Addendum (PDF) — Paso Robles City Council, April 21, 2026 (part 3 of 10)

David Wolff Environmental, LLC MD3 INVESTMENTS – 2930 UNION ROAD DEVELOPMENT PROJECT BIOLOGICAL RESOURCES ASSESSMENT – 7/24/2023
8 BIOLOGICAL & WETLAND RESOURCES ASSESSMENTS – REGULATORY COMPLIANCE SPECIALIST Species Act (FESA); those considered “species of concern” by the USFWS; those listed or proposed for listing as rare, threatened, or endangered by the CDFW under the California Endangered Species Act (CESA); animals designated as “Species of Special Concern” by the CDFW; and plants occurring as a rank 1B, 2, and 4 of the California Native Plant Society (CNPS) Inventory of Rare and Endangered Vascular Plants of California. Natural Communities of Special Concern are habitat types considered rare and worthy of tracking in the California Natural Diversity Database (CNDDB) by the CNPS and CDFW because of their limited distribution or historic loss over time.

The search and review of the CNDDB revealed 17 special-status species composed of seven 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. The 5-mile CNDDB search radius is appropriate to focus the special-status species issues given the project site location at the edge of urban development. The following briefly describes or summarizes the special-status species issues and potential for occurrence on the project site. Figure 5 provides CNDDB mapped locations and Table B-2 in Appendix B provides a list of special-status species recorded in the CNDDB that includes scientific and common name, listing status, habitat requirements, and potential to occur or observations if any on the project site.

5.4.1 Special-Status Botanical Resources
The CNDDB revealed the recorded occurrences of seven special-status plant species within a 5-mile radius of the project site, none of which are formally listed under the Federal or State Endangered Species Acts, only with a CNPS rank suggesting rarity. None of the CNDDB plant occurrences are mapped within the project site. The floristic inventory and rare plant survey conducted on the project site on May 5 and June 23, 2022 resulted in no observations of any special-status plant species. The May 5th field survey was during peak floristic expression for the 2022 growing season.

The special-status plant species occurrences recorded in the CNDDB are herbaceous annuals that are commonly associated with a specific soil type, moisture regime (mesic/moist grasslands, vernal pools). Special-status plants recorded in the CNDDB associated with serpentine or specialized soils that do not occur on the project site include Lemmon’s jewelflower (Caulanthus lemmonii), woodland wollythreads (Monolopia gracilens) and San Luis Obispo owl’s-clover (Castilleja densifllora var. obispoensis). No serpentine or clay soils are mapped or observed within the project area and these species were not observed during the DWE floristic inventory field surveys.

The special-status plant species recorded in the CNDDB known from mesic (moist) habitats occurring in the region are the shining navarretia (Navarretia nigeliformis ssp. radians), Jared's pepper-grass (Lepidium jaredii ssp. jaredii), oval-leaved snapdragon (Antirrhinum Exhibit E

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David Wolff Environmental, LLC MD3 INVESTMENTS – 2930 UNION ROAD DEVELOPMENT PROJECT BIOLOGICAL RESOURCES ASSESSMENT – 7/24/2023
9 BIOLOGICAL & WETLAND RESOURCES ASSESSMENTS – REGULATORY COMPLIANCE SPECIALIST ovatum), and Santa Lucia dwarf rush (Juncus luciensis). The CNDDB has many occurrences of shining navarretia south of the project site (Chandler Ranch occurrences). The nonwetland swale provides mesic conditions but none of these species were observed during the DWE floristic inventory field surveys.

5.4.2 Special-Status Wildlife
The CNDDB search revealed the recorded occurrences of 10 special-status wildlife species within the region of the project site. Special-status wildlife species known from the region evaluated for this study are discussed below by groups based upon habitat preferences, specific habitat use requirements (i.e., terrestrial or aquatic), mobility, and migratory patterns. Table B-2 in Appendix B provides listing status, habitat detail, and potential to occur on the project site for each of the species discussed below.

Aquatic/Riparian Species – The project site does not support habitat for any of the highly aquatic permanent water western pond turtle (Emys marmorata), vernal pool species vernal pool fairy shrimp (Branchinecta lynchi) or western spadefoot (toad) (Spea hammondii). The CNDDB includes occurrences for wide-ranging resident and migratory bird species known from the region of the project site. The tricolored blackbird (Agelaius tricolor) is locally nomadic but requires bulrush and cattail marsh or ponds for breeding that are not present on the project site. The least Bell’s vireo (Vireo bellii pusillus) is a breeding season migrant known from the Salinas River that requires dense riparian habitat that does not occur on the project site. As such, the project site does not support suitable habitat for these bird species.

Reptiles – The northern legless lizard (Anniela pulchra) is closely associated with sandy or very friable loamy soils under coastal scrub or woodland vegetation with soil moisture and vegetative cover being essential. The onsite loam and sandy loam soils, lack of shrub cover, and horse pasturing renders the site unsuitable for this species.

Upland Birds – The project site supports potential limited foraging and/or nesting opportunities for the wide ranging locally nomadic golden eagle. No large stick nests were observed in any of the large onsite valley oak trees. Brief forging on the project site has a low probability of occurrence and does not represent a substantial amount of foraging habitat.

Mammals – San Joaquin Kit Fox Habitat Urban Area Exemption – The SJKF occupies open country grassland, open scrubland, and oak savannah where there are friable soils for burrowing and an abundant rodent prey base. This small species of fox is known to use available ground squirrel or other existing burrows for den sites as they typically do not initially excavate their own dens. The open grassland grazing lands to the southeast offers suitable habitat for the San Joaquin kit fox, although not observed in the Paso Robles area for over ten years. The project site in the developed area of the City falls outside of the SJKF compensatory mitigation area defined in the City General Plan Final Environmental Impact Report as shown on Figure 6 in Appendix A.

Exhibit E

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

6.0 IMPACT ASSESSMENT AND RECOMMENDED MITIGATION MEASURES

6.1 SUFFICIENCY OF BIOLOGICAL DATA
The DWE field surveys on May 5 and June 23, 2022 are sufficient to; 1) adequately establish existing conditions of the project site and context in the landscape and land use mosaic in the vicinity; 2) determine that the site does not support any special-status plant or wildlife species; 3) determine the absence of waters of the U.S./State, wetland or riparian habitats onsite, and 4) adequately evaluate proposed project impacts and provide recommended mitigation measures to reduce potential significant impacts to a less than significant level.

The data collected as articulated in this report provide sufficient biological resources information to adequately address potential significance of impacts on biological resources.

6.2 IMPACT ASSESSMENT
Botanical Resources – The proposed project would develop the entire 12.0 acres of nonnative annual grassland and 2.0 acres of ruderal habitats, including up to eight valley oak trees into industrial park urban uses. Seven valley oaks 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. No natural communities of special concern occur on the project site so none would be impacted. The onsite soil and microhabitat conditions are not suitable for any special-status plant species, and none were observed during the DWE floristic inventory and rare plant survey. Oak tree removals approved as part of the project would be mitigated in accordance with the City ordinance requiring replacement plantings on an inch for inch basis of 25% of the inches of diameter at breast height of oak trees removed. As such, impacts on botanical resources would be considered a less than significant impact and no mitigation is recommended.

Wildlife Resources – Construction of the proposed project and conversion of the entire site into industrial park urban uses could result in the mortality and/or displacement of locally common wildlife such as resident and migratory birds, raccoons, opossums, and small mammals. No special-status wildlife species are expected to occur on the project site. As such, impacts on common wildlife would be considered a less than significant impact and no mitigation is recommended.

