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This completed form must be sent to:City of Palm Springs Office of the City Clerk3200 E. Tahquitz Canyon Way, Palm Springs, CA 92262 Appeal FormFormulario de Apelación City of Palm SpringsTEL (760) 323-8204FAX (760) 322-8332 Reserved for Filing Stamp
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February 24, 2025 Lozeau Drury LLP 1939 Harrison Street, Suite 150 Oakland, CA 94612 Attn: Mr. Mitchell E. ThielemannSubject: Comment Letter on Initial Study/Mitigated Negative Declaration (IS/MND) For Nexus Hotel and Residential Project, City of Palms Springs, CA.Dear Mr. Thielemann: At the request of Lozeau Drury LLP (Lozeau Drury), Clark and Associates (Clark) has reviewed materials related to the above referenced project. Clark’s review of the materials in no way constitutes a validation of the conclusions or materials contained within the City of Palm Springs(the City) Negative Declaration dated January 6, 2025. If we do not comment on a specific item, this does not constitute acceptance of the item.Project Description:The Nexus Hotel and Residential Project (Project) proposes to redevelop the site with a nine-story resort hotel and residential building consisting of 125 hotel rooms and 132 residential condo units which will be associated with the hotel and have access to hotel amenities and services; and a 6,040 square foot stand-alone restaurant. The hotel and condo units will operate on a 24 hour, 7 day a week basis. The hours of operation of the restaurant are not known, but are not expected to be 24 Clark & AssociatesEnvironmental Consulting, Inc.OFFICE12405 Venice BlvdSuite 331Los Angeles, CA [email protected]
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hours a day. The Project is estimated to result in a total of 320 employees.The hotel portion of the building will be seven-stories, and the residential portion will be nine-stories The Project includes onsite amenities catering to visitors and residents including an onsite parking structure and garage, indoor event space and an event lawn, indoor meeting space, three pools and a pool bar, a hotel ground floor restaurant and bar, a rooftop terrace and social club on the hotel’s 7th floor, and ground floor residents’ lounge and fitness center in the residential building. The hotel also includes a kitchen and “back of house” areas including offices, housekeeping and similar operation-related space. In total, the Project proposes 374,933 square feet (SF) of hotel and residential building space, 6,040 SF of standalone restaurant space, and 174,933 SF of parking garage space. The hotel portion proposes up to 125 rooms located in the west wing of the main building. Hotel rooms are located on the 2nd through 6th floors, and the 7th floor consists of a 3,525 SF social club and club terrace. The hotel also includes a 1,716 SF fitness center on the 2nd floor. The maximum height of the hotel portion of the Project, excluding the mechanical units, will be 85 feet 8 inches (seven stories). The residential portion proposes up to 132 residential condo units located in the east wing of the main building. On a 5.65-acre site, this represents a density of 24 DU/AC, consistent with the allowable density of 30 DU/AC for the TRC designation. Residential units are located on the 1st (ground level) through 9th floors. The maximum height of the residential portion is 99’ 8” (9 stories), 3 | P a g e
excluding the mechanical equipment. The standalone restaurant is single-story and located on the southwest quadrant of the site.
Figure 1: Conceptual Project PlanThe Project is proposed for a 5.65-acre site on the southeast corner of N. Calle El Segundo and E. Andreas Road within the City of Palm Springs in the Coachella Valley region of Riverside County,California. Alley ways border the site on its south and east sides. East Andreas Road forms the northboundary of the site, and North Calle El Segundo the west boundary. Existing development occurs onall sides, including the Renaissance Palm Springs hotel on the east, a multi-tenant commercialdevelopment on the south, the Hilton Palm Springs hotel on the west, and the Plaza Villas residentialproject on the north.The site is currently developed and utilized as a surface parking lot for the Palm Springs ConventionCenter. The lot is paved and stripped of natural vegetation apart from water-efficient landscaping that
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follows the parking lot boundary. Demolition and construction are estimated to require approximately 18 months in a single phase.
Figure 2: Project Location Map
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According to the IS/MND, the construction phase of the Project is assumed to last 18-months. The modeling assumes a net material export (dirt/soil) of 38,512 cubic yards per preliminary grading plan dated October 2023, which was prepared by a registered engineer and reflects the flat site and the construction of sub-surface structures. The dust management plan includes requirements for the control of dust during grading, including site watering, track-out devices and restrictions on grading activities during periods of high wind. Specific Comments1. The IS/MND Fails To Address The Significant Health Impacts From Valley Fever Spores Present In The Soils Of Riverside County.The IS/MND fails to adequately address the known presence and significant risk of Coccidiodes Immitis(Valley Fever fungus) in Southern California and in Riverside County in particular. Valley Fever is on the rise in Riverside County and in Palm Springs in particular.According to the CA Dept of Public Health, Valley Fever rates have increased 13% since 2022. Based on a study by UCR it is evident that Palm Springs is a hot spot for the County of Riverside.Figure 3: Rates of Valley Fever In Riverside County 2019-2023Palm Springs has some of the highest incidence of Valley Fever in Riverside County.Valley Fever is Dust exposure is a primary risk factor for contracting Valley Fever (via Coccidiodes imimitis (cocci)exposure). When soil containing the cocci spores are disturbed by construction activities, the fungal spores become airborne, exposing construction workers and other nearby sensitive receptors. The IS/MND assumes that meeting SCAQMD Rule 403 and 403.1 (Fugitive Dust Control) would be sufficient to control the impacts from Valley Fever exposure from the Project Site. According to the grading plan 38,512 cubic yardsof soil will be disturbed during
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the site grading. The disturbed soil onsite represents a significant pathway for VF spore exposure which will impact onsite and offsite works as well as the surrounding community.The fungus lives in the top 2 to 12 inches of soil. When soil containing this fungus is disturbed by activities such as digging, vehicles, construction activities, dust storms, or during earthquakes, the fungal spores become airborne. The most at-risk populations are construction and agricultural workers.1Here, construction workers are the very population that would be most directly exposed by the Project. A referenced journal article on occupational exposures notes that “[l]abor groups where occupation involves close contact with the soil are at greater risk, especially if the work involves dusty digging operations.”2The potentially exposed population in surrounding areas is much larger than construction workers because the nonselective raising of dust during Project construction will carry the very small spores, 0.002–0.005 millimeters (“mm”), into nonendemic areas, potentially exposing large non-Project-related populations.3,4 These very small particles are not controlled by conventional construction dust control mitigation measures. A study in Antelope Valley identified a clear link between soil disturbance - due to large-scale renewable energy construction projects, agricultural management practices and PM10fugitive dust emissions - and increased incidence of coccidioidomycosis.5 1Lawrence L. Schmelzer and R. Tabershaw, Exposure Factors in Occupational Coccidioidomycosis, American Journal of Public Health and the Nation’s Health, v. 58, no. 1, 1968, pp. 107–113, Table 3; available at http://www.ncbi.nlm.nih.gov/pmc/articles/PMC1228046/?page=1. 2Ibid., p. 110. 3Schmelzer and Tabershaw, 1968, p. 110; Pappagianis and Einstein, 1978 4Pappagianis and Einstein, 1978, p. 527 (“The northern areas were not directly affected by the ground level windstorm that had struck Kern County but the dust was lifted to several thousand feet elevation and, borne on high currents, the soil and arthrospores along with some moisture were gently deposited on sidewalks and automobiles as ‘a mud storm’ that vexed the residents of much of California.” The storm originating in Kern County, for example, had major impacts in the San Francisco Bay Area and Sacramento). 5 Colson. 2017. Large-Scale Land Development, Fugitive Dust, and Increased Coccidioidomycosis Incidence in the Antelope Valley of California, 1999-2014. https://knowthecause.com/wp-content/uploads/2017/03/Colson2017FugitiveDustCoccidiodes.pdf 7 | P a g e
Figure 4: Valley Fever Incidence And Soil DisturbanceIt is evident from the figure above that, as the number of acres of soil in the Antelope Valley were disturbed, the incidence rate of Valley Fever also increased. The mass disturbance of soils anticipated by the proposed Project will create the same conditions that were detailed in the study by Colson.6The Project site’s desert location and exposure to desert winds amplify these risks. Even when standard dust control measures are in place, high winds can mobilize substantial amounts of dust from graded areas generating PM10 and PM2.5 emissions that carry Valley Fever spores and silica dust into surrounding communities. Alerts from air pollution control districts frequently accompany such wind events, underlining the inadequacy of typical dust suppression methods in preventing airborne spore exposure. According to research on Valley Fever, outbreaks in populations with intense exposure to aerosolized arthroconidia are at greater risk for infection. These groups include agricultural or construction workers, or persons who participate in outdoor activities such as hunting or digging in the soil. Outbreaks of coccidioidomycosis have been linked to a variety of activities involving 6ibid
