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anticipated end users are expected to provide services ranging from industrial and manufacturing users to service commercial and office (tenants are not known at this time). Each building includes two dock-high doors for a total of 22 for the entire Project.

The Project proposes 677 parking spaces and 121,879 square feet (15%) of irrigated landscaped area. The applicant is proposing approximately 53,300 cubic yards of grading. Furthermore, the Project includes two driveways along Zeiders Road with the southernmost driveway being signalized and aligning with Scott Road Commerce Center.

Location
The site is generally located in the southern area of the City, south of Scott Road, north of Keller Road, west of Interstate 215, along the western side of Zeiders Road (APN: 384-150-001).

IMAGE 1 – PROJECT LOCATION – AERIAL
Appeal No. PLN25-0208
The GSEJA filed an appeal of the Planning Commission’s November 12, 2025 approval of PP No. PLN23-0245, claiming the Planning Commission erred in its decision to approve the Project by determining the Project would not result in further impacts on an already pollution-burdened citizenry. GSEJA provided information depicting the severity of the level of pollution and health hazards the City of Menifee and its citizens are experiencing. The appeal letter reaffirms its concerns that were presented in its original letter dated September 24, 2025 (and reiterated in a Item Title: 11.1
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City of Menifee Staff Report
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February 4, 2026

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November 11, 2025 comment letter), which was responded to by staff, in conjunction with our California Environmental Quality Act (CEQA) consultant, in the Final Environmental Impact Report (EIR).

The commenter provides a table of data which gives the false impression that the area surrounding the Project site is disproportionately impacted. However, the proposed Project would not result in significant and unavoidable air quality impacts. Localized air quality impacts would be less than significant and there are no significant air quality impacts to local residents as a result of approval of the proposed Project.

Both the September 24, 2025 comment letter and the November 11, 2025 comment letter, in addition to the November 19, 2025 appeal letter for the Project, contained concerns from GSEJA regarding air quality, greenhouse gas (GHG) emissions, land use and planning, transportation and traffic, growth inducing impacts, alternatives, and population and housing. Staff, the Project Applicant and our CEQA consultant reviewed the claims presented by GSEJA and have determined that the Final EIR adequately addressed concerns raised and no further CEQA analysis is warranted.

Furthermore, the GSEJA comment letters indicated that there was a technical/procedural error and that a technical appendix (Appendix E – GHG, Energy) was not adequately made accessible to the public as required by CEQA. While this was initially true, the omission was noticed by staff and the Draft EIR was officially re-circulated establishing a new 45-day public review period. The original public circulation date for the Draft EIR was August 13, 2025; however, staff noticed the omission of Appendix E and a new public circulation date began on September 2, 2025 and included the appendix.

As such, the previous responses to these resource topics are still appropriate, and no additional points were raised in the appeal letter which would require further analysis.

Environmental Determination
The Planning Commission adopted Resolution No. PC25-676 certifying an EIR on November 12, 2025 determining the Project will have a significant effect on the environment (related to GHG Emissions). However, an EIR was prepared for this Project pursuant to the provisions of the CEQA. Mitigation measures were made as a condition of the approval of the Project and a Mitigation Reporting or Monitoring Plan (MMRP) was adopted for this Project. A Statement of Overriding Considerations was adopted for this Project and Findings were made pursuant to the provisions of CEQA. Following the Project’s approval, a Notice of Determination (NOD) was filed with the Riverside County Clerk’s Office on November 13, 2025.

The Final EIR, as well as all its technical appendices, can be accessed for review on the City website: https://www.cityofmenifee.us/325/Environmental-Notices-Documents.

Public Notice
The proposed Project was noticed on January 11, 2026 for the January 21, 2026 City Council hearing. The public hearing was continued until the February 4, 2026 City Council meeting. A public notice was published in The Press Enterprise and notices were mailed to property owners and non-owner residents within a 1,000-foot radius of the Project site. The proper public notice Item Title: 11.1
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was posted on-site, and in addition, all relevant public agencies and those requesting notification were notified of the public hearing.

STRATEGIC PLAN OBJECTIVE
Thriving Economy

FISCAL IMPACT
There is no fiscal impact associated with the recommended action.

ATTACHMENTS

1. Appeal Letter – GSEJA

2. Resolution – GSEJA

3. Exhibit A – Response to GSEJA Appeal Letter

4. Resolution – EIR

5. Exhibit A – Final EIR

6. Exhibit B – MMRP

7. Exhibit C – Findings of Fact

8. Resolution – Plot Plan

9. Exhibit A – Conditions of Approval

10. November 12, 2025 PC Staff Report

11. Project Exhibits

12. Public Hearing Notice
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RESOLUTION NO. 26-______

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF MENIFEE, CALIFORNIA DENYING APPEAL NO. PLN25-0208 SUBMITTED ON

BEHALF OF THE GOLDEN STATE ENVIRONMENTAL JUSTICE

ALLIANCE FOR THE MENIFEE (PEMCOR) BUSINESS PARK
PROJECT, PLOT PLAN NO. PLN23-0245
WHEREAS, on December 21, 2023, the project applicant, Pemcor Properties, Inc. (“Applicant”), filed a formal application with the City of Menifee for the approval of Plot Plan (PP) No. PLN23-0245 Menifee (Pemcor) Business Park Project, a business park development consisting of 11 single-story buildings ranging in size from approximately 23,100 square feet to 37,840 square feet (total 337,770 square feet) on approximately 20 acres. The site is generally located in the southern area of the City, south of Scott Road, north of Keller Road, west of Interstate 215, along the western side of Zeiders Road (APN: 384-150-001); and
WHEREAS, collectively, all the applications are referred to as the “Project” or “Menifee (Pemcor) Business Park Project”; and
WHEREAS, pursuant to the requirements of the California Environmental Quality Act (CEQA), a Final Environmental Impact Report (EIR) and Mitigation Monitoring Reporting Program (MMRP) have been prepared to analyze and mitigate the Project's potentially significant environmental impacts; and
WHEREAS, on November 12, 2025, at a legally noticed public hearing, the Planning Commission voted 4-0-1 (Ramirez abstain) to certify the EIR, Findings of Fact, MMRP, and approve PP No. PLN23-0245 for the Project; and WHEREAS, on November 19, 2025, an application to appeal Planning Commission certification of the EIR for the Project and approval of PP No. PLN23-0245 was submitted by the Golden State Environmental Justice Alliance (GSEJA); and WHEREAS, on January 21, 2026, the City Council held a public hearing on the appeal of the Planning Commission’s approval of Plot Plan No. PLN23-0245 and continued the public hearing to a date certain, February 4, 2026; and WHEREAS, on February 4, 2026, the City Council of the City of Menifee held a public hearing on Appeal No. PLN25-0208 of the Planning Commission’s certification of the EIR and approval of PP No. PLN23-0245, considered all public testimony as well as all materials in the staff report and accompanying documents for the appeal, which hearing was publicly noticed by a publication in The Press Enterprise, a newspaper of general circulation, an agenda posting, notice to property owners within 1,000 feet of the Project boundaries, on-site posting at the Project site, and to persons requesting public notice.

NOW, THEREFORE, the City Council of the City of Menifee resolves as follows:

1. That the City Council finds the facts presented within the public record and within Exhibit “A” of the Resolution provides the basis to deny Appeal No. PLN25-0208.

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Appeal of Menifee (Pemcor) Business Park - GSEJA
February 4, 2026

2. The documents and materials that constitute the record of proceedings on which this Resolution has been based are located at the Community Development Department – Planning Division, 29844 Haun Road, Menifee, CA 92586. This information is provided in compliance with Public Resources Code section 21081.6.

PASSED, APPROVED AND ADOPTED this 4th day of February 2026. _________________________
Bob Karwin, Mayor Pro Tem
Attest:
______________________________
Stephanie Roseen, City Clerk
Approved as to form:
______________________________
Jeffery T. Melching, City Attorney
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to Russell Brown, City of Menifee

from Kent Norton, MIG Riverside

re Pemcor Business Park EIR – Response to City Council Appeal by GSEJA

date January 27, 2026

Subsequent to the Planning Commission hearing on November 12, 2025, an appeal to the City Council was submitted for the Menifee (Pemcor) Business Park Project by the Golden State Environmental Justice Alliance (GSEJA) dated November 19, 2025. A second appeal application submitted by Lozeau Drury on behalf of Supporters Alliance For Environmental Responsibility (SAFER) was received on November 20, 2025 . However, the SAFER appeal was subsequently withdrawn during the week of 1/26/26. It should be noted these two commenters each submitted two previous comment letters on the Pemcor project, one during the DEIR 45-day review period and one after the close of the review period and before the Planning Commission hearing. Responses to these previous letters were prepared and distributed per CEQA requirements.

The following are responses to the GSEJA comments raised in the ir 11/19/26 appeal letter. The appeal letter with comments marked in red is provided at the end of this memorandum.

Golden State Environmental Justice Alliance (GSEJA) Letter Response G-1: GSEJA states its reasons for appeal and denial of the project, citing its September 24, 2025, comments on the Draft EIR, inclusive of expert comments prepared by Soil Water Air Protection Enterprise (SWAPE) on the Draft EIR and September 19, 2025, and its November 11, 2025, comment letter on the Final EIR. The City has already provided detailed responses to these comments. The appellant is directed to Final EIR Responses H -1 to H-39 and the memorandum prepared by MIG, Incorporated (Inc.), “Pemcor Business Park EIR – Response to Late GSEJA and SAFER Comment Letters,” dated November 12, 2025. This document is already part of the administrative record as part of the Planning Commission staff report materials.

Response G-2: GSEJA is re -submitting information regarding the existing pollution burden for the census tract (606043279) the Pemcor Business Park is located in. This information is substantially the same as GSEJA submitted in its November 11, 2025, comments on the Final EIR. As explained in the MIG memorandum responding to those comments, this information is substantially the same as that provided in the Draft EIR Item Title: 11.1
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(pp. 4.3-7 to 4.3-11) and Draft EIR Appendix E (pp. 3 -11 to 3-14), which provided a detailed discussion on “Existing Health Risks and Disadvantaged Communities.” The EIR discussion includes not only information on the census tract’s CalEnviroScreen pollution burden, but also information on other existing and planned light industrial facilities within ¼ mile of the project site and South Coast Air Quality Management District (SCAQMD) Multiple Air Toxics Exposure Study (MATES) V study. Importantly, the CalEnviroScreen pollution, health, and socioeconomic percentile data presented by GSEJA are the same as that disclosed in the EIR.

Furthermore, as a point of clarification, the City notes that, as described in CalEnviroScreen 4.0 Report, the CalEnviroScreen model assesse s cumulative impacts using both pollution burden and population characteristic data that are scored and combined to determine a single CalEnviroScreen score.1 This methodology accounts for differences in individual pollution burdens across geographic area so that no one single adverse environmental or public health effect or socioeconomic condition can render an area disadvantaged. Thus, while individual percen tile rankings provide useful information, they may or may not be representative of the total CalEnviroScreen score.

Finally, as another point of clarification, GSEJA has incorrectly referred to census tract 606043279 as an “Senate Bill (SB) 535 Disadvantaged Community designation, clearly identifying this as a disadvantaged community under state law.” As explained in the Draft EIR (p. 4.3 -10, emphasis added), “Communities that are within the top 25th percentile for total CalEnviroScreen scores are considered disadvantaged communities pursuant to SB 535. According to the Office of Environmental Health Hazard Assessment (OEHHA) CalEnviroScreen 4.0 Map, the proposed project is Census Tract 6065043279.

This area shows an average pollution indicator percentile of 41% based on the CalEnviroScreen indicators (e. g., exposure, environmental effects, population characteristics, socioeconomic factors) and has a population of 5,075 people . . . Table

4.3-3 summarizes the CalEnviroScreen indicators for census tract 606504 3279. As shown in Table 4.3 -3, census tract 6065043279 is not within the top 25% of total CalEnviroScreen percentiles throughout the State and, therefore, is not considered a disadvantaged community pursuant to SB 535.” Thus, GSEJA has, again, failed to submit any information that was not already considered in the Draft EIR’s detailed analysis and evaluation of potential adverse air quality impacts.

Response G-2.1: There were no critical omissions of data or materials. When the City determined that one of the DEIR appendices had not been posted for public review, it issued a revised Notice of Availability and Notice of Completion through the State Clearinghouse which provided an extended and complete 45-day public review period after posting the “missing” appendix. Therefore, the critical air quality modeling data was made available to the public for the necessary period of time which was duly noted

1 Office of Health Hazard Assessment, 2021. CalEnviroScreen 4.0. October 2021.

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in the subsequent notices and DEIR document in the appropriate locations. In this way the document did not violate CEQA’s fundamental mandate for adequate informational documents and meaningful disclosure. The second notice is clearly posted on CEQAnet and all the necessary appendices are posted on that site as well.

The commenter also identified the following list of “legal compliance violations” supposedly committed by the EIR:
• CEQA 15121 – Informational Disclosure. DEIR Appendix E was provided to the public for the full 45 -day extended review period, as discussed in Response G-2.1 above.
• CEQA 15378 – Project Piecemealing. The EIR correctly evaluates the whole of the Pemcor project and the commenter incorrectly conflates the project with other non-related industrial projects in the surrounding area (cumulative project). • SB 1000 – Environmental Justice. The commenter is incorrect, the project site is not part of a disadvantaged community as outlined in Response G-3 below. • SB 330/SB 8 – Housing Crisis Act. As explained in the Final EIR response to comments and the response to supplemental comments to the Planning Commission, the Pemcor project is consistent with the General Plan and zoning designation for the site which allows mixed use but does not require residential uses to be built on any one particular project. Similarly, the Housing Element does not rely on or designate specific residential units on this site (see also Response G-4.1 below).
• Govt Code 65302(h) – General Plan Env. Justice Element. Response G-5 below demonstrates the project is consistent with the General Plan goals and policies cited by the commenter.
• Govt Code 1135 – Language Access. The Menifee community may have a 30% Hispanic population but the population of the area surrounding the proposed project does not have similar demographic and language characteristics (see Response G-10.1).
• CEQA 15131(c) – EJ Analysis. In 2021, as part of the City’s adoption of its 6th Cycle Housing Element Update, the City determined there were no disadvantaged communities identified within city limits that would trigger the preparation of environmental justice element. Nonetheless, the City voluntarily incorporated environmental justice goals and policies into its Land Use Element in 2021 (see Responses G-3 and G-4 for more information).

Response G-2.2: The commenter is incorrect – there is no “piecemealing” involved with this project, the entire Pemcor Business Park development was described and analyzed in the DEIR. The “segmentation” seems to refer to the cumulative projects list which identifies other industrial developments proposed by other developers o n other sites at distance from the proposed project. These various projects have no direct Item Title: 11.1
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relationship to the proposed Pemcor project in terms of ownership or application so the CEQA terms piecemealing and segmentation simply do not apply.

Response G-3: GSEJA asserts that, despite census tract 6065043279 being an SB 535 Disadvantaged Community, the City has failed to conduct a required Senate Bill (SB) 1000 analysis of environmental justice. First, as a point of clarification, census tract 6065043279 is not an SB 535 Disadvantaged Community (see response G -2 above).

Second, GSEJA’s references to Government Code Section 65302(h) and CEQA Guidelines Section 15131 (c) as “requiring” a project -level environmental justice analysis is incorrect for the following reasons:
• SB 1000 was adopted in 2016 to promote environmental justice through local land use planning. The law requires local governments with disadvantaged communities in their planning areas to develop environmental justice policies as part of their general plans. This requirement is triggered when a local government adopts or revised two or more general plan elements concurrently. Since the Pemcor Business Park does not involve revisions to the Menifee General Plan, SB 1000 does not apply to the project. The City notes that, in 2021, as part of the City’s adoption of its 6th Cycle Housing Element Update, the City determined there were no disadvantaged communities identified within city limits that would trigger the preparation of environmental justice element. Nonetheless, in 2021, the City voluntarily incorporated environmental justice goals and policies into its Land Use Element.
• CEQA Guidelines Section 15131, Economic and Social Effects, states (emphasis added), “Economic or social information may be included in an EIR or may be presented in whatever form the agency desires.” Pursuant to CEQA Guidelines Section 15005, Terminology, the use of the word “may” identifies “a permissive element which is left fully to the discretion of the public agencies involved” in the CEQA proces s. Thus, this section does not require the City to include an environmental justice analysis in the EIR. Se parately, Subsection (c) sets forth that economic, social, and housing factors shall be considered together with technological and environmental factors “in deciding whether changes in a project are feasible to reduce or avoid significant environmental effects.” As explained in Response G-1 and G -2 and referenced materials, the Menifee Pemcor Business Park EIR constitutes a. fact -based evaluation of the proposed Project that fully identifies and discloses the Project’s potential air quality and GHG impacts and identifies feasible measures given the project’s specific technological, environmental, economic, social, and other factors.

Response G-4: GSEJA asserts the project continues decades of environmental racism systematically concentrating pollution facilities in communities of color while protecting affluent areas, refers to the Inland Empire as a “sacrifice zone” for working class-families Item Title: 11.1
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and communities of color, and provides CalEnviroScreen on environmental and health burdens for census tract 6065043279. This information is substantially the same as GSEJA submitted in its November 11, 2025, comments on the Final EIR. As explained in the M IG memorandum responding to those comments, the Draft EIR discloses pertinent environmental justice information, adequately evaluates all project emissions sources, and concludes, based on substantial evidence, that the project would not result in substant ial pollutant concentrations at sensitive receptor locations. Furthermore, GSEJA’s generalized comments on the land use patterns in the Inland Empire as whole may not be construed on the nature of development in Menifee, which incorporated in 2008, nor the project’s census tract, which is not a disadvantaged community, specifically.

Response G-4.1: The commenter assumes the site must be used for housing but in fact the EDC-SG designation allows housing but does not require it. This designation is primarily intended to generate jobs/employment with housing only helping to support those uses and help reduce trip lengths between residential and non-residential uses in the area. In addition, the City’s Housing Element does not depend on the maximum or any housing being constructed on parcels within the EDC -SG category and is only a small part of the City’s vacant land survey as part of the Housing Element. The Housing Element identifies more vacant land sites for potential residential units than are needed to meet the City’s Regional Housing Needs Assessment (RHNA) allocation from SCAG during the period of the most recently updated Housing Element (6th Cycle, 2021 to 2029). The City has complete discretion as to where it encourages or allows future housing to be built, as well as how it implements its approved Housing Element. Thus, the City may approve a development with anywhere from 487 down to zero residential units on the Project site under the mixed -use EDC-SG designation. There has been no zoning change to the mixed-use EDC-SG designation, there is no evidence that there is in fact a decrease on residential capacity in the EDC-SG zone, and therefore no violation of SB 330 or SB 8. Therefore, the project does not result in any “housing violations”.

Response G-5: GSEJA submits comments regarding the adequacy of the EIR’s evaluation of the project’s consistency with certain Menifee General Plan goals and policies, however, as described in more detail below, the project would not conflict with the General Plan policies identified by GSEJA.
• Policy S-7.1. GSEJA correctly identifies that asserts this policy calls for the City to “continue to require environmental analysis for proposed projects that may produce harmful levels of greenhouse gas”. Consistent with this policy, the Notice of Preparation prepared for the project identified greenhouse gases (GHG) as a potential environmental effect of the project, which was subsequently evaluated in project EIR.

Thus, the City has, in fact, conducted the environmental analysis required by Policy S-7.1.

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• Policy EJ -3.6. This policy states, “Continue to collaborate with the [SCAQMD], California Air Resources Board (CARB), utility providers, Southern California Association of Governments (SCAG), Western Riverside Council of Governments (WRCOG), and nonprofit organizations, neighborhood groups, and other community organizations to improve air quality, food availability, renewable energy systems, sustainable land use and reduce [GHGs].” GSEJA purports the project conflicts with this policy because the project wo uld degrade air quality. GSEJA is mistaken. As discussed in Draft EIR Section 4.3.4, Air Quality Impacts and Mitigation Measures, the proposed Project would not result in any significant and unavoidable air quality impacts. Furthermore, as stated on Draft EIR page 6 -2, “In developing its CEQA significance thresholds, the SCAQMD considered the emission levels at which a project’s individual emissions would be cumulatively considerable (SCAQMD, 2003; page D-3). The proposed project’s construction and operatio nal emissions would be below applicable SCAQMD regional thresholds for criteria air pollutants after the incorporation of recommended Mitigation Measure AQ -1. Therefore, the proposed project would not result in a cumulatively considerable increase in crite ria air pollutants.” Thus, the Project would not degrade air quality. Furthermore, the City provided each of the agencies and organizations identified in Policy EJ -3.6 with the opportunity to comment on the EIR and, therefore, did provide the SCAQMD and CARB with the opportunity to collaborate on the project. For these reasons, the project would not conflict with Policy EJ-3.6.
• Goal OSC -10. GSEJA purports that Goal OSC -10 “mandates” GHG emissions reductions, which the project conflicts with because it increases GHG emissions. As a point of clarification, General Plan Goal OSC -10 states, “An environmentally aware community that is responsive to changing climate conditions and actively seeks to reduce local greenhouse gas emissions.” In the case of the proposed project, the City has incorporated Mitigation Measures (MM)-GHG-1 to GHG-4 to reduce the project’s GHG emissions levels. The project, therefore, is consistent with Goal OSC-10.

• Policy C-5.3. GSEJA purports that the project conflicts with this policy because it was add 239 daily truck trips; however, Policy C -5.3 states, “Support efforts to reduce/eliminate the negative environmental impacts of goods movement.” As discussed in Draft EIR Section 4.17.4, the project would not result in any potentially significant transportation-related impacts, with Impact TRANS -1 finding the project would be consistent with all applicable goals and policies of the General Plan Circulation Element. Thus, the project would not have any negative circulation effects that require mitigati on. While the type and size of the project results in significant GHG emissions compared to the City’s 3,000 MTCO2e threshold, GHG mitigation measures are included to help reduce project GHG emissions while improving the city’s ability to move goods throughout the region.

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Response G-5.1: The following responses regarding VMT are from the Final EIR as prepared by Ganddini:

FEIR Response H-18
This comment claims that the project VMT screening assessment is inaccurate because the WRCOG VMT Tool results for TAZ 1053 are based on conditions as of 2012, which would not have included any warehousing uses.

First, this comment incorrectly references a 2012 model scenario associated with the Riverside County Transportation Analysis Model (RIVTAM), which has now been superseded by the Riverside County Model (RIVCOM). The WRCOG VMT Tool used for the project screening assessment is based on a more recent update, which incorporates the latest RIVCOM data and includes 2018 and 2045 model scenarios.

Furthermore, additional review of the socio-economic data (SED) for the RIVCOM 2018 model scenario shows that TAZ 1053 includes 369 total employment, including 110 employees in the transportation and warehousing sector. Therefore, the latest WRCOG VMT Tool, as used for the project screening assessment, includes SED inputs associated with comparable land uses to the proposed land use such that it is expected to provide a reasonable estimate of the project VMT impacts and there is nothing unique about the project, or the project TAZ, that would otherwise be mis -represented by utilizing the data from the WRCOG VMT Tool.

FEIR Response H-20
This comment quotes the WRCOG SB 743 Implementation Pathway Document Package, which was developed by WRCOG in 2019 as a guidance document to help member agencies implement SB 743. While this document may include general information, the City of Menifee, as the Lead Agency, has ultimate authority in establishing the applicable methodology and thresholds as set forth in the City of Menifee Traffic Impact Analysis Guidelines for Vehicle Miles Traveled (Adopted June 3, 2020, Updated January 2022).

The comment incorrectly describes the threshold of 33.6 VMT per service population as the Citywide average rather than the County average and omits the full quote from the WRCOG SB 743 Implementation Pathway Document Package, which is as follows:
“OPR recommends that a per capita or per employee VMT that is fifteen percent below that of existing development may be a reasonable threshold [emphasis added].” These omissions downplay the intent of the WRCOG SB 743 Implementation Pathway Document Package to serve as an early guidance document for member agencies and Item Title: 11.1
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that other thresholds may also be appropriate. The comment further omits that the WRCOG SB 743 Implementation Pathway Document Package contains additional thresholds for consideration (see “Thresholds Assessment” included in the Executive Summary), as follows:
“Potential VMT thresholds were assessed within the context of the objectives of SB 743, legal opinions related to the legislation, proposed CEQA Guidelines updates, and the technical advisory produced by OPR. Fehr & Peers identified four threshold options for consideration by lead agencies.

1. Thresholds consistent with OPR’s Technical Advisory, recommending that proposed developments generate VMT per person that is 15% below existing VMT per capita,

2. Thresholds consistent with Lead Agency air quality, GHG reduction, and energy conservation goals,

3. Thresholds consistent with RTP/SCS future year VMT projects by jurisdiction or subregion, and

4. Thresholds based on baseline VMT performance by jurisdiction or sub-region [emphasis added].”
The City of Menifee elected to adopt a threshold of significance that is a variation of the fourth option recommended by the WRCOG SB 743 Implementation Pathway Document Package. Therefore, the project’s VMT screening assessment provides substantial evidence in accordance with the appropriate methodology and thresholds established by the City of Menifee, as the Lead Agency, to support a finding of less than significant VMT impact; no revisions to the EIR are necessary.

Conclusion: As noted above and also in FEIR Responses H-18 through H-20, the VMT analysis was conducted in full conformance with City-established methodologies and no revisions to the EIR or VMT technical report prepared by Ganddini Group are necessary.

Response G-5.2: The project site is adjacent to Zeiders Road and the two access points created for the Project and shown on the site plan avoid sharp curves or dangerous intersections. The two access points were identified by City staff based on fire and police department emergency access requirements. The site was modeled using standard WB67 (72’) sized truck trailers to eliminate any site access limitations. The City Engineering Department evaluated truck turning radii in its review of the Project site plans and did not identify any conditions around any of the Project buildings requiring modifications to the site plan in terms of safe truck access. Project Plan Sheet C07 shows the fire truck radius and Sheet AS1 shows truck turning movements in grey scale.

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Relative to emergency access, the site plan shows two full width driveways onto Zeiders Road capable of allowing access for emergency vehicles without the use of a Knox box which can incrementally slow response time. In addition, there is adequate travel lanes around all of the Project buildings wide enough to allow police and fire vehicles unrestricted access. FEIR Response H-24 indicates the site not only has unobstructed horizontal views of Zeiders Road but also no significant elevational (vertical) site distance issues as well. Therefore, the Project has no significant impacts relative to geometric design features and emergency access.

Response G-6: GSEJA re -submits comments on the potential cumulative impacts associated with the concentration of industrial parks in Menifee that are substantially the same as GSEJA submitted on November 11, 2025. The City notes that the Draft EIR discloses there are five existing and planned light industrial facilities within one-quarter mile of the project site, and fully evaluates the potential cumulative air quality, traffic, and other impacts of the proposed project. GSEJA has not submitted any new substantial evidence that demonstrates the proposed project would result in a significant cumulative environmental impact, has not clarified the geographic scope for its cumulative impact assumptions, and has not provided the sources for its employment growth projections.

The appellant is directed to the MIG memorandum responding to GSEJA’s November 11, 2025 comments for additional information on the EIR’s cumulative impacts analysis.

Response G-7: GSEJA re-submits comments on the technical adequacy of the EIR’s air quality analysis that are substantially the same as SWAPE submitted on September 19, 2025.
• As explained in the Final EIR (Response H -35), changes to the project’s modeled fleet mix were made based on site -specific information from the traffic analysis prepared for the project.

• As explained in the Final EIR (Response H-34), the City revised the EIR’s air quality modeling to use a 25.4 mile haul trip distance as suggested by SWAPE. This change did not change the conclusions of the EIR’s air quality analysis.

• As explained in the Final EIR (Response H -36), the City revised the EIR’s health risk assessment to use a Fraction of Time at Home (FAH) of 1 for individuals from the third trimester to age 16 as suggested by SWAPE. This change did not change the conclusions of the EIR’s air quality analysis.

• As explained in the Final EIR (Response H-32), Phase I/II information compiled for the project indicates it is unlikely biosolids containing polyfluoroalkyl substances (PFAS) were deposited at the project site in the past. GSEJA has not submitted any new substantial evidence to indicate PFAS are present at the project site.

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Response G-8: GSEJA states the health risk assessment (HRA) prepared for the EIR is deficient because it did not consider multi -pollutant effects, elevated baseline conditions, vulnerable populations, and cumulative impacts. As noted in Response G-2, the EIR clearly discloses the project’s setting with regard to environmental burdens and socioeconomic conditions, and the City considered this information in its assessment of the project’s potential air quality impacts. Furthermore, the HRA is not deficient. The HRA was conducted in accordance with SCAQMD and OEHHA recommended guidance and reflects a conservative analysis of potential health risks on sensitive populations for the following reasons:
• As explained in the Draft EIR (p. 4.3 -25 and Appendix E, pp. 4 -5 and 4-8), the diesel HRA is based on estimated ground level concentrations of PM 10 instead of PM2.5. While PM 2.5 is a subset of PM 10, use of the PM 10 fraction results in the modeling and assessment of risks on a larger share of particulate pollutants than would occur using the PM2.5 fraction. It should be noted there would be other risks from other pollutants but that DPM is the primary pollutant of concern. This is the reason multi-pollutant risks are not addressed in this analysis.

• As explained in the Draft EIR (Appendix E, Section 4.2.4) and Final EIR (Response C-5), construction diesel particulate matter (DPM) emissions would be the primary driver of health risks when combining construction and operational related emissions. The excess cancer risk estimate at the MEIR assumes the receptor is an infant (including 3rd trimester) for the first 2 years of exposure and then develops to a child and finally to an adult over the next 28 years of exposure. As shown in Table 4 -18 of Appendix E, the modeled annual average DPM concentrations in construction years 1 and 2 are substantially higher than years 3 through 30. Thus, assuming all early life stages occur during these exposure years results in the most conservative estimate of potential adverse health risks.

• As noted in Response G-7, the FEIR revised the HRA to set the fraction of time at home to 1, even though this change was not required pursuant to SCAQMD or OEHHA guidance. Thus, the HRA conservatively assumes receptors are exposed to modeled pollutants 24 hours per day and nearly 365 days per year.

The above assumptions serve to provide a conservative (i.e., likely to overestimate) potential adverse carcinogenic and non-carcinogenic health risks that could potentially be associated with project emissions. As documented in the EIR, the project’s potential carcinogenic and non-carcinogenic health risks would be less than significant even with these health protective assumptions incorporated into the modeling and assessment methodology. Finally, the Draft EIR (p. 4.3 -26) included an evaluation of cumulat ive health risks impacts and concluded this impact would be less than significant. For these Item Title: 11.1
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reasons, the appellant has not provided substantial evidence that supports the assertion that the EIR’s HRA is deficient.

Response G-9: GSEJA generally asserts that the City rejects feasible mitigation measures to reduce GHG emissions but does not provide any substantial evidence to support its assertion. GSEJA’s comments are substantially the same as that submitted by SWAPE on September 1 9, 2025, and by Supporters Alliance for Environmental Responsibility (SAFER) on November 12, 2025. The appellant is directed to the Final EIR Response H-38, and to Response S-3 above for detailed responses on why the measures suggested by GSEJA are not feasible for the project.

Response G-9.1: Alternatives. As outlined in FEIR Response H -25, the EIR did select a reasonable range of alternatives given the General Plan land use designation and zoning classification of the site, as well as the identified significant impacts of the proposed Project (air quality and greenhouse gas emissions). In addition to t he No Project – No Development Alternative, one of the alternatives is less intense development (Alternative 1, -25%) but similar development to the proposed Project which is in keeping with selecting alternatives that could reduce or eliminate the significant impacts of the Project but also meet all or at least to some degree the objectives of the Project.

The introductory sections go into detail about the possible range of alternatives that could have been studied (Section 5.2, No Project Alternatives and Alternatives Considered But Rejected). The General Plan designation for the site (EDC -SG) could allow a wide range of potential residential and non-residential land uses. However, many of these would be mixed use projects based on the General Plan land use designation for the site which does allow certain residential and other non -residential uses.

