Pasadena City Council
August 31, 2026

FINAL

Initial Study/Mitigated Negative Declaration
Eaton Wash Stormwater
Capture Project
JUNE 2026
Prepared for:

CITY OF PASADENA
Public Works Department
100 North Garfield Avenue
Pasadena, California 91101
Contact: Dawn Petschauer
Prepared by:

2280 Historic Decatur Road, Suite 200
San Diego, California 92106
Contact: Alex Hardy
Attachment A

16537 i
JUNE 2026
Table of Contents

SECTION PAGE
Acronyms and Abbreviations ............................................................................................................................................. v 1 Introduction .......................................................................................................................................................... 1

1.1 Project Background and Overview......................................................................................................... 1 2 Project Description ............................................................................................................................................... 3

2.1 Project Location and Environmental Setting ........................................................................................ 3

2.2 Project Characteristics ........................................................................................................................... 4

2.2.1 Stormwater Capture System .................................................................................................... 4

2.2.2 Park Improvements .................................................................................................................. 5

2.2.3 Eaton Wash Channel Pedestrian Bridge ................................................................................. 7

2.2.4 Parking and Access................................................................................................................... 7

2.2.5 Site Cleanup and Slope Stabilization ...................................................................................... 8

2.2.6 Temporary Construction Access, Staging, and Closures ........................................................ 8

2.3 Construction Phasing and Schedule ..................................................................................................... 8

2.4 Project Operation .................................................................................................................................... 9

2.5 City of Pasadena Permits and Approvals ........................................................................................... 10

2.6 Other Required Permits and Approvals .............................................................................................. 10 3 Initial Study Checklist ........................................................................................................................................ 11

3.1 Aesthetics ............................................................................................................................................ 15

3.2 Agriculture and Forestry Resources ................................................................................................... 18

3.3 Air Quality ............................................................................................................................................. 20

3.4 Biological Resources ........................................................................................................................... 35

3.5 Cultural Resources .............................................................................................................................. 43

3.6 Energy .................................................................................................................................................. 50

3.7 Geology and Soils ................................................................................................................................ 53

3.8 Greenhouse Gas Emissions ................................................................................................................ 58

3.9 Hazards and Hazardous Materials ..................................................................................................... 64

3.10 Hydrology and Water Quality ............................................................................................................... 67

3.11 Land Use and Planning ....................................................................................................................... 71

3.12 Mineral Resources .............................................................................................................................. 73

3.13 Noise .................................................................................................................................................... 74

3.14 Population and Housing ...................................................................................................................... 83

3.15 Public Services .................................................................................................................................... 84

3.16 Recreation ............................................................................................................................................ 85

3.17 Transportation ..................................................................................................................................... 86

3.18 Tribal Cultural Resources .................................................................................................................... 93

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 ii
JUNE 2026

3.19 Utilities and Service Systems .............................................................................................................. 97

3.20 Wildfire ................................................................................................................................................. 99

3.21 Mandatory Findings of Significance ................................................................................................. 101 4 References and Preparers .............................................................................................................................. 103

4.1 References Cited ............................................................................................................................... 103

4.2 List of Preparers ................................................................................................................................ 109

APPENDICES
A Air Quality and Greenhouse Gas Emissions Modeling
B Biological Resources Assessment
C Aquatic Resources Jurisdictional Delineation Report
D Arborist’s Report
E Cultural Resources Assessment Report
F Noise Modeling Inputs and Outputs

FIGURES
1 Project Location .............................................................................................................................................. 111 2 Project Site ...................................................................................................................................................... 113 3 Project Stormwater Capture and Treatment System .................................................................................... 115 4 Site Plan Exhibit .............................................................................................................................................. 117

3.4-1 Project Impacts & Vegetation Communities .................................................................................................. 119

3.13-1 Baseline Sound Pressure Level Measurement Locations ............................................................................ 121 TABLES
1 Anticipated Construction Phasing and Equipment ............................................................................................ 9 2 SCAQMD Air Quality Significance Thresholds .................................................................................................. 23 3 Construction Scenario Details .......................................................................................................................... 24 4 Estimated Maximum Daily Construction Criteria Air Pollutant Emissions ..................................................... 26 5 Construction Localized Significance Thresholds for SRA 8 (West San Gabriel Valley) ............................................. 29 6 Construction Localized Significance Thresholds Analysis – Unmitigated ..................................................... 29 7 Construction Localized Significance Thresholds Analysis – Mitigated .......................................................... 30 8 Vegetation Communities and Land Cover Types in the Project Area ............................................................. 36 9 Previously Conducted Studies Intersecting the APE ....................................................................................... 44 10 Previously Recorded Cultural Resources Within 1 Mile of the APE ............................................................... 44 11 Total Proposed Project Construction Petroleum Demand .............................................................................. 51 12 Project Consistency with City CAP Consistency Checklist Option A Sustainable Development Actions ...... 59 13 Measured Samples of Existing Outdoor Ambient Sound Level ...................................................................... 75

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 iii
JUNE 2026
14 Interior Noise Standard .................................................................................................................................... 75 15 Sound Levels of Typical Construction Equipment ........................................................................................... 77 16 On-Site Construction Noise Model Results Summary ..................................................................................... 78 17 On-Site Construction Noise Model Results Summary – Mitigated ................................................................. 79

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 iv
JUNE 2026

INTENTIONALLY LEFT BLANK

16537 v
JUNE 2026
Acronyms and Abbreviations
Acronym/Abbreviation Definition
AB Assembly Bill
APE area of potential effects
AQMP air quality management plan
BMP best management practice
CAAQS California Ambient Air Quality Standards
CalEEMod California Emissions Estimator Model
CAL FIRE California Department of Forestry and Fire Protection Caltrans California Department of Transportation
CAP Climate Action Plan
CARB California Air Resources Board
CDFW California Department of Fish and Wildlife
CEQA California Environmental Quality Act
CH4 methane
CHRIS California Historical Resources Information System CO carbon monoxide
CO2 carbon dioxide
CO2e carbon dioxide equivalent
CRHR California Register of Historic Resources
dBA A-weighted decibel
DPM diesel particulate matter
EWMP Enhanced Watershed Management Program
GHG greenhouse gas
GWP global warming potential
HFC hydrofluorocarbon
ips inches per second
IS initial study
LACM VP Los Angeles County Museum Vertebrate Paleontology LA County Los Angeles County
LCI Governor’s Office of Land Use and Climate Innovation Leq energy equivalent sound level
Leq(h) energy equivalent sound level measured over a 1-hour period LST localized significance threshold
Metro Los Angeles County Metropolitan Transportation Authority MM Mitigation Measure
MND mitigated negative declaration
MS4 Municipal Separate Storm Sewer System
MT metric ton
N2O nitrous oxide
NAAQS National Ambient Air Quality Standards
NAHC Native American Heritage Commission

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 vi
JUNE 2026
Acronym/Abbreviation Definition
NF3 nitrogen trifluoride
NO2 nitrogen dioxide
NOx oxides of nitrogen
NRHP National Register of Historic Places
O3 ozone
PFC perfluorocarbon
PM10 particulate matter with an aerodynamic diameter equal to or less than 10 microns PM2.5 particulate matter with an aerodynamic diameter equal to or less than 2.5 microns PMC Pasadena Municipal Code
ppm parts per million by volume
PPV peak particle velocity
PRC California Public Resources Code
RTP/SCS Regional Transportation Plan/Sustainable Communities Strategy SCAB South Coast Air Basin
SCAG Southern California Association of Governments
SCAQMD South Coast Air Quality Management District
SCCIC South Central Coastal Information Center
SCE Southern California Edison
SF6 sulfur hexafluoride
SO2 sulfur dioxide
SRA source-receptor area
SWPPP stormwater pollution prevention plan
SWRCB State Water Resources Control Board
TAC toxic air contaminant
TAP Transportation Action Plan
TCR tribal cultural resource
ULAR Upper Los Angeles River
VMT vehicle miles traveled
VOC volatile organic compound

16537 1
JUNE 2026
1 Introduction
The City of Pasadena (City) has prepared this mitigated negative declaration (MND) to assess and disclose the potential impacts on the environment of the Eaton Wash Stormwater Capture Project (project) pursuant to the California Environmental Quality Act ( CEQA) (California Public Resources Code [PRC] Section 21000 et seq). This section of the MND provides information on project background and incorporates text and information from the Preliminary Design Report prepared for the project in April 2025 (Craftwater 2025).

1.1 Project Background and Overview
The City is a member of the Upper Los Angeles River (ULAR) Watershed Management Group, which also includes the Cities of Alhambra, Burbank, Calabasas, Glendale, Hidden Hills, La Canada Flintridge, Montebello, Monterey Park, Rosemead, San Gabriel, South El Monte, South Pasadena, San Marino, and Temple City. The ULAR Watershed Management Group is a partnership with the City of Los Angeles, County of Los Angeles, and Los Angeles County (LA County) Flood Control District formed to help accomplish the region’s w ater quality goals and comply with the Los Angeles County Municipal Separate Storm Sewer System (MS4) Permit (Order No. R4 -2021-0105). The ULAR Watershed Management Area comprises 613 square miles and more than 50 miles of the mainstream Los Angeles River from its headwaters to just above the estuary, including Aliso Canyon Creek, Bell Creek, Bull Creek, Tujunga Wash, Burbank Western Channel, Arroyo Seco, Rio Hondo, and Compton Creek (Council for Watershed Health 2023; ULAR Watershed Management Group 2015). The ULAR Watershed Management Area accounts for approximately 58% of the total Los Angeles River Watershed area.

The ULAR Watershed Management Group prepared the ULAR Enhanced Watershed Management Program (EWMP) in 2015 and it was approved in 2016. The objective of the EWMP is to identify a network of control measures, also known as best management practices (BMPs), that will achieve required stormwater pollutant reductions while also providing multiple benefits to the community and leveraging sustainable green infrastructure practices (ULAR Watershed Management Group 2015). The MS4 Permit sets effluent and receiving water limitations for municipal drainage systems in Los Angeles County and requires permittees to establish plans to meet specific total maximum daily load requirements for discharge of pollutants in their respective receiving waters. The City of Pasadena and ULAR Watershed Management Group have identified the proposed project as a critical project contributing to the compliance goals as set in the ULAR EWMP. Additionally, a 2022 Watershed Assessment identified an Eaton Wash project site as a high -priority location to help the City achieve its pollutant load reduction compliance in the ULAR and Rio Hondo Watersheds. The City prepared a Safe, Clean Water Program Feasibility Study application that secured $2.3 million in design funds to re -envision open spaces along the Eaton Wash Channel and create multi - benefit opportunities to address critical City resiliency goals. The project builds upon the Feasibility Study.

The City identified a vacant City -owned property south of Del Mar Boulevard, west of the western termini of Thorndale Road and Grayburn Road, and abutting the Eaton Wash Channel, that could accommodate development of stormwater treatment infrastructure to help meet the MS4 Permit obligations by reducing pollutants discharged into the Rio Hondo River. Figure 1, Project Location, and Figure 2, Project Site, show the general and specific location of the project site, which is primarily located within the City of Pasadena, with a small portion of the project site falling within unincorporated Los Angeles County land. The property had been used in the past as a community garden and educational nature center but has not been used for those purposes since 1995. The City initiated design of the project, relying on funding from the Safe Clean Water Program (Measure W), in Fiscal Year 2023–24, and developed plans for building an underground infiltration reservoir for treating and temporarily storing flows

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 2
JUNE 2026
from the Eaton Wash Channel. Locating the project on a vacant, unused parcel also provided the City an opportunity to plan passive recreational and educational spaces for the community, continuing the legacy of the site’s historical uses. The project site’s proximity to Eaton Blanche Park to the west offers a chance to connect the planned facility to the developed public recreational facilities with a proposed pedestrian bridge , enhancing its connectivity and usefulness to the community. The City implemented a public outreach campaign to gather feedback from the public on the proposed project and the type of facilities that would be most desirable to its citizens, neighbors, and park users. The current design of the stormwater capture infrastructure is shown on Figure 3, Project Stormwater Capture and Treatment System, and Figure 4, Conceptual Site Plan, shows the current design of the community and park amenities proposed at the site.

16537 3
JUNE 2026
2 Project Description
The project description in this chapter incorporates text and information from the Preliminary Design Report prepared for the project in April 2025 (Craftwater 2025).

2.1 Project Location and Environmental Setting
The majority of the project site is in the southeastern portion of the City, near the boundary with unincorporated Los Angeles County (County) land, with a small portion of the project site falling within unincorporated Los Angeles County land as shown on Figure 2. The site includes a channelized segment of the Eaton Wash Channel, which flows north to south from the San Gabriel Mountains north of the site to the Rio Hondo River approximately 5 miles southeast of the site, and the north segment of the Thorndale sidewalk adjacent to Willard Elementary School. The primary location for the proposed facilities is a City -owned property east of the channel, which is vacant and disturbed. Most of the project site is flat, with the western side sloping down toward the concrete channel. The project site sits approximately 25 feet above the invert of the concrete Eaton Wash Channel, with an approximately 17-foot-high, steep embankment slope separating the channel access road at the top of the channel wall from the project site elevation. The property features scattered trees and shrubs, debris from prior vegetation -removal efforts, and remnants of former uses such as wooden railings and planter boxes, a concrete foundation, chain-link perimeter fencing, and a wooden sign. The southeastern portion of the project site is on Southern California Edison (SCE) owned property within SCE overhead electrical transmission right-of-way that features two steel towers. The land within the SCE right-of-way is currently leased to a commercial nursery and is used to grow and store container plants. The Eaton Wash Channel is maintained by the LA County Flood Control District, who has a 100 -foot-wide easement around the channel and maintenance roads on both sides of the channel . West of the channel, the project site includes a portion of the City-owned Eaton Blanche Park, featuring mature trees along the edge of the channel and a grass field that abuts the park’s playground, walking paths, and picnic areas to the northwest. This western portion of the site is mostly flat, then slopes down toward the Eaton Wash Channel. Farther northwest in the park are tennis courts, a basketball court, benches and picnic tables, shade structures, and a restroom building.

Both sides of the project site are mostly flat but slope down toward the concrete channel. The project site totals approximately 3.91 acres.

The site is in a developed part of the City that primarily features single -family residences and institutional uses.

To the north, Exer Urgent Care clinic (urgent care clinic) abuts the site followed by East Del Bar Boulevard and Ability First. The urgent care clinic facility is within the City -owned parcel and Exer Urgent Care leases the land for their use. To the northeast of the site, the site abuts the SCE easement area, followed by the Boys & Girls Club of Pasadena – Slavik Branch (Boys & Girls Club), Willard Elementary School, Madre Street, CALRegional Pasadena adult education center, and a church. To the east, the site abuts single family residences. To the south, the site abuts the SCE easement area, followed by single family residences. To the west, the site abuts the Eaton Wash Channel, followed by Eaton Blanche Park and single family residences. Regional access to the site is from Interstate (I) 210, which is approximately 0.4 miles to the north. Direct access to the eastern part of site is from Thorndale Road and Grayburn Road, each of which dead -ends at existing gates leading to the City property and the SCE right-of-way, along with a maintenance road along the Eaton Wash Channel’s eastern bank that connects to East Del Mar Boulevard. Access to th e western part of the project site is from Oneida Street, La Presa Drive, and Millicent Way, with a small parking lot connected to Millicent Way. The portion of the project site within the City is designated as Open Space and Institutional in the City’s Ge neral Plan Land Use Diagram (City of Pasadena

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 4
JUNE 2026
2025a) and is zoned as Open Space and Public, Semi -Public in the City’s Zoning Map (City of Pasadena 2025b).

The project site within unincorporated LA County is designated as Public and Semi -Public in the County’s Land Use Policy (County of Los Angeles 2014) and is zoned as R-1 Single Family Residence in the County’s Zoning Map (County of Los Angeles 2025).

2.2 Project Characteristics
The project entails constructing and operating a stormwater capture, treatment, and infiltration facility on a vacant property east of the Eaton Wash Channel, developing passive park uses, a dog park, and a community garden within the project site, and constructing a pedestrian bridge over the channel connecting the new features east of Eaton Wash to Eaton Blanche Park. The project is currently in the design phase, and the City has developed certain design and engineering assumptions for purposes of definin g the project for informational purposes and conducting environmental impact review pursuant to CEQA. Actual details of the project may end up varying from the information provided below.

2.2.1 Stormwater Capture System
The stormwater capture and treatment facility would intercept stormwater and dry -weather flow from the Eaton Wash Channel and divert it into a subterranean concrete basin. The project’s stormwater capture features are shown on Figure 3 and described below.

Stormwater Diversion Infrastructure and Pretreatment Devices A diversion structure would be installed in the bottom of the Eaton Wash Channel to collect flows and send water into a 20-inch-diameter ductile iron diversion pipeline that would be installed via trench. Diverted water would flow through the diversion pipeline, through a trash trap, and then be pumped to a pretreatment filter unit to remove debris, sediments, and solids present in the runoff . The pump and pretreatment unit would be installed in underground vaults with hatches for personnel access. The pret reatment device would be a hydrodynamic separator, which directs water through a screen to filter out large debris and into a cylindrical separation chamber where water swirls and forces particles out of the runoff, settling them in an isolated sump. Hydro carbons float to the top of the water surface and are prevented from being transported downstream.

The project would divert flows from a concrete channel that would otherwise continue downstream to existing engineered recharge infrastructure and, therefore, does not support downstream habitat. The volume of flow captured by the project represents a negl igible percentage of the total flow regularly available for capture in the Eaton Wash Channel on an annual basis. The City of Pasadena does not intend to claim any additional "right" to the water that is diverted from the channel. This is consistent with t he Raymond Basin Management Board guidance described in their letter of support dated July 30, 2025.

Storage Reservoir and Infiltration Galler y
After pretreatment, water would flow into the underground storage reservoir installed beneath the vacant City property. The underground storage reservoir would have a capacity of 3.4 acre -feet and would have an area of approximately 0.59 acres, according to preliminary design information. Existing vegetation and remnant hardscape features would be removed from the reservoir area and earthen material would be excavated, removed, and hauled off site for reuse or disposal. The underground reservoir would be fo rmed as a series of precast cells made of

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 5
JUNE 2026
reinforced, high-strength concrete, creating the infiltration gallery, that would be hauled to the site on flatbed trucks, lowered into place by a crane, and grouted together to form a single chamber. The reservoir would feature two personnel access points with stairs leading down from a hatch.

The reservoir would be designed to facilitate infiltration of captured stormwater, allowing water to seep into the underlying aquifer and providing natural filtration through the soil. To reduce the size of the reservoir and maximize treatment capacity, the system would not be designed to handle all captured storm flows solely through infiltration; during periods of heavy flow, some water would be pumped out of the reservoir and filtered again for discharge back into the Eaton Wash Channel.

Discharge System and Treatment
During smaller storm events, stormwater collected by the system is anticipated to infiltrate into the soils beneath the storage reservoir and infiltration gallery.

During larger storm events that fill up the reservoir, water would flow into a flow-control structure with a valve to regulate flow into an outlet pipe and through a post -treatment filter system . The filter would provide additional pollutant removal prior to discharging water back into the outlet pipe flowing into the Eaton Wash Channel. Two manholes would be installed along the outlet pipe. A flap gate would be installed at the outlet point to the channel, preventing water from entering the outlet system.

2.2.2 Park Improvements
The proposed park would feature nature-based recreational and educational elements at a site that once housed similar uses as part of the previous Earthside Nature Center (Earthside). The elements being considered rely upon site context, history, stakehold er and public input, and overall City needs. The location of this space, adjacent to the Eaton Wash Channel, provides an opportunity to re -create plant communities typically found near waterways, highlight other native plant communities, and create tailored gardens that support education and wildlife.

In addition to the extensive underground stormwater capture and infiltration system, filtered stormwater would be brought to the surface of the proposed park for interpretive water features and further filtration. At the Welcome Plaza, water bubbles would surface in a ring of river rocks creating a stormwater spring, meant to resemble a natural spring. An educational kiosk with interpretive signs at the Welcome Plaza would explain the stormwater capture system and detail different types of natural riparian ecosystems that can be found currently and historically in the watershed. The stormwater spring would overflow into a series of culverts before discharging into the stormwater creek, meant to resemble a natural creek, and stormwater basin . The stormwater basin would be surrounded by riparian planting and interpretive signage.

The design team has been looking, and will continue to look, to the community for their input on desired amenities to be added to the proposed site design. From the initial conceptual design, the team sought to incorporate features in the park such as new trees, native plantings, passive recreation features, walking paths, outdoor classrooms, community gardens, a pedestrian bridge to connect to Eaton Blanche Park, and gathering areas with park seating.

Four community outreach meetings have taken place since the initial design was presented, and certain design elements have been changed and added as a result of the community’s input. The new project site’s surface improvement design includes community and pollinator gardens, an aboveground water feature, a do g park, a riparian garden, gathering areas, an outdoor classroom, and a pedestrian bridge connecting Eaton Blanche Park to the proposed project site. The surface improvements are further described below.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 6
JUNE 2026
Welcome Plaza
At the area of confluence of visitors arriving via pedestrian bridge from Eaton Blanche Park and from on-site parking, a paved pedestrian plaza would be developed. As visitors approach the new park from the bridge, the stormwater spring and an educational kiosk with interpretive signage would serve as a focal point. The paving of the plaza would have a pattern of scorelines and materials that represent the concept narrative of watersheds and solar systems, through pattern-making that resembles both planetary orbits and ripples in a body of water. Shade would be provided by trees and/or a shade structure integrated into the kiosk. The plaza surface would be separated from the adjacent parking and maintenance driveway by a raised curb, except for where the cen tral access road leaves the main parking area via a rolled curb controlled by removable bollards. In -ground mounted site furnishings, a drinking fountain, and bike racks would be provided.

Outdoor Classrooms
The project would include educational features intended to be used in partnership with nearby institutions such as Willard Elementary, the Boys & Girls Club, and CIS Academy, where student groups can use the space as an outdoor classroom and learn about th e site’s environmental benefits. A dedicated instruction area would be included next to the surface stormwater storage. This would consist of a decomposed granite (DG) outdoor “room” shaded by riparian trees or a permanent shade structure. Seating would be provided by a series of stone slabs arranged around a central low slab for instructional materials. Space for wheelchair and companion seating would be provided.

Educational Signage
Interpretive signage would help future visitors understand the history, context, and plant communities present on the site. Educational signage is proposed at the community garden, the entry kiosk, on the bridge, and in each gathering area. Sign materials are expected to be a mix of printed aluminum and laser-etched steel, depending on the location. Additional interpretive elements may be added throughout the project site in forms other than signage, such as sandblasting into concrete or boulders, or as sculptural elements.

Community and Educational Learning Garden s
A community garden and an educational learning garden with raised beds are proposed within the project site. The community garden would be located near the northern entrance to the site and the educational learned garden would be located within the SCE easement area. The community garden near the northern site entrance would be open to use by the public and made available for the site’s educational programming. The educational learning garden within the easement is anticipated to be maintained through a partnership with GroWorks, a community garden program to help students experience the outdoors and learn how food is grown. If beds are not allocated for community use, or if GroWorks no longer maintains the space, beds can be converted to native plant and/or wildflower showcases. A lockable storage shed is provided near the community garden in the northern area of the project site.

Gathering Spaces
At least two small gathering spaces would be included in the park, connected by accessible DG pathways. The spaces would include seating for 10 or fewer visitors, in the form of boulders, site furniture, and/or picnic tables.

Shade would be provided by trees and/or shade structures that reference the historic structure of Earthside.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 7
JUNE 2026
Dog Park
A fenced-in dog park, approximately 6,700 square feet in area, is proposed for the south end of the project site and would be accessed through a double gate to prevent off -leash dogs from easily escaping the enclosure. The dog park surface is anticipated to be DG stabilized with soil binder . Existing fallen logs could be retained as climbing features for dogs while preserving a natural aesthetic.

The dog park would be graded towards a centerline that directs surface flows to a protected drainage inlet. Th e inlet would convey runoff out of the dog park and into an adjacent biofiltration basin to treat any runoff . The biofiltration basin includes a 6-inch perforated PVC underdrain, which discharges flows to the subsurface infiltration gallery. From there, flows would mix with other project inflows prior to either infiltrating into the ground or being conveyed through the post-treatment filter and ultimately discharged to the channel.

2.2.3 Eaton Wash Channel Pedestrian Bridge
As currently designed, the pedestrian bridge is proposed to be a 160-foot-long, single-span, pre-fabricated structure that will span Eaton Wash and connect the new features east of Eaton Wash to Eaton Blanche Park. The bridge is anticipated to feature a 10 -foot-wide reinforced concrete deck with vertical picket guardrails and pipe handrails made of weathering steel. A gate will be installed on the Eaton Blanche Park side of the bridge to allow the City to prevent access when the park is not open.

Due to the approximately 19 -foot depth of undocumented fill beneath the bridge landings, each abutment will require deep foundations, consisting of four cast -in-place concrete drilled shafts per abutment, anticipated to be 30 feet long and 24 inches in diameter.

2.2.4 Parking and Access
A small parking lot would be provided at the north end of the site, accessed through a new, lockable vehicular gate at the southeast corner of the urgent care clinic parking lot. Nine new parking spaces would be provided, including one that is Americans with Disabilities (ADA) accessible. The parking lot would be laid out to also serve as a maintenance driveway and turn -around for maintenance trucks servicing the access hatches to the underground stormwater capture system. The parking lot would be paved with a combination of permeable pavers and open-cell pavers to allow infiltration of stormwater. Any remaining surface runoff would enter the site’s surface water features and eventually the subsurface infiltration gallery. Short-term bike parking would be provided on site adjacent to the Welcome Plaza.

On the SCE easement, Thorndale Road would be extended from where it dead -ends to provide vehicular and pedestrian access to the eastern portion of the project site. The vehicular access road extending from Thorndale Road would be for maintenance vehicles only and would be gravel. The pedestrian access extending from Thorndale Road would intersect with the pedestrian path leading to the western portion of the site or continue to amenities in the eastern portion of the site, such as a gathering area or commun ity garden. Additionally, the sidewalk along Thorndale Road, adjacent to Willard Elementary School, would be improved and would connect to the pedestrian path extending from Thorndale Road to allow for pedestrian access from nearby schools and the Boys & Girls Club to the project site.

A 12-foot-wide proposed road would connect the parking lot at the north end of the project site to a vehicular gate at the south end of the site, providing maintenance access to stormwater capture system hatches and fire truck

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 8
JUNE 2026
circulation. An 8-foot-wide vehicular DG lane travels down the center of the road, with 2-foot shoulders of drivable open-cell pavers on each side. The pavers would be seeded with wildflowers and planted with durable species that can withstand light foot traffic. Gates would be provided at all access points to the future park site, including at the Eaton Blanche Park side of the pedestrian bridge.

2.2.5 Site Cleanup and Slope Stabilization
Site cleanup activities would include removal of trash, trees, and existing features such as the concrete pad, embankment, terrace garden walls, wooden stairs and railing, and utility connections. A majority of the trees that would be removed are invasive species (see Section 3.4[e] for further discussion of tree removal). The construction contractor would provide proper slope stabilization for all areas of sloped embankment that are not being excavated or influenced by construction. Slope stabilization east of the Eaton Wash channel would include reconstruction of new fill slope, slope reconstruction with engineered compacted fill reinforced with geogrids , removal and recompaction of existing undocumented fill and loose alluvial soils from the slope face beneath areas where retaining walls and invasive trees are removed , and removal of invasive trees. All slope stability work limits would be defined within the contract documents.

2.2.6 Temporary Construction Access, Staging, and Closures Construction access would be coordinated with the urgent care facility, or with SCE (for use of their easement), or with LA County Flood Control District (for use of their channel maintenance road). Construction equipment, vehicles, and material would be staged and stored overnight on the project site with adequate site security. Construction staging for the underground storage reservoir modules would be located off site at the City -owned Kinneloa Yard located west of South Kinneloa Avenue at the intersecti on of South Kinneloa Avenue and Brandon Street or at a City-owned property south of the Vina Vieja Dog Park, east of the Eaton Wash Channel near the intersection of Avocado Avenue and Alameda Street (see Figure 1). The off site construction staging area located at Kinneloa Yard would be accessed via South Kinneloa Avenue and delivery trucks would travel to the project site via South Kinneloa Avenue and East Del Mar Boulevard. The off site construction staging area located at the property south of the Vina Vieja Dog Park would be accessed via Avocado Avenue and delivery trucks would travel to the project site via Avocado Avenue, Alameda Street, Sierra Madre Villa Avenue / Madre Street, and East Del Mar Boulevard. T he modules would remain on staged delivery truck beds until they are ready to be installed.

Most of Eaton Blanche Park is expected to remain open to the public during construction. The portion of the park proposed for the pedestrian bridge landing and access connections would be closed during construction of those features. Large deliveries of construction materials to the park, such as delivery of pre-fabricated bridge segments, may require short-term closure of the park in the grassy area near the proposed pedestrian bridge landing, for safety purposes. The project site and the area surrounding the project site, east of Eaton Blanche Park across the Eaton Wash Channel, are closed to the public and would remain closed to the public during construction.

2.3 Construction Phasing and Schedule
Table 1 presents the anticipated construction phasing, equipment usage, and duration assumed for the project for purposes of the environmental impact analysis in this MND. These assumptions were developed in consultation with the project design engineers f or consideration in Section 3.3, Air Quality; Section 3.6, Energy; Section 3.8, Greenhouse Gas Emissions; and Section 3.13, Noise. The total duration of project construction is anticipated to be approximately 22 months, with some phases overlapping. Typica l construction work hours

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 9
JUNE 2026
would be Monday through Friday, 7:00 a.m. to 7:00 p.m. Night work is not anticipated. Construction is anticipated to begin in July 2027.

Table 1. Anticipated Construction Phasing and Equipment Construction Phase Anticipated Equipment
Estimated
Duration
Demolition of project site structures/open space area Rubber-tired dozers 3 weeks Graders
Skid steer loaders
Haul trucks
Site preparation, clearing, and grubbing Rubber-tired dozers 3 weeks Tractors/loaders/backhoes
Generator sets
Haul trucks
Reservoir excavation Rubber-tired dozer 6 weeks
Tractors/loaders/backhoes
Skid steer loaders
Haul trucks
Reservoir construction Cranes 10 weeks
Rubber-tired dozers
Skid steer loaders
Installation of pipe, diversion structure, actuated valve, trash trap, pre-treatment unit, and pump
Cranes 9 weeks
Trenchers
Skid steer loaders
Haul trucks
Installation of outlet line, flow control structure, and cartridge filter treatment unit
Rubber-tired dozer 9 weeks
Skid steer loaders
Tractors/loaders/backhoes
Pedestrian bridge construction Tractors/loaders/backhoes 9 weeks Cranes
Project site improvements; installation of park space and walking path, bioswale planting/landscaping, installation of pavers, and other site improvements
Graders 19 weeks
Skid steer loaders
Pavers
Paving equipment
Rollers
Cement and mortar mixers
Air compressors
Aerial lifts

2.4 Project Operation
The park would be open from 7:00 a.m. to 8:00 p.m., seven days a week. The park facilities would be fenced in and gated with the gates closing every night. Visitors to the park would be from the local community or existing park users from Eaton Blanche Park.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 10
JUNE 2026
Once construction is complete, project operation is anticipated to entail routine maintenance performed by the City or the City’s contractors at the stormwater capture facility and other park features. Routine maintenance and operations would require up to three workers. Reservoir maintenance would entail removal of debris and pollutant constituents from the treatment devices, pump testing and c alibration, and cleaning the storage reservoir.

Maintenance to park components would entail tree trimming, landscape and garden care, walkway and pavement maintenance, furnishing and amenity cleaning, irrigation and drainage system services, and general repairs to lighting, signage, fencing, and other site elements as needed.

2.5 City of Pasadena Permits and Approvals
The City of Pasadena is the CEQA lead agency, with the Pasadena City Council holding primary responsibility for adopting this MND and approving the construction contract . Other City of Pasadena departments that would approve the project include Public Works; Planning; Parks, Recreation, and Community Services; and Water and Power. The project would also require the issuance of a grading and building permit by the City for the proposed site grading, plan review of structures, and ADA and fire code compliance

2.6 Other Required Permits and Approvals
Other project approvals from public agencies and SCE would include the following:
▪ Major Modification Permit and Discharge Permit issued by the LA County Flood Control District ▪ Access Easement issued by SCE
▪ Clean Water Act Section 404 Permit and Rivers and Harbors Act Section 408 Permit issued by the U.S.

Army Corps of Engineers
▪ Clean Water Act Section 401 Water Quality Certification by the Regional Water Quality Control Board (RWCQB) ▪ Streambed Alteration Agreement by CDFW
▪ Approval of a stormwater pollution prevention plan (SWPPP) in compliance with the Construction General Permit, issued by the State Water Resources Control Board (SWRCB).

16537 11
JUNE 2026
3 Initial Study Checklist

1. Project title:

Eaton Wash Stormwater Capture Project

2. Lead agency name and address:

City of Pasadena
100 North Garfield Avenue
Pasadena, California 91101

3. Contact person and phone number:

Dawn Petschauer, M.S., Stormwater Program Administrator Public Works Department
100 North Garfield Avenue
Pasadena, California 91101

4. Project location:

The project site is located in the southeastern portion of the City of Pasadena, along Eaton Wash Channel near the western termini of Thorndale and Grayburn Roads. The project’s improvements are primarily located along the east side of the Eaton Wash Channel, with a pedestrian bridge that crosses the Channel and pedestrian pathway impr ovements on the west side of the Channel within Eaton Blanche Park. The project also includes sidewalk improvements along the north segment of Thorndale Road.

The project is primarily located within the City of Pasadena (Los Angeles County, California), with a portion of the site extending into unincorporated Los Angeles County land. See Figure 1, Project Location, and Figure 2, Project Site.

5. Project sponsor’s name and address:

City of Pasadena
100 North Garfield Avenue
Pasadena, California 91101

6. General plan designation:

Pasadena: Open Space and Institutional
Los Angeles County: Public and Semi-Public

7. Zoning:

Pasadena: Open Space and Public, Semi Public
Los Angeles County: R-1 Single Family Residence

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 12
JUNE 2026

8. Description of project. (Describe the whole action involved, including but not limited to later phases of the project, and any secondary, support, or off-site features necessary for its implementation. Attach additional sheets if necessary):

Refer to Chapter 2, Project Description.

9. Surrounding land uses and setting: Briefly describe the project’s surroundings:

Refer to Section 2.1, Project Location and Environmental Setting.

10. Other public agencies whose approval is required (e.g., permits, financing approval, or participation agreement):

LA County Flood Control District; U.S. Army Corps of Engineers; SWRCB; RWQCB; CDFW

11. Have California Native American tribes traditionally and culturally affiliated with the project area requested consultation pursuant to Public Resources Code section 21080.3.1? If so, is there a plan for consultation that includes, for example, the determi nation of significance of impacts to tribal cultural resources, procedures regarding confidentiality, etc.?
Refer to Section 3.18, Tribal Cultural Resources, in this MND.

Environmental Factors Potentially Affected
The environmental factors checked below would be potentially affected by this project, involving at least one impact that is a “Potentially Significant Impact,” as indicated by the checklist on the following pages.

Aesthetics Agriculture and
Forestry Resources
Air Quality
Biological Resources Cultural Resources Energy
Geology and Soils Greenhouse Gas
Emissions
Hazards and Hazardous
Materials
Hydrology and Water Quality Land Use and
Planning
Mineral Resources
Noise Population and
Housing
Public Services
Recreation Transportation Tribal Cultural Resources Utilities and Service Systems Wildfire Mandatory Findings of Significance

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 13
APRIL 2026
Determination (To be completed by the Lead Agency)
On the basis of this initial evaluation:

I find that the proposed project COULD NOT have a significant effect on the environment, and a NEGATIVE DECLARATION will be prepared.

I find that although the proposed project could have a significant effect on the environment, there will not be a significant effect in this case because revisions in the project have been made by or agreed to by the project proponent. A MITIGATED NEGATIVE DECLARATION will be prepared.

I find that the proposed project MAY have a significant effect on the environment, and an ENVIRONMENTAL IMPACT REPORT is required.

document pursuant to applicable legal standards, and (2) has been addressed by mitigation measures based on the earlier analysis as described on attached sheets. An ENVIRONMENTAL IMPACT REPORT is required, but it must analyze only the effects that remain to be addressed.

I find that although the proposed project could have a significant effect on the environment, because all potentially significant effects (a) have been analyzed adequately in an earlier ENVIRONMENTAL IMPACT REPORT or NEGATIVE DECLARATION pursuant to applicable standards, and (b) have been avoided or mitigated pursuant to that earlier ENVIRONMENTAL IMPACT REPORT or NEGATIVE DECLARATION, including revisions or mitigation measures that are imposed upon the proposed project, nothing further is required.

April 3, 2026
Prepared By Date
Alex Hardy
Printed Name

Reviewed By Date

Printed Name
Negative Declaration/Mitigated Negative Declaration adopted on:

Adoption attested to by:

Signature Date

Printed Name

BrentMaue(Apr7,202608:43:45PDT) 04/07/2026
BrentMaue

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 14
JUNE 2026
Evaluation of Environmental Impacts

1. A brief explanation is required for all answers except “No Impact” answers that are adequately supported by the information sources a lead agency cites in the parentheses following each question. A “No Impact” answer is adequately supported if the referenc ed information sources show that the impact simply does not apply to projects like the one involved (e.g., the project falls outside a fault rupture zone). A “No Impact” answer should be explained where it is based on project -specific factors as well as ge neral standards (e.g., the project would not expose sensitive receptors to pollutants, based on a project - specific screening analysis).

2. All answers must take account of the whole action involved, including off-site as well as on-site, cumulative as well as project-level, indirect as well as direct, and construction as well as operational impacts.

3. Once the lead agency has determined that a particular physical impact may occur, then the checklist answers must indicate whether the impact is potentially significant, less than significant with mitigation, or less than significant. “Potentially Significant Impact” is appropriate if there is substantial evidence that an effect may be significant. If there are one or more “Potentially Significant Impact” entries when the determination is made, an Environmental Impact Report (EIR) is required.

4. “Negative Declaration: Less Than Significant With Mitigation Incorporated” applies where the incorporation of mitigation measures has reduced an effect from “Potentially Significant Impact” to a “Less Than Significant Impact.” The lead agency must describe the mitigation measures, and briefly explain how they reduce the effect to a less than significant level.

5. Earlier analyses may be used where, pursuant to the tiering, program EIR, or other CEQA process, an effect has been adequately analyzed in an earlier EIR or negative declaration. Section 15063(c)(3)(D). In this case, a brief discussion should identify the following:
a. Earlier Analysis Used. Identify and state where they are available for review. b. Impacts Adequately Addressed. Identify which effects from the above checklist were within the scope of and adequately analyzed in an earlier document pursuant to applicable legal standards, and state whether such effects were addressed by mitigation measures based on the earlier analysis. c. Mitigation Measures. For effects that are “Less Than Significant With Mitigation Measures Incorporated,” describe the mitigation measures which were incorporated or refined from the earlier document and the extent to which they address site-specific conditions for the project.

6. Lead agencies are encouraged to incorporate into the checklist references to information sources for potential impacts (e.g., general plans, zoning ordinances). Reference to a previously prepared or outside document should, where appropriate, include a ref erence to the page or pages where the statement is substantiated.

7. Supporting Information Sources: A source list should be attached, and other sources used or individuals contacted should be cited in the discussion.

8. This is only a suggested form, and lead agencies are free to use different formats; however, lead agencies should normally address the questions from this checklist that are relevant to a project’s environmental effects in whatever format is selected.

9. The explanation of each issue should identify:
a. the significance criteria or threshold, if any, used to evaluate each question; and b. the mitigation measure identified, if any, to reduce the impact to less than significance

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 15
JUNE 2026

3.1 Aesthetics

Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
I. AESTHETICS – Except as provided in Public Resources Code Section 21099, would the project:
a) Have a substantial adverse effect on a
scenic vista?
b) Substantially damage scenic resources,
including, but not limited to, trees, rock
outcroppings, and historic buildings within a
state scenic highway?

c) In non-urbanized areas, substantially
degrade the existing visual character or
quality of public views of the site and its
surroundings? (Public views are those that
are experienced from [a] publicly accessible
vantage point). If the project is in an
urbanized area, would the project conflict
with applicable zoning and other regulations
governing scenic quality?

d) Create a new source of substantial light or
glare which would adversely affect day or
nighttime views in the area?

a) Would the project have a substantial adverse effect on a scenic vista? Less-Than-Significant Impact. Scenic vistas generally refer to views of expansive open space areas or other natural features, such as mountains, undeveloped hillsides, large natural water bodies, or coastlines.

Certain urban settings or features, such as a striking or renowned skyline, may also represent a scenic vista. Scenic vistas, as assessed under CEQA, are generally those that are accessible from public vantage points, such as public roadways and parks.

The City’s General Plan Open Space and Conservation Element, which provides guidance and policies for the management of the City’s natural resources, does not specifically list or identify any designated scenic vistas or specific scenic resources in the City. However, locations in the City offer distant views of the San Gabriel Mountains, which provide scenic value to residents and visitors (City of Pasadena 2012). The project site is in a developed part of the City that primarily features single-family residences and institutional uses. Institutional uses include an urgent care clinic abutting the site to the north, and to the northeast of the site, the Boys & Girls Club, Willard Elementary School, CALRegional Pasadena adult education center, and a church. Eaton Blanche Park and public streets and sidewalks in the vicinity of the project site offer views of the San Gabriel Mountains that are typically obscured by the presence of mature trees and buildings in the foreground . There are no unobstructed scenic vistas of the mountains within the area surrounding the project site. Various trails in the mountains and foothills miles north of the site offer expansive scenic vistas of the city below. Eaton Blanche Park and the rest of the project site would be

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 16
JUNE 2026
limited to distant elements in those views and are not key focal points from those public vantagepoints, as the site would blend in with the rest of its developed surroundings.

Project construction would result in temporary visual changes to the park, including the presence of excavated areas and staging of construction equipment. Off site construction staging areas would also be visible from residences located adjacent to the proposed staging areas. Visible construction features would not obstruct scenic vistas. Operation of the project would alter views compared to pre -construction conditions; however, the project’s stormwater infrastructure would mostly be located underground a nd would not be visible to the public during project operation. Other project components would include passive park uses, a dog park, and a community garden that are intended in part as improvements to the visual environment, as described in Section 2.2.2, Park Improvements, of this IS/MND . The pedestrian bridge would be visible from portions of Eaton Blanche Park and from the street and sidewalk of Del Mar Boulevard looking south down Eaton Wash; however, the pedestrian bridge would be designed as an aesth etically pleasing component of the park, and would be partially shield ed from off-site views by the existing trees along Eaton Wash. The proposed changes would not be a focal point of distant views of the area from public trails in the mountains and foothills to the north. Because the project would not obstruct or negatively affect scenic vistas, impacts would be less than significant.
b) Would the project substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway? No Impact. There are no designated state scenic highways in the vicinity of the project site. The nearest federal byway is Route 110 (State Route 110/Interstate 110), located approximately 3.5 miles west of the project site (Caltrans 2025). Additionally, the nearest eligible scenic highway is Route 210, located approximately 4 miles northwest of the project site (Caltrans 2025). Due to intervening development and distance, the project site is not visible from either route. Therefore, the project would not s ubstantially damage scenic resources within a state scenic highway and no impact would occur. c) In non-urbanized areas, would the project substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from a publicly accessible vantage point). If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality?
No Impact. Per PRC Section 21071, an “urbanized area” is defined as follows:
(a) An incorporated city that meets either of the following criteria:
(1) Has a population of at least 100,000 persons. [or]
(2) Has a population of less than 100,000 persons if the population of that city and not more than two contiguous incorporated cities combined equals at least 100,000 persons.”
The project site is located in the incorporated City of Pasadena, which has a population of 138,669 persons as of the 2020 census (U.S. Census Bureau 2020); therefore, the project site is considered to be located in an urbanized area.

As discussed in Section 3.1(a), the project site is not visible from any prominent public viewpoints.

Temporary visible elements associated with the project include construction equipment, staging activities,

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 17
JUNE 2026
and temporary fencing to be included for safety and security purposes. Visual impacts resulting from construction activities would be temporary, ceasing upon completion of construction.

The project would comply with any applicable zoning or other regulations governing scenic quality. The project site is not subject to overlay zones or other such designations specific to scenic resources or quality.

The proposed stormwater capture and treatment facility would be located primarily underground. In addition, the project would include the passive park uses, a dog park, and a community garden described in Section 2.2.2, which would enhance the park’s visual quality. Portions of the pedestrian bridge would be visible from Eaton Blanche Park and from Del Mar Boulevard looking south down Eaton Wash; however, the pedestrian bridge would be designed as an aesthetically pleasing component of the site and would be partially shielded from view by the existing trees along Eaton Wash. The project would result in the use of the site as a park and its use would not present elements that are visually incompatible with the existing setting. Implementation of the project would not conflict with the applicable zo ning and other regulations governing scenic quality. No impact would occur.
d) Would the project create a new source of substantial light or glare which would adversely affect day or nighttime views in the area?
Less-Than-Significant Impact. The project site is located in an urban area with existing sources of nighttime lighting from roadways, residences, and institutional uses, including an urgent care clinic abutting the site to the north, and to the northeast of the site, the Boys & Girls Club, Willard Elementary School, CALRegional Pasadena adult education center, and a church . No nighttime work would occur during construction of the project; therefore, construction activities would not result in a new source of nighttime light. Lighting that would be installed as part of the park development would comply with Chapter 17.40.080 of the Pasadena Municipal Code (PMC), which regulates outdoor lighting. The materials that would be used for the project would not be reflective in nature (such as large areas of glass) and would not serve as a new source of glare. Therefore, impacts would be less than significant.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 18
JUNE 2026

3.2 Agriculture and Forestry Resources

Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
II. AGRICULTURE AND FORESTRY RESOURCES – In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Dept. of Conservation as an optional model to use in assessing impacts on agriculture and farmland. In determining whether impacts to forest resources, including timberland, are significant environmental effects, lead agencies may refer to information compiled by the California Department of Forestry and Fire Protection regarding the state’s inventory of forest land, including the Forest and Range Assessment Project and the Forest Legacy Assessment project; and forest carbon measurement methodology provided in Forest Protocols adopted by the California Air Resources Board. Would the project:
a) Convert Prime Farmland, Unique Farmland,
or Farmland of Statewide Importance
(Farmland), as shown on the maps prepared
pursuant to the Farmland Mapping and
Monitoring Program of the California
Resources Agency, to non-agricultural use?

b) Conflict with existing zoning for agricultural
use, or a Williamson Act contract?
c) Conflict with existing zoning for, or cause
rezoning of, forest land (as defined in Public
Resources Code Section 12220(g)),
timberland (as defined by Public Resources
Code Section 4526), or timberland zoned
Timberland Production (as defined by
Government Code Section 51104(g))?

d) Result in the loss of forest land or
conversion of forest land to non-forest use?
e) Involve other changes in the existing
environment which, due to their location or
nature, could result in conversion of
Farmland, to non-agricultural use or
conversion of forest land to non-forest use?

a) Would the project convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use? No Impact. According to the California Important Farmland Finder database, the project site and its immediate surroundings are classified as “Urban and Built -Up Land” (DOC 2025a). The project would not be located on land classified as Farmland pursuant to the Farmland Mapping and Monitoring Program and would therefore not convert any Farmland to non-agricultural use. No impact would occur.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 19
JUNE 2026
b) Would the project conflict with existing zoning for agricultural use, or a Williamson Act contract? No Impact. The project site is zoned Open Space and Public, Semi Public. Surrounding the project site are areas zoned Residential and Institutional (City of Pasadena 2025b). The City does not contain any lands zoned for agricultural use. There are no existing lands under a Williamson Act contract within the City.

Therefore, the project would not conflict with existing zoning for agricultural use or a Williamson Act contract. No impact would occur.
c) Would the project conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code Section 12220(g)), timberland (as defined by Public Resources Code Section 4526), or timberland zoned Timberland Production (as defined by Government Code Section 51104(g))? No Impact. The project site and surrounding areas are entirely urbanized and are not zoned for , nor do they contain, any forest land or timberland. Therefore, the project would not conflict with or cause the rezoning or conversion of forest land or timberland. No impact would occur. d) Would the project result in the loss of forest land or conversion of forest land to non-forest use? No Impact. Refer to Section 3.2(c). No impact would occur. e) Would the project involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use or conversion of forest land to non-forest use? No Impact. Refer to Sections 3.2(a)–(d). The project site is located in an urbanized area with no existing agricultural uses, Farmland, or forest lands in the vicinity. The City does not contain any lands zoned for agricultural uses. Therefore, the project would not involve other changes that could result in conversion of Farmland to non-agricultural use or conversion of forest land to non-forest use. No impact would occur.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 20
JUNE 2026

3.3 Air Quality

Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
III. AIR QUALITY – Where available, the significance criteria established by the applicable air quality management district or air pollution control district may be relied upon to make the following determinations. Would the project:
a) Conflict with or obstruct implementation of
the applicable air quality plan?
b) Result in a cumulatively considerable net
increase of any criteria pollutant for which
the project region is non-attainment under
an applicable federal or state ambient air
quality standard?

c) Expose sensitive receptors to substantial
pollutant concentrations?
d) Result in other emissions (such as those
leading to odors) adversely affecting a
substantial number of people?

This section is based on technical analysis conducted by Dudek, including quantitative estimates of air pollutant emissions based on assumptions developed in consultation with the project engineers. The modeling assumptions and results of the emissions estimates are provided as Appendix A, Air Quality and Greenhouse Gas Emissions Modeling, to this IS/MND.
a) Would the project conflict with or obstruct implementation of the applicable air quality plan? Less-Than-Significant Impact. The project site is located within the South Coast Air Basin (SCAB) and is within the jurisdictional boundaries of the South Coast Air Quality Management District (SCAQMD).

Air districts are delegated with the task of adopting an air quality management plan (AQMP), which is a comprehensive document outlining an air pollution control program for attaining the California Ambient Air Quality Standards (CAAQS) and National Ambient Air Quality Standards (NAAQS). SCAQMD administers SCAB’s AQMP, which is a comprehensive document outlining an air pollution control program for attaining all CAAQS and NAAQS. The most recent adopted AQMP for the SCAB is the 2022 AQMP, which was adopted by SCAQMD’s Governing Board in December 2022 (SCAQMD 2022).

The purpose of a consistency finding is to determine if a project is inconsistent with the assumptions and objectives of the regional air quality plans and thus would interfere with the region’s ability to comply with federal and state air quality standards. SCAQMD has established criteria for determining consistency with

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 21
JUNE 2026
the currently applicable AQMP in Chapter 12, Sections 12.2 and 12.3, in the SCAQMD CEQA Air Quality Handbook. The criteria are as follows (SCAQMD 1993):
▪ Consistency Criterion No. 1: The project will not result in an increase in the frequency or severity of existing air quality violations or cause or contribute to new violations, or delay the timely attainment of air quality standards of the interim emissions reductions specified in the AQMP. ▪ Consistency Criterion No. 2: The project will not exceed the assumptions in the AQMP or increments based on the year of project buildout and phase.

To address the first criterion, project -generated criteria air pollutant emissions have been estimated and analyzed for significance and are addressed in Section 3.3(b). Detailed results of this analysis are included in Appendix A. As presented in Section 3.3(b), construction and operation of the project would not generate air pollutant emissions that would exceed SCAQMD’s thresholds. Therefore, the project would not result in an increase in the frequency or severity of existing air quality violations. As s uch, the project would not conflict with Consistency Criterion No. 1 of the SCAQMD CEQA Air Quality Handbook.

The second criterion regarding the project’s potential to exceed the assumptions in the AQMP or increments based on the year of project buildout and phase is primarily assessed by determining consistency between the project’s land use designations and its potential to generate population growth. In general, projects are considered consistent with, and not in conflict with or obstructing implementation of, the AQMP if the growth in socioeconomic factors is consistent with the underlying regional plans used t o develop the AQMP (per Consistency Criterion No. 2 of the SCAQMD CEQA Air Quality Handbook). SCAQMD primarily uses demographic growth forecasts for various socioeconomic categories (e.g., population, housing, employment by industry) developed by the South ern California Association of Governments (SCAG) for its Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS), “Connect SoCal” (SCAG 2020).1 This document, which is based on general plans for cities and counties in the SCAB, is used by SCAQMD to develop the AQMP emissions inventory (SCAQMD 2022).2 The SCAG RTP/SCS and the associated Regional Growth Forecast are generally consistent with the local plans; therefore, the 2022 AQMP is generally consistent with local government plans.

As discussed in Chapter 2, Project Description, of this IS/MND, the project site is designated as Open Space and Institutional in the City’s Land Use Diagram (City of Pasadena 2025a) and is zoned as Open Space and Public, Semi-Public in the City’s Zoning Map (City of Pasadena 2025b). This designation allows for a variety of active and passive recreational land uses while promoting the preservation and maintenance of undeveloped lands and natural areas. The project would primarily involve constructing and op erating a stormwater capture, treatment, and infiltration facility, with ancillary park uses, including outdoor educational areas, a community garden, and a dog park; as such, the project would be consistent with the underlying land use designation, and no General Plan Amendment would be required. 1 Although there is a newer version of the SCAG RTP/SCS, adopted in 2024, the demographics from the 2020 RTP/SCS are still applicable for the purposes of the air quality analysis, because those are the ones included and used in the current AQMP. 2 Information necessary to produce the emissions inventory for the SCAB is obtained from SCAQMD and other governmental agencies, including the California Air Resources Board (CARB), California Department of Transportation (Caltrans), and SCAG.

Each of these agencies is responsible for collecting data (e.g., industry growth factors, socioeconomic projections, travel activity levels, emission factors, emission speciation profile, and emissions) and developing methodologies (e.g., model and demographic forecast improvements) required to generate a comprehensive emissions inventory. SCAG incorporates these data into its Travel Demand Model for estimating/projecting vehicle miles traveled and driving speeds. SCAG’s socioeconomic and transportation activities projections in their 2020 RTP/SCS are integrated in the 2022 AQMP (SCAQMD 2022).

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 22
JUNE 2026
The Demographics and Growth Forecast within the SCAG RTP/SCS predicts that the City will experience an increase of 13,400 people and an employment increase of 24,000 jobs between 2016 and 2045 (SCAG 2020). The project would not result in a long -term increase to population or employment in the area; therefore, it would not conflict with the growth outlined in the SCAG RTP/SCS. Overall, the proposed project is consistent with the existing land use designation and implementation of the project would not genera te an increase in growth demographics that would conflict with existing projections within the region.

