7.8_G-Greenhouse Gas Analysis.pdf — Moreno Valley City Council, June 3, 2025

Town Center at Moreno
Valley Specific Plan

GREENHOUSE GAS ANALYSIS

CITY OF MORENO VALLEY

PREPARED BY:

Haseeb Qureshi
[email protected]

Ali Dadabhoy
[email protected]

F
EBRUARY 3, 2025

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TABLE OF CONTENTS
TABLE OF CONTENTS ........................................................................................................................... III

APPENDICES IV
LIST OF EXHIBITS ................................................................................................................................. IV LIST OF TABLES ................................................................................................................................... IV LIST OF ABBREVIATED TERMS .............................................................................................................. V EXECUTIVE SUMMARY ......................................................................................................................... 1 ES.1 Summary of Findings ..................................................................................................................... 1 ES.2 Standard Regulatory Requirements .............................................................................................. 1 ES.3 APPLICABLE GHG MITIGATION MEASURES ............................................................................................ 2 1 INTRODUCTION ........................................................................................................................... 6

1.1 Site Location .................................................................................................................................. 6

1.2 Project Description ........................................................................................................................ 6 2 CLIMATE CHANGE SETTING ....................................................................................................... 11

2.1 Introduction to Global Climate Change (GCC) ............................................................................ 11

2.2 Global Climate Change Defined .................................................................................................. 11

2.3 GHGs ........................................................................................................................................... 11

2.4 Global Warming Potential ........................................................................................................... 18

2.5 GHG Emissions Inventories ......................................................................................................... 18

2.6 Effects of Climate Change in California ....................................................................................... 19 3 REGULATORY SETTING .............................................................................................................. 23

3.1 International ............................................................................................................................... 23

3.2 National ....................................................................................................................................... 24

3.3 Multistate .................................................................................................................................... 29

3.4 California ..................................................................................................................................... 30

3.5 Regional ....................................................................................................................................... 45

3.6 City of Moreno Valley ................................................................................................................. 46 4 DISCUSSION ON ESTABLISHMENT OF SIGNIFICANCE THRESHOLDS ............................................ 48 5 PROJECT GREENHOUSE GAS ANALYSIS ...................................................................................... 52

5.1 Introduction ................................................................................................................................ 52

5.2 Methodology ............................................................................................................................... 52

5.3 Construction Emissions ............................................................................................................... 52

5.4 Operational Emissions ................................................................................................................ 55 6 GHG EMISSIONS FINDINGS AND RECOMMENDATIONS .............................................................. 60

6.1 City of Moreno Valley General Plan Measures ........................................................................... 64

6.4 Consistency with SB 375 (SCAG RTP/SCSR) ................................................................................. 66 7 REFERENCES .............................................................................................................................. 69 8 CERTIFICATIONS ........................................................................................................................ 74

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APPENDICES
APPENDIX 5.1: CALEEMOD ANNUAL EMISSIONS MODEL OUTPUTS

LIST OF EXHIBITS
EXHIBIT 1-A: SITE LOCATION ............................................................................................................... 8 EXHIBIT 1-B: PRELIMINARY SITE PLAN ................................................................................................. 9 EXHIBIT 2-A: SUMMARY OF PROJECTED GLOBAL WARMING IMPACT, 2070-2099 (AS COMPARED WITH 1961-1990) .................................................................................................................. 17

LIST OF TABLES
TABLE ES-1: SUMMARY OF CEQA SIGNIFICANCE FINDINGS .................................................................. 1 TABLE 2-1: GREENHOUSE GASES ........................................................................................................ 12 TABLE 5-1: CONSTRUCTION SCHEDULE ............................................................................................... 53 TABLE 5-2: CONSTRUCTION EQUIPMENT ASSUMPTIONS .................................................................... 54 TABLE 5-3: CONSTRUCTION TRIP ASSUMPTIONS ................................................................................ 54 TABLE 5-4: AMORTIZED ANNUAL CONSTRUCTION EMISSIONS ........................................................... 55 TABLE 5-5: PROJECT GHG EMISSIONS – WITHOUT MITIGATION .......................................................... 58 TABLE 6-1: 2006 CITY OF MORENO VALLEY GENERAL PLAN CONSISTENCY .......................................... 65 TABLE 6-2: 2040 CITY OF MORENO VALLEY GENERAL PLAN CONSISTENCY .......................................... 65

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LIST OF ABBREVIATED TERMS
% Percent
°C Degrees Celsius
°F Degrees Fahrenheit
(1) Reference
2020-2045 RTP/SCS Final 2020-2045 Regional Transportation Plan/Sustainable Communities Strategies
2017 Scoping Plan 2017 Scoping Plan
AB Assembly Bill
AB 32 Global Warming Solutions Act of 2006
AB 1493 Pavley Fuel Efficiency Standards
AB 1881 California Water Conservation Landscaping Act of 2006 ACE Affordable Clean Energy
Annex I Industrialized Nations
APA Administrative Procedure Act
AQIA Moreno Valley Town Center Specific Plan Air Quality Impact Analysis
BAU Business As Usual
C2F6 Hexafluoroethane
C2H6 Ethane
CAA Federal Clean Air Act
CalEEMod California Emissions Estimator Model
CalEPA California Environmental Protection Agency
CAL FIRE California Department of Forestry and Fire Protection CALGAPS California LBNL GHG Analysis of Policies Spreadsheet CALGreen California Green Building Standards Code
CalSTA California State Transportation Agency
Caltrans California Department of Transportation
CAP Climate Action Plan
CAPCOA California Air Pollution Control Officers Association CARB California Air Resource Board
CCR California Code of Regulations
CDFA California Department of Food and Agriculture
CEC California Energy Commission
CEQA California Environmental Quality Act
CEQA Guidelines 2019 CEQA Statute and Guidelines
CF4 Tetrafluoromethane
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CFC Chlorofluorocarbons
CFC-113 Trichlorotrifluoroethane
CH4 Methane
CNRA California Natural Resources Agency
CNRA 2009 2009 California Climate Adaptation Strategy
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent
Convention United Nation’s Framework Convention on Climate Change COP Conference of the Parties
CPUC California Public Utilities Commission
CTC California Transportation Commission
DOF Department of Finance
DWR Department of Water Resources
EMFAC Emission Factor Model
EPA Environmental Protection Agency
EV Electric Vehicle
g/L Grams Per Liter
GCC Global Climate Change
Gg Gigagram
GHGA Greenhouse Gas Analysis
GHGRS Greenhouse Gas Reduction Strategy
GO-Biz Governor’s Office of Business and Economic Development GWP Global Warming Potential
H2O Water
HFC Hydrofluorocarbons
HDT Heavy-Duty Trucks
HFC-23 Fluoroform
HFC-134a 1,1,1,2-tetrafluoroethane
HFC-152a 1,1-difluoroethane
HHDT Heavy-Heavy-Duty Trucks
hp Horsepower
HVAC Heating, Ventilation, Air Conditioning
I-215 Interstate 215
IBANK California Infrastructure and Economic Development Bank IPCC Intergovernmental Panel on Climate Change
IRP Integrated Resource Planning
ISO Independent System Operator
kWh Kilowatt Hours
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lbs Pounds
LBNL Lawrence Berkeley National Laboratory
LCA Life-Cycle Analysis
LCD Liquid Crystal Display
LCFS Low Carbon Fuel Standard or Executive Order S-01-07 LDA Light-Duty Auto
LDT1/LDT2 Light-Duty Trucks
LEV III Low-Emission Vehicle
LHDT1/LHDT2 Light-Heavy-Duty Trucks
LULUCF Land-Use, Land-Use Change and Forestry
MCY Motorcycle
MDT Medium-Duty Trucks
MDV Medium-Duty Vehicles
MH Motorhome
MHDT Medium-Heavy-Duty Tucks
MMTCO2e Million Metric Ton of Carbon Dioxide Equivalent mpg Miles Per Gallon
MPOs Metropolitan Planning Organizations
MMTCO2e/yr Million Metric Ton of Carbon Dioxide Equivalent Per Year MT/yr Metric Tons Per Year
MTCO2e Metric Ton of Carbon Dioxide Equivalent
MTCO2e/yr Metric Ton of Carbon Dioxide Equivalent Per Year MW Megawatts
MWh Megawatts Per Hour
MWELO California Department of Water Resources’ Model Water Efficient
N2O Nitrous Oxide
NDC Nationally Determined Contributions
NF3 Nitrogen Trifluoride
NHTSA National Highway Traffic Safety Administration
NIOSH National Institute for Occupational Safety and Health NOX Nitrogen Oxides
Non-Annex I Developing Nations
OAL Office of Administrative Law
OBUS Other Buses
OPR Office of Planning and Research
PFC Perfluorocarbons
ppb Parts Per Billion
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ppm Parts Per Million
ppt Parts Per Trillion
Project Town Center at Moreno Valley Specific Plan
RPS Renewable Portfolio Standards
RTP Regional Transportation Plan
SAR Second Assessment Report
SB Senate Bill
SB 32 California Global Warming Solutions Act of 2006
SB 375 Regional GHG Emissions Reduction Targets/Sustainable Communities Strategies
SB 1078 Renewable Portfolio Standards
SB 1368 Statewide Retail Provider Emissions Performance Standards
SBUS School Buses
SCAB South Coast Air Basin
SCAG Southern California Association of Governments
SCAQMD South Coast Air Quality Management District
Scoping Plan California Air Resources Board Climate Change Scoping Plan SCS Sustainable Communities Strategy
sf Square Feet
SF6 Sulfur Hexaflouride
SGC Strategic Growth Council
SLPS Short-Lived Climate Pollutant Strategy
SP Service Population
Supreme Court United States Supreme Court
Title 20 Appliance Energy Efficiency Standards
Title 24 California Building Code
U.N. United Nations
U.S. United States
UBUS Urban Buses
UNFCCC United Nations’ Framework Convention on Climate Change VMT Vehicle Miles Traveled
VOC Volatile Organic Compound
WCI Western Climate Initiative
WRI World Resources Institute
ZE/NZE Zero and Near-Zero Emissions
ZEV Zero-Emissions Vehicles
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1 EXECUTIVE SUMMARY
ES.1 SUMMARY OF FINDINGS
The results of this Town Center at Moreno Valley Specific Plan Greenhouse Gas Analysis (GHGA) are summarized below based on the significance criteria in Section 4 of this report consistent with Appendix G of the California Environmental Quality Act (CEQA) Guidelines (CEQA Guidelines) as implemented by City of Moreno Valley (1). Table ES-1 shows the findings of significance for each potential greenhouse gas (GHG) impact under CEQA before and after any required mitigation described below.

TABLE ES-1: SUMMARY OF CEQA SIGNIFICANCE FINDINGS
Analysis Report
Section
Significance Findings
Unmitigated Mitigation Measure Mitigated
GHG Impact #1: Would the Project
generate GHG emissions, either
directly or indirectly, that may have
a significant impact on the
environment?

6.0 Potentially Significant
GHG MM-1 through
MM-4 and Air Quality
MM 2
through
MM 6
Significant
and
Unavoidable
GHG Impact #2: Would the Project
conflict with an applicable plan,
policy or regulation adopted for the
purpose of reducing the emissions
of GHGs?

6.0 Less than Significant n/a n/a
ES.2 STANDARD REGULATORY REQUIREMENTS
The Project would be required to comply with regulations imposed by the State of California and the South Coast Air Quality Management District (SCAQMD) aimed at the reduction of GHG emissions. Those that are directly and indirectly applicable to the Project and that would assist in the reduction of GHG emissions include:
• Global Warming Solutions Act of 2006 (Assembly Bill (AB) 32) (2). • Regional GHG Emissions Reduction Targets/Sustainable Communities Strategies ( Senate Bill (SB) 375) (3).
• Pavley Fuel Efficiency Standards (AB 1493). Establishes fuel efficiency ratings for new vehicles (4). • California Building Code (Title 24 California Code of Regulations ( CCR)). Establishes energy efficiency requirements for new construction (5).
• Appliance Energy Efficiency Standards (Title 20 CCR). Establishes energy efficiency requirements for appliances (6).

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2 • Low Carbon Fuel Standard (LCFS). Requires carbon content of fuel sold in California to be 10 percent (%) less by 2020 (7).
• Low Carbon Fuel Standard (LCFS) 2030 Update. Requires carbon content of fuel sold in California to be 20 percent (5) less by 2030 (8)
• California Water Conservation in Landscaping Act of 2006 (AB 1881). Requires local agencies to adopt the Department of Water Resources updated Water Efficient Landscape Ordinance or equivalent by January 1, 2010 to ensure efficient landscapes in new development and reduced water waste in existing landscapes (9).
• Statewide Retail Provider Emissions Performance Standards (SB 1368). Requires energy generators to achieve performance standards for GHG emissions (10). • Renewable Portfolio Standards (SB 1078 – also referred to as RPS). Requires electric corporations to increase the amount of energy obtained from eligible renewable energy resources to 20 % by 2010 and 33% by 2020 (11). This was amended by SB 350 which mandated 50% by 2030. This was further modified by SB 100 which set a target of 60% by 2030 and 100% by 2045. • California Global Warming Solutions Act of 2006 (SB 32). Requires the state to reduce statewide GHG emissions to 40% below 1990 levels by 2030, a reduction target that was first introduced in Executive Order B-30-15 (12).

Promulgated regulations that will affect the Project’s emissions are accounted for in the Project’s GHG calculations provided in this report. In particular, AB 1493, LCFS, and RPS, and therefore are accounted for in the Project’s emission calculations.

ES.3 APPLICABLE GHG MITIGATION MEASURES
The following mitigation measures are recommended to specifically reduce GHG emissions.

MM GHG-1
The project applicant shall design and build future non-residential development to meet/include the following:
• The project will utilize on-site renewable energy sources such as solar, to reduce electrical demand as per Division A5.211, Renewable Energy, of Appendix A5, Nonresidential Voluntary Measures, of the 2022 California Green Building Standards Code. • The project will incorporate measures to reduce the overall use of potable water within the building by 12 percent as per Division A5.3, Water Efficiency and Conservation, as outlined under Section A5.303.2.3.1 of Appendix A5, Nonresidential Voluntary Measures, of the 2022 California Green Building Standards Code.

Prior to the issuance of building permits for new development projects within the project site, the project applicant shall provide documentation (e.g., building plans, site plans) to the City of Moreno Valley Planning Division to verify implementation of the applicable design requirements specified in this mitigation measure. Prior to the issuance of the certificate of occupancy, the City shall verify implementation of these design requirements.

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3 MM GHG-2
The project applicant shall design and build future residential development to meet/include the following:
• No wood-burning fireplaces shall be installed in any of the dwelling units. • All buildings shall be electric, to the extent feasible, meaning that electricity is the primary source of energy for water heating; heating, ventilation, and air conditioning (HVAC) within the building, excluding pool heating.
• All major appliances provided/installed shall be EnergyStar- certified or of equivalent energy efficiency, where applicable.

MM
GHG-3
Exterior electric receptacles on nonresidential buildings shall be provided for charging or powering electric landscaping equipment.

MM
GHG-4
The project shall use light-color roofing and building materials to minimize the heat island effect and reduce lighting, heating, and cooling needs.

ADDITIONAL APPLICABLE AIR QUALITY MITIGATION MEASURES TO REDUCE GHG EMISSIONS The following Project-specific mitigation measures were identified in the Town Center at Moreno Valley Specific Plan Air Quality Impact Analysis Report (AQIA) (Urban Crossroads, Inc.) (13) .

Although these measures are designed to reduce Project air quality emissions, they would also assist in the reduction of GHGs. I t should be noted that to provide a conservative disclosure of Project emissions, no reductions in emissions are assumed to occur with implementation of these measures. Notwithstanding the foregoing, all of the below measures will decrease Project emissions. As such, even with application of MM 2 through MM 6 , Project operational- source emissions impacts would be significant and unavoidable.

MM 2
Legible, durable, weather -proof signs shall be placed at commercial loading docks and truck parking areas that identify applicable CARB anti-idling regulations. At a minimum, each sign shall include: 1) instructions for truck drivers to shut off engines when not in use; 2) instructions for drivers of diesel trucks to restrict idling to no more than five (5) minutes once the vehicle is stopped, the transmission is set to "neutral" or "park," and the parking brake is engaged; and 3) telephone numbers of the building facilities manager and the CARB to report violations. Prior

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4 to the issuance of an occupancy permit, the City shall conduct a site inspection to ensure that the signs are in place.

MM 3
Prior to the issuing of each building permit, the Project proponent and its contractors shall provide plans and specifications to the City that demonstrate that electrical service is provided to each of the areas in the vicinity of the buildings that are to be landscaped in order that electrical equipment may be used for landscape maintenance.

MM
4 Once constructed, the Project proponent shall ensure that all commercial tenants shall utilize only electric or natural gas pallet jacks and forklifts in the loading areas.

MM 5
Upon occupancy and annually thereafter, the operators of the commercial space shall provide information to all delivery truck drivers, regarding:
• Building energy efficiency, solid waste reduction, recycling, and water conservation. • Vehicle GHG emissions, electric vehicle charging availability, and alternate transportation opportunities for commuting.
• Participation in the Voluntary Interindustry Commerce Solutions (VICS) “Empty Miles” program to improve goods trucking efficiencies.
• Health effects of diesel particulates, State regulations limiting truck idling time, and the benefits of minimized idling.
• The importance of minimizing traffic, noise, and air pollutant impacts to any residences in the Project vicinity.

MM 6
Prior to issuance of a building permit, the Project proponent shall provide the City with an onsite signage program that clearly identifies the required onsite circulation system. This shall be accomplished through posted signs and painting on driveways and internal roadways.

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6 1 INTRODUCTION
This report presents the results of the G HGA prepared by Urban Crossroads, Inc., for the proposed Town Center at Moreno Valley Specific Plan (Project). The purpose of this GHGA is to evaluate Project-related construction and operational emissions and determine the level of GHG impacts as a result of constructing and operating the Project.

1.1 SITE LOCATION
The Project site is generally bound by Cottonwood Avenue to the north, Nason Street to the east, Alessandro Boulevard to the south, and vacant land and a residential subdivision to the west. The Project site is currently undeveloped. There is a vacant parc el northeast of the Project site (southwest of the Nason Street and Cottonwood Avenue intersection), and an Eastern Municipal Water District booster station northwest of the Project site (southeast corner of Cottonwood Avenue and Letterman Street) that are not part of the Project. Exhibit 1-A depicts the location of the Project.

1.2 PROJECT DESCRIPTION
The Project includes a proposed Specific Plan and TTM to allow for the development of residential, commercial, and park uses, as shown on the conceptual site plan provided on Figure

3. Access to the Project site would be provided from Cottonwood Avenue, Na son Street, Bay Avenue, and Alessandro Boulevard. Because the proposed Specific Plan is designed to provide flexibility for development within the Specific Plan area, the actual type and amount of uses that would be developed at buildout of the Specific Pl an is unknown. Therefore, a reasonable potential buildout development scenario has been developed for purposes of analysis; the following uses are anticipated in the respective land use areas shown in Exhibit 1-B. • 800 single family detached1 residential dwelling units (DU) • 4.8 acres of parks
• 106-room hotel
• 15,000 square feet (sf) of office use
• 30,000 sf of civic use
• 16,660 sf of high turnover (sit-down) restaurant use
• 3,500 sf of fast-food restaurant with drive-thru window • 60,890 sf of commercial retail use
• 45,000 sf of supermarket use
The existing 2006 Moreno Valley General Plan land use designation and zoning for the site is Public Facilities. Therefore, the proposed Project also involves a General Plan amendment and zone change. The proposed General Plan land use designations are Residential (30 du/acre

1 The Project could include the development of multifamily residential uses, however, for purposes of analysis, and consistent with the Town Center at Moreno Valley Specific Plan Traffic Analysis, this GHGA analyzes 800 single family detached residential DUs.

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7 maximum), Open Space, and Commercial. The proposed change of zone would amend the Public Facilities zoning to the TCMV Specific Plan (SP 222) zoning classification for the subject property.

However, the City of Moreno Valley is currently in the process of readopting the City’s 2040 General Plan Update (2040 General Plan) and zoning.2 The General Plan land use designation and zoning proposed by the City is Downtown Center (DC) District. The proposed Town Center at Moreno Valley Specific Plan is consistent with the City’s proposed Downtown Center (DC) District land use and zoning designations.

This report evaluates the impacts resulting from implementation of the proposed Project under the existing General Plan land use and zoning designations, which would require a General Plan Amendment and zone change, and the City’s proposed 2040 General Pla n land use and zoning designation, if applicable to the analysis.

A preliminary land use plan for the proposed Project is shown on Exhibit 1 -B. For the purposes of this analysis, it is assumed that the Project would be developed in a single phase with an anticipated Opening Year of 2028.

2 In June 2021, the City Council of the City of Moreno Valley (City Council) approved and adopted the City’s 2040 General Plan Update (2040 General Plan), a Change of Zone and Municipal Code Update, and its Climate Action Plan (CAP) and certified an EIR, Sta te Clearinghouse No. 2020039022, as having been prepared in compliance with CEQA in connection with the approvals. A lawsuit entitled Sierra Club v. The City of Moreno Valley, Riverside Superior Court Case No. CVRI2103300, challenged the validity of the CAP and the EIR. In May 2024, the City Council set aside the 2021 approvals and certification, based on a March 2024 ruling and judgment of the court. The City is in the proces s of readopting the 2040 General Plan and issued a Notice of Preparation of a Re vised Environmental Impact Report for MoVal 2040: The Moreno Valley Comprehensive General Plan Update, Municipal Code and Zoning (including Zoning Atlas) Amendments, and Climate Action Plan on July 30, 2024.

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8 EXHIBIT 1-A: SITE LOCATION
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9 EXHIBIT 1-B: PRELIMINARY SITE PLAN
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11 2 CLIMATE CHANGE SETTING

2.1 INTRODUCTION TO GLOBAL CLIMATE CHANGE (GCC)
GCC is defined as the change in average meteorological conditions on the earth with respect to temperature, precipitation, and storms. The majority of s cientists believe that the climate shift taking place since the Industrial Revolution is occurring at a quicker rate and magnitude than in the past. Scientific evidence suggests that GCC is the result of increased concentrations of GHGs in the earth’s atmosphere, including carbon dioxide (CO 2), methane (CH4), nitrous oxide (N2O),
and fluorinated gases. The majority of scientists believe that this increased rate of climate change is the result of GHGs from human activity and industrialization over the past 200 years.

An individual project like the proposed Project evaluated in this GHGA cannot generate enough GHG emissions to affect a discernible change in global climate. However, the proposed Project may participate in the potential for GCC by its incremental contrib ution of GHGs combined with the cumulative increase of all other sources of GHGs, which when taken together constitute potential influences on GCC. Because these changes may have serious environmental consequences, Section 3.0 will evaluate the potential for the proposed Project to have a significant effect upon the environment as a result of its potential contribution to the greenhouse effect.

2.2 GLOBAL CLIMATE CHANGE DEFINED
GCC refers to the change in average meteorological conditions on the earth with respect to temperature, wind patterns, precipitation and storms. Global temperatures are regulated by naturally occurring atmospheric gases such as water vapor, CO 2, N2O, CH4, hydrofluorocarbons
(HFCs), perfluorocarbons (PFCs), and sulfur hexafluoride (SF6). These particular gases are important due to their residence time (duration they stay) in the atmosphere, which ranges from 10 years to more than 100 years. These gases allow solar radiation into the earth’s atmosphere, but prevent radiative heat from escaping, thus warming the earth’s atmosphere. GCC can occur naturally as it has in the past with the previous ice ages.

Gases that trap heat in the atmosphere are often referred to as GHGs. GHGs are released into the atmosphere by both natural and anthropogenic activity. Without the natural GHG effect, the earth’s average temperature would be approximately 61 degrees Fahrenheit (°F) cooler than it is currently. The cumulative accumulation of these gases in the earth’s atmosphere is considered to be the cause for the observed increase in the earth’s temperature.

2.3 GHGS

2.3.1 GHGS AND HEALTH EFFECTS
GHGs trap heat in the atmosphere, creating a GHG effect that results in global warming and climate change. Many gases demonstrate these properties and as discussed in Table 2-1. For the purposes of this analysis, emissions of CO
2, CH4, and N2O were evaluated because these gases are
the primary contributors to GCC from development projects. Although there are other

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12 substances such as fluorinated gases that also contribute to GCC, these fluorinated gases were not evaluated as their sources are not well-defined and do not contain accepted emissions factors or methodology to accurately calculate these gases.

TABLE 2-1: GREENHOUSE GASES
GHG Description Sources Health Effects
Water Water is the most abundant,
important, and variable GHG in
the atmosphere. Water vapor is
not considered a pollutant; in
the atmosphere it maintains a
climate necessary for life.

Changes in its concentration are
primarily considered to be a
result of climate feedbacks
related to the warming of the
atmosphere rather than a direct
result of industrialization. A
climate feedback is an indirect,
or secondary, change, either
positive or negative, that occurs
within the climate system in
response to a forcing
mechanism. The feedback loop
in which water is involved is
critically important to projecting
future climate change.

As the temperature of the
atmosphere rises, more water is
evaporated from ground storage
(rivers, oceans, reservoirs, soil).

Because the air is warmer, the
relative humidity can be higher
(in essence, the air is able to
‘hold’ more water when it is
warmer), leading to more water
vapor in the atmosphere. As a
GHG, the higher concentration of
water vapor is then able to
absorb more thermal indirect
energy radiated from the Earth,
thus further warming the
atmosphere. The warmer
atmosphere can then hold more
water vapor and so on and so
on. This is referred to as a
“positive feedback loop.” The
extent to which this positive
feedback loop will continue is
The main source of
water vapor is
evaporation from
the oceans
(approximately
85%). Other sources
include evaporation
from other water
bodies, sublimation
(change from solid to
gas) from sea ice and
snow, and
transpiration from
plant leaves.

There are no known direct
health effects related to
water vapor at this time. It
should be noted however
that when some pollutants
react with water vapor, the
reaction forms a transport
mechanism for some of
these pollutants to enter the
human body through water
vapor.

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13 GHG Description Sources Health Effects
unknown as there are also
dynamics that hold the positive
feedback loop in check. As an
example, when water vapor
increases in the atmosphere,
more of it will eventually
condense into clouds, which are
more able to reflect incoming
solar radiation (thus allowing
less energy to reach the earth’s
surface and heat it up) (14).

CO2 CO2 is an odorless and colorless
GHG. Since the industrial
revolution began in the mid-
1700s, the sort of human activity
that increases GHG emissions
has increased dramatically in
scale and distribution. Data
from the past 50 years suggests
a corollary increase in levels and
concentrations. As an example,
prior to the industrial revolution,
CO
2 concentrations were fairly
stable at 280 parts per million
(ppm). Today, they are around
370 ppm, an increase of more
than 30%. Left unchecked, the
concentration of CO2 in the
atmosphere is projected to
increase to a minimum of 540
ppm by 2100 as a direct result of
anthropogenic sources (15).

CO2 is emitted from
natural and
manmade sources.

Natural sources
include: the
decomposition of
dead organic matter;
respiration of
bacteria, plants,
animals and fungus;
evaporation from
oceans; and volcanic
outgassing.

Anthropogenic
sources include: the
burning of coal, oil,
natural gas, and
wood. CO
2 is
naturally removed
from the air by
photosynthesis,
dissolution into
ocean water,
transfer to soils and
ice caps, and
chemical weathering
of carbonate rocks
(16).

Outdoor levels of CO
2 are not
high enough to result in
negative health effects.

According to the National
Institute for Occupational
Safety and Health (NIOSH)
high concentrations of CO2
can result in health effects
such as: headaches,
dizziness, restlessness,
difficulty breathing,
sweating, increased heart
rate, increased cardiac
output, increased blood
pressure, coma, asphyxia,
and/or convulsions. It should
be noted that current
concentrations of CO
2 in the
earth’s atmosphere are
estimated to be
approximately 370 ppm, the
actual reference exposure
level (level at which adverse
health effects typically
occur) is at exposure levels
of 5,000 ppm averaged over
10 hours in a 40-hour
workweek and short-term
reference exposure levels of
30,000 ppm averaged over a
15-minute period (17).

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14 GHG Description Sources Health Effects
CH4 CH4 is an extremely effective
absorber of radiation, although
its atmospheric concentration is
less than CO2 and its lifetime in
the atmosphere is brief (10-12
years), compared to other GHGs.

CH4 has both natural
and anthropogenic
sources. It is
released as part of
the biological
processes in low
oxygen
environments, such
as in swamplands or
in rice production (at
the roots of the
plants). Over the
last 50 years, human
activities such as
growing rice, raising
cattle, using natural
gas, and mining coal
have added to the
atmospheric
concentration of
CH4. Other
anthropocentric
sources include
fossil-fuel
combustion and
biomass burning
(18).