Vegetation and tree removal (clearing and grubbing) during the nesting season for birds could result in the destruction of active bird’s nests. Destruction of active nests is prohibited by the Fish and Game Code of California Sections 3503 and 3503.1 (raptors specifically). As such, this could be considered a potentially significant impact. Mitigation to avoid take or destruction of active nests would reduce this potentially significant impact to a less than significant level.

Exhibit E

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David Wolff Environmental, LLC MD3 INVESTMENTS – 2930 UNION ROAD DEVELOPMENT PROJECT BIOLOGICAL RESOURCES ASSESSMENT – 7/24/2023
11 BIOLOGICAL & WETLAND RESOURCES ASSESSMENTS – REGULATORY COMPLIANCE SPECIALIST The project is within the historic range of the SJKF with no observations in the City limits for over 10 years. Although highly unlikely, the SJKF could occupy a den on the project site and be impacted by project construction. Potential direct impacts on an occupied SJKF den is a potentially significant impact requiring mitigation to avoid take of the species.

6.3 RECOMMENDED MITIGATION MEASURES
The following mitigation measure is recommended to avoid, minimize, and mitigate for potentially significant impacts on nesting birds.

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.

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 non-disturbance 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-thansignificant level.

To reduce any potentially significant impact and avoid take of any SJKF from project construction, the following mitigation measures are recommended.

MM BIO-2: To avoid direct take of SJKF during construction in accordance with the USFWS 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 Exhibit E

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

Exhibit E

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

7.0 CONCLUSIONS
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.

8.0 REFERENCES

1. Baldwin, B.G., D.H. Goldman, D.J. Keil, R. Patterson, T.J. Rosatti, Editors. 2012. The Jepson Manual, Vascular Plants of California, Second Edition Thoroughly Revised and Expanded. UC Press.

2. California Native Plant Society, Rare Plant Program. 2022. Rare Plant Inventory (online edition, v9-01 1.5). Website https://www.rareplants.cnps.org (accessed March 2022).

3. California Department of Fish and Wildlife (CDFW). 2022. Natural Diversity Data Base (CNDDB) of recorded occurrences of special-status species. Accessed July 2022.

4. CALFLORA. 2022. Online database of native plants of California. 2022.

5. City of Paso Robles. 2003. General Plan Final Environmental Impact Report Figure 4.3-2 delineating the San Joaquin kit fox compensatory mitigation area.

6. City of Paso Robles. 2017. Notice of Determination and Certified Mitigated Negative Declaration for Planned Development 17-001, Tentative Parcel Map PR 16-0245, and Conditional Use Permit 17-01. November 16, 2017.

7. Google Earth. 2022. Online resource for aerial photography over time.

8. Heritage Tree Arboricultural Consulting. 2022. Oak Tree Assessment Report for Ardmore Road Project, 2930 Union Road, Paso Robles, CA 93446. August 10, 2022.

9. Holland, R.F. 1986. Preliminary Descriptions of the Terrestrial Natural Communities of California. California Department of Fish and Wildlife Nongame-Heritage Program.

Exhibit E

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

10. Holland, V.L., and D.J. Keil. 1990. California Vegetation. Biological Sciences Department, California Polytechnic State University, San Luis Obispo, California.

11. Jameson, E.W. & Hans J. Peeters . 2004. Mammals of California, Revised Edition. University of California Press.

12. Jennings, M.R. and M.P. Hayes. 1994. Amphibian and Reptile Species of Special Concern in California. California Department of Fish and Wildlife Contract # 8023. Inland Fisheries Division, Rancho Cordova, California.

13. Mayer, W. and W. Laudenslayer, Editors. 1988. A Guide to Wildlife Habitats of California.

California Department of Forestry and Fire Protection.

14. Peterson, R.T. 1990. A Field Guide to Western Birds, Houghton Mifflin Company.

15. Stebbins, R.C., and McGinnis, S.M. 2012. Field Guide to Amphibians and Reptiles of California: Revised Edition (California Natural History Guides) University of California Press, 2012

16. Sawyer, J.O., T. Keeler-Wolf, and J.M. Evens. 2009. A Manual of California Vegetation, Second Edition. California Native Plant Society Press, Sacramento.

17. Solid Oak Tree Management. 2021. Arborist Report for Ardmore Project, Paso Robles, CA.

October 31, 2021.

18. U.S.D.A Soil Conservation Service (Natural Resources Conservation Service). Online mapping and soils data for inland San Luis Obispo County (1977/2022).

19. U.S. Fish and Wildlife Service. 2011. Standardized Recommendations for Protection of the Endangered San Joaquin Kit Fox Prior to or During Ground Disturbance. January 2011.

20. U.S. Fish and Wildlife Service. 2020. Species Status Assessment Report for the San Joaquin kit fox (Vulpes macrotis mutica). August 2020.

Exhibit E

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

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
FIGURE 7: REPRESENTATIVE PHOTOGRAPHS
Exhibit E

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Exhibit E

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Exhibit E

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Exhibit E

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Disturbed Non-Native
Annual Grassland
Livestock
Paddocks
and Barn
Non-Wetland
Lot #6
Lot #13
Swale
DP-1
DP-2
DP-3
35°38'28"N 35°38'27"N 35°38'26"N 35°38'25"N 35°38'24"N 35°38'23"N 35°38'22"N 35°38'21"N 35°38'20"N 35°38'19"N 35°38'18"N 35°38'17"N 35°38'16"N 35°38'15"N 120°39'18"W 120°39'17"W 120°39'16"W 120°39'15"W 120°39'14"W 120°39'13"W 120°39'12"W 120°39'11"W 120°39'10"W 120°39'9"W 120°39'8"W 120°39'7"W 120°39'6"W 120°39'5"W 120°39'4"W 120°39'3"W 120°39'2"W 120°39'1"W 120°39'W 120°38'59"W 120°38'58"W 120°38'57"W 120°39'17"W 120°39'16"W 120°39'15"W 120°39'14"W 120°39'13"W 120°39'12"W 120°39'11"W 120°39'10"W 120°39'9"W 120°39'8"W 120°39'7"W 120°39'6"W 120°39'5"W 120°39'4"W 120°39'3"W 120°39'2"W 120°39'1"W 120°39'W 120°38'59"W 120°38'58"W 120°38'57"W 120°38'56"W Regional Map
Legend
Project Site Boundary
Lot Boundary
Non-Wetland Swale
Valley Oak Tree
DP-# | Wetland Delineation Data
Point
Habitats
Disturbed Non-Native Annual
Grassland
Livestock Paddocks and Barn
Ardmore Rd
Ardmore Rd
Figure 4: Habitat Map
2930 Union Road
Lots 6 & 13
Biological Resources Assessment
Sources: Aerial Imagery by Google (2/26/21).

