Appeal Letter - GSEJA — Menifee City Council, February 4, 2026

City of Menifee
City Clerk

CITY OF MENIFEE
NOV 1 9 2025 APPEAL APPLICATION

MENIFEE
Received Decision to be appealed: Menifee (Pemcor)
Business Park APPELLANT/REPRESENTATIVE Golden State Environmental Justice Alliance Project, Plot Plan
PLMON: N04(951) 279-4697 457 E-MAIL._ [email protected] _FAX NO.
765 N Main Street, Suite 151, Corona, CA 92880

ADDRESS

STREET CITY STATE ZIP

PROPERTY OWNER
(if different) LAST FIRST MI.

PHONE NO. FAX NO. _ E-MAIL

ADDRESS
STREET
Menifee (Pemcor) Business Park Project, Plot Plan PLN23-0245 Name of Project, APN/ Address: APN 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): _Planning Commission
Certification of the FEIR for the project at hand, 11/12/2025 Action and Date:

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 prior comments sent.

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

Appellant requests the Menifee City Council reverse the decision of the Planning What result to you want? C mission's certification of the project and require a new EIR Applicant's saure St 2025-11-19
Date:

Owner Certification: I certify 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 cary or Men te of ay, a result of this tons, in adas and contention intens or by the imposed on this real property.

Owner'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.

Green Jobs & Clean Communities
11 November 2025
Planning Commission
City of Menifee
29844 Haun Road
Menifee, CA 92586
Delivered via email to: [email protected]
[email protected]
[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 deficien environmental justice analysis, missing air quality appendix, inadequate General Plar 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 (SWAPE), 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 ft? 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 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 ready bears severe environmental burdens in the entire state of California. According to th "alifornia Environmental Protection Agency's CalEnviroScreen 4.0 analysis, this communit 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
ArcGIS Web Map
11/71/2025, 12-50:55 AM 1:42234
• Emerpancy Departments •, 80 - 90 -**
Cardiovascular Diseaso Parcentle I , 00-100
- 70-60
lahore
CalEnviroScreen Cardiovascular Disease Results Data for Census Tract 6065043279, Source: California Environmental Protection Agency
2 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
Menlfee (Pemcor) Business Park Project Location
Census Tract 6065043279
Crftical Finding: The proposed Industrial development would be built in a community already experiencing severe environmental and health burdens ranking in the top percentles statewide. Adding 337,770 ff? of industrial space with 22 truck docks would worsen conditions in an already overburdene disadvantaged community.

CalEnviroScreen 4.0 Pollution & Health Rankings
• Cardiovascular Disease Burden 93rd Percentile
Worse than 90% of CA
Reflects pollution's severe toll on community health Heart disease rates significantly devated 2 Ozone Pollution Burden 80th Percentile
Worse than 80% of CA
Dangercusly poor air quality from industrial sources and vetude emissions •ll Traffic Impact Burden 78th Percentlle
Worte than 78% of CA
High exposure to truck and vehicle pollution from heavy traffic volumes Hazardous Waste Facility Impacts 50th Percentile
Worse than 50% of CA
Proximity to hazardous waste generators and facilities affecting ai, water, and soll quality.

C PM 2.5 Particulate Matter Burden 46th Percentile
Worse than 46% of CA
Fine particulate contamination affecting respiratory and cardiovascular health /M Asthma Indidence 43rd Percentlie
•Worna than 43% of CA
Bevated asthma rates reflecting poor air quality and respiratory health impacts Community Vulnerability Factors
40% 34% 30%
Lack High School Educalion Below Powerty Line Hispanic Population S8 535 Disadvantaged Community: Offidaly designated under state law as requiring spedal environmentai protection.

Sa 1000 Protections: Colfomia's environmental Justice law specifically designed to protect communities like this from aditional pollution burdens.

Compounding Vulnerabilftles: Poverty Ilmts acres to healthcare, weakens immune systems, and reduces abillity to cope with additional emironmental stressors.

Sour: Callomis Erronmental Protection Agency, CalEnvirosorten 40 Prepared for: Supplemental Comments on Menifee (Pemcor) Business Park Project EIR (SCH No 2024071016) Date: Noverber 11, 2025 | Prepared by: Golden State Environmental Justke Allance 3 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 ft 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 CEQÁ 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 SWAPE correctly noted in their technical review, "Excluding Appendix E: Air 4 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) 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 of Menifee'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 Concentration in Menifee Exceeds 26-Year Growth Forecast Critical Finding: Recent industrial projects approved In Menlfee, Including the proposed Pemcor Business Park, will cumulatively generate approdmatety

18.000 emplovees-representing 210% of the City's total employment growth forecast over 26 years (2019-2045).

Implication: This massive concentration of warehouse and industrlal development represents unplanned, unprecedented growth that will overwhelm community infrastructure and dramatically worsen alr quality In an already disadvantaged area.

Timeline Contrart: The City of Mentfee's General Plan forecasts 8,500 jobs growth between 2019-2045 (26 years). The Industrial projects listed below will gene e than double this amount-concentrated primarily in warehouse and logistics uses that generate slanificant truck traffe and pollut Industrial Development vs. City Employment Forecast
~18,000
warehouse lobs
approved/proposed
8,500
City Employment Cumulative Warehouse
Growth Forecast Employment from
(2019-2045) Recent Projects
210%
Industrial warehouse projects represent MORE THAN DOUBLE the City's entire 26-year employment growth forecast-concentrated in a single, polluting industry sector.
6 Recent Industrial/Warehouse Projects in Menifee (Partial List) Menifee Commerce Center Menileo Commerce Center Phase I1 2,885 employees projected 1,962 employees projected
Northern Gateway Commerce Center Ares Warehouse on Murrieta 2,267 employees projected 952 employees projected
Capstone Industrial Wheat Warehouse
1,205 employees projected 151 employees projected
Corsica Business Park Trumble and Watson Warehouse
477 employees projected 571 employees projected
Pomcor Business Park (Proposed) + Additional Projects
53 employees projected ~7,000 more employees
Cumulative Health & Environmental Impacts
- Coit one leniel truck rath rating colors ok al pluton, contiting to lie death zones where cumulative exposure restes severe public.

1. 24/7 Industrial noise disrupting sleep and contributing to stress-related health problems in surrounding residential areas Increased PM2.5 and ozone worsening respiratory conditions in a community already at 93rd percentile for cardiovascular disease and 43rd percentle for asthma
Traffic safety hazards on residential streets not designed for heavy Industrial truck traffic, endangering pedestrians and cydists A Economic displacement as Industrial uses dive out communtty-serving businesses and elminate housing opportunities Infrastructure strain on roads, utilities, and emergency services beyond what was planned in General Pian forecasts Environmental Justice Violation: This pattem of Industrial concentration in communities of color and low-income areas, while protecting wealthler nelghborhoods from such development, constitutes 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 affluent areas like Newport Beach or other coastal communities.

Sources: Gty of Menifee Land Development Projects Map, SCAG 2024 Connect SoCal Demographies and Growti Forecast, Ind dual Project EIRS Prepared for: Supplemental Comments on Menifee (Perox) Business Park Project ETR (SCH No. 2024071016) Date: November 11, 2025 | Prepared by: Golden State Environmental Justice Alance 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 • 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 emissions
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 PFAS soil testing with appropriate mitigation if contamination found 8 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 93"d percentile for cardiovascular disease burden, 80* 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
+1 951 279 4697
9 Green Jobs & Clean Communities
19 November 2025
City Council
City of Menifee
29844 Haun Road
Menifee, CA 92586
SUBJECT:

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 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 ft 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— 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:
• 93"d percentile for cardiovascular disease burden (worse than 93% of CA) 43rd percentile for asthma incidence
Elevated rates of emergency room visits for heart attacks and respiratory conditions
• Pollution Burden:
• 80"h percentile for ozone pollution (worse than 80% of CA) • 78ih percentile for traffic impacts (worse than 78% of CA) • 50"h percentile for hazardous waste facility impacts
• 46th percentile for PM 2.5 particulate matter burden
• 36"h percentile for solid waste facility impacts
• Socioeconomic Vulnerability:
• 40% of residents lack high school education (educational vulnerability) 34% poverty rate (economic vulnerability limiting healthcare access 30% Hispanic, 1% African American, 2% Asian American residents Senate Bill 535 Disadvantaged Community designation
Environmental Justice community under SB 1000 protections 2 CENSUS TRACT 6065043279 vs. CALIFORNIA AVERAGE
Health Indicator Project Site CA Average Impact
Cardiovascular Disease 93rd %ile 50th %ile +86%
Ozone Pollution 80th %ile 50th %ile +60%
Traffic Impacts 78th %ile 50th %ile +56%
PM2.5 Burden 46th %ile 50th %ile -8%
Asthma 43rd Gile 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.

ArcGIS Web Map
1:42234
I → 60 - 90 oss
© Emergency Departments -043
Cardevascular Disease Percentle I, 90 - 100 05
= 70-80 Clutions
CalEnviroScreen Cardiovascular Disease Results Data for Census Tract 6065043279, Source: California Environmental Protection Agency
3 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.