CH
4 is extremely reactive
with oxidizers, halogens, and
other halogen-containing
compounds. Exposure to
high levels of CH
4 can cause
asphyxiation, loss of
consciousness, headache
and dizziness, nausea and
vomiting, weakness, loss of
coordination, and an
increased breathing rate.

N2O N2O, also known as laughing gas,
is a colorless GHG.

Concentrations of N2O also
began to rise at the beginning of
the industrial revolution. In
1998, the global concentration
was 314 parts per billion (ppb).

N2O is produced by
microbial processes
in soil and water,
including those
reactions which
occur in fertilizer
containing nitrogen.

In addition to
agricultural sources,
some industrial
processes (fossil
fuel-fired power
plants, nylon
production, nitric
acid production, and
vehicle emissions)
also contribute to its
atmospheric load. It
is used as an aerosol
spray propellant, i.e.,
in whipped cream
bottles. It is also
N2O can cause dizziness,
euphoria, and sometimes
slight hallucinations. In
small doses, it is considered
harmless. However, in some
cases, heavy and extended
use can cause Olney’s
Lesions (brain damage) (19).

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15 GHG Description Sources Health Effects
used in potato chip
bags to keep chips
fresh. It is used in
rocket engines and
in race cars. N2O can
be transported into
the stratosphere, be
deposited on the
earth’s surface, and
be converted to
other compounds by
chemical reaction
(19).

Chlorofluorocarbons
(CFCs)
CFCs are gases formed
synthetically by replacing all
hydrogen atoms in CH4 or ethane
(C2H6) with chlorine and/or
fluorine atoms. CFCs are
nontoxic, nonflammable,
insoluble and chemically
unreactive in the troposphere
(the level of air at the earth’s
surface).

CFCs have no natural
source but were first
synthesized in 1928.

They were used for
refrigerants, aerosol
propellants and
cleaning solvents.

Due to the discovery
that they are able to
destroy
stratospheric ozone,
a global effort to halt
their production was
undertaken and was
extremely
successful, so much
so that levels of the
major CFCs are now
remaining steady or
declining. However,
their long
atmospheric
lifetimes mean that
some of the CFCs will
remain in the
atmosphere for over
100 years (20).

In confined indoor locations,
working with CFC-113 or
other CFCs is thought to
result in death by cardiac
arrhythmia (heart frequency
too high or too low) or
asphyxiation.

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16 GHG Description Sources Health Effects
HFCs HFCs are synthetic, man-made
chemicals that are used as a
substitute for CFCs. Out of all
the GHGs, they are one of three
groups with the highest global
warming potential (GWP). The
HFCs with the largest measured
atmospheric abundances are (in
order), fluoroform (CHF
3),
1,1,1,2-tetrafluoroethane
(CH2FCF), and 1,1-difluoroethane
(CH3CF2). Prior to 1990, the only
significant emissions were of
CHF3. CH2FCF emissions are
increasing due to its use as a
refrigerant.

HFCs are manmade
for applications such
as automobile air
conditioners and
refrigerants.

No health effects are known
to result from exposure to
HFCs.

PFCs PFCs have stable molecular
structures and do not break
down through chemical
processes in the lower
atmosphere. High-energy
ultraviolet rays, which occur
about 60 kilometers above
earth’s surface, are able to
destroy the compounds.

Because of this, PFCs have very
long lifetimes, between 10,000
and 50,000 years. Two common
PFCs are tetrafluoromethane
(CF
4) and hexafluoroethane
(C2F6). The EPA estimates that
concentrations of CF4 in the
atmosphere are over 70 parts
per trillion (ppt).

The two main
sources of PFCs are
primary aluminum
production and
semiconductor
manufacture.

No health effects are known
to result from exposure to
PFCs.

SF6 SF6 is an inorganic, odorless,
colorless, nontoxic,
nonflammable gas. It also has
the highest GWP of any gas
evaluated (23,900) (21). The EPA
indicates that concentrations in
the 1990s were about 4 ppt.

SF
6 is used for
insulation in electric
power transmission
and distribution
equipment, in the
magnesium industry,
in semiconductor
manufacturing, and
as a tracer gas for
leak detection.

In high concentrations in
confined areas, the gas
presents the hazard of
suffocation because it
displaces the oxygen needed
for breathing.

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17 GHG Description Sources Health Effects
Nitrogen Trifluoride
(NF3)
NF3 is a colorless gas with a
distinctly moldy odor. The World
Resources Institute (WRI)
indicates that NF
3 has a 100-year
GWP of 17,200 (22).

NF3 is used in
industrial processes
and is produced in
the manufacturing of
semiconductors,
Liquid Crystal Display
(LCD) panels, types
of solar panels, and
chemical lasers.

Long-term or repeated
exposure may affect the liver
and kidneys and may cause
fluorosis (23).

The potential health effects related directly to the emissions of CO2, CH4, and N2O as they relate to development projects such as the proposed Project are still being debated in the scientific community. Their cumulative effects to GCC have the potential to cause adverse effects to human health. Increases in Earth’s ambient temperatures would result in more intense heat waves, causing more heat-related deaths. Climate change will likely cause shifts in weather patterns, potentially resulting in devastating droughts and food shortages in some areas (24). Exhibit 2-A presents the potential impacts of global warming (25).

E
XHIBIT 2-A: SUMMARY OF PROJECTED GLOBAL WARMING IMPACT, 2070-2099 (AS COMPARED WITH 1961-1990)

Source: Barbara H. Allen-Diaz. “Climate change affects us all.” University of California, Agriculture and Natural Resources, 2009.

Higher
Emissions
Scenario
Medium
High
Emissions
Scenario
Lower
Emissions
Scenario
13°F
12 11
10 9
8 7
6 5
4 3
2 0
Higher
Warming Range
(8-10.5°F)
Medium
Warming Range
(5.S-8°F)
Low er
Warming Range
(3-5.5°F)
• !IQlll, loss In Sierra sn-saack
• 22-30 Inches d- 1- 1 rise
• 3-4tlrnes as many hu:WlM! dap In ffl¥11' urban aenters • ..... tlnm as many....,_.allld d..i. In major urban 01ntan • 2.5 11nm mara crltlclllJ dry JNII
• 20IJI, lncrnse m energy demand
70-80% loss in Sierra snowpack
14-22 inches of sea level rise

2.5-4 times as many heat wave days in major urban centers 2-6 times as many heat-related deaths in major urban centers 75-85% increase in days conducive to ozone formation *
2-2.5 times more critically dry years
10% increase in electricity demand
30% decrease in forest yields (pine)
55% increase in the expected risk of large w ildfires
30-60% loss in Sierra snow pack
6-14 inches of sea level rise
2-2.5 times as many heat wave days in major urban centers 2-3 times as many heat-related deaths in major urban centers 25-35% increase in days conducive to ozone formation•
Upto 1.5times more critically dry years
3-6% increase in electricity demand
7-14% decrease in forest yields (pine)
10-35% increase in the risk of large w ildfires
* For high ozone locations in Los Angeles (Riverside)and the San Joaquin Valley (Visalia)

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18 2.4 GLOBAL WARMING POTENTIAL
GHGs have varying GWP values. GWP of a GHG indicates the amount of warming a gas causes over a given period of time and represents the potential of a gas to trap heat in the atmosphere.

CO2 is utilized as the reference gas for GWP, and thus has a GWP of 1. CO2 equivalent (CO2e) is a term used for describing the difference GHGs in a common unit. CO2e signifies the amount of CO2 which would have the equivalent GWP.

The Intergovernmental Panel on Climate Change (IPCC) is the international body for assessing the science related to climate change. IPCC Assessment Reports cover the full scientific, technical and socio-economic assessment of climate change. The atmospheric lifetime and GWP of selected GHGs are summarized at Table 2 -2. As shown in the table below, GWP for the 2 nd Assessment range from 1 for CO2 to 23,900 for SF6 and GWP for the 6th Assessment Report range from 1 for CO2 to 25,200 for SF6 (26).

TABLE 2-2: GWP AND ATMOSPHERIC LIFETIME OF SELECT GHGS
Gas Atmospheric Lifetime
(years)
GWP (100-year time horizon)
2nd Assessment Report 6th Assessment Report
CO2 Multiple 1 1
CH4 11.8 21 28
N2O 109 310 273
HFC-23 228 11,700 14,600
HFC-134a 14 1,300 1,526
HFC-152a 1.6 140 164
SF6 3,200 23,900 25,200
Source: IPCC Second Assessment Report, 1995 and IPCC Sixth Assessment Report, 2023

2.5 GHG EMISSIONS INVENTORIES

2.5.1 GLOBAL
Worldwide anthropogenic GHG emissions are tracked by the IPCC for industrialized nations (referred to as Annex I) and developing nations (referred to as Non- Annex I). Human GHG emissions data for Annex I nations are available through 2021. Based on the latest available data, the sum of these emissions totaled approximately 28,272,940 gigagram (Gg) CO 2e3 (27) (28) as
summarized on Table 2-3.

3 The global emissions are the sum of Annex I and non-Annex I countries, without counting Land-Use, Land-Use Change and Forestry (LULUCF).

For countries without 2021 data, the United Nations’ Framework Convention on Climate Change (UNFCCC) data for the most recent year were used U.N. Framework Convention on Climate Change, “Annex I Parties – GHG total without LULUCF,” The most recent GHG emissions for China and India are from 2014 and 2016, respectively.

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19 2.5.2 UNITED STATES
As noted in Table 2-3, the United States, as a single country, was the number two producer of GHG emissions in 2021.

TABLE 2-3: TOP GHG PRODUCING COUNTRIES AND THE EUROPEAN UNION Emitting Countries GHG Emissions (Gg CO2e)
China 12,300,200
United States 6,340,228
European Union (27-member countries) 3,468,394
India 2,839,425
Russian Federation 2,156,599
Japan 1,168,094
Total 28,272,940

2.5.3 STATE OF CALIFORNIA
California has significantly slowed the rate of growth of GHG emissions due to the implementation of energy efficiency programs as well as adoption of strict emission controls but is still a substantial contributor to the United States (U.S.) emissions inventory total (29). The California Air Resource Board (CARB) compiles GHG inventories for the State of California. Based upon the 2023 GHG inventory data (i.e., the latest year for which data are available) for the 2000- 2021 GHG emissions period, California emitted an average 381.3 million metric tons of CO 2e per
year (MMTCO2e/yr) or 381,300 Gg CO 2e (6.01% of the total United States GHG emissions) (30).

Based on data published by the U.S. Energy Information Administration, California’s per capita (9.12 metric tons) GHG emissions are much less than the nationwide per capita (15.8 metric ton) average (31).

2.6 EFFECTS OF CLIMATE CHANGE IN CALIFORNIA

2.6.1 PUBLIC HEALTH
Higher temperatures may increase the frequency, duration, and intensity of conditions conducive to air pollution formation. For example, days with weather conducive to ozone formation could increase from 25 to 35% under the lower warming range to 75 to 85 % under the medium warming range. In addition, if global background ozone levels increase as predicted in some scenarios, it may become impossible to meet local air quality standards. Air quality could be further compromised by increases in wildfires, which emit fine particulate matter that can travel long distances, depending on wind conditions. Based on Our Changing Climate Assessing the Risks to California by the California Climate Change Center , large wildfires could become up to 55% more frequent if GHG emissions are not significantly reduced (32).

In addition, under the higher warming range scenario, there could be up to 100 more days per year with temperatures above 90°F in Los Angeles and 95°F in Sacramento by 2100. This is a large increase over historical patterns and approximately twice the increase projected if temperatures

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20 remain within or below the lower warming range. Rising temperatures could increase the risk of death from dehydration, heat stroke/exhaustion, heart attack, stroke, and respiratory distress caused by extreme heat.

2.6.2 WATER RESOURCES
A vast network of man-made reservoirs and aqueducts captures and transports water throughout the state from northern California rivers and the Colorado River. The current distribution system relies on Sierra Nevada snowpack to supply water during the dry s pring and summer months.

Rising temperatures, potentially compounded by decreases in precipitation, could severely reduce spring snowpack, increasing the risk of summer water shortages.

If temperatures continue to increase, more precipitation could fall as rain instead of snow, and the snow that does fall could melt earlier, reducing the Sierra Nevada spring snowpack by as much as 70 to 90%. Under the lower warming range scenario, snowpack losses could be only half as large as those possible if temperatures were to rise to the higher warming range. How much snowpack could be lost depends in part on future precipitation patterns, the projecti ons for which remain uncertain. However, even under the wetter climate projections, the loss of snowpack could pose challenges to water managers and hamper hydropower generation. It could also adversely affect winter tourism. Under the lower warming range, the ski season at lower elevations could be reduced by as much as a month. If temperatures reach the higher warming range and precipitation declines, there might be many years with insufficient snow for skiing and snowboarding.

The State’s water supplies are also at risk from rising sea levels. An influx of saltwater could degrade California’s estuaries, wetlands, and groundwater aquifers. Saltwater intrusion caused by rising sea levels is a major threat to the quality and reliab ility of water within the southern edge of the Sacramento/San Joaquin River Delta – a major fresh water supply.

2.6.3 A

GRICULTURE
Increased temperatures could cause widespread changes to the agriculture industry reducing the quantity and quality of agricultural products statewide. First, California farmers could possibly lose as much as 25% of the water supply needed. Although higher CO 2 levels can stimulate plant
production and increase plant water-use efficiency, California’s farmers could face greater water demand for crops and a less reliable water supply as temperatures rise. Crop growth and development could change, as could the intensity and frequency of pest and disease outbreaks.

Rising temperatures could aggravate ozone pollution, which makes plants more susceptible to disease and pests and interferes with plant growth.

Plant growth tends to be slow at low temperatures, increasing with rising temperatures up to a threshold. However, faster growth can result in less -than-optimal development for many crops, so rising temperatures could worsen the quantity and quality of yield for a number of California’s agricultural products. Products likely to be most affected include wine grapes, fruits and nuts.

In addition, continued GCC could shift the ranges of existing invasive plants and weeds and alter competition patterns with native plants. Range expansion could occur in many species while range contractions may be less likely in rapidly evolving species with significant population s

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21 already established. Should range contractions occur, new or different weed species could fill the emerging gaps. Continued GCC could alter the abundance and types of many pests, lengthen pests’ breeding season, and increase pathogen growth rates.

2.6.4 FORESTS AND LANDSCAPES
GCC has the potential to intensify the current threat to forests and landscapes by increasing the risk of wildfire and altering the distribution and character of natural vegetation. If temperatures rise into the medium warming range, the risk of large wildfires in California could increase by as much as 55 %, which is almost twice the increase expected if temperatures stay in the lower warming range. However, since wildfire risk is determined by a combination of factors, including precipitation, winds, temperature, and landscape and vegetation conditions, future risks will not be uniform throughout the state. In contrast, wildfires in northern California could increase by up to 90% due to decreased precipitation.

Moreover, continued GCC has the potential to alter natural ecosystems and biological diversity within the state. For example, alpine and subalpine ecosystems could decline by as much as 60 to 80% by the end of the century as a result of increasing temperatures. The productivity of the state’s forests has the potential to decrease as a result of GCC.

2.6.5 R

ISING SEA LEVELS
Rising sea levels, more intense coastal storms, and warmer water temperatures could increasingly threaten the state’s coastal regions. Under the higher warming range scenario, sea level is anticipated to rise 22 to 35 inches by 2100. Elevations of this mag nitude would inundate low-lying coastal areas with saltwater, accelerate coastal erosion, threaten vital levees and inland water systems, and disrupt wetlands and natural habitats. Under the lower warming range scenario, sea level could rise 12-14 inches.

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23 3 REGULATORY SETTING

3.1 INTERNATIONAL
Climate change is a global issue involving GHG emissions from all around the world; therefore, countries such as the ones discussed below have made an effort to reduce GHGs.

IPCC
In 1988, the United Nations (U.N.) and the World Meteorological Organization established the IPCC to assess the scientific, technical and socioeconomic information relevant to understanding the scientific basis of risk of human -induced climate change, its potential impacts, and options for adaptation and mitigation.

UNITED NATION’S FRAMEWORK CONVENTION ON CLIMATE CHANGE (UNFCCC) On March 21, 1994, the U.S. joined a number of countries around the world in signing the Convention. Under the UNFCCC, governments gather and share information on GHG emissions, national policies, and best practices; launch national strategies for addressing GHG emissions and adapting to expected impacts, including the provision of financial and technological support to developing countries; and cooperate in preparing for adaptation to the impacts of climate change.

NTERNATIONAL CLIMATE CHANGE TREATIES
The Kyoto Protocol is an international agreement linked to the UNFCCC . The major feature of the Kyoto Protocol is that it sets binding targets for 37 industrialized countries and the European community for reducing GHG emissions at an average of 5% against 1990 levels over the five - year period 2008– 2012. The Convention (as discussed above) encouraged industrialized countries to stabilize emissions; however, the Protocol commits them to do so. Developed countries have contributed more emissions over the last 150 years; therefore, the Protocol places a heavier burden on developed nations under the principle of “common but differentiated responsibilities.”
In 2001, President George W. Bush indicated that he would not submit the treaty to the U.S.

Senate for ratification, which effectively ended American involvement in the Kyoto Protocol. In December 2009, international leaders met in Copenhagen to address the future of international climate change commitments post -Kyoto. No binding agreement was reached in Copenhagen; however, the UN Climate Change Committee identified the long -term goal of limiting the maximum global average temperature increase to no more than 2 degrees Celsius (°C) above pre- industrial levels, subject to a review in 2015. The Committee held additional meetings in Durban, South Africa in November 2011; Doha, Qatar in November 2012; and Warsaw, Poland in November 2013. The meetings gradually gain ed consensus among participants on individual climate change issues.

On September 23, 2014, more than 100 Heads of State and Government and leaders from the private sector and civil society met at the Climate Summit in New York hosted by the U.N. At the Summit, heads of government, business and civil society announced actions in areas that would

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24 have the greatest impact on reducing emissions, including climate finance, energy, transport, industry, agriculture, cities, forests, and building resilience.

Parties to the UNFCCC reached a landmark agreement on December 12, 2015 in Paris, charting a fundamentally new course in the two-decade-old global climate effort. Culminating a four- year negotiating round, the new treaty ends the strict differentiation be tween developed and developing countries that characterized earlier efforts, replacing it with a common framework that commits all countries to put forward their best efforts and to strengthen them in the years ahead. This includes, for the first time, requirements that all parties report regularly on their emissions and implementation efforts and undergo international review.

The agreement and a companion decision by parties were the key outcomes of the conference, known as the 21
st session of the UNFCCC Conference of the Parties (COP) 21. Together, the Paris Agreement and the accompanying COP decision:
• Reaffirm the goal of limiting global temperature increase well below 2 °C, while urging efforts to limit the increase to 1.5 degrees;
• Establish binding commitments by all parties to make “nationally determined contributions” (NDCs), and to pursue domestic measures aimed at achieving them; • Commit all countries to report regularly on their emissions and “progress made in implementing and achieving” their NDCs, and to undergo international review; • Commit all countries to submit new NDCs every five years, with the clear expectation that they will “represent a progression” beyond previous ones; • Reaffirm the binding obligations of developed countries under the UNFCCC to support the efforts of developing countries, while for the first time encouraging voluntary contributions by developing countries too;
• Extend the current goal of mobilizing $100 billion a year in support by 2020 through 2025, with a new, higher goal to be set for the period after 2025; • Extend a mechanism to address “loss and damage” resulting from climate change, which explicitly will not “involve or provide a basis for any liability or compensation;” • Require parties engaging in international emissions trading to avoid “double counting;” and • Call for a new mechanism, similar to the Clean Development Mechanism under the Kyoto Protocol, enabling emission reductions in one country to be counted toward another country’s NDC (C2ES 2015a) (33).

Following President Biden’s day one executive order , the United States officially rejoined the landmark Paris Agreement on February 19, 2021, positioning the country to once again be part of the global climate solution. Meanwhile, city, state, business, and civic leaders across the country and around the world have been ramping up efforts to drive the clean energy advances needed to meet the goals of the agreement and put the brakes on dangerous climate change.

3.2 NATIONAL
Prior to the last decade, there have been no concrete federal regulations of GHGs or major planning for climate change adaptation. The following are actions regarding the federal government, GHGs, and fuel efficiency.

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25 GHG ENDANGERMENT
In Massachusetts v. Environmental Protection Agency 549 U.S. 497 (2007), decided on April 2, 2007, the United States Supreme Court ( Supreme Court) found that four GHGs, including CO2, are air pollutants subject to regulation under Section 202(a)(1) of the Clean Air Act (CAA). The Supreme Court held that the EPA Administrator must determine whether emissions of GHGs from new motor vehicles cause or contribute to air pollution, which may reasonably be anticipated to endanger public health or welfare, or whether the science is too uncertain to make a reasoned decision. On December 7, 2009, the EPA Administrator signed two distinct findings regarding GHGs under section 202(a) of the CAA:
• Endangerment Finding: The Administrator finds that the current and projected concentrations of the six key well-mixed GHGs— CO2, CH4, N2O, HFCs, PFCs, and SF6—in the atmosphere threaten the public health and welfare of current and future generations. • Cause or Contribute Finding: The Administrator finds that the combined emissions of these well-mixed GHGs from new motor vehicles and new motor vehicle engines contribute to the GHG pollution, which threatens public health and welfare.

These findings do not impose requirements on industry or other entities. However, this was a prerequisite for implementing GHG emissions standards for vehicles, as discussed in the section “Clean Vehicles” below. After a lengthy legal challenge, the Supreme Court declined to review an Appeals Court ruling that upheld the EPA Administrator’s findings (34).

CLEAN VEHICLES
Congress first passed the Corporate Average Fuel Economy law in 1975 to increase the fuel economy of cars and light duty trucks. The law has become more stringent over time. On May 19, 2009, President Obama put in motion a new national policy to increase fuel economy for all new cars and trucks sold in the U.S. On April 1, 2010, the EPA and the Department of Transportation’s National Highway Traffic Safety Administration (NHTSA) announced a joint final rule establishing a national program that would redu ce GHG emissions and improve fuel economy for new cars and trucks sold in the U.S.

The first phase of the national program applies to passenger cars, light-duty trucks, and medium- duty (MD) passenger vehicles, covering model years 2012 through 2016. They require these vehicles to meet an estimated combined average emissions level of 250 grams of CO 2 per mile,
equivalent to 35.5 miles per gallon (mpg) if the automobile industry were to meet this CO2 level solely through fuel economy improvements. Together, these standards would cut CO2 emissions by an estimated 960 million metric tons an d 1.8 billion barrels of oil over the lifetime of the vehicles sold under the program (model years 2012–2016). The EPA and the NHTSA issued final rules on a second- phase joint rulemaking establishing national standards for light- duty vehicles for model years 2017 through 2025 in August 2012. The new standards for model years 2017 through 2025 apply to passenger cars, light- duty trucks, and MD passenger vehicles. The final standards are projected to result in an average industry fleetwide level of 163 grams/mile of CO2 in model year 2025, which is equivalent to 54.5 mpg if achieved exclusively through fuel economy improvements.

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26 The EPA and the U.S. Department of Transportation issued final rules for the first national standards to reduce GHG emissions and improve fuel efficiency of heavy -duty trucks (HDT) and buses on September 15, 2011, effective November 14, 2011. For combination tractors, the agencies are proposing engine and vehicle standards that begin in the 2014 model year and achieve up to a 20 % reduction in CO
2 emissions and fuel consumption by the 2018 model year.

For HDT and vans, the agencies are proposing separate gasoline and diesel truck standards, which phase in starting in the 2014 model year and achieve up to a 10% reduction for gasoline vehicles and a 15 % reduction for diesel vehicles by the 2018 model year (12 and 17 % respectively if accounting for air conditioning leakage). Lastly, for vocational vehicles, the engine and vehicle standards would achieve up to a 10% reduction in fuel consumption and CO2 emissions from the 2014 to 2018 model years.

On April 2, 2018, the EPA signed the Mid- term Evaluation Final Determination, which declared that the MY 2022-2025 GHG standards are not appropriate and should be revised (35). This Final Determination serves to initiate a notice to further consider appropriate standards for MY 2022- 2025 light-duty vehicles. On August 2, 2018, the NHTSA in conjunction with the EPA, released a notice of proposed rulemaking, the Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule for Model Years 2021-2026 Passenger Cars and Light Trucks (SAFE Vehicles Rule). The SAFE Vehicles Rule was proposed to amend existing Corporate Average Fuel Economy (CAFE) and tailpipe CO 2 standards for passenger cars an d light trucks and to establish new standards covering model years 2021 through 2026. As of March 31, 2020, the NHTSA and EPA finalized the SAFE Vehicle Rule which increased stringency of CAFE and CO2 emissions standards by 1.5% each year through model year 2026 (36). On December 21, 2021, after reviewing all the public comments submitted on NHTSA’s April 2021 Notice of Proposed Rulemaking, NHTSA finalizes the CAFE Preemption rulemaking to withdraw its portions of the so-called SAFE I Rule. The final rule concludes that the SAFE I Rule overstepped the agency’s legal authority and established overly broad prohibitions that did not account for a variety of important state and local interes ts. The final rule ensures that the SAFE I Rule will no longer form an improper barrier to states exploring creative solutions to address their local communities’ environmental and public health challenges (37).

On March 31, 2022, NHTSA finalized CAFE standards for MY 2024 -2026. The standards for passenger cars and light trucks for MYs 2024 -2025 were increased at a rate of 8 % per year and then increased at a rate of 10% per year for MY 2026 vehicles. NHTSA currently projects that the revised standards would require an industry fleet- wide average of roughly 49 mpg in MY 2026 and would reduce average fuel outlays over the lifetimes of affected vehicles that provide consumers hundreds of dollars in net savings. These standards are directly responsive to the agency’s statutory mandate to improve energy conservation and reduce the nation’s energy dependence on foreign sources (38).

ANDATORY REPORTING OF GHGS
The Consolidated Appropriations Act of 2008, passed in December 2007, requires the establishment of mandatory GHG reporting requirements. On September 22, 2009, the EPA issued the Final Mandatory Reporting of GHGs Rule, which became effective January 1, 2010.

The rule requires reporting of GHG emissions from large sources and suppliers in the U.S. and is intended to collect accurate and timely emissions data to inform future policy decisions. Under

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27 the rule, suppliers of fossil fuels or industrial GHGs, manufacturers of vehicles and engines, and facilities that emit 25,000 metric tons per year (MT/yr) or more of GHG emissions are required to submit annual reports to the EPA.

EW SOURCE REVIEW
The EPA issued a final rule on May 13, 2010, that establishes thresholds for GHGs that define when permits under the New Source Review Prevention of Significant Deterioration and Title V Operating Permit programs are required for new and existing industrial facilities. This final rule “tailors” the requirements of these CAA permitting programs to limit which facilities will be required to obtain Prevention of Significant Deterioration and Title V permits. In the preamble to the revisions to the Federal Code of Regulations, the EPA states:
“This rulemaking is necessary because without it the Prevention of Significant Deterioration and Title V requirements would apply, as of January 2, 2011, at the 100 or 250 tons per year levels provided under the CAA, greatly increasing the number of required permits, imposing undue costs on small sources, overwhelming the resources of permitting authorities, and severely impairing the functioning of the programs. EPA is relieving these resource burdens by phasing in the applicability of these programs to G HG sources, starting with the largest GHG emitters. This rule establishes two initial steps of the phase -in. The rule also commits the agency to take certain actions on future steps addressing smaller sources but excludes certain smaller sources from Pre vention of Significant Deterioration and Title V permitting for GHG emissions until at least April 30, 2016.”
The EPA estimates that facilities responsible for nearly 70 % of the national GHG emissions from stationary sources will be subject to permitting requirements under this rule. This includes the nation’s largest GHG emitters—power plants, refineries, and cement production facilities.

S
TANDARDS OF PERFORMANCE FOR GHG EMISSIONS FOR NEW STATIONARY SOURCES: ELECTRIC UTILITY GENERATING UNITS
As required by a settlement agreement, the EPA proposed new performance standards for emissions of CO
2 for new, affected, fossil fuel-fired electric utility generating units on March 27, 2012. New sources greater than 25 megawatts (MW) would be required to meet an output- based standard of 1,000 pounds (lbs) of CO2 per MW-hour (MWh), based on the performance of widely used natural gas combined cycle technology. It should be noted that on February 9, 2016, the Supreme Court issued a stay of this regulation pending litigation. Additionally, the current EPA Administrator has also signed a measure to repeal the Clean Power Plan, including the CO 2 standards. The Clean Power Plan was officially repealed on June 19, 2019, when the EPA issued the final Affordable Clean Energy rule (ACE). Under ACE, new state -specific emission guidelines were established that provided existing coal-fired electric utility generating units with achievable standards.