Accordingly, the project is consistent with the SCAG RTP/SCS forecasts. Thus, the project would not conflict with Consistency Criterion No. 2.

In summary, based on the considerations presented for the two criteria, impacts relating to the project’s potential to conflict with or obstruct implementation of the applicable AQMP would be less than significant. b) Would the project result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard? Less-Than-Significant Impact. Air pollution is largely a cumulative impact, and project-level thresholds of significance for criteria pollutants are used to determine whether a project’s individual emissions would have a cumulatively considerable contribution to air quality impacts. If a project’s emissions would exceed the SCAQMD significance thresholds, it would be considered to have a cumulatively considerable contribution. Conversely, projects that do not exceed the project -specific thresholds are gener ally not considered to be cumulatively significant.

A quantitative analysis was conducted to determine whether the proposed project might result in emissions of criteria air pollutants that may cause exceedances of the NAAQS or CAAQS or cumulatively contribute to existing nonattainment of the NAAQS or CAAQs. Criteria air pollutants include ozone (O3), nitrogen dioxide (NO2), carbon monoxide (CO), sulfur dioxide (SO2), particulate matter with an aerodynamic diameter less than or equal to 10 microns (PM 10), particulate matter with an aerodynamic diameter less than or equal to

2.5 microns (PM2.5), and lead. Pollutants that are evaluated herein include volatile organic compounds (VOCs) and oxides of nitrogen (NOx), which are important because they are precursors to O3, as well as CO, sulfur oxides (SOx), PM10, and PM2.5.

Regarding NAAQS and CAAQS attainment status,3 the SCAB is designated as a nonattainment area for the O3 and PM2.5 NAAQS and CAAQS, as well as for the PM10 CAAQS (CARB 2025).

The proposed project would result in emissions of criteria air pollutants for which the California Air Resources Board (CARB) and U.S. Environmental Protection Agency have adopted ambient air quality standards (i.e., the NAAQS and CAAQS). SCAQMD has adopted thresholds to address the significance of air quality impacts resulting from a project. A project would result in a substantial contribution to an existing air quality violation of the NAAQS or CAAQS for O 3, which is a nonattainment pollutant, if the project’s construction emissions would exceed SCAQMD’s VOC or NO x significance thresholds (shown in Table 2).

These emission -based thresholds for O 3 precursors are intended to serve as a surrogate for an “ozone significance threshold” (i.e., the potential for adverse O3 impacts to occur) because O3 itself is not emitted directly, and the effects of an individual project’s emissions of O 3 precursors (VOCs and NOx) on O3 levels 3 An area is designated as in attainment when it is in compliance with the NAAQS and/or the CAAQS. These standards for the maximum level of a given air pollutant that can exist in the outdoor air without unacceptable effects on human health or the public welfare are set by the U.S. Environmental Protection Agency and CARB, respectively. Attainment = meets the standards; attainment/ maintenance = achieves the standards after a nonattainment designation; nonattainment = does not meet the standards.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 23
JUNE 2026
in ambient air cannot be determined through air quality models or other quantitative methods. The SCAB is also nonattainment for the PM 10 CAAQS and the PM2.5 CAAQS and NAAQS . Although SCAQMD does have a threshold for lead, the project would not be a source of lead during construction or operation.

Therefore, lead was not evaluated herein.

Table 2. SCAQMD Air Quality Significance Thresholds
Criteria Pollutants Mass Daily Thresholds
Pollutant Construction ( Pounds per Day ) Operation ( Pounds per Day ) VOCs 75 55
NOx 100 55
CO 550 550
SOx 150 150
PM10 150 150
PM2.5 55 55
Leada 3 3
Odor Threshold
Odor Project creates an odor nuisance pursuant to SCAQMD Rule 402 Ambient Air Quality Standards for Criteria Pollutants c NO2 1-hour average
NO2 annual arithmetic mean
SCAQMD is in attainment; project is significant if it causes or contributes to an exceedance of the following attainment standards:

0.18 ppm (state)

0.030 ppm (state) and 0.0534 ppm (federal)
CO 1-hour average
CO 8-hour average
SCAQMD is in attainment; project is significant if it causes or contributes to an exceedance of the following attainment standards:
20 ppm (state) and 35 ppm (federal)

9.0 ppm (state/federal)
PM10 24-hour average
PM10 annual average

10.4 g/m3 (construction)d

2.5 g/m3 (operation)

1.0 g/m3
PM2.5 24-hour average 10.4 g/m3 (construction)d

2.5 g/m3 (operation)
Source: SCAQMD 2023.

Notes: SCAQMD = South Coast Air Quality Management District; VOC s = volatile organic compounds; NO x = oxides of nitrogen; CO = carbon monoxide; SO x = sulfur oxides; PM 10 = coarse particulate matter; PM 2.5 = fine particulate matter; TAC = toxic air contaminant; NO2 = nitrogen dioxide; ppm = parts per million by volume; g/m3 = micrograms per cubic meter. a The phaseout of leaded gasoline started in 1976. Because gasoline no longer contains lead, the project is not anticipated to result in impacts related to lead; therefore, it is not discussed in this analysis. b TACs include carcinogens and noncarcinogens.
c Ambient air quality standards for criteria pollutants are based on SCAQMD Rule 1303, Table A-2, unless otherwise stated. d Ambient air quality thresholds are based on SCAQMD Rule 403.

Construction Emissions
The California Emissions Estimator Model (CalEEMod) Version 2022.1.1.30 was used to estimate emissions from construction of the project. CalEEMod is a statewide computer model developed in cooperation with air districts throughout the state to quantify criteria air pollutant emissions from a variety of land use projects, including recreational development.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 24
JUNE 2026
The proposed project would be constructed starting in July 2027 over a period lasting approximately 22 months, ending in April 2029.

Construction activities for the proposed project would include demolition of project site structures/open space area , site preparation, reservoir excavation and construction, installation of stormwater capture infrastructure including a pump, erection of a pedestrian bridge, and project site improvements such as installation of pavers and landscaping. These construction activities would result in the temporary addition of pollutants to the local airshed caused by on -site sources (e.g., off-road construction equipment, soil disturbance, and VOC off -gassing from architectural coatings and asphalt pavement application) and off - site sources (e.g., vendor trucks, haul trucks, and worker vehicle trips). Specifically, entrained dust results from the exposure of earth surfaces to wind from the direct disturbance and movement of soil, resulting in PM10 and PM2.5 emissions. Internal combustion engines used by construction equipment , haul trucks, vendor trucks (i.e., delivery trucks), and worker vehicles would result in emissions of VOCs, NOx, CO, SO2, PM10, and PM 2.5. Application of architectural coatings, such as exterior paint and other finishes, and application of asphalt pavement would also produce VOC emissions. Construction emissions can vary substantially from day to day depending on the level of activity; the specific type of operation; and, for dust, the prevailing weather conditions.

Proposed project construction emissions were estimated using a combination of CalEEMod default assumptions and information provided by the project engineer. Haul trucks would be required for material export of material debris. Demolition would result in approximately 135 tons of debris for export, which would require 4 daily one-way haul truck trips. Earthwork and grading would result in approximately 12,510 cubic yards of soil, which would require 38 daily one -way haul truck trips during the reservoir exca vation phase. Haul trucks were assumed to travel a one-way distance of 20 miles to the disposal site for material export, consistent with model defaults.

The construction equipment mix and vehicle trips used for estimating the project -generated construction emissions are shown in Table 3. For the analysis, it was assumed that heavy construction equipment would be operating at the site 5 days per week (22 days per month) during proposed project construction.4 Table 3. Construction Scenario Details
Construction
Phase
One -Way Vehicle Trips Equipment
Average
Daily
Worker
Trips
Average
Daily
Vendor
Truck Trips
Average
Daily Haul
Truck
Trips Equipment Type Quantity
Usage
Hours
Demolition of project
site structures/open
space area
14 4 4 Rubber-tired dozers 2 8
Skid steer loaders 1 8
Graders 2 8
Site preparation,
clearing, and
grubbing
20 4 4 Rubber-tired dozers 3 8
Generator sets 1 8
Tractors/loaders/backhoes 4 8
4 As shown in Table 3.3 -2, most equipment was assumed to operate for up to 8 hours per day. In reality, it is anticipated that equipment would be used for less than 8 hours a day, when considering mandated worker breaks and that equipment would only be operated when needed; in addition, it is anticipated that the construction areas would be in infill areas and that not every piece of equipment could be in operation at the same time. Therefore, the equipment usage hours are anticipated to be conservative.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 25
JUNE 2026
Table 3. Construction Scenario Details
Construction
Phase
One -Way Vehicle Trips Equipment
Average
Daily
Worker
Trips
Average
Daily
Vendor
Truck Trips
Average
Daily Haul
Truck
Trips Equipment Type Quantity
Usage
Hours
Reservoir excavation 18 4 38 Rubber-tired dozers 2 8
Skid steer loaders 2 8
Tractors/loaders/backhoes 3 8
Reservoir
construction
14 4 0 Cranes 1 8
Rubber-tired dozers 2 8
Skid steer loaders 2 8
Installation of pipe,
diversion structure,
actuated valve, trash
trap, pre-treatment
unit, and pump
14 4 4 Cranes 1 8
Trenchers 2 8
Skid steer loaders 2 8
Installation of outlet
line, flow control
structure, and
cartridge filter
treatment unit
18 4 0 Rubber-tired dozers 2 8
Skid steer loaders 2 8
Tractors/loaders/backhoes 3 8
Pedestrian bridge
construction
10 4 0 Tractors/loaders/backhoes 3 8
Cranes 1 8
Project site
improvements
18 4 0 Graders 1 8
Skid steer loaders 1 8
Pavers 1 8
Paving equipment 1 8
Rollers 1 8
Cement and mortar mixers 1 8
Air compressors 1 6
Aerial lifts 1 8
Note: See Appendix A for additional details.

The project would be required to comply with SCAQMD Rule 403 to control dust emissions generated during any dust-generating activities. Standard construction practices that would be employed to reduce fugitive dust emissions include watering of the active dust areas two times per day, with additional watering depending on weather conditions. The CalEEMod default values were used for estimating fugitive dust emissions from grading on site. The project would involve the application of architectural coating (e.g., paint and other finishes) for parking lot striping. The contractor is required to procure architectural coatings from a supplier that complies with the requirements of SCAQMD’s Rule 1113 (Architectural Coatings). Table 4 presents the estimated maximum daily construction emissions that would be generated during construction of the project. Details of the emission calculations are provided in Appendix A.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 26
JUNE 2026
Table 4. Estimated Maximum Daily Construction Criteria Air Pollutant Emissions Year
VOC NOx CO SOx PM10 PM2.5
Maximum Daily Emissions (Pounds per Day)
Summer a
2027 3.23 29.28 30.19 0.05 9.24 5.14
2028 3.77 33.91 42.91 0.08 1.99 1.34
Winter a
2027 2.31 23.95 24.68 0.06 6.95 3.69
2028 2.29 20.52 20.59 0.04 1.07 0.84
2029 0.94 8.15 13.20 0.02 0.55 0.33
Maximum of Summer and
Winter Emissions

3.77 33.77 42.86 0.08 9.20 5.13
SCAQMD Threshold 75 100 550 150 150 55
Threshold Exceeded? No No No No No No
Notes: VOC = volatile organic compound; NOx = oxides of nitrogen; CO = carbon monoxide; SOx = sulfur oxides; PM10 = coarse particulate matter; PM2.5 = fine particulate matter; SCAQMD = South Coast Air Quality Management District.

Emissions include compliance with SCAQMD Rule 403 and SCAQMD Rule 1113.

See Appendix A for complete results.
a “Summer” emissions are representative of the conditions that may occur during the O3 season (May 1 to October 31), and “winter” emissions are representative of the conditions that may occur during the balance of the year (November 1 to April 30).

As shown in Table 4, the project construction emissions would not exceed SCAQMD’s daily thresholds.

Therefore, construction impacts associated with criteria air pollutant emissions would be less than significant, and no mitigation measures are required.

Operational Emissions
Long-term operation of the project would generate minimal criteria air pollutant (including VOC, NOx, PM10, and PM2.5) emissions, which would occur from mobile sources including vehicular traffic due to visitors and occasional maintenance workers accessing the site, and the use of landscape equipment and occasional striping during ongoing maintenance.

The project would feature passive recreational areas, including outdoor space for education, a community garden, and a small dog park, which would generate a nominal increase in weekday and weekend trips .

Additionally, routine operations would include occasional maintenance, which would require up to three staff members to visit the site per maintenance day. As discussed in Section 3.17, Transportation, the ancillary recreational uses, combined with staff trips, would generate less than 110 daily trips ,5 and the project would therefore be presumed to have a less -than-significant impact relating to vehicle miles 5 This threshold ties directly to the LCI Technical Advisory and notes that CEQA provides a categorical exemption for existing facilities, including additions to existing structures of up to 10,000 square feet, as long as the project is in an area where public infrastructure is available to allow for maximum planned development and the project is not in an environmentally sensitive area (14 CCR 15301[e][2]). Typical project types for which trip generation increases relatively linearly with building footprint (i.e., general office building, single-tenant office building, office park, and business park) generate or attract an additional 110 – 124 trips per 10,000 square feet. Therefore, absent substantial evidence otherwise, it is reasonable to conclude that the addition of 110 or fewer trips could be considered not to lead to a significant impact.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 27
JUNE 2026
traveled (VMT). Mobile sources were therefore assumed to have a negligible impact on operational air pollutant emissions.

Other ongoing maintenance would include the occasional re-striping of the small parking areas and the use of offroad combustion equipment for landscaping. Because the scope of maintenance would be limited, given the project’s size and passive design, these sources were also assumed to have a negligible impact on operational emissions.

Overall, the project is not anticipated to represent a large source of criteria air pollutant emissions during long-term operation, and emissions were not quantified herein. Operational impacts associated with criteria air pollutant emissions would be less than significant.

Health Impacts of Criteria Air Pollutants
Construction of the project would generate criteria air pollutant emissions; however, the project would not exceed the SCAQMD mass-emission thresholds as shown in Table 4. Long-term operations would also not represent a significant source of emissions.

The SCAB is designated as nonattainment for O3 for the NAAQS and CAAQS. Thus, existing O3 levels in the SCAB are at unhealthy levels during certain periods. The health effects associated with O3 generally relate to reduced lung function. Because the project would not involve construction activities that would result in O3 precursor emissions (VOC or NO x) that would exceed the SCAQMD thresholds, the project is not anticipated to substantially contribute to regional O3 concentrations and associated health impacts. Similar to construction, no SCAQMD threshold would be exceeded during operation.

In addition to O 3, NOx emissions contribute to potential exceedances of the NAAQS and CAAQS for NO 2 (since NO2 is a constituent of NO x). Exposure to NO2 can cause lung irritation, bronchitis, and pneumonia and can lower resistance to respiratory infections. As demonstrated in Table 4 and discussed above, project construction would exceed the SCAQMD thresholds for NO x emissions. Thus, the project would not be expected to exceed the NOx standards or contribute to associated health effects.

CO tends to be a localized impact associated with congested intersections. CO competes with oxygen, often replacing it in the blood, reducing the blood’s ability to transport oxygen to vital organs. The results of excess CO exposure can include dizziness, fatigue, and impairment of central nervous system functions. CO hotspots, as discussed in Section 3.3(c), would have a less-than-significant impact. Thus, the project’s CO emissions would not contribute to the health effects associated with this pollutant.

The SCAB is designated as nonattainment for PM 10 under the CAAQS and nonattainment for PM 2.5 under the NAAQS and CAAQS. Particulate matter contains microscopic solids or liquid droplets that are so small that they can get deep into the lungs and cause serious health problems. Particulate matter exposure has been linked to a variety of problems, i ncluding premature death in people with heart or lung disease, nonfatal heart attacks, irregular heartbeat, aggravated asthma, decreased lung function, and increase d respiratory symptoms such as irritation of the airways, coughing, or difficulty breathing (EPA 2016). As with O3 and NOx, the project would not generate emissions of PM 10 or PM2.5 that would exceed SCAQMD’s thresholds. Accordingly, the project ’s PM10 and PM2.5 emissions are not expected to cause any increase in related regional health effects for these pollutants.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 28
JUNE 2026
In summary, as shown in Table 4 and explained above, the project would not result in any potentially significant contribution to local or regional concentrations of nonattainment pollutants and would not result in a significant contribution to the adverse health impacts associated with those pollutants. Impacts would be less than significant.

Cumulative
Due to the cumulative nature of air quality impacts, the threshold for determining if a project significantly contributes to a cumulative impact is based on whether the project exceeds established project -level thresholds. Therefore, a qualitative assessme nt of the cumulative projects indicates that the project's contribution would not be considerable because the incremental emissions increase from the project would be less than significant.
c) Would the project expose sensitive receptors to substantial pollutant concentrations? Less-Than-Significant Impact with Mitigation Incorporated. In addition to the emission -based thresholds listed in Table 2, SCAQMD also recommends the evaluation of localized air quality impacts to sensitive receptors in the immediate vicinity of the project as a result of construction activities. Such an evaluation is referred to as a localized significance threshold (LST) a nalysis. The LST analysis focuses on construction equipment and includes mobile source emissions within a 0.25-mile radius of the project site to represent localized emissions. For project sites of 5 acres or less, the SCAQMD LST Methodology (2009) includes lookup tables that can be used to determine the maximum allowable daily emissions that would satisfy the localized significance crite ria (i.e., the emissions would not cause an exceedance of the applicable concentration limits for NO2, CO, PM10, and PM2.5) without performing project-specific dispersion modeling. The project would disturb less than 5 acres per day, so it is appropriate to use the lookup tables for the LST evaluation.

The LST significance thresholds for NO2 and CO represent the allowable increase in concentrations above background levels in the vicinity of a project site that would not cause or contribute to an exceedance of the relevant ambient air quality standards, while the threshold for PM 10 represents compliance with SCAQMD Rule 403 (Fugitive Dust). The LST significance threshold for PM 2.5 is intended to ensure that construction emissions do not contribute substantially to existing exceedances of the PM 2.5 ambient air quality standards. The allowable emission rates depend on the following parameters:
▪ Source-receptor area (SRA) in which the project is located ▪ Size of the project site
▪ Distance between the project site and the nearest receptor (any areas where persons can be situated for an hour or longer at a time)
The project site is located in SRA 8 (West San Gabriel Valley). LST pollutant screening level concentration data is currently published for 1-, 2-, and 5-acre sites for varying distances. The maximum number of acres disturbed on the peak day was estimated using the Fact Sheet for Applying C alEEMod to Localized Significance Thresholds (SCAQMD 2014). During grading activities, fugitive dust can be generated from the movement of dirt on the project site. CalEEMod estimates dust from dozers moving dirt around, dust from graders or scrapers leveling the land, and loading or unloading dirt into haul trucks. Each of those activities is calculated differently in CalEEMod, based on the number of acres traversed by the grading equipment.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 29
JUNE 2026
Only some pieces of equipment generate fugitive dust in CalEEMod. The CalEEMod manual identifies various equipment and the acreage disturbed in an 8-hour day. For example:
▪ Crawler tractors, graders, and rubber-tired dozers: 0.5 acres per 8-hour day ▪ Scrapers: 1 acre per 8-hour day
The LST lookup tables that can be used to determine the maximum allowable daily emissions are provided at increments of 1 acre, 2 acres, and 5 acres. Therefore, the analysis applies the LSTs for a 2 -acre disturbance area, which are presented in Table 5.

Per the SCAQMD’s Finalized LST Methodology, locations that an individual could remain for 24 hours (i.e., a residence, hospital, convalescent facility, hotel, etc.) should be considered to determine the threshold for PM10 and PM2.5 (SCAQMD 2009). The closest off-site receptors to the project site’s construction activity are residences southeast of the project site. The minimum-recommended distance of 25 meters has been used to determine LST receptor distance for emissions of NO x, CO, PM 10, and PM 2.5. Emissi ons from peak construction represent the most conservative emissions.

The LST threshold values from the SCAQMD lookup tables for SRA 8 (West San Gabriel Valley) are shown in Table 5.

Table 5. Construction Localized Significance Thresholds for SRA 8 (West San Gabriel Valley) Pollutant Threshold ( Pounds /Day)
NO2 98
CO 812
PM10 6
PM2.5 4
Source: SCAQMD 2009.

Notes: SRA = Source-Receptor Area; NO2 = nitrogen dioxide; CO = carbon monoxide; PM 10 = coarse particulate matter; PM 2.5 = fine particulate matter
Localized significance thresholds were determined based on the for a 2 -acre site at a distance of 25 meters (82 feet) from the nearest receptor.

Localized Significance Analysis
Construction activities associated with the project would result in temporary sources of on-site fugitive dust and construction equipment emissions. The maximum allowable daily emissions that would satisfy the SCAQMD localized significance criteria for SRA 8 are presented in Table 6 and compared to the maximum daily on-site construction and operational emissions.

Table 6. Construction Localized Significance Thresholds Analysis – Unmitigated Construction Year
NOx CO PM10 PM2.5
Pounds per Day
2027 28.87 29.92 8.87 5.05
2028 33.28 40.66 1.27 1.16
2029 8.01 12.50 0.29 0.26

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 30
JUNE 2026
Table 6. Construction Localized Significance Thresholds Analysis – Unmitigated Construction Year
NOx CO PM10 PM2.5
Pounds per Day
Maximum 33.28 40.66 8.87 5.05
SCAQMD LST Criteriaa 98 812 6 4
Threshold exceeded? No No Yes Yes
Notes: NOx = oxides of nitrogen; CO = carbon monoxide; PM 10 = particulate matter with a diameter less than or equal to 10 microns; PM2.5 = particulate matter with a diameter less than or equal to 2.5 microns; SCAQMD = South Coast Air Quality Management District; LST = localized significance threshold.

The values shown are the maximum summer or winter daily emissions results from CalEEMod.

Emissions include compliance with SCAQMD Rule 403 and SCAQMD Rule 1113.

The total values may not add up exactly due to rounding.

See Appendix A for detailed results.

As shown in Table 6, proposed construction activities would generate emissions in excess of site-specific LSTs for PM10 and PM2.5 without mitigation, resulting in a potentially significant impact. Mitigation Measure (MM) AQ-1, Fugitive Dust Control During Construction, and MM -AQ-2, Construction Equipment Emissions Reductions, which require site watering and minimum construction equipment emissions standards, would be incorporated into project construction to reduce potentially significant impacts. See “Miti gation Measures” subsection at the end of this section for full text of these mitigation measures.

The maximum daily on -site emissions generated from construction of the proposed project including implementation of MM-AQ-1 and MM -AQ-2 are presented in Table 7 and are compared to the SCAQMD localized significance criteria for SRA 8 to determine whether project-generated on-site emissions would result in potential LST impacts.

Table 7. Construction Localized Significance Thresholds Analysis – Mitigated Construction Year
NOx CO PM10 PM2.5
Pounds per Day
2027 4.03 29.05 5.25 2.76
2028 8.95 44.65 0.29 0.27
2029 4.18 13.14 0.11 0.10
Maximum 8.95 44.65 5.25 2.75
SCAQMD LST Criteriaa 98 812 6 4
Threshold exceeded? No No No No
Notes: NOx = oxides of nitrogen; CO = carbon monoxide; PM 10 = particulate matter with a diameter less than or equal to 10 microns; PM2.5 = particulate matter with a diameter less than or equal to 2.5 microns; SCAQMD = South Coast Air Quality Management District; LST = localized significance threshold.

The values shown are the maximum summer or winter daily emissions results from CalEEMod.

Emissions reflect application of MM-AQ-1 and MM-AQ-2.

The total values may not add up exactly due to rounding.

See Appendix A for detailed results.

Based on the results shown in Table 7, localized project construction emissions would not exceed the established LST significance thresholds for PM10 and PM2.5 emissions with implementation of MM-AQ-1 and MM-AQ-2; therefore, the project would result in a less -than-significant impact with mitigation incorporated in regard to localized impact to sensitive receptors during construction.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 31
JUNE 2026
CO Hotspots
Traffic-congested roadways and intersections have the potential to generate localized high levels of CO.

Localized areas where ambient concentrations exceed federal and/or state standards for CO are termed “CO hotspots.” The transport of CO is extremely limited, because it disperses rapidly with distance from the source. However, under certain extreme meteorological conditions, CO concentrations near a congested roadway or intersection may reach unhealthy levels, affecting sensitive receptors. Typically, high CO concentrations are associated with severely congested intersections operating at an unacceptable level of service (LOS) (LOS E or worse is unacceptable). Projects contributing to adverse traffic impacts may result in the formation of a CO hotspot. Additional analysis of CO hotspot impacts would be conducted if a project would result in a significant impact or contribute to an adverse traffic impact at a signalized intersection that would potentially subject sensitive receptors to CO hotspots.

At the time that the SCAQMD Handbook (1993) was published, the SCAB was designated nonattainment under the CAAQS and NAAQS for CO. In 2007, the SCAQMD was designated in attainment for CO under both the CAAQS and NAAQS as a result of the steady decline in C O concentrations in the SCAB due to turnover of older vehicles, introduction of cleaner fuels, and implementation of control technology on industrial facilities. The SCAQMD conducted CO modeling for the 2003 AQMP (SCAQMD 2003)6 for the four worst-case intersections in the SCAB: (1) Wilshire Boulevard and Veteran Avenue, (2) Sunset Boulevard and Highland Avenue, (3) La Cienega Boulevard and Century Boulevard, and (4) Long Beach Boulevard and Imperial Highway. At the time the 2003 AQMP was prepared, the intersection of Wilshire Boulevard and Veteran Avenue was the most congested intersection in Los Angeles County, with an average daily traffic volume of about 100,000 vehicles per day. The 2003 AQMP also projected 8 -hour CO concentrations at these four intersections for 1997 and from 2002 through 2005. From 2002 through 2005, the maximum 8-hour CO concentration was 3.8 parts per million by volume (ppm) at the Sunset Boulevard and Highland Avenue intersection in 2002 , and the maximum 8-hour CO concentration was 3.4 ppm at the Wilshire Boulevard and Veteran Avenue intersection in 2002. Accordingly, CO concentrations at congested intersections would not exceed the 1 -hour or 8-hour CO CAAQS unless projected daily traffic would be at least over 100,000 vehicles per day. The project would result in less than 110 average daily trips , and as such, the project would not raise the traffic volumes at intersections in proximity to the project to the 100,000 vehicles per day that could result in a CO hotspot.

Additionally, ambient CO levels are monitored at the 752 S outh Wilson Ave nue, Pasadena , air quality monitoring station, which is approximately 3.2 miles south of the project site . These levels represent ambient air quality in the project area. Ambient CO levels monitored at this representative monitoring station indicate that the highest recorded 1 -hour concentration of CO is 10.1 ppm (the state standard is 20 ppm) and highest 8-hour concentration is 5.6 ppm (the state standard is 9 ppm) during the past 3 years of available data (EPA 2025). As discussed above, the highest CO concentrations typically occur during peak traffic hours, so CO impacts calculated under peak traffic conditions represent a worst-case analysis.

Given the low level of CO concentrations in the project area, and less than 110 additional daily trips due to project implementation, project-related mobile emissions would not contribute to CO concentrations, and a CO hotspot is not anticipated to occur. In addition, due to continued improvement in vehicular emissions at a rate faster than the rate of vehicle growth and/or congestion, the potential for CO hotspots in the SCAB 6 SCAQMD’s CO hotspot modeling guidance has not changed since 2003.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 32
JUNE 2026
is steadily decreasing. Based on these considerations, the proposed project would result in no impact to air quality with regard to potential CO hotspots.

Toxic Air Contaminants
A substance is considered toxic if it has the potential to cause adverse health effects in humans, including increasing the risk of cancer upon exposure, or acute (immediate) and/or chronic (cumulative) non-cancer health effects. A toxic substance released into the air is considered a toxic air contaminant (TAC). Adverse health effects associated with exposure to TACs may include carcinogenic (i.e., cancer -causing) and noncarcinogenic effects. Noncarcinogenic effects typically affect one or more target orga n systems and may be experienced upon either short-term (acute) or long -term (chronic) exposure to a given TAC. TACs are identified by federal and state agencies based on a review of available scientific evidence. In the State of California, TACs are identified through a two-step process that was established in 1983 under the Toxic Air Contaminant Identification and Control Act. This two -step process of risk identification and risk management and reduction was designed to protect residents from the health effects of toxic substances in the air. In addition, the California Air Toxics “Hot Spots” Information and Assessment Act, Assembly Bill (AB) 2588, was enacted by the State Legislature in 1987 to address public concern over the release of TACs into the atmosphere.

Examples of TACs include certain aromatic and chlorinated hydrocarbons, certain metals, and asbestos.

TACs are generated by a number of sources, including stationary sources , such as dry cleaners, gas stations, combustion sources, and laboratories; mobile sources , such as automobiles; and area sources , such as landfills. Project construction would result in emissions of diesel particulate matter (DPM) from heavy construction equipment and trucks accessing the site. DPM is characterized as a TAC by the State of California. State law has established the framework for California’s TAC identification and control program, which is generally more stringent than the federal program and is aimed at TACs that are a problem in California. The state has formally identified more than 200 substances as TACs, including the federal hazardous air pollutants (HAPs), and has adopted appropriate control measures for sources of these TACs. The following measures are required by state law to reduce DPM emissions:
▪ Fleet owners of mobile construction equipment are subject to the CARB Regulation for In -Use Off- Road Diesel Vehicles (13 CCR 2449), the purpose of which is to reduce DPM and criteria pollutant emissions from in-use (existing) off-road diesel-fueled vehicles. ▪ All commercial diesel vehicles are subject to Title 13, Section 2485 of the California Code of Regulations, limiting engine idling time. Under this regulation, i dling of heavy -duty diesel construction equipment and trucks during loading and unloading is limited to 5 minutes, and electric auxiliary power units should be used whenever possible.

The Office of Environmental Health Hazard Assessment has identified carcinogenic and chronic noncarcinogenic effects from long -term exposure, but has not identified health effects due to short -term exposure to diesel exhaust. The duration of proposed construction activities would only constitute a small percentage of the total long-term exposure period and would not result in exposure of proximate sensitive receptors to substantial TACs. After proposed construction is completed , there would be no long -term source of TAC emissions during operation. In addition, the project would not require the extensive operation of heavy-duty diesel construction equipment, which is subject to a CARB Airborne Toxics Control Measure for in-use diesel construction equipment to reduce DPM emissions, and would not involve extensive use of

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 33
JUNE 2026
diesel trucks, which are also subject to a CARB Airborne Toxics Control Measure. Furthermore, as shown in Table 4, maximum daily particulate matter (i.e., PM 10 or PM 2.5) emissions generated by construction equipment operation and truck trips during construction (exhaust particulate matter , or DPM), combined with fugitive dust generated by equipment operation and vehicle travel, would be minimal.

The project site is located on an existing infill site, with the closest sensitive receptors (residences) adjacent to the southeast of the site. Emissions during construction would not be concentrated in one area of the site but would be spread over the entirety of the site. Emissions would not be continuous and would cease once construction is complete. Therefore, the project would not expose sensitive receptors to substantial quantities of TACs during construction. Impacts would be less than significant.

No residual TAC emissions and corresponding health risk are anticipated after construction, and no long - term sources of TAC emissions are anticipated during operation of the project. CARB has published the Air Quality and Land Use Handbook: A Community Hea lth Perspective (CARB 2005), which identifies certain types of facilities or sources that may emit substantial quantities of TACs and therefore could conflict with sensitive land uses, such as “schools and schoolyards, parks and playgrounds, daycare center s, nursing homes, hospitals, and residential communities” (CARB 2005). The Air Quality and Land Use Handbook is a guide for siting of new sensitive land uses, and CARB recommends that sensitive receptors not be located downwind of or in proximity to such sources to avoid potential health hazards. The listed facilities or sources include the following: high -traffic freeways and roads, distribution centers, railyards, ports, refineries, chrome plating facilities, dry cleaners, and large gas-dispensing facilities. The project would not include any of the above-listed land uses associated with generation of TAC emissions. Furthermore, it is expected that the operation of the project would not result in any non-permitted direct emissions (e.g., those from a point source such as diesel generators) that could be a TAC source. Therefore, the project would not result in exposure of sensitive receptors in the vicinity of the project site to substantial TAC concentrations due to either construction or operation, and impacts would be less than significant.

In summary, because implementation of the project would not result in exceedances of the SCAQMD evaluation criteria thresholds during construction and operation after the implementation of MM-AQ-1 and MM-AQ-2, the potential health effects associated with criteria air pollutants would be less than significant with mitigation incorporated.

Mitigation Measures
MM-AQ-1 Fugitive Dust Control During Construction. The City shall require its construction contractor to water exposed soil during construction a minimum of three times per day.

The City shall also require its construction contractor to replace ground cover o n areas disturbed during construction.

MM-AQ-2 Construction Equipment Emissions Reductions. Prior to the commencement of construction activities for the project, the City shall require its construction contractor to use California Air Resources Board (CARB) certified Tier 4 engines for all diesel -powered equipment pieces that are 75 horsepower or greater throughout all phases of construction.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 34
JUNE 2026
An exemption from this requirement may be granted under the following two conditions:
(1) The City’s construction contractor shall demonstrate that at least three construction fleet owners/operations in Los Angeles were contacted and that those owners/operations confirmed that Tier 4 Final equipment could not be located within Los Angeles County during the desired construction schedule. (2) The proposed replacement equipment has been evaluated using the California Emissions Estimator Model (CalEEMod) or other industry standard emissions estimation method and documentation has been provided to the City to confirm that the reduction to below significant cancer risk resulting from construction emissions is achieved. d) Would the project result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
Less-Than-Significant Impact. Based on available information, the project is not anticipated to result in other emissions that have not been addressed in Sections 3.3(a)–(c). As such, this analysis focuses on the potential for the project to generate odors.

The occurrence and severity of potential odor impacts depends on numerous factors. The nature, frequency, and intensity of the source; the wind speed and direction; and the sensitivity of the receiving location each contribute to the intensity of the impac t. Although offensive odors seldom cause physical harm, they can be annoying and cause distress among the public and generate citizen complaints.

SCAQMD considers a project to exceed the threshold for objectionable odors if it creates a nuisance odor, as defined under SCAQMD Rule 402.

Odors would be potentially generated from vehicles and equipment exhaust emissions during construction of the project. Potential odors produced during construction would be attributable to concentrations of unburned hydrocarbons from tailpipes of construction equipment and asphalt pavement application. Such odors would disperse rapidly from the project site and would generally occur at magnitudes that would not affect substantial numbers of people. Therefore, impacts associated with odors during construction would be less than significant.

Land uses and industrial operations associated with odor complaints include agricultural uses, wastewater treatment plants, food -processing plants, chemical plants, composting operations, refineries, landfills, dairies, and fiberglass molding facilities (S CAQMD 1993). The project would not include any of these land uses or industrial operations associated with odor complaints. The project is not anticipated to generate any odors during long -term operations, and any emitted odors would be short term in natur e and would disperse rapidly. Further, as stated above, the project would comply with SCAQMD Rule 402, Nuisance, which prohibits the release of odors which may cause annoyance to a considerable number of persons, as well as other SCAQMD rules related to od or generation. The project would not create any new sources of odor during operation. Therefore, project operations would result in an odor impact that would be less than significant .

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 35
JUNE 2026

3.4 Biological Resources

Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
IV. BIOLOGICAL RESOURCES – Would the project:
a) Have a substantial adverse effect, either
directly or through habitat modifications, on
any species identified as a candidate,
sensitive, or special status species in local
or regional plans, policies, or regulations, or
by the California Department of Fish and
Wildlife or U.S. Fish and Wildlife Service?

b) Have a substantial adverse effect on any
riparian habitat or other sensitive natural
community identified in local or regional
plans, policies, regulations or by the
California Department of Fish and Wildlife or
U.S. Fish and Wildlife Service?

c) Have a substantial adverse effect on state
or federally protected wetlands (including,
but not limited to, marsh, vernal pool,
coastal, etc.) through direct removal, filling,
hydrological interruption, or other means?

d) Interfere substantially with the movement
of any native resident or migratory fish or
wildlife species or with established native
resident or migratory wildlife corridors,
or impede the use of native wildlife
nursery sites?

e) Conflict with any local policies or ordinances
protecting biological resources, such as a
tree preservation policy or ordinance?

f) Conflict with the provisions of an adopted
Habitat Conservation Plan, Natural
Community Conservation Plan, or other
approved local, regional, or state habitat
conservation plan?

A Biological Resources Assessment and Aquatic Resources Jurisdictional Delineation Report were prepared by Dudek for the proposed project in April 2025 and an Arborist’s Report was prepared by Dudek for the proposed project in October 2025. The Biological Resources Assessment is included as Appendix B, the Aquatic Resources Jurisdictional Delineation Report is included as Appendix C, and the Arborist’s Report is included as Appendix D of this IS/MND.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 36
JUNE 2026
Literature Review
The following data sources were reviewed to assist with the analys is:
▪ California Department of Fish and Wildlife’s (CDFW) California Natural Diversity Database and the California Native Plant Society’s Rare Plant Inventory (CDFW 2025a; CNPS 2025a). ▪ U.S. Department of Agriculture’s Natural Resources Conservation Service Web Soil Survey (USDA 2025) ▪ CDFW Biogeographic Information and Observation System (CDFW 2025b) ▪ A Manual of California Vegetation, Online Edition (CNPS 2025b) ▪ CDFW California Natural Community list (CDFW 2025c)
▪ State and Federally Listed Endangered, Threatened, and Rare Plants of California (CDFW 2025d) ▪ State and Federally Listed Endangered and Threatened Animals of California (CDFW 2025e) ▪ CDFW California Wildlife Habitat Relationships Life History Accounts and Range Maps (CDFW 2025f) ▪ Current and historical aerial imagery and topographic maps (Google Earth 2025; NETR 2025) Field Visit
Dudek biologists Eilleen Salas and Ryan Stanley performed a field survey on February 11, 2025. Temperatures during the survey were between 58°F and 62°F, under 40% to 90% cloud cover, and wind speeds ranged between 0 and 2 miles per hour. The biological survey included vegetation mapping ; the mapping of sensitive biological resources, if present, within the project site; and an evaluation of the potential for special-status species to occur.

One vegetation community and three land cover types were identified in the project area during the field visit and are presented in Table 8. Permanent and temporary project impacts in relation to vegetation communities and land cover types within the project site are shown in Figure 3.4-1. Representative photos of vegetation and land covers within the study area (defined as the project site plus a 500-foot-wide buffer, for a total of approximately 58.5 acres) are presented in Appendix B and Appendix C and species lists are presented in Appendix B.

Table 8. Vegetation Communities and Land Cover Types in the Project Area Vegetation Community/
Land Cover Type Alliance Association
Acreage Within
the Project Site
Coast live oak woodland and
forest
Quercus agrifolia forest and
woodland alliancea
Quercus agrifolia 0.46
Urban/developed N/A N/A 0.28
Ornamental plantings N/A N/A 0.17
Disturbed habitat N/A N/A 3.02
Totalsb 3.93
Source: Appendix B.

Notes: N/A = not applicable.
a Semi-natural alliances do not have conservation status rankings and are not considered sensitive. b Totals may not sum precisely due to rounding.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 37
JUNE 2026
a) Would the project have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service? Less-Than-Significant Impact with Mitigation Incorporated. No special-status plant or wildlife species were observed during surveys conducted for the project. Database review identified 47 special-status plant species and 40 special-status wildlife species with recorded occurrences in the U.S. Geologic al Survey’s Mt. Wilson California 7.5-minute topographic quadrangle, in which the project is located, and the eight surrounding quadrangles (CDFW 202 5a; CNPS 2025a) or that are included in the U.S. Fish and Wildlife Service Information for Planning and Consultation (IPaC) query (USFWS 2025). For a full list of species identified within the database search , see Attachment C, Species Compendium, to Appendix B of this IS/MND. The productive database results were due to the quadrangle search including extensive undeveloped areas in the mountains and foothills far north of the site , in a vastly different environment than the project site’s urban setting. The project site supports one vegetation community, coast live oak woodland and forest, and three land cover types , ornamental plantings , urban/developed land, and disturbed habitat . The project site was deemed to have no value as habitat for endangered, rare, or threatened wildlife species.

No special-status plant species or wildlife were found to have a potential to occur on site (see Appendix B); therefore, any plant species identified as a candidate, sensitive, or special-status species in local or regional plans, policies, or regulations, or by CDFW or the U.S. Fish and Wildlife Service, are not expected to occur due to the lack of suitable habitat.

One sensitive bird species, Cooper’s hawk ( Accipiter cooperii ), was determined to have a moderate potential to nest in the large trees adjacent to the Eaton Wash. Cooper’s hawk is a CDFW Watch List species and is protected by the federal Migratory Bird Treaty Act . Due to the moderate potential for this special - status species to occur on site, mitigation is warranted to ensure project impacts remain less than significant pursuant to CEQA.

Three bat species, western yellow bat ( Dasypterus xanthinus ), western mastiff bat ( Eumops perotis californicus), and western red bat (Lasiurus frantzii), and one invertebrate, Crotch’s bumble bee (Bombus crotchii), were determined to have a low potential to occur. The bat species are CDFW Species of Special Concern; foraging habitat is present in Eaton Blanche Park and roosting could be supported by large trees, including palms, and the Del Mar Boulevard overpass that spans Eaton Wash. Crotch’s bumble bee i s a candidate species for protection under the California Endangered Species Act . Suitable floral resources and microhabitat nesting opportunities (i.e., small mammal burrows) for Crotch’s bumble bee were not identified in field surveys; however, there are documented occurrences of this species in the nearby vicinity and the species could occur as a transient (Appendix B). Project actions are not expected to have an impact on transitory Crotch’s bumble bee.

To verify the anticipated absence of special-status biological resources prior to commencing construction, MM-BIO-1 would require pre-construction surveys , and MM-BIO-2 would require monitoring of vegetation removal and initial ground disturbance to ensure that project actions remain in compliance with state and federal regulations (see “Mitigation Measures” subsection below for full text of MM -BIO-1 and MM -BIO-2). Any potential impacts to special -status biological resources would be less than significant with mitigation incorporated .

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 38
JUNE 2026
Mitigation Measures
MM-BIO-1 Special-Status Wildlife Species Survey s. Before commencing ground - or vegetation - disturbing activities, the City will perform a pre-construction survey for special -status wildlife species, including Crotch’s bumble bee (Bombus crotchii), Cooper’s hawk (Accipiter cooperii), western yellow bat (Dasypterus xanthinus), western mastiff bat (Eumops perotis californicus), and western red bat ( Lasiurus frantzii) to determine the presence/ absence of these species at the site. The survey shall be conducted within 14 days of the start of ground- or vegetation-disturbing activities. A qualified biologist shall walk the entire study area to determine if any special -status avian, mammal, or invertebrate species are observed or detected. The pre-construction surveys shall incorporate appropriate methods and timing as detailed in the approved survey protocol for each target species, to detect these species, including individuals that could be concealed in burrows, beneath leaf litter, in trees, or in loose soil. If any special-status wildlife are observed or detected during the pre-construction surveys, additional measures may be required, in consultation with the U.S. Fish and Wildlife Service or California Department of Fish and Wildlife , such as establishing a buffer around known locations and/or monitoring construction near occupied areas. If Crotch’s bumble bee is determined to be present prior to construction , an Incidental Take Permit issued b y CDFW would need to be obtained . The City shall prepare and submit a letter report to U.S. Fish and Wildlife Service and California Department of Fish and Wildlife summarizing the methods and results of the surveys.

MM-BIO-2 Monitor Vegetation Clearing. The City will obtain the services of a qualified biologist to observe vegetation removal and monitor for potential conflict with wildlife species. The biologist will prepare daily monitoring logs to document their observations and submit the logs to the City for inclusion in the project’s construction files. If conditions are observed that may lead to wildlife conflicts, the biologist will provide guidance to the construction management team as to how best to avoid impacts on the resource. b) Would the project have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service?
Less-Than-Significant Impact. The project site supports one vegetation community, coast live oak woodland and forest, and three land cover types, urban/developed land, ornamental plantings, and disturbed habitat (see Table 8). The coast live oak woodland and forest on site was mapped due to the presence of a grouping of coast live oak trees , although the understory has experienced disturbance associated with past and ongoing activity on the site. Coast live oak woodland and forest is not considered a sensitive vegetation community by CDFW (2025c), though coast live oak individuals fall under the City’s tree-protection ordinance (see Impact 3.4[e] below for discussion of project conflicts with local policies or ordinances).

As shown in Figure 3.4-1, a small portion of permanent impacts associated with the project would overlap with the coast live oak woodland and forest vegetation community, while most of the coast live oak woodland and forest vegetation community would overlap with the temporary impact area. The project would be required to adhere to the tree protection standards outlined in the City’s Tree Protection Ordinance and Tree Protection Guidelines for any impacts to live oak woodland and forest and would implement MM-BIO-4 and MM-BIO-5 (discussed under Impact 3.4[e] below), which requires tree monitoring during construction activities and after completion of construction. The project area does not contain any riparian habitat or other sensitive natural

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 39
JUNE 2026
community identified in local or regional plans, policies, or regulations, or by CDFW or the U.S. Fish and Wildlife Service. Therefore, the project would not have a substantial adverse effect on any riparian habitat or sensitive vegetation community and impacts would be less than significant. c) Would the project have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?
Less-Than-Significant Impact. The Eaton Wash channel conveys a non-wetland water of the U.S. and state and is regulated by the U.S. Army Corps of Engineers under Section 404 of the Clean Water Act, by the Regional Water Quality Control Board under Section 401 of the Clean Water Act or the California Porter– Cologne Water Quality Control Act, and/or by CDFW under Section 1602 of the California Fish and Game Code (Appendix C). The channel is a concrete-lined flood-control feature that is devoid of habitat.

The Eaton Wash concrete channel, which is adjacent to the project site, collects and conveys relatively permanent water from Eaton Canyon in the San Gabriel Mountains, along with nuisance water and storm runoff from the surrounding urban area. Eaton Wash has a definable ordinary high water mark throughout its length within the study area and contains relatively permanent waters. Based on the jurisdictional delineation performed for the project , the non-wetland waters feature associated with Eaton Wash are assumed to be regulated by the U.S. Army Corps of Engineers , the Regional Water Quality Control Board , and CDFW (Appendix C). Approximately 0.03 acres of non-wetland waters are within the project’s impact boundaries, which includes the pedestrian bridge over Eaton Wash and the diversion structure at the bottom of Eaton Wash. Although these project features are both calculated as an impact on non-wetland waters based on the project boundaries, the pedestrian bridge would span Eaton Wash, so there would be no physical impact from this project component. The diversion structure would be installed at the bottom of Eaton Wash, resulting in a small impact on the jurisdictional feature. This minimal impact would occur within a channelized feature for the purpose of improving water quality. The project’s impact on this feature would be considered a less -than-significant impact pursuant to CEQA. Impacts within Eaton Wash would require permits from all referenced agencies prior to initiating project construction. Permits are likely to identify additional requirements for the City, which would not be considered CEQA mitigation measures. d) Would the project interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites?
Less-Than-Significant Impact with Mitigation Incorporated. The project area is not located within any designated wildlife corridors or habitat linkages ; therefore, impacts on wildlife corridors and habitat connectivity would not occur as a result of the project. However, on -site trees and shrubs provide suitable nesting habitat for bird species protected under the Migratory Bird Treaty Act (16 USC 703 –712) and California Fish and Game Code Sections 3503.5, 3503, and 3513. Vegetation trimming or removal associated with the project could cause mortality to young or breeding adults and/or destruction of eggs or active nests if these activities occur during the general nesting season of February 1 through September 30. Implementation of MM-BIO-3 (Compliance with Migratory Bird Treaty Act and California Fish and Game Code), which requires nesting bird avoidance, would reduce potential direct impacts to nesting birds to a less-than-significant level. Refer to the “Mitigation Measures” subsection at the end of this section for the text of MM-BIO-3.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 40
JUNE 2026
Potential short -term indirect impacts to special -status wildlife could result from noise generated by construction activities conducted during the avian breeding season (February 1 through September 30).

Construction-related noise has the potential to disrupt reproductive and feeding activities for nesting birds, potentially causing mortality due to the abandonment of an active nest. These indirect impacts would be considered significant, absent mitigat ion. Implementation of MM -BIO-3 would reduce these pote ntial indirect impacts to nesting birds to a less-than-significant level.

In summary, impacts relative to impeding the use of native wildlife nursery sites would be less than significant with mitigation incorporated.

Mitigation Measures
MM-BIO-3 Compliance with Migratory Bird Treaty Act and California Fish and Game Code. The proposed project shall be conducted in compliance with all applicable regulations, including the Migratory Bird Treaty Act (MBTA) and California Fish and Game Code regarding migratory birds. Pursuant to the MBTA and California Fish and Game Code, a qualified biologist shall conduct a pre-construction survey for nesting birds and raptors within the project site and a 500-foot-wide buffer no more than 3 days prior to any vegetation disturbance during the general avian breeding season (February 1–September 30). The project shall avoid take of nesting birds protected under the MBTA and California Fish and Game Code by establishing appropriate no-construction buffer zones around any nests identified during the surveys. The buffer should be 150 -300 feet for non -raptor nesting birds, 300 feet for highly sensitive species, and 300–500 feet for nesting raptors. Construction can proceed into the buffer when the qualified Biologist has determined that the nest is no longer active. If the biologist does not find any active nests within or immediately adjacent to the impact areas, the vegetation clearing/ construction work would be allowed to proceed. If the biologist finds an active nest within or immediately adjacent to the vegetation removal area and determines that the nest may be impacted or breeding activities substantially disrupted, the biologist shall delineate an appropriate no -work buffer zone around the nest , depending on the sensitivity of the species, the location of the nest, and the nature of the construction activity, at their discretion. Construction personnel shall be instructed on the sensitivity of nest areas and no-work buffers shall remain in place until the nest is vacated, juveniles have fledged, and there is no evidence of a second attempt at nesting. Limits of construction to avoid an active nest shall be established in the field with flagging or fencing, and construction personnel shall be instructed on the sensitivity of nest areas. e) Would the project conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
Less-Than-Significant Impact with Mitigation Incorporated. The City defines tree protection in PMC Chapter 8.52 – City Trees and Tree Protection (City of Pasadena 2010). A tree inventory and assessment of the project site and nearby area was performed pursuant to PMC Chapter 8.52 (Appendix D). The Arborist Report, which was prepared during the preliminary design phase, documented 298 trees in the survey boundary, including 161 that are inside the project limits, and 1 37 that are outside the project limits.

Species on site include native species such as coast live oak and California sycamore, and non -native, invasive species such as tree of heaven and Mexican fan palm. Appendix D provides additional detail on the tree species, distribution, and health of the specimens observed during the survey.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 41
JUNE 2026
All 298 trees documented in the Arborist Report are considered public trees, as defined by the City, because of their location on City property or within the public right -of-way; therefore, they are considered protected by the PMC. The PMC does not prohibit removal of protected trees but establishes a protocol for City review of requests to remove regulated trees and for identification of avoidance requirements and/or replacement rates. Of the tot al 298 protected trees surveyed for the Arborist Report , 119 would be removed by the project. A majority of the trees that would be removed are non-native, invasive species. Tree removal would include individuals that are within the site boundaries and need to be cleared to enable construction of project features and provide slope stability and invasive species individuals in and out of the site boundaries that would be removed as part of the City’s site improvement efforts.

One hundred seventy-nine trees documented in the Arborist Report would remain in place. This includes 51 existing trees that are within the project’s temporary impact boundary but do not require removal to construct the project and would be preserved, and 121 trees in the survey area that would be preserved in place. An additional seven trees would be considered encroached upon pursuant to the PMC due to their proximity of their canopy to site disturbance.

In accordance with PMC Section 8.52, replacement of protected trees would be required based on the discretion of the City Manager, and tree protection measures would be implemented for encroached-upon trees. Additionally, the treatment of trees preserved within impacted areas and any other City-protected trees on the project site that are not designated for removal or encroachment must adhere to the tree protection standards outlined in the City’s Tree Protection Ordinance and Tree Protection Guidelines. Implementation of MM-BIO-4 and MM-BIO-5 (see “Mitigation Measures” below) would further reduce impacts to a less -than- significant level. Impacts would therefore be less than significant with mitigation incorporated.

Mitigation Measures
MM-BIO-4 Tree Monitoring During Construction Activities. A qualified arborist shall be present during initial ground-disturbing activities on the project site to ensure that project activities stay within the demarcated limits. This qualified arborist shall identify the number of City-protected trees that are removed as a result of project construction activities, as well as trees that would be encroached upon. This inventory of trees shall be used to determine an appropriate tree replacement program that shall be, at a minimum, consistent with the City of Pasadena Tree Ordinance (PMC Chapter 8.52) as it relates to tree replacement of protected trees.

MM-BIO-5 Post-Construction Tree Monitoring. All trees that have been substantially root pruned (30% or more of their root zone) during construction within the tree protection zone (a 4-foot radius beyond the dripline for each tree) shall be monitored by an International Society of Arbori culture (ISA) certified arborist for the first 10 years after construction completion. The arborist shall submit an annual report, photograph each tree, and compare tree health and condition to the original, pre-construction baseline to the City. For trees that do not survive the 5 -year monitoring period, such trees shall be replaced in accordance with the requirements of PMC Chapter 8.52.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 42
JUNE 2026
f) Would the project conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan? No Impact. The project site is not within any habitat conservation plan, natural community conservation plan, or other approved local, regional, or state habitat conservation plan (CDFW 2024). Accordingly, the proposed project would not conflict with the provisions of an adopted conservation plan, and no impact would occur.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 43
JUNE 2026

3.5 Cultural Resources

Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
V. CULTURAL RESOURCES – Would the project:
a) Cause a substantial adverse change in the
significance of a historical resource
pursuant to § 15064.5?

b) Cause a substantial adverse change in the
significance of an archaeological resource
pursuant to § 15064.5?

c) Disturb any human remains, including those
interred outside of dedicated cemeteries?

The analysis in this section is based on the Cultural Resources Assessment Report prepared for the project by Dudek in October 2025 and included as Appendix E of this IS/MND . The are a of potential effects (APE) for archaeological resources encompasses the federally permitted, 3.91 -acre construction footprint in which all ground-disturbing activities will occur. The APE for built environment resources additionally includes the full legal parcel boundaries of properties that may be potentially affected by visual, vibratory, auditory, and atmospheric effects caused by the project.
a) Would the project cause a substantial adverse change in the significance of a historical resource pursuant to Section 15064.5?
Less-Than-Significant Impact. Historic-age structures are those that were built more than 45 years ago and therefore have the potential to be considered historical resources pursuant to Section 15064.5 of the CEQA Guidelines. Although some historical resources are also considered archaeological resources, such resources are addressed in Section 3.5(b), as part of the discussion of archaeological resources.