LEGAL COMPLIANCE VIOLATIONS SUMMARY
IOLATED: CEQA § 15121 - Informational Disclosur
Appendix E excluded from public revle
/OLATED: CEQA § 15378 - Project Plecemealing
• Segmented analysis of related projects
→ fated to reduce pondon 0302/4) - General Plan EJ Element VIOLATED: Gov Code § 11135 - Language Acces
→ No Spanish translation (30% Hispanic populatior
/OLATED: CEQA Guidelines §15131(c) - EJ Analysi
• No analysis of impacts on vulnerable population
4 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 §15378 and precedents established in Laurel Heights Improvement Assn. v. Regents of University of California (1988) 47 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 CEOA 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 93rd 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 • Constitutional equal protection guarantees
Environmental & Health Burden Analysis
Menlfee (Pemcor) Business Park Project Location
Census Tract 6065043279
Iisadvantaged community
CalEnviroScreen 4.0 Pollution & Health Rankings
• Cardiovascular Disease Burden 93rd Percentile
Worse than 93% of CA
Reflects pollution's severe toll on community heath. Heart disease rates significantly elevated. * Ozone Pollution Burden Both Percentile
Worse than 80% of CA
Dangerously poor air quality from industrial sources and vehide emissions. ill Traffic Impact Burden 78th Percentlle
Worse than 78% of CA
High exposure to truck and vehicle pollution from heavy traffic volumes. © Hazardous Waste Facility Impacts 50th Percentile
Worse than 50% of CA
Proximity to hazardaus waste generators and facilities affecting air, water, and soil quality. € PM 2.5 Particulate Matter Burden 46th Percentlle
Worse than 46% of CA
Fine particulate contamination affecting respiratory and cardiovascular health Asthma Incidence 43rd Percentlle
Worse than 43% of CA
Elevated asthma rates reflecting poor air quality and respiratory health impacts.

Community Vulnerability Factors
40% 34% 30%
Lack High School Education Below Poverty Line Hispanic Populabon SB 535 Disadvantaged Community: Offidally designated under state law as requiring special environmental protection.

SB 1000 Protections: Califomia's environmental Justice law specifically designed to protect communities like this from additional pollution burdens.

Compounding Vulnerabilities: Poverty limits access to healthcare, weakens immune systems, and reduces ability to cope with additional environmental stressors.

Source: Callfomla Environmental Protection Agency, CalEnviroScreen 4.0 Prepared for: Supplemental Comments on Menifee (Pemcor) Business Park Project EIR (SCH No 2024071016) Date: November 11, 2025 | Prepared by: Golden State Entronmental Justice Allance invironmental & Health Burden Analysis for Census Tract 6065043279, showing severe pollution burden an ommunity vulnerability factors. Source: California Environmental Protection Agency, CalEnviroScreen 4. 6 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 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. 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)
Residential Capacity: 487 dwelling units
Project Proposal: O dwelling units
NET LOSS: 487 units (100%)
Required by Law: Provided by City:
• Identify replacement sites X None
/ Concurrent approval X None
r Written findings X None
STATUS: VIOLATION OF GOV CODE § 66300(b)(1)(A)
7 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 gasProject 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
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

AIR QUALITY AND HEALTH RISK ASSESSMENT
SWAPE Technical Findings
The technical review by SWAPE 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 PFAS Analysis: Despite agricultural history indicating potential biosolid application, no PFAS testing conducted
Fraction of Time at Home (FAH): 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 (93rd 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.

PROJECT GHG EMISSIONS vs. REGULATORY THRESHOLDS
Greenhouse Gas Emissions
Emission Source Annual GHG Emissions (MTCO2e)
The Project generates 10,419.5 10,419.5
Project Emissions
MTCO2e annually-exceeding both
SCAQMD's 10,000 MTCO2e and the City of Menifee Threshold 3,000 City's 3,000 MTCO2e thresholds. SCAQMD Threshold 10,000 The City acknowledges this as Exceedance over City Threshold 347% significant and unavoidable (Response Exceedance over SCAQMD Threshold 4.2% H-8), yet rejects feasible mitigation SIGNIFICANT & UNAVOIDABLE

IMPACT DETERMINATION
measures including:
10 • Zero-emission truck infrastructure (dismissed despite only 22 docks) • LEED certification requirements
Enhanced solar requirements beyond CalGreen
• 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 • 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 93d 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 calculation
Mischaracterization of legal requirement
• Refusal to consider feasible mitigation
12 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 ft 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 GRIEVANCES
Following 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 nembers equally, while preventing the concentration of pollution impacts on at-risk population r 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 mprehensive environmental justice analysis before project approval. The current FEIR chnical deficiencies and regulatory violations necessitate additional environmental review ensure community protection and legal compliance with state environmental justice mandates. 14 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 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 Stanley Saltzman, MBAc
Corporate Secretary Staff Analyst
Golden State Environmental Justice Alliance Golden State Environmental Justice Alliance 765 N Main Street, Suite 151 765 N Main Street, Suite 151 Corona, CA 92880 Corona, CA 92880
+1 951 279 4697 +1 951 279 4697
16 Technical Consultation, Data Analysis and
SWAPE Litigation Support for the Environment
2656 29th Street, Suite 201
Santa Monica, CA 90405
Matt Hagemann, P.G, C.Hg.
(949) 887-9013
[email protected]
September 19, 2025
Gary Ho
Blum, Collins & Ho LLP
707 Wilshire Blvd, Ste. 4880
Los Angeles, CA 90017
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 | 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.

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 | 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 PAS could be present in any components used or manufactured at the property.

Though invasive testing is not part of a Phase | ESA, consideration should be given to Phase I! 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 I/" 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 | 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").ª CalEEMod uses site-specific 1 https://pfas-1.itrcweb.org/wp-content/uploads/2023/10/Biosolids PFAS Fact Sheet Sept2023 final.pdf 2 https://www.hklaw.com/en/insights/publications/2024/04/epa-designates-2-pfas-compounds-as-hazardous- 3 https://www.kirkland.com/publications/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.
2 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.

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 quantitative details of default value modifications (see screenshot below) (Appendix E, pp. 157).

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

Operations: Vehicle Data Updated per Traffic Scoping Agreement, IP models passenger vehicles, Parking Lot models truck trips. Truck trip length updated based on SCAMD Rule 2305 Rulemaking materials.

Passenger vehicle trip length updated based on
Operations: Fleet Mix Fleet mix updated to reflect IP modeled as passenger vehicles and PL modeled as trucks.

Truck breakdown directly from Ganddin. Passenger veh adjusted based on CMod defaults. removing trucks, buses, and molor homes.

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

Construction: Off-Road Equipment Building construction equipment increased to account for compressed construction schedule, compared to CalEEMod defaults.

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

Table Name Column Name Default Value New Value
tbiConstructionPhase NumDays 230.00 167.00
tbiConstructionPhase PhaseEndDate 11/22/2023 8025/2023
PhaseEndDate 9/27/2023 6/30/2023
tbiConstructionPhase
tb/ConstructionPhase Phase EndDate 10/25/2023 7128/2023 biConstructionPhase PhaseStarDate 10126/2023 7129/2023
Construction Phase Phase StantDate 9/28/2023 7/1/2023
biLandUse LandUseSquareFeet 160,000.00 160,371.00
tbiLandUse SquareFeet 119,000.00 41,155.00
tolLandUse LotAcreage 3.67 3.68

2.73 "274"
tbiLandUse LotAcreage
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.® 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://www.caleemod.com/documents/user- guide/01 User%20Guide.pdf, p. 1.
6 "Video Tutorials for CalEEMod Version 2022.1." CAPCOA, May 2022, available at:
https://www.caleemod.com/tutorials.
3 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).

Phase Name The time Misper Top enide Mix
Demolition -
Demolition Worker 15.0 185 LDA,LDT1,LDT2
Demolition Vendor - 10.2 HHDT.MHDT
Demolition Hauling 1.75 200 HHDT
Demolition Onsile truck - - HHDT
Site Preparation - -
Sile Preparation Worker 17.5 18.5 LDA,LDT1.LDT2
Site Preparation Vendor - 102 HHDT,MHDT
Site Preparation Hauling 0.00 120.0 HHDT
Site Preparation Onsite truck - HHDT
Grading - - -
Grading Worker 20.0 18 Б LDA,LDT1,LDT2
Grading Vendor - 10.2 HHOT,MHOT
Grading Hauling 7.14 200 HHDT
Grading Onsite truck - - HHDT
Building Construction - - - -
Building Construction Worker 142 185 LDA,LDT1,LDT2
Building Construction Vendor 55.4 10.2 HHDT,MHDT
Building Construction Hauling 0.00 20.0 HHDT
Building Construction Onsite truck - - HHDT
Paving - - -
Paving 15.0 18.5 LDA,LDT1,LDT2
Paving - 10.2 HHDT,MHDT

0.00 /20.0 HHDT
HHDT
Architectural Coating -
Archilectural Coating Worker 28.4 18.5 LOA,LDT1,LDT2
Architectural Coating Vendor - 10.2 HHDT.MHDT
Architectural Coating Hauling 0.00 20.0 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).
4 However, review of Google Maps reveals that the El Sobrante Landfill is located approximately 25.4 miles from the Project site (see screenshot below).
33521 Zeiders Rd, Monice CA 92584
Good Hope
10910 Dawson Canyon Rd, Corona, CA S
Add destination
• Leave now •
Meadowbrock
B Send directions to iPhone oa Copy link
via 1-15 N
Fastest route the usua tallie
A This route has restricted usage
.......

