Air Quality & Greenhouse Gas Impact Assessment AMBIENT Air Quality & Noise Consulting Allegretto Resort Expansion Project March 2025
11 that drive on road, with the limited exception of two-engine sweepers. Examples include loaders, crawler tractors, skid steers, backhoes, forklifts, airport ground support equipment, water well drilling rigs, and twoengine cranes. Such vehicles are used in construction, mining, and industrial operations. The regulation does not apply to stationary equipment or portable equipment such as generators. The off-road vehicle regulation establishes emissions performance requirements, reporting, disclosure, and labeling requirements for off-road vehicles, and limits unnecessary idling.
CALIFORNIA BUILDING CODE
The California Building Code (CBC) contains standards that regulate the method of use, properties, performance, or types of materials used in the construction, alteration, improvement, repair, or rehabilitation of a building or other improvement to real property. The CBC is adopted every three years by the Building Standards Commission (BSC). In the interim, the BSC also adopts annual updates to make necessary midterm corrections. The CBC standards apply statewide; however, a local jurisdiction may amend a CBC standard if it makes a finding that the amendment is reasonably necessary due to local climatic, geological, or topographical conditions.
GREEN BUILDING STANDARDS
In essence, green buildings standards are indistinguishable from any other building standards. Both standards are contained in the CBC and regulate the construction of new buildings and improvements. The only practical distinction between the two is that whereas the focus of traditional building standards has been protecting public health and safety, the focus of green building standards is to improve environmental performance.
AB 32, which mandates the reduction of GHG emissions in California to 1990 levels by 2020, increased the urgency around the adoption of green building standards. In its scoping plan for the implementation of AB 32, ARB identified energy use as the second largest contributor to California’s GHG emissions, constituting roughly 25 percent of all such emissions. In recommending a green building strategy as one element of the scoping plan, ARB estimated that green building standards would reduce GHG emissions by approximately 26 million metric tons (MMT) of carbon dioxide equivalent (CO2e) by 2020.
The May 2018 green buildings standards referred to as the 2019 Building Energy Efficiency Standards, focuses on four key areas: smart residential photovoltaic systems, updated thermal envelope standards (preventing heat transfer from the interior to the exterior and vice versa), residential and nonresidential ventilation requirements, and nonresidential lighting requirements. The ventilation measures improve indoor air quality, protecting homeowners from air pollution originating from outdoor and indoor sources. Under the standards, nonresidential buildings will use about 30 percent less energy due mainly to lighting upgrades. The recently updated 2019 Building Energy Efficiency Standards also require new homes built after January 1, 2020, to be equipped with solar photovoltaic (PV) systems. The solar PV systems are to be sized based on the building's annual electricity demand, the building's square footage, and the climate zone within which the home is located. However, under the 2019 Building Energy Efficiency Standards, homes may still rely on other energy sources, such as natural gas. Compliance with the 2019 Building Energy Efficiency Standards, including the solar PV system mandate, residential dwellings will use approximately 50 to 53 percent less energy than those under the 2016 standards. Actual reduction will vary depending on various factors (e.g., building orientation, sun exposure). Non-residential buildings will use about 30 percent less energy due mainly to lighting upgrades (CEC 2018).
The recently updated 2022 Building Energy Efficiency Standards (2022 Standards), which were approved in December 2021, encourage efficient electric heat pumps, establishes electric-ready requirements when natural gas is installed and to support the future installation of battery storage, and further expands solar photovoltaic and battery storage standards. The 2022 Standards extend solar PV system requirements, as well as battery storage capabilities for select land uses, including high-rise multi-family and non-residential land uses, such as office buildings, schools, restaurants, warehouses, theaters, grocery stores, and more.
Depending on the land use and other factors, solar systems should be sized to meet targets of up to 60 percent of the structure’s loads. These new solar requirements went into effect January 1, 2023, and contribute to California’s goal of reaching net-zero carbon footprint by 2045 (CEC 2021).
Exhibit C
Air Quality & Greenhouse Gas Impact Assessment AMBIENT Air Quality & Noise Consulting Allegretto Resort Expansion Project March 2025
12 Table 6. Summary of Ambient Air Quality Standards & Attainment Designations Source: SLOAPCD 2019
Exhibit C
Air Quality & Greenhouse Gas Impact Assessment AMBIENT Air Quality & Noise Consulting Allegretto Resort Expansion Project March 2025
13 Local
COUNTY OF SAN LUIS OBISPO AIR POLLUTION CONTROL DISTRICT The SLOAPCD is the agency primarily responsible for ensuring that NAAQS and CAAQS are not exceeded and that air quality conditions within the region are maintained. Responsibilities of the SLOAPCD include but are not limited to, preparing plans for the attainment of ambient air quality standards, adopting and enforcing rules and regulations concerning sources of air pollution, issuing permits for stationary sources of air pollution, inspecting stationary sources of air pollution and responding to citizen complaints, monitoring ambient air quality and meteorological conditions, and implementing programs and regulations required by the FCAA and the CCAA.
CITY OF PASO ROBLES
The City’s General Plan includes numerous policies related to air quality. These policies address emissions generated by mobile and non-mobile sources and land use compatibility. The General Plan includes the following policies related to air quality:
• Circulation Element - Policy CE-1A. Circulation Master Plan. Revise/update the City’s Circulation Master Plan to address the mobility needs of all users of the streets, roads, and highways including motorists, movers of commercial goods, seniors, children, pedestrians, disabled persons, users of public transportation, and bicyclists.
• Circulation Element - Policy CE-1B. Reduce Vehicle Miles Traveled (VMT). The City shall strive to reduce VMT generated per household per weekday by making efficient use of existing transportation facilities and by providing direct routes for pedestrians and bicyclists through the implementation of sustainable planning principles.
• Circulation Element - Policy CE-1C. Airport. Improve/expand transportation to and from the Paso Robles Municipal Airport as set forth in the Airport Master Plan • Circulation Element - Policy CE-1D. Transit. Improve and expand transit services. • Circulation Element - Policy CE-1E. Rail. Promote regional, interstate, and intra-state rail service. • Circulation Element - Policy CE-1F. Pedestrian and Bicycle Access. Provide safe and convenient pedestrian and bicycle access to all areas of the City. • Conservation Element - Policy C-2A. Traffic Congestion Reduction. Implement circulation systems improvements to reduce congestion and associated air contaminant emissions. • Conservation Element - Policy C-2B. VMT Reduction. Implement programs to reduce the number of VMT, especially by single occupant vehicles, including providing opportunities for mixed-use projects.
• Conservation Element - Policy C-2C. Emissions Reduction. Take steps to reduce creation of air contaminant emissions.
Impact Analysis
Thresholds of Significance
In accordance with Appendix G of the California Environmental Quality Act (CEQA) Guidelines, air quality impacts associated with the proposed project would be considered significant if it would:
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.
To assist in the evaluation of air quality impacts, the SLOAPCD has developed recommended significance thresholds, which are contained in the SLOAPCD’s CEQA Air Quality Handbook (2012). For the purposes of this analysis, project-generated emissions would be considered to have a potentially significant impact if any of the following SLOAPCD thresholds are exceeded:
Exhibit C
Air Quality & Greenhouse Gas Impact Assessment AMBIENT Air Quality & Noise Consulting Allegretto Resort Expansion Project March 2025
14 Construction Impacts
The threshold criteria established by the SLOAPCD to determine the significance and appropriate mitigation level for a project’s short-term construction emissions are presented in Table 7 and discussed, as follows (SLOAPCD 2012):
Table 7. SLOAPCD Thresholds of Significance for Project-Level Construction Impacts Pollutant
Threshold(1)
Daily (lbs/day) Quarterly Tier 1
(tons)
Quarterly Tier 2
(tons)
Ozone Precursors (ROG + NOX) 137 2.5 6.3
Diesel Particulate Matter (DPM) 7 0.13 0.32
Fugitive Particulate Matter (PM10), Dust(2)-- 2.5 --
1. Daily and quarterly emissions thresholds are based on the California Health & Safety Code and the ARB Carl Moyer Guidelines.
2. Any project with a grading area greater than 4.0 acres of a worked area can exceed the 2.5 tons PM10 quarterly threshold.
Source: SLOAPCD 2012
ROG and NOx Emissions
Daily: For construction projects exceeding the 137 lbs/day threshold require Standard Mitigation Measures.
Quarterly – Tier 1: For construction projects exceeding the 2.5 tons/quarter threshold, require Standard Mitigation Measures and Best Available Control Technology (BACT) for construction equipment. Off-site mitigation may be required if feasible mitigation measures are not implemented, or if no mitigation measures are feasible for the project.
Quarterly – Tier 2: For construction projects exceeding the 6.3 tons/quarter threshold, Standard Mitigation Measures, BACT, implementation of a Construction Activity Management Plan (CAMP), and off-site mitigation are required.
DPM Emissions
Daily: For construction projects exceeding the 7 lbs/day threshold, require Standard Mitigation Measures.
Quarterly - Tier 1: For construction projects lasting more than one quarter, exceedance of the 0.13 tons/quarter threshold requires Standard Mitigation Measures, BACT for construction equipment; and, Quarterly - Tier 2: For construction projects exceeding the 0.32 tons/quarter threshold, require Standard Mitigation Measures, BACT, implementation of a CAMP, and off-site mitigation.
Fugitive Particulate Matter (PM10), Dust Emissions
Quarterly- Tier 1: For construction projects exceeding the 2.5 tons/quarter threshold require Fugitive PM10 dust Mitigation Measures and may require the implementation of a CAMP.
Operational Impacts
Criteria Air Pollutants
The threshold criteria established by the SLOAPCD to determine the significance and appropriate mitigation level for long-term operational emissions from a project are presented in Table 8.
For projects exceeding the 25 lbs/day operational ozone precursor threshold but not the corresponding 25 tons/year annual threshold, the project shall implement all applicable SLOAPCD-recommended mitigation measures. Off-site mitigation may be required for projects (exceeding the 25 lbs/day threshold) if all applicable SLOAPCD-recommended mitigation measures are not implemented, or if no mitigation measures are feasible for the project. Off-site mitigation is required for projects exceeding the 25 tons/year threshold (SLOAPCD 2017).
Exhibit C
Air Quality & Greenhouse Gas Impact Assessment AMBIENT Air Quality & Noise Consulting Allegretto Resort Expansion Project March 2025
15 Table 8. SLOAPCD Thresholds of Significance for Project-Level Operational Impacts Pollutant Threshold(1)
Daily (lbs/day) Annual (tons/year)
Ozone Precursors [reactive organic gas (ROG) + oxides of nitrogen (NOX)]
25 25
Diesel Particulate Matter (DPM)(2) 1.25 --
Fugitive Particulate Matter (PM10), Dust 25 25
Carbon Monoxide (CO) 550 --
1. Daily and annual emissions thresholds are based on the California Health & Safety Code Division 26, Part 3, Chapter 10, Section 40918 and the ARB Carl Moyer Guidelines for DPM.
2. Applies to on-site emissions. DPM is seldom emitted from individual projects in quantities which lead to local or regional air quality attainment violations.
Source: SLOAPCD 2012
Toxic Air Contaminants
If a project has the potential to emit toxic or hazardous air pollutants or is located in close proximity to sensitive receptors, impacts may be considered significant due to increased cancer risk for the affected population, even at a very low level of emissions. For the evaluation of new proposed land use projects that generate TACs, such as diesel-fueled engines, the SLOAPCD has defined the excess cancer risk significance threshold at 10 in a million.
Localized CO Concentrations
Localized CO concentrations associated with the proposed project would be considered a less-thansignificant impact if: (1) Traffic generated by the proposed project would not result in deterioration of signalized intersection level of service (LOS) to LOS E or F; or (2) the project would not contribute additional traffic to a signalized intersection that already operates at LOS of E or F (Caltrans 1996).
Odors
Screening of potential odor impacts is typically recommended for the following two situations:
• Projects that would potentially generate odorous emissions proposed to locate near existing sensitive receptors or other land uses where people may congregate; and • Residential or other sensitive receptor projects or other projects that may attract people locating near existing odor sources.
If the proposed project would locate receptors and known odor sources within one mile of each other, a full analysis of odor impacts is recommended. Known odor sources of primary concern, as identified by the SLOAPCD include landfills, transfer stations, asphalt batch plants, rendering plants, petroleum refineries, and painting/coating operations, as well as, composting, food processing, wastewater treatment, chemical manufacturing, and feedlot/dairy facilities.
Methodology
Emissions associated with the construction of the proposed project were calculated using the California Emissions Estimator Model (CalEEMod), version 2022.1.1.29, computer program. Construction information, including construction phase durations, area of disturbance, and area to be paved was based on projectspecific information provided. No existing structure would be demolished. Additional construction information such as off-road equipment use, worker vehicle trips, and equipment load factors were based on default parameters contained in the model for San Luis Obispo County. Modeling assumptions and output files are included in Appendix A of this report.
Long-term operational emissions were calculated using the CalEEMod, version 2022.1.1.29 based, in part, on vehicle trip-generation rates derived from the traffic analysis prepared for this project (CCTC 2025). Vehicle travel distribution/distances were not available and were based on model defaults for San Luis Obispo County. Energy-saving features included as part of the proposed project were also included in the emissions modeling. Based on project-specific information provided, the project would include the installation of a solar photovoltaic (PV) energy system, which is estimated to provide approximately 1,267,700 kWh/year. The Exhibit C
Air Quality & Greenhouse Gas Impact Assessment AMBIENT Air Quality & Noise Consulting Allegretto Resort Expansion Project March 2025
16 project would also include the use of low-flow inline drip irrigation systems with “smart” controllers and flow sensors, which would reduce water use and associated electrical usage. The project would also include the installation of energy-efficient appliances and lighting, per current building code requirements. Emission modeling files are provided in Appendix A.
Project Impacts and Mitigation Measures
Impact AQ-A. Conflict with or obstruct implementation of the applicable air quality plan? SLOAPCD Clean Air Plan
As part of the CCAA, the SLOAPCD is required to develop a plan to achieve and maintain the state ozone standard by the earliest practicable date. The SLOAPCD’s 2001 Clean Air Plan addresses the attainment and maintenance of state and federal ambient air quality standards. The Clean Air Plan was adopted by SLOAPCD on March 26, 2002.
The SLOAPCD’s Clean Air Plan outlines the District's strategies to reduce ozone-precursor pollutants [i.e., reactive organic gas (ROG) and NOX] from a wide variety of sources. The SLOAPCD’s Clean Air Plan includes a stationary-source control program, which includes control measures for permitted stationary sources; as well as transportation and land use management strategies to reduce motor vehicle emissions and use. The stationary-source control program is administered by SLOAPCD. Transportation and land use control measures are implemented at the local or regional level, by promoting and facilitating the use of alternative transportation options, increased pedestrian access and accessibility to community services and local destinations, reductions in VMT, and promotion of congestion management efforts. In addition, local jurisdictions also prepare population forecasts, which are used by SLOAPCD to forecast population-related emissions and air quality attainment, including those contained in the SLOAPCD’s Clean Air Plan. As a result, consistency with the SLOAPCD’s Clean Air Plan has been evaluated based on the proposed project’s consistency with the land use management strategies and transportation control measures identified in the Clean Air Plan. This analysis also provides an analysis of regional vehicle miles traveled (VMT) and consistency with regional VMT-reduction efforts. Regional VMT estimates are relied upon for regional air quality planning purposes. Regional VMT and growth projections are used to determine the strategies to be implemented sufficient to reach the emission reduction targets set by the ARB through Senate Bill (SB) 375 which is transportation legislation that supports the broader 2030 emission reduction targets required in SB 32.
Transportation and Land Use Control Measures
The SLOAPCD’s Clean Air Plan includes multiple transportation and land use control measures intended to reduce emissions through reductions in VMT and the promotion of alternative forms of transportation.
Implementation of the proposed project would not result in increases in regional VMT. The proposed project would include pedestrian and bicycle improvements (CCTC 2025). In addition, Mitigation Measure GHG-1c would require CALGreen Tier 2 compliant electric vehicle (EV) charging stations to be “EV Ready” as opposed to “EV Capable”. These improvements would help to promote the use of alternative means of transportation, including the installation of alternative fueled vehicle infrastructure and bicycle use.
Projected Population, Employment & VMT Growth
According to the Regional Housing Needs Assessment, the City has about 14 percent more housing units than jobs, indicative of a “jobs-poor” community. The City’s jobs-to-housing ratio is estimated to improve from a year 2015 ratio of 0.87 to a 0.89 jobs-housing ratio by the year 2035 (SLOCOG 2019). The proposed project would result in increased employment and would not result in additional housing units. As a result, the proposed project would be anticipated to improve the jobs-housing balance.
For the reasons noted above, this impact would be considered less than significant.
Exhibit C
Air Quality & Greenhouse Gas Impact Assessment AMBIENT Air Quality & Noise Consulting Allegretto Resort Expansion Project March 2025
17 Particulate Matter Report – Implementation of SB 656 Requirements In July 2005, SLOAPCD adopted the Particulate Matter Report (PM Report). The PM Report identifies various measures and strategies to reduce public exposure to PM emitted from a wide variety of sources, including emissions from permitted stationary sources and fugitive sources, such as construction activities. As discussed in Impact AQ-B, uncontrolled fugitive dust generated during construction may result in localized pollutant concentrations that may result in increased nuisance concerns to nearby land uses. Therefore, constructiongenerated emissions of PM would be considered to have a potentially-significant impact with regard to air quality planning efforts.
Mitigation Measures
Implement Mitigation Measures AQ-1 through AQ-2 (refer to Impact AQ-B).
Significance After Mitigation
Implementation of Mitigation Measures AQ-1 and AQ-2 would include measures to reduce constructiongenerated emissions. Together these measures would help to reduce PM emissions and provide consistency with SLOAPCD’s airborne PM-reduction efforts. With mitigation, this impact would be considered less than significant.
Impact AQ-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?
Short-term Construction Emissions
Construction-generated emissions are of temporary duration, lasting only as long as construction activities occur, but have the potential to represent a significant air quality impact. Construction of the proposed project would result in the temporary generation of emissions associated with clearing, site prep, grading, building construction, paving, motor vehicle exhaust associated with construction equipment, and worker trips, as well as the movement of construction equipment on unpaved surfaces. Short-term construction emissions would result in increased emissions of ozone-precursor pollutants (i.e., ROG and NOX) and emissions of PM. Emissions of ozone-precursors would result from the operation of on- and off-road motorized vehicles and equipment. Emissions of airborne PM are largely dependent on the amount of ground disturbance associated with site preparation activities and can result in increased concentrations of PM that can adversely affect nearby sensitive land uses.
Estimated maximum daily and quarterly emissions associated with the construction of the proposed project are presented in Table 9 and Table 10, respectively. Construction-generated emissions were compared to SLOAPCD’s recommended significance thresholds (Daily, Quarterly Tier 1, and Quarterly Tier 2). As depicted in Table 9, the maximum daily emissions associated with project construction would total approximately 50.9 lbs/day of ROG+NOX and 0.7 lbs/day of PM2.5 exhaust. As depicted in Table 10, maximum quarterly construction-generated emissions would total approximately 2.7 tons/quarter of ROG+NOX, 0.3 tons/quarter of fugitive PM10 dust, and <0.1 tons/quarter of PM2.5 exhaust. A summary of unmitigated constructiongenerated emissions in comparison to SLOAPCD-recommended significance thresholds is provided in Table
11. Maximum daily construction emissions would not exceed SLOAPCD’s daily significance threshold. However, maximum quarterly construction emissions are predicted to exceed SLOAPCD’s quarterly significance threshold. Emissions would be largely a result of mobile-source emissions associated with construction vehicle and equipment operations anticipated to occur during the grading. If uncontrolled, fugitive dust generated during construction may also result in localized pollutant concentrations that could exceed ambient air quality standards and result in increased nuisance concerns to nearby land uses. For this reason, constructiongenerated emissions would be considered to have a potentially-significant impact.
Exhibit C
Air Quality & Greenhouse Gas Impact Assessment AMBIENT Air Quality & Noise Consulting Allegretto Resort Expansion Project March 2025
18 Table 9. Daily Construction Emissions without Mitigation Construction Activity
Maximum Daily Emissions (lbs/day)(1)
ROG NOX ROG+NOX CO
PM10 PM2.5
Exhaust Dust Total Exhaust Dust Total
Site Preparation 3.23 30.54 33.78 29.79 1.26 24.00 25.25 1.16 10.59 11.75 Grading 1.73 16.30 18.03 18.35 0.66 11.41 12.07 0.61 3.91 4.52 Construction-2026 1.38 11.04 12.42 15.64 0.39 0.61 1.00 0.36 0.15 0.51 Construction-2027 1.34 10.51 11.85 15.44 0.35 0.61 0.96 0.32 0.15 0.47 Architectural Coating 28.97 0.89 29.86 1.60 0.02 0.09 0.11 0.02 0.02 0.04 Paving 1.33 7.28 8.60 10.50 0.30 0.14 0.45 0.28 0.04 0.31 Maximum Daily Emissions(2) 31.7 19.2 50.9 27.7 0.7 0.8 1.6 0.7 0.2 0.9 SLOAPCD Daily Thresholds (pounds/day) -- -- 137 -- -- -- -- 7 -- -- Exceed SLOAPCD Thresholds? -- -- No -- -- -- -- No -- --
1. Emissions were quantified using the CalEEMod, v2022.1.1.29., computer program.
2. Maximum daily emissions assumes building construction, paving, and application of architectural coatings could potentially occur on the same day. lbs/day = pounds per day; ROG =Reactive Organic Gases; NOX = oxides of nitrogen; CO = carbon monoxide.
PM10 = respirable particulate matter (10 micrometers or less); PM2.5 = respirable particulate matter (2.5 micrometers or less) Refer to Appendix A for emissions modeling assumptions and results.
Table 10. Quarterly Construction Emissions without Mitigation Construction Quarter
Maximum Quarterly Emissions (tons)(1)
ROG NOx ROG+NOX
PM102 PM2.5
Exhaust Dust Total Exhaust Dust Total
Quarter 1 0.06 0.51 0.57 0.02 0.25 0.27 0.02 0.10 0.12
Quarter 2 0.20 0.36 0.56 0.01 0.02 0.03 0.01 0.01 0.02
Quarter 3 1.81 0.70 2.51 0.02 0.04 0.06 0.02 0.01 0.03
Quarter 4 1.97 0.76 2.73 0.03 0.05 0.08 0.02 0.01 0.03
Quarter 5 0.33 0.11 0.44 <0.01 <0.01 0.01 <0.01 <0.01 <0.01 Maximum Quarterly Emissions: -- -- 2.7 -- 0.3 -- 0.02 -- -- SLOAPCD Quarterly Tier 1/Tier 2 Thresholds (tons/quarter) -- -- 2.5/6.3 -- 2.5/None -- 0.13/0.32 -- -- Exceed SLOAPCD Tier 1/Tier 2 Thresholds? -- -- Yes/No -- No/-- -- No/No -- -- Maximum Quarterly Emissions: Based on construction schedule information provided and default assumptions contained in the CalEEMod computer model. Totals may not sum due to rounding. Refer to Appendix A for modeling assumptions and results.
1. Maximum quarterly emissions include on-site and off-site emissions.
Exhibit C
Air Quality & Greenhouse Gas Impact Assessment AMBIENT Air Quality & Noise Consulting Allegretto Resort Expansion Project March 2025
19 Table 11. Summary of Construction Emissions without Mitigation Criteria
Project
Emissions
(lbs/day)
SLOAPCD Significance
Threshold
Exceeds
Significance
Threshold?
Maximum Daily Emissions of ROG+NOX 50.9 137 lbs/day No
Maximum Daily Emissions of PM2.5 Exhaust 0.7 7 lbs/day No (tons/quarter) Tier 1 Tier 2 Tier 1 Tier 2
Maximum Quarterly Emissions of ROG+NOX 2.7 2.5
tons/quarter
6.3 tons/quarter Yes No
Maximum Quarterly Emissions of PM10 Dust 0.3
2.5 tons/quarter None No No
Maximum Quarterly Emissions of PM2.5 Exhaust 0.02 0.13
tons/quarter
0.32 tons/quarter No No
Refer to Appendix A for modeling assumptions and results.
Exhibit C
Air Quality & Greenhouse Gas Impact Assessment AMBIENT Air Quality & Noise Consulting Allegretto Resort Expansion Project March 2025
20 Mitigation Measures
AQ-1: The following mitigation measures shall be implemented to reduce construction-generated fugitive dust. These measures shall be shown on grading and building plans. a. Reduce the amount of disturbed areas where possible. b. Use water trucks, SLOAPCD-approved dust suppressants (see Section 4.3 in the CEQA Air Quality Handbook), or sprinkler systems in sufficient quantities to prevent airborne dust from leaving the site and from exceeding the District’s limit of 20 percent opacity for greater than 3 minutes in any 60-minute period. Increased watering frequency would be required whenever wind speeds exceed 15 mph. Reclaimed (non-potable) water should be used whenever possible. Please note that since water use is a concern due to drought conditions, the contractor or builder shall consider the use of an APCD-approved dust suppressant where possible to reduce the amount of water used for dust control. For a list of suppressants, see Section 4.3 of the CEQA Air Quality Handbook.
c. All dirt stockpile areas should be sprayed daily or covered with tarps or other dust barriers as needed.
d. All roadways, driveways, sidewalks, etc. to be paved should be completed as soon as possible.
In addition, building pads should be laid as soon as possible after grading unless seeding or soil binders are used.
e. All trucks hauling dirt, sand, soil, or other loose materials are to be covered or should maintain at least two feet of freeboard (minimum vertical distance between the top of load and top of trailer) in accordance with California Vehicle Code (CVC) Section 23114. f. “Track-Out” is defined as sand or soil that adheres to and/or agglomerates on the exterior surfaces of motor vehicles and/or equipment (including tires) that may then fall onto any highway or street as described in CVC Section 23113 and California Water Code 13304. To prevent ‘track out’, designate access points and require all employees, subcontractors, and others to use them. Install and operate a ‘track-out prevention device’ where vehicles enter and exit unpaved roads onto paved streets. The ‘track-out prevention device’ can be any device or combination of devices that are effective at preventing track out, located at the point of intersection of an unpaved area and a paved road. Rumble strips or steel plate devices need periodic cleaning to be effective. If paved roadways accumulate tracked out soils, the trackout prevention device may need to be modified. g. Permanent dust control measures identified in the approved project revegetation and landscape plans should be implemented as soon as possible following completion of any soil disturbing activities.
h. Exposed ground areas that are planned to be reworked at dates greater than one month after initial grading should be sown with a fast germinating, non-invasive grass seed and watered until vegetation is established.
i. All disturbed soil areas not subject to revegetation should be stabilized using approved chemical soil binders, jute netting, or other methods approved in advance by the SLOAPCD. j. Vehicle speed for all construction vehicles shall not exceed 15 mph on any unpaved surface at the construction site.
k. Sweep streets at the end of each day if visible soil material is carried onto adjacent paved roads.
Water sweepers with reclaimed water should be used where possible. Roads shall be pre-wetted prior to sweeping when possible.
l. The burning of vegetative material shall be prohibited. Effective February 25, 2000, SLOAPCD prohibited developmental burning of vegetative material within San Luis Obispo County. If you have any questions regarding these requirements, contact the SLOAPCD Engineering & Compliance Division at (805) 781-5912.
m. The contractor or builder shall designate a person or persons to monitor the fugitive dust emissions and enhance the implementation of the measures as necessary to minimize dust complaints, reduce visible emissions below 20 percent opacity, and to prevent the transport of dust off-site. Their duties shall include holidays and weekend periods when work may not be in progress. The name and telephone number of such persons shall be provided to the SLOAPCD Compliance Division prior to the start of any grading, earthwork, or demolition.
Exhibit C
Air Quality & Greenhouse Gas Impact Assessment AMBIENT Air Quality & Noise Consulting Allegretto Resort Expansion Project March 2025
21 AQ-2: The following measures shall be implemented to reduce construction emissions from on and off-road construction equipment (NOx, ROG, and DPM) and area sources. These measures shall be shown on grading and building plans:
a. Maintain all construction equipment in proper tune according to manufacturer’s specifications. b. Fuel all off-road and portable diesel-powered equipment with ARB-certified motor vehicle diesel fuel (non-taxed version suitable for use off-road).
c. To the extent locally available, heavy-duty (50 horsepower or greater) diesel-fueled, off-road construction equipment shall meet Tier 4 emissions standards. d. When applicable, portable equipment, 50 horsepower (hp) or greater, used during construction activities shall be registered with the California statewide portable equipment registration program (issued by the California Air Resources Board) or be permitted by the APCD. Such equipment may include power screens, conveyors, internal combustion engines, crushers, portable generators, tub grinders, trammel screens, and portable plants (e.g, aggregate plant, asphalt plant, concrete plant). For more information, contact the SLOAPCD Engineering & Compliance Division at (805) 781-5912.
e. Use on-road heavy-duty trucks that meet the ARB’s 2010 or cleaner certification standard for onroad heavy-duty diesel engines, and comply with the State On-Road Regulation. f. All on and off-road diesel equipment shall not idle when not in use. Signs shall be posted in the designated queuing areas and or job sites to remind drivers and operators of the 5-minute idling limit.
g. Construction equipment staging areas shall be located at the furthest distance possible from nearby residential land uses.
h. To the extent locally available, electrified, or alternatively powered construction equipment shall be used.
i. Substitute gasoline-powered in place of diesel-powered equipment, where possible; and, j. Use alternative-fueled construction equipment on-site where possible, such as compressed natural gas (CNG), liquefied natural gas (LNG), propane, or biodiesel. k. Construction of the proposed project shall use low-VOC content paints not exceeding 50 grams per liter.
l. To the extent locally available, use prefinished building materials or materials that do not require the application of architectural coatings.
m. Meet or exceed Cal Green Tier 2 standards for reducing cement use in concrete mix as allowed by local ordinance and conditions.
Significance After Mitigation
Implementation of Mitigation Measures AQ-1 and AQ-2 include SLOAPCD-recommended standard and best available control measures to reduce construction-generated emissions of fugitive dust, mobile-source emissions associated with construction vehicles and equipment, and evaporative emissions from architectural coasting (e.g. low VOC-emission paint). Mitigated quarterly construction emissions are presented in Table 12. With mitigation, project-generated construction emissions would not exceed applicable significance thresholds and would be considered less than significant.