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disturbance of impacted soils.7,8,9 Since Valley Fever cases are directly related to the disturbance of soils in the area, the City must directly address the impacts that the project’s construction phase will have on the community. Valley Fever often manifests as a mild respiratory illness, but it can progress to serious chronic forms, especially in immunocompromised individuals, and may even become disseminated, impacting organs including the skin, bones, brain, and spinal cord. Disseminated Valley Fever is associated with severe symptoms like meningitis, painful lesions, and swollen joints. Given the significant public health risks associated with airborne Valley Fever spores, the City must prepare an environmental impact report (EIR) to accurately disclose the Project’s impacts on local air quality and public health, especially for nearby and downwind receptors. The EIR should include effective mitigation measures specifically tailored to Valley Fever, as standard dust controls are inadequate for managing the risks posed by this pathogen. Ensuring robust protections for both on-site workers and off-site receptors is essential to prevent potentially severe health consequences for the surrounding community. 2. The Proposed Dust Control Measures In The IS/MND Fail To Effectively MitigateSignificant Valley Fever Exposure Risks. The standard fugitive dust mitigation measures proposed in the IS/MND are not adequate to protect construction workers and nearby sensitive receptors from exposure to Valley Fever spores. Rule 403 includes requirements for a Dust Control Plan, signage and fencing requirements, as well as surface watering and stabilization with chemicals, gravel and asphaltic pavement to eliminate visible fugitive dust from vehicular travel and wind erosion. All of the mitigation measures outlined 7 Brown. Et al. 2013. Coccidioidomycosis: epidemiology. Clinical Epidemiology. 5:185-197. 8 Rafael Laniado-Laborin, Expanding Understanding of Epidemiology of Coccidioidomycosis in the Western Hemisphere, Annals of the New York Academy of Sciences, v. 111, 2007, pp. 20–22, available at https://nyaspubs.onlinelibrary.wiley.com/doi/abs/10.1196/annals.1406.004; Frederick S. Fisher, Mark W. Bultman, Suzanne M. Johnson, Demosthenes Pappagianis, and Erik Zaborsky, Coccidioides Niches and Habitat Parameters in the Southwestern United States, a Matter of Scale, Annals of the New York Academy of Sciences, v. 111, 2007, pp. 47–72 (“All of the examined soil locations are noteworthy as generally 50% of the individuals who were exposed to the dust or were excavating dirt at the sites were infected.”), available at https://nyaspubs.onlinelibrary.wiley.com/doi/abs/10.1196/annals.1406.031. 9 Lawrence L. Schmelzer and R. Tabershaw, Exposure Factors in Occupational Coccidioidomycosis, American Journal of Public Health and the Nation’s Health, v. 58, no. 1, 1968, pp. 107–113, Table 3; available at http://www.ncbi.nlm.nih.gov/pmc/articles/PMC1228046/?page=1. 9 | P a g e
above allow for a percentage of the dust that could be generated to be migrate offsite. Based on the Mitigation Measures outlined in the CalEEMOD model (utilized in the IS/MND) watering exposed areas twice a day would reduce PM10and PM2.5 emissions by 61 percent (61%). Increasing the watering frequency to 3 times per day would reduce PM10and PM2.5emissions by 74%. Conventional dust control measures primarily focus on visible dust or larger dust particles—the PM10fraction—and fail to address the very fine particles that transport Valley Fever spores, which are approximately 5 times smaller than typical PM10 particles and remain airborne much longer.10These fine particles, when disturbed by soil-disturbing activities, spread widely beyond site, posing a significant risk to both onsite workers and nearby communities. The proposed compliance with SCAQMD Rule 403, which relies on a visual opacity readings for dust control, is insufficient to prevent exposure to Valley Fever spores. This rule is based on smoke-monitoring methods (U.S. EPA Methods 9 and 22) that require active monitoring by certified observers, rely on subjective observation, and are affected by variable such as lighting, distance, and weather conditions. Due to these limitations, opacity readings do not provide accurate, continuous data on fine airborne particles. To address these shortcomings, the City should require active monitoring with dust monitors (particle measuring devices) immediately outside of the facility and around its perimeter. Continuous particle measures would offer several advantages. It eliminates the subjectivity inherent in visual opacity readings, leading to more reliable and consistent data. It allows for real-time tracking of dust particle levels, enabling prompt corrective actions if thresholds are exceeded. And it offers robust data sets that can be used for repeatability test and to validate compliance with air quality standards.Incorporating active dust monitoring systems would ensure that air quality impacts are accurately assessed and mitigated, fulfilling the intent of the mitigation measures and conditions of compliance to protect public health and the environment. Additionally, sampling for and removal of impacted soils is the best solution to Coccidiodes immitis spores. Since Coccidiodes immitis resides in soils and are not subject to degradation, entrainment of the potentially impacted soils may cause additional issues to further development of the site. 10See, e.g., Cummings and others, 2010, p. 509; Schneider et al., 1997, p. 908 (“Primary prevention strategies (e.g., dust-control measures) for coccidioidomycosis in endemic areas have limited effectiveness.”). 10 | P a g e
The City should require that the Proponent implement mitigation measures to actively suppress the spread of Valley Fever by: 1. Include specific requirements in the Project’s Injury and Illness Prevention Program (as required by Title 8, Section 3203) regarding safeguards to prevent Valley Fever.2. Control dust exposure:- Apply chemical stabilizers at least 24-hours prior to high wind event; - Apply water to all disturbed areas a minimum of three times per day. Watering frequency should be increased to a minimum of four times per day if there is any evidence of visible wind-driven fugitive dust; - Provide National Institute for Occupational Safety and Health (NIOSH)-approved respirators for workers with a prior history of Valley Fever. - Half-face respirators equipped with a minimum N-95 protection factor for use during worker collocation with surface disturbance activities. Half-face respirators equipped with N-100 or P-100 filters should be used during digging activities. Employees should wear respirators when working near earth-moving machinery. - Prohibit eating and smoking at the worksite, and provide separate, clean eating areas with hand-washing facilities. - Avoid outdoor construction operations during unusually windy conditions or in dust storms. - Consider limiting outdoor construction during the fall to essential jobs only, as the risk of cocci infection is higher during this season. 3. Prevent transport of cocci outside endemic areas: - Thoroughly clean equipment, vehicles, and other items before they are moved off-site to other work locations.-Prevent spillage or loss of bulk material from holes or other openings in the cargo compartment’s floor, sides, and/or tailgate; -Load all haul trucks such that the freeboard is not less than six inches when material is transported on any paved public access road and apply water to the top of the load sufficient to limit VDE to 20 percent opacity; or cover haul trucks with a tarp or other suitable cover. 11 | P a g e
-Provide workers with coveralls daily, lockers (or other systems for keeping work and street clothing and shoes separate), daily changing and showering facilities. - Clothing should be changed after work every day, preferably at the work site. - Train workers to recognize that cocci may be transported offsite on contaminated equipment, clothing, and shoes; alternatively, consider installing boot-washing.- Post warnings onsite and consider limiting access to visitors, especially those without adequate training and respiratory protection. 4. Improve medical surveillance for employees:- Employees should have prompt access to medical care, including suspected work-related illnesses and injuries.- Work with a medical professional to develop a protocol to medically evaluate employees who have symptoms of Valley Fever.- Consider preferentially contracting with 1-2 clinics in the area and communicate with the health care providers in those clinics to ensure that providers are aware that Valley Fever has been reported in the area. This will increase the likelihood that ill workers will receive prompt, proper and consistent medical care. - Respirator clearance should include medical evaluation for all new employees, annual re-evaluation for changes in medical status, and annual training, and fit-testing.- Skin testing is not recommended for evaluation of Valley Fever.11 - If an employee is diagnosed with Valley Fever, a physician must determine if the employee should be taken off work, when they may return to work, and what type of work activities they may perform. The City must adopt these evidence-based mitigation measures – proven effective in similar construction projects in endemic areas – in a EIR to ensure comprehensive protection of public health. Standard dust control measures are insufficient for preventing Valley Fever exposure, and only concrete, enforceable steps like those listed above will safeguard both onsite workers and surrounding communities. 11Short-term skin tests that produce results within 48 hours are now available. See Kerry Klein, NPR for Central California, New Valley Fever Skin Test Shows Promise, But Obstacles Remain, November 21, 2016; available at http://kvpr.org/post/new-valley-fever-skin-test-shows-promise-obstacles-remain. 12 | P a g e
3. The Air Quality Analysis Incorrectly States That The Construction Phase Does Not Exceed The Local Significance Thresholds (LSTs).The IS/MND states,12“The nearest sensitive receptor is Plaza Villa, located 86.94± feet across E. Andreas Road to the north. The analysis shows that both construction and operational emissions will not exceed localized significance thresholds. Therefore, sensitive receptors in proximity to the project site, including residents at Plaza Villa, will not be adversely affected by air emissions during either phase. No further mitigation measures are required”“Based on the Project’s proximity to existing housing, the 5-acre site tables at a distance of 25 meters (nearest measurement option in LST table) were used for LST analysis. Table 4 shows on-site emission concentrations for Project construction and operation will not exceed LST thresholds. Overall, the impacts will be less than significant.”13Figure 5: LST AnalysisYet, in Table 4 of the IS/MND the City’s LST analysis shows that there are exceedances of the LST for both PM10and PM2.5. Clearly, the construction phase will result in emissions of particulate matter above the site specific LSTs. The City must correct this flaw in an EIR and in addition, prepare a site 12City of Palm Springs. 2025. INITIAL STUDY/MITIGATED NEGATIVE DECLARATION Nexus Hotel and Residential Project. Dated January 6, 2025. Pg 3913ibid. Pg 39