Map Updated: 8/8/2022
Created by: SierraGIS
0 125 250
Feet
0 30 60
Meters
GCS | NAD 1983 StatePlane California V FIPS 0405 Feet
Projection | Lambert Conformal Conic
Datum | North American 1983
Scale | 1:1,600
Project Location

35.63955°N 120.65166°W
Township 26S, Range 12E, Section 26
Paso Robles Quadrangle
San Luis Obispo County, California
Exhibit E

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Exhibit E

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David Wolff Environmental, LLC MD3 INVESTMENTS – 2930 UNION ROAD DEVELOPMENT PROJECT BIOLOGICAL RESOURCES ASSESSMENT 7/24/2023
FIGURE 6 – SAN JOAQUIN KIT FOX PROJECT COMPENSATORY MITIGATION EXEMPT AREA MAP BIOLOGICAL & WETLAND RESOURCES ASSESSMENTS – REGULATORY COMPLIANCE SPECIALIST Project Site
Exhibit E

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DAVID WOLFF ENVIRONMENTAL, LLC MD3 INVESTMENTS – 2930 UNION ROAD DEVELOPMENT PROJECT – BIOLOGICAL RESOURCES ASSESSMENT FIGURE 7 – REPRESENTATIVE PHOTOGRAPHS
BIOLOGICAL & WETLAND RESOURCES ASSESSMENTS – REGULATORY COMPLIANCE SPECIALIST Photo 1: View southeast at ruderal animal paddock area, remnant rectangular “arena” with mustard growth, and barn (arrow). 5/5/2022 Photo 2: View west at ruderal animal paddock area and remnant circular “arena” along Ardmore Road (truck passing by). 5/5/2022 Photo 3: View northeast along west edge of lot #6 at non-native annual grassland heavily used as horse pasture. 5/5/2022
Photo 4: View east along lot #6 edge between pasture and paddock area at non-native annual grassland with scattered valley oak trees. 5/5/2022 Exhibit E

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DAVID WOLFF ENVIRONMENTAL, LLC MD3 INVESTMENTS – 2930 UNION ROAD DEVELOPMENT PROJECT – BIOLOGICAL RESOURCES ASSESSMENT FIGURE 7 – REPRESENTATIVE PHOTOGRAPHS
BIOLOGICAL & WETLAND RESOURCES ASSESSMENTS – REGULATORY COMPLIANCE SPECIALIST Photo 5: View north at non-native annual grassland pasture towards north edge of lot #6 (tree line). 5/5/2022
Photo 6: View west across lot #6 & lot #13 “line” non-native annual grassland & barn/oak at south end of paddock area (arrow). 5/5/2022 Photo 7: View south along east border of lot #13 non-native annual grassland pasture and scattered valley oak trees. 5/5/2022 Photo 8: View west at non-native annual grassland pasture & valley oak along north edge of lot #13. Structures are across Ardmore Road. 5/5/2022 Exhibit E

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DAVID WOLFF ENVIRONMENTAL, LLC MD3 INVESTMENTS – 2930 UNION ROAD DEVELOPMENT PROJECT – BIOLOGICAL RESOURCES ASSESSMENT FIGURE 7 – REPRESENTATIVE PHOTOGRAPHS
BIOLOGICAL & WETLAND RESOURCES ASSESSMENTS – REGULATORY COMPLIANCE SPECIALIST Photo 9: View west at lot #13 non-native annual grassland pasture. West property boundary along fence in background (arrow). 5/5/2022 Photo 10: View west along south edge of lot #13 property boundary where non-jurisdictional swale enters property (arrow). 5/5/2022 Photo 11: View west at non-jurisdictional swale running across southwest corner of lot #13 to culverts on/under adjacent property (arrow). 5/5/2022 Photo 12. View west at non-jurisdictional swale after grazing showing lack of any ordinary highwater mark (OHWM). 6/23/2022
Exhibit E

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DAVID WOLFF ENVIRONMENTAL, LLC MD3 INVESTMENTS – 2930 UNION ROAD DEVELOPMENT PROJECT – BIOLOGICAL RESOURCES ASSESSMENT FIGURE 7 – REPRESENTATIVE PHOTOGRAPHS
BIOLOGICAL & WETLAND RESOURCES ASSESSMENTS – REGULATORY COMPLIANCE SPECIALIST Photo13: View southeast at wetland determination data point DP-1 (arrow) at end of non-jurisdictional swale. 5/5/2022
Photo 14: View southeast at DP-1 (arrow) at end of non-jurisdictional swale after grazing showing lack of any basin topography. 6/23/2022 Photo 15: View south at DP-2 (arrow) upland data point and DP-1 (shovel) at end of non-jurisditinal swale. 5/5/2022
Photo 16. View north after grazing at DP-2 (arrow) upland point and DP-1 (shovel) at end of non-jurisditinal swale. No OHWM. 6/23/2022 Exhibit E

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DAVID WOLFF ENVIRONMENTAL, LLC MD3 INVESTMENTS – 2930 UNION ROAD DEVELOPMENT PROJECT – BIOLOGICAL RESOURCES ASSESSMENT FIGURE 7 – REPRESENTATIVE PHOTOGRAPHS
BIOLOGICAL & WETLAND RESOURCES ASSESSMENTS – REGULATORY COMPLIANCE SPECIALIST Photo 17: View west at DP-3 (arrow) in non-jurisdictional swale. 5/5/2022
Photo 18: View southeast at DP-3 (arrow) after grazing in nonjurisdictional swale. No OHWM. 6/23/2022 Photo 19: View southeast at non-jurisdictional swale after grazing showing no OHWM. 6/23/2022
Photo 20. View southeast across adjacent property where nonjurisdictional swale enters the project site. 5/5/2022 Exhibit E

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

APPENDIX B
TABLES
TABLE B-1: FLORISTIC INVENTORY PLANT SPECIES OBSERVED
TABLE B-2: CNDDB SPECIAL-STATUS SPECIES
Exhibit E

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

FLORISTIC INVENTORY AND RARE PLANT SURVEY SPECIES OBSERVED DWE SURVEYS: MAY 5, 2022, JUNE 23, 2022

SCIENTIFIC NAME COMMON NAME
Amsinckia intermedia Common fiddleneck
Anthemis cotula Mayweed
Bromus diandrus Rip gut brome
Bromus hordeaceus Soft chess
Bromus rubens Red brome
Deinandra fasciculata Clustered tarweed
Festuca perennis Italian rye grass
Erodium botrys Filaree
Erodium cicutarium Redstem filaree
Eryngium vaseyi Coyote thistle
Festuca perennis Italian rye grass
Hirschfeldia incana Short podded mustard
Hordeum jubatum Squirreltail barley
Hordeum marinum ssp. gussoneanum Mediterranean barley
Hordum murinum ssp. leporinum Foxtail barley
Plagiobothrys stipitatus Stalked popcorn flower
Psilocarphus tenellus Woolly marbles
Quercus lobata Valley oak
Rumex crispus Curly dock
Exhibit E

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2930 Union Road
Biological Resources Assessment
Table B-2
CNDDB Special-Status Species Recorded Occurrences
(5-mile Radius; July 2022)
Scientific Name Common Name
Federal
Status State Status
CNPS
Rare Plant
Rank General Habitat Description Micro Habitat Description Potential to Occur
Onsite
Agelaius tricolor tricolored blackbird None Threatened -- Highly colonial species, most numerous in Central Valley & vicinity. Largely endemic to California.

Requires open water, protected nesting substrate, and
foraging area with insect prey within a few km of the
colony.

No suitable wetland
habitat onsite.

Aquila chrysaetos golden eagle None Fully Protected --
Rolling foothills, mountain areas, sage-juniper flats, and desert.

Cliff-walled canyons provide nesting habitat in most parts of range; also, large trees in open areas. low / foraging only Vireo bellii pusillus least Bell's vireo Endangered Endangered -- Summer resident of Southern California in low riparian in vicinity of water or in dry river bottoms; below 2000 ft.

Nests placed along margins of bushes or on twigs projecting into pathways, usually willow, Baccharis, mesquite.

No suitable riparian
habitat onsite.

Anniella pulchra northern California legless lizard None Species of
Special Concern -- Sandy or loose loamy soils under sparse vegetation.

Soil moisture is essential. They prefer soils with a high moisture content.