On January 19, 2021, the D.C. Circuit vacated the ACE rule and remanded to the EPA for further proceedings consistent with its opinion. As of February 12, 2021 - EPA does not expect states to

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28 take any further action to develop and submit plans under Clean Air Act section 111(d) with respect to GHGs emissions from power plants at this time.

CAP-AND-TRADE
Cap-and-trade refers to a policy tool where emissions are limited to a certain amount and can be traded or provides flexibility on how the emitter can comply. Successful examples in the U.S. include the Acid Rain Program and the N
2O Budget Trading Program and Clean Air Interstate Rule in the northeast. There is no federal GHG cap -and-trade program currently; however, some states have joined to create initiatives to provide a mechanism for cap-and-trade.

The Regional GHG Initiative is an effort to reduce GHGs among the states of Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New York, Rhode Island, and Vermont. Each state caps CO
2 emissions from power plants, auctions CO 2 emission allowances, and invests the proceeds in strategic energy programs that further reduce emissions, save consumers money, create jobs, and build a clean energy economy. The Initiative began in 2008 and in 2020 has retained all participating states.

The Western Climate Initiative (WCI) partner jurisdictions have developed a comprehensive initiative to reduce regional GHG emissions to 15% below 2005 levels by 2020. The partners were originally California, British Columbia, Manitoba, Ontario, and Quebec. However, Manitoba and Ontario are not currently participating. California linked with Quebec’s cap -and-trade system January 1, 2014, and joint offset auctions took place in 2015. While the WCI has yet to publish whether it has successfully reached the 2020 emissions goal initiative set in 2007, SB 32 requires that California, a major partner in the WCI, adopt the goal of reducing statewide GHG emissions to 40% below the 1990 level by 2030.

SMARTWAY PROGRAM
The SmartWay Program is a public -private initiative between the EPA, large and small trucking companies, rail carriers, logistics companies, commercial manufacturers, retailers, and other federal and state agencies. Its purpose is to improve fuel efficiency and the environmental performance (reduction of both GHG emissions and air pollution) of the goods movement supply chains. SmartWay is comprised of four components (39):

1. SmartWay Transport Partnership: A partnership in which freight carriers and shippers commit to benchmark operations, track fuel consumption, and improve performance annually.

2. SmartWay Technology Program: A testing, verification, and designation program to help freight companies identify equipment, technologies, and strategies that save fuel and lower emissions.

3. SmartWay Vehicles: A program that ranks light‐duty cars and small trucks and identifies superior environmental performers with the SmartWay logo.

4. SmartWay International Interests: Guidance and resources for countries seeking to develop freight sustainability programs modeled after SmartWay.

SmartWay effectively refers to requirements geared towards reducing fuel consumption. Most large trucking fleets driving newer vehicles are compliant with SmartWay design requirements.

Moreover, over time, all HDTs will have to comply with the CARB GHG Regulation that is designed with the SmartWay Program in mind, to reduce GHG emissions by making them more fuel -

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29 efficient. For instance, in 2015, 53 foot or longer dry vans or refrigerated trailers equipped with a combination of SmartWay -verified low -rolling resistance tires and SmartWay -verified aerodynamic devices would obtain a total of 10% or more fuel savings over traditional trailers.

Through the SmartWay Technology Program, the EPA has evaluated the fuel saving benefits of various devices through grants, cooperative agreements, emissions and fuel economy testing, demonstration projects and technical literature review. As a result, the EPA has determined the following types of technologies provide fuel saving and/or emission reducing benefits when used properly in their designed applications, and has verified certain products:
• Idle reduction technologies – less idling of the engine when it is not needed would reduce fuel consumption.
• Aerodynamic technologies minimize drag and improve airflow over the entire tractor‐trailer vehicle. Aerodynamic technologies include gap fairings that reduce turbulence between the tractor and trailer, side skirts that minimize wind under the trailer, and rear fairings that reduce turbulence and pressure drop at the rear of the trailer. • Low rolling resistance tires can roll longer without slowing down, thereby reducing the amount of fuel used. Rolling resistance (or rolling friction or rolling drag) is the force resisting the motion when a tire rolls on a surface. The wheel will eventua lly slow down because of this resistance.
• Retrofit technologies include things such as diesel particulate filters, emissions upgrades (to a higher tier), etc., which would reduce emissions.
• Federal excise tax exemptions.

EXECUTIVE ORDER 13990
On January 20, 2021, Federal agencies were directed to immediately review, and take action to address, Federal regulations promulgated and other actions taken during the last 4 years that conflict with national objectives to improve public health and the environment; ensure access to clean air and water; limit exposure to dangerous chemicals and pesticides; hold polluters accountable, including those who disproportionately harm communities of color and low-income communities; reduce GHG emissions; bolster resilience to the impacts of climate change; restore and expand our national treasures and monuments; and prioritize both environmental justice and employment.

3.3 MULTISTATE

WESTERN CLIMATE INITIATIVE (WCI)
The WCI is a partnership among seven different US states and four Canadian provinces aimed at developing a regional cap -and-trade economy to reduce GHG emissions. The following comes from the WCI’s website (40):

The WCI was built on existing greenhouse gas reduction efforts in the individual states as well as two existing regional efforts. In 2003, California, Oregon and Washington created the West Coast Global Warming Initiative, and in 2006, Arizona and New Mexico launched the Southwest Climate Change Initiative.

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30 During 2007 and 2008, the Premiers of British Columbia, Manitoba, Ontario, and Quebec, and the Governors of Montana and Utah joined the original five states in committing to tackle climate change at a regional level. All 11 jurisdictions collaborated in t he development of the Design for the WCI Regional Program, which was released in July 2010.

In November 2011, the Western Climate Initiative formed Western Climate Initiative, Inc. (WCI, Inc.), a non-profit corporation that will provide administrative and technical services to support the implementation of state and provincial greenhouse gas emissions trading programs.

British Columbia, California, Ontario, Quebec and Manitoba are continuing to work together through the Western Climate Initiative to develop and harmonize their emissions trading program policies. They are also continuing to work with Western, Midwestern, and Northeast states on a range of other climate and clean energy strategies through the North America 2050 Initiative. North America 2050 is a forum for states, provinces and stakeholders to identify leadership opportunities in climate and clean energy policy. (41)
P

ACIFIC COAST ACTION PLAN ON CLIMATE AND ENERGY
The governors of California, Oregon, Washington and the Premier of British Columbia have joined together to produce the Pacific Coast Action Plan signed on October 28, 2013 to reduce GHG emissions among other goals. The plan organizes their P acific coast economies around several initiatives including (42):
• Leading national and international policy on climate change o Accounting for a price on carbon.
o Harmonizing 2050 targets for GHG emission reductions and developing midterm targets need for long-term reduction goals.
o Affirming the need to inform policy with climate science findings. • Transition the West Coast to clean modes of transportation including 100% zero emissions vehicles by 2050
o Continuing deployment of high-speed rail.
o Supporting emerging markets and innovation for alternative fuels in trucks, buses, rail, and ports.
• Invest in clean energy and climate -resilient infrastructure including transforming the energy efficiency market and lead the way to net-zero buildings.

3.4 CALIFORNIA

3.4.1 LEGISLATIVE ACTIONS TO REDUCE GHGS
The State of California legislature has enacted a series of bills that constitute the most aggressive program to reduce GHGs of any state in the nation. Some legislation such as the landmark AB 32 was specifically enacted to address GHG emissions. Other legislation such as Title 24 and Title 20 energy standards were originally adopted for other purposes such as energy and water

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31 conservation, but also provide GHG reductions. This section describes the major provisions of the legislation.

AB 1881
The Water Conservation in Landscaping Act of 2006 requires local agencies to adopt the updated DWR model ordinance or equivalent. AB 1881 also requires the CEC to consult with the DWR to adopt, by regulation, performance standards and labeling requirements for landscape irrigation equipment, including irrigation controllers, moisture sensors, emission devices, and valves to reduce the wasteful, uneconomic, inefficient, or unnecessary consumption of energy or water.

SB
1368
California SB 1368 adds Sections 8340 and 8341 to the Public Utilities Code (effective January 1, 2007) with the intent “to prevent long-term investments in power plants with GHG emissions in excess of those produced by a combined-cycle natural gas power plant” with the aim of “reducing emissions of GHGs from the state’s electricity consumption, not just the state’s electricity production.” SB 1368 provides a mechanism for reducing the GHG emissions of electricity providers, both in-state and out-of-state, thereby assisting CARB in meeting its mandate under AB 32, the Global Warming Solutions Act of 2006.

AB
32 The California State Legislature enacted AB 32, which require d that GHGs emitted in California be reduced to 1990 levels by the year 2020 (this goal has been met4). GHGs as defined under AB 32 include CO2, CH4, N2O, HFCs, PFCs, and SF6. Since AB 32 was enacted, a seventh chemical, NF3, has also been added to the list of GHGs. CARB is the state agency charged with monitoring and regulating sources of GHGs. Pursuant to AB 32, CARB adopted regulations to achieve the maximum technologically feasible and cost-effective GHG emission reductions. AB 32 states the following:
“Global warming poses a serious threat to the economic well-being, public health, natural resources, and the environment of California. The potential adverse impacts of global warming include the exacerbation of air quality problems, a reduction in the quality and supply of water to the state from the Sierra snowpack, a rise in sea levels resulting in the displacement of thousands of coastal businesses and residences, damage to marine ecosystems and the natural environment, and an increase in the incidence s of infectious diseases, asthma, and other human health-related problems.”
SB
375
On September 30, 2008, SB 375 was signed by Governor Schwarzenegger. According to SB 375, the transportation sector is the largest contributor of GHG emissions, which emits over 40% of the total GHG emissions in California. SB 375 states, “Without improved land use and transportation policy, California will not be able to achieve the goals of AB 32.” SB 375 does the following: it (1) requires

4 Based upon the 2019 GHG inventory data (i.e., the latest year for which data are available) for the 2000-2017 GHG emissions period, California emitted an average 424.1 MMTCO2e (71). This is less than the 2020 emissions target of 431 MMTCO2e.

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32 metropolitan planning organizations (MPOs) to include sustainable community strategies in their regional transportation plans for reducing GHG emissions, (2) aligns planning for transportation and housing, and (3) creates specified incentives for the implementation of the strategies.

SB 375 requires MPOs to prepare a Sustainable Communities Strategy (SCS) within the Regional Transportation Plan (RTP) that guides growth while taking into account the transportation, housing, environmental, and economic needs of the region. SB 375 uses C EQA streamlining as an incentive to encourage residential projects, which help achieve AB 32 goals to reduce GHG emissions. Although SB 375 does not prevent CARB from adopting additional regulations, such actions are not anticipated in the foreseeable future.

Concerning CEQA, SB 375, as codified in Public Resources Code Section 21159.28, states that CEQA findings for certain projects are not required to reference, describe, or discuss (1) growth inducing impacts, or (2) any project-specific or cumulative impacts from cars and light-duty truck trips generated by the project on global warming or the regional transportation network, if the project:

1. Is in an area with an approved sustainable communities strategy or an alternative planning strategy that CARB accepts as achieving the GHG emission reduction targets.

2. Is consistent with that strategy (in designation, density, building intensity, and applicable policies).

3. Incorporates the MMs required by an applicable prior environmental document.

AB 1493 - Pavley Fuel Efficiency Standards
Enacted on July 22, 2002, California AB 1493, also known as the Pavley Fuel Efficiency Standards, required CARB to develop and adopt regulations that reduce GHGs emitted by passenger vehicles and light duty trucks. Implementation of the regulation was delayed by lawsuits filed by automakers and by the EPA’s denial of an implementation waiver. The EPA subsequently granted the requested waiver in 2009, which was upheld by the U.S. District Court for the District of Columbia in 2011.

The standards phase is during the 2009 through 2016 MY . Several technologies stand out as providing significant reductions in emissions at favorable costs. These include discrete variable valve lift or camless valve actuation to optimize valve operation rather than relying on fixed valve timing and lift as has historically been done; turbocharging to boost power and allow for engine downsizing; improved multi -speed transmissions; and improved air conditioning systems that operate optimally, leak less, and/or use an alternative refrigerant.

The second phase of the implementation for the Pavley bill was incorporated into Amendments to the Low-Emission Vehicle Program ( LEV III) or the Advanced Clean Cars (ACC) program. The ACC program combines the control of smog -causing pollutants and GHG emissions into a single coordinated package of requirements for MY 2017 through 2025. The regulation will reduce GHGs from new cars by 34% from 2016 levels by 2025. The new rules will clean up gasoline and diesel-powered cars, and deliver increasing numbers of zero-emission technologies, such as full battery electric cars, newly emerging plug-in hybrid EV and hydrogen fuel cell cars. The package will also ensure adequate fueling infrastructure is available for the increasing numbers of hydrogen fuel cell vehicles planned for deployment in California.

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33 On March 9, 2022, the EPA reinstated California’s authority under the Clean Air Act to implement its own greenhouse gas emission standards for cars and light trucks, which other states can also adopt and enforce. With this authority restored, EPA will continue partnering with states to advance the next generation of clean vehicle technologies.

C
LEAN ENERGY AND POLLUTION REDUCTION ACT OF 2015 (SB 350) In October 2015, the legislature approved, and Governor Jerry Brown signed SB 350, which reaffirms California’s commitment to reducing its GHG emissions and addressing climate change.

Key provisions include an increase in the RPS, higher energy efficiency requirements for buildings, initial strategies towards a regional electricity grid, and improved infrastructure for EV charging stations. Provisions for a 50 % reduction in the use of petroleum statewide were removed from the Bill because of opposition and concern that it would prevent the Bill’s passage. Specifically, SB 350 requires the following to reduce statewide GHG emissions:
• Increase the amount of electricity procured from renewable energy sources from 33 % to 50% by 2030, with interim targets of 40% by 2024, and 25% by 2027. • Double the energy efficiency in existing buildings by 2030. This target will be achieved through the California Public Utilities Commission (CPUC), the California Energy Commission (CEC), and local publicly owned utilities.
• Reorganize the Independent System Operator (ISO) to develop more regional electrify transmission markets and to improve accessibility in these markets, which will facilitate the growth of renewable energy markets in the western United States.

SB 32
On September 8, 2016, Governor Brown signed SB 32 and its companion bill, AB 197. SB 32 requires the state to reduce statewide GHG emissions to 40 % below 1990 levels by 2030, a reduction target that was first introduced in Executive Order B-30-15. The new legislation builds upon the AB 32 goal and provides an intermediate goal to achieving S -3-05, which sets a statewide GHG reduction target of 80 % below 1990 levels by 2050. AB 197 creates a legislative committee to oversee regulators to ensure that CARB not only responds to the Governor, but also the Legislature (12).
2017

CARB SCOPING PLAN
In November 2017, CARB released the Final 2017 Scoping Plan Update (2017 Scoping Plan), which identifies the State’s post- 2020 reduction strategy. The 2017 Scoping Plan reflects the 2030 target of a 40% reduction below 1990 levels, set by Executive Order B -30-15 and codified by SB

32. Key programs that the proposed Second Update builds upon include the Cap- and-Trade Regulation, the LCFS, and much cleaner cars, trucks and freight movement, utilizing cleaner, renewable energy, and strategies to reduce CH4 emissions from agricultural and other wastes.

The 2017 Scoping Plan establishes a new emissions limit of 260 MMTCO 2e for the year 2030, which corresponds to a 40% decrease in 1990 levels by 2030 (43).

California’s climate strategy will require contributions from all sectors of the economy, including the land base, and will include enhanced focus on zero and near -zero emission (ZE/NZE) vehicle technologies; continued investment in renewables, including solar roofs, wind, and other

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34 distributed generation; greater use of low carbon fuels; integrated land conservation and development strategies; coordinated efforts to reduce emissions of short-lived climate pollutants (CH4, black carbon, and fluorinated gases); and an increased focus on integrated land use planning to support livable, transit-connected communities and conservation of agricultural and other lands. Requirements for direct GHG reductions at refineries will further support air quality co-benefits in neighborhoods, including in disadvantaged communities historically located adjacent to these large stationary sources, as well as efforts with California’s local air pollution control and air quality management districts (air districts) to tighten emission limits on a broad spectrum of industrial sources. Major elements of the 2017 Scoping Plan framework include:
• Implementing and/or increasing the standards of the Mobile Source Strategy, which include increasing zero-emission vehicles (ZEV) buses and trucks. • LCFS, with an increased stringency (18% by 2030).
• Implementing SB 350, which expands the RPS to 50 % RPS and doubles energy efficiency savings by 2030.
• California Sustainable Freight Action Plan, which improves freight system efficiency, utilizes near-zero emissions technology, and deployment of ZEV trucks. • Implementing the proposed Short-Lived Climate Pollutant Strategy (SLPS), which focuses on reducing CH
4 and HCF emissions by 40% and anthropogenic black carbon emissions by 50% by year 2030.
• Continued implementation of SB 375.
• Post-2020 Cap-and-Trade Program that includes declining caps. • 20% reduction in GHG emissions from refineries by 2030. • Development of a Natural and Working Lands Action Plan to secure California’s land base as a net carbon sink.

Note, however, that the 2017 Scoping Plan acknowledges that:
“[a]chieving net zero increases in GHG emissions, resulting in no contribution to GHG impacts, may not be feasible or appropriate for every project, however, and the inability of a project to mitigate its GHG emissions to net zero does not imply the projec t results in a substantial contribution to the cumulatively significant environmental impact of climate change under CEQA.”
In addition to the statewide strategies listed above, the 2017 Scoping Plan also identifies local governments as essential partners in achieving the State’s long -term GHG reduction goals and identifies local actions to reduce GHG emissions. As part of the recommended actions, CARB recommends that local governments achieve a community-wide goal to achieve emissions of no more than 6 metric tons of CO
2e (MTCO2e) or less per capita by 2030 and 2 MTCO 2e or less per capita by 2050. For CEQA projects, CARB states that lead agencies may develop evidence- based bright-line numeric thresholds—consistent with the 2017 Scoping Plan and the State’s long-term GHG goals—and projects with emissions over that amount may be required to incorporate on- site design features and MMs that avoid or minimize project emissions to the degree feasible; or, a performance-based metric using a CAP or other plan to reduce GHG emissions is appropriate.

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35 According to research conducted by the Lawrence Berkeley National Laboratory (LBNL) and supported by CARB, California, under its existing and proposed GHG reduction policies, could achieve the 2030 goals under SB 32. The research utilized a new, validated model known as the California LBNL GHG Analysis of Policies Spreadsheet (CALGAPS), which simulates GHG and criteria pollutant emissions in California from 2010 to 2050 in accordance to existing and future GHG-reducing policies. The CALGAPS model showed tha t by 2030, emissions could range from 211 to 428 MTCO
2e per year (MTCO2e/yr), indicating that “even if all modeled policies are not implemented, reductions could be sufficient to reduce emissions 40 % below the 1990 level [of SB 32].” CALGAPS analyzed emissions through 2050 even though it did not generally account for policies that might be put in place after 2030. Although the research indicated that the emissions would not meet the State’s 80 % reduction goal by 2050, various combinations of policies could allow California’s cumulative emissions to remain very low through 2050 (44) (45). 2022 CARB SCOPING PLAN
On December 15, 2022, CARB adopted the 2022 Scoping Plan for Achieving Carbon Neutrality (2022 Scoping Plan) (24). The 2022 Scoping Plan builds on the 2017 Scoping Plan as well as the requirements set forth by AB 1279, which directs the state to become carbon neutral no later than 2045. To achieve this statutory objective, the 2022 Scoping Plan lays out how California can reduce GHG emissions by 85% below 1990 levels and achieve carbon neutrality by 2045. The Scoping Plan scenario to do this is to “deploy a broad portfolio of existing and emerging fossil fuel alternatives and clean technologies, and align with statutes, Executive Orders, Board direction, and direction from the governor.” The 2022 Scoping Plan sets one of the most aggressive approaches to reach carbon neutrality in the world. Unlike the 2017 Scoping Plan, CARB no longer includes a numeric per capita threshold and instead advocates for compliance with a local GHG reduction strategy (CAP) consistent with CEQA Guidelines section 15183.5.

The key elements of the 2022 CARB Scoping Plan focus on transportation - the regulations that will impact this sector are adopted and enforced by CARB on vehicle manufacturers and outside the jurisdiction and control of local governments. As stated in the Plan’s executive summary:
“The major element of this unprecedented transformation is the aggressive reduction of fossil fuels wherever they are currently used in California, building on and accelerating carbon reduction programs that have been in place for a decade and a half. That means rapidly moving to zero - emission transportation; electrifying the cars, buses, trains, and trucks that now constitute California’s single largest source of planet-warming pollution.” “[A]pproval of this plan catalyzes a number of efforts, including the development of new regulations as well as amendments to strengthen regulations and programs already in place, not just at CARB but across state agencies.”
Under the 2022 Scoping Plan, the State will lead efforts to meet the 2045 carbon neutrality goal through implementation of the following objectives:
• Reimagine roadway projects that increase VMT in a way that meets community needs and reduces the need to drive.
• Double local transit capacity and service frequencies by 2030.

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36 • Complete the High-Speed Rail (HSR) System and other elements of the intercity rail network by 2040.
• Expand and complete planned networks of high-quality active transportation infrastructure. • Increase availability and affordability of bikes, e -bikes, scooters, and other alternatives to light - duty vehicles, prioritizing needs of underserved communities. • Shift revenue generation for transportation projects away from the gas tax into more durable sources by 2030.
• Authorize and implement roadway pricing strategies and reallocate revenues to equitably improve transit, bicycling, and other sustainable transportation choices. • Prioritize addressing key transit bottlenecks and other infrastructure investments to improve transit operational efficiency over investments that increase VMT. • Develop and implement a statewide transportation demand management (TDM) framework with VMT mitigation requirements for large employers and large developments. • Prevent uncontrolled growth of autonomous vehicle (AV) VMT, particularly zero-passenger miles. • Channel new mobility services towards pooled use models, transit complementarity, and lower VMT outcomes.
• Establish an integrated statewide system for trip planning, booking, payment, and user accounts that enables efficient and equitable multimodal systems. • Provide financial support for low-income and disadvantaged Californians’ use of transit and new mobility services.
• Expand universal design features for new mobility services. • Accelerate infill development in existing transportation-efficient places and deploy strategic resources to create more transportation-efficient locations. • Encourage alignment in land use, housing, transportation, and conservation planning in adopted regional plans (RTP/SCS and RHNA) and local plans (e.g., general plans, zoning, and local transportation plans).
• Accelerate production of affordable housing in forms and locations that reduce VMT and affirmatively further fair housing policy objectives.
• Reduce or eliminate parking requirements (and/or enact parking maximums, as appropriate) and promote redevelopment of excess parking, especially in infill locations. • Preserve and protect existing affordable housing stock and protect existing residents and businesses from displacement and climate risk.

Included in the 2022 Scoping Plan is a set of Local Actions (Appendix D to the 2022 Scoping Plan) aimed at providing local jurisdictions with tools to reduce GHGs and assist the state in meeting the ambitious targets set forth in the 2022 Scoping Plan. Appendix D to the 2022 Scoping Plan includes a section on evaluating plan- level and project-level alignment with the State’s Climate Goals in CEQA GHG analyses. In this section, CARB identifies several recommendations and strategies that should be considered for new development to determine consistency with the 2022 Scoping Plan. CARB’s primary recommendation for determining consistency with the 2022 Scoping Plan and determining a less than significant impact is for Project’s to rely on a CEQA - qualified Climate Action Plan (CAP).

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37 In Appendix D of the 2022 Scoping Plan, CARB states: “When jurisdictions have a CEQA-qualified CAP, an individual project that complies with the strategies and actions within a CEQA -qualified CAP can tier and streamline its project-specific CEQA GHG analysis to make a determination “that a project’s incremental contribution to a cumulative [GHG] effect is not cumulatively considerable” (CEQA Guidelines Sections 1 5064.4 (b)(3) and 15183.5). CARB states that CEQA - qualified CAPs serve to assist the state with its long-term carbon neutrality goals.

Additionally on Page 21 in Appendix D, CARB states: “The recommendations outlined in this section apply only to residential and mixed- use development project types. California currently faces both a housing crisis and a climate crisis, which necessitates prioritizing recommendations for residential projects to address the housing crisis in a manner that simultaneously supports the State’s GHG and regional air quality goals. CARB plans to continue to explore new approaches for other land use types in the future.” As such, it would be inappropriate to apply the requirements contained in Appendix D of the 2022 Scoping Plan to any land use types other than residential or mixed-use residential development
C

AP-AND-TRADE PROGRAM
The 2017 Scoping Plan identifies a Cap- and-Trade Program as one of the key strategies for California to reduce GHG emissions. According to CARB, a cap -and-trade program will help put California on the path to meet its goal of achieving a 40% reduction in GHG emissions from 1990 levels by 2030. Under cap -and-trade, an overall limit on GHG emissions from capped sectors is established, and facilities subject to the cap will be able to trade permits to emit GHGs within the overall limit.

CARB adopted a California Cap -and-Trade Program pursuant to its authority under AB 32. The Cap-and-Trade Program is designed to reduce GHG emissions from regulated entities by more than 16% between 2013 and 2020, and by an additional 40% by 2030. The statewide cap for GHG emissions from the capped sectors (e.g., electricity generation, petroleum refining, and cement production) commenced in 2013 and will decline over time, achieving GHG emission reductions throughout the program’s duration.

Covered entities that emit more than 25 ,000 MTCO2e/yr must comply with the Cap- and-Trade Program. Triggering of the 25,000 MTCO2e/yr “inclusion threshold” is measured against a subset of emissions reported and verified under the California Regulation for the Mandatory Reporting of GHG Emissions (Mandatory Reporting Rule or “MRR”).

Under the Cap- and-Trade Program, CARB issues allowances equal to the total amount of allowable emissions over a given compliance period and distributes these to regulated entities.

Covered entities are allocated free allowances in whole or part (if eligible), and may buy allowances at auction, purchase allowances from others, or purchase offset credits. Each covered entity with a compliance obligation is required to surrender “compliance instruments” for each MTCO
2e of GHG they emit. There also are requirem ents to surrender compliance instruments covering 30% of the prior year’s compliance obligation by November of each year (46).

The Cap -and-Trade Program provides a firm cap, which provides the highest certainty of achieving the 2030 target. An inherent feature of the Cap- and-Trade program is that it does not guarantee GHG emissions reductions in any discrete location or by any particular source. Rather,

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38 GHG emissions reductions are only guaranteed on an accumulative basis. As summarized by CARB in the First Update to the Climate Change Scoping Plan:
“The Cap-and-Trade Regulation gives companies the flexibility to trade allowances with others or take steps to cost-effectively reduce emissions at their own facilities.

Companies that emit more have to turn in more allowances or other compliance instruments. Companies that can cut their GHG emissions have to turn in fewer allowances. But as the cap declines, aggregate emissions must be reduced. In other words, a covered entity theoretically could increase its GHG emissions every year and still comply with the Cap- and-Trade Program if there is a reduction in GHG emissions from other covered entities. Such a focus on aggregate GHG emissions is considered appropriate because climate change is a global phenomenon, and the effects of GHG emissions are considered cumulative.” (47) The Cap-and-Trade Program covers approximately 80% of California’s GHG emissions (43) . The Cap-and-Trade Program covers the GHG emissions associated with electricity consumed in California, whether generated in-state or imported. Accordingly, GHG emissions associated with CEQA projects’ electricity usage are covered by the Cap-and-Trade Program. The Cap-and-Trade Program also covers fuel suppliers (natural gas and propane fuel providers and transportation fuel providers) to address emissions from such fuels and from combustion of other fossil fuels not directly covered at large sources in the Program’s first compliance period. The Cap-and-Trade Program covers the GHG emissions associated with the combustion of transportation fuels in California, whether refined in-state or imported.

3.4.2 E

XECUTIVE ORDERS RELATED TO GHG EMISSIONS
California’s Executive Branch has taken several actions to reduce GHGs through the use of Executive Orders. Although not regulatory, they set the tone for the state and guide the actions of state agencies.

E
XECUTIVE ORDER S-3-05
California Governor Arnold Schwarzenegger announced on June 1, 2005, through Executive Order S-3-05, the following reduction targets for GHG emissions:
• By 2010, reduce GHG emissions to 2000 levels.
• By 2020, reduce GHG emissions to 1990 levels.
• By 2050, reduce GHG emissions to 80% below 1990 levels.