Exhibit C
Air Quality & Greenhouse Gas Impact Assessment AMBIENT Air Quality & Noise Consulting Allegretto Resort Expansion Project March 2025
22 Table 12. Quarterly Construction Emissions with Mitigation Construction Quarter
Maximum Quarterly Emissions (tons)(1)
ROG NOx ROG+NOX
PM102 PM2.5
Exhaust Dust Total Exhaust Dust Total
Quarter 1 0.02 0.13 0.15 <0.01 0.08 0.08 <0.01 0.03 0.03 Quarter 2 0.18 0.14 0.32 <0.01 0.02 0.02 <0.01 0.01 0.01 Quarter 3 1.77 0.29 2.06 0.01 0.04 0.05 0.01 0.01 0.02
Quarter 4 1.93 0.32 2.25 0.01 0.05 0.06 0.01 0.01 0.02
Quarter 5 0.32 0.04 0.36 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Maximum Quarterly Emissions: -- -- 2.3 -- 0.1 -- 0.01 -- -- SLOAPCD Quarterly Tier 1/Tier 2 Thresholds
(tons/quarter) -- -- 2.5/6.3 -- 2.5/None -- 0.13/0.32 -- -- Exceed SLOAPCD Tier 1/Tier 2 Thresholds? -- -- No/No -- No/-- -- No/No -- -- Maximum Quarterly Emissions: Based on construction schedule information provided and default assumptions contained in the CalEEMod computer model. Totals may not sum due to rounding.
Refer to Appendix A for modeling assumptions and results.
1. Maximum quarterly emissions include on-site and off-site emissions.
2. Includes use of dust control measures, Tier 4 heavy-duty off-road equipment, and low-VOC paints.
Exhibit C
Air Quality & Greenhouse Gas Impact Assessment AMBIENT Air Quality & Noise Consulting Allegretto Resort Expansion Project March 2025
23 Long-term Operational Emissions
Long-term operational emissions associated with the proposed project would be predominantly associated with mobile sources and area sources, such as landscape maintenance activities.
Unmitigated operational emissions associated with the proposed project are summarized in Table 13. As depicted, daily operational emissions would total approximately 15.6 lbs/day of ROG+NOX, 31.2 lbs/day of CO, 3.6 lbs/day of fugitive PM10 dust, and 0.3 lbs/day of PM2.5 exhaust. Annual operational emissions would total approximately 2.7 tons/year of ROG+NOx and 0.6 tons/year of fugitive PM10 dust. Predicted operational emissions would exceed SLOAPCD’s recommended ROG+NOx threshold. As a result, this impact would be considered potentially significant.
Health Effects of Project-Generated Regional Emissions
Project-generated emissions are evaluated based on the pollutants' potential to affect local or regional air quality. As noted earlier in this report, regional pollutants of concern typically include ozone and particulate matter. Whereas, for development projects, localized pollutants of primary concern often include carbon monoxide, TACs, as well as airborne particulates. The health effects of these pollutants are discussed earlier in this report and summarized in Table 1.
For localized pollutants, health impacts can be evaluated using screening criteria or through dispersion modeling. However, for regional pollutants such as ozone, the change in health effects associated with an individual project is a secondary pollutant created by NOX and ROG (also commonly referred to as VOCs).
As previously discussed earlier in this report, ozone is not a directly emitted pollutant. NOX and ROG are not criteria air pollutants but, when in the presence of sunlight, they can form ozone and also contribute to the formation of secondary PM2.5. Because ozone is not a directly emitted pollutant and is created under specific meteorological conditions over a wide transport area, ozone concentrations are typically evaluated at a regional level using complex photochemical models. These models are capable of predicting concentrations that take into account variations in amounts of precursor emissions (e.g., ROG, NOX), temperature, inversions, sunlight, hourly variations, ambient conditions, and wind flow over long distances (e.g., miles). At the project level of analysis, evaluation of ozone concentrations is “not practicable and not likely [to] yield valid information” (SJVAPCD 2015).
Of the criteria pollutants identified, ozone and PM2.5 have the most critical health effects. As a result, concentrations of these pollutants are typically relied upon for determining public health effects. In comparison to modeled regional emissions, the emissions associated with most individual projects would be negligible and too small to produce a measurable change in regional ozone or PM2.5 concentrations or associated public health effects. In addition, the Sacramento Metropolitan Air Quality Management District (SMAQMD) has recently conducted regional emissions modeling analyses using a chemical transport model to evaluate changes in emissions and associated health effects associated with an individual project. The modeling was based on very conservative assumptions representative of the largest projects, which assumed up to approximately eight times the threshold of significance (up to 656 lbs/day) of NOX, ROG, and PM. This level of emissions would be more representative of large community plan projects. Based on the modeling conducted by SMAQMD, even these large projects would have “low overall health effects” (SMAQMD 2020).
It is important to reiterate that the health effects of criteria air pollutants are taken into consideration when the U.S., EPA establishes the NAAQS for individual pollutants. The health effects of a particular pollutant are analyzed on a regional basis based on the area’s attainment of the NAAQS. As previously discussed in this report, the AQI is one common method of evaluating public health impacts for criteria air pollutants of primary concern. Local air districts establish significance thresholds that are based on the evaluation of an individual project’s contribution to regional air quality conditions and associated health effects. Based on the above discussion and given that project-generated criteria pollutants would exceed applicable significance thresholds, Project-generated emissions of regional criteria pollutants (e.g., ROG, NOX, PM) could have an effect on public health. Refer to Impact AQ-C for a discussion of localized air quality impacts.
Exhibit C
Air Quality & Greenhouse Gas Impact Assessment AMBIENT Air Quality & Noise Consulting Allegretto Resort Expansion Project March 2025
24 Table 13. Operational Emissions without Mitigation
Operational Source
Emissions(1)
ROG NOX ROG+NOX CO
PM10 PM2.5
Exhaust Dust Total Exhaust Dust Total
Daily Emissions (lbs/day)
Mobile(2) 5.56 2.80 8.36 21.8 0.04 3.61 3.65 0.04 0.92 0.96 Area 5.57 0.07 5.64 8.07 0.01 >0.01 0.01 0.11 >0.01 0.11 Energy(3) 0.08 1.47 1.55 1.24 0.11 >0.01 0.11 0.11 >0.01 0.11 Total Daily Emissions: 11.2 4.4 15.6 31.2 0.2 3.6 3.8 0.3 0.9 1.1 SLOAPCD Significance Thresholds -- -- 25 550 -- 25 -- 1.25 -- -- Exceeds SLOAPCD Thresholds? -- -- No No -- No -- No -- -- Annual Emissions (tons/year)
Total Annual Emissions(4): 2.0 0.8 2.8 5.5 0.03 0.6 0.6 0.03 0.2 0.2 SLOAPCD Significance Thresholds -- -- 25 -- -- 25 -- -- -- -- Exceeds SLOAPCD Thresholds? -- -- No -- -- No -- -- -- -- Note: Based on operational year 2025. Totals may not sum due to rounding. Refer to Appendix A for modeling output files and assumptions.
1. Daily emissions are based on the worst case between summer and winter buildout operational conditions.
2. Mobile emissions were based on trip-generation rates derived from the traffic analysis prepared for this project and CalEEMod default fleet mix and trip distances.
3. Includes consistency with current building standards related to the use of energy-efficient mechanical equipment/appliances and water-efficient irrigation systems.
4. Annual emissions were derived from the CalEEMod modeling.
Exhibit C
Air Quality & Greenhouse Gas Impact Assessment AMBIENT Air Quality & Noise Consulting Allegretto Resort Expansion Project March 2025
25 Impact AQ-C. Expose sensitive receptors to substantial pollutant concentrations? The proposed project would not result in the installation of any equipment or processes that would be considered a major emission source. However, the proposed project would result in localized increases in pollutant concentrations during project construction. The proposed project’s potential contribution to localized air pollutants is discussed, as follows:
Short-Term Construction Activities
Naturally-Occurring Asbestos
NOA has been identified as a TAC by the ARB. In accordance with ARB’s Air Toxics Control Measure (ATCM), prior to any grading activities, a geologic evaluation should be conducted to determine if NOA is present within the area that will be disturbed. If NOA is not present, an exemption request form, along with a copy of the geologic report, must be filed with the SLOAPCD. If NOA is found at the site, the applicant must comply with all requirements outlined in the Asbestos ATCM (SLOAPCD 2018).
Based on a review of the SLOAPCD’s map depicting potential areas of NOA, the project site is not located in or near an area that has been identified as having a potential for NOA. As a result, this impact would be considered less than significant.
Localized Construction PM Concentrations
Fugitive dust emissions would be primarily associated with site preparation, grading, and vehicle travel on unpaved and paved surfaces. On-site off-road equipment and trucks would also result in short-term emissions of DPM, which could contribute to elevated localized concentration at nearby receptors. Uncontrolled emissions of fugitive dust may also contribute to potential increases in nuisance impacts to nearby receptors.
Short-term exposure to airborne particulates can result in irritation of the eyes and the respiratory system and may affect sensitive individuals, including those suffering from asthma and other medical conditions. For these reasons, localized uncontrolled concentrations of construction-generated PM would be considered to have a potentially-significant impact.
Mitigation Measures
Implement Mitigation Measures AQ-1 and AQ-2.
Significance After Mitigation
With the implementation of Mitigation Measures AQ-1 and AQ-2 construction-related emissions of PM would be substantially reduced. With mitigation, short-term exposure to localized pollutants would be considered to have a less-than-significant impact.
Impact AQ-D. Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
The occurrence and severity of odor impacts depend on numerous factors, including the nature, frequency, and intensity of the source; wind speed and direction; and the sensitivity of the receptors. While offensive odors rarely cause any physical harm, they still can be very unpleasant, leading to considerable distress among the public and often generating citizen complaints to local governments and regulatory agencies.
Projects with the potential to frequently expose members of the public to objectionable odors would be deemed to have a significant impact.
The proposed project would not result in the installation of any equipment or processes that would be considered major odor-emission sources. In addition, no known odor sources are within one mile of the project site. However, construction of the proposed project would involve the use of a variety of gasoline or diesel-powered equipment that would emit exhaust fumes. Exhaust fumes, particularly diesel exhaust, may be considered objectionable by some people. In addition, pavement coatings and architectural coatings used during project construction would also emit temporary odors. However, construction-generated emissions would occur intermittently throughout the workday and would dissipate rapidly with increasing Exhibit C
Air Quality & Greenhouse Gas Impact Assessment AMBIENT Air Quality & Noise Consulting Allegretto Resort Expansion Project March 2025
26 distance from the source. Mitigation measures, such as the implementation of idling restrictions for construction equipment and vehicles and the use of newer, cleaner equipment and vehicles would further reduce construction-generated emissions. For these reasons, short-term construction activities would not expose a substantial number of people to frequent odorous emissions. For these reasons, potential exposure of sensitive receptors to odorous emissions would be considered less than significant.
Exhibit C
Air Quality & Greenhouse Gas Impact Assessment AMBIENT Air Quality & Noise Consulting Allegretto Resort Expansion Project March 2025
27 GREENHOUSE GASES AND CLIMATE CHANGE
Existing Setting
To fully understand global climate change, it is important to recognize the naturally occurring “greenhouse effect” and to define the GHGs that contribute to this phenomenon. Various gases in the earth’s atmosphere, classified as atmospheric GHGs, play a critical role in determining the earth’s surface temperature. Solar radiation enters the Earth’s atmosphere from space and a portion of the radiation is absorbed by the Earth’s surface. The earth emits this radiation back toward space, but the properties of the radiation change from high-frequency solar radiation to lower-frequency infrared radiation. GHGs, which are transparent to solar radiation, are effective in absorbing infrared radiation. As a result, this radiation that otherwise would have escaped back into space is now retained, resulting in a warming of the atmosphere. This phenomenon is known as the greenhouse effect. Among the prominent GHGs contributing to the greenhouse effect are carbon dioxide, methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride.
Primary GHGs attributed to global climate change, are discussed, as follows:
• Carbon Dioxide. Carbon dioxide (CO2) is a colorless, odorless gas. CO2 is emitted in a number of ways, both naturally and through human activities. The largest source of CO2 emissions globally is the combustion of fossil fuels such as coal, oil, and gas in power plants, automobiles, industrial facilities, and other sources. A number of specialized industrial production processes and product uses such as mineral production, metal production, and the use of petroleum-based products can also lead to CO2 emissions. The atmospheric lifetime of CO2 is variable because it is so readily exchanged in the atmosphere (U.S. EPA 2018).
• Methane. Methane (CH4) is a colorless, odorless gas that is not flammable under most circumstances.
CH4 is the major component of natural gas, about 87 percent by volume. It is also formed and released to the atmosphere by biological processes occurring in anaerobic environments. Methane is emitted from a variety of both human-related and natural sources. Human-related sources include fossil fuel production, animal husbandry (enteric fermentation in livestock and manure management), rice cultivation, biomass burning, and waste management. These activities release significant quantities of CH4 into the atmosphere. Natural sources of methane include wetlands, gas hydrates, permafrost, termites, oceans, freshwater bodies, non-wetland soils, and other sources such as wildfires. Methane’s atmospheric lifetime is about 12 years (U.S. EPA 2018). • Nitrous Oxide. Nitrous oxide (N2O) is a clear, colorless gas with a slightly sweet odor. N2O is produced by both natural and human-related sources. Primary human-related sources of N2O are agricultural soil management, animal manure management, sewage treatment, mobile and stationary combustion of fossil fuels, acid production, and nitric acid production. N2O is also produced naturally from a wide variety of biological sources in soil and water, particularly microbial action in wet tropical forests. The atmospheric lifetime of N2O is approximately 114 years (U.S. EPA 2018). • Hydrofluorocarbons. Hydrofluorocarbons (HFCs) are man-made chemicals, many of which have been developed as alternatives to ozone-depleting substances for industrial, commercial, and consumer products. The only significant emissions of HFCs before 1990 were of the chemical HFC-23, which is generated as a byproduct of the production of HCFC-22 (or Freon 22, used in air conditioning applications). The atmospheric lifetime for HFCs varies from just over a year for HFC152a to 270 years for HFC-23. Most of the commercially used HFCs have atmospheric lifetimes of less than 15 years (e.g., HFC-134a, which is used in automobile air conditioning and refrigeration, has an atmospheric life of 14 years) (U.S. EPA 2018).
• Perfluorocarbons. Perfluorocarbons (PFCs) are colorless, highly dense, chemically inert, and nontoxic. There are seven PFC gases: perfluoromethane (CF4), perfluoroethane (C2F6), perfluoropropane (C3F8), perfluorobutane (C4F10), perfluorocyclobutane (C4F8), perfluoropentane (C5F12), and perfluorohexane (C6F14). Natural geological emissions have been responsible for the PFCs that have accumulated in the atmosphere in the past; however, the largest current source is aluminum production, which releases CF4 and C2F6 as byproducts. The estimated atmospheric lifetimes for PFCs ranges from 2,600 to 50,000 years (U.S. EPA 2018).
Exhibit C
Air Quality & Greenhouse Gas Impact Assessment AMBIENT Air Quality & Noise Consulting Allegretto Resort Expansion Project March 2025
28 • Nitrogen Trifluoride. Nitrogen trifluoride (NF3) is an inorganic, colorless, odorless, toxic, nonflammable gas used as an etchant in microelectronics. NF3 is predominantly employed in the cleaning of the plasma-enhanced chemical vapor deposition chambers in the production of liquid crystal displays and silicon-based thin-film solar cells. It has a global warming potential of 16,100 CO2e. While NF3 may have a lower global warming potential than other chemical etchants, it is still a potent GHG. In 2009, NF3 was listed by California as a high (global warming potential) GWP GHG to be listed and regulated under AB 32 (Section 38505 Health and Safety Code). • Sulfur Hexafluoride. Sulfur hexafluoride (SF6) is an inorganic compound that is colorless, odorless, nontoxic, and generally non-flammable. SF6 is primarily used as an electrical insulator in high-voltage equipment. The electric power industry uses roughly 80 percent of all SF6 produced worldwide. Leaks of SF6 occur from aging equipment and during equipment maintenance and servicing. SF6 has an atmospheric life of 3,200 years (U.S. EPA 2018).
• Black Carbon. Black carbon is the strongest light-absorbing component of PM emitted from burning fuels such as coal, diesel, and biomass. Black carbon contributes to climate change both directly by absorbing sunlight and indirectly by depositing on snow and by interacting with clouds and affecting cloud formation. Black carbon is considered a short-lived species, which can vary spatially and, consequently, it is very difficult to quantify associated global warming potentials. The main sources of black carbon in California are wildfires, off-road vehicles (locomotives, marine vessels, tractors, excavators, dozers, etc.), on-road vehicles (cars, trucks, and buses), fireplaces, agricultural waste burning, and prescribed burning (planned burns of forest or wildlands) (U.S. EPA 2018).
Each GHG differs in its ability to absorb heat in the atmosphere based on the lifetime, or persistence, of the gas molecule in the atmosphere. Often, estimates of GHG emissions are presented in CO2e, which weighs each gas by its global warming potential (GWP). Expressing GHG emissions in CO2e takes the contribution of all GHG emissions to the greenhouse effect and converts them to a single unit equivalent to the effect that would occur if only CO2 were being emitted. Table 14 provides a summary of the GWP for GHG emissions of typical concern with regard to community development projects, based on a 100-year time horizon. As indicated, Methane traps over 25 times more heat per molecule than CO2, and N2O absorbs roughly 298 times more heat per molecule than CO2. Additional GHGs with high GWP include NF3, SF6, PFCs, and black carbon.
Table 14. Global Warming Potential for Greenhouse Gases Greenhouse Gas Global Warming Potential (100-year)
Carbon Dioxide (CO2) 1
Methane (CH4) 25
Nitrous Dioxide (N2O) 298
Based on IPCC GWP values for 100-year time horizon.
Source: IPCC 2007
Statewide GHG Emissions
In 2019, GHG emissions within California totaled 418.1 MMT of CO2e. GHG emissions, by sector, are summarized in Figure 3. Within California, the transportation sector is the largest contributor, accounting for approximately 39.7 percent of the total state-wide GHG emissions. Emissions associated with industrial uses are the second-largest contributor, totaling roughly 21.1 percent. Electricity generation totaled roughly 14.1 percent. Other major emission sources included commercial uses, residential uses, agriculture, refrigerants, and waste (ARB 2021).
Exhibit C
Air Quality & Greenhouse Gas Impact Assessment AMBIENT Air Quality & Noise Consulting Allegretto Resort Expansion Project March 2025
29 Figure 3. California GHG Emissions Inventory by Sector & Subsector (2019) Source: ARB 2021
City of Paso Robles GHG Emissions Inventories
The City has completed a community-wide inventory of GHG emissions for the years 2005 and 2020, which are summarized in Table 15. As shown, a majority of the City’s emissions are associated with mobile sources.
Remaining GHG emissions are predominantly associated with energy use and solid waste generation. In comparison to year 2005 community-wide emissions, year 2016 metric tons (MT)CO2e emissions decreased by a total of approximately 20 percent (City of Paso Robles 2013).
Table 15. City of Paso Robles GHG Emissions Inventories Sector
Year 2005
(MTCO2e)
Year 2020
(MTCO2e)
Percent Change from
2005 to 2020
Residential 40,188 46,828 17%
Commercial/Industrial 33,536 30,551 -9%
Transportation 67,801 92,913 37%
Off-Road 13,205 15,878 20%
Solid Waste 13,343 16,653 17%
Wastewater 70 82 17%
Aircraft 1,324 1,543 17%
Total 169,557 203,448 20%
MTCO2e = Metric tons of carbon dioxide equivalent
Source: City of Paso Robles Climate Action Plan 2013
Exhibit C
Air Quality & Greenhouse Gas Impact Assessment AMBIENT Air Quality & Noise Consulting Allegretto Resort Expansion Project March 2025
30 Short-Lived Climate Pollutants
Short-lived climate pollutants (SLCPs), such as black carbon, fluorinated gases, and methane also have a dramatic effect on climate change. Though short-lived, these pollutants create a warming influence on the climate that is many times more potent than that of carbon dioxide.
As part of the ARB’s efforts to address SLCPs, the ARB has developed a statewide emission inventory for black carbon. The black carbon inventory will help support the implementation of the SLCP Strategy, but it is not part of the State’s GHG Inventory that tracks progress towards the State’s climate targets. The most recent inventory for year 2013 conditions is depicted in Figure 4. As depicted, off-road mobile sources account for a majority of black carbon emissions totaling roughly 36 percent of the inventory. Other major anthropogenic sources of black carbon include on-road transportation, residential wood burning, fuel combustion, and industrial processes (ARB 2020).
Figure 4. California Black Carbon Emissions Inventory (Year 2013) Source: ARB 2020
Effects of Global Climate Change
There are uncertainties as to exactly what the climate changes will be in various local areas of the earth.
There are also uncertainties associated with the magnitude and timing of other consequences of a warmer planet: sea-level rise, the spread of certain diseases out of their usual geographic range, the effect on agricultural production, water supply, sustainability of ecosystems, increased strength and frequency of storms, extreme heat events, increased air pollution episodes, and the consequence of these effects on the economy.
Within California, climate changes would likely alter the ecological characteristics of many ecosystems throughout the state. Such alterations would likely include increases in surface temperatures and changes in the form, timing, and intensity of precipitation. For instance, historical records depict an increasing trend toward earlier snowmelt in the Sierra Nevada. This snowpack is a principal supply of water for the state, providing roughly 50 percent of the state’s annual runoff. If this trend continues, some areas of the state may experience an increased danger of floods during the winter months and possible exhaustion of the snowpack during the spring and summer months. Earlier snowmelt would also impact the State’s energy resources.
Currently, approximately 20 percent of California's electricity comes from hydropower. Early exhaustion of the Sierra snowpack may force electricity producers to switch to more costly or non-renewable forms of electricity generation during the spring and summer months. A changing climate may also impact agricultural crop yields, coastal structures, and biodiversity. As a result, changes in climate will likely have detrimental effects on some of California’s largest industries, including agriculture, wine, tourism, skiing, recreational and commercial fishing, and forestry.
Exhibit C
Air Quality & Greenhouse Gas Impact Assessment AMBIENT Air Quality & Noise Consulting Allegretto Resort Expansion Project March 2025
31 Regulatory Framework
Federal
EXECUTIVE ORDER 13514
Executive Order (EO) 13514 is focused on reducing GHGs internally in federal agency missions, programs, and operations. In addition, the executive order directs federal agencies to participate in the Interagency Climate Change Adaptation Task Force, which is engaged in developing a national strategy for adaptation to climate change.
On April 2, 2007, in Massachusetts v. U.S. EPA, 549 U.S. 497 (2007), the Supreme Court found that GHGs are air pollutants covered by the FCAA, and that the U.S. EPA has the authority to regulate GHG. The Court held that the U.S. EPA Administrator must determine whether or not emissions of GHGs from new motor vehicles cause or contribute to air pollution which may reasonably be anticipated to endanger public health or welfare, or whether the science is too uncertain to make a reasoned decision.
On December 7, 2009, the U.S. EPA Administrator signed two distinct findings regarding GHGs under section 202(a) of the Clean Air Act:
• Endangerment Finding: The Administrator found that the current and projected concentrations of the six key well-mixed GHGs (CO2, CH4, N2O, HFCs, PFCs, and SF6) in the atmosphere threaten the public health and welfare of current and future generations. • Cause or Contribute Finding: The Administrator found that the combined emissions of these wellmixed GHGs from new motor vehicles and new motor vehicle engines contribute to the GHG pollution which threatens public health and welfare.
Although these findings did not themselves impose any requirements on industry or other entities, this action was a prerequisite to finalizing the U.S. EPA’s Proposed Greenhouse Gas Emission Standards for Light-Duty Vehicles, which was published on September 15, 2009. On May 7, 2010, the final Light-Duty Vehicle Greenhouse Gas Emissions Standards and Corporate Average Fuel Economy Standards were published in the Federal Register.
The U.S. EPA and the National Highway Traffic Safety Administration (NHTSA) are taking coordinated steps to enable the production of a new generation of clean vehicles with reduced GHG emissions and improved fuel efficiency from on-road vehicles and engines. These next steps include developing the first-ever GHG regulations for heavy-duty engines and vehicles, as well as additional light-duty vehicle GHG regulations.
These steps were outlined by President Obama in a Presidential Memorandum on May 21, 2010.
The final combined U.S. EPA and NHTSA standards that make up the first phase of this national program apply to passenger cars, light-duty trucks, and medium-duty passenger vehicles, covering model years 2012 through 2016. The standards require these vehicles to meet an estimated combined average emissions level of 250 grams of CO2 per mile (the equivalent to 35.5 miles per gallon if the automobile industry were to meet this CO2 level solely through fuel economy improvements). Together, these standards will cut GHG emissions by an estimated 960 MMT and 1.8 billion barrels of oil over the lifetime of the vehicles sold under the program (model years 2012-2016). On August 28, 2012, U.S. EPA and NHTSA issued their joint rule to extend this national program of coordinated GHG and fuel economy standards to model years 2017 through 2025 passenger vehicles.
State
EXECUTIVE ORDER NO. S-3-05
EO S-3-05 (State of California) proclaims that California is vulnerable to the impacts of climate change. It declares that increased temperatures could reduce the Sierra’s snowpack, further exacerbate California’s air quality problems, and potentially cause a rise in sea levels. To combat those concerns, the Executive Order established total GHG emission targets. Specifically, emissions are to be reduced to the 2000 level by 2010, to the 1990 level by 2020, and to 80 percent below the 1990 level by 2050.
Exhibit C
Air Quality & Greenhouse Gas Impact Assessment AMBIENT Air Quality & Noise Consulting Allegretto Resort Expansion Project March 2025
32 The EO directed the secretary of the California Environmental Protection Agency (CalEPA) to coordinate a multi-agency effort to reduce GHG emissions to the target levels. The secretary will also submit biannual reports to the governor and state legislature describing (1) progress made toward reaching the emission targets, (2) impacts of global warming on California’s resources, and (3) mitigation and adaptation plans to combat these impacts. To comply with the EO, the secretary of CalEPA created a Climate Action Team made up of members from various state agencies and commissions. The Climate Action Team released its first report in March 2006 and continues to release periodic reports on progress. The report proposed to achieve the targets by building on voluntary actions of California businesses, local government, and community actions, as well as through state incentives and regulatory programs.
ASSEMBLY BILL 32 - CALIFORNIA GLOBAL WARMING SOLUTIONS ACT OF 2006 AB 32 (Health and Safety Code Sections 38500, 38501, 28510, 38530, 38550, 38560, 38561–38565, 38570, 38571, 38574, 38580, 38590, 38592–38599) requires that statewide GHG emissions be reduced to 1990 levels by the year 2020. The gases that are regulated by AB 32 include CO2, CH4, N2O, HFCs, PFCs, NF3, and SF6. The reduction to 1990 levels will be accomplished through an enforceable statewide cap on GHG emissions that will be phased in starting in 2012. To effectively implement the cap, AB 32 directs ARB to develop and implement regulations to reduce statewide GHG emissions from stationary sources. AB 32 specifies that regulations adopted in response to AB 1493 should be used to address GHG emissions from vehicles.
However, AB 32 also includes language stating that if the AB 1493 regulations cannot be implemented, then ARB should develop new regulations to control vehicle GHG emissions under the authorization of AB 32.
AB 32 requires that ARB adopt a quantified cap on GHG emissions representing 1990 emissions levels and disclose how it arrives at the cap, institute a schedule to meet the emissions cap, and develop tracking, reporting, and enforcement mechanisms to ensure that the state achieves reductions in GHG emissions necessary to meet the cap. AB 32 also includes guidance to institute emissions reductions in an economically efficient manner and conditions to ensure that businesses and consumers are not unfairly affected by the reductions.
CLIMATE CHANGE SCOPING PLAN
In October 2008, ARB published its Climate Change Proposed Scoping Plan, which is the State’s plan to achieve GHG reductions in California required by AB 32. This initial Scoping Plan contained the main strategies to be implemented in order to achieve the target emission levels identified in AB 32. The Scoping Plan included ARB-recommended GHG reductions for each emissions sector of the state’s GHG inventory.
The largest proposed GHG reduction recommendations were associated with improving emissions standards for light-duty vehicles, implementing the Low Carbon Fuel Standard program, implementing energy efficiency measures in buildings and appliances, the widespread development of combined heat and power systems, and developing a renewable portfolio standard for electricity production.
The Scoping Plan states that land use planning and urban growth decisions will play important roles in the state’s GHG reductions because local governments have primary authority to plan, zone, approve, and permit how land is developed to accommodate population growth and the changing needs of their jurisdictions. ARB further acknowledges that decisions on how land is used will have large impacts on the GHG emissions that will result from the transportation, housing, industry, forestry, water, agriculture, electricity, and natural gas emissions sectors. With regard to land use planning, the Scoping Plan expects approximately
5.0 MMT CO2e will be achieved associated with the implementation of SB 375, which is discussed further below.
The initial Scoping Plan was first approved by ARB on December 11, 2008, and is updated every five years.
The first update of the Scoping Plan was approved by the ARB on May 22, 2014, which looked past 2020 to set mid-term goals (2030-2035) on the road to reaching the 2050 goals. The 2017 Climate Change Scoping Plan, was released in November 2017. The 2017 Climate Change Scoping Plan incorporates strategies for achieving the 2030 GHG-reduction target established in SB 32 and EO B-30-15. Most notably, the 2017 Climate Change Scoping Plan encourages zero net increases in GHG emissions. However, the 2017 Climate Change Scoping Plan recognizes that achieving net zero increases in GHG emissions may not be possible or appropriate for all projects and that the inability of a project to mitigate its GHG emissions to zero would not imply the project results in a substantial contribution to the cumulatively significant environmental impact of climate change under CEQA.
