Addendum (PDF) — Paso Robles City Council, April 21, 2026 (part 2 of 10)

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the purpose of avoiding or
mitigating an environmental
effect?
c. Conflict with any applicable
habitat conservation plan or
natural community conservation
plan?
MND, p. 18-19 No No No None required.

Discussion: The project site is adjacent to an urbanized area of the City with existing commercial and industrial development to the west and a few residential uses to the east. There is not an established community in this part of the City, therefore, the existing residences would not be physically divided as a result of the Project, which was also the case for the Covelop development. The integration of the proposed residential Project would create a more natural transition from the commercial uses to the existing residential uses.

The General Plan Land Use Element Policy LU-2I encourages infill residential development, including mixed-use development, in areas within walking distance to transit and other commercial services where the environmental impacts of the development would be minimized. By applying the Mixed-Use Overlay to this site, the Project would meet the policy to encourage opportunities for infill residential/mixed-use development, especially given the project site’s proximity to adjacent commercial uses. Therefore, the Project is found to be consistent adopted General Plan Land Use Element.

As discussed in the Biological Resources section above, there are no sensitive natural habitats or species located on the site; further, no habitat conservation plans or natural community conservation plans established in this area of the City. Therefore, there would be no conflicts.

In summary, the Project does not involve any element that might result in a new significant or substantially more severe impact to land use and planning. Any unanticipated impacts to land use and planning that might occur as a result of the Project would be within the scope of those discussed in the 2024 MND. Furthermore, the City is not aware of any new circumstances or new information that might result in new significant or substantially more severe impacts to land use and planning in relation to the Project.

Mitigation Measures: None required.

Conclusion: The Project would not have any new significant or substantially more severe impacts to land use and planning (CEQA Guidelines § 15162(a)).

12. MINERAL RESOURCES.

Discussion: There are no known mineral resources at this project site. The Project does not involve any element that might result in a new significant or substantially more severe impacts to mineral resources than the previously approved Covelop project. Any impacts to mineral resources that might occur as a result of the Project would be within the scope of those discussed in the 2024 MND. Furthermore, the City is not aware of any Exhibit A

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new circumstances or new information that might result in new significant or substantially more severe impacts to mineral resources in relation to the Project.

Mitigation Measures: None required.

Conclusion: The Project would not have any new significant or substantially more severe impacts to mineral resources (CEQA Guidelines § 15162(a)).

13. NOISE.

Would the project: Where was the impact analyzed? Do proposed changes involve new significant impacts or
substantially more severe
impacts?
Any new circumstances involving
new significant impacts or
substantially more severe
impacts?
Any new information of
substantial importance requiring
new analysis or verification?
What MND MMs address
impacts?
a. Generation of a substantial
temporary or permanent increase
in ambient noise levels in the
vicinity of the project in excess of
standards established in the local
general plan or noise ordinance, or
applicable standards of other
agencies?
MND, p. 19-20 No No No
(Refer to 2025 45dB Acoustics
Supplemental Memo)
None required.
b. Generation of excessive
groundborne vibration or
groundborne noise levels?
MND, p. 19-20 No No No None required.
c. For a project located within the
vicinity of a private airstrip or an
airport land use plan or where such
a plan has not been adopted,
within two miles of a public
airport or public use airport, would
the project expose people residing
or working in the project area to
excessive noise levels?
MND, p. 19-20 No No No None required.

Discussion: An Acoustic Study was completed by 45 dB in March 2023 for the previously approved Covelop project (P22-20), concluding that noise impacts would be less than significant and consistent with both daytime and nighttime standards in the Municipal Code.

In January 2025, 45 dB prepared a supplemental memo evaluating the conversion of the site to a residential housing development. The memo reconfirmed the ambient noise levels identified in the 2023 study and determined that the proposed residential use would remain compatible with surrounding conditions, with outdoor noise levels below the 65 dBA threshold and interior levels projected at DNL 36 dBA, well under the 45 dBA interior limit for Residential receiving land uses.

The Project may result in short-term construction noise and vibration from machinery. However, the construction noise is not anticipated to be excessive, and construction will only take place during daytime hours, 7 a.m. and 7 p.m. excluding Sundays and federal holidays. Therefore, impacts from groundborne vibration noise would be considered less than significant.

The Project is not located within an airport area subject to an airport land use plan and will thus not be impacted by airport-related noise.

Exhibit A

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In summary, the Project does not involve any element that might result in a new significant or substantially more severe impact to noise. Any unanticipated impacts to noise that might occur as a result of the Project would be within the scope of those discussed in the 2024 MND. Furthermore, the City is not aware of any new circumstances or new information that might result in new significant or substantially more severe impacts to noise in relation to the Project.

Mitigation Measures: None required.

Conclusion: The Project would not have any new significant or substantially more severe impacts to noise (CEQA Guidelines § 15162(a)).

14. POPULATION AND HOUSING.

Discussion: The proposed Project does not result in unplanned population growth. There is a large demand to house people who currently reside in the region who may be restricted to overcrowded or other unsatisfactory housing conditions.

The proposed development will be responsible for paying the required fees as part of the City’s entitlement process, therefore impacts to City infrastructure are less than significant.

There are no residences located on the project site, therefore, there are no impacts related to the displacement of people.

In summary, the Project does not involve any element that might result in a new significant or substantially more severe impact to population and housing. Any unanticipated impacts to population and housing that might occur as a result of the Project would be within the scope of those discussed in the 2024 MND. Furthermore, the City is not aware of any new circumstances or new information that might result in new significant or substantially more severe impacts to population and housing in relation to the Project.

Mitigation Measures: None required.

Conclusion: The Project would not have any new significant or substantially more severe impacts to population and housing (CEQA Guidelines § 15162(a)).

Exhibit A

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15. PUBLIC SERVICES.

MND, p. 21 No No No None required.

Fire protection? MND, p. 21 No No No None required.

Police protection? MND, p. 21 No No No None required.

Schools? MND, p. 21 No No No None required.

Parks? MND, p. 21 No No No None required.

Other public facilities? MND, p. 21 No No No None required.

Discussion: The proposed Project would not result in a significant impact to fire or police protection, as the project site is located in the current service area by the City of Paso Robles Police and Fire Department. The project site is within the Paso Robles Joint Unified School District. Solid waste is managed by the San Luis Obispo Regional Integrated Waste Management Authority. Parks and public recreational facilities are located within proximity to the project site, including the regional Barney Schwartz Park located east of the site.

Regarding cumulative effects, the applicant is required to pay fees, which would go towards provision of municipal services. Therefore, potential impacts would be less than significant.

In summary, the Project does not involve any element that might result in a new significant or substantially more severe impact to public services. Any unanticipated impacts to public services that might occur as a result of the Project would be within the scope of those discussed in the 2024 MND. Furthermore, the City is not aware of any new circumstances or new information that might result in new significant or substantially more severe impacts to public services in relation to the Project.

Mitigation Measures: None required.

Conclusion: The Project would not have any new significant or substantially more severe impacts to public services (CEQA Guidelines § 15162(a)). All required impact fees supporting public services will be paid at the appropriate time in the construction process and ongoing as part of local property taxes.

16. RECREATION.

Exhibit A

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Would the project: Where was the impact analyzed? Do proposed changes involve new significant impacts or
substantially more severe
impacts?
Any new circumstances involving
new significant impacts or
substantially more severe
impacts?
Any new information of
substantial importance requiring
new analysis or verification?
What MND MMs address
impacts?
a. Would the project increase the
use of existing neighborhood and
regional parks or other recreational
facilities such that substantial
physical deterioration of the
facility would occur or be
accelerated?
MND, p. 21 No No No None required.
b. Does the project include
recreational facilities or require the
construction or expansion of
recreational facilities which might
have an adverse physical effect on
the environment?
MND, p. 21 No No No None required.

Discussion: The proposed Project would not result in a significant population increase, since the number of residential units being applied to the site in conjunction with the Mixed-Use Overlay is within the General Plan buildout of 44,000 population. Further, the Project is not anticipated to affect projected demand for parks and recreational facilities in the immediate area as the development plan demonstrates there will be on-site recreational facilities, including a central tot lot, clubhouse, and pool. The City’s Parks and Recreation Element of the General Plan dictates improvements of existing parks as well as periodically assessing usage of park facilities, and identifying physical changes needed to accommodate anticipated land use patterns. As a result, several renovation upgrades to existing parks have been made in the last several years. Based on these ongoing actions, impacts to recreational facilities is anticipated to be less than significant.

In summary, the Project does not involve any element that might result in a new significant or substantially more severe impact to recreation. Any unanticipated impacts to recreation that might occur as a result of the Project would be within the scope of those discussed in the 2024 MND. Furthermore, the City is not aware of any new circumstances or new information that might result in new significant or substantially more severe impacts to recreation in relation to the Project.

Mitigation Measures: None required.

Conclusion: The Project would not have any new significant or substantially more severe impacts to recreation (CEQA Guidelines § 15162(a)).

17. TRANSPORTATION.

Exhibit A

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b. Conflict or be inconsistent with
CEQA Guidelines section
15064.3, subdivision (b)?
MND, p. 22 No No No None required.
c. Substantially increase hazards
due to a geometric design feature
(e.g., sharp curves or dangerous
intersections) or incompatible uses
(e.g., farm equipment)?
MND, p. 22 No No No None required.
d. Result in inadequate emergency
access?
MND, p. 22 No No No None required.

Discussion: A Transportation Analysis was completed by CCTC in December 2022 for the previously approved Covelop project (P22-0020), concluding the project would generate 1,194 average daily trips, with 117 AM peak hour trips and 158 PM peak hour trips, and that no VMT or intersection impacts would occur.

In September 2025, CCTC completed a review of the new Project and compared the approved trips to the proposed trips. Using the ITE Trip Generation Manual, CCTC determined that the new Project would generate fewer daily and peak hour trips. Therefore, the proposed Project would result in lower traffic impacts than the previously approved Covelop project and would not cause significant impacts on intersection operations or VMTs.

The proposed circulation system, including roadways, transit, and bicycle and pedestrian facilities all comply with existing plans, ordinances, and policies. The Project will improve bike lane and pedestrian path connectivity along the existing Ardmore Road and will provide new connections to the east that are consistent with the City’s Circulation Plan.

No hazardous geometric design features are included within or adjacent to the site’s circulation.

The new Project has been reviewed by the City’s Department of Emergency Services. The Project will not impede emergency access, and is designed in compliance with all emergency access safety features and to City emergency access standards.

In summary, the Project does not involve any element that might result in a new significant or substantially more severe impact to transportation. Any unanticipated impacts to transportation that might occur as a result of the Project would be within the scope of those discussed in the 2024 MND. Furthermore, the City is not aware of any new circumstances or new information that might result in new significant or substantially more severe impacts to transportation in relation to the Project.

Mitigation Measures: None required.

Conclusion: The Project would not have any new significant or substantially more severe impacts to transportation (CEQA Guidelines § 15162(a)).

18. TRIBAL CULTURAL RESOURCES.

Exhibit A

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21074 as either a site, feature,
place, cultural landscape that is
geographically defined in terms
of the size and scope of the
landscape, sacred place, or
object with cultural value to a
California Native American
tribe, and that is:
i. Listed or eligible for listing
in the California Register of
Historical Resources, or in a
local register of historical
resources as defined in Public
Resources Code section
5020.1(k), or
ii. A resource determined by the
lead agency, in its discretion
and supported by substantial
evidence, to be significant
pursuant to criteria set forth in
subdivision (c) of Public
Resources Code Section
5024.1. In applying the criteria
set forth in subdivision (c) of
Public Resource Code Section
5024.1, the lead agency shall
consider the significance of the
resource to a California Native
American tribe.

Discussion: A Phase I archeological survey was conducted by Padre Associates, Inc. of the project site on July 1, 2022. The field investigation identified no prehistoric materials or historic cultural resources within the project site. The site is located within an area characterized as low to moderate archaeological sensitivity, the existing landform has slightly been altered by an agricultural accessory structure and mainly used as pastureland for horses. The project area has excellent ground surface visibility, ranging from 60 to 95 percent, with discarded construction materials and oak detritus accounting for areas of reduced visibility. No tribal cultural resources were identified within the project area. Further, the original Covelop project initiated tribal notification in accordance with AB 52, with no further consultation requested as part of the project’s review period. Based on the location and characteristics of the site, it is unlikely that there are tribal cultural resources.

The project does not involve any element that might result in a new significant or substantially more severe impact to tribal cultural resources. Any unanticipated impacts to tribal cultural resources that might occur as a result of the project would be within the scope of those discussed in the MND. Furthermore, the City is not aware of any new circumstances or new information that might result in new significant or substantially more severe impacts to tribal cultural resources in relation to the project.

Mitigation Measures: None required.

Conclusion: The project would not have any new significant or substantially more severe impacts to tribal cultural resources (CEQA Guidelines § 15162(a)).

Exhibit A

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19. UTILITIES AND SERVICE SYSTEMS.

Would the project: Where was the impact analyzed? Do proposed changes involve new significant impacts or
substantially more severe
impacts?
Any new circumstances involving
new significant impacts or
substantially more severe
impacts?
Any new information of
substantial importance requiring
new analysis or verification?
What MND MMs address
impacts?
a. Require or result in the
relocation or construction of new
or expanded water, wastewater
treatment, or stormwater drainage,
electric power, natural gas, or
telecommunications facilities, the
construction or relocation of which
could cause significant
environmental effects?
MND, p. 23-24 No No No None required.
b. Have sufficient water supplies
available to serve the project and
reasonably foreseeable future
development during normal, dry
and multiple dry years?
MND, p. 23-24 No No No None required.
c. Result in a determination by the
wastewater treatment provider
which serves or may serve the
project that it has adequate
capacity to serve the project’s
projected demand in addition to
the provider’s existing
commitments?
MND, p. 23-24 No No No None required.
d. Generate solid waste in excess
of State or local standards, or in
excess of the capacity of local
infrastructure, or otherwise impair
the attainment of solid waste
reduction goals?
MND, p. 23-24 No No No None required.
e. Comply with federal, state, and
local statutes and regulations
related to solid waste?
MND, p. 23-24 No No No None required.

Discussion: Per the City’s General Plan EIR, Urban Water Management Plan, and Sewer System Management Plan, the City’s water and wastewater treatment facilities are adequately sized, including planned facility upgrades, to provide water needed for the project and treat effluent resulting from this project. All new storm water resulting from this project will be managed on the project site and will not enter existing storm water drainage facilities or require expansion of new drainage facilities.

No new water or wastewater facilities, electric power, natural gas, or telecommunications will need to be constructed or expanded for this project.

During construction, most debris would consist of recyclable materials such as wood pallets, plastic and paper packaging and scrap metal that can be taken to the nearby waste recycling center and all other non-recyclable construction debris being taken to the nearby landfill. The landfill has a maximum permitted capacity of 6,495,000 cubic yards and a maximum permitted throughput of 450 tons of solid waste per day and 75,000 tons per Exhibit A

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year, through October 1, 2051. As of December 31, 2017, the landfill had a remaining capacity of 4,216,402 cubic yards or approximately 65% of the maximum permitted. Operationally, large residential projects are anticipated to generate approximately 0.3021 yd3/unit, which equates to approximately 46 yd3. Further, the size/density of the project is within the City’s General Plan buildout for population and due to consistency with the General Plan and the the City’s Landfill Master Plan, the City’s landfill has been determined to be adequate capacity to accommodate construction related and operational solid waste disposal for this project; therefore, there is no impact to solid waste infrastructure from this Project.

The Project will comply with all federal, state, and local solid waste regulations and will not generate solid waste in excess beyond state of local standards or capacity.

In summary, the Project does not involve any element that might result in a new significant or substantially more severe impact to utilities and services systems. Any unanticipated impacts to utilities and service systems that might occur as a result of the Project would be within the scope of those discussed in the 2024 MND. Furthermore, the City is not aware of any new circumstances or new information that might result in new significant or substantially more severe impacts to utilities and service systems in relation to the Project.

Mitigation Measures: None required.

Conclusion: The project would not have any new significant or substantially more severe impacts to utilities and service systems (CEQA Guidelines § 15162(a)).

20. WILDFIRE. If located in or near state responsibility areas or lands classified as very high fire hazard severity zones:

Would the project: Where was the impact analyzed? Do proposed changes involve new significant impacts or
substantially more severe
impacts?
Any new circumstances involving
new significant impacts or
substantially more severe
impacts?
Any new information of
substantial importance requiring
new analysis or verification?
What MND MMs address
impacts?
a. Substantially impair an adopted
emergency response plan or
emergency evacuation plan?
MND, p. 24 No No No None required.
b. Due to slope, prevailing winds,
and other factors, exacerbate
wildfire risks, and thereby expose
project occupants to, pollutant
concentrations from a wildfire or
the uncontrolled spread of a
wildfire?
MND, p. 24 No No No None required.
c. Require the installation or
maintenance of associated
infrastructure (such as roads, fuel
breaks, emergency water sources,
power lines or other utilities) that
may exacerbate fire risk or that
may result in temporary or
ongoing impacts to the
environment?
MND, p. 24 No No No None required.
d. Expose people or structures to
significant risks, including
downslope or downstream
flooding or landslides, as a result
MND, p. 24 No No No None required.

Exhibit A

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of runoff, post-fire slope
instability, or drainage changes?
Discussion: The City of Paso Robles does not have an adopted emergency response plan or evacuation plan. Therefore, the Project would not impact an emergency response plan.

As previously identified, the site is not considered as being located within the wildland urban interface (WUI) and therefore would not need specific measures for fire-fighting purposes, beyond emergency vehicle access, clearance around structures, and connection to water. The Project has been reviewed by the City of Paso Robles Fire Department and designed with Fire Codes in mind. Given these considerations the impacts will be less than significant.

The Project site is relatively flat and not subject to landslide potential or significant drainage changes, therefore there would be no impact.

In summary, the Project does not involve any element that might result in a new significant or substantially more severe wildfire risk. Any impacts related to wildfire risk would be within the scope of those discussed in the 2024 MND. Furthermore, the City is not aware of any new circumstances or new information that might result in new significant or substantially more severe wildfire risk in relation to the Project.

Mitigation Measures: None required.

Conclusion: The project would not have any new significant or substantially more severe impacts to wildfire risk (CEQA Guidelines § 15162(a)).

21. MANDATORY FINDINGS OF SIGNIFICANCE.

Would the project: Where was the impact analyzed? Do proposed changes involve new significant impacts or
substantially more severe
impacts?
Any new circumstances involving
new significant impacts or
substantially more severe
impacts?
Any new information of
substantial importance requiring
new analysis or verification?
What MND MMs address
impacts?
a. Does the project have the
potential to degrade the quality of
the environment, substantially
reduce the habitat of a fish or
wildlife species, cause a fish or
wildlife population to drop below
self- sustaining levels, threaten to
eliminate a plant or animal
community, substantially
reduce the number or restrict the
range of an endangered, rare or
threatened species, or eliminate
important examples of the major
periods of California history or
prehistory?
MND, p. 25 No No No None required.
b. Does the project have impacts
that are individually limited, but
cumulatively considerable?
(“Cumulatively considerable”
means that the incremental effects
of a project are considerable when
MND, p. 25 No No No None required.

Exhibit A

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view in connection with the effects
of past projects, the effects of
other current projects, and the
effects of probable future
projects)?
c. Does the project have
environmental effects which will
cause substantial adverse effects
on human beings, either directly or
indirectly?
MND, p. 25 No No No None required.

Discussion: As noted within the Biological Resources section of this environmental document, there are two mitigation measures related to habitat for nesting birds and SJKF that will reduce impacts on biological resources to less than significant. There will be no impact to fish habitat as well as no impact to fish and wildlife populations.

The Project will not have impacts that are individually limited, but cumulatively considerable.

The Project will not cause substantial adverse effects on human beings, either directly or indirectly.

Mitigation Measures: None required.

Conclusion: The project would not have any new significant or substantially more severe impacts to the environment.

C. ANALYSIS AND BACKGROUND MATERIALS. Earlier analyses and new supplemental analyses may be used where, pursuant to tiering, program EIR, or other CEQA process, one or more effects have been adequately analyzed in an earlier EIR or negative declaration. Section 15063 (c)(3)(D). All documents area available for review at the City of Paso Robles Community Development Department - 1000 Spring Street, Paso Robles, CA 93446.

DOCUMENT TITLE

1. Mitigated Negative Declaration for Covelop, 2024

2. 45dB Acoustics Supplemental Memo for Ardmore Townhouses Project, 2025

3. Air Quality and Greenhouse Gas Supplemental Memo for Ardmore Townhouses Project, 2024

4. Heritage Tree Arboricultural Consulting Supplemental Memo for Ardmore Townhouses Project, 2025

5. Proposed Project - Plan Set, 2026

6. Proposed Project - Project Description, 2025
Exhibit A

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4 5 d B A c o u s t i c s , L L C
w w w . 4 5 d B . c o m
C a l i f o r n i a | C o l o r a d o
This report (including any enclosures and attachments) has been prepared for the exclusive use and benefit of the addressee(s) and solely for the purpose for which it is provided. No part of this report shall be reproduced, distributed or communicated to any third party without written permission. We do not accept any liability if this report is used for an alternative purpose from which it is intended, nor to any third party.

January 30, 2025
Acoustical Analysis:

Multifamily Housing
2930 Union Rd.

Paso Robles, CA 93446
Requested by:

Kirk Consulting
Attn: Ian McCarville
8830 Morro Rd.

Atascadero, CA 93422
Client/Owner:

Covelop
1135 Santa Rosa St., Ste #210
San Luis Obispo, CA 93401
Addendum
45dB Acoustics LLC (“45dB”) previously provided an acoustics study for the commercial/light industry development at the above address (most recent revision dated March 8, 2023).

The project plan has since been converted to a multifamily housing development. A site plan is shown in Figure 1.
45dB conducted a short-term measurement on January 29, 2025 between 9:45am and 11:30am north of the site and just north of an existing residence, and approximately 30 feet from the centerline of Ardmore Road (Figure 2). Paso Robles Fire Station Number 3 is located approximately 600 feet to the northwest of the site, at 2924 Union Road. Our previous study determined that noise levels due to transportation noise sources (i.e., primarily Highway 46 and, to a lesser extent, Union Road) for the site would be CNEL/DNL143 dBA or less. Ambient sound levels were approximately 50 dBA due to rather constant distant traffic from Highway 46 and Union Road; however sporadic semi-truck pass-byes on Ardmore Road of up to 82 dBA mean that the equivalent sound level for the 1.75-hour period was 55.6 dBA (Figure 3). Weather was foggy and breezy and may have elevated the noise levels somewhat due to higher propagation than on a clear day, along with wind noise on the sound level meter microphone, which together we anticipate may have elevated the noise levels by no more than 3dB. During our previous study, we were unaware of the frequency of semi-truck traffic on Ardmore Road, and we did not include significant truck traffic on Ardmore Road. 45dB measured during the late morning rush-hour period when traffic counts are expected to be highest/worst case, which can be considered a “design level” and is generally anticipated to approximate the DNL level2.

Sporadic backup beeping of trucks and semi-trucks were audible in our audio recordings. We estimate that the DNL at the measurement location adjacent to the roadway would be 1 Day-Night Level, DNL, and Community Noise Equivalent Level, CNEL, generally agree within 1 dB, and are considered equivalent here.
2 CalTrans: Technical Supplement Traffic Noise Analysis Protocol, Sept 2013: https://dot.ca.gov/-/media/dotmedia/programs/environmental-analysis/documents/env/tens-sep2013-a11y.pdf Exhibit B

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45dB Acoustics, LLC Providence School Gym
page 2 environmental noise : building acoustics : solutions & control www.45dB.com approximately equal to the LAeq for the 1.75-hour measurement period, i.e., DNL 56 dBA.

Sound levels further away from Ardmore Road, and further away from Union Road and Highway 46, are anticipated to be less than DNL 56 dBA. As such, DNL 56 dBA is anticipated to be the highest noise level for the Project.

Per the City of Paso Robles Noise Element of the General Plan3, a sound level of DNL 56 dBA remains below the maximum allowable limit of DNL 65 dBA for noise-sensitive outdoor areas for residential land uses (Table 1). Therefore, no mitigation measures are required for outdoor areas of the Project.