Desale
Communiy O
Explore nearby 10910 Dawson Canyon Rd
Village 813521 zelders R
Roslou:anis Metels G3: More
stations
Go gle Wildomar
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? 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
reen
Land Use Project specific conditions per site plan.

Operations Vehicle Data Updatep or Trati enging pater as IP on i a rule eties parking marmodel. assenger vehicle trip length updated based or
Operations: Fleet Mix
emoving trucks, buses. and motor horne
Construction: Construction Phases Specied by Aprican phase compressed to account for 18 month construction timeline as Construction: Off-Road Equipment wilding construction equipment increased to account for compressed construction schedule ompared to CalEEMod default:

Operations: Energy Use
7 "CalEEMod User Guide." CAPCOA, April 2022, available at: https://www.caleemod.com/documents/user- guide/01 User%20Guide.pdf, p. 38.
5 The CalEEMod User's Guide requires any changes to model defaults be justified. 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):

Table 4.17-1: Project Trip Generation
AM Peak Hour PM Peak Hour TOTAL
Vehicle Type' In Total In Out Total
Industrial Park (80%
Vehicle Trips
Cars 66 15 81 18 63 81 757
Trucks 4 7 11 4 12 154
Total 70 22 92 22 93 911
PCE Trips?
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 (20%)
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: Ganddini TIA, Tables 1-3, Project Trip Generation 1 ITE Land Use Code 130 for Industrial Park and ITE Land Use Code 770 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. By including several unsubstantiated changes to the default 8 "CalEEMod User Guide." CAPCOA, April 2022, available at: https://www.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
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
UTM Location Annual Average DPM Excess Cancer Risk
Concentration (ug/m") (per million population)
Receptor Year 2
Year Construction Year 3-30 Year varr
East North Total
Construction and Operation®*)
Operation 4)
PMIC) 483610.00 3721409.00 0.10716 0.03134 0.00229
MEIR 483654.71 3721301.62 0.03465 0.010055 0.00053 5.2 0.2 16.00 Source: MIG, 2024 (see Appendix C)
(A) Year 2 includes emissions from both construction and operational activities. The Year 2 concentration was calculate multiplying the operational concentration in Year 3-30 by the percent of the year that operation occurs in Year 2(50%), anc (B) The annual average DPM operational concentration is based on the first full year of operation (Year 3). (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 0) and infant (age 0 to 2) receptors, and 0.72 for child receptors (age 2 to 16) (see excerpt below) (Appendix E, pp. 399).

Risk Parameter Values by Age Bin
Residential Age Bin
Variable 3rd Trimester 0-2 Years 2-16 Years : 16-30 Years 30-70 Years DBR 361 1090 572 261 233
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
ASF 10
ED 0.25 2 14 54
AT 70 70
FAH 0.85 0.85 0.72 0.73 0.73
7 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 COze/year") (see screenshot below) (p. 4.8-18, Table 4.8-4).

Table 4.8-4: Unmitigated Project Operational GHG Emissions GHG Emissions (MT / Year)
Emission Source Refrigerant
CO2 CHA N2O GHGs COze
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 0.1 190.3
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 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 COze/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.aqmd.gov/docs/default- source/rule-book/Proposed-Rules/1401/riskassessmentprocedures 2017 080717.pdf, p. 7. 8 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/california- code-of-regulations/title-14-natural-resources/division-6-resources-agency/chapter-3-guidelines-for- implementation-of-the-california-environmental-quality-act/article-7-eir-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://oag.ca.gov/system/files/media/warehouse-best-practices.pdf. p. 8-10. 9 • 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. ' 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.aqmd.gov/docs/default- source/ceqa/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://casetext.com/regulation/california-code-of-regulations/title-14-natural-resources/division-6-resources- agency/chapter-3-guidelines-for-implementation-of-the-california-environmental-quality-act/article-9-contents-of- environmental-impact-reports/section-151264-consideration-and-discussion-of-mitigation-measures-proposed-to- minimize-significant-effects.
15 "Cal. Pub. Resources Code § 21168.6.7." 2023, available at: https://casetext.com/statute/california- codes/california-public-resources-code/division-13-environmental-quality/chapter-6-limitations/section-2116867- oakland-sports-and-mixed-use-project-conditions-for-approval-certification-of-project-for-streamlining. 10 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,
Matt Hagemann, P.G., C.Hg.

Paul Renfeld
Paul E. Rosenfeld, Ph.D.

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

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

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 and Sequestered Emissions by Species - Mitigated

5. Activity Data

5.1. Construction Schedule
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Menifee (Pemcor) Business Park Detailed Report, 9/17/2025

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

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 Details

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

8. User Changes to Default Data
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Menifee (Pemcor) Business Park Detailed Report, 9/17/2025

1. Basic Project Information

1.1. Basic Project Information
Data Field Value
Project Name Menifee (Pemcor) Business Park
Construction Start Date 1/1/2025
Lead Agency
Land Use Scale Project/site
Analysis Level for Defaults County
Windspeed (m/s) 2.50
Precipitation (days) 18.6
Location 33521 Zeiders Rd, Menifee, CA 92584, USA
County Riverside-South Coast
City Menifee
Air District South Coast AQMD
Air Basin South Coast
TAZ 5536
EDFZ 11
Electric Utility Southern California Edison
Gas Utility Southern California Gas
App Version 2022.1.1.30

1.2. Land Use Types
Land Use Subtype Size Unit Lot Acreage Building Area (sq ft) Landscape Area (sq Special Landscape Population Description Area (sq ft)
Industrial Park 338 1000sqft 7.09 337,770 0.00
Parking Lot 12.9 Acre 12.0 0.00 0.00
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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 (Ib/day for daily, ton/yr for annual) and GHGs (Ib/day for daily, MT/yr for annual) Un/Mit. TOG PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N20 C02e 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 1 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

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 (Ib/day for daily, ton/yr for annual) and GHGs (Ib/day for daily, MT/yr for annual) PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N20 CO2e 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 (Ib/day for daily, ton/yr for annual) and GHGs (Ib/day for daily, MT/yr for annual) 8/52
Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 Year TOG ROG NOX co SO2 PM10E PM10D PM10T PM2.5E PM2.50 PM2.5T BCO2 NBCO2 CO2T CH4 N20 coze 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 0.35 122 7,542 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 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 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 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 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 0.20 294

3. Construction Emissions Details

3.1. Demolition (2025) - Unmitigated
Criteria Pollutants (Ib/day for daily, ton/yr for annual) and GHGs (Ib/day for daily, MT/yr for annual) Location TOG ROG NOX co PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N20 co2e Onsite 1 1 1
Daily,
Summer
(Max)
Daily, -
Winter
(Max)
9 / 52
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 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
Oft-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 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
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 0.01 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 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 (Ib/day for daily, ton/yr for annual) and GHGs (Ib/day for daily, MT/yr for annual) Location TOG PM10E PM10D PM10T PM2.5E P2.50PM2.5TBCO2 NBCO2 CO2T 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 Equipm
Demoliti - 0.15 0.15 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
Average -
Daily
11 / 52
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 Equipm

0.01 0.01 < 0.005 < 0.005
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 Equipm
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 1
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 1 152 152 < 0.005 0.02 0.01 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 1 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
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 1.38 1.38 < 0.005 < 0.005 < 0.005 1.45

3.3. Site Preparation (2025) - Unmitigated
Criteria Pollutants (Ib/day for daily, ton/yr for annual) and GHGs (Ib/day for daily, MT/yr for annual) Location TOG PM10E PM1OD PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CO2e Onsite - 1
:

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 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 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
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 Equipm
Dust 0.10 0.10 0.05 0.05
From
Material
Movemert
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

3.4. Site Preparation (2025) - Mitigated
14/52
Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 Criteria Pollutants (Ib/day for daily, ton/yr for annual) and GHGs (Ib/day for daily, MT/yr for annual) Location TOG ROG NOX cO S02 PM10E PMOD PMOT PM25E PM2.50 PM2.5T BCO2 NBCO2 COZTCH4 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 Equipm
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 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 Equipm
15/52
Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 Dust 0.10 0.10 0.05 0.05
From
Material
Movemert
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 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 (Ib/day for daily, ton/yr for annual) and GHGs (Ib/day for daily, MT/yr for annual) Location TOG ROG NOX co SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N20 Co2e Onsite - - - 1
16 / 52
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 Equipm
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 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 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
Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 Annual -
Off-Roa 0.07 0.53 <0.005 0.02 0.02 0.02 0.02 108 108 < 0.005 < 0.005 — 108 Equipm
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,
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 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
Menifee (Pemcor) Business Park Detailed Report, 9/17/2025

3.6. Grading (2025) - Mitigated
Criteria Pollutants (Ib/day for daily, ton/yr for annual) and GHGs (Ib/day for daily, MT/yr for annual) Location TOG NOx S02 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N20 CO2e 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 Equipm
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 Equipm