Exhibit C
Air Quality & Greenhouse Gas Impact Assessment AMBIENT Air Quality & Noise Consulting Allegretto Resort Expansion Project March 2025
33 On November 16, 2022, the ARB approved the 2022 Scoping Plan for Achieving Carbon Neutrality. The 2022 Scoping Plan continues the path to achieve the SB 32 2030 target and expands upon earlier plans by targeting an 85 percent reduction in GHG below 1990 levels by 2045 (ARB 2022).
SENATE BILL 1078 AND GOVERNOR’S ORDER S-14-08
SB 1078 (Public Utilities Code Sections 387, 390.1, 399.25, and Article 16) addresses electricity supply and requires that retail sellers of electricity, including investor-owned utilities and community choice aggregators, provide a minimum of 20 percent of their supply from renewable sources by 2017. This Senate Bill will affect statewide GHG emissions associated with electricity generation. In 2008, Governor Schwarzenegger signed EO S-14-08, which set the Renewables Portfolio Standard target to 33 percent by 2020. It directed state government agencies and retail sellers of electricity to take all appropriate actions to implement this target.
EO S-14-08 was later superseded by EO S-21-09 on September 15, 2009. EO S-21-09 directed the ARB to adopt regulations requiring 33 percent of electricity sold in the State to come from renewable energy by 2020.
Statute SB X1-2 superseded this EO in 2011, which obligated all California electricity providers, including investor-owned utilities and publicly owned utilities, to obtain at least 33 percent of their energy from renewable electrical generation facilities by 2020.
ARB is required by current law, AB 32 of 2006, to regulate sources of GHGs to meet a state goal of reducing GHG emissions to 1990 levels by 2020 and an 80 percent reduction of 1990 levels by 2050. The California Energy Commission and California Public Utilities Commission serve in advisory roles to help ARB develop the regulations to administer the 33 percent by 2020 requirement. ARB is also authorized to increase the target and accelerate and expand the time frame.
MANDATORY REPORTING OF GHG EMISSIONS
The California Global Warming Solutions Act (AB 32, 2006) requires the reporting of GHGs by major sources to the ARB. Major sources required to report GHG emissions include industrial facilities, suppliers of transportation fuels, natural gas, natural gas liquids, liquefied petroleum gas, and CO2, operators of petroleum and natural gas systems, and electricity retail providers and marketers.
CAP-AND-TRADE REGULATION
The cap-and-trade regulation is a key element in California’s climate plan. It sets a statewide limit on sources responsible for 85 percent of California’s GHG emissions and establishes a price signal needed to drive longterm investment in cleaner fuels and more efficient use of energy. The cap-and-trade rules came into effect on January 1, 2013, and apply to large electric power plants and large industrial plants. In 2015, fuel distributors, including distributors of heating and transportation fuels, also became subject to the cap-andtrade rules. At that stage, the program will encompass around 360 businesses throughout California and nearly 85 percent of the state’s total GHG emissions.
Under the cap-and-trade regulation, companies must hold enough emission allowances to cover their emissions and are free to buy and sell allowances on the open market. California held its first auction of GHG allowances on November 14, 2012. California’s GHG cap-and-trade system is projected to reduce GHG emissions to 1990 levels by the year 2020 and would achieve an approximate 80 percent reduction from 1990 levels by 2050.
SENATE BILL 32
SB 32 was signed by Governor Brown on September 8, 2016. SB 32 effectively extends California’s GHG emission-reduction goals from year 2020 to year 2030. This new emission-reduction target of 40 percent below 1990 levels by 2030 is intended to promote further GHG-reductions in support of the State’s ultimate goal of reducing GHG emissions by 80 percent below 1990 levels by 2050. SB 32 also directs the ARB to update the Climate Change Scoping Plan to address this interim 2030 emission-reduction target.
SENATE BILL 97
SB 97 was enacted in 2007. SB 97 required the Office of Planning and Research (OPR) to develop, and the Natural Resources Agency to adopt, amendments to the CEQA Guidelines addressing the analysis and Exhibit C
Air Quality & Greenhouse Gas Impact Assessment AMBIENT Air Quality & Noise Consulting Allegretto Resort Expansion Project March 2025
34 mitigation of GHG emissions. Those CEQA Guidelines amendments clarified several points, including the following:
• Lead agencies must analyze the GHG emissions of proposed projects and must reach a conclusion regarding the significance of those emissions.
• When a project’s GHG emissions may be significant, lead agencies must consider a range of potential mitigation measures to reduce those emissions. • Lead agencies must analyze potentially significant impacts associated with placing projects in hazardous locations, including locations potentially affected by climate change. • Lead agencies may significantly streamline the analysis of GHGs on a project level by using a programmatic GHG emissions reduction plan meeting certain criteria. • CEQA mandates analysis of a proposed project’s potential energy use (including transportationrelated energy), sources of energy supply, and ways to reduce energy demand, including through the use of efficient transportation alternatives.
As part of the administrative rulemaking process, the California Natural Resources Agency developed a Final Statement of Reasons explaining the legal and factual bases, intent, and purpose of the CEQA Guidelines amendments. The amendments to the CEQA Guidelines implementing SB 97 became effective on March 18, 2010.
SENATE BILL 100
SB 100 was signed by Governor Jerry Brown on September 10, 2018. SB 100 sets a goal of phasing out all fossil fuels from the state’s electricity sector by 2045. SB 100 increases to 60 percent, from 50 percent, how much of California’s electricity portfolio must come from renewables by 2030. It establishes a further goal to have an electric grid that is entirely powered by clean energy by 2045, which could include other carbon-free sources, like nuclear power, that are not renewable.
SENATE BILL 375
SB 375 requires Metropolitan Planning Organizations (MPOs) to adopt a sustainable communities strategy (SCS) or alternative planning strategy (APS) that will address land-use allocation in that MPOs regional transportation plan. ARB, in consultation with MPOs, establishes regional reduction targets for GHGs emitted by passenger cars and light trucks for the years 2020 and 2035. These reduction targets will be updated every eight years but can be updated every four years if advancements in emissions technologies affect the reduction strategies to achieve the targets. ARB is also charged with reviewing each MPO’s SCS or APS for consistency with its assigned targets. If MPOs do not meet the GHG reduction targets, funding for transportation projects may be withheld. In 2018, ARB adopted updated SB 375 targets.
SENATE BILLS 1383 & 1206
SB 1383 requires California to reduce hydrofluorocarbon (HFC) emissions associated with the use of refrigerants to 40 percent below 2013 levels by 2030. Starting in 2022, new facilities will be required to use refrigerants that can reduce their emissions by up to 90 percent. The intent of the new rules is to eliminate the use of very high-GWP refrigerants in every sector that uses non-residential refrigeration systems. Compliance begins for most home air conditioning equipment in 2025. Senate Bill 1206, signed into law in September 2022, prohibits the sale or distribution of HFCs that exceed a specified GWP. Under this new law, refrigerants would not be allowed to exceed 2,200 GWP beginning January 1, 2025; 1,500 GWP beginning January 1, 2030; and 750 GWP beginning January 1, 2030. California Building Code The CBC contains standards that regulate the method of use, properties, performance, or types of materials used in the construction, alteration, improvement, repair, or rehabilitation of a building or other improvement to real property. The California Building Code is adopted every three years by the Building Standards Commission (BSC). In the interim, the BSC also adopts annual updates to make necessary mid-term corrections. The CBC standards apply statewide; however, a local jurisdiction may amend a CBC standard if it makes a finding that the amendment is reasonably necessary due to local climatic, geological, or topographical conditions.
Exhibit C
Air Quality & Greenhouse Gas Impact Assessment AMBIENT Air Quality & Noise Consulting Allegretto Resort Expansion Project March 2025
35 CALIFORNIA GREEN BUILDING STANDARDS
In essence, the green building standards are indistinguishable from any other building standards, are contained in the CBC, and regulate the construction of new buildings and improvements. Whereas the focus of traditional building standards has been protecting public health and safety, the focus of green building standards is to improve environmental performance.
The 2019 Building Energy Efficiency Standards (2019 Standards), adopted in May 2018, addressed four key areas: smart residential photovoltaic systems, updated thermal envelope standards (preventing heat transfer from the interior to the exterior and vice versa), residential and nonresidential ventilation requirements, and non-residential lighting requirements. The 2019 Standards required new residential and non-residential construction; as well as major alterations to existing structures, to include EV-capable parking spaces which have electrical panel capacity and conduit to accommodate future installation. In addition, the 2019 Standards also required the installation of PV systems for low-rise residential dwellings, defined as single-family dwellings and multi-family dwellings up to three stories in height. These requirements are based on various factors, including the floor area of the home, sun exposure, and climate zone. Under the 2019 standards, nonresidential buildings will use about 30 percent less energy due mainly to lighting upgrades (CEC 2019).
The recently updated 2022 Building Energy Efficiency Standards (2022 Standards), which were approved in December 2021, encourage efficient electric heat pumps, establish electric-ready requirements when natural gas is installed and support the future installation of battery storage, and further expands solar photovoltaic and battery storage standards. The 2022 Standards extend solar PV system requirements, as well as battery storage capabilities for select land uses, including high-rise multi-family and non-residential land uses, such as office buildings, schools, restaurants, warehouses, theaters, grocery stores, and more.
Depending on the land use and other factors, solar systems should be sized to meet targets of up to 60 percent of the structure’s loads. These new solar requirements will become effective January 1, 2023, and contribute to California’s goal of reaching net-zero carbon footprint by 2045 (CEC 2021).
SHORT-LIVED CLIMATE POLLUTANT REDUCTION STRATEGY
In March 2017, the ARB adopted the Short-Lived Climate Pollutant Reduction Strategy (SLCP Strategy) establishing a path to decrease GHG emissions and displace fossil-based natural gas use. Strategies include avoiding landfill methane emissions by reducing the disposal of organics through edible food recovery, composting, in-vessel digestion, and other processes; and recovering methane from wastewater treatment facilities, and manure methane at dairies, and using the methane as a renewable source of natural gas to fuel vehicles or generate electricity. The SLCP Strategy also identifies steps to reduce natural gas leaks from oil and gas wells, pipelines, valves, and pumps to improve safety, avoid energy losses, and reduce methane emissions associated with natural gas use. Lastly, the SLCP Strategy also identifies measures that can reduce HFC emissions at national and international levels, in addition to State-level action that includes an incentive program to encourage the use of low-GWP refrigerants and limitations on the use of high-GWP refrigerants in new refrigeration and air-conditioning equipment (ARB 2020).
San Luis Obispo County Air Pollution Control District
SLOAPCD is a local public agency with the primary mission of realizing and preserving clean air for all county residents and businesses. Responsibilities of the SLOAPCD include but are not limited to, preparing plans for the attainment of ambient air quality standards, adopting and enforcing rules and regulations concerning sources of air pollution, issuing permits for stationary sources of air pollution, inspecting stationary sources of air pollution and responding to citizen complaints, monitoring ambient air quality and meteorological conditions, and implementing programs and regulations required by federal and state regulatory requirements.
City Of Paso Robles Climate Action Plan
The City’s Climate Action Plan is a long-range plan to reduce GHG emissions from City government operations and community activities. The Climate Action Plan will also help achieve multiple community goals such as lowering energy costs, reducing air pollution, and supporting local economic development.
The Climate Action Plan includes measures to reduce community-wide GHG emissions by 15 percent below 2005 levels by 2020 (City of Paso Robles 2013).
Exhibit C
Air Quality & Greenhouse Gas Impact Assessment AMBIENT Air Quality & Noise Consulting Allegretto Resort Expansion Project March 2025
36 County of San Luis Obispo 2023 Regional Transportation Plan/Sustainable Communities Strategy
The 2023 RTP was adopted by the SLOCOG Board in June 2023. The RTP includes the region's SCS, which outlines how the region will exceed its GHG reduction targets as required by SB 375 through the promotion of a variety of transportation demand management & system management tools and techniques to maximize the efficiency of the transportation network. Consistency with the requirement of SB 375 ensures consistency with the GHG-reduction targets set by ARB. The 2023 SCS was found to be consistent with the requirement of SB 375 and is also consistent with the general plans of the region’s jurisdictions (SLOCOG 2023).
Impact Analysis
Thresholds of Significance
In accordance with Appendix G of the State CEQA Guidelines, increased GHG emissions associated with the implementation of the proposed project would be considered significant if it would:
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.
In accordance with SLOAPCD recommendations, the proposed project would be considered to be consistent with the State’s carbon neutrality goals and would be considered to have a less-than-significant impact if: 1) the project is deemed consistent with regional VMT-reduction targets; 2) the project incorporates best management practices (BMPs) to support the State’s GHG-reduction efforts; and 3) the project would not result in a wasteful, inefficient, or unnecessary energy use as determined by the analysis required under CEQA Section 21100(b)(3) and Section 15126.2(b) of the State CEQA Guidelines.
The SLOAPCD has not identified recommended BMPs for development projects. However, other air districts in the State have recently released BMP-related guidance for the evaluation of GHG impacts. For instance, the Bay Area Air Quality Management District (BAAQMD) has recently released recommended GHG significance thresholds that are based on a “fair share” approach for achieving carbon neutrality goals and to ensure consistency with the State’s GHG-reduction efforts, including the State’s Climate Change Scoping Plan. Accordingly, the BAAQMD recommends that the installation of natural gas infrastructure for development projects be prohibited to the extent that alternatively powered options are available. Similarly, the SMAQMD has also recently released BMPs, which also discourage the installation of natural gas infrastructure for development projects as well as a requirement that projects meet current CalGreen Tier 2 standards for electric-vehicle (EV) spaces, except that EV-capable spaces shall instead be EV ready. This additional requirement requires the installation of electrical infrastructure sufficient to service the future installation of EV chargers. The BAAQMD and SMAQMD thresholds are based on an approach endorsed by the Supreme Court in Center for Biological Diversity v. Department of Fish & Wildlife (2015). Although not located within these jurisdictions, development in San Luis Obispo County and associated GHG emissions are comparable to those generated by developments within other areas of the state, including the BAAQMD and SMAQMD jurisdictions. Given that climate change is inherently a cumulative impact that occurs on a global scale, these BMPs would, likewise, be considered representative of the project’s “fair share” of what would be required to meet the State’s long-term climate goals, including achieving carbon neutrality by 2045 and ensuring consistency with the State’s Climate Change Scoping Plan. It is also important to note that the CARB 2022 Scoping Plan states that under the Lead Agencies discretion with supporting evidence projects that incorporate some but not all key attributes could be found by the lead agency as being consistent with the State’s Scoping Plan. Project-related operational GHG impacts were assessed based on consistency with applicable GHG reduction plans. Refer to Appendix A for emissions modeling assumptions and results.
Exhibit C
Air Quality & Greenhouse Gas Impact Assessment AMBIENT Air Quality & Noise Consulting Allegretto Resort Expansion Project March 2025
37 Methodology
Emissions associated with the construction of the proposed project were calculated using the California Emissions Estimator Model (CalEEMod), version 2022.1.1.29, computer program. Construction information, including construction phase durations, area of disturbance, and area to be paved was based on projectspecific information provided. No existing structure would be demolished. Additional construction information such as off-road equipment use, worker vehicle trips, and equipment load factors were based on default parameters contained in the model for San Luis Obispo County. Modeling assumptions and output files are included in Appendix A of this report.
Long-term operational emissions were calculated using the CalEEMod, version 2022.1.1.29 based, in part, on vehicle trip-generation rates derived from the traffic analysis prepared for this project (CCTC 2025). Vehicle travel distribution/distances were not available and were based on model defaults for San Luis Obispo County. Energy-saving features included as part of the proposed project were also included in the emissions modeling. Based on project-specific information provided, the project would include the installation of a solar photovoltaic (PV) energy system, which is estimated to provide approximately 1,267,700 kWh/year. The project would also include the use of low-flow inline drip irrigation systems with “smart” controllers and flow sensors, which would reduce water use and associated electrical usage. The project would also include the installation of energy-efficient appliances and lighting, per current building code requirements. Emission modeling files are provided in Appendix A.
Project Impacts and Mitigation Measures
Impact GHG-A. Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment? or Conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of greenhouse gas? Estimated GHG emissions attributable to future development would be primarily associated with increases in CO2 from mobile sources. To a lesser extent, other GHG pollutants, such as CH4 and N2O, would also be generated. Short-term and long-term GHG emissions associated with the development of the proposed project are discussed in greater detail, as follows:
Short-term Construction GHG Emissions
Estimated increases in GHG emissions associated with the construction of the proposed project are summarized in Table 16. Based on the modeling conducted, construction-related GHG emissions would total approximately 469 MTCO2e. Amortized GHG emissions, when averaged over the assumed 30-year minimum life of the project, would total approximately 15.6 MTCO2e/year. There would also be a small amount of GHG emissions from waste generated during construction; however, this amount is speculative. Actual emissions may vary, depending on the final construction schedules, equipment required, and activities conducted.
Amortized construction-generated GHG emissions are included in the operational GHG emissions impact discussion provided below.
Table 16. Construction-Generated GHG Emissions
Construction Year GHG Emissions
(MTCO2e/Year)
2026 357
2027 112
Total Construction Emissions: 469
Amortized Construction Emissions: 15.6
Amortized emissions are quantified based on a minimum 30-year project life. Refer to Appendix A for modeling assumptions and results.
Exhibit C
Air Quality & Greenhouse Gas Impact Assessment AMBIENT Air Quality & Noise Consulting Allegretto Resort Expansion Project March 2025
38 Long-term Operational GHG Emissions
For informational purposes, estimated long-term increases in operational GHG emissions associated with the proposed project are summarized in Table 17. As depicted, operational GHG emissions for the proposed project, with the inclusion of amortized construction GHGs, would total approximately 1,197 MTCO2e/year under opening year 2028 conditions. A majority of the operational GHG emissions would be associated with motor vehicle use and energy use. To a lesser extent, operational GHG emissions would also be associated with solid waste generation and water use. Operational GHG emissions would be projected to gradually decrease in future years, due largely to anticipated improvements in mobile-source fuel-efficiency rates.
Table 17. Operational GHG Emissions
Operational Year/Source GHG Emissions (MTCO2e/Year)
Mobile(1) 634.0
Area Source(2) 5.0
Energy(3) 457
Water(3) 15.9
Waste 30.7
Refrigerant(4) 39.2
Amortized Construction Emissions: 15.6
Total Emissions: 1,197
1. Based on default fleet mix for land uses contained in CalEEMod for San Luis Obispo County. Based on opening year 2028 conditions.
2. Area sources include emissions associated primarily with consumer products and the use of landscape maintenance equipment.
3. Includes use of energy-efficient appliances, low-flow water fixtures and water-efficient irrigation systems, per current building code requirements.
4. Reduced service leak emissions.
Refer to Appendix A for modeling assumptions and results.
Consistency With Applicable Plans
As noted in Table 20, operational GHG emissions attributable to the proposed project would be primarily associated with energy use, refrigerant emissions, and mobile sources. Applicable GHG-reduction plans related to reducing operational GHG emissions are the County of San Luis Obispo’s Regional Transportation Plan/Sustainable Communities Strategy, ARB’s 2022 Climate Change Scoping Plan, and the City of Paso Robles CAP. The project’s consistency with these plans is discussed in greater detail, as follows:
City of Paso Robles Climate Action Plan
The City’s Climate Action Plan is a long-range plan to reduce GHG emissions from City government operations and community activities within the community. The City’s Climate Action Plan includes numerous measures to reduce GHG emissions associated with energy use, motor vehicle use, water use, waste generation, and construction. It is important to note, however, that the City’s Climate Action Plan is based on the year 2020 GHG-reduction targets and has not yet been updated to reflect year 2030 GHG-reduction targets, per SB 32. Nonetheless, a summary of the proposed project’s consistency with the measures identified in the City’s Climate Action Plan are summarized in Table 18. As noted, and with the implementation of proposed mitigation measures, the project would be consistent with the GHG-reduction measures identified in the City’s currently adopted Climate Action Plan (City of Paso Robles 2013).
County of San Luis Obispo 2023 Regional Transportation Plan/Sustainable Communities Strategy The 2023 RTP was adopted by the SLOCOG Board in June 2023. The RTP includes the region's SCS, which outlines how the region will meet or exceed its GHG reduction targets as required by SB 375 through the promotion of a variety of transportation demand management & system management tools and techniques to maximize the efficiency of the transportation network. Consistency with the requirement of SB 375 ensures consistency with the GHG-reduction targets set by ARB. The 2023 SCS was found to be consistent with the requirement of SB 375 and is also consistent with the general plans of the region’s jurisdictions (SLOCOG 2023).
Based on the traffic analysis prepared for the project, the project would result in a reduction in regional VMT (CCTC 2025). As a result, the project would be consistent with regional VMT-reduction efforts.
Exhibit C
Air Quality & Greenhouse Gas Impact Assessment AMBIENT Air Quality & Noise Consulting Allegretto Resort Expansion Project March 2025
39 Table 18. Project Consistency with the City’s Climate Action Plan Climate Action Plan Measures Project Consistency
Energy Measures
Does the project exclusively include “All-electric buildings”? Consistent with Mitigation. A mitigation measure has been included to encourage the installation of electrically-powered appliances in place of natural gas to the extent possible.
Where natural gas service for equipment is required,
electrical service to the equipment shall also be required to promote the future conversion from natural gas to electrical service (refer to Mitigation Measure GHG-1a). The proposed project includes the installation of solar photovoltaic systems and installation of energy-efficient appliances and lighting, per building code requirements. The project would comply with the City’s Energy Reach code requirements.
If the project/plan includes a new mixed-fuel building or buildings (plumbed for the use of natural gas as fuel for space heating, water heating, cooking, or clothes drying appliances) does that building/those buildings exceed the City’s Energy Reach code?
Transportation and Land Use Measures
Does the project comply with requirements in the City’s Municipal Code with no exceptions, including bicycle parking, bikeway design, and EV charging stations?
Consistent. The project includes bicycle parking and EV charging stations in accordance with building requirements.
Is the estimated project-generated VMT within the City’s adopted thresholds, as confirmed by the City’s Transportation Division?
Consistent. Based on the traffic analysis prepared for this project, the project would result in a reduction in reginal VMT. Project-generated VMT would, therefore, not exceed If “No”, does the project/plan include VMT mitigation the City’s adopted VMT thresholds. strategies and/or a Transportation Demand Management
(TDM) Plan approved by the City’s Transportation Division? Does the project demonstrate consistency with the City’s Bicycle Network Plan?
Consistent. The project would include improvements to
nearby bicycle and pedestrian facilities (CCTC 2025). The project would, therefore, not conflict with the City’s Bicycle Network Plan.
Off-Road Measure
Will the project work to reduce GHG emissions by reducing off-road equipment and vehicle usage and idling?
Consistent with Mitigation. Mitigation measures have been included to require the project to restrict idling and vehicle usage when feasible and to use alternatively-powered
equipment where possible during construction (refer to
Mitigation Measure AQ-2).
Water Measure
Does the project comply with water efficiency and
conservation requirements?
Consistent. The project includes the use of low-flow water fixtures, water-efficient irrigation systems, and droughttolerant landscaping in accordance with building requirements.
Waste Measure
Does the project include an operational commitment to
reduce the amount of trash and other waste and recycle as many materials as possible?
Consistent. The project would be required to provide organic waste pick up and shall provide the appropriate on-site enclosures consistent with the provisions of the City of Paso Robles Development Standards for Solid Waste Services
(refer to Mitigation Measure GHG-1b).
Tree Planting Measure
Does the project include an operational commitment to
maintain a healthy urban forest and incorporate native
drought-tolerant trees?
Consistent. The project would comply with the City’s Water Efficient Landscape Ordinance and includes the installation of drought tolerant landscaping.
Exhibit C
Air Quality & Greenhouse Gas Impact Assessment AMBIENT Air Quality & Noise Consulting Allegretto Resort Expansion Project March 2025
40 California’s 2022 Climate Change Scoping Plan
The previously adopted 2017 Climate Change Scoping Plan incorporated the State’s GHG emissions reduction target of 40 percent below 1990 emissions levels by 2030, as mandated by SB 32. On November 16, 2022, the ARB approved the 2022 Scoping Plan for Achieving Carbon Neutrality. The recently adopted 2022 Scoping Plan continues the path to achieve the SB 32 2030 target and expands upon earlier Scoping Plans by targeting an 85 percent reduction in GHG below 1990 levels by 2045. A significant part of achieving the SB 32 goals are strategies to promote sustainable communities, such as the promotion of zero net energy buildings, and improved transportation choices that result in reducing VMT. Other measures include the increased use of low-carbon fuels and cleaner vehicles (ARB 2022).
For land use development projects, additional reductions in GHG emissions may be required in order to meet the project’s fair share of the statewide reductions required to achieve carbon neutrality, consistent with EO B-55-18 and ARB’s Draft 2022 Scoping Plan Update. Neither the SLOAPCD nor the City have developed recommended thresholds of significance that are based on achieving carbon neutrality by the year 2045.
However, the Bay Area Air Quality Management District (BAAQMD) has recently released recommended GHG significance thresholds that are based on a “fair share” approach for achieving carbon neutrality goals.
Consistent with this approach, new land use development projects would be considered to be consistent with the State’s carbon neutrality goals and would be considered to have a less-than-significant impact if:
1) the project is deemed consistent with regional VMT-reduction targets; 2) the project prohibits the installation of natural gas infrastructure (to the extent that alternative power sources are available); and 3) the project would not result in a wasteful, inefficient, or unnecessary energy use as determined by the analysis required under CEQA Section 21100(b)(3) and Section 15126.2(b) of the State CEQA Guidelines. Similarly, the SMAQMD has also recently released Best Management Practices (BMPs), which also include the prohibited installation of natural gas infrastructure for development projects, as well as a requirement that projects meet current CALGreen Tier 2 standards for EV spaces, except that EV-capable spaces shall instead be EV ready.
This additional requirement requires the installation of electrical infrastructure sufficient to service the future installation of EV chargers. The BAAQMD and SMAQMD thresholds are based on an approach endorsed by the Supreme Court in Center for Biological Diversity v. Department of Fish & Wildlife (2015). Although not located within these jurisdictions, development in San Luis Obispo County and associated GHG emissions are comparable to those generated by developments within other areas of the state, including the BAAQMD and SMAQMD jurisdictions. Given that climate change is inherently a cumulative impact that occurs on a global scale, these BMPs would, likewise, be considered representative of the project’s “fair share” of what would be required to meet the State’s long-term climate goals, including achieving carbon neutrality by 2045, as identified by the BAAQMD and the SMAQMD.
As noted above, the proposed project would result in an overall reduction in regional VMT and, therefore, would not conflict with regional VMT-reduction targets. However, the proposed project does not include BMPs that would constitute its “fair share” of what would be required to meet the State’s long-term climate goals, including achieving carbon neutrality by 2045. Specifically, the project does not prohibit the installation of natural gas-fueled appliances/equipment, nor require that current CALGreen Tier 2 compliant EV spaces be EV Ready, as opposed to EV Capable. As a result, this impact would be considered potentially significant.
Mitigation Measures
Implement Mitigation Measure AQ-2 and the following:
GHG-1: The project shall include the following measures:
a. CALGreen Tier 2 compliant electric vehicle (EV) charging stations shall be “EV Ready” as opposed to “EV Capable”.
b. Install electrically powered appliances and building mechanical equipment in place of naturalgas-fueled equipment. If natural gas equipment is to be installed, the following shall be implemented: (1) Install electrical service to the natural gas equipment location sufficient to allow for the future conversion from natural gas to electrical service; (2) A Greenhouse Gas (GHG) Reduction Plan shall be prepared for the proposed project. The GHG Reduction Plan shall include a menu of all possible onsite GHG reduction measures sufficient to offset operational natural-gas source emissions. In the event that the City of Paso Robles (City) adopts an updated Climate Action Plan or the San Luis Obispo County Air Pollution Control District (SLOAPCD) Exhibit C
Air Quality & Greenhouse Gas Impact Assessment AMBIENT Air Quality & Noise Consulting Allegretto Resort Expansion Project March 2025
41 releases updated recommended GHG significance thresholds that address future-year GHG emissions reductions, the GHG-Reduction Plan may be evaluated in comparison to the GHG thresholds and reduction measures identified in the Climate Action Plan or those identified by the SLOAPCD and adjusted in order for the project to be in compliance with the Climate Action Plan. The GHG Reduction plan shall be approved by the City prior to issuance of building construction permits.
Under California Environmental Quality Act Guidelines Section 15126.4(c)(3) and (c)(4), respectively, a project’s GHG emissions may also be reduced by offsite measures, including offsets that are not otherwise required by existing regulations and measures that sequester GHGs. In the event that feasible onsite GHG-reduction measures are insufficient to offset operational natural-gas source GHG emissions, offsite mitigation measures may be included to the extent feasible. Offsite mitigation measures may include “Direct Reduction Activities” located in the City of Paso Robles or the SLOAPCD jurisdictional areas. “Direct Reduction Activities” means undertaking or funding activities that will reduce or sequester GHG emissions.
GHG reduction credits shall achieve GHG emission reductions that are real, permanent, quantifiable, verifiable, and enforceable. GHG reduction credits shall be undertaken for the specific purpose of reducing project-generated GHG emissions and shall not include reductions that would otherwise be required by law. All Direct Reduction Activities and associated reduction credits shall be confirmed by an independent, qualified third-party air consultant retained by the Applicant.
c. The project shall provide organic waste pick up and shall provide the appropriate on-site enclosures consistent with the provisions of the City of Paso Robles Development Standards for Solid Waste Services.
Significance After Mitigation
Implementation of Mitigation Measures AQ-2 and GHG-1 would reduce project-generated GHG emissions to ensure consistency with future year 2030 GHG-reduction targets. With mitigation, the project would be considered consistent with the regional GHG-reduction planning efforts, which have been deemed consistent with State-wide GHG-reduction planning efforts.
Mitigation Measure GHG-1a would require the installation of EV-ready parking spaces in support of the State’s carbon neutrality goals. With regard to CALGreen EV parking requirements, “EV Capable” is defined as including the installation of a “raceway” (the enclosed conduit that forms the physical pathway for electrical wiring to protect it from damage) and adequate future installation of a dedicated branch circuit and charging station(s). “EV Ready” includes “EV Capable” requirements plus the addition of dedicated branch circuit(s) (electrical pre-wiring), circuit breakers, and other electrical components, including a receptacle (240-volt outlet) or blank cover needed to support future installation of one or more charging stations.