The 2050 reduction goal represents what some scientists believe is necessary to reach levels that will stabilize the climate. The 2020 goal was established to be a mid-term target. Because this is an executive order, the goals are not legally enforceable for local governments or the private sector.

EXECUTIVE ORDER S-01-07 (LCFS)
Governor Schwarzenegger signed Executive Order S -01-07 on January 18, 2007. The order mandates that a statewide goal shall be established to reduce the carbon intensity of California’s transportation fuels by at least 10% by 2020. CARB adopted the LCFS on April 23, 2009.

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39 The LCFS was challenged in the U.S. District Court in Fresno in 2011. The court’s ruling issued on December 29, 2011, included a preliminary injunction against CARB’s implementation of the rule.

The Ninth Circuit Court of Appeals stayed the injunction on April 23, 2012, pending final ruling on appeal, allowing CARB to continue to implement and enforce the regulation. The Ninth Circuit Court’s decision, filed September 18, 2013, vacated the preliminary injunction. In essence, the court held that LCFS adopted by CARB were not in conflict with federal law. On August 8, 2013, the Fifth District Court of Appeal (California) ruled CARB failed to comply with CEQA and the Administrative Procedure Act (APA) when adopting regulations for LCFS. In a partially published opinion, the Court of Appeal reversed the trial court’s judgment and directed issuance of a writ of mandate setting aside Resolution 09 -31 and two executive orders of CARB approving LCFS regulations promulgated to reduce GHG emissions. However, the court tailored its remedy to protect the public interest by allowing the LCFS regulations to remain operative while CARB complies with the procedural requirements it failed to satisfy.

To address the Court ruling, CARB was required to bring a new LCFS regulation to the Board for consideration in February 2015. The proposed LCFS regulation was required to contain revisions to the 2010 LCFS as well as new provisions designed to foster inv estments in the production of the low- carbon intensity fuels, offer additional flexibility to regulated parties, update critical technical information, simplify and streamline program operations, and enhance enforcement.

On November 16, 2015, the Office of Administrative Law (OAL) approved the Final Rulemaking Package. The new LCFS regulation became effective on January 1, 2016.

In 2018, CARB approved amendments to the regulation, which included strengthening the carbon intensity benchmarks through 2030 in compliance with the SB 32 GHG emissions reduction target for 2030. The amendments included crediting opportunities to promote zero emission vehicle adoption, alternative jet fuel, carbon capture and sequestration, and advanced technologies to achieve deep decarbonization in the transportation sector (48).

E
XECUTIVE ORDER S-13-08
Executive Order S -13-08 states that “climate change in California during the next century is expected to shift precipitation patterns, accelerate sea level rise and increase temperatures, thereby posing a serious threat to California’s economy, to the health and welfare of its population and to its natural resources.” Pursuant to the requirements in the Order, the 2009 California Climate Adaptation Strategy (CNRA 2009) was adopted, which is the “…first statewide, multi-sector, region-specific, and informat ion-based climate change adaptation strategy in the United States.” Objectives include analyzing risks of climate change in California, identifying and exploring strategies to adapt to climate change, and specifying a direction for future research.

E
XECUTIVE ORDER B-30-15
On April 29, 2015, Governor Brown issued an executive order to establish a California GHG reduction target of 40 % below 1990 levels by 2030. The Governor’s executive order align ed California’s GHG reduction targets with those of leading international governments ahead of the U.N. Climate Change Conference in Paris late 2015. The Order sets a new interim statewide GHG emission reduction target to reduce GHG emissions to 40 % below 1990 levels by 2030 in order to ensure California meets its target of reducing GHG emissions to 80% below 1990 levels by 2050

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40 and directs CARB to update the 2017 Scoping Plan to express the 2030 target in terms of MMTCO2e. The Order also requires the state’s climate adaptation plan to be updated every three years, and for the State to continue its climate change research program, among other provisions.

As with Executive Order S-3-05, this Order is not legally enforceable as to local governments and the private sector.

EXECUTIVE ORDER B-55-18 AND SB 100
SB 100 and Executive Order B- 55-18 were signed by Governor Brown on September 10, 2018.

Under the existing RPS, 25 % of retail sales of electricity are required to be from renewable sources by December 31, 2016, 33% by December 31, 2020, 40% by December 31, 2024, 45% by December 31, 2027, and 50% by December 31, 2030. SB 100 raises California’s RPS requirement to 50% renewable resources target by December 31, 2026, and to achieve a 60 % target by December 31, 2030. SB 100 also requires that retail sellers and local publicly owned electric utilities procure a minimum quantity of electricity products from eligible renewable energy resources so that the total kilowatt hours (kWh) of those products sold to their retail end- use customers achieve 44 % of retail sales by December 31, 2024, 52 % by December 31, 2027, and 60% by December 31, 2030. In addition to targets under AB 32 and SB 32, Executive Order B-55- 18 establishes a carbon neutrality goal for the state of California by 2045; and sets a goal to maintain net negative emissions thereafter. The Executive Order directs the California Natural Resources Agency (CNRA), California EPA (CalEPA), the California Department of Food and Agriculture (CDFA), and CARB to include sequestration targets in the Natural and Working Lands Climate Change Implementation Plan consistent with the carbon neutrality goal.

3.4.3 CALIFORNIA REGULATIONS AND BUILDING CODES
California has a long history of adopting regulations to improve energy efficiency in new and remodeled buildings. These regulations have kept California’s energy consumption relatively flat even with rapid population growth.

T
ITLE 20 CCR SECTIONS 1601 ET SEQ. – APPLIANCE EFFICIENCY REGULATIONS The Appliance Efficiency Regulations regulate the sale of appliances in California. The Appliance Efficiency Regulations include standards for both federally regulated appliances and non- federally regulated appliances. 23 categories of appliances are includ ed in the scope of these regulations. The standards within these regulations apply to appliances that are sold or offered for sale in California, except those sold wholesale in California for final retail sale outside the state and those designed and s old exclusively for use in recreational vehicles (RV) or other mobile equipment (CEC 2012).

TITLE 24 CCR PART 6 – CALIFORNIA ENERGY CODE
The California Energy Code was first adopted in 1978 in response to a legislative mandate to reduce California’s energy consumption.

The standards are updated periodically to allow consideration and possible incorporation of new energy efficient technologies and methods.

TITLE 24 CCR PART 11 – CALIFORNIA GREEN BUILDING STANDARDS CODE

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41 The standards are updated periodically to allow consideration and possible incorporation of new energy efficient technologies and methods. CCR, Title 24, Part 11: California Green Building Standards Code (CALGreen) is a comprehensive and uniform regulatory code for all residential, commercial, and school buildings that went in effect on August 1, 2009, and is administered by the California Building Standards Commission.

CALGreen is updated on a regular basis, with the most recent approved update consisting of the 2022 California Green Building Code Standards that became effective on January 1, 20235. The CEC anticipates that the 2022 energy code will provide $1.5 billion in consumer benefits and reduce GHG emissions by 10 million metric tons (49) . The Project would be required to comply with the applicable standards in place at the time plan check submittals are made. Current CALGreen standards require, among other items (50):

ESIDENTIAL MANDATORY MEASURES
• Electric vehicle (EV) charging stations. New construction shall comply with Section 4.106.4.1,

4.106.4.2, 4.106.4.3, to facilitate future installation and use of EV chargers. Electric vehicle supply equipment (EVSE) shall be installed in accordance with th e California Electrical Code , Article 625. (4.106.4).
o New one- and two-family dwellings and town-houses with attached private garages. For each dwelling unit, install a listed raceway to accommodate a dedicated 208/240 -volt branch circuit. The raceway shall not be less than trade size 1 (nominal 1 -inch inside diameter). The raceway shall originate at the main service or subpanel and shall terminate into a listed cabinet, box or other enclosure in close proximity to the proposed location of an EV charger. Raceways are required to be continuous at enclosed, inaccessible or concealed areas and spaces. The service panel and/or subpanel shall provide capacity to install a 40-ampere 208/240-volt minimum dedicated branch circuit and space(s) reserved to permit installation of a branch circuit overcurrent protective device.
o New hotels and motels. All newly constructed hotels and motels shall provide EV spaces capable of supporting future installation of EVSE. The construction documents shall identify the location of the EV spaces. The number of required EV spaces shall be based on the total number of parking spaces provided for all types of parking facilities in accordance with Table 4.106.4.3.1.
• Water conserving plumbing fixtures and fittings . Plumbing fixtures (water closets and urinals) and fittings (faucets and showerheads) shall comply with Sections 4.303.1.1, 4.303.1.2,

4.303.1.3, and 4.303.1.4.
• Outdoor potable water use in landscape areas. Residential developments shall comply with a local water efficient landscape ordinance or the current California Department of Water Resource ‘ Model Water Efficient Landscape Ordinance (MWELO), whichever is more stringent.

5 The 2022 California Energy and Green Building Standard Code became effective on January 1, 2023, however; it has since been amended on July 1, 2024 with the Intervening Code Cycle Update which is reflected in this report. Additionally, i t should be noted that the Energy Code and CALGreen provisions are currently being updated, with the most recent draft update consisting of the 2025 California Energy and Green Building Code Standards that will be effective on January 1, 2025. As construction of the Project is anticipated to be completed in 2028, it is presumed that the Project would be required to comply with the Title 24 standards in place at that time.

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42 • Operation and maintenance manual. At the time of final inspection, a manual, compact disc, web-based reference or other media acceptable to the enforcing agency which includes all of the following shall be placed in the building:
o Directions to the owner or occupant that the manual shall remain with the building throughout the life cycle of the structure.
o Operations and maintenance instructions for the following:

1. Equipment and appliances, including water -saving devices and systems, HVAC systems, photovoltaic systems, EV chargers, water -heating systems and other major appliances and equipment.

2. Roof and yard drainage, including gutter and downspouts.

3. Space conditioning systems, including condensers and air filters.

4. Landscape irrigation systems.

5. Water reuse systems.
o Information from local utility, water and waste recovery providers on methods to future reduce resource consumption, including recycle programs and locations. o Public transportation and/or carpool options available in the area. o Educational material on the positive impacts of an interior relative humidity between 30-60% and what methods an occupants may use to maintain the relative humidity level in that range.
o Information about water -conserving landscape and irrigation design and controllers which conserve water.
o Instructions for maintaining gutters and downspouts and the importance of diverting water at least 5 feet away from the foundation.
o Information about state solar energy and incentive programs available. o A copy of all special inspection verifications required by the enforcing agency of this code.
o Information from CALFIRE on maintenance of defensible space around residential structures.
• Any installed gas fireplace shall be direct-vent sealed-combustion type. Any installed woodstove or pellet stove shall comply with U.S. EPA New Source Performance Standards (NSPS) emission limits as applicable, and shall have a permanent label indicating t hey are certified to meet the emission limits. Woodstoves, pellet stoves and fireplaces shall also comply with applicable local ordinances.
• Paints and coatings. Architectural paints and coatings shall comply with VOC limits in Table 1 of the CARB Architectural Suggested Control Measure, as shown in Table 4.504.3, unless more stringent local limits apply. The VOC content limit for coatings that do not meet the definitions for the specialty coatings categories listed in Table 4.504.3 shall be determined by classifying the coating as a Flat, Nonflat, or Nonflat -high Gloss coating, based on its glass, as defined in subsections 4.21, 4.36, and 4.37 of the 2007 CARB, Suggested Control Measure, and the corresponding Flat, Nonflat, Nonflat-high Gloss VOC limit in Table 4.504.3 shall apply.

NONRESIDENTIAL MANDATORY MEASURES

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43 • Short-term bicycle parking. If the new project or an additional alteration is anticipated to generate visitor traffic, provide permanently anchored bicycle racks within 200 feet of the visitors’ entrance, readily visible to passers-by, for 5% of new visitor motorized vehicle parking spaces being added, with a minimum of one two-bike capacity rack (5.106.4.1.1).
• Long-term bicycle parking. For new buildings with tenant spaces that have 10 or more tenant-occupants, provide secure bicycle parking for 5% of the tenant-occupant vehicular parking spaces with a minimum of one bicycle parking facility (5.106.4.1.2). • EV charging stations. New construction shall facilitate the future installation of EV supply equipment. The compliance requires empty raceways for future conduit and documentation that the electrical system has adequate capacity for the future load. The number of spaces to be provided for is contained in Table 5.106. 5.3.1 (5.106.5.3). Alternatively, the power allocation method may be used as an alternative to the requirements mentioned in Section

5.106.5.1, and associated Table 5.106.5.3. Use of Table 5.106.5.3.6 to can be used to determine the total power in kVA required based on the total number of actual parking spaces.

Additionally, Table 5.106.5.5.1 specifies requirements for the installation of raceway conduit and panel power requirements for medium- and heavy -duty EV supply equipment for warehouses, grocery stores, and retail stores.
• Outdoor light pollution reduction. Outdoor lighting systems shall be designed to meet the backlight, uplight and glare ratings per Table 5.106.8 (5.106.8). • Construction waste management. Recycle and/or salvage for reuse a minimum of 65% of the nonhazardous construction and demolition waste in accordance with Section

5.408.1.1. 5.405.1.2, or 5.408.1.3; or meet a local construction and demolition waste management ordinance, whichever is more stringent (5.408.1). • Excavated soil and land clearing debris. 100% of trees, stumps, rocks and associated vegetation and soils resulting primarily from land clearing shall be reused or recycled. For a phased project, such material may be stockpiled on site until the storage site is developed (5.408.3).
• Recycling by Occupants. Provide readily accessible areas that serve the entire building and are identified for the depositing, storage, and collection of non-hazardous materials for recycling, including (at a minimum) paper, corrugated cardboard, glass, plastics, organic waste, and metals or meet a lawfully enacted local recycling ordinance, if more restrictive (5.410.1).
• Water conserving plumbing fixtures and fittings. Plumbing fixtures (water closets and urinals) and fittings (faucets and showerheads) shall comply with the following:
o Water Closets. The effective flush volume of all water closets shall not exceed 1.28 gallons per flush (5.303.3.1).
o Urinals. The effective flush volume of wall-mounted urinals shall not exceed 0.125 gallons per flush (5.303.3.2.1). The effective flush volume of floor- mounted or other urinals shall not exceed 0.5 gallons per flush (5.303.3.2.2). o Showerheads. Single showerheads shall have a minimum flow rate of not more than 1.8 gallons per minute and 80 psi (5.303.3.3.1). When a shower is served by more than one showerhead, the combined flow rate of all showerheads and/or other shower outlets controlled by a single valve shall not exceed 1.8 gallons per minute at 80 psi (5.303.3.3.2).

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44 o Faucets and fountains. Nonresidential lavatory faucets shall have a maximum flow rate of not more than 0.5 gallons per minute at 60 psi (5.303.3.4.1). Kitchen faucets shall have a maximum flow rate of not more than 1.8 gallons per minute of 60 psi (5.303.3.4.2). Wash fountains shall have a maximum flow rate of not more than 1.8 gallons per minute (5.303.3.4.3). Metering faucets shall not deliver more than 0.20 gallons per cycle (5.303.3.4.4). Metering faucets for wash fountains shall have a maximum flow rate not more than 0.20 gallons per cycle (5.303.3.4.5). • Outdoor potable water uses in landscaped areas. Nonresidential developments shall comply with a local water efficient landscape ordinance or the current California Department of Water Resources’ Model Water Efficient Landscape Ordinance (MWELO), whichever is more stringent (5.304.1).
• Water meters. Separate submeters or metering devices shall be installed for new buildings or additions in excess of 50,000 sf or for excess consumption where any tenant within a new building or within an addition that is projected to consume more than 1,000 gallons per day (GPD) (5.303.1.1 and 5.303.1.2).
• Outdoor water uses in rehabilitated landscape projects equal or greater than 2,500 sf.

Rehabilitated landscape projects with an aggregate landscape area equal to or greater than 2,500 sf requiring a building or landscape permit (5.304.3). • Commissioning. For new buildings 10,000 sf and over, building commissioning shall be included in the design and construction processes of the building project to verify that the building systems and components meet the owner’s or owner representative’s project requirements (5.410.2).

CARB REFRIGERANT MANAGEMENT PROGRAM
CARB adopted a regulation in 2009 to reduce refrigerant GHG emissions from stationary sources through refrigerant leak detection and monitoring, leak repair, system retirement and retrofitting, reporting and recordkeeping, and proper refrigerant cylinder use, sale, and disposal.

The regulation is set forth in sections 95380 to 95398 of Title 17, CCR. The rules implementing the regulation establish a limit on statewide GHG emissions from stationary facilities with refrigeration systems with more than 50 lbs of a high GWP refrigerant. The refrigerant management program is designed to (1) reduce emissions of high -GWP GHG refrigerants from leaky stationary, non -residential refrigeration equipment; (2) reduce emissions from the installation and servicing of ref rigeration and air- conditioning appliances using high- GWP refrigerants; and (3) verify GHG emission reductions.

SB
97 AND THE CEQA GUIDELINES UPDATE
Passed in August 2007, SB 97 added Section 21083.05 to the Public Resources Code. The code states “(a) On or before July 1, 2009, the Office of Planning and Research (OPR) shall prepare, develop, and transmit to the Resources Agency guidelines for the mitigation of GHG emissions or the effects of GHG emissions as required by this division, including, but not limited to, effects associated with transportation or energy consum ption. (b) On or before January 1, 2010, the Resources Agency shall certify and adopt guidelines prepared and developed by the OPR pursuant to subdivision (a).”
In 2012, Public Resources Code Section 21083.05 was amended to state:

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45 “The Office of Planning and Research and the Natural Resources Agency shall periodically update the guidelines for the mitigation of greenhouse gas emissions or the effects of greenhouse gas emissions as required by this division, including, but not limited to, effects associated with transportation or energy consumption, to incorporate new information or criteria established by the State Air Resources Board pursuant to Division 25.5 (commencing with Section 38500) of the Health and Safety Code.”
On December 28, 2018, the Natural Resources Agency announced the OA L approved the amendments to the CEQA Guidelines for implementing C EQA. The CEQA Amendments provide guidance to public agencies regarding the analysis and mitigation of the effects of GHG emissions in CEQA documents. The CEQA Amendments fit within the existing CEQA framework by amending existing CEQA Guidelines to reference climate change.

Section 15064.4 was added the CEQA Guidelines and states that in determining the significance of a project’s GHG emissions, the lead agency should focus its analysis on the reasonably foreseeable incremental contribution of the project’s emissions to the effects of climate change.

A project’s incremental contribution may be cumulatively considerable even if it appea rs relatively small compared to statewide, national or global emissions. The agency’s analysis should consider a timeframe that is appropriate for the project. The agency’s analysis also must reasonably reflect evolving scientific knowledge and state regulatory schemes. Additionally, a lead agency may use a model or methodology to estimate GHG emissions resulting from a project. The lead agency has discretion to select the model or methodology it considers most appropriate to enable decision makers to intelligently take into account the project’s incremental contribution to climate change. The lead agency must support its selection of a model or methodology with substantial evidence . The lead agency sho uld explain the limitations of the particular model or methodology selected for use (51).

3.5 REGIONAL
The project is within the South Coast Air Basin (SCAB), which is under the jurisdiction of the SCAQMD.

SCAQMD
SCAQMD is the agency responsible for air quality planning and regulation in the SCAB. The SCAQMD addresses the impacts to climate change of projects subject to SCAQMD permit as a lead agency if they are the only agency having discretionary approval for the project and acts as a responsible agency when a land use agency must also approve discretionary permits for the project. The SCAQMD acts as an expert commenting agency for impacts to air quality. This expertise carries over to GHG emissions, so the agency helps local land use agencies through the development of models and emission thresholds that can be used to address GHG emissions.

In 2008, SCAQMD formed a Working Group to identify GHG emissions thresholds for land use projects that could be used by local lead agencies in the SCAB. The Working Group developed several different options that are contained in the SCAQMD Draft Guidance Document – Interim CEQA GHG Significance Threshold , which could be applied by lead agencies. The working group

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46 has not provided additional guidance since release of the interim guidance in 2008. The SCAQMD Board has not approved the thresholds; however, the Guidance Document provides substantial evidence supporting the approaches to significance of GHG emissions that can be considered by the lead agency in adopting its own threshold. Notably, SCAQMD provides an interim threshold, which consists of determining whether the project is consistent with a GHG reduction plan. If a project is consistent with a qualifying local GHG reduction plan, it does not have significant GHG emissions.

SCAQMD only has authority over GHG emissions from development projects that include air quality permits. At this time, it is unknown if the project would include stationary sources of emissions subject to SCAQMD permits. Notwithstanding, if the Project requires a stationary permit, it would be subject to the applicable SCAQMD regulations.

3.6 CITY OF MORENO VALLEY

CITY OF MORENO VALLEY GENERAL PLAN MEASURES
Although the 2006 City of Moreno Valley General Plan does not identify specific GHG or climate change policies or goals, a number of the measures identified in the General Plan act to reduce or control criteria pollutant emissions and peripherally reduce GHG emissions.

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48 4 DISCUSSION ON ESTABLISHMENT OF SIGNIFICANCE THRESHOLDS The criteria used to determine the significance of potential Project- related GHG impacts are taken from the Initial Study Checklist in Appendix G of the State CEQA Guidelines (14 CCR of Regulations §§15000, et seq.). Based on these thresholds, the following questions are utilized to determine if a project would result in a significant impact related to GHG (52):
• Would the project generate direct or indirect GHG emissions that would result in a significant impact on the environment (see Impact GHG-1)?
• Would the project conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing emissions of GHGs (see Impact GHG-2)?
The evaluation of an impact under CEQA requires measuring data from a project against both existing conditions and a “threshold of significance.” For establishing significance thresholds, the Office of Planning and Research’s amendments to the CEQA Guidelines Section 15064.7(c) state “[w]hen adopting thresholds of significance, a lead agency may consider thresholds of significance previously adopted or recommended by other public agencies, or recommended by experts, provided the decision of the lead agency to adopt such thresholds is supported by substantial evidence.”
CEQA Guidelines Section 15064.4(a) further states, “. . . A lead agency shall have discretion to determine, in the context of a particular project, whether to: (1) Use a model or methodology to quantify greenhouse gas emissions resulting from a project, and which model or methodology to use . . .; or (2) Rely on a qualitative analysis or performance-based standards.” CEQA Guidelines Section 15064.4 provides that a lead agency should consider the following factors, among others, in assessing the significance of impacts from greenhouse gas emissions:
• Consideration #1: The extent to which the project may increase or reduce greenhouse gas emissions as compared to the existing environmental setting.

• Consideration #2: Whether the project emissions exceed a threshold of significance that the lead agency determines applies to the project.

• Consideration #3: The extent to which the project complies with regulations or requirements adopted to implement a statewide, regional, or local plan for the reduction or mitigation of greenhouse gas emissions. Such regulations or requirements must be adopted by the relevant public agency through a public review process and must reduce or mitigate the project’s incremental contribution of greenhouse gas emissions. In determining the significance of impacts, the lead agency may consider a project’s consistency with the State’s long-term climate goals or strategies, provided that substantial evidence supports the agency’s analysis of how those goals or strategies address the project’s incremental contribution to climate change and its conclusion that the pro ject’s incremental contribution is not cumulatively considerable.

The City of Moreno Valley does not currently have an adopted Climate Action Plan and has not adopted its own numeric threshold of significance for determining impacts with respect to GHG

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49 emissions 6. In the absence of its own numeric threshold, the City of Moreno Valley has elected to use a significance threshold of 3,000 MTCO2e/yr that is based on the SCAQMD staff’s proposed GHG threshold for mixed use residential- commercial projects, as described in the SCAQMD’s Interim CEQA GHG Significance Threshold for Stationary Sources, Rules and Plans (“SCAQMD Interim GHG Threshold”).

The 3,000 MTCO2e/yr threshold is based on a 90% emission “capture” rate methodology. Prior to its use by the SCAQMD, the 90% emissions capture approach was one of the options suggested by the California Air Pollution Control Officers Association (CAPCOA) in their CEQA & Climate Change white paper (2008). A 90% emission capture rate means that unmitigated GHG emissions from the top 90% of all GHG -producing projects within a geographic area – the SCAB in this instance – would be subject to a detailed analysis of potential environmental impacts from GHG emissions, while the bottom 10% of all GHG-producing projects would be excluded from detailed analysis. A GHG significance threshold based on a 90% emission captu re rate is appropriate to address the long-term adverse impacts associated with global climate change because medium and large projects will be required to implement measures to reduce GHG emissions, while small projects, which are generally infill development projects that are not the focus of the State’s GHG reduction targets, are allowed to proceed. Further, a 90% emission capture rate sets the emission threshold low enough to capture a substantial proportion of future development projects and demonstrate that cumulative emissions reductions are being achieved while setting the emission threshold high enough to exclude small projects that will, in aggregate, contribute approximate 1% of projected statewide GHG emissions in the Year 2050 (53).

In setting the threshold at 3,000 MTCO
2e/yr, SCAQMD researched a database of projects kept by the Governor’s Office of Planning and Research (OPR). That database contained 798 projects, 87 of which were removed because they were very large projects and/or outliers that would skew emissions values too high, leaving 711 as the sample population to use in determining the 90th percentile capture rate. The SCAQMD analysis of the 711 projects within the sample population combined commercial, residential, and mixed-use projects. Emissions from each of these projects were calculated by SCAQMD to provide a consistent method of emissions calculations across the sample population and from projects within the sample population. In calculating the emissions, the SCAQMD a nalysis determined that the 90th percentile ranged between 2,983 to 3,143 MTCO
2e/yr. The SCAQMD set their significance threshold at the low-end value of the range when rounded to the nearest hundred tons of emissions (i.e., 3,000 MTCO2e/yr) to define small projects that are considered less than significant and do not need to provide further analysis.

The City understands that the 3,000 MTCO 2e/yr threshold for residential/commercial uses was proposed by SCAQMD a decade ago and was adopted as an interim policy; however, no

6 In June 2021, the City Council of the City of Moreno Valley (City Council) approved and adopted the City’s 2040 General Plan Update (2040 General Plan), a Change of Zone and Municipal Code Update, and its Climate Action Plan (CAP) and certified an EIR, State Clearinghouse No. 2020039022, as having been prepared in compliance with CEQA in connection with the approvals. A lawsuit entitled Sierra Club v. The City of Moreno Valley, Riverside Superior Court Case No. CVRI2103300, challenged the validity of the C AP and the EIR. In May 2024, the City Council set aside the 2021 approvals and certification, based on a March 2024 ruling and judgment of the court. The City is in the process of readopting the 2040 General Plan and issued a Notice of Preparation of a Revised Environmental Impact Report for MoVal 2040: The Moreno Valley Comprehensive General Plan Update, Municipal Code and Zoning (including Zoning Atlas) Amendments, and Climate Action Plan on July 30, 2024.

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50 permanent, superseding policy or threshold has since been adopted. The 3,000 MTCO 2e/yr threshold was developed and recommended by SCAQMD, an expert agency, based on substantial evidence as provided in the Draft Guidance Document – Interim CEQA Greenhouse Gas Significance Threshold (2008) document and subsequent Working Group meetings (l atest of which occurred in 2010). SCAQMD has not withdrawn its support of the interim threshold and all documentation supporting the interim threshold remains on the SCAQMD website on a page that provides guidance to CEQA practitioners for air quality analysis (and where all SCAQMD significance thresholds for regional and local criteria pollutants and toxic air contaminants also are listed). Further, as stated by SCAQMD, this threshold “uses the Executive Order S -3-05 goal [80% below 1990 levels by 2050] as the basis for deriving the screening level” and, thus, remains valid for use in 2022 (53). Lastly, this threshold has been used for hundreds, if not thousands of GHG analyses performed for projects located within the SCAQMD jurisdiction . Thus, and based on guidance from the SCAQMD, if a mixed use project would emit GHGs less than 3,000 MTCO 2e
per year, the project is not considered a substantial GHG emitter and the GHG impact is less than significant, requiring no additional analysis and no mitigation. On the other hand, if a mixed use project would emit GHGs in excess of 3,000 MTCO
2e/yr, then the project could be considered a
substantial GHG emitter, requiring additional analysis and potential mitigation.

As previously discussed, a significance threshold of 3,000 MTCO2e/yr is an acceptable approach for mixed use projects such as this one.

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52 5 PROJECT GREENHOUSE GAS ANALYSIS

5.1 INTRODUCTION
As discussed above, CEQA Guidelines Section 15064.4 recommends quantification of a project’s GHG emissions. However, quantification of the Project’s GHG emissions is provided herein for informational purposes only.