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 Equipm
19 / 52
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 Equipm
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 L00 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
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 (Ib/day for daily, ton/yr for annual) and GHGs (Ib/day for daily, MT/yr for annual) Location TOG PM10E PM1OD PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 C02e 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 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 Equipm
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 Equipm
21 / 52
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 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 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 1 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 1 1
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
Menifee (Pemcor) Business Park Detailed Report, 9/17/2025

3.8. Building Construction (2025) - Mitigated
Criteria Pollutants (Ib/day for daily, ton/yr for annual) and GHGs (Ib/day for daily, MT/yr for annual) Location TOG S02 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N20 CO2e 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 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 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 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 Equipm
23 / 52
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 (Ib/day for daily, ton/yr for annual) and GHGs (Ib/day for daily, MT/yr for annual) Location TOG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 INBCO2 Onsite -
24/52
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 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 Equipm
ent
Onsite 0.00 0.00 0.00 0.00 0.00 0.00 0.00 1 0.00 0.00 0.00 0.00 0.00 0.00 truck
Average — 1
Daily
Off-Roa 0.41 0.34 3.16 4.16 0.01 1 770 770 0.03 0.01 773 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 truck
Annual 1 1
Off-Roa 0.07 0.06 0.58 0.76 < 0.005 0.02 0.02 0.02 0.02 1 127 127 0.01 <0.005 — 128 Equipm
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
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 1 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 (Ib/day for daily, ton/yr for annual) and GHGs (Ib/day for daily, MT/yr for annual) Location TOG ROG NOX s02 PM10E PMIOD PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N20 coze Onsite
Daily, 1
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 Equipm
ent
26 / 52
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 Equipm
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 Equipm
ent

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Insite 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 Equipm
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, 1
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
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 (Ib/day for daily, ton/yr for annual) and GHGs (Ib/day for daily, MT/yr for annual) Location TOG ROG so2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBC02 CO2T 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 Equipm
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 truck
Daily,
Winter
(Max)
Average - 1
Daily
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 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, 1
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 1 0.00 0.00 0.00 0.00 0.00 0.00 Annual 1
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
Menifee (Pemcor) Business Park Detailed Report, 9/17/2025

3.12. Paving (2026) - Mitigated
Criteria Pollutants (Ib/day for daily, ton/yr for annual) and GHGs (Ib/day for daily, MT/yr for annual) Location TOG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T|BCO2 NBCO2 CO2T CH4 N20 CO2e 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 Equipm
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 Equipm
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 Equiom
ent
Paving 0.02 0.02 -
To cos aso
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
Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 Offsite 1
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

3.13. Architectural Coating (2026) - Unmitigated
Criteria Pollutants (Ib/day for daily, ton/yr for annual) and GHGs (Ib/day for daily, MT/yr for annual) Location TOG PM10E PM10D PM10T PM2.5EPM2.5D PM2.5T|BCO2 NBCO2 COLT 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 Equipm
31 / 52
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 Equipm
ent
Architect 8.98 8.98
ural
Coating
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 Equipm
Architect 1.64 1.64
ural
Coating
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
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 (Ib/day for daily, ton/yr for annual) and GHGs (Ib/day for daily, MT/yr for annual) Location TOG ROG NOX co SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N20 co2e 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 Equipm
ent
Architect 22.9 22.9
ural
Coating
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
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 Equipm
ent
Architect 1.26 1.26
ural
Coating
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 Equipom
Architect 0.23 0.23
Coating
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
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 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

4. Operations Emissions Details

4.10. Soil Carbon Accumulation By Vegetation Type

4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated Criteria Pollutants (Ib/day for daily, ton/yr for annual) and GHGs (Ib/day for daily, MT/yr for annual) Vegetati TOG ROG NOX S02 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 COLT CH4 N20 CO2e on
Daily, -
Summer
(Max)
Total - - 1 1
Daily, 1 1 1
Winter
(Max)
Total
Annual -
Total 1 -

4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated 35 / 52
Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 Criteria Pollutants (Ib/day for daily, ton/yr for annual) and GHGs (Ib/day for daily, MT/yr for annual) Land TOG ROG NOX co SO2
Use
Daily,
Summer
(Max)
Total - - -
Daily, - - 1
Winter
(Max)
Total - - -
Annual -
Total

4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated Criteria Pollutants (Ib/day for daily, ton/yr for annual) and GHGs (Ib/day for daily, MT/yr for annual) Species TOG PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 COZT |CHA N20 R Daily, - - -
Summer
(Max)
Avoided -
Subtotal - 1 1
Sequest -
ered
Subtotal - 1 1 -
Remove -
Subtotal -
1 1 1
Daily,
Winter
(Max)
36 / 52
Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 Avoided - -
Subtotal —
Sequest - -
ered
Subtotal - 1
Remove -
Subtotal -
1 Annual - -
Avoided - 1 1 1 1
Subtotal - 1
Sequest -
ered
Subtotal - 1
Remove -
Subtotal - -
- 1

4.10.4. Soil Carbon Accumulation By Vegetation Type - Mitigated Criteria Pollutants (Ib/day for daily, ton/yr for annual) and GHGs (Ib/day for daily, MT/yr for annual) Daily, 1 1 -
Summer
(Max)
Total -
Daily, -
Winter
(Max)
37 / 52
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 (Ib/day for daily, ton/yr for annual) and GHGs (Ib/day for daily, MT/yr for annual) PM10E PM10D PM10T PM2.5E PM2.5D CH4
Daily, -
Summer
(Max)
Total
Daily, 1 1 1 1 1
Winter
(Max)
Total 1
Annual - -
Total -

4.10.6. Avoided and Sequestered Emissions by Species - Mitigated Criteria Pollutants (Ib/day for daily, ton/yr for annual) and GHGs (Ib/day for daily, MT/yr for annual) Species TOG S02 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 Daily,
Summer
(Max)
Avoided -
Subtotal -
Sequest - - -
ered
Subtotal -
38 / 52
Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 Remove -
Subtotal - 1
Daily,
Winter
(Max)
Avoided - 1 1
Subtotal -
Sequest —
ered
Subtotal -
Remove -
Subtotal -
TETIT
Annual
1 LIT
Avoided 1
Subtotal - 1 IlLLLIII ILLLLII
| | | 1 1 1
Sequest —
ered 1 1
Subtotal -
Remove -
I 11 | 1 1 |
Subtotal - | |
| | 1 |

5. Activity Data

5.1. Construction Schedule
39 / 52
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 PavingR 5/6/2026 6/2/2026 5.00 20.0
Architectural Coating Architectural Coating 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
Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 Building Construction Tractors/Loaders/Back Diesel Average 4.00 6.90 84.0 0.37 Paving Pavers Diesel Average 2.00 8.00 81.0 0.42
Paving Paving Equipment Diesel Average 2.00 8.00 89.0 0.36 Paving Rollers Diesel Average 2.00 8.00 36.0 0.38
Architectural Coating Air Compressors Diesel Average 1.00 6.00 37.0 0.48

5.2.2. Mitigated
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 Building Construction Tractors/Loaders/Back Diesel Average 4.00 6.90 84.0 0.37 hoes
Paving Pavers Diesel Average 2.00 8.00 81.0 0.42
Paving Paving Equipment Diesel Average 2.00 8.00 89.0 0.36 41/52
Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 Paving Rollers Diesel Average 2.00 8.00 36.0 0.38
Architectural Coating Air Compressors Diesel Average 1.00 6.00 37.0 0.48

5.3. Construction Vehicles

5.3.1. Unmitigated
Phase Name Trip Type One-Way Trips per Day Miles per Trip Vehicle Mix Demolition
Demolition 15.0 18.5 LDA, LDT1,LDT2
Demolition 10.2 HHDT,MHDT
Demolition 1.75 25.4 HHDT
Demolition 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
GradingR
GradingR 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
Building Construction Worker 142 18.5 LDA,LDT1,LDT2
Building Construction Vendor 55.4 10.2 HHDT.MHDT
Building Construction Hauling 0.00 25.4 HHDT
Building Construction Onsite truck HHDT
Paving
42 / 52
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 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
Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 Building Construction Worker 142 18.5 LDA,LDT1,LDT2
Building Construction Vendor 55.4 10.2 HHDT,MHDT
Building Construction Hauling 0.00 25.4 HHDT
Building Construction Onsite truck HHDT
Paving
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,

5.4. Vehicles

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

5.5. Architectural Coatings
Phase Name Residential Interior Area Residential Exterior Area Non-Residential Interior Area Non-Residential Exterior Area Parking Area Coated (sq ft) Coated (sq ft) Coated (sq ft) Coated (sq ft) Coated (sq ft) Architectural Coating 0.00 0.00 506,655 168,885 31,363

5.6. Dust Mitigation

5.6.1. Construction Earthmoving Activities
44/52
Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 Phase Name Material Imported (cy) Material Exported (cy) Acres Graded (acres) Material Demolished (Building Acres Paved (acres) Square Footage)
Demolition 0.00 0.00 0.00 3,000
Site Preparation 15.0 0.00
Grading 2,000 105 0.00
Paving 0.00 0.00 0.00 0.00 12.0