Alternative 2 – EDC Mixed Use (C/LI/MFR) would provide 75,000 square feet of retail commercial space, 150,000 square feet of light industrial space, and 400 apartments (20 acres x 20 units/acre). Alternative 3 – EDC Mixed Use (O/BP/R) would provide 100,000 square feet of office space, 100,000 square feet of business park uses, and 300 “for ownership” condominiums (20 acres x 15 units/acre).

City staff considered various mixes of these land uses but knowing that a substantial amount of commercial use would generate substantial amounts of traffic, and a substantial amount of residential units in this area would not be compatible with non - residential uses surrounding the project site. In the end the City selected these alternatives as the most reasonable range of alternatives that could reduce or eliminate one or more of the Project’s significant impacts. Due to the size of the site, no reasonable development-related project was found that could eliminate the one significant impact of the project (GHG emissions) and the two mixed use alternatives actually resulted in significant air quality impacts as well.

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Based on the size of the site, it is likely no level of urban development allowed by the General Plan and zoning on this site would reduce potential GHG emissions to less than significant levels due to the City’s relatively low adopted GHG significance thr eshold (3,000 MTCO2e).

FEIR Alternative 1 would not achieve the goals of the Project to the same degree as the proposed Project, and FEIR Alternatives 2 and 3 even less so since they further reduce non-residential development in favor of added residential development. In the end Alternative 1 was selected as the “Environmentally Superior Alternative.” After reviewing this response, the commenter proceeded to suggest five different alternatives to reduce GHG emissions which w as the lone significant impact of the project:
• Zero-Emission Logistics Alternative: All-electric operations with solar canopies and battery storage. The primary objective of this project is to create a multi -tenant business park with a variety of uses (light industrial, manufacturing, office) to support a diverse employment base. Logistics warehousing is not consistent with that primary objective but c ertainly efforts to achieve or strive toward zero emissions would help reduce GHG emissions, possibly even below the City’s 3,000 MTCO2e significance threshold.
• Light Manufacturing Alternative: Lower truck traffic, higher employment density .

As stated above, the primary objective of this project is to create a multi -tenant business park with a variety of uses (light industrial, manufacturing, office) to support a diverse employment base. Focusing on only one aspect of this development category would unduly limit the diversity of future employment in this center, but any land use changes that would reduce truck traffic would incrementally reduce GHG emissions as well.
• Mixed-Use Transit -Oriented Alternative: Incorporating affordable housing near future transit. Zeiders Road will eventually have transit service so it would be possible to add market-rate or affordable housing in this area to take advantage of future transit. However, the DEIR did examine two alternatives that included different forms of housing and determined that the addition of residential uses would substantially increase anticipated traffic which in turn would increase air pollutant and GHG emissions.
• Phased Development Alternative: Allowing technology improvements before full buildout. The business park project has 11 separate buildings with a variety of potential uses (light industrial, manufacturing, office) which will practically result in a phased development or occupancy of future uses. However, it is more difficult Item Title: 11.1
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to require multi-tenant developments to implement “future technology” since it is unknown what such technology will be and if or how various uses could implement such technology.
• Community-Serving Commercial Alternative: Retail, services, and amenities for residents. Section 5 of the DEIR explained that any alternatives that included a high proportion of commercial uses would substantially increase project traffic and thus increase GHG emissions. Therefore this is not a feasible alternative compared to the proposed project.

The commenter concludes that “the City's claim that no alternative could eliminate GHG impacts due to the 3,000 MTCO2e threshold is defeatist and incorrect -a zero-emission facility with renewable energy could achieve carbon neutrality. ” The EIR did propose mitigation measures to help reduce GHG emissions including a Transportation Demand Management (TDM) Plan for future uses to reduce their vehicle miles travelled (VMT) impacts. The project includes allowance for future rooftop photovolta ic solar panels depending on the specific future use/user.

Response G-10: GSEJA submits a general assertion that the City has dismissed “California Department of Justice recommendations” without adequate analysis.

Assuming that GSEJA is referring to the Department of Justice’s (DOJ) guidance document “Warehouse Project: Best Practices and Mitigation Measures to Comply with the California Environmental Quality Act,” this comment is similar to other comments submitted by the South Coast Air Quality Manageme nt District, the Golden State Environmental Justice Alliance (GSEJA), and Advocates for the Environment on the Draft EIR. As explained in Final EIR Responses C-6, C-9, H-38, and I-9, the City has reviewed the referenced document and determined that many of the best practices in the document are commensurate with the requirements of existing regulations and/or the mitigation measures incorporated into t he EIR. The EIR has incorporated feasible measures to reduce GHG emissions, and the additional recommendations made by the appellant are either not feasible for the project or not necessary to address an identified significant impact.

Response G-10.1: The City provides Spanish language translation services at meetings and for critical public documents, however, the City has determined that CEQA documents are not essential public documents per state law. In this case, neither the project site nor the immediate surrounding area is consider ed a disadvantaged community in need of focused language services relative to this project (see Response G-2 above). In addition, it should be noted that no comments were received during the NOP/Scoping period, the Draft EIR review period, or subse quently at the Planning Commission indicating a need or desire for the CEQA documents for this project to be provided in Spanish.

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Response G-10.2: The commenter stated the city’s public notices failed to:
• Identify the site as in a disadvantaged community. As discussed in Response G-2 above, the project site and immediate surrounding area are not within a disadvantaged community.
• Disclose the 93rd percentile cardiovascular disease burden. The appropriate area- specific information from the CalEnviroScreen website was provided in DEIR Section 3.3, Air Quality.
• Mention cumulative impacts from surrounding warehouses. Potential contributions of the proposed project to cumulative impacts were discussed in each of the environmental analysis sections of the DEIR (4.1 through 4.20) and, other than greenhouse gas emissions, the project was not found to make a substantial contribution to any significant cumulative regional impact. Specifically, the Draft EIR (p. 4.3 -26) included an evaluation of cumulative health risks impacts and concluded this impact would be less than significant.
• Provide health risk information in lay terms . DEIR Section 4.3, Air Quality, describes the health effects of various air pollutants and goes into great detail about the potential health risks of the proposed project. • Offer resources for technical assistance to residents. It is not clear what “technical assistance” has not been made available to local residents regarding the planning or environmental processes for this project. The project planner, Russell Brown, was contacted by and discussed project characteristics with only one local resident during the NOP and EIR review process. No other related services were requested.

Response G-10.3: The commenter indicated the following regarding the City’s previous responses to their earlier comments on the DEIR:
• Dismissive tone toward environmental justice concerns . The commenter is not clear about this comment but the DEIR and FEIR both demonstrate the project is not within a disadvantaged community so that it is possible the commenter considered this a “dismissal” of its overall concerns regarding EJ. That is not t he case as the City has actually incorporated a number of EJ goals and policies into various elements of its recently updated General Plan.
• Reliance on technicalities rather than substantive analysis. It is not clear to which sections or analyses the commenter was referring but the City believes the DEIR and DEIR data, analyses, and conclusions are based on substantial evidence and not “technicalities” and opinions.
• Failure to provide requested data and calculations. Not clear what is meant but as indicated above, the City believes the DEIR and DEIR data, analyses, and conclusions are based on substantial evidence and not “technicalities” and Item Title: 11.1
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opinions. The misposting of Appendices E and L -2 have been explained and the 45-day public review period was extended to allow full review time for the DEIR and its appendices once the appendices were posted. All of the calculations for air quality and gre enhouse gas emissions were provided in the appendices and summarized in the DEIR sections.
• Mischaracterization of legal requirements. Again, the commenter did not explain particulars of this comment and all of their comments regarding various legal CEQA requirements were addressed in FEIR (response to comments and errata sections), and subsequent response to comments memos (including this one). • Refusal to consider feasible mitigation. The DEIR did consider feasible mitigation, and the FEIR and subsequent response to comments memos (including this one) indicate a desire to accommodate the recommended additional or expanded mitigation to the extent practical or feasible which is all expl ained in the various CEQA documents as appropriate.

Response G -10.4: The commenter indicated t he FEIR fail ed to analyze economic impacts on the disadvantaged community. Again, it must be made clear the project site and surrounding properties are not located within a disadvantaged community (see Response G-2 above).

Job Quality Analysis Absent:
• No wage data for proposed 553 jobs. CEQA does not involve the evaluation of fiscal impacts such as wages unless a clear connection to adverse physical changes to the environment can be shown. In this case, the commenter did not suggest one other than a supposed link to a disadvantaged community. The DEIR and FEIR clearly indicated the site and surrounding properties are not within or part of a disadvantaged community. Even if such data was requ ested/required by the City and/or CEQA, it would be overly speculative to try to estimate specific wage data since this is a multi- tenant business park with no committed tenants yet.
• No comparison to living wage standards . As outlined above, specific wage data is not required by the City or CEQA and in this case is overly speculative since none of the actual tenants have been identified yet.
• No analysis of benefits availability. The project is consistent with the General Plan and zoning so no specific community benefits are required as part of development, and the commenter did not explain the purpose or content of such an analysis. • No local hire requirements. At most this is a potential planning consideration of the project approval process and not a CEQA-related issue. The project is consistent with the General Plan and zoning and the City has no specific local hiring requirements for such projects.

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• No job training partnerships. This is a potential planning consideration of the project approval process at most and not a CEQA-related issue. The project is consistent with the General Plan and zoning and the City has no specific requirements for such projects regarding job training partnerships.

Displacement Impacts ignored:
• Property value impacts from industrial encroachment. There is no “encroachment” since the project is consistent with the General Plan and zoning designations and only one vacant farmhouse is being removed by this project.
• Small business displacement from truck traffic . The commenter did not clarify the intent of this comment so it is not clear what if any displacement of small businesses might occur from project -related truck traffic. In any case, such financial effects of project planning are not considerations under CEQA which focuses on physical changes to the environment.
• Residential displacement from cumulative impacts. No evidence was presented that critical housing, existing or planned, would be displaced by development of the project or other cumulative development.
• Loss of land for community -serving uses . The project site has a General Plan designation and zoning classification of “Economic Development Corridor -Southern Gateway” designation (EDC-SG) which allows for a mixture of specific uses as part of the “mixed use” land use grouping (i.e., light industrial, manufacturing, office, and residential in support of non -residential uses). The selection of land uses under the mixed use category necessari ly means some uses will be chosen over other uses.

Since the project is consistent with the General Plan and zoning, the General Plan EIR addressed the potential land use and other environmental impacts of this land use selection process.

Fiscal Impact omissions:
• Public health costs from increased pollution . The project is consistent with the General Plan and zoning designations of the site, and the potential environmental and health impacts of project air pollutant emissions were calculated and evaluated in DEIR Section 4.3, Air Quality, and the health risk assessment outlined in DEIR Section

4.3.4, Impacts b and c. CEQA does not involve the evaluation of fiscal impacts unless a clear connection to adverse physical changes to the environment can be shown. • Infrastructure wear from truck traffic . The project is consistent with the General Plan and zoning designations of the site. In addition, the commenter suggested no guidance on how such indirect impacts would be calculated or assessed. CEQA does not involve the evaluation of fiscal impacts unles s a clear connection to adverse physical changes to the environment can be shown.

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• Emergency service demands . Potential impacts of the project on emergency services were addressed in DEIR Section 4.17, Public Services (police and fire) including fiscal impacts related to development impact fees to help fund such services.
• Lost property tax from residential prohibition . The project is consistent with the General Plan and zoning designations of the site. In addition, the commenter suggested no guidance on how such indirect impacts would be calculated or assessed.

Finally, CEQA does not involve the evaluation of fiscal impacts such as these unless a clear connection to adverse physical changes to the environment can be shown and the commenter provided no such connection.

Response G-11: Climate Vulnerability. GSEGA asserts the DEIR fails to analyze general climate vulnerability factors such as heat island effects, extreme heat events, etc. The appellant is direct to Draft EIR p. 4.8 -4 and 4.8-5 for a discussion of potential climate change effects in California , Section 4.10.4 for a discussion of the project’s potential hydrology, flooding, and water quality impacts, and Chapter 4.20 for setting and impact discussions related to wildfire. As a point of clarification, the EIR’s GHG analysis , including the project direct and indirect GHG emissions levels and consistency with applicable plans and policies adopted for the purposes of reducing GHG emissions, is a fact-based analysis of the project’s potential GHG and related climate change impac ts.

This is because, as explained in the Draft EIR (p. 4.8-2), “Gases that “trap” heat in the atmosphere and affect regulation of the Earth’s temperature are known as ‘greenhouse gases’ . . .GHG that contribute to climate regulation are a different type of pollutant than criteria or hazardous air pollutants because climate regulation is global in scale, both in terms of causes and effects . . . GHG emissions from human activities such as fuel combustion (e.g., CO2) and refrigerants use (e.g., hydrofluorocar bons, or HFCs) significantly contribute to overall GHG concentrations in the atmosphere, climate regulation, and global climate change . . . The effects of increased GHG concentrations in the atmosphere include increasing shifts in temperature and precipit ation patterns and amounts, reduced ice and snow cover, sea level rise, and acidification of oceans.

These effects in turn will impact food and water supplies, infrastructure, ecosystems, and overall public health and welfare.”
Response G-12: The City believes it has complied with the spirit (intent) as well as the legal and procedural requirements of CEQA and has made a good faith effort to provide a comprehensive detailed environmental information document for the public and decision-makers. The DEIR indicates the potential impacts of the project would not be unequally distributed onto at -risk populations or neighborhoods already bearing environmental burdens. The project is consistent with the General Plan and zoning designations, will only have one environmental impact that is significant and unavoidable even with mitigation (i.e., greenhouse gas emissions), and would benefit Item Title: 11.1
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the community overall (see “Findings and Statement of Overriding Considerations”) when viewed in relation to its environmental impacts.

Response G -13: The commenter made a number of r ecommendations which was essentially the following laundry list of “requirements” the project should implement. It should be noted that many of these items appear to be related to the project’s supposed impacts to a disadvantaged neighborhood, but as the DEIR and FEIR clearly demonstrate, the project and surrounding properties are not within a disadvantaged community:

Zero-Emission Operations Timeline:
• 50% zero-emission (ZE) trucks by 2030. This project is a multi-tenant business park which has no established tenants at present so the City cannot feasibly place a requirement on future buyers or tenants regarding their trucking fleet. This action would be implemented to the degree that new truck fleet operators will be required to buy zero emission trucks.
• 100% zero-emission trucks by 2035. See response above regarding 50% ZE trucks by 2030. See response above relative to 50% zero emission trucks by 2030.
• Installation of charging infrastructure before occupancy . The project will install charging infrastructure required by the California Green Building Code and the City’s development requirements.
• Monthly emissions monitoring and public reporting. The project is not a logistics warehouse subject to the SCAQMD “Warehouse Actions and Investments to Reduce Emissions (WAIRE) Rule 2305 so monthly emissions monito ring and reporting is not required.

Community Health Protection:
• $5 million community benefit fund for health programs. The DEIR found no nexus or rough proportionality of project impacts that would require or suggest such a contribution since the air pollutant/health risk impacts of the project are less than significant under CEQA (only GHG emissions were found to be significant). • Indoor air filtration systems for nearby schools. As outlined in DEIR Section 4.9, Hazards and Hazardous Materials, there are no schools within a quarter mile of the project site and its air pollutant emissions would not exceed any SCAQMD or state (OEHHA) significance thresholds for health risks. Therefore, there is no nexus o r rough proportionality for imposing such a requirement on this project. • Community air monitoring network with real -time data. There is no nexus or rough proportionality to require such a measure for a project that is consistent with the GP and zoning and the EIR air quality assessment does not indicate it will result in significant air quality or health risk impacts.

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• Quarterly health impact assessments . See response above for community air monitoring network suggestion.

Local Hiring and Training:
• 50% local hire requirement (Menifee residents) . While the City may encourage new employers to hire local workers, it cannot mandate numerical hiring quotas.

In addition, the project is a multi -tenant business park which has no established tenants at present so the City cannot feasibly place a requirement on future buyers or tenants regarding their individual hiring practices. This is also not a CEQA issue but the City may work with the applicant and/or future tenants to encourage local hiring practices.
• Partnership with community colleges for job training . This is not a CEQA issue but the City may work with the applicant and/or future tenants to encourage partnering with local community colleges for job training. • Living wage requirement ($25/hour minimum). The City cannot legally mandate wage requirements for future businesses since at present none have been selected for this multi-tenant business park.
• Healthcare benefits for all employees . The City cannot legally mandate future tenants to provide healthcare benefits to their workers as those business practices are regulated by state and federal agencies and private insurance corporations.

Operational Restrictions:
• No operations between 10 PM and 6 AM . The City will enforce whatever appropriate operational hours limitations are established in its Municipal Code.

Since no tenants are currently identified, it is not possible to restrict or preclude future users from overnight activities.
• No idling beyond 3 minutes . The project is already subject to a 5 -minute idling limitation by City Conditions of Approval (COAs) consistent with SCAQMD recommendations. The appellant/commenter did not provide any support for imposing a more strict idling limit and the air quality ass essment for the project did not recommend a more stringent idling limit since air pollutant emissions were estimated to be less than significant.
• Designated truck routes avoiding residential streets . The City has established truck routes and mapping so trucks/drivers utilizing the proposed project will access the designated streets. The City will also impose a Condition of Approval (COA) restricting project trucks to designated truck routes and to inst all the necessary signage on the site for drivers to follow.
• Maximum 100 truck trips per day . DEIR Section 4.17, Transportation, did not identify any significant traffic -related impacts of the project related to either vehicle miles traveled (VMT) or levels of service (LOS) which is no longer considered a CEQA significance criteria for traffic impa cts. Therefore, there is no nexus or rough proportionality for requiring a daily truck traffic limit on the project.

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Environmental Justice Compliance:
• Environmental Justice Advisory Committee (EJAC) with voting power . The City has an Environmental Justice Element (EJE) of its General Plan. However, CalEnviroScreen has not identified any disadvantaged communities within the City.

The EJE does not include an EJAC at this time and one would have to implemented at a City level and not for a particular development project. • Monthly compliance reports in English and Spanish. This would need to be a city- wide program as part of the EJE monitoring and it not currently in place. • Annual environmental justice impact assessment. This would need to be a city - wide program as part of the EJE monitoring and it not currently in place. • Community right to enforcement action . This would need to be a city -wide program as part of the EJE monitoring and it not currently in place.

Response G-14: The commenter/appellant states “the FEIR is fundamentally flawed and a new EIR must be prepared for the proposed project and circulated for public review. Appellant requests the City of Menifee City Council reverse the decision of the Planning Commission's certification of the project and require a new EIR. ” The City believes the DEIR and FEIR comply with the intent and legal requirements of CEQA and do not require revision and recirculation or preparation of a new EIR.

CONCLUSION
Staff’s conclusion is the GSEJA appeal letter does not provide significant new information or identify new significant impacts or information regarding the project or the DEIR analysis. City staff concludes the information provided in the Draft EIR, its appendices (including Appendices E and L for which the public was provided adequate time to review), the Final EIR and all response to comments and supporting materials adequately address all the issues and comments raised. Therefore, the EIR meets the requirements of CEQA and it and its technical studies d o not need to be revised and recirculated for additional public review.

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City of Menifee
City Cieri<

CITY OF MENIFEE
NOV 1 9 2025 APPEAL APPLICATION
Received
Decision to be appealed: Menifee (Pemcor)
Business Pa APPELLANT/REPRESENTATIVE Golden State Environmental Justice Alliance Projec t, Plot Plan
PL~~~Ei~~{951) 279-4697~AX NO. ______ E-~~L [email protected] ADDRESS 765 N Main Street, Suite 151, Corona, CA 92880

STREET CITY STATE ZIP
PROPERTY OWNER ___________________ _____ _
(if different) LAST FIRST Ml.

PHONE NO. _______ FAX NO. _______ E-MAIL ________ _
ADDRESS _ _______________________ ______ _

STREET CITY STA TE ZIP
Menifee (Pemcor) Business Park Project, Plot Plan PLN23-O245 Name of Project, APN/ Address: .A.PN 384 150 001, 33521 Zeiders Rd Menifee, CA 92584 Appealing the decision of (Specify Community Development Director, Building and Safety Director City Manager' Planning Commission): __._P ..... l ... a ..... nCL.JnLLljn..Llg~C....,o,£1m..L.U.JmUJj.,..scwscuia ... n...__ ______ ______ _ Action and Date: Certification of the FEI R for the project at hand, 11/12/2025 Explain specify what action or decision is being appealed:This appeal seeks to reverse the entire decisio of the Planning Commission's certification on 12 November 2025, which approved the Projec Please reference the attached 16-page appeal letter and pnor comments sent.

Do you have additional evidence not already presented? __ Yes X No. If Yes, please attach.

Appellant requests the Menifee City Council reverse the decision of the Planning What result to you want? i i n' i i n f h r • n r ·r n w EIR. 2025-11-19
Applicant's Signature -=p,f-tti--"Z!i.::::=====r-------- Date: _____ _ Owner Certification: I certi under the penalty of the laws of the State of California that I am the property owner of the property that is the subject matter of this appeal application. I am authorizing and hereby do consent to the filing of this application and acknowledge that the final approval by the City 9f Menifee, if any, may result in restrictions, limitations and construction obligations being imposed on this real property.

Owrter's Signature: ___________________ Date: _____ _
Print Name: ____________________________ _
Written authorization from the legal property owner is required. An authorized agent for the owner must attach a notarized letter of authorization from the legal property owner.

No application will be accepted until is complete and the fee paid.

Once complete, you will receive confirmation and a hearing date as well as additional appeal information. For questions, please contact the City Clerk at (951) 672-6777.

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11 November 2025
Planning Commission
City of Menifee
29844 Haun Road
Menifee, CA 92586
Delivered via email to:

Green Jobs & Clean Communities
[email protected]
[email protected]
planning [email protected]
Re: Supplemental Comments on Menifee (Pemcor) Business Park Project Environmental Impact Report (EIR), SCH No. 2024071016
Commissioners,
Golden State Environmental Justice Alliance (GSEJA) has presented arguments regarding the aforementioned project in the form of a:
• Comment Letter dated 24 September 2025, which objects to the EIR and documents systematic California Environmental Quality Act (CEQA) violations including deficient environmental justice analysis, missing air quality appendix, inadequate General Plan consistency review, violation of Housing Crisis Act requirements, insufficient transportation impact evaluation, and failure to address cumulative impacts on a disadvantaged community already experiencing severe pollution burdens.

GSEJA also provided technical review comments dated 19 September 2025 prepared by Soil Water Air Protection Enterprise (SW APE), concluding the project's air quality and health risk impacts may be underestimated. Most critically, the EIR fails to include Appendix E: Air Quality/Greenhouse Gas/Energy Report, preventing meaningful public review and violating CEQA's fundamental requirements for disclosure and transparency. While the City claims to have reissued the EIR on 2 September 2025 with Appendix E included, this belated disclosure does not cure the original CEQA violation where the entire public comment period proceeded without this critical information.

GSEJA's comprehensive technical review reveals critical deficiencies that warrant the Planning Commission's rejection of this proposed 337,770 ft2 industrial development spread across eleven buildings with 22 truck dock bays. The project site is in census tract 6065043279, which faces 93rd percentile cardiovascular disease burden, 80th percentile ozone pollution, and 78th Item Title: 11.1
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percentile traffic impacts, while the EIR systematically underestimates air quality impacts and fails to provide required environmental justice analysis for this already overburdened disadvantaged community.

Adding Pollution to an Already Overburdened Community
This industrial business park would be built in census tract 6065043279, a community that already bears severe environmental burdens in the entire state of California. According to the California Environmental Protection Agency's CalEnviroScreen 4.0 analysis, this community suffers in the following ways:

Environmental and Personal Health Crisis:
• 93rd percentile for cardiovascular disease burden, which reflects pollution's severe toll on community health
• 80th percentile for ozone burden, demonstrating dangerously poor air quality from industrial sources
• 78th percentile for traffic impacts, showing high exposure to truck and vehicle pollution • 50th percentile for hazardous waste facility impacts
• 46th percentile for PM (particulate matter) 2.5 burden, which indicates PM contamination • 43rd percentile for asthma incidence
• 36th percentile for solid waste facility impacts
• Senate Bill (SB) 535 Disadvantaged Community designation, clearly identifying this as a disadvantaged community under state law
1111~ 1:l~AM
(D E~Oepartmenb - >90-90
CardkNataJlar C~ae Parcenttl11 - ,. 90. 100
- >70 - 80 Cllati0111
ArcGIS Web Map
""'
CalEnviroScreen Cardiovascular Disease Results Data for Census Tract 6065043279, Source: California Environmental Protection Agency
2 Item Title: 11.1
Appeal of Planning Commission Decision for the Menifee (Pemcor) Business Park Project Item Page Number: 159

Menifee Mayor and City Council
February 4, 2026
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Community Vulnerability Factors:
• 40% lack high school education, demonstrating educational vulnerability that limits residents' economic opportunities
• 34% poverty rate, demonstrating economic vulnerability where households have total income below poverty level
• 30% Hispanic, 1 % African American, 2% Asian American residents: populations historically targeted for environmental racism
• Poor communities often located in areas with high levels of pollution, facing additional stress that weakens immune systems
• Poverty indicates residents may lack health insurance or access to vital medical care Environmental & Health Burden Analysis
Menifee (Pemcor) Business Park Project Locatlon
ten1111 Tract 6065043279
Clttlail Rndlng: lhe proposed Industrial development would be built In a community already exper1endng .. ......, environmental and health bunlens ranking In the IDp percentiles statewide. Adding 337,nO It• of Industrial space with 22 truck dod<s would wc,sen a>ndltlons In an already """""'rdened disadvantaged community.

CalEnviroScreen 4.0 Pollution & Health Rankings
f Cardlovucular Disease Burdon
Rel'lects pollution's severe toll on a,mmunlty he.11th Heart disease rates §ignJfic:anlfy elevated :~ Ozone Pollutlon Burden
ifffiiQS,.J,Hti
Wona thlln 91~ vf CA
1+)·$4.i,.J.j,;,,ti
Won;e INJI 80"9 at CA
Dange,(lusty poor air quality from industrial so...ces .ind vehlde emiWDM :II Traffic Impact Burden E+N@-,-J,,!1¢1
Worw tJt.ar, 1&-Y. ol CA
High exposure to truck and vehide pollution from he.ayY b'affic volumes 8 Hazardous Waste Fadllty lmpam li}Niri\JI
WOl'M~~ofCA
Proximity ta hazardous waste generattirs and l'ad6ties affecting air, water, and son quality. (; PM 2.5 Particulate Malter Burden • I • • • f
Wan,athan•~ofCA
Fine pattioJlate cDfltamination affecting respifatory and airdiovasct1lilr health A Asthma Incidence
W01ki than '3ti'. of CA
Bevated asthma rates reflecting poor air Qu.llity and respiratory health impacts Community Vulnerability Factors
400/o 340/o 300/o
LM:k High School EducaUon Below Poverty Line H15pank: PopulaHon sa 5)5 Disadvantaged Community: Offidally d151g~ under state '8w as requlrtng special envlmnment!JI prub!ction.

S8 1000 Prvtactlons: callfumla's envirt>flfTiffll3J justice law spedfkalty designed tD protect cnmmun~ like lhls from addltlonal pollutlon burdens.

Compounding YulnerabUftles: PcMttr lmlts ~ to hestthalre, wtlilkenli lnvoone systfmS, iWw:I reduc:'5" ablllty tD Cllpe wlttl addltlonal ~ stressor1.

Soun:a: Caldcsnll Envlrorvnental Protection Agency, talEIWtroscreen 'IO Prwpared tor: SUpplememal Convne,ts.on Menll'!e (Pema>r) EIL.slne,u Part Pro)ea EIR (501 No 2024071016) Data: Noileffber U, 2025 I PTllpalWI by:: Golden State EnvlftNmetlral Justice Alliance 3 Item Title: 11.1
Appeal of Planning Commission Decision for the Menifee (Pemcor) Business Park Project Item Page Number: 160

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February 4, 2026
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SB 1000, California's environmental justice law, was specifically designed to protect communities like this from additional pollution burdens. The law requires local governments to identify disadvantaged communities and implement policies to reduce cumulative health risks rather than worsen them. Government Code Section 65302(h) mandates that local agencies "identify objectives and policies to reduce the unique or compounded health risks in disadvantaged communities" through measures including "reduction of pollution exposure" and "improvement of air quality . "
The EIR ignores these existing conditions and the local community's legal protections. It fails to meaningfully analyze how industrial operations, 22 truck dock bays, and round-the-clock truck traffic will worsen health outcomes for residents who already face the 93rd percentile cardiovascular disease burden and elevated asthma rates. This breaches CEQA's fundamental mandate under Public Resources Code Section 21001(b) to "take all action necessary to provide the people of this state with clean air and water" and Section 21000(g) requiring "major consideration to preventing environmental damage, while providing a decent home and satisfying living environment for every Californian. "
When a community already ranks in the 93rd percentile for cardiovascular disease and 80th percentile for ozone pollution, adding 337,770 ft2 of industrial development with 22 truck docks generating hundreds of daily truck trips is not just poor planning-it is a violation of civil rights and the right to breathe clean air.

Critical CEQA Violation: Missing Appendix E
The City admits in Response H-4 that ''Appendix E was not initially included for public review" and claims the EIR was "reissued on September 2, 2025 with Appendix E included." This admission reveals a fundamental CEQA violation that cannot be cured by simply re-posting the document.

Appendix E: Air Quality/Greenhouse Gas/Energy Report contains the critical CalEEMod modeling data, emission calculations, and technical assumptions underlying the entire air quality and greenhouse gas analysis. Without this appendix, the public and decision-makers were deprived of the ability to meaningfully review and comment on:
• Model input parameters and assumptions
• Emission calculation methodologies
• Health risk assessment data
• Greenhouse gas (GHG) quantification methods
• Mitigation measure effectiveness calculations
CEQA requires that draft EIRs provide "adequate informational documents and meaningful disclosure" (CEQA § 15121 and PRC 21003(b)). The exclusion of Appendix E during the official public comment period constitutes a complete failure of this fundamental CEQA requirement. As SW APE correctly noted in their technical review, "Excluding Appendix E: Air 4 Item Title: 11.1
Appeal of Planning Commission Decision for the Menifee (Pemcor) Business Park Project Item Page Number: 161

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February 4, 2026
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Quality/Greenhouse Gas/Energy Report from public review does not comply with CEQA s requirements for adequate informational documents and meaningful disclosure. " The City's attempt to cure this violation by belatedly posting the appendix does not satisfy CEQA. The damage was done-the official comment period proceeded without this critical information. The City has not explained why the appendix was initially excluded, raising serious questions about transparency and good faith compliance with CEQA's public disclosure requirements.

A revised EIR with complete appendices must be prepared and recirculated for full public review.

Environmental Racism and the Cumulative Impact of Industrial Concentration This industrial project continues a decades-long pattern of environmental racism that has systematically concentrated polluting facilities in communities of color and low-income areas while protecting wealthier, predominantly white neighborhoods from industrial development.

The Inland Empire, like many other inland California communities, has become dumping grounds for logistics facilities that serve the consumption needs of affluent coastal communities while imposing health burdens on working-class families and communities of color.

The EIR fails to acknowledge or analyze this pattern of discriminatory land use decisions. It provides no cumulative impact analysis of the multiple warehouse and industrial projects that have been approved in the area, creating what environmental justice advocates recognize as a sacrifice zone , which is an area where residents are expected to bear health burdens that would never be tolerated in Newport Beach or other affluent communities.

This discriminatory pattern violates the Fair Housing Act and California's Unruh Civil Rights Act, which prohibit land use decisions that have a disparate impact on protected classes. As the California Attorney General has noted, "the burdens of pollution should not be focused on sensitive populations or on communities that already are experiencing its adverse effects. " Yet that is precisely what this project would do.

Recent industrial projects within Menifee city limits include, but are not limited to:
• Menifee Commerce Center (2,885 employees projected)
• Menifee Commerce Center Phase II (1,962 employees projected) • Northern Gateway Commerce Center (2,267 employees projected) • Ares Warehouse on Murrieta (952 employees projected)
• Capstone Industrial (1,205 employees projected)
• Wheat Warehouse (151 employees projected)
• Corsica Business Park (477 employees projected)
• Trumble and Watson Warehouse (571 employees projected) 5 Item Title: 11.1
Appeal of Planning Commission Decision for the Menifee (Pemcor) Business Park Project Item Page Number: 162

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Combined, these bulleted projects alone will cumulatively generate 10,470 employees, and with the additional other warehouses in the area not mentioned, the cumulative number will expand to about 18,000 employees, which represents about 210% of the City ofMenifee's employment growth forecast over 26 years-all concentrated in industrial uses.