Mitigation has also been included to promote the use of electrically powered appliances/equipment (as opposed to natural gas-fueled appliances/equipment) and to reduce waste per applicable City development standards. In the event that natural-gas appliances/equipment are installed, Mitigation Measure GHG-1b would require the project to implement additional GHG emission reduction measures sufficient to offset any GHG increases associated with the use of natural gas in the event that natural gas appliances/equipment is to be installed. Implementation of Mitigation Measure GHG-1c would help to reduce GHG emissions associated with waste generation and Mitigation Measures AQ-2 would help to reduce GHG emissions associated with construction-related activities, including short-lived climate pollutants, such as black carbon. With mitigation, the project would be considered consistent with the local, regional, and state GHG-reduction planning efforts. With mitigation, this impact would be considered less than significant.
Exhibit C
Air Quality & Greenhouse Gas Impact Assessment AMBIENT Air Quality & Noise Consulting Allegretto Resort Expansion Project March 2025
42 REFERENCES
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Intergovernmental Panel on Climate Change (IPCC). 2007. Fourth Assessment Report, Climate Change 2007: Impacts, Adaptation and Vulnerability. Available at website URL:
https://www.ipcc.ch/site/assets/uploads/2018/03/ar4_wg2_full_report.pdf.
Iowa Environmental Mesonet. Accessed July 2023. IEM Site Information. Website URL:
https://mesonet.agron.iastate.edu/sites/site.php?station=PRB&network=CA_ASOS.
Sacramento Metropolitan Air Quality Management District (SMAQMD). October 2020. Guidance to Address the Friant Ranch Ruling For CEQA Projects in the Sac Metro Air District.
San Joaquin Valley Air Pollution Control District (SJVAPCD). April 13, 2015. Sierra Club, Revive the San Joaquin, and League of Women Voters of Fresno, Plaintiffs and Appellants v. County of Fresno, Defendant and Respondent. Application for Leave to File Amicus Curiae Brief of San Joaquin Valley Unified Air Pollution Control District in Support of Defendant and Respondent, County of Fresno and Real Party in Interest and Respondent, Friant Ranch, L.P. Website URL:
https://www.courts.ca.gov/documents/7-s219783-ac-san-joaquin-valley-unified-air-pollution-control-dist-041315.pdf.
San Luis Obispo Council of Governments (SLOCOG). 2023. SLOCOG 2023 Regional Transportation Plan. Available at Website URL: https://www.slocog.org/programs/regional-planning/2023-rtp.
San Luis Obispo Council of Governments (SLOCOG). 2019. 2019 Regional Housing Needs Allocation Plan. Available at Website URL: https://www.slocog.org/programs/housing/regional-housing-needs-allocation-rhna San Luis Obispo County Air Pollution Control District (SLOAPCD). January 29, 2019. SLO County Attainment Status. Website URL:
https://storage.googleapis.com/slocleanair org/images/cms/upload/files/AttainmentStatus29January2019.pdf.
San Luis Obispo County Air Pollution Control District (SLOAPCD). December 2001. Clean Air Plan.
San Luis Obispo County Air Pollution Control District (SLOAPCD). April 2012. CEQA Air Quality Handbook with 2023 Administrative Updates. Available at website URL: https://www.slocleanair.org/rules-regulations/land-use-ceqa.php.
San Luis Obispo County Air Pollution Control District (SLOAPCD). 2017. Clarification Memo related to the CEQA Air Quality Handbook. Available at website URL: https://www.slocleanair.org/rules-regulations/land-use-ceqa.php.
Exhibit C
Air Quality & Greenhouse Gas Impact Assessment AMBIENT Air Quality & Noise Consulting Allegretto Resort Expansion Project March 2025
43 San Luis Obispo County Air Pollution Control District (SLOAPCD). 2018. APCD Naturally Occurring Asbestos Map. Available at website URL: https://www.slocleanair.org/rules-regulations/land-use-ceqa.php.
United States Environmental Protection Agency (U.S. EPA). Accessed: August 20, 2018. Overview of Greenhouse Gases. Website URL: https://www.epa.gov/ghgemissions/overview-greenhouse-gases.
United States Environmental Protection Agency (U.S. EPA). 2023. Air Quality Index Report. Website URL:
https://www.epa.gov/outdoor-air-quality-data/air-quality-index-report.
Exhibit C
APPENDIX A
EMISSIONS MODELING & SUPPORTIVE DOCUMENTATION
Exhibit C
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Ayres Resort Expansion Detailed Report
Table of Contents
1. Basic Project Information
1.1. Basic Project Information
1.2. Land Use Types
1.3. User-Selected Emission Reduction Measures by Emissions Sector
2. Emissions Summary
2.1. Construction Emissions Compared Against Thresholds
2.2. Construction Emissions by Year, Unmitigated
2.3. Construction Emissions by Year, Mitigated
2.4. Operations Emissions Compared Against Thresholds
2.5. Operations Emissions by Sector, Unmitigated
2.6. Operations Emissions by Sector, Mitigated
3. Construction Emissions Details
3.1. Site Preparation (2026) - Unmitigated
3.2. Site Preparation (2026) - Mitigated
3.3. Grading (2026) - Unmitigated
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3.4. Grading (2026) - Mitigated
3.5. Building Construction (2026) - Unmitigated
3.6. Building Construction (2026) - Mitigated
3.7. Building Construction (2027) - Unmitigated
3.8. Building Construction (2027) - Mitigated
3.9. Paving (2027) - Unmitigated
3.10. Paving (2027) - Mitigated
3.11. Architectural Coating (2026) - Unmitigated
3.12. Architectural Coating (2026) - Mitigated
3.13. Architectural Coating (2027) - Unmitigated
3.14. Architectural Coating (2027) - Mitigated
4. Operations Emissions Details
4.1. Mobile Emissions by Land Use
4.1.1. Unmitigated
4.1.2. Mitigated
4.2. Energy
4.2.1. Electricity Emissions By Land Use - Unmitigated
4.2.2. Electricity Emissions By Land Use - Mitigated
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4.2.3. Natural Gas Emissions By Land Use - Unmitigated
4.2.4. Natural Gas Emissions By Land Use - Mitigated
4.3. Area Emissions by Source
4.3.1. Unmitigated
4.3.2. Mitigated
4.4. Water Emissions by Land Use
4.4.1. Unmitigated
4.4.2. Mitigated
4.5. Waste Emissions by Land Use
4.5.1. Unmitigated
4.5.2. Mitigated
4.6. Refrigerant Emissions by Land Use
4.6.1. Unmitigated
4.6.2. Mitigated
4.7. Offroad Emissions By Equipment Type
4.7.1. Unmitigated
4.7.2. Mitigated
4.8. Stationary Emissions By Equipment Type
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4.8.1. Unmitigated
4.8.2. Mitigated
4.9. User Defined Emissions By Equipment Type
4.9.1. Unmitigated
4.9.2. Mitigated
4.10. Soil Carbon Accumulation By Vegetation Type
4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated
4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated
4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated
4.10.4. Soil Carbon Accumulation By Vegetation Type - Mitigated
4.10.5. Above and Belowground Carbon Accumulation by Land Use Type - Mitigated
4.10.6. Avoided and Sequestered Emissions by Species - Mitigated
5. Activity Data
5.1. Construction Schedule
5.2. Off-Road Equipment
5.2.1. Unmitigated
5.2.2. Mitigated
5.3. Construction Vehicles
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5.3.1. Unmitigated
5.3.2. Mitigated
5.4. Vehicles
5.4.1. Construction Vehicle Control Strategies
5.5. Architectural Coatings
5.6. Dust Mitigation
5.6.1. Construction Earthmoving Activities
5.6.2. Construction Earthmoving Control Strategies
5.7. Construction Paving
5.8. Construction Electricity Consumption and Emissions Factors
5.9. Operational Mobile Sources
5.9.1. Unmitigated
5.9.2. Mitigated
5.10. Operational Area Sources
5.10.1. Hearths
5.10.1.1. Unmitigated
5.10.1.2. Mitigated
5.10.2. Architectural Coatings
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5.10.3. Landscape Equipment
5.10.4. Landscape Equipment - Mitigated
5.11. Operational Energy Consumption
5.11.1. Unmitigated
5.11.2. Mitigated
5.12. Operational Water and Wastewater Consumption
5.12.1. Unmitigated
5.12.2. Mitigated
5.13. Operational Waste Generation
5.13.1. Unmitigated
5.13.2. Mitigated
5.14. Operational Refrigeration and Air Conditioning Equipment
5.14.1. Unmitigated
5.14.2. Mitigated
5.15. Operational Off-Road Equipment
5.15.1. Unmitigated
5.15.2. Mitigated
5.16. Stationary Sources
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5.16.1. Emergency Generators and Fire Pumps
5.16.2. Process Boilers
5.17. User Defined
5.18. Vegetation
5.18.1. Land Use Change
5.18.1.1. Unmitigated
5.18.1.2. 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
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7. Health and Equity Details
7.1. CalEnviroScreen 4.0 Scores
7.2. Healthy Places Index Scores
7.3. Overall Health & Equity Scores
7.4. Health & Equity Measures
7.5. Evaluation Scorecard
7.6. Health & Equity Custom Measures
8. User Changes to Default Data
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1. Basic Project Information
1.1. Basic Project Information
Data Field Value
Project Name Ayres Resort Expansion
Construction Start Date 2/17/2026
Operational Year 2028
Lead Agency —
Land Use Scale Project/site
Analysis Level for Defaults County
Windspeed (m/s) 3.00
Precipitation (days) 0.20
Location 35.64841193637051, -120.67048201594922
County San Luis Obispo
City Paso Robles
Air District San Luis Obispo County APCD
Air Basin South Central Coast
TAZ 3307
EDFZ 6
Electric Utility Pacific Gas & Electric Company
Gas Utility Southern California Gas
App Version 2022.1.1.29
1.2. Land Use Types
Land Use Subtype Size Unit Lot Acreage Building Area (sq ft) Landscape Area (sq ft)
Special Landscape
Area (sq ft)
Population Description
Hotel 100 Room 3.33 145,200 23,661 — — —
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Quality Restaurant 6.00 1000sqft 0.14 6,000 23,661 — — — Junior College (2yr) 16.5 1000sqft 0.38 16,500 23,661 23,661 — — General Office
Building
17.9 1000sqft 0.41 17,950 23,661 — — —
Parking Lot 4.00 Acre 4.00 0.00 23,661 — — —
1.3. User-Selected Emission Reduction Measures by Emissions Sector Sector # Measure Title
Construction C-2* Limit Heavy-Duty Diesel Vehicle Idling Construction C-5 Use Advanced Engine Tiers
Construction C-10-A Water Exposed Surfaces
Construction C-10-C Water Unpaved Construction Roads
Construction C-11 Limit Vehicle Speeds on Unpaved Roads Construction C-12 Sweep Paved Roads
Energy E-2 Require Energy Efficient Appliances
Energy E-10-B Establish Onsite Renewable Energy Systems: Solar Power Water W-4 Require Low-Flow Water Fixtures
Refrigerants R-5 Reduce Service Leak Emissions
Area Sources AS-2 Use Low-VOC Paints
* Qualitative or supporting measure. Emission reductions not included in the mitigated emissions results.
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. ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — — — —
Unmit. 30.4 30.5 29.8 0.06 1.26 24.0 25.3 1.16 10.6 11.7 6,411 Exhibit C
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Mit. 29.7 4.94 29.3 0.06 0.12 6.46 6.57 0.11 2.82 2.93 6,411 % Reduced 2% 84% 2% — 91% 73% 74% 90% 73% 75% —
Daily, Winter
(Max)
— — — — — — — — — — —
Unmit. 30.4 30.5 29.8 0.06 1.26 24.0 25.3 1.16 10.6 11.7 6,405 Mit. 29.7 4.99 29.3 0.06 0.12 6.46 6.57 0.11 2.82 2.93 6,405 % Reduced 2% 84% 2% — 91% 73% 74% 90% 73% 75% —
Average Daily
(Max)
— — — — — — — — — — —
Unmit. 7.76 7.24 9.68 0.02 0.26 1.60 1.86 0.24 0.58 0.82 2,155 Mit. 7.30 2.52 10.6 0.02 0.06 0.67 0.73 0.06 0.21 0.27 2,155 % Reduced 6% 65% -10% — 76% 58% 61% 75% 63% 67% —
Annual (Max) — — — — — — — — — — —
Unmit. 1.42 1.32 1.77 < 0.005 0.05 0.29 0.34 0.04 0.11 0.15 357 Mit. 1.33 0.46 1.93 < 0.005 0.01 0.12 0.13 0.01 0.04 0.05 357 % Reduced 6% 65% -10% — 76% 58% 61% 75% 63% 67% —
2.2. Construction Emissions by Year, Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Year ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily -
Summer
(Max)
— — — — — — — — — — —
2026 30.4 30.5 29.8 0.06 1.26 24.0 25.3 1.16 10.6 11.7 6,411 2027 1.33 7.27 10.5 0.02 0.30 0.14 0.44 0.28 0.04 0.31 1,832 Daily - Winter
(Max)
— — — — — — — — — — —
2026 30.4 30.5 29.8 0.06 1.26 24.0 25.3 1.16 10.6 11.7 6,405 2027 30.3 11.4 17.0 0.03 0.36 0.70 1.06 0.34 0.17 0.51 3,749 Average Daily — — — — — — — — — — —
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2026 7.76 7.24 9.68 0.02 0.26 1.60 1.86 0.24 0.58 0.82 2,155 2027 5.38 2.16 3.20 0.01 0.07 0.12 0.19 0.07 0.03 0.10 678 Annual — — — — — — — — — — —
2026 1.42 1.32 1.77 < 0.005 0.05 0.29 0.34 0.04 0.11 0.15 357 2027 0.98 0.39 0.58 < 0.005 0.01 0.02 0.03 0.01 0.01 0.02 112
2.3. Construction Emissions by Year, Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Year ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily -
Summer
(Max)
— — — — — — — — — — —
2026 29.7 4.94 29.3 0.06 0.12 6.46 6.57 0.11 2.82 2.93 6,411 2027 0.75 2.26 11.1 0.02 0.03 0.14 0.17 0.03 0.04 0.07 1,832 Daily - Winter
(Max)
— — — — — — — — — — —
2026 29.7 4.99 29.3 0.06 0.12 6.46 6.57 0.11 2.82 2.93 6,405 2027 29.6 4.88 18.9 0.03 0.11 0.70 0.81 0.11 0.17 0.28 3,749 Average Daily — — — — — — — — — — —
2026 7.30 2.52 10.6 0.02 0.06 0.67 0.73 0.06 0.21 0.27 2,155 2027 5.24 0.88 3.51 0.01 0.02 0.12 0.14 0.02 0.03 0.05 678 Annual — — — — — — — — — — —
2026 1.33 0.46 1.93 < 0.005 0.01 0.12 0.13 0.01 0.04 0.05 357 2027 0.96 0.16 0.64 < 0.005 < 0.005 0.02 0.02 < 0.005 0.01 0.01 112
2.4. Operations Emissions Compared Against Thresholds
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Un/Mit. ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Exhibit C
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Daily, Summer — — — — — — — — — — —
(Max)
Unmit. 12.2 4.35 31.2 0.05 0.17 3.61 3.78 0.16 0.92 1.08 7,669 Mit. 11.2 4.35 31.2 0.05 0.17 3.61 3.78 0.16 0.92 1.08 7,669 % Reduced 8% — — — — — — — — — —
Daily, Winter
(Max)
— — — — — — — — — — —
Unmit. 10.7 4.53 24.6 0.05 0.15 3.61 3.76 0.15 0.92 1.07 7,506 Mit. 9.76 4.53 24.6 0.05 0.15 3.61 3.76 0.15 0.92 1.07 7,506 % Reduced 9% — — — — — — — — — —
Average Daily
(Max)
— — — — — — — — — — —
Unmit. 11.8 4.35 29.8 0.05 0.16 3.23 3.39 0.16 0.82 0.98 7,142 Mit. 10.9 4.35 29.8 0.05 0.16 3.23 3.39 0.16 0.82 0.98 7,142 % Reduced 8% — — — — — — — — — —
Annual (Max) — — — — — — — — — — —
Unmit. 2.15 0.79 5.45 0.01 0.03 0.59 0.62 0.03 0.15 0.18 1,183 Mit. 1.98 0.79 5.45 0.01 0.03 0.59 0.62 0.03 0.15 0.18 1,183 % Reduced 8% — — — — — — — — — —
2.5. Operations Emissions by Sector, Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Sector ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — — — —
Mobile 5.56 2.80 21.8 0.04 0.04 3.61 3.65 0.04 0.92 0.96 4,355 Area 6.51 0.07 8.07 < 0.005 0.01 — 0.01 0.01 — 0.01 33.3 Energy 0.08 1.47 1.24 0.01 0.11 — 0.11 0.11 — 0.11 2,763 Water — — — — — — — — — — 96.2
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Waste — — — — — — — — — — 185
Refrig. — — — — — — — — — — 236
Total 12.2 4.35 31.2 0.05 0.17 3.61 3.78 0.16 0.92 1.08 7,669 Daily, Winter
(Max)
— — — — — — — — — — —
Mobile 5.44 3.06 23.3 0.04 0.04 3.61 3.65 0.04 0.92 0.96 4,226 Area 5.19 — — — — — — — — — —
Energy 0.08 1.47 1.24 0.01 0.11 — 0.11 0.11 — 0.11 2,763 Water — — — — — — — — — — 96.2
Waste — — — — — — — — — — 185
Refrig. — — — — — — — — — — 236
Total 10.7 4.53 24.6 0.05 0.15 3.61 3.76 0.15 0.92 1.07 7,506 Average Daily — — — — — — — — — — —
Mobile 5.33 2.81 21.3 0.04 0.04 3.23 3.27 0.04 0.82 0.86 3,832 Area 6.38 0.06 7.30 < 0.005 0.01 — 0.01 0.01 — 0.01 30.1 Energy 0.08 1.47 1.24 0.01 0.11 — 0.11 0.11 — 0.11 2,763 Water — — — — — — — — — — 96.2
Waste — — — — — — — — — — 185
Refrig. — — — — — — — — — — 236
Total 11.8 4.35 29.8 0.05 0.16 3.23 3.39 0.16 0.82 0.98 7,142 Annual — — — — — — — — — — —
Mobile 0.97 0.51 3.89 0.01 0.01 0.59 0.60 0.01 0.15 0.16 634 Area 1.17 0.01 1.33 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 4.99 Energy 0.01 0.27 0.23 < 0.005 0.02 — 0.02 0.02 — 0.02 457 Water — — — — — — — — — — 15.9
Waste — — — — — — — — — — 30.7
Refrig. — — — — — — — — — — 39.2
Total 2.15 0.79 5.45 0.01 0.03 0.59 0.62 0.03 0.15 0.18 1,183 Exhibit C
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2.6. Operations Emissions by Sector, Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Sector ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — — — —
Mobile 5.56 2.80 21.8 0.04 0.04 3.61 3.65 0.04 0.92 0.96 4,355 Area 5.57 0.07 8.07 < 0.005 0.01 — 0.01 0.01 — 0.01 33.3 Energy 0.08 1.47 1.24 0.01 0.11 — 0.11 0.11 — 0.11 2,763 Water — — — — — — — — — — 96.2
Waste — — — — — — — — — — 185
Refrig. — — — — — — — — — — 236
Total 11.2 4.35 31.2 0.05 0.17 3.61 3.78 0.16 0.92 1.08 7,669 Daily, Winter
(Max)
— — — — — — — — — — —
Mobile 5.44 3.06 23.3 0.04 0.04 3.61 3.65 0.04 0.92 0.96 4,226 Area 4.24 — — — — — — — — — —
Energy 0.08 1.47 1.24 0.01 0.11 — 0.11 0.11 — 0.11 2,763 Water — — — — — — — — — — 96.2
Waste — — — — — — — — — — 185
Refrig. — — — — — — — — — — 236
Total 9.76 4.53 24.6 0.05 0.15 3.61 3.76 0.15 0.92 1.07 7,506 Average Daily — — — — — — — — — — —
Mobile 5.33 2.81 21.3 0.04 0.04 3.23 3.27 0.04 0.82 0.86 3,832 Area 5.44 0.06 7.30 < 0.005 0.01 — 0.01 0.01 — 0.01 30.1 Energy 0.08 1.47 1.24 0.01 0.11 — 0.11 0.11 — 0.11 2,763 Water — — — — — — — — — — 96.2
Waste — — — — — — — — — — 185
Refrig. — — — — — — — — — — 236
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Total 10.9 4.35 29.8 0.05 0.16 3.23 3.39 0.16 0.82 0.98 7,142 Annual — — — — — — — — — — —
Mobile 0.97 0.51 3.89 0.01 0.01 0.59 0.60 0.01 0.15 0.16 634 Area 0.99 0.01 1.33 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 4.99 Energy 0.01 0.27 0.23 < 0.005 0.02 — 0.02 0.02 — 0.02 457 Water — — — — — — — — — — 15.9
Waste — — — — — — — — — — 30.7
Refrig. — — — — — — — — — — 39.2
Total 1.98 0.79 5.45 0.01 0.03 0.59 0.62 0.03 0.15 0.18 1,183
3. Construction Emissions Details
3.1. Site Preparation (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Onsite — — — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — — — —
Off-Road
Equipment
3.14 29.2 28.8 0.05 1.24 — 1.24 1.14 — 1.14 5,316
Dust From
Material
Movement
— — — — — 19.7 19.7 — 10.1 10.1 —
Onsite truck < 0.005 0.01 < 0.005 < 0.005 < 0.005 4.00 4.00 < 0.005 0.40 0.40 5.89 Daily, Winter
(Max)
— — — — — — — — — — —
Off-Road
Equipment
3.14 29.2 28.8 0.05 1.24 — 1.24 1.14 — 1.14 5,316
Dust From
Material
Movement
— — — — — 19.7 19.7 — 10.1 10.1 —
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Onsite truck < 0.005 0.01 0.01 < 0.005 < 0.005 4.00 4.00 < 0.005 0.40 0.40 5.88 Average Daily — — — — — — — — — — —
Off-Road
Equipment
0.09 0.80 0.79 < 0.005 0.03 — 0.03 0.03 — 0.03 146
Dust From
Material
Movement
— — — — — 0.54 0.54 — 0.28 0.28 —
Onsite truck < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.11 0.11 < 0.005 0.01 0.01 0.16 Annual — — — — — — — — — — —
Off-Road
Equipment
0.02 0.15 0.14 < 0.005 0.01 — 0.01 0.01 — 0.01 24.1
Dust From
Material
Movement
— — — — — 0.10 0.10 — 0.05 0.05 —
Onsite truck < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.02 0.02 < 0.005 < 0.005 < 0.005 0.03 Offsite — — — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — — — —
Worker 0.07 0.04 0.54 0.00 0.00 0.10 0.10 0.00 0.02 0.02 107 Vendor 0.01 0.31 0.13 < 0.005 < 0.005 0.06 0.06 < 0.005 0.02 0.02 231 Hauling 0.02 0.97 0.32 < 0.005 0.01 0.18 0.19 0.01 0.05 0.06 751 Daily, Winter
(Max)
— — — — — — — — — — —
Worker 0.07 0.05 0.52 0.00 0.00 0.10 0.10 0.00 0.02 0.02 102 Vendor 0.01 0.32 0.13 < 0.005 < 0.005 0.06 0.06 < 0.005 0.02 0.02 230 Hauling 0.01 1.00 0.33 < 0.005 0.01 0.18 0.19 0.01 0.05 0.06 750 Average Daily — — — — — — — — — — —
Worker < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 2.82 Vendor < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 6.32 Hauling < 0.005 0.03 0.01 < 0.005 < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 20.6 Annual — — — — — — — — — — —
Exhibit C
Ayres Resort Expansion Detailed Report, 3/17/2025
18 / 77
Worker < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.47 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 1.05 Hauling < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 3.41
3.2. Site Preparation (2026) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Onsite — — — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — — — —
Off-Road
Equipment
0.50 2.59 28.3 0.05 0.10 — 0.10 0.10 — 0.10 5,316
Dust From
Material
Movement
— — — — — 5.11 5.11 — 2.63 2.63 —
Onsite truck < 0.005 0.01 < 0.005 < 0.005 < 0.005 1.01 1.01 < 0.005 0.10 0.10 5.89 Daily, Winter
(Max)
— — — — — — — — — — —
Off-Road
Equipment
0.50 2.59 28.3 0.05 0.10 — 0.10 0.10 — 0.10 5,316
Dust From
Material
Movement
— — — — — 5.11 5.11 — 2.63 2.63 —
Onsite truck < 0.005 0.01 0.01 < 0.005 < 0.005 1.01 1.01 < 0.005 0.10 0.10 5.88 Average Daily — — — — — — — — — — —
Off-Road
Equipment
0.01 0.07 0.78 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 146 Dust From
Material
Movement
— — — — — 0.14 0.14 — 0.07 0.07 —
Onsite truck < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.03 0.03 < 0.005 < 0.005 < 0.005 0.16 Annual — — — — — — — — — — —
Exhibit C
Ayres Resort Expansion Detailed Report, 3/17/2025
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Off-Road
Equipment
< 0.005 0.01 0.14 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 24.1 Dust From
Material
Movement
— — — — — 0.03 0.03 — 0.01 0.01 —
Onsite truck < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 0.03 Offsite — — — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — — — —
Worker 0.07 0.04 0.54 0.00 0.00 0.10 0.10 0.00 0.02 0.02 107 Vendor 0.01 0.31 0.13 < 0.005 < 0.005 0.06 0.06 < 0.005 0.02 0.02 231 Hauling 0.02 0.97 0.32 < 0.005 0.01 0.18 0.19 0.01 0.05 0.06 751 Daily, Winter
(Max)
— — — — — — — — — — —
Worker 0.07 0.05 0.52 0.00 0.00 0.10 0.10 0.00 0.02 0.02 102 Vendor 0.01 0.32 0.13 < 0.005 < 0.005 0.06 0.06 < 0.005 0.02 0.02 230 Hauling 0.01 1.00 0.33 < 0.005 0.01 0.18 0.19 0.01 0.05 0.06 750 Average Daily — — — — — — — — — — —
Worker < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 2.82 Vendor < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 6.32 Hauling < 0.005 0.03 0.01 < 0.005 < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 20.6 Annual — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.47 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 1.05 Hauling < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 3.41
3.3. Grading (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Onsite — — — — — — — — — — —
Exhibit C
Ayres Resort Expansion Detailed Report, 3/17/2025
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Daily, Summer
(Max)
— — — — — — — — — — —
Off-Road
Equipment
1.65 15.0 17.4 0.03 0.65 — 0.65 0.59 — 0.59 2,970
Dust From
Material
Movement
— — — — — 7.08 7.08 — 3.42 3.42 —
Onsite truck < 0.005 0.01 < 0.005 < 0.005 < 0.005 4.00 4.00 < 0.005 0.40 0.40 5.89 Daily, Winter
(Max)
— — — — — — — — — — —
Average Daily — — — — — — — — — — —
Off-Road
Equipment
0.09 0.82 0.96 < 0.005 0.04 — 0.04 0.03 — 0.03 163
Dust From
Material
Movement
— — — — — 0.39 0.39 — 0.19 0.19 —
Onsite truck < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.22 0.22 < 0.005 0.02 0.02 0.32 Annual — — — — — — — — — — —
Off-Road
Equipment
0.02 0.15 0.17 < 0.005 0.01 — 0.01 0.01 — 0.01 26.9
Dust From
Material
Movement
— — — — — 0.07 0.07 — 0.03 0.03 —
Onsite truck < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.04 0.04 < 0.005 < 0.005 < 0.005 0.05 Offsite — — — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — — — —
Worker 0.06 0.04 0.46 0.00 0.00 0.09 0.09 0.00 0.02 0.02 91.4 Vendor 0.01 0.31 0.13 < 0.005 < 0.005 0.06 0.06 < 0.005 0.02 0.02 231 Hauling 0.02 0.97 0.32 < 0.005 0.01 0.18 0.19 0.01 0.05 0.06 751 Daily, Winter
(Max)
— — — — — — — — — — —
Average Daily — — — — — — — — — — —
Exhibit C
Ayres Resort Expansion Detailed Report, 3/17/2025
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Worker < 0.005 < 0.005 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 4.83 Vendor < 0.005 0.02 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 12.6 Hauling < 0.005 0.05 0.02 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 41.1 Annual — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.80 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 2.09 Hauling < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 6.81
3.4. Grading (2026) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Onsite — — — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — — — —
Off-Road
Equipment
0.29 2.04 17.8 0.03 0.06 — 0.06 0.06 — 0.06 2,970
Dust From
Material
Movement
— — — — — 1.84 1.84 — 0.89 0.89 —
Onsite truck < 0.005 0.01 < 0.005 < 0.005 < 0.005 1.01 1.01 < 0.005 0.10 0.10 5.89 Daily, Winter
(Max)
— — — — — — — — — — —
Average Daily — — — — — — — — — — —
Off-Road
Equipment
0.02 0.11 0.97 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 163 Dust From
Material
Movement
— — — — — 0.10 0.10 — 0.05 0.05 —
Onsite truck < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.06 0.06 < 0.005 0.01 0.01 0.32 Annual — — — — — — — — — — —
Exhibit C
Ayres Resort Expansion Detailed Report, 3/17/2025
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Off-Road < 0.005 0.02 0.18 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 26.9 Equipment
Dust From
Material
Movement
— — — — — 0.02 0.02 — 0.01 0.01 —
Onsite truck < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 0.05 Offsite — — — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — — — —
Worker 0.06 0.04 0.46 0.00 0.00 0.09 0.09 0.00 0.02 0.02 91.4 Vendor 0.01 0.31 0.13 < 0.005 < 0.005 0.06 0.06 < 0.005 0.02 0.02 231 Hauling 0.02 0.97 0.32 < 0.005 0.01 0.18 0.19 0.01 0.05 0.06 751 Daily, Winter
(Max)
— — — — — — — — — — —
Average Daily — — — — — — — — — — —
Worker < 0.005 < 0.005 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 4.83 Vendor < 0.005 0.02 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 12.6 Hauling < 0.005 0.05 0.02 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 41.1 Annual — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.80 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 2.09 Hauling < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 6.81
3.5. Building Construction (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Onsite — — — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — — — —
Off-Road
Equipment
1.07 9.85 13.0 0.02 0.38 — 0.38 0.35 — 0.35 2,405
Exhibit C
Ayres Resort Expansion Detailed Report, 3/17/2025
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Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Daily, Winter
(Max)
— — — — — — — — — — —
Off-Road
Equipment
1.07 9.85 13.0 0.02 0.38 — 0.38 0.35 — 0.35 2,405
Onsite truck 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-Road
Equipment
0.51 4.72 6.22 0.01 0.18 — 0.18 0.17 — 0.17 1,153
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — —
Off-Road
Equipment
0.09 0.86 1.13 < 0.005 0.03 — 0.03 0.03 — 0.03 191