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

5.7. Construction Paving
Land Use Area Paved (acres) % Asphalt
Industrial Park 0.00 0%
Parking Lot 12.0 100%

5.8. Construction Electricity Consumption and Emissions Factors kWh per Year and Emission Factor (Ib/Wh)
Year kWh per Year CO2 CH4 N20
2026 0.00 532 0.03 < 0.005
2025 0.00 532 0.03 < 0.005

5.18. Vegetation

5.18.1. Land Use Change

5.18.1.1. Unmitigated
Vegetation Land Use Type Vegetation Soil Type Initial Acres Final Acres 45 / 52
Menifee (Pemcor) Business Park Detailed Report, 9/17/2025

5.18.1.2. Mitigated
Vegetation Land Use Type Vegetation Soil Type Initial Acres Final Acres

5.18.1. Biomass Cover Type

5.18.1.1. Unmitigated
Biomass Cover Type Initial Acres Final Acres

5.18.1.2. Mitigated
Biomass Cover Type Initial Acres Final Acres

5.18.2. Sequestration

5.18.2.1. Unmitigated
Tree Type Number Electricity Saved (kWh/year) Natural Gas Saved (btu/year)

5.18.2.2. Mitigated
Tree Type Number Electricity Saved (kWh/year) Natural Gas Saved (btu/year)

6. Climate Risk Detailed Report

6.1. Climate Risk Summary
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 Result for Project Location Unit
Temperature and Extreme Heat 27.6 annual days of extreme heat Extreme Precipitation 2.85 annual days with precipitation above 20 mm 46 / 52
Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 Sea Level Rise meters of inundation depth
Wildfire 8.86 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 20mm is equivalent to about ¾ 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 Adaptive Capacity Score Vulnerability Score Temperature and Extreme Heat N/A
Extreme Precipitation N/A N/A N/A N/A
Sea Level Rise N/A
Wildfire N/A
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 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 expo sapaiy of a project refers to is bly to manage and reduce vinerabilies from projected dimate hazards. Adaptive capacily 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
47 / 52
Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 Extreme Precipitation N/A N/A N/A N/A
Sea Level Rise
Wildfire
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
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 pive sapacity of a project refers to is abily 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
48/52
Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 CleanUp Sites 0.00
Groundwater 0.00
Haz Waste Facilities/Generators 50.1
Impaired Water Bodies 0.00
Solid Waste 35.7
Sensitive Population
Asthma 42.6
Cardio-vascular 93.2
Low Birth Weights 14.2
Socioeconomic Factor Indicators -
Education 40.1
Housing 23.4
Linguistic 1.81
Poverty 34.0
Unemployment 59.4

7.2. Healthy Places Index Scores
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.

Indicator Result for Project Census Tract
Economic
Above Poverty 54.26664956
Employed 19.64583601
Median HI 50.78916977
Education
Bachelor's or higher 38.73989478
High school enrollment 100
Preschool enrollment 43.68022584
Transportation
49 / 52
Menifee (Pemcor) Business Park Detailed Report, 9/17/2025 Auto Access 76.73553189
Active commuting 4.49121006
Social
2-parent households 67.88143205
Voting 54.67727448
Neighborhood
Alcohol availability 92.14679841
Park access 14.78249711
Retail density 8.161170281
Supermarket access 11.13820095
ree сапору 6.146541768
Housing
Homeownership 90.85076351
Housing habitability 68.00975234
Low-inc homeowner severe housing cost burden 23.40562043 Low-inc renter severe housing cost burden 33.82522777
Uncrowded housing 75.52932119
Health Outcomes
Insured adults 75.63197742
Arthritis 11.1
Asthma ER Admissions 66.8
High Blood Pressure 20.6
Cancer (excluding skin) 18.5
Asthma 37.3
Coronary Heart Disease 13.8
Chronic Obstructive Pulmonary Disease 17.9
Diagnosed Diabetes 51.3
Life Expectancy at Birth 48.3
50 / 52
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
51 / 52
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 3: The maximum Cel lace necoe 10. A god lo, a ta han real etrior on unty onions or pare trier an is hat 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 Justification
Land Use Consistent with DEIR.

Construction: Construction Phases Consistent with DEIR.

Construction: Off-Road Equipment Consistent with DEIR.

Construction: Dust From Material Movement Consistent with DEIR.

Construction: Trips and VMT See comment on: "Incorrect Construction Hauling Trip Length". 52 / 52
Attachment B
Technical Consultation, Data Analysis and
SWAPE Litigation Support for the Environment
2656 29th Street, Suite 201
Santa Monica, CA 90405
(949) 887-9013
[email protected]
Matthew F. Hagemann, P.G., C.Hg.

Geologic and Hydrogeologic Characterization, Investigation and Remediation Strategies • Industrial Stormwater Compliance
• CEQA Review
• 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 (CRA) and directed efforts to improve hydrogeologic characterization and water quality monitoring. For the past 15 years, as a founding partner with SWAPE, 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 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 Regulatory and Litigation Support Analyst:

With SWAPE, 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, CERCLA compliance 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 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.

Reviewed and wrote "part B" permits for the disposal of hazardous waste.

Conducted RCRA Corrective Action investigations of waste sites and led inspections that formed the basis for significant enforcement actions that were developed in close coordination with U.S.EPA legal counsel.
3 • 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:
• 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.

Policy:

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 MTBE 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.
4 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 from 2010 t 2014 and in 2017.

Summary of Testimony Experience 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-c0-14766-RMB-JBC. Deposition in 2025.

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

In Re Edmond Asher, et al., us. RTX Corporation (fik/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 us Consolidated Rail Corporation In the Circuit Court of Cook County, Illinois, Case No: 21L.3966.

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-C0-326. 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 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 (G]Sx). 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-c0-05287-JST. Deposition in 2019. Expert witness representing Plaintiff in matters involving contaminated stormwater runoff at an industrial facility in Eureka, California.

Bells et al. Us. 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 us. 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.

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

Hagemann, M.E., 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.E., 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 of MTBE 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 AddressImpacts to Groundwater. Presentation to the annual meeting of the Society of Environmental Journalists.

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

Hagemann, M.E., 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. lagemann, M.F., 2001. Estimated Cleanup Cost for MTBE in Groundwater Used as Drinking Water Inpublished report
Hagemann, M.F., 2001. Estimated Costs to Address MTBE Releases from Leaking Underground StorageTanks. 7 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.E., 1997, The Potential for MIBE 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 Chlorinated Hydrocarbons, Salt Lake City.

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

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

Hagemann, M.E., 1994. Groundwater Characterization 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 Attachment C
Teston spot or a rani and SOIL, WATER AIR PROTECTION ENTERPRISE SWAPE 2656 29th Street, Suite 201
Santa Monica, California 90405
Attn: Paul Rosenfeld, Ph.D.

Mobil: (310) 795-2335
Office: (310) 452-5555
Fax: (310) 452-5550
Email: [email protected]
Paul Rosenfeld, Ph.D. Chemical Fate and Transport & Air Dispersion Modeling Principal Environmental Chemist Risk Assessment & Remediation Specialist Education
Ph.D. Soil Chemistry, University of Washington, 1999. Dissertation on volatile organic compound filtration.

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

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

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

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

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

Paul E. Rosenfeld, Ph.D. Page 1 of 17 March 2025
Professional History:

Soil Water Air Protection Enterprise (SWAPE); 2003 to present; Principal and Founding Partner UCLA School of Public Health; 2007 to 2011; Lecturer (Assistant Researcher) UCLA School of Public Health; 2003 to 2006; Adjunct Professor UCLA Environmental Science and Engineering Program; 2002-2004; Doctoral Intern Coordinator UCLA Institute of the Environment, 2001-2002; Research Associate Komex H2O Science, 2001 to 2003; Senior Remediation Scientist National Groundwater Association, 2002-2004; Lecturer
San Diego State University, 1999-2001; Adjunct Professor Anteon Corp., San Diego, 2000-2001; Remediation Project Manager Ogden (now Amec), San Diego, 2000-2000; Remediation Project Manager Bechtel, San Diego, California, 1999 - 2000; Risk Assessor King County, Seattle, 1996 - 1999; Scientist
James River Corp., Washington, 1995-96; Scientist
Big Creek Lumber, Davenport, California, 1995; Scientist Plumas Corp., California and USFS, Tahoe 1993-1995; Scientist Peace Corps and World Wildlife Fund, St. Kitts, West Indies, 1991-1993; Scientist Publications:

Rosenfeld, P.E., Spaeth, K.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/s11270-023-06863-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/s11270-023-06165-3 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.

Paul E. Rosenfeld, Ph.D. Page 2 of 17 March 2025
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: Bes ractices 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. var or wod treatment acities in the United Saxes, and transacd ipod conlotra in in populations livin 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 Tw 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.
enslev, A.R. A. Scott, J. J. J. Clark, Rosenfeld, P.E. (2007). Attic Dust and Human Blood Samples Collected ne Former Wood Treatment Facility. Environmental Research. 105. 194-19* 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.
for The Urban Environment water sure de vol Technical Billion Wand olice on Seen 2004. New Orleans, October 2-6, 2004.

