for completion as close to the occupancy of the Project as possible.

6. The applicant shall be required to improve Golden Valley Parkway from Spartan Way to Dos Reis Road. Golden Valley Parkway is currently improved from Spartan Way to about 240 feet south of Does Reis Road and includes utilities, curb & gutter, and bottom lift pavement and subgrade. The applicant shall be required to complete the improvements on Golden Valley Parkway to include but not limited to sidewalk, top lift pavement, striping, signing, landscaping and lighting. The improvements are eligible in part for City Transportation Capital Facility Fee ( CFF) credit or reimbursement as portions are included in the existing City CFF program and this roadway provides a regional benefit.

7. The applicant shall be required to construct a roundabout at the intersection of Golden Valley Parkway and Dos Reis Road. The roundabout shall be an enhanced gateway to the CLSP Phase 2 area and shall include components such as monumentation, art, enhanced landscaping, lighting, etc. The roundabout shall include safetLprovements such as pedestrian actuated flashin warning si n s_ The final design shall be approved by the City Engineer. The applicant shall submit the roundabout plans for approval as part of the offsite improvement plans.

8. The applicant shall be required to abandon and barricade Manthey Road between Lathrop Road and Dos Reis Road upon completion of the improvement of Golden Valley Parkway. This abandonment is necessary to facility the proper traffic circulation for the project.

9. The applicant shall be required to install signage on Lathrop Road, Spartan Way, Golden Valley Parkway, Dos Reis Road and Manthey Road south of Dos Reis Road prohibiting trucks from utilizing these roadways. Location and size of the signage shall be reviewed and approved by the City Engineer prior to issuance of an occupancy permit.

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10. Applicant shall comply with Chapter l 0. l 6, Truck Routes and Commercial Vehicles of the LMC.

11. The a plicant shall construct a raised " pork chop" with bollards at the northeast corner of Spartan Way and Golden Valley Pai k vav to discotira e semi- trucks fi•om makin a ri ht-turn towacds the Central Lathrop Specific Plan ( CLSP) Phase 2 area. The design of the improvements shall be eview ed and a proved by the Citv Engineer and must be installed prior to the issuance of a Certificate of Occupanc

12. The ap licant shall construct a raised median on S. Manthey Road adjacent to the truck driveway at the facility to disco ira e trucks from making a left turn in and a ri ht turn out of the facility.

The desi n of the improvements shall be reviewed and approved by the City Engineer and must be instal led prior to the issuance of a Certificate of Occi anc Wastewater

1. The applicant shall be required to connect to the City sewer system prior to certificate of occupancy for the first building within the project.

2. The applicant shall secure sufficient sewer capacity for the project and pay all connection fees and reimbursements.

3. The project will connect to the existing Central Lathrop Phase 1 gravity sewer main system and the wastewater will be conveyed to the City' s Treatment Plan by use of the existing Central Lathrop Phase 1 wastewater pump station and force mains. The applicant shall provide calculations to the City Engineer proving that these existing facilities can support the additional wastewater discharge from the project and shall install any improvements needed to accommodate the project ifthe existing facilities are deficient.

Potable Water

1. The applicant shall be required to connect to the water utility for domestic supply prior to certificate of occupancy and pay all applicable connection fees. All existing groundwater wells on site shall be abandoned under a permit from San Joaquin County prior to connecting potable water to the site.

2. The applicant shall secure sufficient water capacity for the project and pay all connection fees and reimbursements.

3. The project will connect to the existing Central Lathrop Phase 1 potable water system. The applicant shall provide calculations to the City Engineer proving that these existing facilities can support the projects needs and shall install any improvements needed to accommodate the project if the existing facilities are deficient.

Recvcled Water
l. Applicant shall install recycled water mains along all frontages if not existing. All public landscaping shall be irrigated with recycled water and a recycled water hydrant shall be placed in an accessible location along the frontage to provide a filling station for street sweeping activities and construction.

2. All recycled water points of connection for irrigation require the installation of a recycled water meter.

Storm Drain
l. The applicant shall be required to connect to storm drain utility and pay all applicable connection fees.

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2. Hydrology and hydraulic calculations and plans for on- site and off-site storm drainage systems shall be submitted to the City for review and approval.

3. As part of their onsite improvements, the applicant shall install all necessary Best Management Practices ( BMP' s) for post construction in accordance with City guidelines and standards. The BMP' s must be in place prior to final occupancy for the project.

4. The applicant shall execute a maintenance agreement for all onsite storm water quality treatment devices, swales, and/ or ponds.

5. The project will connect to the existing Central Lathrop Phase 1 storm water system for Watershed 4. The applicant shall provide calculations to the City Engineer proving that these existing facilities can support the projects needs and shall install any improvements needed to accommodate the project ifthe existing facilities are deficient.

General

1. The applicant shall retain the services of a California licensed civil engineer to design the project utility plans for sewer, water, storm drain lines and systems.

2. The applicant shall ensure that all off-site and on- site improvements comply with City Standards as illustrated on the approved Improvement Plans.

3. All on- site water, sewer, and storm drain systems that are privately owned shall be maintained by the property owner.

4. The parking areas and drive aisles on site shall be paved with asphalt concrete.

5. The project shall comply with the Multi- Agency Post Construction Storm Water Manual.

6. Grading and other construction activities that may cause dust shall be watered to control dust at the City Engineer' s direction. A water vehicle shall be available eon site for dust control operations at all times during grading operations. The adjacent public street shall be kept free and clean of any project dirt, mud, materials, and debris.

7. The applicant shall pay all appropriate fees including, but not limited to, North Lathrop Transportation Fee, Levee Impact Fee, Capital Facilities Fees, and Plan Check and Inspection Fees.

8. A geotechnical report shall be submitted for the project, which includes groundwater elevations, percolation rates for retention basins, soil compaction requirements, and recommendations for asphalt paving and concrete. Building PAD certification is required from Geotechnical Engineer and/ or Special Inspector.

9. All water meters shall be installed within the public right of way or public utility easement. The City shall not be the responsible party for maintaining water and sewer lines beyond existing main line stub outs or on private property, unless otherwise agreed to by the City.

10. The applicant has the option to enter into a reimbursement agreement with the City for construction cost reimbursement of any infrastructure that provides regional benefit.

11. All improvements shall be designed and constructed per the most current City Standards.

12. The applicant shall create or participate in a Community Facilities District ( CFD) to fund the maintenance of all public infrastructure prior to issuance of the first building permit associated with the project.

Page 8 of 18 ends

13. If the project is greater than one acre; the applicant shall complete a SWPPP, obtain a WDID number and list the number on the improvement plans, and submit the SWPPP to the City for review and approval.

LATHROP- MANTECA FIRE DISTRICT ( LMFD)

1. The project shall conform to the most currently adopted edition of the California Fire Code and all related standards.

2. Permits shall be obtained from the fire code officiaL Permit( s) and fees, shall be paid prior to issuance of any and/ or all permits. Issued permits shall be kept on the premises designated therein at all times and shall be readily available for inspection by the fire code officiaL ( Permits are to be renewed on an annual basis).

3. Depending on the proposed Occupancy Type & fire area occupant load, Automatic Fire Sprinklers may be required. In the case where automatic fire sprinkler systems are required, such systems shall comply with California Fire Code Section 903. 2 and the Tenant/ Occupant/ Owner shall have the responsibility to ensure that the correct fire suppressions system is added/ modified/ tested and accepted by the ( AHJ) Fire District for review and approval prior to modification. Deferred submittal accepted.

4. All residential structures shall be Fire Sprinkler protected, as per the City of Lathrop' s Fire Sprinkler Ordinance, California Fire Code, California Residential Code, and the California Building Standards Codes. Fire suppression system plans shall be modified under separate fire permit and shall be submitted by a licensed fire contractor, to the ( AHJ) Fire District for review and approval prior installation. Deferred plan submittals are accepted.

5. Fire Sprinkler System alterations and plans shall be submitted directly to LMFD.

6. Fire Alarm System upgrades and plans shall be submitted directly to LMFD.

7. A means of Ingress and Egress Plan shall be submitted with the project Tenant Improvement Plans.

8. An approved fire alarm system shall be installed in accordance with CFC § 907. 2 and NFPA 72.

9. Fire Department Development Impact Fees for all new buildings shall be paid in accordance with the City of Lathrop Municipal Code and Resolutions of the adopted fee schedule.

10. An approved Fire Flow test shall be conducted prior to ground breaking to determine allowable Fire Fighting capabilities for the site.

11. An approved water supply for fire protection, either temporary or permanent, shall be made available prior to commencing construction beyond the foundation stage, or as soon as combustible material arrives on the site.

12. Deferred Plan Submittals for Fire Alarm, Fire Sprinklers and Fire Underground shall be submitted directly to LMFD.

Page 9 of 18 ends

13. Fire apparatus access roads shall be designed and maintained to support the imposed loads of fire apparatus and shall be surfaced so as to provide all- weather driving capabilities. Fire apparatus access roads shall have an unobstructed width of not less than 20 feet ( 6096 mm), exclusive of shoulders, except for approved security gates in accordance with California Fire Code ( CFC) Section 503. 6, and an unobstructed vertical clearance of not less than 13 feet 6 inches ( 4115 mm).

Adequate turnaround shall be provided per City of Lathrop Standards and Appendix D of the 2022 CFC.

14. Where access to the development is restricted because of secured openings or where immediate access is necessary for life- saving or fire- fighting purposes, a key " knox" box is required to be installed in an approved location. The key " knox" box shall be of an approved type and shall contain keys to gain necessary access as required by the fire code officiaL In addition to key knox" box( es), any automatic gates shall have Opticom access ability to provide necessary access for emergency apparatus.

15. Where a portion of the added street is constructed more than 200 feet ( 61 meters) from a hydrant on a fire apparatus access road, as measured by an approved route, the developer shall provide an additional fire hydrant and main shall be provided. NOTE: The developer shall provide exact locations and distances of existing hydrants in the area. ( CFC Appendix C, and City of Lathrop Water System Standards).

16. The developer shall be responsible for providing approved vehicle access for firefighting to all construction and demolition sites. Vehicle access shall be provided to within 100 feet ( 30, 480 mm) of temporary or permanent fire department connections. Vehicle access shall be provided by either temporary or permanent roads, capable of supporting vehicle loading under all weather conditions. Vehicle access shall be maintained until permanent fire apparatus access roads are available.

17. The Fire Department Fire Access Roads shall meet the requirements established by the San Joaquin County Fire Chiefls Association.

18. The turning radius for his project shall be a minimum of 41 feet for all Emergency Fire Apparatus.

19. Buildings exceed 30 feet in height shall have a minimum unobstructed fire apparatus access width of 26 feet.

20. Commercial cooking equipment that produce grease laden vapors shall be provided with a Type I Hood, in accordance with the California Mechanical Code, and automatic fire extinguishing system that is listed and labeled for its intended use as follows:
a. Wet chemical extinguishing system, complying with UL 300 b. Carbon dioxide extinguishing systems
c. Automatic fire sprinkler systems

21. Where a portion of the facility or building hereafter constructed or moved into or within the jurisdiction is more than 400 feet ( 122 meters) from a hydrant on a fire apparatus access road, as measured by an approved route around the exterior of the facility or building, on- site fire hydrants and mains shall be provided where required by the fire code official.

22. At LMFD' s discretion the proposed project may be subject to other fire & life safety requirements at the time of building plan review.

Page 10 of 18 ends

23. Final approval is subject to field inspections. A minimum 48 to 72- hour notice is required prior to any life- safety fire inspections. Other conditions may apply at time of inspections and are subject to correction.

LATHROP POLICE DEPARTMENT ( LPD)

1. The applicant shall paint the address on the roof top for each individual building. The numbers shall be at least 3 feet tall, 2 feet wide, 9 inches apart, with 6- inch brush stroke with a color that contrast the roof top, top of numbers/ letters should point north.

2. The applicant shall install dedicated lights in the parking lot that are properly maintained including the drive access.

3. The applicant shall install an indoor and outdoor recording security camera system that shall be maintained by the property owner and accessible to LPD with camera views covering all ingress and egress to all building( s) and parking areas. The quantity and location shall be reviewed and approved by LPD prior to issuance of an occupancy permit.

4. Where access to the development is restricted because of secured openings or where immediate access is necessary for life- saving or emergency purposes, a key " knox" box is required to be installed in an approved location. The key " knox" box shall be of an approved type and shall contain keys to gain necessary access as required by the police chie£ In addition to key " knox" box( es), any automatic gates shall have Opticom access ability to provide necessary access for emergency vehicles.

5. The proposed landscaping for this project shall conform to the following CPTED measurements:
a. Maintain natural visible surveillance to building from parking lot and street. b. Plants taller than 8 feet shall be trimmed up to 4 feet from ground. c. Plans under S feet shall be trimmed to allow ground level surveillance.

ADMINISTRATIVE SERVICES

1. By exercising this approval, the applicant hereby agrees to indemnify, hold harmless and defend the City, its officers, agents, elected and appointed officials, and employees, from any and all liability or claims that may be brought against the City arising out of its approval of this Site Plan Review and Conditional Use Permit to the fullest extent permitted by law.

SAN JOAQUIN COUNTY ENVIRONMENTAL HEALTH DEPARTMENT
See attached memorandum dated June 21, 2023.

Page 11 of 18 ends

Q( Environmental Heal#h Departme, t
C Ca t. 1 T 1___._... Jasjit Ka. REHS, Director
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From: Cesar Ruv icaba( 209) 953- 62t3
L.ead Seniar Regist ered Envfror m nta Health Specia# is# RE: CUP- 23-08, SPR- 23- 0, Referral, SU i5642, SUOOi56d1 141Q1 S. Martthey Raad ( APN: 192- 020- 14)
The San Jc aquin County Enviranmentat NeaCih Department{ EHa) recommends the faiic wing conditior s as a part af develaping this praject:

1. Any geotechr icat drilling shaii be conduct d und r permii and inspect`ron by The Ernir anmental Neaitt Gepartment ( San Joaquin Caunty Development Titfe, Section 9- 801. 010{b} and 9-601. 020{} j.

2. Any abandoned wells or septic systems shal! be destroyed under permit and inspeetion by the END( San Joaquin Caunty Qevelopment Title, Section 9- 605. 010& 9- 601. 024) t868 E. Hazeiton Avenue Stodctaro. Ga ifom a 95205 T 2f}9 468- 342 F 2€39 464-0138 wwvr sj ay. or t hd

Page 12 of 18 ends

ENVIRONMENTAL CHECKLIST

SUMMARY OF PROJECT REQUIREMENTS

Page 13 of 18 ends

Summary of CEQA Project Requirements for the Ashley Warehouse Project Requirement AG- 1: Imp/ ement Lathrop Municipal Code Chapter 3.40 AGRICULTURAL MITIGATION FEE Section 3. 40. 030 Collection of Agricultural Mitigation Fee.

The Agricultural Mitigation Fee enacted pursuant to this chapter is to be collected by the city before the issuance of building permits, or at approva/ of any discretionary permit if no building permit is required.

Ord. OS- 248§ 1 J
Requirement AG-2: Require a/l deve/opment to coordinate with and participate with SJCOG in the SJMSCPAgricultura/ Mitigation Fee program as required.

Requirement AQ- 1: Comp/ y with SJVAPCD Rule 95101ndirect Source Review Requirement AQ- 2: Comply with SSJVAPCD Regulation Vl/ l for all sites and implementation control measures indicated in Tables 6-2 and 6-3 of the SJVAPCD' s Guide for Assessing and Mitigating Air Quality Impacts.

Requirement BIO- 1: Compliance with the San Joaquin County Mu/ ti-Species Habitat Conservation and Open Space Plan( SJMSCPJ
Requirement 810- 2: Compliance with the mitigation recommendations included within Biological Resources Ana/ ysis Report( AttachmentA).

VELB Buffer and/ or Survey— VELB is a species covered by the SJMSCP ( SJCOG 2000), and the incidental take minimization and mitigation measures outlined in the document are as follows:

In areas with elderberry bushes, as indicated by the SJMSCP Vegetation Maps or per a preconstruction survey identification or other sources indicated in Section 5. 2. 2. 3, the following shall occur:

A. If elderberry shrubs are present on the project site, a setback of 20 feet from the dripline of each elderberry bush shall be established.

B. Brightly colored flags or fencing shall be placed surrounding elderberry shrubs throughout the construction process.

C. For all shrubs without evidence of VELB exit holes which cannot be retained on the project site as described in A and B, above, the JPA shall, during preconstruction surveys, count all stems of 1" or greater in diameter at ground level. Compensation for removal of these stems shall be provided by the JPA within SJMSCP Preserves as provided in SJMSCP Section 5. 5. 4( B).

D. For all shrubs with evidence of VELB exit holes, the JPA shall undertake transplanting of elderberry shrubs displaying evidence of VELB occupation to VELB mitigation sites during the dormant period for elderberry shrubs ( November 1 - February 15). For elderberry shrubs displaying evidence of VELB occupation which cannot be transplanted, compensation for removal of shrubs shall be as provided in SJMSCP Section 5. 5. 4 ( C)." If the elderberry shrub can be maintained on the project site, then a 20 ft. setback will need to be established around the shrub ( See Figure 11). If the shrub cannot be maintained on the project site, then VELB exit hole surveys consistent with the USFWS protocol ( USFWS 2017) will be performed prior to any ground disturbance. Depending on the results of this survey, either mitigation measure C or D above will be used.

Page 14 of 18 ends

Pre- construction Reptile Survey — Both California glossy snake and San Joaquin coachwhip have a low potential to occur on the Property and therefor a pre- construction survey should be performed no more than 48 hours prior to ground disturbance or vegetation removal.

Surveys would be required to determine presence/ absence of this species. If the species are found to occur on the project site, then passive relocation methods should be attempted before ground disturbance.

Pre- Construction Avian Survey — If project construction- related activities would take place during the nesting season ( February through August), preconstruction surveys for nesting passerine birds and raptors ( birds of prey) in large trees adjacent to the project site should be conducted by a competent biologist 14 days prior to the commencement of the tree removal or site grading activities. Specific attention should be paid to the active Swainson' s hawk nest that was identified across Dos Reis Road from the project site. As per the Incidental Take Minimization Measures for Swainson' s hawk that are outlined in Section 5. 2. 4. 11 of the SJMSCP ( SJCOG 2000):

If a nest tree becomes occupied during construction activities, then all construction activities shall remain a distance of two times the dripline of the tree, measured from the nest." The dripline for the tree where the Swainson' s hawk nest was observed is estimated to be 25 feet, making the required buffer for this nest 50 feet. The nest location and buffer are shown in Figure 11.

If any other birds listed under the Migratory Bird Treaty Act are found to be nesting within the project site or within the area of influence, an adequate protective buffer zone should be established by a qualified biologist to protect the nesting site. This buffer shall be a minimum of 50 feet from the project activities for passerine birds, and a minimum of 250 feet for other raptors. The distance shall be determined by a competent biologist based on the site conditions ( topography, if the nest is in a line of sight of the construction and the sensitivity of the birds nesting). The nest site( s) shall be monitored by a competent biologist periodically to see if the birds are stressed by the construction activities and if the protective buffer needs to be increased. Once the young have fledged and are flying well enough to avoid project construction zones ( typically by August), the project can proceed without further regard to the nest site( s).

Burrowing Owl Surveys — Burrowing owls were not identified on the project site during May 2021 survey. However, a burrowing owl pre- construction survey should take place before any construction activities commence. It is recommended that they be conducted whenever burrowing owl habitat or sign is encountered on or adjacent to (within 150 meters) a project site. Occupancy of burrowing owl habitat is confirmed at a site when at least one burrowing owl or its sign at or near a burrow entrance is observed within the last three years. If a burrowing owl or sign is present on the project site three additional protocol level surveys will be initiated. As per the incidental take minimization and mitigation measures outlined in the SJMSCO ( SJCOG 2000): If burrowing owls are identified and work is to commence during the non- breeding season ( September 1 through January 31), then the owls should be evicted from the project site by passive relocation as described in the CDFW' s report on burrowing owls 1995). If work occurs during the breeding season ( February 1 through August 31) then the burrows shall not be disturbed and will be provided with a 75- meter protective buffer.

However, if it is determined that the birds have not begun laying eggs, or the juveniles from the occupied burrows are foraging independently and are capable of independent survival, then the burrows can be destroyed.

Page 1 ends

Erosion Control — Grading and excavation activities could expose soil to increased rates of erosion during construction periods. During construction, runoff from the warehouse site could adversely surrounding habitats and cause increased particulate matter to enter the storm drain system. Implementation of appropriate mitigation measures would ensure that impacts to aquatic systems would be avoided or minimized. Mitigation measures may include best management practices ( BMP' s) such as hay bales, silt fencing, placement of straw mulch and hydro seeding of exposed soils after construction as identified in the Storm Water Pollution Prevention Plan ( SWPPP).

Requirement CUL- 1: Implement General Plan Action: RR 3b RR- 3b: Require all new development, infrastructure, and other ground- disturbing projects to comply with the following conditions in the event of an inadvertent discovery of cultural resources or human remains:

A. If construction or grading activities result in the discovery of significant historic or prehistoric archaeological artifacts or unique paleontological resources, all work within 100 feet of the discovery shall cease, the Community Development Director shall be notified, the resources shall be examined by a qualified archaeologist, paleontologist, or historian for appropriate protection and preservation measures; and work may only resume when appropriate protections are in place and have been approved by the Community Development Director; and
B. If human remains are discovered during any ground disturbing activity, work shall stop until the Community Development Director and the San Joaquin County Coroner have been contacted. If the human remains are determined to be of Native American origin, the Native American Heritage Commission and the most likely descendants shall be consulted; and work may only resume when appropriate measures have been taken and approved by the Community Development Director.

Requirement GEO- 1: Imp/ement recommendations presented in the Preliminary Geotechnical Engineering Report. Prepared by: Terracon Consu/ tants, Inc. during the project design and construction.

Requirement HAZ- 1: If the project will store, transport or hand/ e hazardous materia/ s the project shall be required to prepare and file a Hazardous Materials Business Plan ( HMBP) with the City prior to issuance of Certificate of Occupancy.

Projed Requirement Hydro- 1: The project applicant shall prepare a Storm Water Pollution Prevention Plan ( SWPPPJ that includes specific types and sources of stormwater pollutants, determine the location and nature of potential impacts, and specify appropriate contro/ measures to eliminate impacts on receiving water quality from stormwater runoff. The SWPPP shall require treatment BMPs that incorporate, at a minimum, the required hydraulic sizing design criteria for vo/ume and flow to treat projected stormwater runoff. The SWPPP shall comp/ y with the most current standards established by the RWQCB, and the Lathrop Storm Water Program. Best Management Practices shall be subject to approval by the City Engineer and RWQCB.

Project Requirement Hydro 2: Prior to approval of the building permit, the project applicant shall submit a detailed Stormwater Contro/ P/ an constant with General Plan Action PFS- 4. 5, and the criteria set forth in the Lathrop Stormwater Program.

Requirement N-1: Implement General P/an Policy N- 1. 15, and Lathrop Municipal Code Section 8.20.110 Construction of buildings and projects).

Page 16 of 18 ends

N- 1. 15 Construction Noise. Require construction activities to reduce noise impacts on adjacent uses to the criteria identified in Table N- 3, or, if the criteria cannot be met, to the maximum extent feasible complying with Title 15 of the LMC ( Building and Construction) and use best practices. Construction activities outside of the permitted construction hours identified in the LMC may be approved on a case- bycase basis by the Building Official.

Lathrop Municipal Code Section 8. 20. 110 ( Construction of buildin s and proiects) " It shall be unlawful for any person within a residential zone or within a radius of five hundred ( S00) feet therefrom, to operate equipment or perform any outside construction or repair work on buildings, structures or projects or to operate any pile driver, power shovel, pneumatic hammer, derrick, power hoist, or any other construction type device between the hours of ten p. m. of one day and seven a. m. of the next day, or eleven p. m. and nine a. m. Fridays, Saturdays and legal holidays, in such a manner that a reasonable person of normal sensitiveness residing in the area is caused discomfort or annoyance unless beforehand a permit therefore has been duly obtained from the office or body of the city having the function to issue permits of this kind. No permit shall be required to perform emergency work as defined in Sections 8. 20. 010 through 8. 20. 040. ( Prior code§ 99. 40)"

Page 17 of 18 ends

ACKNOWLEDGEMENT OF TERMS AND CONDITIONS
I have read, understand and acknowledge the Conditions of Approval dated 9/ 13/ 2023
for
the Ashley Furniture Project.

C?- ,--_
Signature of Applicant( s)
Aaron Hodgdon
Print Applicant( s) Name
9/ 6/ 2023
Date

Page 18 of 18 ends

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PROJECT SPECIFIC SITE PLAN REVIEW APPROVAL
Case No. SPR- 23- 09
Development Team
Applicant Hodgdon Management and Construction, Inc.
1461 E Cooley Dr, Ste 230
Colton, CA 92324
Developer Hodgdon Management and Construction, Inc.
1461 E Cooley Dr, Ste 230
Colton, CA 92324
Architect HPA Architects
18831 Bardeen Ave
Irvine, CA 92612
Civil Engineer/ Landscape MacKay& Somps
5142 Franklin Dr, STE B
Pleasanton, CA 94588
Traffic Engineer TJKM
4305 Hacienda Dr, STE SSO
Pleasanton, CA 94588
Acoustical Consultant— Noise Saxelby Acoustics
Assessment 915 Highland Pointe Drive, STE 250
Roseville, CA 95678
CEQA Consultant and Air Toxics De Novo Planning
Health Risk Assessment 1020 Suncast Ln, # 106
EI Dorado Hills, CA 95762
1 TABLE OF CONTENTS
A. REQUESTAND PROPERTY DESCRIPTION.................................................. 3 B. PROJECT DESCRIPTION ............................................................................... 3 C. PERMITTED USES.......................................................................................... 4 D. SITE DETAILS................................................................................................. 5 E. ARCHITECTURAL DESIGN ............................................................................ 7 F. SITE DESIGN CRITERIA ................................................................................. 7 G. LANDSCAPING............................................................................................... 7 H. EMPLOYEE AMENITIES..................................................................... 8 I. GRADING AND DRAINAGE............................................................................. 8 J. UTILITIES AND INFRASTRUCTURE. .............................................................. 9 K. PROJECT SCHEDULE........................................................................ 9 L. SUMMARY........................................................................................ 9 2 ASHLEY FURNITURE
Project Specific Site Plan Review Approval Narrative
A. Request and Property Description
The applicant is requesting a conditional use permit for the development of a new integrated, high- quality warehouse/ light industrial/ retail office development on approximately 89. 5- acre property located at the northwest corner of Dos Reis Rd and Manthey Road ( the " Property"). The proposed development will support the expansion needs of an international company specializing in uses that include light- industrial, warehouse and distribution, office, and retail sales of targeted bulk consumer goods.

The 2022 Lathrop General Plan Update designates the Property within an industrial area in the Central Lathrop Phase II area. The City of Lathrop is currently processing the Central Lathrop Specific Plan Phase II amendment and rezoning to implement the new General Plan Update designation for this area. The Property was formerly agricultural but now currently fallow. The Property is bound by fallow agricultural land directly to the north and De Lima Rd & Manthey Rd and Interstate 5 freeway to the east.

The Property' s western boundary is vacant, fallow agricultural land and the south boundary is Dos Reis Rd adjacent to vacant commercially zoned land and mixed vacant land and commercial/ residential.

B. Proiect Description
The proposed development includes an approximately 1, 486, 607 square foot single or multi- tenant building with a mix of retail, office/ call center, and warehouse and distribution uses ( the " Project").

The Project is anticipated to be an attractive, high- quality development that will provide substantial employment opportunities within the City of Lathrop, including up to 500 diverse jobs at full operation.

The Project consists of a single building, with a mix of tenant- related uses. The primary mix of uses within the Project building include an up to 100, 000 square foot retail showroom, a 24, 000 square foot, 2- 3 story office space consisting of call center and a regional office for up to 50 people. Warehouse and distribution uses will comprise the balance of the 1, 352, 347 square feet. The proposed building' s height is approximately 50 feet, with architectural features that may extend to approximately 60 feet.

Vehicular & Truck access to the Property is proposed via four ( 4) access drives; one 1) access drive on Manthey Rd at the far northeast corner is dedicated for truck ingress/ egress onto and from the Project. One ( 1) public and employee vehicular access mid- block on Manthey Rd is proposed for ingress/ egress of the public and employees' access to the retail and office. Two ( 2) additional access points are 3 proposed along Dos Reis Rd with the most eastern access proposed for public vehicular access to the retail and customer pick- up areas located at the southeast corner of the building. A fourth and final access is closed to the public and trucks and is reserved only for emergency vehicle access. Per the Traffic Impact Analysis completed by TJKM as a part of the Site Design Review package approval the project is expected to generate 680 daily truck trips including 95 a. m. peak hour trips and 45 p. m. peak hour trips.

The developer will widen Dos Reis Road and Manthey Road to their ultimate condition and compliant with the Central Lathrop Specific Plan Phase 2 Amendment CLSP 2). Landscape and sidewalk improvements beyond the back of curb along the southern portion of Dos Reis Road will be constructed by future developers of the adjacent properties.

Per the Traffic Impact Analysis completed by TJKM as a part of the Site Design Review package approval the project is expected to generate 680 daily truck trips including 95 a. m. peak hour trips and 45 p. m. peak hour trips.

Once customers are on site, internal circulation roads will route them to the retail entrance in the center of the building. For furniture pick up, customers are directed to a separate waiting area labeled on the plan as " Customer Pick- up", (" CPU") located on the southeast corner of the building where customers will be guided to the CPU office and their pickup location.

Hours of operation will vary among the distribution, call center, and retail portions of the development. Retail hours are anticipated to align with the typical store hours of other Ashley Furniture locations in the Bay Area, running from 9: 00 am to 9: 00 pm 7 days a week. However, these hours are subject to change with final design.

The call and distribution centers are expected to have a broader range of operating hours, accommodating several shift changes throughout the day to ensure efficient operations. The specific number of shifts and their timeframes will be determined during the final design phase, considering operational requirements and workforce needs.

During final design, more detailed information regarding the hours of operations, the number of shifts, days of operation and the specific timeframes of shifts will be provided.

C. Permitted Uses
I. Permitted land uses for the Project include:

1. Call center

2. General retail sales

3. Office

4. Outdoor trailer parking

5. Outdoor storage associated with an on- site primary use, excluding vehicles
4 6. Sale of products including those assembled on- site as well as imported prod uct

7. Retail showroom

8. Warehousing and Distribution
D. Site Details
I. Liqhtinq
Light levels are not to exceed 1- foo# candle at the property line. All proposed site lighting will comply with city zoning requirements.

II. Screeninq
The project proposes a 30-foot landscape buffer along the Dos Reis Road project frontage, in accordance with the Central Lathrop Specific Plan Phase 2 Amendment CLSP 2). To further enhance screening for trailer parking areas, an 8- foot- tall community wall is proposed along the right-of-way of Dos Reis Road at the project frontage. Additionally, the project proposes an increased number of deciduous trees between the 8- foot paved sidewalk and the 8- foot- tall community wall. This condition will extend along the south boundary of the property until the first driveway east of the proposed Dos Reis Road and Golden Valley Parkway roundabout. Proceeding north along Manthey Road, the tree spacing, and landscape design will transition to a less dense arrangement typically found in retail areas.

III. Air Qualitv Best Manaqement Practices
The project demonstrates compliance with the City of Lathrop General Plan Best Management Practices, as outlined in Implementation Action LU- 5. d. The following measures have been implemented to align with these practices:

The 30- foot landscape buffer described in section D. II provides a physical and structural buffer between possible sensitive receptors and the warehouse/ trailer parking area.

Sufficient onsite parking and queuing locations have been included in the project site plan, accommodating multiple truck lengths. This design ensures that trucks do not idle within public right- of-way.

The project site plan is designed so that truck ingress/ egress is largely isolated to the most Northeastern corner of the development along Manthey Road.

Generous setbacks have been incorporated between loading docks and property lines.

In areas where trailer parking is present, a community wall has been strategically placed along visible sections of right-of-way and property lines to screen views.
5 Wayfinding signs have been specifically designed and positioned at truck ingress/ egress locations, clearly indicating that truck traffic is restricted to Roth Road only.

IV. Walls & Fences
See Screen Wall & Fencing Plan; Sheet DAB-A4.2
V. Parkinq Standards
On- site parking for the Project shall be provided in accordance with Table 1 below:

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6 E. Architectural Desiqn
The architectural character of the development will have a high- tech contemporary appearance. This will be established using clean edges and forms, and colors. The development' s east elevation, facing Manthey Rd & Interstate 5, will convey a high- quality office/ retail appearance while maintaining key functions, including customer pick- up areas along the southeast elevation. This is achieved with glazing to indicate an office appearance and clerestory windows along the upper portions of the fa ade. Please refer to the conceptual building elevations on Sheet DAB-A3.3.

The conceptual building elevations include strong architectural forms and distinct design elements, such as accent shading features, variations in parapet height and colors. Collectively these provide for enhanced visual interest and varied building massing, to create distinctive points of entry for users. A combination of concrete tilt up wall panels with a series of reveals and patterns in the tilts will accent the building elevations. Curtain wall glazing systems at each entry location will highlight the material variation, with portions that reach a high elevation to accommodate two to three- story office/ retail within the building. These various treatments will be incorporated into the project design to provide variation and texture to the building fa ade.

F. Site Desiqn Criteria
The conceptual site plan orients the Project to Manthey Rd. Public access to the Property will be provided via Manthey and Dos Reis Roads in the locations shown on the site plan. These points of access and internal circulation provide good access to users, employees, and customers. Generous landscaping along Dos Reis effectively screens the south elevation from Dos Reis Rd, while dense and tasteful landscape accents the east elevation and the retail portion of the project.

Dedicated truck access located at the very northeast corner of the property is the only access point for ingress and egress of truck traffic. Trucks are restricted from going south of this access point and will come from and to the north towards Roth Rd interchange only.

The conceptual site plan identifies approximately 2, 046 parking spaces provided throughout the development. Parking for trucks and employees is provided behind secured, gated access points as depicted on the conceptual site plan. Approximately 1, 104 trailer parking spaces are provided behind secured, gated access points.

G. Landscapinq
Project landscaping will be consistent with the Site Plan Review package' s landscape plan and area renderings included for conceptual design. The landscape design along rights- of-way and parking areas will be consistent with the Central Lathrop Specific Plan 2 Amendment ( CLSP 2) and city zoning requirements for retail. The landscape design in stormwater quality areas will be compliant with the Multi- Agency Post- Construction Stormwater Standards Manual.
7 Vehicular entries and street frontages will provide a formal entry design sequence, including the use of "offset" of trees along with formal masses of shrubs and groundcovers. The project will match the City of Lathrop' s retail design criteria for retail along Manthey Rd. The city's criteria identify London Plane Tree and Chinese Flame trees as primary and secondary trees. A more diverse plant palette will be used.

Additional street trees along the Dos Reis Rd frontage include Deodar Cedar, and Chinese Flame trees. Massed shrubs will further screen perimeter screen walls around the Project perimeter and colorful accent shrubs and groundcover plantings will be used around all signage.

The landscape design in proximity to the building will complement the building' s high-tech contemporary appearance, as well as the size. Trees and shrubs will provide pedestrian shade and visual interest and will contrast the architectural pop- outs to provide human scale at the entries. Pedestrian walks that connect the Project and parking lots to storefront entries will be appropriately shaded.

H. Emplovee Amenities
Employee outdoor break areas with shading and benches/seating have been incorporated into the site plan to allow employees an outdoor space to enjoy break periods. Employee break areas are compliant with the Design Guidelines ( Chapter 7) section of the Central Lathrop Specific Plan 2 Amendment ( CLSP 2).

I. Gradinq and Drainaqe
The grading and drainage plan for the Property will comply with the City of Lathrop' s drainage design standards and the Multi- Agency Post- Construction Stormwater Standards Manual. Storm drainage will be conveyed via internalized roof drains and downspouts, as well as overland flow across the parking lots and truck dock areas. This flow will be directed to curb openings at stormwater quality treatment areas distributed throughout the site. These treatment areas will effectively treat stormwater before it is discharged into the site' s storm drain system. Ultimately the onsite storm drain system connects to the existing Watershed 4 storm drain line in Dos Reis Road where that storm water continues west to the existing storm drain pump station at Stanford Crossing and Spartan Way. The stormwater quality treatment areas and the underground storm drainpipe system have been sized to together accommodate a 100- year storm event.
8 J. Utilities and Infrastructure
The City of Lathrop will provide water to the Property via a 12- inch public waterline within Golden Valley Parkway. The project proposes new 12- inch public water lines in Manthey Road and Dos Reis Road.

The City of Lathrop will provide storm sewer and wastewater treatment service.

There is an existing sewer main within Golden Valley Parkway. It is anticipated that existing sewer main is to provide a gravity sewer connection to the Property.

K. Proiect Schedule
The design phase of the project is expected to begin immediately after the public approval of the Central Lathrop Specific Plan 2 Amendment, Site Plan Review Package, and Conditional Use Permit. Assuming an Improvement/ Grading Plan approval in the first half of 2024 construction is expected to commence in the second half of 2024.

L. Summary
The proposed development will provide benefits to the City of Lathrop by adding a diversity of up to 500 new jobs at full operation involving a significant capital investment more than $ 100 million, and anticipated retail sales exceeding $ 30 million annually and will activate an undeveloped, long-term vacant parcel of land with a quality use that will provide considerable sales tax revenues and other economic benefits to the City of Lathrop.

This Project implements the General Plan, Central Lathrop Specific Plan Phase 2 Amendment ( CLSP 2), zoning, and Design Guidelines that encourage site development and architectural design that will be integrated with the surrounding mixed use residential development. The projecYs frontage improvement of Dos Reis Road and Manthey Road into their ultimate condition including the landscape buffer previously mentioned along Dos Reis Road will positively influence the area. In summary, this proposal is consistent with the City' s long- term vision for this area, it is compatible with the surrounding area.
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Attachment 10
Ashley Furniture Project CUP- 23- 08 and SPR- 23- 09
Environmental Checklist, prepared by De Novo Planning Group, dated August, 2023
Due to the size of this document, it has not been reproduced in the staff report. A copy of the Environmental Checklist is available for viewing and download on the City' s website at the following links:

Environmental Checklist without Appendices:
https•// www ci lathrop ca us/ sites/ default/ files/ fileattachments/ comm unity development/ pa e/ 5622/ lathrop ashley warehouse 15183 no appendices. pdf
Environmental Checklist with Appendices:
https•// www ci lathrop ca us/ sites/ default/ files/ fileattachments/ comm unity development/ pa e/ 5622/ lathrop ashley warehouse 15183 cle an. df
The Environmental Checklist can also be viewed at the following link:
https•// www ci lathrop ca us/ com- dev/ pa e/ public-review-documents Individuals that are unable to access the Environmental Checklist at the website listed above or would require a computer disk or thumb drive containing a copy of the document should contact Planning Staff at plannin ci. lathrop. ca. us or ( 209) 941-7290 to obtain a copy.

TT CH IENT " "

CITY OF LATHROP
PLAIV NING COMMISSION RESOLUTION NO. 23- 13

A RESOLUTION OF THE PLANNING COMMISSION OF THE CITY OF LATHROP

RECOMMEIVTDING THE CITY COUNCIL FIND THE PROJECT EXEMPT FROM

FURTHER ENVIRONMENTAL REVIEW PURSUANT TO PUBLIC RESOURCES CODE SECTION 21083. 3 AND CEQA GUIDELINES SECTION 15183 AND APPROVE

THE CONDITIONAL USE PERMIT AND THE SITE PLAN REVIEW FOR THE PROPOSED ASHLEY FURNITURE PROJECT (CUP-23- 08 AND SPR-23-09) WHEREAS, the City of Lathrop Planning Commission held a duly noticed public hearing to consider the Conditional Use Permit and 5ite Plan Review pursuant to the Lathrop Municipal Code; and
WHEREAS, the request is for approval of a Conditional Use Permit and Site Plan Review to allow the construction of an approximately 1. 5 million square foot concrete tilt-up building and all necessary supporting infrastructure on property located within the Central Lathrop Specific Plan Phase 2 Amendment area as further defined below in the third recital ( the proposed Project}; and WHEREAS, the property is located at 14101 S. Manthey Road ( APN: 192- 020- 14) ( the property); and
WHEREAS, prior to the City' s approval of the 2022 General Plan Update, the City prepared an Environmental Impact Report ( EIR) which analyzed the environmental impacts af buildout under the General Plan Update pursuant to the California Environnlental Quality Act ( CEQA) ( Public Resources Code Section 21000, et seq.), and the City of Lathrop City Council certified the Final EIR on September 19, 2022 ( State Clearinghouse # 2021100139); and WHEREAS, the analysis in the General Plan Update EIR allows the use of CEQA exempkion/ streamlining provisions for projects developed under the General Plan Update, including the proposed Project; and
WHEREAS, an Environmental Checklist has been prepared for the proposed Project, vhich is attached to the Planning Commission Staff Report as Attachment 9 and can also be found in the Plannin Division project filss located at 390 Towne Centre Drive, Lathrop, CA 95330; and WHEREAS, the Planning Commission finds that the proposed Project is consistent with the Limited Industrialland use goals and policies of the CiCy of Lathrop General Plan and is also consistent with the development standards for the IL-CL, Limited Industrial Zoning District and the Central Lathrop Specific Plan Phase 2 Amendment as further implemented through the Zoning Code Text Amendment; and
Plannin Commission Resolution No. 23- 13 Pa e I of S
WHEREAS, proper notice of this public meeting was given in all respects as required by law includin the publishing of a legal notice of the hearing in the Manteca Bulletin on or about September 1, 2023, mailed the public notice to notify property owners located within a 300-foot radius from the project site boundary, emailed to the City' s Pi blic Hearing subscribers and interested parties and posted at three ( 3) locations accessible tQ the public and the City website; and VHEREAS, the Planning Commission has reviewed all written evidence and oral testimony presented to date.

N W, THEREFORE BE IT RESOLVED, the Planning Commission of the City of Lathrop does hereby make the following findings:
l. California Environmenkal Quality Act ( CEQA) Findinas. Pursuant to Public Resources Code section 21083. 3 and CEQA Guidelines section 15183, the Planning Commission finds as follows:
a. The project complies with CEQA based on the CEQA exemption/ streamlining provisions cantained in Public Resources Code section 21083. 3 and CEQA Guidelines sectio 15183;
b. Pursuant to the Planning Commission Staff Report and the attachments and exhibits thereto, including but not limited to, the CEQA Initial Study Checklist, which are incorporated herein by reference, the proposed Project will not result in any significant impacts that. 1) are peculiar to the project or project site; 2) were not identified as significant project- level, cumulative, or off-site effects in the General Plan Update EIR; or 3) were previously identified significant effects, which as a result of substantial new information that was not known at the time that the General Plan Update EIR was certified, are determined to have a more severe adverse impact than discussed in the General Plan Update EIR.

As a result, pursuant to Pubiic Resources Code section 21083. 3 and CEQA Guideiines section 151$ 3, the proposed Project is exempt from further environmental review under CEQA.
c. All applicable General Plan Update policy and implementation actions and uniformly applied development policies, standards and/ or regulations are, hereby imposed on the proposed Project and must be adhered to by the Project applicant. To the extent the City has not previously made findings regarding any/ all of thase referenced General Plan policy and implementation actions and uniformly applied development policies, standards and/ or regulations, the Pianning Commission hereby finds that all of those General Plan Update policy and implementation actions and uniformly applied development policies, standards andlor regulations, were adopted, in whole or in part, to substantially mitigate the potential environmental effects to which they pertain ( i. e., aesChetics, agricultural and forest resourees, air quality, biological resources, cultural and tribal resources, geology and soils, greenhouse gases, climate change, and energy, hazards and hazardous materials, hydrology and water P anning Commission Resolution No. 23- 13 Pa e 2 of 5
quality, land use, population, and housing, mineral resources noise, public services and recreation, circulation, utilities and services systems, and wildfire}.

2. Conditional Use Permit Findin s. Pursuant to Section 17. 112. 060 of the Lathrop Municipal Code ( LMC), the Planning Commission finds as follows:
a. That there are circumstances or conditians applicable to the land, structure or use which makes the granting of a use permit necessary for the preservation and enjoyment of a substantial property right.

The proposed Project represents ct rnajor expansion of the existing Ashley Furniture Distr-ihutzo 2 Cerr.ter nf2d Retail Outlet locnted on S. Harlan Road.

The proposed Project is corisisterzt witFi the City' s developmeflt standards for Limited Industrial.
b. That the proposed location of the conditional use is in accordance with the objectives of the zoning code and the p arposes of the district in which the site is located. The proposed project is locc ted in the IL-CL, Lir zited Indi strinl Zoning District czrad the Cerztrcrl Lathrop Specific Plan Phase 2 Anae dment aren c ld is a permitted use within the oriing distri.ct for wlaich it is locnted as fcirther estnblished iri tlze Zoning Cvde Text Arnendment. c. That the proposed use will comply with each of the applicable provisions of the LMC, as amended. As noted al ove aricl as described iri the Staff Report, the proposecl roject is a perrrtitted a se ira tlte IL-CL, Limited Indcrstrial Zonirag District and is consistent with the npplicable provisions in the LMC, including screer ing requirements per.rst ctnt to tlae Centrctl Lnthrop Specific Plctn Phase 2 Arnendrnertt. Additionall_y, the General Plan rec atired c pdates to tlae LMC and Central Latlarop Specifzc Plnn Phnse 2 in order to ensc re that netiv development is cornpatible vith e,eisting development ( Go l LU-). The proposed project is consistent tivith the LMC, Poticies and Iniplernentatio z Actioras of the General Plttn as it relates to truck traffic i npacts artd land case corrtpcztibilin.

3. Site Plan Review FindinQs. Pursuant to Section 17. 100. 050 of the Lathrop Municipal Code LiVIC), the Planning Commission finds as follows:
a. The proposed Site Plan Review complies with all applicable provisions of Chapter 17. 100;
b. The proposed Site Plan Review is consistenC with the site improvements listed in Chapter 17. 100 ( a. through i.) and improvements are such that traffic congestion is avoided and pedestrian and vehicular safety and welfare are protected and there will not be adverse effects on surrounding properties; Plannin Commission Resolution No. 23- 13 Page 3 of 5
c. Proposed lighting for the project area is so arranged as to deflect away from adjaining properties; and
d. The proposed Site Plan Review is compatible with surrounding land uses and will not be detrimental to the health, safety and general welfare of the City as further evaluated in the Environmental Checklist.

BE IT FURTHER RESOLVED, based on substantial evidence in the administrative record of proceedings and pursuant to its independent review and consideration, the Lathrop Planning Cominission does hereby recommend that the Lathrop City Council approve Conditional Use Permit Na CUP-23- 08 and Site Plan Review No. SPR- 23- 09, subject to the Conditions of Approval listed in Attachment 2 of the September l3, 2023 Staff Report and incorporated by reference herein.