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specific health risk analysis to ensure the safety of sensitive receptors identified by the City in the IS/MND. 4. The City’s Air Quality Analysis Fails To Include A Quantitative Health Risk Analysis Of The Impacts Of Toxic Air Contaminants From The Construction Phase And Operational Phase Of The Project For The Nearest Sensitive Receptor(s)The determination of a significance threshold for construction activities and operational activities is based on a quantitative risk analysisthat requires the City to perform a multistep, quantitative health risk analysis for toxic air contaminants (TACs) from the construction and operational phases of the Project. No effort is made in the IS/MND to quantify the potential health impacts from TACs generated by construction activities or operational activities from the Project on these sensitive receptors. Given that the closest receptor to the Project site is the residence located less than 25 meters from the edge of the Project Site, it is clear that there is sufficient evidence to warrant a quantitative analysis of the potential health risks to the residents. In addition to TACs from diesel exhaust (assumed to be diesel particulate matter or DPM), the California Air Resources Board’s (CARB’s) analysis of tailpipe emissions shows that in addition to simple alkane hydrocarbons, the emissions also contain benzene (human carcinogen), 1,3-butadiene (human carcinogen), ethylbenzene (human carcinogen), toluene (neurotoxin), acetaldehyde (respiratory irritant), and formaldehyde (human carcinogen), and other air toxins. These air toxins make up approximately 22% of the total organic gases (TOGs) emitted from vehicles. CARB TOG Speciation Profile Run Exhaust14CAS# Chemical NameFraction 75070 Acetaldehyde 0.0028 107028 Acrolein0.0013 71432 Benzene 0.0247 106990 1,3-Butadiene 0.0055 100414 Ethylbenzene0.0105 50000 Formaldehyde0.0158 110543 Hexane0.0160 67561 Methanol0.0012 14https://ww2.arb.ca.gov/speciation-profiles-used-carb-modeling 14 | P a g e
CARBTOG Speciation ProfileRun Exhaust14CAS# Chemical NameFraction 78933 Methyl Ethyl Ketone0.000291203 Naphthalene0.0005115071 Propylene0.0306100425 Styrene0.0012 108883 Toluene 0.0576 1330207 Xylenes 0.0480Clearly the majority of emissions of these compounds from the surrounding sites to the Project site will be associated with passenger vehicles, resulting in significant exposure to benzene (human carcinogen), 1,3-butadiene (human carcinogen), ethylbenzene (human carcinogen), toluene (neurotoxin), acetaldehyde (respiratory irritant), and formaldehyde (human carcinogen), and other air toxins.The City therefore lacks supporting evidence for its conclusion that the emissions from the Project would not result in significant health effects by virtue of the distance to the receptors. The City’s failure to perform such an analysis is clearly a major flaw in the IS/MND and may be placing the residents of the nearby homes at risk from the construction phase and operational phase of the Project. The inherent toxicity of TACs requires the City to first quantify the concentration of each TAC released into the environment at each of the sensitive receptor locations through air dispersion modeling, calculate the dose of each TAC at that location, and quantify the cancer risk and hazard index for each of the chemicals of concern. Following that analysis, then the City can make a determination of the relative significance of the emissions. The results should then be presented in an EIR prior to approving any agreements with the Proponent or issuing any permits for the Project.5. The Air Quality Analysis Fails To Include DPM Emissions From The Fire Pumps And Or Back-Up Generators That Will Be Installed Onsite.The Air Quality Analysis in the IS/MND fails to include the fire pumps that will be required for the Project as well as the back-up generator (BUG) that will need to be included for the Project. A review of the South Coast Air Quality Management District’s (SCAQMD’s) FIND website shows that the Hilton Palm Springs, immediately west of the Project Site, and of a similar size to the Project has 15 | P a g e
an active permit from SCAQMD for a BUG. Fire pumps are powered generally by diesel powered BUGs. BUGs are allowed to operate up to 200 hours per year for testing and maintenance. The operation of a 500 horsepower (hp) backup generator operated for an hour will add up to 0.12 pounds of DPM per day. A 150 hp fire pump operating for one hour will add 0.04 lbs of DPM per day. Since the BUGs are not included in the overall estimate of DPM the AQ analysis along with the health risk analysis does not include all of the relevant sources for the site. The City must update the air quality analysis to include the use of BUGs and fire pumps in an EIR for the Project. Conclusion The facts identified and referenced in this comment letter lead me to reasonably conclude that the Project could result in significant impacts if allowed to proceed. An EIR should be prepared to address these substantial concerns related to the construction and operational emissions from the Project that clearly were not identified in the IS/MND.Sincerely,
James J. J. Clark, Ph.D. Principal Toxicologist Toxicology/Exposure Assessment ModelingRisk Assessment/Analysis/Dispersion ModelingEducation:Ph.D., Environmental Health Science, University of California, 1995 M.S., Environmental Health Science, University of California, 1993 B.S., Biophysical and Biochemical Sciences, University of Houston, 1987 Professional Experience:Dr. Clark is a well recognized toxicologist, air modeler, and health scientist. He has 20 years of experience in researching the effects of environmental contaminants on human health including environmental fate and transport modeling (SCREEN3, AEROMOD, ISCST3, Johnson-Ettinger Vapor Intrusion Modeling); exposure assessment modeling (partitioning of contaminants in the environment as well as PBPK modeling); conducting and managing human health risk assessments for regulatory compliance and risk-based clean-up levels; and toxicological and medical literature research. Significant projects performed by Dr. Clark include the following: LITIGATION SUPPORT Case: James Harold Caygle, et al, v. Drummond Company, Inc. Circuit Court for the Tenth Judicial Circuit, Jefferson County, Alabama. Civil Action. CV-2009 Client: Environmental Litgation Group, Birmingham, Alabama Dr. Clark performed an air quality assessment of emissions from a coke factory located in Tarrant, Alabama. The assessment reviewed include a comprehensive review of air quality standards, measured concentrations of pollutants from factory, an inspection of the facility and detailed assessment of the impacts on the community. The results of the assessment and literature have been provided in a declaration to the court.
Clark & Associates Environmental Consulting, Inc
OFFICE 12405 Venice Blvd. Suite 331 Los Angeles, CA 90066 PHONE 310-907-6165FAX [email protected] Case Result: Settlement in favor of plaintiff. Case: Rose Roper V. Nissan North America, et al. Superior Court of the State Of California for the County Of Los Angeles – Central Civil West. Civil Action. NC041739 Client: Rose, Klein, Marias, LLP, Long Beach, California Dr. Clark performed a toxicological assessment of an individual occupationally exposed to multiple chemicals, including benzene, who later developed a respiratory distress. A review of the individual’s medical and occupational history was performed to prepare an exposure assessment. The exposure assessment was evaluated against the known outcomes in published literature to exposure to respiratory irritants. The results of the assessment and literature have been provided in a declaration to the court. Case Result: Settlement in favor of plaintiff. Case: O’Neil V. Sherwin Williams, et al. United States District Court Central District of California Client: Rose, Klein, Marias, LLP, Long Beach, California Dr. Clark performed a toxicological assessment of an individual occupationally exposed to petroleum distillates who later developed a bladder cancer. A review of the individual’s medical and occupational history was performed to prepare a quantitative exposure assessment. The results of the assessment and literature have been provided in a declaration to the court. Case Result: Summary judgment for defendants. Case: Moore V., Shell Oil Company, et al. Superior Court of the State Of California for the County Of Los Angeles Client: Rose, Klein, Marias, LLP, Long Beach, California Dr. Clark performed a toxicological assessment of an individual occupationally exposed to chemicals while benzene who later developed a leukogenic disease. A review of the individual’s medical and occupational history was performed to prepare a quantitative exposure assessment. The exposure assessment was evaluated against the known outcomes in published literature to exposure to refined petroleum hydrocarbons. The results of the assessment and literature have been provided in a declaration to the court.
Case Result: Settlement in favor of plaintiff. Case: Raymond Saltonstall V. Fuller O’Brien, KILZ, and Zinsser, et al. United States District Court Central District of California Client: Rose, Klein, Marias, LLP, Long Beach, California Dr. Clark performed a toxicological assessment of an individual occupationally exposed to benzene who later developed a leukogenic disease. A review of the individual’s medical and occupational history was performed to prepare a quantitative exposure assessment. The exposure assessment was evaluated against the known outcomes in published literature to exposure to refined petroleum hydrocarbons. The results of the assessment and literature have been provided in a declaration to the court. Case Result: Settlement in favor of plaintiff. Case: Richard Boyer and Elizabeth Boyer, husband and wife, V. DESCO Corporation, et al. Circuit Court of Brooke County, West Virginia. Civil Action Number 04-C-7G. Client: Frankovitch, Anetakis, Colantonio & Simon, Morgantown, West Virginia. Dr. Clark performed a toxicological assessment of a family exposed to chlorinated solvents released from the defendant’s facility into local drinking water supplies. A review of the individual’s medical and occupational history was performed to prepare a qualitative exposure assessment. The exposure assessment was evaluated against the known outcomes in published literature to exposure to chlorinated solvents. The results of the assessment and literature have been provided in a declaration to the court. Case Result: Settlement in favor of plaintiff.
Case: JoAnne R. Cook, V. DESCO Corporation, et al. Circuit Court of Brooke County, West Virginia. Civil Action Number 04-C-9R Client: Frankovitch, Anetakis, Colantonio & Simon, Morgantown, West Virginia. Dr. Clark performed a toxicological assessment of an individual exposed to chlorinated solvents released from the defendant’s facility into local drinking water supplies. A review of the individual’s medical and occupational history was performed to prepare a qualitative exposure assessment. The exposure assessment was evaluated against the known outcomes in published literature to exposure to chlorinated solvents. The results of the assessment and literature have been provided in a declaration to the court. Case Result: Settlement in favor of plaintiff. Case: Patrick Allen And Susan Allen, husband and wife, and Andrew Allen, a minor, V. DESCO Corporation, et al. Circuit Court of Brooke County, West Virginia. Civil Action Number 04-C-W Client: Frankovitch, Anetakis, Colantonio & Simon, Morgantown, West Virginia. Dr. Clark performed a toxicological assessment of a family exposed to chlorinated solvents released from the defendant’s facility into local drinking water supplies. A review of the individual’s medical and occupational history was performed to prepare a qualitative exposure assessment. The exposure assessment was evaluated against the known outcomes in published literature to exposure to chlorinated solvents. The results of the assessment and literature have been provided in a declaration to the court. Case Result: Settlement in favor of plaintiff. Case: Michael Fahey, Susan Fahey V. Atlantic Richfield Company, et al. United States District Court Central District of California Civil Action Number CV-06 7109 JCL.