The cumulative health impacts from multiple warehouse facilities include :
• Concentrated diesel truck traffic creating corridors of toxic air pollution, contributing to what health experts term diesel death zones , where cumulative pollution exposure creates severe public health consequences.
• 24/7 industrial noise disrupting sleep and contributing to stress-related health problems. • Increased PM and ozone worsening respiratory conditions in a community with 93rd percentile cardiovascular disease and 43rd percentile asthma rates • Traffic safety hazards on residential streets not designed for heavy industrial truck traffic. • Economic displacement as industrial uses drives out community-serving businesses and housing opportunities.

Cumulative Warehouse Employment Impact Analysis
Industrial Concenb"ation in Menifee Exceeds 26-Year Growth Forecast Crltlcal Finding: Recent lndus1Jtal projects approved In Menifee, Including the proposed P\?maJr Business Park, wm OJmUlatlvel'/ generat,, appruxlma!el'/ 18,000 empioyees--fl!presenHng 210% of the Oty's total employment growth fon!rast ov.r 26 year.; (2019-2045).

Impllcatlon: This massive mna,m,atlon of warehouse and industrial development represenls unplanned, unprecedented grtJVill, that will overwhelm mmmunlty Infrastructure and dramaH"'li'I worsen air quality In an already disadvantaged area.

I
0 -nn.Jna eoi--= Toe Oly of-•• Gener.II Plan fore<35ts 8,500 Jolls gn,wth belweon 2019-2045 (26 yem}. Toe lndus1!1al proJeds Usted below wlll - mon, than - this amounl--<XIOO!ntrated prtnar1v In warehouse and loglsUcs uses !hat generate 5'grlllc>nt trod< lr.!fflc and -· Industrial Development vs. City Employment Forecast
8,500
,,.,.....,
,,;,.,.,.
aty Employment
Growth Forecast
(201~2045)
Olmulatlve Warehouse
Employment fram
Recent Projecls
210°/o
lndustnal warehouse proJects represent MORE THAN DOUBLE the City's entire 26-year employment growth forecast-concentrated 1n a single, polluting industry sector
6 Item Title: 11.1
Appeal of Planning Commission Decision for the Menifee (Pemcor) Business Park Project Item Page Number: 163

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February 4, 2026
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Recent Industrial/Warehouse Projects in Menifee {Partial Ust) Menffee Commerce Cenl:l!!r
2,885 Mlployees pmjectl!d
Northern GateWay Commerce center
2,267 employees projected
c.apstane Industrial
1,205 employees projected
Corsica Business Park
477 ..,,ployees pmJectl!d
Perna>r llwlness Parle (Proposed)
553 employees pmjectl!d
Cumulative Health & Environmental Impacts
Menifee Commen:e Center Phase II
1,952 employees projected
Ares Warehouse on Murrieta
052 .... p1oyees pmjected
Wheat W111rehou:se
151 employees projected
Trumble .nd Wi ts.on Wilft hou,e
571 employee, projected
+ --Pn>jecb ... 1,ooomoreemp)oyees
• COncentrall!d dlelal truck lnfflc aeaHng C0IT1dors of IDXlc air polMm, contJtbutlng ID "diesel death ,ones" when! rumulatlve exposure creates sew,n, public heallh a,nsequena,s
.a. lA/7 lnd-..l nol111 disrupting sleep and coolr1buUng In stress-related health problems In surrounding resldenHal areas A,,. Inaeuoid PMZ.5 and CIZDIHI worsening resplratnry mndlllons In a a,mmunlty already at 93rd percenUle for cardlffllaSaJlar disease and 43rd percenHle for asthma
.L. Traffic~ hazards on resldenUal sb'eels not designed for heavy lndustnal trud< traffic, endangering pedeslr1ans and cydlsls .A l:canomlc dlsplaament as lndUSlrtal uses drive out comml.lllty-seNlng businesses and elmlnab! t-.JusJng O!)flortlJnllles • Infrutructure slraln on roads, U!Jlltles, and emergency services beyond what was planned In General Plan forecasts Environmental Justice Vlolatlon: This pattem of lndustnal concentraHon In mmmunlHes of <Dior and low-Income areas, while protecting wealthier neighborhoods from such development, mnstitutes environmental racism. Communities like census tract 6065043279 should not be treated as "sacrifice zones" where residents are expected to bear health burdens that would never be tolerated in al!luent areas rtke Newport Beach or other mastal communlUes.

Sourcu: City of Maiifee Land Development Projects Map, SCAG 2024 Connect SoCal Demographics and Growtli Forecast, lnd1VJdual Project EIRs Prapal'tii for: Supplemental Comments on Menifee (PemCDr) Busines.s Parl( Project EIR (SOI No 2024071016) Date: November 11, 2025 I Prepared by: Golden Shltt' Environmental Justice AJHance The Planning Commission must reject this pattern of environmental injustice. Communities of color and low-income families deserve the same environmental protections as wealthy neighborhoods. Children deserve to breathe clean air and attend schools not surrounded by diesel trucks.

Deficient Technical Analysis
The EIR's technical analysis systematically underestimates health risks to our community's most vulnerable residents: children, pregnant women, elderly residents, and those already suffering from cardiovascular and respiratory conditions.
• Fails to meaningfully analyze environmental justice impacts as required by CEQA Guidelines Section 15131(c). Despite census tract 6065043279 ranking in the 93rd percentile for cardiovascular disease, 80th percentile for ozone, 78th percentile for traffic, with a 34% poverty rate and a 40% lacking high school education, the EIR provides no substantive environmental justice analysis.
7 Item Title: 11.1
Appeal of Planning Commission Decision for the Menifee (Pemcor) Business Park Project Item Page Number: 164

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February 4, 2026
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• Fails to acknowledge that health risks from any level of additional pollution are magnified in a community already facing the 93rd percentile cardiovascular disease burden. Residents who already struggle with heart disease and respiratory conditions face exponentially greater harm from additional industrial emissions than healthy residents in clean-air communities.
• Fails to meaningfully analyze the project's compliance with General Plan policies including Goal S-7 (climate protection), Policy EJ-3.6 (air quality improvement), Goal OSC-10 (Greenhouse Gas (GHG) reduction), and Policy C-5.3 (reduce goods movement impacts). The project generates significant and unavoidable GHG emissions yet claims consistency without addressing this fundamental conflict. • Proves to be inconsistent with SCAG's 2024 Connect SoCal policies regarding housing development, equitable engagement, sustainable development, air quality reduction, and climate resilience (Policies 35-53, 64-66). The EIR's consistency analysis is misleading and fails to address the project's significant GHG impacts.

These analytical failures prevent the community from understanding the true health consequences of this project and deny the opportunity to demand adequate protection measures.

In a community already bearing the 93rd percentile cardiovascular disease burden, even "small" additional exposures can trigger severe health consequences including heart attacks, asthma attacks, emergency room visits, and premature death.

Recommendation
The Planning Commission must reject the inadequate EIR and require preparation of a comprehensive EIR that mandates net zero emissions, and includes:
• Complete appendices for full public review
• Corrects all air quality modeling errors with updated calculations and significance determinations
• Provides comprehensive environmental justice analysis as required by CEQA Guidelines Section 15131 ( c) and SB 1000
• Identifies replacement housing sites as required by the Housing Crisis Act • Analyzes cumulative impacts of industrial concentration (210% of employment forecast) • Includes findings regarding General Plan inconsistencies resulting from significant GHG em1ss10ns
• Analyzes alternative locations and lower-intensity alternatives that can avoid significant impacts
• Provides detailed feasibility analysis for all recommended mitigation measures • Includes project-specific VMT modeling appropriate for a project that transforms its TAZ • Includes PF AS soil testing with appropriate mitigation if contamination found 8 Item Title: 11.1
Appeal of Planning Commission Decision for the Menifee (Pemcor) Business Park Project Item Page Number: 165

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February 4, 2026
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The Planning Commission should conduct meaningful community engagement and outreach, as required by SB 1000, which involves holding public workshops (in both English and Spanish) accessible to community members at convenient hours, as well as partner with trusted and rooted community organizations and canvass affected neighborhoods on foot, as a way to meet the requirements of SB 1000, as well as understanding the ramifications of implementing such a large scale change in an impacted community.

Additionally, the Planning Commission should also consider implementing enhanced mitigation measures that protect community health, such as embarking on zero emission vehicle requirements for all project-related traffic, prioritizing local community member employment, and provide health monitoring and reporting systems to reduce the impact of these types of projects, both now and in the future.

Conclusion
Due to the above-mentioned reasons as well as the reasons listed in the original comment letter to the EIR, GSEJA believes the EIR is flawed, and a revised, comprehensive EIR must be prepared and recirculated for public review.

This project, as currently proposed, would add massive pollution burdens to a community already ranking in the 93rd percentile for cardiovascular disease burden, 80th percentile for ozone pollution, and 78th percentile for traffic impacts. The residents of census tract 6065043279, who are consisting of predominantly low-income families with 34% poverty rate, 40% lacking high school education, and elevated rates of heart disease and asthma--deserve the same environmental protections as wealthy neighborhoods.

We cannot accept a future where children struggle to breathe so that corporations can profit from cheap land in sacrifice zones. Environmental justice demands that we reject this pattern of discrimination and require meaningful protection for California's most vulnerable communities.

The health of our children and the future of our community are in your hands.

Onwards.

Steven Piepkorn
Golden State Environmental Justice Alliance
765 N Main Street, Suite 151
Corona, CA 92880
+1 9512794697
9 Item Title: 11.1
Appeal of Planning Commission Decision for the Menifee (Pemcor) Business Park Project Item Page Number: 166

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19 November 2025
City Council
City of Menifee
29844 Haun Road
Menifee, CA 92586
SUBJECT:

Green Jobs & Clean Communities
Appeal to the City Council of the City of Menifee regarding a decision of the Menifee (Pemcor) Business Park Project Final Environmental Impact Report (EIR) (SCH No. 2024071016) PROJECT:

Menifee (Pemcor) Business Park Project Final EIR (SCH No. 2024071016) APPELLANT:

Golden State Environmental Justice Alliance
PURPOSE:

This appeal seeks to reverse the entire decision of the Planning Commission's certification on 12 November 2025, which moved to recommend the Project to the City Council to approve.

REASONS FOR APPEAL AND DENIAL OF PROJECT:

Appellant presented multiple arguments in communications in the form of a:
• Comment letter dated 24 September 2025, which objects to the EIR and documents systematic California Environmental Quality Act (CEQA) violations including deficient environmental justice analysis, missing air quality appendix, inadequate General Plan consistency review, violation of Housing Crisis Act requirements, insufficient transportation impact evaluation, and failure to address cumulative impacts on a disadvantaged community already experiencing severe pollution burdens.

Supplemental comment letter dated 11 November 2025, which reaffirms the position of the September 2025 comment letter and documents additional CEQA violations, environmental racism patterns, and the City's failure to meaningfully respond to substantive concerns.

Appellant also provided a response to comments dated 19 September 2025 by consultant Soil Water Air Protection Enterprise (SWAPE), concluding that the Draft Environmental Impact Report ''fails to adequately evaluate the Project's hazards" as well as "emissions and health risk impacts associated with construction and operation of the proposed Project may be G-1
Item Title: 11.1
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underestimated and inadequately addressed." SWAPE's specific comments are detailed in the forthcoming text.

Appellant's comprehensive technical review of the Project's FEIR reveals critical deficiencies that warrant the City Council's rejection of this proposed 337,770 ft2 industrial development spread across eleven buildings with 22 truck dock bays. The project site is located on a 20.03- acre site at Plot Plan PLN23-0245, situated in census tract 6065043279-a community that CalEnviroScreen 4.0 identifies as bearing extreme environmental burdens that rank among the worst in California.

EXISTING ENVIRONMENTAL BURDEN PROFILE
According to California Environmental Protection Agency's CalEnviroScreen 4.0 analysis, census tract 6065043279 suffers from:
• Health Indicators:
o 93rd percentile for cardiovascular disease burden (worse than 93% of CA) o 43rd percentile for asthma incidence
o Elevated rates of emergency room visits for heart attacks and respiratory conditions
• Pollution Burden:
o 80th percentile for ozone pollution (worse than 80% of CA) o 78th percentile for traffic impacts (worse than 78% of CA) o 50th percentile for hazardous waste facility impacts
o 46th percentile for PM 2.5 particulate matter burden
o 36th percentile for solid waste facility impacts
• Socioeconomic Vulnerability:
o 40% of residents lack high school education ( educational vulnerability) o 34% poverty rate (economic vulnerability limiting healthcare access) o 30% Hispanic, 1 % African American, 2% Asian American residents o Senate Bill 535 Disadvantaged Community designation
o Environmental Justice community under SB 1000 protections 2 G-1
G-2
G-2
Item Title: 11.1
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CENSUS TRACT 6065043279 vs. CALIFORNIA AVERAGE
Health Indicator Project Site CA Average
hi::i·Mi
Cardiovascular Disease 93rd %ile 50th %ile +86%
Ozone Pollution 80th %lie 50th %ile +60%
Traffic Impacts 78th %ile 50th %lie +56%
PM2.5 Burden 46th %ile 50th %ile -8%
Asthma 43rd %ile 50th %ile -14%
Poverty Rate 34% 12% +183%
No High School Education 40% 19% +110%
DESIGNATION : SB 535 DISADVANTAGED COMMUNITY
This data demonstrates that the community already bears pollution burdens that exceed health­ protective standards, with cardiovascular disease rates placing it in the worst 7% of California communities.
11111/2025, 1~511:56 /JM.

C, ErnefVC\CY Departments - > 80 • ~
~O:Ml.wP~ - > 80 •100
- >70- 80 Cn.tions
ArcGIS Web Map
1:A2.2l4
CalEnviroScreen Cardiovascular Disease Results Data for Census Tract 6065043279, Source: California Environmental Protection Agency
3 G-2
Item Title: 11.1
Appeal of Planning Commission Decision for the Menifee (Pemcor) Business Park Project Item Page Number: 169

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LEGAL AND REGULATORY COMPLIANCE ISSUES
The FEIR fails to meet California Environmental Quality Act (CEQA) standards through various critical omissions:

CEQA Disclosure Violations
The City's Response to Comments document (30 October 2025) contains a damning admission in Response H-4: Appendix E was not initially included for public review. This appendix contains the critical CalEEMod modeling data, emission calculations, health risk assessment data, and technical assumptions underlying the entire air quality and greenhouse gas analysis.

Without Appendix E during the official comment period, the public was deprived of:
• Model input parameters and assumptions
• Emission calculation methodologies
• Health risk assessment data supporting cancer risk calculations • Greenhouse gas quantification methods
• Mitigation measure effectiveness calculations
This violates CEQA's fundamental mandate for adequate informational documents and meaningful disclosure (CEQA § 15121 and PRC 21003(b)). The City's attempt to cure this by "reissuing" the document on 2 September 2025, does not satisfy CEQA, as the damage was already done-the official comment period proceeded without this critical information, violating due process and public participation rights under Concerned Citizens of Costa Mesa, Inc. v. 32nd Dist. Agricultural Assn. (1986) 42 Cal.3d 929.

I&)
181
I&)
I&)
181
I&)
llsl

LEGAL COMPLIANCE VIOLATIONS SUMMARY
VIOLATED: CEQA § 15121 - Informational Disclosure
➔ Appendix E excluded from public review
VIOLATED: CEQA § 15378 • Project Placemaallng
➔ Segmented analysis or related projects
VIOLATED: SB 1000 - Environmental Justice
➔ No EJ analysis for disadvantaged community
VIOLATED: SB 330/SB 8 - Hou ■ lng Crisis Act
➔ 487 housing units eliminated without replacement
VIOLATED: Gov Coda § 65302(h) • General Plan EJ Element ➔ Failed to reduce pollution In DAC
VIOLATED: Gov Coda§ 11135 - Language Access
➔ No Spanish translaUon (30% HispanlcpopulaUon)
VIOLATED: CEQA Guidelines §15131(c) - EJ Analysis
➔ No analysis of Impacts on vulnerable populations
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Piecemealing in Violation of CEQA
The environmental analysis improperly segments what should be evaluated as a comprehensive development program. Evidence shows systematic piecemealing of industrial development to avoid cumulative impact analysis, violating CEQA Guidelines § 153 78 and precedents established in Laurel Heights Improvement Assn. v. Regents of University of California (1988) 4 7 Cal.3d 376 and Bozung v. Local Agency Formation Comm. (1975) 13 Cal.3d 263.

ENVIRONMENTAL JUSTICE VIOLATIONS
Failure to Conduct Required Senate Bill (SB) 1000 Analysis Despite census tract 6065043279 being a designated disadvantaged community under SB 535, the FEIR provides no substantive environmental justice analysis as required by Government Code Section 65302(h) and CEQA Guidelines Section 15131(c). The City's Response H-2 merely points to CalEnviroScreen data in an appendix without conducting the required analysis of how the Project's impacts will affect an already overburdened community.

SB 1000 requires local governments to:
• Identify objectives and policies to reduce unique or compounded health risks • Implement measures for "reduction of pollution exposure" • Improve air quality in disadvantaged communities
• Promote civic engagement in the public decision-making process The FEIR violates each of these requirements by:
• Failing to analyze how additional pollution affects residents with 93£d percentile cardiovascular disease
• Adding pollution rather than reducing it
• Degrading rather than improving air quality
• Excluding meaningful community engagement (no Spanish-language outreach despite 30% Hispanic population)
Pattern of Environmental Racism
This project continues decades of environmental racism systematically concentrating polluting facilities in communities of color while protecting affluent areas. The Inland Empire has become a sacrifice zone where working-class families and communities of color bear health burdens never tolerated in wealthy coastal communities. This pattern violates:
• The Fair Housing Act's prohibition on disparate impact • California's Unruh Civil Rights Act
5 G-3
G-4
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• Constitutional equal protection guarantees
Environmental & Health Burden Analysis
Menifee (Pemcor) Business Park Project Location
Census Tract 6065043279
ottlcal Finding: The proposed industrial development would be built In a community already experiendng severe environmental and health burdens ranking In the tap percentiles statewide. Anding 337,770 ft• of lndusbial space with 22 truck dodcs would wo,sen mnditions In an already ovemurdened disadvantaged community.
calEnviroScreen 4.0 Pollution & Health Rankings
f cardlovaSQllar Disease Burden
Rel\ects polluUon's severe toU on rommunity health Heart disease rates significantly elevated . ~.~ Ozone Pollution Burden
inti4J,4Hii
Wars,, than 93.,,_ of CA
IWIH-1··VI/I
wo..., !Nn soo;, ol CA
Dangerousfy poor air quality from tndustrial sources and vehide emissions :I Traffic Impact Burden
Wone than 78% or CA
High exposure to truck and -vehk:le pollution from heavy traffic volumes. ~ Hazardous Waste Fadllty Impacts
1 Wane than SOCM, of CA
Proximity to hazardous waste generators and facilities affecting air, water, and soil quality. {; PM 2.5 Particulate Matter Burden
w ..... lhan 46'11> of CA
Ane particulate contamination affecting respiratory and cardiovascular health A Asthma Incidence iifbi;J.. -,.!fll
Worsa than 43'11, ol CA
8evated asthma rates reflecting poor air quality and respiratory health impacts.

Community Vulnerability Factors
40% 340/o 300/o
Lack High School Education Below Poverty Line Hispanic Populabon SB 535 Disadvantaged community: Offidalv deslgnal2d under state law as requl~ng special enviroomental ~.

SB 1000 Protections: califcmla's environmental Justice law specifically deslgned ID protect a,mmunltles like lhis from addttlonal pollution burdens. compounding VulnerabNltles: Poverty limits access ID healthcare, weakens Immune sysll!ms, and reduce; ability ID cope with addltlooal envtronmental stressors.

Source: Caltcmla Erwlronmental Protection Agtnty, C'.alEnvlroSc:reel 4 O Prepared for: supplemental Comments on Menifee (PelTICDf") BUSlness Part Pro.)ect EIR (501 No 2024071016) Datll: November 11, 2025 I Prepared by: Gokfen state fnWOl'lmental Justlce Alliance Environmental & Health Burden Analysis for Census Tract 6065043279, showing severe pollution burden and community vulnerability factors. Source: California Environmental Protection Agency, CalEnviroScreen 4. 0. 6 G-4
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HOUSING CRISIS ACT VIOLATIONS
Site Capacity and SB 330/SB 8 Requirements
The City's Responses H-9 through H-13 fail to cure fundamental violations of the Housing Crisis Act. The facts are undisputed:
• Site Capacity: The EDC-SG designation accommodates up to 487 dwelling units • Proposed Use: 100% industrial with zero residential units • Net Loss: 487 potential housing units eliminated
Government Code Section 66300(b )(1 )(A) explicitly states that agencies shall not change the general plan land use design,ation, specific plan land use design,ation, or zoning to a less intensive use below what was allowed under the land use designation and zoning ordinances ... in effect at the time of the proposed change. While the City claims in Response H-10 it has complete discretion, this directly contradicts SB 330's plain language.

The City's assertion that the site isn't needed for RHNA compliance is irrelevant-SB 330 protects all residential capacity, not just RHNA sites. The law requires:
• No net loss in residential capacity
• Concurrent approval of replacement sites
• Written findings justifying any reduction
The City has provided none of these required elements. Approval without identifying 487 replacement units violates state law and exposes the City to enforcement action under Government Code Section 66300(b )(2)(A).

HOUSING CRISIS ACT (SB 330) VIOLATION
Site Designation: EDC-SG (Mixed Use)
Reeldentlal Capacity: 487 dwelling units
Project Proposal: 0 dwelling units
NET LOSS: 487 units (100%)
Required by Law: Provided by City:
✓ Identify replacement sites X None
✓ Concurrent approval X None
✓ Written findings X None
STATUS: VIOLATION OF GOV CODE§ 66300(b)(1)(A)
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General Plan Inconsistencies
The City's Response H-6 inadequately addresses fundamental General Plan conflicts:
• Policy S- 7 .1: Requires environmental analysis for proposed projects producing harmful greenhouse gas-Project generates 10,419.5 MTCO2e (significant and unavoidable) • Policy EJ-3.6: Requires collaboration with SCAQMD and CARB to improve air quality-Project degrades air quality
• Goal OSC-10: Mandates GHG reduction-Project increases GHG emissions • Policy C-5.3: Support efforts to reduce goods movement impacts-Project adds 239 daily truck trips

TRANSFORMATION AND VMT ANALYSIS
Outdated and Inaccurate Baseline Data
The City's Responses H-18 through H-20 fail to address fundamental flaws in the VMT analysis:
• TAZ 1053 Misrepresentation: The analysis relies on TAZ data showing existing development that doesn't reflect actual conditions-the TAZ is over 50% vacant land • Inappropriate Threshold: Using County average (33.6 VMT) rather than WRCOG­ recommended 15% below existing violates OPR guidance
• Truck VMT Exclusion: Analysis excludes truck VMT despite 239 daily truck trips, violating CEQA's requirement to analyze all project impacts As documented in our September 2025 comment letter, the Fehr and Peer WRCOG SB 743 Implementation Pathway states that projects generating 1,751 average daily trips (actual vehicles) and 2,030 average daily operations as a warehouse require project-specific VMT analysis. This project will generate these levels yet relies on flawed screening.

Geometric Design Hazards
Despite City claims in Response H-21, the site plan reveals :
• Inadequate truck turning radii requiring use of opposing traffic lanes • Conflicts between truck circulation and employee parking • Emergency access constraints with only two access points on Zeiders Road • No dedicated deceleration lanes for truck traffic
8 G-5
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The assertion in Response H-24 that Zeiders Road is arrow straight ignores that sight distance involves more than horizontal alignment-vertical curves, landscaping, and truck stacking all affect visibility and safety.

CUMULATIVE IMPACT ANALYSIS
Industrial Concentration
The City's Response H-26 demonstrates willful blindness to cumulative industrial concentration impacts. The facts are staggering:

Recent Industrial Parks in Menifee Employee Count
Menifee Commerce Center 2,885
Northern Gateway Commerce Center 2,267
Motte Business Center 1,964
Menifee Commerce Center Phase II 1,962
Capstone Industrial 1,205
Ares Warehouse on Murrieta 952
CADO Menifee 860
McLaughlin San Jacinto Warehouse 846
Northern Logistics Gateway Center 694
Compass Northern Gateway 599
Trumble and Watson Warehouse 571
Mapes and Sherman Warehouse 478
Corsica Business Park 477
Ethanac and Barnett Warehouse 440
Wheat Warehouse 151
Over 16,000 new industrial employees and counting-constituting more than double the City's entire 26-year employment growth forecast concentrated in warehouse/industrial uses.

Cumulative Health and Environmental Impacts
This unprecedented industrial concentration creates:
• Diesel death zones with cumulative PM 2.5 and NOx exposure • Continuous noise pollution disrupting circadian rhythms and causing stress • Traffic safety hazards as trucks infiltrate residential neighborhoods • Economic displacement of community-serving businesses • Loss of housing opportunities in mixed-use zones
• Environmental injustice concentrating pollution in communities of color 9 G-6
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AIR QUALITY AND HEAL TH RISK ASSESSMENT
SW APE Technical Findings
The technical review by SW APE identified critical modeling errors:
• CalEEMod Input Manipulation: The EIR modified default fleet mix percentages without justification, underestimating operational emissions
• Incorrect Hauling Distance: Used 20-mile default instead of actual 25.4 miles to El Sobrante Landfill
• Missing PF AS Analysis: Despite agricultural history indicating potential biosolid application, no PF AS testing conducted
• Fraction of Time at Home (F AH): Originally used incorrect values for sensitive receptors, only corrected after public pressure
Underestimated Health Risks
The Health Risk Assessment fails to account for:
• Synergistic effects of multiple pollutants on cardiovascular disease • Elevated baseline health conditions (9Yd percentile cardiovascular disease) • Vulnerable populations (children, elderly, those with pre-existing conditions) • Cumulative impacts from existing sources
Medical research demonstrates that communities with existing cardiovascular disease face exponentially higher risks from additional PM2.5 exposure. A less than significant finding based on healthy population thresholds is meaningless for a community where heart disease already ranks in the worst 7% statewide.

Greenhouse Gas Emissions
The Project generates 10,419.5
MTCO2e annually-exceeding both
SCAQMD's 10,000 MTCO2e and the
City's 3,000 MTCO2e thresholds.

The City acknowledges this as
• significant and unavoidable (Response
H-8), yet rejects feasible mitigation
measures including:

PROJECT GHG EMISSIONS vs. REGULATORY THRESHOLDS
Emission Source
Project Emissions
City of Menifee Threshold
SCAQMD Threshold
Exceadance over City Threshold
Exceadance over SCAQMD Threshold
Annual GHG Emissions (MTCO2e)
10,419.5
3,000
10,000
347%

4.2%

IMPACT DETERMINATION SIGNIFICANT & UNAVOIDABLE
G-7
G-8
G-9
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• Zero-emission truck infrastructure ( dismissed despite only 22 docks) • LEED certification requirements
• Enhanced solar requirements beyond Cal Green
• Non-diesel emergency generators
• Participation in CARB's SmartWay program
• Real-time emissions monitoring

INADEQUATE ALTERNATIVES ANALYSIS
Alternatives Not Considered
The City's Response H-25 fails to justify the limited alternatives considered. CEQA requires a reasonable range of alternatives that could reduce significant impacts. The EIR only analyzes:
• No Project
• Alternative 1: 25% reduction (still significant GHG impacts) • Alternative 2: Mixed Use with Commercial/Industrial/Residential • Alternative 3: Mixed Use with Office/Business Park/Residential Conspicuously absent:
• Zero-Emission Logistics Alternative: All-electric operations with solar canopies and battery storage
• Light Manufacturing Alternative: Lower truck traffic, higher employment density • Mixed-Use Transit-Oriented Alternative: Incorporating affordable housing near future transit
• Phased Development Alternative: Allowing technology improvements before full buildout
• Community-Serving Commercial Alternative: Retail, services, and amenities for residents
The City's claim that no alternative could eliminate GHG impacts due to the 3,000 MTCO2e threshold is defeatist and incorrect-a zero-emission facility with renewable energy could achieve carbon neutrality.

Mitigation Measures Improperly Rejected
The City dismisses California Department of Justice recommendations without adequate analysis:
• Zero-Emission Infrastructure: Claimed infeasible for 22 docks despite facilities statewide installing such infrastructure
• Carbon Offsets: Rejected without exploring local offset programs or requirements 11 G-9
G-10
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• Community Benefits Agreement: No consideration of health monitoring, air filtration for nearby schools, or community investment
• Truck Routing Restrictions: No evaluation of designated routes avoiding residential areas • Operational Restrictions: No limits on nighttime operations to protect sleep

PROCEDURAL VIOLATIONS
Language Access Failures
Despite 30% Hispanic population in the affected census tract:
• No Spanish translation of notices or documents
• No bilingual public meetings
• No targeted outreach to Spanish-speaking residents
• No interpretation services at hearings
This violates environmental justice principles and Government Code Section 11135 requiring meaningful access for limited-English populations.

Deficient Public Notice
The project's public notice failed to:
• Identify the site as in a disadvantaged community
• Disclose the 93rd percentile cardiovascular disease burden • Mention cumulative impacts from surrounding warehouses • Provide health risk information in lay terms
• Offer resources for technical assistance to residents Response to Comments Inadequacies
The City's responses demonstrate bad faith through:
• Dismissive tone toward environmental justice concerns • Reliance on technicalities rather than substantive analysis • Failure to provide requested data and calculations
• Mischaracterization of legal requirements
• Refusal to consider feasible mitigation
12 G-10
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ECONOMIC ANALYSIS DEFICIENCIES
Job Quality Analysis
The FEIR fails to analyze economic impacts on the disadvantaged community:

Job Quality Analysis Absent
• No wage data for proposed 553 jobs
• No comparison to living wage standards
• No analysis of benefits availability
• No local hire requirements
• No job training partnerships
Displacement Impacts ignored:
• Property value impacts from industrial encroachment
• Small business displacement from truck traffic
• Residential displacement from cumulative impacts
• Loss of land for community-serving uses
Fiscal Impact omissions:
• Public health costs from increased pollution
• Infrastructure wear from truck traffic
• Emergency service demands
• Lost property tax from residential prohibition
Climate Vulnerability and Resilience
The EIR fails to analyze climate vulnerability despite state requirements:
• Heat Island Effect: 337,770 ft2 of impervious surfaces increasing local temperatures • Extreme Heat Events: No cooling centers or shade structures for workers • Flooding Risk: No analysis of increased runoff on downstream communities • Wildfire: No evaluation of evacuation impacts from added traffic • Grid Reliability: No battery storage for resilience
Climate change disproportionately affects disadvantaged communities-this project worsens rather than improves resilience.
13 G-11
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GRIEVANCES
Fallowing the Planning Commission's decision to certify the project FEIR, Appellant maintains that the Planning Commission breached its responsibility to conduct proper environmental reviews and implement necessary safeguards. Additionally, CEQA requires local agencies to take all action necessary to provide the people of this state with clean air and water, enjoyment of aesthetic, natural, scenic, and historic environmental qualities, and freedom from excessive noise.

The centrality of environmental health for California's population underlies CEQA's statutory framework. The Legislature articulated these fundamental mandates when adopting CEQA:
• The maintenance of a quality environment for the people of this state now and in the future is a matter of statewide concern (Pub. Res. Code,§ 21000, subd. (a).). • Agencies must identify any critical thresholds for the health and safety of the people of the state and take all coordinated actions necessary to prevent such thresholds from being reached (Id. at subd. (d).).
• [M}ajor consideration [must be} given to preventing environmental damage, while providing a decent home and satisfying living environment for every Californian (Id. at subd. (g).).
• Agencies must [t}ake all action necessary to provide the people of this state with clean air and water, enjoyment of aesthetic, natural, scenic, and historic environmental qualities, and.freedom from excessive noise (Pub. Res. Code,§ 21001, subd. (b).).