Plannina Commission Resoluti n No. 2- I3 Pa e 4 of 5
PASSED AND ADOPTED by the Planning Cominission of the City of Lathrop at a Special rneeting on the 13` day of September, 2023 by the following vote:

AYES: Ishihara, Camarena, Jackson, Rhodes
NOES: None
ABSTAIN: None
ABSENT: Ralmilay
Tos Ishihara, h'ai
ATTEST: APPROVED AS TO FORM:
ick Ca t, Secretary Salvador Navarrete, City Attorney
Plannin Commission Resolution No. ? 3- 13 Page 5 of 5
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BY E- MAIL
September 13, 2023
Rick Caguiat
Community Development Director
Planning Commission Secretary
Community Development Department
390 Towne Centre Drive
Lathrop, California 95330
planninqCc ci. lathrop.ca. us
Re: Comment on Planning Commission Agenda Items No. 8. 3 Regarding the Ashley Furniture Project ( Conditional Use Permit No. CUP- 23- 08; Site Plan Review No. SPR 23- 09)
Dear Mr. Caguiat and Honorable Members of the Planning Commission:

I am writing on behalf of Laborers' International Union of North America, Local Union No. 73 (" LIUNA") regarding the proposed Ashley Furniture Project proposed to be located at the northwest corner of Dos Reis Rd and Manthey Road. The Planning Commission staff have determined that the project is exempt from the requirement for preparation of environmental documents pursuant to California Environmental Quality Act (" CEQA") Guidelines, Section 15183 and Public Resources Code § 21083. 3.

However, after reviewing the Environmental Checklist and relevant appendices prepared for the Project, and the 2022 General Plan Update EIR that the Project relies upon, we conclude that the Project does not meet the requirements for an exemption under CEQA Guideline § 15183 and PRC § 21083. 3. LIUNA respectfully requests that the Planning Commission not recommend approval of each of the agenda items addressed by the proposed exemption and, in particular, the proposed Ashley Furniture Project, and instead request staff to prepare the necessary environmental documents under CEQA.

I. PROJECT DESCRIPTION
The Project proposes to construct and operate a 1, 486, 607 square foot industrial building including a mix of retail, office/ call center, and warehouse and distribution uses.

About 110,000 square feet would be dedicated to retail use, 24,000 square feet to office and call-center uses, and 1, 352, 347 square feet to warehouse and distribution center uses.

Comment re: Ashley Furniture Project
City of Lathrop
September 13, 2023
Planning Commission Hearing
The Project proposes to construct approximately 2, 046 parking spaces throughout the development site, with 942 spaces for passenger vehicles and 1, 104 spaces for truck trailer parking. The Project expects to generate 2, 798 daily passenger vehicle trips, including 203 a. m. peak hour trips ( 124 inbound, 79 outbound) and 255 p. m. peak hour trips ( 110 inbound, 145 outbound) for passenger vehicles. Another 680 daily truck trips also are expected, including 95 a. m. peak hour trips and 45 p. m. peak hour trips.

II. LEGAL STANDARD
To achieve its objectives of environmental protection, CEQA has a three- tiered structure. 14 CCR § 15002( k); Committee to Save the Hollywoodland Specific Plan v.

City of Los Angeles ( 2008) 161 Cal. App. 4th 1168, 1185- 86 (" Hollywoodland"). First, if a project falls into an exempt category, or it can be seen with certainty that the activity in question will not have a significant effect on the environment, no further agency evaluation is required. Id. Second, if there is a possibility the project will have a significant effect on the environment, the agency must perform an initial threshold study.

Id.; 14 CCR § 15063( a). If the study indicates that there is no substantial evidence that the project or any of its aspects may cause a significant effect on the environment the agency may issue a negative declaration. Id.; 14 CCR §§ 15063( b)( 2), 15070. Finally, if the project will have a significant effect on the environment, an environmental impact report (" EIR") is required. Id.

Here, since the City purports to exempt the Project from CEQA entirely, the first step of the CEQA process applies. " Exemptions to CEQA are narrowly construed and e] xemption categories are not to be expanded beyond the reasonable scope of their statutory language." Mountain Lion Foundation v. Fish & Game Com. ( 1997) 16 Cal. 4th 105, 125. The determination as to the appropriate scope of an exemption is a question of law subject to independent, or de novo, review. San Lorenzo Valley Community Advocates for Responsible Education v. San Lorenzo Valley Unified School Dist., 2006) 139 Cal. App. 4th 1356, 1375 ("[ Q] uestions of interpretation or application of the requirements of CEQA are matters of law. Thus, for example, interpreting the scope of a CEQA exemption presents ` a question of law, subject to de novo review by this court."') Here, the City proposes that the Project is exempt from CEQA review under Section 15183 and PRC § 21083. 3. However, as discussed below, the use of these streamlining provisions is improper, and instead, a full CEQA analysis, such as an EIR, must be prepared for this Project.

Comment re: Ashley Furniture Project
City of Lathrop
September 13, 2023
Planning Commission Hearing
III. DISCUSSION
a. The City Incorrectly Applied CEQA' s Section 15183 Categorical Exemption to the Project and Thus a Full CEQA Analysis is Required.

Section 15183 of the California Environmental Quality Act allows a project to avoid environmental review if it is " consistent with the development density established by existing zoning, community plan, or general plan policies for which an EIR was certified . . . except as might be necessary to examine whether there are projectspecific significant effects which are peculiar to the project or its site." 14 CCR 15183 ( emphasis added). See PRC § 21083. 3( b). The intention of this section is to streamline[]" CEQA review for projects and avoid the preparation of repetitive documents. While the City refers to these provisions as exemptions from CEQA, environmental review is still required for various types of impacts, including those peculiar to the project or parcel on which the project would be located," those which were not analyzed as significant effects in a prior EIR," " are potentially significant offsite impacts and cumulative impacts which were not discussed in the prior EIR," or a] re previously identified significant effects which, as a result of substantial new information which was not known at the time the EIR was certified, are determined to have a more severe adverse impact than discussed in the prior EIR." Section ( fl of section 15183 states that a Project' s environmental effects are not peculiar to a project if" uniformly applied development policies or standards have been previously adopted" which serve to mitigate environmental impacts, " unless substantial new information shows that the policies or standards will not substantially mitigate the environmental effect." The standard set forth by the statute for this analysis is substantial evidence.

Here, there is substantial evidence demonstrating that the Project will have significant impacts which were not addressed in the EIR prepared for the 2022 General Plan Update. Section 15183 therefore does not apply, and the City must prepare appropriate CEQA documents for this Project.
b. The City Must Prepare a Statement of Overriding Considerations With Regard to This Project.

The 2022 General Plan Update concluded that several of the impacts identified as a result of the General Plan Update project were significant and unavoidable. These impacts included agricultural resources, air quality, greenhouse gas, and traffic noise impacts. In the Environmental Checklist prepared for the Project, the City acknowledges these significant and unavoidable impacts, but states that:

Impacts from buildout of the General Plan including cumulative impacts associated with development and buildout of the CLSP Phase 2 plan area Comment re: Ashley Furniture Project
City of Lathrop
September 13, 2023
Planning Commission Hearing
and the warehouse Project site, as proposed, were fully addressed in the General Plan EIR ( State Clearinghouse No. 2021100139), and implementation of the proposed project would not result in any new or altered impacts beyond those addressed in the General Plan EIR.

Envt' I Checklist, p. 13. Similar statements are repeated for each of the specific unavoidable significant impacts. This conclusion does not, however, address all of the City' s obligations to grapple with acknowledged significant and unavoidable cumulative impacts.

In the case of Communities for a Better Environment v. Cal. Resources Agency, the court of appeal held that, although tiering may allow a later project to rely on the environmental analysis contained in a prior program- level EIR, that procedure does not relieve the agency of acknowledging the significant and unavoidable impacts and reconsidering its statement of overriding considerations. As the Court explained:

The section appears to allow an agency, in approving a later project that has significant unavoidable impacts, to forego making a statement of overriding considerations specifically tied to that project. This is contrary to CEQA law. CEQA section 21094, subdivision ( d) requires agencies that approve a later project to comply with CEQA section 21081. Under CEQA section 21081, an agency approving a project with significant environmental effects must find that each effect will be mitigated or avoided, or" that specific overriding economic, legal, social, technological, or other benefits of the project outweigh the ... effect[] ...." 65 The requirement of a statement of overriding considerations is central to CEQA' s role as a public accountability statute; it requires public officials, in approving environmentally detrimental projects, to justify their decisions based on counterbalancing social, economic or other benefits, and to point to substantial evidence in support.66 Under Guidelines section 15152( fl(3)( C), however, an agency apparently could adopt one statement of overriding considerations for a prior, more general EIR, and then avoid future political accountability by approving later, more specific projects with significant unavoidable impacts pursuant to the prior EIR and statement of overriding considerations. Even though a prior EIR' s analysis of environmental effects may be subject to being incorporated in a later EIR for a later, more specific project, the responsible public officials must still go on the record and explain specifically why they are approving the later project despite its significant unavoidable impacts.

Communities for a Better Env't v. California Res. Agency, 103 Cal. App. 4th 98, 124- 25, 126 Cal. Rptr. 2d 441 ( 2002), as modified ( Nov. 21, 2002), and disapproved of on other grounds by Berkeley Hillside Pres. v. City of Berkeley, 60 Cal. 4th 1086, 343 P. 3d 834 2015).

Comment re: Ashley Furniture Project
City of Lathrop
September 13, 2023
Planning Commission Hearing
The same reasoning applies to the implementation of Pub. Res. Code § 21083. 3 and 14 Cal. Admin. Code § 15183. The Project, based on its reliance on the 2022 General Plan Update EIR, will have cumulative impacts on agricultural resources, air quality, greenhouse gas emissions, and traffic noise. Although sections 21083 and 15183 provide for streamlining of the environmental review of a subsequent project, neither section relieves the City from its obligation to make a statement of overriding considerations for the Project. PRC § 21081. Prior to recommending the Project and applying the streamlining provisions, the Planning Commission should prepare a statement of overriding considerations supported by substantial evidence and which evaluates whether any additional feasible mitigation measures applicable to this specific project should be required in order to address the acknowledged cumulative impacts. c. The Project Will Have Project-Specific Significant Effects Which Were Not Addressed in the 2022 General Plan Update EIR.

LIUNA is concerned that a number of significant environmental impacts peculiar to the Project were not addressed in the 2022 General Plan Update EIR. As a result, Pub. Res. Code § 21083. 3 and 14 Cal. Admin. Code § 15183 do not apply and either a mitigated negative declaration or EIR must be prepared to address these unanalyzed impacts.
i. Biological Resources
According to the 2022 General Plan EIR, the federally- listed, endangered valley elderberry longhorn beetle ( Desmocerus californicus dimorphus) did not occur within one- mile of the planning area. GP EIR, p. 3. 4- 15. As a result, there is no focused discussion in the 2022 General Plan EIR on any impacts to this federally-listed species.

In general, the 2022 General Plan EIR concludes that there will be no significant impacts to listed species from the General Plan' s implementation. GP EIR, p. 2. 4- 28 —

3. 4- 29. The valley elderberry longhorn beetle relies on a particular host plant for its survival — the red or blue elderberry. See Biological Resources Analysis Report, p. 18.

The reconnaissance survey conducted for the Biological Resources Analysis observed a 6- foot by 15- foot elderberry shrub on the property. Id., p. 19. The presence of that host plant, the enhanced likelihood of the presence of the endangered valley elderberry longhorn beetle, and the heightened risk of adverse affects on the host plant or potentially present beetles are not addressed as a significant impact in the 2022 General Plan EIR and these effects are peculiar to the Project site. Pub. Res. Code § 21083. 3. Given these facts peculiar to the site, it " might be necessary to examine whether there are project- specific significant effects which are peculiar to the project or its site." 14 CCR 15183.

Likewise, the observed presence of a Swainson' s hawk foraging on the project site and nesting within 20 feet of the site also results in obvious effects peculiar to the Comment re: Ashley Furniture Project
City of Lathrop
September 13, 2023
Planning Commission Hearing
project site, including not only the direct loss of foraging habitat but also disturbances from construction activities at the site and a dramatic increase in vehicles using Dos Reis Road to access the project once it is operational. Because impacts to Swainson' s hawks were not addressed as significant impacts in the 2022 General Plan EIR and impact to a Swainson' s hawk is peculiar to the site, those potential impacts must be addressed in a proper CEQA environmental review document and reliance on Pub.

Res. Code § 21083. 3 and 14 Cal. Admin. Code § 15183 is inappropriate.

Given the very limited reconnaissance- level survey performed on a single day at the Project site on May 5, 2021, LIUNA is concerned that there are numerous other listed and sensitive species foraging or located at the Project site. No effort has been made to determine the current presence of burrowing owls at the site. The past presence of red- tailed hawks and white- tailed kites foraging at the site also excludes the proposed streamlining exemption. A current and more robust survey of the Project site is necessary for the City to make any decision on these potential impacts based on substantial evidence.

In addition, the 2022 General Plan EIR does not identify the significant potential impact of the Project's thousands of trucks and car trips on wildlife from vehicle collisions with wildlife. This impact is peculiar to the Project given its proposed 2, 798 daily passenger vehicle trips and 680 daily truck trips which will lead to wildlife collisions in the vicinity of the Project. Because this project-specific direct and cumulative effect was not addressed at all in the 2022 General Plan EIR, it must be addressed in an EIR or potentially a mitigated negative declaration for the Project. See PRC § 21083. 3( c) Nothing in this section affects any requirement to analyze potentially significant offsite impacts and cumulative impacts of the project not discussed in the prior environmental impact report with respect to the general plan").
ii. Energy
The 2022 General Plan EIR' s discussion of the General Plan' s energy impacts boils down to stating that by complying with California' s Building Energy Efficiency Standards (" CalGreen"), promoting the use of renewable energy sources and encouraging public transportation and bicycle use, and the fact that PG& E will generally make progress on adding new renewable energy sources to its portfolio, projects within the planning area will not have energy impacts. GP EIR, p. 3. 7- 41 — 3. 7- 42. The Environmental Checklist focuses on the Ashley Furniture ProjecYs compliance with CalGreen and PG& E' s long-term efforts. Env't Checklist, p. 66. None of these considerations address the energy effects that are peculiar to a 1. 4 million square feet furniture distribution and retail center.

The standard under CEQA is whether the Project would result in wasteful, inefficient, or unnecessary consumption of energy resources. Failing to undertake " an investigation into renewable energy options that might be available or appropriate for a Comment re: Ashley Furniture Project
City of Lathrop
September 13, 2023
Planning Commission Hearing
project" violates CEQA. California Clean Energy Committee v. City of Woodland (2014) 225 Cal. App. 4th 173, 213. Energy conservation under CEQA is defined as the " wise and efficient use of energy." CEQA Guidelines, app. F, § I. The " wise and efficient use of energy" is achieved by "( 1) decreasing overall per capita energy consumption, ( 2) decreasing reliance on fossil fuels such as coal, natural gas and oil, and ( 3) increasing reliance on renewable energy resources." Id.

Noting compliance with the California Building Energy Efficiency Standards Cal. Code Regs., tit. 24, part 6 ( Title 24) does not constitute an adequate analysis of energy impacts. Ukiah Citizens for Safety First v. City of Ukiah ( 2016) 248 Cal.App. 4th 256, 264- 65. Similarly, the court in City of Woodland held unlawful an energy analysis that relied on compliance with Title 24, that failed to assess transportation energy impacts, and that failed to address renewable energy impacts. California Clean Energy Committee v. City of Woodland, 225 Cal.App.4th 173, 209- 13. As such, the General Plan EIR' s reliance on Title 24 compliance does not address the proposed furniture warehouse Project' s energy impacts. The energy effects of the Project are, by definition, peculiar to the Project. Given the vast expanse of roofing provided by the proposed Project, any evaluation of its energy impacts cannot ignore the obvious feasibility of an array of solar panels on the roof or covering the extensive parking proposed at the site.

Energy efficiency, in the context of the Proposed project and site would require the consideration and implementation of sufficient solar panels to meet all of the Project' s direct electricity demand, as well as solar power that would offset the considerable GHG and other air pollution emissions that will result from the thousands of trucks and cars driving to and from the Project every day once iYs operational.

The Environmental Checklist contains no discussion of the project's cost effectiveness in terms of energy requirements. There is no discussion of ene gy consuming equipment and processes that will be used during the construction or operation of the project. The project' s energy use efficiencies by amount and fuel type for each stage of the project including construction and operation were not identified.

The effect of the project on peak and base period demands for electricity has not been addressed. As such, the Environmental Checklist' s conclusions are unsupported by the necessary discussions of the Project's energy impacts under CEQA. An EIR or possibly a mitigated negative declaration must be prepared to assess these impacts. iii. Greenhouse Gases and Air Quality.

The 2022 General Plan EIR did not project air pollution emissions for any given project that would be allowed by the plan. Instead, it identifies the implementation measure in the General Plan that the City "[ review development, infrastructure, and planning projects for consistency with SJVAPCD requirements during the CEQA review process." GP EIR, p. 3. 3- 35 ( RR- 6a). The General Plan and the EIR go on to further require that:

Comment re: Ashley Furniture Project
City of Lathrop
September 13, 2023
Planning Commission Hearing
Require project applicants to prepare air quality analyses to address SJVAPCD and General Plan requirements, which include analysis and identification of:

A. Air pollutant emissions associated with the project during construction, project operation, and cumulative conditions.

B. Potential exposure of sensitive receptors to toxic air contaminants.

C. Significant air quality impacts associated with the project for construction, project operation, and cumulative conditions.

D. Mitigation measures to reduce significant impacts to less than significant or the maximum extent feasible where impacts cannot be mitigated to less than significant.

Id. Although the Environmental Checklist purports to describe these evaluation efforts, the Checklist does not provide any of the input files for the air pollution modeling conducted for the proposed Project. Only the output files are provided.

Environmental Checklist, Attachment I, p. 162. Given the size of the warehouse and the number of expected daily truck trips, LIUNA is skeptical that the emissions forecasts identified for its construction and operation can be substantiated. Before making a recommendation to the Council, the Planning Commission should require staff and the applicant to share their input files for the CaIEEMod modeling in order for the public to be able to assess the accuracy of the model outputs and whether or not the Project' s may have a significant effect on air quality and GHG emissions and the extent of necessary mitigation measures as required by the General Plan.

IV. CONCLUSION
In light of the above comments, the City must prepare an EIR or, if appropriate, a mitigated negative declaration for the Project. LIUNA reserves its right to submit additional comments and evidence for any subsequent Planning Commission hearing or the City Council' s consideration of the Project. Thank you for considering these comments.

Sincerely,
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Michael R. Lozeau

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BY E- MAIL
October 6, 2023
Lathrop City Council Teresa Vargas, MMC
Sonny Dhaliwal, Mayor City Clerk
Paul Akinjo, Vice Mayor 390 Towne Centre Drive
Minnie Diallo, Councilmember Lathrop, CA 95330
Diane Lazard, Councilmember website_ cco@ci. lathrop. ca. us Jennifer Torres- O' Callaghan, Councilmember
390 Towne Centre Drive
Lathrop, California
website_ cco@ci. lathrop. ca. us
Re: Comment on Ashley Furniture Project( CUP- 23- 08; SPR 23- 09) City Council Agenda Item No. 5. 3
Dear Mayor Dhaliwal, Vice Mayor Akinjo, and Honorable Councilmembers:

I am writing on behalf of Laborers' International Union of North America, Local Union No. 73 (" LIUNA") regarding the Ashley Furniture Project (" Project") proposed to be located at the northwest corner of Dos Reis Rd and Manthey Road. The Planning Commission voted to recommend that the City Council find that the project is exempt from the California Environmental Quality Act(" CEQA") pursuant to CEQA Guidelines section 15183 ( 14 CCR § 15183) and Public Resources Code (" PRC") section 21083. 3. However, after reviewing the Environmental Checklist prepared for the Project and the 2022 General Plan Update EIR that the Project relies upon, we conclude that the Project does not meet the requirements for an exemption under CEQA Guideline § 15l 83 and PRC § 21083. 3. As such, LIUNA respectfully requests that the City Council refrain from approving the Project until the Project undergoes environmental review under CEQA.

PROJECT DESCRIPTION AND BACKGROUND
The Project proposes to construct and operate a 1, 486, 607 square foot industrial building including a mix of retail, office/ call center, and warehouse and distribution uses. About 110, 000 square feet would be dedicated to retail use, 24,000 square feet to office and call- center uses, and 1, 352, 347 square feet to warehouse and distribution center uses.

The Project proposes to construct approximately 2, 046 parking spaces throughout the development site, with 942 spaces for passenger vehicles and 1, 104 spaces for truck trailer LIUNA Comment re: Ashley Furniture Project
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parking. The Project expects to generate 2, 798 daily passenger vehicle trips, including 203 a. m. peak hour trips ( 124 inbound, 79 outbound) and 255 p. m. peak hour trips ( 110 inbound, 145 outbound) for passenger vehicles. Another 680 daily truck trips also are expected, including 95 a. m. peak hour trips and 45 p. m. peak hour trips.

The Project site is located within the Central Lathrop Specific Plan (" CLSP") Phase 2 area, which was approved by the City in 2004. In 2022, the City certified an environmental impact report (" EIR") for the City' s 2022 General Plan Update (" 2022 GP EIR"), which changed the land use designations in the CLSP Phase 2 area from Residential/ Commercial to Limited Industrial. An Environmental Checklist was prepared for the Project to evaluate consistency with the 2022 GP EIR.

On September 13, 2023, the Planning Commission voted to recommend that the City Council approve the Project conditional use permit (CUP-23- 08) and site plan review (SPR-23- 09) and find that the Project is exempt from further environmental review under Public Resources Code section 21083. 3 and CEQA Guidelines section 15183 because the Project would not result in any impacts beyond those addressed in the 2022 GP EIR. Prior to the Planning Commission meeting, LILTNA submitted a written comment attached hereto as Exhibit C and incorporated by reference.

LEGALSTANDARD
To achieve its objectives of environmental protection, CEQA has a three- tiered structure.

Committee to Save the Hollywoodland Specific Plan v. City of Los Angeles ( 2008) 161 Cal. App.4th 1168, 1185- 86 ( Hollywoodlanc [ citing 14 CCR § 15002( k)].). First, if a project falls into an exempt category, or it can be seen with certainty that the activity in question will not have a significant effect on the environment, no further agency evaluation is required. ( Id. at 1185.) Second, ifthere is a possibility the project will have a significant effect on the environment, the agency must perform an initial threshold study and may issue a negative declaration if the study indicates no significant impacts. ( Id. at 1185- 86; see also 14 CCR §§ 15063( b)( 2), 15070.) Finally, ifthe project will have a significant effect on the environment, an environmental impact report(" EIR") is required. ( Hollywoodland, supra, 161 CaLApp. 4th at 1186.)
Here, the Planning Commission recommended that the City Council find the Project exempt from CEQA under CEQA Guidelines section 15183 (" Section 15183"), which, for projects " which are consistent with the development density established by existing zoning, community plan, or general plan policies for which an EIR was certified," does not require additional environmental review for such projects " except as might be necessary to examine whether there are project- specific significant effects which are peculiar to the project or its site." 14 CCR § 15183( a).)
The purpose of Section 15183 is to streamline CEQA review and relieves the City of the obligation to prepare an EIR if a
qualifying project' s impacts "[ are] not peculiar to the parcel or LILTNA Comment re: Ashley Furniture Project
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to the project, [ have] been addressed as a significant effect in the prior EIR, or can be substantially mitigated by the imposition of uniformly applied development policies or standards." ( 14 CCR § 15183 ( c).) Section 15183 further explains, An effect of a project on the environment shall not be considered peculiar to the project or the parcel for the purposes of this section if uniformly applied development policies or standards have been previously adopted by the city or county with a finding that the development policies or standards will substantially mitigate that environmental effect when applied to future projects, unless substantial new information shows that the policies or standards will not substantially mitigate the environmental effect.
14 CCR § 15183(.) A city' s decision to utilize Section 15183 is governed by the substantial evidence standard of review. ( Lucas v. Ciry ofPomona ( 2023) 92 Cal.App.Sth 508, 538.)

DISCUSSION
I. The Project Is Not Exempt from CEQA Under Section 15183 Due to Unmitigated, Project- Specific Impacts to Biological Resources.

LIUNA retained wildlife biology expert Dr. Shawn Smallwood, Ph. D., who conducted a site visit and reviewed the Project' s documentation, including the Environmental Checklist and the Biological Resources Analysis Report prepared by Olberding Environmental, Inc. dated May 2021 (` Biological Report"). Dr. Smallwood found the Project would result in significant, unmitigated impacts to multiple special- status species of wildlife. Dr. Smallwood' s comment and CV are attached as Exhibit A.

A. The Project' s Biological Report underestimates the diversity of species using the Project site.

Dr. Smallwood conducted a site visit to the Project site for approximately 2. 5 hours on September 21, 2023. ( Ex. A, p. l.) During those visits, Dr. Smallwood " detected 35 species of vertebrate wildlife, including 10 special- status species," including Swainson' s hawk, which is listed as a threatened species in California, and loggerhead shrike, a California Species of Special Concern priority level 2. ( Id. at pp. 3- 4.) Dr. Smallwood estimates that with additional surveys, a total of 178 species would be detected at the Project site, of which 51 would be special- status species. ( Id., p. 9.) Based on his site visit and projections, Dr. Smallwood concluded that"[ m] ore surveys are needed" and " the species richness at the site relative to its level of disturbance is peculiar to the site." ( Id., p. 10.)
B. The Project' s Biological Report fails to accurately characterize the existing environmental setting.

Dr. Smallwood found that the Project' s Biological Report failed " to accurately LItJNA Comment re: Ashley Furniture Project
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characterize the existing environmental setting, including the biological species that use the site, their relative abundances, how they use the site, key ecological relationships, and known and ongoing threats to those species with special status." ( Ex. A, p. 10.) He explains that an accurate characterization of the environmental setting typically relies on two factors: ( 1) field surveys and 2) reviews of literature and databases. ( Id.) For this Project, " these needed steps were grossly inadequate." ( Id.)
First, the Biological Report' s field survey lacked critical information, including the time of day of the survey or the duration of the survey, and did not meet the minimum standards for surveys of plants ( Ex. A, p. 11.) Further, the Biological Report' s survey only detected 6 species of vertebrate wildlife at the Project site, which is that number that Dr. Smallwood detected in his first two minutes on the Project site on September 21, 2023. ( Id.) The survey also only detected 3 special- status species, whereas Dr. Smallwood detected 10. ( Id.) Additionally, the Biological Report' s survey made no mention of the great horned owl pellets, kangaroo rat and Botta' s pocket gopher burrow systems, or birds smaller than a white- tailed kite as were observed by Dr.

Smallwood. ( Id.) The Biological Report had no surveys for bats or several special- status species known to occur in the area, including burrowing owl and Swainson' s hawk. (Id.) Second, the Biological Report' s review of available wildlife databases was inadequate.

Ex. A, pp. 12- 13.) The Biological Report relied solely on the California Natural Diversity Data Base (" CNDDB") to determine which species have potential to occur in the project area. The Bio(ogical Report did not consult other known databases, such as iNaturalist or eBird. When searching CNDDB, the Biological Report only searched for species with documented occurrences within the nearest CNDDB quadrangles, which " screens out many special- status species from further consideration in the characterization of the wildlife community as part of the baseline environmental setting." ( Id., p. 12.) Furthermore, " CNDDB is not designed to support absence determinations or to screen out species from characterization of a site' s wildlife community." ( Id.) Based on available databases and site visits, Dr. Smallwood estimates that 107 special- status species of wildlife are known to occur near enough to the site to warrant analysis of occurrence potential." ( Id., p. 20.)
Third, the Biological Report improperly assumed that the Project site' s lack of nesting habitat means that development of the Project would not cause impacts to wildlife species.

However, as Dr. SmaLlwood explains,
T] here is no sound scientific distinction between nesting habitat and some other characterization of habitat. For any given species, the environment of a site is either habitat or it is not, as habitat is defined as that part of the environment that is used by a species. . . . Certain portions of a species' habitat may provide nesting opportunities, but all parts of its habitat are critical to the nesting success of members of the species. If an animal cannot find sufficient forage and cover during non- nesting season or at portions of its habitat where it does not normally nest, then it might not survive to reproduce or its nesting attempt might not succeed. [ The Biological Report] asserts a false distinction of the value of a site based on whether LILJNA Comment re: Ashley Furniture Project
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the species nests on- site.

Ex. A, p. 19.) By limiting habitat to only nesting habitat, the Biological Report underestimates the value of the Project site and the impacts to species that may occur. For example, the Biological Report claimed that loggerhead shrike have a low likelihood of occurrence on the Project site due to lack of trees and shrubs needed for nesting. However, Dr. Smallwood observed a loggerhead shrike foraging on the Project site during his site visit. This is just one example of how the Biological Report misjudged the occurrence likelihood of the many specialstatus species discussed in the Biological Report as well as the potential wildlife impacts peculiar to this specific site.

C. The Biological Report failed to adequately analyze and mitigate the Project' s biological impacts due to habitat loss, wildlife movement, and vehicle collisions.

Dr. Smallwood found that the Biological Report and Environmental Checklist failed to address numerous potentially significant impacts that the Project may have on biological resources, including habitat loss, wildlife movement, collision mortality due to Project- generated traffic, and cumulative impacts. ( Ex. A, pp. 18- 25.)

1. Habitat Loss and Fragmentation
Dr. Smallwood warns that "[ t] he project would destroy 89.92 acres of habitat to every species of wildlife that makes use of the project site." ( Ex. A, p. 20.) Dr. Smallwood predicts that development of the Project would result in the loss of 191 bird nest sites and a lost breeding capacity of 630 birds per year. ( Id., pp. 20- 21.) Dr. Smallwood concludes that this impact is significant. ( Id.)

2. Wildlife Movement
The Biological Report provided a" flawed and misleading" analysis of the Project' s impact on wildlife movement. ( Ex. A, p. 21.) According to the Environmental Checklist, the Biological Report" included a CNDDB record search that did not reveal any documented wildlife corridors or wildlife nursery sites on or adjacent to warehouse site." However, as Dr.

Smallwood explains, " CNDDB is not where an analyst would find information relevant to whether a site is important to wildlife movement. . . . . In effect, there is no analysis of whether the project would interfere with wildlife movement." ( Id.) The Environmental Checklist also claims that the Project' s impacts on wildlife movement were adequately addressed in the 2022 GP EIR. However, the 2022 GP EIR only focused on the San Joaquin River as a wildlife corridor. As such, "[ t] he General Plan EIR implies the premise that interference with wildlife movement in the region can result only from a project' s disruption of the function of a wildlife movement corridor." ( Ex. A, p. 21.) This is not the proper standard under CEQA. Rather, CEQA requires an analysis of impacts to wildlife movement" regardless of LILINA Comment re: Ashley Furniture Project
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whether the movement is channeled by a corridor. A site such as the project site is critically important for wildlife movement because it composes an increasingly diminishing area of open space within a growing expanse of anthropogenic uses, forcing more species of volant wildlife to use the site for stopover and staging during migration, dispersal, and home range patrol." ( Id.) By ignoring this standard, the Biological Report has failed to adequately and mitigate the Project' s impacts on wildlife movement disruptions that are unique to the Project site.

3. Vehicle Collisions
The Biological Report and 2022 GP EIR failed to analyze wildlife mortality and injuries caused by Project- generated traffic. ( Ex. A, pp. 22- 24.) Dr. Smallwood estimates that the Project would result in 6, 151 vertebrate deaths annually due to collisions with Project- generated traffic.

Id., pp. 24.) Especially due to the special- status species likely to occur at or near the Project, these collisions represent a significant impact to wildlife that has not been addressed, discussed, or mitigated by the Environmental Checklist or 2022 GP EIR. But for the Project, these additional wildlife collisions would not occur.

4. Cumulative Impacts
The Environmental Checklist concludes that cumulative impacts to biological resources were addressed in the 2022 GP EIR, which relies on the San Joaquin Multi- Species Habitat Conservation Plan (" SJMSCP") to prevent significant cumulative impacts. However, as discussed in greater detail below, the SJMSCP has failed at conserving wildlife species and cannot be relied upon to conclude that cumulative impacts will be less than significant. ( Ex. A, PP. 24- 25.)
D. The Project cannot rely on the SJMSCP to mitigate the Project' s impacts to biological resources.

To mitigate the project' s impacts to biological resources, the Environmental Checklist requires compliance with the SJMSCP, as required by the 2020 General Plan. ( Envt. Checklist, p. 55.) However, as Dr. Smallwood explains, the SJMSCP cannot be relied upon to mitigate the Project' s impacts "[ d] ue to grossly deficient implementation and due to poor performance of the SJMSCP." ( Ex. A, p. 25.) Dr. Smallwood identified several shortcomings of the SJMSCP, as discussed below.

First, the majority of special- status species likely to occur at the Project site are not covered by the SJMSCP. ( Ex. A, p. 26.) As a result, " the SJMSCP insufficiently covers specialstatus species that would be adversely affected by the project." ( Id.) The reason that so many species are not covered by the SJMSCP is that more and more species have been designated as special- status" since adoption of the SJMSCP. The SJMSCP does not provide any protection for those species.

Second, the SJMSCP requires protocol- level detection surveys. ( Ex. A, p. 26.) Yet, no LIUNA Comment re: Ashley Furniture Project
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such surveys have been conducted on the Project site. ( Id.) Detection surveys must be conducted, especially for burrowing owl and Swainson' s hawk, to properly comply with the SJMSCP.

Third, Dr. Smallwood conducted an in- depth review of the SJMSCP and found that, to date, the SJMSCP has utterly failed at conserving special status- species. ( Ex. A, pp. 26- 33.) To conduct his analysis, Dr. Smallwood reviewed the SJMSCP' s Annual Reports published since 2008. As an initial matter, he found that the Annual Reports had flaws with study design, deficient implementation, and poor reporting, including inconsistent naming of preserve areas, a failure to conduct any trend analysis, and a failure to report survey methods including time, duration, or standards. ( Id., pp. 27- 28.) Dr. Smallwood' s review ofthe Annual Reports revealed several unsettling trends demonstrating the SJMSCP' s failure to conserve species, including a decline in Swainson' s hawk detections ( id., p. 29), a decline in detections of species covered by the SJMSCP ( id., p. 30), a decline in detections of all species ( id.), a decline in the productivity of Swainson' s hawk ( id., p. 32), and a decline in the number of acres surveyed ( id., p. 33). Based on this analysis, Dr. Smallwood concludes that"[ t] he SJMSCP has failed in its implementation, and it has proven ineffective at conserving its covered species; it should not be used to mitigate impacts to wildlife that occur on the project site. ( Id.) Although Section 15183 exempts project from further CEQA review where projectspecific impacts can be mitigated by uniformly applied development policies or standards ( such as the SJMSCP), the exemption does not apply if" new information shows that the policies or standards will not substantially mitigate the environmental effect." ( 14 CCR § 15183( fj.) Here, Dr. Smallwood' s analysis of the SJHSCP' s Annual Records presents new information showing that the SJMSCP has failed to substantially mitigate impacts to wildlife and, therefore, cannot substantially mitigate the Project' s impacts. As a result, the City' s reliance on Section 15183 is misplaced.

E. The additional mitigation measures required for the Project' s impacts to biological resources are inadequate and render the Project ineligible for an exemption under Section 15183.

In addition to compliance with the SJMSCP, the Project is required to adopt the mitigation recommendations identified in the Biological Report, which include preconstruction surveys for reptiles, birds, and burrowing owls. ( Envt' 1 Checklist, pp. 52- 54.) The need for these additional mitigation measures is proof in and of itself that the Project will result in Projectspecific impacts that have not been adequately addressed or mitigated by the 2022 GP EIR.

Section 15183 exempts projects with project- specific impacts only where those impacts " can be substantially mitigated by the imposition of uniformly applied development policies or standards." ( 14 CCR § 5183( c).) The preconstruction surveys required for this Project are not uniformly applied policies or standards. Rather, they are specific mitigation measures taken from The data utilized in Dr. Smallwood' s evaluation ofthe SJMSCP is available at:
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LILINA Comment re: Ashley Furniture Project
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the Biological Report specifically designed to mitigate this Project' s peculiar impacts to wildlife that are not addressed in the 2022 GP EIR. As a result, the Project does not qualify for an exemption under Section 15183 and further CEQA analysis is required for the Project.

Moreover, as Dr. Smallwood explains, pre- construction surveys are inadequate to mitigate the Project' s impacts. ( Ex. A, pp. 33- 35.) Rather, protocol- level detection surveys are necessary because detection surveys have a much greater probability of detection than preconstruction- surveys. ( Id., p. 33.) Dr. Smallwood explains that"[ b] irds are highly skilled at hiding their nests" and"[ l] oggerhead shrikes and burrowing owls, as examples, make efforts to fool human observers into thinking the birds' nests are located where they are not." ( Id. p. 34.) As a result, "[ 1] ocating nest sites of these species and most others requires multiple surveys over long time periods . . . This is why the breeding- season survey protocols require multiple surveys spaced through much of the breeding season." ( Id.) Furthermore, even with pre- construction surveys, impacts to wildlife would not be reduced to less- than- significant levels because such surveys do nothing to mitigate the additional impacts identified by Dr. Smallwood, including breeding capacity and habitat fragmentation. ( Id.) Therefore, the Project will result in Projectspecific impacts to biological resources that remain significant and unmitigated.

II. The Analysis of the Project' s Impacts to Human Health from Emissions of Toxic Air Contaminants Is Inadequate.

For warehouses and distribution centers within 1, 000 feet of planned residential uses or other sensitive receptors, the 2022 General Plan requires " requires the preparation of a Health Risk Assessment(" HRA") that meets the standards established by the Office of Environmental Health Hazard Assessment (" OEHHA"), and the San Joaquin Valley Air Pollution Control District(" SJVAPCD"). ( 2022 GP, p. 3. 3- 31 [ LU- Sc].) The General Plan prohibits approval of such a project" until it can be demonstrated that the project would not result in an exceedance of the established thresholds of significance for public health risks at nearby sensitive receptors." Id.)
Here, there are numerous sensitive receptors within 1, 000 feet of the Project, including clusters of residences 320 feet, 400 feet, and 940 feet away and a single residence 820 feet away Envt' I Checklist, p. 43.) According to the Environmental Checklist, an HRA was conducted and found that the Project' s increased cancer risk from emissions of diesel particulate matter DPM") would not exceed SJVAPCD' s significance threshold of 20 in one million. ( Id., pp. 44-

45.) LILJNA retained air quality experts Matt Hagemann, P. G., C. Hg., and Paul E. Rosenfeld, Ph. D., ofthe Soil/ Water/ Air Protection Enterprise (" SWAPE") to review the HRA. SWAPE found that HRA did not comply with the standards established by OEHHA and, as a result, the Project' s impacts had not been adequately evaluated. SWAPE' s comment and CVs are attached as Exhibit B.

First, SWAPE notes that the Checklist failed to provide the exposure assumptions for the HRA, such as the age sensitivity factors (" ASF") or fraction of time at home (" FAH") values, and, as a result, the HRA may underestimate the Project' s increased cancer risk. (Ex. B, p. 2.) LILINA Comment re: Ashley Furniture Project
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Additionally, the Checklist failed to provide the dose and risk equation used to calculate the Project' s cancer risks. (Id.) Without providing this equation, there is no way to verify that the HRA utilized the proper equation recommended by OEHHA. ( Id.) Second, even though the 2022 General Plan requires that the HRA meet the standards established by OEHHA, the HRA prepared for the Project failed to do so because it only analyzed the Project' s operational cancer risks but completely ignored the Project' s construction- related cancer risks. According to OEHHA, the cancer risk of all short- term projects lasting at least 2 months should be assessed and projects lasting more than 6 months should be evaluated for the duration of the project. ( Ex. B, p. 3.) Because construction of the Project will surely last at least 2 months ( and may exceed six months), the HRA should have included construction- related emissions in addition to operational emissions. The HRA further conflicts with OEHHA guidance by failing to evaluate the lifetime cancer risk to nearby receptors as a result of Project construction and operation combined. ( Id.) Due to these shortcomings, the HRA does not comply with OEHHA standards as required by the 2022 General Plan and underestimates the Project' s cancer risks. As a result, the City lacks substantial evidence to conclude that the Project will not result in specific health impacts. Furthermore, the City lacks substantial evidence to conclude that the Project' s impacts were addressed in the 2022 GP E[ R since the 2022 General Plan required compliance with OEHHA standards, which the Project' s HRA did not do. The HRA must be updated prior to any approval of the Project.

III. The Analysis of the Project' s Energy Impacts Is Inadequate.

The 2022 GP EIR' s discussion of the General Plan' s energy impacts boils down to stating that by complying with California' s Building Energy Efficiency Standards (" CalGreen"), promoting the use of renewable energy sources and encouraging public transportation and bicycle use, and the fact that PG& E will generally make progress on adding new renewable energy sources to its portfolio, projects within the planning area will not have energy impacts. 2022 GP EIR, pp. 3. 7- 41 to 3. 7- 42.) The Environmental Checklist focuses on the Ashley Furniture Project' s compliance with CalGreen and PG& E' s long- term efforts. ( Env' t Checklist,
p. 66.) None of these considerations address the energy effects that are peculiar to a 1. 4 million square feet furniture distribution and retail center.

California Clean Ener Committee v. City of Woodland( 2014) 225 CaLApp. 4th 173, 213.) Energy conservation under CEQA is defined as the " wise and efficient use of energy." ( CEQA Guidelines, app. F, § I.) The " wise and efficient use of energy" is achieved by "( 1) decreasing overall per capita energy consumption, ( 2) decreasing reliance on fossil fuels such as coal, natural gas and oil, and ( 3) increasing reliance on renewable energy resources." ( Id.) LIUNA Comment re: Ashley Furniture Project
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Noting compliance with the California Building Energy Efficiency Standards ( Cal.Code Regs., tit. 24, part 6 ( Title 24)) does not constitute an adequate analysis of energy impacts.

Ukiah Citizens for Safery First v. Ciry of Ukiah ( 2016) 248 CaLApp. 4th 256, 264- 65.) Similarly, the court in City of Woodland held unlawful an energy analysis that relied on compliance with Title 24, that failed to assess transportation energy impacts, and that failed to address renewable energy impacts. ( California Clean Energy Gommittee v. City of Woodland, 225 Cal.App.4th 173, 209- 13.) As such, the General Plan EIR' s reliance on Title 24 compliance does not address the proposed furniture warehouse Project' s energy impacts. The energy effects of the Project are, by definition, peculiar to the Project. Given the vast expanse of roofing provided by the proposed Project, any evaluation of its energy impacts cannot ignore the obvious feasibility of an array of solar panels on the roof or covering the extensive parking proposed at the site. Energy efficiency, in the context of the Proposed project and site would require the consideration and implementation of sufficient solar panels to meet all of the Project' s direct electricity demand, as well as solar power that would offset the considerable GHG and other air pollution emissions that will result from the thousands of trucks and cars driving to and from the Project every day once it' s operational.

The Environmental Checklist contains no discussion of the project' s cost effectiveness in terms of energy requirements. There is no discussion of energy consuming equipment and processes that will be used during the construction or operation of the project. The project' s energy use efficiencies by amount and fuel type for each stage of the project including construction and operation were not identified. The effect of the project on peak and base period demands for electricity has not been addressed. As such, the Environmental Checklist' s conclusions are unsupported by the necessary discussions of the Project' s energy impacts under CEQA and the City lacks substantial evidence to exempt the Project under Section 15183.

IV. The City Must Prepare a Statement of Overriding Considerations.

The 2022 General Plan Update concluded that several ofthe impacts identified as a result of the General Plan Update project were significant and unavoidable. These impacts included agricultural resources, air quality, greenhouse gas, and traffic noise impacts. In the Environmental Checklist prepared for the Project, the City acknowledges these significant and unavoidable impacts, but states that:

Impacts from buildout of the General Plan including cumulative impacts associated with development and buildout of the CLSP Phase 2 plan area and the warehouse Project site, as proposed, were fully addressed in the General Plan EIR State Clearinghouse No. 2021100139), and implementation of the proposed project would not result in any new or altered impacts beyond those addressed in the General Plan EIR.

Envt' l Checklist, p. 13.) Similar statements are repeated for each of the specific unavoidable significant impacts. This conclusion does not, however, address all of the City' s obligations to grapple with acknowledged significant and unavoidable cumulative LILINA Comment re: Ashley Furniture Project
City Council Agenda Item 5. 3 ( October 9, 2023)
October 6, 2023

Page 11 of 12 ends

impacts.

In the case of Communitiesfor a Better Environment v. Cal. Resources Agency, the court of appeal held that, although tiering may allow a later project to rely on the environmental analysis contained in a prior program- level EIR, that procedure does not relieve the agency of acknowledging the significant and unavoidable impacts and reconsidering its statement of overriding considerations. As the Court explained:

CEQA section 21094, subdivision ( d) requires agencies that approve a later project to comply with CEQA section 21081. Under CEQA section 21081, an agency approving a project with significant environmental effects must find that each effect will be mitigated or avoided, or " that specific overriding economic, legal, social, technological, or other benefits of the project outweigh the ... effect[] ...." The requirement of a statement of overriding considerations is central to CEQA' s role as a public accountability statute; it requires public officials, in approving environmentally detrimental projects, to justify their decisions based on counterbalancing social, economic or other benefits, and to point to substantial evidence in support. Under Guidelines section 15152(( 3)( C), however, an agency apparently could adopt one statement of overriding considerations for a prior, more general EIR, and then avoid future political accountability by approving later, more specific projects with significant unavoidable impacts pursuant to the prior EIR and statement of overriding considerations. Even though a prior EIR' s analysis of environmental effects may be subject to being incorporated in a later EIR for a later, more specific project, the responsible public officials must still go on the record and explain specifically why they are approving the later project despite its significant unavoidable impacts.

Communities for a Better Env't v. California Res. Agency( 2002) 103 Cal. App.4th 98, 124- 25.).

The same reasoning applies to the implementation of Section 15183. The Project, based on its reliance on the 2022 GP EIR, will have cumulative impacts on agricultural resources, air quality, greenhouse gas emissions, and traffic noise. Although sections 21083 and 15183 provide for streamlining of the environmental review of a subsequent project, neither section relieves the City from its obligation to make a statement of overriding considerations for the Project. ( PRC § 21081.) Thus, the City must prepare a statement of overriding considerations— supported by substantial evidence and evaluating whether any additional feasible mitigation measures applicable to this specific project— prior to approval of the Project.

CONCLUSION
In light of the above the Project does not qualify for an exemption from CEQA under LILJNA Comment re: Ashley Furniture Project
City Council Agenda Item 5. 3 ( October 9, 2023)
October 6, 2023

Page 12 of 12 ends

Section 15183 and, the City must prepare an EIR or, if appropriate, a mitigated negative declaration for the Project prior to approval.

Sincerely,
1/'
Brian B. Flynn

LOZEAU DRURY LLP

Shawn Smallwood, PhD
3io8 Finch Street
Davis, CA 956 6
Attn: Rick Caguiat, Director of Community Development
The City of Lathrop
390 Towne Centre Dr
Lathrop, CA 9533o i October 2023
RE: Ashley Warehouse Project
Dear Mr. Caguiat,
I write to comment on potential impacts to biological resources that could result from the Ashley Warehouse Project. I reviewed an Environmental Checklist prepared for the Central Lathrop Specific Plan ( CLSP) Phase 2 Update, and Ashley Warehouse Project, and a biological resources assessment prepared by Olberding ( 2021). I understand the project would construct a i,486, 60 square- foot building up to 6o feet in height and 943 vehicle spaces, and , io4 trailer spaces/ stalls on 89. 92 acres of what used to be in dryland agriculture, but which over the past decade has been unfarmed but repeatedly disced, leaving patches of ruderal grassland unreached by the discing assembly. I am concerned that the project would cause significant impacts to multiple special- status species of wildlife and to wildlife in general, and that the impacts would be insufficiently mitigated with participation in the San Joaquin County Multi-Species Habitat Conservation and Open Space Plan ( SJMSCP), which is failing to conserve its covered species ( see below). I am concerned that exemptions per CEQA Guidelines § i5i83 do not apply to this site nor to this project.