Standard construction assemblies and methods for the Project’s constructed buildings would provide an outdoor-to-indoor noise reduction (NR) of at least 20 dB. This would yield interior spaces for the proposed Project’s residences of DNL 36 dBA, which remains below the interior limit of DNL 45 dBA for interior residential projects (Table 1). As such, no additional mitigation measures are required in order for the Project to comply with the interior sound level limits of the Noise Element (and the overarching State Building Code Title 24). Because windows must remain closed in order to meet this interior noise level requirement, means of mechanical ventilation must be included in the Project’s residential units.

Please contact me with any questions.
for 45dB Acoustics, LLC, a California Limited Liability Company:

Sarah Taubitz, INCE, ASA
[email protected]
3 City of Paso Robles Noise Element of the General Plan:
https://www.prcity.com/DocumentCenter/View/28224/20191105-Adopted-Noise-Element Exhibit B

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45dB Acoustics, LLC 2930 Union
page 3 environmental noise : building acoustics : solutions & control www.45dB.com Figure 1: Ardmore site plan (supplied by client)
Exhibit B

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45dB Acoustics, LLC 2930 Union
page 4 environmental noise : building acoustics : solutions & control www.45dB.com Figure 2: Short-term sound level measurement map with project overlaid Exhibit B

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45dB Acoustics, LLC 2930 Union
page 5 environmental noise : building acoustics : solutions & control www.45dB.com Figure 3: Short-term sound level measurement data
Exhibit B

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45dB Acoustics, LLC 2930 Union
page 6 of 6 noise management : room acoustics : environmental impact www.45dB.com Table 1: Noise Standards for New Uses Affected by Traffic or Railroad Noise Exhibit B

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CARLSBAD
CLOVIS
IRVINE

LOS ANGELES

PALM SPRINGS

POINT RICHMOND

RIVERSIDE

ROSEVILLE

SAN LUIS OBISPO
2565 Alluvial Avenue, Suite 112, Clovis, California 93611 559.490.1210 www.lsa.net

MEMORANDUM
DATE: September 24, 2024
TO: Ian McCarville, Senior Planner, Kirk Consulting
FROM: Amy Fischer, President
Bianca Martinez, Air Quality Specialist
SUBJECT: Air Quality and Greenhouse Gas Emissions Results Memorandum for the 2930 Ardmore Road Project

INTRODUCTION
LSA Associates, Inc. (LSA) has prepared an Air Quality and Greenhouse Gas Emissions Results Memorandum for the 2930 Ardmore Road Project (project). This memorandum provides an analysis of the project’s potential air quality and greenhouse gas (GHG) impacts using the California Emissions Estimator Model version 2022.1 (CalEEMod). This analysis has been prepared using methods and assumptions recommended in the air quality impact assessment guidelines of the San Luis Obispo County Air Pollution Control District (SLO County APCD) and by the County of San Luis Obispo (County). This analysis also follows the guidelines within the SLO County APCD’s California Environmental Quality Act (CEQA) Air Quality Handbook1
.

PROJECT BACKGROUND
In 2023, LSA prepared the Air Quality and Greenhouse Gas Analysis to evaluate the potential air quality and climate change impacts associated with the Ardmore Industrial Project (Original Project).

Proposed development under the Original Project consisted of an approximately 125,812 squarefoot (sq ft) warehouse and an office building on Lot 13 (Building 1) and four commercial, storage, manufacturing, and winemaking buildings totaling approximately 114,515 sq ft on Lot 6 (Buildings 2–5). Buildings 2 through 5 would include the following uses: 9,000 sq ft of office uses; 116,812 sq ft of warehouse uses; 7,392 sq feet of retail uses; 41,016 sq ft of winemaking uses; 40,271 sq feet of storage uses, and 25,836 sq ft of manufacturing uses.

The original project is being modified to replace the proposed industrial land uses with a multifamily housing development. The purpose of this memorandum is to determine and quantify the maximum number of dwelling units allowed under the proposed project site without exceeding the air quality SLO County APCD emissions thresholds of significance. This analysis evaluates the project as 170 dwelling units as the minimum and 330 units as the maximum that could be constructed. 1 San Luis Obispo County Air Pollution Control District (SLO County APCD). 2012. CEQA Air Quality Handbook. April.

Exhibit C

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METHODOLOGY
Construction Emissions
The CalEEMod computer program was used to calculate emissions from on-site construction equipment and emissions from worker and vehicle trips to the site (provided as Appendix A).

Construction schedule information is not yet known. Therefore, this analysis utilizes the default construction schedule from CalEEMod, which assumes that construction would begin in January 2025 and would end in 2026. As mentioned above, this analysis uses 170 dwelling units as the minimum and 330 as the maximum number of dwelling units for the project. Consistent with the previous Air Quality and Greenhouse Gas Impact Report2
, this analysis assumes 920 sq ft to be
demolished. In addition, this analysis also assumes that the project would not require any soil import or export to the site. All other construction details are not yet known; therefore, default assumptions (e.g., construction equipment, worker and truck trips, and fleet activities) from CalEEMod were used.

Operational Emissions
Consistent with guidance for estimating emissions associated with land use development projects, the CalEEMod computer program was used to calculate the long-term operational emissions associated with the project. This analysis was conducted using the land use codes Apartments MidRise. Trip generation rates used in CalEEMod for the project were based on CalEEMod default trip generation rates for the proposed land uses. In addition, the proposed project would not include any woodburning hearths, which was assumed in CalEEMod. Detailed project information in not yet known; therefore, this analysis does not include land uses associated with site improvements such as landscape and paved area. When project-specific data were not available, default assumptions from CalEEMod were used to estimate the Modified Project emissions.

Greenhouse Gas Emissions
GHG emissions associated with the project would occur over the short-term from construction activities, consisting primarily of emissions from equipment exhaust. There would also be long-term GHG emissions associated with project-related vehicular trips. Recognizing that the field of global climate change analysis is rapidly evolving, the approaches advocated most recently indicate that for determining a project’s contribution to GHG emissions, lead agencies should calculate, or estimate, emissions from vehicular traffic, energy consumption, water conveyance and treatment, waste generation, construction activities, and any other significant source of emissions within the project area. The CalEEMod results were used to quantify GHG emissions generated by the two project scenarios.

ANALYSIS RESULTS
This section identifies potential air quality and GHG emissions associated with the two project scenarios.
2 LSA, Inc. 2023. Air Quality and Greenhouse Gas Analysis for the Ardmore Industrial Project. April.

Exhibit C

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9/24/24 (P:\20242002 2930 Ardmore Road\Products\2930 Ardmore Rd Results Memo.docx) 3 Air Quality
Construction Emissions
Construction emissions are summarized below in Table A. Attachment A provides CalEEMod output sheets.

Table A: Modified Project Air Quality Construction Emissions ROG + NOx
(combined)
Diesel Particulate Matter
(DPM)
Fugitive Dust2
(PM10)
pounds/day tons/quarter pounds/day tons/quarter tons/quarter 170 dwelling units
Project Construction
Emissions 78.0 0.9 1.4 <0.1 <0.1
SLO County APCD’s
Significance Threshold1 137 2.53 7 0.133 2.53
Exceeds Threshold? No No No No No
330 dwelling units
Project Construction
Emissions 120.35 1.3 1.4 <0.1 0.1
SLO County APCD’s
Significance Threshold1 137 2.53 7 0.133 2.53
Exceeds Threshold? No No No No No
Source: LSA (September 2024). 1 Daily and quarterly emission thresholds are based on the California Health & Safety Code and the CARB Carl Moyer Guidelines. 2 Per SLO County APCD, any project with a grading area greater than 4.0 acres of worked area can exceed the 2.5-ton PM10 quarterly threshold.
3 Quarterly Tier 1 thresholds.

CARB = California Air Resources Board
DPM = diesel particulate matter
NOx = nitrogen oxides
PM10 = particulate matter less than 10 microns in size
ROG = reactive organic gases
SLO County APCD = San Luis Obispo County Air Pollution Control District As shown in Table A, construction emissions associated with the project scenarios would be below the significance thresholds set by the SLO County APCD.

Operational Emissions
Table B provides the projects estimated operational emissions associated with the two project scenarios. Attachment A provides CalEEMod output sheets.

Exhibit C

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9/24/24 (P:\20242002 2930 Ardmore Road\Products\2930 Ardmore Rd Results Memo.docx) 4 Table B: Modified Project Air Quality Operational Emissions ROG + NOx
(combined)
Diesel
Particulate
Matter(DPM)
Fugitive Dust (PM10)
pounds/day tons/year pounds/day pounds/day tons/year
170 Dwelling Units
Project Operational
Emissions 12.9 0.6 0.1 2.1 0.1
SLO County APCD’s
Significance Threshold1 252 25 1.252 25 25
Exceeds Threshold? No No No No No
330 Dwelling Units
Project Operational
Emissions 24.9 1.1 0.2 4.1 0.2
SLO County APCD’s
Significance Threshold1 252 25 1.252 25 25
Exceeds Threshold? No No No No No
Source: LSA (September 2024). 1 Daily and annual emission thresholds are based on the California Health & Safety Code Division 26, Part 3, Chapter 10, Section 40918 CalEEMod = California Emissions Estimator Model
DPM = diesel particulate matter
NOx = nitrogen oxides
PM10 = particulate matter less than 10 microns in size
ROG = reactive organic gases
SLO County APCD = San Luis Obispo County Air Pollution Control District Greenhouse Gas Emissions
Construction Greenhouse Gas Emissions
Using CalEEMod, it is estimated that construction of 170 units would generate a total of approximately 454.8 MT CO2e during construction. When amortized over the 30-year life of the project, annual emissions would be 15.2 MT CO2e. The construction of 330 units would generate 576.0 MT CO2e during construction, when annualized over the life of the project, annual emissions would be 19.2 MT CO2e.

Operational Greenhouse Gas Emissions
Long-term operation of the project would generate GHG emissions from mobile, area, waste, and water sources and indirect emissions from sources associated with energy consumption.

Following guidance from the SLO County APCD, GHG emissions were estimated using CalEEMod.

Table C provides the estimated operational emissions associated with the two scenarios.

Attachment A provides CalEEMod output sheets
Exhibit C

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9/24/24 (P:\20242002 2930 Ardmore Road\Products\2930 Ardmore Rd Results Memo.docx) 5 Table C: Modified Project GHG Emissions (Metric Tons Per Year) Types of Emissions
Operational Emissions
CO2 CH4 N2O CO2e
170 Dwelling Units
Mobile Source Emissions 408.1 <0.1 <0.1 417.6
Area Source Emissions 3.9 <0.1 <0.1 3.9
Energy Source Emissions 272.2 <0.1 <0.1 273.3
Water Source Emissions 4.2 0.2 <0.1 9.6
Waste Source Emissions 11.2 1.1 0.0 39.2
Total Operational Emissions 743.6
Amortized Construction Emissions 15.2
Total Annual Emissions 758.8
SLO County APCD Operational Year Numeric Threshold 1,150.0 Exceed? No
330 Dwelling Units
Mobile Source Emissions 792.2 0.1 0.1 810.7
Area Source Emissions 7.5 <0.1 <0.1 7.5
Energy Source Emissions 528.5 0.1 <0.1 530.6
Water Source Emissions 8.2 0.3 <0.1 18.6
Waste Source Emissions 21.8 2.2 0.0 76.2
Total Operational Emissions 1,443.6
Amortized Construction Emissions 19.2
Total Annual Emissions 1,462.8
SLO County APCD Operational Year Numeric Threshold 1,150 Exceed? Yes
Service Population Emissions 1.6
SLO County APCD Scaled 2031 Service Population Threshold 4.9 Exceeds Threshold? No
Source: LSA (September 2024).

Note = Some values may appear to be incorrect due to rounding.

CH4 = methane
CO2 = carbon monoxide
CO2e = CO2 equivalents
N2O = nitrous oxide
SLO County APCD = San Luis Obispo County Air Pollution Control District
GHG emissions generated by the project would be less than significant if one or more of the following criteria are met: (1) the proposed project result in operational-related GHG emissions of less than 1,150 MT CO2e per year, or (2) the proposed project would result in operational-related GHG emissions of less than 4.9 MT CO2e per year per service population (residents plus employees).

Exhibit C

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9/24/24 (P:\20242002 2930 Ardmore Road\Products\2930 Ardmore Rd Results Memo.docx) 6 As shown in Table C, the 170 units would generate approximately 758.8 MT CO2e per year, which would not exceed the numeric threshold of 1,150 MT CO2e.

Development of 330 units would generate approximately 1,462.8 MT CO2e per year, which would exceed the 1,150 MT CO2e threshold. Therefore, the following discussion evaluates the 330 units under the using the 4.9 MT CO2e per year per service population threshold.

According to the 2050 Regional Growth Forecast for San Luis Obispo County, the forecasted household size in Paso Robles in 2015 was 2.78 residents.3 Under the 330-unit scenario, the project would house approximately 917 persons. As such, the 330-unit scenario would result in a per service population emission of 1.6 MT CO2e per year per service population, which would be below the SLO County APCD efficiency threshold of 4.9 MT CO2e per year per service population.

CONCLUSION
Based on the analysis presented above, short-term construction emissions would not exceed the significant threshold criteria for daily ROG, NOX, PM10, or PM2.5 emissions with a project size between 170 and 330 units. The long-term operational emissions would also not result in the generation of criteria pollutants that would exceed the thresholds of significance. In addition, the GHG emissions would not exceed the threshold of 1,150 MT CO2e/yr; therefore, project-related GHG impacts would remain less than significant under a 170- or 330-unit project scenario. Based on the analysis presented above, the maximum number of units allowed on the project site would be approximately 330 multi-family units.

Attachments: A: CalEEMod Output Sheets
3 San Luis Obispo Council of Governments (SLOCOG). 2017. 2050 Regional Growth Forecast for San Luis Obispo County. Website: https://www.dropbox.com/s/rkukq86qtmtmgjz/2050RegionalGrowthForecast_ June2017.pdf?dl=0 (accessed September 2024).

Exhibit C

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ATTACHMENT A

CALEEMOD OUTPUT SHEETS
Exhibit C

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2930 Ardmore Road Project (170 Dwelling Units Scenario) Custom 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

2.4. Operations Emissions Compared Against Thresholds

2.5. Operations Emissions by Sector, Unmitigated

3. Construction Emissions Details

3.1. Demolition (2025) - Unmitigated

3.3. Site Preparation (2025) - Unmitigated

3.5. Grading (2025) - Unmitigated

3.7. Building Construction (2025) - Unmitigated
Exhibit C

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3.9. Building Construction (2026) - Unmitigated

3.11. Paving (2026) - Unmitigated

3.13. Architectural Coating (2025) - Unmitigated

3.15. Architectural Coating (2026) - Unmitigated

4. Operations Emissions Details

4.1. Mobile Emissions by Land Use

4.1.1. Unmitigated

4.2. Energy

4.2.1. Electricity Emissions By Land Use - Unmitigated

4.2.3. Natural Gas Emissions By Land Use - Unmitigated

4.3. Area Emissions by Source

4.3.1. Unmitigated

4.4. Water Emissions by Land Use

4.4.1. Unmitigated

4.5. Waste Emissions by Land Use

4.5.1. Unmitigated

4.6. Refrigerant Emissions by Land Use

4.6.1. Unmitigated
Exhibit C

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4.7. Offroad Emissions By Equipment Type

4.7.1. Unmitigated

4.8. Stationary Emissions By Equipment Type

4.8.1. Unmitigated

4.9. User Defined Emissions By Equipment Type

4.9.1. Unmitigated

4.10. Soil Carbon Accumulation By Vegetation Type

4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated

4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated

4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated

5. Activity Data

5.1. Construction Schedule

5.2. Off-Road Equipment

5.2.1. Unmitigated

5.3. Construction Vehicles

5.3.1. Unmitigated

5.4. Vehicles

5.4.1. Construction Vehicle Control Strategies
Exhibit C

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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

5.10. Operational Area Sources

5.10.1. Hearths

5.10.1.1. Unmitigated

5.10.2. Architectural Coatings

5.10.3. Landscape Equipment

5.11. Operational Energy Consumption

5.11.1. Unmitigated

5.12. Operational Water and Wastewater Consumption

5.12.1. Unmitigated

5.13. Operational Waste Generation
Exhibit C

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5.13.1. Unmitigated

5.14. Operational Refrigeration and Air Conditioning Equipment

5.14.1. Unmitigated

5.15. Operational Off-Road Equipment

5.15.1. Unmitigated

5.16. Stationary Sources

5.16.1. Emergency Generators and Fire Pumps

5.16.2. Process Boilers

5.17. User Defined

5.18. Vegetation

5.18.1. Land Use Change

5.18.1.1. Unmitigated

5.18.1. Biomass Cover Type

5.18.1.1. Unmitigated

5.18.2. Sequestration

5.18.2.1. Unmitigated

8. User Changes to Default Data
Exhibit C

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1. Basic Project Information

1.1. Basic Project Information
Data Field Value
Project Name 2930 Ardmore Road Project (170 Dwelling Units Scenario) Construction Start Date 1/6/2025
Operational Year 2026
Lead Agency —
Land Use Scale Project/site
Analysis Level for Defaults County
Windspeed (m/s) 3.00
Precipitation (days) 24.6
Location 35.6421954541768, -120.65084092570058
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 2022.1.1.28

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
Apartments Mid
Rise
170 Dwelling Unit 4.47 163,200 0.00 — 408 —
Exhibit C

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

2. Emissions Summary

2.1. Construction Emissions Compared Against Thresholds Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Un/Mit. ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — —
Unmit. 46.3 12.3 19.2 0.03 0.46 0.95 1.41 0.43 0.23 0.65 — 3,835 3,835 0.17 0.12 3,880 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — —
Unmit. 46.3 31.7 30.7 0.05 1.37 19.8 21.1 1.26 10.1 11.4 — 5,398 5,398 0.22 0.12 5,417 Average
Daily
(Max)
— — — — — — — — — — — — — — — —
Unmit. 10.0 9.14 12.8 0.02 0.36 0.94 1.30 0.33 0.34 0.67 — 2,534 2,534 0.10 0.07 2,560 Annual
(Max)
— — — — — — — — — — — — — — — —
Unmit. 1.83 1.67 2.33 < 0.005 0.07 0.17 0.24 0.06 0.06 0.12 — 420 420 0.02 0.01 424

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 BCO2 NBCO2 CO2T CH4 N2O CO2e Daily -
Summer
(Max)
— — — — — — — — — — — — — — — —
2025 46.3 12.3 19.2 0.03 0.46 0.95 1.41 0.43 0.23 0.65 — 3,835 3,835 0.17 0.12 3,880 Exhibit C

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Daily -
Winter
(Max)
— — — — — — — — — — — — — — — —
2025 46.3 31.7 30.7 0.05 1.37 19.8 21.1 1.26 10.1 11.4 — 5,398 5,398 0.22 0.12 5,417 2026 46.2 11.7 18.7 0.03 0.41 0.95 1.35 0.38 0.23 0.60 — 3,774 3,774 0.15 0.12 3,813 Average
Daily
— — — — — — — — — — — — — — — —
2025 10.0 9.14 12.8 0.02 0.36 0.94 1.30 0.33 0.34 0.67 — 2,534 2,534 0.10 0.07 2,560 2026 5.14 0.67 1.07 < 0.005 0.02 0.04 0.06 0.02 0.01 0.03 — 186 186 0.01 < 0.005 187 Annual — — — — — — — — — — — — — — — —
2025 1.83 1.67 2.33 < 0.005 0.07 0.17 0.24 0.06 0.06 0.12 — 420 420 0.02 0.01 424 2026 0.94 0.12 0.20 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 0.01 — 30.8 30.8 < 0.005 < 0.005 31.0

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 BCO2 NBCO2 CO2T CH4 N2O CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — —
Unmit. 9.70 3.13 24.9 0.03 0.12 2.15 2.27 0.12 0.54 0.66 77.6 4,342 4,419 8.16 0.19 4,692 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — —
Unmit. 8.75 3.22 16.4 0.03 0.12 2.15 2.26 0.11 0.54 0.66 77.6 4,241 4,319 8.19 0.20 4,586 Average
Daily
(Max)
— — — — — — — — — — — — — — — —
Unmit. 9.31 3.17 23.9 0.03 0.12 2.01 2.13 0.12 0.51 0.63 77.6 4,148 4,226 8.17 0.19 4,493 Annual
(Max)
— — — — — — — — — — — — — — — —
Unmit. 1.70 0.58 4.35 0.01 0.02 0.37 0.39 0.02 0.09 0.11 12.8 687 700 1.35 0.03 744 Exhibit C

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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 BCO2 NBCO2 CO2T CH4 N2O CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — —
Mobile 3.89 1.97 14.8 0.03 0.03 2.15 2.17 0.03 0.54 0.57 — 2,656 2,656 0.21 0.16 2,719 Area 5.75 0.09 9.64 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 0.00 25.8 25.8 < 0.005 < 0.005 25.9 Energy 0.06 1.07 0.46 0.01 0.09 — 0.09 0.09 — 0.09 — 1,644 1,644 0.17 0.01 1,651 Water — — — — — — — — — — 9.85 15.5 25.4 1.01 0.02 57.9 Waste — — — — — — — — — — 67.8 0.00 67.8 6.77 0.00 237
Refrig. — — — — — — — — — — — — — — — 1.17
Total 9.70 3.13 24.9 0.03 0.12 2.15 2.27 0.12 0.54 0.66 77.6 4,342 4,419 8.16 0.19 4,692 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — —
Mobile 3.79 2.15 16.0 0.03 0.03 2.15 2.17 0.03 0.54 0.57 — 2,581 2,581 0.24 0.17 2,639 Area 4.89 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Energy 0.06 1.07 0.46 0.01 0.09 — 0.09 0.09 — 0.09 — 1,644 1,644 0.17 0.01 1,651 Water — — — — — — — — — — 9.85 15.5 25.4 1.01 0.02 57.9 Waste — — — — — — — — — — 67.8 0.00 67.8 6.77 0.00 237
Refrig. — — — — — — — — — — — — — — — 1.17
Total 8.75 3.22 16.4 0.03 0.12 2.15 2.26 0.11 0.54 0.66 77.6 4,241 4,319 8.19 0.20 4,586 Average
Daily
— — — — — — — — — — — — — — — —
Mobile 3.58 2.01 14.7 0.02 0.03 2.01 2.03 0.03 0.51 0.54 — 2,465 2,465 0.22 0.16 2,522 Area 5.66 0.08 8.71 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 0.00 23.3 23.3 < 0.005 < 0.005 23.4 Energy 0.06 1.07 0.46 0.01 0.09 — 0.09 0.09 — 0.09 — 1,644 1,644 0.17 0.01 1,651 Water — — — — — — — — — — 9.85 15.5 25.4 1.01 0.02 57.9 Waste — — — — — — — — — — 67.8 0.00 67.8 6.77 0.00 237
Exhibit C

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Refrig. — — — — — — — — — — — — — — — 1.17
Total 9.31 3.17 23.9 0.03 0.12 2.01 2.13 0.12 0.51 0.63 77.6 4,148 4,226 8.17 0.19 4,493 Annual — — — — — — — — — — — — — — — —
Mobile 0.65 0.37 2.68 < 0.005 < 0.005 0.37 0.37 < 0.005 0.09 0.10 — 408 408 0.04 0.03 418 Area 1.03 0.02 1.59 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 0.00 3.86 3.86 < 0.005 < 0.005 3.87 Energy 0.01 0.20 0.08 < 0.005 0.02 — 0.02 0.02 — 0.02 — 272 272 0.03 < 0.005 273 Water — — — — — — — — — — 1.63 2.57 4.20 0.17 < 0.005 9.59 Waste — — — — — — — — — — 11.2 0.00 11.2 1.12 0.00 39.2 Refrig. — — — — — — — — — — — — — — — 0.19
Total 1.70 0.58 4.35 0.01 0.02 0.37 0.39 0.02 0.09 0.11 12.8 687 700 1.35 0.03 744

3. Construction Emissions Details

3.1. Demolition (2025) - 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 BCO2 NBCO2 CO2T CH4 N2O CO2e Onsite — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — —
Off-Road
Equipment