Review of historical topographic maps dating back to 1884 and aerial photographs dating back to 1952 is discussed in Appendix E. These show the historic al disturbance the APE has been subject to , including disturbance associated with the channelization of Eaton Wash, building development, demolition, and grading. Additionally, this archival review revealed the presence of historic-era built environment resources located within the APE, which are discussed below.

On April 17, 2024, Dudek conducted a records search of the California Historical Resources Information System (CHRIS) database at the South Central Coastal Information Center (SCCIC), located on the campus of California State University, Fullerton. The records search results identified a total of 36 previous cultural resources studies that have been conducted within 1 mile of the project site. In addition, two previous cultural resources inventories (LA-9705, LA-10175) overlap with the APE and are described in Table 9.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 44
JUNE 2026
Table 9. Previously Conducted Studies Intersecting the APE Report ID Year Author Title
LA-9705 2007 Pacific Legacy Inc. Cultural Resources Inventory of the Southern California Edison Company Tehachapi Renewable Transmission
Project, Kern, Los Angeles and San Bernardino Counties, California. ARR #05-01-01046.

LA-10175 2009 Applied EarthWorks
Inc.

Confidential Cultural Resources Specialist Report for the Tehachapi Transmission Project.

Source: Appendix E.

Report LA -9704 documents the results of an inventory conducted for the Tehachapi Renewables Transmission Project , which overlaps with 100% of the project site. The report cites 43 prehistoric resources, 48 historic-period archaeological sites, 4 multi-component sites, and 8 isolate finds within the 250- to 500 -foot-wide survey corridor. None of the cultural resources identi fied intersect the current proposed APE.

Report LA -10175 documents the results of an inventory conducted for the Tehachapi Renewables Transmission Project, which also overlaps with 100% of the project site. The report cites 57 prehistoric resources, 73 historic-period archaeological sites, and 5 multi-component sites within the 250- to 500-foot- wide survey corridor. None of the cultural resources identified intersect the current currently proposed APE (Appendix E).

The SCCIC records search results indicate that 62 cultural resources have been previously recorded within 1 mile of the APE (Table 10). Of these, one resource intersects the APE (P -19-190502). The vast majority of the remaining 61 resources are historic -era built environment resources associated with the development of the City of Pasadena during the twentieth century.

Table 10. Previously Recorded Cultural Resources Within 1 Mile of the APE Primary
Number Trinomial Age Description

NRHP/ CRHR
Eligibility
Intersects APE
P-19-190502 — Historic SCE Mesa-Anita-Eaton 66 kV
Transmission Line
Recommended
ineligible
Outside of APE
P-19-003682 CA-LAN-003682/H Prehistoric,
Historic
Suangna Native American Village Not evaluated
P-19-003804 CA-LAN-003804H Historic Las Encinas Hospital Not evaluated P-19-183162 — Historic Pasadena Motel Grouping Not evaluated P-19-183164 — Historic Travelodge Not evaluated
P-19-183165 — Historic Swiss Lodge Not evaluated
P-19-183166 — Historic Astro Motel Not evaluated
P-19-183167 — Historic Vagabond Inn Not evaluated
P-19-183168 — Historic Ace Motel Not evaluated
P-19-183181 — Historic United Picture & Frame Co. Recommended ineligible

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 45
JUNE 2026
Table 10. Previously Recorded Cultural Resources Within 1 Mile of the APE Primary
Number Trinomial Age Description

NRHP/ CRHR
Eligibility
P-19-183182 — Historic Sierra Madre Blvd. Commercial
Grouping
Not evaluated
P-19-183185 — Historic Pasadena Fire Station #7 Not evaluated P-19-183186 — Historic Lamanda Park Commercial Area Not evaluated P-19-183187 — Historic Proctor Insurance Co. Not evaluated P-19-183191 — Historic Morton C. Hartzell Methodist Episcopal Church
Not evaluated
P-19-183192 — Historic Third Church of Christ Scientist Not evaluated P-19-183195 — Historic Dudley & White Blacksmiths Recommended ineligible
P-19-183196 — Historic C M Northrup & Son Real Estate Not evaluated P-19-183198 — Historic Royal Palms Trailer Court Not evaluated P-19-183199 — Historic California Sewing Machine Co. Not evaluated P-19-183328 — Historic Pasadena Rubber Stamp Works Not evaluated P-19-183477 — Historic Pasadena Trailer Park Not evaluated P-19-183478 — Historic Sparkle Laundry & Cleaners Not evaluated P-19-183479 — Historic Siam Gourmet Not evaluated
P-19-183480 — Historic Pasadena Hub Caps Not evaluated
P-19-183481 — Historic VCR TV MW Stereo Repair Not evaluated P-19-183482 — Historic Mutual Bldg. & Loan Assn. Not evaluated P-19-183483 — Historic Post Office Not evaluated
P-19-183484 — Historic Locators Agency Not evaluated
P-19-183485 — Historic Sharon Newbold Realtor Not evaluated P-19-183486 — Historic Sud’N Service Not evaluated
P-19-183487 — Historic Silver-Reed Not evaluated
P-19-183488 — Historic Gwinn’s Restaurant Not evaluated P-19-183489 — Historic Serendipity Not evaluated
P-19-183490 — Historic Serendipity Not evaluated
P-19-183491 — Historic Serendipity Not evaluated
P-19-183492 — Historic Serendipity Not evaluated
P-19-183943 — Historic Stuart Co. Plant & Office Bldg. Listed P-19-184686 — Historic Hempel Tile Not evaluated
P-19-184687 — Historic Glo-Quartz Mfg. Not evaluated
P-19-184688 — Historic Pasadena Indoor Swapmeet Not evaluated P-19-188038 — Historic Warner’s Egyptian Theater Recommended ineligible
P-19-189110 — Historic AT & SF RR bridge over Rosemead Blvd. Recommended ineligible
P-19-189225 — Historic First Western Bank Appears eligible P-19-189226 — Historic First National Bank of Lamanda Park Listed P-19-189227 — Historic Denny’s Listed
P-19-189228 — Historic Suzuki Dealership Appears eligible

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 46
JUNE 2026
Table 10. Previously Recorded Cultural Resources Within 1 Mile of the APE Primary
Number Trinomial Age Description

NRHP/ CRHR
Eligibility
P-19-189229 — Historic Fred C Henson Co. Listed
P-19-189230 — Historic Factory Service Recommended
ineligible
P-19-189231 — Historic Vista Paint & Wallcovering Appears eligible P-19-189232 — Historic Glatts Lumber Recommended
ineligible
P-19-189233 — Historic Simpson Bldg. Recommended
ineligible
P-19-189236 — Historic Street lights Appears eligible
P-19-190399 — Historic Single-family residence Not evaluated P-19-190917 — Historic Single-family residence Recommended ineligible
P-19-192125 — Historic Single-family residence Not evaluated P-19-192131 — Historic Single-family residence Not evaluated P-19-192132 — Historic Single-family residence Not evaluated P-19-192133 — Historic Single-family residence Not evaluated P-19-192134 — Historic Single-family residence Not evaluated P-19-192221 — Historic Single-family residence Recommended ineligible
P-19-192479 — Historic Naval Ordinance Test Station (NOTS); Pasadena, Foothill Plant
Appears eligible
for CRHR
Source: Appendix E.

Notes: APE = area of potential effects; NRHP = National Register of Historic Places; CRHR = California Register of Historical Resources.

P-19-190502 is characterized as a historic -age transmission line that runs generally north to south for approximately 13 miles to distribute power between the SCE Mesa Substation, Anita Substation, and Eaton Substation. A segment of the resource intersects the APE. This resource was given the California Office of Historic Preservation status code of 6Z: Found ineligible for National Register, California Register, or local designation through survey evaluation (Appendix E). The segment of P-19-190502 within the APE was inventoried and evaluated as part of the Cultural Resources Assessment Report prepared for the project (Appendix E).

On June 26, 2025, Dudek architectural historian Katie Ahmanson, MHC, survey ed the APE for built environment resources. The built environment survey identified five historic-era (45 years of age or older) properties within the APE for built environment resources, consisting of the Eaton Wash Channel, Eaton Blanche Park, the former Earthside Nature Center site, the urgent care center building at 3160 East Del Mar Boulevard, and the SCE Mesa -Anita Eaton Transmission Line (Appendix E). Dudek evaluated these five historic-age properties in the APE and found that none are eligible for listing in the National Register of Historic Place s (NRHP), California Register of Historical Resources ( CRHR), or the City of Pasadena ’s component of the California Historical Resources Inventory Database due to a lack of significant associations and architectural merit due to a lack of historical significance and architectural merit.

Therefore, no historic properties were identified within the APE.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 47
JUNE 2026
As no resources were identified in the records search or survey, except for the five historic-era properties that would not be eligible for NRHP, CRHR , or City of Pasadena California Historical Resources Inventory Database listing, the project would not cause a substantial adverse change in the significance of a known historical resource pursuant to Section 15064.5. Impacts would be less than significant. b) Would the project cause a substantial adverse change in the significance of an archaeological resource pursuant to Section 15064.5?
Less-Than-Significant Impact with Mitigation Incorporated . The analysis of project impacts on archaeological resources is primarily based on the results of the SCCIC records search, review of historic maps and aerial images, and the pedestrian survey . Dudek contacted the Native American Heritage Commission (NAHC) on April 24, 2025, and requested a review of their Sacred Lands File for the APE and a 1-mile radius. The Sacred Lands File consists of a database of known Native American cultural resources that may not be included in the SCCIC database or be depicted in the records search results. NAHC replied via email correspondence on May 7, 2025, stating that the Sacred Lands File search was completed with positive results. Positive results indicate the presence of Native American cultural resources within 1 mile of the APE, not necessarily directly within the APE. NAHC additionally provided a list of Native American individuals and/or tribal organizations that should be contacted for more information on potent ial tribal sensitivities regarding the currently proposed project (Appendix E).

Dudek archaeologist Roshanne Bakhtiary, MA, RPA, conducted an intensive-level pedestrian survey of the APE for archaeological resources on June 26, 2025. Approximately 75% of the APE for archaeological resources had zero ground surface visibility, while the remainder had moderate ground surface visibility.

The survey observed existing disturbances that include evidence of grading , vegetation clearing , and modern debris throughout. Although the remains of the former Earthside Nature Center were recorded during this field effort, this resource was treated as a built environment resource, as discussed in Section

3.5(a). No archaeological resources were identified during the pedestrian survey of the APE for archaeological resources (Appendix E).

No archaeological resources were identified during the pedestrian survey. Additionally, Dudek’s archival review indicates that the majority of the APE has been previously disturbed by the channelization of Eaton Wash, building development, demolition, and grading. Based on the results of the SCCIC records search and pedestrian survey and the prior disturbance and grading of the project site, the project would not cause a substantial adverse change in the significance of a known archaeological resource pursu ant to CEQA Guidelines Section 15064.5. However, there are previously recorded prehistoric resources located within the 1-mile record search radius, and it is not possible to conclude the absence of subsurface archaeological deposits based on surface observations. Therefore, MM-CUL-1, Archaeological Monitoring, and MM-CUL-2, Unanticipated Discovery of Archaeological Resources, are recommended to ensure that the potential for impacts to unknown archaeological resources would be appropriately addressed (see the “Mitigation Measures” subsection for the text of MM -CUL-1 and MM -CUL-2). With implementation of these mitigation measures, impacts would be less than significant with mitigation incorporated.

Mitigation Measures
MM-CUL-1 Archaeological Monitoring. Prior to ground -disturbing activities, the City of Pasadena (City) and/or subsequent responsible parties should retain a Principal Investigator/ Archaeologist meeting the Secretary of the Interior’s Professional Qualification Standards

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 48
JUNE 2026
in Archaeology and with experience in California prehistoric and historic resources (experience within Los Angeles County preferred) . An archaeological monitor shall be present during all initial ground -disturbing activities for the project. Archaeological monitoring may be adjusted (increased, decreased, or discontinued) at the recommendation of the archaeological principal investigator and based on the inspection of exposed cultural material and the observed potential for soils to contain intact cultural deposits or otherwise significant archaeological material. The archaeological monitor shall be provided a copy of the Cultural Resources Assessment Report for the Eaton Wash Stormwater Capture Project and its pertinent appendices to inform their monitoring efforts.

The archaeological monitor shall have the authority to temporarily halt work to inspect areas for potential cultural material or deposits. The requirement for tribal monitoring, while recommended, shall be determined by the lead agency in consult ation with the traditionally culturally affiliated tribes with geographic ties to the project area.

Daily monitoring logs shall be completed by the on -site archaeological monitor. Within 60 days following completion of construction, the archaeological principal investigator shall provide an archaeological monitoring report to the City. This report shall include the results of the cultural monitoring program (even if negative), including a summary of any findings or evaluation/data recovery efforts, and supporting documentation that demonstrates all mitigation measures defined in the environmental document were appropriately met.

Appendices shall include archaeological monitoring logs and documentation relating to any newly identified or updated cultural resources. This report shall be submitted to the South Central Coastal Information Center (SCCIC) once considered final.

While recommended, the requirement to include a Native American Monitor should be determined by the City, having reviewed cultural resources technical findings, through government-to-government consultation with the traditionally culturally affiliated trib es with geographic ties to the project site and in review of the present report findings.

MM-CUL-2 Unanticipated Discovery of Archaeological Resources. In the event that archaeological resources (sites, features, or artifacts) are exposed during construction activities for the project, all construction work occurring within 50 feet of the find shall immediately stop until a qualified archaeologist meeting the Secretary of the Interior’s Professional Qualification Standards for Archaeology is provided access to the project site and can assess the significance of the find and determine whether additional study is warranted.

The work exclusion buffer may be a djusted as appropriate to allow work to feasibly continue at the recommendation of the archaeological principal investigator. Should it be required, temporary flagging shall be installed around this resource to avoid any disturbance from construction equip ment. The potential for avoidance should be the primary consideration of this initial process. Significance of the find shall be assessed as outlined by the California Environmental Quality Act (CEQA) and its implementing guidelines and Section 106 of the National Historic Protection Act . If the archaeological principal investigator observes the discovery to be potentially significant under CEQA and/or the National Historic Protection Act , additional efforts, such as the preparation of an archaeological treatment plan, testing, and/or data recovery, may be warranted prior to allowing construction to proceed in this area.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 49
JUNE 2026
c) Would the project disturb any human remains, including those interred outside of dedicated cemeteries? Less-Than-Significant Impact. As discussed above, the project site has been subject to past disturbances associated with the channelization of Eaton Wash, building development, demolition, and grading . No prehistoric or historic -period burials, including those interred outside of dedicated cemeteries, were identified within the project site as a result of the CHRIS records search, NAHC Sacred Lands File search, or archival background research. Based on the results of the previous research and ground -disturbing activities, the potential for human remains to exist within the project site is considered unlikely. However, it is possible that unknown human remains could be encountered during ground -disturbing activities associated with project construction.

In the event that human remains are inadvertently encountered during construction activities, the remains and associated resources must be treated in accordance with state and local regulations that provide requirements with regard to the accidental discov ery of human remains, including California Health and Safety Code Section 7050.5, PRC Section 5097.98, and CEQA Guidelines Section 15064.5(e). In accordance with these regulations, if human remains are found, the Los Angeles County Coroner (County Coroner) must be immediately notified of the discovery. No further excavation or disturbance of the project site or any nearby area (within 100 feet of the find) reasonably suspected to overlie adjacent remains must occur until the County Coroner has determined if the remains are potentially human in origin. If the County Coroner determines that the remains are, or are believed to be, Native American, the Coroner is required to notify the NAHC within 24 hours. In accordance with PRC Section 5097.98, the NAHC must immediately notify those persons it believes to be the most likely descendant from the deceased Native American. The most likely descendant must then recommend to the lead agency their preferred treatment of the remains and associated grave goods. Therefore, compliance with state and local regulations identified above would ensure that the project would result in less-than-significant impacts related to the inadvertent disturbance of any human remains.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 50
JUNE 2026

3.6 Energy

Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
VI. Energy – Would the project:
a) Result in potentially significant
environmental impact due to wasteful,
inefficient, or unnecessary consumption of
energy resources, during project
construction or operation?

b) Conflict with or obstruct a state or local plan
for renewable energy or energy efficiency?

a) Would the project result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation? Less-Than-Significant Impact. Project implementation would result in energy use for construction and operation, including the use of electricity and petroleum-based fuels. The following analysis evaluates the potential wasteful, inefficient, or unnecessary consumption of electricity, natural gas, and petroleum during construction and operation.

Construction Energy Use
Electricity
Electricity consumed during project construction would vary throughout the construction period based on the construction activities being performed. Various construction activities would require electricity, including conveying water that would be used for dust control (supply and conveyance), powering any necessary lighting or electronic equipment, or other construction activities necessitating electrical power.

Such electricity demand would be temporary and nominal, and would cease upon the completion of construction. Therefore, the use of electricity during project construction would not be wasteful, inefficient, or unnecessary.

Natural Gas
No natural gas would be used during construction. Equipment and vehicles would be powered by petroleum- based fuels, as discussed below. Therefore, the use of natural gas during project construction would not be wasteful, inefficient, or unnecessary.

Petroleum
Construction of the project would consume energy resources as a result of the use of heavy -duty construction equipment, on-road delivery and haul trucks, and workers commuting to and from the project site. Petroleum emissions associated with the use of con struction equipment and vehicles, which were

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 51
JUNE 2026
used to calculate gallons of petroleum consumed, were calculated using CalEEMod and are provided in Appendix A. Fuel consumption from construction equipment was estimated by converting the total carbon dioxide (CO2) emissions from each construction phase to gallons , using the conversion factors for CO 2 to gallons of gasoline or diesel. The conversion factor for gasoline is 8.78 kilograms per metric ton (MT) CO 2 per gallon, and the conversion factor for diesel is 10.21 kilograms per MT CO 2 per gallon (The Cl imate Registry 2025). The estimated fuel usage from construction of the project is shown in Table 11.

Table 11. Total Proposed Project Construction Petroleum Demand Scenario
Off -Road
Equipment
(Diesel )
Haul Trucks
(Diesel )
Vendor Trucks
(Diesel )
Worker
Vehicles
(Gasoline )
Gallons
Project Construction 75,527 2,977 3,174 6,500
Total Petroleum Consumed for Project Construction 85,178 Source: Appendix A.

In summary, construction associated with the development of the project is estimated to consume a total of approximately 85,178 gallons of petroleum. The project would be subject to CARB’s In -Use Off-Road Diesel Vehicle Regulation, which applies to certain off-road diesel engines, vehicles, or equipment greater than 25 horsepower. The regulation (1) imposes limits on idling, requires a written idling policy, and requires disclosure when selling vehicles; (2) requires all vehicles to be reported to CARB (using the Diesel Off-Road Online Reporting System) and labeled; (3) restricts the adding of older vehicles into fleets starting on January 1, 2014; and (4) requires fleets to reduce their emissions by retiring, replacing, or repowering older engines or installing Verified Diesel Emission Control Strategies (i.e., exhaust retrofits). The fleet must either show that its fleet average index was less than or equal to the calculated fleet average target rate, or that the fleet has met the Best Achievable Control Technology requirements.

Overall, although construction activities would result in the consumption of petroleum-based fuels, consumption of such resources would be temporary and would cease upon the completion of construction.

Further, the petroleum consum ption related to construction would be typical of construction projects of similar types and sizes and would not necessitate new petroleum resources beyond what is typically consumed in California. Therefore, because petroleum use during project construction would be temporary and minimal and would not be wasteful or inefficient, impacts would be less than significant.

Operational Energy Use
Electricity
Project operation would require electricity for the small pump and site lighting. These sources of electricity use are considered negligible and fit within the scope of the City’s communitywide energy demand.

Natural Gas
Long-term operation of the project would not require natural gas consumption, and impacts would be less than significant.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 52
JUNE 2026
Petroleum
During operations, fuel consumption resulting from the project would occur from the use of motor vehicles traveling to and from the project site, as well as fuels used for alternative modes of transportation that may be used by visitors to the project.

Petroleum fuel consumption associated with motor vehicles traveling to and from the project site would be minimal, as it is a function of operational VMT. As discussed in Section 3.18, Transportation, the VMT attributable to the project would be less than 110 VMT per day. Accordingly, fuel consumption from vehicles associated with the project would be negligible.

Over the lifetime of the project, the fuel efficiency of the vehicles being used by the visitors to and maintenance workers for the project is expected to increase. As such, the amount of gasoline consumed as a result of vehicular trips to and from the project site during operation would decrease over time as a result of the numerous regulations in place that require and encourage increased fuel efficiency.

Given these considerations, the petroleum consumption associated with the project would not be considered inefficient or wasteful, and impacts would be less than significant. b) Would the project conflict with or obstruct a state or local plan for renewable energy or energy efficiency? Less-Than-Significant Impact. The project would not include any buildings and would therefore not be required to comply with the majority of the California Building Energy Efficiency Standards (24 CCR Part 6) or the California Green Building Standards (24 CCR Part 11). Any energy consumption related to the project (e.g., outdoor parking lot lighting) would be subject to the appropriate Title 24 standards. As such, the project would comply with the California code requirements for energy efficiency.

Based on these considerations, the project would be consistent with applicable local and statewide energy policies and goals by reducing energy demand through compliance with advanced energy codes and by sourcing electricity from renewable resources. Impacts related to the project’s potential to conflict with plans for renewable energy and energy efficiency would be less than significant.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 53
JUNE 2026

3.7 Geology and Soils

Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
VII. GEOLOGY AND SOILS – Would the project:
a) Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving:
i) Rupture of a known earthquake fault,
as delineated on the most recent
Alquist-Priolo Earthquake Fault Zoning
Map, issued by the State Geologist for
the area or based on other substantial
evidence of a known fault? Refer to
Division of Mines and Geology Special
Publication 42.

ii) Strong seismic ground shaking?
iii) Seismic-related ground failure, including
liquefaction?
iv) Landslides?
b) Result in substantial soil erosion or the loss
of topsoil?
c) Be located on a geologic unit or soil that is
unstable, or that would become unstable as
a result of the project, and potentially result
in on- or off-site landslide, lateral spreading,
subsidence, liquefaction or collapse?

d) Be located on expansive soil, as defined in
Table 18-1-B of the Uniform Building Code
(1994), creating substantial direct or
indirect risks to life or property?

e) Have soils incapable of adequately
supporting the use of septic tanks or
alternative waste water disposal systems
where sewers are not available for the
disposal of waste water?

f) Directly or indirectly destroy a unique
paleontological resource or site or unique
geologic feature?

The analysis in this section is based on the Geotechnical Evaluation prepared for the project by Ninyo & Moore in March 2025.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 54
JUNE 2026
a) Would the project directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving:
i) Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map , issued by the State Geologist for the area or based on other substantial evidence of a known fault? Refer to Division of Mines and Geology Special Publication 42. and
ii) Strong seismic ground shaking?
Less-Than-Significant Impact. The project site is located within a seismically active region, as is most of the Southern California region. The project would likely be exposed to seismic ground shaking at multiple points in the future. The intensity of ground shaking at any specific location within the region depends on the characteristics of the earthquakes, the distance from the earthquake epicenter, and the local geologic and soil conditions. Earthquake fault zones are delineated boundaries encompassing active faults that constitute potential hazards to structures from surface faulting or fault creep (DOC 2018).

The project site is not located within an Alquist -Priolo Earthquake Fault Zone. The closest fault to the project site is the Mount Wilson Fault Zone, located approximately 0.7 miles south of the project site (DOC 2025b). Due to the proximity of the site to active faults , the project area has a high potential to experience strong ground motion. However, project construction and operation would not increase or exacerbate the potential for fault rupture to occur, and engineering design and project development would be performed in accordance with the requirements of governing jurisdictions and applicable building c odes. Therefore, the project would not directly or indirectly cause potential adverse effects involving rupture of a known earthquake fault, and impacts would be less than significant.
iii) Seismic-related ground failure, including liquefaction? Less-Than-Significant Impact. Ground failure is a secondary effect of ground shaking and can include landslides, liquefaction, lurching, and differential settlement. Liquefaction is the loss of soil strength due to seismic forces generating various types of ground failure. Liquefaction occurs when saturated and poorly consolidated granular material is shaken during an earthquake and is transformed into a fluid-like state.

According to maps obtained through the California Department of Conservation and California Geological Survey, the area of the proposed project that includes the location of the proposed pedestrian bridge is not located within a liquefaction zone. However, the southeasternmost end of the site is within a liquefaction zone (DOC 2025b) . The geotechnical investigation determined that the relatively dense to very dense nature of the alluvial materials below the historic high groundwater depth of 40 feet indicate s that the potential for liquefaction and dynamic settlement would be negligible (Ninyo & Moore 2025 ). Additionall y, the proposed project would not include structures for long-term human occupancy. For these reasons, impacts would be less than significant .

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 55
JUNE 2026
iv) Landslides?
No Impact. Landslides typically occur on moderate to steep slopes that are affected by such physical factors as slope height, slope steepness, shear strength, and orientation of weak layers in the underlying geologic units. The project site and surroundings are gen erally flat , with soils stabilized by development and landscaping. The project site is not located within a landslide zone and the project would not result in the creation of moderate to steep slopes that may become susceptible to landslides (DOC 2025b). As such, no impact would occur. b) Would the project result in substantial soil erosion or the loss of topsoil? Less-Than-Significant Impact. Construction of the project would require earthwork activities that would potentially contribute to soil erosion or loss of topsoil. Construction of the project would result in more than 1 acre of land disturbance; therefore, a site -specific SWPPP, in accordance with SWRCB Order No. 2009- 0008-DWQ, National Pollutant Discharge Elimination System General Permit No. CAS00002 (Construction General Permit), amended by Order No. 2010 -0014-DWQ and Order No. 2012 -0006-DWQ, would be prepared and implemented during project construction. One of the purpos es of the SWPPP is to address potential pollutants and their sources, including sources of sediment, and site erosion. Conditions of these existing regulations would include adherence to sediment and stormwater pollutant control BMPs, such as covering of exposed soil stockpiles, sediment barriers, storm drain protection, and various other measures designed to minimize the potential for soil erosion and loss of topsoil. Disturbed areas would be returned to existing conditions or stabilized by new asphalt or landscape plantings. Operation of the proposed stormwater capture and treatment facility , park improvements, and pedestrian bridge would not affect erosion. Therefore, the project would not result in substantial soil erosion of the loss of topsoil and impacts would be less than significant.
c) Would the project be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on - or off-site landslide, lateral spreading, subsidence, liquefaction or collapse?
Less-Than-Significant Impact. As previously discussed, the project site is located in an area susceptible to liquefaction. The geotechnical evaluation included design recommendations that would be incorporated into the final design plans and implemented during construction to minimize potential geotechnical risks, including soil stability, per applicable California Building Code requirements. Therefore, the project would not exacerbate geotechnical hazards related to unstable soils and impacts would be less than significant. d) Would the project be located on expansive soil, as defined in Table 18 -1-B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property? Less-Than-Significant Impact. Expansive soils are clay based and tend to increase in volume due to water absorption and decrease in volume due to drying. The geotechnical evaluation included design recommendations that would be incorporated into the final design plans and implemented during construction, including sampling and analysis of soils on site. If such conditions are encountered, the project would employ standard engineering protocols to limit the potential effects on project -related infrastructure. Therefore, impacts would be less than significant.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 56
JUNE 2026
e) Would the project have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of waste water? No Impact. The project would not involve the use of septic tanks or alternative wastewater disposal systems. Therefore, no impact would occur.
f) Would the project directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
Less-Than-Significant Impact with Mitigation Incorporated. Paleontological resources are the remains or traces of plants and animals that are preserved in the Earth’s crust, and per the Society of Vertebrate Paleontology guidelines (SVP 2010), are older than written history or older than approximately 5,000 years, which approximates the middle Holocene. They are limited, nonrenewable resources of scientific and educational value, which are afforded protection under state laws and regulations.

According to the geotechnical report by Ninyo & Moore ( Ninyo & Moore 2025 ), “it is anticipated that the southwest side of the site, generally adjacent to Eaton Wash, and Eaton Blanche Park have been raised to current site grades with various amounts of fill.” Undocumented fill was encountered in boring B -4 to a depth of approximately 19 feet. Moreover, “alluvium was encountered beneath the fill in boring B-4 and at the ground surface of the remaining borings (except P-6 that encountered shallow refusal) to the explored depths of up to approximately 51.5 feet” (Ninyo & Moore 2025).

According to surficial geological mapping by Dibblee and Ehrenspeck (1998) at a 1:24,000 scale, the project site is underlain by Holocene (<11,700 years ago; Cohen et al. 2024) gravel and sand of major stream channels, with possible Late Pleistocene (approximately 11,700 years ago to 2.58 million years ago) terrace remnants of alluvial gravel and sand deposits mapped approximately 100 meters (330 feet) to the west. The y ounger, Holocene age gravel and sand deposits and undocumented fill within the project site have a low potential to yield paleontological resources and thus require no mitigation during ground-disturbing activities . However, Pleistocene (or “Ice Age”) gravel and sand deposits may be encountered at an unknown depth beneath Holocene gravel and sand deposits ; as such, these deposits have a high potential to produce significant paleontological resources and would require monitoring if impacted during construction.

Although no fossils are recorded from within the project site itself, they are documented nearby from sedimentary deposits similar to those underlying the project site. According to the records search results received from the Natural History Museum of Los Angeles County (NHMLA 2025a) and an in-house records search of the nearby area, the following fossil localities have been documented:
▪ Approximately 2.44 miles northwest of the project site, Los Angeles County Museum Vertebrate Paleontology (LACM VP) 2027 yielded a mammoth from an unknown Pleistocene formation (NHMLA 2025b).
▪ Approximately 7.87 miles southwest of the project site, LACM VP 3363 yielded a fossil horse from an unknown Pleistocene formation (NHMLA 2025a).
▪ Approximately 8.09 miles west -southwest of the project site, LACM California Institute of Technology 342 produced turkey and mammoth specimen s from Quaternary sediments, 14 feet below the ground surface . Both specimens were documented in scientific publications (NHMLA 2019 ).

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 57
JUNE 2026
▪ Approximately 8.18 miles southeast of the project site, San Bernardino County Museum 5.1.14–

5.1.21 produced mastodon, bison, and camel specimens from as shallow as 5 f eet below the ground surface (Caltrans 2014).
▪ Approximately 9 miles southwest of the project site, LACM VP 1652 yielded a sheep specimen from Pleistocene alluvium (NHMLA 2022).
▪ Approximately 9.24 miles southeast of the project site, LACM 1807 produced a mastodon specimen from Pleistocene sediments (NHMLA 2025c; Jefferson 2012).

No paleontological resources were identified within the project site as a result of the institutional records search or desktop geological review. If intact, undocumented paleontological resources are present on site, ground-disturbing activities associated with construction of the project, such as large-diameter (2 feet or greater) drilling, grading during site preparation, and trenching for utilities have the potential to destroy a unique paleontological resource or site. As such, the project site is considered to be potentially sensitive for paleontological resources at depth, and without mitigation, the potential damage to paleontological resources during construction associated with the project is considered a potentially significant impact.

Given the proximity of past fossil discoveries in the surrounding area and potential for underlying Pleistocene-age alluvial deposits, these sedimentary deposits within the project area are considered to be highly sensitive for supporti ng paleontological resources. With implementation of MM-GEO-1, Paleontological Monitoring (see “Mitigation Measures” subsection below) , impacts would be reduced to less than significant with mitigation incorporated.

Mitigation Measures
MM-GEO-1 Paleontological Monitoring. Prior to commencement of grading activity within Pleistocene-age alluvial deposits , the City shall retain a qualified paleontologist per the 2010 Society of Vertebrate Paleontology guidelines. The paleontologist shall prepare a Paleontological Resources Impact Mitigation Program for the project , which shall be consistent with the 2010 Society of Vertebrate Paleontology guidelines. The Paleontological Resources Impact Mitigation Program shall outline requirements for pre - construction meeting attendance and worker environmental awareness training, where monitoring is required within the project site based on construction plans and/or geotechnical repor ts, procedures for adequate paleontological monitoring and discoveries treatment, and paleontological methods (including sediment sampling for microvertebrate fossils), reporting, and collections management. The qualified paleontologist shall attend the pre -construction meeting and a paleontological monitor shall be on site during all rough grading and other significant ground -disturbing activities in previously undisturbed, fine-grained Pleistocene age alluvial deposits. In the event that paleontological resources (e.g., fossils) are unearthed during grading, the paleontological monitor shall temporarily halt and/or divert grading activity to allow recovery of paleontological resources. The area of discovery shall be roped off with a 50 -foot radius buffer. Once documentation and collection of the find is completed, the monitor will remove the rope and allow grading to recommence in the area of the find. Any costs for laboratory work and curation fees at an accredited fossil repository in case of fossil recovery are the responsibility of the City of Pasadena.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 58
JUNE 2026

3.8 Greenhouse Gas Emissions

Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
VIII. GREENHOUSE GAS EMISSIONS – Would the project:
a) Generate greenhouse gas emissions, either
directly or indirectly, that may have a
significant impact on the environment?

b) Conflict with an applicable plan, policy or
regulation adopted for the purpose of
reducing the emissions of greenhouse
gases?

a) Would the project generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment?
and
b) Would the project generate conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases?
Less-Than-Significant Impact. Greenhouse gases (GHGs) are those that absorb infrared radiation (i.e., trap heat) in the Earth’s atmosphere. The trapping and buildup of heat in the atmosphere near the Earth’s surface (the troposphere) is referred to as the “greenhouse effect” and is a natural process that contributes to the regulation of the Earth’s temperature, creating a livable environment on Earth. The Earth’s temperature depends on the balance between energy entering and leaving the planet’s system, and many factors (natural and human) can cause changes in Earth’s energy balance. Human activities that generate and emit GHGs to the atmosphere increase the amount of infrared radiation that gets absorbed before escaping into space, thus enhancing the greenhouse effect and causing the Earth’s surface temperature to rise. Thi s rise in temperature has led to large -scale changes to the Earth’s system (e.g., temperature, precipitation, wind patterns), which are collectively referred to as climate change. Global climate change is a cumulative impact : a project contributes to this impact through its incremental contribution combined with the cumulative increase of all other sources of GHGs. Thus, GHG impacts are recognized exclusively as cumulative impacts (CAPCOA 2008).

As defined in California Health and Safety Code Section 38505(g) , for purposes of administering many of the state’s primary GHG emissions reduction programs, GHGs include CO 2, methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), sulfur hexafluoride (SF6), and nitrogen trifluoride (NF3) (see also CEQA Guidelines Section 15364.5). The primary GHGs that would be emitted by project-related construction and operations include CO2, CH4, and N2O.7 7 Emissions of HFCs, PFCs, SF6, and NF3 are generally associated with industrial activities, including the manufacturing of electrical components and heavy-duty air-conditioning units and the insulation of electrical transmission equipment (substations, power lines, and switch gears). Therefore, emissions of these GHGs were not evaluated or estimated in this analysis because the project would not include these activities or components and would not generate HFCs, PFCs, SF6, or NF3 in measurable quantities.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 59
JUNE 2026
The Intergovernmental Panel on Climate Change developed the global warming potential (GWP) concept to compare the ability of each GHG to trap heat in the atmosphere relative to another gas. The reference gas used is CO2; therefore, GWP-weighted emissions are measured in MT of CO2 equivalent (CO2e). The current version of CalEEMod assumes that the GWP for CH 4 is 25 MT CO2e (so emissions of 1 MT of CH 4 are equivalent to emissions of 25 MT of CO 2), and the GWP for N 2O is 298 MT CO2e, based on the Intergovernmental Panel on Climate Change’s Fourth Assessment Report (IPCC 2007).

Consistency with the Pasadena Climate Action Plan
The Pasadena Climate Action Plan (CAP) was adopted on March 5, 2018, and intends to analyze GHG emissions at a programmatic level, outline a strategy to reduce and mitigate municipal and communitywide GHG emissions, demonstrate Pasadena’s commitment to achieving the statewide emissions reduction targets, and serve as a qualified GHG reduction plan consistent with CEQA Guidelines Section 15183.5 (City of Pasadena 2018). The CAP Consistency Checklist in Appendix D to the CAP (City of Pasadena 2017a) is intended to be used as a tool to determine a project’s consistency with the CAP. Projects that meet the requirements of th e CAP Consistency Checklist would be deemed consistent with the CAP and would be found to have a less -than-significant contribution to cumulative GHGs (i.e., the project’s incremental contribution to cumulative GHG effects would not be cumulatively considerable), pursuant to CEQA Guidelines Sections 15064(h)(3), 15130(d), and 15183(b).

One of three options in Step 3 of the CAP Consistency Checklist can be used to determine consistency with the CAP (City of Pasadena 2017a). Option A requires that the project incorporate sustainable development actions listed in the CAP Consistency Checklist; Option B requires that the project demonstrate consistency with the applicable service person GHG efficiency threshold; and Option C requires that the project achieve net zero GHG emissions.

Option A, which requires that the proposed project incorporate the applicable Sustainable Development Actions as outlined in the CAP Consistency Checklist to ensure that the project contributes to the City’s cumulative GHG reduction goals, was deemed to be the most applicable for the proposed project. The CAP Consistency Checklist was intended to be a tool for new development projects; therefore, many of the Sustainable Development Actions identified therein are not directly applicable to the proposed proje ct, which is primarily a stormwater capture infrastructure project. Nonetheless, Table 12 details the project’s consistency with the applicable actions as identified in the CAP Consistency Checklist.

Table 12. Project Consistency with City CAP Consistency Checklist Option A Sustainable Development Actions
GHG Reduction Strategy Sustainable Development Actions Project Consistency Mandatory Actions
T-1.2: Continue to improve
bicycle and pedestrian safety
Bicycle Storage: Does the project
provide bicycle storage lockers,
racks, or other bicycle storage
facilities for residents/employees?
Not applicable. The project would not
involve residents or full-time
employees. The site would be visited
by nearby residents and periodically
by maintenance staff. Nonetheless,
bike racks would be provided on site
for visitors and staff.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 60
JUNE 2026
Table 12. Project Consistency with City CAP Consistency Checklist Option A Sustainable Development Actions
GHG Reduction Strategy Sustainable Development Actions Project Consistency T-3.1: Decrease annual
commuter miles traveled by
single occupancy vehicles
Transportation Demand Management
(TDM): Does the project include a
TDM plan? A TDM plan is required for
the following projects: multifamily
residential development that are 100
or more units; mixed-use
developments with 50 or more
residential units or 50,000 square
feet or more of non-residential
development; or non-residential
projects which exceed 75,000 square
feet.

Not applicable. The project does
not meet the criteria for a TDM
plan.

T-4.1: Expand the availability
and use of alternative fuel
vehicles and fueling
infrastructure
Alternative Vehicle Fueling Wiring: For
projects with more than three parking
spaces, does the project provide
wiring for at least one 240V Type II
electric car charger?
No conflict. The project features
two small parking areas, which
would include wiring for at least
one 240-volt Type II electric car
charger to accommodate electric
vehicle access.

E-1.2: Encourage the use of
energy conservation devices
and passive design concepts
that make use of the natural
climate to increase energy
efficiency
Passive Design Features: Does the
project utilize passive design
techniques such as awnings or
overhangs on the east, west, and
south facing windows which block the
high summer sun but allow in lower
winter sun?
Not applicable. The project would
not include building space and
would include only passive outdoor
areas for visitors; therefore, the
energy efficiency design features
would not be applicable to the
project.

WC-1.1: Reduce potable water
usage throughout Pasadena
Irrigation Efficiency: Will the project
utilize drought tolerant landscaping
and/or drip irrigation and/or weather
controllers to reduce outdoor water
use?
No conflict. The project’s design is
intended to limit outdoor water
consumption. Landscaping would
feature native and drought-tolerant
plant species. New landscape
areas would be irrigated through a
combination of low-water drip and
rotary irrigation at the surface level,
connected to a typical irrigation
controller and valve system, via
swales and ponds filled with water
from Eaton Wash. Riparian plant
communities would be irrigated via
swales and ponds, with water
redirected from the wash, and via
stormwater during rain events.

WR-1.1: Continue to reduce
solid waste and landfill GHG
emissions
Facilitate Recycling: Does the project
include a space for separate trash
and recycling bins as well as provide
informational signage/handouts for
residents/employees outlining
materials to be recycled?
Not applicable. The project would
not include buildings or involve
residents or employees. The project
would not result in appreciable
long-term solid waste generation.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 61
JUNE 2026
Table 12. Project Consistency with City CAP Consistency Checklist Option A Sustainable Development Actions
GHG Reduction Strategy Sustainable Development Actions Project Consistency Selective Actions – Energy Efficiency and Conservation
E-1.1: Increase energy efficiency
requirements of new buildings
to perform better than 2016
Title 24 Standards
Zero-Net Energy (ZNE): Does the
project generate 100% of electricity
required on site?
Not applicable. Because the project
would not include building space, it
would not be subject to Title 24
standards or the energy efficiency
and conservation measures
described in E-1.1 and E-4.1.

Further, the project would not be a
significant long-term source of
energy consumption.

Energy Efficiency (Exceed 2016 Title
24): Does the project exceed the
2016 Title 24 Efficiency Standards by
at least 5%?
E-4.1: Increase city-wide use of
carbon-neutral energy by
encouraging and/or supporting
carbon-neutral technologies
Renewable Energy: Does the project
generate at least 60% of the
building’s projected electricity needs
through renewable energy?
Selective Actions – Sustainable Mobility and Land Use
T-5.1: Facilitate high density,
mixed-use, transit-oriented, and
infill development
Transit Oriented Development: Is the
project located within 0.25 mile of a
major transit stop as defined in the
Zoning Code?
Not applicable. The project is
located within 0.25 miles of a bus
stop at East Del Mar Boulevard and
Kinneloa Avenue that services Los
Angeles County Metropolitan
Transportation Authority Line 267
and Pasadena Transit Route 60.

The project proposes infrastructure
and park amenities that are not the
focus of this CAP development
action.

Selective Actions – Water Conservation
WC-2.1: Increase access to and
use of non-potable water
Rainwater Capture and Reuse: Does
the project utilize a rainwater capture
and reuse system to reduce the
amount of potable water consumed
on site?
No conflict. The project would not
represent a major long-term source
of potable water consumption, as
landscaping of the site would
primarily feature native and
drought-tolerant species that
require minimal watering.

WC-3.1: Improve storm water to
slow, sink, and treat water run-
off, recharge groundwater, and
improve water quality
Permeable Surfaces: Is at least 30%
of the hardscape (e.g., surface
parking lots, walkways, patios, etc.)
permeable to allow infiltration?
No conflict. The project would
feature minimal hardscape to
accommodate the small parking
areas. The parking areas would be
paved with permeable and open
cell pavers to maximize
groundwater recharge. The project
would also include biofiltration
basins with underdrains to capture
surface site runoff.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 62
JUNE 2026
Table 12. Project Consistency with City CAP Consistency Checklist Option A Sustainable Development Actions
GHG Reduction Strategy Sustainable Development Actions Project Consistency WC-3.1: Improve storm water to
slow, sink, and treat water run-
off, recharge groundwater, and
improve water quality
Stormwater Capture: Is the project
designed to retain stormwater
resulting from the 95th percentile,
24 hour rain event as defined by the
Los Angeles County 95th percentile
precipitation isohyetal map?
No conflict. The project directly
supports the strategy to improve
stormwater management and
water quality, with the primary
purpose of reducing pollutants in
the Rio Hondo/Upper Los Angeles
River Watershed.

Selective Actions – Urban Greening
UG-1.1: Continue to preserve,
enhance, and acquire additional
green space throughout
Pasadena to improve carbon
sequestration, reduce the urban
heat-island effect, and increase
opportunities for active
recreation
Greenspace: Does the project include
at least 500 sq. ft. of public use
greenspace (landscaped yards,
parklets, rooftop garden, etc.)? At a
minimum, 50% of the required
greenspace must include softscape
landscaping (e.g., trees, plants,
grass, etc.).

Not conflict. The project would
include the development of existing
unused property into passive
recreational and educational
spaces for the community. These
proposed amenities include both a
community garden and a pollinator
garden, an aboveground water
feature, a dog park, a riparian
garden, an outdoor classroom, and
new native vegetation.

UG-2.1: Continue to protect
existing trees and plant new
ones to improve and ensure
viability of Pasadena’s urban
forest
Trees: Does the project result in a net
gain of trees? Please include these
specifications on the project plans.

No conflict. The project would
result in a net gain of 449 trees,
including native vegetation, and
would add to Pasadena’s urban
forest.

Source: City of Pasadena 2017a.

As demonstrated in Table 12, the project incorporates several of the GHG reduction strategies that are applicable to the project; therefore, the project is considered consistent with the City’s CAP Consistency Checklist via Option A and thus with the CAP. Therefore, the project is also deemed to be consistent with the GHG reduction targets established under AB 32 and Senate Bill 32.

Because the City’s CAP does not consider the statewide GHG reduction target established under AB 1279, an additional discussion of the project’s consistency with the 2022 CARB Scoping Plan is included below.

Consistency with the 2022 CARB Climate Change Scoping Plan CARB adopted the 2022 Scoping Plan in December 2022. The 2022 CARB Scoping Plan outlines the state’s plan to reach carbon neutrality by 2045 or earlier, while also assessing the progress the state is making toward achieving GHG reduction goals by 2030. Per the Legislative Analyst’s Office, the 2022 CARB Scoping Plan identifies a more aggressive 2030 GHG goal. As it relates to the 2030 goal, perhaps the most significant change in the 2022 Scoping Plan (compared to previous Scoping Plans) is that it identifie s a new GHG target of 48% below the 1990 level, compared to the current statutory goal of 40% below. Current law requires the state to reduce GHG emissions by at least 40% below the 1990 level by 2030, but it does not specify an alternative goal. According to CARB, a focus on the lower target is needed to put the state on a path to meeting the newly established 2045 goal, consistent with the overall path to 2045 carbon

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 63
JUNE 2026
neutrality. The carbon neutrality goal requires CARB to expand proposed actions from only the reduction of anthropogenic sources of GHG emissions to also include those that capture and store carbon (e.g., through natural and working lands or mechanical tec hnologies). The carbon reduction programs build on and accelerate those currently in place, including moving to zero -emission transportation; phasing out use of fossil gas use for heating homes and buildings; reducing chemical s and refrigerants with high G WP; providing communities with sustainable options for walking, biking, and public transit; displacement of fossil-fuel-fired electrical generation through use of renewable energy alternatives (e.g., solar arrays and wind turbines); and scaling up new options, such as green hydrogen (CARB 2022).

Overall, the proposed project would comply with all regulations adopted in furtherance of the 2022 Scoping Plan to the extent applicable and required by law. Scoping Plan measures would result in reductions of project-related GHG emissions with no action required at the project level, including those related to energy efficiency, reduced fossil fuel use, and renewable energy production.

Based on the above considerations, the project would not generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment, nor would it conflict with an applicable plan, policy, or regulation adopted for the purp ose of reducing the emissions of GHGs. Impacts would be less than significant.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 64
JUNE 2026

3.9 Hazards and Hazardous Materials

Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
IX. HAZARDS AND HAZARDOUS MATERIALS – Would the project:
a) Create a significant hazard to the public or
the environment through the routine
transport, use, or disposal of hazardous
materials?

b) Create a significant hazard to the public or
the environment through reasonably
foreseeable upset and accident conditions
involving the release of hazardous materials
into the environment?

c) Emit hazardous emissions or handle
hazardous or acutely hazardous materials,
substances, or waste within one-quarter
mile of an existing or proposed school?

d) Be located on a site which is included on a
list of hazardous materials sites compiled
pursuant to Government Code § 65962.5
and, as a result, would it create a significant
hazard to the public or the environment?

e) For a project located within an airport land
use plan or, where such a plan has not been
adopted, within two miles of a public airport
or public use airport, would the project
result in a safety hazard or excessive noise
for people residing or working in the project
area?

f) Impair implementation of or physically
interfere with an adopted emergency
response plan or emergency evacuation
plan?

g) Expose people or structures, either directly
or indirectly, to a significant risk of loss,
injury or death involving wildland fires?

a) Would the project create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials?
Less-Than-Significant Impact. Relatively small amounts of commonly used hazardous substances such as gasoline, diesel fuel, lubricating oil, adhesive materials, grease, solvents, and architectural coatings would be used during construction. Operation and maintenance of the project wou ld also require routine use of common hazardous substances. These materials are used routinely throughout urban environments for construction projects and operation of utility infrastructure. These materials would be transporte d and

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 65
JUNE 2026
handled in accordance with all federal, state, and local laws regulating the management and use of hazardous materials. Consequently, use of these materials for their intended purpose would not pose a significant risk to the public or environment. With adherence to federal, state, and local regulations, impacts associated with routine transport, use, and disposal of hazardous materials would be less than significant. b) Would the project create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment?
Less-Than-Significant Impact. As discussed in Section 3.9(a), construction and operation would involve relatively small amounts of commonly used hazardous substances such as gasoline, diesel fuel, lubricating oil, grease, adhesive materials, and solvents. These materials are not considered acutely haz ardous and are used routinely throughout urban environments for both construction and operation of projects. Further, these materials would be transported, handled, and disposed of in accordance with all federal, state, and local laws regulating the management of spill prevention and spill response related to hazardous materials.

Impacts would therefore be less than significant.
c) Would the project emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school? Less-Than-Significant Impact. Three schools are located within 0.25 miles of the project site : Willard Elementary School, located at 301 Madre Street, and Wilson Middle School and Rose City High School, co- located at 300 Madre Street. Construction and operation of the proposed project would involve relatively small amounts of commonly used hazardous substances such as gasoline, diesel fuel, lubricating oil, grease, adhesive materials, and solvents. These materials are used routinely throughout urban environments for construction projects and would not pose a significant risk to the public or environment.

These materials would be transported and handled in accordance with all federal, state, and local laws regulating the management and use of hazardous materials.

Additionally, potential health impacts related to construction air emissions are analyzed in Section 3.3, Air Quality, of this IS/MND. MM-AQ-1, Fugitive Dust Control During Construction , and MM-AQ-2, Construction Equipment Emissions Reductions, which require additional site watering and construction equipment emissions reductions (refer to Section 3.3[c] for full text of these mitigation measures), would be incorporated into project construction. As such, impacts would be less than significant. d) Would the project be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code § 65962.5 and, as a result, would it create a significant hazard to the public or the environment?
No Impact. According to the California Department of Toxic Substances Control EnviroStor database, no hazardous materials sites or facilities are located within or adjacent to the project site. The nearest identified active site is Kinneloa Ave nue Property, a Voluntary Cleanup Site, located approximately

0.20 miles north of the project site (DTSC 2025). Other state and local government agencies are required to provide additional hazardous materials release information for the Cortese List. The SWRCB GeoTracker database identifies leaking underground storage tanks, waste discharge sites, oil and gas sites, and other waste or cleanup sites. A review of GeoTracker did not identify any sites or facilities within or adjacent to the project site. The nearest identified site with an open site assessment status is the Goodwill Auto Repair (T0603705548), a Leaking Underground Storage Tank Cleanup Program Site, located approximately

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 66
JUNE 2026

0.70 miles southeast of the project site (SWRCB 2025). These hazardous materials sites are located at adequate distances from the project site, such that they would be of no concern to present a worker hazard for construction crews. Therefore, no impact would occur. e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area? No Impact. The project site is approximately 5 miles north of the San Gabriel Valley Airport ; 6 miles northwest of the RC Airplane Airport at Santa Fe Dam , Irwindale, California; 16.2 miles southwest of the Hollywood Burbank Airport; and 22 miles northeast of the Los Angeles International Airport. The project site does not fall within the airport land use plan for any of these airports and it is not located within 2 miles of a public use airport. Therefore, no impact would occur. f) Would the project impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?
Less-Than-Significant Impact. The City has prepared a Draft Local Hazard Mitigation Plan. The Local Hazard Mitigation Plan is a document that contains information to assist communities in reducing risk from hazards by identifying resources, information, and strategies for risk reduction (City of Pasadena 2025c).

Construction equipment, vehicles, and material would be staged and stored overnight on the project site with adequate site security. Construction staging for the underground storage reservoir modules would be located off site at the Kinneloa Yard or the City -owned property south of the Vina Vieja Dog Park, and the modules would remain on staged delivery truck beds until ready to be installed. Full or partial closures of any public roads for project construction are not anticipated. If temporary closures of Millicent Way or adjoining roadways are required for project construction, the temporary closures would be performed pursuant to a traffic control plan prepared by the contractor and subject to City approval, which would demonstrate that emergency response and evacuation would not be impeded. Traffic would revert to existing conditions upon completion of the project. Because the proposed project would be uninhabited, future emergency response and evacuation planning would not change from current conditions. Impacts would be less than significant.
g) Would the project expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires?
No Impact. According to the California Department of Forestry and Fire Protection (CAL FIRE), the project site is not located within a Local Responsibility Area and is not located within a Very High Fire Hazard Severity Zone ( City of Pasadena 2025 d; CAL FIRE 2025). In the event of an emergency, fire response services for the project would be provided by the Los Angeles Couty Fire Department. Construction and operation of the project would comply with Chapter 14.28 of the PMC, which adopts the California Fire Code by reference. The project would not include structures intended for long -term occupancy or include development that could exacerbate fire risk. The project’s design process would improve the site’s fire safety by implementing fire-safe landscaping measures, such as selecting plant species that are more fire resistant, spacing plantings, and maintaining irrigation at a level that prevents plants from thoroughly drying out in the summer. Furthermore, the project site is relatively flat and the proposed project would not alter land on the project site; therefore , it would not influence prevailing winds or other factors that could exacerbate wildfire risk. As such, people and stru ctures would not be exposed to a significant risk of loss, injury, or death involving wildfires. No impact would occur.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 67
JUNE 2026

3.10 Hydrology and Water Quality

Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
X. HYDROLOGY AND WATER QUALITY – Would the project:
a) Violate any water quality standards or waste
discharge requirements or otherwise
substantially degrade surface or ground
water quality?

b) Substantially decrease groundwater
supplies or interfere substantially with
groundwater recharge such that the project
may impede sustainable groundwater
management of the basin?

c) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would:
i) result in substantial erosion or siltation
on- or off-site;
ii) substantially increase the rate or
amount of surface runoff in a manner
which would result in flooding on-
or offsite;

iii) create or contribute runoff water which
would exceed the capacity of existing or
planned stormwater drainage systems
or provide substantial additional
sources of polluted runoff; or

iv) impede or redirect flood flows?
d) In flood hazard, tsunami, or seiche zones,
risk release of pollutants due to project
inundation?

e) Conflict with or obstruct implementation of
a water quality control plan or sustainable
groundwater management plan?

a) Would the project violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality?
Less-Than-Significant Impact. The project site is located within the boundaries of the ULAR. The ULAR EWMP outlines water quality objectives . The City of Pasadena and ULAR Watershed Management Group have identified the project as a critical project contributing to the compliance goals as set in the ULAR EWMP. Additionally, the 2021 Pasadena Stormwater Master Plan identified an Eaton Wash project site as a high-priority location to help the City achieve its pollutant load reduction compliance in the ULAR and Rio Hondo Watersheds.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 68
JUNE 2026
Construction of the project would involve ground -disturbing activities for grading that could result in sediment discharge in stormwater runoff. Additionally, construction would involve the use of oil, lubricants, and other chemicals that could be discharged from leaks or accidental spills. These potential sediment and chemical discharges during construction would have the potential to impact water quality in receiving water bodies. However, because the proposed project would disturb more than 1 acre of land, the project would be required to prepare and implement a SWPPP, which would include water quality BMPs to ensure that water quality standards are met and that runoff from the construction work areas does not cause degradation of water quality in receiving water bodies. The SWPP would also include the off -site construction staging areas located at the Kinneloa Yard or the City -owned property south of the Vina Vieja Dog Park. Through the incorporation of BMPs and implementation of SWPPP requirements, impac ts associated with water quality standards during construction would be less than significant.