My qualifications for preparing expert comments are the following. I hold a Ph.D. degree in Ecology from University of California at Davis, where I also worked as a postgraduate researcher in the Department of Agronomy and Range Sciences. My research has been on animal density and distribution, habitat selection, wildlife interactions with the anthrosphere, and conservation of rare and endangered species. I authored many papers on these and other topics. I served as Chair of the Conservation Affairs Committee for The Wildlife Society —Western Section. I am a member of The Wildlife Society and Raptor Research Foundation, and I've lectured part-time at California State University, Sacramento. I was Associate Editor of wildlife biology's premier scientific journal, The Journal of Wildlife Management, as well as of Biological Conservation, and I was on the Editorial Board of Environmental Management. I have performed wildlife surveys in California for thirty-seven years. My CV is attached.

SITE VISIT
I visited the site of the proposed project for 2. 55 hours from o6: 53 to 09: 26 hours on 2 September 2023. I scanned for wildlife with use of binoculars from the roads bordering the site. I recorded all species of vertebrate wildlife I detected, including those whose members flew over the site or were seen adjacent to the site. Animals of uncertain l
species identity were either omitted or recorded to a higher taxonomic level. Weather was sunny with no wind and 55- 65° F. The site was mostly disced, and otherwise covered by ruderal annal grassland ( Photos i- 3).
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Table 1. S ecies o wildli e I obserued durin 2.55 hours o surue on 21 Se tember 202,3.

Common name S ecies name Status1 Notes
White- throated swift Aeronautes saxatalis Fora ed
Rock i eon Columba liuia Non- native Fora ed
Eurasian collared- dove Stre to elia decaocto Non- native Fora ed Mournin dove Zenaida macroura Fora ed
Killdeer Charadrius uoci erus Fora ed
California ull Larus cali ornicus BCC, TWL Fl overs
Double- crested cormorant Nanno terum auriturri TWL Fl over Sno e ret E retta thula Fl over
Turke vulture Cathartes aura BOP Fora ed
White- tailed kite Elanus leucurus CFP, BOP Called
Coo er' s hawk Acci iter coo erii TWL, BOP Harassed b kestrels Swainson' s hawk Buteo swainsoni CT, BOP Fora ed
Red- tailed hawk Buteo ' amaicensis BOP Fora ed
Great horned owl Bubo uir inianus BOP Pellets
American kestrel Falco s arverius BOP Fora ed
Black hoebe Sa ornis ni ricans Fora ed
Sa ' s hoebe Sa ornis sa a Fora ed
Lo erhead shrike Lanius ludoutcianus SSC2 Fora ed
California scrub-' a A helocoma cali ornica Fora ed
American crow Corvus brach rh nchos Fora ed
Horned lark Eremo hila al estris Fl over
Barn swallow Hirundo rustica Fora ed
American i it Anthus rubescens Fora ed
Northern mockin bird Mimus ol lottos Fora ed
Euro ean starlin Sturnus vul aris Non- native Fora ed
House finch Haemor hous mexicanus Fora ed
Lesser oldfinch S inus saliria Fora ed
Western meadowlark Sturnella ne lecta Fora ed
Red- win ed blackbird A elaius hoeniceus Fl overs
Brewer' s blackbird Eu ha us c anoce halus Fora ed
Desert cottontail S luila us audubonii Tracks
California round s uirrel Otos ermo hilus beeche i
Co ote Canis lairans
Kan aroo rat Di odom s Burrows
Botta' s ocket o her Thomom s bottae Burrows
3 1 Listed as CT = California threatened, CFP = California Fully Protected ( CFG Code 35ii), SSC2 = California Species of Special Concern priority level2, BCC = U.S. Fish and Wildlife Service Bird of Conservation Concern, T4VL= Taxa to Watch List ( Shuford and Gardali 2008), and BOP = Birds of Prey( California Fish and Game Code 3503• 5)•
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Photo 4. One ofat least three Swainson' s hawkforaging on the project site, 21 September 2023.
4 Photo 5. One oftwo redtailed hawks on the
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Photos 8—l0. Lesser goldfinch and Brewer' s blackbird( top), and housefinches bottom) on the project site, 21 September 202,3.
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Photos 12. A California ground
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7 What I found at the project site qualifies as an exception to CEQA Guidelines § i5i83 regarding exemptions to additional environmental review. Considering the site' s condition and what I have found at 55 other sites throughout California that were of similar condition, the relatively large number of species I detected, and especially the number of special-status species I detected, should the project go forward as proposed, it would result in impacts peculiar to the parcel on which the project would be located.

What I found at the project site is a rate of species' detections that exceeded the 95% confidence interval derived from similar reconnaissance surveys I completed at 55 other sites ( Figure 1). The project site is inherently rich in wildlife, especially in special- status species of wildlife.
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10 _' 95% CI of visualscan surveys 2019- 2023
o Actual count of species
V Model prediction
r2= 0. 98, loss = 60. 8
0 0 50 100 150 200 250 300
Minutes into survey
Figure 1. Actual( circles) and predicted( line) relationship beizueen the number of uertebrate wildlife species detected and the elapsed survey time based on my visualscan surveys on 21 September 2023, and compared to the 9,5% CI of,55 surveys I completed at sites proposed for projects throughout California that had similarly been intensiUely and extensively disturbed in manners to suppress wildlife occurrences. The arrow points to the place on the graph which corresponds with the time it took me to find the same number of uertebrate wildlife species as reportedly detected by Olberding (2021) on 5 May 2021.
8 My surveys provide evidence of the project site' s exceptional habitat value to wildlife, but additional value can be inferred from my data. Reconnaissance surveys, such as the survey I completed, can be useful for confirming presence of species that were detected, but they can also be useful for estimating the number of species that were not detected.

One can model the pattern in species detections during a survey as a means to estimate the number of species that used the site but were undetected during the survey. But whereas this modeling approach is useful for more realistically representing the species richness of the site at the time of a
survey, such as in Figure , it cannot represent the
species richness throughout the year or across multiple years because many species are seasonal or even multi- annual in their movement patterns and in their occupancy of habitat. Multiple surveys are needed to inventory the species that make use of a site over the period of a year or longer.

By use of an analytical bridge, a modeling effort applied to a large, robust data set from a research site can predict the number of vertebrate wildlife species that likely make use of the site over the longer term. As part of my research, I completed a much larger survey effort across i6'7 km2 of annual grasslands of the Altamont Pass Wind Resource Area, where from 20 5 through 2019 I performed 211- hour visual- scan surveys, or 2i hours of surveys, at 46 stations. I used binoculars and otherwise the methods were the same as the methods I and other consulting biologists use for surveys at proposed project sites. At each of the 46 survey stations, I tallied new species detected with each sequential survey at that station, and then related the cumulative species detected to the hours ( number of surveys, as each survey lasted i hour) used to accumulate my counts of species detected. I used combined quadratic and simplex methods of estimation in Statistica to estimate least- squares, best- fit nonlinear models of the number of cumulative species detected regressed on hours of survey( number of surveys) at the station: R = 1
a+ 6x( Hours) ^'
here R represented cumulative species richness detected.

The coefficients of determination, r2, of the models ranged o. 88 to i.00, with a mean of 0•97 95 CI:, o. 96, 0. 98); or in other words, the models were excellent fits to the data.

I projected the predictions of each model to thousands of hours to find predicted asymptotes of wildlife species richness. The mean model- predicted asymptote of species richness was 57 after 11, 857 hours of visual- scan surveys among the 46 stations of my research site. I also averaged model predictions of species richness at each incremental increase of number of surveys, i.e., number of hours ( Figure 2). On average I detected 2 species over the first 2. 55 hours of surveys at my research site in the Altamont Pass

2. 55 hours to match the 2.55 hours I surveyed at the project site), which composed i9. 65% of the predicted total number of species I would detect with a much larger survey effort at the research site. Given the example illustrated in Figure 2, the 35 species I detected after my 2. 55 hours of survey at the project site likely represented

19. 65% of the species to be detected after many more visual- scan surveys over another year or longer. With many more repeat surveys through the year, I would likely detect 35 0. 1965 — 178 species of vertebrate wildlife at the site. Assuming my ratio of specialstatus to non- special- status species was to hold through the detections of a111 8 predicted species, then continued surveys would eventually detect 5 special- status species of vertebrate wildlife.
9 Figure 2. Mean ( 95% CI) 50
predicted wildlife species 1r
richness, R, as a nonlinear
function ofhour-long
suruey tncrements across 40
46 uisual- scan suruey
stations across the
Altamont Pass Wind
30 Resource Area, Alameda U
and Contra Costa o
Counties, 2015- 2o1g. Note
that the location ofthe 2p . p
siudy is largely irreleuant
to the utility ofthe graph 6
to the interpretation of
survey outcomes at the 10 =
project site. It is the
pattern in the data that is
relevant, because the
pattern is typical of the 0 20 40 60 80 100
pattern seen elsewhere. Cumulative number of surveys ( hours) Again, however, my prediction of i 8 species of vertebrate wildlife, including 5i specialstatus species of vertebrate wildlife, is derived from daytime visual- scan surveys, and would not detect nocturnal mammals such as bats. The true number of species composing the wildlife community of the site must be larger. A reconnaissance survey should serve only as a starting point toward characterization of a site' s wildlife community, but it certainly cannot alone inform of the inventory of species that use the site. More surveys are needed. Nevertheless, the large number of species I predict at the project site is exceptional, and in my experience with many reconnaissance surveys in California, the species richness at the site relative to its level of disturbance is peculiar to the site.

EXISTING ENVIRNMENTAL SETTING
The first step in analysis of potential project impacts to biological resources is to accurately characterize the existing environmental setting, including the biological species that use the site, their relative abundances, how they use the site, key ecological relationships, and known and ongoing threats to those species with special status. A reasonably accurate characterization of the environmental setting can provide the basis for determining whether the site holds habitat value to wildlife, as well as a baseline against which to analyze potential project impacts. For these reasons, characterization of the environmental setting, including the project site' s regional setting, is one of CEQA' s essential analytical steps. Methods to achieve this rst step typically include ( i) surveys of the site for biological resources, and( 2) reviews of literature, databases and local experts for documented occurrences of special- status species. In the case of the proposed project, these needed steps were grossly inadequate. 10 Environmental Setting informed by Field Surveys
To CEQA' s primary objective to disclose potential environmental impacts of a proposed project, the analysis should be informed of which biological species are known to occur at the proposed project site, which special- status species are likely to occur, as well as the limitations of the survey effort directed to the site. Analysts need this information to characterize the environmental setting as a basis for opining on, or predicting, potential project impacts to biological resources.

Olberding ( 2o2i) incompletely reports on the reconnaissance survey that was completed at the project site. Although the survey date is reported( 5 May 2o2i), Olberding ( 2o2i) does not report what time of day the survey began, nor the survey' s duration. These are critical omissions that prevent the reader from understanding the survey outcome.

Olberding( 2021) did not achieve the minimum standards for reconnaissance survey directed toward plants ( CDFW 2oi8). Olberding' s ( 2o2i) conclusions regarding the unlikely occurrences of special- status species of plants therefore lack adequate foundation in survey.

The findings of the Olberding ( 2021) are largely unreliable. Olberding ( 202) managed to detect only six species of vertebrate wildlife, which is the number of vertebrate wildlife species I detected within two minutes from the start of my survey on 2i September 2023 ( see the arrow in Figure ). After 2. 55 hours, I detected nearly six times the number of species of vertebrate wildlife as did Olberding ( 2o2i), and the pattern in the data indicate I would have detected many more species had I continued the survey Figure i).Whereas Olberding ( 2o2i) saw three special- status species, I saw ten of them. Olberding (2021) missed the great horned owl pellets that I found under nearly every span of electric distribution lines. Olberding ( 2021) missed the kangaroo rat burrow systems, and the Botta' s pocket gopher burrow systems, both types of burrows of which are readily visible. Furthermore, Olberding ( 202) saw no bird smaller than a white- tailed kite, whereas I saw 22 such species. Perhaps because the survey was too brief of for some other reason, Olberding ( 2o2i) saw and reported few of the vertebrate wildlife species that occur on the project site.

No surveys were completed for bats. Nor were any protocol- level detection surveys completed for special- status species despite known occurrences in the project area. No detection surveys were completed for burrowing owl and Swainson' s hawk( I saw three on site). Swainson's hawks nested on a tree just across Dos Reis Road on the south side of the project site in 2o2i ( Olberding 2o2i) and probably again in 2023, based on my observations. And because ground squirrels occur on and around the project site, there is a reasonable likelihood that burrowing owls also occur on the site. Protocol-level detection surveys are available for these species ( CDFW 2010, 2oi2), and should be implemented.

Olberding ( 2021) fails to accurately inform the Checklist of the wildlife community that is part of the existing environmental setting. Olberding' s ( 2o2i) reporting was deficient, and the surveys were grossly incomplete and unreliable. 11 Environmental Setting informed by Desktop Review
The purpose of literature and database review and of consulting with local experts is to inform the reconnaissance survey, to augment interpretation of its outcome, and to help determine which protocol-level detection surveys should be implemented. Analysts need this information to identify which species are known to have occurred at or near the project site, and to identify which other special- status species could conceivably occur at the site due to geographic range overlap and site conditions. This step is important because the reconnaissance survey is not going to detect all of the species of wildlife that make use of the site over a period of a year or longer. This step can identity those species yet to be detected at the site but which have been documented to occur nearby or whose available habitat associations are consistent with site conditions. Some special- status species can be ruled out of further analysis, but only if compelling evidence is available in support of such determinations.

Olberding( 2021) provides an inadequate database or desktop review. The desktop review neglects iNaturalist and eBird as data sources. It provides no evidence that local experts were consulted for knowledge of occurrences of special- status species in the project area. The methodology for selecting special- status species for analysis of occurrence likelihoods was flawed (see below).

By including in the species' likelihood of occurrence analysis only species whose documented occurrences within the nearest CNDDB quadrangles, Olberding ( 2021) screens out many special-status species from further consideration in the characterization of the wildlife community as part of the baseline environmental setting.

CNDDB is not designed to support absence determinations or to screen out species from characterization of a site' s wildlife community. As noted by CNDDB, " The CNDDB is a positiue sighting database. It does not predict where something may be found. We map occurrences only where we have documentation that the species was found at the site.

There are many areas of the state where no surveys haue been conducted and therefore there is nothing on the map. That does not mean that there are no special status species present." Olberding (2021) misuses CNDDB.

CNDDB relies entirely on volunteer reporting from biologists who were allowed access to whatever properties they report from. Many properties have never been surveyed by biologists. Many properties have been surveyed, but the survey outcomes never reported to CNDDB. Many properties have been surveyed multiple times, but not all survey outcomes reported to CNDDB. Furthermore, CNDDB is interested only in the findings of special- status species, which means that species more recently assigned special status will have been reported many fewer times to CNDDB than were species assigned special status since the inception of CNDDB. The lack of many CNDDB records for species recently assigned special status had nothing to do with whether the species' geographic ranges overlapped the project site, but rather more to do with the brief time for records to have accumulated since the species were assigned special status. And because negative findings are not reported to CNDDB, CNDDB cannot provide the basis for estimating occurrence likelihoods, either.
12 In my assessment based on database reviews and site visits, io special- status species of wildlife are known to occur near enough to the site to warrant analysis of occurrence potential ( Table 2). Of these io species, 10 ( 9%) were recorded on site, and another 22 2i%) species have been documented within i.5
miles of the site (` Very close'), another
i9 (i8%) within 1. 5
and 4 miles (` Nearby'), and another 46 ( 43%) within 4 to 3o miles In region'). Nearly half( 48%) of the species in Table 2 have been reportedly seen within 4 miles of the project site. The site therefore supports multiple special- status species of wildlife and carries the potential for supporting many more special- status species of wildlife based on proximity of recorded occurrences.

Because the project would attempt to mitigate its impacts to wildlife by participating with the SJMSCP, it is important to analyze the occurrence likelihoods of SJMSCPcovered species. Of the o special- status species in Table 2, 36 ( 34%) are covered by the SJMSCP, including 5 that I observed on the project site, io with known occurrences very close, nearby, and io in the region. Of the 36 SJMSCP- covered species, the occurrence likelihoods of only i2 are analyzed by Olberding( 2o2i), including 2 that Olberding 2o2i) observed on site, and determinations by Olberding ( 2o2i) that i may occur on site, 3 are unlikely, and 6 are presumed absent. In summary, only a third of the specialstatus species in Table 2 are covered by the SJMSCP, 6% of which have been recorded within 4 miles of the project site, and only 33% of which have been analyzed in support of the Checklist.

Because the project would attempt to mitigate its impacts to wildlife by participating with the SJMSCP, it is also important to analyze the occurrence likelihoods of specialstatus species that are not covered by the SJMSCP. In fact, for these species, it is even more important to analyze their occurrence likelihoods because the mitigation of the SJMSCP was not formulated with these species in mind. Of the o special- status species that are listed in Table 2, i (66%) are not covered by the SJMSCP, including 5 that I observed on site, and occurrence records of i2 that are very close, i2 nearby, and 36 in the region. Of i the special- status species in table 2 that not covered by the SJMSCP, Olberding ( 202) analyzes the occurrence likelihoods of only 8 ( li%), including of none that I observed on site, and determinations by Olberding (2o2i) of 2 as unlikely and 6 as presumed absent. Of the latter 6 species Olberding ( 2021) presumed absent, 2 have been recorded very close to the project site ( yellow- headed blackbird and Modesto song sparrow only o.46 miles away). In summary, two- thirds of the specialstatus species in Table 2 are not covered by the SJMSCP, 29 ( 4i%) of which have been recorded within 4
miles of the project site, and only 8 ( ii%) of which have been analyzed in support of the Checklist. Except for my own assessments in Table 2, the Checklist is grossly inadequate in its characterization of that part of the wildlife community that lacks coverage under the SJMSCP.
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Habitat Assessment
Olberding( 202) speculates that "Due to the heavily disturbed nature of the Property there were a limited number of wildlife species observed during the survey." However, the heavy disturbance was much less limiting to the number of wildlife species that I detected on the project site, as I found nearly 6 times the number reported by Olberding 2021). This noted, the project site has been intensively disturbed over a number of years, and this level of disturbance undoubtedly diminished the species of wildlife species that occur on the site as compared to times preceding the repeated discing of the site. Nevertheless, wildlife strive to survive, even where conditions are far from ideal.

Some species often fare better on disturbed soils. Horned larks and killdeer are perfectly capable of nesting on the ground of the project site. American pipits, American crows, house finches and red- winged blackbirds often forage on disced soil, and these birds are in turn pursued by Swainson' s hawks, Cooper' s hawks and white- tailed kites, among others. Swainson' s hawks are known for foraging over disturbed fields, especially as the fields are being disturbed by activities such as discing ( Smallwood i995, Smallwood et al. i996, Swolgaard et al. 2008). Swainson' s hawks nested adjacent to the project site for good reasons. The disturbance of a site is no justification for dismissing it as valuable to wildlife ( Smallwood and Smallwood 2023).

For multiple species, Olberding ( 2o2i) speculates that the project site is unsuitable as nesting habitat and therefore is unlikely to cause significant impacts if it is developed.

However, there is no sound scientific distinction between nesting habitat and some other characterization of habitat. For any given species, the environment of a site is either habitat or it is not, as habitat is defined as that part of the environment that is used by a species ( Hall et al. i997). Certain portions of a species' habitat may provide nesting opportunities, but all parts of its habitat are critical to the nesting success of members of the species. If an animal cannot find sufficient forage and cover during nonnesting season or at portions of its habitat where it does not normally nest, then it might not survive to reproduce or its nesting attempt might not succeed. Olberding ( 2o2i) asserts a false distinction of the value of a site based on whether the species nests onsite.

The above- arguments were applied to loggerhead shrike, which serves as a good example of how poorly predictive the Olberding' s ( 2o2i) approach is to determining occurrence likelihood. Olberding ( 2o2i) determines loggerhead shrike to have a low likelihood of occurrence due to lack of trees and shrubs needed for nesting. However, loggerhead shrikes are resourceful when it comes to finding and using nest substrate Smallwood and Smallwood 2o2i). Furthermore, elderberry shrubs occur on the project site ( Photo 3) as do loggerhead shrikes ( Table 1, Photos 6 and). When I arrived at the project site to perform my survey, I expected to see loggerhead shrikes, based on my experience. The occurrence likelihood of loggerhead shrike was not low, and the same can be concluded for many of the other special- status species considered by Olberding 2o2i).
19 POTENTIAL BIOLOGICAL IMPACTS
An impacts analysis should consider whether and how a proposed project would affect members of a species, larger demographic units of the species, the whole of a species, and ecological communities. The accuracy of this analysis depends on an accurate characterization of the existing environmental setting. In the case of the proposed project, the existing environmental setting has not been accurately characterized, and several important types of potential project impact have not been analyzed. These types of impacts include habitat loss, interference with wildlife movement, and collision mortality with solar PV panels and project-generated tra c.

HABITAT LOSS
The project would destroy 89. 92 acres of habitat to every species of wildlife that makes use of the project site. My survey outcomes interpreted with the help of an analytical bridge to more extensive research at another site in a similar environment predict i 8 species of vertebrate wildlife would eventually be detected by repeat visual- scan surveys similar those I completed. Added to these i 8 species would be all the nocturnal species I would unlikely detect during the daytime, such as species of bat, multiple species of small mammal, American badger and perhaps San Joaquin kit fox. What remains without analysis is the magnitude of loss of the numbers of animals that can be produced by the project site.

In the case of birds, two methods exist for estimating the loss of productive capacity that would be caused by the project. One method would involve surveys to count the number of bird nests and chicks produced. The alternative method is to infer productive capacity from estimates of total nest density elsewhere. I am aware of estimates of total nest density elsewhere, but none were on fields that underwent discing every year except for a field I surveyed for total nest density this past spring. The field had been a walnut orchard in Rancho Cordova, California, but the walnuts were abandoned while the floor continued to be disced, sometimes entirely and sometimes partially. I surveyed the i2. 74- acre study site 3o times from March through the first half of August to estimate total nest density. Total nest density of birds was i4.38 nests per acre, but this density included cavity nests and tree- supported cup nests within the scattering of abandoned orchard walnuts. Excluding the cavity nests and tree- supported cup nests, total nest density on the ground and in elderberry shrubs was 2. i2 nests/ acre. Assuming that the estimates of total bird nest densiry on the ground and in elderberry was similar between my study site and the project site, then the project site likely supports i91 nests per year.

The loss of i9i nest sites of birds would qualify as a potentially significant project impact, but the impact does not end with the immediate loss of nest sites as nest substrate is removed and foraging grounds graded in preparation for impervious surfaces. The reproductive capacity of the site would be lost. The average number of fledglings per nest in Young' s ( i948) study was 2. 9. Assuming Young' s ( i948) study site typifies bird productivity, the project would prevent the production of 554 fledglings per year. Assuming an average bird generation time of 5 years, the lost capacity of both breeders and annual fledgling production can be estimated from an equation in 20 Smallwood ( 2022): {( nests/ year x chicks/ nest x number of years) + ( 2 adults/ nest x nests/ year) x ( number of years = years/ generation)} = ( number of years) = 63o birds per year denied to California. In the face of a potential project impact of this magnitude, I conclude that the potential project impacts to the productive capacity of birds would be significant.

INTERFERENCE WITH WILDL•IVE MOVEMENT
The analysis of whether the project would interfere with wildlife movement in the regio is flawed and misleading. According to the Checklist, " The Biological Resources Analysis Report ( Attachment A) [ Olberding 2o2i] included a CNDDB record search that did not reveal any documented wildlife corridors or wildlife nursery sites on or adjacent to warehouse site." However, CNDDB is not where an analyst would find information relevant to whether a site is important to wildlife movement. Nor did Olberding (2o2i) address the issue of wildlife movement in the region. In effect, there is no analysis of whether the project would interfere with wildlife movement.

The Checklist also claims that the impact on wildlife movement corridors was adequately addressed in the General Plan EIR. Indeed, the General Plan EIR addresses wildlife movement corridors, but it does so with a focus on the San Joaquin River as a wildlife corridor, and it does so with a focus solely on the functionality of corridors. The General Plan EIR implies the premise that interference with wildlife movement in the region can result only from a project' s disruption of the function of a wildlife movement corridor. This premise represents a false CEQA standard, and was therefore inappropriate to the analysis. The primary phrase of the CEQA standard goes to wildlife movement regardless of whether the movement is channeled by a corridor. A site such as the project site is critically important for wildlife movement because it composes an increasingly diminishing area of open space within a growing expanse of anthropogenic uses, forcing more species of volant wildlife to use the site for stopover and staging during migration, dispersal, and home range patrol (Warnock 2oio, Taylor et al. 2oii, Runge et al. 2oi4).

In any case, many of the animals I saw on the project site got there by moving there from someplace else, and others were using the airspace of the site as a travel medium.

California gulls flew across the site, as did snowy egrets, double- crested cormorants, mourning doves, horned larks and many other birds. To and from the project site, pocket gophers disperse along linear elements of the landscape ( Smallwood et al. Zooi), and so do kangaroo rats; otherwise, these species would have been extirpated from the site long ago due to the discing. The project site includes grassland patches to and from which many species of wildlife are compelled to travel, and the majority of the site in disturbed soil likely serves as an island of open space in the winter months for stopover by mountain plovers, merlin, ferruginous hawks and many other special- status species.

The Checklist fails to analyze whether and to what degree the project' s 6o- foot- tall building and adjoining impervious surface covering nearly 90 acres would interfere with wildlife movement in the region, and whether the resulting impacts could be mitigated. 21 TRAFFIC IMPACTS TO WILDLIFE
For the following reasons, the project would qualify as an exception to CEQA Guidelines 15 83 regarding exemptions to additional environmental review: i) project- generated traffic impacts to wildlife were mentioned as a bullet item but not analyzed as significant effects in the Lathrop General Plan EIR, and 2) the project- generated traffic impacts to wildlife would be potentially significant off-site and they would contribute cumulatively to traff'ic impacts to wildlife impacts generated by other projects in the region, and which were not discussed in the Lathrop General Plan EIR. The Lathrop General Plan EIR's only mention of traffic impacts to wildlife was " Significant impacts on special status species associated with individual subsequent projects could include: increased mortality caused by higher numbers of automobiles in new areas of development." This is a statement, but not an analysis, and it was followed by no policies or actions to minimize the impacts.

The Checklist fails to address one of the project' s most obvious, substantial impacts to wildlife, and that is wildlife mortality and injuries caused by project- generated traffic.

Project- generated traffic would endanger wildlife that must, for various reasons, cross roads used by the project' s traffic ( Photos i3—i5), including along roads far from the project footprint. Vehicle collisions have accounted for the deaths of many thousands of amphibian, reptile, mammal, bird, and arthropod fauna, and the impacts have often been found to be significant at the population level ( Forman et al. 2003). Across North America traffic impacts have taken devastating tolls on wildlife ( Forman et al. 2003). In Canada, 3, 562 birds were estimated killed per ioo km of road per year( Bishop and Brogan 20 3), and the US estimate of avian mortality on roads is 2, 20o to 8, 405 deaths per 10o km per year, or 89 million to 34o million total per year ( Loss et al. 2oi4). Local impacts can be more intense than nationally.

Photo 13. A coyote uses the
crosswalk to crosses a road on 2
February 202,3.
22 i
Photos 4 and i5. Raccoon killed on Road 31 just east of Highway 505 in Solano County ( left; photo taken on lo November 2oi8), and mourning dove killed by uehicle on a California road( right; photo by Noriko Smallwood, 21 June 2020.) The nearest study of traffic- caused wildlife mortality was performed along a 2. 5- mile stretch of Vasco Road o9nly 2o miles away in Contra Costa County, California. Fatality searches in this study found i,275 carcasses of 49 species of mammals, birds, amphibians and reptiles over i5 months of searches ( Mendelsohn et al. 2009). This fatality number needs to be adjusted for the proportion of fatalities that were not found due to scavenger removal and searcher error. This adjustment is typically made by placing carcasses for searchers to find( or not find) during their routine periodic fatality searches. This step was not taken at Vasco Road ( Mendelsohn et al. 2009), but it was taken as part of another study next to Vasco Road( Brown et al. 2oi6). Brown et al.' s 2oi6) adjustment factors for carcass persistence resembled those of Santos et al. 2oii).Also applying searcher detection rates from Brown et al. ( 20 6), the adjusted total number of fatalities was estimated at 12, i8 animals killed by traffic on the road.

This fatality number over 1. 25 years and 2. 5 miles of road translates to 3, 90o wild animals per mile per year. In terms comparable to the national estimates, the estimates from the Mendelsohn et al. ( 2009) study would translate to 243 74o animals killed per ioo km of road per year, or 29 times that of Loss et al.' s ( 20 4) upper bound estimate and 68 times the Canadian estimate. An analysis is needed of whether increased traffic generated by the project site would similarly result in local impacts on wildlife.

For wildlife vulnerable to front- end collisions and crushing under tires, road mortality can be predicted from the study of Mendelsohn et al. ( 2009) as a basis, although it would be helpful to have the availability of more studies like that of Mendelsohn et al. 2009) at additional locations. My analysis of the Mendelsohn et al. ( 2009) data resulted in an estimated 3,90o animals killed per mile along a county road in Contra Costa County. Two percent of the estimated number of fatalities were birds, and the balance was composed of 34% mammals ( many mice and pocket mice, but also ground squirrels, desert cottontails, striped skunks, American badgers, raccoons, and others),

52. 3% amphibians (large numbers of California tiger salamanders and California red23 legged frogs, but also Sierran treefrogs, western toads, arboreal salamanders, slender salamanders and others), and ii.% reptiles ( many western fence lizards, but also skinks, alligator lizards, and snakes of various species). VMT is useful for predicting wildlife mortality because I was able to quantify miles traveled along the studied reach of Vasco Road during the time period of the Mendelsohn et al. ( 2009), hence enabling a rate of fatalities per VMT that can be projected to other sites, assuming similar collision fatality rates.

Predictin project- enerated traffic impacts to wildlife The Checklist predicts 2, 798 daily tips among i,295 employees and a mean 15•43 daily VMT per employee. Assuming the daily trips are weekdays, the annual VMT not including weekend mileage would amount to ii,225,0 6 annual VMT. During the Mendelsohn et al. ( 2009) study, 19, 50o cars traveled Vasco Road daily, so the vehicle miles that contributed to my estimate of non- volant fatalities was 9, 50o cars and trucks x 2. 5miles x
365 days/ year x 1. 25 years = 22, 242, i87.5 vehicle miles per 2, i8 wildlife fatalities, or i,825 vehicle miles per fatality. This rate divided into the predicted annual VMT would predict 6, 151 vertebrate wildlife fatalities per year. Even if the mortality turns out to be as low as half that of the Mendelsohn et al. ( 2oog) study, the annual death toll to wildlife resulting from project- generated traffic would be 3, 075, which would also qualify as a significant, unmitigated impact to wildlife caused by the project.

Based on my indicator- level analysis, the project- generated traffic would cause substantial, significant impacts to wildlife. The Checklist does not address this potential impact, let alone propose to mitigate it. Mitigation measures to improve wildlife safety along roads are available and are feasible, and they need exploration for their suitability with the proposed project. Given the predicted level of project- generated traffic- caused mortality, and the lack of any proposed mitigation, it is my opinion that the proposed project would result in potentially significant adverse biological impacts. The Checklist fails to analyze the impact of wildlife-automobile collisions resulting from projectgenerated traffic, and how to mitigate it.

CUMULATIVE IMPACTS
Because cumulative impacts are proving more severe than discussed in the Lathrop General Plan EIR, the project would be inconsistent with the CEQA Guideline §i5i83 regarding exemptions to additional environmental review. According to the Checklist ( p. 55) " The 2022 General Plan EIR determined that cumulative impacts to biological resources would be less than significant. ... As such, the proposed warehouse project is consistent with the adopted vision and uses identified within the General Plan, and would not result in any new or increased impacts associated with biological resources, beyond those that were already addressed in the 2022 Lathrop General Plan EIR. The proposed warehouse project would not result in a new or more severe impact than what was previously analyzed." The cumulative impacts analysis of the Lathrop General Plan EIR asserts that participation with the SJMSCP would prevent significant cumulative impacts. But it has not.
24 For example, burrowing owls have all but disappeared from the County, despite the SJMSCP. Over the past month ( since 26 September 2023), there has only been one occurrence of burrowing owl in San Joaquin County that has been reported to eBird, and that was in Tracy. eBird Trends Analysis reveals an average 82% decline in the area of the SJMSCP ( Figure 3).

Figure 3.
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decline of
burrowing
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area of the
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between 200 I I Q
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I r teca
ra

MITIGATION
Requirement BIO- i: Participation with SJMSCP
The principal mitigation measure in the City' s Checklist would be participation with the San Joaquin County Multi-Species Habitat Conservation and Open Space Plan SJMSCP). Due to grossly deficient implementation and due to poor performance of the SJMSCP, the project' s impacts to wildlife should be mitigated outside the SJMSCP. The SJMSCP is currently unsuitable as a mitigation strategy for the project. A projectspecific EIR needs to be prepared in order to formulate more effective mitigation. Below I explain why.
25 There are four major problems with relying on the SJMSCP to mitigate the project's impacts to special- status species of wildlife: ( i) Not all special- status species at the site are covered by the SJMSCP; ( 2) Many non- covered species of birds are still protected by the federal Migratory Bird Treaty Act (MBTA) and California Migratory Bird Protection Act ( MBPA), which warrant CEQA review for potential impacts; ( 3) The SJMSCP requires protocol-level detection surveys at project sites for covered species, but no such surveys have been performed at the site of the proposed project; and, (4) Available evidence indicates that the premise is likely false that SJMSCP participation conserves covered species. These problems are discussed further below. i) Seventy- one ( 66%) of the species in Table 2 are not covered by the SJMSCP. Four of the io special- status species that I saw on the project site are not covered by the SJMSCP. In other words, the SJMSCP insufficiently covers special- status species that would be adversely affected by the project. An important reason for this deficiency has been the continued assignments of special status to additional species as resource agencies have determined these species are declining or are in trouble. The growing list of special- status species is indicative of the effects of cumulative impacts. The SJMSCP failed to effectively prepare for the assignment of special status to so many more species, nor did it provide sufficient conservation benefits to prevent these assignments. Many species of wildlife have declined despite the SJMSCP.
2) Any potentially occurring bird species protected by the MBTA and the MBPA warrants an impact assessment related to the proposed project, regardless of any additional special status. Ground- nesting birds nest on the project site, and tree- and shrub- nesting birds rely on the site for forage. Ground- nesters on the project site could include northern harrier, burrowing owl, and California horned lark among others. City of Lathrop needs to consider project impacts and mitigation for all bird species protected by the MBTA and MBPA.
3) According to SJMSCP § 5. 2. 2. 1 A, there is the requirement for" Preconstruction surveys to ... determine if SJMSCP Covered Species are present..." The purpose of these surveys, according to the SJMSCP §5. 2. 2. 5, is to comply with existing protocols or guidelines for supporting a determination of species' absence as the standard, i.e., if the species is present, the surveys should detect it. In other words, although preconstruction survey normally refer to a clearance survey to avoid take by imminent use of heavy machinery to grade the project site, the SJMSCP requires protocol-level detection surveys. Such surveys are to be performed at project sites where habitat would be destroyed ( SJMSCP § 5. 9. 2. 5). No detection surveys have been implemented at the site of the proposed project. A project- specific DEIR needs to be prepared, and it needs to include the results of detection surveys, including those meeting the guidelines of CDFW 2oi2) for burrowing owls and of CEC and CDFW( 2oio) for Swainson' s hawks. 4) The premise that project mitigation via SJMSCP fees will conserve special- status species lacks support of evidence, which is required in the SJMSCP and its Implementation Agreement.
26 The SJMSCP requires `Pre- acquisition/ Baseline surveys' at" potential or recently acquired SJMSCP Preserues" ( SJMSCP § 5. 9. 2. 6). These surveys are characterized in the SJMSCP as detection surveys. Detection surveys are also required at proposed project sites. The SJMSCP also requires biological effectiveness monitoring at the Preserves, which are said to be needed to inform an adaptive management program. All of these surveys are intended to quantify the initial nexus between project impacts and conservation value in Preserves, and to enable managers to react to emerging deficiencies in this nexus. Monitoring biological effectiveness of the SJMSCP was supposed to be annual, whereas additional focused surveys of certain covered species were to be completed every three years. The SJMSCP also requires Annual Reports. A reasonable presumption is that the monitoring data in the Annual Reports were to be analyzed to inform adaptive management, but no such analysis has been presented during the first 23 years of the SJMSCP.

Detection Surveys at Project Sites.-- In my experience in San Joaquin County, and based on my review of additional CEQA reviews in the County such as the River Project EIR and the Tracy 58o Business Park EIR, protocol-level detection surveys are rarely completed at sites of proposed new projects. The surveys that are completed are typically no more rigorous that reconnaissance- level surveys, which are unsuitable for supporting absence determinations of most animal species. Reconnaissance surveys are not detection surveys. Failure to adequately complete detection surveys as part of this step of the SJMSCP vastly diminishes the likelihood of quantifying the initial nexus between project impacts and conservation value in Preserves, and hampers the ability of managers to react to emerging deficiencies in this nexus.

Detection Surveys atNew PreserUes.-- Baseline surveys were to be completed upon acquisition of each new Preserve, including a focused search for Swainson' s hawk nests within 2 miles of the Preserve and additional focused surveys for SJMCP- covered species. The first evidence of baseline surveys having been completed was at four Preserves, as reported in the 2008 Annual Report. The 2008 Annual Report includes a list of wildlife species seen on the Rustan and Elworthy Preserves. However, no explanation is reported of how these species were detected, who performed the survey, on what date the surveys were completed, at what time the surveys were started, and for how long the surveys lasted and under what conditions. The reporting leaves the reader unable to ascertain whether many other species occurred on these Preserves but were undetected. I could find no evidence that the Baseline surveys at new Preserves qualified as detection surveys. Failure to adequately complete this step of the SJMSCP vastly diminishes the likelihood of quantifying the initial nexus between project impacts and conservation value in Preserves, and hampers the ability of managers to react to emerging deficiencies in this nexus.

Biological effectiUeness monitoring.-- Noriko Smallwood helped me to review the SJMSCP' s Annual Reports that are available online at https:/ lwww. sjco. or/ DocumentCenter/ Index115. Noriko entered data into electronic spreadsheets, which I later analyzed. We also found, in the process of reviewing the reports and processing and analyzing their data, that the Annual Reports reveal flawed study design, deficient implementation, and poor reporting, including poor quality control. Annual Reports 27 failed to include the results of biological effectiveness monitoring over the first five years of the certified SJMSCP. The Annual Report for 2oi2 is missing. The names of Preserves are inconsistent from Annual Report to Annual Report, so anyone attempting to compare survey results by year must carefully investigate the names of Preserves in order to record them consistently in database form. No trend analysis has been performed over 23 years of the SJMSCP. Because none of the Annual Reports compares biological effects monitoring among Preserves or among years, it is up to the reader to do so.

Reporting of survey results, and specifically of which wildlife species were detected, was in paragraph form for a decade, before switching to tables of results in 2oi5. Prior to 20 5, some Annual Reports included counts of all wildlife species, whereas others included counts only of SJMSCP- covered species ( 2oi1). Annual Reports of 2008- 20 0 included counts of all species at certain Preserves and only covered species at other Preserves. Beginning in 20 3, Annual Reports included counts of all species of wildlife, but the 202o Annual Report only recorded the presence of those species detected by survey personnel. It was not unti12o 5 when all vertebrate species detections were recorded in Tables, although the referenced Table in the 2oi6 Annual Report does not actually appear in the Annual Report and was unavailable to us. It was not unti12oi5 when species counts and records of species detections qualified as comparable between years, as counts and records of presence numbered only fractions of what was reported after 20 4, even including counts and records of presence of SJMSCP- covered species.

Other than the date of each survey, little of the survey methods is reported. Survey personnel are not identified. The survey method is characterized as " windshield surveys" on available roads that abut or cross the subject property, but there is no reported standard survey effort to adjust for variation in Preserve size, nor any standard on the minimum time that should be committed to each survey. No survey start time is reported. No survey duration is reported. No standards are reported about whether birds overflying the Preserve are counted, or whether animals seen just offsite are recorded, or if they are counted, then to what height above ground or distance from the Preserve' s boundary they are counted. The Annual Reports fail to report the most fundamental methodological details that the reader needs to interpret the monitoring results.

The windshield surveys for wildlife have been completed at different types of year from year to year, hence rendering inter- annual survey results incomparable for migratory species. One such migratory species is Swainson' s hawk, which has been the most important of the wildlife species covered by the SJMSCP. More than 63% of the surveys have been completed during times of the year when Swainson' s hawks are on migration to Mexico, which means that slightly more than a third of the surveys had any potential for detection of Swainson' s hawks. Therefore, I completed my analysis of Swainson's hawk detections by rst ltering out the surveys that would not have detected Swainson' s hawks while they were on migration.

According to the 2oi8 Annual Report, " Overall, the Swainson's hawk population in San Joaquin County appears to be doing well, with a relatively high density of nesting pairs 28 and a high rate of nest success." According to the 2o2i Annual Report, " the SJMSCP appears to be highly successful with respect to providing high quality habitat for Swainson' s hawk." However, these conclusions were not found on any obvious comparison of performance metrics through time. After filtering the survey results as described above, I found evidence of an ongoing rapid decline of Swainson' s hawks among the SJMSCP Preserves ( Figure 4). Another performance metric further supports this trend, as I will report below under Focused Surveys. In any case, the aboveconclusions in the 20 8 and 2o2i Annual Reports are inaccurate and misleading. The SJMSCP has failed to conserve Swainson' s hawks, and appears to be contributing to its progress towards extirpation in the County.

Figure 4. The number Surveys during months April- September of Swainson' s hawk 0. 6
detections per suruey
Y= 0. 66466X
during the months
r2= 0. 82
April through 0. 5 0
Loss = 0. 04
September has declined
P = 0. 00001
rapidly among
Preserues since 2014. A '

0. 4
nonlinear regression fit
to the data indicates a ,
recent slowing of the Y
declines, but only after 0. 3
detections of the species ,
have reached a Uery o
low leuel. 0. 2
3 0

0. 1
O
O

0. 0
1 2 3 4 5 6 7 8 9
Years since 2014
2014 2015 2016 2017 2018 2019 2020 2021 2022 2023
Not only does the evidence in the Annual Reports support the conclusion that the SJMSCP has failed to conserve Swainson' s hawks, but it also supports the conclusions that the SJMSCP is also failing to conserve other covered species ( Figure 5). The covered species included in Figure 5 are those also identified in Table 2, as these also have other forms of special status. Additionally, the number of species detections of all vertebrate wildlife has been rapidly declining since 2oi4 ( Figure 6). This decline has been a 42% loss of vertebrate species richness among the Preserves in only the last seven years.

Considering the trends of Swainson' s hawk( Figure 4), covered species (Figure 5), and all vertebrate species ( Figure 6), declines of these magnitudes are indicative of regional ecological collapse, the ecological, economic, and cultural signi cance of which are yet to be analyzed, but which are likely to be profound.
29 Figure 5. The 2
number of covered Y = 105. 6551- 0. 0521 X
species detections per
surUey among
Preserues has T

1. 0
declined since 201,3,
according to the data N
from biological 0 8
effectiveness a
monitortng in the
Annual Reports. 0. 6
U
Q
N

0. 4
a
0 U

0. 2

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2012 2014 2016 2018 2020 2022 2024
Year
Figure 6. The
number of all species 13
detections per suruey Y = 1486. 7968 - 0. 7318X
among Preserves has
declined since 2015, 12
according to the data ,
from biological
effectiueness
monitoring in the
11 Annual Reports. 201,5 ai
was when all species
were first routinely 10
recordedfrom the
surueys.
9 O
O
W
O W
a a
0 7
2014 2015 2016 2017 2018 2019 2020 2021 2022 2023
Year
30 Focused Surueys.-- Focused surveys for Swainson' s hawks are supposed to be completed every three years, including searches for nest sites within 2 miles of each Preserve.

However, the first such survey was not completed until2oo, and another eight years went by before the second survey was completed. The fourth survey was completed in 2o2i, thus averaging one survey per 5. 25 years. The reporting of the survey results has been inconsistent, but more importantly there has yet to be a scientifically sound analysis of the data. There has been no accounting of the increase in cumulative Preserve area in the comparisons of performance metrics such as the number of active nest sites and the number of successful nests. And no comparison has been made of the performance metric, the number of fledglings per successful nest.

The number of nests/ ioo acres has in fact been dangerously unstable, at one point nearing zero, and most recently again undergoing a rapid decline ( Figure ). At the same time, the number of fledglings per successful nest has steadily declined by 34% between 200 and 2o21 ( Figure 8). At the present rate of decline, Swainson' s hawks could be extirpated from San Joaquin County before the end of the SJMSCP' s permit term.

Without explanation for the 2o- year delay, focused surveys for burrowing owls — the second most important covered species of the SJMSCP — did not begin unti12o2i. There is obviously no baseline against which to compare the findings of the 2021 survey. In 2021, the focused surveys detected only two pairs of breeding burrowing owls among all of the i6, 66 acres of Preserves acquired by the time of the 2021 survey. Failure to adequately complete focused surveys as required by the SJMSCP hampers the ability of managers to react to emerging deficiencies in this nexus.

Study Design and Implementation.— The positive- sighting nature of the reporting complicates the processing and analysis of data, although none of the Annual Reports analyze the data, anyway. A more effective approach would have been to deliberately record o for all species that could potentially occur on a Preserve, but were not detected.

A randomized selection of sampling plots within the SJMSCP study area would have minimized potential bias in trend analysis of both the biological effectiveness monitoring and focused surveys. Instead, the SJMSCP implemented a survey design that grows and changes with the acquisitions and losses of Preserves. In other words, the sample size and the sampled area are always changing, which could change a performance metric positively or negatively for reasons having nothing to do with actual population trends.

Another trend indicative of a problem of implementation is the declining average number of acres monitored per Preserve ( Figure g). This decline reflects a trend towards acquisition of increasingly smaller properties as Preserves since the SJMSCP' s inception. I do not know the reason for this trend, but it probably results from a diminishing pool of willing sellers of conservation easements in San Joaquin County.

Acquiring smaller properties has likely lessened the probability of inclusion of covered species, which could bias analysis of inter-annual trends in species' detections/ survey.