2.40 22.2 19.9 0.03 0.92 — 0.92 0.84 — 0.84 — 3,425 3,425 0.14 0.03 3,437 Demolitio
n
— — — — — 0.00 0.00 — 0.00 0.00 — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — —
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Off-Road
Equipment

0.13 1.22 1.09 < 0.005 0.05 — 0.05 0.05 — 0.05 — 188 188 0.01 < 0.005 188 Demolitio
n
— — — — — 0.00 0.00 — 0.00 0.00 — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.02 0.22 0.20 < 0.005 0.01 — 0.01 0.01 — 0.01 — 31.1 31.1 < 0.005 < 0.005 31.2 Demolitio
n
— — — — — 0.00 0.00 — 0.00 0.00 — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — —
Worker 0.06 0.04 0.48 0.00 0.00 0.09 0.09 0.00 0.02 0.02 — 87.6 87.6 < 0.005 < 0.005 88.9 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 0.03 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 4.84 4.84 < 0.005 < 0.005 4.92 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.80 0.80 < 0.005 < 0.005 0.81 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Exhibit C

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3.3. Site Preparation (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O CO2e Onsite — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — —
Off-Road
Equipment

3.31 31.6 30.2 0.05 1.37 — 1.37 1.26 — 1.26 — 5,295 5,295 0.21 0.04 5,314 Dust
From
Material
Movement
— — — — — 19.7 19.7 — 10.1 10.1 — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — —
Off-Road
Equipment

0.05 0.43 0.41 < 0.005 0.02 — 0.02 0.02 — 0.02 — 72.5 72.5 < 0.005 < 0.005 72.8 Dust
From
Material
Movement
— — — — — 0.27 0.27 — 0.14 0.14 — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.01 0.08 0.08 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 12.0 12.0 < 0.005 < 0.005 12.1 Dust
From
Material
Movement
— — — — — 0.05 0.05 — 0.03 0.03 — — — — — —
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 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — —
Worker 0.07 0.05 0.56 0.00 0.00 0.10 0.10 0.00 0.02 0.02 — 102 102 < 0.005 < 0.005 104 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 1.41 1.41 < 0.005 < 0.005 1.43 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.23 0.23 < 0.005 < 0.005 0.24 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00

3.5. Grading (2025) - 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 BCO2 NBCO2 CO2T CH4 N2O CO2e Onsite — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — —
Exhibit C

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Off-Road
Equipment

1.74 16.3 17.9 0.03 0.72 — 0.72 0.66 — 0.66 — 2,959 2,959 0.12 0.02 2,970 Dust
From
Material
Movement
— — — — — 7.08 7.08 — 3.42 3.42 — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — —
Off-Road
Equipment

0.04 0.36 0.39 < 0.005 0.02 — 0.02 0.01 — 0.01 — 64.9 64.9 < 0.005 < 0.005 65.1 Dust
From
Material
Movement
— — — — — 0.16 0.16 — 0.08 0.08 — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.01 0.07 0.07 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 10.7 10.7 < 0.005 < 0.005 10.8 Dust
From
Material
Movement
— — — — — 0.03 0.03 — 0.01 0.01 — — — — — —
Onsite
truck

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Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 1.93 1.93 < 0.005 < 0.005 1.97 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.32 0.32 < 0.005 < 0.005 0.33 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00

3.7. Building Construction (2025) - 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 BCO2 NBCO2 CO2T CH4 N2O CO2e Onsite — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — —
Off-Road
Equipment

1.13 10.4 13.0 0.02 0.43 — 0.43 0.40 — 0.40 — 2,398 2,398 0.10 0.02 2,406 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — —
Off-Road
Equipment

1.13 10.4 13.0 0.02 0.43 — 0.43 0.40 — 0.40 — 2,398 2,398 0.10 0.02 2,406 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — —
Exhibit C

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Off-Road 0.69 6.36 7.94 0.01 0.26 — 0.26 0.24 — 0.24 — 1,459 1,459 0.06 0.01 1,464 Equipment
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.13 1.16 1.45 < 0.005 0.05 — 0.05 0.04 — 0.04 — 242 242 0.01 < 0.005 242 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — —
Worker 0.50 0.31 3.99 0.00 0.00 0.70 0.70 0.00 0.16 0.16 — 746 746 0.05 0.03 760 Vendor 0.02 0.60 0.24 < 0.005 0.01 0.11 0.11 0.01 0.03 0.03 — 408 408 0.01 0.06 428 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — —
Worker 0.49 0.35 3.90 0.00 0.00 0.70 0.70 0.00 0.16 0.16 — 715 715 0.03 0.03 726 Vendor 0.02 0.61 0.25 < 0.005 0.01 0.11 0.11 0.01 0.03 0.03 — 408 408 0.01 0.06 427 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — —
Worker 0.29 0.21 2.35 0.00 0.00 0.42 0.42 0.00 0.10 0.10 — 438 438 0.02 0.02 445 Vendor 0.01 0.38 0.15 < 0.005 < 0.005 0.06 0.07 < 0.005 0.02 0.02 — 249 249 0.01 0.04 260 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — —
Worker 0.05 0.04 0.43 0.00 0.00 0.08 0.08 0.00 0.02 0.02 — 72.6 72.6 < 0.005 < 0.005 73.8 Vendor < 0.005 0.07 0.03 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 41.1 41.1 < 0.005 0.01 43.1 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Exhibit C

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3.9. 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 BCO2 NBCO2 CO2T CH4 N2O CO2e Onsite — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — —
Off-Road
Equipment

1.07 9.85 13.0 0.02 0.38 — 0.38 0.35 — 0.35 — 2,397 2,397 0.10 0.02 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 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — —
Off-Road
Equipment

0.03 0.23 0.30 < 0.005 0.01 — 0.01 0.01 — 0.01 — 56.3 56.3 < 0.005 < 0.005 56.5 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — —
Off-Road
Equipment
< 0.005 0.04 0.06 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 9.32 9.32 < 0.005 < 0.005 9.35 Onsite
truck

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Vendor 0.01 0.59 0.23 < 0.005 0.01 0.11 0.11 0.01 0.03 0.03 — 401 401 0.01 0.06 419 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — —
Worker 0.01 0.01 0.08 0.00 0.00 0.02 0.02 0.00 < 0.005 < 0.005 — 16.6 16.6 < 0.005 < 0.005 16.9 Vendor < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 9.41 9.41 < 0.005 < 0.005 9.84 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 2.75 2.75 < 0.005 < 0.005 2.79 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 1.56 1.56 < 0.005 < 0.005 1.63 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00

3.11. Paving (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 BCO2 NBCO2 CO2T CH4 N2O CO2e Onsite — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — —
Off-Road
Equipment

0.68 6.23 8.81 0.01 0.26 — 0.26 0.24 — 0.24 — 1,350 1,350 0.05 0.01 1,355 Paving 0.00 — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — —
Off-Road
Equipment

0.03 0.31 0.43 < 0.005 0.01 — 0.01 0.01 — 0.01 — 66.6 66.6 < 0.005 < 0.005 66.8 Exhibit C

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Paving 0.00 — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.01 0.06 0.08 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 11.0 11.0 < 0.005 < 0.005 11.1 Paving 0.00 — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — —
Worker 0.08 0.05 0.60 0.00 0.00 0.11 0.11 0.00 0.03 0.03 — 115 115 < 0.005 0.01 116 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 0.03 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 — 5.70 5.70 < 0.005 < 0.005 5.79 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.94 0.94 < 0.005 < 0.005 0.96 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00

3.13. Architectural Coating (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Exhibit C

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Location ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O CO2e Onsite — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — —
Off-Road
Equipment

0.13 0.88 1.14 < 0.005 0.03 — 0.03 0.03 — 0.03 — 134 134 0.01 < 0.005 134 Architect
ural
Coatings

44.4 — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — —
Off-Road
Equipment

0.13 0.88 1.14 < 0.005 0.03 — 0.03 0.03 — 0.03 — 134 134 0.01 < 0.005 134 Architect
ural
Coatings

44.4 — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — —
Off-Road
Equipment

0.03 0.17 0.23 < 0.005 0.01 — 0.01 < 0.005 — < 0.005 — 26.4 26.4 < 0.005 < 0.005 26.5 Architect
ural
Coatings

8.78 — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — —
Off-Road
Equipment
< 0.005 0.03 0.04 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 4.37 4.37 < 0.005 < 0.005 4.38 Exhibit C

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Architect 1.60 — — — — — — — — — — — — — — —
ural
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — —
Worker 0.10 0.06 0.80 0.00 0.00 0.14 0.14 0.00 0.03 0.03 — 149 149 0.01 0.01 152 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — —
Worker 0.10 0.07 0.78 0.00 0.00 0.14 0.14 0.00 0.03 0.03 — 143 143 0.01 0.01 145 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — —
Worker 0.02 0.01 0.15 0.00 0.00 0.03 0.03 0.00 0.01 0.01 — 28.5 28.5 < 0.005 < 0.005 28.9 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 0.03 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 4.71 4.71 < 0.005 < 0.005 4.79 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00

3.15. 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 BCO2 NBCO2 CO2T CH4 N2O CO2e Onsite — — — — — — — — — — — — — — — —
Exhibit C

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Daily,
Summer
(Max)
— — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — —
Off-Road
Equipment

0.12 0.86 1.13 < 0.005 0.02 — 0.02 0.02 — 0.02 — 134 134 0.01 < 0.005 134 Architect
ural
Coatings

44.4 — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — —
Off-Road
Equipment

0.01 0.10 0.13 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 15.2 15.2 < 0.005 < 0.005 15.2 Architect
ural
Coatings

5.04 — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — —
Off-Road
Equipment
< 0.005 0.02 0.02 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 2.51 2.51 < 0.005 < 0.005 2.52 Architect
ural
Coatings

0.92 — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — —
Exhibit C

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Daily, — — — — — — — — — — — — — — — —
Winter
(Max)
Worker 0.09 0.06 0.73 0.00 0.00 0.14 0.14 0.00 0.03 0.03 — 140 140 0.01 0.01 143 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — —
Worker 0.01 0.01 0.08 0.00 0.00 0.02 0.02 0.00 < 0.005 < 0.005 — 16.1 16.1 < 0.005 < 0.005 16.3 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 2.66 2.66 < 0.005 < 0.005 2.70 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00

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 BCO2 NBCO2 CO2T CH4 N2O CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — —
Apartmen
ts
Mid Rise

3.89 1.97 14.8 0.03 0.03 2.15 2.17 0.03 0.54 0.57 — 2,656 2,656 0.21 0.16 2,719 Total 3.89 1.97 14.8 0.03 0.03 2.15 2.17 0.03 0.54 0.57 — 2,656 2,656 0.21 0.16 2,719 Exhibit C

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Daily, — — — — — — — — — — — — — — — —
Winter
(Max)
Apartmen
ts
Mid Rise

3.79 2.15 16.0 0.03 0.03 2.15 2.17 0.03 0.54 0.57 — 2,581 2,581 0.24 0.17 2,639 Total 3.79 2.15 16.0 0.03 0.03 2.15 2.17 0.03 0.54 0.57 — 2,581 2,581 0.24 0.17 2,639 Annual — — — — — — — — — — — — — — — —
Apartmen
ts
Mid Rise

0.65 0.37 2.68 < 0.005 < 0.005 0.37 0.37 < 0.005 0.09 0.10 — 408 408 0.04 0.03 418 Total 0.65 0.37 2.68 < 0.005 < 0.005 0.37 0.37 < 0.005 0.09 0.10 — 408 408 0.04 0.03 418

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 BCO2 NBCO2 CO2T CH4 N2O CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — —
Apartmen
ts
Mid Rise
— — — — — — — — — — — 282 282 0.05 0.01 285
Total — — — — — — — — — — — 282 282 0.05 0.01 285
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — —
Apartmen
ts
Mid Rise
— — — — — — — — — — — 282 282 0.05 0.01 285
Total — — — — — — — — — — — 282 282 0.05 0.01 285
Annual — — — — — — — — — — — — — — — —
Exhibit C

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Apartmen — — — — — — — — — — — 46.7 46.7 0.01 < 0.005 47.1 ts
Total — — — — — — — — — — — 46.7 46.7 0.01 < 0.005 47.1

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 BCO2 NBCO2 CO2T CH4 N2O CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — —
Apartmen
ts
Mid Rise

0.06 1.07 0.46 0.01 0.09 — 0.09 0.09 — 0.09 — 1,362 1,362 0.12 < 0.005 1,366 Total 0.06 1.07 0.46 0.01 0.09 — 0.09 0.09 — 0.09 — 1,362 1,362 0.12 < 0.005 1,366 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — —
Apartmen
ts
Mid Rise

0.06 1.07 0.46 0.01 0.09 — 0.09 0.09 — 0.09 — 1,362 1,362 0.12 < 0.005 1,366 Total 0.06 1.07 0.46 0.01 0.09 — 0.09 0.09 — 0.09 — 1,362 1,362 0.12 < 0.005 1,366 Annual — — — — — — — — — — — — — — — —
Apartmen
ts
Mid Rise

0.01 0.20 0.08 < 0.005 0.02 — 0.02 0.02 — 0.02 — 226 226 0.02 < 0.005 226 Total 0.01 0.20 0.08 < 0.005 0.02 — 0.02 0.02 — 0.02 — 226 226 0.02 < 0.005 226

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 BCO2 NBCO2 CO2T CH4 N2O CO2e Exhibit C

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Daily,
Summer
(Max)
— — — — — — — — — — — — — — — —
Hearths 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Consume
r
Products

3.49 — — — — — — — — — — — — — — —
Architect
ural
Coatings

1.40 — — — — — — — — — — — — — — —
Landscap
e
Equipme
nt

0.85 0.09 9.64 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 25.8 25.8 < 0.005 < 0.005 25.9 Total 5.75 0.09 9.64 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 0.00 25.8 25.8 < 0.005 < 0.005 25.9 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — —
Hearths 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Consume
r
Products

3.49 — — — — — — — — — — — — — — —
Architect
ural
Coatings

1.40 — — — — — — — — — — — — — — —
Total 4.89 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — —
Hearths 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Consume
r
Products

0.64 — — — — — — — — — — — — — — —
Architect
ural
Coatings

0.26 — — — — — — — — — — — — — — —
Exhibit C

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Landscap 0.14 0.02 1.59 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 3.86 3.86 < 0.005 < 0.005 3.87 e
Equipme
Total 1.03 0.02 1.59 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 0.00 3.86 3.86 < 0.005 < 0.005 3.87

4.4. Water Emissions by Land Use

4.4.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — —
Apartmen
ts
Mid Rise
— — — — — — — — — — 9.85 15.5 25.4 1.01 0.02 57.9
Total — — — — — — — — — — 9.85 15.5 25.4 1.01 0.02 57.9 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — —
Apartmen
ts
Mid Rise
— — — — — — — — — — 9.85 15.5 25.4 1.01 0.02 57.9
Total — — — — — — — — — — 9.85 15.5 25.4 1.01 0.02 57.9 Annual — — — — — — — — — — — — — — — —
Apartmen
ts
Mid Rise
— — — — — — — — — — 1.63 2.57 4.20 0.17 < 0.005 9.59
Total — — — — — — — — — — 1.63 2.57 4.20 0.17 < 0.005 9.59

4.5. Waste Emissions by Land Use

4.5.1. Unmitigated
Exhibit C

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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 BCO2 NBCO2 CO2T CH4 N2O CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — —
Apartmen
ts
Mid Rise
— — — — — — — — — — 67.8 0.00 67.8 6.77 0.00 237
Total — — — — — — — — — — 67.8 0.00 67.8 6.77 0.00 237
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — —
Apartmen
ts
Mid Rise
— — — — — — — — — — 67.8 0.00 67.8 6.77 0.00 237
Total — — — — — — — — — — 67.8 0.00 67.8 6.77 0.00 237
Annual — — — — — — — — — — — — — — — —
Apartmen
ts
Mid Rise
— — — — — — — — — — 11.2 0.00 11.2 1.12 0.00 39.2
Total — — — — — — — — — — 11.2 0.00 11.2 1.12 0.00 39.2

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 BCO2 NBCO2 CO2T CH4 N2O CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — —
Apartmen
ts
Mid Rise
— — — — — — — — — — — — — — — 1.17
Total — — — — — — — — — — — — — — — 1.17
Exhibit C

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Daily,
Winter
(Max)
— — — — — — — — — — — — — — — —
Apartmen
ts
Mid Rise
— — — — — — — — — — — — — — — 1.17
Total — — — — — — — — — — — — — — — 1.17
Annual — — — — — — — — — — — — — — — —
Apartmen
ts
Mid Rise
— — — — — — — — — — — — — — — 0.19
Total — — — — — — — — — — — — — — — 0.19

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) Equipme
nt
Type
ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — —

4.8. Stationary Emissions By Equipment Type
Exhibit C

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4.8.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipme
nt
Type
ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O 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) Equipme
nt
Type
ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — —
Exhibit C

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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) Vegetatio
n
ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — —

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

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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 BCO2 NBCO2 CO2T CH4 N2O CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — —
Sequeste
red
— — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — —
Removed — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — —
— — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — —
Sequeste
red
— — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — —
Removed — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — —
— — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — —
Exhibit C

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Sequeste — — — — — — — — — — — — — — — —
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 Demolition Demolition 1/6/2025 2/3/2025 5.00 20.0 —
Site Preparation Site Preparation 2/4/2025 2/11/2025 5.00 5.00 — Grading Grading 2/12/2025 2/23/2025 5.00 8.00 —
Building Construction Building Construction 2/24/2025 1/12/2026 5.00 230 — Paving Paving 1/13/2026 2/7/2026 5.00 18.0 —
Architectural Coating Architectural Coating 9/22/2025 2/27/2026 5.00 115 —

5.2. Off-Road Equipment

5.2.1. Unmitigated
Phase Name Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor Demolition Concrete/Industrial
Saws
Diesel Average 1.00 8.00 33.0 0.73
Demolition Excavators Diesel Average 3.00 8.00 36.0 0.38 Demolition Rubber Tired Dozers Diesel Average 2.00 8.00 367 0.40 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
Exhibit C

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Grading Excavators Diesel Average 1.00 8.00 36.0 0.38
Grading Graders Diesel Average 1.00 8.00 148 0.41
Grading Rubber Tired Dozers Diesel Average 1.00 8.00 367 0.40 Grading 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 Cement and Mortar
Mixers
Diesel Average 2.00 6.00 10.0 0.56
Paving Pavers Diesel Average 1.00 8.00 81.0 0.42
Paving Paving Equipment Diesel Average 2.00 6.00 89.0 0.36 Paving Rollers Diesel Average 2.00 6.00 36.0 0.38
Paving Tractors/Loaders/Back
hoes
Diesel Average 1.00 8.00 84.0 0.37
Architectural Coating Air Compressors Diesel Average 1.00 6.00 37.0 0.48

5.3. Construction Vehicles

5.3.1. Unmitigated
Phase Name Trip Type One-Way Trips per Day Miles per Trip Vehicle Mix Demolition — — — —
Demolition Worker 15.0 8.10 LDA,LDT1,LDT2
Demolition Vendor — 6.90 HHDT,MHDT
Demolition Hauling 0.00 20.0 HHDT
Demolition Onsite truck — — HHDT
Site Preparation — — — —
Exhibit C

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Site Preparation Worker 17.5 8.10 LDA,LDT1,LDT2
Site Preparation Vendor — 6.90 HHDT,MHDT
Site Preparation Hauling 0.00 20.0 HHDT
Site Preparation Onsite truck — — HHDT
Grading — — — —
Grading Worker 15.0 8.10 LDA,LDT1,LDT2
Grading Vendor — 6.90 HHDT,MHDT
Grading Hauling 0.00 20.0 HHDT
Grading Onsite truck — — HHDT
Building Construction — — — —
Building Construction Worker 122 8.10 LDA,LDT1,LDT2
Building Construction Vendor 18.2 6.90 HHDT,MHDT
Building Construction Hauling 0.00 20.0 HHDT
Building Construction Onsite truck — — HHDT
Paving — — — —
Paving Worker 20.0 8.10 LDA,LDT1,LDT2
Paving Vendor — 6.90 HHDT,MHDT
Paving Hauling 0.00 20.0 HHDT
Paving Onsite truck — — HHDT
Architectural Coating — — — —
Architectural Coating Worker 24.5 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
Exhibit C

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Control Strategies Applied PM10 Reduction PM2.5 Reduction Water unpaved roads twice daily 55% 55%
Limit vehicle speeds on unpaved roads to 25 mph 44% 44% Sweep paved roads once per month 9% 9%

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 330,480 110,160 0.00 0.00 —

5.6. Dust Mitigation

5.6.1. Construction Earthmoving Activities
Phase Name Material Imported (Cubic
Yards)
Material Exported (Cubic
Yards)
Acres Graded (acres) Material Demolished (sq. ft.) Acres Paved (acres) Demolition 0.00 0.00 0.00 — —
Site Preparation 0.00 0.00 7.50 0.00 —
Grading 0.00 0.00 8.00 0.00 —
Paving 0.00 0.00 0.00 0.00 —

5.6.2. Construction Earthmoving Control Strategies
Control Strategies Applied Frequency (per day) PM10 Reduction PM2.5 Reduction Water Demolished Area 2 36% 36%

5.7. Construction Paving
Land Use Area Paved (acres) % Asphalt
Apartments Mid Rise — 0%
Exhibit C

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5.8. Construction Electricity Consumption and Emissions Factors kWh per Year and Emission Factor (lb/MWh)
Year kWh per Year CO2 CH4 N2O
2025 0.00 204 0.03 < 0.005
2026 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 Apartments Mid
Rise
925 835 695 320,887 3,029 2,734 2,277 1,050,889

5.10. Operational Area Sources

5.10.1. Hearths

5.10.1.1. Unmitigated
Hearth Type Unmitigated (number)
Apartments Mid Rise —
Wood Fireplaces 0
Gas Fireplaces 0
Propane Fireplaces 0
Electric Fireplaces 0
No Fireplaces 170
Conventional Wood Stoves 0
Catalytic Wood Stoves 0
Non-Catalytic Wood Stoves 0
Exhibit C

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Pellet Wood Stoves 0

5.10.2. Architectural Coatings
Residential Interior Area Coated (sq
ft)
Residential Exterior Area Coated (sq
ft)
Non-Residential Interior Area Coated
(sq ft)
Non-Residential Exterior Area
Coated (sq ft)
Parking Area Coated (sq ft)
330480 110,160 0.00 0.00 —

5.10.3. Landscape Equipment
Season Unit Value
Snow Days day/yr 0.00
Summer Days day/yr 330

5.11. Operational Energy Consumption

5.11.1. Unmitigated
Electricity (kWh/yr) and CO2 and CH4 and N2O and Natural Gas (kBTU/yr) Land Use Electricity (kWh/yr) CO2 CH4 N2O Natural Gas (kBTU/yr) Apartments Mid Rise 504,542 204 0.0330 0.0040 4,251,069

5.12. Operational Water and Wastewater Consumption

5.12.1. Unmitigated
Land Use Indoor Water (gal/year) Outdoor Water (gal/year) Apartments Mid Rise 5,137,740 0.00

5.13. Operational Waste Generation

5.13.1. Unmitigated
Exhibit C

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Land Use Waste (ton/year) Cogeneration (kWh/year)
Apartments Mid Rise 126 —

5.14. Operational Refrigeration and Air Conditioning Equipment

5.14.1. Unmitigated
Land Use Type Equipment Type Refrigerant GWP Quantity (kg) Operations Leak Rate Service Leak Rate Times Serviced Apartments Mid Rise Average room A/C &
Other residential A/C
and heat pumps
R-410A 2,088 < 0.005 2.50 2.50 10.0
Apartments Mid Rise Household
refrigerators and/or
freezers
R-134a 1,430 0.12 0.60 0.00 1.00