Municipal governments and other local authorities hold critical responsibilities in safeguarding environmental justice for California communities. Under existing statutes: [E]nvironmental justice means the fair treatment of people of all races, cultures, and incomes with respect to the development, adoption, implementation, and enforcement of environmental laws, regulations, and policies.

Gov. Code,§ 65040.12, subd. (e) demands that environmental benefits reach all community members equally, while preventing the concentration of pollution impacts on at-risk populations or neighborhoods already bearing environmental burdens.

RECOMMENDATION
The Planning Commission should have required a revised Environmental Impact Report addressing cumulative impacts, proper project scope definition, zoning compliance, and comprehensive environmental justice analysis before project approval. The current FEIR's technical deficiencies and regulatory violations necessitate additional environmental review to ensure community protection and legal compliance with state environmental justice mandates. 14 Item Title: 11.1
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Should the City Council not fully reverse the certification, at minimum the following conditions must be required:

Zero-Emission Operations Timeline
• 50% zero-emission trucks by 2030
• 100% zero-emission trucks by 2035
• Installation of charging infrastructure before occupancy • Monthly emissions monitoring and public reporting
Community Health Protection
• $5 million community benefit fund for health programs • Indoor air filtration systems for nearby schools
• Community air monitoring network with real-time data
• Quarterly health impact assessments
Local Hiring and Training
• 50% local hire requirement (Menifee residents)
• Partnership with community colleges for job training
• Living wage requirement ($25/hour minimum)
• Healthcare benefits for all employees
Operational Restrictions
• No operations between 10 PM and 6 AM
• No idling beyond 3 minutes
• Designated truck routes avoiding residential streets
• Maximum 100 truck trips per day
Environmental Justice Compliance
• Environmental Justice Advisory Committee with voting power • Monthly compliance reports in English and Spanish
• Annual environmental justice impact assessment
• Community right to enforcement action

CONCLUSION
Due to the above-mentioned reasons as well as the extensive record of violations documented in our 24 September and 11 November 2025 comment letters, the inadequate SWAPE technical analysis responses, and the City's demonstrated pattern of dismissing environmental justice concerns, Appellant believes the FEIR is fundamentally flawed and a new EIR must be prepared 15 Item Title: 11.1
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for the proposed project and circulated for public review. Appellant requests the City of Menifee City Council reverse the decision of the Planning Commission's certification of the project and require a new EIR.

The health and lives of Menifee's most vulnerable residents are in your hands.

Best.

Rich Golding
Corporate Secretary
Golden State Environmental Justice Alliance
765 N Main Street, Suite 151
Corona, CA 92880
+1 9512794697
16 Stanley Saltzman, MBAc
Staff Analyst
Golden State Environmental Justice Alliance
765 N Main Street, Suite 151
Corona, CA 92880
+l 9512794697
Item Title: 11.1
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I SWA p E I Technical Consultation, Data Analysis and
._ _____ _, Litigation Support for the Environment
September 19, 2025
Gary Ho
Blum, Collins & Ho LLP
707 Wilshire Blvd, Ste. 4880
Los Angeles, CA 90017
2656 29th Street, Suite 201
Santa Monica, CA 90405
Matt Hagemann, P.G, C.Hg.
(949) 887-9013
[email protected]
Subject: Comments on the Menifee (Pemcor) Business Park Project (SCH No. 2024071016) Dear Mr. Ho,
We have reviewed the August 2025 Draft Environmental Impact Report ("DEIR") for the Menifee (Pemcor) Business Park ("Project") located in the City of Menifee ("City"). The Project proposes to construct 337,770-square-feet ('SF") of business park building area spread across 11 buildings on the

20.03-acre site.

Our review concludes that the DEIR fails to adequately evaluate the Project's hazards, hazardous materials, air quality, health risk, and greenhouse gas 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 revised Environmental Impact Report ("EIR") should be prepared to adequately assess and mitigate the potential hazards, hazardous materials, air quality, health risk, and greenhouse gas impacts that the project may have on the environment.

Hazards and Hazardous Materials
Inadequate Disclosure and Analysis of Impacts
The DEIR states: "Based upon a review of the City of Menifee's Permitted Biosolids/Sludge Application Map, the project site is shown as an area where Composite Fields (i.e., biosolids/ sewage sludge) were allowed but not necessarily deposited. Biosolids/sewage sludge were historically applied in the City of Menifee and County of Riverside as a fertilizer both legally under permit, as well as illegally at unknown times and locations." (p. 4.9-2). To address this finding, a Phase I Environmental Site Assessment (ESA) was prepared in 2022 for the Project site (Appendix I). The Phase I ESA included the collection of soil samples which were analyzed for metals, pesticides and.fecal coliform.

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The Phase I ESA did not include the analysis of soil samples for per- and polyfluoroalkyl substances (PFAS) have which are known to be associated with biosolids. The occurrence of PFAS in biosolids "is reported to be prevalent nationwide." 1
On April 19, 2024, two PFAS, perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid {PFOS), were listed as hazardous substances under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) or Superfund. As a result of this rulemaking PFOA and PFOS now should be considered as part of a Phase I ESA under ASTM Standard E1527-21. For example, this analysis found:
"the potential presence of PFOA and PFOS must now be evaluated as part of a standard Phase I ESA (without the need for further updates to ASTM E1527-21). As a result, corporate and real estate due diligence teams should be updating their due diligence protocols to ensure that their consultants are evaluating whether the property was used by any of the aforementioned industries or if PFAS could be present in any components used or manufactured at the property.

Though invasive testing is not part of a Phase I ESA, consideration should be given to Phase II sampling for PFAS during the due diligence process based on historical site use and deal considerations." 2
Another analysis found :
"PFOA and PFOS must now be considered as part of a Phase I Environmental Site Assessment under the new ASTM Standard E1527-21 for purposes of meeting the "all appropriate inquiries" standard. Compliance with this standard is important for prospective real estate and asset purchasers, in particular, who may seek defenses to liability and cleanup obligations under CERCLA. The inclusion of PFOA and PFOS in Phase I Environmental Site Assessments may prompt sampling or "Phase II" investigations that lead to the identification of historical PFOA and PFOS contamination that may trigger cleanup obligations under CERCLA."3 A revised DEIR should be prepared to include a Phase II ESA that samples for PFAS given: {1) the Project site may have been used for biosolids application; (2) that biosolids are known to be associated with PFAS; and (3) according to the interpretations cited above, Phase I ESAs should now consider PFAS sampling where historical use indicates it may be present.

Air Quality
Failure to Provide Complete CalEEMod Output Files
Land use development projects under CEQA assess air quality impacts and calculate criteria air pollutant emissions using the California Emissions Estimator Model {"CalEEMod"). 4 CalEEMod uses site-specific 1 https://pfa s-1.itrcweb.org/wp-content/uploads/2023/10/Biosolids PFAS Fact Sheet Sept2023 final.pdf 2 https ://www .hklaw.com/en/insights/publi cations/2024/04/epa -designates-2-pfas-compounds-as-hazardous­ substances
3 https ://www .kirkland.com/publicat ions/kirkland -alert/2024/04/pfao -and-pfos-hazardous-substances 4 "CalEEMod User Guide." CAPCOA, April 2022, available at: https://www .caleemod.com/documents/user ­ guide/01 User%20Guide.pdf.
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defaults that can be adjusted with justified project-specific data . It calculates construction and operational emissions, generating output files that document inputs, changes, and justifications. 5 The DEIR relies on CalEEMod Version 2022.1 provided in the Air Quality and Health Risk Assessment Report ("AQ Analysis") as Appendix E to the DEIR to estimate Project emissions, which fails to generate complete output files. Specifically, the 'User Changes to Default Data' table omits quant itative details of default value modifications (see screenshot below) (Appendix E, pp. 157).

8. User Changes to Default Data
Land Use Project specific conditions per site plan.

Operations: Vehicle Data Updated per Traffic Scoping Agreement . IP models passenger vehides, Parking Lot models truck trips . Truck trip length updated based on SCAOMD Rule 2305 Rulemaking materials , Passenger vehide trip length updated based on
Operat ions: Fleet MIX
Construction: Construction Phases
Construction: Off-Road Equipment
Operations: Energy Use
Fleet mix updated to reflect IP modeted as passenger vehicJes and PL modeled as trucks~ Trud< breakdown directly from Ganddlnl. Passenger veh adjusted based on CMod defaults. removing lrucks, buses, and m~ or homes.

Building construction phase compressed to account for 18 month cons trud ion timetine as specified by Applicant
Building construction equipment increased to account for compressed construction schedule, compared to CalEEMod defaults.

Previous CalEEMod Versions, such as 2020.4.0, provide the specific numeric changes to a model's default values (see example screenshot below):

TableName I Column Nanie I DerauH Value NewValua
lblConstructionPhase NumOays 230.00 167.00
----··-·-------·········--··· ~- -----·-·-----·-·----------·- ---·-------- ---➔••·····----·-·--·-·- - -----lblConstructionPhase PhaseEndOate ; 11/22/2023 8/25/2023 ...... .................. .. .. ....... .. ....... ...................................... ,._ ·----------- + ........................ .............. . tblConstructionPhase PhaseEndOate 9127/2023 6/30/2023
lblConstructionPhase .;. PhaseEndOate .;.. 10/25/2023 7/2812023 ... ................... ....... " ............. ........ ..... ... .;.-----------------+· ............... .. ..... .. . lblConslructionPhase PhaseStartDate 10/26/2023 7129/2023 tblConstructionPhase .;. PhaseStartOate .;.. 9/2812023 71112023 . . . . . .................... .. .. " ... . ................... . . •·· .. .;.--------------t· ... ..................... . lblLandUse LandUseSquareFeet ,.____ 160,000.00 160,371.00 •••••• • •••
0 lbll.;~ciu,;.; •••••••••• .;. •••••• • L;~dU,;.;sciu"a-;.;F.;;t..... .. --119~ciiio~oo- ----- - •••.••••• 41 :1s5:oci ........ . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . " .. .................... ....... .;.--- ------- -------t· ....... ................. . !bl Land Use LotAcreage 3.67 3.68
........ ..... ........ ........ .;. ....... ............... ....... .;..------------------ ·-·---- - ................ ......... . tblLandUse l.otAcreage 2.73 2.74
............................. " ............ ................. .;.-- - - ---------------................ ........... .

The output files associated with CalEEMod Version 2022.1 do not include a changes table that reveals the exact parameters used to calculate Project emissions. We suggest that the DEIR provide access to the model's ".JSON" files, which can allow third parties to review the model's revised input parameters. 6 We are unable to verify the DEIR's air modeling and subsequent analysis without access to the complete output files and the specific numeric changes to the default values. 5 "CalEEMod User's Guide." CAPCOA, April 2022, available at: https :ljwww .caleemod.com/documents/use r­ guide/01 User%20Guide.pdf, p. 1.
6 "Video Tutorials for CalEEMod Version 2022.1." CAPCOA, May 2022, available at:
https ://www .caleemod.com/tutoria ls.
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Unsubstantiated Input Parameters Used to Estimate Project Emissions When reviewing the Project's CalEEMod output files, provided in the AQ Analysis as Appendix E to the DEIR, we identified several model inputs related to Project construction and operation that are inconsistent with information disclosed in the DEIR. A revised EIR should be prepared to include an updated air quality analysis that provides a more detailed evaluation of the impact that construction and operation of the Project may have on local and regional air quality.

Incorrect Construction Hauling Trip Length
Review of the CalEEMod output files demonstrates that the "PEMCOR Business Park - Menifee Detailed Report" model includes the default 20-mile hauling trip length (see screenshot below) (Appendix E, pp. 144,145).

Demolition
Demolition
-

15.0 18 5 LDA.LDT1,LDT2
Demolition vendor 10.2 HHDT,MHDT
Demaltlon Hauling 1.75 Eo.o HHDT
Demolition Onsite truck HHDT
Ske Preparation
Sile Preparation Wo<ker 17.5 18.5 LDA.LOT1.LDT2
SMe Preparation vendor 10.; HHDT,MHDT
Sito Preparation Hauling 000 1~8 HHDT
s-. Preparatlon Onslte truck HHDT
Grading
Grading
-

20.0 18 6 LDA.LDT1.LDT2
GrncHng vendor 10.2 HHDT.MHDT
Grading Hauling 7.14 Es-a HHDT
Grading Onsite truck HHDT
Building COnstruciion
Building Construction Wor1<er 142 185 LDA.LDT1 ,LDT2
Bulking COnSlrudlon
-

55.4 10.2 HHDT.MHDT
Building COnstruction Hauling 0.00 120,0 HHDT
Building construction Onslte truck HHDT
Paving
Paving Wor1<er 15.0 18.5 LDA,LOT1,LDT2
Paving Vendor 102 HHDT,MHDT
Paving Hauling 0.00 120..0 HHDT
Paving Onslte truck HHDT
Architectural Coaling
Archlteclural Coaling WO<ker 28.4 18.5 LDA.LDT1 ,LDT2
Artllltectural Coaling Vendor 102 HHDT.MHDT
Artllltectural C0etlng Hauling 0.00 120.0 HHDT
In regard to the landfill to be used by the Project during demolition and grading, the DEIR states:
"Solid waste collection, disposal, and recycling services in Menifee are provided by Waste Management Inc. (WM). WM operates the private El Sobrante Landfill located at 10910 Dawson Canyon Road in Corona, CA" (p. 4.19-12).
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However, review of Google Maps reveals that the El Sobrante Landfill is located approximately 25.4 miles from the Project site (see screenshot below).

O [ 335:?1 21!1dffs Ro, Mon1tee CA 9J584
~.
(:) r 10910 D;rwwo c~ Rd, Corona, CA ~ l
0 Add d n,IK\l, 1U1n
8 Send d,rcctions 10 iPhone C-J Copy l,nk
fi viaHSN s
F.;is:r'il r1Y.1: l' 1t-.r us~.i:i 11.111,= ;i, • 1""lllN; • .6 -n,;s,OVU:Pl:ia.,n11lc1•d:"""'"' , •
road11,..

Explore nearby 10910 Dawson Canyon Rd
0 0 0 0 0
0 0
C11rty0n U!ke
ta'l)'C'1 I • -~
CJm'l1.1111) 0
F<tk
,,..,. .
t trl.P •.a,.:::•
" ~ ....... .-r. ., I
,_ - ...,.,....,..,_ ... "------J
The 20-mile hauling trip route is therefore underestimated by 5.4 miles. CalEEMod uses the hauling trips lengths to estimate the construction-related emissions associated with on-road vehicles.7 By including an underestimated hauling trip length, the model underestimates the Project's construction-related emissions and should not be relied upon to determine Project significance.

Unsubstantiated Changes to Operational Vehicle Fleet Mix Review of the CalEEMod output files reveals the "PEMCOR Business Park - Menifee Detailed Report" model includes changes to the default operational vehicle fleet mix percentages (see screenshot below) (Appendix E, pp. 157).

8. User Changes to Default Data
Land Use
Operalions Vehide Data
pofll.lions: Fleet Mix
Construction: Construction Phases
Construction: Off-Road Equipment
Operations: Energy Use
Project specific conditions per site plan,
Updated per Traffic Scoping Agreement IP models passenger vehide s, Parl<ing Lot models truck trips Truck trip lenglh updated based on SCAQMD Rule 2305 Rulemaking materials Passenger vehicle lrip length updated based on
Fleel mix updated to renect IP modele<I as passenger vehicles and PL modeled as trud<s Truck breakdOW'n directly from GanddinL Passenger veh adjusted based on CMod defaults, "' buekO. cuses. aM molar-.

Building construction phase compressed to account for 18 month c:onstruciion timeline as specified by Applicant.

Building construction equipment increased to account for compressed construction schedule, compared lo CalEEMod defaults.
7 "CalEEMod User Guide." CAPCOA, April 2022, available at: https ://www.caleemod.com/documents/user ­ guide/01 User%20Guide.pdf, p. 38.
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The CalEEMod User's Guide requires any changes to model defaults be justified. 8 The justification provided for these changes is:
"Fleet mix updated to reflect IP modeled as passenger vehicles and PL modeled as trucks. Truck breakdown directly from Ganddini. Passenger veh adjusted based on CMod defaults, removing trucks, buses, and motor homes" (Appendix E, pp. 157).

The DEIR also includes the following trip generation table that includes a breakdown of the Project's anticipated passenger car and truck trips (see screenshot below) (p. 4.17-6, Table 4.17-1):
a e . -. ro ect rl I) T bl 4 17 1 P ,j T • G enerat on
Vehicle Type1 AM Peak Hour PII Peak Hour TOTAL In Out Total In Out Total Industrial Park (80%)
Vehicle Trips
Cars 66 15 81 18 63 81 757
Trucks 4 7 11 4 8 12 154
Total 70 22 92 22 71 93 911
PCE Trips2
Cars 66 15 81 18 63 81 757
Trucks 12 19 31 12 22 34 433
Total 78 34 112 30 85 115 1,190
Business Park l20% J
Cars (no trucks) 78 14 92 21 61 82 840
Total Trips
(Vehicles) 148 36 184 43 132 175 1,751
Total Trips (PCE) 156 48 204 51 146 197 2,030
. . Source: Ganddm1 TIA, Tables 1-3, ProJecl Tnp Genera!Jon 1 ITE Land Use Code 130 for Industrial Park and ITE Land Use Code no for Business Park 2 PCE = Passenger Car Equivalent which accounts for greater traffic impacts due to the longer length of trucks compared to cars.

The changes to the model's operational fleet mix values, however, remain unsupported . As discussed in the section of this letter titled "Failure to Provide Complete CalEEMod Output Files," the output files for CalEEMod 2022.1 do not present numeric changes to any model defaults . Changes to fleet mix percentages are not mentioned outside of the "User Changes to Default Data" table. As the DEIR provides a table with proposed fleet mix values without access to the specific changes, we are unable to verify what values were inputted. Until the DEIR verifies the breakdown of heavy-heavy duty, medium­ heavy duty, light-heavy duty trucks used by the model, these values may be inconsistent with the information provided by the DEIR and associated documents.

CalEEMod uses operational vehicle fleet mix percentages to calculate the Project's operational emissions associated with on-road vehicles.9 By including several unsubstantiated changes to the default 8 "CalEEMod User Guide." CAPCOA, April 2022, available at: https:ljwww.caleemod.com/documents/user ­ guide/01 User%20Guide.pdf. p. 13, 14.
9 "CalEEMod User's Guide." CAPCOA, May 2021, available at: https://www .aqmd.gov/caleemod/user's -guide, p. 36,
6 Item Title: 11.1
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February 4, 2026
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operational vehicle fleet mix percentages, the model may underestimate the Project's mobile-source operational emissions and should not be relied upon to determine Project significance.

Diesel Particulate Matter Emissions Inadequately Evaluated The DEIR conducts a health risk analysis ("HRA") evaluating impacts as a result of exposure to diesel particulate matter ("DPM") emissions from Project construction and operation. Specifically, the DEIR estimates that the total maximum cancer risk posed to nearby, existing residential sensitive receptors as a result of Project construction and operation would be 6.9 in one million, which would not exceed the South Coast Air Quality Management District ("SCAQMD") significance threshold of 10 in one million (see excerpt below) (p. 4.3-26, Table 4.3-11).

Table 4.3-11: Unmitigated Cancer Risk at PMI and MEIR
Annual AV9111ge DPM Excess Cancer RJ1k UTM Location Conceutr■tlon (Jlg/m3) (per mllllon popul■llon) Receptor Year2
East North Year1 Construction Ye■r3-30 Yur Year Year Total Con1tructlon and Oper■ tlonCBI 1 2 3~ Operatlon1A1
PMl(C) 483610.00 3721409.00 0.10716 0.03134 0.00229 -- - - - MEIR 483654.71 3721301.62 0.03465 0.010055 0.00053 5.2 1.4 0.2 l5_9<Dt Source: MIG, 2024 (see Appendix CJ
(A) Year 2 includes emissions from both construction and operational activities. The Year 2 concentration was calculated multiplying the operational concentration in Year 3-30 by the percent of the year that operation occurs in Year 2 (50%), and adding that Year 2 operational concentration to the Year 2 construction concentration. The construction DPM concentration for Year 2 was 0.00979 µg/m3. The operational DPM contribution during Year 2 was estimated to be approximately 0.009525 µglm3, which reflects the remaining approximately six (6) months during the Year 2 that the project could be operational. (B) The annual average DPM operational concentration is based on the first full year of operation (Year 3). (C) The PMls vary between Year 1 and Year 2 of construction, as well as project operation; however, the PM ls are always to the south of the site in the field immediately south of the site or, in the case of operations, in the roadway of Zeiders Road. (D) Total may not equal due to rounding.

The DEIR's constriction and operational HRA underestimates Fraction of Time At Home ("FAH") values for third trimester, infant, and child receptors. It uses an FAH value of 0.85 for third trimester (age -0.25 to O) and infant (age Oto 2) receptors, and 0.72 for child receptors (age 2 to 16) (see excerpt below) (Appendix E, pp. 399).

Risk Parameter Values bl£ Age Bin
Variable Residential Age Bin
3rd Trimester 0-2 Years 2-16 Years 16-30 Years 30-70 Years DBR 361 1090 572 261 233
A 1 1 1 1 1
EF 0.96 0.96 0.96 0.96 0.96
CF 1.00E-06 1.00E-06 1.00E-06 1.00E-06 1.00E-06
CPF 1.1 1.1 1.1 1.1 1.1
ASF 10 10 3 1 1
ED 0.25 2 14 14 54
u: :ZQ :ZQ :ZQ 70 70
I FAH 0.85 0.85 0.72 0.73 0.73
7 Item Title: 11.1
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February 4, 2026
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The FAH values for third trimester, infant, and child receptors in the HRA are incorrect. SCAQMD guidance states that for screening purposes, "the FAH is set to 1 for individuals from the third trimester to age 16, assuming children stay near home for school or daycare with no time discount." 10 Per SCAQMD guidance, the HRA Report should have followed this guidance and used an FAH of 1 for third trimester, infant, and child receptors. By using unsupported FAH values, the DEIR may underestimate the cancer risk to nearby sensitive receptors from Project construction and operation.

Failure to Adequately Evaluate Greenhouse Gas Impacts
The DEIR estimates that the Project would result in net annual greenhouse gas ("GHG") emissions of 10,419.5 metric tons of carbon dioxide equivalents per year ("MT CO2e/year'') (see screenshot below) (p. 4.8-18, Table 4.8-4).

Table 4.8-4: Unmitigated Project Operational GHG Emissions GHG Emissions (MT I Year)
Emission Source Refrigerant CO2 CH4 N~ GHGs c~
Area 6.9 <0.1 <0.1 0.0 6.9
Energy 1,497.1 0 .1 <0.1 <0.1 1,504.4
Mobile 8,343.2 0.2 0.6 11.9 8,537.0
Waste 37.4 3.7 0.0 0.0 130.7
Water 108.3 2.6 0.1 0.0 190.3
Refrigerants 0.0 0.0 0.0 14.6 14.6
Amortized Construction 35.1 <0.1 <0.1 <0.1 35.6
Site Subtotal(A> 10,028.0 6.6 0.7 26.4 I 10,419.5
Threshold of Significance 3,000
SCAQMD Interim Threshold Exceeded? Yes
Source : MIG 2024 (see Appendix A).
(A) Totals may not equal due to rounding .

The DEIR concludes that the Project would exceed the SCAQMD bright-line threshold of 3,000 MT CO2e/year and result in a significant-and-unavoidable GHG impact (p. 4.8-22).

While we agree that the Project would result in a significant GHG impact, the DEIR's assertion that this impact is significant-and-unavoidable is unsupported, as additional feasible mitigation is available.

According to CEQA Guidelines §15096(g)(2) :
"When an updated EIR has been prepared for a project, the Responsible Agency shall not approve the project as proposed if the agency finds any feasible alternative or feasible 10 "Risk Assessment Procedures." SCAQMD, August 2017, available at: http://www .agmd.gov/docs/default­ source/rule-book/Proposed-Rules/1401/riskassessmentprocedures 2017 080717.pdf, p. 7. 8 Item Title: 11.1
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mitigation measures within its powers that would substantially lessen or avoid any significant effect the project would have on the environment." 11
As such, the DEIR is required under CEQA to implement all feasible mitigation to reduce impacts to a less-than-significant level. To reduce the Project's GHG impacts to the maximum extent possible, additional mitigation measures should be incorporated, such as those suggested in the section of this letter titled "Feasible Mitigation Measures Available to Reduce Emissions." The Project should not be approved until a revised EIR is prepared, incorporating all feasible mitigation to reduce emissions to less­ than-significant levels if feasible.

Mitigation
Feasible Mitigation Measures Available to Reduce Emissions The DEIR is required under CEQA to implement all feasible mitigation to reduce the Project's potential impacts. As demonstrated in the sections above, the Project would result in potentially significant air quality, health risk, and GHG impacts that should be mitigated further.

To reduce the GHG emissions associated with the Project, we recommend the DEIR consider several mitigation measures as listed below. The California Department of Justice ("CA DOJ") recommends: 12 • Installing solar photovoltaic systems on the project site of a specified electrical generation capacity that is equal to or greater than the building's projected energy needs, including all electrical chargers.
• Designing all project building roofs to accommodate the maximum future coverage of solar panels and installing the maximum solar power generation capacity feasible. • Oversizing electrical rooms by 25 percent or providing a secondary electrical room to accommodate future expansion of electric vehicle charging capability. • Requiring all stand-by emergency generators to be powered by a non-diesel fuel. • Meeting CalGreen Tier 2 green building standards, including all provisions related to designated parking for clean air vehicles, electric vehicle charging, and bicycle parking. • Designing to LEED green building certification standards. • Constructing zero-emission truck charging/fueling stations proportional to the number of dock doors at the project.
• Requiring facility operators to train managers and employees on efficient scheduling and load management to eliminate unnecessary queuing and idling of trucks. 11 "Cal. Code Regs. tit. 14 § 15096." California Legislature, available at: https://casetext.com/regulation/californ ia­ code-of-regulat ions/ti tle-14-natural-resources/division -6-resources-agency/chapter -3-guldelines-for - i mplementation-of-the-california -environmental -q ua lity-act/ article -7-ei_r-process/section-15096 -process-for-a­ responsible-agency.
12 "Warehouse Projects: Best Practices and Mitigation Measures to Comply with the California Environmental Quality Act." State of California Department of Justice, September 2022, available at:
https:lloag.ca .gov/system/files/media/warehouse-best -practices.pdf. p. 8 -10. 9 Item Title: 11.1
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• Requiring that every tenant train its staff in charge of keeping vehicle records in diesel technologies and compliance with CARB regulations, by attending CARB-approved courses. Also require facility operators to maintain records on-site demonstrating compliance and make records available for inspection by the local jurisdiction, air district, and state upon request. • Requiring tenants to enroll in the United States Environmental Protection Agency's SmartWay program, and requiring tenants who own, operate, or hire trucking carriers with more than 100 trucks to use carriers that are SmartWay carriers.
• Providing tenants with information on incentive programs, such as the Carl Moyer Program and Voucher Incentive Program, to upgrade their fleets.

SCAQMD staff recommends: 13
• Maximizing the use of solar energy by installing solar energy arrays. • Using light-colored paving and roofing materials .
• Utilizing only Energy Star heating, cooling, and lighting devices and appliances.

CEQA Guidelines 15126.4 (c)(3) include "[o]ffsite measures, including offsets that are not otherwise required, to mitigate a project's emissions" as an option for GHG mitigation. 14 An example of this was in the case of the Oakland Sports and Mixed-Use Project, where off-site reduction measures in the neighboring communities were recommended. 15 We recommend consideration of local carbon offset programs to reduce the Project's GHG impacts as a measure of last resort.

As demonstrated above, we have provided several mitigation measures that would reduce Project­ related GHG emissions developed from sources including the DOJ and others. These measures offer a cost-effective, feasible way to incorporate lower-emitting design features into the proposed Project, which subsequently reduce emissions released during Project construction and operation.

A revised EIR should be prepared that includes all feasible mitigation measures, as well as updated air quality, health risk and GHG analyses to ensure that the necessary mitigation measures are implemented to reduce emissions to the maximum extent feasible. The revised EIR should also demonstrate a commitment to the implementation of these measures prior to Project approval, to ensure that the Project's potentially significant emissions are reduced to the maximum extent possible. 13 "Draft Environmental Impact Report (EIR) for the Proposed CADO Menifee Industrial Warehouse Project (Proposed Project)." SCAQMD, April 2024, available at: https://www.agmd.gov/docs/default­ source/cega/comment -letters/2024/april-2024/RVC240313-05 .pdf?sfvrsn=8, p. 3. 14 "Cal. Code Regs. tit. 14 § 15126.4." CEQA Guidelines, May 2024, available at:
https://case text.com/regulation/california -code-of-regulations/title -14-natural -resources/division -6-resources­ agency/chapter-3-guldellnes -for-implementation-of-the-california-environmental -guality-act/article-9-contents -of­ environmenta l-impact-reports/section-151264- consideration-and-discussion -of-m itigation-measu res-proposed-to­ mi n imize-significant-effects .
15 "Cal. Pub. Resources Code§ 21168.6.7." 2023, available at: https :ljcasetext .com/statute/california ­ codes/california-public-resources -code/division-13-environmental -guality/chapter-6-limitations/section-2116867- oakland-sports-and -mixed-use-proiect-conditions -for-aoproval -certification-of-project -for-streamlining . 10 Item Title: 11.1
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Disclaimer
SWAPE has received limited documentation regarding this project. Additional information may become available in the future; thus, we retain the right to revise or amend this report when additional information becomes available. Our professional services have been performed using that degree of care and skill ordinarily exercised, under similar circumstances, by reputable environmental consultants practicing in this or similar localities at the time of service. No other warranty, expressed or implied, is made as to the scope of work, work methodologies and protocols, site conditions, analytical testing results, and findings presented. This report reflects efforts which were limited to information that was reasonably accessible at the time of the work, and may contain informational gaps, inconsistencies, or otherwise be incomplete due to the unavailability or uncertainty of information obtained or provided by third parties.

Sincerely,
~11-u~-
Matt Hagemann, P.G., C.Hg.

Paul E. Rosenfeld, Ph.D.