Client: Rose, Klein, Marias, LLP, Long Beach, California Dr. Clark performed a toxicological assessment of an individual occupationally exposed to refined petroleum hydrocarbons who later developed a leukogenic disease. A review of the individual’s medical and occupational history was performed to prepare a qualitative exposure assessment. The exposure assessment was evaluated against the known outcomes in published literature to exposure to refined petroleum hydrocarbons. The results of the assessment and literature have been provided in a declaration to the court.Case Result: Settlement in favor of plaintiff. Case: Constance Acevedo, et al., V. California Spray-Chemical Company, et al., Superior Court of the State Of California, County Of Santa Cruz. Case No. CV 146344 Dr. Clark performed a comprehensive exposure assessment of community members exposed to toxic metals from a former lead arsenate manufacturing facility. The former manufacturing site had undergone a DTSC mandated removal action/remediation for the presence of the toxic metals at the site. Opinions were presented regarding the elevated levels of arsenic and lead (in attic dust and soils) found throughout the community and the potential for harm to the plaintiffs in question. Case Result: Settlement in favor of defendant. Case: Michael Nawrocki V. The Coastal Corporation, Kurk Fuel Company, Pautler Oil Service, State of New York Supreme Court, County of Erie, Index Number I2001-11247 Client: Richard G. Berger Attorney At Law, Buffalo, New York Dr. Clark performed a toxicological assessment of an individual occupationally exposed to refined petroleum hydrocarbons who later developed a leukogenic disease. A review of the individual’s medical and occupational history was performed to prepare a qualitative exposure assessment. The exposure assessment was evaluated against the known outcomes in published literature to exposure to refined petroleum hydrocarbons. The results of the assessment and literature have been provided in a declaration to the court.Case Result: Judgement in favor of defendant. SELECTED AIR MODELING RESEARCH/PROJECTS Client – Confidential Dr. Clark performed a comprehensive evaluation of criteria pollutants, air toxins, and particulate matter emissions from a carbon black production facility to determine the impacts on the surrounding communities. The results of the dispersion model will be used to estimate acute and chronic exposure concentrations to multiple contaminants and will be incorporated into a comprehensive risk evaluation. Client – Confidential Dr. Clark performed a comprehensive evaluation of air toxins and particulate matter emissions from a railroad tie manufacturing facility to determine the impacts on the surrounding communities. The results of the dispersion model have been used to estimate acute and chronic exposure concentrations to multiple contaminants and have been incorporated into a comprehensive risk evaluation. Client – Los Angeles Alliance for a New Economy (LAANE), Los Angeles, California Dr. Clark is advising the LAANE on air quality issues related to current flight operations at the Los Angeles International Airport (LAX) operated by the Los Angeles World Airport (LAWA) Authority. He is working with the LAANE and LAX staff to develop a comprehensive strategy for meeting local community concerns over emissions from flight operations and to engage federal agencies on the issue of local impacts of community airports.
Client – City of Santa Monica, Santa Monica, California Dr. Clark is advising the City of Santa Monica on air quality issues related to current flight operations at the facility. He is working with the City staff to develop a comprehensive strategy for meeting local community concerns over emissions from flight operations and to engage federal agencies on the issue of local impacts of community airports.Client: Omnitrans, San Bernardino, California Dr. Clark managed a public health survey of three communities near transit fueling facilities in San Bernardino and Montclair California in compliance with California Senate Bill 1927. The survey included an epidemiological survey of the effected communities, emission surveys of local businesses, dispersion modeling to determine potential emission concentrations within the communities, and a comprehensive risk assessment of each community. The results of the study were presented to the Governor as mandated by Senate Bill 1927. Client: Confidential, San Francisco, California Summarized cancer types associated with exposure to metals and smoking. Researched the specific types of cancers associated with exposure to metals and smoking. Provided causation analysis of the association between cancer types and exposure for use by non-public health professionals. Client: Confidential, Minneapolis, Minnesota Prepared human health risk assessment of workers exposed to VOCs from neighboring petroleum storage/transport facility. Reviewed the systems in place for distribution of petroleum hydrocarbons to identify chemicals of concern (COCs), prepared comprehensive toxicological summaries of COCs, and quantified potential risks from carcinogens and non-carcinogens to receptors at or adjacent to site. This evaluation was used in the support of litigation. Client – United Kingdom Environmental Agency Dr. Clark is part of team that performed comprehensive evaluation of soil vapor intrusion of VOCs from former landfill adjacent residences for the United Kingdom’s Environment Agency. The evaluation included collection of liquid and soil vapor samples at site, modeling of vapor migration using the Johnson Ettinger Vapor Intrusion model, and calculation of site-specific health based vapor thresholds for chlorinated solvents, aromatic hydrocarbons, and semi-volatile organic compounds. The evaluation also included a detailed evaluation of the use, chemical characteristics, fate and transport, and toxicology of chemicals of concern (COC). The results of the evaluation have been used as a briefing tool for public health professionals. EMERGING/PERSISTENT CONTAMINANT RESEARCH/PROJECTS Client: Ameren Services, St. Louis, Missouri Managed the preparation of a comprehensive human health risk assessment of workers and residents at or near an NPL site in Missouri. The former operations at the Property included the servicing and repair of electrical transformers, which resulted in soils and groundwater beneath the Property and adjacent land becoming impacted with PCB and chlorinated solvent compounds. The results were submitted to U.S. EPA for evaluation and will be used in the final ROD. Client: City of Santa Clarita, Santa Clarita, California Dr. Clark is managing the oversight of the characterization, remediation and development activities of a former 1,000 acre munitions manufacturing facility for the City of Santa Clarita. The site is impacted with a number of contaminants including perchlorate, unexploded ordinance, and volatile organic compounds (VOCs). The site is currently under a number of regulatory consent orders, including an Immanent and Substantial Endangerment Order. Dr. Clark is assisting the impacted municipality with the development of remediation strategies, interaction with the responsible parties and stakeholders, as well as interfacing with the regulatory agency responsible for oversight of the site cleanup. Client: Confidential, Los Angeles, California Prepared comprehensive evaluation of perchlorate in environment. Dr. Clark evaluated the production, use, chemical characteristics, fate and transport, toxicology, and remediation of perchlorate. Perchlorates form the basis of solid rocket fuels and have recently been detected in water supplies in the United States. The results of this research were presented to the USEPA, National GroundWater, and ultimately published in a recent book entitled Perchlorate in the Environment.Client – Confidential, Los Angeles, California Dr. Clark is performing a comprehensive review of the potential for pharmaceuticals and their by-products to impact groundwater and surface water supplies. This evaluation will include a review if available data on the history of pharmaceutical production in the United States; the chemical characteristics of various pharmaceuticals; environmental fate and transport; uptake by xenobiotics; the potential effects of pharmaceuticals on water treatment systems; and the potential threat to public health. The results of the evaluation may be used as a briefing tool for non-public health professionals. PUBLIC HEALTH/TOXICOLOGY Client: Brayton Purcell, Novato, California Dr. Clark performed a toxicological assessment of residents exposed to methyl-tertiary butyl ether (MTBE) from leaking underground storage tanks (LUSTs) adjacent to the subject property. The symptomology of residents and guests of the subject property were evaluated against the known outcomes in published literature to exposure to MTBE. The study found that residents had been exposed to MTBE in their drinking water; that concentrations of MTBE detected at the site were above regulatory guidelines; and, that the symptoms and outcomes expressed by residents and guests were consistent with symptoms and outcomes documented in published literature. Client: Confidential, San Francisco, CaliforniaIdentified and analyzed fifty years of epidemiological literature on workplace exposures to heavy metals. This research resulted in a summary of the types of cancer and non-cancer diseases associated with occupational exposure to chromium as well as the mortality and morbidity rates. Client: Confidential, San Francisco, California Summarized major public health research in United States. Identified major public health research efforts within United States over last twenty years. Results were used as a briefing tool for non-public health professionals.