No suitable friable
soils onsite.

Emys marmorata western pond turtle None
Species of
Special Concern --
A thoroughly aquatic turtle of ponds, marshes, rivers,
streams and irrigation ditches, usually with aquatic
vegetation, below 6000 ft elevation.

Needs basking sites and suitable (sandy banks or grassy open fields) upland habitat up to 0.5 km from water for egglaying.

No suitable wetland
habitat onsite.

Spea hammondii western spadefoot None
Species of
Special Concern --
Occurs primarily in grassland habitats, but can be found in valley-foothill hardwood woodlands. Vernal pools are essential for breeding and egg-laying.

No suitable ponded
wetland habitat
onsite.

Vulpes macrotis mutica San Joaquin kit fox Endangered Threatened -- Annual grasslands or grassy open stages with scattered
shrubby vegetation.

Need loose-textured sandy soils for burrowing, and suitable prey base. Often associated with ground squirrel burrows.

Low. Not observed
in area for more
than 10 years.

Branchinecta lynchi vernal pool fairy shrimp Threatened None -- Endemic to the grasslands of the Central Valley, Central Coast mountains, and South Coast mountains, in astatic rainfilled pools.

Inhabit small, clear-water sandstone-depression pools and grassed swale, earth slump, or basalt-flow depression pools.

No suitable ponded
wetland habitat
onsite.

Polyphylla nubila Atascadero June beetle None None --
Known only from inland sand dunes in San Luis Obispo
County.

No suitable sandy
dune habitat onsite.

Trimerotropis occulens Lompoc grasshopper None None --
Known only from Santa Barbara and San Luis Obispo
counties. Rocky gravelly habitats
No suitable habitat
onsite.

Antirrhinum ovatum oval-leaved snapdragon None None 4.2 Chaparral, cismontane woodland, pinyon and juniper
woodland, valley and foothill grassland.

From open hillsides to small vernal pools in clay or gypsum soils w/in grassland or woodland. Sites often alkaline. 200- 1000 m.

Not observed
during DWE rare
plant survey.

Castilleja densiflora var. obispoensis San Luis Obispo owl's-clover None None 1B.2 Valley and foothill grassland, meadows and seeps. Heavy clay soils; sometimes on serpentine. 9-485 m.

Not observed
during DWE rare
plant survey.

Caulanthus lemmonii Lemmon's jewelflower None None 1B.2 Pinyon and juniper woodland, valley and foothill grassland. 75-1585 m.

Not observed
during DWE rare
plant survey.

Juncus luciensis Santa Lucia dwarf rush None None 1B.2
Vernal pools, meadows and seeps, lower montane
coniferous forest, chaparral, Great Basin scrub.

Vernal pools, ephemeral drainages, wet meadow habitats
and streamsides. 280-2035 m.

Not observed
during DWE rare
plant survey.

Lepidium jaredii ssp. jaredii Jared's pepper-grass None None 1B.2 Valley and foothill grassland.

Alkali flats and sinks. Sandy, alkaline, sometimes adobe soils. 335-1005 m.

Not observed
during DWE rare
plant survey.

Monolopia gracilens woodland woollythreads None None 1B.2 Chaparral, valley and foothill grassland, cismontane
woodland, broadleafed upland forest, North Coast
coniferous forest.

Grassy sites, in openings; sandy to rocky soils. Often seen on serpentine after burns, but may have only weak affinity to serpentine. 120-975 m.

Not observed
during DWE rare
plant survey.

Navarretia nigelliformis ssp. radians shining navarretia None None 1B.2 Cismontane woodland, valley and foothill grassland, vernal pools.

Apparently in grassland, and not necessarily in vernal pools. 60-975 m.

Not observed
during DWE rare
plant survey.

BIRDS

REPTILES / AMPHIBIANS

MAMMALS

INVERTEBRATES
PLANTS
Exhibit E

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

APPENDIX C

WETLAND DETERMINATION DATA SHEETS
Exhibit E

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US Army Corps of Engineers Arid West – Version 2.0
WETLAND DETERMINATION DATA FORM – Arid West Region
Project/Site: City/County: Sampling Date:

Applicant/Owner: State: Sampling Point:

Investigator(s): Section, Township, Range:

Landform (hillslope, terrace, etc.): Local relief (concave, convex, none): Slope (%):

Subregion (LRR): Lat: Long: Datum:

Soil Map Unit Name: NWI classification:

Are climatic / hydrologic conditions on the site typical for this time of year? Yes No (If no, explain in Remarks.) Are Vegetation , Soil , or Hydrology significantly disturbed? Are “Normal Circumstances” present? Yes No Are Vegetation , Soil , or Hydrology naturally problematic? (If needed, explain any answers in Remarks.) SUMMARY OF FINDINGS – Attach site map showing sampling point locations, transects, important features, etc.

Hydrophytic Vegetation Present? Yes No
Hydric Soil Present? Yes No
Wetland Hydrology Present? Yes No
Is the Sampled Area
within a Wetland? Yes No
Remarks:

VEGETATION – Use scientific names of plants.

Dominance Test worksheet:

Number of Dominant Species
That Are OBL, FACW, or FAC: (A)
Total Number of Dominant
Species Across All Strata: (B)
Percent of Dominant Species
That Are OBL, FACW, or FAC: (A/B)
Prevalence Index worksheet:

Total % Cover of: Multiply by:

OBL species x 1 =
FACW species x 2 =
FAC species x 3 =
FACU species x 4 =
UPL species x 5 =
Column Totals: (A) (B)
Prevalence Index = B/A =
Hydrophytic Vegetation Indicators:

Dominance Test is >50%
Prevalence Index is 3.01
Morphological Adaptations1
(Provide supporting
data in Remarks or on a separate sheet)
Problematic Hydrophytic Vegetation1
(Explain)
1 Indicators of hydric soil and wetland hydrology must
be present, unless disturbed or problematic.

Absolute Dominant Indicator
Tree Stratum (Plot size: ) % Cover Species? Status

1. 2.

3. 4.
= Total Cover
Sapling/Shrub Stratum (Plot size: )

1. 2.

3. 4.

5. = Total Cover
Herb Stratum (Plot size: )

1. 2.

3. 4.

5. 6.

7. 8.
= Total Cover
Woody Vine Stratum (Plot size: )

0.20 ac.
470 sq. ft
Eryngium vaseyi 25% Yes FACW
Plagiobothrys stipitatus 40% Yes FACW
Psilocarphus tenellus 40% Yes OBL
Rumex crispus 3% No FAC
108%
100
Swale topography evident in field and available aerial photography. Non-wetland non-jurisdictional swale. 00 3
3 100%
✔
Mesic site at end of swale at property border.

Exhibit E

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US Army Corps of Engineers Arid West – Version 2.0
SOIL Sampling Point:

Profile Description: (Describe to the depth needed to document the indicator or confirm the absence of indicators.) Depth Matrix Redox Features
(inches) Color (moist) % Color (moist) % Type1
Loc2 Texture Remarks

1 Type: C=Concentration, D=Depletion, RM=Reduced Matrix, CS=Covered or Coated Sand Grains. 2Location: PL=Pore Lining, M=Matrix.