Attachment A: CalEEMod Output Files
Attachment B: Matt Hagemann CV
Attachment C: Paul Rosenfeld CV
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Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 Attachment A
Menifee (Pemcor) Business Park Detailed Report
Table of Contents

1. Basic Project Information

1.1. Basic Project Information

1.2. Land Use Types

1.3. User-Selected Emission Reduction Measures by Emissions Sector

2. Emissions Summary

2.1. Construction Emissions Compared Against Thresholds

2.2. Construction Emissions by Year, Unmitigated

2.3. Construction Emissions by Year, Mitigated

3. Construction Emissions Details

3.1. Demolition (2025) - Unmitigated

3.2. Demolition (2025) - Mitigated

3.3. Site Preparation (2025) - Unmitigated

3.4. Site Preparation (2025) - Mitigated

3.5. Grading (2025) - Unmitigated

3.6. Grading (2025) - Mitigated
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3.7. Building Construction (2025) - Unmitigated

3.8. Building Construction (2025) - Mitigated

3.9. Building Construction (2026) - Unmitigated

3.10. Building Construction (2026) - Mitigated

3.11. Paving (2026) - Unmitigated

3.12. Paving (2026) - Mitigated

3.13. Architectural Coating (2026) - Unmitigated

3.14. Architectural Coating (2026) - Mitigated

4. Operations Emissions Details

4.10. Soil Carbon Accumulation By Vegetation Type

4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated Menifee (Pemcor) Business Park Detailed Report, 9/17/2025

4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated

4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated

4.10.4. Soil Carbon Accumulation By Vegetation Type - Mitigated

4.10.5. Above and Belowground Carbon Accumulation by Land Use Type - Mitigated

4.10.6. Avoided an.d Sequestered Emissions by Species - Mitigated

5. Activity Data

5.1. Construction Schedule
2 / 52
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5.2. Off-Road Equipment

5.2.1. Unmitigated

5.2.2. Mitigated

5.3. Construction Vehicles

5.3.1. Unmitigated

5.3.2. Mitigated

5.4. Vehicles

5.4.1. Construction Vehicle Control Strategies

5.5. Architectural Coatings

5.6. Dust Mitigation

5.6.1. Construction Earthmoving Activities

5.6.2. Construction Earthmoving Control Strategies

5. 7. Construction Paving

5.8. Construction Electricity Consumption and Emissions Factors

5.18. Vegetation

5.18.1. Land Use Change

5.18.1.1. Unmitigated

5.18.1.2. Mitigated
Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 3 / 52
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5.18.1. Biomass Cover Type

5.18.1.1. Unmitigated

5.18.1.2. Mitigated

5.18.2. Sequestration

5.18.2.1. Unmitigated

5.18.2.2. Mitigated

6. Climate Risk Detailed Report

6.1. Climate Risk Summary

6.2. Initial Climate Risk Scores

6.3. Adjusted Climate Risk Scores

6.4. Climate Risk Reduction Measures

7. Health and Equity D~tails

7.1. CalEnviroScreen 4.0 Scores

7.2. Healthy Places Index Scores

7.3. Overall Health & Equity Scores

7.4. Health & Equity Measures
7 .5. Evaluation Scorecard
7 .6. Health & Equity Custom Measures
Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 4 I 52
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Menifee (Pemcor) Business Park Detailed Report, 9/17/2025

8. User Changes to Default Data
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1 . Basic Project Information

1.1. Basic Project Information
Data Field
Project Name
Construction Start Date
Lead Agency
Land Use Scale
Analysis Level for Defaults
Windspeed (m/s)
Precipitation (days)
Location
County
City
Air District
Air Basin
TAZ
EDFZ
Electric Utility
Gas Utility
App Version
1 .2. Land Use Types
Land Use Subtype
Industrial Park
Parking Lot
Size
338

12.9 Unit
1000sqft
Acre
Lot Acreage

7.09 12.0
Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 Value
Menifee (Pemcor) Business Park
1/1/2025
Project/site
County

2.50 18.6
33521 Zeiders Rd, Menifee, CA 92584, USA
Riverside-South Coast
Menifee
South Coast AQMD
South Coast
5536
11 Southern California Edison
Southern California Gas
2022.1.1.30
Building Area (sq ft) Landscape Area (sq
ft)
Special Landscape
Area (sq ft)
337,770

0.00 6 I 52

0.00 0.00
Population Description
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Menifee (Pemcor) Business Park Detailed Report, 9/17/2025

1.3. User-Selected Emission Reduction Measures by Emissions Sector Sector Measure Title
Construction C-13 Use Low-VOC Paints for Construction

2. Emissions Summary

2.1. Construction Emissions Compared Against Thresholds Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) i'@M•r•mllll--llll-i#ilMiiHIM·iiHIMli#Ui1iiHti1·iiHtiili:S•f&hi:S-tiB·# ◄r-lllll- Daily,
Summer
(Max)
Unmit. 164 164 30.4 30.0 0.06 1.25 9.63 10.9 1 .15 3.76 4.91 - 7,486 7,486 0.29 0.35 12.2 7,542 Mit. 23.2 23.2 30.4 30.0 0.06 1.25 9.63 10.9 1.15 3.76 4.91 - 7,486 7,486 0.29 0.35 12.2 7,542 % 86% 86%
Reduced
Daily,
Winter
(Max)
Unmit. 4.02 3.38 31.7 31.2 0.06 1.37 19.9 21 .3 1.26 10.2 11.4 - 7,463 7,463 0.29 0.35 0.32 7,518 Mit. 4.02 3.38 31 .7 31 .2 0.06 1.37 19.9 21 .3 1.26 10.2 11 .4 - 7,463 7,463 0.29 0.35 0.32 7,518 %
Reduced
Average
Daily
(Max)
Unmit. 9.72 9.61 13.8 19.0 0.03 0.52 2.74 3.26 0.48 0.95 1.43 - 4,650 4,650 0.18 0.21 2.92 4,719 Mit. 1.99 1.89 13.8 19.0 0.03 0.52 2.74 3.26 0.48 0.95 1.43 - 4,650 4,650 0.18 0.21 2.92 4,719 % 79% 80%
Reduced
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Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 Annual
(Max)
Unmit. 1.77 1.75 2.52 3.46 0.01 0.10 0.50 0.59 0.09 0.17 0.26 - 770 770 0.03 0.03 0.48 781 Mit. 0.36 0.34 2.52 3.46 0.01 0.10 0.50 0.59 0.09 0.17 0.26 - 770 770 0.03 0.03 0.48 781 % 79% 80%
Reduced

2.2. Construction Emissions by Year, Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual ) -------•HIMiiHh+iiiilMlilUi11iiUi1·1iHtiiii=B.PW!!i=M•tlA·HM 1-IIIIII· · Daily-
Summer
(Max)
2025 3.94 3.29 -30.4 30.0 0.06 1.25 9.63 10.9 1.15 3.76 4.91 - 7,486 7,486 0.29 0.35 12.2 7,542 2026 164 164 15.3 27.8 0.04 0.52 2.33 2.85 0.48 0.57 1.05 - 6,770 6,770 0.25 0.35 11.2 6,892 Daily-
Winter
(Max)
2025 4.02 3.38 31.7 31.2 0.06 1.37 19.9 21.3 1.26 10.2 11.4 - 7,463 7,463 0.29 0.35 0.32 7,518 2026 2.39 2.00 15.4 25.3 0.04 0.52 2.33 2.85 0.48 0.57 1.05 - 6,614 6,614 0.19 0.35 0.29 6,724 Average
Daily
2025 1.99 1.67 13.8 19.0 0.03 0.52 2.74 3.26 0.48 0.95 1.43 - 4,650 4,650 0.18 0.21 2.92 4,719 2026 9.72 9.61 4.23 7.02 0.01 0.15 0.59 0.74 0.14 0.14 0.28 - 1,744 1,744 0.05 0.09 1.23 1,773 Annual
2025 0.36 0.30 2.52 3.46 0.01 0.10 0.50 0.59 0.09 0.17 0.26 - 770 770 0.03 0.03 0.48 781 2026 1.77 1.75 0.77 1.28 < 0.005 0.03 0.11 0.14 0.02 0.03 0.05 - 289 289 0.01 0.01 0.20 294

2.3. Construction Emissions by Year, Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) 8 / 52
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Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 -------•4HNiiHH+NiHIMMiHti1iiHti1•1i@ftiiii=ti•!W!!i=M-til ____ Daily-
Summer
(Max)
2025 3.94 3.29 30.4 30.0 0.06 1.25 9.63 10.9 1.15 3.76 4.91 - 7,486 7,486 0.29 0.35 2026 23.2 23.2 15.3 27.8 0.04 0.52 2.33 2.85 0.48 0.57 1.05 - 6,770 6,770 0.25 0.35 Daily-
Winter
(Max)
2025 4.02 3.38 31.7 31.2 0.06 1.37 19.9 21.3 1.26 10.2 11.4 - 7,463 7,463 0.29 0.35 2026 2.39 2.00 15.4 25.3 0.04 0.52 2.33 2.85 0.48 0.57 1.05 - 6,614 6,614 0.19 0.35 Average
Daily
2025 1.99 1.67 13.8 19.0 0.03 0.52 2.74 3.26 0.48 0.95 1.43 - 4,650 4,650 0.18 0.21 2026 1.99 1.89 ·4.23 7.02 0.01 0.15 0.59 0.74 0.14 0.14 0.28 - 1,744 1,744 0.05 0.09 Annual
2025 0.36 0.30 2.52 3.46 0.01 0.10 0.50 0.59 0.09 0.17 0.26 - 770 770 0.03 0.03 2026 0.36 0.34 0.77 1.28 < 0.005 0.03 0.11 0.14 0.02 0.03 0.05 - 289 289 0.01 0.01

3. Construction Emissions Details

3.1. Demolition (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) ii·i&iMflllllamllralB-iHit·i ◄iiili·i·NiHl 111 MiHtiiiHti·iiHtiiii=ti•!W!ii=ti-tiB·HMalllllllll Onsite
Daily,
Summer
(Max)
Daily,
Winter
(Max)
9 / 52

12.2 7,542

11.2 6,892

0.32 7,518

0.29 6,724

2.92 4,719

1.23 1,773

0.48 781

0.20 294
R C02e
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Page
505 of 961

Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 Off-Roa 2.86 2.40 22.2 19.9 0.03 0.92 - 0.92 0.84 - 0.84 - 3,425 3,425 0.14 0.03 - 3,437 Equipment
Demoliti - - - - - - 0.15 0.15 - 0.02 0.02
on
Onsite 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 truck
Average
Daily
Off-Roa 0.16 0.13 1.22 1.09 < 0.005 0.05 - 0.05 0.05 - 0.05 - 188 188 0.01 < 0.005 - 188 d
Equipm
ent
Demoliti - - - - - - 0.01 0.01 - < 0.005 < 0.005
on
Onsite 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 truck
Annual
Off-Roa 0.03 0.02 0.22 0.20 < 0.005 0.01 - 0.01 0.01 - 0.01 - 31.1 31.1 < 0.005 < 0.005 - 31.2 d
Equipm
ent
Demoliti - - - - - - < 0.005 < 0.005 - < 0.005 < 0.005
on
Onsite 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 truck
Offsite
Daily,
Summer
(Max)
Daily,
Winter
(Max)
Worker 0.07 0.06 0.07 0.88 0.00 0.00 0.20 0.20 0.00 0.05 0.05 - 194 194 0.01 0.01 0.02 197 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.01 < 0.005 0.17 0.04 < 0.005 < 0.005 0.04 0.04 < 0.005 0.01 0.01 - 152 152 < 0.005 0.02 0.01 160 10 / 52
Item Title: 11.1
Appeal of Planning Commission Decision for the Menifee (Pemcor) Business Park Project Item Page Number: 203

Menifee Mayor and City Council
February 4, 2026
Page
506 of 961

Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 Average - - ·- - - - - - - - - - - - - - -
Daily
Worker < 0.005 < 0.005 < 0.005 0.05 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 - 10.8 10.8 < 0.005 < 0.005 0.02 10.9 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 Hauling < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 - 8.35 8.35 < 0.005 < 0.005 0.o1 8.76 Annual
Worker < 0.005 < 0.005 . < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 - 1.79 1.79 < 0.005 < 0.005 < 0.005 1.81 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 - 1.38 1.38 < 0.005 <0.005 < 0.005 1.45

3.2. Demolition (2025) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) ·+i&iiH,ial lml-lllB,iHIMl•Hli·i·liHIMMiHtiiiHti·li#Uiii --·- Onsite
Daily,
Summer
(Max)
Daily,
Winter
(Max)
Off-Roa 2.86 2.40 22.2 19.9 0.03 0.92 - 0.92 0.84 - 0.84 - 3,425 3,425 0.14 0.03 - 3,437 d
Equipm
ent
Demoliti - - - - - - 0.15 0.15 - 0.02 0.02
on
Onsite 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 truck
Average
Daily
11 / 52
Item Title: 11.1
Appeal of Planning Commission Decision for the Menifee (Pemcor) Business Park Project Item Page Number: 204

Menifee Mayor and City Council
February 4, 2026
Page
507 of 961

Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 Off-Roa 0.16 0.13 1.22 1.09 < 0.005 0.05 - 0.05 0.05 - 0.05 - 188 188 0.01 < 0.005 - 188 d
Equipm
ent
Demoliti - - - - - - 0.01 0.01 - < 0.005 < 0.005
on
Onsite 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 truck
Annual
Off-Roa 0.03 0.02 0.22 0.20 < 0.005 0.01 - 0.01 0.01 - 0.01 - 31 .1 31 .1 < 0 .005 < 0.005 - 31.2 d
Equipm
ent
Demoliti - - - - - - < 0.005 < 0.005 - < 0.005 < 0.005
on
Onsite 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 truck
Offsite
Daily,
Summer
(Max)
Daily,
Winter
(Max)
Worker 0.07 0.06 0.07 0.88 0.00 0.00 0.20 0.20 0.00 0.05 0.05 - 194 194 0.01 0.01 0.02 197 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.01 < 0.005 0.17 0.04 < 0.005 < 0.005 0.04 0.04 < 0.005 0.01 0.01 - 152 152 < 0.005 0.02 0.01 160 Average
Daily
Worker < 0.005 < 0.005 < 0.005 0.05 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 - 10.8 10.8 < 0.005 < 0.005 0.02 10.9 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 Hauling < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 - 8.35 8.35 < 0.005 < 0.005 0.01 8.76 Annual
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 - 1.79 1.79 < 0.005 < 0.005 < 0.005 1.81 12 / 52
Item Title: 11.1
Appeal of Planning Commission Decision for the Menifee (Pemcor) Business Park Project Item Page Number: 205

Menifee Mayor and City Council
February 4, 2026
Page
508 of 961

Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 - 1.38 1.38 < 0.005 < 0.005 < 0.005 1.45

3.3. Site Preparation (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) ll·lllll-l1lllllllamll-llllllllMllllll·l·llllll·llllltllllltl1·111~tl-lll=l'•r-Hl=ll•t1B·H ---Onsite Daily,
Summer
(Max)
Daily,
Winter
(Max)
Off-Roa 3.94 3.31 31.6 30.2 0.05 1.37 - 1.37 1.26 - 1.26 - 5,295 5,295 0.21 0.04 - 5,314 d
Equipm
ent
Dust - - - - - - 19.7 19.7 - 10.1 10.1
From
Material
Movement
Onsite 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 truck
Average
Daily
Off-Roa 0.11 0.09 . 0.87 0.83 < 0.005 0.04 - 0.04 0.03 - 0.03 - 145 145 0.01 < 0.005 - 146 d
Equipm
ent
Dust - - - - - - 0.54 0.54 - 0.28 0.28
From
Material
Movement
Onsite 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 truck
13 / 52
Item Title: 11.1
Appeal of Planning Commission Decision for the Menifee (Pemcor) Business Park Project Item Page Number: 206

Menifee Mayor and City Council
February 4, 2026
Page
509 of 961

Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 Annual
Off-Roa 0.02 0.02 0.16 0.15 < 0.005 0.01 - 0.01 0.01 - 0.01 - 24.0 24.0 < 0.005 < 0.005 - 24.1 d
Equipm
ent
Dust - - - - - - 0.10 0.10 - 0.05 0.05
From
Material
Movement
Onsite 0.00 0.00 ·o.oo 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 truck
Offsite
Daily,
Summer
(Max)
Daily,
Winter
(Max)
Worker 0.08 0.07 0.08 1.02 0.00 0.00 0.23 0.23 0.00 0.05 0.05 - 227 227 0.01 0.01 0.02 230 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
Worker < 0.005 < 0.005 < 0.005 0.03 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 - 6.29 6.29 < 0.005 < 0.005 0.01 6.38 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 -0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 Annual
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 - 1.04 1.04 < 0.005 < 0.005 < 0.005 1.06 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00

3.4. Site Preparation (2025) - Mitigated
14 / 52
Item Title: 11.1
Appeal of Planning Commission Decision for the Menifee (Pemcor) Business Park Project Item Page Number: 207

Menifee Mayor and City Council
February 4, 2026
Page
510 of 961

Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) •+1¥iil·i,i ■ --llll-llll-iHIMliiili111iiiilMMiiUlliiUl·liHtiili:Q•f&!!i:@•ti 1--IBI- Onsite
Daily,
Summer
(Max)
Daily,
Winter
(Max)
Off-Roa 3.94 3.31 31.6 30.2 0.05 1.37 - 1.37 1.26 - 1.26 - 5,295 5,295 0.21 0.04 - 5,314 d
Equipm
ent
Dust - - - - - - 19.7 19.7 - 10.1 10.1
From
Material
Movement
Onsite 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 truck
Average
Daily
Off-Roa 0.11 0.09 0.87 0.83 < 0.005 0.04 - 0.04 0.03 - 0.03 - 145 145 0.01 < 0.005 - 146 d
Equipm
ent
Dust - - - - - - 0.54 0.54 - 0.28 0.28
From
Material
Movement
Onsite 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 truck
Annual
Off-Roa 0.02 0.02 0.16 0.15 < 0.005 0.01 - 0.01 0.01 - 0.01 - 24.0 24.0 < 0.005 < 0.005 - 24.1 d
Equipm
ent
15/ 52
Item Title: 11.1
Appeal of Planning Commission Decision for the Menifee (Pemcor) Business Park Project Item Page Number: 208

Menifee Mayor and City Council
February 4, 2026
Page
511 of 961

Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 Dust - - - - - - 0.10 0.10 - 0.05 0.05
From
Material
Movement
Onsite 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 truck
Offsite
Daily,
Summer
(Max)
Daily,
Winter
(Max)
Worker 0.08 0.07 0.08 1.02 0.00 0.00 0.23 0.23 0.00 0.05 0.05 - 227 227 0.01 0.01 0.02 230 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
Worker < 0.005 < 0.005 < 0.005 0.03 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 - 6.29 6.29 < 0.005 < 0.005 0.01 6.38 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 Annual
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 - 1.04 1.04 < 0.005 < 0.005 < 0.005 1.06 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00

3.5. Grading (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) i+i&iiH,illllll!llll--lllliiiiMliHIM·NiliiMMiHti11ilUi1·1iHtiili:S-fW!ii:M•timllllllllllll- Onsite
16 / 52
Item Title: 11.1
Appeal of Planning Commission Decision for the Menifee (Pemcor) Business Park Project Item Page Number: 209

Menifee Mayor and City Council
February 4, 2026
Page
512 of 961

Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 Daily,
Summer
(Max)
Off-Roa 3.80 3.20 29.7 28.3 0.06 1.23 - 1.23 1.14 - 1.14 - 6,599 6,599 0.27 0.05 - 6,622 d
Equipm
ent
Dust - - - - - - 9.21 9.21 - 3.65 3.65
From
Material
Movement
Onsite 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 truck
Daily,
Winter
(Max)
Off-Roa 3.80 3.20 29.7 28.3 0.06 1.23 - 1.23 1.14 - 1.14 - 6,599 6,599 0.27 0.05 - 6,622 d
Equipm
ent
Dust - - - - - - 9.21 9.21 - 3.65 3.65
From
Material
Movement
Onsite 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 truck
Average
Daily
Off-Roa 0.38 0.32 2.93 2.79 0.01 0.12 - 0.12 0.11 - 0.11 - 651 651 0.03 0.01 - 653 d
Equipm
ent
Dust - - - - - - 0.91 0.91 - 0.36 0.36
From
Material
Movement
Onsite 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 truck
17 / 52
Item Title: 11.1
Appeal of Planning Commission Decision for the Menifee (Pemcor) Business Park Project Item Page Number: 210

Menifee Mayor and City Council
February 4, 2026
Page
513 of 961

Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 Annual
Off-Roa 0.07 0.06 0.53 0.51 < 0.005 0.02 - 0.02 0.02 - 0.02 - 108 108 < 0.005 < 0.005 - 108 d
Equipm
ent
Dust - - - - - - 0.17 0.17 - 0.07 0.07
From
Material
Movement
Onsite 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 truck
Offsite
Daily,
Summer
(Max)
Worker 0.11 0.09 0.09 1.54 0.00 0.00 0.26 0.26 0.00 0.06 0.06 - 282 282 0.01 0.01 1.04 286 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.02 0.01 0.65 0.15 < 0.005 0.01 0.16 0.17 0.01 0.04 0.06 - 605 605 0.01 0.10 1.30 635 Daily,
Winter
(Max)
Worker 0.09 0.08 0.10 1.17 0.00 0.00 0.26 0.26 0.00 0.06 0.06 - 259 259 0.01 0.01 0.03 262 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.02 O.o1 0.68 0.15 < 0.005 0.01 0.16 0.17 0.01 0.04 0.06 - 605 605 0.01 0.10 0.03 634 Average
Daily
Worker 0.01 0.01 0.01 0.12 0.00 0.00 0.03 0.03 0.00 0.01 0.01 - 25.9 25.9 < 0.005 < 0.005 0.04 26.2 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 Hauling < 0.005 < 0.005 0.07 0.01 < 0.005 < 0.005 0.02 0.02 < 0.005 < 0.005 0.01 - 59.7 59.7 < 0.005 0.01 0.05 62.5 Annual
Worker < 0.005 < 0.005 < 0.005 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 - 4.29 4.29 < 0.005 < 0.005 0.01 4.35 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 Hauling < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 - 9.88 9.88 < 0.005 < 0.005 0.01 10.4 18 / 52
Item Title: 11.1
Appeal of Planning Commission Decision for the Menifee (Pemcor) Business Park Project Item Page Number: 211

Menifee Mayor and City Council
February 4, 2026
Page
514 of 961

Menifee (Pemcor) Business Park Detailed Report, 9/17/2025

3.6. Grading (2025) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) l!·IIIIIIIIIIDIIIIIIBl-lllll·IIIHll·l·IIHll•IIIHtlllHtl•lllltl-lll=l•!IIHl=ll•tll·H ■-111111·· Onsite
Daily,
Summer
(Max)
Off-Roa 3.80 3.20 29.7 28.3 0.06 1.23 - 1.23 1.14 - 1.14 - 6,599 6,599 0.27 0.05 - 6,622 d
Equipm
ent
Dust - - - - - - 9.21 9.21 - 3.65 3.65
From
Material
Movement
Onsite 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 truck
Daily,
Winter
(Max)
Off-Roa 3.80 3.20 29.7 28.3 0.06 1.23 - 1.23 1.14 - 1.14 - 6,599 6,599 0.27 0.05 - 6,622 d
Equipm
ent
Dust - - - - - - 9.21 9.21 - 3.65 3.65
From
Material
Movement
Onsite 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 truck
Average
Daily
Off-Roa 0.38 0.32 2.93 2.79 0.01 0.12 - 0.12 0.11 - 0.11 - 651 651 0.03 0.01 - 653 d
Equipm
ent
19 / 52
Item Title: 11.1
Appeal of Planning Commission Decision for the Menifee (Pemcor) Business Park Project Item Page Number: 212

Menifee Mayor and City Council
February 4, 2026
Page
515 of 961

Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 Dust - - - - - - 0.91 0.91 - 0.36 0.36
From
Material
Movement
Onsite 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 truck
Annual
Off-Roa 0.07 0.06 0.53 0.51 < 0.005 0.02 - 0.02 0.02 - 0.02 - 108 108 < 0.005 < 0.005 - 108 d
Equipm
ent
Dust - - - - - - 0.17 0.17 - 0.07 0.07
From
Material
Movement
Onsite 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 truck
Offsite
Daily,
Summer
(Max)
Worker 0.11 0.09 0.09 1.54 0.00 0.00 0.26 0.26 0.00 0.06 0.06 - 282 282 0.01 0.01 1.04 286 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.02 0.01 0.65 0.15 < 0.005 0.01 0.16 0.17 0.01 0.04 0.06 - 605 605 0.01 0.10 1.30 635 Daily,
Winter
(Max)
Worker 0.09 0.08 0.10 1.17 0.00 0.00 0.26 0.26 0.00 0.06 0.06 - 259 259 0.01 0.01 0.03 262 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.02 0.01 0.68 0.15 < 0.005 0.01 0.16 0.17 0.01 0.04 0.06 - 605 605 0.01 0.10 0.03 634 Average
Daily
Worker 0.01 0.01 0.01 0.12 0.00 0.00 0.03 0.03 0.00 0.01 0.01 - 25.9 25.9 < 0.005 < 0.005 0.04 26.2 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 20 / 52
Item Title: 11.1
Appeal of Planning Commission Decision for the Menifee (Pemcor) Business Park Project Item Page Number: 213

Menifee Mayor and City Council
February 4, 2026
Page
516 of 961

Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 Hauling < 0.005 < 0.005 0.07 0.01 < 0.005 < 0.005 0.02 0.02 < 0.005 < 0.005 0.01 - 59.7 59.7 < 0.005 0.01 0.05 62.5 Annual
Worker < 0.005 < 0.005 < 0.005 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 - 4.29 4.29 < 0.005 < 0.005 0.01 4.35 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 Hauling < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 - 9.88 9.88 < 0.005 < 0.005 0.01 10.4

3.7. Building Construction (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) ;;.;;;a ■ -mlll!llallll-iHIN◄iHh·l·liHIMMi4Ui1ii4Ui1·1iHtiiii=M+EHi=M•►iN·H ---Onsite
Daily,
Summer
(Max)
Off-Roa 1. 77 1.48 13.7 17.1 0.03 0.57 - 0.57 0.52 - 0.52 - 3,148 3,148 0.13 0.03 - 3,159 d
Equipm
ent
Onsite 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 truck
Daily,
Winter
(Max)
Off-Roa 1.77 1.48 13.7 17.1 0 .03 0.57 - 0.57 0.52 - 0.52 - 3,148 3,148 0.13 0.03 - 3,159 d
Equipm
ent
Onsite 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 truck
Average
Daily
Off-Roa 0.94 0.78 7.27 9.08 0.02 0.30 - 0.30 0.28 - 0.28 - 1,669 1,669 0.07 0.01 - 1,675 d
Equipm
ent
21 / 52
Item Title: 11.1
Appeal of Planning Commission Decision for the Menifee (Pemcor) Business Park Project Item Page Number: 214

Menifee Mayor and City Council
February 4, 2026
Page
517 of 961

Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 Onsite 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 truck
Annual
Off-Roa 0.17 0.14 1.33 1.66 < 0.005 0.05 - 0.05 0.05 - 0.05 - 276 276 0.01 < 0.005 - 277 d
Equipm
ent
Onsite 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 truck
Offsite
Daily,
Summer
(Max)
Worker 0.76 0.63 0.62 11.0 0.00 0.00 1.85 1.85 0.00 0.43 0.43 - 1,999 1,999 0.08 0.07 7.35 2,030 Vendor 0.08 0.04 1.86 0.58 0.01 0.02 0.47 0.50 0.02 0.13 0.16 - 1,694 1,694 0.04 0.26 4.81 1,776 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
Worker 0.67 0.60 0.68 8.28 0.00 0.00 1.85 1.85 0.00 0.43 0.43 - 1,838 1,838 0.09 0.07 0.19 1,861 Vendor 0.07 0.03 1.95 0.59 0.01 0.02 0.47 0.50 0.02 0.13 0.16 - 1,695 1,695 0.04 0.26 0.12 1,773 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
Worker 0.35 0.31 0.39 4.64 0.00 0.00 0.97 0.97 0.00 0.23 0.23 - 987 987 0.05 0.04 1.68 1,001 Vendor 0.04 0.02 1.03 0.31 0.01 0.01 0.25 0.26 0.01 0.07 0.08 - 898 898 0.02 0.14 1.10 941 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 Annual
Worker 0.06 0.06 0.07 0.85 0.00 0.00 0.18 0.18 0.00 0.04 0.04 - 163 163 0.01 0.01 0.28 166 Vendor 0.01 < 0.005 0.19 0.06 < 0.005 < 0.005 0.05 0.05 < 0.005 0.01 0.01 - 149 149 < 0.005 0.02 0.18 156 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 22 / 52
Item Title: 11.1
Appeal of Planning Commission Decision for the Menifee (Pemcor) Business Park Project Item Page Number: 215

Menifee Mayor and City Council
February 4, 2026
Page
518 of 961

Menifee (Pemcor) Business Park Detailed Report, 9/17/2025

3.8. Building Construction (2025) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) ll·lll ■EIIIIIIIIIIZllrml-lHll·IIIHll·l·llllll•IIIHtl111Ht11·11Htl-ilMl·!IIHl=l•tll·H ---Onsite
Daily,
Summer
(Max)
Off-Roa 1. 77 1.48 13.7 17.1 0.03 0.57 - 0.57 0.52 - 0.52 - 3,148 3,148 0.13 0.03 - 3,159 d
Equipm
ent
Onsite 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 truck
Daily,
Winter
(Max)
Off-Roa 1. 77 1.48 13.7 17.1 0.03 0.57 - 0.57 0.52 - 0.52 - 3,148 3,148 0.13 0.03 - 3,159 d
Equipm
ent
Onsite 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 truck
Average
Daily
Off-Roa 0.94 0.78 7.27 9.08 0.02 0.30 - 0.30 0.28 - 0.28 - 1,669 1,669 0.07 0.01 - 1,675 d
Equipm
ent
Onsite 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 truck
Annual
Off-Roa 0.17 0.14 1.33 1.66 < 0.005 0.05 - 0.05 0.05 - 0.05 - 276 276 0.01 < 0.005 - 277 d
Equipm
ent
23 / 52
Item Title: 11.1
Appeal of Planning Commission Decision for the Menifee (Pemcor) Business Park Project Item Page Number: 216

Menifee Mayor and City Council
February 4, 2026
Page
519 of 961

Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 Onsite 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 truck
Offsite
Daily,
Summer
(Max)
Worker 0.76 0.63 0.62 11.0 0.00 0.00 1.85 1.85 0.00 0.43 0.43 - 1,999 1,999 0.08 0.07 7.35 2,030 Vendor 0.08 0.04 1.86 0.58 0.01 0.02 0.47 0.50 0.02 0.13 0.16 - 1,694 1,694 0.04 0.26 4.81 1,776 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
Worker 0.67 0.60 0.68 8.28 0.00 0.00 1.85 1.85 0.00 0.43 0.43 - 1,838 1,838 0.09 0.07 0.19 1,861 Vendor 0.07 0.03 1.95 0.59 0.01 0.02 0.47 0.50 0.02 0.13 0.16 - 1,695 1,695 0.04 0.26 0.12 1,773 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
Worker 0.35 0.31 0.39 4.64 0.00 0.00 0.97 0.97 0.00 0.23 0.23 - 987 987 0.05 0.04 1.68 1,001 Vendor 0.04 0.02 1.03 0.31 0.01 0.01 0.25 0.26 0.01 0.07 0.08 - 898 898 0.02 0.14 1.10 941 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 Annual
Worker 0.06 0.06 0.07 0.85 0.00 0.00 0.18 0.18 0.00 0.04 0.04 - 163 163 0.01 0.01 0.28 166 Vendor 0.01 <0.005 0.19 0.06 <0.005 < 0.005 0.05 0.05 <0.005 0.01 0.01 - 149 149 < 0.005 0.02 0.18 156 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00

3.9. Building Construction (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) H·iilMf!IIIIIDl-lllla-iHINii4UN·liHIMMiiUi11iiUi1·MiHtiiii=M•f◄Hi=M•tiii-HMallllllll- Onsite
24 / 52
Item Title: 11.1
Appeal of Planning Commission Decision for the Menifee (Pemcor) Business Park Project Item Page Number: 217

Menifee Mayor and City Council
February 4, 2026
Page
520 of 961

Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 Daily,
Summer
(Max)
Off-Roa 1.68 1.40 12.9 17.0 0.03 0.50 - 0.50 0.46 - 0.46 - 3,147 3,147 0.13 0.03 - 3,158 d
Equipm
ent
Onsite 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 truck
Daily,
Winter
(Max)
Off-Roa 1.68 1.40 12.9 17.0 0.03 0.50 - 0.50 0.46 - 0.46 - 3,147 3,147 0.13 0.03 - 3,158 d
Equipm
ent
Onsite 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 truck
Average
Daily
Off-Roa 0.41 0.34 3.16 4.16 0.01 0.12 - 0.12 0.11 - 0.11 - 770 770 0.03 0.01 - 773 d
Equipm
ent
Onsite 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 truck
Annual
Off-Roa 0.07 0.06 0.58 0.76 < 0.005 0.02 - 0.02 0.02 - 0.02 - 127 127 0.01 < 0.005 - 128 d
Equipm
ent
Onsite 0.00 0.00 .0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 truck
Offsite
Daily,
Summer
(Max)
25 / 52
Item Title: 11.1
Appeal of Planning Commission Decision for the Menifee (Pemcor) Business Park Project Item Page Number: 218