The purpose of the project is to decrease the amount of pollutants in stormwater and dry -weather runoff entering the Eaton Wash and the Rio Hondo River, improving local and regional water quality . The project would be implementing identified improvements in the ULAR EWMP for pollution reduction. Upon operation, existing stormwater flows would be diverted and treated prior to infiltration and/or discharge, resulting in water quality benefits compared to existing conditions. Additionally, runoff from the dog park would be conveyed into a biofiltration basin north of the dog park (see Figure 4) for treatment before it eventually discharges to the infiltration gallery or the post -treatment filter and ultimately the Eaton Wash Channel.

Untreated runoff from the dog park would not be discharged directly into the channel. Ongoing maintenance and sampling would ensure that the project is performing as expected in terms of stormwater treatment.

Therefore, adverse impacts during operation would be less than significant. b) Would the project substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin? Less-Than-Significant Impact. Groundwater was not encountered during subsurface exploration to the explored depths of up to approximately 51.5 feet below ground surface (Ninyo & Moore 2025). The project would include the installation of an underground storage reservoir that would connect to existing storm drains to collect stormwater and would facilitate infiltration of captured stormwater, allowing water to seep into the underlying aquifer and providing natural filtration through the soil . In this way, the project would increase groundwater recharge in areas under the park. The project would not otherwise result in a substantial change in impervious surfaces that would affect groundwater infiltration. The park facilities, as described in Section 2.2.2, Park Improvements, include surface stormwater components , such as an overflow channel leading to a bioswale, riparian planting, and a basin to hold water during storm events, which would collect water flowing across any impervious surfaces and help with ground water infiltration.

Additionally, the project would not entail temporary or permanent use of groundwater and thus would not deplete groundwater in the project vicinity Additionally, the pervious bottom of the storage reservoir would allow for recharge of the Raymond Basin, the groundwater aquifer underlying the project site. Therefore, the project would not substantially decrease groundwater supplies or interfere substantially with groundwater recharge; impacts would be less than significant.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 69
JUNE 2026
c) Would the project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would:
i) Result in substantial erosion or siltation on- or off-site; or
ii) Substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or offsite;
or
iii) Create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff; or
iv) Impede or redirect flood flows?
Less-Than-Significant Impact. The project would not substantially alter existing drainage patterns, including streams or river courses. Construction of the project would entail temporary earthwork to excavate and install the storage reservoir and associated infrastructure . Implementation of the project -specific SWPPP, including BMPs, would prevent substantial erosion and siltation of exposed soils during construction activities. Once construction of the stormwater infrastructure is complete, park facilities, as described in Section 2.2.2, intended to feature nature-based recreational and educational elements would be installed at a site that once housed similar uses.

In operation, the intent of the project is to capture and divert stormwater flows, which would be directed to the underground system and therefore would not result in substantial erosion, siltation, or runoff. Operation of the stormwater infrastructure would improve the stormwater system because it would improve storage and filtration capabilities, which would reduce pollution of stormwater runoff. The project would not result in a substantial change in impervious surfaces within the project site . The park facilities, as described in Section 2.2.2, include surface stormwater components, such as an overflow channel leading to a bioswale, riparian planting, and a basin to hold water during storm events, which would collect water flowing across any impervious surfaces. Additionally, runoff from the dog park would be conveyed into a biofiltration basin for treatment before it eventually discharges to the infiltration gallery or the post -treatment filter and ultimately the Eaton Wash Channel. Therefore, implementation of the project would not substantially alter the existing drainage pattern of the site or area in a way that would cause substantial erosions, flooding, polluted runoff, or changes to flood flows. Impacts would be less than significant. d) In flood hazard, tsunami, or seiche zones, would the project risk release of pollutants due to project inundation?
No Impact. According to Federal Emergency Management Agency (FEMA) flood maps, the project site is located in a Flood Zone X . The western portion of the project site is mapped as an “area of minimal flood hazard” and the eastern portion of the site is mapped as an “ area with reduced flood risk due to levee” (FEMA 2008). Additionally, the project site is not located within a tsunami inundation zone and seiches do not pose a hazard to the project site (DOC 202 5c). The project would include the construction of a stormwater capture and treatment facility, which would improve the water quality of the Eaton Wash, which flows downstream to the Rio Hondo River, then the Los Angeles River, and, ultimately, the Pacific Ocean .

As discussed in Section 3.10(a), the project would involve preparation of a SWPPP, which would include water quality BMPs to ensure that water quality standards are met and that runoff from the construction

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 70
JUNE 2026
work areas would not cause degradation of water quality in receiving water bodies. Upon completion of construction, the project would not require the storage of pollutants that, in the event of inundation, could be released. During larger storm events that fill up the reservoir, water would flow into an outlet pipe and post-treatment filter system, providing additional pollutant removal prior to discharging water back into the Eaton Wash Channel. The water discharged back into Eaton Wash Channel would be similar to existing flow conditions except the water would be pre-treated. Therefore, no impact associated with the risk of release of pollutants due to project inundation in a flood hazard, tsunami, or seiche zone would occur. e) Would the project conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?
Less-Than-Significant Impact. As discussed in greater detail in Chapter 1, Introduction, the proposed project is a critical component of the City’s approach to meeting regional pollutant load reduction goals.

The project would include runoff storage and water quality benefits for the City and other ULAR members, helping to achieve City Stormwater Master Plan goals and MS4 Permit compliance. As such, t he project would implement the applicable water quality control plan for the region. As discussed previously , the project would allow for infiltration into the underlying soils and would not interfere with groundwater supplies. Therefore, the project would not conflict with a water quality control plan or sustainable groundwater management plan and impacts would be less than significant.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 71
JUNE 2026

3.11 Land Use and Planning

Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
XI. LAND USE AND PLANNING – Would the project:
a) Physically divide an established
community?
b) Cause a significant environmental
impact due to a conflict with any land use
plan, policy, or regulation adopted for the
purpose of avoiding or mitigating an
environmental effect?

a) Would the project physically divide an established community? No Impact. The proposed project would be located on a City -owned property east of the Eaton Wash Channel that is vacant and disturbed. T he site is in a developed part of the City that primarily features single-family residences and institutional uses. Institutional uses include an urgent care clinic abutting the site to the north, and to the northeast of the site, the Boys & Girls Club, Willard Elementary School, CALRegional Pasadena adult education center, and a church. The project would not create a physical division of an existing community, such as could occur with the development of a freeway or large linear infrastructure project. The project would entail constructing and operating a stormwater capture, treatment, and infiltration facility on a vacant property east of the channel, developing passive park uses, a dog park, and a community garden within the project site , and constructing a pedestrian bridge over the channel connecting the new features east of Eaton Wash to Eaton Blanche Park. Therefore, the project would not result in the removal of an existing means of access, such as a road or bridge, that would impede mobility between an existing community and other areas. No impact would occur. b) Would the project cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect? No Impact. The project site within the City is designated as Open Space on the City Land Use Diagram (City of Pasadena 2025a) and is zoned as Open Space and Public, Semi -Public on the City Zoning Map (City of Pasadena 2025b). The project site within unincorporated LA County is designated as Public and Semi - Public in the County’s Land Use Policy (County of Los Angeles 2014) and is zoned as R -1 Single Family Residence in the County’s Zoning Map (County of Los Angeles 2025). The project would entail constructing and operating a stormwater capture, treatment, and infiltration facility on a vacant property east of the Eaton Wash Channel, developing passive park uses, a dog park, and a community garden within the project site, and constructing a pedestrian bridge over the channel connecting the new features east of Eaton Wash to Eaton Blanche Park . Upon completion, the project site would be available to the public for recreational use of the park. Implementation of the project would not result in a change to land uses.

Potential environmental impacts associated with the implementation of the project are analyzed throughout this IS/MND. The project will incorporate applicable mitigation measures (see Sections 3.3, Air Quality; 3.4,

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 72
JUNE 2026
Biological Resources; 3.5, Cultural Resources; 3.7, Geology and Soils; 3.9, Hazards and Hazardous Materials; and 3.13, Noise) to reduce environmental impacts. Therefore, the project would not be in conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect. Therefore, no impact would occur.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 73
JUNE 2026

3.12 Mineral Resources

Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
XII. MINERAL RESOURCES – Would the project:
a) Result in the loss of availability of a known
mineral resource that would be a value to
the region and the residents of the state?

b) Result in the loss of availability of a locally
important mineral resource recovery site
delineated on a local general plan, specific
plan or other land use plan?

a) Would the project result in the loss of availability of a known mineral resource that would be a value to the region and the residents of the state?
and
b) Would the project result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan or other land use plan? No Impact. The project site is located in a developed and urban area. The City’s General Plan does not identify any mineral recovery sites within the City (City of Pasadena 2012). Therefore, the project would not result in any loss of availability of a known mineral resource or locally important mineral resource recovery site, and no impact would occur.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 74
JUNE 2026

3.13 Noise

Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
XIII. NOISE – Would the project result in:
a) Generation of a substantial temporary or
permanent increase in ambient noise levels
in the vicinity of the project in excess of
standards established in the local general
plan or noise ordinance, or applicable
standards of other agencies?

b) Generation of excessive groundborne
vibration or groundborne noise levels?
c) For a project located within the vicinity of a
private airstrip or an airport land use plan
or, where such a plan has not been
adopted, within two miles of a public airport
or public use airport, would the project
expose people residing or working in the
project area to excessive noise levels?

This section is based on technical analysis conducted by Dudek, including quantitative predictions of noise emissions based on assumptions developed in consultation with the project design engineers. The results of the noise prediction modeling are provided as Appendix F, Noise Modeling Inputs and Outputs, to this IS/MND.

The majority of the project site is in the southeastern portion of the City with a small portion of the project site, and off-site residences adjacent to the site, falling within unincorporated LA County. The site is in a developed part of the City that primarily features single-family residences and institutional uses. Institutional uses include an urgent care clinic abutting the site to the north, and to the northeast of the site, the Boys & Girls Club, Willard Elementary School, CALRegional Pasadena adult education center, and a church. The urgent care clinic facility is within the City-owned parcel and Exer Urgent Care leases the land for their use.

Represented by locations ST1, ST2, ST3, and ST4 in Table 13 and on Figure 3.13-1, Baseline Sound Pressure Level Measurement Locations, the existing outdoor ambient sound environment of the project location was sampled during a field survey conducted on June 26, 2025. These ambient noise monitor ing locations are intended to be representative of the existing single-family residences and noise-sensitive institutional land uses adjoining project area. Collected sample sound pressure level measurements at these locations, along with documented investigator observations regarding perceived or witnessed acoustic contributors to this baseline or pre -project noise environment, also appear in Table 13. Photographs, tagged survey positions, and instrument details are provided in Appendix F.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 75
JUNE 2026
Table 13. Measured Samples of Existing Outdoor Ambient Sound Level Survey
Position Location Time
Leq
(dBA)
Lmax
(dBA)
L90
(dBA) Notes (Perceived Sound Sources)
ST1 34.141076°,
−118.085894°
10:16 a.m.–
10:31 a.m.
49 60 45 Traffic, birds, distant conversations,
distant dog barking, distant landscape
noise, rustling leaves
ST2 34.141480°,
−118.085022°
09:51 a.m.–
10:06 a.m.
47 63 43 Traffic, birds, distant landscaping,
rustling leaves
ST3 34.140402°,
−118.083051°
10:58 a.m.–
11:13 a.m.
48 59 44 Traffic, birds, distant conversations,
rustling leaves
ST4 34.140259°,
−118.084695°
10:33 a.m.–
10:48 a.m.
44 51 42 Traffic, birds, distant conversations,
rustling leaves
Source: Appendix F.

Notes: Leq = energy equivalent sound level (time-averaged sound level); dBA = A-weighted decibels; Lmax = maximum sound level during the measurement interval; L90 = sound level exceeded 90% of the time.

The measured outdoor energy equivalent sound level (L eq) values presented in Table 13 range from 44 to 49 A - weighted decibels (dBA) and are consistent with expectations for the environment based on the distance to roadways, such as Del Mar Boulevard.

Regulatory Setting and Thresholds of Significance
City of Pasadena Municipal Code
PMC Chapter 9.36 includes noise restrictions (Noise Ordinance). According to PMC Section 9.36.050 (General noise sources), it is unlawful for any person to create, cause, or make or continue to make or permit to be made or continued any noise or sound that exceeds the ambient noise level at the property line of any property by more than 5 decibels (dB; City of Pasadena 2017b).

PMC Section 9.36.060 addresses multifamily residential propert ies. According to this section of the PMC, i t is unlawful to produce sounds at a level greater than those shown in Table 1 of PMC Section 9.36.060 (presented below as Table 14) when measured inside any dwelling unit on the same property or 20 feet from the outside of the source dwelling unit (City of Pasadena 2017b).

Table 14. Interior Noise Standard
Time Interval Interior Noise Standard (dBA)
7:00 a.m. to 10:00 p.m. 60
10:00 p.m. to 7:00 a.m. 50
Source: City of Pasadena 2017b.

Notes: dBA = A-weighted decibel.

Noise impacts from construction and stationary sources are regulated through PMC Section 9.36.070, (Construction Projects), which limits typical construction hours in a residential district or within 500 feet of a residential district to certain hours depending on the day. On weekdays (Monday through Friday), allowable construction hours are from 7:00 a.m. to 7:00 p.m. On Satu rdays, construction can occur between 8:00 a.m. and 5:00 p.m. On Sundays and holidays, construction is prohibited (City of Pasadena 2017b).

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 76
JUNE 2026
In addition to construction hour restrictions, PMC Section 9.36.080 further restricts the noise level of powered construction equipment to no more than 85 dBA when measured at 100 feet from the equipment. PMC Section 9.36.090 also forbids “any person to operate any machinery, equipment, pump fan, air condition apparatus, or similar mechanical device in any manner so as to create any noise which would cause the noise level at the property line of any property to exceed the ambient noise level by more than 5 dB” (City of Pasadena 2017b).

Los Angeles County Noise Regulations
Section 12.08.440 of the LA County Code of Ordinances addresses construction noise restrictions. Construction activity is prohibited between the hours of 7:00 p.m. and 7:00 a.m. Monday through Saturday and all day on Sundays, in cases where the noise would create a disturbance across a residential property line. For single -family residences, that disturbance noise level overnight is defined as greater than 50 dBA (for construction with a duration greater than 10 days). For construction lasting less than 10 days, or when “mobile” construction equipment is in use, the daytime (i.e., between 7:00 a.m. and 7:00 p.m.) limit for noise exposure at a single-family residential property affected by the construction noise is 75 dBA. For construction lasting longer than 10 days, or when “stationary” construction equipment is in use, the daytime limit for noise exposure at a single -family residential property affected by the construction noise is 60 dBA (County of Los Angeles 1978).

With respect to sources of groundborne vibration, such as the operation of installed electro-mechanical equipment on a site, the LA County Code (Section 12.08.560) also specifies that operating or permitting the operation of any device that creates vibration that is above the vibration perception threshold of any individual at or beyond the property boundary of the source if on private property, or at 150 feet (46 meters) from the source if on a public space or public right-of-way, is prohibited. The LA County Noise Regulations were used to assess noise impacts at the unincorporated LA County residence along Thorndale Road, the nearest noise sensitive receptor, east of the project site.
a) Would the project result in generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies?
Construction
Less-Than-Significant Impact with Mitigation Incorporated. Construction of the project would result in the temporary generation of noise at the project site. Construction would involve the use of heavy equipment and machinery, such as excavators, loaders, cranes, temporary generators, scrapers, and other equipment. Construction would generate levels of noise that can vary from hour to hour and day to day depending on the equipment in use, the operations being performed, and the distance between the source and receptor. Typically, construction equipment operates in alternating cycles of full power and low power, producing average noise levels less than the maximum noise level. The average sound level of construction activity also depends on the amount of time that the equipment operates and the intensity of construction activities during that time.

Table 15 provides a list of the sound levels generated by various powered equipment that could be associated with construction of the project, measured at a distance of 50 feet , using a “slow” response time constant (1 second). Sound source information was obtained from the Noise Source Database developed under National Cooperative Highway Research Program 25-49 (NCHRP 25-49), Development of a Highway Construction Noise Prediction Model (NASEM 2022).

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 77
JUNE 2026
Table 15. Sound Levels of Typical Construction Equipment Equipment
Maximum Sound Level (dBA L max) at
50 Feet from Source
Energy E quivalent Sound Level
(dBA L eq) at 50 Feet from Source
Air compressor 67 66
Aerial lift (man lift) 73 72
Backhoe 84 76
Compactor (plate) 75 N/A
Compactor (roller) 83 N/A
Concrete mixer 82 81
Concrete saw 88 85
Crane, mobile 76 74
Dozer 86 80
Forklift 88 N/A
Generator 68 67
Grader 79 N/A
Horizontal bore drill 88 87
Loader 81 72
Paving – asphalt 83 N/A
Paving – concrete 88 85
Pump 74 73
Scraper 92 N/A
Flatbed truck 74 N/A
Welding machine 72 71
Source: NASEM 2022.

Notes: dBA = A-weighted decibel; Lmax = maximum instantaneous noise level; Leq = energy equivalent sound level; N/A = not applicable:
equipment without energy equivalent sound levels (Leq) are non-stationary and best represented only by maximum instantaneous noise level (Lmax).

Aggregate noise emission from construction activities, broken down by phase, was predicted at the following distances: (1) 100 feet away from construction activities, per PMC Section 9.36.080, and (2) the nearest distance from a single-family residence adjoining the project boundary along Thorndale Road , in unincorporated LA County , to each construction phase area across the project site (i.e., reservoir excavation/construction, pedestrian bridge construction). For the receptor located in unincorporated LA County, per Section 12.08.440 of the LA County Code of Ordinances, construction equipment by phase was separated into “mobile” and “stationary” equipment in Table 15; the City does not require such separation of equipment. The construction activities that are expected to occur, grouped by phase, are shown in Table 3, Construction Scenario Details (Section 3.3, Air Quality).

Using the roster from Table 3 as guidance for input parameters, and as detailed in the worksheets appearing in Appendix F, combined construction noise emissions for each listed phase were predicted with a model that emulates an updated version of the Federal Highway Administration Roadway Construction Noise Model and utilizes its reference sound level data by equipment type (e.g., selected data from Table 15; FHWA 2008). The predicted noise level exposures from the proposed construction activities are summarized in Table 16.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 78
JUNE 2026
Table 16. On-Site Construction Noise Model Results Summary Construction
Phase
Distance
to Nearest
County
NSR
(Feet)
Construction Noise at Nearest County NSR a
(dBA) Construction Noise
at 100 feet from
Activity b (dBA) Mobile Equipment Stationary Equipment Phase
1-hour
Leq
Loudest
Equipment
Lmax d
Phase
1-hour
Leq
Loudest
Equipment
Lmax d
Phase
8-hour
Leq
Loudest
Equipment
Lmax d
Demolition of
project site
structures/open
space area
230 68 63 N/A N/A 77 72
Site preparation,
clearing and
grubbingc
230 69 73 60 60 79 72
Reservoir
excavation
280 66 61 N/A N/A 77 72
Reservoir
construction
625 57 53 N/A N/A 76 72
Installation of
pipe, diversion
structure,
actuated valve,
trash trap, pre-
treatment unit,
and pump
625 54 49 N/A N/A 73 68
Installation of
outlet line, flow
control structure,
and cartridge
filter treatment
unit
625 58 53 N/A N/A 77 72
Pedestrian bridge
construction
670 54 48 N/A N/A 73 67
Project site
improvements
50 88 82 N/A N/A 79 74
Source: FHWA 2008; Appendix F.

Notes: NSR = noise-sensitive receptor; dBA = A-weighted decibels; Leq = energy equivalent sound level; Lmax = maximum sound level during the measurement interval; N/A = not applicable.

See Appendix F for complete results.

Bolded values indicate an exceedance of the applicable significance threshold. a Per Section 12.08.440 of Los Angeles County’s Code of Ordinances, the construction noise limit for mobile equipment is 75 dBA Leq, or 60 dBA Leq for stationary equipment.
b Per PMC Section 9.36.080, the construction noise limit is 85 dBA at 100 feet from construction activities. c Predictive analysis assumes a jackhammer is used behind 4-foot × 8-foot plywood sheeting during construction. d Loudest single piece of equipment for indicated phase.

As presented in Table 16, construction noise during all phases would not exceed 85 dBA at 100 feet. Thus, construction noise is predicted to comply with Section 9.36.080 of the City Municipal Code. Lower levels of noise would also be generated at whichever off site construction staging area is selected for contractor use, both of which are in the City. At these locations nearby residences may perceive occasional noise

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 79
JUNE 2026
generated by deliveries, worker vehicle access, and equipment accessing and moving around the staging areas. Occasional construction traffic would generate noise along the routes travelling between the respective staging area and the construction site , including residential streets . This intermittent construction-related activity would not generate noise levels that would exceed City standards.

With respect to Section 12.08.440 of the LA County Code of Ordinances, operation of stationary construction equipment would comply with the applicable daytime limit of 60 dBA Leq measured over 1 hour (Leq[h]), as summarized in Table 16. However, although mobile construction equipment operation would comply with the applicable daytime limit of 75 dBA L eq(h) during most phases, the estimated construction noise from mobile equipment exceeds the applicable limit during the project site improvements phase, as illustrated in Table 16. Thus, MM -NOI-1, Temporary Construction Noise Reduction , is recommended and studied in the predictive analysis, which assumes the implementation of a 10 -foot-tall temporary noise barrier during the project site improvements phase, strategically placed along the eastern project boundary where the SCE easement adjoins the off -site unincorporated LA County residence along Thorndale Road.

Table 17 presents the predicted construction noise levels during the project site improvements phase with the incorporation of MM-NOI-1 (refer to the “Mitigation Measures” subsection at the end of this section for the text of MM-NOI-1).

Table 17. On-Site Construction Noise Model Results Summary – Mitigated Construction
Phase
Distance to
Nearest
County NSR
(Feet)
Construction Noise at Nearest County NSR a
(dBA) Construction Noise at
100 feet from
Activity b (dBA) Mobile Equipment Stationary Equipment Phase
1-hour
Leq
Loudest
Equipment
Lmax d
Phase
1-hour
Leq
Loudest
Equipment
Lmax d
Phase
8-hour
Leq
Loudest
Equipment
Lmax d
Project site
improvements
50 73e 67e N/A N/A 79 74
Notes: NSR = noise-sensitive receptor; dBA = A-weighted decibels; Leq = energy equivalent sound level; Lmax = maximum sound level during the measurement interval; N/A = not applicable.

See Appendix F for complete results.
a Per Section 12.08.440 of Los Angeles County’s Code of Ordinances, the construction noise limit for mobile equipment is 75 dBA Leq, or 60 dBA Leq for stationary equipment.
b Per PMC Section 9.36.080, the construction noise limit is 85 dBA at 100 feet from construction activities. c Predictive analysis assumes a jackhammer is used behind 4-foot × 8-foot plywood sheeting during construction. d Loudest single piece of equipment for indicated phase. e Assumes installation of 10-foot-tall temporary noise barrier during construction phase/activity, per MM-NOI-1.

MM-NOI-1 would require the City to implement certain noise reduction measures as site conditions warrant.

Proper implementation of MM -NOI-1 would reduce noise levels by up to 15 dB if a 10 -foot-tall temporary construction noise barrier is implemented during the project site improvements construction phase along the eastern project boundary, which would correspondingly reduce the highest predicted estimated non-mitigated construction noise level from 88 dBA Leq (h) to 73 dBA Leq (h), which would be within th e applicable 75 dBA Leq(h) threshold for mobile equipment.

With the implementation of MM -NOI-1, estimated construction noise levels are predicted to reach up to 73 dBA Leq(h) at the nearest existing residences, located along Thorndale Road at the project site’s eastern boundary during site preparation and project site improvements activities. Such levels would be up to 22 dB higher than existing outdoor ambient noise levels measured at ST3, or up to 26 dB higher than those

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 80
JUNE 2026
measured at ST4 (Table 13). Given that these levels are below the City and LA County thresholds, construction-related impacts would be less than significant with mitigation incorporated.

Operation
Less-Than-Significant Impact. Upon completion of construction, the project would feature underground infrastructure and above-ground park uses . The stormwater capture system would include a pump with powered mechanical systems installed in underground vaults with hatches for personnel access. Noise from the operation of the stormwater capture system would be isolated by the closed access hatch , resulting in negligible noise levels.

The project’s park improvements and dog park would introduce increased pedestrian foot traffic to the area. Resulting sound sources may include conversations, children playing, or dogs barking that may be received at off-site residences. These noises are common in an urban setting such as the project location, and such activities would not result in a noticeable change in measured noise levels. Noise from the dog park received at nearby residences would be further minimized by its distance from the residences, approximately 225 feet from the nearest home, it’s placement at a slightly lower elevation than the residences, and intervening vegetation, all of which would serve to attenuate sound levels generated by public activity at the park. While noise from increased activity at the site may be noticeable to nearby residences, they would not be considered a significant impact pursuant to CEQA.

On this basis, compared to the measurement samples of Leq presented in Table 13, project operation noise is anticipated to be comparable to or less than the existing outdoor ambient level at the nearest existing homes and thereby to comply with the noise level thresholds set forth in both County and City codes. For these reasons, project operational noise impacts would be less than significant.

Mitigation Measures
MM-NOI-1 Temporary Construction Noise Abatement. The City shall install noise abatement during the project site improvements phase, strategically placed along (or within, as practical and appropriate) the eastern project site boundary where the SCE easement adjoins the off-site unincorporated LA County residence along Thorndale Road.

Noise abatement shall be in the form of sound blankets or comparable temporary solid barriers to occlude construction noise emission between the site (or specific equipment operation as the situation may define) and the noise sensitive receptor(s) of concern (i.e., where the line -of-sight is blocked). By way of example, suspended sound blankets, field - erected plywood sheeting, or comparable temporary solid or flexible but sufficiently massive barriers (of minimum sound transmission class [STC] rating of 25) would occlude construction noise emission between the site and the noise-sensitive receptor(s) of concern.

During the project site improvements phase of construction, noise abatement in the form of sound blankets or temporary solid barriers must be at least 10-feet in height to achieve on-site noise control and sound abatement that would result in a minimum construction noise reduction of approximately 13 decibels (dB) at the unincorporated LA County residence along Thorndale Road, east of the Southern California Edison ( SCE) easement within the project work limits.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 81
JUNE 2026
In addition to the noise abatement discussed above, the following measures should be considered as supplemental abatement strategies to sufficiently reduce construction noise emission:

A. Implement administrative controls (e.g., reduce operating time of equipment and/or prohibit usage of equipment type[s] within certain distances to the nearest receiving occupied off-site property).

B. Implement e ngineering controls (change equipment operating parameters [e.g., speed, capacity], or install features or elements that otherwise reduce equipment noise emission [e.g., upgrade engine exhaust mufflers]).

Appendix F to this IS/MND includes a construction noise prediction worksheet that illustrates a sample scenario of what the anticipated and quantifiable noise reduction effect would be of adding a temporary 10 -foot-tall noise barrier to reduce construction noise exposure at the unincorporated LA County residence along Thorndale Road. Such a wall should be strategically located on the eastern project boundary so as to reduce construction noise exposure by occluding direct line of sight between construction activities and the sensitive receptor of concern.
b) Would the project result in generation of excessive groundborne vibration or groundborne noise levels? Less-Than-Significant Impact. Vibration is oscillatory movement of mass (typically a solid) over time.

Depending on their distances to a sensitive receptor, operation of large bulldozers, graders, loaded dump trucks, or other heavy construction equipment and vehicles on a construction site have the potential to cause high vibration amplitudes.

For purposes of this impact assessment, a vibration velocity level of 0.2 inches per second (ips) peak particle velocity (PPV) is used as the standard for evaluating human annoyance (to perceived groundborne vibration within an occupied structure) and for the potential risk of residential building damage due to “continuous” or frequently occurring groundborne vibration events (Caltrans 2020).

Groundborne vibration attenuates rapidly, even over short distances. The attenuation of groundborne vibration as it propagates from source to receptor through intervening soils and rock can be estimated with expressions found in Federal Transit Administration and Caltrans guidance. For example, if a bulldozer were operating as close as 50 feet to the nearest receiving sensitive land use during the demolition or site preparation construction phases, the estimated vibration velocity level would be 0.031 ips, per the equation as follows (FTA 2018):

PPVrcvr = PPVref × (25/D)1.5 = 0.031 ips PPV = 0.089 × (25/50)1.5 In the above equation, PPV rcvr is the predicted vibration velocity at the receiver position (i.e., residence), PPVref is the reference value at 25 feet from the vibration source (the bulldozer), and D is the actual horizontal distance to the receiver from the source.

Based on the identified distance between construction activities and the closest existing residential structures, predicted groundborne vibration velocity PPV values associated with project construction are

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 82
JUNE 2026
below the 0.2 ips PPV threshold for building occupant annoyance and building damage risk. Impacts during construction would therefore be less than significant.

Once operational, the proposed project would not be expected to feature major producers of groundborne vibration. For this reason, project operation impacts from groundborne vibration at off-site receptors would be considered less than significant.
c) For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels? No Impact. There are no public airports or private airfields within 2 miles of the project site and the project area is far from any aviation traffic noise contour greater than 65 dBA community noise equivalent level.

Construction workers and park users would not be exposed to significant aviation noise levels ; therefore, no impact would occur.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 83
JUNE 2026

3.14 Population and Housing

Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
XIV. POPULATION AND HOUSING – Would the project:
a) Induce substantial unplanned population
growth in an area, either directly (for
example, by proposing new homes and
businesses) or indirectly (for example,
through extension of roads or other
infrastructure)?

b) Displace substantial numbers of
existing people or housing, necessitating
the construction of replacement
housing elsewhere?

a) Would the project induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)?
No Impact. Construction of the project would result in a temporary direct increase in construction jobs in the area. However, given the relatively small footprint of the project construction and the comparatively short anticipated schedule, the demand for construction employment would likely be met within the existing and future labor market in the City and in the greater Los Angeles County area. If construction workers live outside the City, these workers would likely c ommute only during the temporary construction pe riod.

Operationally, the project does not contain land uses that typically result in direct population growth, such as new homes or large commercial/business centers. The project would improve the existing, vacant site to further serve the existing and anticipated future demand for recreational uses within the City.

Additionally, the project is consistent with underlying land use and zoning designations. Therefore, the project would not directly result in substantial unplanned population growth in the area.

The project site is in an area served by existing roads and infrastructure. The project would not include the extension of utility infrastructure, such as sewer lines or roads, into previously undeveloped areas , which could indirectly induce growth. Therefore, the project would not indirectly result in substantial unplanned population growth in the area. No impact would occur.
b) Would the project displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere?
No Impact. The project site does not contain any existing housing or provide other means of housing people. The project would not displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere. No impact would occur.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 84
JUNE 2026

3.15 Public Services

Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
XV. PUBLIC SERVICES – Would the project:
a) Result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for any of the public services:

Fire protection?
Police protection?
Schools?
Parks?
Other public facilities?

a) Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significa nt environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for any of the public services:

Fire protection? Police protection? Schools? Parks? Other public facilities? No Impact. The project would entail constructing and operating a stormwater capture, treatment, and infiltration facility on a vacant property east of the Eaton Wash Channel, developing passive park uses , a dog park, and a community garden within the project site , and constructing a pedestrian bridge over the channel connecting the new features east of Eaton Wash to Eaton Blanche Park. . As discussed in Section 3.14, Population and Housing, the project would not induce substantial unplanned population growth in the area. Additionally, the project would not result in a substantial increase in the number of emergency calls because the project does not propose uses or components associated with the need for additional fire, police, or emergency medical services. As such, construction, operation, and maintenance of the project would not require new or physically altered facilities associated with fire protection, police protection, schools, parks, or other public facilities. Therefore, no impact would occur.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 85
JUNE 2026

3.16 Recreation

Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
XVI. RECREATION
a) Would the project increase the use of
existing neighborhood and regional parks or
other recreational facilities such that
substantial physical deterioration of the
facility would occur or be accelerated?

b) Does the project include recreational
facilities or require the construction or
expansion of recreational facilities which
might have an adverse physical effect on
the environment?

a) Would the project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated? Less-Than-Significant Impact. The project would entail developing new public recreation amenities and constructing a pedestrian bridge over the Eaton Wash channel to connect the new features to Eaton Blanche Park. Most of Eaton Blanche Park is expected to remain open to the public during construction , although a part of the p ark would be closed for construction of the bridge and access path to the bridge.

Upon completion of construction, the new facilities would potentially attract new users that would incrementally increase the use of Eaton Blanche Park. However, the scale of the new facilities and the types of activities that would occur at the site are not anticipated to create a significant attraction to new users that would increase the use of Eaton Blanche Park such that physical deterioration of facilities would occur or be accelerated. As such, impacts to recreational facilities would be less than significant. b) Does the project include recreational facilities or require the construction or expansion of recreational facilities, which might have an adverse physical effect on the environment? Less-Than-Significant Impact. The project would include park improvements at the project site and constructing a pedestrian bridge over the channel connecting the new features east of Eaton Wash to Eaton Blanche Park. Most of Eaton Blanche Park is expected to remain open to the public during construction. As discussed in Section 3.14, Population and Housing, implementation of the project would not induce population growth. As such, the project would not require the construction or expansion of recreational facilities. Potential environmental impacts and mitigation measures associated with the implementation of the project, which includes recreational facilities, are analyzed throughout this IS/MND. The project will incorporate applicable mitigation measures (see Sections 3.3, Air Quality; 3.4, Biological Resources; 3.5, Cultural Resources; 3.7, Geology and Soils; 3.9, Hazards and Hazardous Materials; and 3.13, Noise) to reduce environmental impacts. Impacts would be less than significant.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 86
JUNE 2026

3.17 Transportation

Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
XVII. TRANSPORTATION – Would the project:
a) Conflict with a program, plan, ordinance or
policy addressing the circulation system,
including transit, roadway, bicycle and
pedestrian facilities?

b) Conflict or be inconsistent with CEQA
Guidelines § 15064.3, subdivision (b)?
c) Substantially increase hazards due to a
geometric design feature (e.g., sharp curves
or dangerous intersections) or incompatible
uses (e.g., farm equipment)?

d) Result in inadequate emergency access?

a) Would the project conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities? Less-Than-Significant Impact. The project would not conflict with applicable programs, plans, ordinances, or policies addressing the circulation system, as further discussed below. This includes the City ’s General Plan Mobility Element (City of Pasadena 2015a); the City’s Pedestrian Transportation Action Plan (TAP) (City of Pasadena 2024); the City’s Bicycle TAP (City of Pasadena 2015b) ; and the existing and proposed roadway, pedestrian, bicycle and transit facilities and services in the project area.

General Plan Mobility Element
The vision of the Mobility Element is to promote a livable community where people can circulate without cars. Consistent with this principle, the Mobility Plan has four primary objectives that guide how the City’s transportation system is managed: Promote a livable and economically strong community, encourage non- auto travel, protect neighborhoods by discouraging traffic from passing through neighborhoods, and manage multimodal corridors to improve citywide transportation services (City of Pasadena 2015a).

City of Pasadena Pedestrian Transportation Action Plan
The City of Pasadena Pedestrian TAP (2024) prioritizes and guides investments to create a safer and more walkable Pasadena. The Pedestrian TAP focuses on the implementation of Pasadena’s planning efforts and creates tangible and constructible improvements within the context of the City’s built environment. The Pedestrian TAP aims to make walking in the City safer, more comfortable, and more convenient and accessible for pedestrians of all ages and abilities. The primary goals of the Pedestrian TAP include the following: improve conditions for people walking, increase the percentage of walking trips, improve connections to surrounding destinations, and reduce the environmental impacts of driving and the number of miles traveled by people who drive (City of Pasadena 2024).

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 87
JUNE 2026
City of Pasadena Bicycle Transportation Action Plan
The City of Pasadena Bicycle TAP (2015b) provides specific goals, objectives, actions, and timelines for creating an environment where people can circulate without a car; that significantly increases the number of people who commute by bike and who use a bike for utilitarian trips, fitness, and recreation ; and that provides business and economic benefits for the City. The Bicycle TAP provides details for a network of bikeways so that every neighborhood is within 0.25 miles of an effective bicycling route in the north–south and east–west directions. The Bicycle TAP outlines educational, engagement, enforcement, and evaluation strategies designed to increase bicyclist safety by educating both bicyclists and motorists and outlines strategies for funding the program . A Bikeways Analysis and Feasibility Study was conducted to evaluate the possibility of constructing buffered bike lanes, cycle tracks, or bicycle boulevards on specific roadways throughout the City. The Bicycle TAP builds on the feasibility study and lays out an action plan for the installation of buffered lanes, cycle tracks, and bike boulevards along 10 corridors. In addition, it outlines educational, public outreach, and funding strategies (City of Pasadena 2015b).

Transit, Bicycle, and Pedestrian Facilities
Public transportation in the City is provided by Pasadena Transit, Foothill Transit, Los Angeles Department of Transportation, and the Los Angeles County Metropolitan Transportation Authority (Metro). The nearest transit routes to the project site are Metro Line 267, with service between Altadena, Pasadena, and El Monte via Del Mar Boulevard and Temple City Boulevard, and Pasadena Transit Route 60, with service to the Sierra Madre Villa Metro A Line Station via Del Mar Boulevard. The nearest bus stop to the project site is located at the intersection of East Del Mar Boulevard and Kinneloa Avenue, approximately 0.05 miles north of the project site, servicing Metro Line 267 and Pasadena Transit Route 60. Metro Line 267 operates from approximately 4:45 a.m. to 10:23 p.m. on weekdays, and from 6:00 a.m. to 9:35 p.m. on weekends (Metro 2025). Pasadena Transit Route 60 operates during the AM and PM peak hours on we ekdays (City of Pasadena 2025e).

There are numerous bike facilities in the vicinity of the project site, including a Class II bike lane on Kinneloa Avenue between East Foothill Boulevard and East Del Mar Boulevard and a Class II bike lane on Madre Street between East Del Mar Boulevard and Thorndale Road. The City of Pasadena is well served by sidewalks, with relatively few gaps in the sidewalk network. Sidewalks are present along most roads in the vicinity of the site.

Impact Analysis
The project entails constructing and operating a stormwater capture, treatment, and infiltration facility on a vacant property east of the Eaton Wash Channel, developing passive park uses , a dog park, and a community garden within the project site, and constructing a pedestrian bridge over the channel connecting the new features east of Eaton Wash to Eaton Blanche Park.

Construction
The construction phase is expected to cause a temporary, short -term increase in traffic, due to the arrival of construction workers and the delivery of materials and equipment to the site. The total duration of project construction is anticipated to be 22 months, with some phases overlapping. Typical construction work hours would be Monday through Friday, 7:00 a.m. to 7:00 p.m., pursuant to the PMC, with no night work

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 88
JUNE 2026
anticipated. Construction activities would be carried out in compliance with the City’s noise and construction regulations, ensuring that heavy equipment is used only during the permitted hours. The project would involve traffic impacts primarily related to construction activities, and these impacts are expected to be temporary.

Regional access to the project site is from I-210, which is approximately 0.4 mile s to the north. Direct construction access to the eastern part of the project site would be from Thorndale Road and Grayburn Road, both of which dead -end at existing gates leading to the City property and the SCE right -of-way, along with a maintenance road along the Eaton Wash Channel’s eastern bank that connects to East Del Mar Boulevard. Access to the western part of the project site would be via Millicent Way, with a small parking lot connected to Millicent Way. Local construction access would be provided from East Del Mar Boulevard. Construction access would be coordinated with the urgent care facility, or with SCE (for use of their easement ), or with LA County Flood Control District (for use of their channel maintenance road ).

Construction equipment, vehicles, and material would be staged and stored overnight on the project site with adequate site security. Construction staging for the underground storage reservoir modules would be located off site at the Kinneloa Yard or the City -owned property south of the Vina Vieja Dog Park, and the modules would remain on staged delivery truck beds until they are ready to be inst alled. Delivery trucks from Kinneloa Yard would travel to the project site via South Kinneloa Avenue and East Del Mar Boulevard and delivery trucks from the City -owned property south of the Vina Vieja Dog Park would travel to the project site via Avocado Avenue, Alameda Street, Sierra Madre Villa Avenue / Madre Street, and East Del Mar Boulevard.

Full or partial closures of any public roads for project construction are not anticipated. If temporary closures of Millicent Way or adjoining roadways are required for project construction, the temporary closures would be performed pursuant to a traffic control plan prepared by the contractor and subject to City approval. The traffic control plan would include measures such as identifying the proposed truck routes, minimizing and/or avoiding truck travel during peak hours, and using flaggers for local site access, along with other measures.

All lane closures would be performed pursuant to the traffic control plan. With implementation of the traffic control plan, the potential impact on local circulation would be minimized and there would be no changes that would affect the safety and accessibility of the transportation system.

Construction of the stormwater capture facility would entail excavating earth en material. The excavated material would be placed in dump trucks and hauled off site to a licensed landfill or quarry for reuse or disposal. The full extent of the material haul route or routes would be determined by the contractor and the City Public Works Department once a disposal site has been identified. It is anticipated that the local route would follow East Del Mar Boulevard to access Sierra Madre Boulevard (which is a de signated City truck route) to connect to I-210, which is a designated state truck route (City of Pasadena 2016). Due to the nominal and temporary increase in construction traffic, any effect on the operations of roadways or the overall circulation system along these roads would be minimal.

The nearest bicycle facility to the project site is a Class II bike lane on Madre Street between East Del Mar Boulevard and Thorndale Road . Metro Line 267 and Pasadena Transit Route 60 are the nearest transit routes to the site, with service on East Del Mar Boulevard and bus stop s at the intersection of East Del Mar Boulevard and Kinneloa Avenue. The transit, bicycle, and pedestrian facilities would remain open during construction, and the temporary and minimal VMT increase caused by construction-related traffic would not interfere with existing public transit, bicycle, or pedestrian facilities. Impacts would be less than significant.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 89
JUNE 2026
Operations
The park improvements would allow for passive recreation uses, as detailed in Section 2.2 .2, Park Improvements. Once the project is constructed, the proposed park would be accessible by pedestrians via the proposed pedestrian bridge across Eaton Wash that connects to Eaton Blanche Park , as well as from the pedestrian path extending from Thorndale Road to the eastern portion of the project site, which would provide access to Willard Elementary School and the Boys & Girls Club. Two small parking lots would be provided. One parking lot would be provided at the north end of the site, which would be accessed from the southeast corner of the urgent care clinic parking lot via East Del Mar Boulevard . The other parking lot would be provided at the east end of the site, which would be accessed from a vehicular access road that extends from Thorndale Road to the project site and would be for maintenance vehicles only.

The project would not include site improvements that would extend into the public right-of-way or interfere with the existing roadway network ; interfere with public transit, bicycle, or pedestrian facilities ; or impede the construction of new or the expansion of existing facilities in the future. Bicyclist and pedestrian safety would be maintained at existing levels in the area and improvements to the sidewalk along Thorndale Road, adjacent to Willard Elementary School, would improve pedestrian safety. The project would also not severely delay, impact, or reduce the service level of transit in the area. Operation of the project would result in a minor increase in activity at the site that would lead to park users parking vehicles on nearby residential streets; however, public street parking by non-residents is allowable and common in an urban setting such as the project location, and this would be similar to street parking generated by other existing nearby uses, such as Willard Elementary School , Wilson Middle School, and the tennis courts on Madre Street. This increase in parking may be noticeable to residents in the affected area , but would not be considered a significant impact pursuant to CEQA. Additionally, the project would not have an impact on traffic circulation or result in significant changes to the existing transportation network. Consequently, the project would be in compliance with the City’s transportation policies, which aim to maintain a safe, integrated, and multi - modal transportation network.

Therefore, the proposed project would not conflict with the circulation policies in the City’s General Plan .

Impacts would be less than significant.
b) Would the project conflict or be inconsistent with CEQA Guidelines § 15064.3, subdivision (b)? Less-Than-Significant Impact. CEQA Guidelines Section 15064.3(b) focuses on VMT for determining the significance of transportation impacts. The updated CEQA Guidelines state that “generally, vehicle miles traveled (VMT) is the most appropriate measure of transportation impacts,” and define VMT as “the amount and distance of automobile travel attributable to a project.” “Automobile” refers to on -road passenger vehicles, specifically cars and light trucks. The Governor’s Office of Land Use and Climate Innovation (LCI), formerly known as the Governor’s Office of Planning and Research, has clarified in its Technical Advisory on Evaluating Transportation Impacts in CEQA (LCI Technical Advisory) that heavy-duty truck VMT is not required to be included in the estimation of a project’s VMT (OPR 2018).

Consistent with the LCI Technical Advisory and pursuant to SB 743, the City’s Department of Transportation developed the City of Pasadena Transportation Impact Analysis Guidelines, which adopts VMT as a primary metric for determining transportation impacts for CEQA environmental review and establishes VMT screening criteria and thresholds for evaluating a project’s potential impact on VMT (City of Pasadena 2022). Per the City’s guidelines, a CEQA transportation analysis shall be conducted for development

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 90
JUNE 2026
projects which satisfy either of the following conditions: 1) a project proposes 50 or more net new residential dwelling units or 2) a project proposes 50,000 or more net new non-residential square feet. The project is not a development project , as defined in the City’s guidelines, and does not meet conditions requiring a CEQA transportation analysis. Construction and operations VMT qualitative analyses are discussed below for informational purposes.

Construction
CEQA Guidelines Section 15064.3(b) is divided into four subdivisions: (1) land use projects, (2) transportation projects, (3) qualitative analysis, and (4) methodology. The proposed project is not a land use or transportation project and it would not result in a major expansion of Eaton Blanche Park. Therefore, neither Section 15064.3(b)(1) nor Section 15064.3(b)(2) of the CEQA Guidelines apply. Instead, the project would be categorized under Section 15064.3(b)(3), suitable for qualitative analysis and not subject to a quantitative threshold. Furthermore, the City’s project size screening criteri on (projects generating 110 daily trips or less) is intended to address permanent vehicle trips. Therefore, a qualitative analysis of the project construction is provided.

The project would involve construction that would generate temporary construction -related traffic for approximately 22 months. Even though worker and vendor trips would generate VMT, once construction is completed, the construction -related traffic would cease and traffic would return to pre -construction conditions. Measures to reduce the VMT generated by workers and trucks are limited, and there are no thresholds or significance criteria for temporary, construction-related VMT. The project construction would be generally consistent with construction activities in terms of the temporary nature of activities, trip generation characteristics, and the types of vehicles and equipment required. The increase in VMT associated with project construction is expected to be temporary and would therefore not cause a significant VMT impact. Impacts would be less than significant.

Operations
Once construction is complete, project operation is anticipated to entail routine maintenance activities at the stormwater capture facility and park that would be performed by City staff . The park facilities, as described in Section 2.2.2, Park Improvements, would result in a nominal increase in weekday and weekend trips. The project site is near an existing neighborhood park, Eaton Blanche Park, and the intent of the project is to provide passive recreational and educational spaces for the community, continuing the legacy of the project site’s historical uses, while also connecting the project site to the developed recreational facilities at Eaton Blanche Park to enhance connectivity and usefulness in the community.

Although the park facilities would broaden the recreational opportunities for the residents of Pasadena, the park facilities would continue to serve the local community and are not anticipated to increase VMT. By adding enhanced local recreational opportunities to the community and thereby improving proximity, local- serving projects tend to shorten trips and reduce VMT. The County of Los Angeles Parkland Standards and Classifications define a neighborhood park as having 3–10 acres with a service area of 0.5 miles, which is consistent with the characteristics of the project (County of Los Angeles 2017). Most of the patrons that would utilize the proposed park facilities would be from the surrounding residential neighborhoods, and therefore are not anticipated to increase VMT. Additionally, the project facilities are a neighborhood park and local-serving use; therefore, many visitors are more likely to walk to the site instead of drive. As such, operation of the project would result in a less-than-significant VMT impact.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 91
JUNE 2026
Therefore, the project would not conflict or be inconsistent with CEQA Guidelines Sections 15064.3(b)(1) and 15064.3(b)(3) and impacts would be less than significant. c) Would the project substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? Construction
Less-Than-Significant Impact. The project site is in an established, developed area with direct access to designated local and regional truck routes. Transportation and haul permits would be required from Caltrans and the City of Pasadena for construction truck traffic. The project would not introduce uses (types of vehicles) that are incompatible with existing uses already served by the area’s road system during either construction or operations.

Access (ingress and egress) to the site for construction -related traffic (workers and trucks) would primarily be from East Del Mar Boulevard. Construction access would be coordinated with the urgent care facility, or with SCE (for use of their easement ), or with LA County Flood Control District (for use of their channel maintenance road ). Delivery trucks from Kinneloa Yard would travel to the project site via South Kinneloa Avenue and East Del Mar Boulevard and delivery trucks from the City -owned property south of the Vina Vieja Dog Park would travel to the project site via Avocado Avenue, Alameda Street, Sierra Madre Villa Avenue / Madre Street, and East Del Mar Boulevard. Full or partial closures of any public roads for project construction are not anticipated . If temporary closures of Millicent Way or adjoining roadways are required for project construction, the temporary closures would be performed pursuant to a traffic control plan prepared by the contractor and subject to City approval. All lane closures would be performed pursuant to the traffic control plan. With implementation of the traffic control plan, there would be no changes that would affect the safety and acc essibility of the transportation system.

Therefore, impacts associated with hazardous design features or incompatible land uses du ring construction of the project would be less than significant.

Operations
Less-Than-Significant Impact. Pedestrian a ccess to the site would be provided via the proposed pedestrian bridge across Eaton Wash that connects to Eaton Blanche Park as well as from the pedestrian path extending from Thorndale Road to the eastern portion of the project site, which would provide access to Willard Elementary School and the Boys & Girls Club. Two small parking lots would be provided.

One parking lot would be provided at the north end of the site, which would be accessed from the southeast cor ner of the urgent care clinic parking lot via East Del Mar Boulevard. The other parking lot would be provided at the east end of the site, which would be accessed from a vehicular access road that extends from Thorndale Road to the project site and would be for maintenance vehicles only . The new maintenance vehicular access road extending from Thorndale Road and parking lot entrances would be designed to City standards for sight distance and other safety concerns. There would be no changes to the existing off -site circulation on City roads. Therefore, the project would not substantially increase hazards due to a roadway design feature or introduce incompatible uses during operation of the project .

Impacts would be less than significant.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 92
JUNE 2026
d) Would the project result in inadequate emergency access? Construction
Less-Than-Significant Impact. The project site is located in an established, developed area with sufficient access for emergency service providers. Emergency access is provided to the project site via existing roads, and the project would include a 12-foot-wide road that provides maintenance access to the stormwater capture system’s hatches and fire truck/emergency vehicle circulation. Full or partial closures of any public roads for project construction are not anticipated. If temporary closures of Millicent Way or adjoining roadways are required for project construction, the temporary closures would be performed pursuant to a traffic control plan prepared by the contractor and subject to City approval. As part of the traffic control plan, the contractor would follow standard construction practices and ensure that adequate on -site circulation and access is always maintained for all user s, including coordinating with local emergency response providers (local police, fire, and medical dispatch) regarding proposed construction activities. As such, construction of the project would have a less-than-significant impact related to emergency access.

Operations
Less-Than-Significant Impact. As previously discussed, the project site is in an established, developed area with sufficient access for emergency service providers. Upon completion, the project site would be accessible via the parking lot at the north end of the site, the parking lot at the eastern side of the site, and the pedestrian bridge from Eaton Blanche Park. The proposed project would result in nominal new traffic, and the project driveways/parking lots would provide adequate access to the site duri ng normal operations or any emergency. On-site circulation in the parking lots would include an internal roadway with adequate turn radii for all vehicles, including fire trucks with apparatus. Additionally, the 12-foot-wide road would provide emergency access throughout the project site. There would be no changes to the existing off-site circulation on City or County roads during project operations.

Therefore, the construction or operation of the project would not result in inadequate emergency access, and impacts would be less than significant.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 93
JUNE 2026

3.18 Tribal Cultural Resources

Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
XVIII. TRIBAL CULTURAL RESOURCES
a) Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code § 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
i) Listed or eligible for listing in the
California Register of Historical
Resources, or in a local register of
historical resources as defined in Public
Resources Code section 5020.1(k), or

ii) A resource determined by the lead
agency, in its discretion and supported
by substantial evidence, to be
significant pursuant to criteria set forth
in subdivision (c) of Public Resources
Code § 5024.1. In applying the criteria
set forth in subdivision (c) of Public
Resource Code § 5024.1, the lead
agency shall consider the significance
of the resource to a California Native
American tribe.

The evaluation of potential impacts to tribal cultural resources (TCRs) is primarily based on the findings resulting from tribal consultation conducted by the City, as the lead agency, as well as the findings of Section 3.5 , Cultural Resources, in this IS/MND. Background research and fieldwork conducted to inform this analysis include an NAHC Sacred Lands File search, archival research and a CHRIS database records search, a pedestrian survey of the project site, and the results of formal tribal consultation pursuant to California AB 52.