Client: Confidential, San Francisco, California Quantified the potential multi-pathway dose received by humans from a pesticide applied indoors. Part of team that developed exposure model and evaluated exposure concentrations in a comprehensive report on the plausible range of doses received by a specific person. This evaluation was used in the support of litigation. Client: Covanta Energy, Westwood, California Evaluated health risk from metals in biosolids applied as soil amendment on agricultural lands. The biosolids were created at a forest waste cogeneration facility using 96% whole tree wood chips and 4 percent green waste. Mass loading calculations were used to estimate Cr(VI) concentrations in agricultural soils based on a maximum loading rate of 40 tons of biomass per acre of agricultural soil. The results of the study were used by the Regulatory agency to determine that the application of biosolids did not constitute a health risk to workers applying the biosolids or to residences near the agricultural lands. Client – United Kingdom Environmental Agency Oversaw a comprehensive toxicological evaluation of methyl-tertiary butyl ether (MtBE)for the United Kingdom’s Environment Agency. The evaluation included available data on the production, use, chemical characteristics, fate and transport, toxicology, and remediation of MtBE. The results of the evaluation have been used as a briefing tool for public health professionals.Client – Confidential, Los Angeles, CaliforniaPrepared comprehensive evaluation of tertiary butyl alcohol (TBA) in municipal drinking water system. TBA is the primary breakdown product of MtBE, and is suspected to be the primary cause of MtBE toxicity. This evaluation will include available information on the production, use, chemical characteristics, fate and transport in the environment, absorption, distribution, routes of detoxification, metabolites, carcinogenic potential, and remediation of TBA. The results of the evaluation were used as a briefing tool for non-public health professionals. Client – Confidential, Los Angeles, California Prepared comprehensive evaluation of methyl tertiary butyl ether (MTBE) in municipal drinking water system. MTBE is a chemical added to gasoline to increase the octane rating and to meet Federally mandated emission criteria. The evaluation included available data on the production, use, chemical characteristics, fate and transport, toxicology, and remediation of MTBE. The results of the evaluation have been were used as a briefing tool for non-public health professionals.Client – Ministry of Environment, Lands & Parks, British Columbia Dr. Clark assisted in the development of water quality guidelines for methyl tertiary-butyl ether (MTBE) to protect water uses in British Columbia (BC). The water uses to be considered includes freshwater and marine life, wildlife, industrial, and agricultural (e.g., irrigation and livestock watering) water uses. Guidelines from other jurisdictions for the protection of drinking water, recreation and aesthetics were to be identified. Client: Confidential, Los Angeles, California Prepared physiologically based pharmacokinetic (PBPK) assessment of lead risk of receptors at middle school built over former industrial facility. This evaluation is being used to determine cleanup goals and will be basis for regulatory closure of site. Client: Kaiser Venture Incorporated, Fontana, California Prepared PBPK assessment of lead risk of receptors at a 1,100-acre former steel mill. This evaluation was used as the basis for granting closure of the site by lead regulatory agency.RISK ASSESSMENTS/REMEDIAL INVESTIGATIONS Client: Confidential, Atlanta, Georgia Researched potential exposure and health risks to community members potentially exposed to creosote, polycyclic aromatic hydrocarbons, pentachlorophenol, and dioxin compounds used at a former wood treatment facility. Prepared a comprehensive toxicological summary of the chemicals of concern, including the chemical characteristics, absorption, distribution, and carcinogenic potential. Prepared risk characterization of the carcinogenic and non-carcinogenic chemicals based on the exposure assessment to quantify the potential risk to members of the surrounding community. This evaluation was used to help settle class-action tort.
Client: Confidential, Escondido, California Prepared comprehensive Preliminary Endangerment Assessment (PEA) of dense non-aqueous liquid phase hydrocarbon (chlorinated solvents) contamination at a former printed circuit board manufacturing facility. This evaluation was used for litigation support and may be used as the basis for reaching closure of the site with the lead regulatory agency. Client: Confidential, San Francisco, California Summarized epidemiological evidence for connective tissue and autoimmune diseases for product liability litigation. Identified epidemiological research efforts on the health effects of medical prostheses. This research was used in a meta-analysis of the health effects and as a briefing tool for non-public health professionals. Client: Confidential, Bogotá, Columbia Prepared comprehensive evaluation of the potential health risks associated with the redevelopment of a 13.7 hectares plastic manufacturing facility in Bogotá, Colombia The risk assessment was used as the basis for the remedial goals and closure of the site. Client: Confidential, Los Angeles, California Prepared comprehensive human health risk assessment of students, staff, and residents potentially exposed to heavy metals (principally cadmium) and VOCs from soil and soil vapor at 12-acre former crude oilfield and municipal landfill. The site is currently used as a middle school housing approximately 3,000 children. The evaluation determined that the site was safe for the current and future uses and was used as the basis for regulatory closure of site. Client: Confidential, Los Angeles, California Managed remedial investigation (RI) of heavy metals and volatile organic chemicals (VOCs) for a 15-acre former manufacturing facility. The RI investigation of the site included over 800 different sampling locations and the collection of soil, soil gas, and groundwater samples. The site is currently used as a year round school housing approximately 3,000 children. The Remedial Investigation was performed in a manner that did not interrupt school activities and met the time restrictions placed on the project by the overseeing regulatory agency. The RI Report identified the off-site source of metals that impacted groundwater beneath the site and the sources of VOCs in soil gas and groundwater. The RI included a numerical model of vapor intrusion into the buildings at the site from the vadose zone to determine exposure concentrations and an air dispersion model of VOCs from the proposed soil vapor treatment system. The Feasibility Study for the Site is currently being drafted and may be used as the basis for granting closure of the site by DTSC. Client: Confidential, Los Angeles, California Prepared comprehensive human health risk assessment of students, staff, and residents potentially exposed to heavy metals (principally lead), VOCs, SVOCs, and PCBs from soil, soil vapor, and groundwater at 15-acre former manufacturing facility. The site is currently used as a year round school housing approximately 3,000 children. The evaluation determined that the site was safe for the current and future uses and will be basis for regulatory closure of site. Client: Confidential, Los Angeles, California Prepared comprehensive evaluation of VOC vapor intrusion into classrooms of middle school that was former 15-acre industrial facility. Using the Johnson-Ettinger Vapor Intrusion model, the evaluation determined acceptable soil gas concentrations at the site that did not pose health threat to students, staff, and residents. This evaluation is being used to determine cleanup goals and will be basis for regulatory closure of site. Client –Dominguez Energy, Carson, CaliforniaPrepared comprehensive evaluation of the potential health risks associated with the redevelopment of 6-acre portion of a 500-acre oil and natural gas production facility in Carson, California. The risk assessment was used as the basis for closure of the site. Kaiser Ventures Incorporated, Fontana, CaliforniaPrepared health risk assessment of semi-volatile organic chemicals and metals for a fifty-year old wastewater treatment facility used at a 1,100-acre former steel mill. This evaluation was used as the basis for granting closure of the site by lead regulatory agency.
ANR Freight - Los Angeles, California Prepared a comprehensive Preliminary Endangerment Assessment (PEA) of petroleum hydrocarbon and metal contamination of a former freight depot. This evaluation was as the basis for reaching closure of the site with lead regulatory agency. Kaiser Ventures Incorporated, Fontana, California Prepared comprehensive health risk assessment of semi-volatile organic chemicals and metals for 23-acre parcel of a 1,100-acre former steel mill. The health risk assessment was used to determine clean up goals and as the basis for granting closure of the site by lead regulatory agency. Air dispersion modeling using ISCST3 was performed to determine downwind exposure point concentrations at sensitive receptors within a 1 kilometer radius of the site. The results of the health risk assessment were presented at a public meeting sponsored by the Department of Toxic Substances Control (DTSC) in the community potentially affected by the site. Unocal Corporation - Los Angeles, California Prepared comprehensive assessment of petroleum hydrocarbons and metals for a former petroleum service station located next to sensitive population center (elementary school). The assessment used a probabilistic approach to estimate risks to the community and was used as the basis for granting closure of the site by lead regulatory agency.Client: Confidential, Los Angeles, California Managed oversight of remedial investigation most contaminated heavy metal site in California. Lead concentrations in soil excess of 68,000,000 parts per billion (ppb) have been measured at the site. This State Superfund Site was a former hard chrome plating operation that operated for approximately 40-years. Client: Confidential, San Francisco, California Coordinator of regional monitoring program to determine background concentrations of metals in air. Acted as liaison with SCAQMD and CARB to perform co-location sampling and comparison of accepted regulatory method with ASTM methodology.
Client: Confidential, San Francisco, CaliforniaAnalyzed historical air monitoring data for South Coast Air Basin in Southern California and potential health risks related to ambient concentrations of carcinogenic metals and volatile organic compounds. Identified and reviewed the available literature and calculated risks from toxins in South Coast Air Basin. IT Corporation, North CarolinaPrepared comprehensive evaluation of potential exposure of workers to air-borne VOCs at hazardous waste storage facility under SUPERFUND cleanup decree. Assessment used in developing health based clean-up levels. Professional AssociationsAmerican Public Health Association (APHA) Association for Environmental Health and Sciences (AEHS) American Chemical Society (ACS) California Redevelopment Association (CRA) International Society of Environmental Forensics (ISEF) Society of Environmental Toxicology and Chemistry (SETAC) Publications and Presentations:Books and Book Chapters Sullivan, P., J.J. J. Clark, F.J. Agardy, and P.E. Rosenfeld. (2007). Synthetic Toxins In The Food, Water and Air of American Cities. Elsevier, Inc. Burlington, MA. Sullivan, P. and J.J. J. Clark. 2006. Choosing Safer Foods, A Guide To Minimizing Synthetic Chemicals In Your Diet. Elsevier, Inc. Burlington, MA. Sullivan, P., Agardy, F.J., and J.J.J. Clark. 2005. The Environmental Science of Drinking Water. Elsevier, Inc. Burlington, MA. Sullivan, P.J., Agardy, F.J., Clark, J.J.J. 2002. America’s Threatened Drinking Water: Hazards and Solutions. Trafford Publishing, Victoria B.C. Clark, J.J.J. 2001. “TBA: Chemical Properties, Production & Use, Fate and Transport, Toxicology, Detection in Groundwater, and Regulatory Standards” in Oxygenates in the Environment. Art Diaz, Ed.. Oxford University Press: New York. Clark, J.J.J. 2000. “Toxicology of Perchlorate” in Perchlorate in the Environment. Edward Urbansky, Ed. Kluwer/Plenum: New York. Clark, J.J.J. 1995. Probabilistic Forecasting of Volatile Organic Compound Concentrations At The Soil Surface From Contaminated Groundwater. UMI.