Menifee Mayor and City Council
February 4, 2026
Page
521 of 961

Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 Worker 0.67 0.60 0.56 10.2 0.00 0.00 1.85 1.85 0.00 0.43 0.43 - 1,956 1,956 0.08 0.07 6.63 1,985 Vendor 0.08 0.04 1.78 0.55 0.01 0.02 0.47 0.50 0.02 0.13 0.16 - 1,666 1,666 0.04 0.26 4.56 1,749 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
Worker 0.64 0.57 0.62 7.73 0.00 0.00 1.85 1.85 0.00 0.43 0.43 - 1,799 1,799 0.03 0.07 0.17 1,821 Vendor 0.07 0.03 1.86 0.57 0.01 0.02 0.47 0.50 0.02 0.13 0.16 - 1,668 1,668 0.04 0.26 0.12 1,745 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
Worker 0.15 0.14 .0.17 1.98 0.00 0.00 0.45 0.45 0.00 0.10 0.10 - 446 446 0.01 0.02 0.70 452 Vendor 0.02 0.01 0.46 0.14 < 0.005 0.01 0.11 0.12 0.01 0.03 0.04 - 408 408 0.01 0.06 0.48 427 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 Annual
Worker 0.03 0.03 0.03 0.36 0.00 0.00 0.08 0.08 0.00 0.02 0.02 - 73.8 73.8 < 0.005 < 0.005 0.12 74.8 Vendor < 0.005 < 0.005 0.08 0.02 < 0.005 < 0.005 0.02 0.02 < 0.005 0.01 0.01 - 67.5 67.5 < 0.005 0.01 0.08 70.7 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00

3.10. Building Construction (2026) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) ;;.;;;;r.1,1 ■•1Rll!IIBllllll-iHINiiHH-i·li#IIMii4Ui1iiHti1-ii#Miiii=k•f◄Hi:fi•ti[a_lBI_ Onsite
Daily,
Summer
(Max)
Off-Roa 1.68 1.40 12.9 17.0 0.03 0.50 - 0.50 0.46 - 0.46 - 3,147 3,147 0.13 0.03 - 3,158 d
Equipm
ent
26 / 52
Item Title: 11.1
Appeal of Planning Commission Decision for the Menifee (Pemcor) Business Park Project Item Page Number: 219

Menifee Mayor and City Council
February 4, 2026
Page
522 of 961

Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 Onsite 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 truck
Daily,
Winter
(Max)
Off-Roa 1.68 1.40 12.9 17.0 0.03 0.50 - 0.50 0.46 - 0.46 - 3,147 3,147 0.13 0.03 - 3,158 d
Equipm
ent
Onsite 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 truck
Average
Daily
Off-Roa 0.41 0.34 3.16 4.16 0.01 0.12 - 0.12 0.11 - 0.11 - 770 770 0.03 0.01 - 773 d
Equipm
ent
Onsite 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 truck
Annual
Off-Roa 0.07 0.06 0.58 0.76 < 0.005 0.02 - 0.02 0.02 - 0.02 - 127 127 0.01 < 0.005 - 128 d
Equipm
ent
Onsite 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 truck
Offsite
Daily,
Summer
(Max)
Worker 0.67 0.60 0.56 10.2 0.00 0.00 1.85 1.85 0.00 0.43 0.43 - 1,956 1,956 0.08 0.07 6.63 1,985 Vendor 0.08 0.04 1.78 0.55 0.01 0.02 0.47 0.50 0.02 0.13 0.16 - 1,666 1,666 0.04 0.26 4.56 1,749 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
27 / 52
Item Title: 11.1
Appeal of Planning Commission Decision for the Menifee (Pemcor) Business Park Project Item Page Number: 220

Menifee Mayor and City Council
February 4, 2026
Page
523 of 961

Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 Worker 0.64 0.57 0.62 7.73 0.00 0.00 1.85 1.85 0.00 0.43 0.43 - 1,799 1,799 0.03 0.07 0.17 1,821 Vendor 0.07 0.03 1.86 0.57 0.01 0.02 0.47 0.50 0.02 0.13 0.16 - 1,668 1,668 0.04 0.26 0.12 1,745 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
Worker 0.15 0.14 0.17 1.98 0.00 0.00 0.45 0.45 0.00 0.10 0.10 446 446 0.01 0.02 0.70 452 Vendor 0.02 0.01 0.46 0.14 < 0.005 0.01 0.11 0.12 0.01 0.03 0.04 - 408 408 0.01 0.06 0.48 427 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 Annual
Worker 0.03 0.03 0.03 0.36 0.00 0.00 0.08 0.08 0.00 0.02 0.02 - 73.8 73.8 < 0.005 < 0.005 0.12 74.8 Vendor < 0.005 < 0.005 0.08 0.02 < 0.005 < 0.005 0.02 0.02 < 0.005 0.01 0.01 - 67.5 67.5 < 0.005 0.01 0.08 70.7 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00

3.11. Paving (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) H·iiM-i,lallllm-al--•HU-iiiiilM·liHIMMiHtiiiiitii·iiHtiiiMi·&E!h=S•tiii·H ---Onsite Daily,
Summer
(Max)
Off-Roa 0.91 0.76 7.12 9.94 0.01 0.32 - 0.32 0.29 - 0.29 - 1,511 1,511 0.06 0.01 - 1,516 d
Equipm
ent
Paving 1.57 1.57
Onsite 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 truck
Daily,
Winter
(Max)
Average
Daily
28 / 52
Item Title: 11.1
Appeal of Planning Commission Decision for the Menifee (Pemcor) Business Park Project Item Page Number: 221

Menifee Mayor and City Council
February 4, 2026
Page
524 of 961

Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 Off-Roa 0.05 0.04 0.39 0.54 < 0.005 0.02 - 0.02 0.02 - 0.02 - 82.8 82.8 < 0.005 < 0.005 - 83.1 Equipment
Paving 0.09 0.09
Onsite 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 truck
Annual
Off-Roa 0.01 0.01 0.07 0.10 < 0.005 < 0.005 - < 0.005 < 0.005 - <0.005 - 13.7 13.7 < 0.005 < 0.005 - 13.8 d
Equipm
ent
Paving 0.02 0.02
Onsite 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 truck
Offsite
Daily,
Summer
(Max)
Worker 0.07 0.06 0.06 1.08 0.00 0.00 0.20 0.20 0.00 0.05 0.05 - 207 207 0.01 0.01 0.70 210 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
Average
Daily
Worker < 0.005 < 0.005 < 0.005 0.05 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 - 10.6 10.6 < 0.005 < 0.005 0.02 10.7 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 Annual
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 - 1.75 1.75 < 0.005 < 0.005 < 0.005 1.77 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 29 / 52
Item Title: 11.1
Appeal of Planning Commission Decision for the Menifee (Pemcor) Business Park Project Item Page Number: 222

Menifee Mayor and City Council
February 4, 2026
Page
525 of 961

Menifee (Pemcor) Business Park Detailed Report, 9/17/2025

3.12. Paving (2026) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual} l!·llllllall-lllll-lllllHll·IIIHll·l·llllll·IIIHtl111Htl·IIHtl-lll=ll•l■HMl·~ll·H ■Bllllal~- Onsite
Daily,
Summer
(Max)
Off-Roa 0.91 0.76 7.12 9.94 0.01 0.32 - 0.32 0.29 - 0.29 - 1,511 1,511 0.06 0.01 - 1,516 d
Equipm
ent
Paving 1.57 1.57
Onsite 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 truck
Daily,
Winter
(Max)
Average
Daily
Off-Roa 0.05 0.04 0.39 0.54 < 0.005 0.02 - 0.02 0.02 - 0.02 - 82.8 82.8 < 0.005 < 0.005 - 83.1 d
Equipm
ent
Paving 0.09 0.09
Onsite 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 truck
Annual
Off-Roa 0.01 0.01 0.07 0.10 < 0.005 < 0.005 - < 0.005 < 0.005 - < 0.005 - 13.7 13.7 < 0.005 < 0.005 - 13.8 d
Equipm
ent
Paving 0.02 0.02
Onsite 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 truck
30 / 52
Item Title: 11.1
Appeal of Planning Commission Decision for the Menifee (Pemcor) Business Park Project Item Page Number: 223

Menifee Mayor and City Council
February 4, 2026
Page
526 of 961

Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 Offsite
Daily,
Summer
(Max)
Worker 0.07 0.06 0.06 1.08 0.00 0.00 0.20 0.20 0.00 0.05 0.05 - 207 207 O.Q1 0.01 0.70 210 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
Average
Daily
Worker < 0.005 < 0.005 < 0.005 0.05 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 - 10.6 10.6 < 0.005 < 0.005 0.02 10.7 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 Annual
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 - 1.75 1.75 < 0.005 < 0.005 < 0.005 1.77 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00

3.13. Architectural Coating (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) a-iiiil·ii'L-lllllZlll'llllll-iHlt·iiiHIM·liHIMliHtiiiHti·liHtiili:S•PW!fi:S•►lii·HM,mlllll- Onsite
Daily,
Summer
(Max)
Off-Roa 0.15 0.12 0.86 1.13 < 0.005 0.02 - 0.02 0.02 - 0.02 - 134 134 0.01 < 0.005 - 134 d
Equipm
ent
31 / 52
Item Title: 11.1
Appeal of Planning Commission Decision for the Menifee (Pemcor) Business Park Project Item Page Number: 224

Menifee Mayor and City Council
February 4, 2026
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527 of 961

Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 Architect 164 164
ural
Onsite 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 truck
Daily,
Winter
(Max)
Average
Daily
Off-Roa 0.01 0.01 0.05 0.06 < 0.005 < 0.005 - < 0.005 < 0.005 - < 0.005 - 7.32 7.32 < 0.005 < 0.005 - 7.34 d
Equipm
ent
Architect 8.98 8.98
ural
Coating
s
Onsite 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 truck
Annual
Off-Roa < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 - < 0.005 < 0.005 - < 0.005 - 1.21 1.21 < 0.005 < 0.005 - 1.22 d
Equipm
ent
Architect 1.64 1.64
ural
Coating
s
Onsite 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 truck
Offsite
Daily,
Summer
(Max)
Worker 0.13 0.12 0.11 2.04 0.00 0.00 0.37 0.37 0.00 0.09 0.09 - 391 391 0.02 0.01 1.33 397 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 32 / 52
Item Title: 11.1
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528 of 961

Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
Average
Daily
Worker 0.01 0.01 .0.01 0.09 0.00 0.00 0.02 0.02 0.00 < 0.005 < 0.005 - 20.0 20.0 < 0.005 < 0.005 0.03 20.2 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 Annual
Worker < 0.005 < 0.005 < 0.005 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 - 3.31 3.31 < 0.005 < 0.005 0.01 3.35 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00

3.14. Architectural Coating (2026) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) ii·MiMllllllllllllllllllllliHIMiiHH·i·lilfl111 iiHtiiiHtii·liiUiiiMl•!W ■ ii=B•tilalllllllll· - Onsite
Daily,
Summer
(Max)
Off-Roa 0.15 0.12 0.86 1.13 < 0.005 0.02 - 0.02 0.02 - 0.02 - 134 134 0.01 < 0.005 - 134 d
Equipm
ent
Architect 22.9 22.9
ural
Coating
s
Onsite 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 truck
33 / 52
Item Title: 11.1
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February 4, 2026
Page
529 of 961

Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 Daily,
Winter
(Max)
Average
Daily
Off-Roa 0.01 0.01 0.05 0.06 < 0.005 < 0.005 - < 0.005 < 0.005 - < 0.005 - 7.32 7.32 < 0.005 < 0.005 - 7.34 d
Equipm
ent
Architect 1.26 1.26
ural
Coating
s
Onsite 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 truck
Annual
Off-Roa < 0.005 < 0.005 ·0.01 0.01 < 0.005 < 0.005 - < 0.005 < 0.005 - < 0.005 - 1.21 1.21 < 0.005 < 0.005 - 1.22 d
Equipm
ent
Architect 0.23 0.23
ural
Coating
s
Onsite 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 truck
Offsite
Daily,
Summer
(Max)
Worker 0.13 0.12 0.11 2.04 0.00 0.00 0.37 0.37 0.00 0.09 0.09 - 391 391 0.02 0.01 1.33 397 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
34 / 52
Item Title: 11.1
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Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 Average
Daily
Worker 0.01 0.01 0.01 0.09 0.00 0.00 0.02 0.02 0.00 < 0.005 < 0.005 - 20.0 20.0 < 0.005 < 0.005 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 Annual
Worker < 0.005 < 0.005 ·< 0.005 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 <0.005 - 3.31 3.31 < 0.005 < 0.005 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 - 0.00 0.00 0.00 0.00

4. Operations Emissions Details

4.10. Soil Carbon Accumulation By Vegetation Type

4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) ···············•• 1 Daily,
Summer
(Max)
Total
Daily,
Winter
(Max)
Total
Annual
Total

4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated 35 / 52

0.03 20.2

0.00 0.00

0.00 0.00

0.01 3.35

0.00 0.00

0.00 0.00
•
Item Title: 11.1
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Menifee Mayor and City Council
February 4, 2026
Page
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Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 - •. - . ·- . ·- . . - - . . ·- . ·- . -
Land TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O Use
Daily,
Summer
(Max)
Total
Daily,
Winter
(Max)
Total
Annual
Total

4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) S·Aiitimlllllllll!llala-i#4MiiHIM·liHIMMi4MiiiiMl·ii4Miiii=M•f&Hi=i9-tiA·HM CH4 N2o - Daily,
Summer
(Max)
Avoided
Subtotal
Sequest
ered
Subtotal
Remove
d
Subtotal
Daily,
Winter
(Max)
36 / 52
•
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February 4, 2026
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Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 Avoided
Subtotal
Sequest -
ered
Subtotal
Remove
d
Subtotal - - -
-
Annual
Avoided
Subtotal
Sequest -
ered
Subtotal
Remove
d
Subtotal

4.10.4. Soil Carbon Accumulation By Vegetation Type - Mitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) ••••••••••••••••• Daily,
Summer
(Max)
Total
Daily,
Winter
(Max)
37 / 52
•
Item Title: 11.1
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Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 Total
Annual
Total

4.10.5. Above and Belowground Carbon Accumulation by Land Use Type - Mitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) ••••••••••••••••• Daily,
Summer
(Max)
Total
Daily,
Winter
(Max)
Total
Annual
Total

4.10.6. Avoided and Sequestered Emissions by Species - Mitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) G·Miiiallla--B-•HINiiHli·i·lii&l 111MiliiiiHti1·1i@Uiili;M-fW!!i=M-ti Daily,
Summer
(Max)
Avoided
Subtotal
Sequest
ered
Subtotal
38 / 52
-
N20 R
•
Item Title: 11.1
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February 4, 2026
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Remove
d
Subtotal
Daily,
Winter
(Max)
Avoided
Subtotal
Sequest -
ered
Subtotal
Remove
d
Subtotal
Annual
Avoided
Subtotal
Sequest
ered
Subtotal
Remove
d
Subtotal

5. Activity Data

5.1. Construction Schedule
Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 39 / 52
Item Title: 11.1
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Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 Phase Name Phase Type Start Date End Date Days Per Week Work Days per Phase Phase Description Demolition Demolition 1/1/2025 1/29/2025 5.00 20.0
Site Preparation Site Preparation 1/30/2025 2/13/2025 5.00 10.0 Grading Grading 2/14/2025 4/4/2025 5.00 36.0
Building Construction Building Construction 4/5/2025 5/5/2026 5.00 282 Paving Paving 5/6/2026 6/2/2026 5.00 20.0
Architectural Coating Architectural Coating 6/3/2026 6/30/2026 5.00 20.0

5.2. Off-Road Equipment

5.2.1. Unmitigated
Phase Name Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor Demolition Rubber Tired Dozers Diesel Average 2.00 8.00 367 0.40 Demolition Excavators Diesel Average 3.00 8.00 36.0 0.38 Demolition Concrete/Industrial Diesel Average 1.00 8.00 33.0 0.73 Saws
Site Preparation Rubber Tired Dozers Diesel Average 3.00 8.00 367 0.40 Site Preparation Tractors/Loaders/Back Diesel Average 4.00 8.00 84.0 0.37 hoes
Grading Graders Diesel Average 1.00 8.00 148 0.41
Grading Excavators Diesel Average 2.00 8.00 36.0 0.38
Grading Tractors/Loaders/Back Diesel Average 2.00 8.00 84.0 0.37 hoes ·
Grading Scrapers Diesel Average 2.00 8.00 423 0.48
Grading Rubber Tired Dozers Diesel Average 1.00 8.00 367 0.40 Building Construction Forklifts Diesel Average 4.00 7.90 82.0 0.20 Building Construction Generator Sets Diesel Average 2.00 5.20 14.0 0.74 Building Construction Cranes Diesel Average 2.00 4.60 367 0.29 Building Construction Welders Diesel Average 2.00 5.20 46.0 0.45 40 / 52
Item Title: 11.1
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February 4, 2026
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Building Construction
Paving
Paving
Paving
Architectural Coating

5.2.2. Mitigated
Phase Name
I
Demolition
Demolition
Demolition
Site Preparation
Site Preparation
Grading
Grading
Grading
Grading
Grading
Building Construction
Building Construction
Building Construction
Building Construction
Building Construction
Paving
Paving
Tractors/Loaders/Back Diesel
Pavers Diesel
Paving Equipment Diesel
Rollers Diesel
Air Compressors Diesel
Equipment Type Fuel Type
Rubber Tired Dozers Diesel
Excavators Diesel
Concrete/Industrial Diesel
Saws
Rubber Tired Dozers Diesel
Tractors/Loaders/Back Diesel
hoes
Graders Diesel
Excavators Diesel
Tractors/Loaders/Back Diesel
hoes
Scrapers Diesel
Rubber Tired Dozers Diesel
Forklifts Diesel
Generator Sets Diesel
Cranes Diesel
Welders Diesel
Tractors/Loaders/Back Diesel
hoes
Pavers Diesel
Paving Equipment Diesel
Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 Average 4.00 6.90 84.0 0.37
Average 2.00 8.00 81.0 0.42
Average 2.00 8.00 89.0 0.36
Average 2.00 8.00 36.0 0.38
Average 1.00 6.00 37.0 0.48
Engine Tier Horsepower Load Factor
Average 2.00 8.00 367 0.40
Average 3.00 8.00 36.0 0.38
Average 1.00 8.00 33.0 0.73
Average 3.00 8.00 367 0.40
Average 4.00 8.00 84.0 0.37
Average 1.00 8.00 148 0.41
Average 2.00 8.00 36.0 0.38
Average 2.00 8.00 84.0 0.37
Average 2.00 8.00 423 0.48
Average 1.00 8.00 367 0.40
Average 4.00 7.90 82.0 0.20
Average 2.00 5.20 14.0 0.74
Average 2.00 4.60 367 0.29
Average 2.00 5.20 46.0 0.45
Average 4.00 6.90 84.0 0.37
Average 2.00 8.00 81 .0 0.42
Average 2.00 8.00 89.0 0.36
41 / 52
Item Title: 11.1
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Paving Rollers
Architectural Coating Air Compressors
Diesel
Diesel

5.3. Construction Vehicles

5.3.1. Unmitigated
Phase Name Trip Type
Demolition
Demolition Worker
Demolition Vendor
Demolition Hauling
Demolition Onsite truck
Site Preparation
Site Preparation Worker
Site Preparation Vendor
Site Preparation Hauling
Site Preparation Onsite truck
Grading
Grading Worker
Grading Vendor
Grading Hauling
Grading Onsite truck
Building Construction
Building Construction Worker
Building Construction Vendor
Building Construction Hauling
Building Construction Onsite truck
Paving
Average
Average

2.00 1.00
One-Way Trips per Day

15.0 -

1.75 -

17.5 -

0.00 -

20.0 -

6.94 -
142

55.4 0.00
-
42 / 52
Menifee (Pemcor) Business Park Detailed Report, 9/17/2025

8.00 6.00
Miles per Trip

18.5 10.2

25.4 -

18.5 10.2

25.4 -

18.5 10.2

25.4 -

18.5 10.2

25.4 -

36.0 37.0
Vehicle Mix

0.38 0.48
LDA,LDT1 ,LDT2

HHDT,MHDT
HHDT
HHDT
LDA,LDT1 ,LDT2

HHDT,MHDT
HHDT
HHDT
LDA,LDT1 ,LDT2

HHDT,MHDT
HHDT
HHDT
LDA,LDT1 ,LDT2

HHDT,MHDT
HHDT
HHDT
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February 4, 2026
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Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 Paving Worker 15.0 18.5 LDA,LDT1 ,LDT2
Paving Vendor - 10.2 HHDT,MHDT
Paving Hauling 0.00 25.4 HHDT
Paving Onsite truck - - HHDT
Architectural Coating
Architectural Coating Worker 28.4 18.5 LDA,LDT1 ,LDT2
Architectural Coating Vendor - 10.2 HHDT,MHDT
Architectural Coating Hauling 0.00 20.0 HHDT
Architectural Coating Onsite truck - - HHDT

5.3.2. Mitigated
Phase Name Trip Type One-Way Trips per Day Miles per Trip Vehicle Mix Demolition
Demolition Worker 15.0 18.5 LDA,LDT1 ,LDT2
Demolition Vendor - 10.2 HHDT,MHDT
Demolition Hauling 1.75 25.4 HHDT
Demolition Onsite truck - - HHDT
Site Preparation
Site Preparation Worker 17.5 18.5 LDA,LDT1 ,LDT2
Site Preparation Vendor - 10.2 HHDT,MHDT
Site Preparation Hauling 0.00 25.4 HHDT
Site Preparation Onsite truck - - HHDT
Grading
Grading Worker 20.0 18.5 LDA,LDT1 ,LDT2
Grading Vendor - 10.2 HHDT,MHDT
Grading Hauling 6.94 25.4 HHDT
Grading Onsite truck - - HHDT
Building Construction
43 / 52
Item Title: 11.1
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February 4, 2026
Page
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Building Construction Worker
Building Construction Vendor
Building Construction Hauling
Building Construction Onsite truck
Paving
Paving Worker
Paving Vendor
Paving Hauling
Paving Onsite truck
Architectural Coating
Architectural Coating Worker
Architectural Coating Vendor
Architectural Coating Hauling
Architectural Coating Onsite truck

5.4. Vehicles

5.4.1. Construction Vehicle Control Strategies
Non-applicable. No control strategies activated by user.

5.5. Architectural Coatings
Phase Name
Architectural Coating

5.6. Dust Mitigation
Residential Interior Area
Coated (sq ft)

0.00 5.6.1. Construction Earthmoving Activities
142

55.4 0.00
-

15.0 -

0.00 -

28.4 -

0.00 -
Residential Exterior Area
Coated (sq ft)

0.00 Menifee (Pemcor) Business Park Detailed Report, 9/17/2025

18.5 10.2

25.4 -

18.5 10.2

25.4 -

18.5 10.2

20.0 -
Non-Residential Interior Area
Coated (sq ft)
506,655
44/ 52
LDA,LDT1 ,LDT2

HHDT,MHDT
HHDT
HHDT
LDA,LDT1 ,LDT2

HHDT,MHDT
HHDT
HHDT
LDA,LDT1 ,LDT2

HHDT,MHDT
HHDT
HHDT
Non-Residential Exterior Area
Coated (sq ft)
Parking Area Coated (sq ft)
168,885 31,363
Item Title: 11.1
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Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 Phase Name Material Imported (cy) Material Exported (cy) Acres Graded (acres) Material Demolished (Building Square Footage)
Acres Paved (acres)
Demolition
Site Preparation
Grading
Paving

0.00 0.00

0.00 2,000

0.00 5.6.2. Construction Earthmoving Control Strategies Non-applicable. No control strategies activated by user,

5. 7. Construction Paving
Land Use
Industrial Park
Parking Lot
Area Paved (acres)

0.00 12.0

0.00 15.0
105

0.00 5.8. Construction Electricity Consumption and Emissions Factors kWh per Year and Emission Factor (lb/MWh)
Year
2026
2025

5.18. Vegetation

5.18.1. Land Use Change

5.18.1.1. Unmitigated
Vegetation Land Use Type
kWh per Year

0.00 0.00
532
532
Vegetation Soil Type Initial Acres
45 / 52

0.03 0.03
3,000

0.00 0.00

0.00 % Asphalt
0%
100%

12.0 < 0.005
< 0.005
Final Acres
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5.18.1.2. Mitigated
Vegetation Land Use Type

5.18.1. Biomass Cover Type

5.18.1.1. Unmitigated
Biomass Cover Type

5.18.1 .2. Mitigated
Biomass Cover Type

5.18.2. Sequestration

5.18.2.1. Unmitigated
Tree Type

5.18.2.2. Mitigated
Tree Type
Number
Number

6. Climate Risk Detailed Report

6.1. Climate Risk Summary
Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 Final Acres
Initial Acres Final Acres
Initial Acres Final Acres
Electricity Saved (kWh/year) Natural Gas Saved (btu/year) Electricity Saved (kWh/year) Natural Gas Saved (btu/year) Cal-Adapt midcentury 2040-2059 average projections for four hazards are reported below for your project location. These are under Representation Concentration Pathway (RCP) 8.5 which assumes GHG emissions will continue to rise strongly through 2050 and then plateau around 2100.

Climate Hazard
Temperature and Extreme Heat
Extreme Precipitation
Result for Project Location

27.6 2.85
Unit
annual days of extreme heat
annual days with precipitation above 20 mm
46 / 52
Item Title: 11.1
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February 4, 2026
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Sea Level Rise
Wildfire 8.86
Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 meters of inundation depth
annual hectares burned
Temperature and Extreme Heat data are for grid cell in which your project are located. The projection is based on the 98th historical percentile of daily maximum/minimum temperatures from observed historical data (32 climate model ensemble from Cal-Adapt, 2040-2059 average under RCP 8.5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.

Extreme Precipitation data are for the grid cell in which your project are located . The threshold of 20 mm is equivalent to about¾ an inch of rain, which would be light to moderate rainfall if received over a full day or heavy rain if received over a period of 2 to 4 hours. Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.

Sea Level Rise data are for the grid cell in which your project are located. The projections are from Radke et al. (2017), as reported in Cal-Adapt (Radke et al., 2017, CEC-500-2017-008), and consider inundation location and depth for the San Francisco Bay, the Sacramento-San Joaquin River Delta and California coast resulting different increments of sea level rise coupled with extreme storm events. Users may select from four scenarios to view the range in potential inundation depth for the grid cell. The four scenarios are: No rise, 0.5 meter, 1.0 meter, 1.41 meters Wildfire data are for the grid cell in which your project are located. The projections are from UC Davis, as reported in Cal-Adapt (2040-2059 average under RCP 8.5), and consider historical data of climate, vegetation, population density, and large(> 400 ha) fire history. Users may select from four model simulations to view the range in potential wildfire probabilities for the grid cell. The four simulations make different assumptions about expected rainfall and temperature are: Warmer/drier (HadGEM2-ES), Cooler/wetter (CNRM-CM5), Average conditions (CanESM2), Range of different rainfall and temperature possibilities (MIROC5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.

6.2. Initial Climate Risk Scores
Climate Hazard Exposure Score Sensitivity Score
Temperature and Extreme Heat 3 0 0 N/A
Extreme Precipitation NIA NIA NIA NIA
Sea Level Rise 1 0 0 N/A
Wildfire 1 0 0 NIA
Flooding NIA N/A NIA N/A
Drought NIA NIA NIA N/A
Snowpack Reduction N/A NIA N/A N/A
Air Quality Degradation 0 0 0 N/A
The sensitivity score reflects the extent to which a project would be adversely affected by exposure to a climate hazard. Exposure is rated on a scale of 1 to 5, with a score of 5 representing the greatest exposure.

The adaptive capacity of a project refers to its ability to manage and reduce vulnerabilities from projected climate hazards. Adaptive capacity is rated on a scale of 1 to 5, with a score of 5 representing the greatest ability to adapt.

The overall vulnerability scores are calculated based on the potential impacts and adaptive capacity assessments for each hazard. Scores do not include implementation of climate risk reduction measures.

6.3. Adjusted Climate Risk Scores
Climate Hazard Exposure Score Sensitivity Score Adaptive Capacity Score Vulnerability Score Temperature and Extreme Heat 3 3
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Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 Extreme Precipitation N/A N/A N/A N/A
Sea Level Rise 1 1 1 2
Wildfire 1 1 1 2
Flooding N/A N/A N/A N/A
Drought N/A N/A N/A N/A
Snowpack Reduction N/A N/A N/A N/A
Air Quality Degradation 1 1 1 2
The sensitivity score reflects the extent to which a project would be adversely affected by exposure to a climate hazard. Exposure is rated on a scale of 1 to 5, with a score of 5 representing the greatest exposure.

The adaptive capacity of a project refers to its ability to manage and reduce vulnerabilities from projected climate hazards. Adaptive capacity is rated on a scale of 1 to 5, with a score of 5 representing the greatest ability to adapt.

The overall vulnerability scores are calculated based on the potential impacts and adaptive capacity assessments for each hazard. Scores include implementation of climate risk reduction measures.

6.4. Climate Risk Reduction Measures

7. Health and Equity Details

7.1. CalEnviroScreen 4.0 Scores
The maximum CalEnviroScreen score is 100. A high score (i.e., greater than 50) reflects a higher pollution burden compared to other census tracts in the state. ----------- - - -
Indicator Result for Project Census Tract
Exposure Indicators
AQ-Ozone 80.0
AQ-PM 45.6
AQ-DPM 37.6
Drinking Water 71.7
Lead Risk Housing 21.2
Pesticides 53.0
Toxic Releases 14.5
Traffic 78.4
Effect Indicators
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Cleanup Sites
Groundwater
Haz Waste Facilities/Generators
Impaired Water Bodies
Solid Waste
Sensitive Population
Asthma
Cardio-vascular
Low Birth Weights
Socioeconomic Factor Indicators
Education
Housing
Linguistic
Poverty
Unemployment
7 .2. Healthy Places Index Scores

0.00 0.00

50.1 0.00

35.7 42.6

93.2 14.2

40.1 23.4

1.81 34.0

59.4 Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 The maximum Health Places Index score is 100. A high score (i.e., greater than 50) reflects healt,hier community conditions compared to other census tracts in the state. - ···----- - -
Indicator Result for Project Census Tract
Economic
Above Poverty 54.26664956
Employed 19.64583601
Median HI 50.78916977
Education
Bachelor's or higher 38. 739894 78
High school enrollment 100
Preschool enrollment 43.68022584
Transportation
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Auto Access
Active commuting
Social
2-parent households
Voting
Neighborhood
Alcohol availability
Park access
Retail density
Supermarket access
Tree canopy
Housing
Homeownership
Housing habitability
Low-inc homeowner severe housing cost burden
Low-inc renter severe housing cost burden
Uncrowded housing
Health Outcomes
Insured adults
Arthritis
Asthma ER Admissions
High Blood Pressure
Cancer (excluding skin)
Asthma
Coronary Heart Disease
Chronic Obstructive Pulmonary Disease
Diagnosed Diabetes
Life Expectancy at Birth

76.73553189

4.49121006

67.88143205

54.67727448

92. 14679841

14.78249711

8.161170281

11.13820095

6.146541768

90.85076351

68.00975234

23.40562043

33.82522777

75.52932119

75.63197742

11.1 66.8

20.6 18.5

37.3 13.8

17.9 51 .3

48.3 50 / 52
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Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 Cognitively Disabled 76.7
Physically Disabled 21.7
Heart Attack ER Admissions 8.3
Mental Health Not Good 43.4
Chronic Kidney Disease 45.1
Obesity 32.0
Pedestrian Injuries 48.4
Physical Health Not Good 40.7
Stroke 29.9
Health Risk Behaviors
Binge Drinking 26.9
Current Smoker 33.5
No Leisure Time for Physical Activity 49.0
Climate Change Exposures
Wildfire Risk 91.5
SLR Inundation Area 0.0
Children 64.0
Elderly 37.4
English Speaking 92.0
Foreign-born 6.3
Outdoor Workers 15.9
Climate Change Adaptive Capacity
Impervious Surface Cover 90.5
Traffic Density 71.2
Traffic Access 23.0
Other Indices
Hardship 47.6
Other Decision Support
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Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 2016 Voting 58.6
7 .3. Overall Health & Equity Scores
Metric Result for Project Census Tract
CalEnviroScreen 4.0 Score for Project Location (a) 38.0 Healthy Places Index Score for Project Location (b) 46.0 Project Located in a Designated Disadvantaged Community (Senate Bill 535) No Project Located in a Low-Income Community (Assembly Bill 1550) No Project Located in a Community Air Protection Program Community (Assembly Bill 617) No a: The maximum CalEnviroScreen score is 100. A high score (i.e., greater than 50) reflects a higher pollution burden compared to other census tracts in the state. b: The maximum Health Places Index score is 100. A high score (i.e., greater than 50) reflects healthier community conditions compared to other census tracts in the state. 7 .4. Health & Equity Measures
No Health & Equity Measures selected.
7 .5. Evaluation Scorecard
Health & Equity Evaluation Scorecard not completed.
7 .6. Health & Equity Custom Measures
No Health & Equity Custom Measures created.