5.15. Operational Off-Road Equipment

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

5.16. Stationary Sources

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
Exhibit C

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Equipment Type Fuel Type

5.18. Vegetation

5.18.1. Land Use Change

5.18.1.1. Unmitigated
Vegetation Land Use Type Vegetation Soil Type Initial Acres Final Acres

5.18.1. Biomass Cover Type

5.18.1.1. Unmitigated
Biomass Cover Type Initial Acres Final Acres

5.18.2. Sequestration

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

8. User Changes to Default Data
Screen Justification
Construction: Off-Road Equipment Assuming default equipment with tier 2 engines Construction: Demolition Consistent with previous analysis Construction: Construction Phases Assume building overlap between building construction, architectural coating, and paving phases
Exhibit C

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2930 Ardmore Road Project (330 Dwelling Units Scenario) Custom 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

2.4. Operations Emissions Compared Against Thresholds

2.5. Operations Emissions by Sector, Unmitigated

3. Construction Emissions Details

3.1. Demolition (2025) - Unmitigated

3.3. Site Preparation (2025) - Unmitigated

3.5. Grading (2025) - Unmitigated

3.7. Building Construction (2025) - Unmitigated
Exhibit C

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3.9. Building Construction (2026) - Unmitigated

3.11. Paving (2026) - Unmitigated

3.13. Architectural Coating (2025) - Unmitigated

3.15. Architectural Coating (2026) - Unmitigated

4. Operations Emissions Details

4.1. Mobile Emissions by Land Use

4.1.1. Unmitigated

4.2. Energy

4.2.1. Electricity Emissions By Land Use - Unmitigated

4.2.3. Natural Gas Emissions By Land Use - Unmitigated

4.3. Area Emissions by Source

4.3.1. Unmitigated

4.4. Water Emissions by Land Use

4.4.1. Unmitigated

4.5. Waste Emissions by Land Use

4.5.1. Unmitigated

4.6. Refrigerant Emissions by Land Use

4.6.1. Unmitigated
Exhibit C

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4.7. Offroad Emissions By Equipment Type

4.7.1. Unmitigated

4.8. Stationary Emissions By Equipment Type

4.8.1. Unmitigated

4.9. User Defined Emissions By Equipment Type

4.9.1. Unmitigated

4.10. Soil Carbon Accumulation By Vegetation Type

4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated

4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated

4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated

5. Activity Data

5.1. Construction Schedule

5.2. Off-Road Equipment

5.2.1. Unmitigated

5.3. Construction Vehicles

5.3.1. Unmitigated

5.4. Vehicles

5.4.1. Construction Vehicle Control Strategies
Exhibit C

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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

5.10. Operational Area Sources

5.10.1. Hearths

5.10.1.1. Unmitigated

5.10.2. Architectural Coatings

5.10.3. Landscape Equipment

5.11. Operational Energy Consumption

5.11.1. Unmitigated

5.12. Operational Water and Wastewater Consumption

5.12.1. Unmitigated

5.13. Operational Waste Generation
Exhibit C

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5.13.1. Unmitigated

5.14. Operational Refrigeration and Air Conditioning Equipment

5.14.1. Unmitigated

5.15. Operational Off-Road Equipment

5.15.1. Unmitigated

5.16. Stationary Sources

5.16.1. Emergency Generators and Fire Pumps

5.16.2. Process Boilers

5.17. User Defined

5.18. Vegetation

5.18.1. Land Use Change

5.18.1.1. Unmitigated

5.18.1. Biomass Cover Type

5.18.1.1. Unmitigated

5.18.2. Sequestration

5.18.2.1. Unmitigated

8. User Changes to Default Data
Exhibit C

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1. Basic Project Information

1.1. Basic Project Information
Data Field Value
Project Name 2930 Ardmore Road Project (330 Dwelling Units Scenario) Construction Start Date 1/6/2025
Operational Year 2026
Lead Agency —
Land Use Scale Project/site
Analysis Level for Defaults County
Windspeed (m/s) 3.00
Precipitation (days) 24.6
Location 35.6421954541768, -120.65084092570058
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 2022.1.1.28

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
Apartments Mid
Rise
330 Dwelling Unit 8.68 316,800 0.00 — 792 —
Exhibit C

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

2. Emissions Summary

2.1. Construction Emissions Compared Against Thresholds Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Un/Mit. ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — —
Unmit. 88.7 13.2 23.9 0.03 0.47 1.84 2.31 0.43 0.44 0.87 — 5,062 5,062 0.24 0.21 5,141 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — —
Unmit. 88.6 31.7 30.7 0.05 1.37 19.8 21.1 1.26 10.1 11.4 — 5,398 5,398 0.22 0.21 5,417 Average
Daily
(Max)
— — — — — — — — — — — — — — — —
Unmit. 18.6 9.70 15.3 0.02 0.36 1.42 1.78 0.33 0.45 0.78 — 3,207 3,207 0.13 0.13 3,251 Annual
(Max)
— — — — — — — — — — — — — — — —
Unmit. 3.39 1.77 2.78 < 0.005 0.07 0.26 0.33 0.06 0.08 0.14 — 531 531 0.02 0.02 538

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 BCO2 NBCO2 CO2T CH4 N2O CO2e Daily -
Summer
(Max)
— — — — — — — — — — — — — — — —
2025 88.7 13.2 23.9 0.03 0.47 1.84 2.31 0.43 0.44 0.87 — 5,062 5,062 0.24 0.21 5,141 Exhibit C

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Daily -
Winter
(Max)
— — — — — — — — — — — — — — — —
2025 88.6 31.7 30.7 0.05 1.37 19.8 21.1 1.26 10.1 11.4 — 5,398 5,398 0.22 0.21 5,417 2026 88.5 12.6 23.1 0.03 0.41 1.84 2.25 0.38 0.44 0.82 — 4,945 4,945 0.20 0.21 5,012 Average
Daily
— — — — — — — — — — — — — — — —
2025 18.6 9.70 15.3 0.02 0.36 1.42 1.78 0.33 0.45 0.78 — 3,207 3,207 0.13 0.13 3,251 2026 9.90 0.69 1.23 < 0.005 0.02 0.07 0.10 0.02 0.02 0.04 — 225 225 0.01 0.01 228 Annual — — — — — — — — — — — — — — — —
2025 3.39 1.77 2.78 < 0.005 0.07 0.26 0.33 0.06 0.08 0.14 — 531 531 0.02 0.02 538 2026 1.81 0.13 0.22 < 0.005 < 0.005 0.01 0.02 < 0.005 < 0.005 0.01 — 37.3 37.3 < 0.005 < 0.005 37.7

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 BCO2 NBCO2 CO2T CH4 N2O CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — —
Unmit. 18.8 6.09 48.4 0.06 0.23 4.17 4.40 0.23 1.06 1.29 151 8,428 8,579 15.8 0.38 9,108 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — —
Unmit. 17.0 6.25 31.9 0.06 0.22 4.17 4.39 0.22 1.06 1.28 151 8,233 8,384 15.9 0.40 8,902 Average
Daily
(Max)
— — — — — — — — — — — — — — — —
Unmit. 18.1 6.15 46.3 0.06 0.23 3.90 4.13 0.22 0.99 1.21 151 8,052 8,203 15.9 0.38 8,721 Annual
(Max)
— — — — — — — — — — — — — — — —
Unmit. 3.30 1.12 8.45 0.01 0.04 0.71 0.75 0.04 0.18 0.22 24.9 1,333 1,358 2.63 0.06 1,444 Exhibit C

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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 BCO2 NBCO2 CO2T CH4 N2O CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — —
Mobile 7.56 3.82 28.8 0.05 0.06 4.17 4.22 0.05 1.06 1.11 — 5,156 5,156 0.41 0.31 5,278 Area 11.2 0.18 18.7 < 0.005 0.01 — 0.01 0.01 — 0.01 0.00 50.1 50.1 < 0.005 < 0.005 50.2 Energy 0.12 2.08 0.89 0.01 0.17 — 0.17 0.17 — 0.17 — 3,192 3,192 0.32 0.02 3,205 Water — — — — — — — — — — 19.1 30.2 49.3 1.96 0.05 112
Waste — — — — — — — — — — 132 0.00 132 13.1 0.00 460
Refrig. — — — — — — — — — — — — — — — 2.27
Total 18.8 6.09 48.4 0.06 0.23 4.17 4.40 0.23 1.06 1.29 151 8,428 8,579 15.8 0.38 9,108 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — —
Mobile 7.37 4.17 31.0 0.05 0.06 4.17 4.22 0.05 1.06 1.11 — 5,011 5,011 0.46 0.33 5,122 Area 9.50 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Energy 0.12 2.08 0.89 0.01 0.17 — 0.17 0.17 — 0.17 — 3,192 3,192 0.32 0.02 3,205 Water — — — — — — — — — — 19.1 30.2 49.3 1.96 0.05 112
Waste — — — — — — — — — — 132 0.00 132 13.1 0.00 460
Refrig. — — — — — — — — — — — — — — — 2.27
Total 17.0 6.25 31.9 0.06 0.22 4.17 4.39 0.22 1.06 1.28 151 8,233 8,384 15.9 0.40 8,902 Average
Daily
— — — — — — — — — — — — — — — —
Mobile 6.96 3.90 28.5 0.05 0.05 3.90 3.95 0.05 0.99 1.04 — 4,785 4,785 0.42 0.31 4,896 Area 11.0 0.16 16.9 < 0.005 0.01 — 0.01 0.01 — 0.01 0.00 45.3 45.3 < 0.005 < 0.005 45.4 Energy 0.12 2.08 0.89 0.01 0.17 — 0.17 0.17 — 0.17 — 3,192 3,192 0.32 0.02 3,205 Water — — — — — — — — — — 19.1 30.2 49.3 1.96 0.05 112
Waste — — — — — — — — — — 132 0.00 132 13.1 0.00 460
Exhibit C

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Refrig. — — — — — — — — — — — — — — — 2.27
Total 18.1 6.15 46.3 0.06 0.23 3.90 4.13 0.22 0.99 1.21 151 8,052 8,203 15.9 0.38 8,721 Annual — — — — — — — — — — — — — — — —
Mobile 1.27 0.71 5.20 0.01 0.01 0.71 0.72 0.01 0.18 0.19 — 792 792 0.07 0.05 811 Area 2.01 0.03 3.09 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 0.00 7.49 7.49 < 0.005 < 0.005 7.52 Energy 0.02 0.38 0.16 < 0.005 0.03 — 0.03 0.03 — 0.03 — 528 528 0.05 < 0.005 531 Water — — — — — — — — — — 3.16 4.99 8.16 0.33 0.01 18.6 Waste — — — — — — — — — — 21.8 0.00 21.8 2.18 0.00 76.2 Refrig. — — — — — — — — — — — — — — — 0.38
Total 3.30 1.12 8.45 0.01 0.04 0.71 0.75 0.04 0.18 0.22 24.9 1,333 1,358 2.63 0.06 1,444

3. Construction Emissions Details

2.40 22.2 19.9 0.03 0.92 — 0.92 0.84 — 0.84 — 3,425 3,425 0.14 0.03 3,437 Demolitio
n
— — — — — 0.00 0.00 — 0.00 0.00 — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — —
Exhibit C

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Off-Road
Equipment

0.13 1.22 1.09 < 0.005 0.05 — 0.05 0.05 — 0.05 — 188 188 0.01 < 0.005 188 Demolitio
n
— — — — — 0.00 0.00 — 0.00 0.00 — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.02 0.22 0.20 < 0.005 0.01 — 0.01 0.01 — 0.01 — 31.1 31.1 < 0.005 < 0.005 31.2 Demolitio
n
— — — — — 0.00 0.00 — 0.00 0.00 — — — — — —
Onsite
truck

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3.31 31.6 30.2 0.05 1.37 — 1.37 1.26 — 1.26 — 5,295 5,295 0.21 0.04 5,314 Dust
From
Material
Movement
— — — — — 19.7 19.7 — 10.1 10.1 — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — —
Off-Road
Equipment

0.05 0.43 0.41 < 0.005 0.02 — 0.02 0.02 — 0.02 — 72.5 72.5 < 0.005 < 0.005 72.8 Dust
From
Material
Movement
— — — — — 0.27 0.27 — 0.14 0.14 — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — —
Off-Road
Equipment

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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 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — —
Worker 0.07 0.05 0.56 0.00 0.00 0.10 0.10 0.00 0.02 0.02 — 102 102 < 0.005 < 0.005 104 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 1.41 1.41 < 0.005 < 0.005 1.43 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.23 0.23 < 0.005 < 0.005 0.24 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00

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Off-Road
Equipment

1.74 16.3 17.9 0.03 0.72 — 0.72 0.66 — 0.66 — 2,959 2,959 0.12 0.02 2,970 Dust
From
Material
Movement
— — — — — 7.08 7.08 — 3.42 3.42 — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — —
Off-Road
Equipment

0.04 0.36 0.39 < 0.005 0.02 — 0.02 0.01 — 0.01 — 64.9 64.9 < 0.005 < 0.005 65.1 Dust
From
Material
Movement
— — — — — 0.16 0.16 — 0.08 0.08 — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — —
Off-Road
Equipment

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Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 1.93 1.93 < 0.005 < 0.005 1.97 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.32 0.32 < 0.005 < 0.005 0.33 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00

1.13 10.4 13.0 0.02 0.43 — 0.43 0.40 — 0.40 — 2,398 2,398 0.10 0.02 2,406 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — —
Off-Road
Equipment

1.13 10.4 13.0 0.02 0.43 — 0.43 0.40 — 0.40 — 2,398 2,398 0.10 0.02 2,406 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — —
Exhibit C

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Off-Road 0.69 6.36 7.94 0.01 0.26 — 0.26 0.24 — 0.24 — 1,459 1,459 0.06 0.01 1,464 Equipment
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.13 1.16 1.45 < 0.005 0.05 — 0.05 0.04 — 0.04 — 242 242 0.01 < 0.005 242 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — —
Worker 0.96 0.61 7.74 0.00 0.00 1.36 1.36 0.00 0.32 0.32 — 1,448 1,448 0.09 0.06 1,475 Vendor 0.03 1.16 0.47 0.01 0.01 0.20 0.21 0.01 0.06 0.07 — 793 793 0.03 0.12 830 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — —
Worker 0.95 0.68 7.57 0.00 0.00 1.36 1.36 0.00 0.32 0.32 — 1,388 1,388 0.06 0.06 1,409 Vendor 0.03 1.19 0.48 0.01 0.01 0.20 0.21 0.01 0.06 0.07 — 793 793 0.03 0.12 829 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — —
Worker 0.57 0.41 4.57 0.00 0.00 0.81 0.81 0.00 0.19 0.19 — 851 851 0.04 0.04 865 Vendor 0.02 0.73 0.29 < 0.005 0.01 0.12 0.13 0.01 0.03 0.04 — 482 482 0.02 0.07 505 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — —
Worker 0.10 0.07 0.83 0.00 0.00 0.15 0.15 0.00 0.03 0.03 — 141 141 0.01 0.01 143 Vendor < 0.005 0.13 0.05 < 0.005 < 0.005 0.02 0.02 < 0.005 0.01 0.01 — 79.9 79.9 < 0.005 0.01 83.6 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Exhibit C

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1.07 9.85 13.0 0.02 0.38 — 0.38 0.35 — 0.35 — 2,397 2,397 0.10 0.02 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 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — —
Off-Road
Equipment

0.03 0.23 0.30 < 0.005 0.01 — 0.01 0.01 — 0.01 — 56.3 56.3 < 0.005 < 0.005 56.5 Onsite
truck

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Vendor 0.02 1.14 0.45 0.01 0.01 0.20 0.21 0.01 0.06 0.07 — 778 778 0.03 0.11 813 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — —
Worker 0.02 0.01 0.16 0.00 0.00 0.03 0.03 0.00 0.01 0.01 — 32.2 32.2 < 0.005 < 0.005 32.8 Vendor < 0.005 0.03 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 18.3 18.3 < 0.005 < 0.005 19.1 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 0.03 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 — 5.34 5.34 < 0.005 < 0.005 5.42 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 3.03 3.03 < 0.005 < 0.005 3.16 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00

0.68 6.23 8.81 0.01 0.26 — 0.26 0.24 — 0.24 — 1,350 1,350 0.05 0.01 1,355 Paving 0.00 — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — —
Off-Road
Equipment

0.03 0.31 0.43 < 0.005 0.01 — 0.01 0.01 — 0.01 — 66.6 66.6 < 0.005 < 0.005 66.8 Exhibit C

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Paving 0.00 — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.01 0.06 0.08 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 11.0 11.0 < 0.005 < 0.005 11.1 Paving 0.00 — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — —
Worker 0.08 0.05 0.60 0.00 0.00 0.11 0.11 0.00 0.03 0.03 — 115 115 < 0.005 0.01 116 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 0.03 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 — 5.70 5.70 < 0.005 < 0.005 5.79 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.94 0.94 < 0.005 < 0.005 0.96 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00

3.13. Architectural Coating (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Exhibit C

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Location ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O CO2e Onsite — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — —
Off-Road
Equipment

0.13 0.88 1.14 < 0.005 0.03 — 0.03 0.03 — 0.03 — 134 134 0.01 < 0.005 134 Architect
ural
Coatings

86.2 — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — —
Off-Road
Equipment

0.13 0.88 1.14 < 0.005 0.03 — 0.03 0.03 — 0.03 — 134 134 0.01 < 0.005 134 Architect
ural
Coatings

86.2 — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — —
Off-Road
Equipment

0.03 0.17 0.23 < 0.005 0.01 — 0.01 < 0.005 — < 0.005 — 26.4 26.4 < 0.005 < 0.005 26.5 Architect
ural
Coatings

17.0 — — — — — — — — — — — — — — —
Onsite
truck

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Architect 3.11 — — — — — — — — — — — — — — —
ural
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — —
Worker 0.19 0.12 1.55 0.00 0.00 0.27 0.27 0.00 0.06 0.06 — 290 290 0.02 0.01 295 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — —
Worker 0.19 0.14 1.51 0.00 0.00 0.27 0.27 0.00 0.06 0.06 — 278 278 0.01 0.01 282 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — —
Worker 0.04 0.03 0.30 0.00 0.00 0.05 0.05 0.00 0.01 0.01 — 55.3 55.3 < 0.005 < 0.005 56.2 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — —
Worker 0.01 < 0.005 0.05 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 — 9.15 9.15 < 0.005 < 0.005 9.30 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00

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Daily,
Summer
(Max)
— — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — —
Off-Road
Equipment

0.12 0.86 1.13 < 0.005 0.02 — 0.02 0.02 — 0.02 — 134 134 0.01 < 0.005 134 Architect
ural
Coatings

86.2 — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — —
Off-Road
Equipment

0.01 0.10 0.13 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 15.2 15.2 < 0.005 < 0.005 15.2 Architect
ural
Coatings

9.79 — — — — — — — — — — — — — — —
Onsite
truck

1.79 — — — — — — — — — — — — — — —
Onsite
truck

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Daily, — — — — — — — — — — — — — — — —
Winter
(Max)
Worker 0.18 0.13 1.42 0.00 0.00 0.27 0.27 0.00 0.06 0.06 — 273 273 0.01 0.01 277 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — —
Worker 0.02 0.01 0.16 0.00 0.00 0.03 0.03 0.00 0.01 0.01 — 31.2 31.2 < 0.005 < 0.005 31.7 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 0.03 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 — 5.16 5.16 < 0.005 < 0.005 5.24 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00

4. Operations Emissions Details

4.1. Mobile Emissions by Land Use

7.56 3.82 28.8 0.05 0.06 4.17 4.22 0.05 1.06 1.11 — 5,156 5,156 0.41 0.31 5,278 Total 7.56 3.82 28.8 0.05 0.06 4.17 4.22 0.05 1.06 1.11 — 5,156 5,156 0.41 0.31 5,278 Exhibit C

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Daily, — — — — — — — — — — — — — — — —
Winter
(Max)
Apartmen
ts
Mid Rise

7.37 4.17 31.0 0.05 0.06 4.17 4.22 0.05 1.06 1.11 — 5,011 5,011 0.46 0.33 5,122 Total 7.37 4.17 31.0 0.05 0.06 4.17 4.22 0.05 1.06 1.11 — 5,011 5,011 0.46 0.33 5,122 Annual — — — — — — — — — — — — — — — —
Apartmen
ts
Mid Rise

1.27 0.71 5.20 0.01 0.01 0.71 0.72 0.01 0.18 0.19 — 792 792 0.07 0.05 811 Total 1.27 0.71 5.20 0.01 0.01 0.71 0.72 0.01 0.18 0.19 — 792 792 0.07 0.05 811

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 BCO2 NBCO2 CO2T CH4 N2O CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — —
Apartmen
ts
Mid Rise
— — — — — — — — — — — 547 547 0.09 0.01 553
Total — — — — — — — — — — — 547 547 0.09 0.01 553
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — —
Apartmen
ts
Mid Rise
— — — — — — — — — — — 547 547 0.09 0.01 553
Total — — — — — — — — — — — 547 547 0.09 0.01 553
Annual — — — — — — — — — — — — — — — —
Exhibit C

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Apartmen — — — — — — — — — — — 90.6 90.6 0.01 < 0.005 91.5 ts
Total — — — — — — — — — — — 90.6 90.6 0.01 < 0.005 91.5

0.12 2.08 0.89 0.01 0.17 — 0.17 0.17 — 0.17 — 2,645 2,645 0.23 < 0.005 2,652 Total 0.12 2.08 0.89 0.01 0.17 — 0.17 0.17 — 0.17 — 2,645 2,645 0.23 < 0.005 2,652 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — —
Apartmen
ts
Mid Rise

0.12 2.08 0.89 0.01 0.17 — 0.17 0.17 — 0.17 — 2,645 2,645 0.23 < 0.005 2,652 Total 0.12 2.08 0.89 0.01 0.17 — 0.17 0.17 — 0.17 — 2,645 2,645 0.23 < 0.005 2,652 Annual — — — — — — — — — — — — — — — —
Apartmen
ts
Mid Rise

0.02 0.38 0.16 < 0.005 0.03 — 0.03 0.03 — 0.03 — 438 438 0.04 < 0.005 439 Total 0.02 0.38 0.16 < 0.005 0.03 — 0.03 0.03 — 0.03 — 438 438 0.04 < 0.005 439

4.3. Area Emissions by Source

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Daily,
Summer
(Max)
— — — — — — — — — — — — — — — —
Hearths 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Consume
r
Products

6.78 — — — — — — — — — — — — — — —
Architect
ural
Coatings

2.72 — — — — — — — — — — — — — — —
Landscap
e
Equipme
nt

1.66 0.18 18.7 < 0.005 0.01 — 0.01 0.01 — 0.01 — 50.1 50.1 < 0.005 < 0.005 50.2 Total 11.2 0.18 18.7 < 0.005 0.01 — 0.01 0.01 — 0.01 0.00 50.1 50.1 < 0.005 < 0.005 50.2 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — —
Hearths 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Consume
r
Products

6.78 — — — — — — — — — — — — — — —
Architect
ural
Coatings

2.72 — — — — — — — — — — — — — — —
Total 9.50 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — —
Hearths 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Consume
r
Products

1.24 — — — — — — — — — — — — — — —
Architect
ural
Coatings

0.50 — — — — — — — — — — — — — — —
Exhibit C

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Landscap 0.27 0.03 3.09 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 7.49 7.49 < 0.005 < 0.005 7.52 e
Equipme
Total 2.01 0.03 3.09 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 0.00 7.49 7.49 < 0.005 < 0.005 7.52

4.4. Water Emissions by Land Use

4.4.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — —
Apartmen
ts
Mid Rise
— — — — — — — — — — 19.1 30.2 49.3 1.96 0.05 112
Total — — — — — — — — — — 19.1 30.2 49.3 1.96 0.05 112
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — —
Apartmen
ts
Mid Rise
— — — — — — — — — — 19.1 30.2 49.3 1.96 0.05 112
Total — — — — — — — — — — 19.1 30.2 49.3 1.96 0.05 112
Annual — — — — — — — — — — — — — — — —
Apartmen
ts
Mid Rise
— — — — — — — — — — 3.16 4.99 8.16 0.33 0.01 18.6
Total — — — — — — — — — — 3.16 4.99 8.16 0.33 0.01 18.6