Baker, J.; Clark, J.J.J.; Stanford, J.T. 1994. Ex Situ Remediation of Diesel Contaminated Railroad Sand by Soil Washing. Principles and Practices for Diesel Contaminated Soils, Volume III. P.T. Kostecki, E.J. Calabrese, and C.P.L. Barkan, eds. Amherst Scientific Publishers, Amherst, MA. pp 89-96. Journal and Proceeding Articles Tam L. K.., Wu C. D., Clark J. J. and Rosenfeld, P.E. (2008) A Statistical Analysis Of Attic Dust And Blood Lipid Concentrations Of Tetrachloro-p-Dibenzodioxin (TCDD) Toxicity Equialency Quotients (TEQ) In Two Populations Near Wood Treatment Facilities. Organohalogen Compounds, Volume 70 (2008) page 002254. Tam L. K.., Wu C. D., Clark J. J. and Rosenfeld, P.E. (2008) Methods For Collect Samples For Assessing Dioxins And Other Environmental Contaminants In Attic Dust: A Review. Organohalogen Compounds, Volume 70 (2008) page 000527 Hensley A.R., Scott, A., Rosenfeld P.E., Clark, J.J.J. (2007). “Attic Dust And Human Blood Samples Collected Near A Former Wood Treatment Facility.” Environmental Research. 105:194-199.Rosenfeld, P.E., Clark, J. J., Hensley, A.R., and Suffet, I.H. 2007. “The Use Of An Odor Wheel Classification For The Evaluation of Human Health Risk Criteria For Compost Facilities” Water Science & Technology. 55(5): 345-357. Hensley A.R., Scott, A., Rosenfeld P.E., Clark, J.J.J. 2006. “Dioxin Containing Attic Dust And Human Blood Samples Collected Near A Former Wood Treatment Facility.” The 26th International Symposium on Halogenated Persistent Organic Pollutants – DIOXIN2006, August 21 – 25, 2006. Radisson SAS Scandinavia Hotel in Oslo Norway. Rosenfeld, P.E., Clark, J. J. and Suffet, I.H. 2005. “The Value Of An Odor Quality Classification Scheme For Compost Facility Evaluations” The U.S. Composting Council’s 13th Annual Conference January 23 - 26, 2005, Crowne Plaza Riverwalk, San Antonio, TX. Rosenfeld, P.E., Clark, J. J. and Suffet, I.H. 2004. “The Value Of An Odor Quality Classification Scheme For Urban Odor” WEFTEC 2004. 77th Annual Technical Exhibition & Conference October 2 - 6, 2004, Ernest N. Morial Convention Center, New Orleans, Louisiana. Clark, J.J.J. 2003. “Manufacturing, Use, Regulation, and Occurrence of a Known Endocrine Disrupting Chemical (EDC), 2,4-Dichlorophnoxyacetic Acid (2,4-D) in California Drinking Water Supplies.” National Groundwater Association Southwest Focus Conference: Water Supply and Emerging Contaminants. Minneapolis, MN. March 20, 2003.
Rosenfeld, P. and J.J.J. Clark. 2003. “Understanding Historical Use, Chemical Properties, Toxicity, and Regulatory Guidance” National Groundwater Association Southwest Focus Conference: Water Supply and Emerging Contaminants. Phoenix, AZ. February 21, 2003. Clark, J.J.J., Brown A. 1999. Perchlorate Contamination: Fate in the Environment and Treatment Options. In Situ and On-Site Bioremediation, Fifth International Symposium. San Diego, CA, April, 1999. Clark, J.J.J. 1998. Health Effects of Perchlorate and the New Reference Dose (RfD). Proceedings From the Groundwater Resource Association Seventh Annual Meeting, Walnut Creek, CA, October 23, 1998. Browne, T., Clark, J.J.J. 1998. Treatment Options For Perchlorate In Drinking Water. Proceedings From the Groundwater Resource Association Seventh Annual Meeting, Walnut Creek, CA, October 23, 1998. Clark, J.J.J., Brown, A., Rodriguez, R. 1998. The Public Health Implications of MtBE and Perchlorate in Water: Risk Management Decisions for Water Purveyors. Proceedings of the National Ground Water Association, Anaheim, CA, June 3-4, 1998. Clark J.J.J., Brown, A., Ulrey, A. 1997. Impacts of Perchlorate On Drinking Water In The Western United States. U.S. EPA Symposium on Biological and Chemical Reduction of Chlorate and Perchlorate, Cincinnati, OH, December 5, 1997.Clark, J.J.J.; Corbett, G.E.; Kerger, B.D.; Finley, B.L.; Paustenbach, D.J. 1996. Dermal Uptake of Hexavalent Chromium In Human Volunteers: Measures of Systemic Uptake From Immersion in Water At 22 PPM. Toxicologist. 30(1):14. Dodge, D.G.; Clark, J.J.J.; Kerger, B.D.; Richter, R.O.; Finley, B.L.; Paustenbach, D.J. 1996. Assessment of Airborne Hexavalent Chromium In The Home Following Use of Contaminated Tapwater. Toxicologist. 30(1):117-118. Paulo, M.T.; Gong, H., Jr.; Clark, J.J.J. (1992). Effects of Pretreatment with Ipratroprium Bromide in COPD Patients Exposed to Ozone. American Review of Respiratory Disease. 145(4):A96. Harber, P.H.; Gong, H., Jr.; Lachenbruch, A.; Clark, J.; Hsu, P. (1992). Respiratory Pattern Effect of Acute Sulfur Dioxide Exposure in Asthmatics. American Review of Respiratory Disease. 145(4):A88. McManus, M.S.; Gong, H., Jr.; Clements, P.; Clark, J.J.J. (1991). Respiratory Response of Patients With Interstitial Lung Disease To Inhaled Ozone. American Review of Respiratory Disease. 143(4):A91. Gong, H., Jr.; Simmons, M.S.; McManus, M.S.; Tashkin, D.P.; Clark, V.A.; Detels, R.; Clark, J.J. (1990). Relationship Between Responses to Chronic Oxidant and Acute Ozone Exposures in Residents of Los Angeles County. American Review of Respiratory Disease. 141(4):A70. Tierney, D.F. and J.J.J. Clark. (1990). Lung Polyamine Content Can Be Increased By Spermidine Infusions Into Hyperoxic Rats. American Review of Respiratory Disease. 139(4):A41.
0 50 100 150 200 250 300Minutes into survey051015202530Model predictionr2= 0.98, loss = 8.295% CI of 7 visual-scan surveys 2019-2024Actual count of species
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1 Kenneth Shawn Smallwood Curriculum Vitae 3108 Finch Street Born May 3, 1963 in Davis, CA 95616 Sacramento, California. Phone (530) 756-4598 Married, father of two. Cell (530) 601-6857 [email protected] Ecologist Expertise Finding solutions to controversial problems related to wildlife interactions with human industry, infrastructure, and activities; Wildlife monitoring and field study using GPS, thermal imaging, behavior surveys; Using systems analysis and experimental design principles to identify meaningful ecological patterns that inform management decisions. Education Ph.D. Ecology, University of California, Davis. September 1990. M.S. Ecology, University of California, Davis. June 1987. B.S. Anthropology, University of California, Davis. June 1985. Corcoran High School, Corcoran, California. June 1981. Experience 762 professional reports, including: 90 peer reviewed publications 24 in non-reviewed proceedings 646 reports, declarations, posters and book reviews 8 in mass media outlets 92 public presentations of research results Editing for scientific journals: Guest Editor, Wildlife Society Bulletin, 2012-2013, of invited papers representing international views on the impacts of wind energy on wildlife and how to mitigate the impacts. Associate Editor, Journal of Wildlife Management, March 2004 to 30 June 2007. Editorial Board Member, Environmental Management, 10/1999 to 8/2004. Associate Editor, Biological Conservation, 9/1994 to 9/1995. Member, Alameda County Scientific Review Committee (SRC), August 2006 to April 2011. The five-member committee investigated causes of bird and bat collisions in the Altamont Pass Wind Resource Area, and recommended mitigation and monitoring measures. The SRC reviewed the science underlying the Alameda County Avian Protection Program, and advised Smallwood CV 2 the County on how to reduce wildlife fatalities. Consulting Ecologist, 2004-2007, California Energy Commission (CEC). Provided consulting services as needed to the CEC on renewable energy impacts, monitoring and research, and produced several reports. Also collaborated with Lawrence-Livermore National Lab on research to understand and reduce wind turbine impacts on wildlife. Consulting Ecologist, 1999-2013, U.S. Navy. Performed endangered species surveys, hazardous waste site monitoring, and habitat restoration for the endangered San Joaquin kangaroo rat, California tiger salamander, California red-legged frog, California clapper rail, western burrowing owl, salt marsh harvest mouse, and other species at Naval Air Station Lemoore; Naval Weapons Station, Seal Beach, Detachment Concord; Naval Security Group Activity, Skaggs Island; National Radio Transmitter Facility, Dixon; and, Naval Outlying Landing Field Imperial Beach. Part-time Lecturer, 1998-2005, California State University, Sacramento. Instructed Mammalogy, Behavioral Ecology, and Ornithology Lab, Contemporary Environmental Issues, Natural Resources Conservation. Senior Ecologist, 1999-2005, BioResource Consultants. Designed and implemented research and monitoring studies related to avian fatalities at wind turbines, avian electrocutions on electric distribution poles across California, and avian fatalities at transmission lines. Chairman, Conservation Affairs Committee, The Wildlife Society--Western Section, 1999-2001. Prepared position statements and led efforts directed toward conservation issues, including travel to Washington, D.C. to lobby Congress for more wildlife conservation funding. Systems Ecologist, 1995-2000, Institute for Sustainable Development. Headed integrated resources management. Developed indicators of ecological integrity for large areas, using remotely sensed data, local community involvement and GIS. Associate, 1997-1998, Department of Agronomy and Range Science, University of California, Davis. Worked with Shu Geng and Mingua Zhang on several studies related to wildlife interactions with agriculture and patterns of fertilizer and pesticide residues in groundwater across a large landscape. Lead Scientist, 1996-1999, National Endangered Species Network. Informed academic scientists and environmental activists about emerging issues regarding the Endangered Species Act and other environmental laws. Testified at public hearings on endangered species issues. Ecologist, 1997-1998, Western Foundation of Vertebrate Zoology. Conducted field research to determine the impact of past mercury mining on the status of California red-legged frogs in Santa Clara County, California. Senior Systems Ecologist, 1994-1995, EIP Associates, Sacramento, California. Provided consulting services in environmental planning, and quantitative assessment of land units for their conservation and restoration opportunities basedon ecological resource requirements of 29 special-status species. Developed ecological indicators for prioritizing areas