8. User Changes to Default Data
Screen
Land Use
Construction: Construction Phases
Construction: Off-Road Equipment
Construction: Dust From Material Movement
Construction: Trips and VMT
Justification
Consistent with DEIR.

Consistent with DEIR.

Consistent with DEIR.

Consistent with DEIR.

See comment on: "Incorrect Construction Hauling Trip Length". 52 / 52
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I SWAP E I
Technical Consultation, Data Analysis and
Litigation Support for the Environment .._ _____ _.

Matthew F. Hagemann, P.G., C.Hg.

Attachment B
2656 29th Street, Suite 201
Santa Monica, CA 90405
(949) 887-9013
[email protected]
• Geologic and Hydrogeologic Characterization, Investigation and Remediation Strategies • Industrial Stormwater Compliance
• CEQAReview
• Expert Testimony
Professional Certifications:

California Professional Geologist, P.G.

California Certified Hydrogeologist, C.Hg.

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

Positions held include:

Government:

Senior Science Policy Advisor and Hydrogeologist, U.S. Environmental Protection Agency (1989-1998); 1 Item Title: 11.1
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Hydrogeologist, National Park Service, Water Resources Division (1998 - 2000); Geologist, U.S. Forest Service (1986-1998).

Educational:

Geology Instructor, Golden West College, 2010 - 2104, 2017; Adjunct Faculty Member, San Francisco State University, Department of Geosciences (1993 -1998); Instructor, College of Marin, Department of Science (1990 - 1995).

Private Sector:

Founding Partner, Soil/Water/Air Protection Enterprise (SWAPE) (2003 - present); Senior Environmental Analyst, Komex H2O Science, Inc. (2000 --2003); Executive Director, Orange Coast Watch (2001- 2004);
Geologist, Dames & Moore (1984 -1986).

Senior Regulatozy and Litigation Support Analyst:

With SW APE, responsibilities have included:
• Lead analyst and testifying expert, for both plaintiffs and defendants, 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 .
• Recommending 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 exposure to hazards from toxins.
• Stormwater analysis, sampling and best management practice evaluation, for both government agencies and corporate clients, at more than 150 industrial facilities . • Serving as expert witness for both plaintiffs and defendants in cases including contamination of groundwater, CERCLAcompliance in assessment and remediation, and industrial stormwater contamination.
• Technical assistance and litigation support for vapor intrusion concerns, for both government agencies and corporate clients.
• Lead analyst and testifying expert in the review of environmental issues in license applicationsfor 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 H2O Science Inc., 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 2 Item Title: 11.1
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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.
• Lead author for a multi-volume remedial investigation report for an operating school in LosAngeles that met strict Sate of California regulatory requirements. • Development of strategic approaches for cleanup of contaminated sites in consultation withclients and regulators.

Hydrogeology:

As a Senior Hydrogeologist with the U.S. Environmental Protection Agency, 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 included:
• Leading efforts to model groundwater flow and contaminant transport, ensured adequacy of monitoring networks, and assessed cleanup alternatives for contaminated sediment, soil, and groundwater.
• Initiating a regional program for evaluation of groundwater sampling practices and laboratory analysis at military bases.
• Identifying 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, developed a methodology to determine the vulnerability of groundwater to contamination on the islands of Maui and Oahu. 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, 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 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. Prepared geologic reports, conducted hearings, and responded to public comments from residents who were very concerned about the impact of designation.
• Reviewed a number of Environmental Impact Statements for planned major developments, including large hazardous and solid waste disposal facilities, mine reclamation, and water transfer.

Served as a hydrogeologist with the RCRA Hazardous Waste program. Duties included:
• Supervised the hydrogeologic investigation of hazardous waste sites to determine compliancewith Subtitle C requirements.
• Re.viewed 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.
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• Wrote contract specifications and supervised contractor's investigations of waste sites.

With the National Park Service, directed service-wide investigations of contaminant sources to prevent degradation of water quality, including the following:

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

Served as senior management as the Senior Science Policy Advisor with the U.S. Environmental Protection Agency, Region 9. Activities included the following:
• Advising the Regional Administrator and senior management on emerging issues such as the potential for the gasoline additive MfBE and ammonium perchlorate to contaminate drinkingwater supplies.
• Shaping EPA' s national response to these threats by serving on workgroups and by contributingto guidance, including the Office of Research and Development publication, Oxygenates in Water :

Critical Information and Research Needs.
• Improving the technical training of EPA's scientific and engineering staff. • Earning an EPA Bronze Medal for representing the region's 300 scientists and engineers in negotiations with the Administrator and senior management to better integrate scientific principles into the policy-making process.
• Establishing national protocol for the peer review of scientific documents.

Geology :

With the U.S. Forest Service, led investigations to determine hillslope stability of areas proposed for timber harvest in the central Oregon Coast Range. Specific activities included:
• Mapping geology in the field, and used aerial photographic interpretation and mathematical models to determine slope stability.
• Coordinating research with community stakeholders who were concerned with natural resource protection .
• Characterizing the geology of an aquifer that serves as the sole source of drinking water for thecity of Medford, Oregon .
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As a consultant with Dames and Moore, led geologic investigations of two contaminated sites (later listed on the Superfund NPL) in the Portland, Oregon, area and a large RCRA hazardous waste site in eastern Oregon.

Duties included the following:
• Supervising year-long effort for soil and groundwater sampling. • Conducting aquifer tests.
• Investigating active faults beneath sites proposed for hazardous waste disposal.

Teaching:

From 1990 to 1998, 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. • Part time geology instructor at Golden West College in Huntington Beach, California from2010 to 2014 and in 2017.

Summary of Testimony Ex.verience Over Past Four Years
In Re New Jersey Department of Environmental Protection et al. vs. E.I. DuPont de Nemours and Company, in the United States District Court, District of New Jersey, Civil Action No. 1:19-cv-14766-RMB-JBC. Deposition in 2025.

Representing Plaintiffs in matters regarding contamination of groundwater, wastewater, soil, and air with per- and poly­ jluoroalkyl substances.

In Re Edmond Asher, et al., vs. RTX Corporation (flk/a Raytheon Technologies Corporation, et al.) in the County of Huntington Superior Court, Indiana, Cause number 35D01-2006-CT-000338. Deposition in 2024. Representing Plaintiffs in matters regarding contamination of groundwater and soil vapor with trichlorethylene.

In Re Wright vs Consolidated Rail Corporation In the Circuit Court of Cook County, Illinois, Case No: 21L3966.

Deposition in 2023, Representing Plaintiff in matters involving groundwater and drinking water contamination of perchloroethylene, trichlorethylene, 1,2-dichloroethane, and carbon tetrachloride.

In Re Behr Dayton Thermal Products LLC In the United States District Court for the Southern District of Ohio Western Division at Dayton, Case No: 08-cv-326. Deposition in 2022. Representing Plaintiff in matters regarding contamination of groundwater and indoor air with perchloroethylene and trichloethelene.

Orange County Water District vs. Sabic Innovative Plastics US, LLC, et al. In the Court of Appeal, Fourth District, 5 Item Title: 11.1
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Division 1, California, Case No: D070553. Deposition in 2020. Representing Plaintiff in matters involving compliance with The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA).

Los Angeles Waterkeeper vs. AAA Plating and Inspection, Inc. In the United States District Court for the Central District of California, Case No: No. CV 18-5916 PA (GJSx). Deposition in 2019. Expert witness representing Plaintiff in matters involving contaminated stormwater runoff at an industrial facility in Compton, California.

Californians for Alternatives to Toxics vs. Schneider Dock and Intermodal Facility. In the United States District Court for the Northern District of California, Case No: 3:17-cv-05287-JST. Deposition in 2019. Expert witness representing Plaintiff in matters involving contaminated stormwater runoff at an industrial facility in Eureka, California.

Bells et al. vs. The 3M Company et al. In the United States District Court for the District of Colorado, Case No: 1:16-CV- 02531-RBJ. Deposition in 2018. Expert witness representing Plaintiff on matters regarding the general hydrogeological conditions present in an area impacted by per- and poly-fluoroalkyl substances.

Ungar vs. Foundation for Affordable Housing. In the Superior Court, State of California, Los Angeles County, Case No.

BC628890 Deposition in 2017. Expert witness representing defendant on matters involving alleged drinking water contamination.

Invited Testimony, Reports, Papers and Presentations:

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

Hagemann, M.F., 2008. Disclosure of Hazardous Waste Issues under CEQA. Invited presentation to U.S.EPA Region 9, San Francisco, California.

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

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

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

Brown, A., Farrow, J., Gray, A. and Hagemann, M., 2004. An Estimate of Costs to Address MTBEReleases from Underground Storage Tanks and the Resulting Impact to Drinking Water Wells. 6 Item Title: 11.1
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Presentation to the Ground Water and Environmental Law Conference, National GroundwaterAssociation.

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

Hagemann, M.F., 2003. Perchlorate Contamination of the Colorado River and Impacts to Drinking Waterin 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 atribal EPA meeting, Pechanga, CA.

Hagemann, M.F., 2003. Perchlorate Contamination of the Colorado River. Invited presentation to ameeting of tribal representatives, Parker, AZ.

Hagemann, M.F., 2003. Impact of Perchlorate on the Colorado River and Associated Drinking WaterSupplies.

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 ofthe National Groundwater Association.

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

Hagemann, M.F., 2002. A Chronology of MTBE in Groundwater and an Estimate of Costs to Addresslmpacts 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 andState Underground Storage Tank Program managers.

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

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 StorageTanks. 7 Item Title: 11.1
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Unpublished report.

Hagemann, M.F., and VanMouwerik, M., 1999. Potential Water 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 WatercraftUsage.

Water Resources Division, National Park Service, Technical Report.

Hagemann, M.F., 1999, Is Dilution the Solution to Pollution in National Parks? The George WrightSociety 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 AirStation, Conference on Intrinsic Remediation of Otlorinated Hydrocarbons, Salt Lake City.

Hagemann, M.F., Fukunaga, G.L., 1996, The VuJnerability 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, Airand Waste Management Association Publication VIP-61.

Hagemann, M.F., 1994. Groundwater Gt ar ac te r i z a ti on and Clean up at Closing Military Basesin California. Proceedings, California Groundwater Resources Association Meeting.

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

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

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 Item Title: 11.1
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Technical Consultation, Data Analysis and
Litigation Support for the Environment
Paul Rosenfeld, Ph.D.

Principal Environmental Chemist
Education
Attachment C

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

Mobil: (310) 795-2335
Office: (310) 452-5555
Fax: (310) 452-5550
Email: µro~enfeld@.~wape.com
Chemical Fate and Transport & Air Dispersion Modeling
Risk Assessment & Remediation Specialist
Ph.D. Soil Chemistry, University of Washington, 1999. Dissertation on volatile organic compound filtration.

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

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

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

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

Dr. Rosenfeld has investigated and designed remediation programs and risk assessments for contaminated sites containing lead, heavy metals, mold, bacteria, particulate matter, petroleum hydrocarbons, chlorinated solvents, pesticides, radioactive waste, dioxins and furans, semi- and volatile organic compounds, PCBs, P AHs, creosote, perchlorate, asbestos, per- and poly-fluoroalkyl substances (PFOA/PFOS), unusual polymers, fuel oxygenates (MTBE), among other pollutants. Dr. Rosenfeld also has experience evaluating greenhouse gas emissions from various projects and is an expert on the assessment of odors from industrial and agricultural sites, as well as the evaluation of odor nuisance impacts and technologies for abatement of odorous emissions. As a principal scientist at SW APE, 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.

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Professional History:

Soil Water Air Protection Enterprise (SW APE); 2003 to present; Principal and Founding Partner UCLA School of Public Health; 2007 to 2011; Lecturer (Assistant Researcher) UCLA School of Public Health; 2003 to 2006; Adjunct Professor UCLA Environmental Science and Engineering Program; 2002-2004; Doctoral Intern Coordinator UCLA Institute of the Environment, 2001-2002; Research Associate Komex H2O Science, 2001 to 2003; Senior Remediation Scientist National Groundwater Association, 2002-2004; Lecturer
San Diego State University, 1999-2001; Adjunct Professor Anteon Corp., San Diego, 2000-2001; Remediation Project Manager Ogden (now Amee), 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.R., McCarthy, S.J. et al. Camp Lejeune Marine Cancer Risk Assessment for Exposure to Contaminated Drinking Water From 1955 to 1987. Water Air Soil Pollut 235, 124 (2024). https://doi.org/10.1007 /sl 1270-023-06863-y.

Rosenfeld P.E., Spaeth K.R., Remy L.L., Byers V., Muerth S.A., Hallman R,C., Summers-Evans J., Barker S. (2023) Perfluoroalkyl substances exposure in firefighters: Sources and implications, Environmental Research, Volume 220, https://doi.org/10.1016/j.envres.2022.115164.

Rosenfeld P.E. and Spaeth K.R., (2023) Authors' Response to Letter to the Editor from Bullock and Ramacciotti, Water Air Soil Pollution Volume 234, https://doi.org/10.1007/sl 1270-023-06165-3 Rosenfeld P. E., Spaeth K., Hallman R., Bressler R., Smith, G., (2022) Cancer Risk and Diesel Exhaust Exposure Among Railroad Workers. Water Air Soil Pollution. 233, 171.

Remy, L.L., Clay T., Byers, V., Rosenfeld P. E. (2019) Hospital, Health, and Community Burden After Oil Refinery Fires, Richmond, California 2007 and 2012. Environmental Health. 18 :48 Simons, R.A., Seo, Y. Rosenfeld, P., (2015) Modeling the Effect of Refinery Emission On Residential Property Value. Journal of Real Estate Research. 27(3):321-342
Chen, J. A, Zapata A. R., Sutherland A. J., Molmen, D.R., Chow, B. S., Wu, L. E., Rosenfeld, P. E., Hesse, R. C., (2012) Sulfur Dioxide and Volatile Organic Compound Exposure To A Community In Texas City Texas Evaluated Using Aermod and Empirical Data. American Journal of Environmental Science, 8( 6), 622-632.

Rosenfeld, P.E. & Feng, L. (2011 ). The Risks of Hazardous Waste. Amsterdam: Elsevier Publishing.

Cheremisinoff, N.P., & Rosenfeld, P.E. (2011). Handbook of Pollution Prevention and Cleaner Production : Best Practices in the Agrochemical Industry, Amsterdam: Elsevier Publishing.

Gonzalez, J., Feng, L., Sutherland, A., Waller, C., Sok, H., Hesse, R., Rosenfeld, P. (2010). PCBs and Dioxins/Furans in Attic Dust Collected Near Former PCB Production and Secondary Copper Facilities in Sauget, IL.

Procedia Environmental Sciences. 113-125.

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Feng, L., Wu, C., Tam, L., Sutherland, A.J., Clark, J.J., Rosenfeld, P.E. (2010). Dioxin and Furan Blood Lipid and Attic Dust Concentrations in Populations Living Near Four Wood Treatment Facilities in the United States. Journal of Environmental Health. 73(6), 34-46.

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

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

Wu, C., Tam, L., Clark, J., Rosenfeld, P. (2009). Dioxin and furan blood lipid concentrations in populations living near four wood treatment facilities in the United States. WIT Transactions on Ecology and the Environment, Air Pollution, 123 (17), 319-327.

Cheremisinoff, N.P., Rosenfeld, P.E. Davletshin, A.R. (2008). Responsible Care. Gulf Publishing. Texas.

Tam L. K., Wu C. D., Clark J. J. and Rosenfeld, P.E. (2008). A Statistical Analysis Of Attic Dust And Blood Lipid Concentrations Of Tetrachloro-p-Dibenzodioxin (TCDD) Toxicity Equivalency Quotients (TEQ) In Two Populations Near Wood Treatment Facilities. Organohalogen Compounds, 70, 002252-002255.

Tam L. K., Wu C. D., Clark J. J. and Rosenfeld, P.E. (2008). Methods For Collect Samples For Assessing Dioxins And Other Environmental Contaminants In Attic Dust: A Review. Organohalogen Compounds, 70, 000527- 000530.

Hensley, A.R. A. Scott, J. J. J. Clark, Rosenfeld, P.E. (2007). Attic Dust and Human Blood Samples Collected near a Former Wood Treatment Facility. Environmental Research. 105, 194-197.

Rosenfeld, P.E., J. J. J. Clark, A. R. Hensley, M. Suffet. (2007). The Use of an Odor Wheel Classification for Evaluation of Human Health Risk Criteria for Compost Facilities. Water Science & Technology 55(5), 345-357.

Rosenfeld, P. E., M. Suffet. (2007). The Anatomy of Odour Wheels for Odours of Drinking Water, Wastewater, Compost And The Urban Environment. Water Science & Technology 55(5), 335-344.

Sullivan, P. J. Clark, J.J.J., Agardy, F. J., Rosenfeld, P.E. (2007). Toxic Legacy, Synthetic Toxins in the Food, Water, and Air in American Cities. Boston Massachusetts: Elsevier Publishing Rosenfeld, P.E., and Suffet I.H. (2004). Control of Compost Odor Using High Carbon Wood Ash. Water Science and Technology. 49(9),171-178.

Rosenfeld P. E., J.J. Clark, 1.H. (Mel) Suffet (2004). The Value of An Odor-Quality-Wheel Classification Scheme for The Urban Environment. Water Environment Federation's Technical Exhibition and Conference (WEFTEC) 2004. New Orleans, October 2-6, 2004.

Rosenfeld, P.E., and Suffet, I.H. (2004). Understanding Odorants Associated with Compost, Biomass Facilities, and the Land Application ofBiosolids. Water Science and Technology. 49(9), 193-199.

Rosenfeld, P.E., and Suffet I.H. (2004). Control of Compost Odor Using High Carbon Wood Ash, Water Science and Technology, 49(9), 171-178.

Rosenfeld, P. E., Grey, M. A., Sellew, P. (2004). Measurement of Biosolids Odor and Odorant Emissions from Windrows, Static Pile and Biofilter. Water Environment Research. 76(4),. 310-315.

Rosenfeld, P.E., Grey, M and Suffet, M. (2002). Compost Demonstration Project, Sacramento California Using High-Carbon Wood Ash to Control Odor at a Green Materials Composting Facility. Integrated Waste Management Board Public Affairs Office, Publications Clearinghouse (MS-6), Sacramento, CA Publication #442-02-008.

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Rosenfeld, P.E., and C.L. Henry. (2001). Characterization of odor emissions from three different biosolids. Water Soil and Air Pollution. 127(1-4), 173-191.

Rosenfeld, P.E., and Henry C. L., (2000). Wood ash control of odor emissions from biosolids application. Journal of Environmental Quality. 29, 1662-1668.

Rosenfeld, P.E., C.L. Henry and D. Bennett. (2001). Wastewater dewatering polymer affects on biosolids odor emissions and microbial activity. Water Environment Research. 73(4), 363-367.

Rosenfeld, P.E., and C.L. Henry. (2001). Activated Carbon and Wood Ash Sorption of Wastewater, Compost, and Biosolids Odorants. Water Environment Research, 73, 388-393.

Rosenfeld, P.E., and Henry C. L., (2001). High carbon wood ash effect on biosolids microbial activity and odor.

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

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

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

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

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

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

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

Presentations:

Rosenfeld, P.E., "The science for Perfluorinated Chemicals (PFAS): What makes remediation so hard?" Law Seminars International, (May 9-10, 2018) 800 Fifth Avenue, Suite 101 Seattle, WA.

Rosenfeld, P.E., Sutherland, A; Hesse, R.; Zapata, A. (October 3-6, 2013). Air dispersion modeling of volatile organic emissions from multiple natural gas wells in Decatur, TX. 44th Western Regional Meeting, American Chemical Society. Lecture conducted from Santa Clara, CA.

Sok, H.L.; Waller, C.C.; Feng, L.; Gonzalez, J.; Sutherland, A.J.; Wisdom-Stack, T.; Sahai, R.K.; Hesse, R.C.; Rosenfeld, P.E. (June 20-23, 2010). Atrazine: A Persistent Pesticide in Urban Drinking Water.

Urban Environmental Pollution. Lecture conducted from Boston, MA.

Feng, L.; Gonzalez, J.; Sok, H.L.; Sutherland, A.J.; Waller, C.C.; Wisdom-Stack, T.; Sahai, R.K.; La, M.; Hesse, R.C.; Rosenfeld, P.E. (June 20-23, 2010). Bringing Environmental Justice to East St. Louis, Illinois. Urban Environmental Pollution. Lecture conducted from Boston, MA.

Rosenfeld, P.E. (April 19-23, 2009). Perfluoroctanoic Acid (PFOA) and Perfluoroactane Sulfonate (PFOS) Contamination in Drinking Water From the Use of Aqueous Film Forming Foams (AFFF) at Airports in the United States. 2009 Ground Water Summit and 2009 Ground Water Protection Council Spring Meeting, Lecture conducted from Tuscon, AZ.

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Rosenfeld, P.E. (April 19-23, 2009). Cost to Filter Atrazine Contamination from Drinking Water in the United States" Contamination in Drinking Water From the Use of Aqueous Film Forming Foams (AFFF) at Airports in the United States. 2009 Ground Water Summit and 2009 Ground Water Protection Council Spring Meeting. Lecture conducted from Tuscon, AZ.

Wu, C., Tam, L., Clark, J., Rosenfeld, P. (20-22 July (2009). Dioxin and furan blood lipid concentrations in populations living near four wood treatment facilities in the United States. Brebbia, C.A. and Popov, V., eds., Air Pollution XVII: Proceedings of the Seventeenth International Conference on Modeling, Monitoring and Management of Air Pollution. Lecture conducted from Tallinn, Estonia.

Rosenfeld, P. E. (October 15-18, 2007). Moss Point Community Exposure To Contaminants From A Releasing Facility. The 23rd Annual International Co,iferences on Soils Sediment and Water. Platform lecture conducted at University of Massachusetts, Amherst MA.

Rosenfeld, P. E. (October 15-18, 2007). The Repeated Trespass of Tritium-Contaminated Water Into A Surrounding Community Form Repeated Waste Spills From A Nuclear Power Plant The 23rd Annual International Co,iferences on Soils Sediment and Water. Platform lecture conducted from University of Massachusetts, Amherst MA.

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

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

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

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

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

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

Mealey's C8/PFOA. Science, Risk & Litigation Co,iference. Lecture conducted from The Rittenhouse Hotel, Philadelphia, PA.

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

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

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

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

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

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

Lecture conducted from Wyndham Baltimore Inner Harbor, Baltimore Maryland.

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

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

Paul Rosenfeld, Ph.D. (March 2004). Perchlorate Toxicology. Meeting of the American Groundwater Trust.

Lecture conducted from Phoenix Arizona.

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

Meeting of tribal representatives. Lecture conducted from Parker, AZ.

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

Dryc/eaner Symposium. California Ground Water Association. Lecture conducted from Radison Hotel, Sacramento, California.

Rosenfeld, P. E., Grey, M., (June 2003) Two stage biofilter for biosolids composting odor control. Seventh International In Situ And On Site Bioremediation Symposium Batte/le Conference Orlando, FL.

Paul Rosenfeld, Ph.D. and James Clark Ph.D. (February 20-21, 2003) Understanding Historical Use, Chemical Properties, Toxicity and Regulatory Guidance of 1,4 Dioxane. National Groundwater Association. Southwest Focus Conference. Water Supply and Emerging Contaminants. Lecture conducted from Hyatt Regency Phoenix Arizona.

Paul Rosenfeld, Ph.D. (February 6-7, 2003). Underground Storage Tank Litigation and Remediation. California CUPA Forum. Lecture conducted from Marriott Hotel, Anaheim California.

Paul Rosenfeld, Ph.D. (October 23, 2002) Underground Storage Tank Litigation and Remediation. EPA Underground Storage Tank Roundtab/e. Lecture conducted from Sacramento California.

Rosenfeld, P.E. and Suffet, M. (October 7- 10, 2002). Understanding Odor from Compost, Wastewater and Industrial Processes. Sixth Annual Symposium on Off Flavors in the Aquatic Environment. International Water Association. Lecture conducted from Barcelona Spain.

Rosenfeld, P.E. and Suffet, M. (October 7- 10, 2002). Using High Carbon Wood Ash to Control Compost Odor.

Sixth Annual Symposium on Off Flavors in the Aquatic Environment. International Water Association. Lecture conducted from Barcelona Spain.

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

Northwest Biosolids Management Association. Lecture conducted from Vancouver Washington.

Rosenfeld, P.E. and Grey, M.A. (November 11-14, 2002). Using High-Carbon Wood Ash to Control Odor at a Green Materials Composting Facility. Soil Science Society Annual Conference. Lecture conducted from Indianapolis, Maryland.

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

Rosenfeld. P.E. (October 16, 2000). Wood ash and biofilter control of compost odor. Biofest. Lecture conducted from Ocean Shores, California.

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Rosenfeld, P.E. (2000). Bioremediation Using Organic Soil Amendments. California Resource Recovery Association. Lecture conducted from Sacramento California.

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

Rosenfeld, P.E., and C.L. Henry. (1999). An evaluation of ash incorporation with biosolids for odor reduction. Soil Science Society of America. Lecture conducted from Salt Lake City Utah.

Rosenfeld, P.E., C.L. Henry, R. Harrison. (1998). Comparison of Microbial Activity and Odor Emissions from Three Different Biosolids Applied to Forest Soil. Brown and Caldwell. Lecture conducted from Seattle Washington.

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

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

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

Teaching Experience:

UCLA Department of Environmental Health (Summer 2003 through 20010) Taught Environmental Health Science 100 to students, including undergrad, medical doctors, public health professionals and nurses. The 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 tan.ks.

National Ground Water Association; Successful Remediation Technologies Course in Chicago Illinois. April 1, 2002. Focused on fate and transport of contaminants associated with Superfund and RCRA sites.

California Integrated Waste Management Board, April and May 200 l . Alternative Landfill Caps Seminar in San Diego, Ventura, and San Francisco. Focused on both prescriptive and innovative landfill cover design.

UCLA Department of Environmental Engineering, February 5, 2002. Seminar on Successful Remediation Technologies focusing on Groundwater Remediation.

University Of Washington, Soil Science Program, Teaching Assistant for several courses including Soil Chemistry, Organic Soil Amendments, and Soil Stability.

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

Academic Grants Awarded:

California Integrated Waste Management Board. $41,000 grant awarded to UCLA Institute of the Environment.

Goal: To investigate the effect of high carbon wood ash on volatile organic emissions from compost. 2001.

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Synagro Technologies, Corona California: $10,000 grant awarded to San Diego State University.

Goal: investigate the effect ofbiosolids for restoration and remediation of degraded coastal sage soils. 2000.

King County, Department of Research and Technology, Washington State. $100,000 grant awarded to University of Washington: Goal: To investigate odor emissions from biosolids application and the effect of polymers and ash on voe emissions. 1998.

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

James River Corporation, Oregon: $10,000 grant was awarded to investigate the success of genetically engineered Poplar trees with resistance to round-up. 1996.

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

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

In the District Court of Harris County Texas
Mt Davis Interest, Inc v Sesco Cement Co:rp
Cause No 2023-26512
Trial 6-6-2-25
In the United States Southern District of New York
Gallo vs Avon Products Inc., et al
Civil Action No.: 1 :23-cv-2023
Deposition 4-24-2025
In Vanderburgh Superior Court 5, County of Vanderburgh, Indiana Markello v CSX
Civil Action No 82D05-2011-CT-004962
Deposition 3-26-25
Iin the Circuit Court of Cook County Illinois
Jarosiewicz v Northeast Regional Railroad
Case No 2023 L 002290
Deposition 2-27-25
In the District Court 191st Judicial District Dallas County Acklin v Poly America International
Cause No DC-22-08610
Deposition 1-8-2025
United States District Court, Norther District of California Asustin Vs Monsanto
Case No 2:23-cv-272
Deposition 12-20-25
In Jefferson Circuit Court Division One, Louisville, Kentucky Stafford vs, CSX
Case No. 18-CI-001790
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Deposition: 8-27-24
In the Twenty-Second Judicial Circuit of St. Louis. State of Missouri Patricia Godfrey vs, Amtrak
Case No. 2122-CC-00525
Deposition: 7-17-24
In the Circuit Court of Jefferson County Alabama
Linda Early Vs. CSX
Case number CV-2021-00241
Deposition 6-24-24
In the Court of Common Please Lucas County, Ohio
Brenda Conkright vs. CSX
Case No. G-4801-CI-0202102664-000
Deposition: 6-4-24
In the Commonwealth of Kentucky, Greenup Circuit Court
Patsy Sue Napier vs. CSX
Case No. 19-CI-0012
Deposition: 5-8-2-24
In United States District Court of Hawaii
Patrick Feindt, Jr. et al. vs. The United States of America Case No. 1:22-cv-LEK-KJM
Trial 3-29-24 and 4-5-24
In the District Court of Hood County State of Texas
Artie Gray vs. Exxon Mobil
Case No. C-2018047
Rosenfeld Deposition:4-22-2024
In the Elkhart Superior Court State of Indiana
Estate of Clark Stacy vs. Penn Central Corporation
Cause No 2D01-2001-CT-00007
Rosenfeld Deposition 1-25-2024 and 3-7-2024
In the Circuit Court of Trempealeau County, State of Wisconsin Michael J. Sylla et al. vs. High-Crush Whitehall LLC
Case No. 2019-CV-63, 2019-CV-64, 2019-CV-65, 2019-CV-66 Rosenfeld Deposition: 3-5-2024
In the Circuit Court of Trempealeau County, State of Wisconsin Leland Drangstveit vs. High-Crush Blair LLC
Case No. 19-CV-66
Rosenfeld Deposition 3-5-2024
In the Circuit Court of Jefferson County Alabama
Donald Lee Ashworth vs. CSX Transportation Inc.

Case No CV-2021-901261
Rosenfeld Depo_sition 1-23-2024
In the United States District Court for the Eastern District of Wisconsin Gary L Siepe vs. Soo Line Railroad
Case No. 2:21-cv-00919
Rosenfeld Deposition 1-19-2024
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In the United States District Court for the Western District of Louisiana Ricky Bush v. Clean Harbors Colfax LLC
Case No. 1 :22-cv-02026-DDD-JPM
Rosenfeld Deposition 12-18-2023 and 1-15-2024
In United States District Court of Hawaii
Patrick Feindt, Jr. et al. vs. The United States of America Case No. 1:22-cv-LEK-KJM
Rosenfeld Deposition 11-29-2023
In the Circuit Court for the Twentieth Judicial Circuit St. Clair County, Illinois Timothy Gray vs. Rural King et al.

Case No 2022-LA-355
Rosenfeld Deposition 9-26-2023
In United States District Court Eastern District of Wisconsin Gary L. Siepe vs. Soo Line Railroad Company
Case No. 2:21-cv-00919
Rosenfeld Deposition 9-15-2023
In the Circuit Court of Cook County Illinois
Donald Fox vs. BNSF
Case No. 2021 L12
Rosenfeld Deposition 9-12-2023
In the Court of Common Please Cuyahoga County, Ohio
Thomas Schleich vs. Penn Central Corporation
Lead Case No. CV-20-939184
Rosenfeld Deposition 8-27-2023
In the Circuit Court of Jackson County Missouri at Kansas City Timothy Dalsing vs. BNSF
Case No. No. 2216-cv06539
Rosenfeld Deposition 7-28-2023
In the United States District Court for the Southern District of Texas Houston Division International Terminals Company LLC Deer Park Fire Litigation Lead Case No. 4:19-cv-01460
Rosenfeld Deposition 7-25-2023
In the Circuit Court of Livingston County Missouri
Shirley Ralls vs. Canadian Pacific Railway and Soo Lind Railroad Case No. 28L V-CV0020
Rosenfeld Daubert Hearing 7-18-2023 Trial Testimony 7-19-2023 In the Circuit Court of Cook County Illinois
Brenda Wright vs. Penn Central and Conrail
Case No. No. 2032L003966
Rosenfeld Deposition 6-13-2023
In the Circuit Court Common Please Philadelphia of Jefferson County Alabama Frank Belle vs. Birmingham Southern Railroad Company et al.