4.5. Waste Emissions by Land Use

4.5.1. Unmitigated
Exhibit C

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2930 Ardmore Road Project (330 Dwelling Units Scenario) Custom Report, 9/24/2024 28 / 40
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 BCO2 NBCO2 CO2T CH4 N2O CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — —
Apartmen
ts
Mid Rise
— — — — — — — — — — 132 0.00 132 13.1 0.00 460
Total — — — — — — — — — — 132 0.00 132 13.1 0.00 460
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — —
Apartmen
ts
Mid Rise
— — — — — — — — — — 132 0.00 132 13.1 0.00 460
Total — — — — — — — — — — 132 0.00 132 13.1 0.00 460
Annual — — — — — — — — — — — — — — — —
Apartmen
ts
Mid Rise
— — — — — — — — — — 21.8 0.00 21.8 2.18 0.00 76.2
Total — — — — — — — — — — 21.8 0.00 21.8 2.18 0.00 76.2

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 BCO2 NBCO2 CO2T CH4 N2O CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — —
Apartmen
ts
Mid Rise
— — — — — — — — — — — — — — — 2.27
Total — — — — — — — — — — — — — — — 2.27
Exhibit C

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2930 Ardmore Road Project (330 Dwelling Units Scenario) Custom Report, 9/24/2024 29 / 40
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — —
Apartmen
ts
Mid Rise
— — — — — — — — — — — — — — — 2.27
Total — — — — — — — — — — — — — — — 2.27
Annual — — — — — — — — — — — — — — — —
Apartmen
ts
Mid Rise
— — — — — — — — — — — — — — — 0.38
Total — — — — — — — — — — — — — — — 0.38

4.7. Offroad Emissions By Equipment Type

4.8. Stationary Emissions By Equipment Type
Exhibit C

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2930 Ardmore Road Project (330 Dwelling Units Scenario) Custom Report, 9/24/2024 30 / 40

4.9. User Defined Emissions By Equipment Type

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2930 Ardmore Road Project (330 Dwelling Units Scenario) Custom Report, 9/24/2024 31 / 40
Total — — — — — — — — — — — — — — — —

4.10. Soil Carbon Accumulation By Vegetation Type

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2930 Ardmore Road Project (330 Dwelling Units Scenario) Custom Report, 9/24/2024 32 / 40
Total — — — — — — — — — — — — — — — —

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2930 Ardmore Road Project (330 Dwelling Units Scenario) Custom Report, 9/24/2024 33 / 40
Sequeste — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — —
Removed — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — —
— — — — — — — — — — — — — — — — —

5. Activity Data

5.2. Off-Road Equipment

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2930 Ardmore Road Project (330 Dwelling Units Scenario) Custom Report, 9/24/2024 34 / 40
Grading Excavators Diesel Average 1.00 8.00 36.0 0.38
Grading Graders Diesel Average 1.00 8.00 148 0.41
Grading Rubber Tired Dozers Diesel Average 1.00 8.00 367 0.40 Grading 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 Cement and Mortar
Mixers
Diesel Average 2.00 6.00 10.0 0.56
Paving Pavers Diesel Average 1.00 8.00 81.0 0.42
Paving Paving Equipment Diesel Average 2.00 6.00 89.0 0.36 Paving Rollers Diesel Average 2.00 6.00 36.0 0.38
Paving Tractors/Loaders/Back
hoes
Diesel Average 1.00 8.00 84.0 0.37
Architectural Coating Air Compressors Diesel Average 1.00 6.00 37.0 0.48

5.3. Construction Vehicles

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2930 Ardmore Road Project (330 Dwelling Units Scenario) Custom Report, 9/24/2024 35 / 40
Site Preparation Worker 17.5 8.10 LDA,LDT1,LDT2
Site Preparation Vendor — 6.90 HHDT,MHDT
Site Preparation Hauling 0.00 20.0 HHDT
Site Preparation Onsite truck — — HHDT
Grading — — — —
Grading Worker 15.0 8.10 LDA,LDT1,LDT2
Grading Vendor — 6.90 HHDT,MHDT
Grading Hauling 0.00 20.0 HHDT
Grading Onsite truck — — HHDT
Building Construction — — — —
Building Construction Worker 238 8.10 LDA,LDT1,LDT2
Building Construction Vendor 35.3 6.90 HHDT,MHDT
Building Construction Hauling 0.00 20.0 HHDT
Building Construction Onsite truck — — HHDT
Paving — — — —
Paving Worker 20.0 8.10 LDA,LDT1,LDT2
Paving Vendor — 6.90 HHDT,MHDT
Paving Hauling 0.00 20.0 HHDT
Paving Onsite truck — — HHDT
Architectural Coating — — — —
Architectural Coating Worker 47.5 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
Exhibit C

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2930 Ardmore Road Project (330 Dwelling Units Scenario) Custom Report, 9/24/2024 36 / 40
Control Strategies Applied PM10 Reduction PM2.5 Reduction Water unpaved roads twice daily 55% 55%
Limit vehicle speeds on unpaved roads to 25 mph 44% 44% Sweep paved roads once per month 9% 9%

5.6. Dust Mitigation

5.6.2. Construction Earthmoving Control Strategies
Control Strategies Applied Frequency (per day) PM10 Reduction PM2.5 Reduction Water Demolished Area 2 36% 36%

5.7. Construction Paving
Land Use Area Paved (acres) % Asphalt
Apartments Mid Rise — 0%
Exhibit C

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2930 Ardmore Road Project (330 Dwelling Units Scenario) Custom Report, 9/24/2024 37 / 40

5.8. Construction Electricity Consumption and Emissions Factors kWh per Year and Emission Factor (lb/MWh)
Year kWh per Year CO2 CH4 N2O
2025 0.00 204 0.03 < 0.005
2026 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 Apartments Mid
Rise
1,795 1,620 1,350 622,899 5,879 5,306 4,420 2,039,961

5.10. Operational Area Sources

5.10.1. Hearths

5.10.1.1. Unmitigated
Hearth Type Unmitigated (number)
Apartments Mid Rise —
Wood Fireplaces 0
Gas Fireplaces 0
Propane Fireplaces 0
Electric Fireplaces 0
No Fireplaces 330
Conventional Wood Stoves 0
Catalytic Wood Stoves 0
Non-Catalytic Wood Stoves 0
Exhibit C

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2930 Ardmore Road Project (330 Dwelling Units Scenario) Custom Report, 9/24/2024 38 / 40
Pellet Wood Stoves 0

5.10.3. Landscape Equipment
Season Unit Value
Snow Days day/yr 0.00
Summer Days day/yr 330

5.11. Operational Energy Consumption

5.11.1. Unmitigated
Electricity (kWh/yr) and CO2 and CH4 and N2O and Natural Gas (kBTU/yr) Land Use Electricity (kWh/yr) CO2 CH4 N2O Natural Gas (kBTU/yr) Apartments Mid Rise 979,406 204 0.0330 0.0040 8,252,074

5.12. Operational Water and Wastewater Consumption

5.12.1. Unmitigated
Land Use Indoor Water (gal/year) Outdoor Water (gal/year) Apartments Mid Rise 9,973,260 0.00

5.13. Operational Waste Generation

5.13.1. Unmitigated
Exhibit C

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2930 Ardmore Road Project (330 Dwelling Units Scenario) Custom Report, 9/24/2024 39 / 40
Land Use Waste (ton/year) Cogeneration (kWh/year)
Apartments Mid Rise 244 —

5.14. Operational Refrigeration and Air Conditioning Equipment

5.15. Operational Off-Road Equipment

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

5.16. Stationary Sources

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
Exhibit C

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2930 Ardmore Road Project (330 Dwelling Units Scenario) Custom Report, 9/24/2024 40 / 40
Equipment Type Fuel Type

5.18. Vegetation

5.18.1. Land Use Change

5.18.1.1. Unmitigated
Vegetation Land Use Type Vegetation Soil Type Initial Acres Final Acres

5.18.1. Biomass Cover Type

5.18.1.1. Unmitigated
Biomass Cover Type Initial Acres Final Acres

5.18.2. Sequestration

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

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1343 Bishop Street, San Luis Obispo, CA 93401
Tel: 805 234 8760 - Email: [email protected] July 31, 2025 To: Michael Stoltey - MD3 Investments, 893 Marsh Street, San Luis Obispo, CA 93401 Mr. Stoltey,
Per your request, the following memo is an update of recommendations regarding two (2) native oaks at your Ardmore Project located at 2930 Union Road, in Paso Robles, California.

You recently communicated to me that your intended use of the property located at 2930 Union Road, in the city of Paso Robles has changed from light industrial to residential.

You have asked me to review the oak impact and tree protection report I prepared for you on October 19, 2022 and update my recommendations regarding Tree 3 due to its failure and Tree #13 based on the new intended use of the property. Further, you have requested that oak mitigation calculations be updated to be consistent with the new assessments and recommendations.

Tree Assessment Updates
Since my original report was submitted to you in October of 2022, Tree #3 has failed to internal decay and root rot that affected its structural integrity. In my original report, I noted that the tree had several decay cavities throughout the trunk as well as in one scaffold branch. My recommendation at the time was for the tree’s removal. Now that the tree has failed, this tree should be eliminated from the survey.

The failed tree should not count toward the oak tree mitigation replacement calculation since it is no longer alive or standing. See Appendix A- Photographs – Photo 7.

Review of data from the original assessment of Tree 13:

I performed an advanced inspection of the tree’s trunk integrity by employing the use of a Resistograph wood density measurement tool. The device measures the density of live wood and detects voids in the tree that are caused by decay.

I took 4 measurements of the wood density of the trunk at 3.5’ above ground and 1 measurement at approximately 1’ above ground. See below.
o Sample 1 – westside of tree. Outer shell thickness was 7” o Sample 2 – south side of tree. Outer shell thickness was 8.5” o Sample 3 – eastside of tree. Outer shell thickness was 8.5” o Sample 4 – eastside of tree at scarred area on eastside of trunk approximately 1’ above ground. Outer shell thickness was 12”.
o Sample 5 – north side of tree. Outer shell thickness was 5”.

The tree had a diameter of 42 inches. The outer shell, live wood thickness of the trunk measured by the Resistograph showed a substantial loss of internal wood that provides structure to the tree. Sample 5 was the thinnest sample measured at 3.5’ above ground.

Exhibit D

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2 At this location there was an approximate 77% radial loss of wood. Samples 2 and 3 were the thickest samples measured at 3.5’ above ground, at these locations there was an approximate 60% radial loss of wood. Essentially all that is left of the trunk is a hollow tube that is supporting multiple tons of canopy weight.

As the decay continues, the wood will lose more structural integrity. Combined with forces from high wind events during winter storms, the tree will be even more likely to fail.

In my report dated October 19, 2022, I concluded through a tree risk assessment, that the risk of Tree #13 failing at the trunk due to advanced internal decay was HIGH.

When the project was planned for light industrial, I asserted that the only way I felt comfortable recommending retention of the tree was to restrict access by installing a permanent fence around the tree at the limits of a tree protection zone. The idea was that once access was restricted, the risk rating could be reduced to Moderate.

Through negotiations with the city planning department, your team agreed that the tree would be retained, but only if a permanent fence were built at the limits of a tree protection zone to restrict access.

Furthermore, no buildings were to be constructed within the strike zone in the event the tree were to fail at the trunk.

The reason for the restriction wase to protect people from being in the strike zone of the tree if it were to fail.

The use of light industrial, likely gives access to the property and the tree for approximately 12 hours per day. The conversion of this property to residential will raise the potential access to the tree to 24 hours per day. People and especially young people are attracted to trees for shade and for recreation.

Although a fence could be built around the tree, I am not convinced the access would be restricted to a level high enough to protect the occupants of the proposed residential community.

I recommend to the City of Paso Robles planning department that Tree 13 be removed based on the risk of it failing and potentially severely injuring residents of the development.

See Appendix A Photographs – Photos 1-7 for photos of Tree 13 and for comparison, Trees 2 and 3.

Tree 2 had significant internal decay similar to Tree 13 and was approved for removal by the City Council due to internal decay and risk of failure as part of your original oak tree removal permit. Tree 3, addressed earlier in this memo, failed due to internal decay and root rot. This is an example of what to expect as Tree 13 continues to decay.

Mitigation Tree Replacement Updates
In light of the changes of use for this project and the failure of one tree, I have updated oak the tree mitigation calculations. As a review, I have included the City’s mitigation requirements below.

Exhibit D

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3 The City of Paso Robles requires replacements for any native oak removed that is 6-inches in diameter or greater. This requirement is at the discretion of the Director of Public Works. The following is excerpted from the city’s Oak Tree Ordinance 835 N.S.:

Replacement oaks being equivalent to twenty-five percent of the diameter of the removed tree(s). (For example, the replacement requirement for removal of two trees of fifteen-inch DBH (thirty total diameter inches), would be seven and one-half inches (thirty inches removed multiplied by twenty-five hundredths replacement factor).

This requirement could be satisfied by planting five, one and one-half inch caliper trees, or three, twoand one-half-inch caliper trees or any other combination totaling seven and one-half inches). A minimum of two, twenty-four-inch box, one and one-half inch minimum trunk caliper measurement trees shall be required for each oak tree removed.

Replacement trees shall be located on the same property as where the tree is approved for removal or, subject to approval of the director, arrangements can be made to locate the replacement trees on public property. Planting standards for replacement trees shall he consistent with City Standard Details and Specification L-4 except that deep root barriersshall not be required if the trees are not adjacentto sidewalk areas. Oak tree preservation and maintenance measures shall be consistent with the provisions of this chapter.

The combined diameter of the oak trees proposed for removal within your project is 265 inches.

Twenty-five percent of 265 inches is 67 inches. Therefore thirty-four (34) native oaks at 2-inch caliper would be required to be planted on the premises or somewhere in the city if approved by the Public Works Director’s. See table below for replacement calculations.

Tree # DBH Recommendation
Tree 1 43” Remove
Tree 2 47” Remove
Tree 3 47” Dead (not included in calcs.)
Tree 4 52” Remove
Tree 9 51” Remove
Tree 10 51” Retain and Protect
Tree 11 30” Remove
Tree 13 42” Remove
Total inches proposed for
removal
265”
25% of 265” 67”
Tree replacements @ 2” caliper 34
Exhibit D

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4 Please feel free to contact me with any questions.

Thank you,
Rodney D. Thurman – Owner
ISA Board Certified Master Arborist PN-2684BUM
ISA Tree Risk Assessors Qualification
Appendices: Photographs
Appendix A – Photographs
Photo 1 – Tree 13 with view to northeast. Outwardly, the tree appears to be healthy but internal rot makes it structurally unstable.

Exhibit D

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5 Photo 2 – Tree 13 with root decay cavity on south side of tree indicated by arrow.

Exhibit D

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6 Photo 3 – Tree 13 with bulging root-crown indicating possible butt-rot.

Exhibit D

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7 Photo 4 – Tree 2 in 2022. Outwardly, the tree appears to be healthy but internal rot makes it structurally unstable.

Exhibit D

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8 #2
#1
Photo 5 – Tree 2 in 2022. View of interior decay cavity formed by failed scaffold. Arrow 1 shows depth of cavity down to roots of tree.

Arrow 2 shows decay that has advanced into eastern scaffold branch.

The tree has high potential to fail due to internal decay.

Exhibit D

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9 Photo 6 – Tree 3 in 2022. Outwardly, the tree appears to be moderately healthy but internal rot made it structurally unstable.

Exhibit D

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10 Photo 7 – Tree 3 – July 2025. The tree has died due to root rot and failed because of internal decay and root rot.

Exhibit D

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CALIFORNIA ENVIRONMENTAL QUALITY ACT

ENVIRONMENTAL INITIAL STUDY CHECKLIST FORM
Covelop
Public Review Period September 11, 2023 to October 10, 2023

1. PROJECT TITLE: Covelop
Entitlements: Planned Development PD 22-20, Conditional Use Permit 22-20 and Tentative Parcel Map PR
22-0054

2. LEAD AGENCY: City of Paso Robles
1000 Spring Street
Paso Robles, CA 93446
Contact Person: Darren Nash, City Planner
Phone Number: (805) 237-3970
Email: [email protected]

3. PROJECT LOCATION: 2930 Union Road, Paso Robles, CA
APN: 025-362-043

4. PROJECT PROPONENT: Covelop/MDF
Contact Person: Ian McCarville
Phone Number: (805) 461-5765
Email: [email protected]

5. GENERAL PLAN DESIGNATION: CS (Commercial Service)

6. ZONING: C3-PD (Commercial-Light Industrial, Planned
Development Overlay)

7. PROJECT DESCRIPTION:

The project consists of subdividing an existing 7.54-acre gross lot (Lot 6), into two parcels totaling 4.15 acres gross (Parcel A) and 3.39 acres gross (Parcel B). The site has a General Plan land use designation of Commercial Service (CS) and is zoned Commercial-Light industrial with a Planned Development Overlay (C3-PD). Site development will consist of six (6) buildings totaling 240,327 square feet of floor area across Lots 6 and 13, site access, circulation, drainage improvements, and the extension of Ardmore Road. Lot 13 will be developed with one large warehouse building consisting of 116,812 sq. ft. of warehouse space and 9,000 sq. ft. of office space. Parcels A and Parcel B will be developed with five (5) smaller buildings totaling 114,515 sq. ft. of building area that will consist of a mix of retail, manufacturing, winemaking, and storage uses. A retention basin is proposed at the northeastern corner of the site to capture surface runoff. The project will result in approximately 14 acres of site disturbance and +/-19,803 CY cut and +/- 43,612 CY fill. The project also includes the construction of 310 vehicle parking spaces, 16 motorcycle parking spaces, and 114,529 sq. ft. of landscaping. (See Site Plan, Attachment 3) Exhibit E

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The project is proposed to be implemented in two phases. Phase I will consist of the development of Lot 13, the construction of buildings 2, 3 and 4 and access, circulation, parking, retention basin, and landscaping on Lot 6 (“Parcel A”), and the construction of Ardmore Extension. Phase II will consist of buildings 5 & 6 (“Parcel B”) with the adjacent parking and site circulation improvements.

There are eight (8) existing native oak trees onsite, seven (7) of which are in poor or very poor condition and one (1) that is in good condition. The project proposes the removal of six (6) oak trees that are in poor or very poor condition. The two remaining trees are to be protected and preserved during construction. The City has an Oak Tree Preservation Ordinance which requires the City Council to authorize the removal of trees that are not clearly diseased or dying. This project will require the City Council to review the oak trees requested for removal.

8. Surrounding Land Uses and Setting: Briefly describe the project’s surroundings:

Existing uses on the project site consist of abandoned agricultural structures and a +/- 12 acres of horse pasture. The site is mostly flat with gently rolling slopes downwards from north to south to a nonjurisdictional swale running across the southern edge of the site. There are eight (8) existing native oak trees onsite, seven (7) of which are in poor or very poor condition and one (1) that is in good condition.

Native soils withing the project site are predominantly within the Arbuckle-San Ysidro Complex and the San Ysidro Loam.

Surrounding uses include Commercial/Light Industry zoned parcels to the north (residence, horse pasture), east (residences, animal raising), and west (Daniels Wood Land, Spurr/Case Pacific Construction/outdoor storage yard), and Residential Single Family and Residential Agriculture zoned parcels to the south (vacant, rangeland). The parcels to the south of the project area are within the boundary of the North Chandler Ranch Specific Plan. North Chandler Ranch was approved for 879 dwelling units, however, there are no current plans to start on this development. (See Vicinity Map, Attachment 2)

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

San Luis Obispo County Air Pollution Control District, Regional Water Quality Control Board

10. Have California Native American tribes traditionally and culturally affiliated with the project area requested consultation pursuant to Public Resources Code section 21080.3.1? If so, is there a plan for consultation that includes, for example, the determination of significance of impacts to tribal cultural resources, procedures regarding confidentiality, etc.? In accordance with AB 52, the City provided formal notification on April 11th, 2023 to the designated contact or tribal representative of traditionally and culturally affiliated California Native American tribes that have requested notice. At the time of publishing this report no consultation request has been received.

Exhibit E

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ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED:

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

Aesthetics Agriculture / Forestry Resources Air Quality Biological Resources Cultural Resources Energy
Geology/Soils Greenhouse Gas Emissions Hazards & Hazardous Materials
Hydrology/Water Quality Land Use / Planning Mineral Resources Noise Population / Housing Public Services
Recreation Transportation Tribal Cultural Resources
Utilities / Service Systems Wildfire Mandatory Findings of Significance
DETERMINATION (To be completed by the Lead Agency)
On the basis of this initial Discussion:

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

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

A MITIGATED NEGATIVE DECLARATION will be prepared.

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

I find that the proposed project MAY have a “potentially significant impact” or “potentially significant unless mitigated” impact on the environment, but at least one effect 1) has been adequately analyzed in an earlier document pursuant to applicable legal standards, and 2) has been addressed by mitigation measures based on the earlier analysis as described on attached sheets. An ENVIRONMENTAL IMPACT REPORT is required, but it must analyze only the effects that remain to be addressed.

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

September 8, 2023
Signature Date
Exhibit E

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EVALUATION OF ENVIRONMENTAL IMPACTS

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

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

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

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

5. Earlier analyses may be used where, pursuant to the tiering, program EIR, or other CEQA process, an effect has been adequately analyzed in an earlier EIR or negative declaration. Section 15063(c)(3)(D).

In this case, a brief discussion should identify the following:
a) Earlier Analyses Used. Identify and state where they are available for review. b) Impacts Adequately Addressed. Identify which effects from the above checklist were within the scope of and adequately analyzed in an earlier document pursuant to applicable legal standards, and state whether such effects were addressed by mitigation measures based on the earlier analysis. c) Mitigation Measures. For effects that are “Less than Significant with Mitigation Measures Incorporated,” describe the mitigation measures which were incorporated or refined from the earlier document and the extent to which they address site-specific conditions for the project.

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

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

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

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

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Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact Source
I. AESTHETICS. Except as provided in Public Resources Code Section 21099, would the project:
a) Have a substantial adverse effect on a scenic vista? Discussion: The site is located in an area where there are existing large acreage residential uses in an area of the City that is zoned for commercial and light-industrial uses (C3). In addition to the residential properties, there are existing adjacent industrial uses such as the Case Pacific and Dave Spurr construction office and outdoor storage yards. The Paso Robles School District bus maintenance yard is also located on Ardmore Road, at Golden Hill Road. The other surrounding properties consist of existing residences on C3 zoned land. The project site is not located on a scenic vista and does not include scenic resources, therefore there is no impact. b) Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway?
Discussion: The project will not substantially damage any scenic resources within a state scenic highway. The project proposesto remove 6 out of the 8 oak trees on the site as a result of the project Arborist concluding that the trees are in poor health, but none of these trees are located within or visible from a state scenic highway. Moreover, the City’s Oak Tree Preservation Ordinance allows for the City Council to approve the removal of oak trees in relation to a development project by making findings. The Arborist reports for the project indicate that the 6 oaks proposed for removal have health issues and need to be removed to prevent future hazard situations with the new proposed buildings. Based on the trees not being located within a scenic highway, and since the oaks would be removed in a manner consistent with the City Ordinance, including the requirement to plant mitigation trees at a rate of 25-percent of the diameter removed, the proposed project would result in a less than significant impact relating to this issue. c) Substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from publicly accessible vantage point). If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality?
Discussion: The project would not conflict with applicable zoning or other regulations governing scenic quality. This site is zoned C3-PD, and since it has PD Overlay Zoning, a development plan is required. In addition to the PD requirement, Section 21.13 of the Zoning Code requires a conditional use permit to be processed. The overlay zoning, along with the special conditions, is required to give the Planning Commission the opportunity to review land use proposals to ensure quality development is approved in this area of the City.

The proposed light industrial, warehouse project is the type of development anticipated in the C3-PD zoning district in this Ardmore Road area of the City. The project is designed in a manner that has high aesthetic quality and will not substantially degrade visual character from surrounding public views, therefore this project’s impacts to existing visual character and quality of public views is less than significant. d) Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area? Discussion: Standard conditions require that all new lighting be adequately shielded. A condition of approval requires Staff to review light fixtures for proper shielding prior to the issuance of a building permit. As a result, the proposed project would not create a new source of substantial light or glare which would adversely affect day or nighttime views in the area, and the proposed project’s potential impact relating to this issue would be less than significant.