Hydric Soil Indicators: (Applicable to all LRRs, unless otherwise noted.) Indicators for Problematic Hydric Soils3:

Histosol (A1) Sandy Redox (S5) 1 cm Muck (A9) (LRR C)
Histic Epipedon (A2) Stripped Matrix (S6) 2 cm Muck (A10) (LRR B) Black Histic (A3) Loamy Mucky Mineral (F1) Reduced Vertic (F18) Hydrogen Sulfide (A4) Loamy Gleyed Matrix (F2) Red Parent Material (TF2) Stratified Layers (A5) (LRR C) Depleted Matrix (F3) Other (Explain in Remarks) 1 cm Muck (A9) (LRR D) Redox Dark Surface (F6)
Depleted Below Dark Surface (A11) Depleted Dark Surface (F7) Thick Dark Surface (A12) Redox Depressions (F8) 3
Indicators of hydrophytic vegetation and
Sandy Mucky Mineral (S1) Vernal Pools (F9) wetland hydrology must be present, Sandy Gleyed Matrix (S4) unless disturbed or problematic.

Restrictive Layer (if present):

Type:

Depth (inches): Hydric Soil Present? Yes No
Remarks:

HYDROLOGY
Wetland Hydrology Indicators:

Primary Indicators (minimum of one required; check all that apply) Secondary Indicators (2 or more required) Surface Water (A1) Salt Crust (B11) Water Marks (B1) (Riverine) High Water Table (A2) Biotic Crust (B12) Sediment Deposits (B2) (Riverine) Saturation (A3) Aquatic Invertebrates (B13) Drift Deposits (B3) (Riverine) Water Marks (B1) (Nonriverine) Hydrogen Sulfide Odor (C1) Drainage Patterns (B10) Sediment Deposits (B2) (Nonriverine) Oxidized Rhizospheres along Living Roots (C3) Dry-Season Water Table (C2) Drift Deposits (B3) (Nonriverine) Presence of Reduced Iron (C4) Crayfish Burrows (C8) Surface Soil Cracks (B6) Recent Iron Reduction in Tilled Soils (C6) Saturation Visible on Aerial Imagery (C9) Inundation Visible on Aerial Imagery (B7) Thin Muck Surface (C7) Shallow Aquitard (D3) Water-Stained Leaves (B9) Other (Explain in Remarks) FAC-Neutral Test (D5) Field Observations:

Surface Water Present? Yes No Depth (inches):

Water Table Present? Yes No Depth (inches):

Saturation Present? Yes No Depth (inches):
(includes capillary fringe)
Wetland Hydrology Present? Yes No
Describe Recorded Data (stream gauge, monitoring well, aerial photos, previous inspections), if available:

Remarks:

DP-1
0-3 10YR 4/2 100% NONE Loam No redox features
3-6 10YR 4/2 100% NONE Loam No redox features
6-17 10YR 3/2 100% NONE Loam No redox features
None
Loam soils with no redox features.
✔
✔
✔
✔
✔
✔
Swale topography. No other secondary indicators and no OHWM.

Exhibit E

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US Army Corps of Engineers Arid West – Version 2.0
WETLAND DETERMINATION DATA FORM – Arid West Region
Project/Site: City/County: Sampling Date:

Applicant/Owner: State: Sampling Point:

Investigator(s): Section, Township, Range:

Landform (hillslope, terrace, etc.): Local relief (concave, convex, none): Slope (%):

Subregion (LRR): Lat: Long: Datum:

Soil Map Unit Name: NWI classification:

Hydrophytic Vegetation Present? Yes No
Hydric Soil Present? Yes No
Wetland Hydrology Present? Yes No
Is the Sampled Area
within a Wetland? Yes No
Remarks:

VEGETATION – Use scientific names of plants.

Dominance Test worksheet:

Total % Cover of: Multiply by:

OBL species x 1 =
FACW species x 2 =
FAC species x 3 =
FACU species x 4 =
UPL species x 5 =
Column Totals: (A) (B)
Prevalence Index = B/A =
Hydrophytic Vegetation Indicators:

Absolute Dominant Indicator
Tree Stratum (Plot size: ) % Cover Species? Status

1. 2.

3. 4.
= Total Cover
Sapling/Shrub Stratum (Plot size: )

1. 2.

3. 4.

5. = Total Cover
Herb Stratum (Plot size: )

1. 2.

3. 4.

5. 6.

7. 8.
= Total Cover
Woody Vine Stratum (Plot size: )

1. 2.
= Total Cover
% Bare Ground in Herb Stratum % Cover of Biotic Crust
Hydrophytic
Vegetation
Present? Yes No
Remarks:
2930 Union Road Development Project Paso Robles, San Luis Obispo May 5, 2022 MD3 Investments CA DP-2
David Wolff, DWE Principal Ecologist S26 T26S R12E
Upland Terrace Level 0-2%
LRR C 35.638104 -120.652409 NAD 1983
San Ysidro loam, 0 to 2 percent slopes (197) None
✔
✔
✔
✔
✔ ✔
500 sq. ft
Bromus hordeaceus 85% Yes FACU
Hordeum marinum ssp. gussoneanum 25% Yes FAC
Bromus rubens 5% No UPL
Eryngium vaseyi 10% No FACW
125%
Upland data point above non-wetland non-jurisdictional swale. 00 1
2 50%
✔
Not greater than 50% dominance by wetland indicator species. Upland data point Exhibit E

Page 312 of 1344 ends

US Army Corps of Engineers Arid West – Version 2.0
SOIL Sampling Point:

1 Type: C=Concentration, D=Depletion, RM=Reduced Matrix, CS=Covered or Coated Sand Grains. 2Location: PL=Pore Lining, M=Matrix.

Hydric Soil Indicators: (Applicable to all LRRs, unless otherwise noted.) Indicators for Problematic Hydric Soils3:

Restrictive Layer (if present):

Type:

Depth (inches): Hydric Soil Present? Yes No
Remarks:

HYDROLOGY
Wetland Hydrology Indicators:

Surface Water Present? Yes No Depth (inches):

Water Table Present? Yes No Depth (inches):

Remarks:

DP-2
0-3 10YR 3/2 100% NONE Loam No redox features
3-10 10YR 3/2 100% NONE Loam No redox features
None
Loam soils with no redox features.
✔
✔
✔
✔
✔
Data point above swale topography. No indicators of wetland hydrology Exhibit E

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US Army Corps of Engineers Arid West – Version 2.0
WETLAND DETERMINATION DATA FORM – Arid West Region
Project/Site: City/County: Sampling Date:

Applicant/Owner: State: Sampling Point:

Investigator(s): Section, Township, Range:

Landform (hillslope, terrace, etc.): Local relief (concave, convex, none): Slope (%):

Subregion (LRR): Lat: Long: Datum:

Soil Map Unit Name: NWI classification:

Hydrophytic Vegetation Present? Yes No
Hydric Soil Present? Yes No
Wetland Hydrology Present? Yes No
Is the Sampled Area
within a Wetland? Yes No
Remarks:

VEGETATION – Use scientific names of plants.

Dominance Test worksheet:

Total % Cover of: Multiply by:

OBL species x 1 =
FACW species x 2 =
FAC species x 3 =
FACU species x 4 =
UPL species x 5 =
Column Totals: (A) (B)
Prevalence Index = B/A =
Hydrophytic Vegetation Indicators:

Absolute Dominant Indicator
Tree Stratum (Plot size: ) % Cover Species? Status

1. 2.

3. 4.
= Total Cover
Sapling/Shrub Stratum (Plot size: )

1. 2.

3. 4.

5. = Total Cover
Herb Stratum (Plot size: )

1. 2.

3. 4.

5. 6.