Case No. 0l-cv-2021-900901.00
Rosenfeld Deposition 4-6-2023
Paul E. Rosenfeld, Ph.D. Page 10 of 17 March2025
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February 4, 2026
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In the Circuit Court of Jefferson County Alabama
Linda De Gregorio vs. Penn Central
Case No. 002278
Rosenfeld Deposition 3-27-20203
In the United States District Court Eastern District of New York Rosalie Romano et al. vs. Northrup Grumman Corporation
Case No. 16-cv-5760
Rosenfeld Deposition 3-16-2023
In the Superior Court of Washington, Spokane County
Judy Cundy vs. BNSF
Case No. 21-2-03718-32
Rosenfeld Deposition 3-9-2023
In The Court of Common Pleas of Philadelphia County, PA Civil Trial Division Feaster v Conrail
Case No. 001075
Rosenfeld Deposition 2-1-2023
In United States District Court for the Central District of Illinois Sherman vs. BNSF
Case No. 3:l 7-cv-01192
Rosenfeld Deposition 1-18-2023
In United States District Court District of Colorado
Gonzales vs. BNSF
Case No. l:21-cv-01690
Rosenfeld Deposition 1-17-2023
In United States District Court District of Colorado
Abeyta vs. BNSF
Case No. l:21-cv-01689-KMT
Rosenfeld Deposition 1-3-2023
In United States District Court For The Easter District of Louisiana Nathaniel Smith vs. Illinois Central Railroad
Case No. 2:21-cv-01235
Rosenfeld Deposition 11-30-2022
In the Superior Court of the State of California, County of San Bernardino Billy Wildrick, Plaintiff vs. BNSF Railway Company
Case No. CIVDSl 711810
Rosenfeld Deposition 10-17-2022
In the State Court of Bibb County, State of Georgia
Richard Hutcherson, Plaintiff vs Norfolk Southern Railway Company Case No. 10-SCCV-092007
Rosenfeld Deposition 10-6-2022
In the Civil District Court of the Parish of Orleans, State of Louisiana Millard Clark, Plaintiff vs. Dixie Carriers, Inc. et al.

Case No. 2020-03891
Rosenfeld Deposition 9-15-2022
In The Circuit Court of Livingston County, State of Missouri, Circuit Civil Division Paul E. Rosenfeld, Ph.D. Page 11 of 17 March2025
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Shirley Ralls, Plaintiff vs. Canadian Pacific Railway and Soo Line Railroad Case No. 18-LV-CC0020
Rosenfeld Deposition 9-7-2022
In The Circuit Court of the 13th Judicial Circuit Court, Hillsborough County, Florida Civil Division Jonny C. Daniels, Plaintiff vs. CSX Transportation Inc.

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

Case No. 19SL-CC03191
Rosenfeld Deposition 8-25-2022
In The Circuit Court of the 13th Judicial Circuit Court, Hillsborough County, Florida Civil Division Jeffery S. Lamotte, Plaintiff vs. CSX Transportation Inc.

Case No. NO. 20-CA-0049
Rosenfeld Deposition 8-22-2022
In State of Minnesota District Court, County of St. Louis Sixth Judicial District Greg Bean, Plaintiff vs. Soo Line Railroad Company
Case No. 69-DU-CV-21-760
Rosenfeld Deposition 8-17-2022
In United States District Court Western District of Washington at Tacoma, Washington John D. Fitzgerald Plaintiff vs. BNSF
Case No. 3:21-cv-05288-RJB
Rosenfeld Deposition 8-11-2022
In Circuit Court of the Sixth Judicial Circuit, Macon Illinois Rocky Bennyhoff Plaintiffvs. Norfolk Southern
Case No. 20-L-56
Rosenfeld Deposition 8-3-2022, Trial 1-10-2023
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 Kem George LaFazia vs. BNSF Railway Company.

Case No. BCV-19-103087
Rosenfeld Deposition 5-17-2022
In the Circuit Court of Cook County Illinois
Bobby Earles vs. Penn Central et. al.

Case No. 2020-L-000550
Rosenfeld Deposition 4-16-2022
In United States District Court Easter District of Florida Albert Hartman Plaintiff vs. Illinois Central
Case No. 2:20-cv-1633
Rosenfeld Deposition 4-4-2022
In the Circuit Court of the 4th Judicial Circuit, in and For Duval County, Florida Barbara Steele vs. CSX Transportation
Paul E. Rosenfeld, Ph.D. Page 12 of 17 March2025
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Case No.16-219-Ca-008796
Rosenfeld Deposition 3-15-2022
In United States District Court Easter District of New York Romano et al. vs. Northrup Grumman Corporation
Case No. 16-cv-5760
Rosenfeld Deposition 3-10-2022
In the Circuit Court of Cook County Illinois
Linda Benjamin vs. Illinois Central
Case No. No. 2019 L 007599
Rosenfeld Deposition 1-26-2022
In the Circuit Court of Cook County Illinois
Donald Smith vs. Illinois Central
Case No. No. 2019 L 003426
Rosenfeld Deposition 1-24-2022
In the Circuit Court of Cook County Illinois
Jan Holeman vs. BNSF
Case No. 2019 L 000675
Rosenfeld Deposition 1-18-2022
In the State Court of Bibb County State of Georgia
Dwayne B. Garrett vs. Norfolk Southern
Case No. 20-SCCV-091232
Rosenfeld Deposition 11-10-2021
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 Badus vs. Soo Line Railroad and BNSF
Case No. DV 19-1056
Rosenfeld Deposition 10-21-2021
In the Circuit Court Of The Twentieth Judicial Circuit, St Clair County, Illinois Martha Custer et al. vs Cerro Flow Products, Inc.

Case No. 0i9-L-2295
Rosenfeld Deposition 5-14-2021
Trial October 8-4-2021
In the Circuit Court of Cook County Illinois
Joseph Rafferty vs. C_onsolidated 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 Paul E. Rosenfeld, Ph.D. Page 13 of 17 March2025
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Theresa Romcoe vs. Northeast Illinois Regional Commuter Railroad Corporation d/b/a METRA Rail Case No. 17-cv-8517
Rosenfeld Deposition 5-25-2021
In the Superior Court of the State of Arizona In and For the Cunty of Maricopa Mary Tryon et al. vs. The City of Pheonix v. Cox Cactus Farm, L.L.C., Utah Shelter Systems, Inc.

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

Case No. 1: l 7-cv-000508
Rosenfeld Deposition 3-25-2021
In the Superior Court of the State of California, County of San Bernardino Gary Garner, Personal Representative for the Estate of Melvin Gamer 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. l 716-CV10006
Rosenfeld Deposition 8-30-2019
In the United States District Court For The District of New Jersey Duarte et al, Plaintiffs, vs. United States Metals Refining Company et. al. Defendant.

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

Case No. 3:15-CV-00106 consolidated with 3:15-CV-00237
Rosenfeld Deposition 5-9-2019
In The Superior Court of the State of California In And For The County Of Los Angeles - Santa Monica Carole-Taddeo-Bates et al., vs. Ifran Khan et al., Defendants Case No. BC615636
Rosenfeld Deposition 1-26-2019
In The Superior Court of the State of California In And For The County Of Los Angeles - Santa Monica The San Gabriel Valley Council of Governments et al. vs El Adobe Apts. Inc. et al., Defendants Case No. BC646857
Rosenfeld Deposition 10-6-2018; Trial 3-7-19
In United States District Court For The District of Colorado Bells et al. Plaintiffs vs . The 3M Company et al., Defendants Case No. l :16-cv-02531-RBJ
Rosenfeld Deposition 3-15-2018 and 4-3-2018
In The District Court Of Regan County, Texas, 112th Judicial District Phillip Bales et al., Plaintiff vs. Dow Agrosciences, LLC, et al., Defendants Paul E. Rosenfeld, Ph.D. Page 14 of 17 March2025
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Cause No. 1923
Rosenfeld Deposition 11-17-2017
In The Superior Court of the State of California In And For The County Of Contra Costa Simons et al., Plaintifs vs. Chevron Corporation, et al., Defendants Cause No. Cl2-01481
Rosenfeld Deposition 11-20-2017
In The Circuit Court of The Twentieth Judicial Circuit, St Clair County, Illinois Martha Custer et al., Plaintiff vs. Cerro Flow Products, Inc., Defendants Case No.: No. 0i9-L-2295
Rosenfeld Deposition 8-23-2017
In United States District Court For The Southern District of Mississippi Guy Manuel vs. The BP Exploration et al., Defendants
Case No. l:19-cv-00315-RHW
Rosenfeld Deposition 4-22-2020
In The Superior Court of the State of California, For The County of Los Angeles Warm Gilbert and Penny Gilber, Plaintiff vs. BMW of North America LLC Case No. LC102019 (c/w BC582154)
Rosenfeld Deposition 8-16-2017, Trail 8-28-2018
In the Northern District Court of Mississippi, Greenville Division Brenda J. Cooper, et al., Plaintifs, vs. Meritor Inc., et al., Defendants Case No. 4:16-cv-52-DMB-NM
Rosenfeld Deposition July 2017
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. RG14711 l 15
Rosenfeld Deposition September 2015
In The Iowa District Court In And For Poweshiek County
Russell D. Winburn, et al., Plaintiffs vs. Doug Hoksbergen, et al., Defendants Case No. LALA002187
Rosenfeld Deposition August 2015
In The Circuit Court of Ohio County, West Virginia
Robert Andrews, et al. vs. Antero, et al.

Civil Action No. 14-C-30000
Rosenfeld Deposition June 2015
In The Iowa District Court for Muscatine County
Laurie Freeman et. al. Plaintiffs vs. Grain Processing Corporation, Defendant Case No. 4980
Rosenfeld Deposition May 2015
In the Circuit Court of the 1 jli Judicial Circuit, in and For Broward County, Florida Walter Hinton, et. al. Plaintiff, vs. City of Fort Lauderdale, Florida, a Municipality, Defendant.

Paul E. Rosenfeld, Ph.D. Page 15 of 17 March2025
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Case No. CACE07030358 (26)
Rosenfeld Deposition December 2014
In the United States District Court Western District of Oklahoma Tommy McCarty, et al., Plaintiffs, vs. Oklahoma City Landfill, LLC d/b/a Southeast Oklahoma City Landfill, et al. Defendants .

Case No. 5:12-cv-01152-C
Rosenfeld Deposition: July 2014
In the County Court of Dallas County Texas
Lisa Parr et al, Plaintiff, vs. Aruba et al, Defendant.

Case Number cc-11-01650-E
Rosenfeld Deposition: March and September 2013
Rosenfeld Trial: April 2014
In the County of Kern, Unlimited Jurisdiction
Rose Propagation Services vs. Heppe Enterprises
Case No. S-1500-CV-278190, LIIB
Rosenfeld Deposition: May 2014
In the Circuit Court of Baltimore County Maryland
Philip E. Cvach, II et al., Plaintiffs vs. Two Farms, Inc. d/b/a Royal Farms, Defendants Case Number: 03-C-12-012487 OT
Rosenfeld Deposition: September 2013
In the Court of Galveston County, Texas 56thJudicial District MDL Litigation Regarding Texas City Refinery Ultracracker Emission Event Litigation Cause No. 10-UC-0001
Rosenfeld Deposition: March 2013
Rosenfeld Trial: September 2013
In the United States District Court of Southern District of Texas Galveston Division Kyle Cannon, Eugene Donovan, Genaro Ramirez, Carol Sassler, and Harvey Walton, each Individually and on behalf of those similarly situated, Plaintiffs, vs. BP Products North America, Inc., Defendant.

Case 3: 10-cv-00622
Rosenfeld Deposition: February 2012
Rosenfeld Trial: April 2013
In the United States District court of Southern District of California United States of America, Plaintiff vs. 2,560 Acres of Land, more or less, located in Imperial County, State of California; and Donald L. Crawford, et. al.

Civil No. 3:11-cv-02258-IEG-RBB
Rosenfeld Deposition: December 2012, January 2013
In the Court of Common Pleas of Tuscarawas County Ohio
John Michael Abicht, et al., Plaintiffs, vs. Republic Services, Inc., et al., Defendants Case No. 2008 CT 10 0741 (Cons. w/ 2009 CV 10 0987)
Rosenfeld Deposition October 2012
In the Court of Common Pleas of Tuscarawas County Ohio
John Michael Abicht, et al., Plaintiffs, vs. Republic Services, Inc., et al., Defendants Case Number: 2008 CT 10 0741 (Cons. w/ 2009 CV 10 0987) Rosenfeld Deposition: October 2012
In the United States District Court for the Middle District of Alabama, Northern Division James K. Benefield, et al., Plaintiffs, vs. International Paper Company, Defendant.

Paul E. Rosenfeld, Ph.D. Page 16 of 17 March2025
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Civil Action No. 2:09-cv-232-WHA-TFM
Rosenfeld Deposition July 2010, June 201 l
Paul E. Rosenfeld, Ph.D. Page 17 of 17 March2025
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Russell Brown
AICP, Senior Planner

BLUM, COLLINS & HO LLP

ATTORNEYS AT LAW
10250 CONSTELLATION BOULEVARD
SUITE2300
LOS ANGELES, CALIFORNIA 90067
(213) 572-0400
September 24, 2025
Via Email to:
[email protected]
City of Menifee Planning Department
29844 Haun Road
Menifee, CA 92586
Subject: Comments on Menifee (Pemcor) Business Park Project, Plot Plan PLN23-0245 EIR (SCH NO. 2024071016)
Dear Mr. Brown,
Thank you for the opportunity to comment on the Environmental Impact Report (EIR) for the proposed Menifee (Pemcor) Business Park Plot Plan PLN 23-0245 Project. Please accept and consider these comments on behalf of Golden State Environmental Justice Alliance. Also, Golden State Environmental Justice Alliance formally requests to be added to the public interest list regarding any subsequent environmental documents, public notices, public hearings, and notices of determination for this project. Send all communications to Golden State Environmental Justice Alliance P.O. Box 79222 Corona, CA 92877.

1.0 Summary
The project proposes the construction and operation of 337,770 square feet of industrial building area, which would be spread across 11 buildings (Plot Plan PLN23-0245) on a 20.03 acre site. The entire 20.03-acre site would be graded and the portions of the site not developed with buildings would either be hardscaped (e.g., parking or sidewalks) or landscaping. Two buildings will face Howard Way and two buildings will front on to Zeiders Road. The buildings range in size from 23,100. square feet to 37,840 square feet and each feature two_ truck dock bays each that would be oriented toward the center of the site (a total of 22 truck docks at the site). Building heights are 38 to 40 feet above ground level.

Item Title: 11.1
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4.3 Air Quality, 4.6 Energy, and 4.9 Greenhouse Gas Emissions The EIR does not include for analysis relevant environmental justice issues in reviewing potential impacts, including cumulative impacts from the proposed project. This is in conflict with CEQA Guidelines Section 15131 ( c ), which requires that "Economic, social, and particularly housing factors shall be considered by public agencies together with technological and environmental factors in deciding whether changes in a project are feasible to reduce or avoid the significant effects on the environment identified in the EIR. If information on these factors is not contained in the EIR, the information must be added to the record in some other manner to allow the agency to consider the factors in reaching a decision on the project." This is especially significant as the surrounding community is highly burdened by pollution. See also the attached air quality comments and analysis from SW APE.

According to CalEnviroScreen 4.01, CalEPA's screening tool that ranks each census tract in the state for pollution and socioeconomic vulnerability, the proposed project's census tract (6065043279) is highly burdened by pollution. The surrounding community bears the impact of multiple sources of pollution and is more polluted than average on several pollution indicator measured by CalEnviroScreen. For example, the project census tract ranks in the 80th percentile for ozone burden, the 46th percentile for particulate matter (PM) 2.5 burden, and 78th percentile for traffic burden. All of these environmental factors are attributed to heavy truck activity in the area. While California has strict vehicle-emissions standards, exhaust from cars and trucks is the main source of air pollution in much of the state2. Ozone can cause lung irritation, inflammation, and worsening of existing chronic health conditions, even at low levels of exposure3. Exhaust fumes contain toxic chemicals that can damage DNA, cause cancer, make breathing difficult, and cause low weight and premature births4.

The census tract also ranks in the 50th percentile for hazardous waste facility impacts and 36th percentile for solid waste facility impacts. Hazardous waste generators and facilities contribute to the contamination of air, water and soil near waste generators and facilities can harm the environment as well as people5. Solid waste facilities can expose people to hazardous chemicals, 1 https://experience.arcgis .com/experience/l ld2f52282a54ceebcac7428e6184203 /page/Ca1EnviroScreen- 4 0 /
2 OEHHA Traffic bttps://oehha,ca.gov/calenviroscreen/indicator /traffic-density 3 OEHHA Ozone bttps ://oehha.ca.gov /calenviroscreen/indicator /air-quality -ozone 4 OEHHA Traffic https ://oehha.ca.gov /calenviroscreen/indicator /traffic-density 5 OEHHA Hazardous Waste Generators and Facilities
https://oehha.ca.gov/calenv iroscreen/indicator/hazardous-waste -generators-and-facilities Item Title: 11.1
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release toxic gases into the air ( even after these facilites are closed), and chemicals can leach into soil around the facility and pose a health risk to nearby populations6.

Further, the census tract is a diverse community including 30% Hispanic, 1 % African-American, and 2% Asian-American residents, whom are especially vulnerable to the impacts of pollution. The community has a high rate of low educational attainment, meaning 40% of the census tract residents over age 25 has not attained a high school diploma. The community also has a high rate of poverty, meaning 34% of the households in the census tract have a total income before taxes that is less than the poverty level. Income can affect health when people cannot afford healthy living and working conditions, nutritious food and necessary medical care7. Poor communities are often located in areas with high levels of pollution8. Poverty can cause stress that weakens the immune system and causes people to become ill from pollution9. Living in poverty is also an indication that residents may lack health insurance or access to medical care. Medical care is vital for this census tract as it ranks in the 93rd percentile for incidence of cardiovascular disease and 43rd percentile for incidence of asthma.

The State of California lists three approved compliance modeling softwares10 for non-residential buildings: CBECC-Com, EnergyPro, and IES VE. Appendix E: Air Quality/Greenhouse Gas/Energy Report is not included as attachment for public review. It is listed in the EIR Table of Contents, but not included within the compiled appendices file uploaded to the City's website11 and the LCI (formerly OPR) CEQAnet database12. Excluding Appendix E: Air Quality/Greenhouse Gas/Energy Report from public review does not comply with CEQA's requirements for adequate informational documents and meaningful disclosure (CEQA § 15121 and PRC 21003(b)). Incorporation by reference (CEQA § 15150 (f)) is not appropriate as Appendix E: Air Quality/Greenhouse Gas/Energy Report contributes directly to analysis of the 6 OEHHA Solid Waste Facilities https://oehha.ca.gov /calenviroscreen/indicator /solid-waste-sites-and­ facilities
7 OEHHA Poverty https://oehha.ca.gov/calenviroscreen/indicator /poverty 8 Ibid.
9 Ibid.
1° California Energy Commission 2022 Energy Code Compliance Software https://www.energy.ca.gov/programs-and-topics/programs/building-energy -efficiency-standards /2022- building-energy-efficiency-l
11 Menifee Perncor DEIR Compiled Appendices
https://www.cityofinenifee.us/DocumentCenterNiew /2407 4/DEIR-Appendices­ https://www.cityofinenifee.us/DocumentCenterNiew /24074/DEIR-Appendices- 12 Menifee Perncor DEIR Appendices via CEQAnet https://files.ceqanet.lci.ca .gov/303525- 3/attachment/nAju2TQyzveJvArb0k-A iV7VmUhZr;p5bTNbjZpl7mehznEXuGkWm- 73X50z8q2S98 CGtGVXjVNdWwB0
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problem at hand. A revised EIR must be prepared and recirculated to include Appendix E: Air Quality/Greenhouse Gas/Energy Report for review, analysis, and comment by the public and decision makers in order to comply with CEQA's requirements for adequate informational documents and meaningful disclosure (CEQA § 15121 and PRC 21003(b)). Commenter reserves the right to provide additional and/or updated comments should Appendix E become available, including after the conclusion of the public review period.

4.11 Land Use and Planning
The EIR does not meaningfully discuss or analyze the project's compliance with the General Plan's Land Use Buildout Scenario. Exhibit LU-4: Land Use Buildout Summary within the General Plan Land Use Element13 analyzes a 0.38 FAR for Business Park development within EDC-SG and 21,357,032 square feet of non-retail development within all EDC areas. Table 3-2:

Project Development Characteristics states the project site has a FAR of 0.46, which is greater than the assumption of the environmental analysis which it attempts to tier from. The EIR has not provided evidence that the growth generated by the proposed project was anticipated by the General Plan, RTP/SCS, or AQMP. The EIR must be revised to provide an accurate build-out scenario of the City's General Plan.

Table 4.11-1: 2024-2050 RTP/SCS Consistency Analysis provides a misleading and erroneous consistency analysis with SCAG's 2024 Connect SoCal RTP/SCS14. The EIR has exclude relevant analysis regarding the project's significant and unavoidable cumulatively considerable GHG impacts and has not provided any analysis in accordance with the policies of the RTP. Due to errors in modeling, modeling without supporting evidence ( as noted throughout this comment letter), and the EIR's determination that the project will generate significant and unavoidable cumulatively considerable Greenhouse Gas Emissions, the proposed project is directly inconsistent with the following and a revised EIR must be included with a finding of significance:
l. Housing the Region Policy 35. Encourage housing development in areas with access to important resources and amenities ( economic, educational, health, social and similar) to further fair housing access and equity across the region.

2. Housing the Region Policy 36. Encourage housing development in transit-supportive and walkable areas to create more interconnected and resilient communities. 13 Menifee General Plan Land Use Element
https://www .cityofmenifee.us/DocumentCenterNiew/14 70 I /FINAL Land-Use-Element 11322 14 https://scag .ca.gov /sites/ default/files/2024-05/23-29 87-connect-socal -2024-final-comp lete-040424. pdf Item Title: 11.1
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3. Housing the Region Policy 37. Support local, regional, state and federal efforts to produce and preserve affordable housing while meeting additional housing needs across the region.

4. Housing the Region Policy 38. Prioritize communities that are vulnerable to displacement pressures by supporting community stabilization and increasing access to housing that meets the needs of the region.

5. Housing the Region Policy 39. Promote innovative strategies and partnerships to increase homeownership opportunities across the region with an emphasis on communities that have been historically impacted by redlining and other systemic barriers to homeownership for people of color and other marginalized groups.

6. Housing the Region Policy 40. Advocate for and support programs that emphasize reducing housing cost burden (for renters and homeowners), with a focus on the communities with the greatest needs and vulnerabilities.

7. Equitable Engagement and Decision-Making Policy 46. Promote racial equity that is grounded in the recognition of the past and current harms of systemic racism and one that advances restorative justice.

8. Equitable Engagement and Decision-Making Policy 47. Increase equitable, inclusive, and meaningful representation and participation of people of color and disadvantaged communities in planning processes.

9. Sustainable Development Policy 48. Promote sustainable development and best practices that enhance resource conservation, reduce resource consumption and promote resilience.

10. Sustainable Development Policy 49. Support communities across the region to advance innovative sustainable development practices.

11. Sustainable Development Policy 50. Recognize and support the diversity of communities across the region by promoting local place-making, planning and development efforts that advance equity, mobility, resilience and sustainability.

12. Air Quality Policy 51. Reduce hazardous air pollutants and greenhouse gas emissions and improve air quality throughout the region through planning and implementation efforts.

13. Air Quality Policy 52. Support investments that reduce hazardous air pollutants and greenhouse gas emissions.

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14. Air Quality Policy 53. Reduce the exposure and impacts of emissions and pollutants and promote local and regional efforts that improve air quality for vulnerable populations, including but not limited to Priority Equity Communities and the AB 617 Communities.

15. Climate Resilience Policy 64. Prioritize the most vulnerable populations and communities subject to climate hazards to help the people, places and infrastructure that are most at risk for climate change impacts. In doing so, recognize that disadvantaged communities are often overburdened.

16. Climate Resilience Policy 65. Support local and regional climate and hazard planning and implementation efforts for transportation, land use, and other factors.

17. Climate Resilience Policy 66. Support nature-based solutions to increase regional resilience of the natural and built environment.

The EIR does not provide a consistency analysis with all land use plans, policies, or regulations adopted for the purpose of avoiding or mitigating an environmental effect. Further, Table 4.11-2:

City General Plan Consistency Analysis includes consistency analysis that is erroneous and misleading to the public and decision makers. The EIR is inadequate as an informational document and a revised EIR must be prepared with a consistency analysis with all General Plan policies, including but not limited to the following:

1. Goal S-7: A community that has protected its sensitive structures, functions, and populations from the risks associated with climate change.

2. Policy S-7.1: Continue to require environmental analysis for proposed projects which may produce harmful levels of greenhouse gas.

3. Policy EJ-3.6: Continue to collaborate with the South Coast Air Quality Management District (SCAQl\ID), California Air Resources Board (CARB), utility providers, Southern California Association of Governments (SCAG), Western Riverside Council of Governments (WRCOG) and nonprofit organizations, neighborhoods groups, and other community organizations to improve air quality, food availability, renewable energy systems, sustainable land use and reduce greenhouse gas emissions (GHGs).

4. Goal OSC-10: An environmentally aware community that is responsive to changing climate conditions and actively seeks to reduce local greenhouse gas emissions.

Item Title: 11.1
Appeal of Planning Commission Decision for the Menifee (Pemcor) Business Park Project Item Page Number: 276

Menifee Mayor and City Council
February 4, 2026
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Russell Brown
September 24, 2025
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5. Policy OCS-10.1: Align the city's local GHG reduction targets to be consistent with the statewide GHG reduction target of AB 32.

6. Policy OCS-10.2: Align the city's long-term GHG reduction goal consistent with the statewide GHG reduction goal of Executive Order S-03-05.

7. Policy OCS-10.3: Participate in regional greenhouse gas emission reduction initiatives.

8. Policy OCS-10.4: Consider impacts to climate change as a factor in evaluation of policies, strategies, and projects

9. Policy C-5.3: Support efforts to reduce/eliminate the negative environmental impacts of goods movement.

10. Policy C-1.2: Require development to mitigate its traffic impacts and achieve a peak hour Level of Service (LOS) D or better at intersections, except at constrained intersections at close proximity to the 1-215 where LOSE may be permitted.

Additionally, the EIR concludes that the project is consistent with "Policy C-5.3: Support efforts to reduce/eliminate the negative environmental impacts of goods movement" because "An EIR is being prepared for this project which is the most extensive environmental documentation that can be prepared under CEQA. Mitigation is recommended where potential significant impacts result from the project. This is erroneous and misleading to the public and decision makers because it omits the fact that the project will generate significant and unavoidable cumulatively considerable Greenhouse Gas Emissions. The EIR must be revised to include information regarding the project 's significant and unavoidable impacts to Greenhouse Gas Emissions for analysis in this section and a finding of significance due to the project's inconsistency with this policy.

4.14 Population and Housing
The project faces significant inconsistencies with statutory requirements of the Housing Crisis Act (HCA) of 2019/Senate Bill (SB) 33015/SB 816. The HCA/SB 330/SB 8 require replacement housing sites when land designated for housing development experience changes to ensure no net loss of housing capacity. The project site has a General Plan land use designation of Economic Development Corridor - Southern Gateway (EDC-SG) that has a maximum density of 24 units per 15 Housing Crisis Act of 2019/SB 330
https ://leginfo . legislature.ca. gov/faces/bill TextClient.xhtml ?bill id=201920200SB3 3 0 16 SB 8 bttps ://leginfo.legislature .ca.gov/faces/billTextClient.xhtml?bill id=202120220SB8 Item Title: 11.1
Appeal of Planning Commission Decision for the Menifee (Pemcor) Business Park Project Item Page Number: 277

Menifee Mayor and City Council
February 4, 2026
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Russell Brown
September 24, 2025
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acre17. The approximately 20.3 acre project site can accommodate the development ofup to 487 dwelling units. Additionally, Exhibit LU-4 within the City's General Plan depicts that the EDC­ SG designation only permits residential development on 30 acres within the planning area, which accommodates the development ofresidential dwelling units on the project site. The General Plan also states that residential development in the EDC areas, " ... shall not be allowed on parcels or properties directly adjacent to the freeway," indicating that the project site is one of the few parcels that could accommodate residential development in the EDC-SG.

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

Government Code Section 66300 (h)(i)(l) states that, "this section does not prohibit an affected county or an affected city, including the local electorate acting through the initiative process, from changing a land use designation or zoning ordinance to a less intensive use, or reducing the intensity of land use, if the city or county concurrently changes the development standards, policies, and conditions applicable to other parcels within the jurisdiction to ensure that there is no net loss in residential capacity." As calculated above, the project site's EDC-SG designation provides development capacity for 487 residential units. Approval of the proposed project will result in a reduction of the existing residential development capacity by 487 units to a decreased development capacity of 0 residential units.

This is in conflict with SB 8 that expanded the provisions of the HCA to include Government Code Section 66300 (h)(i)(l) requiring concurrent approval ofreplacement sites to ensure no net loss in residential capacity, and Section 66300 (h)(2)(A) defining "concurrently" to mean the action is 17 Menifee General Plan Exhibit LU-4: Land Use Buildout Summary https://www.cityofmenifee.us/Docume ntCenterNiew/14675/3 LU-4 FINAL Item Title: 11.1
Appeal of Planning Commission Decision for the Menifee (Pemcor) Business Park Project Item Page Number: 278

Menifee Mayor and City Council
February 4, 2026
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581 of 961

Russell Brown
September 24, 2025
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approved at the same meeting of the legislative body. The EIR has not identified replacement sites for the net loss in residential capacity for 487 units as a result of project implementation. The loss in residential capacity must be included as a finding of significance as part of a revised EIR. The EIR does not act in conformance with the HCA/SB 330/SB 8 and the lost zoning capacity of any dwelling units is a significant environmental impact in violation of the HCA/SB 330/SB 8. The EIR must be revised to include a finding of significance due to this inconsistency.

Additionally, deferring the environmental analysis of construction and operation of replacement sites to a later date is project piecemealing in violation of CEQA. The EIR does not accurately or adequately describe the project, meaning "the whole of an action, which has a potential for resulting in either a direct physical change in the environment, or a reasonably foreseeable indirect physical change in the environment" (CEQA § 15378). The whole of the action must statutorily and legally include the identification of replacement sites and all associated actions required to implement development of at least 678 residential units.

The EIR utilizes uncertain language and does not provide any meaningful analysis or supporting evidence to substantiate the conclusion that there will be no significant impact to population and housing. The EIR only briefly discusses the construction related jobs and states that, "Construction workers and employees would come from the City and from surrounding areas as well. These workers are temporary and would not need to be accounted for in the estimated population growth provided in Table 4.14-1 and the employment forecasts provided in Table 4.14-3." Notably, the geographic boundaries of the "surrounding areas" are undefined and will result in the project attracting a workforce that is exponentially further than that of the "low VMT TAZ" utilized in the EIR to conclude less than significant VMT impacts.

The EIR does not provide substantial evidence that the construction or operational workforce in the City is qualified for or interested in construction work or work in the industrial sector to support a less than significant finding. Relying on the unemployed workforce population of the overall SCAG region will increase project related VMT and emissions during all phases of construction and operations and a revised EIR must be prepared to account for longer worker trip distances.

The EIR states that the project will generate 553 operational employees, but does not provide the source or methodology for this calculation. Excluding the methodology for calculating employment generation does not comply with CEQA's requirements for adequate informational documents and meaningful disclosure (CEQA § 15121 and PRC 21003(b)). Incorporation by reference (CEQA § 15150 (f)) is not appropriate as the methodology for calculating employment Item Title: 11.1
Appeal of Planning Commission Decision for the Menifee (Pemcor) Business Park Project Item Page Number: 279

Menifee Mayor and City Council
February 4, 2026
Page
582 of 961

Russell Brown
September 24, 2025