Exhibit E

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Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact Source
II. AGRICULTURE AND FORESTRY RESOURCES. In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Dept. of Conservation as an optional model to use in assessing impacts on agriculture and farmland. In determining whether impacts to forest resources, including timberland, are significant environmental effects, lead agencies may refer to information compiled by the California Department of Forestry and Fire Protection regarding the state’s inventory of forest land, including the Forest and Range Assessment Project and the Forest Legacy Assessment project; and forest carbon measurement methodology provided in Forest Protocols adopted by the California Air Resources Board. Would the project:
a) Convert Prime Farmland, Unique Farmland, or
Farmland of Statewide Importance (Farmland), as
shown on the maps prepared pursuant to the Farmland
Mapping and Monitoring Program of the California
Resources Agency, to non-agricultural use?
Discussion: The project site is designated in the General Plan and is zoned on the City’s Zoning Map for commercial development. The property is not identified in the City General Plan, Conservation Element (Figure OS-1, Important Farmland) as having either prime or unique farmland of statewide importance. Therefore, the project would not result in impacts on converting prime or other significant soils to urban land uses.
b) Conflict with existing zoning for agricultural use, or a Williamson Act contract?
Discussion: The project would not conflict with zoning for agricultural use. The Project Site is not zoned for agriculture and is not under a Williamson Act Contract. Therefore, the project would not conflict with existing zoning for agricultural use or a Williamson Act contract and would result in no impact.
c) Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code
Section 12220(g)), timberland (as defined by Public
Resources Code Section 4526), or timberland zoned
Timberland Production (as defined by Government
Code Section 51104(g))?
d) Result in the loss of forest land or conversion of forest land to non-forest use?
Discussion (c-d): The project site is not zoned for forest land or timberland resources and only contains a few scattered Oak trees. Therefore, no impacts associated with forest land or timberland would occur with the implementation of the project. Additionally, the project site is an open field and contains no forest land. The project would not result in the removal or conversion of forest land; therefore, no impacts would occur.
e) Involve other changes in the existing environment
which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use or
conversion of forest land to non-forest use?
Discussion: The proposed project would not cause other changes in the environments that could indirectly result in the conversion of farmland to non-agricultural uses. The project site does not conflict with existing zoning either, as the site is not designated as farmland or forest land, nor is it surrounded by those uses. The development of this project will have no impact on agricultural or forest resources.

Exhibit E

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Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact Source
III. AIR QUALITY. Where available, the significance criteria established by the applicable air quality management district or air pollution control district may be relied upon to make the following determinations. Would the project:
a) Conflict with or obstruct implementation of the
applicable air quality plan?
Discussion (a): The San Luis Obispo County area is a non-attainment area for the State standards for ozone and suspended particulate matter.

The SLO County Air Pollution Control District (APCD) administers a permit system to ensure that stationary sources do not collectively create emissions which would cause local and state standards to be exceeded. The CEQA thresholds of significance established by the SLOAPCD are designed to meet the objectives of the Clean Air Plan and in doing so achieve attainment status with state standards.

The potential for future project development to create adverse air quality impacts falls generally into two categories: Short term and Long term impacts. Short term impacts are associated with the grading and development portion of a project where construction generates dust from grading and site preparation, and emissions from construction equipment, but the impacts end when construction is complete. Long term impacts are related to the ongoing operational characteristics of a project and are generally related to mobile sources (e.g., vehicle trips), energy sources (e.g., electricity and natural gas), and area sources (e.g., architectural coatings and the use of landscape maintenance equipment), related to the proposed project.

Short term impacts:

An Air Quality and GHG Analysis was prepared for the project by LSA (Attachment 7). Predicted maximum daily construction emissions for the proposed project are summarized in Table J (below). Construction generated emissions are short term and of temporary duration, lasting only as long as construction activities occur, but would be considered a significant air quality impact if the volume of pollutants exceeds the SLO APCD’s thresholds of significance. The emission projections in Table J account for the conventional construction equipment that will be utilized during grading and construction activities. Additional sources of air pollutant emissions include emissions from on-road motor vehicles used to transport materials and personnel.

As identified in the Air Quality and GHG analysis, Table J Air Quality Construction Emissions demonstrate that although the activities would increase the emission of O3 precursor pollutants GOD and NOx, DPM, and fugitive dust, it would not exceed the thresholds of significance establish by the SLO APCD for the purposes of reducing air pollution and its deleterious health effects, and therefore not require mitigation. Based on the project not exceeding the established threshold, criteria pollutant emissions generated during project construction would not result in a cumulatively considerable net increase of any criteria pollutant for which the project region is nonattainment under an applicable federal or state ambient air quality standard.

Long term impacts:

Implementation of the project would result in long-term operational emissions of criteria air pollutants such as PM10, PM2.5, and CO as well as ozone precursors such as ROG and NOx. Project generated increases in emissions would be predominantly associated with motor vehicle use. Long-term operational emissions attributable to the project are identified in Table K (below) and are compared to the operational significance thresholds established by the SLO APCD. As shown in Table K, the Project’s emissions would not exceed any SLO APCD thresholds for any criteria air pollutants, therefore impacts would be less than significant.

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Based on the analysis presented above, the proposed project would not conflict with the 2001 Clean Air Plan and construction and operation of the proposed project would not result in the generation of criteria air pollutants that would exceed SLO County APCD thresholds of significance. The proposed project is not expected to produce significant emissions that would affect nearby sensitive receptors. The project would also not result in objectionable odors affecting a substantial number of people. GHG emissions released during construction and operation of the project are estimated to be lower than significance thresholds and would not be cumulatively considerable. The proposed project would generally be consistent with the State GHG reduction goals and the City’s CAP. 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 standard?
Discussion: As shown in Table K in Discussion A above, the emissions associated with the operations of the project would be well below the significance thresholds set by the SLO County APCD. Therefore, operation of the proposed project would not result in a cumulatively considerable net increase of any criteria pollutant for which the project region is in nonattainment under an applicable federal or State AAQS, resulting in no impact.
c) Expose sensitive receptors to substantial pollutant
concentrations?
Discussion: There are no sensitive receptors located within 1,000 feet of the project site. The project site is primarily surrounded by commercial and a few residential land uses. Therefore, it is not anticipated that sensitive receptors would be exposed to airborne particulates and construction equipment pollutants. In addition, project construction pollutant emissions would be below the SLO County APCD significance thresholds. Once the project is constructed, the project would not be a source of substantial pollutant emissions.

Therefore, impacts to sensitive receptors are less than significant. d) Result in other emissions (such as those leading to
odors) adversely affecting a substantial number of
people?
Discussion: During construction, the various diesel-powered vehicles and equipment in use on site would result in localized odors. These odors would be temporary and will not be noticeable for extended periods of time beyond the project site. Additionally, the proposed uses that would be developed within the project site are not expected to produce any offensive odors that would result in frequent odor complaints. Therefore, odor impacts from the project will be less than significant.

Exhibit E

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Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact Source
IV. BIOLOGICAL RESOURCES. Would the project:
a) Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service?
Discussion: The proposed project will not have a substantial adverse effect on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife (CDFW) or the U.S. Fish and Wildlife Service (USFWS). A Biological Resource Assessment (BRA) was prepared by David Wolff Environmental, LLC, dated July 24, 2023 (See Attachment 4). The BRA studied the 14-acre study area for biological resources. . The BRA concluded that there are no special status plant species within the project site. Additionally, no special status wildlife species or evidence of nesting birds was identified. The BRA did indicate that the project site may provide suitable habitat to support some special-status wildlife species, based on suitable habitat and regional (less than five miles) documented occurrences. These species include the San Joaquin Kit Fox (SJKF) and migratory nesting birds.

Based on the potential impacts to occur to special status biological resources, mitigation measures are included for this project. With incorporation of the following mitigation measures the projects impacts on Biological Resources will be less than significant.

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MM BIO-1: Vegetation removal and initial site disturbance shall be conducted between September 1 and January 31 outside of the nesting season for birds. If vegetation and/or tree removal is planned for the bird nesting season (February 1 to August 31), then preconstruction nesting bird surveys shall be conducted by a qualified biologist to determine if any active nests would be impacted by project construction. If no active nests are found, then no further mitigation shall be required.

If any active nests are found that would be impacted by construction, then the nest sites shall be avoided with the establishment of a nondisturbance buffer zone around active nests as determined by a qualified biologist. Nest sites shall be avoided and protected with the nondisturbance buffer zone until the adults and young of the year are no longer reliant on the nest site for survival as determined by a qualified biologist. As such, avoiding disturbance or take of an active nest would reduce potential impacts on nesting birds to a less-than-significant level.

MM BIO-2: To avoid direct take of SJKF during construction in accordance with the CDFW and San Luis Obispo County Guide to SJKF Mitigation Procedures Under CEQA, the project owner shall adopt the Standard Kit Fox CEQA Mitigation Measures and shall be included on development plans. The following measures shall be implemented:
• A maximum 25 mph speed limit shall be required at the project site during construction activities. • All construction activities shall cease at dusk and not start before dawn. • A qualified biologist shall be on-site immediately prior to initiation of project activities to inspect for any large burrows (e.g., known and potential dens) and to ensure no wildlife are injured during project activities. If dens are encountered, they should be avoided as discussed below.
• Exclusion zone boundaries shall be established around all known and potential SJKF dens. • All excavations deeper than 2 feet shall be completely covered at the end of each working day, or fitted with wildlife escape ramps. • All pipes, culverts, or similar structures shall be inspected for SJKF and other wildlife before burying, capping, or moving. • All exposed openings of pipes, culverts, or similar structures shall be capped or temporarily sealed prior to the end of each working day.
• All food-related trash shall be removed from the site at the end of each workday. • Project-related equipment shall be prohibited outside of designated work areas and access routes. • No firearms shall be allowed in the project area.
• Disturbance to burrows shall be avoided to the greatest extent feasible. • No rodenticides or herbicides should be applied in the project area. • Permanent fences between any remaining habitat areas shall allow for SJKF passage through or underneath (i.e., an approximate 4- inch passage gap shall remain at ground level).
• To avoid take of any SJKF and/or active SJKF dens, within 30 days prior to the initiation of site disturbance, implement the SJKF den survey and den closure protocol for unoccupied dens. Any SJKF occupied dens shall be avoided until the SJKF leave the den/site.
• Prior to issuance of grading and/or construction permit and within 30 days prior to initiation of site disturbance and/or construction, all personnel associated with the project shall attend a worker education training program, conducted by a qualified biologist, to avoid or reduce impacts on sensitive biological resources (i.e. San Joaquin kit fox). At a minimum, as the program relates to the kit fox, the training shall include the kit fox’s life history, all mitigation measures specified by the City, as well as any related biological report(s) prepared for the project. The applicant shall notify the City shortly prior to this meeting. A kit fox fact sheet shall also be developed prior to the training program, and distributed at the training program to all contractors, employers and other personnel involved with the construction of the project.
• During the site-disturbance and/or construction phase, any contractor or employee that inadvertently kills or injures a San Joaquin kit fox or who finds any such animal either dead, injured, or entrapped shall be required to report the incident immediately to the applicant and City. In the event that any observations are made of injured or dead kit fox, the applicant shall immediately notify the USFWS and CDFW by telephone. In addition, formal notification shall be provided in writing within three working days of the finding of any such animal(s). Notification shall include the date, time, location and circumstances of the incident. Any threatened or endangered species found dead or injured shall be turned over immediately to CDFW for care, analysis, or disposition.

Based on the findings described above establishing the existing conditions of biological resources within the project site, and incorporation of the recommended mitigation measures, implementation of the proposed project would not result in any substantial adverse effects on biological, botanical, or wetland habitat resources. Therefore, with mitigation measures incorporated into the project, direct and indirect project impacts on biological resources would be considered to be less than significant. b) Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the
California Department of Fish and Wildlife or U.S. Fish and Wildlife Service?
Discussion: A Biological Resource Assessment (BRA) was prepared for the project dated July 24, 2023. The BRA indicates that field surveys were conducted and concludes that no wetlands, water of the U.S./State or riparian habitat occur on the project site. Additionally, there were not any other sensitive natural communities are located on the site. Therefore, this project’s impacts on riparian and sensitive habitats are less than significant.

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c) Have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?
Discussion: The Biological Study indicates that there are two swale features observed onsite and were determined to not be subject to the Clean Water Act or California Fish and Game Code jurisdiction due to a lack of defined bed and bank structure. In addition, consultation with the RWQCB confirmed that similar to the Case Pacific project and Spurr project sites to the west, they would not regulate the swales as waters of the state pursuant to the Porter Cologne Act due to lack of wetland habitat and low beneficial uses. Therefore, this project’s impact on protected wetlands are less than significant.
d) Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with
established native resident or migratory wildlife
corridors, or impede the use of native wildlife nursery sites?
Discussion: The project will not substantially interfere with the movement of any native resident or migratory fish or wildlife species, nor will it substantially interfere with established native resident or migratory wildlife corridors. Furthermore, the project will not impede the use of native wildlife nursery sites. According to Figure 4.3-2 San Joaquin Kit Fox Mitigation Area (see Figure 6 of the BRA, Attachment 4), of the City of Paso Robles General Plan EIR, the project site is not located within the Kit Fox Mitigation Area and considered part of the developed portion of the City, therefore, compensatory mitigation is not required. e) Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
Discussion: There are eight oak trees on the site. The project proposes the removal of six oak trees, all of which are in poor or very poor condition. The two remaining oak trees (Tree No. 10 & 13) may have additional impacts associated with grading within the critical root zone and trimming for construction purposes. Oak tree removals approved as part of this project would be mitigated in accordance with the City Zoning Code, requiring replacement plantings on an inch for inch basis of 25% of the inches of diameter at breast height of the oak trees removed. Additionally, the project has been designed in a manner to protect the Tree No. 10 and 13 and protection measures such as protection fencing will be required as conditions of approval.

As a result of the trees being removed being in poor condition and mitigation oak trees will be planted on site as outlined in the City’s Oak Preservation Ordinance, this project impacts on oak trees will be less than significant. f) Conflict with the provisions of an adopted Habitat
Conservation Plan, Natural Community Conservation
Plan, or other approved local, regional, or state habitat conservation plan?
Discussion: There are no Habitat Conservation Plans or other related plans in the City of Paso Robles; therefore, no impact will occur.

Exhibit E

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Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact Source
V. CULTURAL RESOURCES. Would the project:
a) Cause a substantial adverse change in the significance of a historical resource pursuant to § 15064.5?
Discussion: The project will not result in a substantial adverse change in the significance of a historical resource; indeed, the project will not impact a historical resource at all. A Phase I Archaeological Study completed for the project did not identify any historic resources within the Project site; moreover, no historic resources were identified within the Project site during the pedestrian survey. Proposed Project impacts will not affect historic resources and no further historic study or monitoring is warranted. b) Cause a substantial adverse change in the significance of an archaeological resource pursuant to § 15064.5?
Discussion: The Phase I Archaeological Study prepared for the Project did not identify any cultural resources within the project site, and no cultural resources were identified within the project site during the pedestrian survey. Proposed project impacts will not affect cultural resources and no further archaeological study or monitoring is warranted.

Although the study did not identify any cultural resources, mitigation measure CUL-1 will require work to stop in the event that cultural materials are encountered during future ground disturbance. With the implementation of this mitigation measure, the project’s impacts related to archeological resource is less than significant with mitigation incorporated.

MM CUL-1 In the event that cultural resources including human remains are encountered during ground disturbance activity, the project shall stop all activity within a 100-foot radius of the find and the project archaeologist shall access the situation with the County Coroner to verify the next steps and determine when construction may resume. c) Disturb any human remains, including those interred
outside of dedicated cemeteries?
Discussion (c): A Phase I archeological survey was conducted by Padre Associates, Inc. of the project site on July 1, 2022. The field investigation identified no prehistoric materials or historic cultural resources within the project site. Located within an area characterized as low to moderate archaeological sensitivity, the existing landform has slightly been altered by an agricultural accessory structure and mainly used as pastureland for horses. The project area has excellent ground surface visibility, ranging from 60 to 95 percent, with discarded construction materials and oak detritus accounting for areas of reduced visibility.

Although the study did not identify any cultural resources including human remains, mitigation measure CUL-1 will require work to stop in the event that cultural materials including human remains are encountered during future ground disturbance, Padre recommends stopping all activity within a 100-foot radius of the find and contacting a County-qualified archaeologist, therefore this project impacts on human remain disturbance is less than significant with mitigation incorporated.

Exhibit E

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Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact Source
VI. ENERGY. Would the project:
a) Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or
operation?
1 Discussion: The proposed project is a commercial development, consistent with the City’s General Plan and does not require rezoning. The existing land use and proposed development will not use or promote the use of non-renewable resources in a wasteful and inefficient manner.

Further, the project is subject to air quality and energy efficiency requirements which are often referred to as Green Building Standards or the Building Energy Efficiency Standards, all of which are applicable standards to reduce inefficient, wasteful, or unnecessary consumption of energy. Therefore, impacts to energy resources are less than significant. b) Conflict with or obstruct a state or local plan for
renewable energy or energy efficiency?
1, 5
Discussion: The project would be required to be in full compliance with the California Building Code, including applicable green building standards and building energy efficiency standards. Furthermore, the City’s General Plan and Conservation Element ensures the conservation and preservation of energy resources by increasing the energy efficiency of buildings, appliances, and buildings to the use of alternative forms of energy. Additionally, the project would not exceed the Efficiency Threshold for operational emissions or operation emission plus the amortized constriction emissions, the Project would not conflict with the CAP, Updated Strategic Action Plan Update, or the City of Paso Robles Climate Action Plan (PRCAP). Therefore, impacts to this environmental factor are less than significant.

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

Discussion (a-i): The project would not cause potential substantial adverse effects relating to the rupture of a known earthquake fault, as addressed in the General Plan EIR, pg. 4.5-8. There are two known fault zones on either side of the Salinas River valley. The Rinconada Fault system runs on the west side of the valley and grazes the City on its western boundary. The San Andreas Fault is on the east side of the valley and is situated about 30 miles east of Paso Robles. The City of Paso Robles recognizes these geologic influences in the application of the California Building Code (CBC) to all new development within the city. Review of available information and examinations indicate that neither of these faults is active with respect to ground rupture in Paso Robles. Soils and geotechnical reports and structural engineering in accordance with local seismic influences would be applied in conjunction with any new development proposal. Based on standard conditions of approval, the potential for fault rupture and exposure of person or property to seismic hazards is not considered significant. There are no Alquist-Priolo Earthquake Fault Zones within City limits. ii) Strong seismic ground shaking? 1, 2, 3
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Discussion: The proposed project will be constructed to current CBC codes. The General Plan EIR identified impacts resulting from ground shaking as less than significant and provided mitigation measures that will be incorporated into the design of this project including adequate structural design and not constructing overactive or potentially active faults. Therefore, impacts that may result from seismic ground shaking are less than significant.
iii) Seismic-related ground failure, including
liquefaction?
1, 2, 3
Discussion: Per the General Plan EIR, the project site is located in an area with soil conditions that have a low potential for liquefaction or other type of ground failure due to seismic events and soil conditions. To implement the EIR’s mitigation measures to reduce this potential impact, the City has a standard condition to require submittal of soils and geotechnical reports, which include site-specific analysis of liquefaction potential for all building permits for new construction, and incorporation of the recommendations of said reports into the design of the project. The design of any structures on-site would incorporate measures to incorporate design measures into the project; therefore, impacts for seismic-related ground failure are less than significant. iv) Landslides? 1
Discussion: Per the General Plan Safety Element, the project site is in an area that is designated a low-risk area for landslides. Therefore, potential impacts due to landslides are less than significant. b) Result in substantial soil erosion or the loss of topsoil? 1, 2, 3 Discussion: Per the General Plan EIR the soil condition is not erosive or otherwise unstable. As such, no significant impacts are anticipated.

A geotechnical/soils analysis will be required prior to issuance of building permits that will evaluate the site-specific soil stability and suitability of the development proposed. This study will determine the necessary grading techniques that will ensure that potential impacts due to soil stability will not occur; therefore, impacts due to soil erosion or loss of topsoil. c) Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project,
and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction or collapse?
Discussion: See response to item VII.a.iii above.
d) Be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating
substantial direct or indirect risks to life or property? Discussion: See response to item VII.a.iii above.
e) Have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of
wastewater?
Discussion: The project does not propose to use septic tanks or alternative wastewater disposal systems; therefore, no impacts would occur.

No further analysis is warranted.
f) Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
Discussion: There are no known paleontological or unique geologic features identified on-site. If resources are found during grading activities, appropriate recommendations will be made regarding their treatment and/or disposition; therefore, this project will result in less than significant impacts on paleontological resources and/or unique geologic features.

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

Short term:

Construction-related activities that would generate GHG emissions include worker commute trips, haul trucks carrying supplies and materials to the project site, and off-road construction equipment. The SLO County APCD does not have an adopted threshold of significance for construction related emissions. It’s estimated that the proposed project would generate a total of approximately 1,875.0 metric tons of CO2E during construction. When amortized over the 30-year life the of project, annual emissions would be

62.5 metric tons of CO2e. Once construction is complete, the generation of these emissions will cease.

Long Term:

Operation of the project would result in GHG emissions predominantly associated with motor vehicle use Long-term operational GHG emissions attributable to the project as a whole are identified in Table L. Project operations are expected to generate 1,201.6 metric tons of CO2E emissions annually.

The project is compared with the SLO APCD efficiency-based threshold of 4.9 metric tons of CO2E per project service population per year. The SLO APCD’s approach is to identify the emissions level for which a project would not be expected to substantially conflict with existing California legislation adopted to reduce statewide GHG emissions. The project would emit 4.8 metric tons of CO2E per service population per year, which is below the SLO APCD threshold of 4.9 metric tons of CO2E per service population per year. Since the project would not exceed the Efficiency Threshold, the Project for operation emissions or operational emissions plus amortized construction emissions would not conflict with the CAP, Updated Strategic Action Plan, or the City of Paso Robles Climate Action Plan (PRCAP). Therefore, the project’s cumulative contribution of GHG emissions would be less than significant and the projects cumulative GHG impacts would be less than cumulatively considerable.

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b) Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of
greenhouse gases?
The following analysis evaluates the proposed project’s consistency with adopted plans to reduce GHG emissions.

As described above, the City adopted a CAP in November 2013. The consistency of the project with the goals of this CAP fulfills the CEQA goal of fully informing local-agency decision-makers of the environmental impact of the project under consideration at a stage early enough to ensure that GHG emissions are addressed. Although the CAP does not include a target for 2030, the measures in the plan will continue to provide reductions after the milestone year and help demonstrate continued progress toward achieving the SB 32 2030 target. The following CAP measures would be applicable to the proposed project:
• Measure E-4: Incentives for Exceeding Title 24 Energy Efficiency Building Standards • Measure E-5: Energy Efficient Public Realm Lighting Requirements • Measure E-6: Small-Scale On-Site Solar PV Incentive Program • Measure TL-5: Transport Demand Management Incentives
• Measure TL-6: Parking Supply Management
• Measure W-1: Exceed the SB X7-7 Water Conservation Target • Measure S-1: Solid Waste Diversion Rate
Future tenants of the project are unknown at this time, but they would implement transportation measures consistent with the CAP to reduce VMT. The proposed project would also be consistent with the CAP goal of increasing water and energy efficiency in new buildings by complying with the latest California Building Code (Title 24), including the latest CALGreen Code standards. In addition, the proposed project would comply with local and State laws regarding solar energy. Construction of the project would include a diversion of construction waste from landfills to recycling consistent with current local and State standards and CAP goals to increase diversion and reduction of waste. As such, the proposed project would be consistent with applicable CAP measures. Therefore, the proposed project would be consistent with applicable plans and programs designed to reduce GHG emissions. Therefore, the proposed project would not conflict with plans, policies, or regulations adopted for the purpose of reducing GHG emissions.

Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact Source
IX. HAZARDS AND HAZARDOUS MATERIALS. Would the project:
a) Create a significant hazard to the public or the
environment through the routine transport, use, or
disposal of hazardous materials?
Discussion: The proposed project does not include the routine transport, use or disposal of hazardous materials. Therefore, the project will not have an impact on this environmental factor.
b) Create a significant hazard to the public or the
environment through reasonably foreseeable upset and
accident conditions involving the release of hazardous
materials into the environment?
Discussion: The proposed project would not result in impacts from hazards and hazardous materials with respect to creating a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials, nor would it result in impacts from accidental release of materials into the environment. During construction, the proposed project would involve the transport of general construction materials. Construction activities would involve the use of fuels and greases for the construction equipment; however, the use, storage, transport, and disposal of these materials will be carried out in accordance with federal, state, and local laws, ordinances and regulations. Therefore, the project would have a less than significant impact on this environmental factor. c) Emit hazardous emissions or handle hazardous or
acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school?
Discussion: There are no existing or proposed schools located within ¼ mile of the project; therefore, there would be no impact of hazardous materials emission on local schools.

Exhibit E

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d) Be located on a site which is included on a list of
hazardous materials sites compiled pursuant to
Government Code § 65962.5 and, as a result, would it
create a significant hazard to the public or the
environment?
Discussion: The project site is not included on a hazardous materials site list; therefore, there is no impact from this project. e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two
miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area?
Discussion: The project is not located within an airport safety zone; therefore, there is no impact. f) Impair implementation of or physically interfere with an adopted emergency response plan or emergency
evacuation plan?
Discussion: The City does not have any adopted emergency response plans. As proposed, the development would not interfere with emergency response, therefore there is not impact.
g) Expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires?
Discussion: The site is not located in an area that is considered wildland, therefore there is no impact from wildland fires.

X. HYDROLOGY AND WATER QUALITY. Would the project:
a) Violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality?
Discussion: Water use during construction would be limited to dust control measures for grading activities. The project will not result in releasing water or wastewater from the site. The project is subject to several existing regulations and programs, including the City’s Storm Water Management Program and State Water Resources Control Board (SWRCB) Regulations. BMPs and PPMs are required to be incorporated into grading and construction plans for the short and long-term management and protection of water quality. The proposed project’s Stormwater Control plans include the use of drainage management areas (DMAs) and the use of low impact designs (LIDs).

Therefore, considering these factors, the impacts as a result of the development of this project on storm water will be less than significant. b) Substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the
project may impede sustainable groundwater
management of the basin?
7 Discussion: The project site is within the city limits and is zoned for commercial development. The City’s municipal water supply is composed of groundwater from the Paso Robles Groundwater Basin, an allocation of the Salinas River underflow, and a surface water allocation from the Nacimiento Lake pipeline project. According to the 2020 Urban Water Management Plan (UWMP), Citywide, the City of Paso Robles anticipates a water demand of 9,451 acre-feet/year at full buildout, with supply availability projected to be 15,088 acre-feet/year to serve development during normal, dry, and multiple dry years. Based on UWMP indicating that City water resources exceeds the projected demand city wide, this projects water use will have less than significant impact on the City’s overall water system Standard conditions applied to all new developments require the payment of development fees for water service expansion to mitigate its proportionate share of related impacts.
c) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the
course of a stream or river or through the addition of
impervious surfaces, in a manner which would:

Exhibit E

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Discussion: The proposed new/replaced impervious surface area is approximately 11.52-acres. Post-Construction Stormwater Requirements (PCRs) will be satisfied through a variety of methods. Several different Stormwater Control Measures (SCMs) have been designed for implementation across the site, depending on proposed surface drainage conditions and subsurface retention requirements. In conclusion, the project’s drainage system was designed to meet minimum drainage requirements outlined in the City of Paso Robles Standard Specifications and the Regional Water Quality Control Board’s PCRs. Based on the stormwater retention plan, the impact will be less than significant.
i) result in a substantial erosion or siltation on- or offsite; Discussion: The proposed project site, as discussed in Section VII. Geology/Soils, is generally flat, and therefore will not result in substantial erosion on or off-site. Additionally, in compliance with State and local regulations, during construction erosion and/or stormwater control measures will be implemented during site disturbance; therefore, the project is not expected to result in substantial erosion or siltation and impacts will be less than significant.
ii) substantially increase the rate or amount of surface runoff in a manner which would result in flooding
on- or offsite;
iii) create or contribute runoff water which would
exceed the capacity of existing or planned
stormwater drainage systems or provide substantial
additional sources of polluted runoff; or
iv) impede or redirect flood flows?
Discussion (ii-iv): See the discussion in X.a (above) for discussion on the stormwater management approach. Measures and BMPs will be installed and implemented to decrease the amount/rate of surface runoff during storm events. Impacts will be less than significant.

d) In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation?
Discussion: The proposed project is not in any flood hazard, tsunami, or seiche zones; therefore, there no impact will occur due to this environmental factor.
e) Conflict with or obstruct implementation of a water
quality control plan or sustainable groundwater
management plan?
Discussion: See the discussion in X.a for discussion on the stormwater management approach. Measures and BMPs will be installed and implemented to adhere to the City’s Stormwater Management Program, therefore impacts would be reduced to less than significant.

Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact Source
XI. LAND USE AND PLANNING. Would the project:
a) Physically divide an established community? 1, 2
Discussion: The project is a commercial development in a commercial district and is adjacent to other commercial uses. Some residences are located to the east of the site, but no established community would be physically divided as a result of the project. b) Cause a significant environmental impact due to a
conflict with any land use plan, policy, or regulation
adopted for the purpose of avoiding or mitigating an
environmental effect?
1, 2
Exhibit E

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Discussion: The proposed project is located within the Commercial Service (C3) District, which is defined as, “Areas for highway-related, commercial services, and light industrial uses,” in the City of Paso Robles General Plan Land Use Element. The application includes a request to establish a mix of commercial services and light industrial uses; warehouse, retail, manufacturing, and winemaking uses with supporting office and storage space. The proposed uses are consistent with the C3 District land use category, therefore, there is no impact.

Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact Source
XII. MINERAL RESOURCES. Would the project:
a) Result in the loss of availability of a known mineral resource that would be a value to the region and the
residents of the state? 1
b) Result in the loss of availability of a locally important mineral resource recovery site delineated on a local
general plan, specific plan or other land use plan?
1 Discussion (a and b): There are no known mineral resources at this project site. No impacts will occur.

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

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Discussion: An Acoustical Analysis was completed by 45 dB in March of 2023.

The Study concluded that existing daytime hourly noise levels due to road traffic noise, primarily from Highway 46, range up to 43 dBA at the north property line adjacent to an existing residence, as predicted from published traffic counts and the FHWA’s Traffic Noise Model implemented into SoundPLAN®. The proposed project was modeled to analyze the potential noise impact on the neighboring land uses.

Noise levels associated with the project are anticipated to comprise of the following:
• Traffic noise associated with the increased traffic on Ardmore Road • Traffic and parking activities of 994 passenger vehicles daily in the surrounding parking lots • Truck traffic and loading of up to 80 semi-trucks daily at the loading docks on the west side of Building 1 • Truck traffic and loading of up to 60 medium delivery trucks daily at the loading dock and in the service/loading lane along the north side of Building 6
• Truck traffic and loading of up to 60 medium delivery trucks daily in the service/loading lane along the south side of Building 3 • 37 rooftop HVAC units on the six Project buildings, each modeled with a sound power level of 87 dBA rel 10-12 W (i.e., sound pressure level of 76 dBA rel 20µPa at 1-m).
• All site activities were assumed to occur during daytime hours between 7am and 7pm • No vehicle idling was included for the service/loading lanes near Buildings 3 and 6 or near the loading docks at Building 1 • Refrigerated trucks are not expected at the Project site and were not included as a noise source in the model With the project in place and the above assumptions about site traffic and rooftop HVAC equipment, the modeled Daytime Hourly LAeq levels along the property lines adjacent to residential land uses ranged up to 55 dBA and Nighttime Hourly LAeq levels ranged up to 45 dBA, both of which comply with the City of Paso Robles Municipal Code Daytime limit of 55 dBA and Nighttime limit of 45 dBA for residential land uses, therefore, this projects impacts to ambient noise levels are less than significant. The analysis concluded that the project would comply with the Paso Robles Municipal Code Daytime, Evening, and Nighttime Hourly limits. b) Generation of excessive groundborne vibration or
groundborne noise levels? 1
Discussion: Based on the proposed light-industrial/commercial type uses, groundborne noise and vibration generated by the project will not be significant. All construction activity will be required to comply with the City’s construction time requirements of 7am to 7pm Monday thru Saturday, unless exception is allowed for by the Building Official. Groundborne vibration and noise related to construction activity is anticipated to be low, since noise would only occur during daytime hours of construction and would cease upon completion of the project.

Therefore, impacts from groundborne vibrations are considered to be less than significant. c) For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public
airport or public use airport, would the project expose people residing or working in the project area to
excessive noise levels?
Discussion: The project is not located within the geographic boundaries of the Airport Land Use Plan, therefore there is no impact.

Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact Source
XIV. POPULATION AND HOUSING. Would the project:
a) Induce substantial unplanned population growth in an area, either directly (for example, by proposing new
homes and businesses) or indirectly (for example,
through extension of roads or other infrastructure)?
2 Discussion: The project site is currently undeveloped land and jobs created can be absorbed by the local and regional employment market and will not create the demand for new housing or population growth. Therefore, impacts to population growth are less than significant. b) Displace substantial numbers of existing people or
housing, necessitating the construction of replacement
housing elsewhere?
Exhibit E

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Discussion: There are no residences located on the project site, therefore, there are no impacts related to the displacement of people.

Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact Source
XV. PUBLIC SERVICES. Would the project:
a) Result in substantial adverse physical impacts associated with the provision of new or physically altered
governmental facilities, need for new or physically
altered governmental facilities, the construction of
which could cause significant environmental impacts, in order to maintain acceptable service ratios, response
times, or other performance objectives for any of the
public services:
1, 10
Fire protection?
Police protection?
Schools?
Parks?
Other public facilities?
Discussion: The project would be designed and constructed in accordance with Paso Robles Department of Emergency Services (EMS) requirements for access, fire water supply, and vegetation management. With adherence to these requirements, the project poses a low fire hazard and is not expected to impact capacity or service levels. No new or modified government facilities are needed to provide fire protection for the project. Therefore, there would be no impact to EMS.

The project site is located in the City of Paso Robles, which provides police protection and public safety within the city limits. Construction and operation of the project would not generate a material demand on police services. As such, the project is not expected to result in an adverse impact on City of Paso Robles Police Department response times, service ratios, or other performance objectives, nor would the project result in the need for new or modified police facilities to serve the site. No new or modified government facilities are needed to provide police protection for the project, therefore, there would be no impact for Police services.

The project would not generate population growth. Therefore, there would be no impact to schools, parks, or other public facilities.

Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact Source
XVI. RECREATION.
a) Would the project increase the use of existing
neighborhood and regional parks or other recreational
facilities such that substantial physical deterioration of the facility would occur or be accelerated?
1 b) Does the project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the
environment?
1 Discussion (a and b): The project would not encourage new housing demands and use of recreational facilities, therefore the project results in no impacts to recreational facilities.

Exhibit E

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Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact Source
XVII. TRANSPORTATION. Would the project:
a) Conflict with a program, plan, ordinance or policy
addressing the circulation system, including transit,
roadway, bicycle and pedestrian facilities?
Discussion: This project is consistent with the City’s C3 and CS zoning and land use designations. The proposed project would generate approximately 1,194 net new vehicle trips per weekday, including 117 AM peak hour trips and 158 PM peak hour trips. The project would not significantly impact intersection operations and would have a less than significant impact on vehicle miles traveled.

As required by all development projects with the approval of a building permit, the applicant shall be required to pay transportation impact fees established by the City Council in affect at the time of occupancy to mitigate future impacts with planned development in the City. b) Conflict or be inconsistent with CEQA Guidelines §
15064.3, subdivision (b)?
Discussion: A Transportation Analysis was prepared for this project by Central Coast Transportation Consulting, dated December 7, 2022 (Attachment 10), which indicates that the project would generate approximately 1,194 net new vehicle trips per weekday, including 117 AM peak hour trips and 158 PM peak hour trips, which would not significantly impact intersection operations and would have a less than significant impact on vehicle miles traveled, and therefore would not conflict or be inconsistent with CEQA Section 1504.3(b). c) Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)?
Discussion: There are no hazardous design features associated with, planned for, or will result from this project. No impact will occur. d) Result in inadequate emergency access?
Discussion: The project has been reviewed by the City’s Department of Emergency Services. The project will not impede emergency access and is designed in compliance with all emergency access safety features and City emergency access standards. The project would result in no impact to emergency access.

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

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ii) A resource determined by the lead agency, in its
discretion and supported by substantial evidence, to
be significant pursuant to criteria set forth in
subdivision (c) of Public Resources Code § 5024.1.

In applying the criteria set forth in subdivision (c)
of Public Resource Code § 5024.1, the lead agency
shall consider the significance of the resource to a
California Native American tribe.

Discussion: A Phase I archeological survey was conducted by Padre Associates, Inc. of the project site on July 1, 2022. The field investigation identified no prehistoric materials or historic cultural resources within the project site. Located within an area characterized as low to moderate archaeological sensitivity, the existing landform has slightly been altered by an agricultural accessory structure and mainly used as pastureland for horses. The project area has excellent ground surface visibility, ranging from 60 to 95 percent, with discarded construction materials and oak detritus accounting for areas of reduced visibility. No tribal cultural resources were identified within the project area. Therefore, impacts to tribal cultural resources are less than significant.

Letters were sent to the six tribes who requested notification for development plans as outlined in AB 52. As of this time the city has not received any request for further consultation. As mentioned above, based on the location and characteristics, it is unlikely that there are tribal cultural resources.

Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact Source
XIX. UTILITIES AND SERVICE SYSTEMS. Would the project:
a) Require or result in the relocation or construction of new or expanded water, wastewater treatment or storm
water drainage, electric power, natural gas, or
telecommunications facilities, the construction or
relocation of which could cause significant
environmental effects?
Discussion: Per the City’s General Plan EIR, Urban Water Management Plan, and Sewer System Management Plan, the City’s water and wastewater treatment facilities are adequately sized, including planned facility upgrades, to provide water needed for the project and treat effluent resulting from this project. All new storm water resulting from this project will be managed on the project site and will not enter existing storm water drainage facilities or require expansion of new drainage facilities. No new water or wastewater facilities, electric power, natural gas, or telecommunications will need to be constructed or expanded for this project, therefore there are no impacts. b) Have sufficient water supplies available to serve the project and reasonably foreseeable future development
during normal, dry and multiple dry years?
Discussion: The project is permitted is permitted with a Development Plan and a Conditional Use Permit, in the current land use and zoning designations; therefore, the project can be served with existing water resource entitlements available and will not require expansion of new water resource entitlements. This project will have a less than significant impact on the City’s water supply. c) Result in a determination by the wastewater treatment provider, which serves or may serve the project that it has adequate capacity to serve the project’s projected
demand in addition to the provider’s existing
commitments?
Discussion: Per the City’s SSMP, the wastewater treatment facility has adequate capacity to serve this project as well as existing commitments; therefore, there is no impact.

Exhibit E

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d) Generate solid waste in excess of state or local
standards, or in excess of the capacity of local
infrastructure, or otherwise impair the attainment of
solid waste reduction goals?
Discussion: During construction, most debris would consist of recyclable materials such as wood pallets, plastic and paper packaging and scrap metal that can be taken to the nearby waste recycling center and all other non-recyclable construction debris being taken to the nearby landfill. The landfill has a maximum permitted capacity of 6,495,000 cubic yards and a maximum permitted throughput of 450 tons of solid waste per day and 75,000 tons per year, through October 1, 2051. As of December 31, 2017, the landfill had a remaining capacity of 4,216,402 cubic yards or approximately 65% of the maximum permitted. Per the City’s Landfill Master Plan, the City’s landfill has adequate capacity to accommodate construction related and operational solid waste disposal for this project; therefore, there is no impact to solid waste infrastructure from this project.
e) Comply with federal, state, and local management and reduction statutes and regulations related to solid waste? Discussion: The proposed project will comply with federal, state, and local management and reduction statutes and regulations. No impact will occur.

Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact Source
XX. WILDFIRE. If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project:
a) Substantially impair an adopted emergency response
plan or emergency evacuation plan?
Discussion: The City of Paso Robles does not have an adopted emergency response plan or evacuation plan. Therefore, the project would not impact an emergency response plan.
b) Due to slope, prevailing winds, and other factors,
exacerbate wildfire risks, and thereby expose project
occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire?
c) Require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency
water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment?
Discussion (b and c): As previously identified, the site is not considered as being located within the wildland urban interface (WUI) and therefore would not need specific measures for fire-fighting purposes, beyond emergency vehicle access, clearance around structures, and connection to water. The project has been reviewed by the City of Paso Robles Fire Department and designed with Fire Codes in mind. Given these considerations the impacts will be less than significant. d) Expose people or structures to significant risks,
including downslope or downstream flooding or
landslides, as a result of runoff, post-fire slope
instability, or drainage changes?
Discussion: The project site is relatively flat and not subject to landslide potential or significant drainage changes, therefore there would be no impact.

Exhibit E

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Issues
Potentially
Significant
Impact
Less Than
Significant
With
Mitigation
Incorporated
Less Than
Significant
Impact
No Impact Source
XXI. MANDATORY FINDINGS OF SIGNIFICANCE.
a) Does the project have the potential to substantially degrade the quality of the environment, substantially
reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal
community, substantially reduce the number or restrict
the range of a rare or endangered plant or animal or
eliminate important examples of the major periods of
California history or prehistory?
Discussion: As noted within the Biological Resources section of this environmental document, there are mitigation measures related to habitat that will reduce impacts on biological resources to less than significant. b) Does the project have impacts that are individually
limited, but cumulatively considerable? (“Cumulatively
considerable” means that the incremental effects of a
project are considerable when viewed in connection
with the effects of past projects, the effects of other current projects, and the effects of probable future
projects.)
Discussion: The project will not have impacts that are individually limited, but cumulatively considerable. c) Does the project have environmental effects which will cause substantial adverse effects on human beings,
either directly or indirectly?
Discussion: As noted within this environmental document, the project’s potential to cause what may be considered substantial, adverse effects on human beings either directly or indirectly is less than significant. As such, there would be no impact on the effects on human beings as a result of the project.

Exhibit E

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EARLIER ANALYSIS AND BACKGROUND MATERIALS.

Earlier analyses may be used where, pursuant to tiering, program EIR, or other CEQA process, one or more effects have been adequately analyzed in an earlier EIR or negative declaration. CEQA Guidelines, Section 15152(b), (f).

Earlier Documents Prepared and Utilized in this Analysis and Background / Explanatory Materials Reference # Document Title Available for Review at:
1 City of Paso Robles General Plan City of Paso Robles Community Development Department
1000 Spring Street
Paso Robles, CA 93446
2 City of Paso Robles Zoning Code Same as above
3 City of Paso Robles Environmental Impact Report for General Plan Update
Same as above
4 2005 Airport Land Use Plan Same as above
5 City of Paso Robles Municipal Code Same as above
6 City of Paso Robles Water Master Plan Same as above
7 City of Paso Robles Urban Water Management Plan 2020 Same as above 8 City of Paso Robles Sewer Master Plan Same as above
9 City of Paso Robles Housing Element Same as above
10 City of Paso Robles Standard Conditions of
Approval for New Development
Same as above
11 Uptown/Town Centre Specific Plan Same as above
12 San Luis Obispo County Air Pollution Control District Guidelines for Impact Thresholds
APCD
3433 Roberto Court
San Luis Obispo, CA 93401
13 San Luis Obispo County – Land Use Element San Luis Obispo County Department of Planning
County Government Center
San Luis Obispo, CA 93408
14 USDA, Soils Conservation Service,
Soil Survey of San Luis Obispo County,
Paso Robles Area, 1983
Soil Conservation Offices
Paso Robles, Ca 93446
15 City of Paso Robles Climate Action Plan 2013 City of Paso Robles Community Development Department
1000 Spring Street
Paso Robles, CA 93446
Exhibit E

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Attachments:

1. Mitigation Monitoring and Reporting Plan

2. Vicinity Map

3. Project Site Plan

4. Biological Resource Assessment by David Wolff Environmental, LLC (July 2023) a. Biological Consistency Letter and SJKF Habitat Evaluation

5. Oak Tree Assessment Report by Heritage Tree (August 2022)

6. Phase I Archaeological Study by Padre Associates, Inc (July 2022)

7. Air Quality and Greenhouse Gas Analysis by LSA (April 2023)

8. Storm Water Control Plan by Wallace Group (February 2023)

9. Drainage Design Report by Wallace Group (February 2023)

10. Transportation Analysis by Central Coast Transportation Consultants (December 2022)

11. Acoustical Analysis by 45dB Acoustics (March 2023)
Exhibit E

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Mitigation Monitoring Program – Page 1 of 5
Attachment 1
Mitigation Monitoring and Reporting Plan
Project File No./Name: Covelop Project – Ardmore Road
Approving Resolution No.: by: Planning Commission City Council Date: September 26, 2023 The following environmental mitigation measures were either incorporated into the approved plans or were incorporated into the conditions of approval. Each and every mitigation measure listed below has been found by the approving body indicated above to lessen the level of environmental impact of the project to a level of non-significance. A completed and signed checklist for each mitigation measure indicates that it has been completed.

Explanation of Headings:

Type: ............................................................ Project, ongoing, cumulative Monitoring Department or Agency: ........ Department or Agency responsible for monitoring a particular mitigation measure Shown on Plans: .........................................When a mitigation measure is shown on the plans, this column will be initialed and dated.

Verified Implementation: ..........................When a mitigation measure has been implemented, this column will be initialed and dated.

Remarks: ...................................................... Area for describing status of ongoing mitigation measure, or for other information.

Mitigation Measure
PD 22-20, CUP 22-20, VTPM 22-0054, OTR
(Covelop)
Type
Monitoring
Department
or Agency
Shown on Plans Verified
Implementation Timing/Remarks
To reduce any potentially significant impact on nesting birds from vegetation removal to a less than significant level, the following mitigation measures are
recommended.

MM BIO-1: Vegetation removal and initial site disturbance shall be conducted between
September 1 and January 31 outside of the nesting season for birds. If vegetation and/or tree removal is planned for the bird nesting season (February 1 to August 31), then preconstruction nesting bird surveys shall be conducted by a qualified biologist to determine if any active nests would be impacted by project construction. If no active nests are found, then no further mitigation shall be required.

OngoingCDD Prior to issuance of
grading permit
Exhibit E

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Mitigation Monitoring Program – Page 2 of 5
Mitigation Measure
PD 22-20, CUP 22-20, VTPM 22-0054, OTR
(Covelop)
Type
Monitoring
Department
or Agency
Shown on Plans Verified
Implementation Timing/Remarks
If any active nests are found that would be impacted by construction, then the nest sites shall be avoided with the establishment of a non-disturbance buffer zone around
active nests as determined by a qualified biologist. Nest sites shall be avoided and protected with the nondisturbance buffer zone until the adults and young of the year are no longer reliant on the nest site for survival as determined by a qualified biologist. As such, avoiding
disturbance or take of an active nest would reduce
potential impacts on nesting birds to a less-than-significant level.

MM BIO-2: To avoid direct take of SJKF during construction in accordance with theSFWS and San Luis Obispo County
Guide to SJKF Mitigation Procedures Under CEQA, the
project owner shall adopt the Standard Kit Fox CEQA
Mitigation Measures and shall be included on
development plans. The following measures shall be
implemented:
• A maximum 25 mph speed limit shall be required at
the project site during construction activities.
• All construction activities shall cease at dusk and not start before dawn.
• A qualified biologist shall be on-site immediately prior to initiation of project activities to inspect for any large burrows (e.g., known and potential dens) and to
ensure no wildlife are injured during project activities. If dens are encountered, they should be avoided as
discussed below.
• Exclusion zone boundaries shall be established around all known and potential SJKF dens.

Project CDD Notes shown on
construction
documents.

Prior to issuing Building
Permit.