5.2 METHODOLOGY

5.2.1 CALEEMOD
The California Air Pollution Control Officers Association (CAPCOA) in conjunction with other California air districts, including SCAQMD, released CalEEMod 2022 in May 2022. CalEEMod periodically releases updates, as such the latest version available at the time of this report (2022.1.1.29), has been utilized in this analysis . The purpose of this model is to calculate construction-source and operational -source criteria pollutants and GHG emissions from direct and indirect sources; and quantify applicable air quality and GHG reductions achieved from mitigation measures (54). Accordingly, the latest version of CalEEMod has been used for this Project to determine GHG emissions. Output from the model runs for construction and operational activity are provided in Appendices 5.1 and 5.2. CalEEMod includes GHG emissions from the following source categories: construction, area, energy, mobile, water, and waste.

5.2.2 L

IFE-CYCLE ANALYSIS NOT REQUIRED
A full life ‐cycle analysis (LCA) for construction and operational activity is not included in this analysis due to the lack of consensus guidance on LCA methodology at this time (55). Life‐cycle analysis (i.e., assessing economy‐wide GHG emissions from the processes in manufacturing and transporting all raw materials used in the P roject development, infrastructure and on- going operations) depends on emission factors or econometric factors that are not well established for all processes. At this time , an LCA would be extremely speculative and thus has not been prepared.

Additionally, the SC AQMD recommends analyzing direct and indirect project GHG emissions generated within California and not life -cycle emissions because the life -cycle effects from a project could occur outside of California, might not be very well understood or documented, and would be challenging to mitigate (56). Additionally, the science to calculate life cycle emissions is not yet established or well defined; therefore, SCAQMD has not recommended, and is not requiring, life-cycle emissions analysis.

5.3 CONSTRUCTION EMISSIONS

5.3.1 CONSTRUCTION ACTIVITIES
Project construction actvities would generate CO 2 and CH 4 emissions. The Town Center at Moreno Valley Specific Plan Air Quality Impact Analysis Report (AQIA) prepared by Urban Crossroads, Inc., contains detailed information regarding Project construction activities (57) . As

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53 discussed in the AQIA, c onstruction related emissions are expected from the following construction activities:
• Site Preparation
• Grading
• Building Construction
• Paving
• Architectural Coating

5.3.2 CONSTRUCTION DURATION
For purposes of analysis, c onstruction is assumed to commence in November 2025 and to be complete by October 2028. The construction schedule utilized in the analysis, shown in Table 5 - 1, represents a “ conservative” analysis scenario should construction occur any time after the respective dates since emission factors for construction decrease as time passes and the analysis year increases due to emission regulations becoming more stringent. 7 The duration of construction activity and associated equipment represents a reasonable approximation of the expected construction fleet as required per CEQA Guidelines.

TABLE 5-1: CONSTRUCTION SCHEDULE
Construction Activity Start Date End Date Days
Site Preparation 11/5/2025 11/26/2025 16
Grading 11/26/2025 03/23/2026 84
Building Construction 03/23/2026 11/6/2028 686
Paving 07/23/2026 11/6/2026 77
Architectural Coating 08/23/2028 11/6/2028 54

5.3.3 CONSTRUCTION EQUIPMENT
Site specific construction fleet may vary due to specific project needs at the time of construction.

A detailed summary of construction equipment assumptions by phase is provided at Table 5 -2.

Please refer to specific detailed modeling inputs/outputs contained in Appendix 5.1 of this GHGA.

7 As shown in the CalEEMod User’s Guide Version 2022, Appendix G “Table G-11. Statewide Average Annual Offoad Equipment Emission Factors” as the analysis year increases, emission factors for the same equipment pieces decrease due to the natural turnover of older equipment being replaced by newer less polluting equipment and new regulatory requirements.

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54 TABLE 5-2: CONSTRUCTION EQUIPMENT ASSUMPTIONS
Construction Activity Equipment Amount Hours Per Day Horsepower Load Factor Site Preparation
Crawler Tractors 4 8 87 0.43
Rubber Tired Dozers 3 8 367 0.40
Grading
Crawler Tractors 2 8 87 0.43
Excavators 2 8 36 0.38
Graders 1 8 148 0.41
Rubber Tired Dozers 1 8 367 0.40
Scrapers 2 8 423 0.48
Building Construction
Cranes 2 8 367 0.29
Forklifts 5 8 82 0.20
Generator Sets 2 8 14 0.74
Tractors/Loaders/Backhoes 5 8 84 0.37
Welders 2 8 46 0.45
Paving
Pavers 2 8 81 0.42
Paving Equipment 2 8 89 0.36
Rollers 2 8 36 0.38
Architectural Coating Air Compressors 1 8 37 0.48

5.3.4 GHG EMISSIONS FROM ON-ROAD TRIPS
Construction generates on- road vehicle emissions from vehicle usage for workers and vendors commuting to and from the site. The number of worker and vendor trips are presented below in Table 5-3.

TABLE 5-3: CONSTRUCTION TRIP ASSUMPTIONS
Construction Activity Worker Trips
Per Day
Vendor Trips
Per Day
Site Preparation 18 3
Grading 20 13
Building Construction 372 107
Paving 15 0
Architectural Coating 74 0

5.3.5 CONSTRUCTION EMISSIONS SUMMARY
For construction phase Project emissions, GHGs are quantified and amortized over the life of the Project. To amortize the emissions over the life of the Project , the SCAQMD recommends calculating the total GHG emissions for the construction activities, dividing it by a 30-year Project

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55 life then adding that number to the annual operational phase GHG emissions (58). As such, construction emissions were amortized over a 30‐year period and added to the annual operational phase GHG emissions. The amortized construction emissions are presented in Table 5‐4.

TABLE 5‐4: AMORTIZED ANNUAL CONSTRUCTION EMISSIONS
Year
Construction Equipment
CO2e Emissions
(MT/yr)
On‐Road Vehicle
CO2e Emissions
(MT/yr)
Total
2025 118.85 10.35 129.20
2026 676.72 781.09 1,457.81
2027 571.56 953.59 1,525.15
2028 491.47 819.23 1,310.70
Total Annual Construction Emissions 1,858.60 2,564.26 4,422.87 Amortized Construction Emissions (MTCO2e) 147.43

5.4 OPERATIONAL EMISSIONS
Operational activities associated with the Project will result in emissions of CO2, CH4, N2O and Refrigerants from the following primary sources:
 Area Source Emissions
 Energy Source Emissions
 Mobile Source Emissions
 Water Supply, Treatment, and Distribution
 Solid Waste
 Refrigerants

5.4.1 AREA SOURCE EMISSIONS
CalEEMod estimates area source emissions for the following sources: architectural coating, consumer products, and landscape maintenance equipment. Detailed operational model outputs are presented in Appendix 5.1.

ARCHITECTURAL COATING
Over a period of time, the buildings that are part of this Project will be subject to emissions resulting from the evaporation of solvents contained in paints, varnishes, primers, and other surface coatings as part of Project maintenance. The emissions associated with architectural coatings were calculated using CalEEMod.

CONSUMER PRODUCTS
Consumer products include, but are not limited to, detergents, cleaning compounds, polishes, personal care products, and lawn and garden products. Many of these products contain organic compounds which, when released in the atmosphere, can react to form O3 and other

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56 photochemically reactive pollutants. The emissions associated with use of consumer products were calculated based on defaults provided within CalEEMod.

LANDSCAPE MAINTENANCE EQUIPMENT
Landscape maintenance equipment would generate emissions from fuel combustion and evaporation of unburned fuel. Equipment in this category would include lawnmowers, shedders/grinders, blowers, trimmers, chain saws, and hedge trimmers used to maintain the landscaping of the Project. It should be noted that as October 9, 2021, Governor Gavin Newsom signed AB 1346. The bill aims to ban the sale of new gasoline-powered equipment under 25 gross horsepower (known as small off-road engines [SOREs]) by January 1, 2024, which is now in effect.

However, for purposes of analysis, t he emissions associated with landscape maintenance equipment were calculated based on assumptions provided in CalEEMod and do not incorporate the emissions reductions from AB 1346.

5.4.2 ENERGY SOURCE EMISSIONS
GHGs are emitted from buildings as a result of activities for which electricity and natural gas are typically used as energy sources; these emissions are considered to be indirect emissions. Natural gas would be supplied to the Project by Southern California Gas and electricity would be supplied to the Project by Moreno Valley Utility (MVU). Natural gas and electricity usage associated with the Project was calculated by CalEEMod using default parameters.

5.4.3 MOBILE SOURCE EMISSIONS
The Project related GHG emissions derive primarily from vehicle trips generated by the Project.

Trip characteristics available from the Town Center at Moreno Valley Specific Plan (PEN21 -0334 and PEN22-0077) Traffic Analysis were utilized in this analysis (59). The mobile-source emissions were calculated based on trip rates and trip lengths. Detailed operational model outputs are presented in Appendix 5.1.

Per the Town Center at Moreno Valley Specific Plan (PEN21-0334 and PEN22-007) Traffic Analysis, the Project is expected to generate a total of approximately 12,0108 two-way vehicular trips per day (6,005 trips inbound and 6,005 trips outbound) (59).

TRIP RATES
The trip generation rates used for this analysis are consistent with the rates provided in the Town Center at Moreno Valley Specific Plan (PEN21- 0334 and PEN22-007) Traffic Analysis which are based upon information collected by the Institute of Transportation Engineers (ITE) as provided in the Trip Generation Manual, 11
th Edition, 2021 (59).

8 It should be noted that the total trips for each land use is modeled in CalEEMod and that the internal capture and pass- by trip reductions are credited within CalEEMod. As such, the model outputs present the gross trips for all land uses (e.g., 22,508 daily weekday trips), without the reduction of the internal capture and pass-by trips which are calculated internal to the model.

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57 TRIP LENGTHS
For all vehicle types (Light-Duty-Auto vehicles [LDA], Light-Duty Trucks [LDT1]9, Light-Duty Trucks [LDT2]10, Medium-Duty Trucks [MDV], Other Buses [OBUS11], Urban Buses [UBUS12], Motorcycle [MCY], School Buses [SBUS], and Motor Homes [MH], heavy duty trucks (2-axle/Light-Heavy-Duty Trucks [LHDT113 and LHDT214], 3-axle/Medium-Heavy-Duty Trucks [MHDT], and 4+ -axle/Heavy- Heavy-Duty Trucks [HHDT]), the CalEEMod default for a one-way trip length was used.

In order to determine emissions from passenger car vehicles, CalEEMod defaults for trip length and trip purpose were utilized (60). Default vehicle trip lengths for primary trips will be populated using data from the local metropolitan planning organizations/Regional Transportation Planning Agencies (MPO/RTPA). Trip type percentages and trip lengths provided by MPO/RTPAs truncate data at their demonstrative borders.

5.4.4 W

ATER SUPPLY, TREATMENT AND DISTRIBUTION
Indirect GHG emissions result from the production of electricity used to convey, treat, and distribute water and wastewater. The amount of electricity required to convey, treat, and distribute water depends on the volume of water as well as the sources of the water. Unless otherwise noted, CalEEMod default parameters were used.

5.4.5 SOLID WASTE
Residential and commercial land uses would result in the generation and disposal of solid waste.

A percentage of this waste would be diverted from landfills by a variety of means, such as reducing the amount of waste generated, recycling, and/or composting. The remainder of the waste not diverted would be disposed of at a landfill. GHG emissions from landfills are associated with the anaerobic breakdown of material. GHG emissions associated with the disposal of solid waste associated with the proposed Project were calculated by CalEEMod using default parameters.

5.4.6 R

EFRIGERANTS
Air conditioning (A/C) and refrigeration equipment associated with the buildings are anticipated to generate GHG emissions. CalEEMod automatically generates a default A/C and refrigeration equipment inventory for each project land use subtype based on industry data from the USEPA (2016b). CalEEMod quantifies refrigerant emissions from leaks during regular operation and routine servicing over the equipment lifetime and then derives average annual emissions from the lifetime estimate. Note that CalEEMod does not quantify emissions from the disposal of refrigeration and A/C equipment at the end of its lifetime. Per 17 CCR 95371, new facilities with refrigeration equipment containing more than 50 pounds of refrigerant are prohibited from utilizing refrigerants w ith a GWP of 150 or greater as of January 1, 2022. As such, it was

9 Vehicles under the LDT1 category have a gross vehicle weight rating (GVWR) of less than 6,000 lbs. and equivalent test weight (ETW) of less than or equal to 3,750 lbs.
10 Vehicles under the LDT2 category have a GVWR of less than 6,000 lbs. and ETW between 3,751 lbs. and 5,750 lbs. 11 OBUS vehicle classes refers to all other buses except school buses and urban buses. 12 UBUS vehicle classes consist of natural gas buses, gasoline buses, and diesel buses. 13 Vehicles under the LHDT1 category have a GVWR of less than 8,501-10,000 lbs. 14 Vehicles under the LHDT2 category have a GVWR of less than 10,001-14,000 lbs.

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58 conservatively assumed that refrigeration systems installed at the supermarket portion of the Project would utilize refrigerants with a GWP of 150. GHG emissions associated with refrigerants were calculated by CalEEMod.

5.4.7 EMISSIONS SUMMARY
The annual GHG emissions associated with the operation of the proposed Project are estimated to be 22,940.60 MTCO
2e/yr as summarized in Table 5-5.

TABLE 5-5: PROJECT GHG EMISSIONS – WITHOUT MITIGATION
Emission Source
CO2e Emissions (MT/yr)
Unmitigated
Annual construction-related emissions amortized over 30 years 147.43 Mobile Source 17,406.70
Area Source 209.69
Energy Source 4,320.48
Water Usage 354.80
Waste 433.55
Refrigerants 67.95
Project Total CO2e Emissions (All Sources) 22,940.60

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60 6 GHG EMISSIONS FINDINGS AND RECOMMENDATIONS
GHG CEQA THRESHOLD NO. 1
Would the Project have the p otential to generate direct or indirect GHG emissions that would result in a significant impact on the environment?

IMPACTS WITHOUT MITIGATION
As shown previously on Table 5 -5, construction and operation of the Project would generate a total of approximately 22,940.60 MTCO2e/yr, which would exceed the significance threshold of 3,000 MTCO2 e/yr; therefore, Project -related GHG emissions are considered potentially significant. The majority of the GHG emissions ( 76%) are associated with non- construction related mobile sources. Emissions of motor vehicles are controlled by State and Federal standards, and neither the City nor the Project have control over these emissions.

LEVEL OF SIGNIFICANCE BEFORE MITIGATION
Potentially Significant.

MITIGATION MEASURES
MM GHG-1
The project applicant shall design and build future non-residential development to meet/include the following:
• The project will utilize on-site renewable energy sources such as solar, to reduce electrical demand as per Division A5.211, Renewable Energy, of Appendix A5, Nonresidential Voluntary Measures, of the 2022 California Green Building Standards Code. • The project will incorporate measures to reduce the overall use of potable water within the building by 12 percent as per Division A5.3, Water Efficiency and Conservation, as outlined under Section A5.303.2.3.1 of Appendix A5, Nonresidential Voluntary Measures, of the 2022 California Green Building Standards Code.

MM
GHG-2
The project applicant shall design and build future residential development to meet/include the following:
• No wood-burning fireplaces shall be installed in any of the dwelling units.

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61 • All buildings shall be electric, to the extent feasible, meaning that electricity is the primary source of energy for water heating; heating, ventilation, and air conditioning (HVAC) within the building, excluding pool heating.
• All major appliances provided/installed shall be EnergyStar- certified or of equivalent energy efficiency, where applicable.

MM
GHG-3
Exterior electric receptacles on nonresidential buildings shall be provided for charging or powering electric landscaping equipment.

MM
GHG-4
The project shall use light-color roofing and building materials to minimize the heat island effect and reduce lighting, heating, and cooling needs.

MM
3 Prior to the issuing of each building permit, the Project proponent and its contractors shall provide plans and specifications to the City that demonstrate that electrical service is provided

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62 to each of the areas in the vicinity of the buildings that are to be landscaped in order that electrical equipment may be used for landscape maintenance.

MM 4
Once constructed, the Project proponent shall ensure that all commercial tenants shall utilize only electric or natural gas pallet jacks and forklifts in the loading areas.

MM
5 Upon occupancy and annually thereafter, the operators of the commercial space shall provide information to all delivery truck drivers, regarding:
• Building energy efficiency, solid waste reduction, recycling, and water conservation. • Vehicle GHG emissions, electric vehicle charging availability, and alternate transportation opportunities for commuting.
• Participation in the Voluntary Interindustry Commerce Solutions (VICS) “Empty Miles” program to improve goods trucking efficiencies.
• Health effects of diesel particulates, State regulations limiting truck idling time, and the benefits of minimized idling.
• The importance of minimizing traffic, noise, and air pollutant impacts to any residences in the Project vicinity.

LEVEL OF SIGNIFICANCE AFTER MITIGATION
Significant and Unavoidable
Because the majority ( 76%) of the Project GHG emissions would be generated by Project vehicular sources, the Project cannot feasibly achieve the SCAQMD 3,000 MTCO 2e per year threshold. Because responsibility and authority for regulation of vehicular -source emissions resides with the State of California (CARB, et al.), neither the Applicant nor the Lead Agency can affect or mandate substantial reductions in vehicular -source GHG emissions, much less reductions that would achieve the SCAQMD’s 3,000 MTCO 2e per year threshold. In effect, all Project traffic (mobile) and energy would need to be eliminated or be “zero GHG emissions sources” to reduce emissions below the SCAQ MD’s numeric threshold. There are no feasible means to or alternatives to eliminate all Project traffic or energy to ensure that Project traffic and energy would be zero GHG emissions sources. In terms of its practical application, this would constitute a “no build” condition. While neither the City nor the Project have regulatory authority to control mobile source emissions, it is noted, however, that emissions of motor vehicles are controlled by state and federal standards, and these fuel efficiency and e missions standards are becoming more stringent over the years to reduce mobile source emissions . On this basis, even
with implementation of applicable Mitigation Measures the Project would generate direct or

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63 indirect GHG emissions that would exceed SCAQMD’s interim numeric threshold and therefore are conservatively concluded to result in a significant impact on the environment. As there are no additional feasible mitigation measures that would reduce GHG emissions to levels below the threshold, this is a significant and unavoidable impact.

GHG CEQA THRESHOLD NO. 2
Would the Project have the potential to conflict with any applicable plan, policy or regulation of an agency adopted for the purpose of reducing the emissions of GHGs? As previously stated, pursuant to Section 15604.4 of the State CEQA Guidelines, a lead agency may rely on qualitative analysis or performance -based standards to determine the significance of impacts from GHG emissions (61) . As such, the Project’s consistency with the 2022 Scoping Plan is discussed below. It should be noted that the Project’s consistency with the 2022 Scoping Plan also satisfies consistency with AB 32 since the 20 22 Scoping Plan is based on the overall targets established by AB 32 and SB 32. Consistency with the 2008 and 2017 Scoping Plan is not necessary, since both of these plans have been superseded by the 2022 Scoping Plan. For reasons outlined herein, the proposed Project would result in a less than significant impact with respect to GHG emissions for GHG Impact #2.

ITY OF MORENO VALLEY CAP
In June 2021, the City Council of the City of Moreno Valley (City Council) approved and adopted the City’s 2040 General Plan Update (2040 General Plan), a Change of Zone and Municipal Code Update, and its Climate Action Plan (CAP) and certified an EIR, State Clearinghouse No. 2020039022, as having been prepared in compliance with CEQA in connection with the approvals. A lawsuit entitled Sierra Club v. The City of Moreno Valley, Riverside Superior Court Case No. CVRI2103300, challenged the validity of the C AP and the EIR. In May 2024, the City Council set aside the 2021 approvals and certification, based on a March 2024 ruling and judgment of the court. The City is in the process of readopting the 2040 General Plan and issued a Notice of Preparation of a Revised Environmental Impact Report for MoVal 2040: The Moreno Valley Comprehensive General Plan Update, Municipal Code and Zoning (including Zoning Atlas) Amendments, and Climate Action Plan on July 30, 2024.

As such, if the City adopts a qualified CAP and future development is determined to be consistent with that CAP, then impacts for implementing projects would be considered less than significant.

However, because at this time there is no adopted CAP, the Project cannot be determined to be consistent, as such a significant and unavoidable impact is expected.

2022 SCOPING PLAN
As previously stated, pursuant to 15604.4 of the CEQA Guidelines, a lead agency may rely on qualitative analysis or performance -based standards to determine the significance of impacts from GHG emissions (51). As such, the Project’s consistency with the 2022 Scoping Plan, is qualitatively discussed below.

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64 Included in the 2022 Scoping Plan is a set of Local Actions (Appendix D to the 2022 Scoping Plan) aimed at providing local jurisdictions with tools to reduce GHGs and assist the state in meeting the ambitious targets set forth in the 2022 Scoping Plan. Appendix D to the 2022 Scoping Plan includes a section on evaluating plan- level and project-level alignment with the State’s Climate Goals in CEQA GHG analyses. In this section, CARB identifies several recommendations and strategies that should be considered for new development in order to determine if a project would conflict with the 2022 Scoping Plan.

The 2022 Scoping Plan includes three priority areas to reduce GHG emissions that would apply to all land use development projects. More specifically, the three priority areas include: (1) transportation electrification, (2) VMT reduction, and (3) Building Decarbonization. The potential for the Project to conflict with these three priority areas is discussed as follows:

Transportation Electrification: No Conflict. The Project would include EV charging infrastructure that, at minimum, would equal the Residential and Non- Residential Mandatory Measures in sections 4.106.4.1, 4.106.4.2, 4.106.4.3 and Section A5.106.5.3 of the California Green Building Standards Code. Therefore, the Project does not conflict with this priority area.

VMT Reduction: No Conflict. As noted in the Project’s VMT Assessment, the Project’s effect on VMT was found to be less than significant and therefore the Project would not result in a per - capita increase in VMT. Additionally, the Project cumulative effect on VMT was not found to increase VMT per service population in the baseline year or horizon year conditions . As such, based on the VMT Assessment conclusions, the Project would not conflict with this priority area.

Building Decarbonization: No Conflict. Per Title 24 requirements, the Project would be required to incorporate solar for the residential and commercial portion of the buildings. Additionally, the Project would be required to comply with all Title 24 Energy and CalGreen requirements as discussed in Section 3.4.3 of this Report. Further , the required GHG MMs require building electrification features. As such, the Project does not conflict with this priority area.

As shown in the preceding discussion, the Project does not conflict with the 2022 Scoping Plan.

6.1 CITY OF MORENO VALLEY GENERAL PLAN MEASURES
This report evaluates the impacts resulting from implementation of the proposed Project under the existing 2006 General Plan land use and zoning designations, which would require a General Plan Amendment and zone change, and the City’s proposed 2040 General Plan land use and zoning designation, if applicable to the analysis.

As previously stated, although the City of Moreno Valley General Plan does not identify specific GHG or climate change policies or goals, a number of the goals/policies identified in the General Plan act to reduce or control criteria pollutant emissions and peripherally reduce GHG emissions.

As shown on Table s 6-1 and 6-2, the Project has been evaluated for consistency with both the 2006 and 2040 City of Moreno Valley General Plan.

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65 TABLE 6-1: 2006 CITY OF MORENO VALLEY GENERAL PLAN CONSISTENCY Objective/Policy Project Consistency
Objective 6.6: Promote land use patterns that reduce
daily automotive trips and reduce trip distance for
work, shopping, school, and recreation.

No Conflict. The Project site is providing employment
opportunities to Moreno Valley and the surrounding
area.

Objective 6.7: Reduce mobile and stationary source
air pollutant emissions.

No Conflict. The Project site is located proximate to
existing and proposed major roadways, acting to
generally reduce vehicle trip lengths, thereby reducing mobile source emissions. The Project will further
reduce mobile source emissions by creating local
employment opportunities, reducing commuter VMT
within the region. Additionally, the Project will
implement energy efficient designs and operational
programs meeting or surpassing California Code of
Regulations (CCR) Title 24 Building Standards,
including but not limited to compliance with or
betterment of, energy conservation requirements
identified at CCR Title 24, Part 6, Energy Code. Energy efficient designs and programs implemented by the
Project reduce resources consumption with
correlating reductions in stationary-source emissions.

Policy 6.7.5: Require grading activities to comply with SCAQMD District’s Rule 403 regarding the control of
fugitive dust.

No Conflict. The Project will be required to implement
fugitive dust control measures consistent with
SCAQMD Rule 403.

Policy 6.7.6: Require building construction to comply
with the energy conservation requirements of Title 24
of the California Administrative Code [CCR].

No Conflict. Pursuant to City and State Building Code
requirements, the Project will meet or surpass
applicable CCR Title 24 energy conservation
requirements.

Source: City of Moreno Valley General Plan, Safety Element TABLE 6-2: 2040 CITY OF MORENO VALLEY GENERAL PLAN CONSISTENCY Goal Project Consistency
Goal LCC-2: Foster vibrant gathering places for
Moreno Valley residents and visitors.

Consistent. The Project’s proposed
commercial/residential land uses provide for
gathering places for Moreno Valley residents and
visitors.

Goal E-1: Diversity and grow the local economy.

Consistent. The Project’s proposed
commercial/residential land uses will supplement the
City’s goal in diversifying and growing the local
economy. The proposed uses would improve the
jobs/housing balance within the City which would
reduce the need for residents to travel to employment
outside the City.

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66 Goal Project Consistency
Goal E-4: Promote education and workforce
development.

Consistent. The Project site is providing employment
opportunities to Moreno Valley and the surrounding
area. The proposed uses would improve the
jobs/housing balance within the City which would
reduce the need for residents to travel to employment
outside the City.

Goal C-2: Plan, design, construction, and maintain a
local transportation network that provides safe and
efficient access throughout the city and optimizes
travel by all modes.

Consistent. The Project site is located proximate to
existing and proposed major roadways, acting to
generally reduce vehicle trip lengths, thereby reducing mobile source emissions. The Project will further
reduce mobile source emissions by creating local
employment opportunities, reducing commuter VMT
within the region. Additionally, the Project will
implement energy efficient designs and operational
programs meeting California Code of Regulations
(CCR) Title 24 Building Standards, including but not
limited to compliance with or betterment of, energy
conservation requirements identified at CCR Title 24,
Part 6, Energy Code. Energy efficient designs and
programs implemented by the Project reduce
resources consumption with correlating reductions in
stationary-source emissions.

Goal C-3: Manage the City’s transportation system to
minimize congestion, improve flow, and improve air
quality.

Goal C-4: Provide convenient and safe connections
between neighborhoods and destinations within
Moreno Valley.

Goal C-5: Enhance the range of transportation
operations in Moreno Valley and reduce VMT.

Goal OSRC-3: Use energy and water wisely and
promote reduced consumption.

Consistent. Pursuant to City and State Building Code
requirements, the Project will meet or surpass
applicable CCR Title 24 energy conservation
requirements.

Source: City of Moreno Valley General Plan, Safety Element

6.4 CONSISTENCY WITH SB 375 (SCAG RTP/SCSR)
The proposed Project would increase regional employment. According to SCAG’s 202 4-2050 RTP/SCS, housing within Riverside County in 20 24 is approximately 883,000 jobs with an anticipated increase to approximately 1, 179,000 jobs by 20 50, a growth of approximately 296,000 jobs (62). The proposed P roject represents a nominal percentage of the anticipated increase in jobs, and therefore, would not result in long -term operational employment growth that exceeds planned growth projections in the RTP/SCS, or result in employment growth that would substantially add to traffic congestion.

According to SCAG’s 2024 -2050 RTP/SCS, housing within Riverside County in 20 24 is approximately 7 83,000 households with an anticipated increase to approximately 1,149,000 households by 2050, a growth of approximately 366,000 households (62). The proposed Project represents a nominal percentage of the anticipated increase in homes, and therefore, would not result in long -term operational household growth that exceeds planned growth projections in

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67 the RTP/SCS or the AQMP, or result in household growth that would substantially add to traffic congestion. As such, the Project would be consistent with the SCAG’s 2024-2050 RTP/SCS.

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69 7 REFERENCES

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34. Agency, United States Environmental Protection. Endangerment and Cause or Contribute Findings for Greenhouse Gases under the Section 202(a) of the Clean Air Act. United States Environmental Protection Agency. [Online] 2020. https://www.epa.gov/climate- change/endangerment-and-cause- or-contribute-findings-greenhouse-gases-under-section-
202a#:~:text=The%20Court%20held%20that%20the,to%20make%20a%20reasoned%20decision..

35. Federal Register. Mid-Term Evaluation of Greenhouse Gas Emissions Standards for Model Year 2022- 2025 Light -Duty Vehicles. [Online] 2018.
https://www.federalregister.gov/documents/2018/04/13/2018-07364/mid-term-evaluation-of- greenhouse-gas-emissions-standards-for-model-year-2022-2025-light-duty.