More importantly, smaller properties are less capable of conserving covered species. 31 Figure 7. Focused 0. 7
surueys for Swainson' s
a Active nests
hawk nest sites within Successful nests
two miles ofPreserves 0. 6
haUe revealed an
a
unstable trend in nests

0. 5
per loo acres of
cumulative PreserUes,
and a dangerously low o 0. 4
density in 201.
r

0. 3
Y
t6

0. 2
c
0 0. 1
3 0. 0
2006 2010 2014 2018 2022
2008 2012 2016 2020
Year
Figure 8. Focused g
surveysfor Swainson' s
o
Y = 104. 545- 0. 0512X
hawk nest sites within $
two miles of Preserues
have revealed a rapid
decline in produciivity
1' 7
between 200 and 2021. o

1. 6

1. 5
rn

1. 4
Y
3 1. 3
c
0 1. 2
3 O

1. 1

1. 0
2006 2008 2010 2012 2014 2016 2018 2020 2022
Year
32 Figure 9. The 800
average number Y = 59970. 2714- 29. 5541 X
of acres
monitored among 700
Preserues has
declined by year
since 2008. 600
c O
500
O O
a
N
400 Q O
U O
m
300
O O
200
100
2006 2008 2010 2012 2014 2016 2018 2020 2022 2024
Year
Finally, although the SJMSCP' s monitoring data are fraught with errors and potential biases, they are the data the SJMSCP is supposed to rely upon as evidence of the SJMSCP' s performance. The absence of analysis of the data collected to date has prevented administrators of the SJMSCP from seeing ( 1) problems with study design, 2) problems with the data, ( 3) mismatches of biological resources between new project sites and Preserves, and ( 4) the alarming declines of covered species including Swainson' s hawks and burrowing owls. Unable to see the impacts of the SJMSCP and the ineffectiveness of its mitigation plan, managers have been unable to react to emerging deficiencies in the nexus sought by the SJMSCP. The SJMSCP has failed in its implementation, and it has proven ineffective at conserving its covered species; it should not be used to mitigate impacts to wildlife that occur on the project site.

Requirement BIO- 2: Recommendations ofBiological Resources Analysis Report
Pre- construction Reptile Survey. Contrary to the implication by Olberding ( 2021), preconstruction surveys for California glossy snake and San Joaquin coachwhip cannot support absence determinations of either species. Preconstruction, take- avoidance surveys are unequal to detection surveys, as they do not carry anywhere close to the same probability of detection. Detection surveys by qualified biologists need to be 33 completed as part of the CEQA review, and they need to inform preconstruction surveys about where members of the species are likely to be found.

Pre- Construction Avian Survey. Olberding ( 2o2i) characterizes the avian breeding season as February through August. However, the avian breeding season recognized by the California Department of Fish and Wildlife is now i February through 15 September.

I concur that preconstruction surveys for nesting birds should be implemented.

However, having performed nest surveys for many bird species, I can attest to the difficulty of finding nest sites. Birds are highly skilled at hiding their nests, because with the exception of a few species, those birds that fail to hide their nests would fail in their nest attempts due to predation. Loggerhead shrikes and burrowing owls, as examples, make efforts to fool human observers into thinking the birds' nests are located where they are not. Locating nest sites of these species and most others requires multiple surveys over long time periods to note behavior patterns that can lead the observer to nest sites. This is why the breeding-season survey protocols require multiple surveys spaced through much of the breeding season, such as for burrowing owls ( CDFW 2oi2).

None of the available survey protocols for breeding birds recommend surveys to be completed within only a few days such as prior to construction, and this is because the notion that such a briefly conducted survey would detect more than a small fraction of nest sites is fantasy.

Preconstruction surveys should be performed for nesting birds, but not without first having completed detection surveys to inform where biologists can expect to find nests during their subsequent preconstruction surveys. Preconstruction surveys are only intended as last- minute, one-time salvage and rescue operations targeting readily detectable nests or individuals before they are crushed under heavy construction machinery. Because most special- status species are rare and cryptic, and because most bird species are expert at hiding their nests lest they get predated, most of their nests will not be detected by preconstruction surveys without prior support of detection surveys. For one thing, bird species vary in the timing of their nesting. For example, at a project site that I searched for nest attempts this past February through August, some bird species had already produced fledglings and some species began re- nesting before other bird species began nesting. Locating all of the nests on site would require more effort than is committed during preconstruction surveys. Furthermore, I found cavitynesters to be easiest to locate, and ground- nesters the most difficult.

Regardless of whether construction timing avoids the nesting season or preconstruction surveys are completed, this measure would not reduce impacts to less- than- significant levels because the project would destroy the productive capacity of the birds that breed on the project site. Neither would the preconstruction surveys do anything to thwart or diminish the impacts of further habitat fragmentation.

Should the project go forward, I recommend that it be required of the preconstruction survey biologists to prepare a report of the methods and outcomes of preconstruction surveys. The report should be made available to the public. 34 Burrowing Owl Surveys. Contrary to the implication by Olberding (202), preconstruction surveys for burrowing owls cannot support an absence determination.

Preconstruction surveys are supposed to be preceded by protocol- level detection surveys CDF4V 2oi2). Note, also, that Olberding ( 2021) cites obsolete survey guidelines for burrowing owls. Furthermore, Olberding' s ( 2o2i) recommendation for burrow destruction or passive relocation, no matter the behaviors of the associated burrowing owls, can be regarded as take, according to CDFW( 2oi2).

Thank you for your attention,
Shawn Smallwood, Ph. D.

LITERATURE CITED
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S. Y. Chun, and S. G. Torres. 2oi9. Population and Distribution of Swainson' s Hawks ( Buteo Swainsoni) in California' s Great Valley: A Framework for Long- Term Monitoring. Journal of Raptor Research 53 253- 265•
Bishop, C. A. and J. M. Brogan. 2oi3. Estimates ofAvian Mortality Attributed to Vehicle Collisions in Canada. Avian Conservation and Ecology 8: 2. htt•// dx. doi. or/ 1o. 7/ ACE-oo604- 0$ 0202.

Brown, K., K. S. Smallwood, J. Szewczak, and B. Karas. 2oi6. Final 2oi2- 2oi5 Report Avian and Bat Monitoring Project Vasco Winds, LLC. Prepared for NextEra Energy Resources, Livermore, California.

CDFW( California Department of Fish and Wildlife). 2oi2. Staff Report on Burrowing Owl Mitigation. Sacramento, California.

CDFW( California Department of Fish and Wildlife). 2018. Protocols for surveying and evaluating impacts to special status native plant populations and sensitive natural communities. htt s: l/nrm.dfg.ca.go
CEC and CDFW ( California Energy Commission and California Department of Fish and Wildlife). 2oio. Swainson' s Hawk Survey Protocols, Impact Avoidance, and Minimization Measures for Renewable Energy Projects in the Antelope Valley of Los Angeles and Kern Counties, California. California Department of Fish and Wildlife, Sacramento, California.
35 Calvert, A. M., C. A. Bishop, R. D. Elliot, E. A. Krebs, T. M. Kydd, C. S. Machtans, and G.

J. Robertson. 2oi3. A synthesis of human-related avian mortality in Canada. Avian Conservation and Ecology 8( 2): ii. htt•// dx doi. org/ lo.S/ ACE- oo 8i-o$ o211 Forman, T. T., D. Sperling, J. A. Bisonette, A. P. Clevenger, C. D. Cutshall, V. H. Dale, L.

Fahrig, R. France, C. R. Goldman, K. Heanue, J. A. Jones, F. J. Swanson, T.

Turrentine, and T. C. Winter. 2003. Road Ecology. Island Press, Covello, California.

Hall, L. S., P. R. Krausman, and M. L. Morrison. i997. " The habitat concept and a plea for standard terminology." Wildlife Society Bulletin 25: 73- 82.

Loss, S. R., T. Will, and P. P. Marra. 2014. Estimation of bird-vehicle collision mortality on U.S. roads. Journal of Wildlife Management 8: 63-.

Mendelsohn, M., W. Dexter, E. Olson, and S. Weber. 2009. Vasco Road wildlife movement study report. Report to Contra Costa County Public Works Department, Martinez, California.

Olberding Environmental, Inc. 2o2i. Biological Resources Analysis Report for the Dos Reis Ranch Property, San Joaquin County, California. Report to Hodgdon Group Reality, Inc. and HMC Construction, Inc., Colton, California.

Runge, C. A., T. G. Martin, H. P. Possingham, S. G. Willis, and R. A. Fuller. 2oi4.

Conserving mobile species. Frontiers in Ecology and Environment i2(): 395- 402 doi:io.i89o/ i3o23.

SJCOG, Inc. 2oi. San Joaquin County Multi- species Habitat Conservation and Open Space Plan: 2oi Annual Report. http:// ca- sico g2. civic lus.comf 17 jPlanDocuments SJCOG, Inc. 2oi8. San Joaquin County Multi- species Habitat Conservation and Open Space Plan: 2018 Annual Report. htt•// ca- sico 2
ci ic lus com i 3/ PlanDocuments
SJCOG, Inc. 2oi9. San Joaquin County Multi- species Habitat Conservation and Open Space Plan: 2oi9 Annual Report. http:// ca- sjco 2. civic lus. com/ 17/ PlanDocuments SJCOG, Inc. 2020. San Joaquin County Multi- species Habitat Conservation and Open Space Plan: 202o Annual Report. htt:// ca- s cog2. ci ic lus. corn/ i jPlanDocuments
SJCOG, Inc. 202. San Joaquin County Multi- species Habitat Conservation and Open Space Plan: 2021 Annual Report. htt// ca- slco$ 2. citi cvlus. com/ 17/ PlanDocuments 36 SJCOG, Inc. 2022. San Joaquin County Multi- species Habitat Conservation and Open Space Plan: 2022 Annual Report. http•// ca- sjco 2.ci icplus. comji/ PlanDocuments Santos, S. M., F. Carvalho, and A. Mira. 2011. How long do the dead survive on the road? Carcass persistence probability and implications for road- kill monitoring surveys.

PLoS ONE 6( 9): e25383• doi: lo.i37/ journal. pone. 0025383 Shuford, W. D., and T. Gardali, [ eds.]. 2008. California bird species of special concern: a ranked assessment of species, subspecies, and distinct populations of birds of immediate conservation concern in California. Studies of Western Birds . Western Field Ornithologists, Camarillo, California.

Smallwood, K. S. 1995• Scaling Swainson' s hawk population density for assessing habitat-use across an agricultural landscape. J. Raptor Research 29: i 2- i 8.

Smallwood, K. S. 2022. Utility- scale solar impacts to volant wildlife. Journal of Wildlife Management: e222i6. htt s• jdoi.or/ 1o. l0o2/' vm . 22216 Smallwood, K. S. and M. L. Morrison. 2oi8. Nest- site selection in a high- density colony of burrowing owls. Journal of Raptor Research 52 454- 470• Smallwood, K. S., and N. L. Smallwood. 2o2i. Breeding Density and Collision Mortality of Loggerhead Shrike ( Lanius ludouicianus) in the Altamont Pass Wind Resource Area. Diversity 13 540• htt s:// doi.or Jio. 2/d1 11o540.

Smallwood, K. S., and N. L. Smallwood. 2023. Measured effects of anthropogenic development on vertebrate wildlife diversity. Diversity i5: In press.

Smallwood, K.S., S. Geng, and M. Zhang. 2ooi. Comparing pocket gopher( Thomomys bottae) density in alfalfa stands to assess management and conservation goals in northern California. Agriculture, Ecosystems & Environment 8: 93- io9.

Smallwood, K. S., B. J. Nakamoto, and S. Geng. i996. Association analysis of raptors on an agricultural landscape. Pages 1- 90 in D. M. Bird, D. E. Varland, and J.J.

Negro, eds., Raptors in human landscapes. Academic Press, London.

Swolgaard, C. A., K. A. Reeves, and D. A. Bell. 2008. Foraging by Swainson' s Hawks in a vineyard-dominated landscape. Journal of Raptor Research 42: i88—i96.

Taylor, P. D., S. A. Mackenzie, B. G. Thurber, A. M. Calvert, A. M. Mills, L. P. McGuire, and C. G. Guglielmo. 20. Landscape movements of migratory birds and bats reveal an expanded scale of stopover. PlosOne 6( ii): e2 o54• doi: io.i3'7/ journal. pone. 002 054•
Warnock, N. 2oio. Stopping vs. staging: the difference between a hop and a jump.

Journal of Avian Biology 4i:62i- 626.
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38 Kenneth Shawn Smallwood
Curriculum Vitae
3108 Finch Street Born May 3, 1963 in
Davis, CA 95616 Sacramento, California.

Phone ( 530) 756- 4598 Married, father of two.

Cell ( 530) 601- 6857
puma,idcn. or
Ecologist
Expertise
Finding solutions to controversial problems related to wildlife interactions with human industry, infrastructure, and activities;
Wildlife monitoring and field study using GPS, thermal imaging, behavior surveys; Using systems analysis and experimental design principles to identify meaningful ecological patterns that inform management decisions.

Education
Ph. D. Ecology, University of California, Davis. September 1990.

M. S. Ecology, University of California, Davis. June 1987.

B. S. Anthropology, University of California, Davis. June 1985.

Corcoran High School, Corcoran, California. June 1981.

Experience
762 professional reports, including:
90 peer reviewed publications
24 in non- reviewed proceedings
646 reports, declarations, posters and book reviews
8 in mass media outlets
92 public presentations of research results
Editing for scientific journals: Guest Editor, Wildlife Society Bulletin, 2012- 2013, of invited papers representing international views on the impacts of wind energy on wildlife and how to mitigate the impacts. Associate Editor, Journal of Wildlife Management, March 2004 to 30 June 2007.

Editorial Board Member, Environmental Management, 10/ 1999 to 8/ 2004. Associate Editor, Biological Conservation, 9/ 1994 to 9/ 1995.

Member, Alameda County Scientific Review Committee ( SRC), August 2006 to April 2011. The five-member committee investigated causes of bird and bat collisions in the Altamont Pass Wind Resource Area, and recommended mitigation and monitoring measures. The SRC reviewed the science underlying the Alameda County Avian Protection Program, and advised 1 Smallwood CV
the County on how to reduce wildlife fatalities.

Consulting Ecologist, 2004- 2007, California Energy Commission ( CEC). Provided consulting services as needed to the CEC on renewable energy impacts, monitoring and research, and produced several reports. Also collaborated with Lawrence- Livermore National Lab on research to understand and reduce wind turbine impacts on wildlife.

Consulting Ecologist, 1999- 2013, U. S. Navy. Performed endangered species surveys, hazardous waste site monitoring, and habitat restoration for the endangered San Joaquin kangaroo rat, California tiger salamander, California red- legged frog, California clapper rail, western burrowing owl, salt marsh harvest mouse, and other species at Naval Air Station Lemoore; Naval Weapons Station, Seal Beach, Detachment Concord; Naval Security Group Activity, Skaggs Island; National Radio Transmitter Facility, Dixon; and, Naval Outlying Landing Field Imperial Beach.

Part- time Lecturer, 1998- 2005, California State University, Sacramento. Instructed Mammalogy, Behavioral Ecology, and Ornithology Lab, Contemporary Environmental Issues, Natural Resources Conservation.

Senior Ecologist, 1999- 2005, BioResource Consultants. Designed and implemented research and monitoring studies related to avian fatalities at wind turbines, avian electrocutions on electric distribution poles across California, and avian fatalities at transmission lines.

Chairman, Conservation Affairs Committee, The Wildlife Society-- Western Section, 1999- 2001.

Prepared position statements and led efforts directed toward conservation issues, including travel to Washington, D. C. to lobby Congress for more wildlife conservation funding.

Systems Ecologist, 1995- 2000, Institute for Sustainable Development. Headed ISD' s program on integrated resources management. Developed indicators of ecological integrity for large areas, using remotely sensed data, local community involvement and GIS.

Associate, 1997- 1998, Department of Agronomy and Range Science, University of California, Davis. Worked with Shu Geng and Mingua Zhang on several studies related to wildlife interactions with agriculture and patterns of fertilizer and pesticide residues in groundwater across a large landscape.

Lead Scientist, 1996- 1999, National Endangered Species Network. Informed academic scientists and environmental activists about emerging issues regarding the Endangered Species Act and other environmental laws. Testified at public hearings on endangered species issues.

Ecologist, 1997- 1998, Western Foundation of Vertebrate Zoology. Conducted field research to determine the impact of past mercury mining on the status of California red- legged frogs in Santa Clara County, California.

Senior Systems Ecologist, 1994- 1995, EIP Associates, Sacramento, California. Provided consulting services in environmental planning, and quantitative assessment of land units for their conservation and restoration opportunities basedon ecological resource requirements of 29 special- status species. Developed ecological indicators for prioritizing areas within Yolo County Smallwood CV 3
to receive mitigation funds for habitat easements and restoration.

Post- Graduate Researcher, 1990- 1994, Department of Agronomy and Range Science, U.C. Davis.

Under Dr. Shu Geng' s mentorship, studied landscape and management effects on temporal and spatial patterns of abundance among pocket gophers and species of Falconiformes and Carnivora in the Sacramento Valley. Managed and analyzed a data base of energy use in California agriculture. Assisted with landscape ( GIS) study of groundwater contamination across Tulare County, California.

Work experience in graduate school: Co- taught Conservation Biology with Dr. Christine Schonewald, 1991 & 1993, UC Davis Graduate Group in Ecology; Reader for Dr. Richard Coss' s course on Psychobiology in 1990, UC Davis Department of Psychology; Research Assistant to Dr. Walter E. Howard, 1988- 1990, UC Davis Department of Wildlife and Fisheries Biology, testing durable baits for pocket gopher management in forest clearcuts; Research Assistant to Dr. Terrell P. Salmon, 1987- 1988, UC Wildlife Extension, Department of Wildlife and Fisheries Biology, developing empirical models of mammal and bird invasions in North America, and a rating system for priority research and control of exotic species based on economic, environmental and human health hazards in California. Student Assistant to Dr. E.

Lee Fitzhugh, 1985- 1987, UC Cooperative Extension, Department of Wildlife and Fisheries Biology, developing and implementing statewide mountain lion track count for long- term monitoring.

Fulbright Research Fellow, Indonesia, 1988. Tested use of new sampling methods for numerical monitoring of Sumatran tiger and six other species of endemic felids, and evaluated methods used by otherresearchers.

Projects
Repowerin wind energ projects through careful siting of new wind turbines using map- based collision hazard models to minimize impacts to volant wildlife. Funded by wind companies principally NextEra Renewable Energy, Inc.), California Energy Commission and East Bay Regional Park District, I have collaborated with a GIS analyst and managed a crew of five field biologists performing golden eagle behavior surveys and nocturnal surveys on bats and owls. The goal is to quantify flight patterns for development of predictive models to more carefully site new wind turbines in repowering projects. Focused behavior surveys began May 2012 and continue.

Collision hazard models have been prepared for seven wind projects, three of which were built.

Planning for additional repowering projects is underway.

Test avian safety of new mixer-ejector wind turbine ( MEWT. Designed and implemented a beforeafter, control- impact experimental design to test the avian safety of a new, shrouded wind turbine developed by Ogin Inc. ( formerly known as FloDesign Wind Turbine Corporation). Supported by a 718, 000 grant from the California Energy Commission' s Public Interest Energy Research program and a 20% match share contribution from Ogin, I managed a crew of seven field biologists who performed periodic fatality searches and behavior surveys, carcass detection trials, nocturnal behavior surveys using a thermal camera, and spatial analyses with the collaboration of a GIS analyst. Field work began 1 April 2012 and ended 30 March 2015 without Ogin installing its MEWTs, but we still achieved multiple important scientific advances.

Smallwood CV 4
Reduce avian mortalitydue to wind turbines at Altamont Pass. Studied wildlife impacts caused by 5, 400 wind turbines at the world' s most notorious wind resource area. Studied how impacts are perceived by monitoring and how they are affected by terrain, wind patterns, food resources, range management practices, wind turbine operations, seasonal patterns, population cycles, infrastructure management such as electric distribution, animal behavior and social interactions.

Reduce avian mortality on electric distribution poles. Directed research toward reducing bird electrocutions on electric distribution poles, 2000- 2007. Oversaw 5 founds of fatality searches at 10, 000 poles from Orange County to Glenn County, California, and produced two large reports.

Cook et al. v. Rockwell International et al., No. 90- K- 181 ( D. Colorado). Provided expert testimony on the role of burrowing animals in affecting the fate of buried and surface- deposited radioactive and hazardous chemical wastes at the Rocky Flats Plant, Colorado. Provided expert reports based on four site visits and an extensive document review of burrowing animals. Conducted transect surveys for evidence of burrowing animals and other wildlife on and around waste facilities.

Discovered substantial intrusion of waste structures by burrowing animals. I testified in federal court in November 2005, and my clients were subsequently awarded a $ 553, 000, 000 judgment by a jury. After appeals the award was increased to two billion dollars.

Hanford Nuclear Reservation Liti a tion. Provided expert testimony on the role of burrowing animals in affecting the fate of buried radioactive wastes at the Hanford Nuclear Reservation, Washington. Provided three expert reports based on three site visits and extensive document review.

Predicted and verified a certain population density of pocket gophers on buried waste structures, as well as incidence of radionuclide contamination in body tissue. Conducted transect surveys for evidence of burrowing animals and other wildlife on and around waste facilities. Discovered substantial intrusion of waste structures by burrowing animals.

Expert testimony and declarations on proposed residential and commercial developments, gas- fired power plants, wind, solar and geothermal projects, water transfers and water transfer delivery systems, endangered species recovery plans, Habitat Conservation Plans and Natural Communities Conservation Programs. Testified before multiple government agencies, Tribunals, Boards of Supervisors and City Councils, and participated with press conferences and depositions. Prepared expert witness reports and court declarations, which are summarized under Reports ( below).

Protocol- level surve
for special- status species. Used California Department of Fish and Wildlife and US Fish and Wildlife Service protocols to search for California red- legged frog, California tiger salamander, arroyo southwestern toad, blunt- nosed leopard lizard, western pond turtle, giant kangaroo rat, San Joaquin kangaroo rat, San Joaquin kit fox, western burrowing owl, Swainson' s hawk, Valley elderberry longhorn beetle and other special- status species.

Conservation of San Joaquin kan aroo rat. Performed research to identify factors responsible for the decline ofthis endangered species at Lemoore Naval Air Station, 2000- 2013, and implemented habitat enhancements designed to reverse the trend and expand the population.

Impact of West Nile Virus on yellow- billed magpies. Funded by Sacramento- Yolo Mosquito and Vector Control District, 2005- 2008, compared survey results pre- and post- West Nile Virus epidemic for multiple bird species in the Sacramento Valley, particularly on yellow- billed magpie and American crow due to susceptibility to WNV.

Smallwood CV 5
Workshops on HCPs. Assisted Dr. Michael Morrison with organizing and conducting a 2- day workshop on Habitat Conservation Plans, sponsored by Southern California Edison, and another 1- day workshop sponsored by PG& E. These Workshops were attended by academics, attorneys, and consultants with HCP experience. We guest- edited a Proceedings published in Environmental Management.

Ma pin of biological resources along Hi hways 101, 46 and 41. Used GPS and GIS to delineate vegetation complexes and locations of special- status species along 26 miles of highway in San Luis Obispo County, 14 miles of highway and roadway in Monterey County, and in a large area north of Fresno, including within reclaimed gravel mining pits.

GPS mappi and monitorin at restoration sites and at Caltrans mitigation sites. Monitored the success of elderberry shrubs at one location, the success of willows at another location, and the response of wildlife to the succession of vegetation at both sites. Also used GPS to monitor the response of fossorial animals to yellow star-thistle eradication and natural grassland restoration efforts at Bear Valley in Colusa County and at the decommissioned Mather Air Force Base in Sacramento County.

Mercury effects on Red- le e. Assisted Dr. Michael Morrison and US Fish and Wildlife Service in assessing the possible impacts of historical mercury mining on the federally listed California red- legged frog in Santa Clara County. Also measured habitat variables in streams.

Opposition to pro osed No Surprises rule. Wrote a white paper and summary letter explaining scientific grounds for opposing the incidental take permit ( ITP) rules providing ITP applicants and holders with general assurances they will be free of compliance with the Endangered Species Act once they adhere to the terms of a" properly functioning HCP." Submitted 188 signatures of scientists and environmental professionals concerned about No Surprises rule US Fish and Wildlife Service, National Marine Fisheries Service, all US Senators.

Natomas Basin Habitat Conservation Plan alternative. Designed narrow channel marsh to increase the likelihood of survival and recovery in the wild of giant garter snake, Swainson' s hawk and Valley Elderberry Longhorn Beetle. The design included replication and interspersion of treatments for experimental testing of critical habitat elements. I provided a report to Northern Territories, Inc.

Assessments of a ricultural production system and environmental technolo y transfer to China.

Twice visited China and interviewed scientists, industrialists, agriculturalists, and the Directors of the Chinese Environmental Protection Agency and the Department of Agriculture to assess the need and possible pathways for environmental clean- up technologies and trade opportunities between the US and China.

Yolo Countv Habitat Conservation Plan. Conducted landscape ecology study of Yolo County to spatially prioritize allocation of mitigation efforts to improve ecosystem functionality within the County from the perspective of 29 special- status species of wildlife and plants. Used a hierarchically structured indicators approach to apply principles of landscape and ecosystem ecology, conservation biology, and local values in rating land units. Derived GIS maps to help guide the conservation area design, and then developed implementation strategies.

Smallwood CV 6
Mountain lion track count. Developed and conducted a carnivore monitoring program throughout California since 1985. Species counted include mountain lion, bobcat, black bear, coyote, red and gray fox, raccoon, striped skunk, badger, and black-tailed deer. Vegetation and land use are also monitored. Track survey transect was established on dusty, dirt roads within randomly selected quadrats.

Sumatran tiger and other felids. Upon award of Fulbright Research Fellowship, I designed and initiated track counts for seven species of wild cats in Sumatra, including Sumatran tiger, fishing cat, and golden cat. Spent four months on Sumatra and Java in 1988, and learned Bahasa Indonesia, the official Indonesian language.

Wildlife in agriculture. Beginning as post- graduate research, I studied pocket gophers and other wildlife in 40 alfalfa fields throughout the Sacramento Valley, and I surveyed for wildlife along a 200 mile road transect since 1989 with a hiatus of 1996- 2004. The data are analyzed using GIS and methods from landscape ecology, and the results published and presented orally to farming groups in California and elsewhere. I also conducted the first study of wildlife in cover crops used on vineyards and orchards.

Agricultural ener y use and Tulare Countv roundwater studv. Developed and analyzed a data base of energy use in California agriculture, and collaborated on a landscape ( GIS) study of groundwater contamination across Tulare County, California.

Pocket opher damage in forest clear- cuts. Developed gopher sampling methods and tested various poison baits and baiting regimes in the largest- ever field study of pocket gopher management in forest plantations, involving 68 research plots in 55 clear- cuts among 6 National Forests in northern California.

Risk assessment of exotic species in North America. Developed empirical models of mammal and bird species invasions in North America, as well as a rating system for assigning priority research and control to exotic species in California, based on economic, environmental, and human health hazards.

Peer Reviewed Publications
Smallwood, K. S. 2022. Utility- scale solar impacts to volant wildlife. Journal of Wildlife Management: e22216. https:// doi. org/ 10. 1002/jwm Z2216 Smallwood, K. S., and N. L. Smallwood. 2021. Breeding Density and Collision Mortality of Loggerhead Shrike ( Lanius ludovicianus) in the Altamont Pass Wind Resource Area. Diversity 13, 540. https:// doi. or/ 10. 3390/ d 131 10540.

Smallwood, K. S. 2020. USA wind energy- caused bat fatalities increase with shorter fatality search intervals. Diversity 12( 98); IZttps: l/doi. org/ 10. 3390/ d 12030098 Smallwood, K. S., D. A. Bell, and S. Standish. 2020. Dogs detect larger wind energy impacts on bats and birds. Journal of Wildlife Management 84: 852- 864. DOL• 10. 1oo2/ jwmg.21863.

Smallwood, K. S., and D. A. Bell. 2020. Relating bat passage rates to wind turbine fatalities.

Smallwood CV
Diversity 12( 84); doi: 10. 3390/ d12020084.

Smallwood, K. S., and D. A. Bell. 2020. Effects of wind turbine curtailment on bird and bat fatalities. Journal of Wildlife Management 84: 684- 696. DOL• 10. 1002/ jwmg. 21844 Kitano, M., M. Ino, K. S. Smallwood, and S. Shiraki. 2020. Seasonal difference in carcass persistence rates at wind farms with snow, Hokkaido, Japan. Ornithological Science 19: 63 —

71. Smallwood, K. S. and M. L. Morrison. 2018. Nest- site selection in a high- density colony of burrowing owls. Journal of Raptor Research 52: 454- 470.

Smallwood, K. S., D. A. Bell, E. L. Walther, E. Leyvas, S. Standish, J. Mount, B. Karas. 2018.

Estimating wind turbine fatalities using integrated detection trials. Journal of Wildlife Management 82: 1169- 1184.

Smallwood, K. S. 2017. Long search intervals under- estimate bird and bat fatalities caused by wind turbines. Wildlife Society Bulletin 41: 224- 230.

Smallwood, K. S. 2017. The challenges of addressing wildlife impacts when repowering wind energy projects. Pages 175- 187 in Koppel, J., Editor, Wind Energy and Wildlife Impacts:

Proceedings from the CWW2015 Conference. Springer. Cham, Switzerland.

May, R., Gill, A. B., Koppel, J. Langston, R. H. W., Reichenbach, M., Scheidat, M., Smallwood, S., Voigt, C. C., Huppop, O., and Portman, M. 2017. Future research directions to reconcile wind turbine—wildlife interactions. Pages 255- 276 in Koppel, J., Editor, Wind Energy and Wildlife Impacts: Proceedings from the CWW2015 Conference. Springer. Cham, Switzerland.

Smallwood, K. S. 2017. Monitoring birds. M. Perrow, Ed., Wildlife and Wind Farms - Conflicts and Solutions, Volume 2. Pelagic Publishing, Exeter, United Kingdom. www. bit. ly/ 2v3cR9Q Smallwood, K. S., L. Neher, and D. A. Bell. 2017. Turbine siting for raptors: an example from Repowering of the Altamont Pass Wind Resource Area. M. Perrow, Ed., Wildlife and Wind Farms - Conflicts and Solutions, Volume 2. Pelagic Publishing, Exeter, United Kingdom. wwtiv. bit.tX/2v3cR9Q
Johnson, D. H., S. R. Loss, K. S. Smallwood, W. P. Erickson. 2016. Avian fatalities at wind energy facilities in North America: A comparison of recent approaches. Human—Wildlife Interactions 10( 1): 7- 18.

Sadar, M. J., D. S.- M. Guzman, A. Mete, J. Foley, N. Stephenson, K. H. Rogers, C. Grosset, K. S.

Smallwood, J. Shipman, A. Wells, S. D. White, D. A. Bell, and M. G. Hawkins. 2015. Mange Caused by a novel Micnemidocoptes mite in a Golden Eagle ( Aquila chrysaetos). Journal of Avian Medicine and Surgery 29( 3): 231- 237.

Smallwood, K. S. 2015. Habitat fragmentation and corridors. Pages 84- 101 in M. L. Morrison and H. A. Mathewson, Eds., Wildlife habitat conservation: concepts, challenges, and solutions.

John Hopkins University Press, Baltimore, Maryland, USA.

Technical Consultation, Data Analysis and
AP L igation Suppon for the Envlronment
2656 29th Street, Suite 201
Santa Monica, CA 90405
Matt Hagemann, P. G, C. Hg.
949) 887- 9013
mhagemann@swape. com
Paul E. Rosenfeld, PhD
310) 795- 2335
prosenfeld @swape. com
October 4, 2023
Mike Lozeau
Lozeau Drury LLP
1939 Harrison Street, Suite 150
Oakland, CA 94618
Subject: Comments on the Municipal Code, Central Lathrop Specific Plan( CLSP) Phase 2 Update, And Ashley Warehouse Project
Dear Mr. Lozeau,
We have reviewed the August 2023 Environmental Checklist (" Checklist") forthe Municipal Code, Central Lathrop Specific Plan ( CLSP) Phase 2 Update, And Ashley Warehouse Project (" Project") located in the City of Lathrop (" City'). The Project proposes to construct 1, 486, 607- square-feet(" SF") of mixeduse space, including 1, 352, 347- SF of warehouse space, 110, 000- SF of retail space, 24, 000- SF of office space, and 2, 046 parking spaces on the 89. 82- acre site.

Our review concludes that the Checklist fails to adequately evaluate the Project' s health risk impacts. As a result, emissions and health risk impacts associated with construction and operation of the proposed Project may be underestimated and inadequately addressed. A subsequent Environmental Impact Report (" EIR") should be prepared to adequately assess and mitigate the potential health risk impacts that the project may have on the environment.

Air Quality
Diesel Pat ticulate Matter Bmissions Inadequately Eva( uated The Checklist estimates that the maximum incremental cancer risk posed to nearby, existing sensitive receptors as a result of heavy- duty diesel trucks during Project operation would be 7. 0 in one million, which would not exceed the San Joaquin Valley Air Pollution Control District (" SJVAPCD") significance threshold of 20 in one million ( see excerpt below) ( p. 44, Table AIR- 4).

T rble A7R-4: S mmaay of faxinref ai Neatth Risks
Ras rM rc M iu,t rs, t tt 7' IsT arQt. 1
T 11RE hitiLv EA?
Residential Cancer fiisk

7. 20 per million Mc
70- year exposure}
Warkplace Cancer Etisk

1. 3 20 per mil(inr Va
40- yearexpnsure)
Chranic( non- cancer) 0. 1 Hazard lndex? 1 No
Acute non- cancer) Q Hazard lndex>_ i No
SaurrcEs. AERMDD 1I. Z.t1( Ia s E rn+cr v, t v' So' nva, Zt723)„ AND HAR13- 2 AId2I313PERSJ NAdVD' tISK Tt3l1L However, the Checklist fails to conduct a construction health risk analysis (" HRA") or discuss the toxic air contaminant (" TAC") emissions associated with Project construction whatsoever. Consequently, the Checklist' s evaluation of the Project' s potential health risk impacts, as well as the subsequent less- thansignificant impact conclusion, is incorrect for four reasons.

First, the Checklist fails to mention or provide the exposure assumptions for the HRA, such as the age sensitivity factors (" ASF") or fraction of time at home (" FAH") values whatsoever. Until the Checklist substantiates the use of correct exposure assumptions, the HRA may underestimate the cancer risk posed to nearby, existing sensitive receptors because of Project construction. Furthermore, according to the RiskAssessment Guidelines provided by the Office of Environmental Health Hazard Assessment OEHHA"), the organization responsible for providing guidance on conducting HRAs in California, the Checklist' s models should have used the following equation:l A. Equa#ion 8. 2. 4 A: RISKinh- res = DOSEair x CPF x ASF x EDIAT x FAH

7. RISK inh- res = Residential inhalation cancer risk

8. QOSEair = Daily inhalation dose { mglkg-day)

9. CPF Inhalatian cancer potency factor (mg/ kg-day')

10. ASF Age sensitivity factor for a specified age group { unitless)

11. ED Exposure duration (in years) for a specified age group

12. AT Averaging time for lifetime cancer risk ( years)

13. FAH Fraction of time spent at home { unitless)
The Checklist fails to include a dose and risk equation to calculate the Project' s construction cancer risks.

As such, we cannot verify that the Checklist' s HRA is accurate, and the ProjecYs cancer risks may be underestimated.
1" Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments." OEHHA, February 2015, available at: https:// oehha. ca. ovlmedia/ downloads/ crnr/ 2015 uidancemanual. pdf, p. 8- 7 Equation 8. 2. 4. 2 Second, by failing to prepare a quantified construction HRA, the Checklist is inconsistent with CEQA' s requirement to correlate the increase in emissions that the Project would generate to the adverse impacts on human health caused by those emissions. Z This is incorrect, as construction of the proposed Project will produce DPM emissions through the exhaust stacks of construction equipment over the total construction duration. However, the Checklist fails to evaluate the potential Project- generated TACs or indicate the concentrations at which such pollutants would trigger adverse health effects.

Without making a reasonable effort to connect the Project' s construction- related TAC emissions to the potential health risks posed to nearby receptors, the Checklist is inconsistent with CEQA' s requirement to correlate the increase in emissions generated by the Project with the potential adverse impacts on human health.

Third, the State of California Department of Justice recommends that warehouse projects prepare a quantitative HRA pursuant to OEHHA, the organization responsible for providing guidance on conducting HRAs in California, as well as local air district guidelines. 3 OEHHA released its most recent Risk Assessment Guidelines: Guidance Manual for Preparation of Health Risk Assessments in February 2015.

This guidance document describes the types of projects that warrant the preparation of an HRA.

Specifically, OEHHA recommends that all short- term projects lasting at least 2 months assess cancer risks. 4 Furthermore, according to OEHHA:

Exposure from projects lasting more than 6 months should be evaluated for the duration of the project. In all cases, for assessing risk to residential receptors, the exposure should be assumed to start in the third trimester to allow for the use of the ASFs ( OEHHA, 2009)." 5 As the Project' s anticipated construction duration likely exceeds the 2- month and 6- month requirements set forth by OEHHA, construction of the Project meets the threshold warranting a quantified HRA under OEHHA guidance and should be evaluated for the entire construction period.

These recommendations reflect the most recent state health risk policies, and consequently, a subsequent EIR should be prepared to include an analysis of health risk impacts posed to nearby sensitive receptors from Project- generated DPM emissions.

Fourth, while the Checklist includes an HRA evaluating the health risk impacts to nearby, existing receptors as a result of Project operation, the HRA fails to evaluate the combined lifetime cancer risk to nearby, existing receptors as a result of Project construction and operation together. According to OEHHA guidance " the excess cancer risk is calculated separately for each age grouping and then z" Sierra Club v. County of Fresno." Supreme Court of California, December 2018, available at:
https:// ceqaportal. or/ decisions/ 1907/ Sierra% 20CI u b% 20v.% 20Countv% 20of% 20Fresno. pdf. 3" Warehouse Projects: Best Practices and Mitigation Measures to Comply with the California Environmental Quality Act." State of California Department of Justice, available at:
https: l/ oa. ca. gov/ sites/ all/ files/ agweb/ pdfs/ environment/ warehouse- best- practices. pdf, p. 6. 4" Risk Assessment Guidelines: Guidance Manual for Preparation of Health Risk Assessments." OEHHA, February 2015, available at: https:// oehha. ca. gov/ media/ downloads/ crnr/ 2015 uidancemanual. pdf, p. 8- 18. 5" Risk Assessment Guidelines: Guidance Manual for Preparation of Health Risk Assessments." OEHHA, February 2015, available at: https:// oehha. ca. ov/ media/ downloads/ crnr/ 2015 uidancemanual. pdf, p. 8- 18. 3 summed to yield cancer risk at the receptor location." 6 However, the Project' s HRA fails to sum each age bin to evaluate the total cancer risk over the course of the Project' s total construction and operation.

This is incorrect, and an updated analysis should quantify the entirety of the Project' s construction and operational health risks together and sum them to compare to the SJVAPCD threshold of 20 in one million, as referenced by the Checklist ( p. 44, Table AIR- 4).

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,
1,2, lC,,....__-
Matt Hagemann, P. G., C. Hg.
µ. 4' L "
Paul E. Rosenfeld, Ph. D.

Attachment A: Paul Rosenfeld CV
Attachment B: Matt Hagemann CV
6" Guidance Manual for preparation of Health Risk Assessments." OEHHA, February 2015, available at:
https:// oehha. ca. ov/ media/ downloads/ crnr/ 2015 uidancemanual. pdf p. 8- 4 4 Attachment A
c Technicai Consultation, Data Analysis and P G Litigation Support for the Environment 2656 29`h Street, Suite 201
Santa Monica, CA 90405
Matt Hagemann, P. G, C. Hg.
949) 887- 9013
mha emann@swape. com
Matthew F. Hagemann, P.G., C.Hg., QSD, QSP
Geologic and Hydrogeologic Characterization
Investigation and Remediation Strategies
Litigation Support and Testifying Eacpert
Industrial Stormwater Compliance
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 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 characterizaHon 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 ofimpacts 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 I- 20 Science, Inc.( 2000-- 2003); 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 mare 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 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.

With Komex H20 Science Inc., MatYs 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.
2 Expert witness testimony in a case of oil production- related contamination in Mississippi.

Lead author for a multi- volume remedial investigation report for an operating school in Los Angeles that met strict regulatory requirements and rigorous deadlines.

Development of strategic approaches for cleanup of contaminated sites in consultation with clients and regulators.

Executive Director:

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

Hydrogeology:

As a Senior Hydrogeologist with the U.S. Environmental Protection Agency, Matt led investigations to characterize and cleanup closing military bases, including Mare Island Naval Shipyard, Hunters Point Naval Shipyard, Treasure Island Naval Station, Alameda Naval Station, Moffett Field, Mather Army Airfield, and Sacramento Army Depot. Specific activities were as follows:

Led efforts to model groundwater flow and contaminant transport, ensured adequacy of monitoring networks, and assessed cleanup alternatives for contaminated sediment, soil, and groundwater.

Initiated a regional program for evaluation of groundwater sampling practices and laboratory analysis at military bases.

Identified emerging issues, wrote technical guidance, and assisted in policy and regulation development through work on four national U. S. EPA workgroups, including the Superfund Groundwater Technical Forum and the Federal Facilities Forum.

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

As a hydrogeologist with the EPA Groundwater Protection Section, Matt worked with provisions of the Safe Drinking Water Act and NEPA to prevent drinking water contamination. Specific activities included the following:

Received an EPA Bronze Medal for his contribution to the development of national guidance for the protection of drinking water.

Managed the Sole Source Aquifer Program and protected the drinking water of two communities through designation under the Safe Drinking Water Act. He prepared geologic reports, conducted 3 public hearings, and responded to public comments f.rom residents who were very concerned about the impact of designation.

Reviewed a number oE Environmental Impact Statements for planned major developments, including large hazardous and solid waste disposal facilities, mine reclamation, and water transfer.

Matt served as a hydrogeologist with the RCRA Hazardous Waste program. Duties were as follows:

Supervised the hydrogeologic investigation of hazardous waste sites to determine compliance with Subtitle C requirements.

Reviewed and wrote" part B" 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.

Condu.cted 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- luthored 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 nationwide 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.

Policv:

Served seniar 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 EPA' s scientific and engineering staff.

Earned an EPA Bronze Medal for representing the regiori s 300 scientists and engineers in negotiations with the Administrator and senior management to better integrate scientific 4 principles into the policy- making process.

Established national protocol for the peer review of scientific documents.

GeoloQv:

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 t ie 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 Pordand, 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.

Teachin:

From 1990 to 1998, Matt taught at least one course per semester at the community college and university levels:

At San Francisco State University, held an adjunct faculty position and taught courses in environmental geology, oceanography( lab and lecture), hydrogeology, and groundwater contamination.

Served as a committee member for graduate and undergraduate students.

Taught courses in environmental geology and oceanography at the College of Marin.

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

Invited Testimonp, R orts, Papers and Presentations:

Hagemann, M. F., 2008. Disclosure of Hazardous Waste Issues under CEQA. Presentation to the Public Environmental Law Conferen. ce, 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).
5 Hagemann, M.F., 2004. Invited testimony to a California Senate coini ittee 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.

Hagernann, 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 Tnist, 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 Narional 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.
6 Hagemann, M.F., 2001. From Tank to Tap: A Chronology of MTBE in Groundwater. Unpublished report.

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

Unpublished report.

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

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

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

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

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

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

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

Hagemann, M. F., Fukanaga, G. L., 1996, Ranking Groundwater Vulnerability in Central Oahu, Hawaii. Proceedings, Geographic Information Systems in Environmental Resources Management, Air and 1Naste Management Association Publication VIP- 61.

Hagemann, M. F., 1994. GroundwaterCharacterization and Cleanup at Closing Niilitary 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 DNAPLcontaminated Groundwater. Califarnia Groundwater Resources Association Meetin. 7 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.
8 Attachment B
SWAP E
Technical Consultation, Data Analysis and SO[ L WATER AIR PROTECTION ENTERPR[ SE Litigation SuppoR for the Environment 2656 29th Street, Suite 201 Santa Monica, California 90405
Attn: Paul Rosenfeld, Ph. D.

MobiL( 3l0) 795- 2335
Ot ice:( 310) 452- 5555
Fax( 310) 452- 5 50
Email: prosenfeld! aswape. com
Paul Rosenfeldj Ph. D. Chemical Fate and Transport& Air Dispersion Modeling Principal Environmenta! Chemist Risk Assessment& Remediation Specialist Education
Ph. D. Soil Chemistry, University of Washington, 1999. Dissertation on volatile organic compound filtration.

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

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

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

Rosenfeld has evaluated and modeled emissions from oil spilis, landfills, boilers and incinerators, process stacks, storage tanks, confined animal feeding operations, industrial, military and agricultural sources, unconventional oil drilling operations, and locomotive and construction engines. His project experience ranges from monitoring and mode( ing of pollution sources to evaluating impacts of poilution on workers at industrial facilities and residents in surrounding communities. Dr. Rosenfeld has also successfully modeled exposure to contaminants distributed by water systems and via vapor intrusion.

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

Paul E. Rosenfeld, Ph. D. Page 1 of 12 October 2022
Professional History:

Soil Water Air Protection Enterprise( SWAPE); 2003 to present; Principal and Founding Partner UCLA School of Public Health; 2007 to 2011; Lecturer( Assistant Researcher) UCLA School of Public Health; 2003 to 2006; Adjunct Professor UCLA Environmental Science and Engineering Program; 2002- 2004; Doctoral Intern Coordinator UCLA Institute of the Environment, 2001- 2002; Research Associate Komex Hz0 Science, 2001 to 2003; Senior Remediation Scientist National Groundwater Association, 2002- 2004; Lecturer
San Diego State University, 1999- 2001; Adjunct Professor Anteon Corp., San Diego, 2000- 2001; Remediation Project Manager Ogden( now Amec), San Diego, 2000- 2000; Remediation Project Manager Bechtel, San Diego, California, 1999— 2000; Risk Assessor King County, Seattle, 1996— 1999; Scientist
James River Corp., Washington, 1995- 96; Scientist
Big Creek Lumber, Davenport, California, 1995; Scientist Plumas Corp., California and USFS, Tahoe 1993- 1995; Scientist Peace Corps and World Wildlife Fund, St. Kitts, West Indies, 1991- 1993; Scientist Publications:

Rosenfeld P. E., Spaeth K., Hallman R., Bressler R., Smith, G.,( 2022) Cancer Risk and Diesel Exhaust Exposure Among Railroad Workers. Water Air Soil Pol/iEtion. 233, 171.

Remy, L.L., Clay T., Byers, V., Rosenfeld P. E.( 2019) Hospital, Health, and Community Burden After Oil Refinery Fires, Richmond, California 2007 and 2012. Environ» rental f/ealth. 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 Journa/ of Environmental Science, 8( 6), 622- 632.

Rosenfeld, P. E.& Feng, L. (2011). The Risks of Ha=ardo«s Waste. Amsterdam: Elsevier Publishing.

Cheremisinoff, N. P., & Rosenfeld, P. E. ( 2011). Handbook of Pollz tion Prevention and Cleaner Production: Best Practices in the Agrochemical lndustry, 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 F.nvironmental 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 flealth. 73( 6), 34- 46.

Cheremisinoff, N. P., & Rosenfeld, P. E. ( 2010). Handbook of Pollattion Prevention and Cleaner Prodiiction: Best Practices in the Wood and Paper Industries. Amsterdam: Elsevier Publishing.

Cheremisinoff, N.P., & Rosenfeld, P. E. ( 2009). Handbook of Pollzetion Prevention and Cleaner Production: Best Pr actices in the Petroleum Industry. Amsterdam: Elsevier Publishing.