The project is subject to compliance with AB 52 (PRC 21074), which requires consideration of impacts to TCRs as part of the CEQA process and requires that the lead agency notify California Native American tribal representatives (that have requested notification) who are traditionally or culturally affiliated with the geographic area of the proposed project. All NAHC listed California Native American tribal representatives who have requested project notification pursuant to AB 52 were sent letters by the Cit y on July 29, 2025. The notification letters contained a project description, an outline of AB 52 timing, an invitation to consult, a project site figure, and contact information for the appropriate lead agency representative. To date, one response has been received by the City from the Gabrieleño Band of Mission Indians–Kizh Nation, which requested consultation pursuant to AB 52.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 94
JUNE 2026
Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code § 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
a) Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code section 5020.1(k)? Less-Than-Significant Impact with Mitigation Incorporated. As discussed in Section 3.5, no previously recorded archaeological resources of Native American origin or TCRs listed in the CRHR or a local register were identified in the project area as a result of the SCCIC records search, the NAHC Sacred Lands File results, or the pedestrian survey. Additionally, the City notified California Native American tribal representatives who are traditionally or culturally affiliated with the geographic area of the project pursuant to AB 52. A response was received from the Gabrieleño Band of Mission Indians-Kizh Nation on August 11, 2025, requesting AB 52 consultation for the project. Mitigation measures for cultural resources monitoring and unanticipated discovery of TCR objects and human remains were provided on December 15, 2025. The City agreed to the mitigation measures and consultation was concluded on December 15, 2025. No TCRs were identified as a result of information provided from the Gabrieleño Band of Mission Indians-Kizh Nation. Therefore, the project would not adversely affect TCRs that are listed or eligible for listing in the state or local register.

Although the potential for encountering subsurface TCRs are low, it is possible previously unknown TCRs could be inadvertently discovered during construction. As such, MM-TCR-1 through MM-TCR-3 would be implemented to prevent impacts to potential TCRs.

Mitigation Measures
MM-TCR-1 Retain a Native American Monitor Prior to Commencement of Ground - Disturbing Activities
A. The project applicant/lead agency shall retain a Native American Monitor from or approved by the Gabrieleño Band of Mission Indians –Kizh Nation. The monitor shall be retained prior to the commencement of any “ground -disturbing activity” for the subject project at all project locations (i.e., both on-site and any off-site locations that are included in the project description/definition and/or required in connection with the project, such as public improvement work). “Ground -disturbing activity” shall include, but is not limited to, demolition, pavement removal, potholing, auguring, grubbing, tree removal, boring, grading, excavation, drilling, and trenching.

B. A copy of the executed monitoring agreement shall be submitted to the lead agency prior to the earlier of the commencement of any ground -disturbing activity, or the issuance of any permit necessary to commence a ground-disturbing activity.

C. The monitor will complete daily monitoring logs that will provide descriptions of the relevant ground -disturbing activities, the type of construction activities performed, locations of ground-disturbing activities, soil types, cultural-related materials, and any other facts, conditions, materials, or discoveries of significance to the Tribe. Monitor logs will identify and describe any discovered TCRs, including but not limited to, Native American cultural and historical artifacts, remains, places of signifi cance, etc., (collectively, tribal cultural resources, or “TCR”), as well as any discovered Native

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 95
JUNE 2026
American (ancestral) human remains and burial goods. Copies of monitor logs will be provided to the project applicant/lead agency upon written request to the Tribe.

D. On-site tribal monitoring shall conclude upon the latter of the following (1) written confirmation to the Kizh from a designated point of contact for the project applicant/lead agency that all ground -disturbing activities and phases that may involve ground - disturbing activities on the project site or in connection with the project are complete; or (2) a determination and written notification by the Kizh to the project applicant/lead agency that no future, planned construction activity and/or development/construction phase at the project site possesses the potential to impact Kizh TCRs.

MM-TCR-2 Unanticipated Discovery of Tribal Cultural Resource Objects (Non -Funerary/ Non-Ceremonial)
A. Upon discovery of any TCRs, all construction activities in the immediate vicinity of the discovery shall cease (i.e., not less than the surrounding 50 feet) and shall not resume until the discovered TCR has been fully assessed by the Kizh monitor and/or Ki zh archaeologist. The Kizh will recover and retain all discovered TCRs in the form and/or manner the Tribe deems appropriate, in the Tribe’s sole discretion, and for any purpose the Tribe deems appropriate, including for educational, cultural, and/or histo ric purposes.

MM-TCR-3 Unanticipated Discovery of Human Remains and Associated Funerary Objects or Ceremonial Objects
A. Native American human remains are defined in PRC 5097.98 (d)(1) as an inhumation or cremation, and in any state of decomposition or skeletal completeness. Funerary objects, called associated grave goods in Public Resources Code Section 5097.98, are also to be treated according to this statute.

B. If Native American human remains and/or grave goods are discovered or recognized on the project site, then Public Resources Code section 5097.9 as well as Health and Safety Code Section 7050.5 shall be followed.

C. Human remains and grave/burial goods shall be treated alike per California Public Resources Code section 5097.98(d)(1) and (2).

D. Preservation in place (i.e., avoidance) is the preferred manner of treatment for discovered human remains and/or burial goods.

E. Any discovery of human remains/burial goods shall be kept confidential to prevent further disturbance.
b) A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code § 5024.1? In applying the criteria set forth in subdivision (c) of Public Resource Code § 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe.

Less-Than-Significant Impact with Mitigation Incorporated. The project is subject to compliance with AB 52 (PRC 21074), which requires consideration of impacts to TCRs as part of the CEQA process and requires lead agencies to provide notification of proposed projects to California Native American tribal representatives that have requested such notifications.

No TCRs were identified as a result of the response provided by the Gabrieleño Band of Mission Indians–Kizh Nation . Therefore, the project would not adversely affect TCRs that are listed or

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 96
JUNE 2026
eligible for listing in the state or local register. Although potential for encountering subsurface TCRs is low, it is possible previously unknown TCRs could be inadvertently discovered during construction. As such, MM- TCR-1 through MM-TCR-3 would be implemented to prevent impacts to potential TCRs.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 97
JUNE 2026

3.19 Utilities and Service Systems

Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
XIX. UTILITIES AND SERVICE SYSTEMS – Would the project:
a) Require or result in the relocation or
construction of new or expanded water,
wastewater treatment or storm water
drainage, electric power, natural gas, or
telecommunications facilities, the
construction or relocation of which could
cause significant environmental effects?

b) Have sufficient water supplies available to
serve the project and reasonably
foreseeable future development during
normal, dry and multiple dry years?

c) Result in a determination by the waste
water treatment provider, which serves or
may serve the project that it has adequate
capacity to serve the project’s projected
demand in addition to the provider’s
existing commitments?

d) Generate solid waste in excess of state or
local standards, or in excess of the
capacity of local infrastructure, or
otherwise impair the attainment of solid
waste reduction goals?

e) Comply with federal, state, and local
management and reduction statutes and
regulations related to solid waste?

a) Would the project require or result in the relocation or construction of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects? Less-Than-Significant Impact. The project would entail constructing and operating a stormwater capture, treatment, and infiltration facility on a vacant property east of the Eaton Wash Channel, developing passive park uses, a dog park, and a community garden within the project site, and constructing a pedestrian bridge over the channel connecting the new features east of Eaton Wash to Eaton Blanche Park. The stormwater capture and treatment facility would intercept stormwater and dry -weather flow from the E aton Wash Channel and divert it into a subterranean concrete basin. The proposed pump station and new irrigation system would be electrically powered, thus requiring an additional connection to the electrical power that currently serves the project site. Connection to these existing distribution facilities would be sufficient for providing power to the project and would not require any other relocation or construction of electrical power facilities. These minor improvements are features of the project that would be subject to engineering design

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 98
JUNE 2026
to ensure that adjacent facilities and users are not negatively affected. Any relocation of existing facilities would not be substantial enough to result in a significant impact pursuant to CEQA. Impacts would be less than significant.
b) Would the project have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years? Less-Than-Significant Impact. Project construction would temporarily require a minor amount of water , primarily associated with site watering in compliance with SCAQMD Rule 403 to prevent, reduce, or mitigate fugitive dust emissions from construction activities. Once construction is complete, operational changes in water use would include installation of a new irrigation system and drinking fountains . The water supply demand associated with the project would be minimal as landscaping of the site would primarily feature native and drought -tolerant species that require minimal watering . As such, operation of the project would not result in a substantial significant increase in demand for water supplies .

Therefore, impacts would be less than significant.
c) Would the project result in a determination by the waste water treatment provider , which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments?
No Impact. Construction of the project and operation of the stormwater capture infrastructure would not generate wastewater demand. The park development would not include any uses, such as restrooms, that would generate wastewater demand. Therefore, no impact would occur. d) Would the project generate solid waste in excess of state or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals? Less-Than-Significant Impact. During construction, the project would generate solid waste such as residual wastes, plastics, and soils. Construction -generated solid waste would be temporary and would cease once construction is completed. Solid waste generated by project construction wo uld be properly disposed of at designated landfill facilities for construction and demolition debris. In 2011, California AB 341 was passed, establishing a state goal to reduce, recycle, or compost no less than 75% of waste generated by the year 2020. Operation of the project, including stormwater capture and park operations, would not generate a significant amount of solid waste that would be beyond the capacity of local infrastructure. The closest solid waste disposal site would be the Scholl Canyon Landfill , approximately

6.13 miles west of the project site. Solid waste generated by the project would not exceed state or local standards or the capacity of local infrastructure. Impacts would be less than significant. e) Would the project comply with federal, state, and local management and reduction statutes and regulations related to solid waste?
No Impact. As discussed in Section 3.19(d), construction-generated solid waste would be temporary, and operation of the project would not generate substantially more solid waste than is generated under existing conditions. Solid waste generated by the project construction would be disposed of at designated landfill facilities in compliance with federal, state, and local regulations. Additionally, the project would be required to adhere to City and County ordinances with respect to waste reduction and recycl ing. As a result, no impacts related to state and local statutes governing solid waste are anticipated.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 99
JUNE 2026

3.20 Wildfire

Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
XX. WILDFIRE – If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project:
a) Substantially impair an adopted emergency
response plan or emergency evacuation
plan?

b) Due to slope, prevailing winds, and other
factors, exacerbate wildfire risks, and
thereby expose project occupants to
pollutant concentrations from a wildfire or
the uncontrolled spread of a wildfire?

c) Require the installation or maintenance of
associated infrastructure (such as roads,
fuel breaks, emergency water sources,
power lines or other utilities) that may
exacerbate fire risk or that may result in
temporary or ongoing impacts to the
environment?

d) Expose people or structures to significant
risks, including downslope or downstream
flooding or landslides, as a result of runoff,
post-fire slope instability, or drainage
changes?

a) Would the project substantially impair an adopted emergency response plan or emergency evacuation plan? Less-Than-Significant Impact. Please see Section 3.9(f) in Section 3.9, Hazards and Hazardous Materials, of this IS/MND. According to CAL FIRE, the project site is not located in a Local Responsibility Area and or in a Very High Fire Hazard Severity Zone (City of Pasadena 2025d; CAL FIRE 2025). The City has prepared a Draft Local Hazard Mitigation Plan. The Local H azard Mitigation Plan is a document that contains information to assist communities in reducing risk from hazards by identifying resources, information, and strategies for risk reduction (City of Pasadena 2025 c). The proposed project would involve construction within the project site and small portions of Eaton Blanche Park and the Eaton Wash Channel. Construction equipment, vehicles, and material would be staged and stored overnight on the project site with adequate site security. Construction staging for the underground storage reservoir modules would be located off site at the Kinneloa Yard or the City -owned property south of the Vina Vieja Dog Park, and the modules would remain on staged delivery truck beds until ready to be installed. Full or partial closures of any public roads for project construction are not anticipated. If temporary closures of Millicent Way or adjoining roadways are required for project construction, the temporary closures would be performed pursuant to a traffic control plan prepared by the contract or and subject to City approval, which would demonstrate that emergency access or evacuation would not be impeded. Traffic would revert to existing conditions upon

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 100
JUNE 2026
completion of the project. Because the project would be uninhabited, future emergency response and evacuation planning would not change from current conditions. Impacts would be less than significant. b) Due to slope, prevailing winds, and other factors, would the project exacerbate wildfire risks, and thereby expose project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire? Less-Than-Significant Impact. Construction of the project would comply with Chapter 14.28 of the PMC, which adopts the California Fire Code by reference. Chapter 33 of the California Fire Code outlines general fire safety precautions during construction and demolition that are intended to maintain minimum levels of fire protection and limit the spread of fire. The project would not include structures intended for long -term occupancy. Further, the project site is relatively flat and would not influence prevailing winds or other factors that could exacerbate wildfire risk. As such, the project would not exacerbate wildfire risks such that project users would be exposed to pollutant concentrations. Impacts would be less than significant. c) Would the project require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment? Less-Than-Significant Impact. As discussed previously, the project overall would not exacerbate fire risk.

Construction would comply with California Fire Code requirements to manage and minimize fire risk during construction. Operation of the project would not include potential sources of fire risk. As such, the project would not result in installation or maintenance of associated infrastructure that may exacerbate fire risk.

Impacts would be less than significant.
d) Would the project expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes? Less-Than-Significant Impact. For reasons described previously in Sections 3.9(g) and 3.20(a) –(c), the project would not pose a substantial risk of wildfire. The project site is on relatively flat land and no changes to site topography associated with project implementation are planned . As such, implementation of the project would not expose people or structures to significant risks from post-fire slope instability or drainage changes. Impacts would be less than significant.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 101
JUNE 2026

3.21 Mandatory Findings of Significance

Potentially
Significant
Impact
Less Than
Significant
Impact With
Mitigation
Incorporated
Less Than
Significant
Impact No Impact
XXI. MANDATORY FINDINGS OF SIGNIFICANCE
a) Does the project have the potential to
substantially degrade the quality of the
environment, substantially reduce the
habitat of a fish or wildlife species, cause a
fish or wildlife population to drop below self-
sustaining levels, threaten to eliminate a
plant or animal community, substantially
reduce the number or restrict the range of a
rare or endangered plant or animal or
eliminate important examples of the major
periods of California history or prehistory?

b) Does the project have impacts that are
individually limited, but cumulatively
considerable? (“Cumulatively considerable”
means that the incremental effects of a
project are considerable when viewed in
connection with the effects of past projects,
the effects of other current projects, and the
effects of probable future projects.)

c) Does the project have environmental effects
which will cause substantial adverse effects
on human beings, either directly or
indirectly?

a) Does the project have the potential to substantially degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self - sustaining levels, threaten to eliminate a p lant or animal community, substantially reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory?
Less-Than-Significant Impact with Mitigation Incorporated. Potential impacts related to sensitive and special-status habitat, wildlife species, and plant species are discussed in Section 3.4, Biological Resources. As discussed in Section 3.4, all potentially significant impacts to biological resources would be reduced to a level below significance with incorporation of mitigation measures. The proposed project would not substantially degrade the quality of the environment or impact fish or wildlife species or plant communities. As discussed in Section 3.5, potentia l impacts to cultural resources would be reduced to a level below significance with incorporation of mitigation measures. The proposed project would not eliminate important examples of the major periods of California history or prehistory. Overall, impacts would be less than significant with incorporation of mitigation measures.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 102
JUNE 2026
b) Does the project have impacts that are individually limited, but cumulatively considerable? (“Cumulatively considerable” means that the incremental effects of a project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects.) Less-Than-Significant Impact with Mitigation Incorporated . As indicated in the analysis presented throughout Chapter 3, Initial Study Checklist, of this IS/MND, the proposed project would not result in significant and unavoidable impacts in any issue area. Mitigation measures would reduce any potentially significant impacts to below a level of significance.

Cumulative projects in the City include the Lamanda Park Specific Plan; the Central District Specific Plan; the East Colorado Specific Plan; the Pasadena Rusnak Porsche Project located at 2915 East Walnut Street, approximately 0.5 miles northwest of the project site; the Viña Vieja Park Pickleball Court Project located at 3026 East Orange Grove Boulevard, approximately 1.21 miles north of the project site; the Patton Reservoir Replacement Project located at 1100 Arden Road , approximately 2.45 miles southwes t of the project site; the Planned Development No. 39 Affinity Project located at 465–577 South Arroyo Parkway, approximately 3.49 miles west of the project site; the Glenarm BESS Project located at 52 East Glenarm Street, approximately 3.68 miles southwest of the project site; the Central Park Apartments Project located at 86 South Fair Oaks Avenue, approximately 3.72 miles west of the project site; the Planned Development No. 40 Project located at 444 North Fair Oaks Avenue and 425 North Raymond Avenue, a pproximately

3.76 miles west of the project site; the Sunset Complex Project located at 201 West Mountain Street , approximately 4.29 miles northwest of the project site; the Mayberry Parker Bridge Access Improvements Project located at 1 South Arroyo Seco and 845 West Colorado Boulevard, approximately 4.47 miles west of the project site; and the Holly Street Bridge Seismic Retrofit Project located near the intersection of Holly Street and Linda Vista Avenue, approximately 4.55 miles west of the project site.

Cumulative projects in the County include the West San Gabriel Valley Area Plan and the Altadena Main Library Renovation Project located at 600 East Mariposa Street in Altadena, approximately 4.46 miles northwest of the project site. The proposed project, as with potential cumulative projects, would incorporate mitigation measures to reduce impacts, as applicable, particularly during construction. Upon completion of construction, the proposed project would have no potential to contribu te to a cumulative impact. Impacts would be less than significant with mitigation measures incorporated. c) Does the project have environmental effects which will cause substantial adverse effects on human beings, either directly or indirectly?
Less-Than-Significant Impact with Mitigation Incorporated. The potential for adverse direct or indirect impacts to human beings was considered throughout Chapter 3 of this IS/MND. Based on this evaluation, there is no substantial evidence that construction or operation of the project with the proposed mitigation measures incorporated would result in a substantial adverse effect on human beings. Impacts would be less than significant with mitigation measures incorporated.

16537 103
JUNE 2026
4 References and Preparers

4.1 References Cited
Applied EarthWorks Inc. 2009. Confidential Cultural Resources Specialist Report for the Tehachapi Transmission Project . On file at the South Central Coastal Information Center.

CAL FIRE (California Department of Forestry and Fire Protection). 2025. Fire Hazard Severity Zone Viewer.

Accessed March July 25, 2025. https://calfire-forestry.maps.arcgis.com/apps/webappviewer/ index.html?id=988d431a42b242b29d89597ab693d008.

Caltrans (California Department of Transportation). 2013. Technical Noise Supplement to the Traffic Noise Analysis Protocol. September 2013.

Caltrans. 2014. Combined Paleontological Identification and Paleontological Evaluation Report Interstate 10 Corridor Project, San Bernardino and Los Angeles Counties. December 2014.

Caltrans. 2020. Transportation and Construction Vibration Guidance Manual. Division of Environmental Analysis, Environmental Engineering, Hazardous Waste, Air, Noise, Paleontology Office, Sacramento. April 2020.

Caltrans. 2025. “California State Scenic Highway System Map.” Accessed July 2025. https://caltrans.maps.arcgis.com/ apps/webappviewer/index.html?id=465dfd3d807c46cc8e8057116f1aacaa.

CAPCOA (California Air Pollution Control Officers Association). 2008. CEQA & Climate Change: Evaluating and Addressing Greenhouse Gas Emissions from Projects Subject to the California Environmental Quality Act.

January 2008. Accessed June 19, 2025. https://www.ourair.org/wp-content/uploads/CAPCOA-CEQA-and- Climate-Change.pdf.

CARB (California Air Resources Board). 2005. Air Quality and Land Use Handbook: A Community Health Perspective. April 2005. Accessed October 2025. https://www.aqmd.gov/docs/default-source/ceqa/ handbook/california-air-resources-board-air-quality-and-land-use-handbook- a-community-health-perspective.pdf.

CARB. 2022. 2022 Scoping Plan for Achieving Carbon Neutrality. Accessed October 2025. https://ww2.arb.ca.gov/sites/default/files/2023-04/2022-sp.pdf.

CDFW (California Department of Fish and Wildlife). 2024. Survey of California Vegetation Classification and Mapping Standards, March 6, 2024. Accessed March 2025. https://nrm.dfg.ca.gov/ FileHandler.ashx?DocumentID=102342&inline.

CDFW. 2025a. California Natural Diversity Database (CNDDB). RareFind 5.3.0 (Commercial Subscription).

Sacramento, California: CDFW, Biogeographic Data Branch. Accessed March 2025. https://apps. wildlife.ca.gov/rarefind/view/RareFind.aspx.

CDFW. 2025b. Biogeographic Information and Observation System; online database viewer. Accessed March 2025. https://apps.wildlife.ca.gov/bios6/.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 104
JUNE 2026
CDFW. 2025c. California Natural Community List. February 27, 2025. Accessed March 2025. https://wildlife.ca.gov/Data/VegCAMP/Natural-Communities.

CDFW. 2025d. State and Federally Listed Endangered, Threatened, and Rare Plants of California. Accessed March 2025. https://wildlife.ca.gov/Data/CNDDB/Plants-and-Animals.

CDFW. 2025e. State and Federally Listed Endangered and Threatened Animals of California. January 2025.

Accessed March 2025. https://wildlife.ca.gov/Data/CNDDB/Plants-and-Animals.

CDFW. 2025f. California Wildlife Habitat Relationships Life History Accounts and Range Maps (online). Accessed March 2025. https://wildlife.ca.gov/Data/CWHR/Life-History-and-Range.

City of Pasadena. 2010. Municipal Code: Chapter 8.52 – City Trees and Tree Protection Ordinance. Accessed October 2025. https://www.cityofpasadena.net/wp-content/uploads/sites/29/TPO_2-Pasadena-Tree- Ordinance-Municipal-Code-8.52.pdf.

City of Pasadena. 2012. “Open Space and Conservation Element.” In City of Pasadena General Plan Update.

Accessed July 2025. https://www.cityofpasadena.net/planning/wp-content/uploads/sites/30/General- Plan-Open-Space-and-Conservation-Element-2012.pdf?v=1753218930695.

City of Pasadena. 2015a. “Mobility Element.” In City of Pasadena General Plan. Accessed July 2025. https://www.cityofpasadena.net/planning/wp-content/uploads/sites/30/Adopted-Mobility-Element- 2015-08-18.pdf?v=1753732348584.

City of Pasadena. 2015b. City of Pasadena Bicycle Transportation Action Plan. August 2015. Accessed October 2025. https://www.cityofpasadena.net/transportation/wp-content/uploads/sites/20/Pasadena-Bike- Action-Plan-08-17-2015.pdf.

City of Pasadena. 2016. “City of Pasadena Truck Route Map.” January 2016. Accessed October 2025. https://www.cityofpasadena.net/transportation/wp-content/uploads/sites/20/ Truck-Routes-Map-PDF.pdf.

City of Pasadena. 2017a. “Climate Action Plan Consistency Checklist.” Appendix D in Pasadena Climate Action Plan. December 28, 2017. Accessed October 2025. https://www.cityofpasadena.net/planning/ wp-content/uploads/sites/30/D-CAP-Consistency-Checklist.pdf?v=1756232681388.

City of Pasadena. 2017b. Municipal Code Section 9.36.090. Accessed October 2025. https://library.municode.com/ca/pasadena/codes/code_of_ordinances?nodeId=TIT9PUPEMOWE_ARTIV OFAGPUPE_CH9.36NORE_9.36.060INNOSTULREPR#:~:text=9.36.090%20-%20Machinery%2C%20 equipment%2C%20fans%20and%20air%20conditioning.,ambient%20noise%20level%20by%20more%20 than%205%20decibels.

City of Pasadena. 2018. Pasadena Climate Action Plan. March 5, 2018. Accessed October 2025. https://www.cityofpasadena.net/planning/wp-content/uploads/sites/30/Final-Pasadena-Climate-Action- Plan_3.5.2018.pdf?v=1756232681388.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 105
JUNE 2026
City of Pasadena. 2022. City of Pasadena Transportation Impact Analysis Guidelines. April 2022. Accessed October 2025. https://www.cityofpasadena.net/transportation/wp-content/uploads/sites/20/ City-of-Pasadena-TIA-Guidelines.pdf.

City of Pasadena. 2024. City of Pasadena Pedestrian Transportation Action Plan. Revised March 2024. Accessed October 2025. https://www.cityofpasadena.net/transportation/wp-content/uploads/sites/20/ 2024-Revised-Pasadena-Pedestrian-Transportation-Action-Plan.pdf.

City of Pasadena. 2025a. “City of Pasadena Land Use Diagram.” Accessed July 2025. https://www.cityofpasadena.net/ planning/wp-content/uploads/sites/30/Land-Use-Diagram.pdf?v=1752778032089.

City of Pasadena. 2025b. “City of Pasadena Zoning Map.” Accessed July 2025. https://www.cityofpasadena.net/ planning/wp-content/uploads/sites/30/Zoning-Map.pdf?v=1752778455562.

City of Pasadena. 2025c. City of Pasadena Local Hazard Mitigation Plan. 2025 Final Draft. Accessed July 2025. https://www.cityofpasadena.net/wp-content/uploads/sites/25/2025-Local-Hazard-Mitigation-Plan- Draft.pdf#:~:text=The%20City%20of%20Pasadena%20%28City%29%20has%20prepared%20the,impact %20of%20these%20hazards%20by%20creating%20mitigation%20strategies.

City of Pasadena 2025d. “City of Pasadena Fire Hazard Severity Zone Map (FHSZ).” Accessed July 2025. https://www.cityofpasadena.net/fire/fire-hazard-severity-zones/ City of Pasadena. 2025e. “Pasadena Transit Route 60.” Accessed October 2025. https://www.cityofpasadena.net/ pasadena-transit/wp-content/uploads/sites/19/PT-RT-60-Schedule.pdf.

CNPS (California Native Plant Society). 2025a. Rare Plant Inventory, online ed. Version 9.5.1. CNPS, Rare Plant Program. Accessed March 2025. http://www.rareplants.cnps.org.

CNPS. 2025b. A Manual of California Vegetation Online. Accessed March 2025. https://vegetation.cnps.org.

Cohen, K.M., S.C. Finney, P.L. Gibbard, and J.-X. Fan. 2024. “The ICS International Chronostratigraphic Chart.” Episodes 36:199–204. Accessed September 2025. https://stratigraphy.org/ICSchart/ ChronostratChart2024-12.pdf.

Council for Watershed Health. 2023. Upper Los Angeles River Watershed Area Strategic Outreach and Engagement Plan, Fiscal Year 2023–2024. Accessed July 2025. https://safecleanwaterla.org/ content/uploads/2023/07/FY2023-2024-ULAR-Draft-SOEP-2023-06-30.pdf.

County of Los Angeles. 1978. Los Angeles County Code of Ordinances, Chapter 12.08.

County of Los Angeles. 2014. Los Angeles County Land Use Policy, East Pasadena – East San Gabriel / San Pasqual. Accessed November 2025. https://planning.lacounty.gov/wp-content/uploads/ 2022/11/A.7-gp_2035_LUP_2014_E_Pasadena_E_San_Gabriel_San_Pasqual.pdf.

County of Los Angeles. 2017. “County of Los Angeles Parkland Standards and Classifications.” Appendix in Park Design Guidelines and Standards, 169. Accessed October 2025. https://file.lacounty.gov/ SDSInter/dpr/1029701_ParkDesignGuideline2017.pdf.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 106
JUNE 2026
County of Los Angeles. 2025. Z-Net. Accessed November 2025. https://experience.arcgis.com/ experience/0eecc2d2d0b944a787f282420c8b290c/#data_s=id%3AdataSource_ 3-18d80ecc2df-layer-15%3A1439455.

Craftwater. 2025. “Preliminary Design Report, Eaton Wash Stormwater Capture Project.” April 2025.

Dibblee, T.W. Jr., and H.E. Ehrenspeck. 1998. “Geologic Map of the Mt. Wilson and Azusa Quadrangles, Los Angeles County, California” [map]: 1:24,000. Edited by H.E. Ehrenspeck. Dibblee Geological Foundation, Dibblee Foundation Map DF-67. https://ngmdb.usgs.gov/Prodesc/proddesc_71696.htm.

DOC (California Department of Conservation). 2018. Earthquake Fault Zones: A Guide for Government Agencies, Property Owners/Developers, and Geoscience Practitioners for Assessing Fault Rupture Hazards in California. Accessed July 2025. https://www.conservation.ca.gov/cgs/documents/publications/special- publications/SP_042-a11y.pdf.

DOC. 2025a. California Important Farmland Finder. Accessed July 25th, 2025. https://maps.conservation.ca.gov/DLRP/CIFF/.

DOC. 2025b. “Earthquake Zones of Required Investigation.” EQZapp [web application]. DOC, California Geological Survey. Accessed July 2025.https://maps.conservation.ca.gov/cgs/EQZApp/app/.

DOC. 2025c. “Tsunami Hazard Area Map, Los Angeles County.” Accessed July 2025. https://maps.conservation.ca.gov/cgs/informationwarehouse/ts_evacuation/.

DTSC (Department of Toxic Substances Control). 2025. EnviroStor Database. Accessed July 25th, 2025. https://www.envirostor.dtsc.ca.gov/public/map/?myaddress=Search.

EPA (U.S. Environmental Protection Agency). 2016. “Health and Environmental Effects of Particulate Matter (PM).” Accessed October 2025. https://www.epa.gov/pm-pollution/health-and-environmental-effects- particulate-matter-pm.

EPA. 2025. “Monitor Values Report.” Last updated March 28, 2025. Accessed October 2025. https://www.epa.gov/outdoor-air-quality-data/monitor-values-report.

FEMA (Federal Emergency Management Agency). 2008. “FEMA’s National Flood Hazard Layer (NFHL) Viewer” Effective September 25, 2008. Accessed October 2025. https://hazards-fema.maps.arcgis.com/ apps/webappviewer/index.html?id=8b0adb51996444d4879338b5529aa9cd.

FHWA (Federal Highway Administration). December 8, 2008. Roadway Construction Noise Model (RCNM), Software Version 1.1. Prepared by John A. Volpe National Transportation Systems Center. Washington, DC: U.S. Department of Transportation, Research and Innovative Technology Administration, Environmental Measurement and Modeling Division.

FTA (Federal Transit Administration). 2018. Transit Noise and Vibration Impact Assessment Manual. FTA Report No. 0123. Prepared by John A. Volpe National Transportation Systems Center. Washington, DC: U.S.

Department of Transportation, Office of Planning and Environment, FTA. September 2018.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 107
JUNE 2026
Google Earth. 2025. Google Earth; desktop application; centered on the project site. Accessed March 2025. https://www.google.com/earth/.

IPCC (Intergovernmental Panel on Climate Change). 2007. IPCC Fourth Assessment Synthesis of Scientific- Technical Information Relevant to Interpreting Article 2 of the U.N. Framework Convention on Climate Change. September 2007. https://www.ipcc.ch/report/ar4/syr/.

Jefferson, G.T. 2012. “A Catalog of Late Quaternary Vertebrates from California.” Natural History Museum of Los Angeles County Technical Report No. 7. Published 1991; revised May 18, 2012.

Metro (Los Angeles County Metropolitan Transportation Authority). 2025. “Line 267.” Accessed October 2025. https://cdn.beta.metro.net/wp-content/uploads/2025/06/20101421/267_TT_06-22-25.pdf.

NASEM (National Academies of Sciences, Engineering, and Medicine). 2022. Development of a Highway Construction Noise Prediction Model. Prepared for National Cooperative Highway Research Program, Project 25-49 (NCHRP 25-49). https://onlinepubs.trb.org/onlinepubs/nchrp/docs/NCHRP25- 49/nchrp_25-49RCNM2.0finalreport.pdf.

NETR (Nationwide Environmental Title Research). 2025b. Historical Topographic Maps dating from 1894, 1896, 1898, 1900, 1904, 1907, 1908, 1910, 1913, 1915, 1920, 1927, 1928, 1931, 1940, 1941, 1955, 1960, 1968, 1975, 1988, 1994, 1999, 2012, 2015, 2018, and 2022. Accessed July 2025. https://www.historicaerials.com/viewer.

NETR. 2025a. Historical Aerial Photographs of the City of Pasadena, CA, dating from 1948,1952, 1953, 1964, 1972, 1977, 1978, 1980, 1987, 1988, 1992, 1993, 1994, 1995, 1996, 1997, 1998, 1999, 2000, 2002, 2004, 2005, 2009, 2010, 2012, 2014, 2016, 2018, 2020, and 2022. Accessed July 2025. https://www.historicaerials.com/viewer.

NHMLA (Natural History Museum of Los Angeles County). 2019. Vertebrate Paleontology Records Check for paleontological resources for the proposed Arroyo Seco Project, Dudek Project No. 11884, in the City of Pasadena, Los Angeles County, project area. Unpublished records search results letter from A. Bell of the Natural History Museum of Los Angeles County, Los Angeles, California. October 1, 2019.

NHMLA. 2022. Paleontological resources for the 6821 Fairlynn Boulevard Project, Kimley-Horn. Unpublished records search results letter from A. Bell of the Natural History Museum of Los Angeles County, Los Angeles, California. March 29, 2022.

NHMLA. 2025a. Paleontological resources records search for the Eaton Wash Stormwater Capture Project (Project No. 16537 phase 07.2-05).” Unpublished records search results letter from A. Bell of the Natural History Museum of Los Angeles County, Los Angeles, California. August 3, 2025.

NHMLA. 2025b. Paleontological resources records search for the 234 S. Marguerita Avenue Project (Project Number 9907.0007. Unpublished records search results letter from A. Bell of the Natural History Museum of Los Angeles County, Los Angeles, California. April 20, 2025.

NHMLA. 2025c. Paleontological resources records search for the Mauna Loa Ave Project (PN:18193.02.01.05).

Unpublished records search results letter from A. Bell of the Natural History Museum of Los Angeles County, Los Angeles, California. July 20, 2025.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 108
JUNE 2026
Ninyo & Moore. 2025. Geotechnical Evaluation for the Eaton Wash Stormwater Capture Project, 3160 East Del Mar Boulevard, Pasadena, California. March 2025.

OPR (California Governor’s Office of Planning and Research). 2018. Technical Advisory on Evaluating Transportation Impacts in CEQA. December 2018. Accessed July 2025. https://lci.ca.gov/docs/ 20190122-743_Technical_Advisory.pdf.

Pacific Legacy Inc. 2007. Cultural Resources Inventory of the Southern California Edison Company Tehachapi Renewable Transmission Project, Kern, Los Angeles and San Bernardino Counties, California, ARR #05- 01-01046. On file at the South Central Coastal Information Center.

SCAG (Southern California Association of Governments). 2020. Connect SoCal: The 2020–2045 Regional Transportation Plan/Sustainable Communities Strategy of the Southern California Association of Government. Adopted September 3, 2020.

SCAQMD (South Coast Air Quality Management District). 1993. CEQA Air Quality Handbook. Accessed October 2025. http://www.aqmd.gov/home/rules-compliance/ceqa/air-quality-analysis-handbook/ ceqa-air-quality-handbook-(1993).

SCAQMD. 2003. “Modeling and Attainment Demonstrations.” Appendix V in Final 2003 AQMP. August 2003.

Accessed October 2025. https://www.aqmd.gov/docs/default-source/clean-air-plans/air-quality- management-plans/2003-air-quality-management-plan/2003-aqmp-appendix-v.pdf?sfvrsn=2.

SCAQMD. 2009. Final Localized Significance Threshold Methodology. July 2009. Accessed October 2025. http://www.aqmd.gov/docs/default-source/ceqa/handbook/localized-significance-thresholds/ final-lst-methodology-document.pdf?sfvrsn=2.

SCAQMD. 2014. “Fact Sheet for Applying CalEEMod to Localized Significance Thresholds.” Accessed October 2025. http://www.aqmd.gov/docs/default-source/ceqa/handbook/localized-significance-thresholds/ caleemod-guidance.pdf.

SCAQMD. 2022. 2022 Air Quality Management Plan. Accessed October 2025. http://www.aqmd.gov/docs/ default-source/clean-air-plans/air-quality-management-plans/2022-air-quality-management-plan/ final-2022-aqmp/final-2022-aqmp.pdf?sfvrsn=16.

SCAQMD. 2023. “SCAQMD Air Quality Significance Thresholds.” Originally published in CEQA Air Quality Handbook, Table A9-11-A. Revised March 2023. https://www.aqmd.gov/docs/default-source/ceqa/ handbook/south-coast-aqmd-air-quality-significance-thresholds.pdf?sfvrsn=25.

SVP (Society of Vertebrate Paleontology). 2010. “Standard Procedures for the Assessment and Mitigation of Adverse Impacts to Paleontological Resources.” Accessed September 2024. https://vertpaleo.org/ wp-content/uploads/2021/01/SVP_Impact_Mitigation_Guidelines.pdf.

SWRCB (State Water Resources Control Board). 2025. GeoTracker. Accessed July 2025. https://geotracker.waterboards.ca.gov/map/?CMD=runreport&myaddress=Search+GeoTracker.

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 109
JUNE 2026
The Climate Registry. 2025. 2025 Default Emission Factors. February 2025. Accessed June 2025. https://theclimateregistry.org/wp-content/uploads/2025/03/2025-Default-Emission-Factors- 03-2025.pdf.

ULAR Watershed Management Group (Upper Los Angeles River Watershed Management Group). 2015. Draft Enhanced Watershed Management Program (EWMP) for the Upper Los Angeles River EWMP Group.

Accessed July 2025.
https://www.waterboards.ca.gov/rwqcb4/water_issues/programs/stormwater/municipal/ watershed_management/los_angeles/upper_losangeles/UpperLARiver_DraftEWMP.pdf.

U.S. Census Bureau. 2020. “Quick Facts, Pasadena city, California; United States.” April 1, 2020. Accessed July 2025. https://www.census.gov/quickfacts/fact/table/pasadenacitycalifornia/AGE295223.

USDA (U.S. Department of Agriculture). 2025. Web Soil Survey. USDA, Natural Resources Conservation Service, Soil Survey Staff. Accessed July 2025. https://websoilsurvey.sc.egov.usda.gov/App/WebSoilSurvey.aspx.

USFWS (U.S. Fish and Wildlife Service). 2025. Information, Planning, and Conservation System (IPaC). Accessed July 2025. https://ecos.fws.gov/ipac/.

4.2 List of Preparers
City of Pasadena
Dawn Petschauer – Stormwater Program Administrator
Dudek
Alex Hardy – Senior Project Manager
Hayley Rundle – Deputy Project Manager/Environmental Planner Claire Alfano – Environmental Planner
Jason Greenstein – Geospatial Analyst
Shawna Johnson – Paleontologist
Collin Paludi – Air Quality Specialist
Nick Segovia – Environmental Acoustician
Sarah Siren – Paleontologist

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 110
JUNE 2026

INTENTIONALLY LEFT BLANK

Poject Site
ÄÆ19
§¨¦210
§¨¦210
Project Boundary
Off Site Construction Staging Area
0 2,0001,000
Feet
n
Date: 3/3/2026 User: jgreenstein Path: Z:\Projects\j1653700\MAPDOC\MND\Easton Wash MND.aprx Map: Figure 1 Project Location Layout: Figure 1 Project LocationDate: 3/3/2026 User: jgreenstein Path: Z:\Projects\j1653700\MAPDOC\MND\Easton Wash MND.aprx Map: Figure 1 Project Location Layout: Figure 1 Project Location Project Site
Brea PlacentiaBellflowerGardena Norwalk
La Habra HeightsBell GardensInglewood
Huntington
Park Maywood
Commerce Diamond
Bar
Pomona
Pico Rivera
WalnutIndustry
South El Monte
West
Hollywood El Monte CovinaAlhambra
Temple City San Dimas
La Verne
Azusa
Arcadia GlendoraDuarte
Pasadena
Glendale
San
Fernando
Santa Clarita
Chino
Burbank
Los
Angeles
£¤101
ÄÆ90
ÄÆ57
ÄÆ118
ÄÆ134
ÄÆ39
ÄÆ66
ÄÆ142
ÄÆ187
ÄÆ170
ÄÆ1
ÄÆ90
ÄÆ72 ÄÆ19
ÄÆ60
ÄÆ2
§¨¦5
§¨¦710
§¨¦10
§¨¦605
§¨¦210
§¨¦405
§¨¦105
L o s A n g e l e s
C o u n t y
SOURCE: USGS National Map 2026
Eaton Wash Stormwater Capture Project
Project Location
FIGURE 1
....
~
2: 0
"' 2:
as.adena ....
1tyColl :,.
<(
! ~
2:
2:
0 "' "'
ST

ORLANDO RD
c::::J
0 sU LN
~
<(
,._
~ ....
"' "' ....
"' "'

LOMBARDY RD
p
DUDEI<
.... :,.
<(
0 :1;
"' <(
:t
2:
<l
"'

PALOMA ST

RIDA ST
-e-~
~

LANDFAIR RD
st-1ADOW GROVE RD
LOWEL
Pasadena GREENHILL RD
~
<(
0 "' c3
2:
~
<(
...
i;j :,. ....
"' 0 0
"' "'

ONEIDA ST
San Pasqua l

HOMETRD

ROBLES AVE
,.._oNTECtro D,p D
0 Tract of Land
Near San Gabrie l
1:. 0
,; "' ,.
l> ,._
C
"' "' "' 0 Q ::,
"' 0 0 Q
,. "'
<(
Q
"' Cl
0 ~
~
Lamanda Park
"-l>
z
0 -<
" "' &

NINA ST
San
Gabriel
0 ESTADO ST
a,

E GREEN ST
0 MILTON ST
F4IRft1£ADE RD SINGING WOOD DR

NEW HAVEN RD
,._
"' Q
::5 ,._
"' ~
2: 119
[f FOOTHILL BLVD
.... :,.
<l
"' ::,
"' lJ
:i
0 ~
"' 0
::5 :t ....
"' 0
"' "'
East Pasadena
19 I]

MAYFAIR DR

SEARS WAY

ELMA RD
0 SYCAMORE AVE
0 ~
"' Q
"' ~
Q
0 ~

SOUTHVIEW RD

HAMPTON RD

ANOAKIA LN

FOOTHILL FWY

COLORADO ST
n
~
~
~ :;: ,.
0 0 C
"' "1b
"'0.,,,1: -Po l>I
'vc- -1
'o~~ P4to,.,. ,f>O, D,f>
E,i,, '40
~~ <'-1,1, 'P
,..0
<',p Baldwin Lttke
<'o
~
0 "' 0
Dll,it,.
'o .,.
0 ~
~ ,.
0 PORTOLA DR

HUGO REID DR
94lBoA DR

ARCADIA AVE
West
Arcadia
I]

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 112
JUNE 2026

INTENTIONALLY LEFT BLANK

E Del Mar Blvd
Madre St
Millicent Way
SKinnel
oa
Ave
LaPresa Dr
Oneida D
r
El Encanto Dr Plumosa Dr
Thorndale Rd
Oneida St
Grayburn Rd
Unincorporated
Pasadena
Boys & Girls Club of Pasadena - Slavik Branch
Willard Elementary School
Church
Eaton Blanche Park
CALRegional Pasadena Adult Education Center
Exer Urgent Care Clinic
Project Boundary
0 15075
Feet
n
Date: 11/21/2025 User: kholmes Path: Z:\Projects\j1653700\MAPDOC\MND\Easton Wash MND.aprx Map: Figure 2 Project Site Layout: Figure 2 Project SiteDate: 11/21/2025 User: kholmes Path: Z:\Projects\j1653700\MAPDOC\MND\Easton Wash MND.aprx Map: Figure 2 Project Site Layout: Figure 2 Project Site SOURCE: ESRI Maps 2024; Open Street Map 2024; Los Angeles County Eaton Wash Stormwater Capture Project
Project Site
FIGURE 2
Los Angeles County
DUDEI<

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 114
JUNE 2026

INTENTIONALLY LEFT BLANK

Channel
Diversion
Structure
Eaton Wash
Diversion
Line
Actuated
Valve
Trash Trap
Wet Well
Pump Station
Laser Flow
Meter in
Manhole
Manhole
Cartridge Filter
Manhole
Easton Wash
Outlet
Flow Meter
Vault
Hydrodynamic
Seperator
Infiltration
Gallery
Air Vent
Air Vent
Underdrain
to Bioswale
Gallery
Access
Vault
Gallery
Access
Vault
Connection to
Channel
Flow
Control
Structure
Oneida Dr
Oneida St
Project Boundary
Stormwater Capture System
0 5025
Feetn
Date: 11/20/2025 User: jgreenstein Path: Z:\Projects\j1653700\MAPDOC\MND\Easton Wash MND.aprx Map: Figure 3 Project Stormwater Capture and Treatment System Layout: Figure 3 Project Stormwater Capture and Treatment SystemDate: 11/20/2025 User: jgreenstein Path: Z:\Projects\j1653700\MAPDOC\MND\Easton Wash MND.aprx Map: Figure 3 Project Stormwater Capture and Treatment System Layout: Figure 3 Project Stormwater Capture and Treatment System SOURCE: Vantor 2024; Open Street Map 2024; Craftwater 2025 Eaton Wash Stormwater Capture Project
Project Stormwater Capture and Treatment System
FIGURE 3
Map Extent
c::::J
D
DUDEI<

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 116
JUNE 2026

INTENTIONALLY LEFT BLANK

ONEIDA ST

EATON WASH

EATON WASH

THORNDALE RD
GRAYBURNRD(6) RAISED GARDEN BEDS

FOR COMMUNITY GARDEN

DOG PARK

PEDESTRIAN BRIDGE
ACROSS CHANNEL.

PERMEABLE PAVERS

PARKING LOT

EATON BLANCHE PARK
EX. LANDSCAPE

WAREHOUSE NURSERY

SOUTHERN CALIFORNIA

EDISON ROW

EDUCATIONAL SPACESGARDEN SHED

EDUCATIONAL
KIOSK

STORMWATER
SPRING

STORMWATER CREEK

STORMWATER BASIN

CONCRETE PATH TO CONNECT TO EXISTING PARK CONCRETE WALKWAY

SCE SUSPENSION
TOWER

SCE SUSPENSION
TOWER

SCE WOOD
POLES

SCE WOOD
POLES

DG PATH LINED WITH

BOX TREES

GRAVEL ROAD

EDUCATIONAL SPACE

EDUCATIONAL SPACE

SHADE STRUCTURES

SCE WOOD
POLES

CITY MAINTAINED GARDEN AREA,

FENCED, WITH RAISED GARDEN BEDS

SHADE STRUCTURES

BOX TREES SCREENING

ADJACENT RESIDENCES

CHANNEL DIVERSION STRUCTURE

ACTUATED VALVE

TRASH TRAP
10 CFS & 75 GPM PUMP

STATION WET WELL

UTILITY VAULT

CDS PRETREATMENT

RAINBIRD DISC FILTER

JELLYFISH FILTER

MANHOLE

FLOW CONTROL STRUCTURE

LASER FLOW METER

IN MANHOLE

MANHOLE

OUTLET TO CHANNEL

AIR VENT

AIR VENT

BASIN OUTLET CONTROL STRUCTURE
12" RCP CULVERT
6" HDPE CULVERT

3.44 ACRE-FOOT SUBSURFACE

INFILTRATION GALLERY

BIOFILTRATION BASINS

SHADE STRUCTURESBIOFILTRATION BASIN

RAIN GUARDIAN

STORM DRAIN INLET
6" PERFORATED

PVC UNDERDRAINS

MANHOLE

WINGED HEADWALL WITH RIP RAP ENERGY DISSIPATERLACFCD DIRT ACCESS ROAD

LACFCD DIRT

ACCESS ROAD

LACFCD DIRT ACCESS ROAD
8" HDPE

EQUALIZATION PIPES
8" HDPE OUTLET PIPE

SHADE STRUCTURE

WATER FOUNTAIN

WATER FOUNTAIN

WATER FOUNTAIN

EATON WASH

WATER SERVICE LINE

SECRET PATH AREA

UTILITY PAD

PEDESTRIAN GATE
PICNIC TABLE (TYP.)
Site Plan Exhibit
Eaton Wash Stormwater Capture Project
FIGURE 4
Z:\Projects\j1653700\MAPDOC\MND
SOURCE: Craftwater 2025
DUDEK

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 118
JUNE 2026

INTENTIONALLY LEFT BLANK

E Del Mar Blvd
SKinnel
oa Ave
Plumosa Dr
Thorndale Rd
Oneida St
Oneida Dr
DEV
DEV
ORN
Queagr
ORN
ORN
ORN
DH
DH
Project Boundary
Vegetation Communities and Land Cover Types
Bridge Span
Permanent Impacts
Park/Hardscape
Diversion Structure
Temporary Impacts
Access & Site Cleanup
Utility Connections
Drainage Pipe
0 10050
Feet
n
Date: 11/11/2025 User: jgreenstein Path: Z:\Projects\j1653700\MAPDOC\MND\Easton Wash MND.aprx Map: Figure 3.4-1 Project Impacts and Vegetation Layout: Figure 3.4-1 Project Impacts and VegetationDate: 11/11/2025 User: jgreenstein Path: Z:\Projects\j1653700\MAPDOC\MND\Easton Wash MND.aprx Map: Figure 3.4-1 Project Impacts and Vegetation Layout: Figure 3.4-1 Project Impacts and Vegetation SOURCE: Vantor 2024; Open Street Map 2024; Craftwater 2025 Eaton Wash Stormwater Capture Project
Project Impacts & Vegetation Communities
FIGURE 3.4-1
DUDEI<
-
D
--

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 120
JUNE 2026

INTENTIONALLY LEFT BLANK

E Del Mar Blvd
One
ida
Dr
Plumosa Dr
Oneida St
ST1
ST2
ST3
ST4
Survey Area
Noise Measurement Locations
0 10050
Feet
n
Date: 11/6/2025 User: jgreenstein Path: Z:\Projects\j1653700\MAPDOC\Noise\Eaton Wash Stormwater Noise.aprx Map: Noise Layout: Figure 3.13-1 Baseline Sound Pressure Level Measurement Locations SOURCE: Vantor 2024; Open Street Maps 2019
Eaton Wash Stormwater Capture Project
Baseline Sound Pressure Level Measurement Locations
FIGURE 3.13-1
CJ
0 DUDEI<

EATON WASH STORMWATER CAPTURE PROJECT / INITIAL STUDY/MITIGATED NEGATIVE DECLARATION 16537 122
JUNE 2026

INTENTIONALLY LEFT BLANK

Appendix A
Air Quality and Greenhouse Gas Emissions Modeling

Table of Contents
Eaton Wash Detailed Report (2)
Eaton Wash LST Analysis Detailed Report
2 65
Eaton Wash Detailed Report, 10/16/2025
1 / 63
Eaton Wash 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

2.3. Construction Emissions by Y ear, Mitigated

3. Construction Emissions Details

3.1. Demolition (2027) - Unmitigated

3.2. Demolition (2027) - Mitigated

3.3. Site preparation, clearing and grubbing (2027) - Unmitigated

3.4. Site preparation, clearing and grubbing (2027) - Mitigated

3.5. Reservoir excavation (2027) - Unmitigated

3.6. Reservoir excavation (2027) - Mitigated
Eaton Wash Detailed Report, 10/16/2025
2 / 63

3.7. Reservoir construction (2027) - Unmitigated

3.8. Reservoir construction (2027) - Mitigated

3.9. Reservoir construction (2028) - Unmitigated

3.10. Reservoir construction (2028) - Mitigated

3.11. Installation of pipes, pump etc. (2028) - Unmitigated

3.12. Installation of pipes, pump etc. (2028) - Mitigated

3.13. Installation of outlet line etc. (2028) - Unmitigated

3.14. Installation of outlet line etc. (2028) - Mitigated

3.15. Pedestrian Bridge Construction (2028) - Unmitigated

3.16. Pedestrian Bridge Construction (2028) - Mitigated

3.17. Site Improvements (2028) - Unmitigated

3.18. Site Improvements (2028) - Mitigated

3.19. Site Improvements (2029) - Unmitigated

3.20. Site Improvements (2029) - Mitigated

4. Operations Emissions Details

4.10. Soil Carbon Accumulation By Vegetation Type

4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated

4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated Eaton Wash Detailed Report, 10/16/2025
3 / 63

4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated

4.10.4. Soil Carbon Accumulation By Vegetation Type - Mitigated

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

4.10.6. Avoided and Sequestered Emissions by Species - Mitigated

5. Activity Data

5.1. Construction Schedule

5.2. Off-Road Equipment

5.2.1. Unmitigated

5.2.2. Mitigated

5.3. Construction Vehicles

5.3.1. Unmitigated

5.3.2. Mitigated

5.4. Vehicles

5.4.1. Construction Vehicle Control Strategies

5.5. Architectural Coatings

5.6. Dust Mitigation

5.6.1. Construction Earthmoving Activities

5.6.2. Construction Earthmoving Control Strategies
Eaton Wash Detailed Report, 10/16/2025
4 / 63

5.7. Construction Paving

5.8. Construction Electricity Consumption and Emissions Factors

5.18. Vegetation

5.18.1. Land Use Change

5.18.1.1. Unmitigated

5.18.1.2. Mitigated

5.18.1. Biomass Cover Type

5.18.1.1. Unmitigated

5.18.1.2. Mitigated

5.18.2. Sequestration

5.18.2.1. Unmitigated

5.18.2.2. Mitigated

6. Climate Risk Detailed Report

6.1. Climate Risk Summary

6.2. Initial Climate Risk Scores

6.3. Adjusted Climate Risk Scores

6.4. Climate Risk Reduction Measures

7. Health and Equity Details
Eaton Wash Detailed Report, 10/16/2025
5 / 63

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
Eaton Wash Detailed Report, 10/16/2025
6 / 63

1. Basic Project Information

1.1. Basic Project Information
Data Field Value
Project Name Eaton Wash
Construction Start Date 7/1/2027
Lead Agency —
Land Use Scale Project/site
Analysis Level for Defaults County
Windspeed (m/s) 0.50
Precipitation (days) 19.6
Location 34.169645957296936, -118.08973754480081
County Los Angeles-South Coast
City Pasadena
Air District South Coast AQMD
Air Basin South Coast
TAZ 4993
EDFZ 7
Electric Utility Pasadena Water & Power
Gas Utility Southern California Gas
App Version 2022.1.1.30

1.2. Land Use Types
Land Use Subtype Size Unit Lot Acreage Building Area (sq ft) Landscape Area (sq ft)
Special Landscape
Area (sq ft)
Population Description
City Park 0.57 Acre 3.85 0.00 56,830 56,830 — —
Parking Lot 8.00 Space 0.07 0.00 0.00 — — —
Eaton Wash Detailed Report, 10/16/2025
7 / 63
Other Non-Asphalt
Surfaces