7. 8.
= Total Cover
Woody Vine Stratum (Plot size: )

1. 2.
= Total Cover
% Bare Ground in Herb Stratum % Cover of Biotic Crust
Hydrophytic
Vegetation
Present? Yes No
Remarks:
2930 Union Road Development Project Paso Robles, San Luis Obispo May 5, 2022 MD3 Investments CA DP-3
David Wolff, DWE Principal Ecologist S26 T26S R12E
Upland Terrace Level 0-2%
LRR C 35.638003 -120.652354 NAD 1983
San Ysidro loam, 0 to 2 percent slopes (197) None
✔
✔
✔
✔
✔ ✔
500 sq. ft
Hordeum marinum ssp. gussoneanum 65% Yes FAC
Hordeum jubatum 35% Yes FAC
Erodium cicutarium 20% Yes OBL
120%
Swale topography evident in field and available aerial photography. Non-wetland non-jurisdictional swale. 00 2
3 66%
✔
Swale with dominance of FAC grasses.

Exhibit E

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US Army Corps of Engineers Arid West – Version 2.0
SOIL Sampling Point:

1 Type: C=Concentration, D=Depletion, RM=Reduced Matrix, CS=Covered or Coated Sand Grains. 2Location: PL=Pore Lining, M=Matrix.

Hydric Soil Indicators: (Applicable to all LRRs, unless otherwise noted.) Indicators for Problematic Hydric Soils3:

Restrictive Layer (if present):

Type:

Depth (inches): Hydric Soil Present? Yes No
Remarks:

HYDROLOGY
Wetland Hydrology Indicators:

Surface Water Present? Yes No Depth (inches):

Water Table Present? Yes No Depth (inches):

Remarks:

DP-3
0-3 10YR 3/2 100% NONE Loam No redox features
3-10 10YR 3/2 100% NONE Loam No redox features
None
Loam soils with no redox features.
✔
✔
✔
✔
✔
✔
Swale topography. No other secondary indicators and no OHWM.

Exhibit E

Page 315 of 1344 ends

1343 Bishop Street, San Luis Obispo, CA 93401
Tel: 805 234 8760 Email: [email protected] August 17, 2022 To: Michael Stoltey – MD3 Investments & Damien Mavis – CoVelop Re: Oak Tree Assessment report for Ardmore Road Project, 2930 Union Rd, Paso Robles, CA 93446 Gentlemen,
In response to your request for an Oak Tree Assessment for trees growing on a lot you intend to purchase and develop at 2930 Union Road, I have produced the following report.

Assignment
• Collect tree data and perform Level 2 inspection on 9 valley oaks (Quercus lobata) to determine condition and suitability for retention.
• Perform advanced Level 3 Assessment with Resistograph for 3 valley oaks. • Provide written summary of condition and suitability for retention for all 9 valley oaks.

Introduction
On August 2, 2022, I visited the site and performed a Level 2, basic assessment on all native oaks 6-inch diameter and greater on lots you intend to develop. As a result, 3 of the trees required a Level 3 advanced inspection with a Resistograph, wood density measuring device. I returned to the site on August 5, 2022, and performed the advanced inspections with a Resistograph to measure wood density.

On August 12, 2022, I collected additional data for tree #2 via a climbing inspection. I analyzed data collected during the advanced inspections and have made recommendations regarding tree condition, tree risk and potential for retention. All tree inspections were based on the potential for a tree to fail within the next 5 years from the date of this report. Any tree retained should be re-inspected on an annual basis to determine health and structural integrity status.

MethodologyMy initial level 2 inspection consisted of a ground based, visual inspection and full walk around of the tree. I used a rubber mallet to sound the trunk to detect decay. I tagged each tree with an aluminum tag and assigned it a number. Based on a previous arborist’s inspection of the trees, I assigned the same number that was listed in their report so we would have consistency when referencing the trees.

Advanced inspections consisted of Resistograph wood density testing, and in one instance, an aerial inspection that consisted of determining the extent of decay with a tape measure.

Exhibit E

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2 Tree Condition Ratings
All trees in the inventory were given a condition rating. The rating was based on the health, structure and presence of disease and insects. See the following definitions:
• Dead = Severely declining or no foliage, large dead branches, decay cavities, loss of bark, roots decayed or dead.
• Very Poor = Evidence of multiple large past failures, advanced decay, uncontrollable pest infestations or disease infection. Tree in severe decline. • Poor = Tree may be suppressed, drought stressed, or had at least 1 large branch failure.

Disease or pest infestations may be present. Can potentially be retained with attention to mitigation pruning, cultural care changes, pest and disease control. • Fair = May have had minor past failures. Some pests or structural defects may be present, small deadwood. Minor to moderate drought stress present. Defects may be mitigated with pruning and pests can be controlled.
• Good = A relatively healthy tree with minor to no structural defects with minimal to no pest observed. Defects can be mitigated with pruning and pests can be controlled. • Very Good = Trees that have had professional arboricultural care. No structural defects, disease or pests identified.
• Excellent = Specimen tree with superior form, root structure and health. Tree has been regularly cared for by professional arborists over its lifetime, E.g., estate or arboretum tree.

Inspection Levels
Level 1 – Limited Visual Inspection – This is a limited walk-by or drive-by, which does not typically include a complete walk around a tree. The inspection focuses on obvious defects, imminent or probable likelihood of failures. There are generally no tools used at this level. This is the fastest and least thorough assessment.

Level 2 – Basic Assessment – Generally includes a complete walk around inspection. Basic tools such as probes, measuring devices, binoculars, mallet or magnifying glass are used. At this level, an aerial inspection is not included. A Level 2 assessment is usually necessary to establish the need for a Level 3 assessment.

Level 3 – Advanced Inspection – Detailed inspection which usually employs the use of special equipment, data collection and analysis. A higher level of training is also required, such as International Society of Arboriculture (ISA) Tree Risk Assessment Qualification. Specialized equipment may include an Air Spade (device that uses compressed air to expose roots or root crown for inspections without causing damage to sensitive plant tissues). Resistograph (drilling devise used to measure and graph wood density) Level 3 inspections may also include sending samples to labs for analysis. A Level 3 inspections will usually take place later because of time needed to perform a Level 2 inspection.

Assessing Tree Structure and Potential to Fail
Estimating the structural integrity of trees is a challenge because, unlike steel I-beams or other construction materials there is no precise engineering standard to help determine the load a tree can withstand.

Exhibit E

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3 Arborists must use measurement of decay, experience with previous, similar trees as well as factor in the various stressors on the compromised areas within the tree. Trees with thicker outer shells are going to be stronger. Oval internal decay areas and areas of decay that have broken through the outer shell of the trunk or branch will be weaker due to the inconsistency of the cylinder.

Tree Risk
Tree risk is determined by identifying the targets e.g. (people, buildings, cars or property) that could be injured or damaged by a whole or partial tree failure, the occupancy rate, exposure of the target to the tree hazard, the size of part of the tree that may impact the target if it were to fail, the likelihood of impact on the target, and the consequences of failure on the target.

The part of the tree most likely to fail and cause the largest impact is used to determine the highest overall risk for the tree.

When considering likelihood of failure, the definitions are as follows:
• Imminent – Failure has started or most likely to occur in the near future. Even if there is no significant wind or increased load. The imminent category overrides the time frame stated in the scope of work.
• Probable – Failure may be expected under normal weather conditions within the specified time frame.
• Possible – Failure may be expected in extreme weather conditions, but is unlikely during normal weather conditions during a specified time frame. • Improbable – The tree or part is not likely to fail during normal weather conditions and may not fail in extreme weather conditions within the specified time frame.