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

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

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

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

Paul E. Rosenfeld, Ph.D. Page 3 of 17 March 2025
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 Of Biogas 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.

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, Atrazine: A Persistent Pesticide Urban Drinking 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, Rosenfeld, Bringing Environmental Justice to
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 Paul E. Rosenfeld, Ph.D. Page 4 of 17 March 2025
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.
populations Twin, ear our rod realmen facia ly to nited skies nd Etin, Cod pid concentration in.

Pollution XVII: Proceedings of the Seventeenth International Conference on Modeling, Monitoring and Management of Air Pollution. Lecture conducted from Tallinn, Estonia. acented e 0 Octal -18. 2007) ferences Sis Seen sure Water: Pation lecture outed a acility. The 23rd-
University of Massachusetts, Amherst MA.

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

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

Hotel in Oslo Norway.

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

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

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

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

Emerging Ordinan. (Sefence, 19, 205, date, from prit, Toil, And Pocalitence of 12,3-TCP. PEMA 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.

Inter aromat so pay D. wit i-mental Forensics: Focus on Emerging nee of paris. Indure cod Chen col. Paul Rosenfeld Ph.D. (June 7-8, 2005). Fate, Sheraton Oceanfront Hotel, Virginia Beach, Virginia.

Paul E. Rosenfeld, Ph.D. Page 5 of 17 March 2025
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.

Drycleaner Symposium. California Ground Water Association. Lecture conducted from Radison Hotel, Sacramento, California.

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

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

Paul Rosenfeld, Ph.D. (February 6-7, 2003). Underground Storage Tank Litigation and Remediation. California CUPA Forum. Lecture conducted from Marriott Hotel, Anaheim California. aul Rosenfeld, Ph.D. (October 23, 2002) Underground Storage Tank Litigation and Remediation. EP nderground Storage Tank Roundtable. Lecture conducted from Sacramento Californi Palestial Processed Suth mal Simpsim on 2002) Worses and quador om Com. I atomate and 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.

Paul E. Rosenfeld, Ph.D. Page 6 of 17 March 2025
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 Biosolds 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.

Mexico May 21, War. ouse on ate ans transport or tion contamingies ate it eidergre trage.

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

California Integrated Waste Management Board, April and May 2001. Alternative Landfill Caps Seminar in San Diego, Ventura, and San Francisco. Focused on both prescriptive and innovative landfill cover design.

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

University Of Washington, Soil Science Program, Teaching Assistant for several courses including Soil Chemistry, Organic Soil Amendments, and Soil Stability
U.C. Berkeley, Environmental Science Program Teaching Assistant for Environmental Science 10.

Academic Grants Awarded:

Califoria Integrated Waste Management Board. $41,000 grant awarded to UCLA Institute of the Environment Joal: To investigate the effect of high carbon wood ash on volatile organic emissions from compost. 2001 Paul E. Rosenfeld, Ph.D. Page 7 of 17 March 2025
Synagro Technologies, Corona California: $10,000 grant awarded to San Diego State University.

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

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

Northwest Biosolids Management Association, Washington State. $20,000 grant awarded to investigate 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 Corp
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
Tin 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
Paul E. Rosenfeld, Ph.D. Page 8 of 17 March 2025
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 Deposition 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
Paul E. Rosenfeld, Ph.D. Page 9 of 17 March 2025
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 isuitey al Li. Castin Pact Mailway and Soo Lind Railroad Case No. 28LV-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 Conrai
Case No. No. 2032L003966
Rosenfeld Deposition 6-13-2023
In the Ciruin Belle s. Biminghac Phiuden is ofoad con anyny Alabama, Case No. 01-cv-2021-900901.00
Rosenfeld Deposition 4-6-2023
Paul E. Rosenfeld, Ph.D. Page 10 of 17 March 2025
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. 3:17-cv-01192
Rosenfeld Deposition 1-18-2023
In United States District Court District of Colorado
Gonzales vs. BNSF
Case No. 1:21-cv-01690
Rosenfeld Deposition 1-17-2023
In United States District Court District of Colorado
Abeyta vs. BNSF
ase No. 1:21-cv-01689-KM
Losenfeld Deposition 1-3-202
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 Supiy Wildick, Paint vs. BF Rai voy oF Say Bermardino Case No. CIVDS1711810
Rosenfeld Deposition 10-17-2022
Case No. 10-SCCV-092007
Rosenfeld Deposition 10-6-2022
the Civil District Court of the Parish of Orleans, State of Louisia illard Clark. Plaintiff vs. Dixie Carriers. Inc. et
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 March 2025
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. CS 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 Plaintiff vs. 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 Kern George LaFazia vs. BNSF Railway Company.

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

Case No. 2020-L-000550
Rosenfeld Deposition 4-16-2022
In United States District Court Easter District of Florida Albert Hartman Plaintiff vs. Illinois Centra
Case No. 2:20-cv-1633
Rosenfeld Deposition 4-4-2022
In the Circuit Court of the 4" Judicial Circuit, in and For Duval County, Florida Barbara Steele vs. CS Transportation
Paul E. Rosenfeld, Ph.D. Page 12 of 17 March 2025
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 Eadus vs. Soo Line Railroad and BNSF
Case No. DV 19-1056
Rosenfeld Deposition 10-21-2021
In the Circuit Court Of The Twentieth Judicial Circuit, St Clair County, Illinois Martha Custer et al. vs Cerro Flow Products, Inc.

Case No. 0i9-L-2295
Rosenfeld Deposition 5-14-2021
Trial October 8-4-2021
n the Circuit Court of Cook County Illinoi
oseph Rafferty vs. Consolidated Rail Corporation and National Railroad Passenger Corporation d/b/

AMTRAK,
Case No. 18-L-6845
Rosenfeld Deposition 6-28-2021
In the United States District Court For the Northern District of Illinois Paul B. Rosenfeld, Ph.D. Page 13 of 17 March 2025
Theresa Romcoe vs. Northeast Illinois Regional Commuter Railroad Corporation d/b/a METRA Rail Case No. 17-cv-8517
Rosenfeld Deposition 5-25-2021
In the Superior Court of the State of Arizona In and For the Cunty of Maricopa Mary Tryon et al. vs. The City of Pheonix v. Cox Cactus Farm, L.L.C., Utah Shelter Systems, Inc.

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

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

Case No. 1720288
Rosenfeld Deposition 2-23-2021
in the Superior Court of the State of California, County of Los Angeles, Spring Street Courthous Benny M Rodriguez vs. Union Pacific Railroad, A Corporation, et al Case No. 18STCV01162
Rosenfeld Deposition 12-23-2020
In the Circuit Court of Jackson County, Missouri
Karen Cornwell, Plaintiff, vs. Marathon Petroleum, LP, Defendant.

Case No. 1716-CV10006
Rosenfeld Deposition 8-30-2019
In the United States District Court For The District of New Jersey Duarte et al, Plaintiffs, vs. United States Metals Refining Company et. al. Defendant.

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

Case No. 3:15-CV-00106 consolidated with 3:15-CV-00237
Rosenfeld Deposition 5-9-2019
In The Superior Court of the State of California In And For The County Of Los Angeles - Santa Monica Carole-Taddeo-Bates et al., vs. Ifran Khan et al., Defendants Case No. BC615636
Rosenfeld Deposition 1-26-2019
In The Superior Court of the State of California In And For The County Of Los Angeles - Santa Monica The San Gabriel Valley Council of Governments et al. vs El Adobe Apts. Inc. et al., Defendants Case No. BC646857
Rosenfeld Deposition 10-6-2018; Trial 3-7-19
In United States District Court For The District of Colorado Bells et al. Plaintiffs vs. The 3M Company et al., Defendants Case No. 1:16-cv-02531-RBJ
Rosenfeld Deposition 3-15-2018 and 4-3-2018
In The District Court Of Regan County, Texas, 112ü Judicial District Phillip Bales et al., Plaintiff vs. Dow Agrosciences, LLC, et al., Defendants Paul E. Rosenfeld, Ph.D. Page 14 of 17 March 2025
Cause No. 1923
Rosenfeld Deposition 11-17-2017
In The Superior Court of the State of California In And For The County Of Contra Costa Simons et al., Plaintifs vs. Chevron Corporation, et al., Defendants Cause No. C12-01481
Rosenfeld Deposition 11-20-2017
In The Circuit Court of The Twentieth Judicial Circuit, St Clair County, Illinois Martha Custer et al., Plaintiff vs. Cerro Flow Products, Inc., Defendants Case No.: No. 0i9-L-2295
Rosenfeld Deposition 8-23-2017
In United States District Court For The Southern District of Mississippi Guy Manuel vs. The BP Exploration et al., Defendants
Case No. 1:19-cv-00315-RHW
Rosenfeld Deposition 4-22-2020
In The Sular Gilbert at Penny of Car, Plain fovs. Count ort Anita LIC 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-JVM
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. RG14711115
Rosenfeld Deposition September 2015
In The Iowa District Court In And For Poweshiek County
Russell D. Winburn, et al., Plaintiffs vs. Doug Hoksbergen, et al., Defendants Case No. LALA002187
Rosenfeld Deposition August 2015
In The Circuit Court of Ohio County, West Virginia
Robert Andrews, et al. 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 Rosenfeld Deposition May 2015
In the Circuit Court of the 17ih Judicial Circuit, in and For Broward County, Florid Walter Hinton, et. al. Plaintiff, vs. City of Fort Lauderdale, Florida, a Municipality, Defendant Paul E. Rosenfeld, Ph.D. Page 15 of 17 March 2025
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-B
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, LHB
Rosenfeld Deposition: May 2014
In the Circuit Court of Baltimore County Maryland
Philip E. Cvach, Il 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 56th Judicial 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.