within Yolo County Smallwood CV 3 to receive mitigation funds for habitat easements and restoration. Post-Graduate Researcher, 1990-1994, Department of Agronomy and Range Science, U.C. Davis. Under Dr. Shu Geng mentorship, studied landscape and management effects on temporal and spatial patterns of abundance among pocket gophers and species of Falconiformes and Carnivora in the Sacramento Valley. Managed and analyzed a data base of energy use in California agriculture. Assisted with landscape (GIS) study of groundwater contamination across Tulare County, California. Work experience in graduate school: Co-taught Conservation Biology with Dr. Christine Schonewald, 1991 & 1993, UC Davis Graduate Group in Ecology; Reader for Dr. Richard CossPsychobiology in 1990, UC Davis Department of Psychology; Research Assistant to Dr. Walter E. Howard, 1988-1990, UC Davis Department of Wildlife and Fisheries Biology, testing durable baits for pocket gopher management in forest clearcuts; Research Assistant to Dr. Terrell P. Salmon, 1987-1988, UC Wildlife Extension, Department of Wildlife and Fisheries Biology, developing empirical models of mammal and bird invasions in North America, and a rating system for priority research and control of exotic species based on economic, environmental and human health hazards in California. Student Assistant to Dr. E. Lee Fitzhugh, 1985-1987, UC Cooperative Extension, Department of Wildlife and Fisheries Biology, developing and implementing statewide mountain lion track count for long-term monitoring. Fulbright Research Fellow, Indonesia, 1988. Tested use of new sampling methods for numerical monitoring of Sumatran tiger and six other species of endemic felids, and evaluated methods used by other researchers. Projects Repowering wind energy projects through careful siting of new wind turbines using map-based collision hazard models to minimize impacts to volant wildlife. Funded by wind companies (principally NextEra Renewable Energy, Inc.), California Energy Commission and East Bay Regional Park District, I have collaborated with a GIS analyst and managed a crew of five field biologists performing golden eagle behavior surveys and nocturnal surveys on bats and owls. The goal is to quantify flight patterns for development of predictive models to more carefully site new wind turbines in repowering projects. Focused behavior surveys began May 2012 and continue. Collision hazard models have been prepared for seven wind projects, three of which were built. Planning for additional repowering projects is underway. Test avian safety of new mixer-ejector wind turbine (MEWT). Designed and implemented a before-after, control-impact experimental design to test the avian safety of a new, shrouded wind turbine developed by Ogin Inc. (formerly known as FloDesign Wind Turbine Corporation). Supported by a Research program and a 20% match share contribution from Ogin, I managed a crew of seven field biologists who performed periodic fatality searches and behavior surveys, carcass detection trials, nocturnal behavior surveys using a thermal camera, and spatial analyses with the collaboration of a GIS analyst. Field work began 1 April 2012 and ended 30 March 2015 without Ogin installing its MEWTs, but we still achieved multiple important scientific advances.
Smallwood CV 4 Reduce avian mortality due to wind turbines at Altamont Pass. Studied wildlife impacts caused by 5,400 wind turbines notorious wind resource area. Studied how impacts are perceived by monitoring and how they are affected by terrain, wind patterns, food resources, range management practices, wind turbine operations, seasonal patterns, population cycles, infrastructure management such as electric distribution, animal behavior and social interactions. Reduce avian mortality on electric distribution poles. Directed research toward reducing bird electrocutions on electric distribution poles, 2000-2007. Oversaw 5 founds of fatality searches at 10,000 poles from Orange County to Glenn County, California, and produced two large reports. Cook et al. v. Rockwell International et al., No. 90-K-181 (D. Colorado). Provided expert testimony on the role of burrowing animals in affecting the fate of buried and surface-deposited radioactive and hazardous chemical wastes at the Rocky Flats Plant, Colorado. Provided expert reports based on four site visits and an extensive document review of burrowing animals. Conducted transect surveys for evidence of burrowing animals and other wildlife on and around waste facilities. Discovered substantial intrusion of waste structures by burrowing animals. I testified in federal court in November 2005, and my clients were subsequently awarded a $553,000,000 judgment by a jury. After appeals the award was increased to two billion dollars. Hanford Nuclear Reservation Litigation. Provided expert testimony on the role of burrowing animals in affecting the fate of buried radioactive wastes at the Hanford Nuclear Reservation, Washington. Provided three expert reports based on three site visits and extensive document review. Predicted and verified a certain population density of pocket gophers on buried waste structures, as well as incidence of radionuclide contamination in body tissue. Conducted transect surveys for evidence of burrowing animals and other wildlife on and around waste facilities. Discovered substantial intrusion of waste structures by burrowing animals. Expert testimony and declarations on proposed residential and commercial developments, gas-fired power plants, wind, solar and geothermal projects, water transfers and water transfer delivery systems, endangered species recovery plans, Habitat Conservation Plans and Natural Communities Conservation Programs. Testified before multiple government agencies, Tribunals, Boards of Supervisors and City Councils, and participated with press conferences and depositions. Prepared expert witness reports and court declarations, which are summarized under Reports (below). Protocol-level surveys for special-status species. Used California Department of Fish and Wildlife and US Fish and Wildlife Service protocols to search for California red-legged frog, California tiger salamander, arroyo southwestern toad, blunt-nosed leopard lizard, western pond turtle, giant kangaroo rat, San Joaquin kangaroo rat, San Joaquin kit fox, western burrowing owl, Swainshawk, Valley elderberry longhorn beetle and other special-status species. Conservation of San Joaquin kangaroo rat. Performed research to identify factors responsible for the decline of this endangered species at Lemoore Naval Air Station, 2000-2013, and implemented habitat enhancements designed to reverse the trend and expand the population. Impact of West Nile Virus on yellow-billed magpies. Funded by Sacramento-Yolo Mosquito and Vector Control District, 2005-2008, compared survey results pre- and post-West Nile Virus epidemic for multiple bird species in the Sacramento Valley, particularly on yellow-billed magpie and American crow due to susceptibility to WNV.
Smallwood CV 5 Workshops on HCPs. Assisted Dr. Michael Morrison with organizing and conducting a 2-day workshop on Habitat Conservation Plans, sponsored by Southern California Edison, and another 1-day workshop sponsored by PG&E. These Workshops were attended by academics, attorneys, and consultants with HCP experience. We guest-edited a Proceedings published in Environmental Management. Mapping of biological resources along Highways 101, 46 and 41. Used GPS and GIS to delineate vegetation complexes and locations of special-status species along 26 miles of highway in San Luis Obispo County, 14 miles of highway and roadway in Monterey County, and in a large area north of Fresno, including within reclaimed gravel mining pits. GPS mapping and monitoring at restoration sites and at Caltrans mitigation sites. Monitored the success of elderberry shrubs at one location, the success of willows at another location, and the response of wildlife to the succession of vegetation at both sites. Also used GPS to monitor the response of fossorial animals to yellow star-thistle eradication and natural grassland restoration efforts at Bear Valley in Colusa County and at the decommissioned Mather Air Force Base in Sacramento County. Mercury effects on Red-legged Frog. Assisted Dr. Michael Morrison and US Fish and Wildlife Service in assessing the possible impacts of historical mercury mining on the federally listed California red-legged frog in Santa Clara County. Also measured habitat variables in streams. Opposition to proposed No Surprises rule. Wrote a white paper and summary letter explaining scientific grounds for opposing the incidental take permit (ITP) rules providing ITP applicants and holders with general assurances they will be free of compliance with the Endangered Species Act Submitted 188 signatures of scientists and environmental professionals concerned about No Surprises rule US Fish and Wildlife Service, National Marine Fisheries Service, all US Senators. Natomas Basin Habitat Conservation Plan alternative. Designed narrow channel marsh to increase the likelihood of survival aValley Elderberry Longhorn Beetle. The design included replication and interspersion of treatments for experimental testing of critical habitat elements. I provided a report to Northern Territories, Inc. Assessments of agricultural production system and environmental technology transfer to China. Twice visited China and interviewed scientists, industrialists, agriculturalists, and the Directors of the Chinese Environmental Protection Agency and the Department of Agriculture to assess the need and possible pathways for environmental clean-up technologies and trade opportunities between the US and China. Yolo County Habitat Conservation Plan. Conducted landscape ecology study of Yolo County to spatially prioritize allocation of mitigation efforts to improve ecosystem functionality within the County from the perspective of 29 special-status species of wildlife and plants. Used a hierarchically structured indicators approach to apply principles of landscape and ecosystem ecology, conservation biology, and local values in rating land units. Derived GIS maps to help guide the conservation area design, and then developed implementation strategies.