2.00 1000sqft 0.05 0.00 0.00 — — —

1.3. User-Selected Emission Reduction Measures by Emissions Sector Sector # Measure Title
Construction C-5 Use Advanced Engine Tiers

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. 4.50 3.77 33.9 42.9 0.08 1.26 8.04 9.24 1.16 4.03 5.14 — 9,044 9,044 0.35 0.18 3.00 9,108 Mit. 1.18 1.09 9.12 47.0 0.08 0.21 8.04 8.17 0.21 4.03 4.16 — 9,044 9,044 0.35 0.18 3.00 9,108 %
Reduced
74% 71% 73% -9% — 83% — 12% 82% — 19% — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 2.86 2.31 23.9 24.7 0.06 0.88 6.09 6.95 0.81 2.88 3.69 — 7,002 7,002 0.30 0.47 0.17 7,151 Mit. 0.75 0.57 6.74 24.7 0.06 0.15 6.09 6.23 0.14 2.88 3.03 — 7,002 7,002 0.30 0.47 0.17 7,151 %
Reduced
74% 76% 72% > -0.5% — 83% — 10% 82% — 18% — — — — — — — Average
Daily
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 1.50 1.25 11.2 13.7 0.02 0.43 1.21 1.50 0.40 0.58 0.84 — 2,820 2,820 0.11 0.07 0.43 2,838 Mit. 0.42 0.39 3.06 14.8 0.02 0.08 1.21 1.25 0.08 0.58 0.62 — 2,820 2,820 0.11 0.07 0.43 2,838 Eaton Wash Detailed Report, 10/16/2025
8 / 63
%
Reduced
72% 69% 73% -8% — 82% — 17% 81% — 27% — — — — — — —
Annual
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 0.27 0.23 2.05 2.49 < 0.005 0.08 0.22 0.27 0.07 0.11 0.15 — 467 467 0.02 0.01 0.07 470 Mit. 0.08 0.07 0.56 2.69 < 0.005 0.01 0.22 0.23 0.01 0.11 0.11 — 467 467 0.02 0.01 0.07 470 %
Reduced
72% 69% 73% -8% — 82% — 17% 81% — 27% — — — — — — —

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)
— — — — — — — — — — — — — — — — — —
2027 3.86 3.23 29.3 30.2 0.05 1.21 8.04 9.24 1.11 4.03 5.14 — 6,056 6,056 0.25 0.11 1.71 6,098 2028 4.50 3.77 33.9 42.9 0.08 1.26 0.73 1.99 1.16 0.18 1.34 — 9,044 9,044 0.35 0.18 3.00 9,108 Daily -
Winter
(Max)
— — — — — — — — — — — — — — — — — —
2027 2.86 2.31 23.9 24.7 0.06 0.88 6.09 6.95 0.81 2.88 3.69 — 7,002 7,002 0.30 0.47 0.17 7,151 2028 2.73 2.29 20.5 20.6 0.04 0.86 0.27 1.07 0.79 0.06 0.84 — 4,532 4,532 0.18 0.06 0.03 4,554 2029 1.11 0.94 8.15 13.2 0.02 0.28 0.27 0.55 0.26 0.06 0.33 — 2,242 2,242 0.08 0.04 0.02 2,256 Average
Daily
— — — — — — — — — — — — — — — — — —
2027 0.91 0.75 7.13 7.31 0.01 0.29 1.21 1.50 0.26 0.58 0.84 — 1,732 1,732 0.07 0.07 0.43 1,756 2028 1.50 1.25 11.2 13.7 0.02 0.43 0.21 0.65 0.40 0.05 0.45 — 2,820 2,820 0.11 0.05 0.37 2,838 2029 0.20 0.16 1.44 2.33 < 0.005 0.05 0.05 0.10 0.05 0.01 0.06 — 395 395 0.01 0.01 0.07 398 Annual — — — — — — — — — — — — — — — — — —
2027 0.17 0.14 1.30 1.33 < 0.005 0.05 0.22 0.27 0.05 0.11 0.15 — 287 287 0.01 0.01 0.07 291 2028 0.27 0.23 2.05 2.49 < 0.005 0.08 0.04 0.12 0.07 0.01 0.08 — 467 467 0.02 0.01 0.06 470 Eaton Wash Detailed Report, 10/16/2025
9 / 63
2029 0.04 0.03 0.26 0.43 < 0.005 0.01 0.01 0.02 0.01 < 0.005 0.01 — 65.5 65.5 < 0.005 < 0.005 0.01 65.9

2.3. Construction Emissions by Y ear, Mitigated
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)
— — — — — — — — — — — — — — — — — —
2027 0.72 0.68 3.89 30.2 0.05 0.14 8.04 8.17 0.13 4.03 4.16 — 6,056 6,056 0.25 0.11 1.71 6,098 2028 1.18 1.09 9.12 47.0 0.08 0.21 0.73 0.94 0.21 0.18 0.39 — 9,044 9,044 0.35 0.18 3.00 9,108 Daily -
Winter
(Max)
— — — — — — — — — — — — — — — — — —
2027 0.75 0.57 6.74 24.7 0.06 0.15 6.09 6.23 0.14 2.88 3.03 — 7,002 7,002 0.30 0.47 0.17 7,151 2028 0.65 0.56 4.37 22.1 0.04 0.11 0.27 0.38 0.11 0.06 0.17 — 4,532 4,532 0.18 0.06 0.03 4,554 2029 0.62 0.54 4.32 13.8 0.02 0.11 0.27 0.38 0.10 0.06 0.16 — 2,242 2,242 0.08 0.04 0.02 2,256 Average
Daily
— — — — — — — — — — — — — — — — — —
2027 0.20 0.17 1.44 7.43 0.01 0.04 1.21 1.25 0.04 0.58 0.62 — 1,732 1,732 0.07 0.07 0.43 1,756 2028 0.42 0.39 3.06 14.8 0.02 0.08 0.21 0.29 0.08 0.05 0.13 — 2,820 2,820 0.11 0.05 0.37 2,838 2029 0.11 0.10 0.76 2.44 < 0.005 0.02 0.05 0.07 0.02 0.01 0.03 — 395 395 0.01 0.01 0.07 398 Annual — — — — — — — — — — — — — — — — — —
2027 0.04 0.03 0.26 1.36 < 0.005 0.01 0.22 0.23 0.01 0.11 0.11 — 287 287 0.01 0.01 0.07 291 2028 0.08 0.07 0.56 2.69 < 0.005 0.01 0.04 0.05 0.01 0.01 0.02 — 467 467 0.02 0.01 0.06 470 2029 0.02 0.02 0.14 0.45 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 0.01 — 65.5 65.5 < 0.005 < 0.005 0.01 65.9

3. Construction Emissions Details

3.1. Demolition (2027) - Unmitigated
Eaton Wash Detailed Report, 10/16/2025
10 / 63
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

2.94 2.47 21.7 22.5 0.04 1.00 — 1.00 0.92 — 0.92 — 4,140 4,140 0.17 0.03 — 4,154 Demoliti
on
— — — — — — 0.08 0.08 — 0.01 0.01 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.18 0.15 1.31 1.36 < 0.005 0.06 — 0.06 0.06 — 0.06 — 250 250 0.01 < 0.005 — 250 Demoliti
on
— — — — — — < 0.005 < 0.005 — < 0.005 < 0.005 — — — — — — — Onsite
truck

0.00 0.00 0.00 0.00 0.00 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 0.24 0.25 < 0.005 0.01 — 0.01 0.01 — 0.01 — 41.3 41.3 < 0.005 < 0.005 — 41.5 Demoliti
on
— — — — — — < 0.005 < 0.005 — < 0.005 < 0.005 — — — — — — — Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Eaton Wash Detailed Report, 10/16/2025
11 / 63
Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.06 0.05 0.05 0.84 0.00 0.00 0.18 0.18 0.00 0.04 0.04 — 186 186 0.01 0.01 0.58 189 Vendor 0.01 < 0.005 0.13 0.06 < 0.005 < 0.005 0.03 0.04 < 0.005 0.01 0.01 — 122 122 0.01 0.02 0.32 128 Hauling 0.02 < 0.005 0.32 0.13 < 0.005 < 0.005 0.07 0.08 < 0.005 0.02 0.02 — 267 267 0.01 0.04 0.57 281 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.05 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 — 10.8 10.8 < 0.005 < 0.005 0.02 10.9 Vendor < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 7.37 7.37 < 0.005 < 0.005 0.01 7.69 Hauling < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 16.1 16.1 < 0.005 < 0.005 0.01 16.9 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 1.79 1.79 < 0.005 < 0.005 < 0.005 1.81 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 1.22 1.22 < 0.005 < 0.005 < 0.005 1.27 Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 2.66 2.66 < 0.005 < 0.005 < 0.005 2.80

3.2. Demolition (2027) - Mitigated
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

0.44 0.43 2.72 22.9 0.04 0.09 — 0.09 0.09 — 0.09 — 4,140 4,140 0.17 0.03 — 4,154 Eaton Wash Detailed Report, 10/16/2025
12 / 63
———————0.010.01—0.080.08——————Demoliti
on
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.03 0.03 0.16 1.38 < 0.005 0.01 — 0.01 0.01 — 0.01 — 250 250 0.01 < 0.005 — 250 Demoliti
on
— — — — — — < 0.005 < 0.005 — < 0.005 < 0.005 — — — — — — — Onsite
truck

0.00 0.00 0.00 0.00 0.00 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 0.25 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 41.3 41.3 < 0.005 < 0.005 — 41.5 Demoliti
on
— — — — — — < 0.005 < 0.005 — < 0.005 < 0.005 — — — — — — — Onsite
truck

0.00 0.00 0.00 0.00 0.00 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 0.06 0.05 0.05 0.84 0.00 0.00 0.18 0.18 0.00 0.04 0.04 — 186 186 0.01 0.01 0.58 189 Vendor 0.01 < 0.005 0.13 0.06 < 0.005 < 0.005 0.03 0.04 < 0.005 0.01 0.01 — 122 122 0.01 0.02 0.32 128 Hauling 0.02 < 0.005 0.32 0.13 < 0.005 < 0.005 0.07 0.08 < 0.005 0.02 0.02 — 267 267 0.01 0.04 0.57 281 Eaton Wash Detailed Report, 10/16/2025
13 / 63
——————————————————Daily,
Winter
(Max)
Average
Daily
— — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.05 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 — 10.8 10.8 < 0.005 < 0.005 0.02 10.9 Vendor < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 7.37 7.37 < 0.005 < 0.005 0.01 7.69 Hauling < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 16.1 16.1 < 0.005 < 0.005 0.01 16.9 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 1.79 1.79 < 0.005 < 0.005 < 0.005 1.81 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 1.22 1.22 < 0.005 < 0.005 < 0.005 1.27 Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 2.66 2.66 < 0.005 < 0.005 < 0.005 2.80

3.3. Site preparation, clearing and grubbing (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

3.75 3.15 28.8 28.8 0.05 1.20 — 1.20 1.11 — 1.11 — 5,402 5,402 0.22 0.04 — 5,420 Dust
From
Material
Movement
— — — — — — 7.67 7.67 — 3.94 3.94 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 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)
— — — — — — — — — — — — — — — — — —
Eaton Wash Detailed Report, 10/16/2025
14 / 63
Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.22 0.18 1.65 1.66 < 0.005 0.07 — 0.07 0.06 — 0.06 — 311 311 0.01 < 0.005 — 312 Dust
From
Material
Movement
— — — — — — 0.44 0.44 — 0.23 0.23 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 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 0.30 < 0.005 0.01 — 0.01 0.01 — 0.01 — 51.5 51.5 < 0.005 < 0.005 — 51.6 Dust
From
Material
Movement
— — — — — — 0.08 0.08 — 0.04 0.04 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 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 0.08 0.07 0.07 1.20 0.00 0.00 0.26 0.26 0.00 0.06 0.06 — 266 266 0.01 0.01 0.83 270 Vendor 0.01 < 0.005 0.13 0.06 < 0.005 < 0.005 0.03 0.04 < 0.005 0.01 0.01 — 122 122 0.01 0.02 0.32 128 Hauling 0.02 < 0.005 0.32 0.13 < 0.005 < 0.005 0.07 0.08 < 0.005 0.02 0.02 — 267 267 0.01 0.04 0.57 281 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.06 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 — 14.7 14.7 < 0.005 < 0.005 0.02 14.9 Eaton Wash Detailed Report, 10/16/2025
15 / 63
Vendor < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 7.04 7.04 < 0.005 < 0.005 0.01 7.34 Hauling < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 15.3 15.3 < 0.005 < 0.005 0.01 16.1 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 2.44 2.44 < 0.005 < 0.005 < 0.005 2.47 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 1.17 1.17 < 0.005 < 0.005 < 0.005 1.22 Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 2.54 2.54 < 0.005 < 0.005 < 0.005 2.67

3.4. Site preparation, clearing and grubbing (2027) - Mitigated 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

0.62 0.60 3.38 28.8 0.05 0.13 — 0.13 0.13 — 0.13 — 5,402 5,402 0.22 0.04 — 5,420 Dust
From
Material
Movement
— — — — — — 7.67 7.67 — 3.94 3.94 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.04 0.03 0.19 1.66 < 0.005 0.01 — 0.01 0.01 — 0.01 — 311 311 0.01 < 0.005 — 312 Eaton Wash Detailed Report, 10/16/2025
16 / 63
———————0.230.23—0.440.44——————Dust
From
Material
Movement
Onsite
truck

0.00 0.00 0.00 0.00 0.00 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

0.01 0.01 0.04 0.30 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 51.5 51.5 < 0.005 < 0.005 — 51.6 Dust
From
Material
Movement
— — — — — — 0.08 0.08 — 0.04 0.04 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 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 0.08 0.07 0.07 1.20 0.00 0.00 0.26 0.26 0.00 0.06 0.06 — 266 266 0.01 0.01 0.83 270 Vendor 0.01 < 0.005 0.13 0.06 < 0.005 < 0.005 0.03 0.04 < 0.005 0.01 0.01 — 122 122 0.01 0.02 0.32 128 Hauling 0.02 < 0.005 0.32 0.13 < 0.005 < 0.005 0.07 0.08 < 0.005 0.02 0.02 — 267 267 0.01 0.04 0.57 281 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.06 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 — 14.7 14.7 < 0.005 < 0.005 0.02 14.9 Vendor < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 7.04 7.04 < 0.005 < 0.005 0.01 7.34 Hauling < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 15.3 15.3 < 0.005 < 0.005 0.01 16.1 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 2.44 2.44 < 0.005 < 0.005 < 0.005 2.47 Eaton Wash Detailed Report, 10/16/2025
17 / 63
Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 1.17 1.17 < 0.005 < 0.005 < 0.005 1.22 Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 2.54 2.54 < 0.005 < 0.005 < 0.005 2.67

3.5. Reservoir excavation (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)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

2.60 2.19 20.6 22.5 0.04 0.83 — 0.83 0.77 — 0.77 — 4,119 4,119 0.17 0.03 — 4,133 Dust
From
Material
Movement
— — — — — — 5.11 5.11 — 2.63 2.63 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 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

0.31 0.26 2.43 2.65 < 0.005 0.10 — 0.10 0.09 — 0.09 — 485 485 0.02 < 0.005 — 487 Dust
From
Material
Movement
— — — — — — 0.60 0.60 — 0.31 0.31 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Eaton Wash Detailed Report, 10/16/2025
18 / 63
Annual — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.06 0.05 0.44 0.48 < 0.005 0.02 — 0.02 0.02 — 0.02 — 80.3 80.3 < 0.005 < 0.005 — 80.6 Dust
From
Material
Movement
— — — — — — 0.11 0.11 — 0.06 0.06 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 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 0.07 0.06 0.08 0.92 0.00 0.00 0.24 0.24 0.00 0.06 0.06 — 227 227 < 0.005 0.01 0.02 229 Vendor 0.01 < 0.005 0.14 0.06 < 0.005 < 0.005 0.03 0.04 < 0.005 0.01 0.01 — 122 122 0.01 0.02 0.01 128 Hauling 0.18 0.04 3.13 1.20 0.02 0.03 0.70 0.74 0.03 0.19 0.23 — 2,535 2,535 0.13 0.41 0.14 2,661 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.01 0.01 0.01 0.11 0.00 0.00 0.03 0.03 0.00 0.01 0.01 — 27.1 27.1 < 0.005 < 0.005 0.04 27.5 Vendor < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 14.4 14.4 < 0.005 < 0.005 0.02 15.0 Hauling 0.02 < 0.005 0.37 0.14 < 0.005 < 0.005 0.08 0.09 < 0.005 0.02 0.03 — 299 299 0.01 0.05 0.27 314 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 4.49 4.49 < 0.005 < 0.005 0.01 4.55 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 2.39 2.39 < 0.005 < 0.005 < 0.005 2.49 Hauling < 0.005 < 0.005 0.07 0.03 < 0.005 < 0.005 0.02 0.02 < 0.005 < 0.005 < 0.005 — 49.4 49.4 < 0.005 0.01 0.05 51.9

3.6. Reservoir excavation (2027) - Mitigated
Eaton Wash Detailed Report, 10/16/2025
19 / 63
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

0.48 0.46 3.40 22.6 0.04 0.11 — 0.11 0.11 — 0.11 — 4,119 4,119 0.17 0.03 — 4,133 Dust
From
Material
Movement
— — — — — — 5.11 5.11 — 2.63 2.63 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 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

0.06 0.05 0.40 2.66 < 0.005 0.01 — 0.01 0.01 — 0.01 — 485 485 0.02 < 0.005 — 487 Dust
From
Material
Movement
— — — — — — 0.60 0.60 — 0.31 0.31 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 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

0.01 0.01 0.07 0.48 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 80.3 80.3 < 0.005 < 0.005 — 80.6 Eaton Wash Detailed Report, 10/16/2025
20 / 63
———————0.060.06—0.110.11——————Dust
From
Material
Movement
Onsite
truck

0.00 0.00 0.00 0.00 0.00 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 0.07 0.06 0.08 0.92 0.00 0.00 0.24 0.24 0.00 0.06 0.06 — 227 227 < 0.005 0.01 0.02 229 Vendor 0.01 < 0.005 0.14 0.06 < 0.005 < 0.005 0.03 0.04 < 0.005 0.01 0.01 — 122 122 0.01 0.02 0.01 128 Hauling 0.18 0.04 3.13 1.20 0.02 0.03 0.70 0.74 0.03 0.19 0.23 — 2,535 2,535 0.13 0.41 0.14 2,661 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.01 0.01 0.01 0.11 0.00 0.00 0.03 0.03 0.00 0.01 0.01 — 27.1 27.1 < 0.005 < 0.005 0.04 27.5 Vendor < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 14.4 14.4 < 0.005 < 0.005 0.02 15.0 Hauling 0.02 < 0.005 0.37 0.14 < 0.005 < 0.005 0.08 0.09 < 0.005 0.02 0.03 — 299 299 0.01 0.05 0.27 314 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 4.49 4.49 < 0.005 < 0.005 0.01 4.55 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 2.39 2.39 < 0.005 < 0.005 < 0.005 2.49 Hauling < 0.005 < 0.005 0.07 0.03 < 0.005 < 0.005 0.02 0.02 < 0.005 < 0.005 < 0.005 — 49.4 49.4 < 0.005 0.01 0.05 51.9

3.7. Reservoir 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 — — — — — — — — — — — — — — — — — —
Eaton Wash Detailed Report, 10/16/2025
21 / 63
——————————————————Daily,
Summer
(Max)
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

2.69 2.26 20.9 19.8 0.04 0.88 — 0.88 0.81 — 0.81 — 4,238 4,238 0.17 0.03 — 4,252 Onsite
truck

0.00 0.00 0.00 0.00 0.00 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

0.16 0.14 1.27 1.20 < 0.005 0.05 — 0.05 0.05 — 0.05 — 257 257 0.01 < 0.005 — 258 Onsite
truck

0.00 0.00 0.00 0.00 0.00 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 0.23 0.22 < 0.005 0.01 — 0.01 0.01 — 0.01 — 42.6 42.6 < 0.005 < 0.005 — 42.7 Onsite
truck

0.00 0.00 0.00 0.00 0.00 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 0.06 0.05 0.06 0.71 0.00 0.00 0.18 0.18 0.00 0.04 0.04 — 176 176 < 0.005 0.01 0.02 178 Vendor 0.01 < 0.005 0.14 0.06 < 0.005 < 0.005 0.03 0.04 < 0.005 0.01 0.01 — 122 122 0.01 0.02 0.01 128 Eaton Wash Detailed Report, 10/16/2025
22 / 63
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 — 10.9 10.9 < 0.005 < 0.005 0.02 11.0 Vendor < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 7.42 7.42 < 0.005 < 0.005 0.01 7.74 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 — 1.80 1.80 < 0.005 < 0.005 < 0.005 1.82 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 1.23 1.23 < 0.005 < 0.005 < 0.005 1.28 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

3.8. Reservoir construction (2027) - Mitigated
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

0.50 0.47 3.46 21.3 0.04 0.11 — 0.11 0.11 — 0.11 — 4,238 4,238 0.17 0.03 — 4,252 Onsite
truck

0.00 0.00 0.00 0.00 0.00 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 0.03 0.21 1.30 < 0.005 0.01 — 0.01 0.01 — 0.01 — 257 257 0.01 < 0.005 — 258 Eaton Wash Detailed Report, 10/16/2025
23 / 63
Onsite
truck

0.00 0.00 0.00 0.00 0.00 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

0.01 0.01 0.04 0.24 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 42.6 42.6 < 0.005 < 0.005 — 42.7 Onsite
truck

0.00 0.00 0.00 0.00 0.00 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 0.06 0.05 0.06 0.71 0.00 0.00 0.18 0.18 0.00 0.04 0.04 — 176 176 < 0.005 0.01 0.02 178 Vendor 0.01 < 0.005 0.14 0.06 < 0.005 < 0.005 0.03 0.04 < 0.005 0.01 0.01 — 122 122 0.01 0.02 0.01 128 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 — 10.9 10.9 < 0.005 < 0.005 0.02 11.0 Vendor < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 7.42 7.42 < 0.005 < 0.005 0.01 7.74 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 — 1.80 1.80 < 0.005 < 0.005 < 0.005 1.82 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 1.23 1.23 < 0.005 < 0.005 < 0.005 1.28 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. Reservoir 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 Eaton Wash Detailed Report, 10/16/2025
24 / 63
Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

2.67 2.24 20.3 19.9 0.04 0.86 — 0.86 0.79 — 0.79 — 4,240 4,240 0.17 0.03 — 4,254 Onsite
truck

0.00 0.00 0.00 0.00 0.00 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

0.47 0.40 3.62 3.54 0.01 0.15 — 0.15 0.14 — 0.14 — 755 755 0.03 0.01 — 758 Onsite
truck

0.00 0.00 0.00 0.00 0.00 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

0.09 0.07 0.66 0.65 < 0.005 0.03 — 0.03 0.03 — 0.03 — 125 125 0.01 < 0.005 — 125 Onsite
truck

0.00 0.00 0.00 0.00 0.00 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 0.05 0.05 0.05 0.67 0.00 0.00 0.18 0.18 0.00 0.04 0.04 — 173 173 < 0.005 0.01 0.01 175 Eaton Wash Detailed Report, 10/16/2025
25 / 63
Vendor 0.01 < 0.005 0.13 0.06 < 0.005 < 0.005 0.03 0.04 < 0.005 0.01 0.01 — 120 120 < 0.005 0.02 0.01 125 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 0.13 0.00 0.00 0.03 0.03 0.00 0.01 0.01 — 31.3 31.3 < 0.005 < 0.005 0.04 31.7 Vendor < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 21.3 21.3 < 0.005 < 0.005 0.02 22.2 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 0.01 0.01 0.00 < 0.005 < 0.005 — 5.18 5.18 < 0.005 < 0.005 0.01 5.25 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 3.52 3.52 < 0.005 < 0.005 < 0.005 3.68 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.10. Reservoir construction (2028) - Mitigated
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

0.49 0.47 3.42 21.4 0.04 0.11 — 0.11 0.11 — 0.11 — 4,240 4,240 0.17 0.03 — 4,254 Onsite
truck

0.00 0.00 0.00 0.00 0.00 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
— — — — — — — — — — — — — — — — — —
Eaton Wash Detailed Report, 10/16/2025
26 / 63
758—0.010.03755755—0.02—0.020.02—0.020.013.800.610.080.09Off-Roa d
Equipm
Onsite
truck

0.00 0.00 0.00 0.00 0.00 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

0.02 0.02 0.11 0.69 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 125 125 0.01 < 0.005 — 125 Onsite
truck

0.00 0.00 0.00 0.00 0.00 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 0.05 0.05 0.05 0.67 0.00 0.00 0.18 0.18 0.00 0.04 0.04 — 173 173 < 0.005 0.01 0.01 175 Vendor 0.01 < 0.005 0.13 0.06 < 0.005 < 0.005 0.03 0.04 < 0.005 0.01 0.01 — 120 120 < 0.005 0.02 0.01 125 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 0.13 0.00 0.00 0.03 0.03 0.00 0.01 0.01 — 31.3 31.3 < 0.005 < 0.005 0.04 31.7 Vendor < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 21.3 21.3 < 0.005 < 0.005 0.02 22.2 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 0.01 0.01 0.00 < 0.005 < 0.005 — 5.18 5.18 < 0.005 < 0.005 0.01 5.25 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 3.52 3.52 < 0.005 < 0.005 < 0.005 3.68 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 Eaton Wash Detailed Report, 10/16/2025
27 / 63

3.11. Installation of pipes, pump etc. (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

0.93 0.78 6.99 8.88 0.02 0.24 — 0.24 0.22 — 0.22 — 1,896 1,896 0.08 0.02 — 1,902 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.17 0.14 1.24 1.58 < 0.005 0.04 — 0.04 0.04 — 0.04 — 338 338 0.01 < 0.005 — 339 Onsite
truck

0.00 0.00 0.00 0.00 0.00 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 0.23 0.29 < 0.005 0.01 — 0.01 0.01 — 0.01 — 55.9 55.9 < 0.005 < 0.005 — 56.1 Onsite
truck

0.00 0.00 0.00 0.00 0.00 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)
— — — — — — — — — — — — — — — — — —
Eaton Wash Detailed Report, 10/16/2025
28 / 63
Worker 0.05 0.05 0.05 0.79 0.00 0.00 0.18 0.18 0.00 0.04 0.04 — 183 183 < 0.005 0.01 0.52 185 Vendor 0.01 < 0.005 0.13 0.06 < 0.005 < 0.005 0.03 0.04 < 0.005 0.01 0.01 — 119 119 < 0.005 0.02 0.30 125 Hauling 0.02 < 0.005 0.31 0.12 < 0.005 < 0.005 0.07 0.08 < 0.005 0.02 0.02 — 261 261 0.01 0.04 0.53 274 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.01 0.01 0.01 0.13 0.00 0.00 0.03 0.03 0.00 0.01 0.01 — 31.3 31.3 < 0.005 < 0.005 0.04 31.7 Vendor < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 21.3 21.3 < 0.005 < 0.005 0.02 22.2 Hauling < 0.005 < 0.005 0.06 0.02 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 46.4 46.4 < 0.005 0.01 0.04 48.7 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.02 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 — 5.18 5.18 < 0.005 < 0.005 0.01 5.25 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 3.52 3.52 < 0.005 < 0.005 < 0.005 3.68 Hauling < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 7.69 7.69 < 0.005 < 0.005 0.01 8.07

3.12. Installation of pipes, pump etc. (2028) - Mitigated 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

0.30 0.27 4.01 10.8 0.02 0.07 — 0.07 0.06 — 0.06 — 1,896 1,896 0.08 0.02 — 1,902 Onsite
truck

0.00 0.00 0.00 0.00 0.00 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)
— — — — — — — — — — — — — — — — — —
Eaton Wash Detailed Report, 10/16/2025
29 / 63
Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.05 0.05 0.71 1.92 < 0.005 0.01 — 0.01 0.01 — 0.01 — 338 338 0.01 < 0.005 — 339 Onsite
truck

0.00 0.00 0.00 0.00 0.00 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

0.01 0.01 0.13 0.35 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 55.9 55.9 < 0.005 < 0.005 — 56.1 Onsite
truck

0.00 0.00 0.00 0.00 0.00 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 0.05 0.05 0.05 0.79 0.00 0.00 0.18 0.18 0.00 0.04 0.04 — 183 183 < 0.005 0.01 0.52 185 Vendor 0.01 < 0.005 0.13 0.06 < 0.005 < 0.005 0.03 0.04 < 0.005 0.01 0.01 — 119 119 < 0.005 0.02 0.30 125 Hauling 0.02 < 0.005 0.31 0.12 < 0.005 < 0.005 0.07 0.08 < 0.005 0.02 0.02 — 261 261 0.01 0.04 0.53 274 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.01 0.01 0.01 0.13 0.00 0.00 0.03 0.03 0.00 0.01 0.01 — 31.3 31.3 < 0.005 < 0.005 0.04 31.7 Vendor < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 21.3 21.3 < 0.005 < 0.005 0.02 22.2 Hauling < 0.005 < 0.005 0.06 0.02 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 46.4 46.4 < 0.005 0.01 0.04 48.7 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.02 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 — 5.18 5.18 < 0.005 < 0.005 0.01 5.25 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 3.52 3.52 < 0.005 < 0.005 < 0.005 3.68 Hauling < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 7.69 7.69 < 0.005 < 0.005 0.01 8.07 Eaton Wash Detailed Report, 10/16/2025
30 / 63

3.13. Installation of outlet line etc. (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

2.59 2.17 20.2 22.5 0.04 0.81 — 0.81 0.75 — 0.75 — 4,120 4,120 0.17 0.03 — 4,134 Architect
ural
Coating
s

0.02 0.02 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.46 0.39 3.60 4.02 0.01 0.14 — 0.14 0.13 — 0.13 — 734 734 0.03 0.01 — 736 Architect
ural
Coating
s
< 0.005 < 0.005 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 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 — — — — — — — — — — — — — — — — — —
Eaton Wash Detailed Report, 10/16/2025
31 / 63
122—< 0.005< 0.005121121—0.02—0.020.03—0.03< 0.0050.730.660.070.08Off-Roa d
Equipm
ent
Architect
ural
Coating
s
< 0.005 < 0.005 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 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 1.02 0.00 0.00 0.24 0.24 0.00 0.06 0.06 — 235 235 < 0.005 0.01 0.67 238 Vendor 0.01 < 0.005 0.13 0.06 < 0.005 < 0.005 0.03 0.04 < 0.005 0.01 0.01 — 119 119 < 0.005 0.02 0.30 125 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.01 0.01 0.01 0.16 0.00 0.00 0.04 0.04 0.00 0.01 0.01 — 40.3 40.3 < 0.005 < 0.005 0.05 40.8 Vendor < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 21.3 21.3 < 0.005 < 0.005 0.02 22.2 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 — 6.66 6.66 < 0.005 < 0.005 0.01 6.75 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 3.52 3.52 < 0.005 < 0.005 < 0.005 3.68 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.14. Installation of outlet line etc. (2028) - Mitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Eaton Wash Detailed Report, 10/16/2025
32 / 63
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

0.48 0.46 3.36 22.6 0.04 0.11 — 0.11 0.10 — 0.10 — 4,120 4,120 0.17 0.03 — 4,134 Architect
ural
Coating
s

0.02 0.02 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.09 0.08 0.60 4.02 0.01 0.02 — 0.02 0.02 — 0.02 — 734 734 0.03 0.01 — 736 Architect
ural
Coating
s
< 0.005 < 0.005 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 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

0.02 0.01 0.11 0.73 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 121 121 < 0.005 < 0.005 — 122 Eaton Wash Detailed Report, 10/16/2025
33 / 63
————————————————< 0.005< 0.005Architect
ural
Coating
Onsite
truck

0.00 0.00 0.00 0.00 0.00 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 1.02 0.00 0.00 0.24 0.24 0.00 0.06 0.06 — 235 235 < 0.005 0.01 0.67 238 Vendor 0.01 < 0.005 0.13 0.06 < 0.005 < 0.005 0.03 0.04 < 0.005 0.01 0.01 — 119 119 < 0.005 0.02 0.30 125 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.01 0.01 0.01 0.16 0.00 0.00 0.04 0.04 0.00 0.01 0.01 — 40.3 40.3 < 0.005 < 0.005 0.05 40.8 Vendor < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 21.3 21.3 < 0.005 < 0.005 0.02 22.2 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 — 6.66 6.66 < 0.005 < 0.005 0.01 6.75 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 3.52 3.52 < 0.005 < 0.005 < 0.005 3.68 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. Pedestrian Bridge 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)
— — — — — — — — — — — — — — — — — —
Eaton Wash Detailed Report, 10/16/2025
34 / 63
Off-Roa
Equipment

0.76 0.64 5.88 8.80 0.02 0.20 — 0.20 0.19 — 0.19 — 1,862 1,862 0.08 0.02 — 1,868 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.13 0.11 1.05 1.57 < 0.005 0.04 — 0.04 0.03 — 0.03 — 332 332 0.01 < 0.005 — 333 Onsite
truck

0.00 0.00 0.00 0.00 0.00 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

0.02 0.02 0.19 0.29 < 0.005 0.01 — 0.01 0.01 — 0.01 — 54.9 54.9 < 0.005 < 0.005 — 55.1 Onsite
truck

0.00 0.00 0.00 0.00 0.00 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 0.04 0.03 0.03 0.56 0.00 0.00 0.13 0.13 0.00 0.03 0.03 — 131 131 < 0.005 < 0.005 0.37 132 Vendor 0.01 < 0.005 0.13 0.06 < 0.005 < 0.005 0.03 0.04 < 0.005 0.01 0.01 — 119 119 < 0.005 0.02 0.30 125 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.01 0.01 0.01 0.09 0.00 0.00 0.02 0.02 0.00 0.01 0.01 — 22.4 22.4 < 0.005 < 0.005 0.03 22.6 Eaton Wash Detailed Report, 10/16/2025
35 / 63
Vendor < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 21.3 21.3 < 0.005 < 0.005 0.02 22.2 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 — 3.70 3.70 < 0.005 < 0.005 < 0.005 3.75 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 3.52 3.52 < 0.005 < 0.005 < 0.005 3.68 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

3.16. Pedestrian Bridge Construction (2028) - Mitigated 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

0.18 0.18 0.92 11.0 0.02 0.04 — 0.04 0.04 — 0.04 — 1,862 1,862 0.08 0.02 — 1,868 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.03 0.03 0.16 1.95 < 0.005 0.01 — 0.01 0.01 — 0.01 — 332 332 0.01 < 0.005 — 333 Onsite
truck

0.00 0.00 0.00 0.00 0.00 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 — — — — — — — — — — — — — — — — — —
Eaton Wash Detailed Report, 10/16/2025
36 / 63

55.1—< 0.005< 0.00554.954.9—< 0.005—< 0.005< 0.005—< 0.005< 0.0050.360.030.010.01Off-Roa d
Onsite
truck

0.00 0.00 0.00 0.00 0.00 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 0.04 0.03 0.03 0.56 0.00 0.00 0.13 0.13 0.00 0.03 0.03 — 131 131 < 0.005 < 0.005 0.37 132 Vendor 0.01 < 0.005 0.13 0.06 < 0.005 < 0.005 0.03 0.04 < 0.005 0.01 0.01 — 119 119 < 0.005 0.02 0.30 125 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.01 0.01 0.01 0.09 0.00 0.00 0.02 0.02 0.00 0.01 0.01 — 22.4 22.4 < 0.005 < 0.005 0.03 22.6 Vendor < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 21.3 21.3 < 0.005 < 0.005 0.02 22.2 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 — 3.70 3.70 < 0.005 < 0.005 < 0.005 3.75 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 3.52 3.52 < 0.005 < 0.005 < 0.005 3.68 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

3.17. Site Improvements (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)
— — — — — — — — — — — — — — — — — —
Eaton Wash Detailed Report, 10/16/2025
37 / 63
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

1.08 0.90 8.28 12.3 0.02 0.31 — 0.31 0.28 — 0.28 — 1,907 1,907 0.08 0.02 — 1,913 Paving < 0.005 < 0.005 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 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 1.49 2.22 < 0.005 0.06 — 0.06 0.05 — 0.05 — 343 343 0.01 < 0.005 — 344 Paving < 0.005 < 0.005 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 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 0.27 0.41 < 0.005 0.01 — 0.01 0.01 — 0.01 — 56.8 56.8 < 0.005 < 0.005 — 57.0 Paving < 0.005 < 0.005 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 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 0.07 0.06 0.07 0.86 0.00 0.00 0.24 0.24 0.00 0.06 0.06 — 223 223 < 0.005 0.01 0.02 225 Eaton Wash Detailed Report, 10/16/2025
38 / 63
Vendor 0.01 < 0.005 0.13 0.06 < 0.005 < 0.005 0.03 0.04 < 0.005 0.01 0.01 — 120 120 < 0.005 0.02 0.01 125 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 0.16 0.00 0.00 0.04 0.04 0.00 0.01 0.01 — 40.7 40.7 < 0.005 < 0.005 0.05 41.2 Vendor < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 21.5 21.5 < 0.005 < 0.005 0.02 22.5 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 — 6.74 6.74 < 0.005 < 0.005 0.01 6.82 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 3.56 3.56 < 0.005 < 0.005 < 0.005 3.72 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

3.18. Site Improvements (2028) - Mitigated
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

0.57 0.49 4.17 13.0 0.02 0.11 — 0.11 0.10 — 0.10 — 1,907 1,907 0.08 0.02 — 1,913 Paving < 0.005 < 0.005 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 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
— — — — — — — — — — — — — — — — — —
Eaton Wash Detailed Report, 10/16/2025
39 / 63
344—< 0.0050.01343343—0.02—0.020.02—0.02< 0.0052.340.750.090.10Off-Roa d
Paving < 0.005 < 0.005 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 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

0.02 0.02 0.14 0.43 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 56.8 56.8 < 0.005 < 0.005 — 57.0 Paving < 0.005 < 0.005 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 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 0.07 0.06 0.07 0.86 0.00 0.00 0.24 0.24 0.00 0.06 0.06 — 223 223 < 0.005 0.01 0.02 225 Vendor 0.01 < 0.005 0.13 0.06 < 0.005 < 0.005 0.03 0.04 < 0.005 0.01 0.01 — 120 120 < 0.005 0.02 0.01 125 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 0.16 0.00 0.00 0.04 0.04 0.00 0.01 0.01 — 40.7 40.7 < 0.005 < 0.005 0.05 41.2 Vendor < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 21.5 21.5 < 0.005 < 0.005 0.02 22.5 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 — 6.74 6.74 < 0.005 < 0.005 0.01 6.82 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 3.56 3.56 < 0.005 < 0.005 < 0.005 3.72 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 Eaton Wash Detailed Report, 10/16/2025
40 / 63

3.19. Site Improvements (2029) - 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

1.04 0.87 7.96 12.3 0.02 0.28 — 0.28 0.26 — 0.26 — 1,906 1,906 0.08 0.02 — 1,913 Paving < 0.005 < 0.005 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 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

0.18 0.15 1.40 2.17 < 0.005 0.05 — 0.05 0.05 — 0.05 — 336 336 0.01 < 0.005 — 337 Paving < 0.005 < 0.005 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 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 0.26 0.40 < 0.005 0.01 — 0.01 0.01 — 0.01 — 55.6 55.6 < 0.005 < 0.005 — 55.8 Paving < 0.005 < 0.005 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Eaton Wash Detailed Report, 10/16/2025
41 / 63
Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.06 0.06 0.06 0.80 0.00 0.00 0.24 0.24 0.00 0.06 0.06 — 219 219 < 0.005 0.01 0.02 222 Vendor 0.01 < 0.005 0.12 0.06 < 0.005 < 0.005 0.03 0.04 < 0.005 0.01 0.01 — 116 116 < 0.005 0.02 0.01 122 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 0.15 0.00 0.00 0.04 0.04 0.00 0.01 0.01 — 39.1 39.1 < 0.005 < 0.005 0.05 39.6 Vendor < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 20.5 20.5 < 0.005 < 0.005 0.02 21.4 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 — 6.48 6.48 < 0.005 < 0.005 0.01 6.56 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 3.39 3.39 < 0.005 < 0.005 < 0.005 3.54 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

3.20. Site Improvements (2029) - Mitigated
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)
— — — — — — — — — — — — — — — — — —
Eaton Wash Detailed Report, 10/16/2025
42 / 63
1,913—0.020.081,9061,906—0.10—0.100.11—0.110.0213.04.130.480.56Off-Roa d
Equipm
Paving < 0.005 < 0.005 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 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

0.10 0.08 0.73 2.28 < 0.005 0.02 — 0.02 0.02 — 0.02 — 336 336 0.01 < 0.005 — 337 Paving < 0.005 < 0.005 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 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

0.02 0.02 0.13 0.42 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 55.6 55.6 < 0.005 < 0.005 — 55.8 Paving < 0.005 < 0.005 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 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 0.06 0.06 0.06 0.80 0.00 0.00 0.24 0.24 0.00 0.06 0.06 — 219 219 < 0.005 0.01 0.02 222 Vendor 0.01 < 0.005 0.12 0.06 < 0.005 < 0.005 0.03 0.04 < 0.005 0.01 0.01 — 116 116 < 0.005 0.02 0.01 122 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
— — — — — — — — — — — — — — — — — —
Eaton Wash Detailed Report, 10/16/2025
43 / 63
Worker 0.01 0.01 0.01 0.15 0.00 0.00 0.04 0.04 0.00 0.01 0.01 — 39.1 39.1 < 0.005 < 0.005 0.05 39.6 Vendor < 0.005 < 0.005 0.02 0.01 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 20.5 20.5 < 0.005 < 0.005 0.02 21.4 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 — 6.48 6.48 < 0.005 < 0.005 0.01 6.56 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 3.39 3.39 < 0.005 < 0.005 < 0.005 3.54 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

4. Operations Emissions Details

4.10. Soil Carbon Accumulation By Vegetation Type

4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated Criteria Pollutants (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 — — — — — — — — — — — — — — — — — —
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) Eaton Wash Detailed Report, 10/16/2025
44 / 63
CO2eRN2OCH4CO2TNBCO2BCO2PM2.5TPM2.5DPM2.5EPM10TPM10DPM10ESO2CONOxROGTOGLand Use
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) 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
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
— — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — — — —
Eaton Wash Detailed Report, 10/16/2025
45 / 63
Subtotal — — — — — — — — — — — — — — — — — —
Sequest
ered
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Remove
d
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
— — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Sequest
ered
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Remove
d
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
— — — — — — — — — — — — — — — — — — —

4.10.4. Soil Carbon Accumulation By Vegetation Type - Mitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) 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 — — — — — — — — — — — — — — — — — —
Eaton Wash Detailed Report, 10/16/2025
46 / 63
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.10.5. Above and Belowground Carbon Accumulation by Land Use Type - Mitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) 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 — — — — — — — — — — — — — — — — — —

4.10.6. Avoided and Sequestered Emissions by Species - Mitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) 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
— — — — — — — — — — — — — — — — — —
Eaton Wash Detailed Report, 10/16/2025
47 / 63
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 Demolition Demolition 7/1/2027 7/31/2027 5.00 22.0 —
Eaton Wash Detailed Report, 10/16/2025
48 / 63
Site preparation, clearing
and grubbing
Site Preparation 8/1/2027 8/30/2027 5.00 21.0 —
Reservoir excavation Grading 10/1/2027 11/30/2027 5.00 43.0 — Reservoir construction Building Construction 12/1/2027 3/31/2028 5.00 88.0 — Installation of pipes, pump
etc.

Building Construction 5/1/2028 7/30/2028 5.00 65.0 —
Installation of outlet line
etc.

Building Construction 5/1/2028 7/30/2028 5.00 65.0 —
Pedestrian Bridge
Construction
Building Construction 7/1/2028 9/30/2028 5.00 65.0 —
Site Improvements Paving 10/1/2028 3/31/2029 5.00 130 —

5.2. Off-Road Equipment

5.2.1. Unmitigated
Phase Name Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor Demolition Rubber Tired Dozers Diesel Average 2.00 8.00 367 0.40 Demolition Skid Steer Loaders Diesel Average 1.00 8.00 71.0 0.37 Demolition Graders Diesel Average 2.00 8.00 148 0.41
Site preparation,
clearing and grubbing
Rubber Tired Dozers Diesel Average 3.00 8.00 367 0.40
Site preparation,
clearing and grubbing
Generator Sets Diesel Average 1.00 8.00 14.0 0.74
Site preparation,
clearing and grubbing
Tractors/Loaders/Back
hoes
Diesel Average 4.00 8.00 84.0 0.37
Reservoir excavation Rubber Tired Dozers Diesel Average 2.00 8.00 367 0.40 Reservoir excavation Skid Steer Loaders Diesel Average 2.00 8.00 71.0 0.37 Reservoir excavation Tractors/Loaders/Back
hoes
Diesel Average 3.00 8.00 84.0 0.37
Reservoir construction Cranes Diesel Average 1.00 8.00 367 0.29 Reservoir construction Rubber Tired Dozers Diesel Average 2.00 8.00 367 0.40 Eaton Wash Detailed Report, 10/16/2025
49 / 63
Reservoir construction Skid Steer Loaders Diesel Average 2.00 8.00 71.0 0.37 Installation of pipes,
pump etc.

Cranes Diesel Average 1.00 8.00 367 0.29
Installation of pipes,
pump etc.

Trenchers Diesel Average 2.00 8.00 40.0 0.50
Installation of pipes,
pump etc.

Skid Steer Loaders Diesel Average 2.00 8.00 71.0 0.37
Installation of outlet
line etc.

Rubber Tired Dozers Diesel Average 2.00 8.00 367 0.40
Installation of outlet
line etc.

Skid Steer Loaders Diesel Average 2.00 8.00 71.0 0.37
Installation of outlet
line etc.

Tractors/Loaders/Back
hoes
Diesel Average 3.00 8.00 84.0 0.37
Pedestrian Bridge
Construction
Tractors/Loaders/Back
hoes
Diesel Average 3.00 8.00 84.0 0.37
Pedestrian Bridge
Construction
Cranes Diesel Average 1.00 8.00 367 0.29
Site Improvements Graders Diesel Average 1.00 8.00 148 0.41 Site Improvements Skid Steer Loaders Diesel Average 1.00 8.00 71.0 0.37 Site Improvements Pavers Diesel Average 1.00 8.00 81.0 0.42 Site Improvements Paving Equipment Diesel Average 1.00 8.00 89.0 0.36 Site Improvements Rollers Diesel Average 1.00 8.00 36.0 0.38 Site Improvements Cement and Mortar
Mixers
Diesel Average 1.00 8.00 10.0 0.56
Site Improvements Aerial Lifts Diesel Average 1.00 8.00 46.0 0.31 Site Improvements Air Compressors Diesel Average 1.00 6.00 37.0 0.48

5.2.2. Mitigated
Phase Name Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor Demolition Rubber Tired Dozers Diesel Tier 4 Final 2.00 8.00 367 0.40 Demolition Skid Steer Loaders Diesel Average 1.00 8.00 71.0 0.37 Eaton Wash Detailed Report, 10/16/2025
50 / 63
Demolition Graders Diesel Tier 4 Final 2.00 8.00 148 0.41 Site preparation,
clearing and grubbing
Rubber Tired Dozers Diesel Tier 4 Final 3.00 8.00 367 0.40 Site preparation,
clearing and grubbing
Generator Sets Diesel Average 1.00 8.00 14.0 0.74
Site preparation,
clearing and grubbing
Tractors/Loaders/Back
hoes
Diesel Tier 4 Final 4.00 8.00 84.0 0.37
Reservoir excavation Rubber Tired Dozers Diesel Tier 4 Final 2.00 8.00 367 0.40 Reservoir excavation Skid Steer Loaders Diesel Average 2.00 8.00 71.0 0.37 Reservoir excavation Tractors/Loaders/Back
hoes
Diesel Tier 4 Final 3.00 8.00 84.0 0.37
Reservoir construction Cranes Diesel Tier 4 Final 1.00 8.00 367 0.29 Reservoir construction Rubber Tired Dozers Diesel Tier 4 Final 2.00 8.00 367 0.40 Reservoir construction Skid Steer Loaders Diesel Average 2.00 8.00 71.0 0.37 Installation of pipes,
pump etc.

Cranes Diesel Tier 4 Final 1.00 8.00 367 0.29
Installation of pipes,
pump etc.

Trenchers Diesel Tier 4 Final 2.00 8.00 40.0 0.50
Installation of pipes,
pump etc.

Skid Steer Loaders Diesel Average 2.00 8.00 71.0 0.37
Installation of outlet
line etc.

Rubber Tired Dozers Diesel Tier 4 Final 2.00 8.00 367 0.40 Installation of outlet
line etc.

Skid Steer Loaders Diesel Average 2.00 8.00 71.0 0.37
Installation of outlet
line etc.

Tractors/Loaders/Back
hoes
Diesel Tier 4 Final 3.00 8.00 84.0 0.37
Pedestrian Bridge
Construction
Tractors/Loaders/Back
hoes
Diesel Tier 4 Final 3.00 8.00 84.0 0.37
Pedestrian Bridge
Construction
Cranes Diesel Tier 4 Final 1.00 8.00 367 0.29
Site Improvements Graders Diesel Tier 4 Final 1.00 8.00 148 0.41 Site Improvements Skid Steer Loaders Diesel Average 1.00 8.00 71.0 0.37 Site Improvements Pavers Diesel Tier 4 Final 1.00 8.00 81.0 0.42 Eaton Wash Detailed Report, 10/16/2025
51 / 63
Site Improvements Paving Equipment Diesel Tier 4 Final 1.00 8.00 89.0 0.36 Site Improvements Rollers Diesel Average 1.00 8.00 36.0 0.38 Site Improvements Cement and Mortar
Mixers
Diesel Average 1.00 8.00 10.0 0.56
Site Improvements Aerial Lifts Diesel Average 1.00 8.00 46.0 0.31 Site Improvements Air Compressors Diesel Average 1.00 6.00 37.0 0.48

5.3. Construction Vehicles

5.3.1. Unmitigated
Phase Name Trip Type One-Way Trips per Day Miles per Trip Vehicle Mix Demolition — — — —
Demolition Worker 14.0 18.5 LDA,LDT1,LDT2
Demolition Vendor 4.00 10.2 HHDT,MHDT
Demolition Hauling 4.00 20.0 HHDT
Demolition Onsite truck — — HHDT
Site preparation, clearing and
grubbing
— — — —
Site preparation, clearing and
grubbing
Worker 20.0 18.5 LDA,LDT1,LDT2
Site preparation, clearing and
grubbing
Vendor 4.00 10.2 HHDT,MHDT
Site preparation, clearing and
grubbing
Hauling 4.00 20.0 HHDT
Site preparation, clearing and
grubbing
Onsite truck — — HHDT
Reservoir excavation — — — —
Reservoir excavation Worker 18.0 18.5 LDA,LDT1,LDT2
Reservoir excavation Vendor 4.00 10.2 HHDT,MHDT
Reservoir excavation Hauling 38.0 20.0 HHDT
Eaton Wash Detailed Report, 10/16/2025
52 / 63
Reservoir excavation Onsite truck — — HHDT
Reservoir construction — — — —
Reservoir construction Worker 14.0 18.5 LDA,LDT1,LDT2
Reservoir construction Vendor 4.00 10.2 HHDT,MHDT
Reservoir construction Hauling 0.00 20.0 HHDT
Reservoir construction Onsite truck — — HHDT
Installation of pipes, pump etc. — — — —
Installation of pipes, pump etc. Worker 14.0 18.5 LDA,LDT1,LDT2 Installation of pipes, pump etc. Vendor 4.00 10.2 HHDT,MHDT Installation of pipes, pump etc. Hauling 4.00 20.0 HHDT Installation of pipes, pump etc. Onsite truck — — HHDT
Installation of outlet line etc. — — — —
Installation of outlet line etc. Worker 18.0 18.5 LDA,LDT1,LDT2 Installation of outlet line etc. Vendor 4.00 10.2 HHDT,MHDT Installation of outlet line etc. Hauling 0.00 20.0 HHDT Installation of outlet line etc. Onsite truck — — HHDT
Pedestrian Bridge Construction — — — —
Pedestrian Bridge Construction Worker 10.0 18.5 LDA,LDT1,LDT2 Pedestrian Bridge Construction Vendor 4.00 10.2 HHDT,MHDT Pedestrian Bridge Construction Hauling 0.00 20.0 HHDT
Pedestrian Bridge Construction Onsite truck — — HHDT
Site Improvements — — — —
Site Improvements Worker 18.0 18.5 LDA,LDT1,LDT2
Site Improvements Vendor 4.00 10.2 HHDT,MHDT
Site Improvements Hauling 0.00 20.0 HHDT
Site Improvements Onsite truck — — HHDT

5.3.2. Mitigated
Eaton Wash Detailed Report, 10/16/2025
53 / 63
Phase Name Trip Type One-Way Trips per Day Miles per Trip Vehicle Mix Demolition — — — —
Demolition Worker 14.0 18.5 LDA,LDT1,LDT2
Demolition Vendor 4.00 10.2 HHDT,MHDT
Demolition Hauling 4.00 20.0 HHDT
Demolition Onsite truck — — HHDT
Site preparation, clearing and
grubbing
— — — —
Site preparation, clearing and
grubbing
Worker 20.0 18.5 LDA,LDT1,LDT2
Site preparation, clearing and
grubbing
Vendor 4.00 10.2 HHDT,MHDT
Site preparation, clearing and
grubbing
Hauling 4.00 20.0 HHDT
Site preparation, clearing and
grubbing
Onsite truck — — HHDT
Reservoir excavation — — — —
Reservoir excavation Worker 18.0 18.5 LDA,LDT1,LDT2
Reservoir excavation Vendor 4.00 10.2 HHDT,MHDT
Reservoir excavation Hauling 38.0 20.0 HHDT
Reservoir excavation Onsite truck — — HHDT
Reservoir construction — — — —
Reservoir construction Worker 14.0 18.5 LDA,LDT1,LDT2
Reservoir construction Vendor 4.00 10.2 HHDT,MHDT
Reservoir construction Hauling 0.00 20.0 HHDT
Reservoir construction Onsite truck — — HHDT
Installation of pipes, pump etc. — — — —
Installation of pipes, pump etc. Worker 14.0 18.5 LDA,LDT1,LDT2 Installation of pipes, pump etc. Vendor 4.00 10.2 HHDT,MHDT Installation of pipes, pump etc. Hauling 4.00 20.0 HHDT Eaton Wash Detailed Report, 10/16/2025
54 / 63
Installation of pipes, pump etc. Onsite truck — — HHDT
Installation of outlet line etc. — — — —
Installation of outlet line etc. Worker 18.0 18.5 LDA,LDT1,LDT2 Installation of outlet line etc. Vendor 4.00 10.2 HHDT,MHDT Installation of outlet line etc. Hauling 0.00 20.0 HHDT Installation of outlet line etc. Onsite truck — — HHDT
Pedestrian Bridge Construction — — — —
Pedestrian Bridge Construction Worker 10.0 18.5 LDA,LDT1,LDT2 Pedestrian Bridge Construction Vendor 4.00 10.2 HHDT,MHDT Pedestrian Bridge Construction Hauling 0.00 20.0 HHDT
Pedestrian Bridge Construction Onsite truck — — HHDT
Site Improvements — — — —
Site Improvements Worker 18.0 18.5 LDA,LDT1,LDT2
Site Improvements Vendor 4.00 10.2 HHDT,MHDT
Site Improvements Hauling 0.00 20.0 HHDT
Site Improvements Onsite truck — — HHDT

5.4. Vehicles

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

5.5. Architectural Coatings
Phase Name Residential Interior Area
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)
Installation of outlet line etc. 0.00 0.00 0.00 0.00 308

5.6. Dust Mitigation
Eaton Wash Detailed Report, 10/16/2025
55 / 63

5.6.1. Construction Earthmoving Activities
Phase Name Material Imported (Cubic
Y ards)
Material Exported (Cubic
Y ards)
Acres Graded (acres) Material Demolished (Ton of
Debris)
Acres Paved (acres)
Demolition 0.00 0.00 0.00 135 —
Site preparation, clearing and
grubbing
— — 31.5 0.00 —
Reservoir excavation — 12,510 43.0 0.00 —
Site Improvements 0.00 0.00 0.00 0.00 0.12

5.6.2. Construction Earthmoving Control Strategies
Control Strategies Applied Frequency (per day) PM10 Reduction PM2.5 Reduction Water Exposed Area 2 61% 61%
Water Demolished Area 2 36% 36%

5.7. Construction Paving
Land Use Area Paved (acres) % Asphalt
City Park 0.00 0%
Parking Lot 0.07 100%
Other Non-Asphalt Surfaces 0.05 0%

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
2028 0.00 1,028 0.03 < 0.005
2029 0.00 1,028 0.03 < 0.005
2027 0.00 1,028 0.03 < 0.005
Eaton Wash Detailed Report, 10/16/2025
56 / 63

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

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

5.18.1. Biomass Cover Type

5.18.1.1. Unmitigated
Biomass Cover Type Initial Acres Final Acres

5.18.1.2. Mitigated
Biomass Cover Type Initial Acres Final Acres

5.18.2. Sequestration

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

5.18.2.2. Mitigated
Tree Type Number Electricity Saved (kWh/year) Natural Gas Saved (btu/year) Eaton Wash Detailed Report, 10/16/2025
57 / 63

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 20.8 annual days of extreme heat Extreme Precipitation 7.85 annual days with precipitation above 20 mm Sea Level Rise — meters of inundation depth
Wildfire 6.20 annual hectares burned
Temperature and Extreme Heat data are for grid cell in which your project are located. The projection is based on the 98th historical percentile of daily maximum/minimum temperatures from observed historical data (32 climate model ensemble from Cal-Adapt, 2040–2059 average under RCP 8.5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.