Paul E. Rosenfeld, Ph. D. Page 2 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 treahnent facilities in the United States. WIT Tr ansactions on Ecolo and the Envir• onment, Air Po/[ ution, 123( l7), 319- 327.

Tam L. K.., Wu C. D., C( ark 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 Compoa nds, 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. O ganohalogen Compoz nd.s, 70, 000527- 000530.

Hensley, A.R. A. Scott, J. J. J. C( ark, Rosenfeld, P. E. ( 2007). Attic Dust and Human Biood Samples Collected near a Former Wood Treatment Facility. Envir•onmental 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. 1" ater Science c c 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& Technolo 55( 5), 335- 344.

Sullivan, P. J. Clark, J. J. J., Agardy, F. J., Rosenfeld, P. E. ( 2007). Toxic Gegacy, Synthetic Toxins in the Food, Water, and Air in American Cities. Boston Massachusetts: Elsevier Publishing Rosenfeld, P. E., and Suffet LH. ( 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 C( assification Scheme For The Urban Environment. Water Environment Federation' s Technical Exhibition and Conference ( 6t FFTF.C) 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. Y' ater Science and 7echnology. 49( 9), 193- 199.

Rosenfeld, P. E., and Suffet I.H. ( 2004). Control of Compost Odor Using High Carbon Wood Ash, w'ater Science anc 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 Reseai ch. 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 Materia( s Composting Facility. Integrated Waste Management Boa d Public Affairs O ce, 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. W'ater Soil and Air Pollution. 127( 1- 4), U3- 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. 6[ ater 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. G ater Environment Researeh, 73, 388- 393.

Paul E. Rosenfeld, Ph. D. Page 3 of 12 October 2022
Rosenfeld, P. E., and Henry C. L., ( 2001). High carbon wood ash effect on biosolids microbial activity and odor.

Water Environment Research. 131( 1- 4), 247- 262.

Chollack, T. and P. Rosenfeld. ( 1998). Compost Amendment Handbook For Landscaping. Prepared for and distributed by the City of Redmond, Washington State.

Rosenfeld, P. E. ( 1992). The Mount Liamuiga Crater Trail. Heritage Magazine ofSt. Kitts, 3( 2).

Rosenfeld, P. E. ( 1993). High School Biogas Project to Prevent Deforestation On St. Kitts. Biomass Users Nettivork, 7( 1).

Rosenfeld, P. E. ( 1998). Characterization, Quantification, and Control of Odor Emissions From Biosolids Application To Forest Soil. Doctoral Thesis. University of Washington College of Forest Resources.

Rosenfeld, P. E. ( 1994). Potential Utilization of Small Diameter Trees on Sierra County Public Land. Masters thesis reprinted by the Sierra County Economic CounciL Sierra County, California.

Rosenfeld, P. E.( 1991). How to Build a Small Rural Anaerobic Digester& Uses Of Biogas In The First And Third World. Bachelors Thesis. University of California.

Presentations:

Rosenfeld, P. E., " The science for Perfluorinated Chemicals ( PFAS): What makes remediation so hard?" Law Seminars International,( May 9- 10, 2018) 800 Fifth Avenue, Suite lO l Seattle, WA.

Rosenfeld, P. E., Sutherland, A; Hesse, R.; Zapata, A. ( October 3- 6, 2013). Air dispersion modeling of volatile organic emissions from multiple natural gas wells in Decatur, TX. 4th G' estern Regional tifeeting 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 Cround Water Summit and 2009 Groz nd Water• Protection Council Spring tleeting, 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 Cround Water Summit and 2009 Groaend Water Protection Council Spring Meeling. 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 Pollz tion X6' Ll.• Proceedings of the Seventeenth / nternational Conference on Alodeling, i tonitoring and Manngement ofAir 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/ nternational Conferences on Soils Sediinent nnd Water. Platform lecture conducted from University of Massachusetts, Amherst MA.

Paul E. Rosenfeld, Ph. D. Page 4 of 12 October 2022
Rosenfeld, P. E. ( October 15- 18, 2007). The Repeated Trespass of Tritium- Contaminated Water Into A Surrounding Community Form Repeated Waste Spills From A Nuclear Power Plant. The 23" Annual lnternational Confe- ences on Soils Sediment und Wcrter. Platform lecture conducted from University of Massachusetts, Amherst MA.

Rosenfeld, P. E.( October 15- 18, 2007). Somerville Community Exposure To Contaminants From Wood Treatment Facility Emissions. The 23r` An rual 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( AF,HS) Annual A9eeting. 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 AEIfS Anm al leeting. 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 Intei nationa! Symposiarm on f alogenated Persisteht Organic Pollcrtants — 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 l3 Annaeal Aleeting & F position. 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 & Gitigation 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, "loxicology and Remediation PEMA Emerging Contaminant Conference. Lecture conducted from Hilton Hotel, [ rvine California.

Paul Rosenfeld Ph. D. ( September 19, 2005). Fate, Transport, Toxicity, And Persistence of 1, 2, 3- TCP. PF,r1 1A Emerging Contamirrant Conference. Lecture conducted from Hilton Hotel in Irvine, California.

Paul Rosenfeld Ph. D.( September 26- 27, 2005). Fate, Transport and Persistence of PDBEs. Afealey' s Groirndwater 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. nternatianal Society of F.nvironnxental Forensics: Focus On F,merging 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 Groundivater Associalion Ground Water And Environrraental Lcnv Conference.

Lecture conducted from Wyndham Baltimore [ nner Harbor, Baltimore Maryland.

Paul Rosenfeld Ph. D. ( July 21- 22, 2005). Brominated Flame Retardants in Groundwater: Pathways to Human Ingestion, Toxicology and Remediation. 200. i Natiorral Groundwater Association Grotand 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 G ounchvater Association. Environmental Law Conference. Lecture conducted from Congress Plaza Hotel, Chicago Illinois.

Paul E. Rosenfeld, Ph. D. Page 5 of 12 October 2022
Paul Rosenfeld, Ph. D. ( March 2004). Perchlorate Toxicology. Meeting of the Amer•ican Groundtivater T'rzrst.

Lecture conducted from Phoenix Arizona.

Hagemann, M. F., Paul Rosenfeld, Ph. D. and Rob Hesse( 2004). Perchlorate Contamination of the Colorado River.

A leeting of tribal representatives. Lecture conducted from Parker, AZ.

Paul Rosenfeld, Ph. D. ( April 7, 2004). A National Damage Assessment Model For PCE and Dry Cleaners.

Drycleuner Symposium. California Grozrnd Y' ater Association. Lecture conducted from Radison Hotel, Sacramento, California.

Rosenfeld, P. E., Grey, M., ( June 2003) Two stage biofilter for biosolids composting odor control. Seventh Inter national/ n Sitz 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 Grouna'water 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 CUP,9 Forum. Lecture conducted from Marriott Hotel, Anaheim Ca( ifornia.

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, Wastetivater and Industrial Processes. Sixth Anni al Symposium On Off Flavors in the Aquatic Environment. International b ater 4ssociation. 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 Anyn al Symposium On Off Flavors in the Aquatic Environment. Interhational bi ater Association. Lecture conducted from Barcelona Spain.

Rosenfeld, P. E. and Grey, M. A. ( September 22- 24, 2002). Biocycle Composting For Coastal Sage Restoration.

Nor•thtivest Biosolids Management lssociation. 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 Eacility. Soil Science Sociery Annual Conference. Lecture conducted from ndianapolis, Maryland.

Rosenfeld. P. E. ( September 16, 2000). Two stage biofilter for biosolids composting odor control. Water F_nvironment Federation. Lecture conducted from Anaheim California.

Rosenfeld. P. E. ( October 16, 2000). Wood ash and biofilter control of compost odor. 6iofest. 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 F'ederation 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. Soi! Science Society ofAmerica. Lecture conducted from Salt Lake City Utah.

Paul E. Rosenfeid, Ph. D. Page 6 of 12 October 2022
Rosenfeld, P. E., C. L. Henry, R. Harrison. ( 1998). Comparison of Microbial Activity and Odor Emissions from Three Different Biosolids Applied to Forest Soil. Brown and Caldtivell. Lecture conducted from Seattle Washington.

Rosenfeld, P.E., C. L. Henry. ( 1998). Characterization, Quantification, and Control of Odor Emissions from Biosolids Application To Forest Soil. Biofest. Lecture conducted from Lake Chelan, Washington.

Rosenfeld, P. E, C. L. Henry, R. Harrison. ( 1998). Oat and Grass Seed Germination and Nitrogen and Sulfur Emissions Following Biosolids Incorporation With High- Carbon Wood- Ash. Water Environment Federation 12th Annual Residuals and Biosolids Management Conference Proceedings. Lecture conducted from Bellevue Washington.

Rosenfeld, P. E., C. L. Henry, R. B. Harrison, and R. Dills. ( 1997). Comparison of Odor Emissions From Three Different Biosolids Applied to Forest Soil. Soi! Science Sociery of America. Lecture conducted from Anaheim California.

Teaching Experience:

UCLA Department of Environmental Heaith ( Summer 2003 through 20010) Taught Environmental Health Science l00 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 [ llinois. April l, 2002. Focused on fate and transport of contaminants associated with Superfund and RCRA sites.

California [ ntegrated 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, Soi( Science Program, Teaching Assistant for several courses including: Soil Chemistry, Organic Soil Amendments, and Soil Stabi( ity.

U. C. Berkeley, Environmental Science Program Teaching Assistant for Environmental Science 10.

Academic Grants Awarded:

California lntegrated 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: $( 0, 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 Technotogy, Washington State. $ 100, 000 grant awarded to University of Washington: Goal: To investigate odor emissions from biosolids application and the effect of polymers and ash on VOC emissions. 1998.

Northwest Biosolids Management Association, Washington State. $ 20, 000 grant awarded to investigate effect of polymers and ash on VOC emissions from biosolids. 1997.

Paul E. Rosenfeld, Ph. D. Page 7 of 12 October 2022
James River Corporation, Oregon: $ 10, 000 grant was awarded to investigate the success of genetically engineered Poplar trees with resistance to round- up. 1996.

United State Forest Service, Tahoe National Forest: $ 15, 000 grant was awarded to investigating fire ecology of the Tahoe National Forest. 1995.

Kellogg Foundation, Washington D. C. $ 500 grant was awarded to construct a large anaerobic digester on St. Kitts in West Indies. 1993
Deposition and/or Trial Testimony:

In the Superior Court of the State of California, County of San Bernardino Billy Wildrick, Piaintiff vs. BNSF Railway Company
Case No. CIVDS1711810
Rosenfeld Deposition 10- 17- 2022
ln the State Court of Bibb County, State of Georgia
Richard Hutcherson, Plaintiff vs Norfolk Southern Railway Company Case No. 10- SCCV- 092007
Rosenfeld Deposition 10- 6- 2022
In the Civi) District Court of the Parish of Orleans, State of Louisiana Millard Clark, Plaintiff vs. Dixie Carriers, [ nc. et a(.

Case No. 2020- 03891
Rosenfeld Deposition 9- 15- 2022
In The Circuit Court of Livingston County, State of Missouri, Circuit Civi( Division Shirley Ralls, Plaintiff vs. Canadian Pacific Railway and Soo Line Railroad Case No. 18- LV- CC0020
Rosenfeld Deposition 9- 7- 2022
n The Circuit Court of the l3th Judicial Circuit Court, Hillsborough County, Florida Civil Division Jonny C. Daniels, Plaintiff vs. CSX Transportation Inc.

Case No. 20- CA- 5502
Rosenfe( d Deposition 9- 1- 2022
In The Circuit Court of St. Louis County, State of Missouri Kieth Luke et. aL Plaintiff vs. Monsanto Company et. al.

Case No. 19SL- CC03191
Rosenfeld Deposition 8- 25- 2022
In The Circuit Court ofthe l3th Judicial Circuit Court, Hillsborough County, Florida Civil Division Jeffery S. Lamotte, Plaintiff vs. CSX Transportation Inc.

Case No. NO. 20- CA- 0049
Rosenfeld Deposition 8- 22- 2022
In State of Minnesota District Court, County of St. Louis Sixth Judicia( District Greg Bean, Plaintiff vs. Soo Line Railroad Company
Case No. 69- DU- CV- 21- 760
Rosenfeld Deposition 8- 17- 2022
In United States District Court Western District of Washington at Tacoma, Washington John D. Fitzgerald Plaintiffvs. BNSF
Case No. 3: 21- cv-05288- RJB
Rosenfe( d Deposition 8- 11- 2022
Paul E. Rosenfeld, Ph. D. Page 8 of 12 October 2022
ln Circuit Court of the Sixth Judicial Circuit, Macon Illinois Rocky Bennyhoff Plaintiff vs. Norfolk Southern
Case No. 20- L- 56
Rosenfeld Deposition 8- 3- 2022
In Court of Common Pleas, Hamilton County Ohio
Joe Briggins Plaintiff vs. CSX
Case No. A2004464
Rosenfeld Deposition 6- 17- 2022
In the Superior Court of the State of California, County of Kern George LaFazia vs. BNSF Railway Company.

CaseNo. BCV- 19- 103087
Rosenfeld Deposition 5- 17- 2022
n the Circuit Court of Cook County Illinois
Bobby Earles vs. Penn Centra( et. al.

Case No. 2020- L- 000550
Rosenfeld Deposition 4- 16- 2022
In United States District Court Easter District of Florida Albert Hartman Plaintiffvs. Illinois Central
Case No. 2: 20- cv- 1633
Rosenfeld Deposition 4- 4- 2022
In the Circuit Court of the 4' Judicial Circuit, in and For Duval County, Florida Barbara Steele vs. CSX Transportation
Case No. 16- 219- Ca- 008796
Rosenfeld Deposition 3- 15- 2022
In United States District Court Easter District of New York Romano et al. vs. Northrup Grumman Corporation
Case No. l6- cv- 5760
Rosenfeld Deposition 3- 10- 2022
n the Circuit Court of Cook County Illinois
Linda Benjamin vs. [ llinois Central
Case Na No. 2019 L 007599
Rosenfeld Deposition i- 26- 2022
In the Circuit Court of Cook County lllinois
Donald Smith vs. Illinois Central
Case No. No. 2019 L 003426
Rosenfeld Deposition 1- 24- 2022
n the Circuit Court of Cook County [ Ilinois
Jan Holeman vs. BNSF
Case No. 2019 L 000675
Rosenfeld Deposition 1- 18- 2022
In the State Court of Bibb County State of Georgia
Dwayne B. Garrett vs. Norfolk Southern
Case No. 20- SCCV- 091232
Rosenfeld Deposition I 1- 10- 2021
Paul E. Rosenfeld, Ph. D. Page 9 of l2 October 2022
In the Circuit Court of Cook County Illinois
Joseph Ruepke vs. BNSF
Case No. 2019 L 007730
Rosenfeld Deposition 11- 5- 2021
In the United States District Court For the District of Nebraska Steven Gillett vs. BNSF
Case No. 4: 20- cv- 03120
Rosenfeld Deposition 10- 28- 2021
In the Montana Thirteenth District Court of Yellowstone County James Eadus vs. Soo Line Railroad and BNSF
CaseNo. DV 19- 1056
Rosenfeld Deposition 10- 21- 2021
In the Circuit Court Of The Twentieth Judicia( Circuit, St Clair County, [] linois Martha Custer et aLcvs. Cerro Flow Products, Inc.

Case No. Oi9- L- 2295
Rosenfeld Deposition 5- 14- 2021
Trial October 8- 4- 2021
In the Circuit Court of Cook County Illinois
Joseph Rafferty vs. Consolidated Rail Corporation and National Railroad Passenger Corporation d/ b/ a

AMTRAK,
Case No. 18- L- 6845
Rosenfeld Deposition 6- 28- 2021
In the United States District Court For the Northern District of Illinois Theresa Romcoe vs. Northeast Illinois Regional Commuter Railroad Corporation d/ b/ a METRA Rail Case No. 17- cv- 8517
Rosenfeld Deposition 5- 25- 2021
In the Superior Court of the State of Arizona In and For the Cunty of Maricopa Mary Tryon et al. vs. The City ofPheonix v. Cox Cactus Farro, L. L. C., Utah Shelter Systems, [ nc.

Case No. CV20127- 094749
Rosenfeld Deposition 5- 7- 2021
In the United States District Court for the Eastern District of Texas Beaumont Division Robinson, Jeremy et al vs. CNA Insurance Company et al.

Case No. 1: 17- cv- 000508
Rosenfeld Deposition 3- 25- 2021
n the Superior Court of the State of California, County of San Bernardino Gary Garner, Personal Representative for the Estate of Melvin Garner vs. BNSF Railway Company.

Case No. 1720288
Rosenfeld Deposition 2- 23- 2021
In the Superior Court of the State of California, County of Los Angeles, Spring Street Courthouse Benny M Rodriguez vs. Union Pacific Railroad, A Corporation, et al.

Case No. 18STCV01162
Rosenfeld Deposition 12- 23- 2020
In the Circuit Court of Jackson County, Missouri
Karen Cornwell, Plaintiff, vs. Marathon Petroleum, LP, Defendant.

Case No. 1716- CV 10006
Rosenfeld Deposition 8- 30- 2019
Paul E. Rosenfeld, Ph. D. Page 10 of 12 October 2022
In the United States District Court For The District of New Jersey Duarte et al, P( aintiffs, vs. United States Metals Refining Company et. al. Defendant.

Case No. 2: 17- cv-01624- ES- SCM
Rosenfeld Deposition 6- 7- 2019
In the United States District Court of Southern District of Texas Galveston Division M/T Carla Maersk vs. Conti 168., Schiffahrts- GMBH& Co. Bulker KG MS" Conti Perdido" Defendant.

Case No. 3: 15- CV- 00106 consolidated with 3: 15- CV- 00237 Rosenfeld Deposition 5- 9- 2019
In The Superior Court of the State of California in And For The County Of Los Angeles— Santa Monica Carole- Taddeo- Bates et al., vs. Ifran Khan et al., Defendants Case No. BC615636
Rosenfeld Deposition 1- 26- 2019
In The Superior Court of the State of California ln And For The County Of Los Angeles— Santa Monica The San Gabriel Valley Council of Governments et al. vs EI Adobe Apts. Inc. et al., Defendants Case No. BC646857
Rosenfeld Deposition 10- 6- 2018; Trial 3- 7- 19
In United States District Court For The District of Colorado Bells et al. Plaintiffs vs. The 3M Company et al., Defendants Case No. l: l 6- cv- 02531- RBJ
Rosenfeld Deposition 3- 15- 2018 and 4- 3- 2018
In The District Court Of Regan County, Texas, 1 12` h 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 ln And For The County Of Contra Costa Simons et al., Plaintifs vs. Chevron Corporation, et al., Defendants Cause No. C12- 01481
Rosenfeid 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. Oi9- L- 2295
Rosenfeld Deposition 8- 23- 2017
In United States District Court For The Southern District of Mississippi Guy Manuel vs. The BP Exploration et al., Defendants
Case No. 1: 19- cv- 00315- RHW
Rosenfeld Deposition 4- 22- 2020
In The Superior Court of the State of California, For The County of Los Angeles Warrn Gilbert and Penny Gilber, Plaintiff vs. BMW ofNorth America LLC Case No. LC102019( c/ w BC582154)
Rosenfe( d Deposition 8- 16- 2017, Trail 8- 28- 2018
tn the Northern District Court of Mississippi, Greenville Division Brenda J. Cooper, et al., Plaintiffs, vs. Meritor Inc., et al., Defendants Case No. 4: 16- cv- 52- DMB- JVM
Rosenfeld Deposition July 2017
Paul E. Rosenfeld, Ph. D. Page 11 of 12 October 2022
In The Superior Court of the State of Washington, County of Snohomish Michael Davis and Julie Davis et al., Plaintiff vs. Cedar Grove Composting Inc., Defendants Case No. 13- 2- 03987- 5
Rosenfeld Deposition, February 2017
Trial March 2017
In The Superior Court of the State of California, County of Alameda Charles Spain., Plaintiff vs. Thermo Fisher Scientific, et al., Defendants Case No. RG 14711115
Rosenfeld Deposition September 2015
In The lowa District Court In And For Poweshiek County
Russefl D. Winburn, et al., Plaintiffs vs. Doug Hoksbergen, et al., Defendants Case No. LALA002187
Rosenfeld Deposition August 2015
In The Circuit Court of Ohio County, West Virginia
Robert Andrews, et al. v. Antero, et al.

Civil Action No. 14- G30000
Rosenfeld Deposition June 2015
In The Iowa District Court for Muscatine County
Laurie Freeman et. al. Plaintiffs vs. Grain Processing Corporation, Defendant Case No. 4980
Rosenfeld Deposition May 2015
In the Circuit Court of the 17` h Judicial Circuit, in and For Broward County, Florida Walter Hinton, et. al. Plaintiff, vs. City of Fort Lauderdale, Florida, a Municipality, Defendant.

Case No. CACE07030358( 26)
Rosenfeld Deposition December 2014
In the County Court of Dallas County Texas
Lisa Parr et al, Plaintiff, vs. Aruba et al, Defendant.

Case No. co-1 l- O l 650- E
Rosenfeld Deposition: March and September 2013
Rosenfeld Trial April 2014
In the Court of Common Pleas of Tuscarawas County Ohio
John Michael Abicht, et al., Plaintiffs, vs. Republic Services, Inc., et al., Defendants Case No. 2008 CT 10 0741 ( Cons. w/ 2009 CV 10 0987)
Rosenfeld Deposition October 2012
n the United States District Court for the Middle District of Alabama, Northern Division James K. Benefie( d, et al., Plaintiffs, vs. [ nternational Paper Company, Defendant.

Civil Action No. 2: 09- cv- 232- WHA- TFM
Rosenfeld Deposition July 2010, June 201 1
In the Circuit Court of Jefferson County A(abama
Jaeanette Moss Anthony, et al., Plaintiffs, vs. Drummond Company Inc., et al., Defendants Civil Action No. CV 2008- 2076
Rosenfeld Deposition September 2010
In the United States District Court, Western District Lafayette Division Ackle et al., Plaintiffs, vs. Citgo Petroleum Corporation, et al., Defendants.

Case No. 2: 07CV 1052
Rosenfeld Deposition July 2009
Paul E. Rosenfeld, Ph. D. Page 12 of 12 October 2022

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V, p 1' S1 7. 836 4200 7939 Harr! son Street, Ste. 150 www. lozeaudrury. com x , F 510.836.4205 Oakland, CA 94612 michaei( iozeaudrury. com 1 +•',<
i

BY E- MAIL
September 13, 2023
Rick Caguiat
Community Development Director
Planning Commission Secretary
Community Development Department
390 Towne Centre Drive
Lathrop, California 95330
planninq( ci. lathrop. ca. us
Re: Comment on Planning Commission Agenda Items No. 8. 3 Regarding the Ashley Furniture Project ( Conditional Use Permit No. CUP- 23- 08; Site Plan Review No. SPR 23- 09)
Dear Mr. Caguiat and Honorable Members of the Planning Commission:

I. PROJECT DESCRIPTION
The Project proposes to construct and operate a 1, 486, 607 square foot industrial building including a mix of retail, office/ call center, and warehouse and distribution uses.

About 110, 000 square feet would be dedicated to retail use, 24, 000 square feet to office and call- center uses, and 1, 352, 347 square feet to warehouse and distribution center uses.

II. LEGAL STANDARD
To achieve its objectives of environmental protection, CEQA has a three-tiered structure. 14 CCR § 15002( k); Committee to Save the Hollywoodland Specific Plan v.

Here, since the City purports to exempt the Project from CEQA entirely, the first step of the CEQA process applies. " Exemptions to CEQA are narrowly construed and e] xemption categories are not to be expanded beyond the reasonable scope of their statutory language." Mountain Lion Foundation v. Fish & Game Com. ( 1997) 16 Cal. 4th 105, 125. The determination as to the appropriate scope of an exemption is a question of law subject to independent, or de novo, review. San Lorenzo Valley Community Advocates for Responsible Education v. San Lorenzo Valley Unified School Dist., 2006) 139 Cal. App. 4th 1356, 1375 ("[ Q] uestions of interpretation or application of the requirements of CEQA are matters of law. Thus, for example, interpreting the scope of a CEQA exemption presents `a question of law, subject to de novo review by this court."') Here, the City proposes that the Project is exempt from CEQA review under Section 15183 and PRC § 21083. 3. However, as discussed below, the use of these streamlining provisions is improper, and instead, a full CEQA analysis, such as an EIR, must be prepared for this Project.

I//
Comment re: Ashley Furniture Project
City of Lathrop
September 13, 2023
Planning Commission Hearing
III. DISCUSSION
a. The City Incorrectly Applied CEQA' s Section 15183 Categorical Exemption to the Project and Thus a Full CEQA Analysis is Required.

Envt' I Checklist, p. 13. Similar statements are repeated for each of the specific unavoidable significant impacts. This conclusion does not, however, address all of the City's obligations to grapple with acknowledged significant and unavoidable cumulative impacts.

The section appears to allow an agency, in approving a later project that has significant unavoidable impacts, to forego making a statement of overriding considerations specifically tied to that project. This is contrary to CEQA law. CEQA section 21094, subdivision ( d) requires agencies that approve a later project to comply with CEQA section 21081. Under CEQA section 21081, an agency approving a project with significant environmental effects must find that each effect will be mitigated or avoided, or "that specific overriding economic, legal, social, technological, or other benefits of the project outweigh the ... effect[] ...." 65 The requirement of a statement of overriding considerations is central to CEQA' s role as a public accountability statute; it requires public officials, in approving environmentally detrimental projects, to justify their decisions based on counterbalancing social, economic or other benefits, and to point to substantial evidence in support. ss Under Guidelines section 15152( fl( 3)( C), however, an agency apparently could adopt one statement of overriding considerations for a prior, more general EIR, and then avoid future political accountability by approving later, more specific projects with significant unavoidable impacts pursuant to the prior EIR and statement of overriding considerations. Even though a prior EIR' s analysis of environmental effects may be subject to being incorporated in a later EIR for a later, more specific project, the responsible public officials must still go on the record and explain specifically why they are approving the later project despite its significant unavoidable impacts.

Comment re: Ashley Furniture Project
City of Lathrop
September 13, 2023
Planning Commission Hearing
The same reasoning applies to the implementation of Pub. Res. Code § 21083. 3 and 14 Cal. Admin. Code § 15183. The Project, based on its reliance on the 2022 General Plan Update EIR, will have cumulative impacts on agricultural resources, air quality, greenhouse gas emissions, and traffic noise. Although sections 21083 and 15183 provide for streamlining of the environmental review of a subsequent project, neither section relieves the City from its obligation to make a statement of overriding considerations for the Project. PRC § 21081. Prior to recommending the Project and applying the streamlining provisions, the Planning Commission should prepare a statement of overriding considerations supported by substantial evidence and which evaluates whether any additional feasible mitigation measures applicable to this specific project should be required in order to address the acknowledged cumulative impacts. c. The Project Will Have Project- Specific Significant Effects Which Were Not Addressed in the 2022 General Plan Update EIR.

LIUNA is concerned that a number of significant environmental impacts peculiar to the Project were not addressed in the 2022 General Plan Update EIR. As a result, Pub. Res. Code § 21083. 3 and 14 Cal. Admin. Code § 15183 do not apply and either a mitigated negative declaration or EIR must be prepared to address these unanalyzed impacts.
i. Biological Resources
According to the 2022 General Plan EIR, the federally-listed, endangered valley elderberry longhorn beetle ( Desmocerus californicus dimorphus) did not occur within one- mile of the planning area. GP EIR, p. 3. 4- 15. As a result, there is no focused discussion in the 2022 General Plan EIR on any impacts to this federally- listed species.

In general, the 2022 General Plan EIR concludes that there will be no significant impacts to listed species from the General Plan' s implementation. GP EIR, p. 2. 4- 28 —

3. 4- 29. The valley elderberry longhorn beetle relies on a particular host plant for its survival — the red or blue elderberry. See Biological Resources Analysis Report, p. 18.

The reconnaissance survey conducted for the Biological Resources Analysis observed a 6-foot by 15-foot elderberry shrub on the property. Id., p. 19. The presence of that host plant, the enhanced likelihood of the presence of the endangered valley elderberry longhorn beetle, and the heightened risk of adverse affects on the host plant or potentially present beetles are not addressed as a significant impact in the 2022 General Plan EIR and these effects are peculiar to the Project site. Pub. Res. Code § 21083. 3. Given these facts peculiar to the site, it " might be necessary to examine whether there are project- specific significant effects which are peculiar to the project or its site." 14 CCR 15183.

Res. Code § 21083. 3 and 14 Cal. Admin. Code § 15183 is inappropriate.

In addition, the 2022 General Plan EIR does not identify the significant potential impact of the Project' s thousands of trucks and car trips on wildlife from vehicle collisions with wildlife. This impact is peculiar to the Project given its proposed 2, 798 daily passenger vehicle trips and 680 daily truck trips which will lead to wildlife collisions in the vicinity of the Project. Because this project-specific direct and cumulative effect was not addressed at all in the 2022 General Plan EIR, it must be addressed in an EIR or potentially a mitigated negative declaration for the Project. See PRC § 21083. 3( c) Nothing in this section affects any requirement to analyze potentially significant offsite impacts and cumulative impacts of the project not discussed in the prior environmental impact report with respect to the general plan").
ii. Energy
The 2022 General Plan EIR' s discussion of the General Plan' s energy impacts boils down to stating that by complying with California' s Building Energy Efficiency Standards (" CalGreen"), promoting the use of renewable energy sources and encouraging public transportation and bicycle use, and the fact that PG& E will generally make progress on adding new renewable energy sources to its portfolio, projects within the planning area will not have energy impacts. GP EIR, p. 3. 7- 41 — 3. 7- 42. The Environmental Checklist focuses on the Ashley Furniture Project' s compliance with CalGreen and PG& E' s long- term efforts. Env' t Checklist, p. 66. None of these considerations address the energy effects that are peculiar to a 1. 4 million square feet furniture distribution and retail center.

The standard under CEQA is whether the Project would result in wasteful, inefficient, or unnecessary consumption of energy resources. Failing to undertake " an investigation into renewable energy options that might be available or appropriate for a Comment re: Ashley Furniture Project
City of Lathrop
September 13, 2023
Planning Commission Hearing
projecY' violates CEQA. California Clean Energy Committee v. City of Woodland ( 2014) 225 Cal.App.4th 173, 213. Energy conservation under CEQA is defined as the "wise and efficient use of energy." CEQA Guidelines, app. F, § I. The " wise and efficient use of energy" is achieved by "( 1) decreasing overall per capita energy consumption, ( 2) decreasing reliance on fossil fuels such as coal, natural gas and oil, and ( 3) increasing reliance on renewable energy resources." Id.

Noting compliance with the California Building Energy Efficiency Standards Cal. Code Regs., tit. 24, part 6 ( Title 24) does not constitute an adequate analysis of energy impacts. Ukiah Citizens for Safety First v. City of Ukiah ( 2016) 248 Cal. App. 4th 256, 264-65. Similarly, the court in City of Woodland held unlawful an energy analysis that relied on compliance with Title 24, that failed to assess transportation energy impacts, and that failed to address renewable energy impacts. California Clean Energy Committee v. City of Woodland, 225 Cal.App.4th 173, 209- 13. As such, the General Plan EIR' s reliance on Title 24 compliance does not address the proposed furniture warehouse Project's energy impacts. The energy effects of the Project are, by definition, peculiar to the Project. Given the vast expanse of roofing provided by the proposed Project, any evaluation of its energy impacts cannot ignore the obvious feasibility of an array of solar panels on the roof or covering the extensive parking proposed at the site.

The effect of the project on peak and base period demands for electricity has not been addressed. As such, the Environmental Checklist' s conclusions are unsupported by the necessary discussions of the Project' s energy impacts under CEQA. An EIR or possibly a mitigated negative declaration must be prepared to assess these impacts. iii. Greenhouse Gases and Air Quality.

A. Air pollutant emissions associated with the project during construction, project operation, and cumulative conditions.

B. Potential exposure of sensitive receptors to toxic air contaminants.

C. Significant air quality impacts associated with the project for construction, project operation, and cumulative conditions.

D. Mitigation measures to reduce significant impacts to less than significant or the maximum extent feasible where impacts cannot be mitigated to less than significant.

Environmental Checklist, Attachment I, p. 162. Given the size of the warehouse and the number of expected daily truck trips, LIUNA is skeptical that the emissions forecasts identified for its construction and operation can be substantiated. Before making a recommendation to the Council, the Planning Commission should require staff and the applicant to share their input files for the CaIEEMod modeling in order for the public to be able to assess the accuracy of the model outputs and whether or not the Project's may have a significant effect on air quality and GHG emissions and the extent of necessary mitigation measures as required by the General Plan.

Sincerely,
T - /' ,! t --
le G"- GC. 4', f j4- ...*' '._''
1_. rt' K"+_'2'..t.
r
Michael R. Lozeau

LOZEAU DRURY LLP
T'1", i i i
rP i :
o Victorla Brunn,
Manteta Unified Sthool District Chief Business and Information Officer vbrunn@musd. net( 209) 858- 0764
y4Qt
r;,,„ r}<«, September 28, 2023
I. iric WrrKa,
Prr; h ritf
c: ath l p- c; t. chall VIA E- MAIL( T4/ ARGAS( t. CI. IATNROP CA 13S,)$ c U S MAIL 6 ic' r„ rr rdrur
Mayor and City Council
ri, trr i City of Lathrop
la iseii. i t'. Gucrrrrc5 Attn: City Clerk
h,,,,,,,{,,,,.. 390 Towne Centre Dr.

E, h•„., n,<< r Lathrop, CA 95330
np rintenci nt
i, c` r:. i' Re. Conditional Use Permit and Site Pian Review for the Ashley Furniture Project to Allow for the Construction of an Approximately 1. 5 Miilion Squa e Foat Concrete Tilt-Up Building Located within the Central Lathrop Speci c Plan Phase 2 Area.
tiuperinttnctt• nl. C: l inet
4<< r, s,,,, Honorable Mayor and City Council Members:
t r r,,,„. r„ r,: tE,
r th; r The District remains concemed with the Limited Industrial Zoning Districts behind the t i.,,,, s4,,,,, t,, f, Lathrop High Schoal site, as noted in our response to the Central Lathrop Specific Plan r<< r rf ,;, r,{,,,, r,,,,,,,>„ and therefore the proposed Ashley Furniture development project has the potential to r r F<< impact the District. Lathrop High School is located immediately to the southwest of the ra r,, r, rt< z: FE i"""
project site on the soufhem side of C7os Reis, District steff has reviewed the buffer and r`'. C' s r, r<, screening requirements and finds the 73-foot buffer requirements that include an 8-foot solid wall in addition to pedestrian improvements along Dos Reis to be critical to provide Il\ C[ Ulltt', 8} 11llC1 fior separation of uses. The District is supportive of the addition of the 8-foot separated a., , n,,,; multi-use trail along the southern side of Dos Reis for improved pedestrian safety. r`""` "``.
11 uf1 SI Ci The District is in agreement with the circulation requirements that prohibit truck traffic on r r r r,,,-. x,,;,,,, r,,,. Dos Reis, and the requirement for traffic to be directed to S. Manthey Road as the access a, ,;,,,,;,,.,:,,,> point ta the project site. The District would request the City include MUSD in the review Li, rr,, 14,,,;, F,,, process and route any modifieation to existing lane striping plans that could impact District l F: transportation. This coordination would ensure minimal impacts. fli; J at r»; rrt nrr I ri n i1,;}

4.,,,,, E,,,,, Please let us know if there is any additional information needed from MUSD to assist in r, r„„>>,» r,,«,,, the review process. Do not hesitate to contact me should you have any questions at 209) 858- 0858 or developerfees@musd. net.

U; r. t, rr: i Ertii„ r t.
1,,,,,,,-,,, r,,, Sincerely,
tt } tt.
t): r. Cltrrs, rrA/ ti, nf'rttt>
a, il. L/ f/./ li ir zt ri=rtilt° L
i`'' Victoria Brunn
1) F7 i' a( e fJ.) 7;; t` t.+' 71' Fl! li:
r11$,,,, i,,, Chief Business and Information Officer
t .;,,<<, h,,,,„., Manteca Unified school District
1) arI i ti;u h rn
1 tir C' GtsriJi• rl i/ K
ti, t. t.,,, Cc: Rick Cagivat, Directar Community Development, via email( RCaqivattc' ci. lathrop.ca.us) ur, r;,,, t. ti,,,, t.

P.O. Box 32 Phone( 2Q9) 825- 3200
Manteca, CA 95336 Fax( 209) 858- 7570
2271 West Louise Avenue, Manteca, CA 95337 www. mantecausd. net TT CHN(EN " •`
De Nova Planning Group
A Land 1) Se Planning, I) E sigrf, and Environmental f' irm October 31, 2023
Rick Caguiat, Community Development Director
City of Lathrop
390 Towne Centre Drive
Lathrop, CA 95330
SUBJECT: Response to LIUNA Comments on the Ashley Warehouse CEQA Analysis The City Council received written correspondence from Lozeau Drury, LLP, representing LIUNA regarding the City' s environmental analysis for the Ashley Warehouse Project prepared under the California Environmental Quality Act CEQA") pursuant to Public Resources Code Section 21083. 3 and CEQA Guidelines Section 15183 ( the Environmental Analysis"). The comment letter incorrectly asserts that additional CEQA analysis must be completed for the Ashley Warehouse project, and the City must adopt a statement of overriding considerations.

The City correctly applied Public Resources Code Section 21083. 3 and Section 15183 of the CEQ/ Guidelines The City relied on the exemption provisions provided under Public Resources Code Section 21083. 3 and Section 15183 of the CEQA Guidelines. Public Resources Code Section 21083. 3 and corresponding State CEQA Guidelines Section 15183 allows a streamlined environmental review process for projects that are consistent with the densities established by existing zoning, community plan or general plan policies for which an EIR was certified. The Ashley Warehouse project is consistent with the City of Lathrop General Plan land uses and development intensities designated on the project site. As such, the application of CEQA to the approval of development projects, such as the proposed Ashley Project, shall be limited to effects on the environment which are peculiar to the parcel or to the Project and which were not addressed as significant effects in the prior environmental impact report, or which substantial new information shows will be more significant than described in the prior environmental impact report.

Pub. Res. Code § 21083. 3.) Further, an effect of a project on the environment is not considered peculiar to the parcel or the project, if uniformly applied development policies or standards have been adopted by the local agency with a finding that they will substantially mitigate that effect when applied to future projects.( State CEQA Guidelines 15183( f).)
The lead agency must make a finding at a public hearing that any mitigation measures in the prior EIR that apply to the project' s specific effects, and that the lead agency found to be feasible, will be undertaken. ( Pub. Res. Code § 21083. 3( c); State CEQA Guidelines § 15183( e).) The City has done that here, by incorporating relevant policies, actions, standards, and other mitigating requirements as Conditions of Approval for the Ashley Warehouse project.

These requirements and standards are specifically identified throughout the Environmental Analysis the City prepared for the Ashley Warehouse project. Such a finding is not required for potentially significant environmental effects that are not considered peculiar to the parcel or the project if uniformly applied development policies or standards were previously adopted by the agency with a finding that the policies or standards would substantially mitigate the environmental effect when applied to future projects. ( State CEQA Guidelines § 15183( f).) When the agency has failed to make such a finding previously, it can do so when it approves the later project.

Often, such certified prior EIRs are Program EIRs and, in fact, the factual questions as to whether project impacts fall within the scope of the prior EIR are very similar. As to reliance on a Program EIR, later activities are examined to determine whether an additional environmental document must be prepared. ( State CEQA Guidelines§ 15168( c).) As the commenter notes, if a later activity would result in environmental effects that were not examined in the

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Subjer.t: } tespons to I,IUNA 1sPie( y b` arehouse CE 1A (: omments ate; October 3" l, 7. 22
Program EIR, the agency must prepare an initial study to determine whether an EIR or negative declaration is required to address those effects.( Id.J However, as is the case here, if a later activity would not have any effects that were not examined in the Program EIR ( including any new or more severe impacts), the agency can approve the activity as being within the scope of the project covered by the Program EIR, and no new environmental document would be required. ( Id.)
Factors that an agency may consider in determining whether a later activity is within the scope of a Program EIR include " consistency of the later activity with the type of allowable land use, overall planned density and building intensity, geographic area analyzed for environmental impacts, and covered infrastructure as described in the program EIR." ( State CEQA Guidelines § 15168( c).) An agency must incorporate feasible mitigation measures and alternatives developed in the Program EIR into later activities in the program.( Id.)" Where the later activities involve site specific operations, the agency should use a written checklist or similar device to document the evaluation of the site and the activity to determine whether the environmental effects of the operation were within the scope of the program EIR." ( Id. J
The City' s Environmental Analysis complies with both Section 15183 and Section 15168 of the State CEQA Guidelines.

The commenter claims that an EIR is required for the Project. While the applicability of the exemption provided by State CEQA Guidelines 15183 does not turn on whether the City completes some form of preliminary review, here the City did use an environmental checklist which identifies whether or not each CEQA Appendix G environmental checklist question, and its corresponding impacts, were adequately addressed in the Lathrop General Plan EIR, if there is a significant impact due to new information, or if the Project would result in a significant impact peculiar to the Project site that was not adequately addressed in the General Plan EIR. The Environmental Analysis identifies the applicable City of Lathrop development standards and policies that would apply to the proposed Project during both the construction and operational phases, identifies applicable state- level standards and requirements, and explains how the application of these uniformly applied standards and policies would ensure that no peculiar or sitespecific environmental impacts would occur.

The Project would not result in site- specific biological impacts that cannot be mitigated through application of uniform standards and requirements
The Biological Resources Analysis Report( BRA) prepared by Olberding Environmental, dated May 2021, and updated on November 1, 2023, identified several special- status species having the potential to occur on the subject Property based on the presence of suitable habitat. In fact, several protected avian species were observed during the site visit but in a foraging capacity only. The BRA document was prepared to provide a preliminary orgeneral assessment of biological habitats present on the subject property and to evaluate current wildlife usage of those habitats during a single day site visit. The intent of this document was to provide initial biological information and make recommendations for additional studies if suitable habitat for a particular species was present.

As indicated above, the BRA determined that there is a potential for impacts to several special- status species. In particular, it noted the presence of a Swainson' s Hawk nest on the adjacent project. As such, mitigation for foraging habitat is normally required, in addition to a setback buffer during the nesting season for this species and additional survey requirements as contemplated in the City of Lathrop General Plan Update EIR. These requirements have been made conditions of approval for the project, as required by both the Lathrop General Plan and the San Joaquin County Multi- Species Habitat Conservation and Open Space Plan( SJMSCP).

It should also be recognized that resources agencies have determined that mitigation should proceed through the San Joaquin County Multi- Species Habitat Conservation and Open Space Plan ( SJMSCP). In November of 2000, San DE NOVO ° LANN3NG GhOU'
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To_ ;] r. Itick Ca; ui t
3 Subject: Kesponse ta LIlINA Astiely Wareh 3use (: EQA Cornnaer ts Date: C) cto6 r :', l, 2022
Joaquin County adopted and began implementing the San Joaquin County Multi- Species Habitat Conservation and Open Space Plan ( SJCOG 2000). The plan was developed to provide a strategy for balancing the protection of Open Space and wildlife with the protection of local landowners and agricultural practices. The SJMSCP, in accordance with ESA Section 10( a)( 1)( B) and CESA Section 2081( b) Incidental Take Permits, provides compensation for the Conversion of Open Space to non- Open Space uses which affect the plant, fish and wildlife species covered by the SJMSCP. Species that are covered by the SJMSCP that have the potential to occur within the Property include VELB, Swainson' s hawk, burrowing owl, and the western mastiff bat as discussed in the BRA. Compliance with the requirements established in the SJMSCP, which are clearly identified in the BRA and Environmental Analysis, would ensure that impacts to special status species would be reduced to a less than significant level.

The Project' s Biological Report does not underestimate the diversity of species using the Project site.

The BRA was prepared to provide a preliminary or general assessment of biological habitats present on the subject property and to evaluate current wildlife usage of those habitats during the site visit. This information was provided for supporting informational purposes in order to initially assess biological resources and make recommendations for a more focused evaluation consistent with the SJMSCP and associated incidental take permits prior to grading.

The Project' s Biological Report accurately characterizes the existing environmental setting.

The site survey, literature and databases review conducted by Olberding Environmental provided adequate information to determine special- status species having potential to occur on the Property. As documented in the BRA, the site contains a single habitat type referred to as ruderal/ disturbed grassland. This habitat type is generally associated with agricultural fields and is generally dominated by non- native invasive species. The commenter did not provide any evidence that the assessment was inadequate, just because Dr. Smallwood saw different species using the Property than Olberding Environmental noted during their site visits.

The Biological Report adequately analyzed and mitigated the ProjecYs biological impacts due to habitat loss, wildlife movement, and vehicle collisions.

The BRA document was prepared to provide a preliminary or general assessment of biological habitats present on the subject property and to evaluate current wildlife usage of those habitats.

In its October 9 Letter, LIUNA summarizes the findings from Dr. Smallwood' s review of the Project which jumbles a transportation and biological impact analysis to misleadingly suggest that only the Project will result in a certain number of wildlife roadway mortality incidents. This explanation, however, ignores the City of Lathrop' s summary of the biological resource impacts discussed in the CEQA consistency analysis and reference to and incorporation of the findings from the City' s General Plan Update EIR prepared in 2022. CEQA requires later activities to be" examined in the light of the program EIR to determine whether an additional environmental document must be prepared." CEQA Guidelines, § 15168( c).) Here, the City not only relied on the CEQA Consistency review under 15183 and its analysis of biological resources based on the BRA analysis, but it also incorporated by reference into the CEQA consistency analysis the General Plan Update EIR which anticipated development of the Property.

With respect to roadway wildlife fatalities, the CEQA Guidelines do not recognize this as an environmental impact.

See CEQA Guidelines, Appendix G.) Although an analysis of this impact is unwarranted, Olberding visited the project site again on October 25, 2023 and confirmed that few bird species were observed on roads surrounding the Property. No federally or state listed bird species were observed on the property other than a Swainson' s hawk foraging on the Property. Habitat present on- site offers marginal foraging habitat for raptors. There is no evidence UE' NOVO PLANNING G 20UP
1020 SUNCAST LAN, SUETE Il3b, EL U RADO NIL, CA 95762
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To; r. Rick Ga, uiaC 4
Subject: Response ta LIUNA Ashely Warellouse C£ Qf Coinn e ts Date: (} ctober 1, 2022
to support Dr. Smallwood' s claim that the Project traffic would result in 6, 151 roadway wildlife fatalities due to additional traffic only from the Project( traffic that was previously accounted for in the General Plan Update EIR).

No new species with potential to occur on the Property have been listed, no critical habitat has been designated that may be affected by the Project, and no project description changes that would change a level of potential effect were identified.

The Project correctly relies on the SJMSCP to mitigate the Project' s potential impacts to biological resources.

The SJMSCP, in accordance with ESA Section 10( a)( 1)( B) and CESA Section 2081( b) Incidental Take Permits, provides compensation for the Conversion of Open Space to non- Open Space uses which affect the plant, fish and wildlife species covered by the SJMSCP. Species that are covered by the SJMSCP that have the potential to occur within the Property include VELB, Swainson' s hawk, burrowing owl, and the western mastiff bat.