36. Administration, National Highway Traffic Safety. SAFE: The Safer Affordable Fuel- Efficient 'SAFE' Vehicle Rule. National Highway Traffic Safety Administration. [Online] 2020. https://www.nhtsa.gov/corporate-average-fuel-economy/safe.

14556-11 GHG Report
71 37. National Highway Traffic Safety Administration. Corporate Average Fuel Economy. [Online] https://www.nhtsa.gov/laws-regulations/corporate-average-fuel-economy.

38. Department of Transportation. Corporate Average Fuel Economy Standards for Model Years 2024- 2026 Passenger Cars and Light Trucks. [Online] https://www.nhtsa.gov/sites/nhtsa.gov/files/2022 - 04/Final-Rule-Preamble_CAFE-MY-2024-2026.pdf.

39. United States Environmental Protection Agency. SmartWay. [Online] 2017. https://www.epa.gov/smartway/learn-about-smartway.

40. Western Regional Climate Initiative. WCI. [Online] http://westernclimateinitiative.org/.

41. Western Climate Initiative. History. Western Climate Initiative. [Online] http://westernclimateinitiative.org/index.php?option=com_content&view=article&id=29&Itemid =44.

42. Pacific Coast Action Plan on Climate and Energy. San Francisco : The Pacific Coast Collaborative, 2013.

43. California Air Resources Board. California's 2017 Climate Change Scoping Plan . [Online] 2017. https://ww3.arb.ca.gov/cc/scopingplan/scoping_plan_2017_es.pdf.

44. Lawrence Berkeley National Laboratory. California's Policies Can Significantly Cut Greenhouse Gas Emissions through 2030. Lawrence Berkeley National Laboratory. [Online] January 22, 2015. http://newscenter.lbl.gov/2015/01/22/californias-policies-can-significantly-cut-greenhouse-gas- emissions-2030/.

45. Ernest Orlando Lawrence Berkeley National Laboratory. Modeling California policy impacts on greenhouse gas emissions. [Online] 2015. https://eta -publications.lbl.gov/sites/default/files/lbnl- 7008e.pdf.

46. California Air Resources Board. Legal Disclaimer & User's Notice. [Online] April 2019. https://ww2.arb.ca.gov/sites/default/files/2021-02/ct_reg_unofficial.pdf.

47. —. Climate Change Scoping Plan. [Online] 2014.
https://ww3.arb.ca.gov/cc/scopingplan/2013_update/first_update_climate_change_scoping_pla n.pdf.

48. —. Low Carbon Fuel Standard. [Online] December 2019. https://ww3.arb.ca.gov/fuels/lcfs/lcfs.htm.

49. California Energy Commission. Energy Commission Adopts Updated Building Standards to Improve Efficiency, Reduce Emissions from Homes and Businesses. [Online] August 11, 2021. https://www.energy.ca.gov/news/2021-08/energy-commission-adopts-updated-building- standards-improve-efficiency-reduce-0.

50. California Department of General Services. 2022 CALGreen Code. CALGreen. [Online] https://codes.iccsafe.org/content/CAGBC2022P1.

51. Association of Environmental Professionals. 2018 CEQA California Environmental Quality Act. 2018.

52. State of California. 2020 CEQA California Environmental Quality Act. 2020.

53. South Coast Air Quality Management District. Interim CEQA GHG Threshold for Stationary Sources, Rules and Plans. [Online] December 5, 2008. http://www.aqmd.gov/docs/default - source/ceqa/handbook/greenhouse-gases-(ghg)-ceqa-significance- thresholds/ghgboardsynopsis.pdf.

54. California Air Pollution Control Officers Association (CAPCOA). California Emissions Estimator Model (CalEEMod). [Online] May 2022. www.caleemod.com.

14556-11 GHG Report
72 55. California Natural Resources Agency. Final Statement of Reasons for Regulatory Action, Amendments to the State CEQA Guidelines Addressing Analysis and Mitigation of Greenhouse Gas Emissions Pursuant to SB97. [Online] December 2009.

56. Minutes for the GHG CEQA Significance. South Coast Air Quality Managment District. 2008.

57. Urban Crossroads, Inc. Moreno Valley Town Center Specific Plan Air Quality Impact Analysis Report. 2024.

58. South Coast Air Quality Management District. Greenhouse Gas CEQA Significance Threshold Stakeholder Working Group #13. [Powerpoint] Diamond Bar : s.n., 2009.

59. Urban Crossroads, Inc. Town Center at Moreno Valley Specific Plan (PEN21 -0034, -0035, -0036) Traffic Analysis. 2022.

60. —. Nevada Street Warehouse Vehicle Miles Traveled (VMT) Screening Evaluation. 2022.

61. California Natural Resources Agency. 2023 California Environmental Quality Act (CEQA) Statute and Guidelines. s.l. : Association of Environmental Professionals, 2023.

62. Southern California Association of Governments. Certified Final Connect SoCAL PEIR. [Online] 2024. chrome-extension://efaidnbmnnnibpcajpcglclefindmkaj/https://scag.ca.gov/sites/main/files/file- attachments/23-2987-tr-demographics-growth-forecast-final-040424.pdf?1712261839.

63. Air Resources Board. 2022 GHG Inventory. California Greenhouse Gas Emission Inventory 2000-2020 Edition. [Online] https://ww2.arb.ca.gov/sites/default/files/classic/cc/inventory/2000 - 2020_ghg_inventory_trends.pdf.

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14556-11 GHG Report
74 8 CERTIFICATIONS
The contents of this GHG study report represent an accurate depiction of the GHG impacts associated with the proposed Town Center at Moreno Valley Specific Plan Project. The information contained in this GHG report is based on the best available data at the time of preparation. If you have any questions, please contact me directly [email protected].

Haseeb Qureshi
Principal
Urban Crossroads, Inc.
[email protected]

EDUCATION
Master of Science in Environmental Studies
California State University, Fullerton • May 2010
Bachelor of Arts in Environmental Analysis and Design
University of California, Irvine • June 2006

ROFESSIONAL AFFILIATIONS
AEP – Association of Environmental Planners
AWMA – Air and Waste Management Association
ASTM – American Society for Testing and Materials

ROFESSIONAL CERTIFICATIONS
Planned Communities and Urban Infill – Urban Land Institute • June 2011 Indoor Air Quality and Industrial Hygiene – EMSL Analytical • April 2008 Principles of Ambient Air Monitoring – California Air Resources Board • August 2007 AB2588 Regulatory Standards – Trinity Consultants • November 2006 Air Dispersion Modeling – Lakes Environmental • June 2006

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14556-11 GHG Report

APPENDIX 5.1:

CALEEMOD ANNUAL EMISSIONS MODEL OUTPUTS
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14556-Moreno Valley Towne Center (Unmitigated) 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 Y ear, Unmitigated

2.4. Operations Emissions Compared Against Thresholds

2.5. Operations Emissions by Sector, Unmitigated

3. Construction Emissions Details

3.1. Site Preparation (2025) - Unmitigated

3.3. Grading (2025) - Unmitigated

3.5. Grading (2026) - Unmitigated

3.7. Building Construction (2026) - Unmitigated

3.9. Building Construction (2027) - Unmitigated
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3.11. Building Construction (2028) - Unmitigated

3.13. Paving (2026) - Unmitigated

3.15. Architectural Coating (2028) - Unmitigated

4. Operations Emissions Details

4.1. Mobile Emissions by Land Use

4.1.1. Unmitigated

4.2. Energy

4.2.1. Electricity Emissions By Land Use - Unmitigated

4.2.3. Natural Gas Emissions By Land Use - Unmitigated

4.3. Area Emissions by Source

4.3.1. Unmitigated

4.4. Water Emissions by Land Use

4.4.1. Unmitigated

4.5. Waste Emissions by Land Use

4.5.1. Unmitigated

4.6. Refrigerant Emissions by Land Use

4.6.1. Unmitigated

4.7. Offroad Emissions By Equipment Type
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4.7.1. Unmitigated

4.8. Stationary Emissions By Equipment Type

4.8.1. Unmitigated

4.9. User Defined Emissions By Equipment Type

4.9.1. Unmitigated

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

5. Activity Data

5.1. Construction Schedule

5.2. Off-Road Equipment

5.2.1. Unmitigated

5.3. Construction Vehicles

5.3.1. Unmitigated

5.4. Vehicles

5.4.1. Construction Vehicle Control Strategies

5.5. Architectural Coatings
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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

5.9. Operational Mobile Sources

5.9.1. Unmitigated

5.10. Operational Area Sources

5.10.1. Hearths

5.10.1.1. Unmitigated

5.10.2. Architectural Coatings

5.10.3. Landscape Equipment

5.11. Operational Energy Consumption

5.11.1. Unmitigated

5.12. Operational Water and Wastewater Consumption

5.12.1. Unmitigated

5.13. Operational Waste Generation

5.13.1. Unmitigated
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5.14. Operational Refrigeration and Air Conditioning Equipment

5.14.1. Unmitigated

5.15. Operational Off-Road Equipment

5.15.1. Unmitigated

5.16. Stationary Sources

5.16.1. Emergency Generators and Fire Pumps

5.16.2. Process Boilers

5.17. User Defined

5.18. Vegetation

5.18.1. Land Use Change

5.18.1.1. Unmitigated

5.18.1. Biomass Cover Type

5.18.1.1. Unmitigated

5.18.2. Sequestration

5.18.2.1. Unmitigated

6. Climate Risk Detailed Report

6.1. Climate Risk Summary

6.2. Initial Climate Risk Scores
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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

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

1.1. Basic Project Information
Data Field Value
Project Name 14556-Moreno Valley Towne Center (Unmitigated) Construction Start Date 11/5/2025
Operational Y ear 2028
Lead Agency —
Land Use Scale Plan/community
Analysis Level for Defaults County
Windspeed (m/s) 2.50
Precipitation (days) 24.0
Location 33.920986394588446, -117.193682312174
County Riverside-South Coast
City Moreno Valley
Air District South Coast AQMD
Air Basin South Coast
TAZ 5592
EDFZ 11
Electric Utility Moreno Valley Utility
Gas Utility Southern California Gas
App Version 2022.1.1.29

1.2. Land Use Types
Land Use Subtype Size Unit Lot Acreage Building Area (sq ft) Landscape Area (sq ft)
Special Landscape
Area
(sq ft)
Population Description
Single Family
Housing
800 Dwelling Unit 33.1 1,440,000 9,370,286 — 2,584 —
14556-Moreno Valley Towne Center (Unmitigated) Detailed Report, 12/13/2024 8 / 68
City Park 4.80 Acre 4.80 0.00 209,088 0.00 — —
Hotel 106 Room 1.34 58,409 0.00 — — —
General Office
Building

15.0 1000sqft 0.34 15,000 0.00 — — —
Library 30.0 1000sqft 0.69 30,000 0.00 — — —
High Turnover (Sit
Do
wn Restaurant)

16.7 1000sqft 0.38 16,660 0.00 — — —
Fast Food
Restaur
ant with
Drive Thru

3.50 1000sqft 0.08 3,500 0.00 — — —
Regional Shopping
Center

60.9 1000sqft 1.40 60,890 0.00 — — —
Supermarket 45.0 1000sqft 1.03 45,000 0.00 — — —
Parking Lot 930 Space 3.07 0.00 0.00 — — —
Other Asphalt
Surf
aces
434 1000sqft 9.97 0.00 0.00 — — —

1.3. User-Selected Emission Reduction Measures by Emissions Sector No measures selected

2. Emissions Summary

2.1. Construction Emissions Compared Against Thresholds Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Un/Mit. TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 194 193 31.7 64.0 0.09 1.12 6.75 7.43 1.03 1.62 2.47 — 14,890 14,890 0.55 0.73 26.9 15,149 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
-------------------
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Unmit. 194 193 70.8 76.4 0.14 3.46 8.96 12.4 3.18 3.82 7.00 — 20,122 20,122 0.63 0.85 0.73 20,391 Average
Daily
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 30.5 30.2 20.3 33.5 0.05 0.73 4.07 4.58 0.68 0.98 1.62 — 9,052 9,052 0.25 0.49 7.31 9,212 Annual
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 5.56 5.51 3.71 6.11 0.01 0.13 0.74 0.84 0.12 0.18 0.30 — 1,499 1,499 0.04 0.08 1.21 1,525

2.2. Construction Emissions by Y ear, Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Y ear TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily -
Summer
(Max)
— — — — — — — — — — — — — — — — — —
2026 5.88 5.05 31.7 64.0 0.09 1.12 5.98 7.10 1.03 1.44 2.47 — 14,890 14,890 0.55 0.73 26.9 15,149 2027 4.28 3.62 23.3 50.9 0.07 0.72 5.78 6.50 0.67 1.39 2.06 — 13,018 13,018 0.33 0.69 23.7 13,255 2028 194 193 23.5 55.3 0.07 0.67 6.75 7.43 0.62 1.62 2.24 — 14,020 14,020 0.32 0.73 24.2 14,269 Daily -
Winter
(Max)
— — — — — — — — — — — — — — — — — —
2025 9.26 7.79 70.8 64.2 0.12 3.46 8.96 12.4 3.18 3.82 7.00 — 13,219 13,219 0.53 0.19 0.09 13,290 2026 8.51 7.16 55.3 76.4 0.14 2.19 8.82 11.0 2.02 2.47 4.48 — 20,122 20,122 0.63 0.85 0.73 20,391 2027 4.20 3.53 23.6 44.9 0.07 0.72 5.78 6.50 0.67 1.39 2.06 — 12,616 12,616 0.33 0.69 0.62 12,830 2028 194 193 23.9 48.6 0.07 0.67 6.75 7.43 0.62 1.62 2.24 — 13,547 13,547 0.33 0.73 0.63 13,772 Average
Daily
— — — — — — — — — — — — — — — — — —
2025 0.52 0.44 3.99 3.64 0.01 0.19 0.47 0.67 0.18 0.20 0.37 — 776 776 0.03 0.01 0.09 780 2026 3.39 2.87 20.3 33.5 0.05 0.73 3.69 4.43 0.68 0.94 1.62 — 8,666 8,666 0.25 0.43 6.48 8,805 2027 3.00 2.53 17.0 32.7 0.05 0.51 4.07 4.58 0.48 0.98 1.46 — 9,052 9,052 0.24 0.49 7.31 9,212 2028 30.5 30.2 13.9 27.9 0.04 0.40 3.61 4.01 0.37 0.87 1.24 — 7,779 7,779 0.19 0.42 5.79 7,917 -------------------
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Annual — — — — — — — — — — — — — — — — — —
2025 0.10 0.08 0.73 0.66 < 0.005 0.04 0.09 0.12 0.03 0.04 0.07 — 128 128 0.01 < 0.005 0.01 129 2026 0.62 0.52 3.71 6.11 0.01 0.13 0.67 0.81 0.12 0.17 0.30 — 1,435 1,435 0.04 0.07 1.07 1,458 2027 0.55 0.46 3.10 5.97 0.01 0.09 0.74 0.84 0.09 0.18 0.27 — 1,499 1,499 0.04 0.08 1.21 1,525 2028 5.56 5.51 2.54 5.08 0.01 0.07 0.66 0.73 0.07 0.16 0.23 — 1,288 1,288 0.03 0.07 0.96 1,311

2.4. Operations Emissions Compared Against Thresholds
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Un/Mit. TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 138 131 78.1 567 1.34 2.69 106 109 2.63 27.0 29.6 854 166,802 167,656 94.1 6.42 755 172,675 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 127 120 81.4 451 1.26 2.65 106 109 2.60 27.0 29.6 854 159,398 160,252 94.4 6.61 419 165,000 Average
Daily
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 119 113 63.5 446 1.07 1.58 93.3 94.8 1.53 23.7 25.2 854 132,173 133,027 93.4 5.93 543 137,672 Annual
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 21.7 20.6 11.6 81.4 0.20 0.29 17.0 17.3 0.28 4.32 4.60 141 21,883 22,024 15.5 0.98 89.9 22,793

2.5. Operations Emissions by Sector, Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Sector TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
-------------------
-------------------
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Mobile 91.2 85.8 55.3 501 1.19 0.86 106 107 0.80 27.0 27.8 — 122,112 122,112 5.92 5.96 344 124,381 Area 46.2 45.1 13.8 61.1 0.09 1.11 — 1.11 1.10 — 1.10 0.00 17,007 17,007 0.32 0.03 — 17,025 Energy 1.04 0.52 9.03 4.61 0.06 0.72 — 0.72 0.72 — 0.72 — 25,999 25,999 2.07 0.15 — 26,096 Water — — — — — — — — — — — 105 1,683 1,789 10.9 0.27 — 2,143 Waste — — — — — — — — — — — 748 0.00 748 74.8 0.00 — 2,619 Refrig. — — — — — — — — — — — — — — — — 410 410
Total 138 131 78.1 567 1.34 2.69 106 109 2.63 27.0 29.6 854 166,802 167,656 94.1 6.42 755 172,675 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Mobile 85.7 80.2 59.1 441 1.12 0.86 106 107 0.80 27.0 27.8 — 114,871 114,871 6.28 6.15 8.93 116,870 Area 40.2 39.5 13.3 5.65 0.08 1.07 — 1.07 1.07 — 1.07 0.00 16,845 16,845 0.32 0.03 — 16,862 Energy 1.04 0.52 9.03 4.61 0.06 0.72 — 0.72 0.72 — 0.72 — 25,999 25,999 2.07 0.15 — 26,096 Water — — — — — — — — — — — 105 1,683 1,789 10.9 0.27 — 2,143 Waste — — — — — — — — — — — 748 0.00 748 74.8 0.00 — 2,619 Refrig. — — — — — — — — — — — — — — — — 410 410
Total 127 120 81.4 451 1.26 2.65 106 109 2.60 27.0 29.6 854 159,398 160,252 94.4 6.61 419 165,000 Average
Daily
— — — — — — — — — — — — — — — — — —
Mobile 74.8 70.0 53.2 403 1.01 0.76 93.3 94.0 0.72 23.7 24.4 — 103,225 103,225 5.57 5.51 132 105,137 Area 42.9 42.6 1.26 38.4 0.01 0.10 — 0.10 0.09 — 0.09 0.00 1,265 1,265 0.03 < 0.005 — 1,267 Energy 1.04 0.52 9.03 4.61 0.06 0.72 — 0.72 0.72 — 0.72 — 25,999 25,999 2.07 0.15 — 26,096 Water — — — — — — — — — — — 105 1,683 1,789 10.9 0.27 — 2,143 Waste — — — — — — — — — — — 748 0.00 748 74.8 0.00 — 2,619 Refrig. — — — — — — — — — — — — — — — — 410 410
Total 119 113 63.5 446 1.07 1.58 93.3 94.8 1.53 23.7 25.2 854 132,173 133,027 93.4 5.93 543 137,672 Annual — — — — — — — — — — — — — — — — — —
Mobile 13.7 12.8 9.70 73.6 0.18 0.14 17.0 17.2 0.13 4.32 4.45 — 17,090 17,090 0.92 0.91 21.9 17,407 Area 7.83 7.77 0.23 7.00 < 0.005 0.02 — 0.02 0.02 — 0.02 0.00 209 209 < 0.005 < 0.005 — 210 14556-Moreno Valley Towne Center (Unmitigated) Detailed Report, 12/13/2024 12 / 68
Energy 0.19 0.10 1.65 0.84 0.01 0.13 — 0.13 0.13 — 0.13 — 4,304 4,304 0.34 0.02 — 4,320 Water — — — — — — — — — — — 17.5 279 296 1.81 0.04 — 355 Waste — — — — — — — — — — — 124 0.00 124 12.4 0.00 — 434 Refrig. — — — — — — — — — — — — — — — — 68.0 68.0
Total 21.7 20.6 11.6 81.4 0.20 0.29 17.0 17.3 0.28 4.32 4.60 141 21,883 22,024 15.5 0.98 89.9 22,793

3. Construction Emissions Details

3.1. Site Preparation (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/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 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

4.82 4.05 37.5 32.4 0.05 1.93 — 1.93 1.78 — 1.78 — 5,528 5,528 0.22 0.04 — 5,547 Dust
F
rom
Material
Movement
— — — — — — 5.66 5.66 — 2.69 2.69 — — — — — — —
Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 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
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.21 0.18 1.64 1.42 < 0.005 0.08 — 0.08 0.08 — 0.08 — 242 242 0.01 < 0.005 — 243 -------------------
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Dust
F
rom
Material
Movement
— — — — — — 0.25 0.25 — 0.12 0.12 — — — — — — —
Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 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 — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.04 0.03 0.30 0.26 < 0.005 0.02 — 0.02 0.01 — 0.01 — 40.1 40.1 < 0.005 < 0.005 — 40.3 Dust
F
rom
Material
Movement
— — — — — — 0.05 0.05 — 0.02 0.02 — — — — — — —
Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 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 < 0.005 < 0.005 0.11 0.03 < 0.005 < 0.005 0.03 0.03 < 0.005 0.01 0.01 — 91.8 91.8 < 0.005 0.01 0.01 96.1 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 0.05 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 — 10.1 10.1 < 0.005 < 0.005 0.02 10.2 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 4.02 4.02 < 0.005 < 0.005 < 0.005 4.21 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 — 1.67 1.67 < 0.005 < 0.005 < 0.005 1.69 14556-Moreno Valley Towne Center (Unmitigated) Detailed Report, 12/13/2024 14 / 68
Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 0.67 0.67 < 0.005 < 0.005 < 0.005 0.70 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

3.3. Grading (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/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 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

4.24 3.57 32.6 29.4 0.06 1.52 — 1.52 1.40 — 1.40 — 6,715 6,715 0.27 0.05 — 6,738 Dust
F
rom
Material
Movement
— — — — — — 2.67 2.67 — 0.98 0.98 — — — — — — —
Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 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
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.30 0.25 2.30 2.07 < 0.005 0.11 — 0.11 0.10 — 0.10 — 473 473 0.02 < 0.005 — 475 Dust
F
rom
Material
Movement
— — — — — — 0.19 0.19 — 0.07 0.07 — — — — — — —
Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 -------------------
14556-Moreno Valley Towne Center (Unmitigated) Detailed Report, 12/13/2024 15 / 68
Annual — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.05 0.05 0.42 0.38 < 0.005 0.02 — 0.02 0.02 — 0.02 — 78.3 78.3 < 0.005 < 0.005 — 78.6 Dust
F
rom
Material
Movement
— — — — — — 0.03 0.03 — 0.01 0.01 — — — — — — —
Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
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 0.02 0.01 0.46 0.14 < 0.005 0.01 0.11 0.12 0.01 0.03 0.04 — 398 398 0.01 0.06 0.03 416 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 0.01 0.01 0.01 0.09 0.00 0.00 0.02 0.02 0.00 < 0.005 < 0.005 — 18.5 18.5 < 0.005 < 0.005 0.03 18.7 Vendor < 0.005 < 0.005 0.03 0.01 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 28.0 28.0 < 0.005 < 0.005 0.03 29.3 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 — 3.06 3.06 < 0.005 < 0.005 0.01 3.10 Vendor < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 4.64 4.64 < 0.005 < 0.005 0.01 4.86 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 (2026) - Unmitigated
14556-Moreno Valley Towne Center (Unmitigated) Detailed Report, 12/13/2024 16 / 68
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/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 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

4.03 3.39 30.0 28.7 0.06 1.38 — 1.38 1.27 — 1.27 — 6,715 6,715 0.27 0.05 — 6,738 Dust
F
rom
Material
Movement
— — — — — — 2.67 2.67 — 0.98 0.98 — — — — — — —
Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 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
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.65 0.54 4.81 4.60 0.01 0.22 — 0.22 0.20 — 0.20 — 1,078 1,078 0.04 0.01 — 1,081 Dust
F
rom
Material
Movement
— — — — — — 0.43 0.43 — 0.16 0.16 — — — — — — —
Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 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 — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.12 0.10 0.88 0.84 < 0.005 0.04 — 0.04 0.04 — 0.04 — 178 178 0.01 < 0.005 — 179 -------------------
14556-Moreno Valley Towne Center (Unmitigated) Detailed Report, 12/13/2024 17 / 68
———————0.030.03—0.080.08——————Dust
From
Mater
ial
Movement
Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.09 0.08 0.09 1.09 0.00 0.00 0.26 0.26 0.00 0.06 0.06 — 254 254 < 0.005 0.01 0.02 257 Vendor 0.02 0.01 0.44 0.13 < 0.005 0.01 0.11 0.12 0.01 0.03 0.04 — 392 392 0.01 0.06 0.03 410 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 0.01 0.01 0.02 0.18 0.00 0.00 0.04 0.04 0.00 0.01 0.01 — 41.2 41.2 < 0.005 < 0.005 0.06 41.8 Vendor < 0.005 < 0.005 0.07 0.02 < 0.005 < 0.005 0.02 0.02 < 0.005 < 0.005 0.01 — 62.8 62.8 < 0.005 0.01 0.07 65.8 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 0.03 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 — 6.82 6.82 < 0.005 < 0.005 0.01 6.92 Vendor < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 10.4 10.4 < 0.005 < 0.005 0.01 10.9 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

3.7. Building Construction (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/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 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —------------------- 14556-Moreno Valley Towne Center (Unmitigated) Detailed Report, 12/13/2024 18 / 68
——————————————————Daily,
Summer
(Max)
Off-Roa
d
Equipm
ent

2.56 2.14 19.6 25.2 0.05 0.75 — 0.75 0.69 — 0.69 — 4,817 4,817 0.20 0.04 — 4,833 Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 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)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

2.56 2.14 19.6 25.2 0.05 0.75 — 0.75 0.69 — 0.69 — 4,817 4,817 0.20 0.04 — 4,833 Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 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
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

1.42 1.19 10.9 14.0 0.03 0.42 — 0.42 0.38 — 0.38 — 2,677 2,677 0.11 0.02 — 2,686 Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 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 — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.26 0.22 1.99 2.55 < 0.005 0.08 — 0.08 0.07 — 0.07 — 443 443 0.02 < 0.005 — 445 Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
14556-Moreno Valley Towne Center (Unmitigated) Detailed Report, 12/13/2024 19 / 68
Worker 1.75 1.58 1.46 26.7 0.00 0.00 4.87 4.87 0.00 1.14 1.14 — 5,134 5,134 0.22 0.18 17.4 5,210 Vendor 0.15 0.07 3.44 1.07 0.02 0.05 0.92 0.96 0.05 0.25 0.30 — 3,221 3,221 0.07 0.50 8.81 3,380 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 1.67 1.49 1.63 20.3 0.00 0.00 4.87 4.87 0.00 1.14 1.14 — 4,721 4,721 0.07 0.18 0.45 4,778 Vendor 0.14 0.06 3.59 1.10 0.02 0.05 0.92 0.96 0.05 0.25 0.30 — 3,223 3,223 0.07 0.50 0.23 3,374 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 0.92 0.82 0.99 11.8 0.00 0.00 2.66 2.66 0.00 0.62 0.62 — 2,657 2,657 0.04 0.10 4.18 2,693 Vendor 0.08 0.04 2.00 0.60 0.01 0.03 0.50 0.53 0.03 0.14 0.17 — 1,791 1,791 0.04 0.28 2.10 1,876 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 0.17 0.15 0.18 2.15 0.00 0.00 0.49 0.49 0.00 0.11 0.11 — 440 440 0.01 0.02 0.69 446 Vendor 0.01 0.01 0.37 0.11 < 0.005 < 0.005 0.09 0.10 < 0.005 0.03 0.03 — 296 296 0.01 0.05 0.35 311 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 (2027) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/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 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

2.46 2.06 18.7 25.1 0.05 0.67 — 0.67 0.62 — 0.62 — 4,817 4,817 0.20 0.04 — 4,833 -------------------
14556-Moreno Valley Towne Center (Unmitigated) Detailed Report, 12/13/2024 20 / 68

0.000.000.000.000.000.00—0.000.000.000.000.000.000.000.000.000.000.00Onsite truck
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

2.46 2.06 18.7 25.1 0.05 0.67 — 0.67 0.62 — 0.62 — 4,817 4,817 0.20 0.04 — 4,833 Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 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
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