Rosenfeld Deposition: February 2012
Rosenfeld Trial: April 2013
In the United States District court of Southern District of Califoria 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
1 the United States District Court for the Middle District of Alabama, Northern Divisio ames K. Benefield, et al., Plaintiffs, vs. International Paper Company, Defendar Paul E. Rosenfeld, Ph.D. Page 16 of 17 March 2025
Civil Action No. 2:09-cv-232-WHA-TFM
Rosenfeld Deposition July 2010, June 2011
Paul E. Rosenfeld, Ph.D. Page 17 of 17 March 2025

BLUM, COLLINS & HO LLP

ATTORNEYS AT LAV
10250 CONSTELLATION BOULEVARI
SUITE 2300
LOS ANGELES, CALIFORNIA 90067
(213) 572-0400
September 24, 2025
Russell Brown Via Email to:

AICP, Senior Planner [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.

Russell Brown
September 24, 2025

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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 SWAPE.

According to CalEnviroScreen 4.0', 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 state? 2. Ozone can cause lung irritation, inflammation, and worsening of existing chronic health conditions, even at low levels of exposure?. Exhaust fumes contain toxic chemicals that can damage DNA, cause cancer, make breathing difficult, and cause low weight and premature births*.

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 people. Solid waste facilities can expose people to hazardous chemicals, 'https://experience.arcgis.com/experience/11d2f52282a54ceebcac7428e6184203/page/CalEnviroScreen- A OFFHA Traffic hts//ocha.ca.zov/calenviroseren/indicator/ratic-density 3ОЕННА Ozone https://oehha.ca.gov/calenviroscreen/indicator/air-quality-ozone 4ОЕННА Traffic https://oehha.ca.gov/calenviroscreen/indicator/traffic-density S OEHHA Hazardous Waste Generators and Facilities
https://oehha.ca.gov/calenviroscreen/indicator/hazardous-waste-generators-and-facilities Russell Brown
September 24, 2025

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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 populations.

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 care. Poor communities are often located in areas with high levels of pollution. Poverty can cause stress that weakens the immune system and causes people to become ill from pollution?. 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 softwares!° 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 website!! and the LCI (formerly OPR) CEQAnet database!?. 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 6ОЕННА Solid Waste Facilities https://oehha.ca.gov/calenviroscreen/indicator/solid-waste-sites-and- facilities
ТОЕННА Poverty https://oehha.ca.gov/calenviroscreen/indicator/poverty 8 Ibid.
9 Ibid.
10 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
I Menifee Pemcor DEIR Compiled Appendices
https://www.cityofmenifee.us/DocumentCenter/View/24074/DEIR-Appendices- https://www.cityofmenifee.us/DocumentCenter/View/24074/DEIR-Appendices- 12 Menifee Pemcor DEIR Appendices via CEQAnet https://files.ceqanet.lci.ca.gov/303525- 3/attachment/nAju2TOvzveJvArb0k-A iV7VmUhZrp5bTNbjZpl7mehznEXuGkWm- 73X50z8q2S98 CGtGVXjVNdWwBO
Russell Brown
September 24, 2025

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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 Element'3 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/SCS'4. 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:

1. 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/DocumentCenter/View/14701/FINAL_Land-Use-Element_11322 14https://scag.ca.gov/sites/default/files/2024-05/23-2987-connect-socal-2024-final-complete-040424.pdf Russell Brown
September 24, 2025

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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.

Russell Brown
September 24, 2025

Page 6 ends

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 (SCAQMD), 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.

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 I-215 where LOS E 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) 330'5/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/billTextClient.xhtml?billid=201920200SB330 16 SB 8 https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=202120220SB8 Russell Brown
September 24, 2025

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acre!?. The approximately 20.3 acre project site can accommodate the development of up 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 of residential 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)(1)(A) requires that agencies shall not "change the general plan land use designation, specific plan land use designation, or zoning to a less intensive use below what was allowed under the land use designation and zoning ordinances in effect at the time of the proposed change." Under Government Code Section 66300(b)(1)(A), a "less intensive use" includes, but is not limited to, reductions to height, density, or floor area ratio, new or increased open space or lot size requirements, or new or increased setback requirements, minimum frontage requirements, or maximum lot coverage limitations, or any other action that would individually or cumulatively reduce residential development capacity. Pursuant to SB 330, replacement capacity for any displaced residential units must be provided concurrently at the time of project approval.

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)(1) states that, "this section does not prohibit an affected county or an affected city, including the local electorate acting through the initiative process, from changing a land use designation or zoning ordinance to a less intensive use, or reducing the intensity of land use, if the city or county concurrently changes the development standards, policies, and conditions applicable to other parcels within the jurisdiction to ensure that there is no net loss in residential capacity." 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)(1) requiring concurrent approval of replacement 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/DocumentCenter/View/14675/3_LU-4_FINAL 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 Russell Brown
September 24, 2025

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generation contributes directly to analysis of the problem at hand. A revised EIR must be prepared and recirculated to include the methodology for calculating employment generation 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)).

SCAG's Connect SoCal Demographics and Growth Forecast & notes that the City will add 8,500 jobs between 2019 - 2035. Utilizing the SCAG Employment Density Study calculation of 553 employees, the project represents 3.5% of the City's employment growth from 2019 - 2035. A single project accounting for this amount of the projected employment growth over 26 years represents a significant amount of growth. A revised EIR must be prepared to include this analysis, and also provide a cumulative analysis discussion of projects approved since 2019 and projects 'in the pipeline" to determine the City's progress towards SCAG's employment growth forecast for the City. For example, other recent industrial projects!° such as Menifee Commerce Center (2,885 employees), Menifee Commerce Center Phase II (1,962 employees), Northern Gateway Commerce Center (2,267 employees), Ares Warehouse on Murrieta (952 employees), Capstone Industrial (1,205 employees), Wheat Warehouse (151 employees), Corsica Business Park (477 employees), Trumble and Watson Warehouse (571 employees), McLaughlin San Jacinto Warehouses (846 employees), Mapes and Sherman Warehouse (478 employees), United Carports Warehouse (105 employees), Motte Business Center (1,964 employees), Ethanac and Barnett Warehouse (440 employees), CADO Menifee (860 employees), Compass Northern Gateway (599 employees), Ares Murrieta Road Warehouse (652 employees), and Northern Logistics Gateway Center (694 employees) combined with the proposed project will cumulatively generate 17,906 employees, which is 210% of the City's employment growth forecast over 26 years accounted for by these industrial projects submitted since 2020. This exceeds the projected growth forecast for the City. This number increases exponentially when the City's commercial development activity and other projects since 2019 (SCAG) and 2013 (General Plan) are added to the calculation. A 18 SCAG 2024 Connect SoCal Demographics and Growth Forecast https://scag.ca.gov/sites/default/files/2024-05/23-2987-tr-demographics-growth-forecast-final-040424.pdf 19 Data for listed projects via City of Menifee Land Development Projects Map https://cityofmenifee.maps.arcgis.com/apps/instant/minimalist/index.html?appid=55fc56d4eee94e588a28 a958cebac908 and Accela Menifee https://aca-
prod.accela.com/MENIFEE/Cap/CapHome.aspx?module=Planning&TabName=Planning&TabList=Hom e%7C0%7CPermits%7C1%7CEngineering%7C2%7CPlanning%7C3%7CFire%7C4%7CCurrentTabInde x%7C3
Russell Brown
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revised EIR must be prepared to include a cumulative analysis on this topic in order to provide an adequate and accurate environmental analysis.

4.17 Transportation
The project's VMT impacts are misrepresented by the VMT analysis. The EIR relies upon a VMT screening analysis which concludes that the proposed project site is located in a low VMT- generating Traffic Analysis Zone (TAZ) which results in less than significant Transportation impacts. The project site is located in TAZ ID 1053, which is bound by Scott Road to the north, the 1-215 highway to the east, Howard Road to the west, Case Road and Keller Road to the south.

WRCOG VMT Tool Powered by Fehr & Peers User's Guide
33521 Zeiders Rd, Menifee, CA, X Q
Show search results for 33521 Zeider...

X
TAZ: 1053
Scott Rd Scott Rd

CITY MENIFEE
Howard Rd.