The Project' s impacts to biological resources would require compliance with the SJMSCP, as required by the General Plan update and the incidental take permits. It has been stated that the SJMSCP cannot be relied upon to mitigate the Project' s impacts due to grossly deficient implementation and poor performance of the SJMSCP. We have not been provided any information as to SJMSCP mitigation requirements so we cannot fully evaluate the adequacy of these claims. There is no evidence that USFWS or CDFW have threatened to suspend or revoke the incidental take permits because the SJMSCP is not effective in mitigating impacts.

The Project' s potential biological impacts are mitigated via the application of uniformly applied standards and requirements, rendering the 15183 exemption appropriate The recommendations in the initial BRA include preconstruction surveys for reptiles, birds, and burrowing owls. They are project requirements in order to ensure that direct take would not occur and to provide additional information as to the presence/ absence of a particular species which had been identified as having potential to occur on the Property based on multiple factors. The BRA acknowledged that Swainson' s Hawk foraging habitat will be negatively impacted when existing foraging habitat is converted to develop lands. Standard mitigation requires that adequate foraging habitat be permanent protected/ preserved at an agency approved mitigation ratio and site consistent with the SJMSCP.

The Project' s potential Air Quality and Health Risk Impacts were properly evaluated LIUNA( the commenter) asserts that the analysis of the Project' s impacts to human health from emissions of toxic air contaminants is inadequate. Specifically, the commenter states that, for warehouses and distribution centers within 1, 000 feet of planned residential uses or other sensitive receptors, the 2022 General Plan requires" requires the preparation of a Health Risk Assessment (" HRA") that meets the standards established by the Office of Environmental Health Hazard Assessment (" OEHHA"), and the San Joaquin Valley Air Pollution Control District SJVAPCD"). ( 2022 GP, p. 3. 3- 31[ LU- 5c].). The commenter states that, that HRA did not comply with the standards established by OEHHA and, as a result, the Project' s impacts had not been adequately evaluated.

Specifically, the commenter states that the environmental analysis failed to provide the exposure assumptions for the HRA, such as the age sensitivity factors(" ASF") or fraction of time at home(" FAH") values. The commenter also states that the environmental analysis failed to provide the dose and risk equation used to calculate the Project' s cancer risks.( Id.) Without providing this equation, there is no way to verify that the HRA utilized the proper equation recommended by OEHHA.
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1020 SUNCAST LANE, Sll€ TE i0b, E DORAC) O HILLS, CA 95762 britchiet; denz voplannir< g. cam ( 916j 9A 9 3231
To: 9a'. Ricl; (; aguiat 5
Subject: Response ta I. IU[!\ Ashe( y VVarehouse CEQ 1 Comn ents Date: Octoher 31, 2022
The commenter also states that the HRA prepared for the Project failed to follow OEHHA guidance because it only analyzed the Project' s operational cancer risks but not the Project' s construction- related cancer risks.

With regard to operational HRA age sensitivity factors( ASF), it is important to note that such factors are calculated automatically by the HARP2 application, which was used for the HRA, consistent with OEHHA and SJVAPCD guidance.

As described on page 3 of the previously developed HRA for the project, the health risks that were evaluated were a 70- year exposure, starting at the third trimester( for residential cancer risk) and a 40- year exposure starting at age 16 ( for workplace cancer risk), which is fully consistent with SJVAPCD guidance. Separately, with regard to FAH values, the HRA conservatively assumed a 24- hour per day ( i. e. 100%) FAH value for all scenarios; this is a highly conservative assumption, given that operations would almost certainly occur less than 24 hours per day ( i. e. less than 100% of the time). Therefore, these assumptions, taken together, provide for a conservative assessment of the Project' s operational cancer risk.

With regard to the commenter' s claim that the environmental analysis" failed to provide the dose and risk equation used to calculate the Project' s cancer risks", this is a moot point. This is because, consistent with OEHHA and SJVAPCD guidance, dose and risk equations are handled by the AERMOD and HARP2 models; separate ' dose and risk equation[ s]' would be duplicative and inappropriate, given that the analysis of health risks is undertaken by the applicable models. Moreover, Appendix 3 and Appendix 4 of the previously developed HRA include the AERMOD Output File, and the HARP2 Output File, respectively, which allows for verification of the modeling parameters.

With regard to the commenter' s claim that the Project failed to follow OEHHA guidance because it only analyzed the Project' s operational cancer risks but ignored the Project' s construction- related cancer risks, this comment is noted.

While the SJVAPCD does not require an assessment of a project' s construction- related cancer risks, in contrast to the commenter' s claim, for the sake of a conservative assessment, a subsequent analysis of the Project' s construction- related cancer risks is provided below. The parameters used for this subsequent construction- related health risk modeling in AERMOD and HARP2 are as follows:

AERMOD:

Six( 6) Off- road Construction Vehicle volume sources;
Release height: 10 feet;
24- hour fraction of time at- home( FAH) value.

HARP2
Exposure duration: 70 year, starting at 3 d trimester( Residential Cancer); 40 year, starting at age 16 Workplace Cancer);
Intake Rate Percentile: 95` h( High End);
Pathways to Evaluate: Mandatory Minimum Pathways;
Deposition Rate: 0. 05 m/ s( uncontrolled sources).

The results of the construction HRA subsequently conducted for the Project are provided in the below table. The construction HRA uses conservative assumptions, such as a 24- hour FAH value. As shown in the below table( Table A- 1), construction health risks associated with the Project, in conjunction with the operational health risks associated with the Project, would remain below the applicable thresholds. It should be noted that the' combined health risks' for residential cancer risk is less than the combination of the individual maximum operational- related and construction- related health risks, since the residential receptors with the highest operational- related health risks are not the same receptors as those with the highest construction- related health risks( and vice versa). a Novo r rvrviur ; ou
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Subject: Respuii, e to I. IUNA Aslleiy W rellouse CEQA Comii ents Date: ( ctober 31, 2022
Table A- 1: Summary of Project Health Risks
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Operational- related Health Risks
Residential Cancer Risk

7. 0 20 per million No
70-year exposure)
Workplace Cancer Risk

1. 3 20 per million No
40- year exposure)
Chronic( non- cancer) 0. 01 Hazard Index>_1 No
Acute( non- cancer) 0 Hazard Index>_1 No
Construction- related Health Risks
Residential Cancer Risk

10. 3 20 per million No
70- year exposure) 1
Workplace Cancer Risk

5. 2 20 per million No
40- year exposure)
Chronic( non- cancer) 0. 01 Hazard Index>_1 No
Acute( non- cancer) 0 Hazard Index>_1 No
Combined Health RisksZ
Residential Cancer Risk

13. 3 20 per million No
70- year exposure) 3
Workplace Cancer Risk

6. 5 20 per million No
40-year exposure)
Chronic( non- cancer) 0. 01 Hazard Index>_1 No
Acute( non- cancer) 0 Hazard Index>_1 No
Sources: AERMOD 11. 2. 0( Lakes Environmental5oftware, 2023J; and HARP- 2 Air Dispersion and Risk Tool. 1 The residential receptor with the highest construction- related health risk is the residence located at 14302 Harlan Rd.

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ZThe combined health risks are less than the combination of the maximum operational- related and constructionrelated health risks, since the residential receptor with the highest operational-related health risk( located at 12965 Manthey Road) is not the same receptor as the receptor with the highest construction- related health risk( and vice versaJ.
3The residential receptor with the highest combined operational- related and construction- related health risk is located at 14302 Harlan Road.

Furthermore, the Construction Emissions Calculations, the AERMOD Output File, and the HARP2 Output file for the construction HRA is provided in Appendices A through C of this Response to Comments chapter, respectively. With this supplemental information, the commenter' s claim that the analysis could underestimate the Project' s health impacts is unsubstantiated. Furthermore, the commenter' s claim that the HRA does not comply with the OEHHA standards as required by the 2022 General Plan, and that the City lacks substantial evidence to conclude that the Project will not result in specific health impacts, is also unsubstantiated. No further response to this comment is warranted.

The Project would not result in Energy- Related impacts The commenter states that the environmental analysis focuses on the Project' s compliance with CalGreen and PG& E' s long-term efforts, but that this does not address the energy effects that are particular to the project itself.

This comment is noted. A supplemental energy analysis is provided below. The below supplemental energy analysis includes a more detailed qualitative and quantitative discussion of the energy effects that are particular to the Project itself, and addresses some additional issues, consistent with requests of the commenter.

According to the CEQA Guidelines, the means to achieve the goal of conserving energy include decreasing overall energy consumption, decreasing reliance on natural gas and oil, and increasing reliance on renewable energy sources. In particular, the proposed project would be considered " wasteful, inefficient, and unnecessary" if it were to violate State and federal energy standards and/ or result in significant adverse impacts related to project energy requirements, energy inefficiencies, energy intensiveness of materials, effects on local and regional energy supplies or on requirements for additional capacity, compliance with existing energy standards, effects on energy resources, or transportation energy use requirements. In addition, the project could have a significant energy impact if it would conflict or create an inconsistency with an applicable plan, policy, or regulation for renewable energy or energy efficiency.

The proposed warehouse project includes various characteristics that reduce the inefficient, wasteful, or unnecessary use of energy. For example, the proposed project would comply with all of the energy efficiency requirements of the latest version of the California Title 24 Energy Efficiency Standards. Moreover, it should be noted that, over time, electrification of the vehicles will increase due to state requirements, and state and national trends.

The amount of energy used by the proposed warehouse project during operation would include the amount of energy used by project buildings and outdoor lighting, and the fuel used by vehicle trips generated during Project construction and operation, fuel used by off-road construction vehicles during construction activities, and fuel used by project maintenance activities during project operation. The following discussion provides a detailed calculation of energy usage expected for the proposed project, as provided by applicable modelling software (i. e. CaIEEMod v2022. 1 and the CARB EMFAC2021).

UE NOVO PIANNING GROUP
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To: Vlr. Ricic Cagtiiat g
Subjeet: Re> E onse to LIUN[ i ,'1s} eiy V:` arel ouse CE: QA Camr ents pate: OcCob i' 31, 2022
Electricitv and Natural Gas
Electricity and natural gas used by the proposed warehouse project would be used primarily to generate energy for the warehouse building, as well as for outdoor parking lot lighting. " Energy" is one of the categories that was modeled for GHG emissions. As also shown in the CaIEEMod modeling outputs, the proposed project is anticipated to consume approximately 155, 122 kWh of electricity per year and approximately 82, 578 kBTU per of natural gas per year. Moreover, this is likely a conservative estimate, given that the CaIEEMod model does not account for the latest version of Title 24.

On- road Vehicles( Operation)
The proposed warehouse project would generate vehicle trips ( i. e., passenger vehicles for employees and heavyduty trucks for hauling) during its operational phase. Requirements to limit the idling of vehicles and equipment would result in fuel savings. Similarly, compliance with applicable State laws and regulations would limit idling and a part of a comprehensive regulatory framework that is implemented by the CARB. A description of project operational on- road mobile energy usage is provided below.

De Novo Planning Group used fleet mix data from the CaIEEMod ( v. 2022. 1) output for the proposed project, and Year 2025 gasoline and diesel MPG ( miles per gallon) factors for individual vehicle classes as provided by EMFAC2021, to derive weighted average gasoline and diesel MPG factors for the vehicle fleet as a whole. Based on these calculations, as provided in Appendix D, upon full buildout, the proposed project would generate operational vehicle trips that would use a total of approximately 481 gallons of gasoline and 1, 113 gallons of diesel per day, or 175, 665 gallons of gasoline and 406, 148 gallons of diesel per year.

The proposed warehouse would be designed and constructed in accordance with the City' s latest adopted energy efficiency standards, which are based on the State' s Title 24 Energy Efficiency Standards for Nonresidential Buildings and Green Building Code Standards. These standards include minimum energy efficiency requirements related to building envelope, mechanical systems ( e. g., heating, ventilation, and air conditioning [ HVAC] and water heating systems), and indoor and outdoor lighting, are widely regarded as the some of the most advanced and stringent building energy efficiency standards in the country. Moreover, as specified in Chapter 5, Part 11 of the Title 24 standards, the proposed project would be required to incorporate electrical conduit to facilitate future installation of EV charging infrastructure. In addition, as specified in Subchapter 6, Part 6 of the Title 24 standards, the proposed project would be required to design the proposed buildings to structurally accommodate future installation of a rooftop solar system. As such, the design of the proposed project would facilitate the future commitment to renewable energy resources. Therefore, building energy consumption would not be considered wasteful, inefficient, or unnecessary.

On- road Vehicles( Construction)
The proposed warehouse would also generate on- road vehicle trips during project construction (from construction workers and vendors travelling to and from the project site). De Novo Planning Group estimated the vehicle fuel consumed during these trips based on the assumed construction schedule, vehicle trip lengths and number of workers per construction phase as provided by CaIEEMod, and Year 2023 gasoline and diesel MPG factors provided by EMFAC2021 ( year 2023 factors were used to represent a conservative analysis, as the energy efficiency of construction activities is anticipated to improve over time). For the sake of simplicity and to be conservative, it was assumed that all construction worker light duty passenger cars and truck trips use gasoline as a fuel source, and all medium and heavy- duty vendortrucks use diesel fuel. Table A- 2, below, describes gasoline and diesel fuel consumed during each construction phase ( in aggregate). As shown, the vast majority of on- road mobile vehicle fuel used during the construction of the proposed project would occur during the building construction phase. See Appendix D of document for a detailed accounting of construction on- road vehicle fuel usage estimates.

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Subjec. t: Fes oi se to LIUNA Ashely blla- ehouse CE( Comments Uate: () ctoher 31, 2022
Table A- 2: On- road Mobile Fuel USE by Project Construction Activities— By Phase TQ#a G( ldt s ¢.. Gasofrn . iTdfaf Ga tor s of t3i s l. Cbns r r tron Phase y r t bJ, , uet(bJ.

Site Preparation 1, 328
Grading 1, 420
Building Construction 429 388
Paving 618
Architectural Coatings 69
Total 3, 864 388
Note:° Provided by CaIEEMod Output. b 5ee Appendix D ofthis E/ R for Further Detail Source: CaIEEMod( v.2022. 1); EMFAC2021.

Off-road Equipment( Construction)
Off-road construction equipment would use diesel fuel during the construciion phase ofihe proposed project. A nonexhaustive list of off-road constructive equipment expected to be used during the construction phase of the proposed Project includes: forklifts, generator sets, tractors, excavators, and dozers. Based on the total amount of COZ emissions expected to be generated by the proposed Project( as provided by the CaIEEMod output), and standard conversion factors ( as provided by the U.S. Energy Information Administration), the proposed Project would use a total of approximately 107, 094 gallons of diesel fuel for off-road construction equipment. Detailed calculations are provided in Appendix D.

State laws and regulations would limit idling from both on- road and off- road diesel- powered equipment and are part of a comprehensive regulatory framework that is implemented by the CARB. Additionally, as a practical matter, it is reasonable to assume that the overall construction schedule and process would be designed to be as efficient as feasible in order to avoid excess monetary costs. For example, equipment and fuel are not typically used wastefully due to the added expense associated with renting the equipment, maintaining it, and fueling it. Therefore, the opportunities for further future efficiency gains during construction are limited. For the foregoing reasons, it is anticipated that the construction phase of the project would not result in wasteful, inefficient, and unnecessary consumption of energy.

Other
The project is anticipated to install a solar photovoltaic( PV) roof system, including on- site PV connection to the local electric grid. This would be consistent with, at minimum, state requirements. This addition of renewable energy to a currently vacant site would help the State make progress on adding new renewable energy resources within the state.

Separately, it should be noted that the proposed warehouse would not be anticipated to result in a wasteful, inefficient, or unnecessary consumption of energy resources for several reasons. For example, the proposed warehouse would generate a substantial amount of economic activity on a site that currently produces virtually no economic activity( being a vacant site); furthermore, the usage of energy resources on the site would be to dense, economically productive activities. The addition of on- site renewable energy resources would reduce any risk that the proposed project would results in any kind of wasteful or inefficient usage of energy resources.

Dc NOVt PLANNING GROUP
1020 SUNCAST tANE, SUITE 106, EL DO ADO HilLS, CA : 5762 britchie(= denovoplanni; g. corri ( U16j 949- 3232
o: vlt. Ricl, Ca b*i iat 10
Subject: Response to LIU( vl1 Asheiy Warehouse CGQA t; orrimer3Cs Date: Oetober 31, Z022
It should further be noted that the proposed project would, over time, take advantage of the increasing electrification and improved energy efficiency of the vehicle fleet, which is anticipated to improve considerably over time, due to technological advancements as well as state requirements.

Lastly, the proposed project is anticipated to operational throughout the day and night, which would reduce potential issues associated with adding inordinate demand to typical' peak' hours for the electric utility( i. e. PG& E).

Conclusion
The proposed project would use energy resources for the operation of the project warehouse building( natural gas and electricity), outdoor lighting ( electricity), on- road vehicle trips ( e. g. gasoline and diesel fuel) generated by the proposed project, and off-road and on- road construction activities associated with the proposed project( e.g. diesel fuel). Each of these activities would require the use of energy resources. The proposed project would be responsible for conserving energy, including through project features, as well as through the implementation of statewide and local measures.

The proposed project would comply with all applicable federal, State, and local regulations regulating energy usage.

For example, PG& E, the electric and natural gas provider to the proposed project, is responsible for the mix of energy resources used to provide electricity for its customers, and it is in the process of implementing the statewide RPS to increase the proportion of renewable energy ( e. g. solar and wind) within its energy portfolio. PG& E has already achieved renewable energy mix of 50%( as of 2021) 1, and is on track to achieve the required renewable energy mix of 60% by 2030. Other statewide measures, including those intended to improve the energy efficiency of the statewide passenger and heavy- duty truck vehicle fleet ( e. g. the Pavley Bill and the Low Carbon Fuel Standard), would improve vehicle fuel economies, thereby conserving gasoline and diesel fuel. These energy savings would continue to accrue over time. Moreover, the proposed project would comply with the City' s General Plan goals, objectives and policies related to energy conservation that are relevant to this analysis.

The proposed project would comply with all existing energy standards and would not be expected to result in significant adverse impacts on energy resources. For these reasons, the proposed project would not cause an inefficient, wasteful, or unnecessary use of energy resources nor cause a significant impact on any of the energyrelated thresholds as described by the CEQA Guidelines.

As described above, the supplemental energy analysis provided above addresses transportation energy impacts, renewable energy impacts, energy efficiency, cost effectiveness in terms of energy requirements, a discussion of the Project' s energy- consuming equipment and processes that would be used during the construction or operation of the Project, and the effect of the Project on peak and base period demands for electricity ( as requested by the commenter). No further response to this comment is warranted.

A Statement of Overriding Considerations is not required CEQA only requires a statement of overriding considerations when a lead agency determines that a project will result in significant and unavoidable impacts( CEQA Guidelines Section 15093). The General Plan EIR evaluated full buildout of the Lathrop General Plan and Land Use Map, both of which this project is consistent with. While full buildout of the entire Lathrop General Plan was determined to result in some significant and unavoidable impacts in the General Plan EIR, that EIR has been certified, and a statement of overriding considerations was adopted for the General Plan and the associated EIR.
1 See here for more detail: https:// www. pge. com/ en_ US/ about- pge/ environment/ what- we- are- doing/ cleanenergy- solutions/ clean- energy- solutions. page DE NQVO PIAN( vING CR UP
1026 SUNCAST LANE, SUfTE i06, E! UORAUQ Hi LS, Ct, 95702 britchie;a novoplat ning. cc rn ( 916j 4 J- 323.

I'': ; vlr. } Ztek (: as,;=uir3t 11
Subject: Kesponse. ta 1. 3UNt1 Ashei}r Wareli use C£ Qr1 Com« ients Date: Octc ber 1, 2022
In this instance, the environmental analysis completed for the proposed Ashley Warehouse project correctly concluded that this individual project would not result in any new or more severe significant impacts than those that were analyzed and disclosed in the General Plan EIR, and that the project would not result in any project- specific significant and unavoidable impacts. As such, there is no need for the City to prepare further environmental review or adopt a Statement of Overriding Considerations for the proposed Ashley Warehouse project.

DF: N( VO PIANNING Gi C7UP
1020 SUNCAST LANE, SUfFE 106, [ L UQf{AUG HIILS, CA U5762 britchie( 7d novopianning. com ( 916) Q49 3231
Construction Emissions( Off- Road Equipment) 365 days peryear Phase Avera e Dailv PM10 Days
Site Preparation( 2023) 032 Ibs/ day 70 Source: CaIEEMod( v2022. 1) Site Preparation( 2024) 0. 42 Ibs/ day 91 Source: CaIEEMod( v2022. 1) Grading( 2024) 0. 61 Ibs/ day 155 Source: CalEEMod( v2022. 1) Building Construction( 2024) 0. 01 Ibs/ day 9 Source: CaIEEMod( v2022. 1) Building Construction( 2025) 0. 17 Ibs/ day 141 Source: CaIEEMod( v2022. 1) Paving( 2025) 0. 09 Ibs/ day 90 Source: CaIEEMod( v2022. 1) Architectural Coating( 2025) 0. 01 Ibs/ day 121 Source: CaIEEMod( v2022. 1) 188. 54 Ibs( total)
Given 27 months of total construction activities:
h; j y "
H
x/ p„ , Ibs/ year( averege)
Per Volume Saurce( of 6:
r y k r ,, a
i w..
lbs/ year( averege)
Lakes Environmental AERMOD MPI
AERMOD Input Produced by:

AERMOD View Ver. 11. 2. 0
Lakes Environmental Software Inc.

Date: 10/ 26/ 2023
File: C:\ Users\ Smith\ Dropbox\ My PC ( DESKTOP- 977GSBU)\ Documents\ HRA\ Ashley Warehouse - Revised ( Construction)\ Ashley Warehouse. ADI AERMOD Control Pathway

CO STARTING
TITLEONE C:\ Users\ Smith\ Dropbox\ My PC ( DESKTOP- 977GSBU)\ Documents\ HRA\ Ashley

MODELOPT CONC FLAT
AVERTIME 1 PERIOD

POLLUTID OTHER

RUNORNOT RUN
ERRORFIL " Ashley Warehouse. err"

CO FINISHED
AERMOD Source Pathway

SO STARTING
Source Location **
Source ID - Type - X Coord. - Y Coord. **
LOCATION VOL1 VOLUME 650380. 000 4188444. 670 0. 0
DESCRSRC Construction Volume Source ( 1)
LOCATION VOL2 VOLUME 649783. 770 4188428. 620 0. 0
DESCRSRC Construction Volume Source ( 2)
LOCATION VOL3 VOLUME 649783. 770 4188630. 660 0. 0
DESCRSRC Construction Volume Source ( 3)
LOCATION VOL4 VOLUME 650380. 000 4188635. 710 0. 0
DESCRSRC Construction Volume Source ( 4)
LOCATION VOLS VOLUME 650090. 120 4188630. 380 0. 0
DESCRSRC Construction Volume Source ( 5)
LOCATION VOL6 VOLUME 650096. 690 4188433. 810 0. 0
DESCRSRC Construction Volume Source ( 6)
Source Parameters **
SRCPARAM VOL1 1. 0 3. 048 35. 240 0. 000
SRCPARAM VOL2 1. 0 3. 048 35. 240 0. 000
SRCPARAM VOL3 1. 0 3. 048 35. 514 0. 000
SRCPARAM VOL4 1. 0 3. 048 36. 481 0. 000
SRCPARAM VOLS 1. 0 3. 048 35. 253 0. 000
SRCPARAM VOL6 1. 0 3. 048 37. 370 0. 000
SRCGROUP VOL1 VOL1
SRCGROUP VOL2 VOL2
SRCGROUP VOL3 VOL3
SRCGROUP VOL4 VOL4

SRCGROUP VOLS VOLS
SRCGROUP VOL6 VOL6

SO FINISHED
AERMOD Receptor Pathway

RE STARTING
DESCRREC "" ""
DISCCART 649676. 34 4188314. 55
DISCCART 649629. 66 4188294. 84
DISCCART 649810. 15 4188312. 48
DISCCART 649364. 10 4188360. 20
DISCCART 649327. 80 4188355. 01
DISCCART 649380. 70 4188758. 52
DISCCART 650495. 81 4188841. 51
DISCCART 650597. 47 4188832. 17
DISCCART 650536. 27 4188878. 85
DISCCART 650577. 76 4188877. 81
DISCCART 650602. 66 4188860. 18
DISCCART 650610. 95 4188880. 93
DISCCART 650638. 10 4188858. 53
DISCCART 650664. 10 4188331. 03
DISCCART 650668. 72 4188350. 83
DISCCART 650677. 96 4188379. 86
DISCCART 650699. 74 4188414. 84
DISCCART 650758. 47 4188658. 36
DISCCART 650765. 73 4188678. 82
DISCCART 650773. 65 4188706. 54
DISCCART 650778. 27 4188726. 34
DISCCART 650805. 33 4188805. 53
DISCCART 650806. 65 4188824. 01
DISCCART 650811. 27 4188843. 81
DISCCART 650814. 57 4188862. 29
DISCCART 650846. 24 4188924. 98
DISCCART 650850. 86 4188951. 38
DISCCART 650854. 82 4188976. 46
DISCCART 650698. 00 4188307. 32
DISCCART 650692. 60 4188291. 80
DISCCART 650724. 82 4189245. 80
DISCCART 650726. 07 4189273. 37
DISCCART 650856. 27 4189006. 30
DISCCART 650857. 23 4189022. 60
DISCCART 650859. 15 4189041. 29
DISCCART 650859. 15 4189058. 54
DISCCART 650860. 58 4189076. 28
DISCCART 650861. 54 4189094. 49
DISCCART 650857. 71 4189113. 19
DISCCART 650847. 16 4189118. 94
DISCCART 650848. 12 4189134. 76
DISCCART 650850. 04 4189155. 37
DISCCART 650851. 48 4189171. 66
DISCCART 650853. 87 4189184. 12
DISCCART 650856. 75 4189199. 46
DISCCART 650857. 71 4189213. 36
DISCCART 650860. 58 4189226. 30
DISCCART 650862. 50 4189242. 60
DISCCART 650865. 38 4189258. 42
DISCCART 650867. 77 4189275. 19
DISCCART 650868. 73 4189291. 49
DISCCART 650872. 09 4189309. 23
DISCCART 650874. 00 4189325. 04
DISCCART 650875. 92 4189340. 38
DISCCART 650878. 80 4189355. 24
DISCCART 650881. 19 4189373. 45
DISCCART 650884. 55 4189390. 71
DISCCART 650888. 86 4189407. 01
DISCCART 650889. 82 4189427. 14
DISCCART 650891. 74 4189443. 43
DISCCART 650895. 09 4189461. 17
DISCCART 650898. 45 4189475. 55
DISCCART 650898. 45 4189489. 93
DISCCART 650902. 28 4189504. 31
DISCCART 650709. 41 4188344. 56
DISCCART 650722. 45 4188284. 03
DISCCART 650745. 73 4188280. 30
DISCCART 650735. 49 4188223. 50
DISCCART 650721. 52 4188167. 62
DESCRREC " UCARTI" " Receptors generated from Uniform Cartesian Grid" DISCCART 650525. 76 4188133. 34
DISCCART 651125. 76 4188133. 34
DISCCART 649125. 76 4188183. 34
DISCCART 649225. 76 4188183. 34
DISCCART 649325. 76 4188183. 34
DISCCART 649425. 76 4188183. 34
DISCCART 649525. 76 4188183. 34
DISCCART 649625. 76 4188183. 34
DISCCART 649725. 76 4188183. 34
DISCCART 649825. 76 4188183. 34
DISCCART 649925. 76 4188183. 34
DISCCART 650025. 76 4188183. 34
DISCCART 650125. 76 4188183. 34
DISCCART 650225. 76 4188183. 34
DISCCART 650325. 76 4188183. 34
DISCCART 650425. 76 4188183. 34
DISCCART 650525. 76 4188183. 34
DISCCART 650625. 76 4188183. 34
DISCCART 650725. 76 4188183. 34
DISCCART 650825. 76 4188183. 34
DISCCART 651125. 76 4188183. 34
DISCCART 649125. 76 4188233. 34
DISCCART 649225. 76 4188233. 34
DISCCART 649325. 76 4188233. 34
DISCCART 649425. 76 4188233. 34
DISCCART 649525. 76 4188233. 34
DISCCART 649625. 76 4188233. 34
DISCCART 649725. 76 4188233. 34
DISCCART 649825. 76 4188233. 34
DISCCART 649925. 76 4188233. 34
DISCCART 650025. 76 4188233. 34
DISCCART 650125. 76 4188233. 34
DISCCART 650225. 76 4188233. 34
DISCCART 650325. 76 4188233. 34
DISCCART 650425. 76 4188233. 34
DISCCART 650525. 76 4188233. 34
DISCCART 650625. 76 4188233. 34
DISCCART 650725. 76 4188233. 34
DISCCART 650825. 76 4188233. 34
DISCCART 651125. 76 4188233. 34
DISCCART 649125. 76 4188283. 34
DISCCART 649225. 76 4188283. 34
DISCCART 649325. 76 4188283. 34
DISCCART 649425. 76 4188283. 34
DISCCART 649525. 76 4188283. 34
DISCCART 649625. 76 4188283. 34
DISCCART 649725. 76 4188283. 34
DISCCART 649825. 76 4188283. 34
DISCCART 649925. 76 4188283. 34
DISCCART 650025. 76 4188283. 34
DISCCART 650125. 76 4188283. 34
DISCCART 650225. 76 4188283. 34
DISCCART 650325. 76 4188283. 34
DISCCART 650425. 76 4188283. 34
DISCCART 650525. 76 4188283. 34
DISCCART 650625. 76 4188283. 34
DISCCART 650725. 76 4188283. 34
DISCCART 650825. 76 4188283. 34
DISCCART 651125. 76 4188283. 34
DISCCART 649125. 76 4188333. 34
DISCCART 649225. 76 4188333. 34
DISCCART 649325. 76 4188333. 34
DISCCART 649425. 76 4188333. 34
DISCCART 649525. 76 4188333. 34
DISCCART 649625. 76 4188333. 34
DISCCART 649725. 76 4188333. 34
DISCCART 649825. 76 4188333. 34
DISCCART 649925. 76 4188333. 34
DISCCART 650025. 76 4188333. 34
DISCCART 650125. 76 4188333. 34
DISCCART 650225. 76 4188333. 34
DISCCART 650325. 76 4188333. 34
DISCCART 650425. 76 4188333. 34
DISCCART 650525. 76 4188333. 34
DISCCART 650625. 76 4188333. 34
DISCCART 650725. 76 4188333. 34
DISCCART 650825. 76 4188333. 34
DISCCART 651125. 76 4188333. 34
DISCCART 649125. 76 4188383. 34
DISCCART 649225. 76 4188383. 34
DISCCART 649325. 76 4188383. 34
DISCCART 649425. 76 4188383. 34
DISCCART 649525. 76 4188383. 34
DISCCART 649625. 76 4188383. 34
DISCCART 649725. 76 4188383. 34
DISCCART 649825. 76 4188383. 34
DISCCART 649925. 76 4188383. 34
DISCCART 650025. 76 4188383. 34
DISCCART 650125. 76 4188383. 34
DISCCART 650225. 76 4188383. 34
DISCCART 650325. 76 4188383. 34
DISCCART 650425. 76 4188383. 34
DISCCART 650525. 76 4188383. 34
DISCCART 650625. 76 4188383. 34
DISCCART 650725. 76 4188383. 34
DISCCART 650825. 76 4188383. 34
DISCCART 651125. 76 4188383. 34
DISCCART 649125. 76 4188433. 34
DISCCART 649225. 76 4188433. 34
DISCCART 649325. 76 4188433. 34
DISCCART 649425. 76 4188433. 34
DISCCART 649525. 76 4188433. 34
DISCCART 649625. 76 4188433. 34
DISCCART 649725. 76 4188433. 34
DISCCART 649825. 76 4188433. 34
DISCCART 649925. 76 4188433. 34
DISCCART 650025. 76 4188433. 34
DISCCART 650125. 76 4188433. 34
DISCCART 650225. 76 4188433. 34
DISCCART 650325. 76 4188433. 34
DISCCART 650425. 76 4188433. 34
DISCCART 650525. 76 4188433. 34
DISCCART 650625. 76 4188433. 34
DISCCART 650725. 76 4188433. 34
DISCCART 650825. 76 4188433. 34
DISCCART 651125. 76 4188433. 34
DISCCART 649125. 76 4188483. 34
DISCCART 649225. 76 4188483. 34
DISCCART 649325. 76 4188483. 34
DISCCART 649425. 76 4188483. 34
DISCCART 649525. 76 4188483. 34
DISCCART 649625. 76 4188483. 34
DISCCART 649725. 76 4188483. 34
DISCCART 650425. 76 4188483. 34
DISCCART 650525. 76 4188483. 34
DISCCART 650625. 76 4188483. 34
DISCCART 650725. 76 4188483. 34
DISCCART 650825. 76 4188483. 34
DISCCART 651125. 76 4188483. 34
DISCCART 649125. 76 4188533. 34
DISCCART 649225. 76 4188533. 34
DISCCART 649325. 76 4188533. 34
DISCCART 649425. 76 4188533. 34
DISCCART 649525. 76 4188533. 34
DISCCART 649625. 76 4188533. 34
DISCCART 649725. 76 4188533. 34
DISCCART 650425. 76 4188533. 34
DISCCART 650525. 76 4188533. 34
DISCCART 650625. 76 4188533. 34
DISCCART 650725. 76 4188533. 34
DISCCART 650825. 76 4188533. 34
DISCCART 651125. 76 4188533. 34
DISCCART 649125. 76 4188583. 34
DISCCART 649225. 76 4188583. 34
DISCCART 649325. 76 4188583. 34
DISCCART 649425. 76 4188583. 34
DISCCART 649525. 76 4188583. 34
DISCCART 649625. 76 4188583. 34
DISCCART 649725. 76 4188583. 34
DISCCART 650425. 76 4188583. 34
DISCCART 650525. 76 4188583. 34
DISCCART 650625. 76 4188583. 34
DISCCART 650725. 76 4188583. 34
DISCCART 650825. 76 4188583. 34
DISCCART 651125. 76 4188583. 34
DISCCART 649125. 76 4188633. 34
DISCCART 649225. 76 4188633. 34
DISCCART 649325. 76 4188633. 34
DISCCART 649425. 76 4188633. 34
DISCCART 649525. 76 4188633. 34
DISCCART 649625. 76 4188633. 34
DISCCART 649725. 76 4188633. 34
DISCCART 649825. 76 4188633. 34
DISCCART 649925. 76 4188633. 34
DISCCART 650025. 76 4188633. 34
DISCCART 650125. 76 4188633. 34
DISCCART 650225. 76 4188633. 34
DISCCART 650325. 76 4188633. 34
DISCCART 650425. 76 4188633. 34
DISCCART 650525. 76 4188633. 34
DISCCART 650625. 76 4188633. 34
DISCCART 650725. 76 4188633. 34
DISCCART 650825. 76 4188633. 34
DISCCART 651125. 76 4188633. 34
DISCCART 649125. 76 4188683. 34
DISCCART 649225. 76 4188683. 34
DISCCART 649325. 76 4188683. 34
DISCCART 649425. 76 4188683. 34
DISCCART 649525. 76 4188683. 34
DISCCART 649625. 76 4188683. 34
DISCCART 649725. 76 4188683. 34
DISCCART 649825. 76 4188683. 34
DISCCART 649925. 76 4188683. 34
DISCCART 650025. 76 4188683. 34
DISCCART 650125. 76 4188683. 34
DISCCART 650225. 76 4188683. 34
DISCCART 650325. 76 4188683. 34
DISCCART 650425. 76 4188683. 34
DISCCART 650525. 76 4188683. 34
DISCCART 650625. 76 4188683. 34
DISCCART 650725. 76 4188683. 34
DISCCART 650825. 76 4188683. 34
DISCCART 651125. 76 4188683. 34
DISCCART 649125. 76 4188733. 34
DISCCART 649225. 76 4188733. 34
DISCCART 649325. 76 4188733. 34
DISCCART 649425. 76 4188733. 34
DISCCART 649525. 76 4188733. 34
DISCCART 649625. 76 4188733. 34
DISCCART 649725. 76 4188733. 34
DISCCART 649825. 76 4188733. 34
DISCCART 649925. 76 4188733. 34
DISCCART 650025. 76 4188733. 34
DISCCART 650125. 76 4188733. 34
DISCCART 650225. 76 4188733. 34
DISCCART 650325. 76 4188733. 34
DISCCART 650425. 76 4188733. 34
DISCCART 650525. 76 4188733. 34
DISCCART 650625. 76 4188733. 34
DISCCART 650725. 76 4188733. 34
DISCCART 650825. 76 4188733. 34
DISCCART 651125. 76 4188733. 34
DISCCART 649125. 76 4188783. 34
DISCCART 649225. 76 4188783. 34
DISCCART 649325. 76 4188783. 34
DISCCART 649425. 76 4188783. 34
DISCCART 649525. 76 4188783. 34
DISCCART 649625. 76 4188783. 34
DISCCART 649725. 76 4188783. 34
DISCCART 649825. 76 4188783. 34
DISCCART 649925. 76 4188783. 34
DISCCART 650025. 76 4188783. 34
DISCCART 650125. 76 4188783. 34
DISCCART 650225. 76 4188783. 34
DISCCART 650325. 76 4188783. 34
DISCCART 650425. 76 4188783. 34
DISCCART 650525. 76 4188783. 34
DISCCART 650625. 76 4188783. 34
DISCCART 650725. 76 4188783. 34
DISCCART 650825. 76 4188783. 34
DISCCART 651125. 76 4188783. 34
DISCCART 649125. 76 4188833. 34
DISCCART 649225. 76 4188833. 34
DISCCART 649325. 76 4188833. 34
DISCCART 649425. 76 4188833. 34
DISCCART 649525. 76 4188833. 34
DISCCART 649625. 76 4188833. 34
DISCCART 649725. 76 4188833. 34
DISCCART 649825. 76 4188833. 34
DISCCART 649925. 76 4188833. 34
DISCCART 650025. 76 4188833. 34
DISCCART 650125. 76 4188833. 34
DISCCART 650225. 76 4188833. 34
DISCCART 650325. 76 4188833. 34
DISCCART 650425. 76 4188833. 34
DISCCART 650525. 76 4188833. 34
DISCCART 650625. 76 4188833. 34
DISCCART 650725. 76 4188833. 34
DISCCART 650825. 76 4188833. 34
DISCCART 651125. 76 4188833. 34
DISCCART 649125. 76 4188883. 34
DISCCART 649225. 76 4188883. 34
DISCCART 649325. 76 4188883. 34
DISCCART 649425. 76 4188883. 34
DISCCART 649525. 76 4188883. 34
DISCCART 649625. 76 4188883. 34
DISCCART 649725. 76 4188883. 34
DISCCART 649825. 76 4188883. 34
DISCCART 649925. 76 4188883. 34
DISCCART 650025. 76 4188883. 34
DISCCART 650125. 76 4188883. 34
DISCCART 650225. 76 4188883. 34
DISCCART 650325. 76 4188883. 34
DISCCART 650425. 76 4188883. 34
DISCCART 650525. 76 4188883. 34
DISCCART 650625. 76 4188883. 34
DISCCART 650725. 76 4188883. 34
DISCCART 650825. 76 4188883. 34
DISCCART 651125. 76 4188883. 34
DISCCART 650125. 76 4188933. 34
DISCCART 650225. 76 4188933. 34
DISCCART 650325. 76 4188933. 34
DISCCART 650425. 76 4188933. 34
DISCCART 650525. 76 4188933. 34
DISCCART 650625. 76 4188933. 34
DISCCART 650725. 76 4188933. 34
DISCCART 650825. 76 4188933. 34
DISCCART 651125. 76 4188933. 34
DISCCART 650425. 76 4188983. 34
DISCCART 650525. 76 4188983. 34
DISCCART 650625. 76 4188983. 34
DISCCART 650725. 76 4188983. 34
DISCCART 650825. 76 4188983. 34
DISCCART 651125. 76 4188983. 34
DISCCART 650525. 76 4189033. 34
DISCCART 650625. 76 4189033. 34
DISCCART 650725. 76 4189033. 34
DISCCART 650825. 76 4189033. 34
DISCCART 651125. 76 4189033. 34
DISCCART 650525. 76 4189083. 34
DISCCART 650625. 76 4189083. 34
DISCCART 650725. 76 4189083. 34
DISCCART 650825. 76 4189083. 34
DISCCART 651125. 76 4189083. 34
DISCCART 650525. 76 4189133. 34
DISCCART 650625. 76 4189133. 34
DISCCART 650725. 76 4189133. 34
DISCCART 650825. 76 4189133. 34
DISCCART 651125. 76 4189133. 34
DESCRREC "" ""
DISCCART 650781. 98 4189510. 65
DISCCART 650760. 33 4189397. 50

RE FINISHED
AERMOD Meteorology Pathway

ME STARTING
SURFFILE AERMET\ Stockton 2013- 2017. SFC
PROFFILE AERMET\ Stockton 2013- 2017. PFL
SURFDATA 23237 2013 Stockton_ International_ Airport
UAIRDATA 23230 2013 OAKLAND/ WSO AP
PROFBASE 10. 06 METERS

ME FINISHED
AERMOD Output Pathway

OU STARTING
RECTABLE ALLAVE 15T
RECTABLE 1 1ST
Auto- Generated Plotfiles
PLOTFILE 1 VOL1 1ST " Ashley Warehouse. AD\ 01H1G001. PLT" 31 PLOTFILE 1 VOL2 1ST " Ashley Warehouse. AD\ 01H1G002. PLT" 32 PLOTFILE 1 VOL3 1ST " Ashley Warehouse. AD\ 01H1G003. PLT" 33 PLOTFILE 1 VOL4 15T " Ashley Warehouse. AD\ 01H1G004. PLT" 34 PLOTFILE 1 VOLS 15T " Ashley Warehouse. AD\ 01H1G005. PLT" 35 PLOTFILE 1 VOL6 15T " Ashley Warehouse. AD\ 01H1G006. PLT" 36 PLOTFILE PERIOD VOL1 " Ashley Warehouse. AD\ PE00G001. PLT" 37 PLOTFILE PERIOD VOL2 " Ashley Warehouse. AD\ PE00G002. PLT" 38 PLOTFILE PERIOD VOL3 " Ashley Warehouse. AD\ PE00G003. PLT" 39 PLOTFILE PERIOD VOL4 " Ashley Warehouse. AD\ PE00G004. PLT" 40 PLOTFILE PERIOD VOLS " Ashley Warehouse. AD\ PE00G005. PLT" 41 PLOTFILE PERIOD VOL6 " Ashley Warehouse. AD\ PE00G006. PLT" 42 SUMMFILE " Ashley Warehouse. sum"

OU FINISHED
Message Summary For AERMOD Model Setup ***
Summary of Total Messages --------
A Total of 0 Fatal Error Message( s)
A Total of 8 Warning Message( s)
A Total of 0 Informational Message( s)
FATAL ERROR MESSAGES ********
NONE ***
WARNING MESSAGES ********
SO W320 48 VPARM: Input Parameter May Be Out- of- Range for Parameter SZINIT
SO W320 49 VPARM: Input Parameter May Be Out- of- Range for Parameter SZINIT
SO W320 50 VPARM: Input Parameter May Be Out- of- Range for Parameter SZINIT
SO W320 51 VPARM: Input Parameter May Be Out- of- Range for Parameter SZINIT
SO W320 52 VPARM: Input Parameter May Be Out- of- Range for Parameter SZINIT
SO W320 53 VPARM: Input Parameter May Be Out- of- Range for Parameter SZINIT
ME W186 454 MEOPEN: THRESH_ 1MIN 1- min ASOS wind speed threshold used

0. 50
ME W187 454 MEOPEN: ADJ_ U* Option for Stable Low Winds used in AERMET SETUP Finishes Successfully ***
T *** AERMOD - VERSION 19191 *** *** C:\ Users\ Smith\ Dropbox\ My PC DESKTOP- 977GSBU)\ Documents\ HRA\ Ashley *** 10/ 26/ 23 AERMET - VERSION 18081 *** ***
16: 20: 52
PAGE 1
MODELOPTs: NonDFAULT CONC FLAT RURAL ADJ U*

MODEL SETUP OPTIONS SUMMARY
Model Is Setup For Calculation of Average CONCentration Values.

DEPOSITION LOGIC --
NO GAS DEPOSITION Data Provided.

NO PARTICLE DEPOSITION Data Provided.

Model Uses NO DRY DEPLETION. DRYDPLT = F
Model Uses NO WET DEPLETION. WETDPLT = F
Model Uses RURAL Dispersion Only.

Model Allows User- Specified Options:

1. Stack- tip Downwash.

2. Model Assumes Receptors on FLAT Terrain.

3. Use Calms Processing Routine.

4. Use Missing Data Processing Routine.

5. No Exponential Decay.

Other Options Specified:

ADJ_ U* - Use ADJ_ U* option for SBL in AERMET
CCVR_ Sub - Meteorological data includes CCVR substitutions TEMP_ Sub - Meteorological data includes TEMP substitutions Model Assumes No FLAGPOLE Receptor Heights.

The User Specified a Pollutant Type of: OTHER
Model Calculates 1 Short Term Average( s) of: 1- HR
and Calculates PERIOD Averages
This Run Includes: 6 Source( s); 6 Source Group( s); and 370 Receptor( s)
with: 0 POINT( s), including
0 POINTCAP( s) and 0 POINTHOR( s)
and: 6 VOLUME source( s)
and: 0 AREA type source( s)
and: 0 LINE source( s)
and: 0 RLINE/ RLINEXT source( s)
and: 0 OPENPIT source( s)
and: 0 BUOYANT LINE source( s) with 0 line( s)
Model Set To Continue RUNning After the Setup Testing.

The AERMET Input Meteorological Data Version Date: 18081 Output Options Selected:

Model Outputs Tables of PERIOD Averages by Receptor
Model Outputs Tables of Highest Short Term Values by Receptor ( RECTABLE Keyword)
Model Outputs External File( s) of High Values for Plotting ( PLOTFILE Keyword)
Model Outputs Separate Summary File of High Ranked Values ( SUMMFILE Keyword)
NOTE: The Following Flags May Appear Following CONC Values: c for Calm Hours m for Missing
Hours
b for Both Calm
and Missing Hours
Misc. Inputs: Base Elev. for Pot. Temp. Profile ( m MSL) = 10. 06 ; Decay Coef. = 0. 000 Rot. Angle = 0. 0
Emission Units = GRAMS/ SEC
Emission Rate Unit Factor = 0. 10000E+ 07
Output Units = MICROGRAMS/ M** 3
Approximate Storage Requirements of Model = 3. 6 MB of RAM.

Input Runstream File: aermod. inp
Output Print File: aermod. out
Detailed Error/ Message File: Ashley Warehouse. err
File for Summary of Results: Ashley Warehouse. sum
T *** AERMOD - VERSION 19191 *** *** C:\ Users\ Smith\ Dropbox\ My PC DESKTOP- 977GSBU)\ Documents\ HRA\ Ashley *** 10/ 26/ 23 AERMET - VERSION 18081 *** ***
16: 20: 52
PAGE 2
MODELOPTs: NonDFAULT CONC FLAT RURAL ADJ U*
VOLUME SOURCE DATA ***
NUMBER EMISSION RATE BASE RELEASE INIT.