1.76 1.47 13.4 18.0 0.03 0.48 — 0.48 0.44 — 0.44 — 3,440 3,440 0.14 0.03 — 3,452 Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 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 — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.32 0.27 2.44 3.28 0.01 0.09 — 0.09 0.08 — 0.08 — 570 570 0.02 < 0.005 — 572 Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Worker 1.68 1.49 1.29 24.7 0.00 0.00 4.87 4.87 0.00 1.14 1.14 — 5,039 5,039 0.06 0.18 15.7 5,109 Vendor 0.14 0.07 3.31 1.04 0.02 0.05 0.92 0.96 0.05 0.25 0.30 — 3,162 3,162 0.07 0.47 8.05 3,313 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)
— — — — — — — — — — — — — — — — — —
14556-Moreno Valley Towne Center (Unmitigated) Detailed Report, 12/13/2024 21 / 68
Worker 1.60 1.41 1.46 18.7 0.00 0.00 4.87 4.87 0.00 1.14 1.14 — 4,635 4,635 0.07 0.18 0.41 4,689 Vendor 0.14 0.06 3.46 1.07 0.02 0.05 0.92 0.96 0.05 0.25 0.30 — 3,164 3,164 0.07 0.47 0.21 3,308 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 1.14 1.01 1.15 14.0 0.00 0.00 3.42 3.42 0.00 0.80 0.80 — 3,352 3,352 0.05 0.13 4.82 3,396 Vendor 0.10 0.05 2.46 0.75 0.02 0.03 0.65 0.68 0.03 0.18 0.21 — 2,259 2,259 0.05 0.34 2.48 2,364 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 0.21 0.18 0.21 2.56 0.00 0.00 0.62 0.62 0.00 0.15 0.15 — 555 555 0.01 0.02 0.80 562 Vendor 0.02 0.01 0.45 0.14 < 0.005 0.01 0.12 0.12 0.01 0.03 0.04 — 374 374 0.01 0.06 0.41 391 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. Building Construction (2028) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/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 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

2.37 1.98 17.8 25.1 0.05 0.60 — 0.60 0.55 — 0.55 — 4,818 4,818 0.20 0.04 — 4,834 Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 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)
— — — — — — — — — — — — — — — — — —
-------------------
14556-Moreno Valley Towne Center (Unmitigated) Detailed Report, 12/13/2024 22 / 68
4,834—0.040.204,8184,818—0.55—0.550.60—0.600.0525.117.81.982.37Off-Roa d
Equipm
ent
Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 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
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

1.44 1.21 10.8 15.3 0.03 0.37 — 0.37 0.34 — 0.34 — 2,932 2,932 0.12 0.02 — 2,942 Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 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 — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.26 0.22 1.97 2.79 0.01 0.07 — 0.07 0.06 — 0.06 — 485 485 0.02 < 0.005 — 487 Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Worker 1.62 1.44 1.28 23.0 0.00 0.00 4.87 4.87 0.00 1.14 1.14 — 4,945 4,945 0.06 0.18 14.0 5,013 Vendor 0.14 0.07 3.15 1.01 0.02 0.05 0.92 0.96 0.05 0.25 0.30 — 3,090 3,090 0.05 0.47 7.33 3,240 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 1.40 1.36 1.45 17.4 0.00 0.00 4.87 4.87 0.00 1.14 1.14 — 4,549 4,549 0.07 0.18 0.36 4,603 Vendor 0.14 0.06 3.29 1.04 0.02 0.05 0.92 0.96 0.05 0.25 0.30 — 3,093 3,093 0.05 0.47 0.19 3,235 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 14556-Moreno Valley Towne Center (Unmitigated) Detailed Report, 12/13/2024 23 / 68
——————————————————Average
Daily
Worker 0.84 0.82 0.88 11.2 0.00 0.00 2.92 2.92 0.00 0.68 0.68 — 2,803 2,803 0.04 0.11 3.69 2,840 Vendor 0.09 0.04 2.02 0.63 0.01 0.03 0.55 0.58 0.03 0.15 0.18 — 1,881 1,881 0.03 0.29 1.92 1,970 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 0.15 0.15 0.16 2.04 0.00 0.00 0.53 0.53 0.00 0.12 0.12 — 464 464 0.01 0.02 0.61 470 Vendor 0.02 0.01 0.37 0.11 < 0.005 0.01 0.10 0.11 0.01 0.03 0.03 — 312 312 0.01 0.05 0.32 326 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. Paving (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/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 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

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 Paving 0.44 0.44 — — — — — — — — — — — — — — — —
Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 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)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

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 Paving 0.44 0.44 — — — — — — — — — — — — — — — —
-------------------
14556-Moreno Valley Towne Center (Unmitigated) Detailed Report, 12/13/2024 24 / 68
Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 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
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.19 0.16 1.50 2.10 < 0.005 0.07 — 0.07 0.06 — 0.06 — 319 319 0.01 < 0.005 — 320 Paving 0.09 0.09 — — — — — — — — — — — — — — — —
Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 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 — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.03 0.03 0.27 0.38 < 0.005 0.01 — 0.01 0.01 — 0.01 — 52.8 52.8 < 0.005 < 0.005 — 52.9 Paving 0.02 0.02 — — — — — — — — — — — — — — — —
Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.07 0.06 0.06 1.08 0.00 0.00 0.20 0.20 0.00 0.05 0.05 — 207 207 0.01 0.01 0.70 210 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.07 0.06 0.07 0.82 0.00 0.00 0.20 0.20 0.00 0.05 0.05 — 190 190 < 0.005 0.01 0.02 193 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
— — — — — — — — — — — — — — — — — —
14556-Moreno Valley Towne Center (Unmitigated) Detailed Report, 12/13/2024 25 / 68
Worker 0.01 0.01 0.02 0.18 0.00 0.00 0.04 0.04 0.00 0.01 0.01 — 40.6 40.6 < 0.005 < 0.005 0.06 41.2 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 0.03 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 — 6.73 6.73 < 0.005 < 0.005 0.01 6.82 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

3.15. Architectural Coating (2028) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/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 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.17 0.14 1.08 1.49 < 0.005 0.02 — 0.02 0.02 — 0.02 — 178 178 0.01 < 0.005 — 179 Architect
ur
al
Coating
s
190 190 — — — — — — — — — — — — — — — —
Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 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)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.17 0.14 1.08 1.49 < 0.005 0.02 — 0.02 0.02 — 0.02 — 178 178 0.01 < 0.005 — 179 -------------------
14556-Moreno Valley Towne Center (Unmitigated) Detailed Report, 12/13/2024 26 / 68
————————————————190190Architect
ur
al
Coating
Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 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
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.03 0.02 0.16 0.22 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 26.3 26.3 < 0.005 < 0.005 — 26.4 Architect
ur
al
Coating
s

28.0 28.0 — — — — — — — — — — — — — — — —
Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 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 — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent
< 0.005 < 0.005 0.03 0.04 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 4.36 4.36 < 0.005 < 0.005 — 4.38 Architect
ur
al
Coating
s

5.12 5.12 — — — — — — — — — — — — — — — —
Onsite
tr
uck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.32 0.29 0.26 4.61 0.00 0.00 0.97 0.97 0.00 0.23 0.23 — 989 989 0.01 0.04 2.81 1,003 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 14556-Moreno Valley Towne Center (Unmitigated) Detailed Report, 12/13/2024 27 / 68
——————————————————Daily,
Winter
(Max)
Worker 0.28 0.27 0.29 3.49 0.00 0.00 0.97 0.97 0.00 0.23 0.23 — 910 910 0.01 0.04 0.07 921 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 0.04 0.04 0.04 0.54 0.00 0.00 0.14 0.14 0.00 0.03 0.03 — 136 136 < 0.005 0.01 0.18 138 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 0.01 0.01 0.01 0.10 0.00 0.00 0.03 0.03 0.00 0.01 0.01 — 22.6 22.6 < 0.005 < 0.005 0.03 22.9 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 0.00 0.00 0.00 0.00 0.00 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

4.1. Mobile Emissions by Land Use

4.1.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Single
F
amily
Housing

27.6 25.8 17.7 162 0.40 0.28 35.4 35.7 0.26 8.98 9.25 — 40,487 40,487 1.86 1.92 115 41,221 City
P
ark

0.04 0.04 0.04 0.40 < 0.005 < 0.005 0.10 0.10 < 0.005 0.03 0.03 — 111 111 < 0.005 < 0.005 0.32 113 14556-Moreno Valley Towne Center (Unmitigated) Detailed Report, 12/13/2024 28 / 68
Hotel 3.14 2.94 2.07 19.1 0.05 0.03 4.23 4.26 0.03 1.07 1.11 — 4,830 4,830 0.22 0.23 13.7 4,917 General
Office
Building

0.82 0.75 0.75 7.30 0.02 0.01 1.80 1.81 0.01 0.46 0.47 — 2,026 2,026 0.07 0.09 5.83 2,059 Library 9.59 8.83 7.70 73.7 0.19 0.13 17.5 17.7 0.13 4.45 4.58 — 19,812 19,812 0.75 0.86 56.8 20,145 High
T
urnover
(Sit
Down
Restaurant)

7.68 7.39 3.23 26.3 0.05 0.04 4.13 4.17 0.04 1.05 1.09 — 4,993 4,993 0.40 0.32 13.4 5,113 Fast
F
ood
Restaurant
with
Drive
Thru

7.24 6.90 3.58 30.8 0.07 0.05 5.70 5.75 0.05 1.45 1.49 — 6,686 6,686 0.41 0.37 18.5 6,826 Regiona
l
Shoppin
g
Center

16.9 16.1 9.00 79.0 0.18 0.13 15.5 15.6 0.12 3.93 4.05 — 17,999 17,999 1.01 0.95 50.2 18,358 Superm
ar
ket

18.2 17.1 11.3 102 0.25 0.18 21.9 22.1 0.17 5.57 5.73 — 25,167 25,167 1.20 1.22 71.1 25,631 Parking
Lot

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Other
Asphalt
Surf
aces

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Total 91.2 85.8 55.3 501 1.19 0.86 106 107 0.80 27.0 27.8 — 122,112 122,112 5.92 5.96 344 124,381 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Single
F
amily
Housing

25.9 24.2 18.9 141 0.37 0.28 35.4 35.7 0.26 8.98 9.25 — 38,074 38,074 1.96 1.98 2.97 38,717 City
P
ark

0.04 0.04 0.04 0.33 < 0.005 < 0.005 0.10 0.10 < 0.005 0.03 0.03 — 104 104 < 0.005 < 0.005 0.01 106 14556-Moreno Valley Towne Center (Unmitigated) Detailed Report, 12/13/2024 29 / 68
Hotel 2.96 2.75 2.22 16.6 0.04 0.03 4.23 4.26 0.03 1.07 1.11 — 4,542 4,542 0.23 0.23 0.36 4,617 General
Office
Building

0.78 0.70 0.80 6.06 0.02 0.01 1.80 1.81 0.01 0.46 0.47 — 1,902 1,902 0.07 0.09 0.15 1,931 Library 9.06 8.29 8.25 62.1 0.18 0.13 17.5 17.7 0.13 4.45 4.58 — 18,614 18,614 0.78 0.89 1.47 18,900 High
T
urnover
(Sit
Down
Restaurant)

7.18 6.88 3.44 25.1 0.05 0.04 4.13 4.17 0.04 1.05 1.09 — 4,715 4,715 0.43 0.33 0.35 4,826 Fast
F
ood
Restaurant
with
Drive
Thru

6.78 6.44 3.82 28.2 0.06 0.05 5.70 5.75 0.05 1.45 1.49 — 6,300 6,300 0.44 0.38 0.48 6,426 Regiona
l
Shoppin
g
Center

15.8 15.0 9.61 71.2 0.17 0.13 15.5 15.6 0.12 3.93 4.05 — 16,948 16,948 1.08 0.98 1.30 17,268 Superm
ar
ket

17.1 16.0 12.0 89.7 0.23 0.18 21.9 22.1 0.17 5.57 5.73 — 23,672 23,672 1.27 1.26 1.84 24,080 Parking
Lot

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Other
Asphalt
Surf
aces

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Total 85.7 80.2 59.1 441 1.12 0.86 106 107 0.80 27.0 27.8 — 114,871 114,871 6.28 6.15 8.93 116,870 Annual — — — — — — — — — — — — — — — — — —
Single
F
amily
Housing

4.60 4.28 3.44 26.1 0.07 0.05 6.24 6.29 0.05 1.58 1.63 — 6,242 6,242 0.32 0.32 8.04 6,354 City
P
ark
< 0.005 < 0.005 < 0.005 0.03 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 9.44 9.44 < 0.005 < 0.005 0.01 9.59 Hotel 0.51 0.47 0.39 2.99 0.01 0.01 0.73 0.73 0.01 0.18 0.19 — 726 726 0.04 0.04 0.94 738 14556-Moreno Valley Towne Center (Unmitigated) Detailed Report, 12/13/2024 30 / 68
2410.310.010.01237237—0.060.06< 0.0050.240.24< 0.005< 0.0050.860.110.090.11General Office
Building
Library 1.41 1.29 1.32 10.1 0.03 0.02 2.71 2.73 0.02 0.69 0.71 — 2,677 2,677 0.11 0.13 3.49 2,722 High
T
urnover
(Sit
Down
Restaurant)

1.04 1.00 0.51 3.77 0.01 0.01 0.60 0.60 0.01 0.15 0.16 — 632 632 0.06 0.04 0.77 647 Fast
F
ood
Restaurant
with
Drive
Thru

0.97 0.92 0.56 4.20 0.01 0.01 0.81 0.82 0.01 0.21 0.21 — 836 836 0.06 0.05 1.05 854 Regiona
l
Shoppin
g
Center

2.33 2.20 1.44 10.9 0.02 0.02 2.26 2.28 0.02 0.57 0.59 — 2,302 2,302 0.15 0.13 2.92 2,348 Superm
ar
ket

2.68 2.51 1.93 14.7 0.04 0.03 3.42 3.45 0.03 0.87 0.89 — 3,430 3,430 0.18 0.18 4.41 3,493 Parking
Lot

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Other
Asphalt
Surf
aces

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Total 13.7 12.8 9.70 73.6 0.18 0.14 17.0 17.2 0.13 4.32 4.45 — 17,090 17,090 0.92 0.91 21.9 17,407

4.2. Energy

4.2.1. Electricity Emissions By Land Use - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e 14556-Moreno Valley Towne Center (Unmitigated) Detailed Report, 12/13/2024 31 / 68
——————————————————Daily,
Summer
(Max)
Single
F
amily
Housing
— — — — — — — — — — — — 9,277 9,277 0.68 0.08 — 9,318
City
P
ark
— — — — — — — — — — — — 0.00 0.00 0.00 0.00 — 0.00
Hotel — — — — — — — — — — — — 1,168 1,168 0.09 0.01 — 1,174 General
Office
Building
— — — — — — — — — — — — 325 325 0.02 < 0.005 — 326
Library — — — — — — — — — — — — 356 356 0.03 < 0.005 — 358 High
T
urnover
(Sit
Down
Restaurant)
— — — — — — — — — — — — 726 726 0.05 0.01 — 730
Fast
F
ood
Restaurant
with
Drive
Thru
— — — — — — — — — — — — 153 153 0.01 < 0.005 — 153
Regiona
l
Shoppin
g
Center
— — — — — — — — — — — — 738 738 0.05 0.01 — 741
Superm
ar
ket
— — — — — — — — — — — — 1,792 1,792 0.13 0.02 — 1,800
Parking
Lot
— — — — — — — — — — — — 145 145 0.01 < 0.005 — 146
Other
Asphalt
Surf
aces
— — — — — — — — — — — — 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — — — 14,681 14,681 1.07 0.13 — 14,747 14556-Moreno Valley Towne Center (Unmitigated) Detailed Report, 12/13/2024 32 / 68
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Single
F
amily
Housing
— — — — — — — — — — — — 9,277 9,277 0.68 0.08 — 9,318
City
P
ark
— — — — — — — — — — — — 0.00 0.00 0.00 0.00 — 0.00
Hotel — — — — — — — — — — — — 1,168 1,168 0.09 0.01 — 1,174 General
Office
Building
— — — — — — — — — — — — 325 325 0.02 < 0.005 — 326
Library — — — — — — — — — — — — 356 356 0.03 < 0.005 — 358 High
T
urnover
(Sit
Down
Restaurant)
— — — — — — — — — — — — 726 726 0.05 0.01 — 730
Fast
F
ood
Restaurant
with
Drive
Thru
— — — — — — — — — — — — 153 153 0.01 < 0.005 — 153
Regiona
l
Shoppin
g
Center
— — — — — — — — — — — — 738 738 0.05 0.01 — 741
Superm
ar
ket
— — — — — — — — — — — — 1,792 1,792 0.13 0.02 — 1,800
Parking
Lot
— — — — — — — — — — — — 145 145 0.01 < 0.005 — 146
Other
Asphalt
Surf
aces
— — — — — — — — — — — — 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — — — 14,681 14,681 1.07 0.13 — 14,747 14556-Moreno Valley Towne Center (Unmitigated) Detailed Report, 12/13/2024 33 / 68
Annual — — — — — — — — — — — — — — — — — —
Single
F
amily
Housing
— — — — — — — — — — — — 1,536 1,536 0.11 0.01 — 1,543
City
P
ark
— — — — — — — — — — — — 0.00 0.00 0.00 0.00 — 0.00
Hotel — — — — — — — — — — — — 193 193 0.01 < 0.005 — 194 General
Office
Building
— — — — — — — — — — — — 53.8 53.8 < 0.005 < 0.005 — 54.0 Library — — — — — — — — — — — — 59.0 59.0 < 0.005 < 0.005 — 59.3 High
T
urnover
(Sit
Down
Restaurant)
— — — — — — — — — — — — 120 120 0.01 < 0.005 — 121
Fast
F
ood
Restaurant
with
Drive
Thru
— — — — — — — — — — — — 25.3 25.3 < 0.005 < 0.005 — 25.4 Regiona
l
Shoppin
g
Center
— — — — — — — — — — — — 122 122 0.01 < 0.005 — 123
Superm
ar
ket
— — — — — — — — — — — — 297 297 0.02 < 0.005 — 298
Parking
Lot
— — — — — — — — — — — — 24.1 24.1 < 0.005 < 0.005 — 24.2 Other
Asphalt
Surf
aces
— — — — — — — — — — — — 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — — — 2,431 2,431 0.18 0.02 — 2,441 14556-Moreno Valley Towne Center (Unmitigated) Detailed Report, 12/13/2024 34 / 68

4.2.3. Natural Gas Emissions By Land Use - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Single
F
amily
Housing

0.84 0.42 7.18 3.06 0.05 0.58 — 0.58 0.58 — 0.58 — 9,118 9,118 0.81 0.02 — 9,144 City
P
ark

0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 — 0.00 0.00 0.00 0.00 — 0.00 Hotel 0.05 0.03 0.47 0.39 < 0.005 0.04 — 0.04 0.04 — 0.04 — 559 559 0.05 < 0.005 — 561 General
Office
Building

0.01 0.01 0.11 0.09 < 0.005 0.01 — 0.01 0.01 — 0.01 — 133 133 0.01 < 0.005 — 133 Library 0.04 0.02 0.35 0.29 < 0.005 0.03 — 0.03 0.03 — 0.03 — 413 413 0.04 < 0.005 — 414 High
T
urnover
(Sit
Down
Restaurant)

0.06 0.03 0.51 0.43 < 0.005 0.04 — 0.04 0.04 — 0.04 — 609 609 0.05 < 0.005 — 611 Fast
F
ood
Restaurant
with
Drive
Thru

0.01 0.01 0.11 0.09 < 0.005 0.01 — 0.01 0.01 — 0.01 — 128 128 0.01 < 0.005 — 128 Regiona
l
Shoppin
g
Center

0.01 0.01 0.10 0.08 < 0.005 0.01 — 0.01 0.01 — 0.01 — 116 116 0.01 < 0.005 — 116 Superm
ar
ket

0.02 0.01 0.20 0.17 < 0.005 0.02 — 0.02 0.02 — 0.02 — 242 242 0.02 < 0.005 — 243 14556-Moreno Valley Towne Center (Unmitigated) Detailed Report, 12/13/2024 35 / 68

0.00—0.000.000.000.00—0.00—0.000.00—0.000.000.000.000.000.00Parking Lot
Other
Asphalt
Surf
aces

0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 — 0.00 0.00 0.00 0.00 — 0.00 Total 1.04 0.52 9.03 4.61 0.06 0.72 — 0.72 0.72 — 0.72 — 11,318 11,318 1.00 0.02 — 11,349 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Single
F
amily
Housing

0.84 0.42 7.18 3.06 0.05 0.58 — 0.58 0.58 — 0.58 — 9,118 9,118 0.81 0.02 — 9,144 City
P
ark

0.06 0.03 0.51 0.43 < 0.005 0.04 — 0.04 0.04 — 0.04 — 609 609 0.05 < 0.005 — 611 Fast
F
ood
Restaurant
with
Drive
Thru

0.01 0.01 0.11 0.09 < 0.005 0.01 — 0.01 0.01 — 0.01 — 128 128 0.01 < 0.005 — 128 Regiona
l
Shoppin
g
Center

0.01 0.01 0.10 0.08 < 0.005 0.01 — 0.01 0.01 — 0.01 — 116 116 0.01 < 0.005 — 116 Superm
ar
ket

0.02 0.01 0.20 0.17 < 0.005 0.02 — 0.02 0.02 — 0.02 — 242 242 0.02 < 0.005 — 243 14556-Moreno Valley Towne Center (Unmitigated) Detailed Report, 12/13/2024 36 / 68
Parking
Lot

0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 — 0.00 0.00 0.00 0.00 — 0.00 Other
Asphalt
Surf
aces

0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 — 0.00 0.00 0.00 0.00 — 0.00 Total 1.04 0.52 9.03 4.61 0.06 0.72 — 0.72 0.72 — 0.72 — 11,318 11,318 1.00 0.02 — 11,349 Annual — — — — — — — — — — — — — — — — — —
Single
F
amily
Housing

0.15 0.08 1.31 0.56 0.01 0.11 — 0.11 0.11 — 0.11 — 1,510 1,510 0.13 < 0.005 — 1,514 City
P
ark

0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 — 0.00 0.00 0.00 0.00 — 0.00 Hotel 0.01 < 0.005 0.09 0.07 < 0.005 0.01 — 0.01 0.01 — 0.01 — 92.6 92.6 0.01 < 0.005 — 92.9 General
Office
Building
< 0.005 < 0.005 0.02 0.02 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 22.0 22.0 < 0.005 < 0.005 — 22.0 Library 0.01 < 0.005 0.06 0.05 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 68.4 68.4 0.01 < 0.005 — 68.6 High
T
urnover
(Sit
Down
Restaurant)

0.01 0.01 0.09 0.08 < 0.005 0.01 — 0.01 0.01 — 0.01 — 101 101 0.01 < 0.005 — 101 Fast
F
ood
Restaurant
with
Drive
Thru
< 0.005 < 0.005 0.02 0.02 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 21.2 21.2 < 0.005 < 0.005 — 21.2 Regiona
l
Shoppin
g
Center
< 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 19.1 19.1 < 0.005 < 0.005 — 19.2 Superm
ar
ket
< 0.005 < 0.005 0.04 0.03 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 40.1 40.1 < 0.005 < 0.005 — 40.2 Parking
Lot

0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 — 0.00 0.00 0.00 0.00 — 0.00 14556-Moreno Valley Towne Center (Unmitigated) Detailed Report, 12/13/2024 37 / 68
Other
Asphalt
Surf
aces

0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 — 0.00 0.00 0.00 0.00 — 0.00 Total 0.19 0.10 1.65 0.84 0.01 0.13 — 0.13 0.13 — 0.13 — 1,874 1,874 0.17 < 0.005 — 1,879

4.3. Area Emissions by Source

4.3.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Source TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Hearths 1.55 0.78 13.3 5.65 0.08 1.07 — 1.07 1.07 — 1.07 0.00 16,845 16,845 0.32 0.03 — 16,862 Consum
er
Product
s

35.9 35.9 — — — — — — — — — — — — — — — —
Architect
ur
al
Coating
s

2.80 2.80 — — — — — — — — — — — — — — — —
Landsca
pe
Equipm
ent

5.95 5.59 0.51 55.4 < 0.005 0.04 — 0.04 0.03 — 0.03 — 162 162 0.01 < 0.005 — 163 Total 46.2 45.1 13.8 61.1 0.09 1.11 — 1.11 1.10 — 1.10 0.00 17,007 17,007 0.32 0.03 — 17,025 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Hearths 1.55 0.78 13.3 5.65 0.08 1.07 — 1.07 1.07 — 1.07 0.00 16,845 16,845 0.32 0.03 — 16,862 Consum
er
Product
s

35.9 35.9 — — — — — — — — — — — — — — — —
-------------------
14556-Moreno Valley Towne Center (Unmitigated) Detailed Report, 12/13/2024 38 / 68
Architect
Coatings

2.80 2.80 — — — — — — — — — — — — — — — —
Total 40.2 39.5 13.3 5.65 0.08 1.07 — 1.07 1.07 — 1.07 0.00 16,845 16,845 0.32 0.03 — 16,862 Annual — — — — — — — — — — — — — — — — — —
Hearths 0.02 0.01 0.17 0.07 < 0.005 0.01 — 0.01 0.01 — 0.01 0.00 191 191 < 0.005 < 0.005 — 191 Consum
er
Product
s

6.55 6.55 — — — — — — — — — — — — — — — —
Architect
ur
al
Coating
s

0.51 0.51 — — — — — — — — — — — — — — — —
Landsca
pe
Equipm
ent

0.74 0.70 0.06 6.93 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 18.4 18.4 < 0.005 < 0.005 — 18.5 Total 7.83 7.77 0.23 7.00 < 0.005 0.02 — 0.02 0.02 — 0.02 0.00 209 209 < 0.005 < 0.005 — 210

4.4. Water Emissions by Land Use

4.4.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Single
F
amily
Housing
— — — — — — — — — — — 62.4 1,472 1,534 6.50 0.16 — 1,746 City
P
ark
— — — — — — — — — — — 0.00 21.8 21.8 < 0.005 < 0.005 — 21.9 Hotel — — — — — — — — — — — 5.15 22.7 27.9 0.53 0.01 — 44.9 14556-Moreno Valley Towne Center (Unmitigated) Detailed Report, 12/13/2024 39 / 68
General
Office
Building
— — — — — — — — — — — 5.11 22.5 27.6 0.53 0.01 — 44.5
Library — — — — — — — — — — — 1.80 7.93 9.73 0.19 < 0.005 — 15.7 High
T
urnover
(Sit
Down
Restaurant)
— — — — — — — — — — — 9.69 42.7 52.4 1.00 0.02 — 84.5
Fast
F
ood
Restaurant
with
Drive
Thru
— — — — — — — — — — — 2.04 8.98 11.0 0.21 0.01 — 17.8
Regiona
l
Shoppin
g
Center
— — — — — — — — — — — 8.64 38.1 46.8 0.89 0.02 — 75.4
Superm
ar
ket
— — — — — — — — — — — 10.6 46.9 57.5 1.09 0.03 — 92.7
Parking
Lot
— — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00
Other
Asphalt
Surf
aces
— — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — — 105 1,683 1,789 10.9 0.27 — 2,143 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Single
F
amily
Housing
— — — — — — — — — — — 62.4 1,472 1,534 6.50 0.16 — 1,746 City
P
ark
— — — — — — — — — — — 0.00 21.8 21.8 < 0.005 < 0.005 — 21.9 Hotel — — — — — — — — — — — 5.15 22.7 27.9 0.53 0.01 — 44.9 14556-Moreno Valley Towne Center (Unmitigated) Detailed Report, 12/13/2024 40 / 68
General
Office
Building
— — — — — — — — — — — 5.11 22.5 27.6 0.53 0.01 — 44.5
Library — — — — — — — — — — — 1.80 7.93 9.73 0.19 < 0.005 — 15.7 High
T
urnover
(Sit
Down
Restaurant)
— — — — — — — — — — — 9.69 42.7 52.4 1.00 0.02 — 84.5
Fast
F
ood
Restaurant
with
Drive
Thru
— — — — — — — — — — — 2.04 8.98 11.0 0.21 0.01 — 17.8
Regiona
l
Shoppin
g
Center
— — — — — — — — — — — 8.64 38.1 46.8 0.89 0.02 — 75.4
Superm
ar
ket
— — — — — — — — — — — 10.6 46.9 57.5 1.09 0.03 — 92.7
Parking
Lot
— — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00
Other
Asphalt
Surf
aces
— — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — — 105 1,683 1,789 10.9 0.27 — 2,143 Annual — — — — — — — — — — — — — — — — — —
Single
F
amily
Housing
— — — — — — — — — — — 10.3 244 254 1.08 0.03 — 289
City
P
ark
— — — — — — — — — — — 0.00 3.62 3.62 < 0.005 < 0.005 — 3.63 Hotel — — — — — — — — — — — 0.85 3.76 4.62 0.09 < 0.005 — 7.44 14556-Moreno Valley Towne Center (Unmitigated) Detailed Report, 12/13/2024 41 / 68