Exhibit E

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Mitigation Monitoring Program – Page 3 of 5
Mitigation Measure
PD 22-20, CUP 22-20, VTPM 22-0054, OTR
(Covelop)
Type
Monitoring
Department
or Agency
Shown on Plans Verified
Implementation Timing/Remarks
• All excavations deeper than 2 feet shall be completely covered at the end of each working day, or fitted with
wildlife escape ramps.
• All pipes, culverts, or similar structures shall be
inspected for SJKF and other wildlife before burying,
capping, or moving.
• All exposed openings of pipes, culverts, or similar
structures shall be capped or temporarily sealed prior
to the end of each working day.
• All food-related trash shall be removed from the site at the end of each workday.
• Project-related equipment shall be prohibited outside of designated work areas and access routes.
• No firearms shall be allowed in the project area.
• Disturbance to burrows shall be avoided to the
greatest extent feasible.
• No rodenticides or herbicides should be applied in the project area.
• Permanent fences between any remaining habitat
areas shall allow for SJKF passage through or
underneath (i.e., an approximate 4-inch passage gap
shall remain at ground level).
• To avoid take of any SJKF and/or active SJKF dens,
within 30 days prior to the initiation of site disturbance, implement the SJKF den survey and den closure
protocol for unoccupied dens. Any SJKF occupied
dens shall be avoided until the SJKF leave the den/site. • Prior to issuance of grading and/or construction permit and within 30 days prior to initiation of site disturbance and/or construction, all personnel associated with the
project shall attend a worker education training
program, conducted by a qualified biologist, to avoid
or reduce impacts on sensitive biological resources
(i.e. San Joaquin kit fox). At a minimum, as the
Exhibit E

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Mitigation Monitoring Program – Page 4 of 5
Mitigation Measure
PD 22-20, CUP 22-20, VTPM 22-0054, OTR
(Covelop)
Type
Monitoring
Department
or Agency
Shown on Plans Verified
Implementation Timing/Remarks
program relates to the kit fox, the training shall include the kit fox’s life history, all mitigation measures
specified by the City, as well as any related biological report(s) prepared for the project. The applicant shall notify the City shortly prior to this meeting. A kit fox fact sheet shall also be developed prior to the training
program, and distributed at the training program to all contractors, employers and other personnel involved
with the construction of the project.
• During the site-disturbance and/or construction phase, any contractor or employee that inadvertently kills or
injures a San Joaquin kit fox or who finds any such
animal either dead, injured, or entrapped shall be
required to report the incident immediately to the
applicant and City. In the event that any observations
are made of injured or dead kit fox, the applicant shall immediately notify the USFWS and CDFW by
telephone. In addition, formal notification shall be
provided in writing within three working days of the
finding of any such animal(s). Notification shall include the date, time, location and circumstances of the
incident. Any threatened or endangered species
found dead or injured shall be turned over
immediately to CDFW for care, analysis, or disposition.

Project CDD Prior to site
disturbance, grading
permit issued
(add additional measures as necessary)
Exhibit E

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Mitigation Monitoring Program – Page 5 of 5
Explanation of Headings:

Verified Implementation: ..........................When a mitigation measure has been implemented, this column will be initialed and dated.

Remarks: ...................................................... Area for describing status of ongoing mitigation measure, or for other information.

Exhibit E

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Exhibit E

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Exhibit E Page 277 of 1344 City Council Agenda April 21, 2026 BIOLOGICAL & WETLAND RESOURCES ASSESSMENTS – REGULATORY COMPLIANCE SPECIALIST

2930 UNION ROAD DEVELOPMENT PROJECT

CITY OF PASO ROBLES, CA
(LOTS 6 & 13 APN: 025-362-043)

BIOLOGICAL RESOURCES ASSESSMENT
WATERS OF THE U.S./STATE JURISDICTIONAL DETERMINATION

SAN JOAQUIN KIT FOX EXEMPT AREA HABITAT EVALUATION
JULY 24, 2023
Prepared for:

MD3 INVESTMENTS
893 MARSH ST # 13914
SAN LUIS OBISPO, CA 93406
PREPARED BY:

David Wolff Environmental, LLC
Exhibit E

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David Wolff Environmental, LLC MD3 INVESTMENTS – 2930 UNION ROAD DEVELOPMENT PROJECT |i BIOLOGICAL RESOURCES ASSESSMENT – 7/24/2023
BIOLOGICAL & WETLAND RESOURCES ASSESSMENTS – REGULATORY COMPLIANCE SPECIALIST

TABLE OF CONTENTS

1.0 EXECUTIVE SUMMARY .................................................................................................................................. 1

2.0 INTRODUCTION, PROJECT DESCRIPTION, AND PURPOSE ............................................................................... 2

3.0 EXISTING CONDITIONS – SETTING................................................................................................................. 2

4.0 METHODS ..................................................................................................................................................... 3

5.0 RESULTS........................................................................................................................................................ 4

5.1 HABITAT TYPES AND PLANT COMMUNITIES.................................................................................................. 4

5.1.1 ANNUAL BROME GRASSLAND ....................................................................................................................... 4

5.1.2 RUDERAL – LIVESTOCK PADDOCKS AND BARN ............................................................................................. 5

5.2 WILDLIFE ..................................................................................................................................................... 5

5.3 WATERS OF THE U.S., WETLANDS, AND WATERS OF THE STATE .................................................................. 5

5.4 SPECIAL-STATUS SPECIES AND NATURAL COMMUNITIES OF SPECIAL CONCERN............................................ 7

5.4.1 SPECIAL-STATUS BOTANICAL RESOURCES..................................................................................................... 8

5.4.2 SPECIAL-STATUS WILDLIFE .......................................................................................................................... 9

6.0 IMPACT ASSESSMENT AND RECOMMENDED MITIGATION MEASURES ..........................................................10

6.1 SUFFICIENCY OF BIOLOGICAL DATA............................................................................................................10

6.2 IMPACT ASSESSMENT ..................................................................................................................................10

6.3 RECOMMENDED MITIGATION MEASURES ...................................................................................................11

7.0 CONCLUSIONS.............................................................................................................................................13

8.0 REFERENCES ...............................................................................................................................................13

APPENDIX A – FIGURES
FIGURE 1: REGIONAL LOCATION MAP
FIGURE 2: VICINITY LOCATION AERIAL MAP
FIGURE 3: SOILS MAP
FIGURE 4: HABITAT MAP
FIGURE 5: CNDDB OCCURRENCE MAP
FIGURE 6: SAN JOAQUIN KIT FOX EXEMPT AREA MAP (2003 GENERAL PLAN FEIR) FIGURE 7: REPRESENTATIVE PHOTOGRAPHS
APPENDIX B – TABLES
TABLE B-1: FLORISTIC INVENTORY PLANT SPECIES OBSERVED
TABLE B-2: CNDDB SPECIAL-STATUS SPECIES OCCURRENCES

APPENDIX C – WATERS OF THE U.S./STATE WETLAND DETERMINATION DATA SHEETS Exhibit E

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David Wolff Environmental, LLC MD3 INVESTMENTS – 2930 UNION ROAD DEVELOPMENT PROJECT BIOLOGICAL RESOURCES ASSESSMENT – 7/24/2023
1 BIOLOGICAL & WETLAND RESOURCES ASSESSMENTS – REGULATORY COMPLIANCE SPECIALIST MD3 INVESTMENTS
2930 UNION ROAD DEVELOPMENT PROJECT

CITY OF PASO ROBLES, CA
(LOTS 6 & 13 APN: 025-362-043)

BIOLOGICAL RESOURCES ASSESSMENT

1.0 EXECUTIVE SUMMARY
The 2930 Union Road Development Project (project) proposes an industrial park development on approximately 14 acres of undeveloped land in the City of Paso Robles. The proposed project site is on the edge of commercial, industrial and residential developments to the north, east and west of the site. Open grazing grasslands are to the south of the project site. Field surveys established existing conditions of the site as non-native annual grassland habitat and ruderal barn and paddock area. Eight mature valley oak trees are spread around the site. Based on a formal jurisdictional determination, a non-wetland non-jurisdictional swale runs across the southern end of the site. No wetlands or other waters of the U.S./State or riparian habitat occur on the project site.

The search and review of the CNDDB revealed 17 special-status species composed of 7 special-status plants, 10 special-status wildlife species, and no natural communities of special concern with recorded occurrences within an approximately 5-mile radius of the proposed project site. A floristic inventory and rare plant survey conducted during the spring/summer 2022 confirmed that no special-status plant species occur on the project site. No specialstatus wildlife species were observed or expected to occur on the project site. The project site is outside of and exempt from the City of Paso Robles (City) San Joaquin kit fox (SJKF) compensatory mitigation area as delineated in the City’s General Plan Final Environmental Impact Report. No SJKF have been observed in the Paso Robles area for over 10 years.

Implementation of the standard SJKF take avoidance measures would reduce potentially significant direct impacts on the SJKF to a less than significant level.

The conversion of disturbed non-native annual grassland to development and displacement of common local wildlife at the edge of urban development may be considered a less than significant impact. Valley oak tree removal (7 trees in poor or very poor condition; 1 tree in good conditions) would require implementation of the City’s replacement policy, therefore, would be considered a less than significant impact. Locally common resident and migratory ground nesting birds that may use the site for breeding, foraging, and roosting could be impacted by project construction. Mitigation to avoid potentially significant impacts on nesting birds is recommended.

Based on the findings described in this biological resources assessment establishing the existing conditions of the proposed project site, and incorporation of the recommended Exhibit E

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2 BIOLOGICAL & WETLAND RESOURCES ASSESSMENTS – REGULATORY COMPLIANCE SPECIALIST mitigation measures, implementation of the proposed project would not result in any substantial adverse effects on biological or botanical resources. Therefore, with mitigation measures incorporated into the project, direct and indirect project impacts on biological resources would be considered less than significant.

2.0 INTRODUCTION, PROJECT DESCRIPTION, AND PURPOSE
The 2930 Union Road Development Project (project) proposes industrial park development on approximately 14.0 acres of undeveloped land within the urbanized area in the City of Paso Robles (City). The site supports approximately 12.0 acres of disturbed non-native grassland with evidence of intensive horse pasturing, and approximately 2.0 acres of livestock paddocks, barn, and horse training areas (“arenas”). There are eight mature valley oak trees on the site that have been documented and evaluated by arborists (7 trees in poor or very poor condition; 1 tree in good conditions). The project site is surrounded by industrial and residential development to the north, west, and east. Grassland hills with grazing cattle are to the south and southeast. Figures 1 and 2 in Appendix A provide regional and vicinity context location maps respectively.

David Wolff Environmental (DWE) conducted the review of available background data, biological resources field surveys, a floristic inventory and rare plant survey, and a waters of the U.S./State jurisdictional determination on the project site on May 5 and June 23, 2022.

The purpose of the field surveys and this biological resources assessment is to document existing conditions of the proposed project site, determine the suitability and presence or absence of rare, threatened, or endangered plants or wildlife (special-status species), and to evaluate the potential for any direct or indirect significant impacts on biological or waters of the U.S./State resources, or adverse effects on any special-status species.

3.0 EXISTING CONDITIONS – SETTING
The proposed project site has been used as horse pasturing for many years and is surrounded by residential and industrial developments, with active grazing lands to the southeast. The site is mostly flat gently sloping downwards from north to south to a swale running across the southern edge of the site to culverts on and under the recent adjacent development on the western site boundary. The site appears to have been substantially and regularly used as horse pasture over time evidenced by abundant horse droppings all over the site. The northwest two acres show more intense horse use in paddocks, barn, and a rectangular and circular “arena” training areas.

The USDA Natural Resources Conservation Service (NRCS; Soil Conservation Service, 1977/2022) has identified two soil series mapping units within the project site as shown in Appendix A Figure 3. Onsite soils are mapped as Arbuckle-San Ysidro Complex (106), 2 to 9 percent slopes, and San Ysidro Loam (197), 0 to 2 percent slopes. The Arbuckle soil is a very Exhibit E

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3 BIOLOGICAL & WETLAND RESOURCES ASSESSMENTS – REGULATORY COMPLIANCE SPECIALIST deep, well drained soil with moderately low permeability formed in alluvium from mixed rocks. Typically, the surface layer is pale brown fine sandy loam to 10 inches thick. The San Ysidro soil is a very deep, moderately well drained soil with very slow permeability formed in alluvium from mixed rocks. Typically, the surface layer is pale brown loam about 20 inches thick. Field observations of surface soils, spoils from ground squirrel burrows, and wetland delineation soil test pits corroborate the loamy and sandy loam soils mapping throughout the project site.

4.0 METHODS
Prior to field surveys, DWE Principal Ecologist David Wolff conducted a review of available background information including aerial photography of the project area over time (Google Earth), the Natural Resources Conservation Service soil survey, arborists’ reports, environmental review documentation from the adjacent City of Paso Robles approved Planned Development 17-015, City of Paso Robles General Plan Final Environmental Impact Report, and the query results of an approximately 5-mile search radius of the California Natural Diversity Data Base (CNDDB). The 5-mile radius search is appropriate given project location mostly surrounded by and at the edge of urban development in the City. The CNDDB provided a list and mapped locations of special-status plant and wildlife species that have been recorded in the region of the project site. The CNDDB records help to focus the field survey efforts and evaluation of potential project effects on specific species or habitats.

It is noted that the CNDDB does not necessarily include all special-status species potentially occurring onsite or in the region, but rather only those that have been recorded by the CNDDB.

DWE Principal Ecologist David Wolff reviewed the available background data described above and conducted biological resources field surveys and a floristic inventory and rare plant survey on the project site on May 5 and June 23, 2022, to document existing conditions of the onsite biological resources. Surveys were conducted by walking the entirety of the proposed project site recording plant and wildlife species observed and general site characteristics. Conditions for the site survey were conducive to the purpose of documenting plant and wildlife habitat to establish existing conditions. The field surveys included conducting a wetland delineation and jurisdictional determination of swale running across the southern corner of the site. It appears that cattle were brought in to reduce the grassland cover between the two DWE field surveys that provided additional observations of the swale configuration and general site microtopography.

The overall purpose of the field surveys was to document existing conditions in terms of habitat for plant and wildlife species, determination of the presence/absence of special-status plant or wildlife species, and the potential to support wetland habitat and/or other waters of the U.S./State. The study area habitat types were described by the aggregation of plants and wildlife based on the composition and structure of the dominant vegetation observed at the Exhibit E

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4 BIOLOGICAL & WETLAND RESOURCES ASSESSMENTS – REGULATORY COMPLIANCE SPECIALIST time the field reconnaissance was conducted and through review of multiple years of aerial photography.

DWE Principal Ecologist David Wolff reviewed the available background information and available aerial photography, conducted the field surveys, and is the primary author and principal in charge of report preparation. The survey data collected on plant and wildlife species and conclusions presented in this biological resources assessment are based on the methods and field reconnaissance conducted over the project site as described above.

5.0 RESULTS

5.1 HABITAT TYPES AND PLANT COMMUNITIES
Plant communities are generally described by the assemblages of plant species that occur together in the same area forming habitat types. The best fit based on observed site conditions for community alliance and alliance codes habitat classifications used in this report follow, A manual of California vegetation, 2nd edition (Sawyer et al. 2009) and California Department of Fish and Wildlife California Natural Community List. Plant names used in this report follow The Jepson Manual, Vascular Plants of California, Second Edition Thoroughly Revised and Expanded (Baldwin et al. 2012) with updated taxonomy referenced through the CalFlora database (2022). The proposed project site supports one plant community, non-native annual grassland over the entire site, with a more disturbed/ruderal area where there are paddocks, evidence of horse “arenas,” and a barn. Eight mature valley oak trees are spread across the site. Figure 4 in Appendix A provides a habitat map showing the locations and extent of the habitat types and oak trees on the proposed project site.

Figure 7 includes a set of onsite representative photographs from DWE field surveys. Table B-1 in Appendix B provides a complete list of plant species observed during DWE floristic inventory and rare plant field surveys.

5.1.1 ANNUAL BROME GRASSLAND – DISTURBED NON-NATIVE ANNUAL GRASSLAND The Annual Brome Grassland or Bromus (diandrus, hordeaceus), Semi-Natural Herbaceous Stands (CDFW: Bromus hordaceus – Erodium botrys, 42.026.09), is best described as disturbed non-native annual grassland habitat from what appears to be ongoing horse pasturing. The disturbed non-native annual grassland habitat covers 12 acres of the project site and is dominated by non-native annual grasses and herbaceous broadleaf plant species, with few native forbs. Plant species diversity is generally low on the site given what appears to be long-term horse grazing practices. Dominant plant species in the disturbed annual grassland habitat include soft chess (Bromus hordeaceus) and filarees (Erodium spp.). Other associated grasses and herbaceous broadleaf species include ripgut brome (Bromus diandrus), red brome (Bromus rubens), foxtail barley (Hordum murinum ssp. leporinum), short podded Exhibit E

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5 BIOLOGICAL & WETLAND RESOURCES ASSESSMENTS – REGULATORY COMPLIANCE SPECIALIST mustard (Hirschfeldia incana), clustered tarweed (Deinandra fasciculata), and fiddleneck (Amsinckia intermedia). See Figure 7 Photos 1 through 9.

Eight mature valley oak trees (Quercus lobata) are spread across the non-native annual grassland site that were evaluated by arborists. Seven of which are in poor or very poor condition with arborist’s recommendation for removal for development, and one in good condition that could be retained with maintenance pruning.

A non-wetland swale running southeast to northwest emanating from the southern edge of site was dominated by squirrel-tail barley (Hordeum jubatum) with mayweed (Anthemis cotula) transitioning to Mediterranean barley (Hordeum marinum ssp. gussoneanum) (see Figure 4). A full discussion of the jurisdictional determination of the non-wetland swale is included in Section 5.3 below.

5.1.2 RUDERAL – LIVESTOCK PADDOCKS AND BARN
Approximately two acres on the northwest corner of the site supports a barn, fenced paddocks, and what appears to have been rectangular and circular horse training “arenas” that created a ruderal (disturbed) grassland area. There is no official classification for “ruderal” but is accepted for describing areas subject to human and livestock disturbed areas.

The intensive animal use reduces vegetative cover and habitat values for native species with an increase in cover of short-podded mustard in the disturbed areas.

5.2 WILDLIFE
The project site soft chess and filaree dominated non-native grassland with evidence of substantial horse grazing provides minimal quality habitat for locally common wildlife species that have become adapted to the habitat edges along the urban interface. Common wildlife observed were gopher mounds and abundant ground squirrels. Bird species observed included northern mockingbird, mourning dove, European starling, common raven, western meadowlark, with red tailed hawk and turkey vulture fly overs. The large valley oak trees can provide roosting and nesting habitat for birds. No large raptor stick nests were observed in any of the trees. The habitat on the project area does not support a substantial amount habitat in the context of the greater expanse of undeveloped lands abutting urban development to the north and west, and agricultural/grazing lands to the south and west. As such, the site adjacent to developed City of Paso Robles does not represent a migratory or movement corridor for wildlife.

5.3 WATERS OF THE U.S., WETLANDS, AND WATERS OF THE STATE The project site is upland non-native grassland/pasture with a non-wetland nonjurisdictional swale running southeast to northwest across the southern corner of the project site. In addition to review of aerial photography over time, data on vegetation, soils, and Exhibit E

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6 BIOLOGICAL & WETLAND RESOURCES ASSESSMENTS – REGULATORY COMPLIANCE SPECIALIST hydrology were collected at three wetland determination data observation points on May 5, 2022, and reaffirmed on June 23, 2022 (see Figure 4). The swale is evident onsite from Google Earth aerial photographs back to 1994 leading offsite on adjacent properties to the west running towards Union Road where it likely entered storm drains.

Presently, the western end of the swale at the property line is met by culverts on and under the adjacent property. Recent City approved adjacent development placed culverts at the western end of the swale at the property line. There is no surface evidence of the swale remaining on the recent developed areas. The certified mitigated negative declaration (MND) for the adjacent approved project (Planned Development PD 17-001) determined that the swale emanating from and “downstream” of the project site lacked an ordinary high water mark (OHWM; limits of Federal Clean Water Act jurisdiction) and, therefore, was not a wetland or waters of the U.S./State (City of Paso Robles MND, Attachment 4, Kevin Merk Associates, 2017). The onsite broad low gradient swale also lacks any distinct bed, bank, or channel, evidence of flow such as scour or sediment deposits, or basin topography. The lack of any defined OHWM was very evident during the DWE June 23, 2022 field survey after cattle grazing had reduced the grassland cover exposing the microtopography of the site (see Figure 7, Photos 10 through 20). As such, there is no OHWM present and the swale does not represent a waters of the U.S./State.

DWE gathered data at wetland determination data points at two locations in the swale that supported wetland indicator plant species, and one location above the swale representing uplands. The wetland determination data forms corroborating the following findings are included in Appendix C. The following current wetland plant indicators status and 2020 Arid West Wetland Plant List were used.
• OBL – (Obligate) almost always occur in wetlands;
• FACW – (Facultative Wetland) usually occur in wetlands, but may occur in nonwetlands; • FAC – (Facultative) occur in wetlands and non-wetlands; • FACU – (Facultative Upland) usually occur in non-wetlands, but may occur in wetlands;
• UPL – (Upland) almost always occur in non-wetlands.

Data Point 1 (DP-1) was taken at the western (“downstream”) end of the swale at the property line where there was a dominance of seasonal wetland plants coyote thistle (Eryngium vaseyi; FACW), popcorn flower (Plagiobothrys stipitatus; FACW), and woolly marbles (Psilocarphus tenellus; OBL) within an approximately 470 square foot oval area.

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7 BIOLOGICAL & WETLAND RESOURCES ASSESSMENTS – REGULATORY COMPLIANCE SPECIALIST indicators (1 required) of wetland hydrology were present. As such, the area does not meet the three-parameter jurisdictional wetland determination criteria and is a non-wetland nonjurisdictional swale.

Data Point 2 (DP-2) was taken above the swale topography to represent an upland point.

This data point was dominated by 85% cover of soft chess (Bromus hordeaceus: FACU), with red brome (Bromus rubens; UPL), Mediterranean barley (Hordeum marinum ssp. gussoneanum; FAC), and a few coyote thistle (FACW) that does not meet the wetland vegetation criteria. There were no field indicators of hydric soil (redoxomorphic features from sufficient wetting/drying). The data point was outside of the swale drainage pattern so no primary or secondary wetland hydrology indicators were present. As such, the area does not meet the three-parameter jurisdictional wetland determination criteria and represents uplands.

Data Point 3 (DP-3) was taken in the swale where there was a predominance of seasonal wetland grasses Mediterranean barley (Hordeum marinum ssp. gussoneanum; FAC) and squirreltail barley (Hordum jubatum; FAC), with filaree (Erodium cicutarium; UPL).

However, there were no field indicators of hydric soil (redoxomorphic features from sufficient wetting/drying). While the swale could be considered a drainage pattern (a secondary indicator), two secondary indicators are needed (i.e., water marks, sediment/drift deposits) to be determine a wetland. No other secondary indicators or any primary indicators (1 required) of wetland hydrology were present. As such, the area does not meet the three-parameter jurisdictional wetland determination criteria and is a non-wetland nonjurisdictional swale.

The State Water Resources Control Board (Water Board) issued policy, procedures, and wetland definition for the discharge of dredged or fill material into waters of the State (2021 Procedures). In brief, the 2021 Procedures define wetlands as waters of the State to be consistent with the federal three parameter definition requiring the presence of hydrophytic vegetation, hydric soils, and wetland hydrology. As described above and detailed on the wetland determination data sheets in Appendix C, the project site does not support any three parameter wetlands. As such, there are no State wetlands present on the project site. Further, the State determined the swale on the adjacent property to the west (now in culverts) did not represent a waters of the State (City of Paso Robles, 2017).

Based on the above detailed findings, no waters of the U.S./State, wetlands, or riparian habitat under any regulatory jurisdictions or definitions occur on the project site.

5.4 SPECIAL-STATUS SPECIES AND NATURAL COMMUNITIES OF SPECIAL CONCERN Special-status species are those plants and animals listed, proposed for listing, or candidates for listing as threatened or endangered by the United States Fish and Wildlife Service (USFWS) or the National Marine Fisheries Service (NMFS) under the federal Endangered Exhibit E

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Paso Robles City CouncilApril 21, 2026

Paso Robles City Council
April 21, 2026