Smallwood CV 6 Mountain lion track count. Developed and conducted a carnivore monitoring program throughout California since 1985. Species counted include mountain lion, bobcat, black bear, coyote, red and gray fox, raccoon, striped skunk, badger, and black-tailed deer. Vegetation and land use are also monitored. Track survey transect was established on dusty, dirt roads within randomly selected quadrats. Sumatran tiger and other felids. Upon award of Fulbright Research Fellowship, I designed and initiated track counts for seven species of wild cats in Sumatra, including Sumatran tiger, fishing cat, and golden cat. Spent four months on Sumatra and Java in 1988, and learned Bahasa Indonesia, the official Indonesian language. Wildlife in agriculture. Beginning as post-graduate research, I studied pocket gophers and other wildlife in 40 alfalfa fields throughout the Sacramento Valley, and I surveyed for wildlife along a 200 mile road transect since 1989 with a hiatus of 1996-2004. The data are analyzed using GIS and methods from landscape ecology, and the results published and presented orally to farming groups in California and elsewhere. I also conducted the first study of wildlife in cover crops used on vineyards and orchards. Agricultural energy use and Tulare County groundwater study. Developed and analyzed a data base of energy use in California agriculture, and collaborated on a landscape (GIS) study of groundwater contamination across Tulare County, California. Pocket gopher damage in forest clear-cuts. Developed gopher sampling methods and tested various poison baits and baiting regimes in the largest-ever field study of pocket gopher management in forest plantations, involving 68 research plots in 55 clear-cuts among 6 National Forests in northern California. Risk assessment of exotic species in North America. Developed empirical models of mammal and bird species invasions in North America, as well as a rating system for assigning priority research and control to exotic species in California, based on economic, environmental, and human health hazards. Peer Reviewed Publications Smallwood, K. S. 2022. Utility-scale solar impacts to volant wildlife. Journal of Wildlife Management: e22216. https://doi.org/10.1002/jwmg.22216 Smallwood, K. S., and N. L. Smallwood. 2021. Breeding Density and Collision Mortality of Loggerhead Shrike (Lanius ludovicianus) in the Altamont Pass Wind Resource Area. Diversity 13, 540. https://doi.org/10.3390/d13110540. Smallwood, K. S. 2020. USA wind energy-caused bat fatalities increase with shorter fatality search intervals. Diversity 12(98); https://doi.org/10.3390/d12030098 Smallwood, K. S., D. A. Bell, and S. Standish. 2020. Dogs detect larger wind energy impacts on bats and birds. Journal of Wildlife Management 84:852-864. DOI: 10.1002/jwmg.21863. Smallwood, K. S., and D. A. Bell. 2020. Relating bat passage rates to wind turbine fatalities.
Smallwood CV7Diversity 12(84); doi:10.3390/d12020084.Smallwood, K. S., and D. A. Bell. 2020. Effects of wind turbine curtailment on bird and bat fatalities. Journal of Wildlife Management 84:684-696. DOI: 10.1002/jwmg.21844Kitano, M., M. Ino, K. S. Smallwood, and S. Shiraki. 2020. Seasonal difference in carcasspersistence rates at wind farms with snow, Hokkaido, Japan. Ornithological Science 19: 63 71.Smallwood, K. S. and M. L. Morrison. 2018. Nest-site selection in a high-density colony of burrowing owls. Journal of Raptor Research 52:454-470.Smallwood, K. S., D. A. Bell, E. L. Walther, E. Leyvas, S. Standish, J. Mount, B. Karas. 2018. Estimating wind turbine fatalities using integrated detection trials. Journal of WildlifeManagement 82:1169-1184.Smallwood, K. S. 2017. Long search intervals under-estimate bird and bat fatalities caused by wind turbines. Wildlife Society Bulletin 41:224-230.Smallwood, K. S. 2017. The challenges of addressing wildlife impacts when repowering windenergy projects. Pages 175-187 in Köppel, J., Editor, Wind Energy and Wildlife Impacts:Proceedings from the CWW2015 Conference. Springer. Cham, Switzerland.May, R., Gill, A. B., Köppel, J. Langston, R. H.W., Reichenbach, M., Scheidat, M., Smallwood, S., Voigt, C. C., Hüppop, O., and Portman, M. 2017. Future research directions to reconcile wind turbinewildlife interactions. Pages 255-276 in Köppel, J., Editor, Wind Energy and Wildlife Impacts: Proceedings from the CWW2015 Conference. Springer. Cham, Switzerland.Smallwood, K. S. 2017. Monitoring birds. M. Perrow, Ed., Wildlife and Wind Farms - Conflicts and Solutions, Volume 2. Pelagic Publishing, Exeter, United Kingdom.www.bit.ly/2v3cR9QSmallwood, K. S., L. Neher, and D. A. Bell. 2017. Turbine siting for raptors: an example from Repowering of the Altamont Pass Wind Resource Area. M. Perrow, Ed., Wildlife and Wind Farms - Conflicts and Solutions, Volume 2. Pelagic Publishing, Exeter, United Kingdom.www.bit.ly/2v3cR9QJohnson, D. H., S. R. Loss, K. S. Smallwood, W. P. Erickson. 2016. Avian fatalities at wind energy facilities in North America: A comparison of recent approaches. HumanWildlife Interactions 10(1):7-18.Sadar, M. J., D. S.-M. Guzman, A. Mete, J. Foley, N. Stephenson, K. H. Rogers, C. Grosset, K. S. Smallwood, J. Shipman, A. Wells, S. D. White, D. A. Bell, and M. G. Hawkins. 2015. Mange Caused by a novel Micnemidocoptes mite in a Golden Eagle (Aquila chrysaetos). Journal ofAvian Medicine and Surgery 29(3):231-237.Smallwood, K. S. 2015. Habitat fragmentation and corridors. Pages 84-101 in M. L. Morrison and H. A. Mathewson, Eds., Wildlife habitat conservation: concepts, challenges, and solutions. John Hopkins University Press, Baltimore, Maryland, USA.
1975 / Professional Engineer / California – Civil, No. 245771977 / Professional Engineer / California – Traffic, No. 7242006 / Professional Engineer / Hawaii – Civil, No. 123211969 / BSE / Civil Engineering / Duke University40+ Years1977 / Institute of Transportation Engineers – Fellow, Life1978 / Orange County Traffic Engineers Council - Chair 1982-19831981 / American Public Works Association – Life MemberTom is a recognized expert in the field of traffic engineering and transportation planning.His background also includes responsibility for leading and managing the delivery of various contract services to numerous cities in Southern California. Tom has extensive experience in providing transportation planning and traffic engineering services to public agencies. Since May 2005, he has served as Consulting City Traffic Engineer for the City of Indio. He also currently provides “on call” Traffic and Transportation Engineer services to the Cities of Big Bear Lake, Mission Viejo, and San Fernando. In addition to conducting traffic engineering investigations for Los Angeles County from 1972 to 1978, he has previously served as City Traffic Engineer in the following communities:oBellflower..................................................... 1997 - 1998oBell Gardens................................................ 1982 - 1995oHuntington Beach........................................ 1998 - 2004oLawndale ..................................................... 1973 - 1978oLos Alamitos................................................ 1981 - 1982oOceanside ................................................... 1981 - 1982oParamount................................................... 1982 - 1988oRancho Palos Verdes.................................. 1973 - 1978oRolling Hills.................................................. 1973 - 1978, 1985 - 1993oRolling Hills Estates..................................... 1973 - 1978, 1984 - 1991oSan Marcos ................................................. 1981oSanta Ana.................................................... 1978 - 1981oWestlake Village.......................................... 1983 - 1994During these assignments, Tom has supervised City staff and directed other consultants including traffic engineers and transportation planners, traffic signal and street lighting personnel, and signing, striping, and marking crews. He has secured over $5 million in grant funding for various improvements. He has managed and directed many traffic and transportation studies and projects. While serving these communities, he has personally conducted investigations of hundreds of citizen requests for various traffic control devices. Tom has also successfully presented numerous engineering reports at City Council, Planning Commission, and Traffic Commission meetings in these and other municipalities.
In his service to the City of Indio since May 2005, Tom has accomplished the following:Oversaw preparation and adoption of the Circulation Element Update of the General Plan including development of Year 2035 buildout traffic volumes, revised and simplified arterial roadway cross sections, and reduction in acceptable Level of Service criteria under certain constraints. Reviewed Riverside County’s updated traffic model for consistency with the adopted City of Indio Circulation Plan.Oversaw preparation of fact sheets/design exceptions to reduce shoulder widths on Jackson Street over I-10 as well as justifications for protected-permissive left turn phasing at I-10 on-ramps, the first such installation in Caltrans District 8 in RiversideCounty; reviewed plans and provided assistance during construction of a $1.5 million project to install traffic signals and widen three of four ramps at the I-10/Jackson Street Interchange under a Caltrans encroachment permit.Oversaw preparation of fact sheets/design exceptions to reduce shoulder widths on Monroe Street over I-10 as well as striping plans to install left turn lanes on Monroe Street at the I-10 Interchange under a Caltrans encroachment permit; reviewed plans to install traffic signals and widen three of four ramps at the I-10/Monroe Street Interchange. Reviewed traffic impact analyses for Project Study Reports evaluating different alternatives for buildout improvement of the I-10 Interchanges at Jefferson Street, Monroe Street, Jackson Street and Golf Center Parkway.Oversaw preparation of plans, specifications, and contract documents and provided construction assistance for over 40 traffic signal installations and modifications.Reviewed and approved over 600 work area traffic control plans as well as signing and striping plans for all City and developer funded roadway improvement projects.Oversaw preparation of a City wide traffic safety study of conditions at all schools.Prepared over 500 work orders directing City forces to install, modify, and/or remove traffic signs, pavement and curb markings, and roadway striping.Oversaw preparation of engineering and traffic surveys to establish enforceable speed limits on over 200 street segments.Reviewed and approved traffic impact studies for more than 25 major developments.Developed the Golf Cart Transportation Program and administrative procedures; implemented routes forming the initial baseline system.Since forming Tom Brohard and Associates in 2000, Tom has reviewed many traffic impact reports and environmental documents for various development projects. He has provided expert witness services and also prepared traffic studies for public agencies and private sector clients.