INIT. URBAN EMISSION RATE
SOURCE PART. ( GRAMS/ SEC) X Y ELEV. HEIGHT SY

SZ SOURCE SCALAR VARY
ID CATS. METERS) ( METERS) ( METERS) ( METERS) ( METERS)

METERS) BY
VOL1 0 0. 10000E+ 01 650380. 0 4188444. 7 10. 1 3. 05 35. 24

0. 00 NO
VOL2 0 0. 10000E+ 01 649783. 8 4188428. 6 10. 1 3. 05 35. 24

0. 00 NO
VOL3 0 0. 10000E+ 01 649783. 8 4188630. 7 10. 1 3. 05 35. 51

0. 00 NO
VOL4 0 0. 10000E+ 01 650380. 0 4188635. 7 10. 1 3. 05 36. 48

0. 00 NO
VOLS 0 0. 10000E+ 01 650090. 1 4188630. 4 10. 1 3. 05 35. 25

0. 00 NO
VOL6 0 0. 10000E+ 01 650096. 7 4188433. 8 10. 1 3. 05 37. 37

0. 00 NO
T *** AERMOD - VERSION 19191 *** *** C:\ Users\ Smith\ Dropbox\ My PC DESKTOP- 977GSBU)\ Documents\ HRA\ Ashley *** 10/ 26/ 23 AERMET - VERSION 18081 *** ***
16: 20: 52
PAGE 3
MODELOPTs: NonDFAULT CONC FLAT RURAL ADJ U*
SOURCE IDs DEFINING SOURCE GROUPS
SRCGROUP ID SOURCE IDs
VOL1 VOL1
VOL2 VOL2
VOL3 VOL3
VOL4 VOL4

VOLS VOLS
VOL6 VOL6
T *** AERMOD - VERSION 19191 *** *** C:\ Users\ Smith\ Dropbox\ My PC DESKTOP- 977GSBU)\ Documents\ HRA\ Ashley *** 10/ 26/ 23 AERMET - VERSION 18081 *** ***
16: 20: 52
PAGE 4
MODELOPTs: NonDFAULT CONC FLAT RURAL ADJ U*
DISCRETE CARTESIAN RECEPTORS ***

X- COORD, Y- COORD, ZELEV, ZHILL, ZFLAG)

METERS)
649676. 3, 4188314. 5, 10. 1, 10. 1, 0. 0); 649629. 7,
4188294. 8, 10. 1, 10. 1, 0. 0);
649810. 2, 4188312. 5, 10. 1, 10. 1, 0. 0); 649364. 1,
4188360. 2, 10. 1, 10. 1, 0. 0);
649327. 8, 4188355. 0, 10. 1, 10. 1, 0. 0); 649380. 7,
4188758. 5, 10. 1, 10. 1, 0. 0);
650495. 8, 4188841. 5, 10. 1, 10. 1, 0. 0); 650597. 5,
4188832. 2, 10. 1, 10. 1, 0. 0);
650536. 3, 4188878. 8, 10. 1, 10. 1, 0. 0); 650577. 8,
4188877. 8, 10. 1, 10. 1, 0. 0);
650602. 7, 4188860. 2, 10. 1, 10. 1, 0. 0); 650611. 0,
4188880. 9, 10. 1, 10. 1, 0. 0);
650638. 1, 4188858. 5, 10. 1, 10. 1, 0. 0); 650664. 1,
4188331. 0, 10. 1, 10. 1, 0. 0);
650668. 7, 4188350. 8, 10. 1, 10. 1, 0. 0); 650678. 0,
4188379. 9, 10. 1, 10. 1, 0. 0);
650699. 7, 4188414. 8, 10. 1, 10. 1, 0. 0); 650758. 5,
4188658. 4, 10. 1, 10. 1, 0. 0);
650765. 7, 4188678. 8, 10. 1, 10. 1, 0. 0); 650773. 7,
4188706. 5, 10. 1, 10. 1, 0. 0);
650778. 3, 4188726. 3, 10. 1, 10. 1, 0. 0); 650805. 3,
4188183. 3, 10. 1, 10. 1, 0. 0);
649225. 8, 4188183. 3, 10. 1, 10. 1, 0. 0); 649325. 8,
4188183. 3, 10. 1, 10. 1, 0. 0);
649425. 8, 4188183. 3, 10. 1, 10. 1, 0. 0); 649525. 8,
4188183. 3, 10. 1, 10. 1, 0. 0);
649625. 8, 4188183. 3, 10. 1, 10. 1, 0. 0); 649725. 8,
4188183. 3, 10. 1, 10. 1, 0. 0);
649825. 8, 4188183. 3, 10. 1, 10. 1, 0. 0); 649925. 8,
4188183. 3, 10. 1, 10. 1, 0. 0);
650025. 8, 4188183. 3, 10. 1, 10. 1, 0. 0); 650125. 8,
4188183. 3, 10. 1, 10. 1, 0. 0);
650225. 8, 4188183. 3, 10. 1, 10. 1, 0. 0); 650325. 8,
4188183. 3, 10. 1, 10. 1, 0. 0);
650425. 8, 4188183. 3, 10. 1, 10. 1, 0. 0); 650525. 8,
4188183. 3, 10. 1, 10. 1, 0. 0);
650625. 8, 4188183. 3, 10. 1, 10. 1, 0. 0); 650725. 8,
4188183. 3, 10. 1, 10. 1, 0. 0);
650825. 8, 4188183. 3, 10. 1, 10. 1, 0. 0); 651125. 8,
4188183. 3, 10. 1, 10. 1, 0. 0);
T *** AERMOD - VERSION 19191 *** *** C:\ Users\ Smith\ Dropbox\ My PC DESKTOP- 977GSBU)\ Documents\ HRA\ Ashley *** 10/ 26/ 23 AERMET - VERSION 18081 *** ***
16: 20: 52
PAGE 5
MODELOPTs: NonDFAULT CONC FLAT RURAL ADJ U*
DISCRETE CARTESIAN RECEPTORS ***

X- COORD, Y- COORD, ZELEV, ZHILL, ZFLAG)

METERS)
649125. 8, 4188233. 3, 10. 1, 10. 1, 0. 0); 649225. 8,
4188233. 3, 10. 1, 10. 1, 0. 0);
649325. 8, 4188233. 3, 10. 1, 10. 1, 0. 0); 649425. 8,
4188233. 3, 10. 1, 10. 1, 0. 0);
649525. 8, 4188233. 3, 10. 1, 10. 1, 0. 0); 649625. 8,
4188233. 3, 10. 1, 10. 1, 0. 0);
649725. 8, 4188233. 3, 10. 1, 10. 1, 0. 0); 649825. 8,
4188233. 3, 10. 1, 10. 1, 0. 0);
649925. 8, 4188233. 3, 10. 1, 10. 1, 0. 0); 650025. 8,
4188233. 3, 10. 1, 10. 1, 0. 0);
650125. 8, 4188233. 3, 10. 1, 10. 1, 0. 0); 650225. 8,
4188233. 3, 10. 1, 10. 1, 0. 0);
650325. 8, 4188233. 3, 10. 1, 10. 1, 0. 0); 650425. 8,
4188233. 3, 10. 1, 10. 1, 0. 0);
650525. 8, 4188233. 3, 10. 1, 10. 1, 0. 0); 650625. 8,
4188233. 3, 10. 1, 10. 1, 0. 0);
650725. 8, 4188233. 3, 10. 1, 10. 1, 0. 0); 650825. 8,
4188233. 3, 10. 1, 10. 1, 0. 0);
651125. 8, 4188233. 3, 10. 1, 10. 1, 0. 0); 649125. 8,
4188283. 3, 10. 1, 10. 1, 0. 0);
649225. 8, 4188283. 3, 10. 1, 10. 1, 0. 0); 649325. 8,
4188283. 3, 10. 1, 10. 1, 0. 0);
649425. 8, 4188283. 3, 10. 1, 10. 1, 0. 0); 649525. 8,
4188283. 3, 10. 1, 10. 1, 0. 0);
649625. 8, 4188283. 3, 10. 1, 10. 1, 0. 0); 649725. 8,
4188283. 3, 10. 1, 10. 1, 0. 0);
649825. 8, 4188283. 3, 10. 1, 10. 1, 0. 0); 649925. 8,
4188283. 3, 10. 1, 10. 1, 0. 0);
650025. 8, 4188283. 3, 10. 1, 10. 1, 0. 0); 650125. 8,
4188283. 3, 10. 1, 10. 1, 0. 0);
650225. 8, 4188283. 3, 10. 1, 10. 1, 0. 0); 650325. 8,
4188283. 3, 10. 1, 10. 1, 0. 0);
650425. 8, 4188283. 3, 10. 1, 10. 1, 0. 0); 650525. 8,
4188283. 3, 10. 1, 10. 1, 0. 0);
650625. 8, 4188283. 3, 10. 1, 10. 1, 0. 0); 650725. 8,
4188283. 3, 10. 1, 10. 1, 0. 0);
650825. 8, 4188283. 3, 10. 1, 10. 1, 0. 0); 651125. 8,
4188283. 3, 10. 1, 10. 1, 0. 0);
649125. 8, 4188333. 3, 10. 1, 10. 1, 0. 0); 649225. 8,
4188333. 3, 10. 1, 10. 1, 0. 0);
649325. 8, 4188333. 3, 10. 1, 10. 1, 0. 0); 649425. 8,
4188333. 3, 10. 1, 10. 1, 0. 0);
649525. 8, 4188333. 3, 10. 1, 10. 1, 0. 0); 649625. 8,
4188333. 3, 10. 1, 10. 1, 0. 0);
649725. 8, 4188333. 3, 10. 1, 10. 1, 0. 0); 649825. 8,
4188333. 3, 10. 1, 10. 1, 0. 0);
649925. 8, 4188333. 3, 10. 1, 10. 1, 0. 0); 650025. 8,
4188333. 3, 10. 1, 10. 1, 0. 0);
650125. 8, 4188333. 3, 10. 1, 10. 1, 0. 0); 650225. 8,
4188333. 3, 10. 1, 10. 1, 0. 0);
650325. 8, 4188333. 3, 10. 1, 10. 1, 0. 0); 650425. 8,
4188333. 3, 10. 1, 10. 1, 0. 0);
650525. 8, 4188333. 3, 10. 1, 10. 1, 0. 0); 650625. 8,
4188333. 3, 10. 1, 10. 1, 0. 0);
650725. 8, 4188333. 3, 10. 1, 10. 1, 0. 0); 650825. 8,
4188333. 3, 10. 1, 10. 1, 0. 0);
651125. 8, 4188333. 3, 10. 1, 10. 1, 0. 0); 649125. 8,
4188383. 3, 10. 1, 10. 1, 0. 0);
649225. 8, 4188383. 3, 10. 1, 10. 1, 0. 0); 649325. 8,
4188383. 3, 10. 1, 10. 1, 0. 0);
649425. 8, 4188383. 3, 10. 1, 10. 1, 0. 0); 649525. 8,
4188383. 3, 10. 1, 10. 1, 0. 0);
649625. 8, 4188383. 3, 10. 1, 10. 1, 0. 0); 649725. 8,
4188383. 3, 10. 1, 10. 1, 0. 0);
649825. 8, 4188383. 3, 10. 1, 10. 1, 0. 0); 649925. 8,
4188383. 3, 10. 1, 10. 1, 0. 0);
650025. 8, 4188383. 3, 10. 1, 10. 1, 0. 0); 650125. 8,
4188383. 3, 10. 1, 10. 1, 0. 0);
650225. 8, 4188383. 3, 10. 1, 10. 1, 0. 0); 650325. 8,
4188383. 3, 10. 1, 10. 1, 0. 0);
650425. 8, 4188383. 3, 10. 1, 10. 1, 0. 0); 650525. 8,
4188383. 3, 10. 1, 10. 1, 0. 0);
650625. 8, 4188383. 3, 10. 1, 10. 1, 0. 0); 650725. 8,
4188383. 3, 10. 1, 10. 1, 0. 0);
650825. 8, 4188383. 3, 10. 1, 10. 1, 0. 0); 651125. 8,
4188383. 3, 10. 1, 10. 1, 0. 0);
649125. 8, 4188433. 3, 10. 1, 10. 1, 0. 0); 649225. 8,
4188433. 3, 10. 1, 10. 1, 0. 0);
649325. 8, 4188433. 3, 10. 1, 10. 1, 0. 0); 649425. 8,
4188433. 3, 10. 1, 10. 1, 0. 0);
649525. 8, 4188433. 3, 10. 1, 10. 1, 0. 0); 649625. 8,
4188433. 3, 10. 1, 10. 1, 0. 0);
649725. 8, 4188433. 3, 10. 1, 10. 1, 0. 0); 649825. 8,
4188433. 3, 10. 1, 10. 1, 0. 0);
649925. 8, 4188433. 3, 10. 1, 10. 1, 0. 0); 650025. 8,
4188433. 3, 10. 1, 10. 1, 0. 0);
650125. 8, 4188433. 3, 10. 1, 10. 1, 0. 0); 650225. 8,
4188433. 3, 10. 1, 10. 1, 0. 0);
650325. 8, 4188433. 3, 10. 1, 10. 1, 0. 0); 650425. 8,
4188433. 3, 10. 1, 10. 1, 0. 0);
T *** AERMOD - VERSION 19191 *** *** C:\ Users\ Smith\ Dropbox\ My PC DESKTOP- 977GSBU)\ Documents\ HRA\ Ashley *** 10/ 26/ 23 AERMET - VERSION 18081 *** ***
16: 20: 52
PAGE 6
MODELOPTs: NonDFAULT CONC FLAT RURAL AD] U*
DISCRETE CARTESIAN RECEPTORS ***

X- COORD, Y- COORD, ZELEV, ZHILL, ZFLAG)

METERS)
650525. 8, 4188433. 3, 10. 1, 10. 1, 0. 0); 650625. 8,
4188433. 3, 10. 1, 10. 1, 0. 0);
650725. 8, 4188433. 3, 10. 1, 10. 1, 0. 0); 650825. 8,
4188433. 3, 10. 1, 10. 1, 0. 0);
651125. 8, 4188433. 3, 10. 1, 10. 1, 0. 0); 649125. 8,
4188483. 3, 10. 1, 10. 1, 0. 0);
649225. 8, 4188483. 3, 10. 1, 10. 1, 0. 0); 649325. 8,
4188483. 3, 10. 1, 10. 1, 0. 0);
649425. 8, 4188483. 3, 10. 1, 10. 1, 0. 0); 649525. 8,
4188483. 3, 10. 1, 10. 1, 0. 0);
649625. 8, 4188483. 3, 10. 1, 10. 1, 0. 0); 649725. 8,
4188483. 3, 10. 1, 10. 1, 0. 0);
650425. 8, 4188483. 3, 10. 1, 10. 1, 0. 0); 650525. 8,
4188483. 3, 10. 1, 10. 1, 0. 0);
650625. 8, 4188483. 3, 10. 1, 10. 1, 0. 0); 650725. 8,
4188483. 3, 10. 1, 10. 1, 0. 0);
650825. 8, 4188483. 3, 10. 1, 10. 1, 0. 0); 651125. 8,
4188483. 3, 10. 1, 10. 1, 0. 0);
649125. 8, 4188533. 3, 10. 1, 10. 1, 0. 0); 649225. 8,
4188533. 3, 10. 1, 10. 1, 0. 0);
649325. 8, 4188533. 3, 10. 1, 10. 1, 0. 0); 649425. 8,
4188533. 3, 10. 1, 10. 1, 0. 0);
649525. 8, 4188533 3, 10. 1, 10. 1, 0. 0); 649625. 8,
4188533. 3, 10. 1, 10. 1, 0. 0);
649725. 8, 4188533. 3, 10. 1, 10. 1, 0. 0); 650425. 8,
4188533. 3, 10. 1, 10. 1, 0. 0);
650525. 8, 4188533. 3, 10. 1, 10. 1, 0. 0); 650625. 8,
4188533. 3, 10. 1, 10. 1, 0. 0);
650725. 8, 4188533. 3, 10. 1, 10. 1, 0. 0); 650825. 8,
4188533. 3, 10. 1, 10. 1, 0. 0);
651125. 8, 4188533. 3, 10. 1, 10. 1, 0. 0); 649125. 8,
4188583. 3, 10. 1, 10. 1, 0. 0);
649225. 8, 4188583. 3, 10. 1, 10. 1, 0. 0); 649325. 8,
4188583. 3, 10. 1, 10. 1, 0. 0);
649425. 8, 4188583. 3, 10. 1, 10. 1, 0. 0); 649525. 8,
4188583. 3, 10. 1, 10. 1, 0. 0);
649625. 8, 4188583. 3, 10. 1, 10. 1, 0. 0); 649725. 8,
4188583. 3, 10. 1, 10. 1, 0. 0);
650425. 8, 4188583. 3, 10. 1, 10. 1, 0. 0); 650525. 8,
4188583. 3, 10. 1, 10. 1, 0. 0);
650625. 8, 4188583. 3, 10. 1, 10. 1, 0. 0); 650725. 8,
4188583. 3, 10. 1, 10. 1, 0. 0);
650825. 8, 4188583. 3, 10. 1, 10. 1, 0. 0); 651125. 8,
4188583. 3, 10. 1, 10. 1, 0. 0);
649125. 8, 4188633. 3, 10. 1, 10. 1, 0. 0); 649225. 8,
4188633. 3, 10. 1, 10. 1, 0. 0);
649325. 8, 4188633. 3, 10. 1, 10. 1, 0. 0); 649425. 8,
4188633. 3, 10. 1, 10. 1, 0. 0);
649525. 8, 4188633. 3, 10. 1, 10. 1, 0. 0); 649625. 8,
4188633. 3, 10. 1, 10. 1, 0. 0);
649725. 8, 4188633. 3, 10. 1, 10. 1, 0. 0); 649825. 8,
4188633. 3, 10. 1, 10. 1, 0. 0);
649925. 8, 4188633. 3, 10. 1, 10. 1, 0. 0); 650025. 8,
4188633. 3, 10. 1, 10. 1, 0. 0);
650125. 8, 4188633. 3, 10. 1, 10. 1, 0. 0); 650225. 8,
4188633. 3, 10. 1, 10. 1, 0. 0);
650325. 8, 4188633. 3, 10. 1, 10. 1, 0. 0); 650425. 8,
4188633. 3, 10. 1, 10. 1, 0. 0);
650525. 8, 4188633. 3, 10. 1, 10. 1, 0. 0); 650625. 8,
4188633. 3, 10. 1, 10. 1, 0. 0);
650725. 8, 4188633. 3, 10. 1, 10. 1, 0. 0); 650825. 8,
4188633. 3, 10. 1, 10. 1, 0. 0);
651125. 8, 4188633. 3, 10. 1, 10. 1, 0. 0); 649125. 8,
4188683. 3, 10. 1, 10. 1, 0. 0);
649225. 8, 4188683. 3, 10. 1, 10. 1, 0. 0); 649325. 8,
4188683. 3, 10. 1, 10. 1, 0. 0);
649425. 8, 4188683. 3, 10. 1, 10. 1, 0. 0); 649525. 8,
4188683. 3, 10. 1, 10. 1, 0. 0);
649625. 8, 4188683. 3, 10. 1, 10. 1, 0. 0); 649725. 8,
4188683. 3, 10. 1, 10. 1, 0. 0);
649825. 8, 4188683. 3, 10. 1, 10. 1, 0. 0); 649925. 8,
4188683. 3, 10. 1, 10. 1, 0. 0);
650025. 8, 4188683. 3, 10. 1, 10. 1, 0. 0); 650125. 8,
4188683. 3, 10. 1, 10. 1, 0. 0);
650225. 8, 4188683. 3, 10. 1, 10. 1, 0. 0); 650325. 8,
4188683. 3, 10. 1, 10. 1, 0. 0);
650425. 8, 4188683. 3, 10. 1, 10. 1, 0. 0); 650525. 8,
4188683. 3, 10. 1, 10. 1, 0. 0);
650625. 8, 4188683. 3, 10. 1, 10. 1, 0. 0); 650725. 8,
4188683. 3, 10. 1, 10. 1, 0. 0);
650825. 8, 4188683. 3, 10. 1, 10. 1, 0. 0); 651125. 8,
4188683. 3, 10. 1, 10. 1, 0. 0);
649125. 8, 4188733. 3, 10. 1, 10. 1, 0. 0); 649225. 8,
4188733. 3, 10. 1, 10. 1, 0. 0);
649325. 8, 4188733. 3, 10. 1, 10. 1, 0. 0); 649425. 8,
4188733. 3, 10. 1, 10. 1, 0. 0);
649525. 8, 4188733. 3, 10. 1, 10. 1, 0. 0); 649625. 8,
4188733. 3, 10. 1, 10. 1, 0. 0);
649725. 8, 4188733. 3, 10. 1, 10. 1, 0. 0); 649825. 8,
4188733. 3, 10. 1, 10. 1, 0. 0);
T *** AERMOD - VERSION 19191 *** *** C:\ Users\ Smith\ Dropbox\ My PC DESKTOP- 977GSBU)\ Documents\ HRA\ Ashley *** 10/ 26/ 23 AERMET - VERSION 18081 *** ***
16: 20: 52
PAGE 7
MODELOPTs: NonDFAULT CONC FLAT RURAL ADJ U*
DISCRETE CARTESIAN RECEPTORS ***

X- COORD, Y- COORD, ZELEV, ZHILL, ZFLAG)

METERS)
649925. 8, 4188733. 3, 10. 1, 10. 1, 0. 0); 650025. 8,
4188733. 3, 10. 1, 10. 1, 0. 0);
650125. 8, 4188733. 3, 10. 1, 10. 1, 0. 0); 650225. 8,
4188733. 3, 10. 1, 10. 1, 0. 0);
650325. 8, 4188733. 3, 10. 1, 10. 1, 0. 0); 650425. 8,
4188733. 3, 10. 1, 10. 1, 0. 0);
650525. 8, 4188733. 3, 10. 1, 10. 1, 0. 0); 650625. 8,
4188733. 3, 10. 1, 10. 1, 0. 0);
650725. 8, 4188733. 3, 10. 1, 10. 1, 0. 0); 650825. 8,
4188733. 3, 10. 1, 10. 1, 0. 0);
651125. 8, 4188733. 3, 10. 1, 10. 1, 0. 0); 649125. 8,
4188783. 3, 10. 1, 10. 1, 0. 0);
649225. 8, 4188783. 3, 10. 1, 10. 1, 0. 0); 649325. 8,
4188783. 3, 10. 1, 10. 1, 0. 0);
649425. 8, 4188783. 3, 10. 1, 10. 1, 0. 0); 649525. 8,
4188783. 3, 10. 1, 10. 1, 0. 0);
649625. 8, 4188783. 3, 10. 1, 10. 1, 0. 0); 649725. 8,
4188783. 3, 10. 1, 10. 1, 0. 0);
649825. 8, 4188783. 3, 10. 1, 10. 1, 0. 0); 649925. 8,
4188783. 3, 10. 1, 10. 1, 0. 0);
650025. 8, 4188783. 3, 10. 1, 10. 1, 0. 0); 650125. 8,
4188783. 3, 10. 1, 10. 1, 0. 0);
650225. 8, 4188783. 3, 10. 1, 10. 1, 0. 0); 650325. 8,
4188783. 3, 10. 1, 10. 1, 0. 0);
650425. 8, 4188783. 3, 10. 1, 10. 1, 0. 0); 650525. 8,
4188783. 3, 10. 1, 10. 1, 0. 0);
650625. 8, 4188783. 3, 10. 1, 10. 1, 0. 0); 650725. 8,
4188783. 3, 10. 1, 10. 1, 0. 0);
650825. 8, 4188783. 3, 10. 1, 10. 1, 0. 0); 651125. 8,
4188783. 3, 10. 1, 10. 1, 0. 0);
649125. 8, 4188833. 3, 10. 1, 10. 1, 0. 0); 649225. 8,
4188833. 3, 10. 1, 10. 1, 0. 0);
649325. 8, 4188833. 3, 10. 1, 10. 1, 0. 0); 649425. 8,
4188833. 3, 10. 1, 10. 1, 0. 0);
649525. 8, 4188833. 3, 10. 1, 10. 1, 0. 0); 649625. 8,
4188833. 3, 10. 1, 10. 1, 0. 0);
649725. 8, 4188833. 3, 10. 1, 10. 1, 0. 0); 649825. 8,
4188833. 3, 10. 1, 10. 1, 0. 0);
649925. 8, 4188833. 3, 10. 1, 10. 1, 0. 0); 650025. 8,
4188833. 3, 10. 1, 10. 1, 0. 0);
650125. 8, 4188833. 3, 10. 1, 10. 1, 0. 0); 650225. 8,
4188833. 3, 10. 1, 10. 1, 0. 0);
650325. 8, 4188833. 3, 10. 1, 10. 1, 0. 0); 650425. 8,
4188833. 3, 10. 1, 10. 1, 0. 0);
650525. 8, 4188833. 3, 10. 1, 10. 1, 0. 0); 650625. 8,
4188833. 3, 10. 1, 10. 1, 0. 0);
650725. 8, 4188833. 3, 10. 1, 10. 1, 0. 0); 650825. 8,
4188833. 3, 10. 1, 10. 1, 0. 0);
651125. 8, 4188833. 3, 10. 1, 10. 1, 0. 0); 649125. 8,
4188883. 3, 10. 1, 10. 1, 0. 0);
649225. 8, 4188883. 3, 10. 1, 10. 1, 0. 0); 649325. 8,
4188883. 3, 10. 1, 10. 1, 0. 0);
649425. 8, 4188883. 3, 10. 1, 10. 1, 0. 0); 649525. 8,
4188883. 3, 10. 1, 10. 1, 0. 0);
649625. 8, 4188883. 3, 10. 1, 10. 1, 0. 0); 649725. 8,
4188883. 3, 10. 1, 10. 1, 0. 0);
649825. 8, 4188883. 3, 10. 1, 10. 1, 0. 0); 649925. 8,
4188883. 3, 10. 1, 10. 1, 0. 0);
650025. 8, 4188883. 3, 10. 1, 10. 1, 0. 0); 650125. 8,
4188883. 3, 10. 1, 10. 1, 0. 0);
650225. 8, 4188883. 3, 10. 1, 10. 1, 0. 0); 650325. 8,
4188883. 3, 10. 1, 10. 1, 0. 0);
650425. 8, 4188883. 3, 10. 1, 10. 1, 0. 0); 650525. 8,
4188883. 3, 10. 1, 10. 1, 0. 0);
650625. 8, 4188883. 3, 10. 1, 10. 1, 0. 0); 650725. 8,
4188883. 3, 10. 1, 10. 1, 0. 0);
650825. 8, 4188883. 3, 10. 1, 10. 1, 0. 0); 651125. 8,
4188883. 3, 10. 1, 10. 1, 0. 0);
650125. 8, 4188933. 3, 10. 1, 10. 1, 0. 0); 650225. 8,
4188933. 3, 10. 1, 10. 1, 0. 0);
650325. 8, 4188933. 3, 10. 1, 10. 1, 0. 0); 650425. 8,
4188933. 3, 10. 1, 10. 1, 0. 0);
650525. 8, 4188933. 3, 10. 1, 10. 1, 0. 0); 650625. 8,
4188933. 3, 10. 1, 10. 1, 0. 0);
650725. 8, 4188933. 3, 10. 1, 10. 1, 0. 0); 650825. 8,
4188933. 3, 10. 1, 10. 1, 0. 0);
651125. 8, 4188933. 3, 10. 1, 10. 1, 0. 0); 650425. 8,
4188983. 3, 10. 1, 10. 1, 0. 0);
650525. 8, 4188983. 3, 10. 1, 10. 1, 0. 0); 650625. 8,
4188983. 3, 10. 1, 10. 1, 0. 0);
650725. 8, 4188983. 3, 10. 1, 10. 1, 0. 0); 650825. 8,
4188983. 3, 10. 1, 10. 1, 0. 0);
651125. 8, 4188983. 3, 10. 1, 10. 1, 0. 0); 650525. 8,
4189033. 3, 10. 1, 10. 1, 0. 0);
650625. 8, 4189033. 3, 10. 1, 10. 1, 0. 0); 650725. 8,
4189033. 3, 10. 1, 10. 1, 0. 0);
650825. 8, 4189033. 3, 10. 1, 10. 1, 0. 0); 651125. 8,
4189033. 3, 10. 1, 10. 1, 0. 0);
650525. 8, 4189083. 3, 10. 1, 10. 1, 0. 0); 650625. 8,
4189083. 3, 10. 1, 10. 1, 0. 0);
T *** AERMOD - VERSION 19191 *** *** C:\ Users\ Smith\ Dropbox\ My PC DESKTOP- 977GSBU)\ Documents\ HRA\ Ashley *** 10/ 26/ 23 AERMET - VERSION 18081 *** ***
16: 20: 52
PAGE 8
MODELOPTs: NonDFAULT CONC FLAT RURAL ADJ U*
DISCRETE CARTESIAN RECEPTORS ***

X- COORD, Y- COORD, ZELEV, ZHILL, ZFLAG)

METERS)
650725. 8, 4189083. 3, 10. 1, 10. 1, 0. 0); 650825. 8,
4189083. 3, 10. 1, 10. 1, 0. 0);
651125. 8, 4189083. 3, 10. 1, 10. 1, 0. 0); 650525. 8,
4189133. 3, 10. 1, 10. 1, 0. 0);
650625. 8, 4189133. 3, 10. 1, 10. 1, 0. 0); 650725. 8,
4189133. 3, 10. 1, 10. 1, 0. 0);
650825. 8, 4189133. 3, 10. 1, 10. 1, 0. 0); 651125. 8,
4189133. 3, 10. 1, 10. 1, 0. 0);
650782. 0, 4189510. 6, 10. 1, 10. 1, 0. 0); 650760. 3,
4189397. 5, 10. 1, 10. 1, 0. 0);
T *** AERMOD - VERSION 19191 *** *** C:\ Users\ Smith\ Dropbox\ My PC DESKTOP- 977GSBU)\ Documents\ HRA\ Ashley *** 10/ 26/ 23 AERMET - VERSION 18081 *** ***
16: 20: 52
PAGE 9
MODELOPTs: NonDFAULT CONC FLAT RURAL ADJ U*

SOURCE- RECEPTOR COMBINATIONS FOR WHICH CALCULATIONS MAY NOT BE PERFORMED *
LESS THAN 1. 0 METER; WITHIN OPENPIT; OR BEYOND 80KM FOR

FASTAREA/ FASTALL

SOURCE RECEPTOR LOCATION - -

DISTANCE

ID XR ( METERS) YR ( METERS)

METERS)
VOL1 650425. 8 4188383. 3

0. 75
VOL1 650325. 8 4188433. 3

20. 36
VOL1 650425. 8 4188433. 3

28. 62
VOL1 650425. 8 4188483. 3

15. 85
VOL2 649725. 8 4188383. 3

2. 18
VOL2 649825. 8 4188383. 3

14. 01
VOL2 649725. 8 4188433. 3

17. 56
VOL2 649825. 8 4188433. 3

33. 51
VOL3 649725. 8 4188583. 3

1. 49
VOL3 649725. 8 4188633. 3

18. 28
VOL3 649825. 8 4188633. 3

34. 28
VOL3 649825. 8 4188683. 3

8. 99
VOL4 650425. 8 4188583. 3

8. 89
VOL4 650325. 8 4188633. 3

24. 14
VOL4 650425. 8 4188633. 3

32. 61
VOL4 650325. 8 4188683. 3

6. 25
VOL4 650425. 8 4188683. 3

12. 38
VOLS 650025. 8 4188633. 3

11. 37
VOLS 650125. 8 4188633. 3

40. 03
VOLS 650125. 8 4188683. 3

11. 96
VOL6 650125. 8 4188383. 3

22. 10
VOL6 650025. 8 4188433. 3

9. 41
VOL6 650125. 8 4188433. 3

51. 27
T *** AERMOD - VERSION 19191 *** *** C:\ Users\ Smith\ Dropbox\ My PC DESKTOP- 977GSBU)\ Documents\ HRA\ Ashley *** 10/ 26/ 23 AERMET - VERSION 18081 *** ***
16: 20: 52
PAGE 10
MODELOPTs: NonDFAULT CONC FLAT RURAL ADJ U*

METEOROLOGICAL DAYS SELECTED FOR
PROCESSING ***
1= YES; 0= N0)
1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1
1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1
1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1
1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1
1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1
1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1
1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1
1 1 1 1 1 1 1 1 1 1 1 1 1 1 1
NOTE: METEOROLOGICAL DATA ACTUALLY PROCESSED WILL AL50 DEPEND ON WHAT IS INCLUDED IN THE DATA FILE.

UPPER BOUND OF FIRST THROUGH FIFTH WIND SPEED
CATEGORIES ***

METERS/ SEC)

1. 54, 3. 09, 5. 14, 8. 23,

10. 80,
T *** AERMOD - VERSION 19191 *** *** C:\ Users\ Smith\ Dropbox\ My PC DESKTOP- 977GSBU)\ Documents\ HRA\ Ashley *** 10/ 26/ 23 AERMET - VERSION 18081 *** ***
16: 20: 52
PAGE 11
MODELOPTs: NonDFAULT CONC FLAT RURAL ADJ U*
UP TO THE FIRST 24 HOURS OF METEOROLOGICAL
DATA ***
Surface file: AERMET\ Stockton 2013- 2017. SFC
Met Version: 18081
Profile file: AERMET\ Stockton 2013- 2017. PFL
Surface format: FREE
Profile format: FREE
Surface station no. : 23237 Upper air station no. : 23230 Name: STOCKTON INTERNATIONAL AIRPORT Name:

OAKLAND/ WSO AP
Year: 2013 Year: 2013
First 24 hours of scalar data
YR MO DY JDY HR H0 U* W* DT/ DZ ZICNV ZIMCH M- 0 LEN Z0 BOWEN

ALBEDO REF WS WD HT REF TA HT
13 01 01 1 01 - 22. 0 0. 211 - 9. 000 - 9. 000 - 999. 232. 48. 8 0. 07 2. 20

1. 00 2. 78 149. 10. 0 273. 8 2. 0
13 01 01 1 02 - 14. 6 0. 158 - 9. 000 - 9. 000 - 999. 152. 27. 6 0. 04 2. 20

1. 00 2. 37 77. 10. 0 273. 8 2. 0
13 01 01 1 03 - 18. 4 0. 181 - 9. 000 - 9. 000 - 999. 185. 36. 0 0. 06 2. 20

1. 00 2. 52 97. 10. 0 273. 1 2. 0
13 01 01 1 04 - 6. 7 0. 105 - 9. 000 - 9. 000 - 999. 84. 16. 0 0. 04 2. 20

1. 00 1. 63 349. 10. 0 272. 5 2. 0
13 01 01 1 05 - 20. 1 0. 193 - 9. 000 - 9. 000 - 999. 203. 40. 9 0. 04 2. 20

1. 00 2. 86 356. 10. 0 274. 2 2. 0
13 01 01 1 06 - 3. 9 0. 081 - 9. 000 - 9. 000 - 999. 64. 12. 6 0. 04 2. 20

1. 00 1. 23 77. 10. 0 273. 8 2. 0
13 01 01 1 07 - 18. 3 0. 180 - 9. 000 - 9. 000 - 999. 184. 35. 8 0. 06 2. 20

1. 00 2. 52 255. 10. 0 273. 1 2. 0
13 01 01 1 08 - 26. 9 0. 259 - 9. 000 - 9. 000 - 999. 316. 73. 8 0. 08 2. 20

0. 73 3. 29 287. 10. 0 274. 2 2. 0
13 01 01 1 09 - 1. 9 0. 212 - 9. 000 - 9. 000 - 999. 236. 461. 6 0. 05 2. 20

0. 39 2. 81 315. 10. 0 275. 9 2. 0
13 01 01 1 10 61. 1 0. 155 0. 630 0. 005 150. 147. 5. 5 0. 04 2. 20

0. 27 1. 60 336. 10. 0 277. 5 2. 0
13 01 01 1 11 110. 2 0. 238 1. 137 0. 005 488. 279. - 11. 2 0. 06 2. 20

0. 23 2. 45 228. 10. 0 279. 9 2. 0
13 01 01 1 12 137. 1 0. 276 1. 492 0. 008 886. 347. - 14. 0 0. 08 2. 20

0. 22 2. 69 286. 10. 0 280. 4 2. 0
13 01 01 1 13 141. 1 0. 271 1. 531 0. 007 929. 339. - 12. 9 0. 05 2. 20

0. 21 2. 88 325. 10. 0 282. 5 2. 0
13 01 01 1 14 121. 3 0. 232 1. 475 0. 006 965. 269. 9. 4 0. 04 2. 20

0. 22 2. 57 356. 10. 0 283. 8 2. 0
13 01 01 1 15 78. 7 0. 218 1. 287 0. 005 988. 244. - 12. 0 0. 04 2. 20

0. 26 2. 47 357. 10. 0 284. 2 2. 0
13 01 01 1 16 17. 6 0. 265 0. 783 0. 005 993. 327. - 96. 0 0. 03 2. 20

0. 35 3. 59 2. 10. 0 284. 2 2. 0
13 01 01 1 17 - 11. 2 0. 143 - 9. 000 - 9. 000 - 999. 139. 24. 1 0. 04 2. 20

0. 60 2. 16 346. 10. 0 282. 5 2. 0
13 01 01 1 18 - 8. 7 0. 125 - 9. 000 - 9. 000 - 999. 107. 20. 6 0. 08 2. 20

1. 00 1. 67 273. 10. 0 279. 2 2. 0
13 01 01 1 19 - 13. 3 0. 154 - 9. 000 - 9. 000 - 999. 145. 26. 0 0. 06 2. 20

1. 00 2. 15 238. 10. 0 278. 1 2. 0
13 01 01 1 20 - 10. 2 0. 134 - 9. 000 - 9. 000 - 999. 117. 21. 4 0. 06 2. 20

1. 00 1. 89 230. 10. 0 275. 9 2. 0
13 01 01 1 21 - 12. 5 0. 148 - 9. 000 - 9. 000 - 999. 137. 24. 2 0. 05 2. 20

1. 00 2. 11 300. 10. 0 276. 4 2. 0
13 01 01 1 22 - 999. 0 - 9. 000 - 9. 000 - 9. 000 - 999. - 999. - 99999. 0 0. 05 2. 20

1. 00 0. 00 0. 10. 0 275. 9 2. 0
13 01 01 1 23 - 24. 0 0. 230 - 9. 000 - 9. 000 - 999. 264. 57. 9 0. 04 2. 20

1. 00 3. 36 80. 10. 0 274. 2 2. 0
13 01 01 1 24 - 16. 1 0. 169 - 9. 000 - 9. 000 - 999. 167. 31. 3 0. 06 2. 20

1. 00 2. 36 100. 10. 0 274. 2 2. 0
First hour of profile data
YR MO DY HR HEIGHT F WDIR WSPD AMB_ TMP sigmaA sigmaW sigmaV 13 01 01 01 10. 0 1 149. 2. 78 273. 8 99. 0 - 99. 00 - 99. 00 F indicates top of profile (= 1) or below (= 0)
T *** AERMOD - VERSION 19191 *** *** C:\ Users\ Smith\ Dropbox\ My PC DESKTOP- 977GSBU)\ Documents\ HRA\ Ashley *** 10/ 26/ 23 AERMET - VERSION 18081 *** ***
16: 20: 52
PAGE 12
MODELOPTs: NonDFAULT CONC FLAT RURAL ADJ U*
THE PERIOD ( 43824 HRS) AVERAGE CONCENTRATION
VALUES FOR SOURCE GROUP: VOL1
INCLUDING SOURCE( 5) : VOL1

DISCRETE CARTESIAN RECEPTOR POINTS
CONC OF OTHER IN MICROGRAMS/ M** 3

X- COORD ( M) Y- COORD ( M) CONC X- COORD ( M)

Y- COORD ( M) CONC
649676. 34 4188314. 55 3. 17886 649629. 66
4188294. 84 2. 81498
649810. 15 4188312. 48 4. 33466 649364. 10
4188360. 20 1. 88281
649327. 80 4188355. 01 1. 77280 649380. 70
4188758. 52 1. 84706
650495. 81 4188841. 51 4. 28073 650597. 47
4188832. 17 3. 93483
650536. 27 4188878. 85 3. 56783 650577. 76
4188877. 81 3. 42873
650602. 66 4188860. 18 3. 53924 650610. 95
4188880. 93 3. 26850
650638. 10 4188858. 53 3. 40358 650664. 10
4188331. 03 21. 36195
650668. 72 4188350. 83 21. 42188 650677. 96
4188379. 86 20. 70636
650699. 74 4188414. 84 18. 04783 650758. 47
4188658. 36 5. 99965
650765. 73 4188678. 82 5. 40633 650773. 65
4188706. 54 4. 74863
650778. 27 4188726. 34 4. 35960 650805. 33
4188805. 53 3. 18808
650806. 65 4188824. 01 3. 00930 650811. 27
4188843. 81 2. 82339
650814. 57 4188862. 29 2. 66944 650846. 24
4188924. 98 2. 18464
650850. 86 4188951. 38 2. 03971 650854. 82
4188976. 46 1. 91630
650698. 00 4188307. 32 17. 19609 650692. 60
4188291. 80 17. 10889
650724. 82 4189245. 80 1. 23247 650726. 07
4189273. 37 1. 17147
650856. 27 4189006. 30 1. 78991 650857. 23
4189022. 60 1. 72624
650859. 15 4189041. 29 1. 65647 650859. 15
4189058. 54 1. 59875
650860. 58 4189076. 28 1. 54084 650861. 54
4189094. 49 1. 48561
650857. 71 4189113. 19 1. 43818 650847. 16
4189118. 94 1. 43550
650848. 12 4189134. 76 1. 39223 650850. 04
4189155. 37 1. 33808
650851. 48 4189171. 66 1. 29761 650853. 87
4189184. 12 1. 26667
650856. 75 4189199. 46 1. 23019 650857. 71
4189213. 36 1. 19992
650860. 58 4189226. 30 1. 17113 650862. 50
4189242. 60 1. 13767
650865. 38 4189258. 42 1. 10583 650867. 77
4189275. 19 1. 07402
650868. 73 4189291. 49 1. 04532 650872. 09
4189309. 23 1. 01398
650874. 00 4189325. 04 0. 98792 650875. 92
4189340. 38 0. 96358
650878. 80 4189355. 24 0. 94035 650881. 19
4189373. 45 0. 91366
650884. 55 4189390. 71 0. 88893 650888. 86
4189407. 01 0. 86604
650889. 82 4189427. 14 0. 84094 650891. 74
4189443. 43 0. 82100
650895. 09 4189461. 17 0. 79964 650898. 45
4189475. 55 0. 78273
650898. 45 4189489. 93 0. 76764 650902. 28
4189504. 31 0. 75163
650709. 41 4188344. 56 17. 06524 650722. 45
4188284. 03 14. 75034
650745. 73 4188280. 30 13. 28972 650735. 49
4188223. 50 12. 26662
650721. 52 4188167. 62 10. 82224 650525. 76
4188133. 34 12. 79783
651125. 76 4188133. 34 3. 87169 649125. 76
4188183. 34 1. 18255
649225. 76 4188183. 34 1. 33591 649325. 76
4188183. 34 1. 52301
649425. 76 4188183. 34 1. 75398 649525. 76
4188183. 34 2. 04325
649625. 76 4188183. 34 2. 41298 649725. 76
4188183. 34 2. 89948
649825. 76 4188183. 34 3. 56054 649925. 76
4188183. 34 4. 47388
T *** AERMOD - VERSION 19191 *** *** C:\ Users\ Smith\ Dropbox\ My PC DESKTOP- 977GSBU)\ Documents\ HRA\ Ashley *** 10/ 26/ 23 AERMET - VERSION 18081 *** ***
16: 20: 52
PAGE 13
MODELOPTs: NonDFAULT CONC FLAT RURAL ADJ U*
THE PERIOD ( 43824 HRS) AVERAGE CONCENTRATION
VALUES FOR SOURCE GROUP: VOL1
INCLUDING SOURCE( S) : VOL1

DISCRETE CARTESIAN RECEPTOR POINTS
CONC OF OTHER IN MICROGRAMS/ M** 3

X- COORD ( M) Y- COORD ( M) CONC X- COORD ( M)

Y- COORD ( M) CONC
650025. 76 4188183. 34 5. 72299 650125. 76
4188183. 34 7. 55527
650225. 76 4188183. 34 10. 88539 650325. 76
4188183. 34 14. 88797
650425. 76 4188183. 34 16. 92231 650525. 76
4188183. 34 17. 11096
650625. 76 4188183. 34 14. 40536 650725. 76
4188183. 34 11. 26403
650825. 76 4188183. 34 8. 49856 651125. 76
4188183. 34 3. 99264
649125. 76 4188233. 34 1. 22716 649225. 76
4188233. 34 1. 39059
649325. 76 4188233. 34 1. 59195 649425. 76
4188233. 34 1. 84404
649525. 76 4188233. 34 2. 16523 649625. 76
4188233. 34 2. 58269
649725. 76 4188233. 34 3. 13927 649825. 76
4188233. 34 3. 90757
649925. 76 4188233. 34 5. 01379 650025. 76
4188233. 34 6. 65512
650125. 76 4188233. 34 9. 14189 650225. 76
4188233. 34 13. 66522
650325. 76 4188233. 34 20. 87001 650425. 76
4188233. 34 25. 17975
650525. 76 4188233. 34 23. 96208 650625. 76
4188233. 34 18. 33298
650725. 76 4188233. 34 13. 00909 650825. 76
4188233. 34 9. 23105
651125. 76 4188233. 34 4. 08713 649125. 76
4188283. 34 1. 27356
649225. 76 4188283. 34 1. 44784 649325. 76
4188283. 34 1. 66373
649425. 76 4188283. 34 1. 93630 649525. 76
4188283. 34 2. 28803
649625. 76 4188283. 34 2. 75356 649725. 76
4188283. 34 3. 38834
649825. 76 4188283. 34 4. 28613 649925. 76
4188283. 34 5. 61852
650025. 76 4188283. 34 7. 72063 650125. 76
4188283. 34 11. 23886
650225. 76 4188283. 34 17. 86116 650325. 76
4188283. 34 31. 59663
650425. 76 4188283. 34 42. 08194 650525. 76
4188283. 34 35. 08637
650625. 76 4188283. 34 22. 79576 650725. 76
4188283. 34 14. 52431
650825. 76 4188283. 34 9. 79288 651125. 76
4188283. 34 4. 14689
649125. 76 4188333. 34 1. 31918 649225. 76
4188333. 34 1. 50511
649325. 76 4188333. 34 1. 73675 649425. 76
4188333. 34 2. 03115
649525. 76 4188333. 34 2. 41441 649625. 76
4188333. 34 2. 92807
649725. 76 4188333. 34 3. 64161 649825. 76
4188333. 34 4. 67820
649925. 76 4188333. 34 6. 27372 650025. 76
4188333. 34 8. 92948
650125. 76 4188333. 34 13. 85270 650225. 76
4188333. 34 24. 50193
650325. 76 4188333. 34 55. 04523 650425. 76
4188333. 34 85. 81087
650525. 76 4188333. 34 51. 60304 650625. 76
4188333. 34 26. 82172
650725. 76 4188333. 34 15. 57474 650825. 76
4188333. 34 10. 12759
651125. 76 4188333. 34 4. 15801 649125. 76
4188383. 34 1. 36116
649225. 76 4188383. 34 1. 55812 649325. 76
4188383. 34 1. 80503
649425. 76 4188383. 34 2. 12112 649525. 76
4188383. 34 2. 53619
649625. 76 4188383. 34 3. 09853 649725. 76
4188383. 34 3. 89103
649825. 76 4188383. 34 5. 06650 649925. 76
4188383. 34 6. 93420
650025. 76 4188383. 34 10. 20530 650125. 76
4188383. 34 16. 85414
650225. 76 4188383. 34 34. 35059 650325. 76
4188383. 34 118. 70330
T *** AERMOD - VERSION 19191 *** *** C:\ Users\ Smith\ Dropbox\ My PC DESKTOP- 977GSBU)\ Documents\ HRA\ Ashley *** 10/ 26/ 23 AERMET - VERSION 18081 *** ***
16: 20: 52
PAGE 14
MODELOPTs: NonDFAULT CONC FLAT RURAL ADJ U*
THE PERIOD ( 43824 HRS) AVERAGE CONCENTRATION
VALUES FOR SOURCE GROUP: VOL1
INCLUDING SOURCE( 5) : VOL1