Risk Matrices
I used the International Society of Arboriculture’s Basic Tree Risk Assessment Form to determine risk. Matrix 1 the “Likelihood Matrix” determines the likelihood of failure and impact. The result is entered into Matrix 2, the “Risk Rating Matrix” which factors in Consequences of Failure to get the overall risk rating. In the example below, Likelihood of failure of a part was Probable. The Likelihood of Impact was High. The result was Likely. In Matrix 2, I entered the result of Likely and entered Severe in the Consequences of Failure which gave me a risk rating of High.

Exhibit E

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4 For each tree requiring a level 3 inspection, I have highlighted matrix tables to show how risk was determined for the part or parts of the tree being considered regarding failure potential.

Mitigation
When assessing risk for a tree, it is important to determine if the risk of tree failure can be reduced through mitigation. Mitigation can be made through pruning, installing cabling or bracing support structures. Moving targets out of the strike zone of a tree or restricting access to a tree are also viable mitigation measures. The recommended mitigation should not be so excessive that they compromise the health of the tree.

Tree Assessments
I performed level 2 assessments on trees 1,2,3,4,9,10,11 & 13. See Tree Map Appendix B. From those assessments, I determined that trees 1,2 and 13 required level 3 advanced inspections. Each assessment below includes a condition rating as well as potential for retention and mitigation recommendations. For level 3 inspections, I included a tree risk assessment matrix.

Tree 1 – A 43” diameter valley oak was in Very Poor condition. See Appendix A - Photographs - Photo 1
Basic Level 2 Inspection –
This tree had drought stress which was indicated by dead wood in the canopy. It also had decay throughout its scaffold branches which was indicated by decay cavities and woodpecker nests excavated in dead wood. See Appendix A - Photographs - Photos 1 & 4.

The trunk had an approximate lean to the east of 10 degrees. It also had a horizontal compression bulge on the east side of its trunk approximately 1’ above ground. Compression bulges or wrinkles, indicate that wood fibers are being crushed by the weight of the canopy and trunk due to lack of supportive structure in the trunk. Further the tree had a large, decayed, anchor root on its southwest side. The root was on the opposing side of the lean of the tree and is likely to fail as decay advances and stress from the weight of the canopy continues to build.

See Appendix A -Photographs - Photos 1-3.

Although this tree had a full canopy it has significant trunk decay. When I sounded the trunk with a rubber mallet, it resounded hollow on all sides. To further confirm the sounding results, I performed an advanced inspection of the decay using a Resistograph.

Advanced Level 3 Inspection -
I took 4 measurements of the wood density of the trunk at 3.5’ above ground. o Sample 1 – west side of tree. Outer shell thickness was 4” o Sample 2 – south side of tree. Outer shell thickness was 6” o Sample 3 – east side of tree. Outer shell thickness was 4” with a small 1.25” pocket of sound wood at 8” laterally, then total decay
Exhibit E

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5 o Sample 4 – north side of tree. Outer shell thickness was 5.25” Based on the Resistograph results, it was apparent that interior wood of the trunk is significantly decayed. The evidence of compression bulges showed that the trunk is losing structural integrity and leaning due to lack of supportive wood fibers.

Armillaria mellea, a.k.a. Oak root fungus is a common disease in valley oaks and is likely the cause of the decay in the roots and the trunk. Christopher J. Luley in his guide Wood Decay Fungi calls this fungus Number one of the “Big Three” of the important decay fungi. Again, according to Mr. Luley, “Armillaria is a root and butt rot fungus that increases the risk of tree failure and is a pathogen capable of killing cambium of roots and lower trunk of stressed trees”.

See Appendix A - Photographs - Photos 29 & 30 for example of failed oak due to root and butt rot.

Parts Assessed – Roots and Trunk

I used the International Society of Arboriculture’s Basic Tree Risk Assessment Form to determine risk for this tree. In Matrix 1 the “Likelihood Matrix” I selected Likelihood of Failure of the roots and trunk as Probable. The Likelihood of impacting a target in a built environment would be High. The resulting Likelihood of Impact was Likely, which I entered into Matrix 2, the “Risk Rating Matrix” in the Likelihood of Failure and Impact section. For the Consequences of Failure section of Matrix 2, I entered Severe. The Likelihood of Failure and Impact rating combined with the Consequences of Failure resulted in a risk rating of High.

Part Assessed – Scaffold Branches
In Matrix 1 the “Likelihood Matrix” I selected Likelihood of Failure of the scaffold branches as Probable. The Likelihood of impacting a target in a built environment would be High. The resulting Likelihood of Impact was Likely, which I entered into Matrix 2, the “Risk Rating Matrix” for the Likelihood of Failure and Impact section. Under Consequences of Failure in Matrix 2, I entered Severe. The Likelihood of Failure and Impact rating combined with the Consequences of Failure resulted in a risk rating of High.

Exhibit E

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6 Combined Inspection Results and Risk Assessment
The highest risk rating for this tree was High and was associated with root and trunk failure. I found decay in one anchor root and significant decay was detected in the trunk. Buckling of trunk fibers was evident. Based on shell strength measurements, the likelihood of trunk failure was probable, due to lack of structural integrity. Root failure was Probable due to significant decay in the anchor root on the southwest side of the tree. Scaffold failure was also probable with a high likelihood of failure.

Mitigation:

Scaffolds - Reducing the canopy through end weight reduction and removing decayed branches 2” diameter and larger would relieve some stress on remaining scaffold branches and reduce their risk to Moderate.

Roots and Trunk - Reducing the canopy through end weight reduction would relieve some stress on the trunk but not enough to offset the overall stress being exerted on the buckling area on the north side of the tree. No structural support or bracing will help the stability of the tree’s trunk or roots. Significant decay has been detected in the roots as well as the trunk. Based on shell strength measurements, lean of the tree and buckling of wood fibers on the east side of the trunk made failure likely due to lack of structural integrity. I recommend removing the tree before commencement of construction.

Tree 2 – A 47” diameter valley oak was in Poor condition. See Appendix A - Photographs - Photo 5.

Basic Level 2 Inspection –
On the south side of the trunk there was a decay cavity originating at the root-crown and extending approximately 5.5’ upward. When sounded with a rubber mallet on either side of the cavity, it resounded hollow. Moving around the trunk to the east side, I detected another hollow sounding area with my mallet at approximately 3.5’ above ground. See Appendix A - Photographs - Photo 6. Like Tree 1, I suspect Armillaria mellea - Oak root fungus, is the cause of the rot.

Exhibit E

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7 At approximately 8 feet above ground, on the southwest side of the trunk there was another decay area that was almost closed over with scar tissue. Although almost closed, I suspected a large area of decay behind the scar. See Appendix A - Photographs – Photo 7. There was a large scaffold branch attached to the trunk above the scar. It had a desiccated fungal fruiting body growing on it and cankers had killed strips of bark near the fungus. See Appendix A - Photographs – Photo 8. I identified the fungi genus to be that of Inonotus. Jessie A. Glaeser and Kevin T. Smith in the winter 2010 issue of Western Arborist, note this fungus to cause a whiterot of heartwood in the trunk of living oaks and also decays strips or sections of sapwood, forming elongate cankers and killing the cambium. According to Swiecki, T. J.; Bernhardt, E. A. 2006, A Field Guide to Insects and Diseases of California Oaks, “Inonotus dryophilus is one of the most serious pathogens of living oaks in California associated with decline, failure, and mortality”. In this tree, the combined weakened trunk area at the scar combined with the heavy, decayed scaffold branch make this section of the tree likely to fail.