7.38—< 0.0050.094.583.730.85———————————General
Office
Building
Library — — — — — — — — — — — 0.30 1.31 1.61 0.03 < 0.005 — 2.60 High
T
urnover
(Sit
Down
Restaurant)
— — — — — — — — — — — 1.60 7.08 8.68 0.17 < 0.005 — 14.0 Fast
F
ood
Restaurant
with
Drive
Thru
— — — — — — — — — — — 0.34 1.49 1.82 0.03 < 0.005 — 2.94 Regiona
l
Shoppin
g
Center
— — — — — — — — — — — 1.43 6.31 7.74 0.15 < 0.005 — 12.5 Superm
ar
ket
— — — — — — — — — — — 1.76 7.76 9.52 0.18 < 0.005 — 15.3 Parking
Lot
— — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00
Other
Asphalt
Surf
aces
— — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — — 17.5 279 296 1.81 0.04 — 355

4.5. Waste Emissions by Land Use

4.5.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e 14556-Moreno Valley Towne Center (Unmitigated) Detailed Report, 12/13/2024 42 / 68
——————————————————Daily,
Summer
(Max)
Single
F
amily
Housing
— — — — — — — — — — — 395 0.00 395 39.5 0.00 — 1,381
City
P
ark
— — — — — — — — — — — 0.22 0.00 0.22 0.02 0.00 — 0.78
Hotel — — — — — — — — — — — 31.3 0.00 31.3 3.13 0.00 — 109 General
Office
Building
— — — — — — — — — — — 7.52 0.00 7.52 0.75 0.00 — 26.3
Library — — — — — — — — — — — 14.9 0.00 14.9 1.49 0.00 — 52.1 High
T
urnover
(Sit
Down
Restaurant)
— — — — — — — — — — — 107 0.00 107 10.7 0.00 — 374
Fast
F
ood
Restaurant
with
Drive
Thru
— — — — — — — — — — — 21.7 0.00 21.7 2.17 0.00 — 76.0
Regiona
l
Shoppin
g
Center
— — — — — — — — — — — 34.5 0.00 34.5 3.44 0.00 — 121
Superm
ar
ket
— — — — — — — — — — — 137 0.00 137 13.7 0.00 — 479
Parking
Lot
— — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00
Other
Asphalt
Surf
aces
— — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — — 748 0.00 748 74.8 0.00 — 2,619 14556-Moreno Valley Towne Center (Unmitigated) Detailed Report, 12/13/2024 43 / 68
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Single
F
amily
Housing
— — — — — — — — — — — 395 0.00 395 39.5 0.00 — 1,381
City
P
ark
— — — — — — — — — — — 0.22 0.00 0.22 0.02 0.00 — 0.78
Hotel — — — — — — — — — — — 31.3 0.00 31.3 3.13 0.00 — 109 General
Office
Building
— — — — — — — — — — — 7.52 0.00 7.52 0.75 0.00 — 26.3
Library — — — — — — — — — — — 14.9 0.00 14.9 1.49 0.00 — 52.1 High
T
urnover
(Sit
Down
Restaurant)
— — — — — — — — — — — 107 0.00 107 10.7 0.00 — 374
Fast
F
ood
Restaurant
with
Drive
Thru
— — — — — — — — — — — 21.7 0.00 21.7 2.17 0.00 — 76.0
Regiona
l
Shoppin
g
Center
— — — — — — — — — — — 34.5 0.00 34.5 3.44 0.00 — 121
Superm
ar
ket
— — — — — — — — — — — 137 0.00 137 13.7 0.00 — 479
Parking
Lot
— — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00
Other
Asphalt
Surf
aces
— — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — — 748 0.00 748 74.8 0.00 — 2,619 14556-Moreno Valley Towne Center (Unmitigated) Detailed Report, 12/13/2024 44 / 68
Annual — — — — — — — — — — — — — — — — — —
Single
F
amily
Housing
— — — — — — — — — — — 65.4 0.00 65.4 6.53 0.00 — 229
City
P
ark
— — — — — — — — — — — 0.04 0.00 0.04 < 0.005 0.00 — 0.13 Hotel — — — — — — — — — — — 5.18 0.00 5.18 0.52 0.00 — 18.1 General
Office
Building
— — — — — — — — — — — 1.24 0.00 1.24 0.12 0.00 — 4.35
Library — — — — — — — — — — — 2.47 0.00 2.47 0.25 0.00 — 8.62 High
T
urnover
(Sit
Down
Restaurant)
— — — — — — — — — — — 17.7 0.00 17.7 1.77 0.00 — 61.9
Fast
F
ood
Restaurant
with
Drive
Thru
— — — — — — — — — — — 3.60 0.00 3.60 0.36 0.00 — 12.6
Regiona
l
Shoppin
g
Center
— — — — — — — — — — — 5.70 0.00 5.70 0.57 0.00 — 20.0
Superm
ar
ket
— — — — — — — — — — — 22.6 0.00 22.6 2.26 0.00 — 79.2
Parking
Lot
— — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00
Other
Asphalt
Surf
aces
— — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — — 124 0.00 124 12.4 0.00 — 434 14556-Moreno Valley Towne Center (Unmitigated) Detailed Report, 12/13/2024 45 / 68

4.6. Refrigerant Emissions by Land Use

4.6.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Single
F
amily
Housing
— — — — — — — — — — — — — — — — 9.22 9.22
City
P
ark
— — — — — — — — — — — — — — — — 0.00 0.00
Hotel — — — — — — — — — — — — — — — — 32.8 32.8
General
Office
Building
— — — — — — — — — — — — — — — — 0.02 0.02
Library — — — — — — — — — — — — — — — — 0.04 0.04
High
T
urnover
(Sit
Down
Restaurant)
— — — — — — — — — — — — — — — — 9.35 9.35
Fast
F
ood
Restaurant
with
Drive
Thru
— — — — — — — — — — — — — — — — 1.96 1.96
Regiona
l
Shoppin
g
Center
— — — — — — — — — — — — — — — — 0.23 0.23
14556-Moreno Valley Towne Center (Unmitigated) Detailed Report, 12/13/2024 46 / 68
357357————————————————Superm
arket
Total — — — — — — — — — — — — — — — — 410 410
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Single
F
amily
Housing
— — — — — — — — — — — — — — — — 9.22 9.22
City
P
ark
— — — — — — — — — — — — — — — — 0.00 0.00
Hotel — — — — — — — — — — — — — — — — 32.8 32.8
General
Office
Building
— — — — — — — — — — — — — — — — 0.02 0.02
Library — — — — — — — — — — — — — — — — 0.04 0.04
High
T
urnover
(Sit
Down
Restaurant)
— — — — — — — — — — — — — — — — 9.35 9.35
Fast
F
ood
Restaurant
with
Drive
Thru
— — — — — — — — — — — — — — — — 1.96 1.96
Regiona
l
Shoppin
g
Center
— — — — — — — — — — — — — — — — 0.23 0.23
Superm
ar
ket
— — — — — — — — — — — — — — — — 357 357
Total — — — — — — — — — — — — — — — — 410 410
Annual — — — — — — — — — — — — — — — — — —
14556-Moreno Valley Towne Center (Unmitigated) Detailed Report, 12/13/2024 47 / 68

1.531.53————————————————Single
Family
Housing
City
P
ark
— — — — — — — — — — — — — — — — 0.00 0.00
Hotel — — — — — — — — — — — — — — — — 5.43 5.43
General
Office
Building
— — — — — — — — — — — — — — — — < 0.005 < 0.005
Library — — — — — — — — — — — — — — — — 0.01 0.01
High
T
urnover
(Sit
Down
Restaurant)
— — — — — — — — — — — — — — — — 1.55 1.55
Fast
F
ood
Restaurant
with
Drive
Thru
— — — — — — — — — — — — — — — — 0.33 0.33
Regiona
l
Shoppin
g
Center
— — — — — — — — — — — — — — — — 0.04 0.04
Superm
ar
ket
— — — — — — — — — — — — — — — — 59.1 59.1
Total — — — — — — — — — — — — — — — — 68.0 68.0

4.7. Offroad Emissions By Equipment Type

4.7.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) 14556-Moreno Valley Towne Center (Unmitigated) Detailed Report, 12/13/2024 48 / 68
CO2eRN2OCH4CO2TNBCO2BCO2PM2.5TPM2.5DPM2.5EPM10TPM10DPM10ESO2CONOxROGTOGEquipm ent
Type
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.8. Stationary Emissions By Equipment Type

4.8.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipm
ent
T
ype
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
14556-Moreno Valley Towne Center (Unmitigated) Detailed Report, 12/13/2024 49 / 68

4.9. User Defined Emissions By Equipment Type

4.9.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipm
ent
T
ype
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.10. Soil Carbon Accumulation By Vegetation Type

4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Vegetati
on
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
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Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Species TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Sequest
ered
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Remove
d
— — — — — — — — — — — — — — — — — —
-------------------
14556-Moreno Valley Towne Center (Unmitigated) Detailed Report, 12/13/2024 51 / 68
Subtotal — — — — — — — — — — — — — — — — — —
— — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Sequest
ered
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Remove
d
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
— — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Sequest
ered
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Remove
d
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
— — — — — — — — — — — — — — — — — — —

5. Activity Data

5.1. Construction Schedule
Phase Name Phase Type Start Date End Date Days Per Week Work Days per Phase Phase Description Site Preparation Site Preparation 11/5/2025 11/26/2025 5.00 16.0 — 14556-Moreno Valley Towne Center (Unmitigated) Detailed Report, 12/13/2024 52 / 68
Grading Grading 11/26/2025 03/23/2026 5.00 84.0 —
Building Construction Building Construction 03/23/2026 11/6/2028 5.00 686 — Paving Paving 07/23/2026 11/6/2026 5.00 77.0 —
Architectural Coating Architectural Coating 08/23/2028 11/6/2028 5.00 54.0 —

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 Site Preparation Rubber Tired Dozers Diesel Average 3.00 8.00 367 0.40 Site Preparation Crawler Tractors Diesel Average 4.00 8.00 87.0 0.43 Grading Excavators Diesel Average 2.00 8.00 36.0 0.38
Grading Graders Diesel Average 1.00 8.00 148 0.41
Grading Rubber Tired Dozers Diesel Average 1.00 8.00 367 0.40 Grading Scrapers Diesel Average 2.00 8.00 423 0.48
Grading Crawler Tractors Diesel Average 2.00 8.00 87.0 0.43 Building Construction Cranes Diesel Average 2.00 8.00 367 0.29 Building Construction Forklifts Diesel Average 5.00 8.00 82.0 0.20 Building Construction Generator Sets Diesel Average 2.00 8.00 14.0 0.74 Building Construction Tractors/Loaders/Back
hoes
Diesel Average 5.00 8.00 84.0 0.37
Building Construction Welders Diesel Average 2.00 8.00 46.0 0.45 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 8.00 37.0 0.48

5.3. Construction Vehicles
14556-Moreno Valley Towne Center (Unmitigated) Detailed Report, 12/13/2024 53 / 68

5.3.1. Unmitigated
Phase Name Trip Type One-Way Trips per Day Miles per Trip Vehicle Mix Site Preparation — — — —
Site Preparation Worker 17.5 18.5 LDA,LDT1,LDT2
Site Preparation Vendor 3.00 10.2 HHDT,MHDT
Site Preparation Hauling 0.00 20.0 HHDT
Site Preparation Onsite truck — — HHDT
Grading — — — —
Grading Worker 20.0 18.5 LDA,LDT1,LDT2
Grading Vendor 13.0 10.2 HHDT,MHDT
Grading Hauling 0.00 20.0 HHDT
Grading Onsite truck — — HHDT
Building Construction — — — —
Building Construction Worker 372 18.5 LDA,LDT1,LDT2
Building Construction Vendor 107 10.2 HHDT,MHDT
Building Construction Hauling 0.00 20.0 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 20.0 HHDT
Paving Onsite truck — — HHDT
Architectural Coating — — — —
Architectural Coating Worker 74.5 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
14556-Moreno Valley Towne Center (Unmitigated) Detailed Report, 12/13/2024 54 / 68

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
Coated
(sq ft)
Residential Exterior Area
Coated
(sq ft)
Non-Residential Interior Area
Coated
(sq ft)
Non-Residential Exterior Area
Coated
(sq ft)
Parking Area Coated (sq ft)
Architectural Coating 2,916,000 972,000 344,189 114,730 34,081

5.6. Dust Mitigation

5.6.1. Construction Earthmoving Activities
Phase Name Material Imported (cy) Material Exported (cy) Acres Graded (acres) Material Demolished (sq. ft.) Acres Paved (acres) Site Preparation — — 320 0.00 —
Grading — — 1,680 0.00 —
Paving 0.00 0.00 0.00 0.00 21.9

5.6.2. Construction Earthmoving Control Strategies
Control Strategies Applied Frequency (per day) PM10 Reduction PM2.5 Reduction Water Exposed Area 3 74% 74%

5.7. Construction Paving
Land Use Area Paved (acres) % Asphalt
Single Family Housing 8.82 0%
City Park 0.00 0%
Hotel 0.00 0%
General Office Building 0.00 0%
14556-Moreno Valley Towne Center (Unmitigated) Detailed Report, 12/13/2024 55 / 68
Library 0.00 0%
High Turnover (Sit Down Restaurant) 0.00 0%
Fast Food Restaurant with Drive Thru 0.00 0%
Regional Shopping Center 0.00 0%
Supermarket 0.00 0%
Parking Lot 3.07 100%
Other Asphalt Surfaces 9.97 100%

5.8. Construction Electricity Consumption and Emissions Factors kWh per Y ear and Emission Factor (lb/MWh)
Y ear kWh per Y ear CO2 CH4 N2O
2025 0.00 453 0.03 < 0.005
2026 0.00 453 0.03 < 0.005
2027 0.00 453 0.03 < 0.005
2028 0.00 453 0.03 < 0.005

5.9. Operational Mobile Sources

5.9.1. Unmitigated
Land Use Type Trips/Weekday Trips/Saturday Trips/Sunday Trips/Y ear VMT/Weekday VMT/Saturday VMT/Sunday VMT/Y ear Single Family
Housing
7,544 7,584 6,784 2,716,017 49,727 49,990 44,717 17,902,768 City Park 4.00 9.41 10.5 2,082 53.0 125 139 27,578
Hotel 848 855 630 298,521 5,923 5,975 4,398 2,085,156
General Office
Building
192 33.1 10.5 52,333 2,544 439 139 693,376
Library 2,162 2,403 1,263 754,815 22,281 24,760 13,012 7,778,475 High Turnover (Sit
Do
wn Restaurant)
1,786 2,039 2,376 695,863 4,387 5,009 5,837 1,709,283
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Fast Food
Restaur
ant with
Drive Thru
1,636 2,156 1,654 625,218 6,107 8,050 6,175 2,334,026
Regional Shopping
Center
4,112 4,936 2,599 1,464,935 18,216 21,868 11,513 6,489,740 Supermarket 4,224 5,074 4,609 1,606,201 25,801 30,993 28,151 9,810,512 Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Other Asphalt
Surf
aces

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

5.10. Operational Area Sources

5.10.1. Hearths

5.10.1.1. Unmitigated
Hearth Type Unmitigated (number)
Single Family Housing —
Wood Fireplaces 0
Gas Fireplaces 800
Propane Fireplaces 0
Electric Fireplaces 0
No Fireplaces 0
Conventional Wood Stoves 0
Catalytic Wood Stoves 0
Non-Catalytic Wood Stoves 0
Pellet Wood Stoves 0

5.10.2. Architectural Coatings
Residential Interior Area Coated (sq
ft)
Residential Exterior Area Coated (sq
ft)
Non-Residential Interior Area Coated
(sq
ft)
Non-Residential Exterior Area
Coated
(sq ft)
Parking Area Coated (sq ft)
14556-Moreno Valley Towne Center (Unmitigated) Detailed Report, 12/13/2024 57 / 68
2916000 972,000 344,189 114,730 34,081

5.10.3. Landscape Equipment
Season Unit Value
Snow Days day/yr 0.00
Summer Days day/yr 250

5.11. Operational Energy Consumption

5.11.1. Unmitigated
Electricity (kWh/yr) and CO2 and CH4 and N2O and Natural Gas (kBTU/yr) Land Use Electricity (kWh/yr) CO2 CH4 N2O Natural Gas (kBTU/yr) Single Family Housing 7,471,395 453 0.0330 0.0040 28,451,451 City Park 0.00 453 0.0330 0.0040 0.00
Hotel 940,998 453 0.0330 0.0040 1,745,474
General Office Building 261,648 453 0.0330 0.0040 413,800 Library 287,072 453 0.0330 0.0040 1,288,510
High Turnover (Sit Down
Restaur
ant)
585,014 453 0.0330 0.0040 1,900,220
Fast Food Restaurant with
Dr
ive Thru
122,902 453 0.0330 0.0040 399,206
Regional Shopping Center 594,189 453 0.0330 0.0040 360,601 Supermarket 1,443,587 453 0.0330 0.0040 755,314
Parking Lot 117,147 453 0.0330 0.0040 0.00
Other Asphalt Surfaces 0.00 453 0.0330 0.0040 0.00

5.12. Operational Water and Wastewater Consumption

5.12.1. Unmitigated
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Land Use Indoor Water (gal/year) Outdoor Water (gal/year) Single Family Housing 32,539,020 181,588,668
City Park 0.00 3,315,245
Hotel 2,688,878 0.00
General Office Building 2,666,006 0.00
Library 938,667 0.00
High Turnover (Sit Down Restaurant) 5,056,872 0.00
Fast Food Restaurant with Drive Thru 1,062,368 0.00
Regional Shopping Center 4,510,276 0.00
Supermarket 5,547,070 0.00
Parking Lot 0.00 0.00
Other Asphalt Surfaces 0.00 0.00

5.13. Operational Waste Generation

5.13.1. Unmitigated
Land Use Waste (ton/year) Cogeneration (kWh/year)
Single Family Housing 732 —
City Park 0.41 —
Hotel 58.0 —
General Office Building 14.0 —
Library 27.6 —
High Turnover (Sit Down Restaurant) 198 —
Fast Food Restaurant with Drive Thru 40.3 —
Regional Shopping Center 63.9 —
Supermarket 254 —
Parking Lot 0.00 —
Other Asphalt Surfaces 0.00 —
14556-Moreno Valley Towne Center (Unmitigated) Detailed Report, 12/13/2024 59 / 68

5.14. Operational Refrigeration and Air Conditioning Equipment

5.14.1. Unmitigated
Land Use Type Equipment Type Refrigerant GWP Quantity (kg) Operations Leak Rate Service Leak Rate Times Serviced Single Family Housing Average room A/C &
Other
residential A/C
and heat pumps
User Defined 750 < 0.005 2.50 2.50 10.0
Single Family Housing Household
refr
igerators and/or
freezers
R-134a 1,430 0.12 0.60 0.00 1.00
City Park Other commercial A/C
and
heat pumps
User Defined 750 < 0.005 4.00 4.00 18.0
City Park Stand-alone retail
refr
igerators and
freezers
R-134a 1,430 0.04 1.00 0.00 1.00
Hotel Household
refr
igerators and/or
freezers
R-134a 1,430 0.00 0.60 0.00 1.00
Hotel Other commercial A/C
and
heat pumps
User Defined 750 1.80 4.00 4.00 18.0
Hotel Walk-in refrigerators
and
freezers
User Defined 150 < 0.005 7.50 7.50 20.0
General Office
Building
Household
refr
igerators and/or
freezers
R-134a 1,430 0.02 0.60 0.00 1.00
General Office
Building
Other commercial A/C
and
heat pumps
User Defined 750 < 0.005 4.00 4.00 18.0
Library Household
refr
igerators and/or
freezers
R-134a 1,430 0.02 0.60 0.00 1.00
Library Other commercial A/C
and
heat pumps
User Defined 750 < 0.005 4.00 4.00 18.0
Library Stand-alone retail
refr
igerators and
freezers
R-134a 1,430 < 0.005 1.00 0.00 1.00
14556-Moreno Valley Towne Center (Unmitigated) Detailed Report, 12/13/2024 60 / 68
Library Walk-in refrigerators
and
freezers
User Defined 150 < 0.005 7.50 7.50 20.0
High Turnover (Sit
Do
wn Restaurant)
Household
refr
igerators and/or
freezers
R-134a 1,430 0.00 0.60 0.00 1.00
High Turnover (Sit
Do
wn Restaurant)
Other commercial A/C
and
heat pumps
User Defined 750 1.80 4.00 4.00 18.0
High Turnover (Sit
Do
wn Restaurant)
Walk-in refrigerators
and
freezers
User Defined 150 < 0.005 7.50 7.50 20.0
Fast Food Restaurant
with
Drive Thru
Household
refr
igerators and/or
freezers
R-134a 1,430 0.00 0.60 0.00 1.00
Fast Food Restaurant
with
Drive Thru
Other commercial A/C
and
heat pumps
User Defined 750 1.80 4.00 4.00 18.0
Fast Food Restaurant
with
Drive Thru
Walk-in refrigerators
and
freezers
User Defined 150 < 0.005 7.50 7.50 20.0
Regional Shopping
Center
Other commercial A/C
and
heat pumps
User Defined 750 < 0.005 4.00 4.00 18.0
Regional Shopping
Center
Stand-alone retail
refr
igerators and
freezers
R-134a 1,430 0.04 1.00 0.00 1.00
Supermarket Other commercial A/C
and
heat pumps
User Defined 750 < 0.005 4.00 4.00 18.0
Supermarket Supermarket
refr
igeration and
condensing units
User Defined 150 26.5 16.5 16.5 18.0

5.15. Operational Off-Road Equipment

5.15.1. Unmitigated
Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor

5.16. Stationary Sources
14556-Moreno Valley Towne Center (Unmitigated) Detailed Report, 12/13/2024 61 / 68

5.16.1. Emergency Generators and Fire Pumps
Equipment Type Fuel Type Number per Day Hours per Day Hours per Y ear Horsepower Load Factor

5.16.2. Process Boilers
Equipment Type Fuel Type Number Boiler Rating (MMBtu/hr) Daily Heat Input (MMBtu/day) Annual Heat Input (MMBtu/yr)

5.17. User Defined
Equipment Type Fuel Type

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

5.18.1. Biomass Cover Type

5.18.1.1. Unmitigated
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) 14556-Moreno Valley Towne Center (Unmitigated) Detailed Report, 12/13/2024 62 / 68

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 28.0 annual days of extreme heat Extreme Precipitation 2.05 annual days with precipitation above 20 mm Sea Level Rise — meters of inundation depth
Wildfire 7.76 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 obser
ved historical data (32 climate model ensemble from Cal-Adapt, 2040–2059 average under RCP 8.5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.

Extreme Precipitation data are for the grid cell in which your project are located. The threshold of 20 mm is equivalent to about ¾ an inch of rain, which would be light to moderate rainfall if receiv
ed 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 3 0 0 N/A
Extreme Precipitation N/A N/A N/A N/A
Sea Level Rise 1 0 0 N/A
Wildfire 1 0 0 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 0 0 0 N/A
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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 g
reatest exposure.

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

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

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

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 99.1
14556-Moreno Valley Towne Center (Unmitigated) Detailed Report, 12/13/2024 64 / 68
AQ-PM 56.1
AQ-DPM 64.1
Drinking Water 10.2
Lead Risk Housing 19.2
Pesticides 62.3
Toxic Releases 54.3
Traffic 43.8
Effect Indicators —
CleanUp Sites 17.1
Groundwater 0.00
Haz Waste Facilities/Generators 40.9
Impaired Water Bodies 0.00
Solid Waste 0.00
Sensitive Population —
Asthma 72.0
Cardio-vascular 93.5
Low Birth Weights 68.4
Socioeconomic Factor Indicators —
Education 49.4
Housing 62.4
Linguistic 56.3
Poverty 60.6
Unemployment 58.4

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 —
14556-Moreno Valley Towne Center (Unmitigated) Detailed Report, 12/13/2024 65 / 68
Above Poverty 46.40061594
Employed 68.38188118
Median HI 54.09983318
Education —
Bachelor's or higher 45.52803798
High school enrollment 100
Preschool enrollment 16.32234056
Transportation —
Auto Access 70.20402926
Active commuting 11.88245862
Social —
2-parent households 45.51520595
Voting 16.7842936
Neighborhood —
Alcohol availability 82.6767612
Park access 53.93301681
Retail density 39.66380085
Supermarket access 38.16245348
Tree canopy 0.898242012
Housing —
Homeownership 49.23649429
Housing habitability 68.70268189
Low-inc homeowner severe housing cost burden 15.42409855 Low-inc renter severe housing cost burden 85.268831
Uncrowded housing 85.268831
Health Outcomes —
Insured adults 21.95560118
Arthritis 90.5
14556-Moreno Valley Towne Center (Unmitigated) Detailed Report, 12/13/2024 66 / 68
Asthma ER Admissions 30.2
High Blood Pressure 79.9
Cancer (excluding skin) 85.3
Asthma 49.0
Coronary Heart Disease 94.7
Chronic Obstructive Pulmonary Disease 86.1
Diagnosed Diabetes 80.8
Life Expectancy at Birth 17.2
Cognitively Disabled 33.5
Physically Disabled 52.4
Heart Attack ER Admissions 3.3
Mental Health Not Good 51.7
Chronic Kidney Disease 90.3
Obesity 37.0
Pedestrian Injuries 19.6
Physical Health Not Good 69.2
Stroke 88.3
Health Risk Behaviors —
Binge Drinking 20.5
Current Smoker 45.9
No Leisure Time for Physical Activity 52.7
Climate Change Exposures —
Wildfire Risk 18.6
SLR Inundation Area 0.0
Children 35.2
Elderly 94.0
English Speaking 77.1
Foreign-born 60.7
14556-Moreno Valley Towne Center (Unmitigated) Detailed Report, 12/13/2024 67 / 68
Outdoor Workers 46.4
Climate Change Adaptive Capacity —
Impervious Surface Cover 84.1
Traffic Density 36.6
Traffic Access 23.0
Other Indices —
Hardship 35.1
Other Decision Support —
2016 Voting 26.1

7.3. Overall Health & Equity Scores
Metric Result for Project Census Tract
CalEnviroScreen 4.0 Score for Project Location (a) 63.0 Healthy Places Index Score for Project Location (b) 42.0 Project Located in a Designated Disadvantaged Community (Senate Bill 535) No Project Located in a Low-Income Community (Assembly Bill 1550) No Project Located in a Community Air Protection Program Community (Assembly Bill 617) No a: The maximum CalEnviroScreen score is 100. A high score (i.e., greater than 50) reflects a higher pollution burden compared to other census tracts in the state. b: The maximum Health Places Index score is 100. A high score (i.e., greater than 50) reflects healthier community conditions compared to other census tracts in the state.

7.4. Health & Equity Measures
No Health & Equity Measures selected.

7.5. Evaluation Scorecard
Health & Equity Evaluation Scorecard not completed.

7.6. Health & Equity Custom Measures
No Health & Equity Custom Measures created.

8. User Changes to Default Data
14556-Moreno Valley Towne Center (Unmitigated) Detailed Report, 12/13/2024 68 / 68
Screen Justification
Land Use Land uses modeled consistent with information provided in Traffic and on Site Plan Construction: Construction Phases Taken from latest provided construction schedule Construction: Off-Road Equipment Construction equipment based on consultation with the Project Team Construction: Dust From Material Movement Analysis conservatively assumes that up to 20 acres can be disturbed per day As
such, the “Total Acres Graded” field in CalEEMod has been revised to 320 acres for site preparation (20 acres disturbed per day x 16 working days) and 1680 acres for grading activities (20 acres disturbed per day x 84 working days) Construction: Trips and VMT Vendor Trips adjusted based on CalEEMod defaults for Building Construction and number of da
ys for Site Preparation, Grading, and Building Construction Construction: Architectural Coatings SCAQMD Rule 1113
Operations: Vehicle Data Trip characteristics based on information provided in the Traffic analysis P
ass-by and internal capture was accounted for in the "Pass By Trip" category.

Operations: Hearths SCAQMD Rule 445
Characteristics: Project Details —
Operations: Architectural Coatings SCAQMD Rule 1113
Operations: Refrigerants As of 1 January 2022, new commercial refrigeration equipment may not use refrigerants with a GWP
of 150 or greater. Further, R-404A (the CalEEMod default) is unacceptable for new supermarket and cold storage systems as of 1 January 2019 and 2023, respectively.

Beginning 1 January 2025, all new air conditioning equipment may not use refrigerants with a GWP of 750 or greater.

14556-11 GHG Report

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Moreno Valley City CouncilJune 3, 2025

Moreno Valley City Council
June 3, 2025