COUNTY Riverside
Billy Ln Zoom to
Marcalope Ln
Chancy Rd Nancy Ln
Tulita Ln
Ciccotti St Ciccotti St
Mapleton St
Howard Rd eiders Ra Mapleton Ave
Hoffman Ln Oak Meadow
Elementary
School
Antelope RO Poinsetta 51
Keller Rd Keller Rd
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The TAZ is primarily comprised of vacant land with scattered rural residences, a strip shopping center, and two industrial buildings that were completed sometime between June 2023 and March 202420. The proposed project is unique in that the TAZ in which the Project site is located is over 50% vacant land and the two warehouse buildings were not operational until 2023/2024, which is more than 10 years past the 2012 VMT baseline year the WRCOG tool utilizes for analysis?!. The VMT screening analysis does not adequately or accurately represent the VMT impacts of the proposed project and a revised EIR must be prepared with a project-specific VMT analysis.

The Fehr and Peer's WRCOG SB 743 Implementation Pathway Document Package? states that the exemption for projects in low VMT areas, "may not be appropriate if the project land uses would alter the existing built environment in such a way as to increase the rate or length of vehicle trips." The proposed project will generate 1,751 average daily trips (actual vehicles; 2,030 average daily trips PCE) and daily operations as a warehouse involves extremely high VMT rates during the course of business. The operational nature of industrial/warehouse uses involves high rates of truck/trailer/delivery van VMT due to traveling from large import hubs to regional distribution centers to smaller industrial parks and then to their final delivery destinations. Once employees arrive at work at the proposed distribution facility, they will conduct their jobs by driving delivery vans across the region as part of the daily operations as a distribution facility, which will drastically increase project-generated VMT. The project's truck/trailer and delivery van activity is unable to utilize public transit or active transportation and it is misleading to the public and decision makers to exclude this activity from VMT analysis. A revised EIR must be prepared to reflect a quantified VMT analysis that includes all truck/trailer and delivery van activity and remove the applied VMT exemption.

Further, Fehr and Peer's WRCOG SB 743 Implementation Pathway Document Package23 states "that a per capita or per employee VMT that is fifteen percent below that of existing development" is a reasonable threshold to determine that a project would have a less than significant VMT impact. The EIR states that the Citywide VMT per service population is 33.6 VMT and the Project TAZ rate is 30.7 VMT per service population, which is 2.9 VMT lower than the City average. This does not meet the Implementation threshold of a 15% below existing VMT because it is only a 8% 20 Google Street View
21 https://scag.ca.gov/sites/default/files/2024-05/wrcog-sb743-implementation-pathway.pdf 2 WRCOG SB 743 Implementation Pathway Document Package https://www.fehrandpeers.com/wp- content/uploads/2019/12/WRCOG-SB743-Document-Package.pdf 23 WRCOG SB 743 Implementation Pathway Document Package https://www.fehrandpeers.com/wp- content/uploads/2019/12/WRCOG-SB743-Document-Package.pdf Russell Brown
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less than the TAZ VMT. The EIR must be revised to include a finding of significance as it has not presented any substantial evidence to support a less than significant finding.

The EIR has not adequately analyzed the project's potential to substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses; or the project's potential to result in inadequate emergency access. There are no dedicated exhibits adequately depicting the available maneuvering and queueing space for trucks/trailers at the intersection of the project driveways and the adjacent streets. There are also no dedicated exhibits adequately depicting the onsite turning radius available for trucks/trailers maneuvering throughout the site. The EIR has not presented any substantial evidence to support a less than significant finding and a finding of significance must be provided in a revised EIR.

The EIR states that there are, "farm-related uses in the area, there is a potential for conflicts with farm equipment. However, drivers/operators of such equipment will likely utilize the remaining rural dirt roads in the area for farm-related access as it minimizes conflicts with more urban vehicles (both passenger vehicles and multi-axle trucks). The rural land north and south of the project site is designated within the Economic Development Corridor-Southern Gateway designations in the General Plan and zoning. Therefore, it is likely that eventually these rural lands will convert to more urban-style development. Project impacts relative to traffic hazards will be less than significant and no mitigation is required." There are no exhibits depicting the location of farms, the alleged dirt roads the farm equipment would utilize, or how the project would not conflict the farming equipment. The EIR has not presented any substantial evidence to support a less than significant finding and a finding of significance must be provided in a revised EIR.

There are also no exhibits depicting emergency vehicle access during construction or operations.

Deferring this environmental analysis required by CEQA to the construction permitting phase is improper mitigation, deferred mitigation, and does not comply with CEQA's requirement for meaningful disclosure and adequate informational documents. The EIR must be revised to include a finding of significance as it has not provided any substantial evidence to support a less than significant finding.

Additionally, the EIR has not provided any analysis of the available horizontal and vertical sight distance at the intersection of the project driveways and adjacent streets. Sight distance is the continuous length of street ahead visible to the driver. At unsignalized intersections, corner sight distance must provide a substantially clear line of sight between the driver of the vehicle waiting on the minor road (driveway) and the driver of an approaching vehicle. The industry standard for Russell Brown
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this analysis is the American Association of State Highway and Transportation Officials (AASHTO) Stopping Sight Distance requirements. The EIR must be revised to include a finding of significance as it has not provided any substantial evidence to support a less than significant finding.

5.0 Alternatives to the Proposed Project
The EIR is required to evaluate a reasonable range of alternatives to the proposed project which will avoid or substantially lessen any of the significant effects of the project (CEQA § 15126.6.) The alternatives chosen for analysis include the CEQA required "No Project/No Development" alternative and only three others - Less Intense Development Alternative, EDC Mixed Use (C/LI/MFR) Alternative, and EDC Mixed Use (O/BP/MFR) Alternative. The EIR does not include an alternative that meets the project objectives and also eliminates all of the project's significant and unavoidable impacts. The EIR must be revised to include analysis of a reasonable range of alternatives and foster informed decision making (CEQA § 15126.6). This could include alternatives such as development of the site with a project that reduces all of the proposed project's significant and unavoidable impacts to a less than significant level, and a mixed-use project that provides affordable housing and exclusively local-serving commercial uses that may reduce VMT, GHG emissions and simultaneously improve Air Quality.

6.2 Growth-Inducing Effects
The EIR has not provided an adequate or accurate cumulative analysis discussion here to demonstrate the impact of the proposed project in a cumulative setting. SCAG's Connect SoCal Demographics and Growth Forecast?4 notes that the City will add 8,500 jobs between 2019 - 2035.

Utilizing the SCAG Employment Density Study calculation of 553 employees, the project represents 3.5% of the City's employment growth from 2019 - 2035. A single project accounting for this amount of the projected employment growth over 26 years represents a significant amount of growth. A revised EIR must be prepared to include this analysis, and also provide a cumulative analysis discussion of projects approved since 2019 and projects "in the pipeline" to determine the City's progress towards SCAG's employment growth forecast for the City. For example, other recent industrial projects? such as Menifee Commerce Center (2,885 employees), Menifee 24 SCAG 2024 Connect SoCal Demographics and Growth Forecast https://scag.ca.gov/sites/default/files/2024-05/23-2987-tr-demographics-growth-forecast-final-040424.pdf 25 Data for listed projects via City of Menifee Land Development Projects Map https://cityofmenifee.maps.arcgis.com/apps/instant/minimalist/index.html?appid-55fc56d4eee94e588a28 a958cebac908 and Accela Menifee https://aca-
prod.accela.com/MENIFEE/Cap/CapHome.aspx?module=Planning&TabName=Planning&TabList-Hom Russell Brown
September 24, 2025

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Commerce Center Phase II (1,962 employees), Northern Gateway Commerce Center (2,267 employees), Ares Warehouse on Murrieta (952 employees), Capstone Industrial (1,205 employees), Wheat Warehouse (151 employees), Corsica Business Park (477 employees), Trumble and Watson Warehouse (571 employees), McLaughlin San Jacinto Warehouses (846 employees), Mapes and Sherman Warehouse (478 employees), United Carports Warehouse (105 employees), Motte Business Center (1,964 employees), Ethanac and Barnett Warehouse (440 employees), CADO Menifee (860 employees), Compass Northern Gateway (599 employees), Ares Murrieta Road Warehouse (652 employees), and Northern Logistics Gateway Center (694 employees) combined with the proposed project will cumulatively generate 17,906 employees, which is 210% of the City's employment growth forecast over 26 years accounted for by these industrial projects submitted since 2020. This exceeds the projected growth forecast for the City.

This number increases exponentially when the City's commercial development activity and other projects since 2019 (SCAG) and 2013 (General Plan) are added to the calculation. A revised EIR must be prepared to include a cumulative analysis on this topic in order to provide an adequate and accurate environmental analysis.

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 Element26 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:

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 jobs generated by the project and states that, "It is reasonable to assume that these jobs would be filled by people living in the City, unincorporated County area, and surrounding cities." Relying upon the entire unemployed workforce within an unspecified distance will result in the project attracting a workforce that is exponentially further e%7C0%7CPermits%7C1%7CEngineering%7C2%7CPlanning%7C3%7CFire%7C4%7CCurrentTabInde x%7C3
26 Menifee General Plan Land Use Element
https://www.cityofmenifee.us/DocumentCenter/View/14701/FINAL_Land-Use-Element_11322 Russell Brown
September 24, 2025

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than that of the "low VMT TAZ" utilized in the EIR to conclude less than significant VMT impacts.

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

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

SWAPE Technical Analysis

Menifee City CouncilFebruary 4, 2026

Menifee City Council
February 4, 2026