Onsite truck 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 0.30 0.18 2.33 0.00 0.00 0.44 0.44 0.00 0.10 0.10 464 Vendor 0.02 0.95 0.38 < 0.005 0.01 0.18 0.19 0.01 0.05 0.06 702 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Daily, Winter
(Max)
— — — — — — — — — — —
Worker 0.29 0.20 2.28 0.00 0.00 0.44 0.44 0.00 0.10 0.10 444 Vendor 0.02 0.98 0.39 < 0.005 0.01 0.18 0.19 0.01 0.05 0.06 701 Hauling 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 0.14 0.10 1.08 0.00 0.00 0.21 0.21 0.00 0.05 0.05 214 Vendor 0.01 0.47 0.18 < 0.005 < 0.005 0.08 0.09 < 0.005 0.02 0.03 336 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — —
Worker 0.03 0.02 0.20 0.00 0.00 0.04 0.04 0.00 0.01 0.01 35.5 Exhibit C
Ayres Resort Expansion Detailed Report, 3/17/2025
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Vendor < 0.005 0.09 0.03 < 0.005 < 0.005 0.02 0.02 < 0.005 < 0.005 0.01 55.7 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
3.6. Building Construction (2026) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Onsite — — — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — — — —
Off-Road
Equipment
0.47 3.12 15.0 0.02 0.11 — 0.11 0.10 — 0.10 2,405
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Daily, Winter
(Max)
— — — — — — — — — — —
Off-Road
Equipment
0.47 3.12 15.0 0.02 0.11 — 0.11 0.10 — 0.10 2,405
Onsite truck 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-Road
Equipment
0.22 1.50 7.18 0.01 0.05 — 0.05 0.05 — 0.05 1,153
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — —
Off-Road
Equipment
0.04 0.27 1.31 < 0.005 0.01 — 0.01 0.01 — 0.01 191
Onsite truck 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 0.30 0.18 2.33 0.00 0.00 0.44 0.44 0.00 0.10 0.10 464 Vendor 0.02 0.95 0.38 < 0.005 0.01 0.18 0.19 0.01 0.05 0.06 702 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Exhibit C
Ayres Resort Expansion Detailed Report, 3/17/2025
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Daily, Winter
(Max)
— — — — — — — — — — —
Worker 0.29 0.20 2.28 0.00 0.00 0.44 0.44 0.00 0.10 0.10 444 Vendor 0.02 0.98 0.39 < 0.005 0.01 0.18 0.19 0.01 0.05 0.06 701 Hauling 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 0.14 0.10 1.08 0.00 0.00 0.21 0.21 0.00 0.05 0.05 214 Vendor 0.01 0.47 0.18 < 0.005 < 0.005 0.08 0.09 < 0.005 0.02 0.03 336 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — —
Worker 0.03 0.02 0.20 0.00 0.00 0.04 0.04 0.00 0.01 0.01 35.5 Vendor < 0.005 0.09 0.03 < 0.005 < 0.005 0.02 0.02 < 0.005 < 0.005 0.01 55.7 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
3.7. Building Construction (2027) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Onsite — — — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — — — —
Daily, Winter
(Max)
— — — — — — — — — — —
Off-Road
Equipment
1.03 9.39 12.9 0.02 0.34 — 0.34 0.31 — 0.31 2,405
Onsite truck 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-Road
Equipment
0.16 1.43 1.97 < 0.005 0.05 — 0.05 0.05 — 0.05 367
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — —
Exhibit C
Ayres Resort Expansion Detailed Report, 3/17/2025
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Off-Road
Equipment
0.03 0.26 0.36 < 0.005 0.01 — 0.01 0.01 — 0.01 60.8
Onsite truck 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 0.28 0.18 2.13 0.00 0.00 0.44 0.44 0.00 0.10 0.10 436 Vendor 0.02 0.93 0.37 < 0.005 0.01 0.18 0.19 0.01 0.05 0.06 687 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily — — — — — — — — — — —
Worker 0.04 0.03 0.32 0.00 0.00 0.07 0.07 0.00 0.02 0.02 67.1 Vendor < 0.005 0.14 0.06 < 0.005 < 0.005 0.03 0.03 < 0.005 0.01 0.01 105 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — —
Worker 0.01 0.01 0.06 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 11.1 Vendor < 0.005 0.03 0.01 < 0.005 < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 17.4 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
3.8. Building Construction (2027) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Onsite — — — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — — — —
Daily, Winter
(Max)
— — — — — — — — — — —
Off-Road
Equipment
0.45 3.08 15.0 0.02 0.10 — 0.10 0.09 — 0.09 2,405
Exhibit C
Ayres Resort Expansion Detailed Report, 3/17/2025
27 / 77
Onsite truck 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-Road
Equipment
0.07 0.47 2.28 < 0.005 0.02 — 0.02 0.01 — 0.01 367
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — —
Off-Road
Equipment
0.01 0.09 0.42 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 60.8 Onsite truck 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 0.28 0.18 2.13 0.00 0.00 0.44 0.44 0.00 0.10 0.10 436 Vendor 0.02 0.93 0.37 < 0.005 0.01 0.18 0.19 0.01 0.05 0.06 687 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily — — — — — — — — — — —
Worker 0.04 0.03 0.32 0.00 0.00 0.07 0.07 0.00 0.02 0.02 67.1 Vendor < 0.005 0.14 0.06 < 0.005 < 0.005 0.03 0.03 < 0.005 0.01 0.01 105 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — —
Worker 0.01 0.01 0.06 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 11.1 Vendor < 0.005 0.03 0.01 < 0.005 < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 17.4 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
3.9. Paving (2027) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Exhibit C
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Onsite — — — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — — — —
Off-Road
Equipment
0.74 6.94 9.95 0.01 0.30 — 0.30 0.27 — 0.27 1,516
Paving 0.52 — — — — — — — — — —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Daily, Winter
(Max)
— — — — — — — — — — —
Off-Road
Equipment
0.74 6.94 9.95 0.01 0.30 — 0.30 0.27 — 0.27 1,516
Paving 0.52 — — — — — — — — — —
Onsite truck 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-Road
Equipment
0.04 0.38 0.55 < 0.005 0.02 — 0.02 0.02 — 0.02 83.1
Paving 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 Annual — — — — — — — — — — —
Off-Road
Equipment
0.01 0.07 0.10 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 13.8 Paving 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 Offsite — — — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — — — —
Worker 0.06 0.03 0.43 0.00 0.00 0.09 0.09 0.00 0.02 0.02 89.7 Vendor 0.01 0.30 0.12 < 0.005 < 0.005 0.06 0.06 < 0.005 0.02 0.02 226 Hauling 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)
— — — — — — — — — — —
Exhibit C
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Worker 0.06 0.04 0.42 0.00 0.00 0.09 0.09 0.00 0.02 0.02 85.8 Vendor 0.01 0.31 0.12 < 0.005 < 0.005 0.06 0.06 < 0.005 0.02 0.02 226 Hauling 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 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 4.74 Vendor < 0.005 0.02 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 12.4 Hauling 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 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.78 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 2.05 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
3.10. Paving (2027) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Onsite — — — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — — — —
Off-Road
Equipment
0.16 1.93 10.6 0.01 0.03 — 0.03 0.03 — 0.03 1,516
Paving 0.52 — — — — — — — — — —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Daily, Winter
(Max)
— — — — — — — — — — —
Off-Road
Equipment
0.16 1.93 10.6 0.01 0.03 — 0.03 0.03 — 0.03 1,516
Paving 0.52 — — — — — — — — — —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily — — — — — — — — — — —
Exhibit C
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Off-Road
Equipment
0.01 0.11 0.58 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 83.1 Paving 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 Annual — — — — — — — — — — —
Off-Road
Equipment
< 0.005 0.02 0.11 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 13.8 Paving 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 Offsite — — — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — — — —
Worker 0.06 0.03 0.43 0.00 0.00 0.09 0.09 0.00 0.02 0.02 89.7 Vendor 0.01 0.30 0.12 < 0.005 < 0.005 0.06 0.06 < 0.005 0.02 0.02 226 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Daily, Winter
(Max)
— — — — — — — — — — —
Worker 0.06 0.04 0.42 0.00 0.00 0.09 0.09 0.00 0.02 0.02 85.8 Vendor 0.01 0.31 0.12 < 0.005 < 0.005 0.06 0.06 < 0.005 0.02 0.02 226 Hauling 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 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 4.74 Vendor < 0.005 0.02 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 12.4 Hauling 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 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.78 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 2.05 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Exhibit C
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3.11. Architectural Coating (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Onsite — — — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — — — —
Off-Road
Equipment
0.12 0.86 1.13 < 0.005 0.02 — 0.02 0.02 — 0.02 134
Architectural
Coatings
28.8 — — — — — — — — — —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Daily, Winter
(Max)
— — — — — — — — — — —
Off-Road
Equipment
0.12 0.86 1.13 < 0.005 0.02 — 0.02 0.02 — 0.02 134
Architectural
Coatings
28.8 — — — — — — — — — —
Onsite truck 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-Road
Equipment
0.03 0.20 0.27 < 0.005 0.01 — 0.01 0.01 — 0.01 32.0
Architectural
Coatings
6.87 — — — — — — — — — —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — —
Off-Road
Equipment
0.01 0.04 0.05 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 5.30 Architectural
Coatings
1.25 — — — — — — — — — —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — —
Exhibit C
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Daily, Summer
(Max)
— — — — — — — — — — —
Worker 0.06 0.04 0.47 0.00 0.00 0.09 0.09 0.00 0.02 0.02 92.8 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Daily, Winter
(Max)
— — — — — — — — — — —
Worker 0.06 0.04 0.46 0.00 0.00 0.09 0.09 0.00 0.02 0.02 88.7 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily — — — — — — — — — — —
Worker 0.01 0.01 0.11 0.00 0.00 0.02 0.02 0.00 < 0.005 < 0.005 21.4 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — —
Worker < 0.005 < 0.005 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 3.54 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
3.12. Architectural Coating (2026) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Onsite — — — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — — — —
Off-Road
Equipment
0.02 0.65 0.96 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 134 Architectural
Coatings
28.8 — — — — — — — — — —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Exhibit C
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Daily, Winter
(Max)
— — — — — — — — — — —
Off-Road
Equipment
0.02 0.65 0.96 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 134 Architectural
Coatings
28.8 — — — — — — — — — —
Onsite truck 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-Road
Equipment
0.01 0.15 0.23 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 32.0 Architectural
Coatings
6.87 — — — — — — — — — —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — —
Off-Road
Equipment
< 0.005 0.03 0.04 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 5.30 Architectural
Coatings
1.25 — — — — — — — — — —
Onsite truck 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 0.04 0.47 0.00 0.00 0.09 0.09 0.00 0.02 0.02 92.8 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Daily, Winter
(Max)
— — — — — — — — — — —
Worker 0.06 0.04 0.46 0.00 0.00 0.09 0.09 0.00 0.02 0.02 88.7 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily — — — — — — — — — — —
Worker 0.01 0.01 0.11 0.00 0.00 0.02 0.02 0.00 < 0.005 < 0.005 21.4 Exhibit C
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Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — —
Worker < 0.005 < 0.005 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 3.54 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
3.13. Architectural Coating (2027) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Onsite — — — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — — — —
Daily, Winter
(Max)
— — — — — — — — — — —
Off-Road
Equipment
0.11 0.83 1.13 < 0.005 0.02 — 0.02 0.02 — 0.02 134
Architectural
Coatings
28.8 — — — — — — — — — —
Onsite truck 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-Road
Equipment
0.02 0.15 0.20 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 23.6 Architectural
Coatings
5.07 — — — — — — — — — —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — —
Off-Road
Equipment
< 0.005 0.03 0.04 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 3.91 Architectural
Coatings
0.93 — — — — — — — — — —
Exhibit C
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Onsite truck 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 0.04 0.43 0.00 0.00 0.09 0.09 0.00 0.02 0.02 87.1 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily — — — — — — — — — — —
Worker 0.01 0.01 0.07 0.00 0.00 0.02 0.02 0.00 < 0.005 < 0.005 15.5 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — —
Worker < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 2.56 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
3.14. Architectural Coating (2027) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Onsite — — — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — — — —
Daily, Winter
(Max)
— — — — — — — — — — —
Off-Road
Equipment
0.02 0.65 0.96 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 134 Architectural
Coatings
28.8 — — — — — — — — — —
Exhibit C
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Onsite truck 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-Road
Equipment
< 0.005 0.11 0.17 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 23.6 Architectural
Coatings
5.07 — — — — — — — — — —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — —
Off-Road
Equipment
< 0.005 0.02 0.03 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 3.91 Architectural
Coatings
0.93 — — — — — — — — — —
Onsite truck 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 0.04 0.43 0.00 0.00 0.09 0.09 0.00 0.02 0.02 87.1 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily — — — — — — — — — — —
Worker 0.01 0.01 0.07 0.00 0.00 0.02 0.02 0.00 < 0.005 < 0.005 15.5 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — —
Worker < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 2.56 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Exhibit C
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4. Operations Emissions Details
4.1. Mobile Emissions by Land Use
4.1.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — — — —
Hotel 2.28 1.15 8.97 0.02 0.02 1.48 1.50 0.02 0.38 0.39 1,788 Quality
Restaurant
1.55 0.78 6.07 0.01 0.01 1.00 1.01 0.01 0.25 0.27 1,210 Junior College
(2yr)
0.66 0.33 2.61 < 0.005 0.01 0.43 0.44 < 0.005 0.11 0.11 520 General Office
Building
1.07 0.54 4.20 0.01 0.01 0.69 0.70 0.01 0.18 0.18 836
Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Total 5.56 2.80 21.8 0.04 0.04 3.61 3.65 0.04 0.92 0.96 4,355 Daily, Winter
(Max)
— — — — — — — — — — —
Hotel 2.23 1.25 9.58 0.02 0.02 1.48 1.50 0.02 0.38 0.39 1,735 Quality
Restaurant
1.51 0.85 6.49 0.01 0.01 1.00 1.02 0.01 0.25 0.27 1,174 Junior College
(2yr)
0.65 0.36 2.79 < 0.005 0.01 0.43 0.44 < 0.005 0.11 0.11 505 General Office
Building
1.04 0.59 4.48 0.01 0.01 0.69 0.70 0.01 0.18 0.18 812
Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Total 5.44 3.06 23.3 0.04 0.04 3.61 3.65 0.04 0.92 0.96 4,226 Annual — — — — — — — — — — —
Hotel 0.40 0.23 1.69 < 0.005 < 0.005 0.27 0.27 < 0.005 0.07 0.07 289 Exhibit C
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Quality
Restaurant
0.26 0.12 0.91 < 0.005 < 0.005 0.11 0.12 < 0.005 0.03 0.03 126 Junior College
(2yr)
0.12 0.07 0.49 < 0.005 < 0.005 0.08 0.08 < 0.005 0.02 0.02 84.0 General Office
Building
0.19 0.11 0.79 < 0.005 < 0.005 0.13 0.13 < 0.005 0.03 0.03 135 Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Total 0.97 0.51 3.89 0.01 0.01 0.59 0.60 0.01 0.15 0.16 634
4.1.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — — — —
Hotel 2.28 1.15 8.97 0.02 0.02 1.48 1.50 0.02 0.38 0.39 1,788 Quality
Restaurant
1.55 0.78 6.07 0.01 0.01 1.00 1.01 0.01 0.25 0.27 1,210 Junior College
(2yr)
0.66 0.33 2.61 < 0.005 0.01 0.43 0.44 < 0.005 0.11 0.11 520 General Office
Building
1.07 0.54 4.20 0.01 0.01 0.69 0.70 0.01 0.18 0.18 836
Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Total 5.56 2.80 21.8 0.04 0.04 3.61 3.65 0.04 0.92 0.96 4,355 Daily, Winter
(Max)
— — — — — — — — — — —
Hotel 2.23 1.25 9.58 0.02 0.02 1.48 1.50 0.02 0.38 0.39 1,735 Quality
Restaurant
1.51 0.85 6.49 0.01 0.01 1.00 1.02 0.01 0.25 0.27 1,174 Junior College
(2yr)
0.65 0.36 2.79 < 0.005 0.01 0.43 0.44 < 0.005 0.11 0.11 505 General Office
Building
1.04 0.59 4.48 0.01 0.01 0.69 0.70 0.01 0.18 0.18 812
Exhibit C
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Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Total 5.44 3.06 23.3 0.04 0.04 3.61 3.65 0.04 0.92 0.96 4,226 Annual — — — — — — — — — — —
Hotel 0.40 0.23 1.69 < 0.005 < 0.005 0.27 0.27 < 0.005 0.07 0.07 289 Quality
Restaurant
0.26 0.12 0.91 < 0.005 < 0.005 0.11 0.12 < 0.005 0.03 0.03 126 Junior College
(2yr)
0.12 0.07 0.49 < 0.005 < 0.005 0.08 0.08 < 0.005 0.02 0.02 84.0 General Office
Building
0.19 0.11 0.79 < 0.005 < 0.005 0.13 0.13 < 0.005 0.03 0.03 135 Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Total 0.97 0.51 3.89 0.01 0.01 0.59 0.60 0.01 0.15 0.16 634
4.2. Energy
4.2.1. Electricity Emissions By Land Use - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — — — —
Hotel — — — — — — — — — — 506
Quality
Restaurant
— — — — — — — — — — 144
Junior College
(2yr)
— — — — — — — — — — 51.5
General Office
Building
— — — — — — — — — — 211
Parking Lot — — — — — — — — — — 86.1
Total — — — — — — — — — — 999
Daily, Winter
(Max)
— — — — — — — — — — —
Exhibit C
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Hotel — — — — — — — — — — 506
Quality
Restaurant
— — — — — — — — — — 144
Junior College
(2yr)
— — — — — — — — — — 51.5
General Office
Building
— — — — — — — — — — 211
Parking Lot — — — — — — — — — — 86.1
Total — — — — — — — — — — 999
Annual — — — — — — — — — — —
Hotel — — — — — — — — — — 83.8
Quality
Restaurant
— — — — — — — — — — 23.8
Junior College
(2yr)
— — — — — — — — — — 8.52
General Office
Building
— — — — — — — — — — 35.0
Parking Lot — — — — — — — — — — 14.3
Total — — — — — — — — — — 165
4.2.2. Electricity Emissions By Land Use - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — — — —
Hotel — — — — — — — — — — 506
Quality
Restaurant
— — — — — — — — — — 144
Junior College
(2yr)
— — — — — — — — — — 51.5
General Office
Building
— — — — — — — — — — 211
Exhibit C
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Parking Lot — — — — — — — — — — 86.1
Total — — — — — — — — — — 999
Daily, Winter
(Max)
— — — — — — — — — — —
Hotel — — — — — — — — — — 506
Quality
Restaurant
— — — — — — — — — — 144
Junior College
(2yr)
— — — — — — — — — — 51.5
General Office
Building
— — — — — — — — — — 211
Parking Lot — — — — — — — — — — 86.1
Total — — — — — — — — — — 999
Annual — — — — — — — — — — —
Hotel — — — — — — — — — — 83.8
Quality
Restaurant
— — — — — — — — — — 23.8
Junior College
(2yr)
— — — — — — — — — — 8.52
General Office
Building
— — — — — — — — — — 35.0
Parking Lot — — — — — — — — — — 14.3
Total — — — — — — — — — — 165
4.2.3. Natural Gas Emissions By Land Use - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — — — —
Hotel 0.06 1.01 0.85 0.01 0.08 — 0.08 0.08 — 0.08 1,205 Exhibit C
Ayres Resort Expansion Detailed Report, 3/17/2025
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Quality 0.01 0.20 0.17 < 0.005 0.02 — 0.02 0.02 — 0.02 239 Restaurant
Junior College
(2yr)
0.01 0.16 0.13 < 0.005 0.01 — 0.01 0.01 — 0.01 189
General Office
Building
0.01 0.11 0.09 < 0.005 0.01 — 0.01 0.01 — 0.01 130
Parking Lot 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00 Total 0.08 1.47 1.24 0.01 0.11 — 0.11 0.11 — 0.11 1,764 Daily, Winter
(Max)
— — — — — — — — — — —
Hotel 0.06 1.01 0.85 0.01 0.08 — 0.08 0.08 — 0.08 1,205 Quality
Restaurant
0.01 0.20 0.17 < 0.005 0.02 — 0.02 0.02 — 0.02 239
Junior College
(2yr)
0.01 0.16 0.13 < 0.005 0.01 — 0.01 0.01 — 0.01 189
General Office
Building
0.01 0.11 0.09 < 0.005 0.01 — 0.01 0.01 — 0.01 130
Parking Lot 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00 Total 0.08 1.47 1.24 0.01 0.11 — 0.11 0.11 — 0.11 1,764 Annual — — — — — — — — — — —
Hotel 0.01 0.18 0.15 < 0.005 0.01 — 0.01 0.01 — 0.01 200 Quality
Restaurant
< 0.005 0.04 0.03 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 39.5 Junior College
(2yr)
< 0.005 0.03 0.02 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 31.3 General Office
Building
< 0.005 0.02 0.02 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 21.6 Parking Lot 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00 Total 0.01 0.27 0.23 < 0.005 0.02 — 0.02 0.02 — 0.02 292
4.2.4. Natural Gas Emissions By Land Use - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Exhibit C
Ayres Resort Expansion Detailed Report, 3/17/2025
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Land Use ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — — — —
Hotel 0.06 1.01 0.85 0.01 0.08 — 0.08 0.08 — 0.08 1,205 Quality
Restaurant
0.01 0.20 0.17 < 0.005 0.02 — 0.02 0.02 — 0.02 239
Junior College
(2yr)
0.01 0.16 0.13 < 0.005 0.01 — 0.01 0.01 — 0.01 189
General Office
Building
0.01 0.11 0.09 < 0.005 0.01 — 0.01 0.01 — 0.01 130
Parking Lot 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00 Total 0.08 1.47 1.24 0.01 0.11 — 0.11 0.11 — 0.11 1,764 Daily, Winter
(Max)
— — — — — — — — — — —
Hotel 0.06 1.01 0.85 0.01 0.08 — 0.08 0.08 — 0.08 1,205 Quality
Restaurant
0.01 0.20 0.17 < 0.005 0.02 — 0.02 0.02 — 0.02 239
Junior College
(2yr)
0.01 0.16 0.13 < 0.005 0.01 — 0.01 0.01 — 0.01 189
General Office
Building
0.01 0.11 0.09 < 0.005 0.01 — 0.01 0.01 — 0.01 130
Parking Lot 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00 Total 0.08 1.47 1.24 0.01 0.11 — 0.11 0.11 — 0.11 1,764 Annual — — — — — — — — — — —
Hotel 0.01 0.18 0.15 < 0.005 0.01 — 0.01 0.01 — 0.01 200 Quality
Restaurant
< 0.005 0.04 0.03 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 39.5 Junior College
(2yr)
< 0.005 0.03 0.02 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 31.3 General Office
Building
< 0.005 0.02 0.02 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 21.6 Parking Lot 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00 Exhibit C
Ayres Resort Expansion Detailed Report, 3/17/2025
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Total 0.01 0.27 0.23 < 0.005 0.02 — 0.02 0.02 — 0.02 292
4.3. Area Emissions by Source
4.3.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Source ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — — — —
Consumer
Products
3.99 — — — — — — — — — —
Architectural
Coatings
1.20 — — — — — — — — — —
Landscape
Equipment
1.33 0.07 8.07 < 0.005 0.01 — 0.01 0.01 — 0.01 33.3
Total 6.51 0.07 8.07 < 0.005 0.01 — 0.01 0.01 — 0.01 33.3 Daily, Winter
(Max)
— — — — — — — — — — —
Consumer
Products
3.99 — — — — — — — — — —
Architectural
Coatings
1.20 — — — — — — — — — —
Total 5.19 — — — — — — — — — —
Annual — — — — — — — — — — —
Consumer
Products
0.73 — — — — — — — — — —
Architectural
Coatings
0.22 — — — — — — — — — —
Landscape
Equipment
0.22 0.01 1.33 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 4.99 Total 1.17 0.01 1.33 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 4.99 Exhibit C
Ayres Resort Expansion Detailed Report, 3/17/2025
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4.3.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Source ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — — — —
Consumer
Products
3.99 — — — — — — — — — —
Architectural
Coatings
0.26 — — — — — — — — — —
Landscape
Equipment
1.33 0.07 8.07 < 0.005 0.01 — 0.01 0.01 — 0.01 33.3
Total 5.57 0.07 8.07 < 0.005 0.01 — 0.01 0.01 — 0.01 33.3 Daily, Winter
(Max)
— — — — — — — — — — —
Consumer
Products
3.99 — — — — — — — — — —
Architectural
Coatings
0.26 — — — — — — — — — —
Total 4.24 — — — — — — — — — —
Annual — — — — — — — — — — —
Consumer
Products
0.73 — — — — — — — — — —
Architectural
Coatings
0.05 — — — — — — — — — —
Landscape
Equipment
0.22 0.01 1.33 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 4.99 Total 0.99 0.01 1.33 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 4.99
4.4. Water Emissions by Land Use
4.4.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Exhibit C
Ayres Resort Expansion Detailed Report, 3/17/2025
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Land Use ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — — — —
Hotel — — — — — — — — — — 29.0
Quality
Restaurant
— — — — — — — — — — 20.9
Junior College
(2yr)
— — — — — — — — — — 9.51
General Office
Building
— — — — — — — — — — 36.4
Parking Lot — — — — — — — — — — 0.39
Total — — — — — — — — — — 96.2
Daily, Winter
(Max)
— — — — — — — — — — —
Hotel — — — — — — — — — — 29.0
Quality
Restaurant
— — — — — — — — — — 20.9
Junior College
(2yr)
— — — — — — — — — — 9.51
General Office
Building
— — — — — — — — — — 36.4
Parking Lot — — — — — — — — — — 0.39
Total — — — — — — — — — — 96.2
Annual — — — — — — — — — — —
Hotel — — — — — — — — — — 4.80
Quality
Restaurant
— — — — — — — — — — 3.46
Junior College
(2yr)
— — — — — — — — — — 1.57
General Office
Building
— — — — — — — — — — 6.02
Parking Lot — — — — — — — — — — 0.06
Exhibit C
Ayres Resort Expansion Detailed Report, 3/17/2025
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Total — — — — — — — — — — 15.9
4.4.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — — — —
Hotel — — — — — — — — — — 29.0
Quality
Restaurant
— — — — — — — — — — 20.9
Junior College
(2yr)
— — — — — — — — — — 9.51
General Office
Building
— — — — — — — — — — 36.4
Parking Lot — — — — — — — — — — 0.39
Total — — — — — — — — — — 96.2
Daily, Winter
(Max)
— — — — — — — — — — —
Hotel — — — — — — — — — — 29.0
Quality
Restaurant
— — — — — — — — — — 20.9
Junior College
(2yr)
— — — — — — — — — — 9.51
General Office
Building
— — — — — — — — — — 36.4
Parking Lot — — — — — — — — — — 0.39
Total — — — — — — — — — — 96.2
Annual — — — — — — — — — — —
Hotel — — — — — — — — — — 4.80
Quality
Restaurant
— — — — — — — — — — 3.46
Exhibit C
Ayres Resort Expansion Detailed Report, 3/17/2025
48 / 77
Junior College
(2yr)
— — — — — — — — — — 1.57
General Office
Building
— — — — — — — — — — 6.02
Parking Lot — — — — — — — — — — 0.06
Total — — — — — — — — — — 15.9
4.5. Waste Emissions by Land Use
4.5.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — — — —
Hotel — — — — — — — — — — 103
Quality
Restaurant
— — — — — — — — — — 10.3
Junior College
(2yr)
— — — — — — — — — — 40.4
General Office
Building
— — — — — — — — — — 31.5
Parking Lot — — — — — — — — — — 0.00
Total — — — — — — — — — — 185
Daily, Winter
(Max)
— — — — — — — — — — —
Hotel — — — — — — — — — — 103
Quality
Restaurant
— — — — — — — — — — 10.3
Junior College
(2yr)
— — — — — — — — — — 40.4
General Office
Building
— — — — — — — — — — 31.5
Exhibit C
Ayres Resort Expansion Detailed Report, 3/17/2025
49 / 77
Parking Lot — — — — — — — — — — 0.00
Total — — — — — — — — — — 185
Annual — — — — — — — — — — —
Hotel — — — — — — — — — — 17.1
Quality
Restaurant
— — — — — — — — — — 1.71
Junior College
(2yr)
— — — — — — — — — — 6.70
General Office
Building
— — — — — — — — — — 5.21
Parking Lot — — — — — — — — — — 0.00
Total — — — — — — — — — — 30.7
4.5.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — — — —
Hotel — — — — — — — — — — 103
Quality
Restaurant
— — — — — — — — — — 10.3
Junior College
(2yr)
— — — — — — — — — — 40.4
General Office
Building
— — — — — — — — — — 31.5
Parking Lot — — — — — — — — — — 0.00
Total — — — — — — — — — — 185
Daily, Winter
(Max)
— — — — — — — — — — —
Hotel — — — — — — — — — — 103
Exhibit C
Ayres Resort Expansion Detailed Report, 3/17/2025
50 / 77
Quality — — — — — — — — — — 10.3
Restaurant
Junior College
(2yr)
— — — — — — — — — — 40.4
General Office
Building
— — — — — — — — — — 31.5
Parking Lot — — — — — — — — — — 0.00
Total — — — — — — — — — — 185
Annual — — — — — — — — — — —
Hotel — — — — — — — — — — 17.1
Quality
Restaurant
— — — — — — — — — — 1.71
Junior College
(2yr)
— — — — — — — — — — 6.70
General Office
Building
— — — — — — — — — — 5.21
Parking Lot — — — — — — — — — — 0.00
Total — — — — — — — — — — 30.7
4.6. Refrigerant Emissions by Land Use
4.6.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — — — —
Hotel — — — — — — — — — — 227
Quality
Restaurant
— — — — — — — — — — 9.38
Junior College
(2yr)
— — — — — — — — — — 0.06
Exhibit C
Ayres Resort Expansion Detailed Report, 3/17/2025
51 / 77
General Office — — — — — — — — — — 0.04
Building
Total — — — — — — — — — — 236
Daily, Winter
(Max)
— — — — — — — — — — —
Hotel — — — — — — — — — — 227
Quality
Restaurant
— — — — — — — — — — 9.38
Junior College
(2yr)
— — — — — — — — — — 0.06
General Office
Building
— — — — — — — — — — 0.04
Total — — — — — — — — — — 236
Annual — — — — — — — — — — —
Hotel — — — — — — — — — — 37.6
Quality
Restaurant
— — — — — — — — — — 1.55
Junior College
(2yr)
— — — — — — — — — — 0.01
General Office
Building
— — — — — — — — — — 0.01
Total — — — — — — — — — — 39.2
4.6.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — — — —
Hotel — — — — — — — — — — 227
Quality
Restaurant
— — — — — — — — — — 9.38
Exhibit C
Ayres Resort Expansion Detailed Report, 3/17/2025
52 / 77
Junior College — — — — — — — — — — 0.06
(2yr)
General Office
Building
— — — — — — — — — — 0.04
Total — — — — — — — — — — 236
Daily, Winter
(Max)
— — — — — — — — — — —
Hotel — — — — — — — — — — 227
Quality
Restaurant
— — — — — — — — — — 9.38
Junior College
(2yr)
— — — — — — — — — — 0.06
General Office
Building
— — — — — — — — — — 0.04
Total — — — — — — — — — — 236
Annual — — — — — — — — — — —
Hotel — — — — — — — — — — 37.6
Quality
Restaurant
— — — — — — — — — — 1.55
Junior College
(2yr)
— — — — — — — — — — 0.01
General Office
Building
— — — — — — — — — — 0.01
Total — — — — — — — — — — 39.2
4.7. Offroad Emissions By Equipment Type
4.7.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipment
Type
ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Exhibit C
Ayres Resort Expansion Detailed Report, 3/17/2025
53 / 77
Daily, Summer — — — — — — — — — — —
(Max)
Total — — — — — — — — — — —
Daily, Winter
(Max)
— — — — — — — — — — —
Total — — — — — — — — — — —
Annual — — — — — — — — — — —
Total — — — — — — — — — — —
4.7.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipment
Type
ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — — — —
Total — — — — — — — — — — —
Daily, Winter
(Max)
— — — — — — — — — — —
Total — — — — — — — — — — —
Annual — — — — — — — — — — —
Total — — — — — — — — — — —
4.8. Stationary Emissions By Equipment Type
4.8.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipment
Type
ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — — — —
Total — — — — — — — — — — —
Exhibit C
Ayres Resort Expansion Detailed Report, 3/17/2025
54 / 77
Daily, Winter
(Max)
— — — — — — — — — — —
Total — — — — — — — — — — —
Annual — — — — — — — — — — —
Total — — — — — — — — — — —
4.8.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipment
Type
ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — — — —
Total — — — — — — — — — — —
Daily, Winter
(Max)
— — — — — — — — — — —
Total — — — — — — — — — — —
Annual — — — — — — — — — — —
Total — — — — — — — — — — —
4.9. User Defined Emissions By Equipment Type
4.9.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipment
Type
ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — — — —
Total — — — — — — — — — — —
Daily, Winter
(Max)
— — — — — — — — — — —
Total — — — — — — — — — — —
Exhibit C
Ayres Resort Expansion Detailed Report, 3/17/2025
55 / 77
Annual — — — — — — — — — — —
Total — — — — — — — — — — —
4.9.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipment
Type
ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — — — —
Total — — — — — — — — — — —
Daily, Winter
(Max)
— — — — — — — — — — —
Total — — — — — — — — — — —
Annual — — — — — — — — — — —
Total — — — — — — — — — — —
4.10. Soil Carbon Accumulation By Vegetation Type
4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Vegetation ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — — — —
Total — — — — — — — — — — —
Daily, Winter
(Max)
— — — — — — — — — — —
Total — — — — — — — — — — —
Annual — — — — — — — — — — —
Total — — — — — — — — — — —
Exhibit C
Ayres Resort Expansion Detailed Report, 3/17/2025
56 / 77
4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — — — —
Total — — — — — — — — — — —
Daily, Winter
(Max)
— — — — — — — — — — —
Total — — — — — — — — — — —
Annual — — — — — — — — — — —
Total — — — — — — — — — — —
4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Species ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — — — —
Avoided — — — — — — — — — — —
Subtotal — — — — — — — — — — —
Sequestered — — — — — — — — — — —
Subtotal — — — — — — — — — — —
Removed — — — — — — — — — — —
Subtotal — — — — — — — — — — —
— — — — — — — — — — — —
Daily, Winter
(Max)
— — — — — — — — — — —
Avoided — — — — — — — — — — —
Subtotal — — — — — — — — — — —
Sequestered — — — — — — — — — — —
Exhibit C
Ayres Resort Expansion Detailed Report, 3/17/2025
57 / 77
Subtotal — — — — — — — — — — —
Removed — — — — — — — — — — —
Subtotal — — — — — — — — — — —
— — — — — — — — — — — —
Annual — — — — — — — — — — —
Avoided — — — — — — — — — — —
Subtotal — — — — — — — — — — —
Sequestered — — — — — — — — — — —
Subtotal — — — — — — — — — — —
Removed — — — — — — — — — — —
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) Vegetation ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — — — —
Total — — — — — — — — — — —
Daily, Winter
(Max)
— — — — — — — — — — —
Total — — — — — — — — — — —
Annual — — — — — — — — — — —
Total — — — — — — — — — — —
4.10.5. Above and Belowground Carbon Accumulation by Land Use Type - Mitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Exhibit C
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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 ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — — — —
Avoided — — — — — — — — — — —
Subtotal — — — — — — — — — — —
Sequestered — — — — — — — — — — —
Subtotal — — — — — — — — — — —
Removed — — — — — — — — — — —
Subtotal — — — — — — — — — — —
— — — — — — — — — — — —
Daily, Winter
(Max)
— — — — — — — — — — —
Avoided — — — — — — — — — — —
Subtotal — — — — — — — — — — —
Sequestered — — — — — — — — — — —
Subtotal — — — — — — — — — — —
Removed — — — — — — — — — — —
Subtotal — — — — — — — — — — —
— — — — — — — — — — — —
Exhibit C
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Annual — — — — — — — — — — —
Avoided — — — — — — — — — — —
Subtotal — — — — — — — — — — —
Sequestered — — — — — — — — — — —
Subtotal — — — — — — — — — — —
Removed — — — — — — — — — — —
Subtotal — — — — — — — — — — —
— — — — — — — — — — — —
5. Activity Data
5.1. Construction Schedule
Phase Name Phase Type Start Date End Date Days Per Week Work Days per Phase Phase Description Site Preparation Site Preparation 3/18/2026 4/1/2026 5.00 10.0 — Grading Grading 4/2/2026 4/30/2026 5.00 20.0 —
Building Construction Building Construction 5/1/2026 3/19/2027 5.00 230 — Paving Paving 3/20/2027 4/17/2027 5.00 20.0 —
Architectural Coating Architectural Coating 9/1/2026 3/31/2027 5.00 152 —
5.2. Off-Road Equipment
5.2.1. Unmitigated
Phase Name Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor Site Preparation Rubber Tired Dozers Diesel Average 3.00 8.00 367 0.40 Site Preparation Tractors/Loaders/Back
hoes
Diesel Average 4.00 8.00 84.0 0.37
Grading Excavators Diesel Average 1.00 8.00 36.0 0.38
Grading Graders Diesel Average 1.00 8.00 148 0.41
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Grading Rubber Tired Dozers Diesel Average 1.00 8.00 367 0.40 Grading Tractors/Loaders/Back
hoes
Diesel Average 3.00 8.00 84.0 0.37
Building Construction Cranes Diesel Average 1.00 7.00 367 0.29 Building Construction Forklifts Diesel Average 3.00 8.00 82.0 0.20 Building Construction Generator Sets Diesel Average 1.00 8.00 14.0 0.74 Building Construction Tractors/Loaders/Back
hoes
Diesel Average 3.00 7.00 84.0 0.37
Building Construction Welders Diesel Average 1.00 8.00 46.0 0.45 Paving Pavers Diesel Average 2.00 8.00 81.0 0.42
Paving Paving Equipment Diesel Average 2.00 8.00 89.0 0.36 Paving Rollers Diesel Average 2.00 8.00 36.0 0.38
Architectural Coating Air Compressors Diesel Average 1.00 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 Site Preparation Rubber Tired Dozers Diesel Tier 4 Final 3.00 8.00 367 0.40 Site Preparation Tractors/Loaders/Back
hoes
Diesel Tier 4 Final 4.00 8.00 84.0 0.37
Grading Excavators Diesel Tier 4 Final 1.00 8.00 36.0 0.38 Grading Graders Diesel Tier 4 Final 1.00 8.00 148 0.41
Grading Rubber Tired Dozers Diesel Tier 4 Final 1.00 8.00 367 0.40 Grading Tractors/Loaders/Back
hoes
Diesel Tier 4 Final 3.00 8.00 84.0 0.37
Building Construction Cranes Diesel Tier 4 Final 1.00 7.00 367 0.29 Building Construction Forklifts Diesel Tier 4 Final 3.00 8.00 82.0 0.20 Building Construction Generator Sets Diesel Average 1.00 8.00 14.0 0.74 Building Construction Tractors/Loaders/Back
hoes
Diesel Tier 4 Final 3.00 7.00 84.0 0.37
Building Construction Welders Diesel Average 1.00 8.00 46.0 0.45 Exhibit C
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Paving Pavers Diesel Tier 4 Final 2.00 8.00 81.0 0.42
Paving Paving Equipment Diesel Tier 4 Final 2.00 8.00 89.0 0.36 Paving Rollers Diesel Tier 4 Final 2.00 8.00 36.0 0.38
Architectural Coating Air Compressors Diesel Tier 4 Final 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 Site Preparation — — — —
Site Preparation Worker 17.5 8.10 LDA,LDT1,LDT2
Site Preparation Vendor 10.0 6.90 HHDT,MHDT
Site Preparation Hauling 10.0 20.0 HHDT
Site Preparation Onsite truck 1.00 2.00 MHDT
Grading — — — —
Grading Worker 15.0 8.10 LDA,LDT1,LDT2
Grading Vendor 10.0 6.90 HHDT,MHDT
Grading Hauling 10.0 20.0 HHDT
Grading Onsite truck 1.00 2.00 MHDT
Building Construction — — — —
Building Construction Worker 76.2 8.10 LDA,LDT1,LDT2
Building Construction Vendor 30.4 6.90 HHDT,MHDT
Building Construction Hauling 0.00 20.0 HHDT
Building Construction Onsite truck — — HHDT
Paving — — — —
Paving Worker 15.0 8.10 LDA,LDT1,LDT2
Paving Vendor 10.0 6.90 HHDT,MHDT
Paving Hauling 0.00 20.0 HHDT
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Paving Onsite truck — — HHDT
Architectural Coating — — — —
Architectural Coating Worker 15.2 8.10 LDA,LDT1,LDT2
Architectural Coating Vendor — 6.90 HHDT,MHDT
Architectural Coating Hauling 0.00 20.0 HHDT
Architectural Coating Onsite truck — — HHDT
5.3.2. Mitigated
Phase Name Trip Type One-Way Trips per Day Miles per Trip Vehicle Mix Site Preparation — — — —
Site Preparation Worker 17.5 8.10 LDA,LDT1,LDT2
Site Preparation Vendor 10.0 6.90 HHDT,MHDT
Site Preparation Hauling 10.0 20.0 HHDT
Site Preparation Onsite truck 1.00 2.00 MHDT
Grading — — — —
Grading Worker 15.0 8.10 LDA,LDT1,LDT2
Grading Vendor 10.0 6.90 HHDT,MHDT
Grading Hauling 10.0 20.0 HHDT
Grading Onsite truck 1.00 2.00 MHDT
Building Construction — — — —
Building Construction Worker 76.2 8.10 LDA,LDT1,LDT2
Building Construction Vendor 30.4 6.90 HHDT,MHDT
Building Construction Hauling 0.00 20.0 HHDT
Building Construction Onsite truck — — HHDT
Paving — — — —
Paving Worker 15.0 8.10 LDA,LDT1,LDT2
Paving Vendor 10.0 6.90 HHDT,MHDT
Paving Hauling 0.00 20.0 HHDT
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Paving Onsite truck — — HHDT
Architectural Coating — — — —
Architectural Coating Worker 15.2 8.10 LDA,LDT1,LDT2
Architectural Coating Vendor — 6.90 HHDT,MHDT
Architectural Coating Hauling 0.00 20.0 HHDT
Architectural Coating Onsite truck — — HHDT
5.4. Vehicles
5.4.1. Construction Vehicle Control Strategies
Non-applicable. No control strategies activated by user.
5.5. Architectural Coatings
Phase Name Residential Interior Area
Coated (sq ft)
Residential Exterior Area
Coated (sq ft)
Non-Residential Interior Area
Coated (sq ft)
Non-Residential Exterior Area
Coated (sq ft)
Parking Area Coated (sq ft)
Architectural Coating 0.00 0.00 278,475 92,825 10,454
5.6. Dust Mitigation
5.6.1. Construction Earthmoving Activities
Phase Name Material Imported (cy) Material Exported (cy) Acres Graded (acres) Material Demolished (sq. ft.) Acres Paved (acres) Site Preparation — — 15.0 0.00 —
Grading — — 20.0 0.00 —
Paving 0.00 0.00 0.00 0.00 4.00
5.6.2. Construction Earthmoving Control Strategies
Non-applicable. No control strategies activated by user.
5.7. Construction Paving
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Land Use Area Paved (acres) % Asphalt
Hotel 0.00 0%
Quality Restaurant 0.00 0%
Junior College (2yr) 0.00 0%
General Office Building 0.00 0%
Parking Lot 4.00 100%
5.8. Construction Electricity Consumption and Emissions Factors kWh per Year and Emission Factor (lb/MWh)
Year kWh per Year CO2 CH4 N2O
2026 0.00 204 0.03 < 0.005
2027 0.00 204 0.03 < 0.005
5.9. Operational Mobile Sources
5.9.1. Unmitigated
Land Use Type Trips/Weekday Trips/Saturday Trips/Sunday Trips/Year VMT/Weekday VMT/Saturday VMT/Sunday VMT/Year Hotel 588 588 588 214,620 2,095 2,095 2,095 764,500
Quality Restaurant 398 398 398 145,270 667 1,418 1,418 321,698 Junior College (2yr) 171 171 171 62,415 609 609 609 222,329 General Office
Building
275 275 275 100,375 980 980 980 357,547
Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
5.9.2. Mitigated
Land Use Type Trips/Weekday Trips/Saturday Trips/Sunday Trips/Year VMT/Weekday VMT/Saturday VMT/Sunday VMT/Year Hotel 588 588 588 214,620 2,095 2,095 2,095 764,500
Quality Restaurant 398 398 398 145,270 667 1,418 1,418 321,698 Exhibit C
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Junior College (2yr) 171 171 171 62,415 609 609 609 222,329 General Office
Building
275 275 275 100,375 980 980 980 357,547
Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
5.10. Operational Area Sources
5.10.1. Hearths
5.10.1.1. Unmitigated
5.10.1.2. Mitigated
5.10.2. Architectural Coatings
Residential Interior Area Coated (sq
ft)
Residential Exterior Area Coated (sq
ft)
Non-Residential Interior Area Coated
(sq ft)
Non-Residential Exterior Area
Coated (sq ft)
Parking Area Coated (sq ft)
0 0.00 278,475 92,825 10,454
5.10.3. Landscape Equipment
Season Unit Value
Snow Days day/yr 0.00
Summer Days day/yr 330
5.10.4. Landscape Equipment - Mitigated
Season Unit Value
Snow Days day/yr 0.00
Summer Days day/yr 330
5.11. Operational Energy Consumption
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5.11.1. Unmitigated
Electricity (kWh/yr) and CO2 and CH4 and N2O and Natural Gas (kBTU/yr) Land Use Electricity (kWh/yr) CO2 CH4 N2O Natural Gas (kBTU/yr) Hotel 896,676 204 0.0330 0.0040 3,750,043
Quality Restaurant 254,716 204 0.0330 0.0040 743,210
Junior College (2yr) 91,173 204 0.0330 0.0040 589,199
General Office Building 374,641 204 0.0330 0.0040 405,454 Parking Lot 152,634 204 0.0330 0.0040 0.00
5.11.2. Mitigated
Electricity (kWh/yr) and CO2 and CH4 and N2O and Natural Gas (kBTU/yr) Land Use Electricity (kWh/yr) CO2 CH4 N2O Natural Gas (kBTU/yr) Hotel 896,676 204 0.0330 0.0040 3,750,043
Quality Restaurant 254,716 204 0.0330 0.0040 743,210
Junior College (2yr) 91,173 204 0.0330 0.0040 589,199
General Office Building 374,641 204 0.0330 0.0040 405,454 Parking Lot 152,634 204 0.0330 0.0040 0.00
5.12. Operational Water and Wastewater Consumption
5.12.1. Unmitigated
Land Use Indoor Water (gal/year) Outdoor Water (gal/year) Hotel 2,536,677 177,839
Quality Restaurant 1,821,202 177,839
Junior College (2yr) 809,309 177,839
General Office Building 3,190,321 177,839
Parking Lot 0.00 177,839
Exhibit C
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5.12.2. Mitigated
Land Use Indoor Water (gal/year) Outdoor Water (gal/year) Hotel 2,536,677 177,839
Quality Restaurant 1,821,202 177,839
Junior College (2yr) 809,309 177,839
General Office Building 3,190,321 177,839
Parking Lot 0.00 177,839
5.13. Operational Waste Generation
5.13.1. Unmitigated
Land Use Waste (ton/year) Cogeneration (kWh/year)
Hotel 54.8 —
Quality Restaurant 5.47 —
Junior College (2yr) 21.4 —
General Office Building 16.7 —
Parking Lot 0.00 —
5.13.2. Mitigated
Land Use Waste (ton/year) Cogeneration (kWh/year)
Hotel 54.8 —
Quality Restaurant 5.47 —
Junior College (2yr) 21.4 —
General Office Building 16.7 —
Parking Lot 0.00 —
5.14. Operational Refrigeration and Air Conditioning Equipment Exhibit C
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5.14.1. Unmitigated
Land Use Type Equipment Type Refrigerant GWP Quantity (kg) Operations Leak Rate Service Leak Rate Times Serviced Hotel Household
refrigerators and/or
freezers
R-134a 1,430 0.00 0.60 0.00 1.00
Hotel Other commercial A/C
and heat pumps
R-410A 2,088 1.80 4.00 4.00 18.0
Hotel Walk-in refrigerators
and freezers
R-404A 3,922 < 0.005 7.50 7.50 20.0
Quality Restaurant Household
refrigerators and/or
freezers
R-134a 1,430 0.00 0.60 0.00 1.00
Quality Restaurant Other commercial A/C
and heat pumps
R-410A 2,088 1.80 4.00 4.00 18.0
Quality Restaurant Walk-in refrigerators
and freezers
R-404A 3,922 < 0.005 7.50 7.50 20.0
Junior College (2yr) Household
refrigerators and/or
freezers
R-134a 1,430 0.02 0.60 0.00 1.00
Junior College (2yr) Other commercial A/C
and heat pumps
R-410A 2,088 < 0.005 4.00 4.00 18.0
Junior College (2yr) Stand-alone retail
refrigerators and
freezers
R-134a 1,430 < 0.005 1.00 0.00 1.00
Junior College (2yr) Walk-in refrigerators
and freezers
R-404A 3,922 < 0.005 7.50 7.50 20.0
General Office
Building
Household
refrigerators and/or
freezers
R-134a 1,430 0.02 0.60 0.00 1.00
General Office
Building
Other commercial A/C
and heat pumps
R-410A 2,088 < 0.005 4.00 4.00 18.0
5.14.2. Mitigated
Land Use Type Equipment Type Refrigerant GWP Quantity (kg) Operations Leak Rate Service Leak Rate Times Serviced Exhibit C
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Hotel Household
refrigerators and/or
freezers
R-134a 1,430 0.00 0.60 0.00 1.00
Hotel Other commercial A/C
and heat pumps
R-410A 2,088 1.80 4.00 4.00 18.0
Hotel Walk-in refrigerators
and freezers
R-404A 3,922 < 0.005 7.50 7.50 20.0
Quality Restaurant Household
refrigerators and/or
freezers
R-134a 1,430 0.00 0.60 0.00 1.00
Quality Restaurant Other commercial A/C
and heat pumps
R-410A 2,088 1.80 4.00 4.00 18.0
Quality Restaurant Walk-in refrigerators
and freezers
R-404A 3,922 < 0.005 7.50 7.50 20.0
Junior College (2yr) Household
refrigerators and/or
freezers
R-134a 1,430 0.02 0.60 0.00 1.00
Junior College (2yr) Other commercial A/C
and heat pumps
R-410A 2,088 < 0.005 4.00 4.00 18.0
Junior College (2yr) Stand-alone retail
refrigerators and
freezers
R-134a 1,430 < 0.005 1.00 0.00 1.00
Junior College (2yr) Walk-in refrigerators
and freezers
R-404A 3,922 < 0.005 7.50 7.50 20.0
General Office
Building
Household
refrigerators and/or
freezers
R-134a 1,430 0.02 0.60 0.00 1.00
General Office
Building
Other commercial A/C
and heat pumps
R-410A 2,088 < 0.005 4.00 4.00 18.0
5.15. Operational Off-Road Equipment
5.15.1. Unmitigated
Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor Exhibit C
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5.15.2. Mitigated
Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor
5.16. Stationary Sources
5.16.1. Emergency Generators and Fire Pumps
Equipment Type Fuel Type Number per Day Hours per Day Hours per Year Horsepower Load Factor
5.16.2. Process Boilers
Equipment Type Fuel Type Number Boiler Rating (MMBtu/hr) Daily Heat Input (MMBtu/day) Annual Heat Input (MMBtu/yr)
5.17. User Defined
Equipment Type Fuel Type
5.18. Vegetation
5.18.1. Land Use Change
5.18.1.1. Unmitigated
Vegetation Land Use Type Vegetation Soil Type Initial Acres Final Acres
5.18.1.2. Mitigated
Vegetation Land Use Type Vegetation Soil Type Initial Acres Final Acres
5.18.1. Biomass Cover Type
5.18.1.1. Unmitigated
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Biomass Cover Type Initial Acres Final Acres
5.18.1.2. Mitigated
Biomass Cover Type Initial Acres Final Acres
5.18.2. Sequestration
5.18.2.1. Unmitigated
Tree Type Number Electricity Saved (kWh/year) Natural Gas Saved (btu/year)
5.18.2.2. Mitigated
Tree Type Number Electricity Saved (kWh/year) Natural Gas Saved (btu/year)
6. Climate Risk Detailed Report
6.1. Climate Risk Summary
Cal-Adapt midcentury 2040–2059 average projections for four hazards are reported below for your project location. These are under Representation Concentration Pathway (RCP) 8.5 which assumes GHG emissions will continue to rise strongly through 2050 and then plateau around 2100.
Climate Hazard Result for Project Location Unit
Temperature and Extreme Heat 21.8 annual days of extreme heat Extreme Precipitation 3.80 annual days with precipitation above 20 mm Sea Level Rise — meters of inundation depth
Wildfire 21.9 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.
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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 1 0 0 N/A
Wildfire 1 0 0 N/A
Flooding N/A N/A N/A N/A
Drought 0 0 0 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 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 1 1 1 2
Wildfire 1 1 1 2
Flooding N/A N/A N/A N/A
Drought 1 1 1 2
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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 42.8
AQ-PM 6.43
AQ-DPM 11.4
Drinking Water 63.5
Lead Risk Housing 6.78
Pesticides 70.3
Toxic Releases 11.7
Traffic 15.7
Effect Indicators —
CleanUp Sites 79.8
Groundwater 22.1
Haz Waste Facilities/Generators 96.0
Impaired Water Bodies 33.2
Solid Waste 0.00
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Sensitive Population —
Asthma 50.5
Cardio-vascular 23.5
Low Birth Weights 41.9
Socioeconomic Factor Indicators —
Education 29.3
Housing 48.5
Linguistic 0.00
Poverty 31.3
Unemployment 57.2
7.2. Healthy Places Index Scores
The maximum Health Places Index score is 100. A high score (i.e., greater than 50) reflects healthier community conditions compared to other census tracts in the state.
Indicator Result for Project Census Tract
Economic —
Above Poverty 71.0252791
Employed 91.65918132
Median HI 67.58629539
Education —
Bachelor's or higher 51.50776338
High school enrollment 100
Preschool enrollment 48.90286154
Transportation —
Auto Access 68.11240857
Active commuting 3.644296163
Social —
2-parent households 87.79674066
Voting 92.57025536
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Neighborhood—
Alcohol availability 54.70293853
Park access 8.084178109
Retail density 13.90991916
Supermarket access 33.38893879
Tree canopy 42.24303862
Housing—
Homeownership 83.48517901
Housing habitability 88.47683819
Low-inc homeowner severe housing cost burden 31.90042346 Low-inc renter severe housing cost burden 92.57025536
Uncrowded housing 64.30129603
Health Outcomes—
Insured adults 91.7875016
Arthritis 0.0
Asthma ER Admissions 45.7
High Blood Pressure 0.0
Cancer (excluding skin) 0.0
Asthma 0.0
Coronary Heart Disease 0.0
Chronic Obstructive Pulmonary Disease 0.0
Diagnosed Diabetes 0.0
Life Expectancy at Birth 59.3
Cognitively Disabled 93.6
Physically Disabled 83.0
Heart Attack ER Admissions 67.5
Mental Health Not Good 0.0
Chronic Kidney Disease 0.0
Exhibit C
Ayres Resort Expansion Detailed Report, 3/17/2025
76 / 77
Obesity 0.0
Pedestrian Injuries 19.6
Physical Health Not Good 0.0
Stroke 0.0
Health Risk Behaviors —
Binge Drinking 0.0
Current Smoker 0.0
No Leisure Time for Physical Activity 0.0
Climate Change Exposures —
Wildfire Risk 0.0
SLR Inundation Area 0.0
Children 50.1
Elderly 23.5
English Speaking 92.9
Foreign-born 8.5
Outdoor Workers 8.2
Climate Change Adaptive Capacity —
Impervious Surface Cover 86.1
Traffic Density 17.1
Traffic Access 0.0
Other Indices —
Hardship 25.3
Other Decision Support —
2016 Voting 89.1
7.3. Overall Health & Equity Scores
Metric Result for Project Census Tract
CalEnviroScreen 4.0 Score for Project Location (a) 27.0 Exhibit C
Ayres Resort Expansion Detailed Report, 3/17/2025
77 / 77
Healthy Places Index Score for Project Location (b) 76.0 Project Located in a Designated Disadvantaged Community (Senate Bill 535) No Project Located in a Low-Income Community (Assembly Bill 1550) No Project Located in a Community Air Protection Program Community (Assembly Bill 617) No a: The maximum CalEnviroScreen score is 100. A high score (i.e., greater than 50) reflects a higher pollution burden compared to other census tracts in the state. b: The maximum Health Places Index score is 100. A high score (i.e., greater than 50) reflects healthier community conditions compared to other census tracts in the state.
7.4. Health & Equity Measures
No Health & Equity Measures selected.
7.5. Evaluation Scorecard
Health & Equity Evaluation Scorecard not completed.
7.6. Health & Equity Custom Measures
No Health & Equity Custom Measures created.
8. User Changes to Default Data
Screen Justification
Construction: Construction Phases Based on model defaults. Arch coating estimated to begin four months after start of construction.
Operations: Vehicle Data Based on traffic analysis trip gen rates Operations: Water and Waste Water Based on project ETAF dispersed equally Construction: Trips and VMT Includes 2 miles of travel daily for onsite water truck travel. Includes 10 MHD/HHDT vendor trips/day and 10 HHDT trips/day during site preparation and grading. All other based on model defaults.