Extreme Precipitation data are for the grid cell in which your project are located. The threshold of 20 mm is equivalent to about ¾ an inch of rain, which would be light to moderate rainfall if received over a full day or heavy rain if received over a period of 2 to 4 hours. Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.

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

6.2. Initial Climate Risk Scores
Climate Hazard Exposure Score Sensitivity Score Adaptive Capacity Score Vulnerability Score Temperature and Extreme Heat N/A N/A N/A N/A
Extreme Precipitation N/A N/A N/A N/A
Sea Level Rise N/A N/A N/A N/A
Wildfire N/A N/A N/A N/A
Flooding N/A N/A N/A N/A
Drought N/A N/A N/A N/A
Snowpack Reduction N/A N/A N/A N/A
Air Quality Degradation N/A N/A N/A N/A
Eaton Wash Detailed Report, 10/16/2025
58 / 63
The sensitivity score reflects the extent to which a project would be adversely affected by exposure to a climate hazard. Exposure is rated on a scale of 1 to 5, with a score of 5 representing the greatest exposure.

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

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

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

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

The overall vulnerability scores are calculated based on the potential impacts and adaptive capacity assessments for each hazard. Scores 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 84.6
Eaton Wash Detailed Report, 10/16/2025
59 / 63
AQ-PM 61.6
AQ-DPM 14.4
Drinking Water 87.7
Lead Risk Housing 57.2
Pesticides 41.7
Toxic Releases 67.5
Traffic 16.4
Effect Indicators —
CleanUp Sites 61.4
Groundwater 0.00
Haz Waste Facilities/Generators 1.80
Impaired Water Bodies 0.00
Solid Waste 35.7
Sensitive Population —
Asthma 11.4
Cardio-vascular 8.28
Low Birth Weights 1.01
Socioeconomic Factor Indicators —
Education 20.9
Housing 39.2
Linguistic 46.0
Poverty 9.85
Unemployment 52.5

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 —
Eaton Wash Detailed Report, 10/16/2025
60 / 63
Above Poverty 91.55652509
Employed 66.62389324
Median HI 93.46849737
Education —
Bachelor's or higher 81.99666367
High school enrollment 100
Preschool enrollment 95.7141024
Transportation —
Auto Access 81.29090209
Active commuting 28.7950725
Social —
2-parent households 61.81188246
Voting 85.88476838
Neighborhood —
Alcohol availability 81.62453484
Park access 49.90375978
Retail density 20.12062107
Supermarket access 12.33157962
Tree canopy 87.66842038
Housing —
Homeownership 87.77107661
Housing habitability 91.27422045
Low-inc homeowner severe housing cost burden 52.23918902 Low-inc renter severe housing cost burden 80.48248428
Uncrowded housing 96.93314513
Health Outcomes —
Insured adults 81.97099962
Arthritis 17.5
Eaton Wash Detailed Report, 10/16/2025
61 / 63
Asthma ER Admissions 85.4
High Blood Pressure 16.4
Cancer (excluding skin) 6.6
Asthma 83.3
Coronary Heart Disease 17.4
Chronic Obstructive Pulmonary Disease 56.7
Diagnosed Diabetes 52.6
Life Expectancy at Birth 88.2
Cognitively Disabled 56.3
Physically Disabled 47.8
Heart Attack ER Admissions 82.4
Mental Health Not Good 85.8
Chronic Kidney Disease 35.4
Obesity 78.7
Pedestrian Injuries 51.7
Physical Health Not Good 68.2
Stroke 34.3
Health Risk Behaviors —
Binge Drinking 71.2
Current Smoker 86.5
No Leisure Time for Physical Activity 79.7
Climate Change Exposures —
Wildfire Risk 46.9
SLR Inundation Area 0.0
Children 71.1
Elderly 13.2
English Speaking 80.3
Foreign-born 61.2
Eaton Wash Detailed Report, 10/16/2025
62 / 63
Outdoor Workers 72.8
Climate Change Adaptive Capacity —
Impervious Surface Cover 84.1
Traffic Density 14.1
Traffic Access 23.0
Other Indices —
Hardship 16.5
Other Decision Support —
2016 Voting 68.0

7.3. Overall Health & Equity Scores
Metric Result for Project Census Tract
CalEnviroScreen 4.0 Score for Project Location (a) 15.0 Healthy Places Index Score for Project Location (b) 91.0 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
Eaton Wash Detailed Report, 10/16/2025
63 / 63
Screen Justification
Land Use Based on applicant provided information.

Construction: Construction Phases Based on applicant schedule.

Construction: Off-Road Equipment applicant provided information Construction: Trips and VMT Trips based on applicant provided information. Vendor trucks added to represent water trucks, other materials transported to site. Haul truck trip length changed to 9 miles to reflect the project specific distance to the disposal site.

Operations: Vehicle Data Up to 3 staff would visit site on a daily basis, reflected in Parking Lot use.

Operations: Off-Road Equipment Wash operations would include a pump (or 2) to move water. Based on preliminary project info, pump(s) would be electrically powered and assumed to 75 hp, operated year-round.

Eaton Wash LST Analysis Detailed Report, 9/5/2025
1 / 63
Eaton Wash LST Analysis 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

2.3. Construction Emissions by Y ear, Mitigated

3. Construction Emissions Details

3.1. Demolition (2027) - Unmitigated

3.2. Demolition (2027) - Mitigated

3.3. Site preparation, clearing and grubbing (2027) - Unmitigated

3.4. Site preparation, clearing and grubbing (2027) - Mitigated

3.5. Reservoir excavation (2027) - Unmitigated

3.6. Reservoir excavation (2027) - Mitigated
Eaton Wash LST Analysis Detailed Report, 9/5/2025
2 / 63

3.7. Reservoir construction (2027) - Unmitigated

3.8. Reservoir construction (2027) - Mitigated

3.9. Reservoir construction (2028) - Unmitigated

3.10. Reservoir construction (2028) - Mitigated

3.11. Installation of pipes, pump etc. (2028) - Unmitigated

3.12. Installation of pipes, pump etc. (2028) - Mitigated

3.13. Installation of outlet line etc. (2028) - Unmitigated

3.14. Installation of outlet line etc. (2028) - Mitigated

3.15. Pedestrian Bridge Construction (2028) - Unmitigated

3.16. Pedestrian Bridge Construction (2028) - Mitigated

3.17. Site Improvements (2028) - Unmitigated

3.18. Site Improvements (2028) - Mitigated

3.19. Site Improvements (2029) - Unmitigated

3.20. Site Improvements (2029) - Mitigated

4. Operations Emissions Details

4.10. Soil Carbon Accumulation By Vegetation Type

4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated

4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated Eaton Wash LST Analysis Detailed Report, 9/5/2025
3 / 63

4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated

4.10.4. Soil Carbon Accumulation By Vegetation Type - Mitigated

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

4.10.6. Avoided and Sequestered Emissions by Species - Mitigated

5. Activity Data

5.1. Construction Schedule

5.2. Off-Road Equipment

5.2.1. Unmitigated

5.2.2. Mitigated

5.3. Construction Vehicles

5.3.1. Unmitigated

5.3.2. Mitigated

5.4. Vehicles

5.4.1. Construction Vehicle Control Strategies

5.5. Architectural Coatings

5.6. Dust Mitigation

5.6.1. Construction Earthmoving Activities

5.6.2. Construction Earthmoving Control Strategies
Eaton Wash LST Analysis Detailed Report, 9/5/2025
4 / 63

5.7. Construction Paving

5.8. Construction Electricity Consumption and Emissions Factors

5.18. Vegetation

5.18.1. Land Use Change

5.18.1.1. Unmitigated

5.18.1.2. Mitigated

5.18.1. Biomass Cover Type

5.18.1.1. Unmitigated

5.18.1.2. Mitigated

5.18.2. Sequestration

5.18.2.1. Unmitigated

5.18.2.2. Mitigated

6. Climate Risk Detailed Report

6.1. Climate Risk Summary

6.2. Initial Climate Risk Scores

6.3. Adjusted Climate Risk Scores

6.4. Climate Risk Reduction Measures

7. Health and Equity Details
Eaton Wash LST Analysis Detailed Report, 9/5/2025
5 / 63

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
Eaton Wash LST Analysis Detailed Report, 9/5/2025
6 / 63

1. Basic Project Information

1.1. Basic Project Information
Data Field Value
Project Name Eaton Wash LST Analysis
Construction Start Date 7/1/2027
Lead Agency —
Land Use Scale Project/site
Analysis Level for Defaults County
Windspeed (m/s) 0.50
Precipitation (days) 19.6
Location 34.169645957296936, -118.08973754480081
County Los Angeles-South Coast
City Pasadena
Air District South Coast AQMD
Air Basin South Coast
TAZ 4993
EDFZ 7
Electric Utility Pasadena Water & Power
Gas Utility Southern California Gas
App Version 2022.1.1.30

1.2. Land Use Types
Land Use Subtype Size Unit Lot Acreage Building Area (sq ft) Landscape Area (sq ft)
Special Landscape
Area (sq ft)
Population Description
City Park 0.57 Acre 3.85 0.00 56,830 56,830 — —
Parking Lot 8.00 Space 0.07 0.00 0.00 — — —
Eaton Wash LST Analysis Detailed Report, 9/5/2025
7 / 63
Other Non-Asphalt
Surfaces

2.00 1000sqft 0.05 0.00 0.00 — — —

1.3. User-Selected Emission Reduction Measures by Emissions Sector Sector # Measure Title
Construction C-5 Use Advanced Engine Tiers

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. 4.43 3.73 33.3 40.7 0.07 1.26 5.12 6.32 1.16 2.63 3.73 — 7,922 7,922 0.33 0.07 0.05 7,951 Mit. 1.42 1.30 8.95 44.6 0.07 0.28 5.12 5.25 0.27 2.63 2.76 — 7,922 7,922 0.33 0.07 0.05 7,951 %
Reduced
68% 65% 73% -10% — 78% — 17% 77% — 26% — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 2.73 2.30 21.2 23.1 0.04 0.88 3.42 4.26 0.81 1.75 2.52 — 4,251 4,251 0.20 0.05 < 0.005 4,267 Mit. 0.62 0.54 4.22 23.2 0.04 0.11 3.42 3.53 0.11 1.75 1.86 — 4,251 4,251 0.20 0.05 < 0.005 4,267 %
Reduced
77% 76% 80% > -0.5% — 87% — 17% 86% — 26% — — — — — — — Average
Daily
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 1.47 1.24 11.1 13.1 0.02 0.43 0.70 0.98 0.40 0.36 0.62 — 2,513 2,513 0.11 0.02 0.01 2,523 Mit. 0.46 0.42 2.97 14.2 0.02 0.09 0.70 0.74 0.09 0.36 0.39 — 2,513 2,513 0.11 0.02 0.01 2,523 Eaton Wash LST Analysis Detailed Report, 9/5/2025
8 / 63
%
Reduced
69% 66% 73% -8% — 79% — 25% 79% — 37% — — — — — — —
Annual
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 0.27 0.23 2.02 2.38 < 0.005 0.08 0.13 0.18 0.07 0.07 0.11 — 416 416 0.02 < 0.005 < 0.005 418 Mit. 0.08 0.08 0.54 2.58 < 0.005 0.02 0.13 0.13 0.02 0.07 0.07 — 416 416 0.02 < 0.005 < 0.005 418 %
Reduced
69% 66% 73% -8% — 79% — 25% 79% — 37% — — — — — — —

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)
— — — — — — — — — — — — — — — — — —
2027 3.82 3.21 28.9 29.0 0.05 1.20 5.12 6.32 1.11 2.63 3.73 — 5,425 5,425 0.23 0.05 0.03 5,445 2028 4.43 3.73 33.3 40.7 0.07 1.26 0.01 1.27 1.16 < 0.005 1.16 — 7,922 7,922 0.33 0.07 0.05 7,951 Daily -
Winter
(Max)
— — — — — — — — — — — — — — — — — —
2027 2.73 2.30 21.2 23.1 0.04 0.88 3.42 4.26 0.81 1.75 2.52 — 4,249 4,249 0.20 0.05 < 0.005 4,265 2028 2.71 2.28 20.4 20.0 0.04 0.86 < 0.005 0.86 0.79 < 0.005 0.79 — 4,251 4,251 0.18 0.04 < 0.005 4,267 2029 1.09 0.92 8.01 12.5 0.02 0.28 < 0.005 0.29 0.26 < 0.005 0.26 — 1,919 1,919 0.08 0.02 < 0.005 1,926 Average
Daily
— — — — — — — — — — — — — — — — — —
2027 0.88 0.74 6.75 6.97 0.01 0.28 0.70 0.98 0.26 0.36 0.62 — 1,319 1,319 0.06 0.01 0.01 1,324 2028 1.47 1.24 11.1 13.1 0.02 0.43 < 0.005 0.43 0.40 < 0.005 0.40 — 2,513 2,513 0.11 0.02 0.01 2,523 2029 0.19 0.16 1.41 2.20 < 0.005 0.05 < 0.005 0.05 0.05 < 0.005 0.05 — 338 338 0.01 < 0.005 < 0.005 339 Annual — — — — — — — — — — — — — — — — — —
2027 0.16 0.14 1.23 1.27 < 0.005 0.05 0.13 0.18 0.05 0.07 0.11 — 218 218 0.01 < 0.005 < 0.005 219 2028 0.27 0.23 2.02 2.38 < 0.005 0.08 < 0.005 0.08 0.07 < 0.005 0.07 — 416 416 0.02 < 0.005 < 0.005 418 Eaton Wash LST Analysis Detailed Report, 9/5/2025
9 / 63
2029 0.04 0.03 0.26 0.40 < 0.005 0.01 < 0.005 0.01 0.01 < 0.005 0.01 — 56.0 56.0 < 0.005 < 0.005 < 0.005 56.2

2.3. Construction Emissions by Y ear, Mitigated
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)
— — — — — — — — — — — — — — — — — —
2027 0.68 0.66 3.49 29.0 0.05 0.13 5.12 5.25 0.13 2.63 2.76 — 5,425 5,425 0.23 0.05 0.03 5,445 2028 1.42 1.30 8.95 44.6 0.07 0.28 0.01 0.29 0.27 < 0.005 0.27 — 7,922 7,922 0.33 0.07 0.05 7,951 Daily -
Winter
(Max)
— — — — — — — — — — — — — — — — — —
2027 0.59 0.53 4.03 23.2 0.04 0.11 3.42 3.53 0.11 1.75 1.86 — 4,249 4,249 0.20 0.05 < 0.005 4,265 2028 0.62 0.54 4.22 21.5 0.04 0.11 < 0.005 0.11 0.11 < 0.005 0.11 — 4,251 4,251 0.18 0.04 < 0.005 4,267 2029 0.61 0.53 4.18 13.1 0.02 0.11 < 0.005 0.11 0.10 < 0.005 0.10 — 1,919 1,919 0.08 0.02 < 0.005 1,926 Average
Daily
— — — — — — — — — — — — — — — — — —
2027 0.17 0.16 1.06 7.10 0.01 0.03 0.70 0.74 0.03 0.36 0.39 — 1,319 1,319 0.06 0.01 0.01 1,324 2028 0.46 0.42 2.97 14.2 0.02 0.09 < 0.005 0.09 0.09 < 0.005 0.09 — 2,513 2,513 0.11 0.02 0.01 2,523 2029 0.11 0.09 0.74 2.31 < 0.005 0.02 < 0.005 0.02 0.02 < 0.005 0.02 — 338 338 0.01 < 0.005 < 0.005 339 Annual — — — — — — — — — — — — — — — — — —
2027 0.03 0.03 0.19 1.29 < 0.005 0.01 0.13 0.13 0.01 0.07 0.07 — 218 218 0.01 < 0.005 < 0.005 219 2028 0.08 0.08 0.54 2.58 < 0.005 0.02 < 0.005 0.02 0.02 < 0.005 0.02 — 416 416 0.02 < 0.005 < 0.005 418 2029 0.02 0.02 0.13 0.42 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 56.0 56.0 < 0.005 < 0.005 < 0.005 56.2

3. Construction Emissions Details

3.1. Demolition (2027) - Unmitigated
Eaton Wash LST Analysis Detailed Report, 9/5/2025
10 / 63
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

2.94 2.47 21.7 22.5 0.04 1.00 — 1.00 0.92 — 0.92 — 4,140 4,140 0.17 0.03 — 4,154 Demoliti
on
— — — — — — 0.08 0.08 — 0.01 0.01 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.18 0.15 1.31 1.36 < 0.005 0.06 — 0.06 0.06 — 0.06 — 250 250 0.01 < 0.005 — 250 Demoliti
on
— — — — — — < 0.005 < 0.005 — < 0.005 < 0.005 — — — — — — — Onsite
truck

0.00 0.00 0.00 0.00 0.00 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 0.24 0.25 < 0.005 0.01 — 0.01 0.01 — 0.01 — 41.3 41.3 < 0.005 < 0.005 — 41.5 Demoliti
on
— — — — — — < 0.005 < 0.005 — < 0.005 < 0.005 — — — — — — — Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Eaton Wash LST Analysis Detailed Report, 9/5/2025
11 / 63
Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.04 0.04 0.01 0.10 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 4.80 4.80 < 0.005 < 0.005 0.01 5.17 Vendor < 0.005 < 0.005 0.04 0.03 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 7.02 7.02 < 0.005 < 0.005 0.01 7.40 Hauling 0.01 < 0.005 0.06 0.04 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 9.85 9.85 < 0.005 < 0.005 0.01 10.4 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.29 0.29 < 0.005 < 0.005 < 0.005 0.31 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 0.42 0.42 < 0.005 < 0.005 < 0.005 0.45 Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 0.60 0.60 < 0.005 < 0.005 < 0.005 0.63 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.05 0.05 < 0.005 < 0.005 < 0.005 0.05 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 0.07 0.07 < 0.005 < 0.005 < 0.005 0.07 Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 0.10 0.10 < 0.005 < 0.005 < 0.005 0.10

3.2. Demolition (2027) - Mitigated
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

0.44 0.43 2.72 22.9 0.04 0.09 — 0.09 0.09 — 0.09 — 4,140 4,140 0.17 0.03 — 4,154 Eaton Wash LST Analysis Detailed Report, 9/5/2025
12 / 63
———————0.010.01—0.080.08——————Demoliti
on
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.03 0.03 0.16 1.38 < 0.005 0.01 — 0.01 0.01 — 0.01 — 250 250 0.01 < 0.005 — 250 Demoliti
on
— — — — — — < 0.005 < 0.005 — < 0.005 < 0.005 — — — — — — — Onsite
truck

0.00 0.00 0.00 0.00 0.00 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 0.25 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 41.3 41.3 < 0.005 < 0.005 — 41.5 Demoliti
on
— — — — — — < 0.005 < 0.005 — < 0.005 < 0.005 — — — — — — — Onsite
truck

0.00 0.00 0.00 0.00 0.00 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 0.04 0.04 0.01 0.10 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 4.80 4.80 < 0.005 < 0.005 0.01 5.17 Vendor < 0.005 < 0.005 0.04 0.03 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 7.02 7.02 < 0.005 < 0.005 0.01 7.40 Hauling 0.01 < 0.005 0.06 0.04 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 9.85 9.85 < 0.005 < 0.005 0.01 10.4 Eaton Wash LST Analysis Detailed Report, 9/5/2025
13 / 63
——————————————————Daily,
Winter
(Max)
Average
Daily
— — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.29 0.29 < 0.005 < 0.005 < 0.005 0.31 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 0.42 0.42 < 0.005 < 0.005 < 0.005 0.45 Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 0.60 0.60 < 0.005 < 0.005 < 0.005 0.63 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.05 0.05 < 0.005 < 0.005 < 0.005 0.05 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 0.07 0.07 < 0.005 < 0.005 < 0.005 0.07 Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 0.10 0.10 < 0.005 < 0.005 < 0.005 0.10

3.3. Site preparation, clearing and grubbing (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

3.75 3.15 28.8 28.8 0.05 1.20 — 1.20 1.11 — 1.11 — 5,402 5,402 0.22 0.04 — 5,420 Dust
From
Material
Movement
— — — — — — 5.11 5.11 — 2.63 2.63 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 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)
— — — — — — — — — — — — — — — — — —
Eaton Wash LST Analysis Detailed Report, 9/5/2025
14 / 63
Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.22 0.18 1.65 1.66 < 0.005 0.07 — 0.07 0.06 — 0.06 — 311 311 0.01 < 0.005 — 312 Dust
From
Material
Movement
— — — — — — 0.29 0.29 — 0.15 0.15 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 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 0.30 < 0.005 0.01 — 0.01 0.01 — 0.01 — 51.5 51.5 < 0.005 < 0.005 — 51.6 Dust
From
Material
Movement
— — — — — — 0.05 0.05 — 0.03 0.03 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 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 0.06 0.05 0.01 0.15 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 6.86 6.86 < 0.005 < 0.005 0.01 7.38 Vendor < 0.005 < 0.005 0.04 0.03 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 7.02 7.02 < 0.005 < 0.005 0.01 7.40 Hauling 0.01 < 0.005 0.06 0.04 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 9.85 9.85 < 0.005 < 0.005 0.01 10.4 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.39 0.39 < 0.005 < 0.005 < 0.005 0.42 Eaton Wash LST Analysis Detailed Report, 9/5/2025
15 / 63
Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 0.41 0.41 < 0.005 < 0.005 < 0.005 0.43 Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 0.57 0.57 < 0.005 < 0.005 < 0.005 0.60 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.06 0.06 < 0.005 < 0.005 < 0.005 0.07 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 0.07 0.07 < 0.005 < 0.005 < 0.005 0.07 Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 0.09 0.09 < 0.005 < 0.005 < 0.005 0.10

3.4. Site preparation, clearing and grubbing (2027) - Mitigated 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

0.62 0.60 3.38 28.8 0.05 0.13 — 0.13 0.13 — 0.13 — 5,402 5,402 0.22 0.04 — 5,420 Dust
From
Material
Movement
— — — — — — 5.11 5.11 — 2.63 2.63 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.04 0.03 0.19 1.66 < 0.005 0.01 — 0.01 0.01 — 0.01 — 311 311 0.01 < 0.005 — 312 Eaton Wash LST Analysis Detailed Report, 9/5/2025
16 / 63
———————0.150.15—0.290.29——————Dust
From
Material
Movement
Onsite
truck

0.00 0.00 0.00 0.00 0.00 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

0.01 0.01 0.04 0.30 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 51.5 51.5 < 0.005 < 0.005 — 51.6 Dust
From
Material
Movement
— — — — — — 0.05 0.05 — 0.03 0.03 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 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 0.06 0.05 0.01 0.15 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 6.86 6.86 < 0.005 < 0.005 0.01 7.38 Vendor < 0.005 < 0.005 0.04 0.03 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 7.02 7.02 < 0.005 < 0.005 0.01 7.40 Hauling 0.01 < 0.005 0.06 0.04 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 9.85 9.85 < 0.005 < 0.005 0.01 10.4 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.39 0.39 < 0.005 < 0.005 < 0.005 0.42 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 0.41 0.41 < 0.005 < 0.005 < 0.005 0.43 Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 0.57 0.57 < 0.005 < 0.005 < 0.005 0.60 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.06 0.06 < 0.005 < 0.005 < 0.005 0.07 Eaton Wash LST Analysis Detailed Report, 9/5/2025
17 / 63
Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 0.07 0.07 < 0.005 < 0.005 < 0.005 0.07 Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 0.09 0.09 < 0.005 < 0.005 < 0.005 0.10

3.5. Reservoir excavation (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)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

2.60 2.19 20.6 22.5 0.04 0.83 — 0.83 0.77 — 0.77 — 4,119 4,119 0.17 0.03 — 4,133 Dust
From
Material
Movement
— — — — — — 3.41 3.41 — 1.75 1.75 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 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

0.31 0.26 2.43 2.65 < 0.005 0.10 — 0.10 0.09 — 0.09 — 485 485 0.02 < 0.005 — 487 Dust
From
Material
Movement
— — — — — — 0.40 0.40 — 0.21 0.21 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Eaton Wash LST Analysis Detailed Report, 9/5/2025
18 / 63
Annual — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.06 0.05 0.44 0.48 < 0.005 0.02 — 0.02 0.02 — 0.02 — 80.3 80.3 < 0.005 < 0.005 — 80.6 Dust
From
Material
Movement
— — — — — — 0.07 0.07 — 0.04 0.04 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 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 0.05 0.05 0.01 0.16 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 6.06 6.06 < 0.005 < 0.005 < 0.005 6.52 Vendor < 0.005 < 0.005 0.04 0.03 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 7.09 7.09 < 0.005 < 0.005 < 0.005 7.46 Hauling 0.05 0.02 0.58 0.43 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 94.7 94.7 0.03 0.02 < 0.005 100 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.01 0.01 < 0.005 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.72 0.72 < 0.005 < 0.005 < 0.005 0.77 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 0.83 0.83 < 0.005 < 0.005 < 0.005 0.87 Hauling 0.01 < 0.005 0.07 0.05 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 11.1 11.1 < 0.005 < 0.005 < 0.005 11.7 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.12 0.12 < 0.005 < 0.005 < 0.005 0.13 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 0.14 0.14 < 0.005 < 0.005 < 0.005 0.14 Hauling < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 1.83 1.83 < 0.005 < 0.005 < 0.005 1.94

3.6. Reservoir excavation (2027) - Mitigated
Eaton Wash LST Analysis Detailed Report, 9/5/2025
19 / 63
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

0.48 0.46 3.40 22.6 0.04 0.11 — 0.11 0.11 — 0.11 — 4,119 4,119 0.17 0.03 — 4,133 Dust
From
Material
Movement
— — — — — — 3.41 3.41 — 1.75 1.75 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 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

0.06 0.05 0.40 2.66 < 0.005 0.01 — 0.01 0.01 — 0.01 — 485 485 0.02 < 0.005 — 487 Dust
From
Material
Movement
— — — — — — 0.40 0.40 — 0.21 0.21 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 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

0.01 0.01 0.07 0.48 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 80.3 80.3 < 0.005 < 0.005 — 80.6 Eaton Wash LST Analysis Detailed Report, 9/5/2025
20 / 63
———————0.040.04—0.070.07——————Dust
From
Material
Movement
Onsite
truck

0.00 0.00 0.00 0.00 0.00 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 0.05 0.05 0.01 0.16 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 6.06 6.06 < 0.005 < 0.005 < 0.005 6.52 Vendor < 0.005 < 0.005 0.04 0.03 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 7.09 7.09 < 0.005 < 0.005 < 0.005 7.46 Hauling 0.05 0.02 0.58 0.43 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 94.7 94.7 0.03 0.02 < 0.005 100 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.01 0.01 < 0.005 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.72 0.72 < 0.005 < 0.005 < 0.005 0.77 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 0.83 0.83 < 0.005 < 0.005 < 0.005 0.87 Hauling 0.01 < 0.005 0.07 0.05 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 11.1 11.1 < 0.005 < 0.005 < 0.005 11.7 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.12 0.12 < 0.005 < 0.005 < 0.005 0.13 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 0.14 0.14 < 0.005 < 0.005 < 0.005 0.14 Hauling < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 1.83 1.83 < 0.005 < 0.005 < 0.005 1.94

3.7. Reservoir 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 — — — — — — — — — — — — — — — — — —
Eaton Wash LST Analysis Detailed Report, 9/5/2025
21 / 63
——————————————————Daily,
Summer
(Max)
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

2.69 2.26 20.9 19.8 0.04 0.88 — 0.88 0.81 — 0.81 — 4,238 4,238 0.17 0.03 — 4,252 Onsite
truck

0.00 0.00 0.00 0.00 0.00 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

0.16 0.14 1.27 1.20 < 0.005 0.05 — 0.05 0.05 — 0.05 — 257 257 0.01 < 0.005 — 258 Onsite
truck

0.00 0.00 0.00 0.00 0.00 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 0.23 0.22 < 0.005 0.01 — 0.01 0.01 — 0.01 — 42.6 42.6 < 0.005 < 0.005 — 42.7 Onsite
truck

0.00 0.00 0.00 0.00 0.00 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 0.04 0.04 0.01 0.12 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 4.71 4.71 < 0.005 < 0.005 < 0.005 5.07 Vendor < 0.005 < 0.005 0.04 0.03 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 7.09 7.09 < 0.005 < 0.005 < 0.005 7.46 Eaton Wash LST Analysis Detailed Report, 9/5/2025
22 / 63
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 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.29 0.29 < 0.005 < 0.005 < 0.005 0.31 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 0.43 0.43 < 0.005 < 0.005 < 0.005 0.45 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 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.05 0.05 < 0.005 < 0.005 < 0.005 0.05 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 0.07 0.07 < 0.005 < 0.005 < 0.005 0.07 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

3.8. Reservoir construction (2027) - Mitigated
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

0.50 0.47 3.46 21.3 0.04 0.11 — 0.11 0.11 — 0.11 — 4,238 4,238 0.17 0.03 — 4,252 Onsite
truck

0.00 0.00 0.00 0.00 0.00 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 0.03 0.21 1.30 < 0.005 0.01 — 0.01 0.01 — 0.01 — 257 257 0.01 < 0.005 — 258 Eaton Wash LST Analysis Detailed Report, 9/5/2025
23 / 63
Onsite
truck

0.00 0.00 0.00 0.00 0.00 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

0.01 0.01 0.04 0.24 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 42.6 42.6 < 0.005 < 0.005 — 42.7 Onsite
truck

0.00 0.00 0.00 0.00 0.00 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 0.04 0.04 0.01 0.12 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 4.71 4.71 < 0.005 < 0.005 < 0.005 5.07 Vendor < 0.005 < 0.005 0.04 0.03 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 7.09 7.09 < 0.005 < 0.005 < 0.005 7.46 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 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.29 0.29 < 0.005 < 0.005 < 0.005 0.31 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 0.43 0.43 < 0.005 < 0.005 < 0.005 0.45 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 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.05 0.05 < 0.005 < 0.005 < 0.005 0.05 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 0.07 0.07 < 0.005 < 0.005 < 0.005 0.07 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. Reservoir 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 Eaton Wash LST Analysis Detailed Report, 9/5/2025
24 / 63
Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

2.67 2.24 20.3 19.9 0.04 0.86 — 0.86 0.79 — 0.79 — 4,240 4,240 0.17 0.03 — 4,254 Onsite
truck

0.00 0.00 0.00 0.00 0.00 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

0.47 0.40 3.62 3.54 0.01 0.15 — 0.15 0.14 — 0.14 — 755 755 0.03 0.01 — 758 Onsite
truck

0.00 0.00 0.00 0.00 0.00 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

0.09 0.07 0.66 0.65 < 0.005 0.03 — 0.03 0.03 — 0.03 — 125 125 0.01 < 0.005 — 125 Onsite
truck

0.00 0.00 0.00 0.00 0.00 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 0.04 0.04 0.01 0.11 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 4.62 4.62 < 0.005 < 0.005 < 0.005 4.97 Eaton Wash LST Analysis Detailed Report, 9/5/2025
25 / 63
Vendor < 0.005 < 0.005 0.04 0.03 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 6.97 6.97 < 0.005 < 0.005 < 0.005 7.34 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 < 0.005 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.83 0.83 < 0.005 < 0.005 < 0.005 0.89 Vendor < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 1.23 1.23 < 0.005 < 0.005 < 0.005 1.30 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 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.14 0.14 < 0.005 < 0.005 < 0.005 0.15 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 0.20 0.20 < 0.005 < 0.005 < 0.005 0.22 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.10. Reservoir construction (2028) - Mitigated
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

0.49 0.47 3.42 21.4 0.04 0.11 — 0.11 0.11 — 0.11 — 4,240 4,240 0.17 0.03 — 4,254 Onsite
truck

0.00 0.00 0.00 0.00 0.00 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
— — — — — — — — — — — — — — — — — —
Eaton Wash LST Analysis Detailed Report, 9/5/2025
26 / 63
758—0.010.03755755—0.02—0.020.02—0.020.013.800.610.080.09Off-Roa d
Equipm
Onsite
truck

0.00 0.00 0.00 0.00 0.00 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

0.02 0.02 0.11 0.69 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 125 125 0.01 < 0.005 — 125 Onsite
truck

0.00 0.00 0.00 0.00 0.00 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 0.04 0.04 0.01 0.11 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 4.62 4.62 < 0.005 < 0.005 < 0.005 4.97 Vendor < 0.005 < 0.005 0.04 0.03 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 6.97 6.97 < 0.005 < 0.005 < 0.005 7.34 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 < 0.005 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.83 0.83 < 0.005 < 0.005 < 0.005 0.89 Vendor < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 1.23 1.23 < 0.005 < 0.005 < 0.005 1.30 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 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.14 0.14 < 0.005 < 0.005 < 0.005 0.15 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 0.20 0.20 < 0.005 < 0.005 < 0.005 0.22 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 Eaton Wash LST Analysis Detailed Report, 9/5/2025
27 / 63

3.11. Installation of pipes, pump etc. (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

0.93 0.78 6.99 8.88 0.02 0.24 — 0.24 0.22 — 0.22 — 1,896 1,896 0.08 0.02 — 1,902 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.17 0.14 1.24 1.58 < 0.005 0.04 — 0.04 0.04 — 0.04 — 338 338 0.01 < 0.005 — 339 Onsite
truck

0.00 0.00 0.00 0.00 0.00 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 0.23 0.29 < 0.005 0.01 — 0.01 0.01 — 0.01 — 55.9 55.9 < 0.005 < 0.005 — 56.1 Onsite
truck

0.00 0.00 0.00 0.00 0.00 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)
— — — — — — — — — — — — — — — — — —
Eaton Wash LST Analysis Detailed Report, 9/5/2025
28 / 63
Worker 0.04 0.04 0.01 0.10 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 4.71 4.71 < 0.005 < 0.005 0.01 5.06 Vendor < 0.005 < 0.005 0.04 0.03 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 6.90 6.90 < 0.005 < 0.005 0.01 7.25 Hauling 0.01 < 0.005 0.06 0.04 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 9.68 9.68 < 0.005 < 0.005 0.01 10.2 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.01 0.01 < 0.005 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.83 0.83 < 0.005 < 0.005 < 0.005 0.89 Vendor < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 1.23 1.23 < 0.005 < 0.005 < 0.005 1.30 Hauling < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 1.73 1.73 < 0.005 < 0.005 < 0.005 1.83 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.14 0.14 < 0.005 < 0.005 < 0.005 0.15 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 0.20 0.20 < 0.005 < 0.005 < 0.005 0.22 Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 0.29 0.29 < 0.005 < 0.005 < 0.005 0.30

3.12. Installation of pipes, pump etc. (2028) - Mitigated 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

0.61 0.53 4.47 10.7 0.02 0.14 — 0.14 0.13 — 0.13 — 1,896 1,896 0.08 0.02 — 1,902 Onsite
truck

0.00 0.00 0.00 0.00 0.00 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)
— — — — — — — — — — — — — — — — — —
Eaton Wash LST Analysis Detailed Report, 9/5/2025
29 / 63
Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.11 0.09 0.80 1.91 < 0.005 0.02 — 0.02 0.02 — 0.02 — 338 338 0.01 < 0.005 — 339 Onsite
truck

0.00 0.00 0.00 0.00 0.00 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

0.02 0.02 0.15 0.35 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 55.9 55.9 < 0.005 < 0.005 — 56.1 Onsite
truck

0.00 0.00 0.00 0.00 0.00 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 0.04 0.04 0.01 0.10 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 4.71 4.71 < 0.005 < 0.005 0.01 5.06 Vendor < 0.005 < 0.005 0.04 0.03 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 6.90 6.90 < 0.005 < 0.005 0.01 7.25 Hauling 0.01 < 0.005 0.06 0.04 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 9.68 9.68 < 0.005 < 0.005 0.01 10.2 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.01 0.01 < 0.005 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.83 0.83 < 0.005 < 0.005 < 0.005 0.89 Vendor < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 1.23 1.23 < 0.005 < 0.005 < 0.005 1.30 Hauling < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 1.73 1.73 < 0.005 < 0.005 < 0.005 1.83 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.14 0.14 < 0.005 < 0.005 < 0.005 0.15 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 0.20 0.20 < 0.005 < 0.005 < 0.005 0.22 Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 0.29 0.29 < 0.005 < 0.005 < 0.005 0.30 Eaton Wash LST Analysis Detailed Report, 9/5/2025
30 / 63

3.13. Installation of outlet line etc. (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

2.59 2.17 20.2 22.5 0.04 0.81 — 0.81 0.75 — 0.75 — 4,120 4,120 0.17 0.03 — 4,134 Architect
ural
Coating
s

0.02 0.02 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.46 0.39 3.60 4.02 0.01 0.14 — 0.14 0.13 — 0.13 — 734 734 0.03 0.01 — 736 Architect
ural
Coating
s
< 0.005 < 0.005 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 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 — — — — — — — — — — — — — — — — — —
Eaton Wash LST Analysis Detailed Report, 9/5/2025
31 / 63
122—< 0.005< 0.005121121—0.02—0.020.03—0.03< 0.0050.730.660.070.08Off-Roa d
Equipm
ent
Architect
ural
Coating
s
< 0.005 < 0.005 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 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 0.05 0.05 0.01 0.12 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 6.06 6.06 < 0.005 < 0.005 0.01 6.51 Vendor < 0.005 < 0.005 0.04 0.03 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 6.90 6.90 < 0.005 < 0.005 0.01 7.25 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.01 0.01 < 0.005 0.03 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 1.06 1.06 < 0.005 < 0.005 < 0.005 1.15 Vendor < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 1.23 1.23 < 0.005 < 0.005 < 0.005 1.30 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 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.18 0.18 < 0.005 < 0.005 < 0.005 0.19 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 0.20 0.20 < 0.005 < 0.005 < 0.005 0.22 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.14. Installation of outlet line etc. (2028) - Mitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Eaton Wash LST Analysis Detailed Report, 9/5/2025
32 / 63
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

0.48 0.46 3.36 22.6 0.04 0.11 — 0.11 0.10 — 0.10 — 4,120 4,120 0.17 0.03 — 4,134 Architect
ural
Coating
s

0.02 0.02 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.09 0.08 0.60 4.02 0.01 0.02 — 0.02 0.02 — 0.02 — 734 734 0.03 0.01 — 736 Architect
ural
Coating
s
< 0.005 < 0.005 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 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

0.02 0.01 0.11 0.73 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 121 121 < 0.005 < 0.005 — 122 Eaton Wash LST Analysis Detailed Report, 9/5/2025
33 / 63
————————————————< 0.005< 0.005Architect
ural
Coating
Onsite
truck

0.00 0.00 0.00 0.00 0.00 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 0.05 0.05 0.01 0.12 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 6.06 6.06 < 0.005 < 0.005 0.01 6.51 Vendor < 0.005 < 0.005 0.04 0.03 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 6.90 6.90 < 0.005 < 0.005 0.01 7.25 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.01 0.01 < 0.005 0.03 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 1.06 1.06 < 0.005 < 0.005 < 0.005 1.15 Vendor < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 1.23 1.23 < 0.005 < 0.005 < 0.005 1.30 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 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.18 0.18 < 0.005 < 0.005 < 0.005 0.19 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 0.20 0.20 < 0.005 < 0.005 < 0.005 0.22 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. Pedestrian Bridge 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)
— — — — — — — — — — — — — — — — — —
Eaton Wash LST Analysis Detailed Report, 9/5/2025
34 / 63
Off-Roa
Equipment

0.76 0.64 5.88 8.80 0.02 0.20 — 0.20 0.19 — 0.19 — 1,862 1,862 0.08 0.02 — 1,868 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.13 0.11 1.05 1.57 < 0.005 0.04 — 0.04 0.03 — 0.03 — 332 332 0.01 < 0.005 — 333 Onsite
truck

0.00 0.00 0.00 0.00 0.00 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

0.02 0.02 0.19 0.29 < 0.005 0.01 — 0.01 0.01 — 0.01 — 54.9 54.9 < 0.005 < 0.005 — 55.1 Onsite
truck

0.00 0.00 0.00 0.00 0.00 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 0.03 0.03 0.01 0.07 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 3.37 3.37 < 0.005 < 0.005 0.01 3.62 Vendor < 0.005 < 0.005 0.04 0.03 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 6.90 6.90 < 0.005 < 0.005 0.01 7.25 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.59 0.59 < 0.005 < 0.005 < 0.005 0.64 Eaton Wash LST Analysis Detailed Report, 9/5/2025
35 / 63
Vendor < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 1.23 1.23 < 0.005 < 0.005 < 0.005 1.30 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 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.10 0.10 < 0.005 < 0.005 < 0.005 0.11 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 0.20 0.20 < 0.005 < 0.005 < 0.005 0.22 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

3.16. Pedestrian Bridge Construction (2028) - Mitigated 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

0.18 0.18 0.92 11.0 0.02 0.04 — 0.04 0.04 — 0.04 — 1,862 1,862 0.08 0.02 — 1,868 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.03 0.03 0.16 1.95 < 0.005 0.01 — 0.01 0.01 — 0.01 — 332 332 0.01 < 0.005 — 333 Onsite
truck

0.00 0.00 0.00 0.00 0.00 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 — — — — — — — — — — — — — — — — — —
Eaton Wash LST Analysis Detailed Report, 9/5/2025
36 / 63

55.1—< 0.005< 0.00554.954.9—< 0.005—< 0.005< 0.005—< 0.005< 0.0050.360.030.010.01Off-Roa d
Onsite
truck

0.00 0.00 0.00 0.00 0.00 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 0.03 0.03 0.01 0.07 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 3.37 3.37 < 0.005 < 0.005 0.01 3.62 Vendor < 0.005 < 0.005 0.04 0.03 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 6.90 6.90 < 0.005 < 0.005 0.01 7.25 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.59 0.59 < 0.005 < 0.005 < 0.005 0.64 Vendor < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 1.23 1.23 < 0.005 < 0.005 < 0.005 1.30 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 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.10 0.10 < 0.005 < 0.005 < 0.005 0.11 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 0.20 0.20 < 0.005 < 0.005 < 0.005 0.22 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

3.17. Site Improvements (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)
— — — — — — — — — — — — — — — — — —
Eaton Wash LST Analysis Detailed Report, 9/5/2025
37 / 63
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

1.08 0.90 8.28 12.3 0.02 0.31 — 0.31 0.28 — 0.28 — 1,907 1,907 0.08 0.02 — 1,913 Paving < 0.005 < 0.005 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 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 1.49 2.22 < 0.005 0.06 — 0.06 0.05 — 0.05 — 343 343 0.01 < 0.005 — 344 Paving < 0.005 < 0.005 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 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 0.27 0.41 < 0.005 0.01 — 0.01 0.01 — 0.01 — 56.8 56.8 < 0.005 < 0.005 — 57.0 Paving < 0.005 < 0.005 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 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 0.05 0.05 0.01 0.15 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 5.94 5.94 < 0.005 < 0.005 < 0.005 6.39 Eaton Wash LST Analysis Detailed Report, 9/5/2025
38 / 63
Vendor < 0.005 < 0.005 0.04 0.03 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 6.97 6.97 < 0.005 < 0.005 < 0.005 7.34 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 < 0.005 0.03 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 1.08 1.08 < 0.005 < 0.005 < 0.005 1.16 Vendor < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 1.25 1.25 < 0.005 < 0.005 < 0.005 1.31 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 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.18 0.18 < 0.005 < 0.005 < 0.005 0.19 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 0.21 0.21 < 0.005 < 0.005 < 0.005 0.22 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

3.18. Site Improvements (2028) - Mitigated
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

0.57 0.49 4.17 13.0 0.02 0.11 — 0.11 0.10 — 0.10 — 1,907 1,907 0.08 0.02 — 1,913 Paving < 0.005 < 0.005 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 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
— — — — — — — — — — — — — — — — — —
Eaton Wash LST Analysis Detailed Report, 9/5/2025
39 / 63
344—< 0.0050.01343343—0.02—0.020.02—0.02< 0.0052.340.750.090.10Off-Roa d
Paving < 0.005 < 0.005 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 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

0.02 0.02 0.14 0.43 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 56.8 56.8 < 0.005 < 0.005 — 57.0 Paving < 0.005 < 0.005 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 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 0.05 0.05 0.01 0.15 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 5.94 5.94 < 0.005 < 0.005 < 0.005 6.39 Vendor < 0.005 < 0.005 0.04 0.03 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 6.97 6.97 < 0.005 < 0.005 < 0.005 7.34 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 < 0.005 0.03 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 1.08 1.08 < 0.005 < 0.005 < 0.005 1.16 Vendor < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 1.25 1.25 < 0.005 < 0.005 < 0.005 1.31 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 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.18 0.18 < 0.005 < 0.005 < 0.005 0.19 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 0.21 0.21 < 0.005 < 0.005 < 0.005 0.22 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 Eaton Wash LST Analysis Detailed Report, 9/5/2025
40 / 63

3.19. Site Improvements (2029) - 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

1.04 0.87 7.96 12.3 0.02 0.28 — 0.28 0.26 — 0.26 — 1,906 1,906 0.08 0.02 — 1,913 Paving < 0.005 < 0.005 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 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

0.18 0.15 1.40 2.17 < 0.005 0.05 — 0.05 0.05 — 0.05 — 336 336 0.01 < 0.005 — 337 Paving < 0.005 < 0.005 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 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 0.26 0.40 < 0.005 0.01 — 0.01 0.01 — 0.01 — 55.6 55.6 < 0.005 < 0.005 — 55.8 Paving < 0.005 < 0.005 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Eaton Wash LST Analysis Detailed Report, 9/5/2025
41 / 63
Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.05 0.04 0.01 0.14 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 5.83 5.83 < 0.005 < 0.005 < 0.005 6.28 Vendor < 0.005 < 0.005 0.04 0.03 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 6.85 6.85 < 0.005 < 0.005 < 0.005 7.21 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 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.01 0.01 < 0.005 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 1.03 1.03 < 0.005 < 0.005 < 0.005 1.11 Vendor < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 1.20 1.20 < 0.005 < 0.005 < 0.005 1.26 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 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.17 0.17 < 0.005 < 0.005 < 0.005 0.18 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 0.20 0.20 < 0.005 < 0.005 < 0.005 0.21 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

3.20. Site Improvements (2029) - Mitigated
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)
— — — — — — — — — — — — — — — — — —
Eaton Wash LST Analysis Detailed Report, 9/5/2025
42 / 63
1,913—0.020.081,9061,906—0.10—0.100.11—0.110.0213.04.130.480.56Off-Roa d
Equipm
Paving < 0.005 < 0.005 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 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

0.10 0.08 0.73 2.28 < 0.005 0.02 — 0.02 0.02 — 0.02 — 336 336 0.01 < 0.005 — 337 Paving < 0.005 < 0.005 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 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

0.02 0.02 0.13 0.42 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 55.6 55.6 < 0.005 < 0.005 — 55.8 Paving < 0.005 < 0.005 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 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 0.05 0.04 0.01 0.14 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 5.83 5.83 < 0.005 < 0.005 < 0.005 6.28 Vendor < 0.005 < 0.005 0.04 0.03 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 6.85 6.85 < 0.005 < 0.005 < 0.005 7.21 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 Average
Daily
— — — — — — — — — — — — — — — — — —
Eaton Wash LST Analysis Detailed Report, 9/5/2025
43 / 63
Worker 0.01 0.01 < 0.005 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 1.03 1.03 < 0.005 < 0.005 < 0.005 1.11 Vendor < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 1.20 1.20 < 0.005 < 0.005 < 0.005 1.26 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 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.17 0.17 < 0.005 < 0.005 < 0.005 0.18 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 0.20 0.20 < 0.005 < 0.005 < 0.005 0.21 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

4. Operations Emissions Details

4.10. Soil Carbon Accumulation By Vegetation Type

4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) 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 — — — — — — — — — — — — — — — — — —
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) Eaton Wash LST Analysis Detailed Report, 9/5/2025
44 / 63
CO2eRN2OCH4CO2TNBCO2BCO2PM2.5TPM2.5DPM2.5EPM10TPM10DPM10ESO2CONOxROGTOGLand Use
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) 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
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
— — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — — — —
Eaton Wash LST Analysis Detailed Report, 9/5/2025
45 / 63
Subtotal — — — — — — — — — — — — — — — — — —
Sequest
ered
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Remove
d
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
— — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Sequest
ered
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Remove
d
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
— — — — — — — — — — — — — — — — — — —

4.10.4. Soil Carbon Accumulation By Vegetation Type - Mitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) 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 — — — — — — — — — — — — — — — — — —
Eaton Wash LST Analysis Detailed Report, 9/5/2025
46 / 63
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.10.5. Above and Belowground Carbon Accumulation by Land Use Type - Mitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) 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 — — — — — — — — — — — — — — — — — —

4.10.6. Avoided and Sequestered Emissions by Species - Mitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) 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
— — — — — — — — — — — — — — — — — —
Eaton Wash LST Analysis Detailed Report, 9/5/2025
47 / 63
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 Demolition Demolition 7/1/2027 7/31/2027 5.00 22.0 —
Eaton Wash LST Analysis Detailed Report, 9/5/2025
48 / 63
Site preparation, clearing
and grubbing
Site Preparation 8/1/2027 8/30/2027 5.00 21.0 —
Reservoir excavation Grading 10/1/2027 11/30/2027 5.00 43.0 — Reservoir construction Building Construction 12/1/2027 3/31/2028 5.00 88.0 — Installation of pipes, pump
etc.

Building Construction 5/1/2028 7/30/2028 5.00 65.0 —
Installation of outlet line
etc.

Building Construction 5/1/2028 7/30/2028 5.00 65.0 —
Pedestrian Bridge
Construction
Building Construction 7/1/2028 9/30/2028 5.00 65.0 —
Site Improvements Paving 10/1/2028 3/31/2029 5.00 130 —

5.2. Off-Road Equipment

5.2.1. Unmitigated
Phase Name Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor Demolition Rubber Tired Dozers Diesel Average 2.00 8.00 367 0.40 Demolition Skid Steer Loaders Diesel Average 1.00 8.00 71.0 0.37 Demolition Graders Diesel Average 2.00 8.00 148 0.41
Site preparation,
clearing and grubbing
Rubber Tired Dozers Diesel Average 3.00 8.00 367 0.40
Site preparation,
clearing and grubbing
Generator Sets Diesel Average 1.00 8.00 14.0 0.74
Site preparation,
clearing and grubbing
Tractors/Loaders/Back
hoes
Diesel Average 4.00 8.00 84.0 0.37
Reservoir excavation Rubber Tired Dozers Diesel Average 2.00 8.00 367 0.40 Reservoir excavation Skid Steer Loaders Diesel Average 2.00 8.00 71.0 0.37 Reservoir excavation Tractors/Loaders/Back
hoes
Diesel Average 3.00 8.00 84.0 0.37
Reservoir construction Cranes Diesel Average 1.00 8.00 367 0.29 Reservoir construction Rubber Tired Dozers Diesel Average 2.00 8.00 367 0.40 Eaton Wash LST Analysis Detailed Report, 9/5/2025
49 / 63
Reservoir construction Skid Steer Loaders Diesel Average 2.00 8.00 71.0 0.37 Installation of pipes,
pump etc.

Cranes Diesel Average 1.00 8.00 367 0.29
Installation of pipes,
pump etc.

Trenchers Diesel Average 2.00 8.00 40.0 0.50
Installation of pipes,
pump etc.