DISCRETE CARTESIAN RECEPTOR POINTS
CONC OF OTHER IN MICROGRAMS/ M** 3

X- COORD ( M) Y- COORD ( M) CONC X- COORD ( M)

Y- COORD ( M) CONC
650425. 76 4188383. 34 0. 00000 650525. 76
4188383. 34 68. 99120
650625. 76 4188383. 34 29. 05155 650725. 76
4188383. 34 15. 92582
650825. 76 4188383. 34 10. 15734 651125. 76
4188383. 34 4. 11435
649125. 76 4188433. 34 1. 39675 649225. 76
4188433. 34 1. 60246
649325. 76 4188433. 34 1. 86146 649425. 76
4188433. 34 2. 19477
649525. 76 4188433. 34 2. 63526 649625. 76
4188433. 34 3. 23682
649725. 76 4188433. 34 4. 09335 649825. 76
4188433. 34 5. 38160
649925. 76 4188433. 34 7. 47032 650025. 76
4188433. 34 11. 24952
650125. 76 4188433. 34 19. 40688 650225. 76
4188433. 34 44. 15056
650325. 76 4188433. 34 0. 00000 650425. 76
4188433. 34 0. 00000
650525. 76 4188433. 34 72. 28796 650625. 76
4188433. 34 28. 22045
650725. 76 4188433. 34 15. 38260 650825. 76
4188433. 34 9. 83764
651125. 76 4188433. 34 4. 02218 649125. 76
4188483. 34 1. 42201
649225. 76 4188483. 34 1. 63249 649325. 76
4188483. 34 1. 89761
649425. 76 4188483. 34 2. 23898 649525. 76
4188483. 34 2. 69037
649625. 76 4188483. 34 3. 30715 649725. 76
4188483. 34 4. 18593
650425. 76 4188483. 34 0. 00000 650525. 76
4188483. 34 53. 52462
650625. 76 4188483. 34 24. 03494 650725. 76
4188483. 34 13. 88538
650825. 76 4188483. 34 9. 14839 651125. 76
4188483. 34 3. 88105
649125. 76 4188533. 34 1. 43149 649225. 76
4188533. 34 1. 64100
649325. 76 4188533. 34 1. 90391 649425. 76
4188533. 34 2. 24092
649525. 76 4188533. 34 2. 68419 649625. 76
4188533. 34 3. 28618
649725. 76 4188533. 34 4. 13760 650425. 76
4188533. 34 64. 20726
650525. 76 4188533. 34 31. 31016 650625. 76
4188533. 34 18. 11002
650725. 76 4188533. 34 11. 65529 650825. 76
4188533. 34 8. 10942
651125. 76 4188533. 34 3. 67694 649125. 76
4188583. 34 1. 42097
649225. 76 4188583. 34 1. 62365 649325. 76
4188583. 34 1. 87669
649425. 76 4188583. 34 2. 19937 649525. 76
4188583. 34 2. 62164
649625. 76 4188583. 34 3. 19193 649725. 76
4188583. 34 3. 99226
650425. 76 4188583. 34 27. 36469 650525. 76
4188583. 34 18. 53854
650625. 76 4188583. 34 12. 87742 650725. 76
4188583. 34 9. 28504
650825. 76 4188583. 34 6. 90245 651125. 76
4188583. 34 3. 40857
649125. 76 4188633. 34 1. 39243 649225. 76
4188633. 34 1. 58572
649325. 76 4188633. 34 1. 82676 649425. 76
4188633. 34 2. 13394
649525. 76 4188633. 34 2. 53518 649625. 76
4188633. 34 3. 07388
649725. 76 4188633. 34 3. 81932 649825. 76
4188633. 34 4. 88613
649925. 76 4188633. 34 6. 47125 650025. 76
4188633. 34 8. 94589
650125. 76 4188633. 34 13. 10152 650225. 76
4188633. 34 18. 87239
650325. 76 4188633. 34 19. 76408 650425. 76
4188633. 34 16. 03700
650525. 76 4188633. 34 12. 28390 650625. 76
4188633. 34 9. 30563
T *** AERMOD - VERSION 19191 *** *** C:\ Users\ Smith\ Dropbox\ My PC DESKTOP- 977GSBU)\ Documents\ HRA\ Ashley *** 10/ 26/ 23 AERMET - VERSION 18081 *** ***
16: 20: 52
PAGE 15
MODELOPTs: NonDFAULT CONC FLAT RURAL ADJ U*
THE PERIOD ( 43824 HRS) AVERAGE CONCENTRATION
VALUES FOR SOURCE GROUP: VOL1
INCLUDING SOURCE( S) : VOL1

DISCRETE CARTESIAN RECEPTOR POINTS
CONC OF OTHER IN MICROGRAMS/ M** 3

X- COORD ( M) Y- COORD ( M) CONC X- COORD ( M)

Y- COORD ( M) CONC
650725. 76 4188633. 34 7. 25697 650825. 76
4188633. 34 5. 74610
651125. 76 4188633. 34 3. 10398 649125. 76
4188683. 34 1. 35560
649225. 76 4188683. 34 1. 54149 649325. 76
4188683. 34 1. 77364
649425. 76 4188683. 34 2. 06882 649525. 76
4188683. 34 2. 45092
649625. 76 4188683. 34 2. 95480 649725. 76
4188683. 34 3. 63310
649825. 76 4188683. 34 4. 56740 649925. 76
4188683. 34 5. 89206
650025. 76 4188683. 34 7. 88298 650125. 76
4188683. 34 10. 87060
650225. 76 4188683. 34 13. 44324 650325. 76
4188683. 34 12. 59596
650425. 76 4188683. 34 10. 75885 650525. 76
4188683. 34 8. 84657
650625. 76 4188683. 34 7. 05404 650725. 76
4188683. 34 5. 72657
650825. 76 4188683. 34 4. 74382 651125. 76
4188683. 34 2. 80045
649125. 76 4188733. 34 1. 32157 649225. 76
4188733. 34 1. 50267
649325. 76 4188733. 34 1. 72726 649425. 76
4188733. 34 2. 00872
649525. 76 4188733. 34 2. 36548 649625. 76
4188733. 34 2. 82412
649725. 76 4188733. 34 3. 42360 649825. 76
4188733. 34 4. 22196
649925. 76 4188733. 34 5. 32929 650025. 76
4188733. 34 6. 94956
650125. 76 4188733. 34 8. 90104 650225. 76
4188733. 34 9. 76400
650325. 76 4188733. 34 8. 79703 650425. 76
4188733. 34 7. 79849
650525. 76 4188733. 34 6. 71310 650625. 76
4188733. 34 5. 57506
650725. 76 4188733. 34 4. 64059 650825. 76
4188733. 34 3. 93530
651125. 76 4188733. 34 2. 51757 649125. 76
4188783. 34 1. 29390
649225. 76 4188783. 34 1. 46890 649325. 76
4188783. 34 1. 68199
649425. 76 4188783. 34 1. 94355 649525. 76
4188783. 34 2. 26841
649625. 76 4188783. 34 2. 67754 649725. 76
4188783. 34 3. 19947
649825. 76 4188783. 34 3. 88298 649925. 76
4188783. 34 4. 83325
650025. 76 4188783. 34 6. 10541 650125. 76
4188783. 34 7. 20649
650225. 76 4188783. 34 7. 31749 650325. 76
4188783. 34 6. 54318
650425. 76 4188783. 34 5. 95372 650525. 76
4188783. 34 5. 28615
650625. 76 4188783. 34 4. 53609 650725. 76
4188783. 34 3. 85998
650825. 76 4188783. 34 3. 31983 651125. 76
4188783. 34 2. 25548
649125. 76 4188833. 34 1. 26771 649225. 76
4188833. 34 1. 43253
649325. 76 4188833. 34 1. 62976 649425. 76
4188833. 34 1. 86853
649525. 76 4188833. 34 2. 16124 649625. 76
4188833. 34 2. 52329
649725. 76 4188833. 34 2. 97808 649825. 76
4188833. 34 3. 57862
649925. 76 4188833. 34 4. 39648 650025. 76
4188833. 34 5. 30588
650125. 76 4188833. 34 5. 82895 650225. 76
4188833. 34 5. 66565
650325. 76 4188833. 34 5. 09083 650425. 76
4188833. 34 4. 71923
650525. 76 4188833. 34 4. 28202 650625. 76
4188833. 34 3. 77056
650725. 76 4188833. 34 3. 27207 650825. 76
4188833. 34 2. 85387
651125. 76 4188833. 34 2. 01240 649125. 76
4188883. 34 1. 23701
T *** AERMOD - VERSION 19191 *** *** C:\ Users\ Smith\ Dropbox\ My PC DESKTOP- 977GSBU)\ Documents\ HRA\ Ashley *** 10/ 26/ 23 AERMET - VERSION 18081 *** ***
16: 20: 52
PAGE 16
MODELOPTs: NonDFAULT CONC FLAT RURAL ADJ U*
THE PERIOD ( 43824 HRS) AVERAGE CONCENTRATION
VALUES FOR SOURCE GROUP: VOL1
INCLUDING SOURCE( S) : VOL1

DISCRETE CARTESIAN RECEPTOR POINTS
CONC OF OTHER IN MICROGRAMS/ M** 3

X- COORD ( M) Y- COORD ( M) CONC X- COORD ( M)

Y- COORD ( M) CONC
649225. 76 4188883. 34 1. 38933 649325. 76
4188883. 34 1. 57025
649425. 76 4188883. 34 1. 78762 649525. 76
4188883. 34 2. 05033
649625. 76 4188883. 34 2. 37030 649725. 76
4188883. 34 2. 77464
649825. 76 4188883. 34 3. 31418 649925. 76
4188883. 34 3. 98435
650025. 76 4188883. 34 4. 56086 650125. 76
4188883. 34 4. 75582
650225. 76 4188883. 34 4. 51491 650325. 76
4188883. 34 4. 09578
650425. 76 4188883. 34 3. 84874 650525. 76
4188883. 34 3. 54722
650625. 76 4188883. 34 3. 18748 650725. 76
4188883. 34 2. 81448
650825. 76 4188883. 34 2. 48727 651125. 76
4188883. 34 1. 79407
650125. 76 4188933. 34 3. 93276 650225. 76
4188933. 34 3. 68622
650325. 76 4188933. 34 3. 38138 650425. 76
4188933. 34 3. 20974
650525. 76 4188933. 34 2. 99247 650625. 76
4188933. 34 2. 73233
650725. 76 4188933. 34 2. 45079 650825. 76
4188933. 34 2. 18869
651125. 76 4188933. 34 1. 60744 650425. 76
4188983. 34 2. 72544
650525. 76 4188983. 34 2. 56300 650625. 76
4188983. 34 2. 37022
650725. 76 4188983. 34 2. 15561 650825. 76
4188983. 34 1. 94264
651125. 76 4188983. 34 1. 45331 650525. 76
4189033. 34 2. 22350
650625. 76 4189033. 34 2. 07733 650725. 76
4189033. 34 1. 91146
650825. 76 4189033. 34 1. 73886 651125. 76
4189033. 34 1. 32635
650525. 76 4189083. 34 1. 95038 650625. 76
4189083. 34 1. 83687
650725. 76 4189083. 34 1. 70692 650825. 76
4189083. 34 1. 56789
651125. 76 4189083. 34 1. 21908 650525. 76
4189133. 34 1. 72726
650625. 76 4189133. 34 1. 63683 650725. 76
4189133. 34 1. 53412
650825. 76 4189133. 34 1. 42176 651125. 76
4189133. 34 1. 12496
650781. 98 4189510. 65 0. 78373 650760. 33
4189397. 50 0. 93604
T *** AERMOD - VERSION 19191 *** *** C:\ Users\ Smith\ DropbOx\ My PC DESKTOP- 977GSBU)\ Documents\ HRA\ Ashley *** 10/ 26/ 23 AERMET - VERSION 18081 *** ***
16: 20: 52
PAGE 17
MODELOPTs: NonDFAULT CONC FLAT RURAL ADJ U*
THE PERIOD ( 43824 HRS) AVERAGE CONCENTRATION
VALUES FOR SOURCE GROUP: VOL2
INCLUDING SOURCE( S) : VOL2

DISCRETE CARTESIAN RECEPTOR POINTS
CONC OF OTHER IN MICROGRAMS/ M** 3

X- COORD ( M) Y- COORD ( M) CONC X- COORD ( M)

Y- COORD ( M) CONC
649676. 34 4188314. 55 33. 87899 649629. 66
4188294. 84 21. 15952
649810. 15 4188312. 48 79. 34923 649364. 10
4188360. 20 7. 73569
649327. 80 4188355. 01 6. 73633 649380. 70
4188758. 52 5. 56104
650495. 81 4188841. 51 1. 96862 650597. 47
4188832. 17 1. 81267
650536. 27 4188878. 85 1. 73706 650577. 76
4188877. 81 1. 67592
650602. 66 4188860. 18 1. 70016 650610. 95
4188880. 93 1. 61532
650638. 10 4188858. 53 1. 64865 650664. 10
4188331. 03 3. 11342
650668. 72 4188350. 83 3. 07133 650677. 96
4188379. 86 2. 98946
650699. 74 4188414. 84 2. 82815 650758. 47
4188658. 36 2. 01682
650765. 73 4188678. 82 1. 93522 650773. 65
4188706. 54 1. 83426
650778. 27 4188726. 34 1. 76791 650805. 33
4188805. 53 1. 51569
650806. 65 4188824. 01 1. 47154 650811. 27
4188843. 81 1. 42084
650814. 57 4188862. 29 1. 37651 650846. 24
4188924. 98 1. 21324
650850. 86 4188951. 38 1. 15952 650854. 82
4188976. 46 1. 11070
650698. 00 4188307. 32 2. 92717 650692. 60
4188291. 80 2. 96080
650724. 82 4189245. 80 0. 81555 650726. 07
4189273. 37 0. 78752
650856. 27 4189006. 30 1. 05751 650857. 23
4189022. 60 1. 02937
650859. 15 4189041. 29 0. 99763 650859. 15
4189058. 54 0. 97056
650860. 58 4189076. 28 0. 94297 650861. 54
4189094. 49 0. 91620
650857. 71 4189113. 19 0. 89267 650847. 16
4189118. 94 0. 89078
650848. 12 4189134. 76 0. 86979 650850. 04
4189155. 37 0. 84357
650851. 48 4189171. 66 0. 82401 650853. 87
4189184. 12 0. 80904
650856. 75 4189199. 46 0. 79139 650857. 71
4189213. 36 0. 77687
650860. 58 4189226. 30 0. 76291 650862. 50
4189242. 60 0. 74685
650865. 38 4189258. 42 0. 73146 650867. 77
4189275. 19 0. 71613
650868. 73 4189291. 49 0. 70246 650872. 09
4189309. 23 0. 68717
650874. 00 4189325. 04 0. 67453 650875. 92
4189340. 38 0. 66264
650878. 80 4189355. 24 0. 65106 650881. 19
4189373. 45 0. 63776
650884. 55 4189390. 71 0. 62514 650888. 86
4189407. 01 0. 61316
650889. 82 4189427. 14 0. 60029 650891. 74
4189443. 43 0. 58973
650895. 09 4189461. 17 0. 57807 650898. 45
4189475. 55 0. 56864
650898. 45 4189489. 93 0. 56031 650902. 28
4189504. 31 0. 55105
650709. 41 4188344. 56 2. 84592 650722. 45
4188284. 03 2. 80191
650745. 73 4188280. 30 2. 68702 650735. 49
4188223. 50 2. 72437
650721. 52 4188167. 62 2. 75311 650525. 76
4188133. 34 3. 94406
651125. 76 4188133. 34 1. 51395 649125. 76
4188183. 34 2. 95255
649225. 76 4188183. 34 3. 63714 649325. 76
4188183. 34 4. 59801
649425. 76 4188183. 34 5. 94775 649525. 76
4188183. 34 7. 91642
649625. 76 4188183. 34 11. 48611 649725. 76
4188183. 34 16. 35374
649825. 76 4188183. 34 18. 95305 649925. 76
4188183. 34 19. 05660
T *** AERMOD - VERSION 19191 *** *** C:\ Users\ Smith\ Dropbox\ My PC DESKTOP- 977GSBU)\ Documents\ HRA\ Ashley *** 10/ 26/ 23 AERMET - VERSION 18081 *** ***
16: 20: 52
PAGE 18
MODELOPTs: NonDFAULT CONC FLAT RURAL ADJ U*
THE PERIOD ( 43824 HRS) AVERAGE CONCENTRATION
VALUES FOR SOURCE GROUP: VOL2
INCLUDING SOURCE( S) : VOL2

DISCRETE CARTESIAN RECEPTOR POINTS
CONC OF OTHER IN MICROGRAMS/ M** 3

X- COORD ( M) Y- COORD ( M) CONC X- COORD ( M)

Y- COORD ( M) CONC
650025. 76 4188183. 34 15. 71655 650125. 76
4188183. 34 11. 96681
650225. 76 4188183. 34 8. 84872 650325. 76
4188183. 34 6. 63257
650425. 76 4188183. 34 5. 11472 650525. 76
4188183. 34 4. 05922
650625. 76 4188183. 34 3. 30337 650725. 76
4188183. 34 2. 74572
650825. 76 4188183. 34 2. 32296 651125. 76
4188183. 34 1. 52402
649125. 76 4188233. 34 3. 19338 649225. 76
4188233. 34 3. 99064
649325. 76 4188233. 34 5. 14720 649425. 76
4188233. 34 6. 89965
649525. 76 4188233. 34 9. 62693 649625. 76
4188233. 34 14. 54632
649725. 76 4188233. 34 23. 29348 649825. 76
4188233. 34 29. 10509
649925. 76 4188233. 34 27. 21619 650025. 76
4188233. 34 20. 01226
650125. 76 4188233. 34 13. 72709 650225. 76
4188233. 34 9. 55414
650325. 76 4188233. 34 6. 94719 650425. 76
4188233. 34 5. 27249
650525. 76 4188233. 34 4. 14569 650625. 76
4188233. 34 3. 35391
650725. 76 4188233. 34 2. 77636 650825. 76
4188233. 34 2. 34159
651125. 76 4188233. 34 1. 52633 649125. 76
4188283. 34 3. 43994
649225. 76 4188283. 34 4. 36860 649325. 76
4188283. 34 5. 75956
649425. 76 4188283. 34 7. 98535 649525. 76
4188283. 34 11. 82794
649625. 76 4188283. 34 19. 25100 649725. 76
4188283. 34 36. 18937
649825. 76 4188283. 34 51. 39279 649925. 76
4188283. 34 40. 50726
650025. 76 4188283. 34 24. 66881 650125. 76
4188283. 34 15. 17722
650225. 76 4188283. 34 10. 06874 650325. 76
4188283. 34 7. 16051
650425. 76 4188283. 34 5. 37023 650525. 76
4188283. 34 4. 19259
650625. 76 4188283. 34 3. 37591 650725. 76
4188283. 34 2. 78511
650825. 76 4188283. 34 2. 34295 651125. 76
4188283. 34 1. 51993
649125. 76 4188333. 34 3. 69039 649225. 76
4188333. 34 4. 75550
649325. 76 4188333. 34 6. 40890 649425. 76
4188333. 34 9. 19867
649525. 76 4188333. 34 14. 50431 649625. 76
4188333. 34 26. 58858
649725. 76 4188333. 34 66. 40581 649825. 76
4188333. 34 115. 66569
649925. 76 4188333. 34 59. 35489 650025. 76
4188333. 34 28. 49179
650125. 76 4188333. 34 16. 07340 650225. 76
4188333. 34 10. 32503
650325. 76 4188333. 34 7. 23684 650425. 76
4188333. 34 5. 38634
650525. 76 4188333. 34 4. 18652 650625. 76
4188333. 34 3. 36155
650725. 76 4188333. 34 2. 76811 650825. 76
4188333. 34 2. 32575
651125. 76 4188333. 34 1. 50625 649125. 76
4188383. 34 3. 92745
649225. 76 4188383. 34 5. 12482 649325. 76
4188383. 34 7. 03674
649425. 76 4188383. 34 10. 41404 649525. 76
4188383. 34 17. 39565
649625. 76 4188383. 34 36. 56392 649725. 76
4188383. 34 0. 00000
649825. 76 4188383. 34 0. 00000 649925. 76
4188383. 34 75. 69188
650025. 76 4188383. 34 29. 97742 650125. 76
4188383. 34 16. 16770
650225. 76 4188383. 34 10. 24658 650325. 76
4188383. 34 7. 14784
T *** AERMOD - VERSION 19191 *** *** C:\ Users\ Smith\ Dropbox\ My PC DESKTOP- 977GSBU)\ Documents\ HRA\ Ashley *** 10/ 26/ 23 AERMET - VERSION 18081 *** ***
16: 20: 52
PAGE 19
MODELOPTs: NonDFAULT CONC FLAT RURAL ADJ U*
THE PERIOD ( 43824 HRS) AVERAGE CONCENTRATION
VALUES FOR SOURCE GROUP: VOL2
INCLUDING SOURCE( S) : VOL2

DISCRETE CARTESIAN RECEPTOR POINTS
CONC OF OTHER IN MICROGRAMS/ M** 3

X- COORD ( M) Y- COORD ( M) CONC X- COORD ( M)

Y- COORD ( M) CONC
650425. 76 4188383. 34 5. 31101 650525. 76
4188383. 34 4. 12592
650625. 76 4188383. 34 3. 31306 650725. 76
4188383. 34 2. 72904
650825. 76 4188383. 34 2. 29394 651125. 76
4188383. 34 1. 48793
649125. 76 4188433. 34 4. 09850 649225. 76
4188433. 34 5. 38675
649325. 76 4188433. 34 7. 47396 649425. 76
4188433. 34 11. 24624
649525. 76 4188433. 34 19. 37265 649625. 76
4188433. 34 43. 87140
649725. 76 4188433. 34 0. 00000 649825. 76
4188433. 34 0. 00000
649925. 76 4188433. 34 71. 42414 650025. 76
4188433. 34 27. 95271
650125. 76 4188433. 34 15. 29271 650225. 76
4188433. 34 9. 80085
650325. 76 4188433. 34 6. 89117 650425. 76
4188433. 34 5. 14954
650525. 76 4188433. 34 4. 01748 650625. 76
4188433. 34 3. 23650
650725. 76 4188433. 34 2. 67283 650825. 76
4188433. 34 2. 25135
651125. 76 4188433. 34 1. 46661 649125. 76
4188483. 34 4. 14584
649225. 76 4188483. 34 5. 43779 649325. 76
4188483. 34 7. 52052
649425. 76 4188483. 34 11. 24996 649525. 76
4188483. 34 19. 10168
649625. 76 4188483. 34 41. 03794 649725. 76
4188483. 34 130. 57562
650425. 76 4188483. 34 4. 89254 650525. 76
4188483. 34 3. 85514
650625. 76 4188483. 34 3. 12782 650725. 76
4188483. 34 2. 59666
650825. 76 4188483. 34 2. 19594 651125. 76
4188483. 34 1. 44144
649125. 76 4188533. 34 4. 06011 649225. 76
4188533. 34 5. 28197
649325. 76 4188533. 34 7. 21659 649425. 76
4188533. 34 10. 55872
649525. 76 4188533. 34 17. 07083 649625. 76
4188533. 34 32. 01676
649725. 76 4188533. 34 57. 93812 650425. 76
4188533. 34 4. 52709
650525. 76 4188533. 34 3. 62536 650625. 76
4188533. 34 2. 97579
650725. 76 4188533. 34 2. 49180 650825. 76
4188533. 34 2. 12106
651125. 76 4188533. 34 1. 40944 649125. 76
4188583. 34 3. 90282
649225. 76 4188583. 34 5. 02943 649325. 76
4188583. 34 6. 75592
649425. 76 4188583. 34 9. 56368 649525. 76
4188583. 34 14. 53751
649625. 76 4188583. 34 23. 39309 649725. 76
4188583. 34 28. 97272
650425. 76 4188583. 34 4. 08468 650525. 76
4188583. 34 3. 33682
650625. 76 4188583. 34 2. 78027 650725. 76
4188583. 34 2. 35505
650825. 76 4188583. 34 2. 02275 651125. 76
4188583. 34 1. 36769
649125. 76 4188633. 34 3. 72968 649225. 76
4188633. 34 4. 74210
649325. 76 4188633. 34 6. 21997 649425. 76
4188633. 34 8. 48439
649525. 76 4188633. 34 12. 17934 649625. 76
4188633. 34 16. 78164
649725. 76 4188633. 34 17. 00003 649825. 76
4188633. 34 14. 06344
649925. 76 4188633. 34 11. 08611 650025. 76
4188633. 34 8. 54761
650125. 76 4188633. 34 6. 76726 650225. 76
4188633. 34 5. 44856
650325. 76 4188633. 34 4. 42148 650425. 76
4188633. 34 3. 62945
650525. 76 4188633. 34 3. 02478 650625. 76
4188633. 34 2. 55945
T *** AERMOD - VERSION 19191 *** *** C:\ Users\ Smith\ Dropbox\ My PC DESKTOP- 977GSBU)\ Documents\ HRA\ Ashley *** 10/ 26/ 23 AERMET - VERSION 18081 *** ***
16: 20: 52
PAGE 20
MODELOPTs: NonDFAULT CONC FLAT RURAL ADJ U*
THE PERIOD ( 43824 HRS) AVERAGE CONCENTRATION
VALUES FOR SOURCE GROUP: VOL2
INCLUDING SOURCE( S) : VOL2

DISCRETE CARTESIAN RECEPTOR POINTS
CONC OF OTHER IN MICROGRAMS/ M** 3

X- COORD ( M) Y- COORD ( M) CONC X- COORD ( M)

Y- COORD ( M) CONC
650725. 76 4188633. 34 2. 19518 650825. 76
4188633. 34 1. 90481
651125. 76 4188633. 34 1. 31544 649125. 76
4188683. 34 3. 54000
649225. 76 4188683. 34 4. 41903 649325. 76
4188683. 34 5. 65015
649425. 76 4188683. 34 7. 48381 649525. 76
4188683. 34 10. 10749
649625. 76 4188683. 34 12. 07443 649725. 76
4188683. 34 11. 19883
649825. 76 4188683. 34 9. 68918 649925. 76
4188683. 34 8. 12036
650025. 76 4188683. 34 6. 56786 650125. 76
4188683. 34 5. 37382
650225. 76 4188683. 34 4. 49128 650325. 76
4188683. 34 3. 78825
650425. 76 4188683. 34 3. 20285 650525. 76
4188683. 34 2. 72327
650625. 76 4188683. 34 2. 33772 650725. 76
4188683. 34 2. 02818
650825. 76 4188683. 34 1. 77717 651125. 76
4188683. 34 1. 25469
649125. 76 4188733. 34 3. 32787 649225. 76
4188733. 34 4. 07783
649325. 76 4188733. 34 5. 11491 649425. 76
4188733. 34 6. 60710
649525. 76 4188733. 34 8. 27367 649625. 76
4188733. 34 8. 87962
649725. 76 4188733. 34 7. 99377 649825. 76
4188733. 34 7. 14654
649925. 76 4188733. 34 6. 23314 650025. 76
4188733. 34 5. 23947
650125. 76 4188733. 34 4. 39124 650225. 76
4188733. 34 3. 73943
650325. 76 4188733. 34 3. 23486 650425. 76
4188733. 34 2. 81220
650525. 76 4188733. 34 2. 44422 650625. 76
4188733. 34 2. 12996
650725. 76 4188733. 34 1. 86773 650825. 76
4188733. 34 1. 65058
651125. 76 4188733. 34 1. 18916 649125. 76
4188783. 34 3. 10612
649225. 76 4188783. 34 3. 75222 649325. 76
4188783. 34 4. 64830
649425. 76 4188783. 34 5. 80068 649525. 76
4188783. 34 6. 70985
649625. 76 4188783. 34 6. 73588 649725. 76
4188783. 34 6. 03619
649825. 76 4188783. 34 5. 52439 649925. 76
4188783. 34 4. 95109
650025. 76 4188783. 34 4. 29080 650125. 76
4188783. 34 3. 67502
650225. 76 4188783. 34 3. 17341 650325. 76
4188783. 34 2. 77768
650425. 76 4188783. 34 2. 46084 650525. 76
4188783. 34 2. 18508
650625. 76 4188783. 34 1. 93730 650725. 76
4188783. 34 1. 71912
650825. 76 4188783. 34 1. 53183 651125. 76
4188783. 34 1. 12288
649125. 76 4188833. 34 2. 89165 649225. 76
4188833. 34 3. 46450
649325. 76 4188833. 34 4. 23114 649425. 76
4188833. 34 5. 03403
649525. 76 4188833. 34 5. 44932 649625. 76
4188833. 34 5. 26968
649725. 76 4188833. 34 4. 74826 649825. 76
4188833. 34 4. 42024
649925. 76 4188833. 34 4. 03828 650025. 76
4188833. 34 3. 58430
650125. 76 4188833. 34 3. 12904 650225. 76
4188833. 34 2. 74064
650325. 76 4188833. 34 2. 41749 650425. 76
4188833. 34 2. 15962
650525. 76 4188833. 34 1. 94672 650625. 76
4188833. 34 1. 75579
650725. 76 4188833. 34 1. 58020 650825. 76
4188833. 34 1. 42195
651125. 76 4188833. 34 1. 05913 649125. 76
4188883. 34 2. 69783
T *** AERMOD - VERSION 19191 *** *** C:\ Users\ Smith\ Dropbox\ My PC DESKTOP- 977GSBU)\ Documents\ HRA\ Ashley *** 10/ 26/ 23 AERMET - VERSION 18081 *** ***
16: 20: 52
PAGE 21
MODELOPTs: NonDFAULT CONC FLAT RURAL AD] U*
THE PERIOD ( 43824 HRS) AVERAGE CONCENTRATION
VALUES FOR SOURCE GROUP: VOL2
INCLUDING SOURCE( 5) : VOL2

DISCRETE CARTESIAN RECEPTOR POINTS
CONC OF OTHER IN MICROGRAMS/ M** 3

X- COORD ( M) Y- COORD ( M) CONC X- COORD ( M)

Y- COORD ( M) CONC
649225. 76 4188883. 34 3. 21332 649325. 76
4188883. 34 3. 83056
649425. 76 4188883. 34 4. 32597 649525. 76
4188883. 34 4. 46952
649625. 76 4188883. 34 4. 23511 649725. 76
4188883. 34 3. 85216
649825. 76 4188883. 34 3. 63143 649925. 76
4188883. 34 3. 36404
650025. 76 4188883. 34 3. 04215 650125. 76
4188883. 34 2. 70140
650225. 76 4188883. 34 2. 39548 650325. 76
4188883. 34 2. 13413
650425. 76 4188883. 34 1. 91367 650525. 76
4188883. 34 1. 73655
650625. 76 4188883. 34 1. 58591 650725. 76
4188883. 34 1. 44763
650825. 76 4188883. 34 1. 31819 651125. 76
4188883. 34 0. 99972
650125. 76 4188933. 34 2. 35936 650225. 76
4188933. 34 2. 11301
650325. 76 4188933. 34 1. 90294 650425. 76
4188933. 34 1. 71586
650525. 76 4188933. 34 1. 55983 650625. 76
4188933. 34 1. 43284
650725. 76 4188933. 34 1. 32186 650825. 76
4188933. 34 1. 21810
651125. 76 4188933. 34 0. 94472 650425. 76
4188983. 34 1. 55299
650525. 76 4188983. 34 1. 41469 650625. 76
4188983. 34 1. 30094
650725. 76 4188983. 34 1. 20657 650825. 76
4188983. 34 1. 12212
651125. 76 4188983. 34 0. 89282 650525. 76
4189033. 34 1. 29439
650625. 76 4189033. 34 1. 19041 650725. 76
4189033. 34 1. 10519
650825. 76 4189033. 34 1. 03291 651125. 76
4189033. 34 0. 84240
650525. 76 4189083. 34 1. 19137 650625. 76
4189083. 34 1. 09795
650725. 76 4189083. 34 1. 01861 650825. 76
4189083. 34 0. 95313
651125. 76 4189083. 34 0. 79266 650525. 76
4189133. 34 1. 09985
650625. 76 4189133. 34 1. 01898 650725. 76
4189133. 34 0. 94536
650825. 76 4189133. 34 0. 88383 651125. 76
4189133. 34 0. 74394
650781. 98 4189510. 65 0. 57575 650760. 33
4189397. 50 0. 66456
T *** AERMOD - VERSION 19191 *** *** C:\ USerS\ Smith\ DrOpbox\ My PC DESKTOP- 977GSBU)\ Documents\ HRA\ Ashley *** 10/ 26/ 23 AERMET - VERSION 18081 *** ***
16: 20: 52
PAGE 22
MODELOPTs: NonDFAULT CONC FLAT RURAL ADJ U*
THE PERIOD ( 43824 HRS) AVERAGE CONCENTRATION
VALUES FOR SOURCE GROUP: VOL3
INCLUDING SOURCE( 5) : VOL3

DISCRETE CARTESIAN RECEPTOR POINTS
CONC OF OTHER IN MICROGRAMS/ M** 3

X- COORD ( M) Y- COORD ( M) CONC X- COORD ( M)

Y- COORD ( M) CONC
649676. 34 4188314. 55 9. 98764 649629. 66
4188294. 84 8. 12311
649810. 15 4188312. 48 11. 52187 649364. 10
4188360. 20 4. 75178
649327. 80 4188355. 01 4. 31161 649380. 70
4188758. 52 8. 50456
650495. 81 4188841. 51 3. 14728 650597. 47
4188832. 17 2. 69525
650536. 27 4188878. 85 2. 71563 650577. 76
4188877. 81 2. 54997
650602. 66 4188860. 18 2. 53762 650610. 95
4188880. 93 2. 40977
650638. 10 4188858. 53 2. 40974 650664. 10
4188331. 03 3. 00590
650668. 72 4188350. 83 3. 00567 650677. 96
4188379. 86 2. 98686
650699. 74 4188414. 84 2. 89867 650758. 47
4188658. 36 2. 49311
650765. 73 4188678. 82 2. 43348 650773. 65
4188706. 54 2. 35703
650778. 27 4188726. 34 2. 30322 650805. 33
4188805. 53 2. 03584
650806. 65 4188824. 01 1. 98520 650811. 27
4188843. 81 1. 92107
650814. 57 4188862. 29 1. 86396 650846. 24
4188924. 98 1. 63562
650850. 86 4188951. 38 1. 56519 650854. 82
4188976. 46 1. 50226
650698. 00 4188307. 32 2. 80084 650692. 60
4188291. 80 2. 80687
650724. 82 4189245. 80 1. 08672 650726. 07
4189273. 37 1. 03794
650856. 27 4189006. 30 1. 43650 650857. 23
4189022. 60 1. 40172
650859. 15 4189041. 29 1. 36179 650859. 15
4189058. 54 1. 32828
650860. 58 4189076. 28 1. 29264 650861. 54
4189094. 49 1. 25736
650857. 71 4189113. 19 1. 22695 650847. 16
4189118. 94 1. 22756
650848. 12 4189134. 76 1. 19677 650850. 04
4189155. 37 1. 15671
650851. 48 4189171. 66 1. 12578 650853. 87
4189184. 12 1. 10152
650856. 75 4189199. 46 1. 07242 650857. 71
4189213. 36 1. 04795
650860. 58 4189226. 30 1. 02434 650862. 50
4189242. 60 0. 99665
650865. 38 4189258. 42 0. 97008 650867. 77
4189275. 19 0. 94340
650868. 73 4189291. 49 0. 91931 650872. 09
4189309. 23 0. 89297
650874. 00 4189325. 04 0. 87114 650875. 92
4189340. 38 0. 85085
650878. 80 4189355. 24 0. 83152 650881. 19
4189373. 45 0. 80952
650884. 55 4189390. 71 0. 78921 650888. 86
4189407. 01 0. 77042
650889. 82 4189427. 14 0. 75039 650891. 74
4189443. 43 0. 73450
650895. 09 4189461. 17 0. 71745 650898. 45
4189475. 55 0. 70394
650898. 45 4189489. 93 0. 69236 650902. 28
4189504. 31 0. 67960
650709. 41 4188344. 56 2. 78784 650722. 45
4188284. 03 2. 65860
650745. 73 4188280. 30 2. 55403 650735. 49
4188223. 50 2. 52499
650721. 52 4188167. 62 2. 49239 650525. 76
4188133. 34 3. 22934
651125. 76 4188133. 34 1. 43944 649125. 76
4188183. 34 2. 15334
649225. 76 4188183. 34 2. 48010 649325. 76
4188183. 34 2. 89100
649425. 76 4188183. 34 3. 48684 649525. 76
4188183. 34 4. 40262
649625. 76 4188183. 34 5. 53061 649725. 76
4188183. 34 6. 08776
649825. 76 4188183. 34 6. 32118 649925. 76
4188183. 34 6. 82259
T *** AERMOD - VERSION 19191 *** *** C:\ Users\ Smith\ Dropbox\ My PC DESKTOP- 977GSBU)\ Documents\ HRA\ Ashley *** 10/ 26/ 23 AERMET - VERSION 18081 *** ***
16: 20: 52
PAGE 23
MODELOPTs: NonDFAULT CONC FLAT RURAL ADJ U*
THE PERIOD ( 43824 HRS) AVERAGE CONCENTRATION
VALUES FOR SOURCE GROUP: VOL3
INCLUDING SOURCE( 5) : VOL3

DISCRETE CARTESIAN RECEPTOR POINTS
CONC OF OTHER IN MICROGRAMS/ M** 3

X- COORD ( M) Y- COORD ( M) CONC X- COORD ( M)

Y- COORD ( M) CONC
650025. 76 4188183. 34 6. 61625 650125. 76
4188183. 34 6. 00279
650225. 76 4188183. 34 5. 40258 650325. 76
4188183. 34 4. 72209
650425. 76 4188183. 34 4. 04499 650525. 76
4188183. 34 3. 43893
650625. 76 4188183. 34 2. 92518 650725. 76
4188183. 34 2. 50265
650825. 76 4188183. 34 2. 15896 651125. 76
4188183. 34 1. 46044
649125. 76 4188233. 34 2. 33495 649225. 76
4188233. 34 2. 73792
649325. 76 4188233. 34 3. 22526 649425. 76
4188233. 34 3. 90123
649525. 76 4188233. 34 4. 97688 649625. 76
4188233. 34 6. 48972
649725. 76 4188233. 34 7. 43349 649825. 76
4188233. 34 7. 82330
649925. 76 4188233. 34 8. 41621 650025. 76
4188233. 34 7. 94074
650125. 76 4188233. 34 7. 09997 650225. 76
4188233. 34 6. 19546
650325. 76 4188233. 34 5. 23507 650425. 76
4188233. 34 4. 36138
650525. 76 4188233. 34 3. 63010 650625. 76
4188233. 34 3. 04296
650725. 76 4188233. 34 2. 57813 650825. 76
4188233. 34 2. 20928
651125. 76 4188233. 34 1. 47993 649125. 76
4188283. 34 2. 52179
649225. 76 4188283. 34 3. 01585 649325. 76
4188283. 34 3. 62624
649425. 76 4188283. 34 4. 42566 649525. 76
4188283. 34 5. 68923
649625. 76 4188283. 34 7. 70406 649725. 76
4188283. 34 9. 30317
649825. 76 4188283. 34 9. 98479 649925. 76
4188283. 34 10. 63775
650025. 76 4188283. 34 9. 73193 650125. 76
4188283. 34 8. 46513
650225. 76 4188283. 34 7. 06798 650325. 76
4188283. 34 5. 74576
650425. 76 4188283. 34 4. 65065 650525. 76
4188283. 34 3. 79721
650625. 76 4188283. 34 3. 14450 650725. 76
4188283. 34 2. 64313
650825. 76 4188283. 34 2. 25306 651125. 76
4188283. 34 1. 49799
649125. 76 4188333. 34 2. 72119 649225. 76
4188333. 34 3. 30781
649325. 76 4188333. 34 4. 08164 649425. 76
4188333. 34 5. 09378
649525. 76 4188333. 34 6. 61190 649625. 76
4188333. 34 9. 27628
649725. 76 4188333. 34 12. 01002 649825. 76
4188333. 34 13. 27410
649925. 76 4188333. 34 13. 86341 650025. 76
4188333. 34 12. 20215
650125. 76 4188333. 34 10. 09155 650225. 76
4188333. 34 7. 96944
650325. 76 4188333. 34 6. 21641 650425. 76
4188333. 34 4. 90067
650525. 76 4188333. 34 3. 93887 650625. 76
4188333. 34 3. 23043
650725. 76 4188333. 34 2. 69860 650825. 76
4188333. 34 2. 29105
651125. 76 4188333. 34 1. 51342 649125. 76
4188383. 34 2. 94317
649225. 76 4188383. 34 3. 62377 649325. 76
4188383. 34 4. 57719
649425. 76 4188383. 34 5. 91204 649525. 76
4188383. 34 7. 85905
649625. 76 4188383. 34 11. 38792 649725. 76
4188383. 34 16. 14259
649825. 76 4188383. 34 18. 67285 649925. 76
4188383. 34 18. 80664
650025. 76 4188383. 34 15. 56022 650125. 76
4188383. 34 11. 89170
650225. 76 4188383. 34 8. 81638 650325. 76
4188383. 34 6. 61793
T *** AERMOD - VERSION 19191 *** *** C:\ Users\ Smith\ Dropbox\ My PC DESKTOP- 977GSBU)\ Documents\ HRA\ Ashley *** 10/ 26/ 23 AERMET - VERSION 18081 *** ***
16: 20: 52
PAGE 24
MODELOPTs: NonDFAULT CONC FLAT RURAL ADJ U*
THE PERIOD ( 43824 HRS) AVERAGE CONCENTRATION
VALUES FOR SOURCE GROUP: VOL3
INCLUDING SOURCE( 5) : VOL3

DISCRETE CARTESIAN RECEPTOR POINTS
CONC OF OTHER IN MICROGRAMS/ M** 3

X- COORD ( M) Y- COORD ( M) CONC X- COORD ( M)

Y- COORD ( M) CONC
650425. 76 4188383. 34 5. 10733 650525. 76
4188383. 34 4. 05511
650625. 76 4188383. 34 3. 30091 650725. 76
4188383. 34 2. 74415
650825. 76 4188383. 34 2. 32192 651125. 76
4188383. 34 1. 52375
649125. 76 4188433. 34 3. 18352 649225. 76
4188433. 34 3. 97586
649325. 76 4188433. 34 5. 12403 649425. 76
4188433. 34 6. 85915
649525. 76 4188433. 34 9. 54992 649625. 76
4188433. 34 14. 40340
649725. 76 4188433. 34 22. 93402 649825. 76
4188433. 34 28. 55914
649925. 76 4188433. 34 26. 80518 650025. 76
4188433. 34 19. 82327
650125. 76 4188433. 34 13. 65907 650225. 76
4188433. 34 9. 52885
650325. 76 4188433. 34 6. 93632 650425. 76
4188433. 34 5. 26721
650525. 76 4188433. 34 4. 14290 650625. 76
4188433. 34 3. 35236
650725. 76 4188433. 34 2. 77549 650825. 76
4188433. 34 2. 34114
651125. 76 4188433. 34 1. 52640 649125. 76
4188483. 34 3. 42997
649225. 76 4188483. 34 4. 35322 649325. 76
4188483. 34 5. 73416
649425. 76 4188483. 34 7. 93948 649525. 76
4188483. 34 11. 73148
649625. 76 4188483. 34 19. 02810 649725. 76
4188483. 34 35. 49091
650425. 76 4188483. 34 5. 36777 650525. 76
4188483. 34 4. 19167
650625. 76 4188483. 34 3. 37570 650725. 76
4188483. 34 2. 78525
650825. 76 4188483. 34 2. 34326 651125. 76
4188483. 34 1. 52035
649125. 76 4188533. 34 3. 68035 649225. 76
4188533. 34 4. 74001
649325. 76 4188533. 34 6. 38280 649425. 76
4188533. 34 9. 14908
649525. 76 4188533. 34 14. 39134 649625. 76
4188533. 34 26. 24989
649725. 76 4188533. 34 64. 67384 650425. 76
4188533. 34 5. 38754
650525. 76 4188533. 34 4. 18790 650625. 76
4188533. 34 3. 36287
650725. 76 4188533. 34 2. 76929 650825. 76
4188533. 34 2. 32678
651125. 76 4188533. 34 1. 50693 649125. 76
4188583. 34 3. 91863
649225. 76 4188583. 34 5. 11108 649325. 76
4188583. 34 7. 01342
649425. 76 4188583. 34 10. 36891 649525. 76
4188583. 34 17. 28721
649625. 76 4188583. 34 36. 17104 649725. 76
4188583. 34 0. 00000
650425. 76 4188583. 34 5. 31588 650525. 76
4188583. 34 4. 12942
650625. 76 4188583. 34 3. 31565 650725. 76
4188583. 34 2. 73102
650825. 76 4188583. 34 2. 29549 651125. 76
4188583. 34 1. 48875
649125. 76 4188633. 34 4. 09341 649225. 76
4188633. 34 5. 37934
649325. 76 4188633. 34 7. 46234 649425. 76
4188633. 34 11. 22592
649525. 76 4188633. 34 19. 33046 649625. 76
4188633. 34 43. 76064
649725. 76 4188633. 34 0. 00000 649825. 76
4188633. 34 0. 00000
649925. 76 4188633. 34 72. 15382 650025. 76
4188633. 34 28. 10931
650125. 76 4188633. 34 15. 34833 650225. 76
4188633. 34 9. 82653
650325. 76 4188633. 34 6. 90505 650425. 76
4188633. 34 5. 15787
650525. 76 4188633. 34 4. 02287 650625. 76
4188633. 34 3. 24020
T *** AERMOD - VERSION 19191 *** *** C:\ Users\ Smith\ Dropbox\ My PC DESKTOP- 977GSBU)\ Documents\ HRA\ Ashley *** 10/ 26/ 23 AERMET - VERSION 18081 *** ***
16: 20: 52
PAGE 25
MODELOPTs: NonDFAULT CONC FLAT RURAL ADJ U*
THE PERIOD ( 43824 HRS) AVERAGE CONCENTRATION
VALUES FOR SOURCE GROUP: VOL3
INCLUDING SOURCE( 5) : VOL3

Lathrop City CouncilNovember 13, 2023

Lathrop City Council
November 13, 2023