Exhibit C
Ayres Resort Expansion Quarterly Report, 3/17/2025
1 / 5
Ayres Resort Expansion Quarterly 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
2.1.1. Construction Emissions Compared Against Thresholds
2.1.2. Construction Quarters
2.4. Operations Emissions Compared Against Thresholds
Exhibit C
Ayres Resort Expansion Quarterly Report, 3/17/2025
2 / 5
1. Basic Project Information
1.1. Basic Project Information
Data Field Value
Project Name Ayres Resort Expansion
Construction Start Date 2/17/2026
Operational Year 2028
Lead Agency —
Land Use Scale Project/site
Analysis Level for Defaults County
Windspeed (m/s) 3.00
Precipitation (days) 0.20
Location 35.64841193637051, -120.67048201594922
County San Luis Obispo
City Paso Robles
Air District San Luis Obispo County APCD
Air Basin South Central Coast
TAZ 3307
EDFZ 6
Electric Utility Pacific Gas & Electric Company
Gas Utility Southern California Gas
App Version 2022.1.1.29
1.2. Land Use Types
Land Use Subtype Size Unit Lot Acreage Building Area (sq ft) Landscape Area (sq ft)
Special Landscape
Area (sq ft)
Population Description
Hotel 100 Room 3.33 145,200 23,661 — — —
Exhibit C
Ayres Resort Expansion Quarterly Report, 3/17/2025
3 / 5
Quality Restaurant 6.00 1000sqft 0.14 6,000 23,661 — — — Junior College (2yr) 16.5 1000sqft 0.38 16,500 23,661 23,661 — — General Office
Building
17.9 1000sqft 0.41 17,950 23,661 — — —
Parking Lot 4.00 Acre 4.00 0.00 23,661 — — —
1.3. User-Selected Emission Reduction Measures by Emissions Sector Sector # Measure Title
Construction C-2* Limit Heavy-Duty Diesel Vehicle Idling Construction C-5 Use Advanced Engine Tiers
Construction C-10-A Water Exposed Surfaces
Construction C-10-C Water Unpaved Construction Roads
Construction C-11 Limit Vehicle Speeds on Unpaved Roads Construction C-12 Sweep Paved Roads
Energy E-2 Require Energy Efficient Appliances
Energy E-10-B Establish Onsite Renewable Energy Systems: Solar Power Water W-4 Require Low-Flow Water Fixtures
Refrigerants R-5 Reduce Service Leak Emissions
Area Sources AS-2 Use Low-VOC Paints
* Qualitative or supporting measure. Emission reductions not included in the mitigated emissions results.
2. Emissions Summary
2.1. Construction Emissions
2.1.1. Construction Emissions Compared Against Thresholds Criteria Pollutants (ton/quarter) and GHGs (MT/quarter) Un/Mit. ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Q1 — — — — — — — — — — —
Exhibit C
Ayres Resort Expansion Quarterly Report, 3/17/2025
4 / 5
Unmit. 0.06 0.51 0.61 < 0.005 0.02 0.25 0.27 0.02 0.10 0.12 122 Mit. 0.02 0.13 0.64 < 0.005 < 0.005 0.08 0.08 < 0.005 0.03 0.03 122 % Reduced 65% 75% -6% — 84% 70% 71% 83% 71% 73% —
Q2 — — — — — — — — — — —
Unmit. 0.20 0.36 0.52 < 0.005 0.01 0.02 0.03 0.01 0.01 0.02 106 Mit. 0.18 0.14 0.58 < 0.005 < 0.005 0.02 0.02 < 0.005 0.01 0.01 106 % Reduced 10% 61% -12% — 70% — 27% 69% — 49% —
Q3 — — — — — — — — — — —
Unmit. 1.81 0.70 1.02 < 0.005 0.02 0.04 0.06 0.02 0.01 0.03 204 Mit. 1.77 0.29 1.13 < 0.005 0.01 0.04 0.05 0.01 0.01 0.02 204 % Reduced 2% 58% -11% — 71% — 25% 69% — 47% —
Q4 — — — — — — — — — — —
Unmit. 1.97 0.76 1.11 < 0.005 0.03 0.05 0.07 0.02 0.01 0.03 222 Mit. 1.93 0.32 1.23 < 0.005 0.01 0.05 0.05 0.01 0.01 0.02 222 % Reduced 2% 58% -11% — 70% — 25% 69% — 47% —
Q5 — — — — — — — — — — —
Unmit. 0.33 0.11 0.16 < 0.005 < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 26.2 Mit. 0.32 0.04 0.17 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 26.2 % Reduced 3% 63% -6% — 86% — 45% 85% — 68% —
Quarterly
(Max)
— — — — — — — — — — —
Unmit. 1.87 0.63 0.84 < 0.005 0.02 0.10 0.10 0.02 0.05 0.05 142 Mit. 1.87 0.20 0.97 < 0.005 0.01 0.04 0.04 0.01 0.01 0.01 142 % Reduced — 68% -16% — 71% 63% 63% 70% 74% 74% —
2.1.2. Construction Quarters
Quarter Start Date End Date Length (days)
Q1 3/18/2026 6/16/2026 91
Exhibit C
Ayres Resort Expansion Quarterly Report, 3/17/2025
5 / 5
Q2 6/17/2026 9/15/2026 91
Q3 9/16/2026 12/15/2026 91
Q4 12/16/2026 3/16/2027 91
Q5 3/17/2027 4/17/2027 32
2.4. Operations Emissions Compared Against Thresholds
Criteria Pollutants (ton/quarter) and GHGs (MT/quarter) Un/Mit. ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Quarterly — — — — — — — — — — —
Unmit. 0.54 0.20 1.36 < 0.005 0.01 0.15 0.15 0.01 0.04 0.04 296 Mit. 0.50 0.20 1.36 < 0.005 0.01 0.15 0.15 0.01 0.04 0.04 296 % Reduced 8% — — — — — — — — — —
Exhibit C
Biological Resource Assessment
for
Allegretto Resort Expansion
APN 025-410-004
City of El Paso de Robles, California
Prepared for
Ayres Group
355 Bristol Street, Suite A
Costa Mesa, CA 92626
by
ALTHOUSE AND MEADE, INC.
BIOLOGICAL AND ENVIRONMENTAL SERVICES
1650 Ramada Drive, Suite 180
Paso Robles, CA 93446
(805) 237-9626
March 2025 (Updated December 2025)
3135
Exhibit D
Althouse and Meade, Inc.
Biological Resource Assessment for Allegretto Resort Expansion, City of El Paso de Robles i March 2025 (Updated December 2025)
Reporting Biologist(s)
Raymond Danner, PhD
Associate Principal Biologist
Althouse and Meade, Inc.
1650 Ramada Drive, Suite 180
Paso Robles, CA 93446
(805) 237-9626
[email protected]
Jenna Heaphy
Biologist II, Certified Field Botanist #0074
Althouse and Meade, Inc.
1650 Ramada Drive, Suite 180 Paso Robles,
CA 93446
(805) 237-9626
[email protected]
LynneDee Althouse, MS
Principal Scientist
Althouse and Meade, Inc.
1650 Ramada Drive, Suite 180
Paso Robles, CA 93446
(805) 237-9626
[email protected]
This Biological Resource Assessment was prepared according to the Guidelines established by the County of San Luis Obispo Department of Planning and Building (2016) and the statements furnished in the report and associated maps are true and correct to the best of my knowledge and belief.
3/24/25, 12/17/25
Signature Date
3/24/25
Signature Date
3/24/25
Signature Date
Exhibit D
Althouse and Meade, Inc.
Biological Resource Assessment for Allegretto Resort Expansion, City of El Paso de Robles ii March 2025 (Updated December 2025)
Table of Contents
SYNOPSIS...................................................................................................................... 1 1 INTRODUCTION ........................................................................................................ 2
1.1 Purpose............................................................................................................... 2
1.2 Project Location................................................................................................... 2
1.3 Local and Regional Context ................................................................................ 2
1.4 Project Description .............................................................................................. 2
1.5 Regulatory Framework ........................................................................................ 6
1.5.1 Federal Law and Regulations ........................................................................... 6
1.5.2 State Law and Regulations .............................................................................. 7
1.5.3 Local Policies and Regulations ......................................................................... 8
1.6 Special Status Species and Sensitive Habitat Regulations ................................. 9
1.6.1 California Natural Diversity Database (CNDDB) ............................................. 9
1.6.2 Federal and State Endangered Species Listings .......................................... 10
1.6.3 Global and State Ranks ................................................................................ 10
1.6.4 California Rare Plant Ranks.......................................................................... 10
1.6.5 California Department of Fish and Wildlife Animal Rank............................... 11
1.6.6 Sensitive Habitats ......................................................................................... 12 2 METHODS................................................................................................................ 13
2.1 Literature and Data Review............................................................................... 13
2.2 Sensitive Species Evaluation ............................................................................ 13
2.3 Soils................................................................................................................... 14
2.4 Biological Surveys ............................................................................................. 14
2.4.1 Vegetation Communities............................................................................... 14
2.4.2 Botanical ....................................................................................................... 14
2.4.3 Wildlife .......................................................................................................... 15
2.5 Maps.................................................................................................................. 15 3 RESULTS ................................................................................................................. 16
3.1 Existing Conditions............................................................................................ 16
3.2 Soils................................................................................................................... 16
3.3 Habitat Types .................................................................................................... 19
3.3.1 California Annual Grassland ......................................................................... 19
3.4 Individual Oak Trees.......................................................................................... 21
3.5 Potential Wetlands and Jurisdictional Waters.................................................... 21
3.6 Sensitive Natural Communities.......................................................................... 21
3.7 Botanical Resources.......................................................................................... 21 Exhibit D
Althouse and Meade, Inc.
Biological Resource Assessment for Allegretto Resort Expansion, City of El Paso de Robles iii March 2025 (Updated December 2025)
3.7.1 Special Status Plant Species ........................................................................ 21
3.7.2 Botanical Survey Results .............................................................................. 25
3.8 Wildlife Resources............................................................................................. 26
3.8.1 Special Status Animal Species ..................................................................... 26
3.8.2 Wildlife Survey Results ................................................................................. 34
3.8.3 Habitat Connectivity and Wildlife Movement................................................. 34 4 ENVIRONMENTAL IMPACT ANALYSIS AND AVOIDANCE MEASURES............... 35
4.1 Habitats ............................................................................................................. 35
4.2 Individual Oak Trees.......................................................................................... 35
4.3 Botanical Resources.......................................................................................... 37
4.4 Wildlife Resources............................................................................................. 37
4.4.1 Nesting Birds................................................................................................. 37
4.4.2 Crotch’s Bumble Bee .................................................................................... 37
4.4.3 Western Spadefoot ....................................................................................... 38
4.4.4 Salinas Pocket Mouse .................................................................................. 38
4.4.5 American Badger .......................................................................................... 38
4.4.6 San Joaquin Kit Fox...................................................................................... 38
4.4.7 Habitat Connectivity and Wildlife Movement................................................. 41 5 REFERENCES ......................................................................................................... 42 6 APPENDICES........................................................................................................... 45 Exhibit D
Althouse and Meade, Inc.
Biological Resource Assessment for Allegretto Resort Expansion, City of El Paso de Robles iv March 2025 (Updated December 2025)
List of Tables
Table 1. Responsible Parties .......................................................................................... 3 Table 2. Biological Surveys........................................................................................... 14 Table 3. Special Status Plant List.................................................................................. 23 Table 4. Vascular Plant List........................................................................................... 25 Table 5. Special Status Animal List............................................................................... 31 Table 6. Impacts and Mitigation Summary .................................................................... 35 Table 7. Impacts to Oak Trees ...................................................................................... 37 List of Figures
Figure 1. USGS Topographic Map .................................................................................. 4 Figure 2. Aerial Photograph ............................................................................................ 5 Figure 3. United States Department of Agriculture Soil Survey..................................... 18 Figure 4. Biological Resources...................................................................................... 20 Figure 5. CNDDB Plant Records................................................................................... 24 Figure 6. CNDDB Animal Records and USFWS Critical Habitat ................................... 33 List of Appendices
Appendix A. Site Plan (North Coast Engineering, Inc., March 2025) Appendix B. Special Status Plants Reported from the Region Appendix C. Special Status Animals Reported from the Region Cover Page: Blue oak tree on the eastern part of the site. March 3, 2025.
Exhibit D
Althouse and Meade, Inc.
Biological Resource Assessment for Allegretto Resort Expansion, City of El Paso de Robles 1 March 2025 (Updated December 2025)
SYNOPSIS
• This report focuses on biological resources at a 10.8-acre addition to the existing Allegretto Resort in Paso Robles, San Luis Obispo County, California. The Study Area encompasses a portion of Assessor’s Parcel Number (APN) 025-410-004, currently owned by Cuesta College. • The proposed Allegretto Resort Expansion would expand an existing 172-room resort to provide 93 additional guest rooms as well as additional resort amenities including a spa, gym, conference center, restaurant, wine education, parking areas, and other associated uses. • Habitat type identified in the 10.8 acres is California annual grassland. • A botanical survey in March 2025 identified 29 species, subspecies, and varieties of vascular plants in the Study Area. Two special status plants have low potential to occur in the Study Area. No special status plants were observed. Two blue oaks occur in the eastern portion of the Study Area.
• A wildlife survey in March 2025 focused on eight special status animals with some potential to occur in the Study Area. No special status animals were observed in the Study Area. • Mitigation recommendations are provided to reduce potential impacts to sensitive biological resources.
• Spring surveys for special status plants and animals will be conducted in April 2025 and will include aquatic surveys for western spadefoot in manmade ponded landscape features on the existing Allegretto Resort.
Exhibit D
Althouse and Meade, Inc.
Biological Resource Assessment for Allegretto Resort Expansion, City of El Paso de Robles 2 March 2025 (Updated December 2025)
1 INTRODUCTION
1.1 Purpose
This report provides information regarding biological resources associated with the proposed Allegretto Resort Expansion (Project), at 2700 Buena Vista Drive, Paso Robles, San Luis Obispo County, California (Study Area). Results include a habitat assessment, botanical and wildlife inventory, a discussion of special status species that have potential to occur in the Study Area, and an analysis of potential impacts to biological resources from the proposed Project. Mitigation recommendations for potential impacts to biological resources are also provided.
1.2 Project Location
The Study Area is a 10.8-acre portion of an approximate 75.8-acre parcel, APN 025-410-004, located along the northern border of the City of El Paso de Robles (City), in a developed area of San Luis Obispo County (Figure 1). The center of the Property is 35.648484°N, 120.668477°W (WGS84) in the Paso Robles United States Geological Survey (USGS) 7.5-minute topographic quadrangle.
1.3 Local and Regional Context
The Study Area is approximately 1.8 miles northeast of downtown Paso Robles, within the limits of the City (Figure 2). The Study Area is within the Salinas River Watershed, approximately 0.7 miles east of the Salinas River, and 0.8 miles southwest of Huerhuero Creek. The Property is zoned Public Facilities. Elevations within the site are generally flat with an average of 794 feet above mean sea level. State Route 46 is approximately 0.2 miles south of the Study Area. Dallons Drive creates the northern and eastern borders of the Study Area, and Buena Vista Drive borders the western portion. Cuesta College North County Campus is adjacent to the Study Area on the north side of Dallons Drive, and Allegretto Vineyard Resort is directly south of the Study Area. There are residential areas to the west and southeast of the Study Area. Local residents use the area to play fetch with their dogs.
1.4 Project Description
The Project would expand Allegretto Vineyard Resort with an additional 93 hotel rooms, a spa, a conference center, a restaurant, and a wine production/classroom building. The project would create new parking areas and pathways, extend existing infrastructure (water systems, drainage, etc.), and provide landscaping. The expansion would include 10.8 acres of land purchased from Cuesta College and property rezone determination by the City to align with the resort’s current zoning. The Project would amend Planned Development 12-001 and Conditional Use Permit 12- 003 to incorporate the new property into the resort.
A Site Plan is provided in Appendix A, for reference.
Contact information for the project property owner, biological consultant, project engineer, and lead agency are provided in Table 1.
Exhibit D
Althouse and Meade, Inc.
Biological Resource Assessment for Allegretto Resort Expansion, City of El Paso de Robles 3 March 2025 (Updated December 2025)
TABLE 1. RESPONSIBLE PARTIES
Property Owner Project Engineer
Ayres Group
355 Bristol Street, Suite A
Costa Mesa, CA 92626
(714) 540-6060
Douglas Ayres
[email protected]
North Coast Engineering, Inc.
725 Creston Road, Suite B
San Luis Obispo, CA 93446
(805) 239-3127
Biological Consultant Lead Agency
Althouse and Meade, Inc.
1650 Ramada Drive, Suite 180
Paso Robles, CA 93446
(805) 237-9626
Raymond Danner, Associate Principal
[email protected]
City of El Paso de Robles
Department of Planning
1000 Spring Street
Paso Robles, CA 93446
(805) 237-3970
Exhibit D
Legend
Project Location
Map Updated:
BIOLOGICAL AND ENVIRONMENTAL SERVICES
March 19, 2025 09:16 AM by SS ALTHOUSE AND MEADE, INC.
0 500 1,000 Feet
Allegretto Resort Expansion
Map Center: 35.64812°N 120.66911°W
Paso Robles, San Luis Obispo County
USGS Quadrangle: Paso Robles
Figure 1. United States Geological Survey Topographic Map Sacramento
San Francisco
Fresno
Los Angeles
Las Vegas
G:\ayresAllegretto3135\aprx\bioReport.aprx
Layout: Figure 1. Topo
Map: Topo
46 Exhibit D
Legend
Study Area (10.8 acres)
Map Updated:
BIOLOGICAL AND ENVIRONMENTAL SERVICES
March 21, 2025 01:16 PM by SS ALTHOUSE AND MEADE, INC.
0 200 400 Feet
Allegretto Resort Expansion
Map Center: 35.64897°N 120.66829°W
Paso Robles, San Luis Obispo County
Imagery Source: USDA NAIP, 09/23/2024
Figure 2. Aerial
G:\ayresAllegretto3135\aprx\bioReport.aprx
Layout: Figure 2. Aerial
Map: Aerial
Buena Vista Drive
Dallons Drive
Exhibit D
Althouse and Meade, Inc.
Biological Resource Assessment for Allegretto Resort Expansion, City of El Paso de Robles 6 March 2025 (Updated December 2025)
1.5 Regulatory Framework
Standards for environmental protection, in the form of laws and regulations, are created within three different organizational levels of government: Federal, State, and Local. Entities exist within each level to create and enforce regulations that help ensure protection of specific and pertinent regional issues threatening ecosystems and environments. The following regulations are applicable to the proposed Project.
1.5.1 Federal Law and Regulations
Bald and Golden Eagle Protection Act. The Bald and Golden Eagle Protection Act (BGEPA) prohibits anyone, without a permit issued by the Secretary of the Interior, from taking (pursue, shoot, shoot at, poison, wound, kill, capture, trap, collect, molest or disturb) bald or golden eagles, including their parts, nests, or eggs. This includes substantially interfering with normal breeding, feeding, or sheltering behavior. Activities that may result in the take of a bald or golden eagle require permits; the three activities eligible for permits include to remove or relocate an eagle nest; to transport, exhibit, collect, or control eagles or eagle parts, and for incidental take of eagles.
Endangered Species Act. The federal Endangered Species Act (FESA) provides the legal framework for the listing and protection of species (and their habitats) identified as being endangered or threatened with extinction. “Critical Habitat” is a term within the FESA designed to guide actions by federal agencies and is defined as “an area occupied by a species listed as threatened or endangered within which are found physical or geographical features essential to the conservation of the species, or an area not currently occupied by the species which is itself essential to the conservation of the species.” Actions that jeopardize endangered or threatened species and/or critical habitat are considered a ‘take’ under the FESA. “Take” under federal definition means to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or to attempt to engage in any such conduct.
Projects that would result in “take” of any federally listed threatened or endangered species, or critical habitats, are required to obtain permits from the USFWS through either Section 7 (interagency consultation with a federal nexus) or Section 10 (Habitat Conservation Plan) of FESA, depending on the involvement by the federal government in permitting and/or funding of the project. Through Section 10, it is required to prepare a Habitat Conservation Plan (HCP) to be approved by the United States Fish and Wildlife Service (USFWS), which results in the issuance of an Incidental Take Permit (ITP). Through Section 7, which can only occur when a separate federal nexus in a project exists (prompting interagency consultation), a consultation by the various federal agencies involved can take place to determine appropriate actions to mitigate negative effects on endangered and threatened species and their habitat.
Migratory Bird Treaty Act. All migratory, non-game bird species that are native to the U.S. or its territories are protected under the federal Migratory Bird Treaty Act (MBTA) of 1918 (50 C.F.R. Section 10.13), as amended under the Migratory Bird Treaty Reform Act of 2004. The MBTA makes it illegal to purposefully take (pursue, hunt, shoot, wound, kill, trap, capture, or collect) any migratory bird, or the parts, nests, or eggs of such a bird, except under the terms of a valid Federal permit. Migratory non-game native bird species are protected by international treaty under the federal MBTA.
Exhibit D
Althouse and Meade, Inc.
Biological Resource Assessment for Allegretto Resort Expansion, City of El Paso de Robles 7 March 2025 (Updated December 2025)
1.5.2 State Law and Regulations
California Endangered Species Act. The California Endangered Species Act (CESA), similar to FESA, contains a process for listing of species and regulating potential impacts to listed species.
State threatened and endangered species include both plants and wildlife, but do not include invertebrates. The designation “rare species” applies only to California native plants. State threatened and endangered plant species are regulated largely under the Native Plant Preservation Act in conjunction with the CESA. State threatened and endangered animal species are legally protected against “take.” The CESA authorizes the California Department of Fish and Wildlife (CDFW) to enter into a memorandum of agreement for take of listed species to issue an incidental take permit for a state-listed threatened and endangered species only if specific criteria are met.
Section 2080 of the CESA prohibits the take of species listed as threatened or endangered pursuant to the Act. Section 2081 allows CDFW to authorize take prohibited under Section 2080 provided that: 1) the taking is incidental to an otherwise lawful activity; 2) the taking will be minimized and fully mitigated; 3) the applicant ensures adequate funding for minimization and mitigation; and 4) the authorization will not jeopardize the continued existence of the listed species.
California Environmental Quality Act (CEQA). CEQA defines a “project” as any action undertaken from public or private entity that requires discretionary governmental review (a non-ministerial permittable action). All “projects” are required to undergo some level of environmental review pursuant to CEQA, unless an exemption applies. CEQA’s environmental review process includes an assessment of existing resources, broken up by categories (i.e., air quality, aesthetics, etc.), a catalog of potential impacts to those resources caused by the proposed project, and a quantifiable result determining the level of significance an impact would generate. The goal of environmental review under CEQA is to avoid or mitigate impacts that would lead to a “significant effect” on a given resource; section 15382 of the CEQA Guidelines defines a “significant effect” as a substantial, or potentially substantial, adverse change in any of the physical conditions within the area affected by the project including land, air, water, minerals, flora, fauna, ambient noise, and objects of historic or aesthetic significance. An economic or social change by itself shall not be considered a significant effect on the environment, but may be considered in determining whether the physical change is significant.
Public agencies are required to implement CEQA and execute jurisdiction to determine when applicable activities are or are not subject to CEQA. A public agency with the most prominent nexus and jurisdiction to a project is called the lead agency. The lead agencies determine the scope of what is considered an impact and what constitutes a “significant effect”. “Biological resources” is one of the varying categories considered during environmental review through CEQA. A lead agency can require a biological assessment to be prepared to report on existing biological resources and recommended mitigation measures that will reduce or lessen potential negative impacts to those biological resources. The questions listed in CEQA’s Appendix G:
Biological Resources section, which are used to guide assessment of impacts to biological resources are as follows:
• Does 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 Game or U.S. Fish and Wildlife Service?
• Does 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 Game or US Fish and Wildlife Service?
Exhibit D
Althouse and Meade, Inc.
Biological Resource Assessment for Allegretto Resort Expansion, City of El Paso de Robles 8 March 2025 (Updated December 2025)
• Does 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?
• Does 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?
• Does the project conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
• Does 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? The lead agency has the final determination over whether a project is or is not permissible, based upon the environmental review, completed requirements and environmental documentation, and their judgement that the project will not have a significant effect on the environment, or that all significant effects have been mitigated for.
Natural Community Conservation Planning (NCCP) Act of 1991. The NCCP Act is designed to conserve natural communities at the ecosystem scale while accommodating compatible land use. CDFW is the primary state agency that implements the NCCP. The NCCP plan provides for the comprehensive management and conservation of multiple wildlife species. It identifies and provides for regional protection of natural wildlife diversity while allowing for compatible and appropriate development and growth.
California Fish and Game Code (CFGC). The California Fish and Game Code (CFGC) is one of the many legal codes that form the general statutory law of California. A myriad of statutes regarding fish and game are specified in the CFGC; the following codes are specifically relevant to the proposed Project:
California Native Plant Protection Act. Sections 1900-1913 of the CFGC contain the regulations of the Native Plant Protection Act of 1977. The intent of this act is to help conserve and protect rare and endangered plants in the state. The act allowed the CFGC to designate plants as rare or endangered.
Nesting Birds. Sections 3503, 3503.5 and 3513 of the CFGC states that it is “unlawful to take, possess, or needlessly destroy the nest or eggs of any bird, except as otherwise provided by this code or any regulation made pursuant thereto,” and “unlawful to take, possess, or destroy any birds of prey or to take, possess, or destroy the nest or eggs of any such bird” unless authorized.
1.5.3 Local Policies and Regulations
Oak Tree Preservation Ordinance. The Oak Tree Preservation Ordinance (City 2002) provides policies, regulations, and specifications necessary to govern the preservation of oak trees within the City and to control their pruning and/or removal. The provisions apply to private property owners, to tree maintenance services and arborists, and to new development, redevelopment, and any discretionary considerations by the City that result in development of intensities that could impact existing oak trees. Preservation of existing oak trees and opportunities to promote the establishment of new oak trees is considered for development projects or development related entitlements.
Exhibit D
Althouse and Meade, Inc.
Biological Resource Assessment for Allegretto Resort Expansion, City of El Paso de Robles 9 March 2025 (Updated December 2025)
Pursuant to the City’s Oak Tree Preservation Ordinance oak tree protection measures are for trees measured at six inches or greater in diameter at 4.5 feet above ground level [diameter at breast height (dbh)]. Any oak tree slated for removal requires a permit and mitigation, as evaluated by an arborist. Oak trees marked for removal require mitigation, where the total dbh of replacement tree (or caliper) shall be equivalent to 25 percent of the total dbh of trees removed.
Trees not marked for removal or completely avoided are assessed according to their Critical Root Zone (CRZ). The City of Paso Robles defines the CRZ as the area circumscribed around the tree’s trunk using a radius of one foot per one inch dbh. Although not specified in the ordinance, mitigation of CRZ impacts are often assessed according to the percent of CRZ impact, i.e. less than 50 percent or greater than 50 percent.
1.6 Special Status Species and Sensitive Habitat Regulations For purposes of this Biological Resource Assessment, special status species are those plants and animals listed, proposed for listing, or candidates for listing as threatened or endangered by the USFWS under the FESA; those listed or proposed for listing as rare, threatened, or endangered by the CDFW under the CESA; animals designated as “Species of Special Concern,” “Fully Protected,” or “Watch List” by the CDFW; and plants with a California Rare Plant Rank (CRPR) of 1, 2, 3, or 4. In the following sections, further details are provided to highlight the different guidelines and qualifications that are used to help identify special status species in this report. In Sections 3.7 and 3.8, the various qualifications are listed in the special status species tables (Table 3 and Table 5) for each species with potential to occur in the project area.
1.6.1 California Natural Diversity Database (CNDDB)
"Special Plants" and “Special Animals” are broad terms used to refer to all the plant and animal taxa inventoried by the CNDDB, regardless of their legal or protection status (CNDDB 2024b, CNDDB 2024c). The Special Plants list includes vascular plants, high priority bryophytes (mosses, liverworts, and hornworts), and lichens. The Special Animals list is also referred to by the California Department of Fish and Wildlife (CDFW) as the list of “species at risk” or “special status species.”
According to the CNDDB, Special Plants and Animals lists include: taxa that are officially listed or proposed for listing by California or the Federal Government as Endangered, Threatened, or Rare; taxa which meet the criteria for listing, as described in Section 15380 of CEQA Guidelines; taxa deemed biologically rare, restricted in range, declining in abundance, or otherwise vulnerable; population(s) in California that may be marginal to the taxon’s entire range but are threatened with extirpation in California; and/or taxa closely associated with a habitat that is declining in California at a significant rate. Separately, the Special Plants List includes taxa listed in the California Native Plant Society’s Inventory of Rare and Endangered Plants of California, as well as taxa determined to be Sensitive Species by the Bureau of Land Management, U.S. Fish and Wildlife Service, or U.S. Forest Service. The Special Animals List distinctively includes taxa considered by the CDFW to be a Species of Special Concern (SSC) and taxa designated as a special status, sensitive, or declining species by other state or federal agencies.
Exhibit D
Althouse and Meade, Inc.
Biological Resource Assessment for Allegretto Resort Expansion, City of El Paso de Robles 10 March 2025 (Updated December 2025)
1.6.2 Federal and State Endangered Species Listings
The Federal and California Endangered Species Acts are the regulations that govern the listing and protection of species, and their habitats, identified as being endangered or threatened with extinction. Possible listing status under both Federal and California ESA includes Endangered and Threatened (FE, FT, CE, or CT). Species in the process of being listed are given the status of either Proposed Federally Endangered/Threatened, or Candidate for California Endangered/Threatened (PE, PT, CCE, or CCT). The CESA has one additional status: Rare (CR).
1.6.3 Global and State Ranks
Global and State Ranks reflect an assessment of the condition of the species or habitats across its entire range. Basic ranks assign a numerical value from 1 to 5, respectively for species with highest risk to most secure. Other ranking variations include rank ranges, rank qualifiers, and infraspecific taxon ranks. All Heritage Programs, such as the CNDDB use the same ranking methodology, originally developed by The Nature Conservancy and now maintained and recently revised by NatureServe. Procedurally, state programs such as the CNDDB develop the State ranks. The Global ranks are determined collaboratively among the Heritage Programs for the states/provinces containing the species. Rank definitions, where G represents Global and S represents State, are as follows:
• G1/S1: Critically imperiled globally/in state because of extreme rarity (5 or fewer populations)
• G2/S2: Imperiled globally/in state because of rarity (6 to 20 populations) • G3/S3: Vulnerable; rare and local throughout range or in a special habitat or narrowly endemic (on the order of 21 to 100 populations)
• G4/S4: Apparently secure globally/in state; uncommon but not rare (of no immediate conservation concern)
• G5/S5: Secure; common, widespread, and abundant
• G#G#/S#S#: Rank range - numerical range indicating uncertainty in the status of a species, (e.g., G2G3 more certain than G3, but less certain that G2) • G/S#?: Inexact numeric rank
• Q: Questionable taxonomy - Taxonomic distinctiveness of this entity is questionable • T#: Infraspecific taxa (subspecies or varieties) – indicating an infraspecific taxon that has a lower numerical ranking (rarer) than the given global rank of species
1.6.4 California Rare Plant Ranks
Plant species are considered rare when their distribution is confined to localized areas, their habitat is threatened, they are declining in abundance, or they are threatened in a portion of their range.