Skid Steer Loaders Diesel Average 2.00 8.00 71.0 0.37
Installation of outlet
line etc.

Rubber Tired Dozers Diesel Average 2.00 8.00 367 0.40
Installation of outlet
line etc.

Skid Steer Loaders Diesel Average 2.00 8.00 71.0 0.37
Installation of outlet
line etc.

Tractors/Loaders/Back
hoes
Diesel Average 3.00 8.00 84.0 0.37
Pedestrian Bridge
Construction
Tractors/Loaders/Back
hoes
Diesel Average 3.00 8.00 84.0 0.37
Pedestrian Bridge
Construction
Cranes Diesel Average 1.00 8.00 367 0.29
Site Improvements Graders Diesel Average 1.00 8.00 148 0.41 Site Improvements Skid Steer Loaders Diesel Average 1.00 8.00 71.0 0.37 Site Improvements Pavers Diesel Average 1.00 8.00 81.0 0.42 Site Improvements Paving Equipment Diesel Average 1.00 8.00 89.0 0.36 Site Improvements Rollers Diesel Average 1.00 8.00 36.0 0.38 Site Improvements Cement and Mortar
Mixers
Diesel Average 1.00 8.00 10.0 0.56
Site Improvements Aerial Lifts Diesel Average 1.00 8.00 46.0 0.31 Site Improvements Air Compressors Diesel Average 1.00 6.00 37.0 0.48

5.2.2. Mitigated
Phase Name Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor Demolition Rubber Tired Dozers Diesel Tier 4 Final 2.00 8.00 367 0.40 Demolition Skid Steer Loaders Diesel Average 1.00 8.00 71.0 0.37 Eaton Wash LST Analysis Detailed Report, 9/5/2025
50 / 63
Demolition Graders Diesel Tier 4 Final 2.00 8.00 148 0.41 Site preparation,
clearing and grubbing
Rubber Tired Dozers Diesel Tier 4 Final 3.00 8.00 367 0.40 Site preparation,
clearing and grubbing
Generator Sets Diesel Average 1.00 8.00 14.0 0.74
Site preparation,
clearing and grubbing
Tractors/Loaders/Back
hoes
Diesel Tier 4 Final 4.00 8.00 84.0 0.37
Reservoir excavation Rubber Tired Dozers Diesel Tier 4 Final 2.00 8.00 367 0.40 Reservoir excavation Skid Steer Loaders Diesel Average 2.00 8.00 71.0 0.37 Reservoir excavation Tractors/Loaders/Back
hoes
Diesel Tier 4 Final 3.00 8.00 84.0 0.37
Reservoir construction Cranes Diesel Tier 4 Final 1.00 8.00 367 0.29 Reservoir construction Rubber Tired Dozers Diesel Tier 4 Final 2.00 8.00 367 0.40 Reservoir construction Skid Steer Loaders Diesel Average 2.00 8.00 71.0 0.37 Installation of pipes,
pump etc.

Cranes Diesel Tier 4 Final 1.00 8.00 367 0.29
Installation of pipes,
pump etc.

Trenchers Diesel Average 2.00 8.00 40.0 0.50
Installation of pipes,
pump etc.

Skid Steer Loaders Diesel Average 2.00 8.00 71.0 0.37
Installation of outlet
line etc.

Rubber Tired Dozers Diesel Tier 4 Final 2.00 8.00 367 0.40 Installation of outlet
line etc.

Skid Steer Loaders Diesel Average 2.00 8.00 71.0 0.37
Installation of outlet
line etc.

Tractors/Loaders/Back
hoes
Diesel Tier 4 Final 3.00 8.00 84.0 0.37
Pedestrian Bridge
Construction
Tractors/Loaders/Back
hoes
Diesel Tier 4 Final 3.00 8.00 84.0 0.37
Pedestrian Bridge
Construction
Cranes Diesel Tier 4 Final 1.00 8.00 367 0.29
Site Improvements Graders Diesel Tier 4 Final 1.00 8.00 148 0.41 Site Improvements Skid Steer Loaders Diesel Average 1.00 8.00 71.0 0.37 Site Improvements Pavers Diesel Tier 4 Final 1.00 8.00 81.0 0.42 Eaton Wash LST Analysis Detailed Report, 9/5/2025
51 / 63
Site Improvements Paving Equipment Diesel Tier 4 Final 1.00 8.00 89.0 0.36 Site Improvements Rollers Diesel Average 1.00 8.00 36.0 0.38 Site Improvements Cement and Mortar
Mixers
Diesel Average 1.00 8.00 10.0 0.56
Site Improvements Aerial Lifts Diesel Average 1.00 8.00 46.0 0.31 Site Improvements Air Compressors Diesel Average 1.00 6.00 37.0 0.48

5.3. Construction Vehicles

5.3.1. Unmitigated
Phase Name Trip Type One-Way Trips per Day Miles per Trip Vehicle Mix Demolition — — — —
Demolition Worker 14.0 0.25 LDA,LDT1,LDT2
Demolition Vendor 4.00 0.25 HHDT,MHDT
Demolition Hauling 4.00 0.25 HHDT
Demolition Onsite truck — — HHDT
Site preparation, clearing and
grubbing
— — — —
Site preparation, clearing and
grubbing
Worker 20.0 0.25 LDA,LDT1,LDT2
Site preparation, clearing and
grubbing
Vendor 4.00 0.25 HHDT,MHDT
Site preparation, clearing and
grubbing
Hauling 4.00 0.25 HHDT
Site preparation, clearing and
grubbing
Onsite truck — — HHDT
Reservoir excavation — — — —
Reservoir excavation Worker 18.0 0.25 LDA,LDT1,LDT2
Reservoir excavation Vendor 4.00 0.25 HHDT,MHDT
Reservoir excavation Hauling 38.0 0.25 HHDT
Eaton Wash LST Analysis Detailed Report, 9/5/2025
52 / 63
Reservoir excavation Onsite truck — — HHDT
Reservoir construction — — — —
Reservoir construction Worker 14.0 0.25 LDA,LDT1,LDT2
Reservoir construction Vendor 4.00 0.25 HHDT,MHDT
Reservoir construction Hauling 0.00 0.25 HHDT
Reservoir construction Onsite truck — — HHDT
Installation of pipes, pump etc. — — — —
Installation of pipes, pump etc. Worker 14.0 0.25 LDA,LDT1,LDT2 Installation of pipes, pump etc. Vendor 4.00 0.25 HHDT,MHDT Installation of pipes, pump etc. Hauling 4.00 0.25 HHDT Installation of pipes, pump etc. Onsite truck — — HHDT
Installation of outlet line etc. — — — —
Installation of outlet line etc. Worker 18.0 0.25 LDA,LDT1,LDT2 Installation of outlet line etc. Vendor 4.00 0.25 HHDT,MHDT Installation of outlet line etc. Hauling 0.00 0.25 HHDT Installation of outlet line etc. Onsite truck — — HHDT
Pedestrian Bridge Construction — — — —
Pedestrian Bridge Construction Worker 10.0 0.25 LDA,LDT1,LDT2 Pedestrian Bridge Construction Vendor 4.00 0.25 HHDT,MHDT Pedestrian Bridge Construction Hauling 0.00 0.25 HHDT
Pedestrian Bridge Construction Onsite truck — — HHDT
Site Improvements — — — —
Site Improvements Worker 18.0 0.25 LDA,LDT1,LDT2
Site Improvements Vendor 4.00 0.25 HHDT,MHDT
Site Improvements Hauling 0.00 0.25 HHDT
Site Improvements Onsite truck — — HHDT

5.3.2. Mitigated
Eaton Wash LST Analysis Detailed Report, 9/5/2025
53 / 63
Phase Name Trip Type One-Way Trips per Day Miles per Trip Vehicle Mix Demolition — — — —
Demolition Worker 14.0 0.25 LDA,LDT1,LDT2
Demolition Vendor 4.00 0.25 HHDT,MHDT
Demolition Hauling 4.00 0.25 HHDT
Demolition Onsite truck — — HHDT
Site preparation, clearing and
grubbing
— — — —
Site preparation, clearing and
grubbing
Worker 20.0 0.25 LDA,LDT1,LDT2
Site preparation, clearing and
grubbing
Vendor 4.00 0.25 HHDT,MHDT
Site preparation, clearing and
grubbing
Hauling 4.00 0.25 HHDT
Site preparation, clearing and
grubbing
Onsite truck — — HHDT
Reservoir excavation — — — —
Reservoir excavation Worker 18.0 0.25 LDA,LDT1,LDT2
Reservoir excavation Vendor 4.00 0.25 HHDT,MHDT
Reservoir excavation Hauling 38.0 0.25 HHDT
Reservoir excavation Onsite truck — — HHDT
Reservoir construction — — — —
Reservoir construction Worker 14.0 0.25 LDA,LDT1,LDT2
Reservoir construction Vendor 4.00 0.25 HHDT,MHDT
Reservoir construction Hauling 0.00 0.25 HHDT
Reservoir construction Onsite truck — — HHDT
Installation of pipes, pump etc. — — — —
Installation of pipes, pump etc. Worker 14.0 0.25 LDA,LDT1,LDT2 Installation of pipes, pump etc. Vendor 4.00 0.25 HHDT,MHDT Installation of pipes, pump etc. Hauling 4.00 0.25 HHDT Eaton Wash LST Analysis Detailed Report, 9/5/2025
54 / 63
Installation of pipes, pump etc. Onsite truck — — HHDT
Installation of outlet line etc. — — — —
Installation of outlet line etc. Worker 18.0 0.25 LDA,LDT1,LDT2 Installation of outlet line etc. Vendor 4.00 0.25 HHDT,MHDT Installation of outlet line etc. Hauling 0.00 0.25 HHDT Installation of outlet line etc. Onsite truck — — HHDT
Pedestrian Bridge Construction — — — —
Pedestrian Bridge Construction Worker 10.0 0.25 LDA,LDT1,LDT2 Pedestrian Bridge Construction Vendor 4.00 0.25 HHDT,MHDT Pedestrian Bridge Construction Hauling 0.00 0.25 HHDT
Pedestrian Bridge Construction Onsite truck — — HHDT
Site Improvements — — — —
Site Improvements Worker 18.0 0.25 LDA,LDT1,LDT2
Site Improvements Vendor 4.00 0.25 HHDT,MHDT
Site Improvements Hauling 0.00 0.25 HHDT
Site Improvements Onsite truck — — HHDT

5.4. Vehicles

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

5.5. Architectural Coatings
Phase Name Residential Interior Area
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)
Installation of outlet line etc. 0.00 0.00 0.00 0.00 308

5.6. Dust Mitigation
Eaton Wash LST Analysis Detailed Report, 9/5/2025
55 / 63

5.6.1. Construction Earthmoving Activities
Phase Name Material Imported (Cubic
Y ards)
Material Exported (Cubic
Y ards)
Acres Graded (acres) Material Demolished (Ton of
Debris)
Acres Paved (acres)
Demolition 0.00 0.00 0.00 135 —
Site preparation, clearing and
grubbing
— — 31.5 0.00 —
Reservoir excavation — 12,510 43.0 0.00 —
Site Improvements 0.00 0.00 0.00 0.00 0.12

5.6.2. Construction Earthmoving Control Strategies
Control Strategies Applied Frequency (per day) PM10 Reduction PM2.5 Reduction Water Exposed Area 3 74% 74%
Water Demolished Area 2 36% 36%

5.7. Construction Paving
Land Use Area Paved (acres) % Asphalt
City Park 0.00 0%
Parking Lot 0.07 100%
Other Non-Asphalt Surfaces 0.05 0%

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
2028 0.00 1,028 0.03 < 0.005
2029 0.00 1,028 0.03 < 0.005
2027 0.00 1,028 0.03 < 0.005
Eaton Wash LST Analysis Detailed Report, 9/5/2025
56 / 63

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

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

5.18.1. Biomass Cover Type

5.18.1.1. Unmitigated
Biomass Cover Type Initial Acres Final Acres

5.18.1.2. Mitigated
Biomass Cover Type Initial Acres Final Acres

5.18.2. Sequestration

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

5.18.2.2. Mitigated
Tree Type Number Electricity Saved (kWh/year) Natural Gas Saved (btu/year) Eaton Wash LST Analysis Detailed Report, 9/5/2025
57 / 63

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 20.8 annual days of extreme heat Extreme Precipitation 7.85 annual days with precipitation above 20 mm Sea Level Rise — meters of inundation depth
Wildfire 6.20 annual hectares burned
Temperature and Extreme Heat data are for grid cell in which your project are located. The projection is based on the 98th historical percentile of daily maximum/minimum temperatures from observed historical data (32 climate model ensemble from Cal-Adapt, 2040–2059 average under RCP 8.5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.

Extreme Precipitation data are for the grid cell in which your project are located. The threshold of 20 mm is equivalent to about ¾ an inch of rain, which would be light to moderate rainfall if received over a full day or heavy rain if received over a period of 2 to 4 hours. Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.

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

6.2. Initial Climate Risk Scores
Climate Hazard Exposure Score Sensitivity Score Adaptive Capacity Score Vulnerability Score Temperature and Extreme Heat N/A N/A N/A N/A
Extreme Precipitation N/A N/A N/A N/A
Sea Level Rise N/A N/A N/A N/A
Wildfire N/A N/A N/A N/A
Flooding N/A N/A N/A N/A
Drought N/A N/A N/A N/A
Snowpack Reduction N/A N/A N/A N/A
Air Quality Degradation N/A N/A N/A N/A
Eaton Wash LST Analysis Detailed Report, 9/5/2025
58 / 63
The sensitivity score reflects the extent to which a project would be adversely affected by exposure to a climate hazard. Exposure is rated on a scale of 1 to 5, with a score of 5 representing the greatest exposure.

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

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

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

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

The overall vulnerability scores are calculated based on the potential impacts and adaptive capacity assessments for each hazard. Scores 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 84.6
Eaton Wash LST Analysis Detailed Report, 9/5/2025
59 / 63
AQ-PM 61.6
AQ-DPM 14.4
Drinking Water 87.7
Lead Risk Housing 57.2
Pesticides 41.7
Toxic Releases 67.5
Traffic 16.4
Effect Indicators —
CleanUp Sites 61.4
Groundwater 0.00
Haz Waste Facilities/Generators 1.80
Impaired Water Bodies 0.00
Solid Waste 35.7
Sensitive Population —
Asthma 11.4
Cardio-vascular 8.28
Low Birth Weights 1.01
Socioeconomic Factor Indicators —
Education 20.9
Housing 39.2
Linguistic 46.0
Poverty 9.85
Unemployment 52.5

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 —
Eaton Wash LST Analysis Detailed Report, 9/5/2025
60 / 63
Above Poverty 91.55652509
Employed 66.62389324
Median HI 93.46849737
Education —
Bachelor's or higher 81.99666367
High school enrollment 100
Preschool enrollment 95.7141024
Transportation —
Auto Access 81.29090209
Active commuting 28.7950725
Social —
2-parent households 61.81188246
Voting 85.88476838
Neighborhood —
Alcohol availability 81.62453484
Park access 49.90375978
Retail density 20.12062107
Supermarket access 12.33157962
Tree canopy 87.66842038
Housing —
Homeownership 87.77107661
Housing habitability 91.27422045
Low-inc homeowner severe housing cost burden 52.23918902 Low-inc renter severe housing cost burden 80.48248428
Uncrowded housing 96.93314513
Health Outcomes —
Insured adults 81.97099962
Arthritis 17.5
Eaton Wash LST Analysis Detailed Report, 9/5/2025
61 / 63
Asthma ER Admissions 85.4
High Blood Pressure 16.4
Cancer (excluding skin) 6.6
Asthma 83.3
Coronary Heart Disease 17.4
Chronic Obstructive Pulmonary Disease 56.7
Diagnosed Diabetes 52.6
Life Expectancy at Birth 88.2
Cognitively Disabled 56.3
Physically Disabled 47.8
Heart Attack ER Admissions 82.4
Mental Health Not Good 85.8
Chronic Kidney Disease 35.4
Obesity 78.7
Pedestrian Injuries 51.7
Physical Health Not Good 68.2
Stroke 34.3
Health Risk Behaviors —
Binge Drinking 71.2
Current Smoker 86.5
No Leisure Time for Physical Activity 79.7
Climate Change Exposures —
Wildfire Risk 46.9
SLR Inundation Area 0.0
Children 71.1
Elderly 13.2
English Speaking 80.3
Foreign-born 61.2
Eaton Wash LST Analysis Detailed Report, 9/5/2025
62 / 63
Outdoor Workers 72.8
Climate Change Adaptive Capacity —
Impervious Surface Cover 84.1
Traffic Density 14.1
Traffic Access 23.0
Other Indices —
Hardship 16.5
Other Decision Support —
2016 Voting 68.0

7.3. Overall Health & Equity Scores
Metric Result for Project Census Tract
CalEnviroScreen 4.0 Score for Project Location (a) 15.0 Healthy Places Index Score for Project Location (b) 91.0 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
Eaton Wash LST Analysis Detailed Report, 9/5/2025
63 / 63
Screen Justification
Land Use Based on applicant provided information.

Construction: Construction Phases Based on applicant schedule.

Construction: Off-Road Equipment applicant provided information Construction: Trips and VMT Trips based on applicant provided information. Vendor trucks added to represent water trucks, other materials transported to site. Trip length for all types adjusted to 0.25 to reflect localized emissions.

Operations: Vehicle Data Up to 3 staff would visit site on a daily basis, reflected in Parking Lot use.

Operations: Off-Road Equipment Wash operations would include a pump (or 2) to move water. Based on preliminary project info, pump(s) would be electrically powered and assumed to 75 hp, operated year-round.

Appendix B
Biological Resources Assessment

April 15, 2025 16537
Courtney Semlow, Director of Civil Design
Craftwater Engineering Inc.
11026 Camanito Vista Pacifica
San Diego, California 92131
Subject: Biological Resources Assessment for the Eaton Wash Stormwater Capture Project in Pasadena, California Dear Courtney Semlow:

Craftwater Engineering Inc., the contract operator for the City of Pasadena’s (City) Eaton Wash Stormwater Capture Project (project), is proposing to establish infrastructure for a multi-benefit stormwater capture site aimed at improving water quality and efficiently managing stormwater runoff. The project would involve usable public infrastructure that will be used to capture, treat, and enhance water flowing through Eaton Wash and ultimately into the Rio Hondo River, Los Angeles River, and the Pacific Ocean. Water will be stored subsurface as well as in surface ponds and treated using various methods. Although finalized plans are dependent upon community feedback, which were not available at the time of this report, the project will also include an above-ground park space with community amenities.

This letter report details the methodology and results of Dudek’s field reconnaissance survey and analysis of biological resources along the proposed Eaton Wash project site, within the City of Pasadena, California (Attachment A – Figures: Figure 1, Project Location; all figures are provided in Attachment A). For the purposes of this report, the project site is defined as Eaton Canyon Wash and the area of land immediately adjacent to the west and partially (approximately 100 feet) into Eaton Balance Park, and a larger portion of land to the east within the Southern California Edison right-of-way (ROW), a total project site footprint of approximately 4 acres. This report also reviews potential biological constrains within a 500-foot buffer around the project site, encompassing an approximately 59- acre study area.
1 Project Location
The project site is located within southeastern Pasadena within Los Angeles County, just west of the City of Arcadia.

The project site is situated within Township 1 North, Ranges 12 and 11 West,1 of the Mt. Wilson, California, 7.5- minute U.S. Geological Survey (USGS) quadrangle. (Attachment A – Figures: Figure 1, Project Location). The site is south of Del Mar Boulevard and north of San Pasqual Street, between Eaton Blanche Park and Madre Street. 1 Per the Public Land Survey System.

DUDEK225 SOUTH LAKE AVENUE
SUITE M210
PASADENA, CALIFORNIA 91101
T 626.204.9800
DUDEK.COM
TO: COURTNEY SEMLOW
SUBJECT: BIOLOGICAL RESOURCES ASSESSMENT FOR THE EATON WASH STORMWATER CAPTURE PROJECT IN

PASADENA, CALIFORNIA

16537 2
APRIL 2025
2 Methodology

2.1 Literature Review
Prior to conducting the field investigation, a literature search and database review was conducted by Dudek biologists to evaluate the natural resources found or potentially occurring within the study area. The database review included queries of the most recent versions of the California Department of Fish and Wildlife’s (CDFW) California Natural Diversity Database (CNDDB) and the California Native Plant Society’s (CNPS) Rare Plant Inventory (CDFW 2025a; CNPS 2025a). These databases were reviewed to identify sensitive biological resources present or potentially present for the USGS 7.5-minute quadrangle on which the study area is located (i.e., Mt.

Wilson) and the eight surrounding quadrangles (i.e., Condor Peak, Chilao Flat, Waterman Mtn., Pasadena, Azusa, Los Angeles, El Monte, and Baldwin Park) (USGS 2022) . The review also includes the resource list returned in the U.S. Fish and Wildlife Service (USFWS) Information for Planning and Consultation (IPaC) tool query for the study area (USFWS 2025a).

Other literature reviewed included U.S. Department of Agriculture (USDA) Natural Resources Conservation Service (NRCS) Web Soil Survey (USDA 2025a); CDFW Biogeographic Information and Observation System (CDFW 2025b); A Manual of California Vegetation, Online Edition (CNPS 2025b); the CDFW California Natural Community list (CDFW 2025c); State and Federally Listed Endangered, Threatened, and Rare Plants of California (CDFW 2025d); State and Federally Listed Endangered and Threatened Animals of California (CDFW 2025e); and the CDFW California Wildlife Habitat Relationships (CWHR) Life History Accounts and Range Maps (CDFW 2025f).

The following available resources were reviewed to assess the potential for jurisdictional waters: aerial photographs (Google Earth 2025; NETR 2025); the subject USGS 7.5-minute topographic quadrangle map (USGS 2022); the National Hydrography Dataset and Watershed Boundary Dataset (USGS 2025); and the USFWS National Wetland Inventory (USFWS 2025b).

2.2 Field Reconnaissance Survey
Dudek biologists Eilleen Salas and Ryan Stanley performed the field survey on February 11, 2025. Temperatures during the survey were between 58°F and 62°F, under 40% to 90% cloud cover, and wind speeds ranging between 0 and 2 miles per hour. The biological survey included vegetation mapping, the mapping of sensitive biological resources, if present, within the project site, and an evaluation of the potential for special-status species to occur.

2.2.1 Vegetation Community and Land Cover Mapping
Methods for vegetation mapping followed CDFW’s “Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Sensitive Natural Communities” (CDFW 2018) and the Survey of California Vegetation Classification and Mapping Standards (CDFW 2024). Where feasible, vegetation communities within the study area were mapped using CDFW’s List of Vegetation Alliances and Associations (or California Natural Community List) (CDFW 2025c), which is based on A Manual of California Vegetation, Second Edition (Sawyer et al. 2009) and A Manual of California Vegetation, Online Edition (CNPS 2025b). Vegetation communities and land covers were delineated to the vegetation association level. In cases where the vegetation classification standards from the CDFW Natural Communities List did not apply, classification standards from Draft Vegetation Communities of San DUDEK
TO: COURTNEY SEMLOW
SUBJECT: BIOLOGICAL RESOURCES ASSESSMENT FOR THE EATON WASH STORMWATER CAPTURE PROJECT IN

PASADENA, CALIFORNIA

16537 3
APRIL 2025
Diego County (Oberbauer et al. 2008) or Methods Used to Survey the Vegetation of Orange County Parks and Open Space Areas and The Irvine Company Property (Jones and Stokes 1993) were incorporated to accommodate the lack of conformity of conditions observed on site (e.g., developed/disturbed land cover types).

Special-status vegetation communities are those communities identified as high priority for inventory in the California Natural Communities List (CDFW 2025c) by a state (S) rarity ranking of S1, S2, S3, or have been separately identified in the list as sensitive. In addition, communities that are regulated by CDFW under California Fish and Game Code Sections 1600–1616, and/or that provide suitable habitat for special-status species may also be considered special status under the California Environmental Quality Act (CEQA).

Vegetation communities and other land cover types within the study area were mapped in the field using the Esri Field Maps, a mobile data collection application, on a digital aerial-based background (Esri 2025). Communities were classified based on dominant species and associated cover classes, site factors, stand descriptions (e.g., slope aspect, canopy structure), geographic setting, and characteristic species present within an area. Following completion of the fieldwork, all vegetation linework was finalized using Esri ArcGIS software and geographic information system coverage was created. Once in ArcGIS, the acreage of each vegetation community and land cover type within the study area was determined.

2.2.2 Plants
All native and naturalized plant species encountered within the study area during the survey were identified and recorded to the extent feasible given the available plant phenology. Latin and common names for plant species with a California Rare Plant Rank (CRPR) follow the names provided in the CNPS Rare Plant Inventory (CNPS 2025a).

For plant species without a CRPR, Latin names follow the Jepson Interchange List of Currently Accepted Names of Native and Naturalized Plants of California (Jepson Flora Project 2025), and common names follow the USDA NRCS Plants Database (USDA 2025b).

2.2.3 Wildlife
Dudek biologists walked portions of the study area to identify and record all wildlife species as detected during field surveys by sight, calls, tracks, scat, or other signs. In addition to species observed, expected wildlife usage of the site was determined according to known habitat preferences of regional wildlife species and knowledge of their relative distributions in the area. No trapping or focused surveys for nocturnal species were conducted. Latin and common names of animals follow Crother (2012) for reptiles and amphibians, American Ornithological Society (AOS 2025) for birds, Wilson and Reeder (2005) for mammals, North American Butterfly Association (NABA 2025) for butterflies, and Moyle (2002) for fish.

2.2.4 Jurisdictional Aquatic Resources
A formal delineation of aquatic resources was conducted following the methodology described in U.S. Army Corps of Engineers (USACE) A Field Guide to the Identification of the Ordinary High Water Mark (OHWM) in the Arid West Region of the Western United States (USACE 2008a), 1987 Wetlands Delineation Manual (USACE 1987), and the Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Arid West Region (USACE 2008b).

DUDEK
TO: COURTNEY SEMLOW
SUBJECT: BIOLOGICAL RESOURCES ASSESSMENT FOR THE EATON WASH STORMWATER CAPTURE PROJECT IN

PASADENA, CALIFORNIA

16537 4
APRIL 2025

2.3 Special-Status Species Assessment
Endangered, rare, or threatened plant species as defined in Section 15380(b) of the CEQA Guidelines (14 CCR 15000 et seq.) are referred to as “special-status plant species” and, as used in this report, include (1) plant species listed, proposed for listing, or candidates for listing as endangered or threatened recognized in the context of the California Endangered Species Act and federal Endangered Species Act (CDFW 2025d); and/or (2) plant species with a CRPR of 1 or 2 as designated by CNPS (2025a). Species with a CRPR or 3 or 4 generally do not qualify for protection under CEQA; therefore, they are not considered special-status and impacts to these species are not analyzed in this biological resources technical report.

Endangered, rare, or threatened wildlife species as defined in CEQA Guidelines, Section 15380(b) (14 CCR 15000 et seq.), are referred to as “special-status wildlife species” and, as used in this report, include (1) wildlife species listed, proposed for listing, or candidates for listing as endangered or threatened recognized in the context of the California Endangered Species Act and federal Endangered Species Act (CDFW 2025e); (2) California Species of Special Concern as designated by CDFW (2025g); and (3) mammals and birds that are fully protected species as described in the California Fish and Game Code, Sections 4700 and 3511 (CDFW 2025h).

The potential for special-status plant species to occur within the study area was assessed based on known geographic and elevation ranges as well as habitat and soil conditions that are known to support species occurring in the region. Potential for special-status wildlife species to occur within the study area was assessed based on known geographic ranges, the presence/absence of suitable habitat, and other natural history elements that might predict their occurrence. After completion of the reconnaissance surveys, the potential for special-status plant and wildlife species to occur on or near the project site was summarized according to the following categories. Because not all species are accommodated precisely by a given category (i.e., category definitions may be too restrictive), an expanded rationale for each category assignment is provided:
▪ Known to occur: the species has been documented on the property by a reliable source ▪ High potential to occur: the species has not been documented on the property but is known to recently occur in the vicinity and suitable habitat is present
▪ Moderate potential to occur: the species has not been documented on the property or in the vicinity, but the site is within the known range of the species and suitable habitat for the species is present ▪ Low potential to occur: the species has not been documented in the vicinity or on the property, but the site is within the known range of the species; however, suitable habitat for the species on site is of low quality ▪ Not expected to occur: the property is outside the known geographic or elevational range of the species and/or the site does not support suitable habitat for the species 3 Environmental Setting

3.1 Climate
The study area is located in Los Angeles County, approximately 11 miles northeast of downtown Los Angeles.

Pasadena has a Mediterranean climate with cool, wet winters and warm, dry summers. Based on climate summaries from the nearest climate weather station, August is the average warmest month with an average DUDEK
TO: COURTNEY SEMLOW
SUBJECT: BIOLOGICAL RESOURCES ASSESSMENT FOR THE EATON WASH STORMWATER CAPTURE PROJECT IN

PASADENA, CALIFORNIA

16537 5
APRIL 2025
maximum temperature of 89.2˚F and January is the coolest month with an average minimum of 42.6˚F (WRCC 2025). Rainfall occurs primarily between October and April, with the maximum average precipitation occurring in February (WRCC 2025). The mean annual rainfall for the region is 20.24 inches of rain per year (WRCC 2025).

3.2 Topography
The topography of the study area varies slightly between the Eaton Wash portion of the project site and the developed or actively landscaped areas. The topography within the wash consists of a concrete storm channel bordered by dirt access roads. There are short and steep slopes to the east and west, with a park on the western side and a sparsely developed/undeveloped area to the west with a working plant nursery. The remainder of the study area consists of residential development with no changes in topography. Elevations on site range between 633 feet above mean sea level and 702 feet above mean sea level (Google Earth 2025).

3.3 Surrounding Land Use
The study area is located within a suburban residential neighborhood typical of Pasadena. Residential housing tracts are prevalent throughout the area surrounding the project site, along with a community park, a middle school, and business tracts to the north. The vegetation and landscaping are typical of residential and business areas.

Additionally, a transmission line ROW follows alongside Eaton Wash immediately to the east, where the ROW is being used as a commercial nursery (Google Earth 2025).

3.4 Soils
According to the USDA NRCS Web Soil Survey (USDA 2025a), three soil map unit types were identified within the study area: Palmview, 0% to 5% slopes; Tujunga, 0% to 5% slopes; and Soboba, 0% to 5% slopes. All soil types occur within the undeveloped portion of the project site (Attachment A – Figures: Figure 2, Soils). None of these map units are included in the U.S. Department of Agriculture NRCS hydric soils list (USDA 2025c). Based on historic aerial imagery (NETR 2025), the study area has remained relatively unchanged since at least 1952, with a gradual increase in development of the surrounding residential tracts.

Palmview , 0% to 5% Slopes
This soil series is characterized by very deep, well drained soils that formed in alluvium on alluvial fans and flood plains. These soils consist of coarse-loamy and mixed material. Typical vegetation includes annual grasses and forbs. This soil series exhibits very low runoff and is used for urban residential and commercial development, as a result, ornamental plants and turn-grass are common users of this soil (USDA 1978).

Tujunga, 0% to 5% Slopes
This soil series consists of very deep, somewhat excessively drained soils that formed in alluvium on alluvial fans and flood plains. These soils consist of mixed sources. Vegetation is primarily made up of shrubs, annual grasses and forbs, but also includes ornamentals and turfgrass in developed areas. This soil unit exhibits efficient drainage with low runoff and is used for urban and commercial development (USDA 1978).

DUDEK
TO: COURTNEY SEMLOW
SUBJECT: BIOLOGICAL RESOURCES ASSESSMENT FOR THE EATON WASH STORMWATER CAPTURE PROJECT IN

PASADENA, CALIFORNIA

16537 6
APRIL 2025
Soboba , 0% to 5% Slopes
This soil type is composed of deep and excessively drained soils that formed in alluvium on alluvial fans and flood plains. These soils are comprised of a sandy-skeletal mixture and exhibits very slow runoff and rapid permeability.

Vegetation is primarily made up of annual grasses, forbs, and chapparal shrubs, and is used mostly for pasture (USDA 1978).
4 Results

4.1 Vegetation Communities and Land Covers
One vegetation community and three land cover types were identified within the study area during the survey: coast live oak woodland and forest (Quercus agrifolia association), Urban/Developed land, Ornamental Plantings, and Disturbed Habitat. These vegetation communities and land cover types are described below, their acreages are presented in Table 1, and their spatial distributions are presented in Attachment A – Figures: Figure 4, Vegetation Communities and Land Cover Types. Representative photos of the study area are included in Attachment B, Photo Exhibit.

Table 1. Vegetation Communities and Land Cover Types in the Study Area Vegetation Community/
Land Cover Type Alliance Association
Acreage within the
Project Site
Acreage within
the Study Area
(Project Site Plus
500-Foot Buffer)
Coast Live Oak Woodland
and Forest
Quercus agrifolia Forest
and Woodland Alliance1
Quercus
agrifolia

0.46 0.53
Urban/Developed N/A N/A 0.28 45.59
Ornamental Plantings N/A N/A 0.17 7.27
Disturbed Habitat N/A N/A 3.02 5.10
Total2 3.93 58.50
Notes: N/A = not applicable.
1 Semi-natural alliances do not have conservation status rankings and are not considered sensitive. 2 Totals may differ due to rounding.

4.1.1 Coast Live Oak Woodland and Forest
Coast live oak woodland and forest (Quercus agrifolia Forest and woodland alliance) includes coast live oak (Quercus agrifolia) as the dominant species or co-dominant in the upland tree canopy with bigleaf maple ( Acer macrophyllum), Pacific madrone (Arbutus menziesii), southern California black walnut ( Juglans californica), blue oak (Quercus douglasii), Engelmann oak (Quercus engelmannii), black oak (Quercus kelloggii), valley oak (Quercus lobata), and California bay (Umbellularia californica). The shrub layer is sparse to intermittent, and the herbaceous layer is sparse or grassy (CNPS 2025b). The coast live oak woodland and forest vegetation community within the study area (Attachment A – Figures: Figure 4, Vegetation Communities and Land Cover Types) is dominated by coast live oak and was therefore mapped as the Quercus agrifolia association. The coast live oak woodland and forest is not considered sensitive by CDFW (2025c), though coast live oak does fall under the City’s tree protection ordinance (City of Pasadena 2010).

DUDEK
TO: COURTNEY SEMLOW
SUBJECT: BIOLOGICAL RESOURCES ASSESSMENT FOR THE EATON WASH STORMWATER CAPTURE PROJECT IN

PASADENA, CALIFORNIA

16537 7
APRIL 2025

4.1.2 Urban/Developed Land
Although not recognized by the Manual of California Vegetation (CNPS 2025b) or the CDFW California Natural Community List (CDFW 2025c), the urban/developed land cover type is described in Draft Vegetation Communities of San Diego County (Oberbauer et al. 2008). According to Oberbauer et al. (2008), urban/developed land represents areas that have been constructed upon or otherwise physically altered to an extent that native vegetation communities are not supported. This land cover type generally includes permanent or semi-permanent structures, pavement or hardscape, landscaped areas, and areas with a large accumulation of debris or other materials (Oberbauer et al. 2008). Typically, this land cover type is unvegetated or only supports a variety of ornamental plants and landscaping. Paved ROWs, residential properties, the middle school, and the community park were mapped as urban/developed land within the study area. This land cover type is primarily found on the eastern side of the project site and includes the Eaton Wash channel and the adjacent dirt access road.

4.1.3 Ornamental Plantings
Although not recognized by the Manual of California Vegetation (CNPS 2025b) or the CDFW California Natural Community List (CDFW 2025c), the parks and ornamental plantings (or ornamental vegetation) land cover type is described in Methods Used to Survey the Vegetation of Orange County Parks and Open Space Areas and The Irvine Company Property (Jones and Stokes 1993). This mapping unit is described as vegetation comprised of non-native trees, shrubs, flowers, and turf grass introduced for landscaping purposes. This mapping unit type typically occurs in greenbelts, parks, and horticultural plantings (Jones and Stokes 1993). Ornamental plantings were mapped where non-native ornamental plant species were present at a cover of 75% or higher and did not occur in an assemblage described in the California Natural Community List. This land cover type was found on the west slope adjacent to Eaton Wash and the transmission line ROW where the commercial nursery is operating, as well as the western side of Eaton Wash w ithin the community park grounds (Attachment A – Figures: Figure 4, Vegetation Communities and Land Cover Types).

4.1.4 Disturbed Habitat
Although not recognized by the Manual of California Vegetation, Online Edition (CNPS 2025b), or the Natural Communities List (CDFW 2025c), disturbed habitat is described in the Draft Vegetation Communities of San Diego County (Oberbauer et al. 2008). Disturbed habitat is described as areas generally lacking vegetation due to high levels of existing or historical human disturbance and no longer recognizable as a native or naturalized vegetation association. Areas mapped as disturbed habitat may include unpaved roads, trails, and graded areas. Vegetation in these areas, if present at all, is usually sparse and dominated by non-native weedy herbaceous species (Oberbauer et al. 2008). Disturbed habitat consists of unpaved roads and areas where vehicles have regularly gone off-road.

4.2 Plants
A total of 18 plant species, 10 native (56%) and 8 non-native (44%), were recorded on the site. Plant species observed within the study area were predominantly composed of native species consisting of shrubs, small trees, and trees.

The vegetation classified within the study area can be found in the vegetation community descriptions above and a list of plant species observed during the field survey is available in Attachment C, Species Compendium.

DUDEK
TO: COURTNEY SEMLOW
SUBJECT: BIOLOGICAL RESOURCES ASSESSMENT FOR THE EATON WASH STORMWATER CAPTURE PROJECT IN

PASADENA, CALIFORNIA

16537 8
APRIL 2025

4.2.1 Special-Status Plant Species Assessment
Forty-seven plant species that meet the special-status definition (see Section 2.3, Special-Status Species Assessment) have recorded occurrences in the USGS Mt. Wilson 7.5-minute quadrangle and eight surrounding quadrangles (CDFW 2025a; CNPS 2025a) or are included in the IPaC report for the study area (USFWS 2025a). Each special-status plant species is assessed in Attachment D, Special-Status Plant Species Potential to Occur. The study area is not within any designated critical habitat (USFWS 2025c). No state or federally listed wildlife species were determined to have a potential to occur, and no non-listed special-status wildlife species were determined to have a moderate or high potential to occur within the study area due to lack of suitable habitat and microhabitat conditions.

4.3 Wildlife
Thirteen species of wildlife were observed during the survey. Wildlife species observed within the study area consisted solely of bird species. No amphibian species were observed. No reptile species were observed; however, western fence lizard (Sceloporus occidentalis) and common side-blotched lizard (Uta stansburiana) are common reptile species that could occur within the study area. No mammal species were observed but coyote (Canis latrans), common raccoon (Procyon lotor), striped skunk (Mephitis mephitis), and Virginia opossum (Didelphis virginiana) are common mammal species that would be expected to occasionally pass through within the study area. A comprehensive list of wildlife species observed during the field survey is available in Attachment C, Species Compendium.

4.3.1 Special-Status Wildlife Species Assessment
Forty wildlife species that meet the special-status definition (see Section 2.3) have recorded occurrences in the USGS Mt. Wilson 7.5-minute quadrangle and eight surrounding quadrangles (CDFW 2025a) or are included in the IPaC report for the study area (USFWS 2025a). Each special-status wildlife species is assessed in Attachment E, Special-Status Wildlife Species Potential to Occur. The study area is not within any designated critical habitat (USFWS 2025c).

One sensitive bird species, Cooper’s hawk (Accipiter cooperii), was determined to have a moderate potential to nest in the large trees adjacent to the Eaton Wash. Cooper’s hawk is a CDFW Watch List2 species. Three bat species, western yellow bat (Dasypterus xanthinus), western mastiff bat (Eumops perotis californicus), and western red bat (Lasiurus frantzii), and one invertebrate, Crotch’s bumble bee (Bombus crotchii), were determined to have a low potential to occur. The bat species are CDFW Species of Special Concern.3 and foraging habitat is present in the park and roosting could be supported by large trees, including palms, and the Del Mar Boulevard overpass that spans Eaton Wash. Crotch’s bumble bee is a candidate for state listing and suitable floral resources and microhabitat nesting opportunities (i.e., small mammal burrows) were not identified in field surveys; however, there are numerous occurrences of this species in the nearby vicinity and the species could occur as a transient. Project actions are not expected to impact transitory individuals. 2 Watch list species are taxa that were previously considered Species of Special Concern but do not currently meet Species of Special Concern criteria, and for which there is concern and a need for additional information to clarify status (CDFW 2025i). 3 Species with declining population levels, limited ranges, and/or continuing threats that have made them vulnerable to extinction (CDFW 2025i).

DUDEK
TO: COURTNEY SEMLOW
SUBJECT: BIOLOGICAL RESOURCES ASSESSMENT FOR THE EATON WASH STORMWATER CAPTURE PROJECT IN

PASADENA, CALIFORNIA

16537 9
APRIL 2025

4.4 Potential Jurisdictional Aquatic Resources
The Eaton Wash storm channel collects and conveys relatively permanent water from Eaton Canyon in the San Gabriel Mountains, along with nuisance water and storm runoff from the surrounding urban area. The ordinary high watermark was observed at the top of the storm channel and the wetted channel feature in the storm channel bottom (see Attachment B, Photo Exhibit). The Eaton Wash waters flow into the Rio Hondo, the Los Angeles River, and eventually to the Pacific Ocean. Based on a review of current and historic aerial photographs and USGS topographic maps, these features observed on site are remnant of a natural watercourse such as a river, stream, or lake, and contain hydrologic nexus with a Traditional Navigable Water. As such, the 1.5 acres of Eaton Wash in the study area are expected to fall under jurisdiction of the Regional Water Quality Control Board (RWQCB), CDFW, and the USACE.

4.5 Wildlife Movement, Wildlife Corridors, and Wildlife Nursery Sites
Wildlife corridors are linear features that connect large patches of natural open space and provide avenues for the migration of animals. Corridors can also be aquatic resources that provide passage for fish. Habitat linkages are small patches that join larger blocks of habitat and help reduce the adverse effects of habitat fragmentation; they may be continuous habitat or discrete habitat islands that function as steppingstones for wildlife dispersal.

On a regional level, the study area does not occur within any designated wildlife corridors or habitat linkages identified in the South Coast Missing Linkages analysis conducted by South Coast Wildlands (2008) or CDFW’s California Essential Habitat Connectivity Project (Spenser et al. 2010), as shown in the CDFW BIOS (CDFW 2025b). The project site provides no habitat connectivity with anything documented by the sources. Although the project site may provide live-in habitat for birds, reptiles, and small to medium mammals, the project site is isolated by surrounding urban development and does not provide connectivity to significant open space areas or to natural features. The study area is isolated from streams that do support habitat and therefore does not support fish movement.

Trees within the study area do not contain suitable cavities for bat maternities or overwintering roosts and are exposed to noise disturbance from traffic and urban development. In addition, no diagnostic signs of bird rookeries (e.g., numerous nests, whitewash) or large maternal or overwintering bat roosts (e.g., large concentrations of guano or guano odors) were identified in the study area. Therefore, it is unlikely for the study area to support wildlife nursery sites. The study area does contain vegetation and structure (e.g. Del Mar Blvd overpass) that could provide nesting habitat for bats along with nesting habitat for birds protected under the Migratory Bird Treaty Act (MBTA) and California Fish and Game Code Sections 3503, 3503.5, and 3513.

Compliance with Migratory Bird Treaty Act and California Fish and Game Code The proposed project will be conducted in compliance with all applicable regulations, including the MBTA and California Fish and Game Code regarding migratory birds. Pursuant to MBTA and California Fish and Game Code, a qualified biologist will conduct a pre-construction survey for nesting birds and raptors within the project site and a 500-foot buffer no more than three days prior to any vegetation disturbance during the general avian breeding season (February 1–September 30). The project will avoid take of nesting birds protected under the MBTA and California Fish and Game Code by establishing appropriate no-construction buffer zones around any nests identified DUDEK
TO: COURTNEY SEMLOW
SUBJECT: BIOLOGICAL RESOURCES ASSESSMENT FOR THE EATON WASH STORMWATER CAPTURE PROJECT IN

PASADENA, CALIFORNIA

16537 10
APRIL 2025
during the surveys. If the biologist does not find any active nests within or immediately adjacent to the impact areas, the vegetation clearing/construction work would be allowed to proceed. If the biologist finds an active nest within or immediately adjacent to the vegetation removal area and determines that the nest may be impacted or breeding activities substantially disrupted, the biologist will delineate an appropriate no-work buffer zone around the nest depending on the sensitivity of the species, location of the nest, and the nature of the construction activity at their discretion. Construction personnel would be instructed on the sensitivity of nest areas and no-work buffers would remain in place until the nest is vacated, juveniles have fledged, and there is no evidence of a second attempt at nesting. Limits of construction to avoid an active nest would be established in the field with flagging or fencing, and construction personnel shall be instructed on the sensitivity of nest areas.

4.6 Habitat Conservation Plans/Natural Community
Conservation Plans
The study area does not occur in any Natural Community Conservation Plan/Habitat Conservation Plan, as identified by CDFW’s Natural Community Conservation Planning (CDFW 2019). Construction of the project will not result in impacts to covered habitats or species. The project is not within any other habitat conservation plan, natural community conservation plan, or other approved local, regional, or state habitat conservation plan (CDFW 2019).

4.7 Local Ordinances
The City defines tree protection in PMC Chapter 8.52 – City Trees and Tree Protection (City of Pasadena 2010).

Various species including the Coast live oak (Quercus agrifolia) found on the project site fall under the City’s native tree ordinance as follows:

Native tree: any tree with a trunk more than 8 inches in diameter at a height of 4 ½ feet above natural grade that is one of the following species: Quercus agrifolia (Coast live oak), Quercus engelmannii (Engelmann oak), Quercus chrysolepis (Canyon oak), Platanus racemosa (California sycamore), Juglans californica (California walnut), Quercus berberidifolia (Scrub oak), Quercus lobata (Valley oak), Umbellularia californica (California bay), Populus fremontii (Cottonwood), Alnus rhombifolia (California alder), Populus trichocarpa (Black cottonwood), Salix lasiolepis (Arroyo willow), and Aesculus californica (California buckeye). 5 Conclusion
At this time, project plans have not been finalized and total impacts have yet to be determined. No sensitive vegetation communities or special-status plant species were identified within the study area. Additionally, no special-status plant species are expected to occur in the project site and the project site also is not within a designated wildlife corridor or habitat linkage and is not expected to be used as a wildlife corridor, habitat linkage, or native wildlife nursery site. As noted in Section 4.5, Wildlife Movement, Wildlife Corridors, and Wildlife Nursery Sites, the project will comply with regulations under the MBTA and the California Fish and Game Code, along with the local policies or ordinances protecting biological resources. One species of bird has a moderate potential to occur on the project site, and three species of bat and one invertebrate species have a low potential to occur (see Section 4.3.1, Special-Status Wildlife Species Assessment).

DUDEK
TO: COURTNEY SEMLOW
SUBJECT: BIOLOGICAL RESOURCES ASSESSMENT FOR THE EATON WASH STORMWATER CAPTURE PROJECT IN

PASADENA, CALIFORNIA

16537 11
APRIL 2025
Potential jurisdictional waters regulated by the RWQCB, CDFW, and the ACOE were identified within the Eaton Wash channel (Attachment A – Figures : Figure 3, Hydrologic Setting). Should dredging, filling, or discharging of materials occur within these potential RWQCB-jurisdictional features as part of project implementation, the proposed project will need to maintain compliance with the Clean Water Act and California Fish and Game Code Sections 1600– 1616.

The project site has no value as habitat for endangered, rare, or threatened species. However, in order to identify any potential impacts to special-status biological resources, pre-construction surveys and project monitoring of vegetation removal and initial ground disturbance should be conducted to ensure project actions remain in compliance with state and federal regulations, and any potential impacts to special-status biological resources are identified.

Sincerely,
__________________________________
Ryan Stanley
Biologist
Atts.: A – Figures
B – Photo Exhibit
C – Species Compendium
D – Special-Status Plant Species Potential to Occur
E – Special-Status Wildlife Species Potential to Occur
cc: Alex Hardy, Dudek
6 References
AOS (American Ornithological Society). 2025. American Ornithological Society Checklist of North and Middle American Birds (Online). American Ornithological Society. Accessed March 2025. https://checklist. americanornithology.org/taxa/.

CDFW (California Department of Fish and Wildlife). 2018. Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Sensitive Natural Communities. March 20, 2018. Accessed March 2025. https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=18959.

CDFW. 2019. California Natural Community Conservation Plans. April 2019. Accessed March 2025. https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=68626&inline.

CDFW. 2024. Survey of California Vegetation Classification and Mapping Standards, March 6, 2024. Accessed March 2025. https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=102342&inline.

CDFW. 2025a. California Natural Diversity Database (CNDDB). RareFind 5.3.0 (Commercial Subscription).

Sacramento, California: CDFW, Biogeographic Data Branch. Accessed March 2025. https://apps. wildlife.ca.gov/rarefind/view/RareFind.aspx.

CDFW. 2025b. Biogeographic Information and Observation System; online database viewer. Accessed March 2025. https://apps.wildlife.ca.gov/bios6/.

DUDEK
TO: COURTNEY SEMLOW
SUBJECT: BIOLOGICAL RESOURCES ASSESSMENT FOR THE EATON WASH STORMWATER CAPTURE PROJECT IN

PASADENA, CALIFORNIA

16537 12
APRIL 2025
CDFW. 2025c. California Natural Community List, February 27, 2025. Accessed March 2025. https://wildlife.ca.gov/Data/VegCAMP/Natural-Communities.

CDFW. 2025d. State and Federally Listed Endangered, Threatened, and Rare Plants of California. Accessed March 2025. https://wildlife.ca.gov/Data/CNDDB/Plants-and-Animals.

CDFW. 2025e. State and Federally Listed Endangered and Threatened Animals of California, January 2025.

Accessed March 2025. https://wildlife.ca.gov/Data/CNDDB/Plants-and-Animals.

CDFW. 2025f. California Wildlife Habitat Relationships Life History Accounts and Range Maps (online). Accessed March 2025. https://wildlife.ca.gov/Data/CWHR/Life-History-and-Range.

CDFW. 2025g. Species of Special Concern. Accessed March 2025. https://www.wildlife.ca.gov/Conservation/SSC.

CDFW. 2025h. Fully Protected Animals. Accessed March 2025. https://wildlife.ca.gov/Conservation/ Fully-Protected.

CDFW. 2025i. Special Animal List. Accessed March 2025. https://nrm.dfg.ca.gov/FileHandler. ashx?DocumentID=109406.

City of Pasadena. 2010. “Municipal Code: Chapter 8.52 – City Trees and Tree Protection Ordinance.” Accessed March 2025. https://www.cityofpasadena.net/public-works/wp-content/uploads/sites/29/ TPO_2-Pasadena-Tree-Ordinance-Municipal-Code-8.52.pdf.

CNPS (California Native Plant Society). 2025a. Rare Plant Inventory, online ed. Version 9.5.1. California Native Plant Society, Rare Plant Program. Accessed March 2025. http://www.rareplants.cnps.org.

CNPS. 2025b. A Manual of California Vegetation Online. Accessed March 2025. https://vegetation.cnps.org.

Crother, B.I. 2012. Scientific and Standard English Names of Amphibians and Reptiles of North America North of Mexico, with Comments Regarding Confidence in our Understanding, edited by J.J. Moriarty. 7th ed.

Society for the Study of Amphibians and Reptiles; Herpetological Circular, No. 39. August 2012.

Esri. 2025. “World Imagery” [basemap]. Accessed March 2025. https://www.arcgis.com/home/item.html?id= 10df2279f9684e4a9f6a7f08febac2a9.

Google Earth. 2025. Google Earth; desktop application; centered on the project site. Accessed March 2025. https://www.google.com/earth/.

Jepson Flora Project. 2025. Jepson eFlora. Berkeley, California: University of California. Accessed March 2025. https://ucjeps.berkeley.edu/eflora/.

Jones & Stokes Inc. 1993. Methods Used to Survey the Vegetation of Orange County Parks and Open Space Areas and The Irvine Company Property. JSA 92-032. February 10, 1993.

DUDEK
TO: COURTNEY SEMLOW
SUBJECT: BIOLOGICAL RESOURCES ASSESSMENT FOR THE EATON WASH STORMWATER CAPTURE PROJECT IN

PASADENA, CALIFORNIA

16537 13
APRIL 2025
Moyle, P.B. 2002. Inland Fishes of California. Berkeley and Los Angeles, California: University of California Press.

NABA (North American Butterfly Association). 2025. NABA Checklist and English Names of North American Butterflies. Edited by Braby, M., Cassie, B., Edwards, A., Epstein, M., Glassberg, J., Hall, P.W., Heath, F., Hsu, Y.-F., Larsen, T., Lohman, D., Pierce, N., Scoble, M., Springer, J., Swengel, A., Tennent, J., Tudor, G., Vane-Wright, D., Viloria, A., West, J. and Yen, S.-H. Edition 2.6. North American Butterfly Association.

Morristown, New Jersey. Accessed March 2025. https://naba.org/butterfly-names-checklist/.

NETR (National Environmental Title Research LLC). 2025. Historical Aerials Viewer. NETR Online. Accessed March 2025. https://www.historicaerials.com/viewer.

Oberbauer, T., M. Kelly, and J. Buegge. 2008. Draft Vegetation Communities of San Diego County. Based on Preliminary Descriptions of the Terrestrial Natural Communities of California, Robert F. Holland, Ph.D., October 1986.

Sawyer, J., T. Keeler-Wolf, and J. Evens. 2009. A Manual of California Vegetation. 2nd ed. Sacramento, California:

California Native Plant Society.

South Coast Wildlands. 2008. South Coast Missing Linkages: A Wildland Network for the South Coast Ecoregion.

Produced in cooperation with partners in the South Coast Missing Linkages Initiative. Accessed March 2025. http://www.scwildlands.org/reports/scmlregionalreport.pdf.

Spenser, W.D., P. Beier, K. Penrod, K. Winters, C. Paulman, H. Rustigian-Romsos, J. Strittholt, M. Parisi, and A.

Pettler. 2010. California Essential Habitat Connectivity (CEHC) Project: A Strategy for Conserving a Connected California. Prepared for California Department of Transportation, California Department of Fish and Game, and Federal Highways Administration. Accessed March 2025. https://nrm.dfg.ca.gov/ FileHandler.ashx?DocumentID=18504.