The California Rare Plant Rank (CRPR) categories range from species with a low threat (4) to species that are presumed extinct (1A). All but a few species are endemic to California. All of them are judged to be vulnerable under present circumstances, or to have a high potential for Exhibit D
Althouse and Meade, Inc.
Biological Resource Assessment for Allegretto Resort Expansion, City of El Paso de Robles 11 March 2025 (Updated December 2025)
becoming vulnerable. Threat ranks are assigned as decimal values to a CRPR to further define the level of threat to a given species. The rare plant ranks and threat levels are defined below. • 1A: Plants presumed extirpated in California and either rare or extinct elsewhere • 1B: Plants rare, threatened, or endangered in California and elsewhere • 2A: Plants presumed extirpated in California, but common elsewhere • 2B: Plants rare, threatened, or endangered in California, but more common elsewhere • 4: Plants of limited distribution - a watch list
• 0.1: Seriously threatened in California (over 80% of occurrences threatened/high degree and immediacy of threat)
• 0.2: Moderately threatened in California (20-80% occurrences threatened/moderate degree and immediacy of threat)
• 0.3: Not very threatened in California (less than 20% of occurrences threatened/low degree and immediacy of threat or no current threats known)
1.6.5 California Department of Fish and Wildlife Animal Rank The California Department of Fish and Wildlife (CDFW) assigns one of three ranks to Special Animals: Watch List (WL), Species of Special Concern (SSC), or Fully Protected (FP). Unranked species are referred to by the term Special Animal (SA).
Animals listed as Watch List (WL) are taxa that were previously designated as SSC, but no longer merit that status, or taxa that which do not yet meet SSC criteria, but for which there is concern and a need for additional information to clarify status.
Animals listed as California Species of Special Concern (SSC) may or may not be listed under California or federal Endangered Species Acts. They are considered rare or declining in abundance in California. The Special Concern designation is intended to provide the CDFW biologists, land planners, and managers with lists of species that require special consideration during the planning process to avert continued population declines and potential costly listing under federal and state endangered species laws. For many species of birds, the primary emphasis is on the breeding population in California. For some species that do not breed in California but winter here, emphasis is on wintering range. The SSC designation thus may include a comment regarding the specific protection provided such as nesting or wintering.
Animals listed as Fully Protected (FP) are those species considered by CDFW as rare or faced with possible extinction. Most, but not all, have subsequently been listed under the CESA or FESA.
Exhibit D
Althouse and Meade, Inc.
Biological Resource Assessment for Allegretto Resort Expansion, City of El Paso de Robles 12 March 2025 (Updated December 2025)
1.6.6 Sensitive Habitats
Sensitive Natural Community is a state-wide designation given by CDFW to specific vegetation associations of ecological importance. Sensitive Natural Communities rarity and ranking involves the knowledge of range and distribution of a given type of vegetation, and the proportion of occurrences that are of good ecological integrity (CDFW 2023). Evaluation is conducted at both the Global (G) and State (S) levels, resulting in a rank ranging from 1 for very rare and threatened to 5 for demonstrably secure. Natural Communities with ranks of S1-S3 are considered Sensitive Natural Communities in California and may need to be addressed in the environmental review processes of CEQA and its equivalents.
Exhibit D
Althouse and Meade, Inc.
Biological Resource Assessment for Allegretto Resort Expansion, City of El Paso de Robles 13 March 2025 (Updated December 2025)
2 METHODS
2.1 Literature and Data Review
Background research includes review of relevant plans, policies, and biological information to determine what biological resources may occur near or in the Study Area. Research included:
• Review of agency plans pertaining to sensitive and special-status species; • Queries of special-status species occurrence records and databases; • Review of literature on sensitive species and biological resources in the project area and region.
Althouse and Meade, Inc. (A&M) conducted a search of the CNDDB and the California Native Plant Society (CNPS) Online Inventory of Rare and Endangered Plants of California on February 25, 2025 (CNDDB 2025, CNPS 2025). Other database searches included online museum and herbarium specimen records for locality data within San Luis Obispo and southern Monterey Counties, as maintained by eBird (eBird 2021), and the Global Biodiversity Information Facility (GBIF 2025). The search area included the Paso Robles USGS 7.5-minute quadrangle and the 8 surrounding quadrangles (Adelaida, Bradley, Creston, Estrella, Ranchito Canyon, San Miguel, Templeton, and York Mountain). Data was compiled for sensitive plant and wildlife species and reviewed according to each species' potential to occur in the Study Area. Special status species lists produced by database and literature searches were cross-referenced with the described habitat types in the Study Area. A complete list of species and determinations are provided in Appendix B and Appendix C.
2.2 Sensitive Species Evaluation
Special status species lists produced by database and literature searches were cross-referenced and analyzed according to Study Area habitat types. Identification of all potential special status species that could occur in or near the Study Area are provided in Table 3 and Table 5. After review of the literature, and site visits, the following criteria were used to determine the potential for specialstatus species to occur on the Study Area:
• Present: The species was observed on the Study Area during field surveys. • High Potential: Highly suitable habitat and CNDDB or CNPS occurrence records indicate the species is likely to occur on the Study Area or the immediate vicinity. Individuals may not have been observed during field surveys; however, the species likely occurs in or immediately adjacent to the Study Area and (for wildlife) could move into the Study Area in the future.
• Moderate Potential: Moderately suitable habitat is present in the Study Area and CNDDB occurrences or surveys have recorded the species in the vicinity of the Study Area.
Individuals were not observed during field surveys, but the species could be present, at least seasonally or as a transient.
• Low Potential: Marginally suitable habitat is present in the Study Area, and there are no occurrence records or other historical (i.e., 50 years or older) records in the vicinity of the Study Area. Individuals were not observed during surveys and are not expected to be present.
Exhibit D
Althouse and Meade, Inc.
Biological Resource Assessment for Allegretto Resort Expansion, City of El Paso de Robles 14 March 2025 (Updated December 2025)
• No Potential: Suitable habitat for the species is not present on the Study Area, and/or the species is not known to occur in the region.
Each special status species that could occur in or near the Study Area is individually discussed in Sections 3.7.1 and 3.8.1.
2.3 Soils
A soil report was created by importing the Study Area as an Area of Interest (AOI) into the Natural Resources Conservation Service (NRCS) Soil Survey Geographic Database (SSURGO) via their online portal. The resulting soil report was reviewed, and a map was created using the U.S.
Department of Agriculture (USDA) NRCS Soil Survey GIS data (USDA 2024a). Soils data are summarized in Section 3.2.
2.4 Biological Surveys
On March 3, 2025, A&M Biologist Jenna Heaphy (Certified Field Botanist, CCB#0074) conducted a pedestrian survey to inventory plant and wildlife species, describe habitat types, and to collect photographic documentation of the Study Area. Each habitat type was field inspected and described by species composition, as interpreted in Section 3.3. All plant and animal species observed in the field were identified and documented in Sections 3.7.2 and 3.8.2. Transects were meandering with an emphasis on locating habitat appropriate for special status plants, while also describing general conditions and dominant species and compiling a species lists. Surveys occurred in the Study Area and along both sides of Buena Vista Dr. adjacent to the Property.
TABLE 2. BIOLOGICAL SURVEYS
Survey Date Biologist Weather Observations Activities
03/03/2025 Jenna Heaphy Partially cloudy, 51 to 53 °F, calm Biological survey Habitat mapping
Botanical survey
2.4.1 Vegetation Communities
Vegetation communities were visually assessed on March 3, 2025, in the field. Vegetation communities were evaluated using the Keys for California Vegetation to confirm vegetation communities to the Alliance and Association level dependent on diagnostic species and quantitative definitions of the stand according to the Manual of California Vegetation (MCV) (CNPS 2025).
2.4.2 Botanical
Identification of botanical resources included field observations and laboratory analysis of collected material. Each habitat type occurring in the Study Area was inspected, described, and catalogued (Section 3.3). All plant species observed in the Study Area were identified and recorded by a qualified botanist (Table 4). Transects were meandering with an emphasis on locating habitat appropriate for special status plants. Transects were also utilized to map boundaries of different Exhibit D
Althouse and Meade, Inc.
Biological Resource Assessment for Allegretto Resort Expansion, City of El Paso de Robles 15 March 2025 (Updated December 2025)
vegetation types, describe general conditions and dominant species, compile species lists, and evaluate potential habitat for special status species. Early season botanical surveys were conducted in March 2025. Given the time of year, this survey was not floristic in nature. Follow-up surveys will be conducted in late spring to ensure all taxa occurring in the Study Area are identifiable and that complete survey protocols are met. Botanical nomenclature used in this document follows the Jepson eFlora (Jepson Flora Project 2025).
2.4.3 Wildlife
Identification of wildlife resources were made by direct observations or by visual signs of animal presence such as burrows/dens, vocalization, tracks, and/or scat. Wildlife observations were recorded during Study Area field surveys. Birds were identified by sight, using 10-power binoculars, or by vocalizations. Mammals recorded in the Study Area were identified by sight, burrow/dens, scat, and tracks. Wildlife surveys focused on identifying habitat suitable to support special status animal species known from the region that have potential to occur in the Study Area (Table 5). Wildlife nomenclature for birds is in accordance with the American Ornithological Society Checklist (Chesser et al. 2019) and Revised Checklist of North American Mammals North of Mexico (Bradley et al. 2014).
2.5 Maps
Field spatial data were collected using mobile devices equipped with GPS receivers and a thirdparty mapping application. Hand notation of habitats on high resolution aerials were digitized into polygon layers. Maps were created by importing GPS data into ArcGIS Pro, a Geographic Information System (GIS) software program. Data were overlaid onto recent aerial imagery for further analysis and visualization (Esri 2024). Soil data were overlaid on a 2020 National Agriculture Imagery Program (NAIP) aerial of San Luis Obispo County (USDA 2024b).
Exhibit D
Althouse and Meade, Inc.
Biological Resource Assessment for Allegretto Resort Expansion, City of El Paso de Robles 16 March 2025 (Updated December 2025)
3 RESULTS
3.1 Existing Conditions
The Study Area is primarily flat land with minimal undulation in topography that is split into two halves by a driveway to the parking lot and the curve of Dallons Drive to the north (Photo 1, Photo 2). The western half is bordered by Buena Vista Drive where a series of telephone poles run parallel to it, as well as a small utility structure in the southwest corner. South of the property line (outside the Study Area) in the southwest corner, there is a manmade landscape feature that is occasionally ponded. Ornamental conifer trees line the parking lot south of the Study Area. The eastern half is larger and has two mature blue oak trees. A culvert passes beneath Dallons Drive near the blue oak tree, where seasonal water collects near the outfall. An old ranch road follows the southern border of the eastern half of the Study Area. A sidewalk paralleling Dallons Drive follows the northern and eastern borders of the Study Area, planted with sweetgum saplings.
Annual grasses and forbs dominate the Study Area, with density and species composition varying among microhabitats. The Study Area is heavily disturbed as the land has been previously graded and is currently used as an open space by pedestrians and their dogs. This land has also been used in recent years as rangeland for animals of the Allegretto-owned petting zoo, though there is little sign of current grazing. Historical aerial imagery shows tillage lines from historical dryland grain farming for livestock feed.
Photo 1. Eastern half of the Study Area, view north,
March 3, 2025.
Photo 2. Western half of the Study Area, view
west, March 3, 2025.
3.2 Soils
Two soil map units are represented on the Study Area: San Ysidro loam, 0 to 2 percent slopes, MLRA 14 and Arbuckle-San Ysidro complex, 2 to 9 percent slopes (Figure 3, USDA 2024a).
Arbuckle-San Ysidro complex, 2 to 9 percent slopes (106) is the dominant soil type represented on Property, accounting for 96 percent of the project footprint. The typical soil profile is a top layer consisting of fine sandy loam (0 to 29 inches), a middle layer of sandy clay loam (29 to 38 inches), and a third layer consisting of stratified sandy loam to very gravelly sandy clay loam (38 to 62 inches). This soil class is considered well drained with a low runoff class. This soil class is formed from terraces derived from alluvium from mixed rocks sources (USDA 2024a).
Exhibit D
Althouse and Meade, Inc.
Biological Resource Assessment for Allegretto Resort Expansion, City of El Paso de Robles 17 March 2025 (Updated December 2025)
San Ysidro loam, 0 to 2 percent slopes, MLRA 14 (197) is a soil type represented in a narrow band along Dallon’s Drive, accounting for 4 percent of the project footprint. The typical soil profile is a top layer consisting of loam (0 to 23 inches), a middle layer of clay loam (23 to 38 inches), and a third layer consisting of loam (38 to 64 inches). This soil class is considered moderately well drained with a low runoff class. This soil class is formed from valley floors/alluvial fans/terraces from alluvium derived from sedimentary rock (USDA 2024a).
Exhibit D
Legend
Study Area (10.8 acres)
USDA NRCS Soils
Map Updated:
BIOLOGICAL AND ENVIRONMENTAL SERVICES
March 19, 2025 09:15 AM by SS ALTHOUSE AND MEADE, INC.
0 200 400 Feet
Allegretto Resort Expansion
Map Center: 35.64897°N 120.66829°W
Paso Robles, San Luis Obispo County
Data Source: USDA NRCS Soil Survey
Imagery Source: USDA NAIP, 09/23/2024
Figure 3. USDA Soil Survey
G:\ayresAllegretto3135\aprx\bioReport.aprx
Layout: Figure 3. USDA Soil Survey
Map: USDA Soil Survey
Buena Vista Drive
Dallons Drive
106
106
197
Soil Type Study Area
106 - Arbuckle-San Ysidro complex, 2 to 9 percent slopes 197 - San Ysidro loam, 0 to 2 percent slopes, MLRA 14
96%
4%
Exhibit D
Althouse and Meade, Inc.
Biological Resource Assessment for Allegretto Resort Expansion, City of El Paso de Robles 19 March 2025 (Updated December 2025)
3.3 Habitat Types
The entire Study Area, approximately 10.8 acres, is mapped as California annual grassland habitat (Avena spp. - Bromus spp. Herbaceous Semi-Natural Alliance).
3.3.1 California Annual Grassland
California annual grassland comprises the entire 10.8-acre Study Area (Figure 4). Vegetation is dominated by annual non-native grasses, such as bromes (Bromus rubens, B. hordeaceus), wall barley (Hordeum murinum), and slender wild oat (Avena barbata), with associate non-native forbs such as filarees (Erodium brachycarpum, E. cicutarium), yellow star-thistle (Centaurea solstitialis), and wild mustard (Hirschfeldia incana). Native wildflowers are scattered throughout the grassland and create a mosaic of species including California poppy (Eschscholzia californica), fiddlenecks (Amsinckia menziesii, A. intermedia), and popcorn flowers (Cryptantha sp. and Plagiobothrys sp.).
This habitat type conforms to the Avena spp. - Bromus spp. Herbaceous Semi-Natural Alliance (wildoats and annual brome grasslands; CNPS 2025), where varying membership rules apply.
California annual grassland in the western half of the Study Area is co-dominant with annual nonnative grasses (Bromus hordeaceus and Avena barbata) and short-fruited filaree (Erodium brachycarpum) with little changes in species composition. In the eastern half of the Study Area, there are more microhabitats with slight changes in species composition, such as a high density of yellow star-thistle that roughly follows an old ranch road along the southeastern border of the Study Area. Beneath the shade of the blue oaks, wall barley grows dense with fiddlenecks. In the centers of both halves of the Study Area, there is a high cover of wild mustard. There is also one small swale-like depression on the eastern edge of the Study Area that supports stickwort (Spergula arvensis) and red maids (Calandrinia menziesii) in addition to short fruit filaree, a composition unique to that area.
California annual grassland habitat provides foraging habitat for birds and denning habitat for small mammals. Numerous California ground squirrel (Otospermophilus beecheyi) burrows were observed as well as small trails connecting them. Open grassland habitat provides visual hunting grounds for birds of prey.
Photo 3. Grassland habitat in the western half of the Study Area, view southwest, March 3, 2025.
Exhibit D
Legend
Study Area (10.8 acres)
Annual Grassland
Tree Species
Blue Oak
Map Updated:
BIOLOGICAL AND ENVIRONMENTAL SERVICES
March 21, 2025 01:16 PM by SS ALTHOUSE AND MEADE, INC.
0 200 400 Feet
Allegretto Resort Expansion
Map Center: 35.64919°N 120.66836°W
Paso Robles, San Luis Obispo County
Imagery Source: USDA NAIP, 09/23/2024
Figure 4. Biological Resources
G:\ayresAllegretto3135\aprx\bioReport.aprx
Layout: Figure 4. Bio Resources
Map: Impacts
Buena Vista Drive
Dallons Drive
Exhibit D
Althouse and Meade, Inc.
Biological Resource Assessment for Allegretto Resort Expansion, City of El Paso de Robles 21 March 2025 (Updated December 2025)
3.4 Individual Oak Trees
Two blue oaks (Quercus douglasii) are present in the eastern portion of the Study Area. The tree near the center of the eastern portion of the Study Area has a dbh of 32 inches, which translates to a CRZ with a radius of 32 feet from the trunk. The tree along the northern edge of the eastern portion of the Study Area has a dbh of 36 inches, which translates to a CRZ with a radius of 36 feet.
3.5 Potential Wetlands and Jurisdictional Waters
No potential wetlands or waters are present in the Study Area.
3.6 Sensitive Natural Communities
None of the habitats in the Study Area are considered sensitive.
3.7 Botanical Resources
Research on special status plant occurrences conducted within the designated search area (see Methods) determined 46 special status plant species are known to occur in the region (Appendix B, CNDDB 2025, CNPS 2025). Figure 5 depicts the current GIS data for special status plants mapped near the Study Area by the CNDDB. There is no USFWS Critical Habitat for plants near the Study Area.
3.7.1 Special Status Plant Species
Based on an analysis of known ecological requirements for the special status plant species reported from the region, and habitat conditions that were observed in the Study Area, it was determined that two special status plant species have low potential to occur (Santa Lucia dwarf rush and shining navarretia). No species listed under the FESA and/or CESA have no potential to occur in the Study Area. Two special status plant species are discussed below and summarized in Table 3.
1. Santa Lucia dwarf rush (Juncus luciensis) is a CRPR 1B.2 species endemic to coastal California. It is known to occur in sandy soils in meadows, seeps, vernal pools, roadsides, chaparral, Great Basin scrub, and lower montane coniferous forest between 300 and 2,040 meters in elevation. It is an annual herb that typically blooms between April and July. The closest known record is approximately 4.0 miles northeast of the Study Area (CNDDB #30).
Along the northeastern edge of the Study Area, there is a culvert that goes beneath Dallons Drive, creating a small roadside ditch that holds water in heavy rain years. This microhabitat could support the Santa Lucia dwarf rush, though the conditions are marginal due to the inconsistent presence of water. Additionally, both nearby occurrences are historical. Given these conditions, Santa Lucia dwarf rush has a low potential to occur in the Study Area. Santa Lucia dwarf rush was not detected in the Study Area during the early spring 2025 survey, though surveys were conducted outside of the species’ typical bloom period. Follow-up late spring surveys are necessary to detect this species.
Exhibit D
Althouse and Meade, Inc.
Biological Resource Assessment for Allegretto Resort Expansion, City of El Paso de Robles 22 March 2025 (Updated December 2025)
2. Shining navarretia (Navarretia nigelliformis subsp. radians) is a CRPR 1B.2 subspecies endemic to California, primarily occurring in central California, with occurrences as far north as Butte and as far south as San Luis Obispo counties. It is known to occur in vernal pools, grassland, and cismontane woodland habitats, often on clay and alkaline sites between 65- and 1,000 meters elevation. It is an annual herb that typically blooms between March and July.
Branches are spreading to ascending from base and herbage is light gray-green (Keil and Hoover 2023, Jepson Flora Project 2025). Shining navarretia is further differentiated in the field by its yellow corolla (9-11 mm) and generally glabrous bract tips (Keil and Hoover 2023).
The closest known record is approximately 0.7 miles northeast of the Study Area (CNDDB #4). Annual grassland habitat in the Study Area is marginally suitable for the shining navarretia, as it typically occurs in soils with more clay. Given these conditions, shining navarretia has a low potential to occur in the Study Area. Shining navarretia was not detected in the Study Area during the early spring 2025 survey, though surveys were conducted outside of the species’ typical bloom period. Follow-up late spring surveys are necessary to detect this species.
Exhibit D
Althouse and Meade, Inc.
Biological Resource Assessment for Allegretto Resort Expansion, City of El Paso de Robles 23 March 2025 (Updated December 2025)
TABLE 3. SPECIAL STATUS PLANT LIST
Scientific Name Common Name
Federal/State Status
Global/State Rank
CA Rare Plant Rank
Blooming
Period Habitat Preference Potential to Occur
1. Juncus luciensis Santa Lucia
dwarf rush
-/-
G3/S3
1B.2
Apr-Jul Wet, sandy soils of seeps,
meadows, vernal pools,
streams, roadsides
Low. Grassy areas adjacent to the
road and small ditches could
support this species, though the
nearest occurrences are historic and
approximately 4 miles away
(CNDDB #30, 1937 and CNDDB
#8, 1958).
2. Navarretia
nigelliformis subsp.
radians
Shining navarretia -/-
G4T2T3/S2S3
1B.2
Mar-Jul Grassland and cismontane
woodland. Often on clay
and alkaline sites,
sometimes vernal pools.
65-1,000 m.
Low. Marginally suitable grassland
habitat is present in the Study Area,
though it is highly disturbed.
Nearest occurrence is 0.7 miles
northeast of the Study Area
(CNDDB #4, 2006).
See Section 1.6 for status and rank definitions
Exhibit D
4 6
5 7
1 3
5 2
6 Legend
Project Location
5-mile Buffer
Map Updated:
BIOLOGICAL AND ENVIRONMENTAL SERVICES
March 19, 2025 09:18 AM by SS ALTHOUSE AND MEADE, INC.
0 1 2 Miles
Allegretto Resort Expansion
Map Center: 35.64892°N 120.66823°W
Paso Robles, San Luis Obispo County
CNDDB GIS Data Last Updated: February 2025
Figure 5. California Natural Diversity Database Plant Records Jared's Pepper-grass
Lemmon's Jewelflower
Oval-leaved Snapdragon
San Luis Obispo Owl's-clover
Santa Lucia Dwarf Rush
Shining Navarretia
Woodland Woollythreads
Common Name
1 2
3 4
5 6
7 Label
G:\ayresAllegretto3135\aprx\bioReport.aprx
Layout: Figure 5. CNDDB Plants
Map: CNDDB Plants
Exhibit D
Althouse and Meade, Inc.
Biological Resource Assessment for Allegretto Resort Expansion, City of El Paso de Robles 25 March 2025 (Updated December 2025)
3.7.2 Botanical Survey Results
Botanical surveys conducted on March 3, 2025 identified 29 species, subspecies, and varieties of vascular plant taxa in the Study Area (Table 4). The list includes 13 species native to California and 16 introduced (naturalized or planted) species. Native plant species account for approximately 45 percent of the Study Area flora; introduced species account for approximately 55 percent.
TABLE 4. VASCULAR PLANT LIST
Scientific Name Common Name Special
Status Origin
Trees - 2 Species
Liquidambar sp. Sweetgum None Ornamental
Quercus douglasii Blue oak None Native
Shrubs - 1 Species
Baccharis pilularis Coyote brush None Native
Forbs - 21 Species
Acmispon americanus
var. americanus
American bird's foot
trefoil None Native
Amsinckia intermedia Common fiddleneck None Native
Amsinckia menziesii Small-flowered fiddleneck None Native Centaurea solstitialis Yellow star-thistle None Introduced Centromadia pungens Common tarweed None Native
Crassula connata Pygmy-weed None Native
Croton setiger Doveweed None Native
Cryptantha sp. Popcorn flower None Native
Erodium brachycarpum Short fruited filaree None Introduced Erodium cicutarium Redstem filaree None Introduced
Erodium moschatum Greenstem filaree None Introduced
Eschscholzia californica California poppy None Native
Hirschfeldia incana Wild mustard None Introduced
Hypochaeris glabra Smooth cat's-ear None Introduced
Lactuca serriola Prickly lettuce None Introduced
Lupinus bicolor Miniature lupine None Native
Malva parviflora Cheeseweed None Introduced
Exhibit D
Althouse and Meade, Inc.
Biological Resource Assessment for Allegretto Resort Expansion, City of El Paso de Robles 26 March 2025 (Updated December 2025)
Scientific Name Common Name Special
Status Origin
Medicago polymorpha California burclover None Introduced Plagiobothrys sp. Popcorn flower None Native
Spergula arvensis Stickwort None Introduced
Trichostema lanceolatum Vinegar weed None Native
Graminoids – 5 Species
Avena barbata Slender wild oat None Introduced
Bromus diandrus Ripgut grass None Introduced
Bromus hordeaceus Soft chess None Introduced
Bromus rubens Red brome None Introduced
Hordeum murinum Wall barley None Introduced
3.8 Wildlife Resources
Research on special status animal occurrences conducted within the designated search area (see Methods) determined 33 special status animal species are known to occur in the region (Appendix C, CNDDB 2025). Figure 6 depicts the current location data for special status species mapped near the Study Area by the CNDDB and USFWS Critical Habitat.
3.8.1 Special Status Animal Species
Based on an analysis of known ecological requirements for the special-status wildlife species reported or known from the region (Appendix C), and the habitat conditions that were observed in the Study Area, it was determined that eight special-status animal species have some potential to occur in the Study Area. Two species have a moderate potential to occur (ferruginous hawk and western spadefoot), and six species have a low potential to occur in the Study Area (golden eagle, burrowing owl, Crotch's bumble bee, Salinas pocket mouse, American badger, and San Joaquin kit fox). One species (American bumble bee) has been documented in the vicinity but is not likely to occur within the Study Area. Each species is discussed below and summarized in Table 5. The remaining 25 special status animal species that were evaluated were determined to have no potential to occur in the Study Area due to lack of suitable habitat present.
1. Golden eagle (Aquila chrysaetos) is designated a Fully Protected species by the CDFW and is federally protected by the Bald and Golden Eagle Protection Act. The species range extends throughout much of North America and in California is found in broadleaved upland and montane coniferous forests, cismontane, pinon and juniper woodlands, coastal prairie, great basin scrub and great basin, valley, and foothill grassland habitat types (CDFW 2025). Most golden eagles in California are residents year-round, but in the winter months, this population will be augmented with individuals from other nearby western states. The breeding season in California is generally from late January through August. The golden eagle prefers open habitat and in California, it extensively utilizes grazed grasslands and open shrublands for preying on Exhibit D
Althouse and Meade, Inc.
Biological Resource Assessment for Allegretto Resort Expansion, City of El Paso de Robles 27 March 2025 (Updated December 2025)
its main food source of hares or rabbits and marmots or ground squirrels (Hunt 1995; Watson 2010). Studies have shown that both the golden eagle’s reproduction rate and success declines with a decrease in prey abundance. The golden eagle will even refrain from egg-laying when prey numbers are low (Driscoll 2010). In California, the golden eagle nests almost exclusively in trees (82% trees in central California) but in montane regions, it also has a preference for cliffs and will avoid nesting in densely forested habitat (Hunt 1995; Pagel et al. 2010). The golden eagle is highly sensitive to anthropogenic presences and will avoid nesting near urban areas (Pagel et al. 2010). Golden eagles will even abandon nests when human activity and development increases in their territory (Driscoll 2010). The nearest nest occurrence is 0.7 miles northeast (CNDDB 122). Nesting in the Study Area is very unlikely.
Suitable foraging habitat and marginally suitable nesting habitat is present in and around the Study Area. With the nearby nest occurrence, there is a moderate potential for golden eagles to be seen in flight near the Study Area. No golden eagles were observed during the March 2025 site survey.
2. Burrowing owl (Athene cunicularia) is a California Species of Special Concern. In October 2024 it was approved by the California Fish and Game Commission to be a Candidate species under CESA. It is a small, rare owl that occupies abandoned mammal holes in the ground, most notably those of the California ground squirrel (Otospermophilus beecheyi). In California, the burrowing owl is a year-round resident in the Carrizo Plain, Central Valley, Imperial Valley, and the San Francisco Bay region. In the winter months, burrowing owl individuals from other western populations will augment the year-round Californian populations (Shuford and Gardali 2008). The breeding season is generally from March through August. Suitable habitat types for the burrowing owl are dry, open annual or perennial grasslands and deserts with an abundance of burrows (CDFW 2014, CNDDB 2025). Specific habitats where the owl is found include coastal prairie, coastal scrub, great basin, Mojavean and Sonoran Desert scrub, and valley and foothill grassland habitats (CNDDB 2025). While burrowing owls usually nest in burrows created by California ground squirrels, the owl is also known to inhabit badger and fox dens and man-made holes, such as pipes and culverts. Rarely, it has been known to dig its own burrow in softer soil types (Coulombe 1971, Gervais et al. 2008). Burrows with high horizontal visibility and low vegetation coverage are preferred but burrows with dense vegetation with high perch sites will be used (Green and Anthony 1989). Orthoptera are the main food source for the owl, but it will also consume other insects, as well as amphibians, carrion, small mammals, reptiles and birds (York et al. 2002, Gervais et al. 2008, CDFW 2014).
The Study Area has grassland habitat with numerous ground squirrel holes that could support this species, though it is highly disturbed. The nearest occurrence is approximately 2.2 miles southeast (eBird 2018). There are no nesting records in the City of Paso Robles and very few detections within the City. Due to the development and disturbance of surrounding land, this species has a low potential to occur. The burrowing owl was not observed in the Study Area during the March 2025 site survey.
3. Crotch’s bumble bee (Bombus crotchii) is designated by CDFW as a Special Animal and is presently a Candidate for listing as Endangered under CESA. Crotch’s bumble bee is known from California, western Nevada, and northern Baja California, Mexico. The species inhabits open grassland and scrub habitats. Requirements for this, as well as all bumble bee species include suitable nesting sites, pollen and nectar sources, and suitable overwintering sites for the queen. In California, the flight period for the queen is approximately February to late October, peaking in early April, with a second pulse in July and the flight period for workers Exhibit D