In the upper canopy at approximately 14’ above ground there was another decay cavity in the center of the canopy, where a large scaffold branch had failed many years ago. I suspected advanced decay in the trunk at this location. See Appendix A - Photographs - Photo 9 Advanced Level 3 Inspection -
During the aerial inspection, it was discovered that the opening of the decayed scaffold in the upper canopy was 13” in diameter. The depth of the cavity was 13’2” deep. When the distance to the ground from the outside of the cavity was measured, it was 14’3”, which illustrated that the entire trunk of the tree was hollow. See Appendix A - Photographs – Photos 9 -14.

From the cavity opening, the decay continued upward into the scaffold branch growing east.

This scaffold is very likely to fail due to weak trunk structure. See Appendix A - Photographs – Photo 12.

Based on the decay detected during mallet sounding, I wanted to investigate the extent of the decay further. I performed an advanced inspection for decay using a Resistograph. I took 6 measurements of the wood density of the trunk at 3.5’ above ground unless otherwise indicated.
o Sample 1 – west side of tree. Outer shell thickness was 8” o Sample 2 – south side of tree, 1’ west of decay cavity, outer shell thickness was 8.5” o Sample 3 – south side of tree at decay cavity seam, outer shell thickness was 3” at 3’ above ground.
o Sample 4 – south side of tree, 1’ east of decay cavity, outer shell thickness was 7.25” o Sample 5 – east side of tree, outer shell thickness was 5.5” o Sample 6 – north side of tree, outer shell thickness was 12” I have highlighted the tables below to show how risk was determined for the part or parts of the tree that was being considered regarding failure potential.

I used the International Society of Arboriculture’s Basic Tree Risk Assessment Form to determine risk for this tree.

Exhibit E

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8 Part Assessed - Trunk
In Matrix 1 the “Likelihood Matrix” I selected Likelihood of Failure of the trunk as Probable.

The Likelihood of impacting a target in a built environment would be High. The resulting Likelihood of Impact was Likely, which I entered into Matrix 2, the “Risk Rating Matrix” in the Likelihood of Failure and Impact section. Under Consequences of Failure in Matrix 2, I entered Severe. The Likelihood of the Failure and Impact rating combined with the Consequences of Failure resulted in a risk rating of High.

Combined Inspection Results and Risk AssessmentThe highest risk rating for this tree was High and was associated with trunk and scaffold branch failure. Significant decay was detected in the trunk and eastern scaffold branch.

Exhibit E

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9 Based on shell strength measurements, and the void caused by decay on the south side of the tree, the trunk is likely to fail due to lack of structural integrity. In regard to the eastern scaffold branch and other decayed branches, they could be removed, and end-weight could be reduced to relieve some stress on remaining scaffold branches. However, the reduction of the canopy would be close to 50% and would compromise the health of the tree. Further, since the trunk is not structurally sound, this negates the mitigation measure.

Mitigation: Remove tree before commencement of construction. No structural support or bracing will help the stability of the tree’s trunk.

Tree 3 – A 47” diameter valley oak was in Very Poor condition. When I sounded the trunk with a rubber mallet, it resounded hollow on the southwest side. A large wound left by a scaffold branch failure in the crown of the tree has since decayed and left a 3’x 4’ hollow at approximately 14’ above ground on the east side of tree. Another decay cavity on the north side of the tree at the same height as the previous, measured approximately 2’ in diameter.

Remaining scaffold was overextended and attached to the decaying trunk. The remaining parts of this tree have a high likelihood of failure. See Appendix A - Photographs – Photos 15 & 16.

Mitigation: Remove tree before commencing project.
• Tree 4 – A 52” diameter valley oak was in Very Poor condition. The tree was growing off-site but had critical root zone (CRZ) and crown encroachments into your proposed construction area.

This tree has had several large scaffold branch failures. At the failure points, significant decay was visible. The remaining scaffolds were overextended and potentially had similar internal decay and had a high likelihood of failure. See Appendix A - Photographs – Photo 17.

Mitigation: I highly recommend removal of this tree due to the advancement of decay in the scaffold branches which is compromising their structural integrity. Crown reduction needed to reduce the risk of scaffold branches failing would take up to 50% of the live canopy and jeopardize the tree’s health. Because this tree is off site, you will need to coordinate with the owner regarding removal.

At minimum this tree should have all overextended branches reduced to help prevent further failures and protect any buildings or other targets you may place on your property within striking distance of the tree. If the owner of the tree chooses to retain it, you will need to design buildings, service and loading zones outside of the CRZ. • Tree 9 – A 51” diameter valley oak was in Very Poor condition. Multiple large scaffold branches had failed. Extensive decay was present at branch failure points. Only 2 overextended scaffold branches remain, and they are connected to a decaying trunk.

When I sounded the trunk with a rubber mallet, it resounded hollow. A 3’ long by 10” wide decay cavity was on the northeast side of trunk. This tree has a high risk of complete failure. See Appendix A - Photographs – Photos 18 & 19.

Mitigation: Remove tree before commencing project.

Exhibit E

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10 • Tree 10 – A 51” diameter valley oak was in Good condition. The trunk of the tree resounded solid when sounded with a rubber mallet. Tree form was good, but there was some large dead wood and decaying scaffolds. This tree can be retained, but it should have maintenance pruning performed prior to commencement of your project. See Appendix A - Photographs – Photos 20 & 21.

Mitigation: Reduce end-weight on overextended branches. Remove dead wood 2” diameter and larger. Remove decayed and structurally unsound scaffold branches. • Tree 11 – A 30” diameter valley oak was in Very Poor condition. The tree was in severe decline due to drought stress and root disease. Many of the smaller branches had died. I detected decay at the root crown on the southwest side of the tree. I found an ant nest at the root-crown decay area indicating ants are excavating and nesting in dead roots and root crown.

The dead roots contribute to the decline of the canopy and compromise the stability of the tree.

At least five, 12” average diameter scaffolds had extensive decay on the east side of the tree. To reduce scaffold failure risk, up to 50% of the live canopy would need to be removed, which would compromise the health of and already unhealthy tree. See Appendix A - Photographs – Photos 22-24.

Mitigation: Remove tree prior do commencement of project. • Tree 13 – A 42” diameter valley oak was in Poor condition.

Basic Level 2 Inspection –
The tree had a full canopy with a balanced form. On the south side of the tree at the root crown, there was an area of decay in the underside of one of the anchor roots. Like trees 1 and 2, the decay is likely caused by Armillaria mellea. I also noted the lower trunk was bulging and larger than normal which may indicate butt-rot caused by A. mellea. Further, I observed that the eastern scaffold branch was decayed, and large dead wood was present throughout the canopy.

See Appendix A - Photographs – Photos 25 - 28.

A previous report, by another arborist, expressed concern that a scar at the base of the tree might indicate decay and structural instability. When I sounded the tree’s trunk with a rubber mallet, it resounded solid, except on the north side of the trunk. Due to the difference of opinion regarding the structural integrity of the trunk, I performed an advanced inspection for decay using a Resistograph.

Advanced Level 3 Inspection -
I took 5 measurements of the wood density of the trunk at 3.5’ above ground. o Sample 1 – west side of tree. Outer shell thickness was 7” o Sample 2 – south side of tree. Outer shell thickness was 8.5” o Sample 3 – east side of tree. Outer shell thickness was 8.5” o Sample 4 – east side of tree scarred area on east side of trunk approximately 1’ above ground. Outer shell thickness was 12”.

Exhibit E

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11 o Sample 5 – north side of tree. Outer shell thickness was 5” Like Tree 1, the trunk of this tree had advanced internal decay, however when comparing outer shell thickness, this specimen had thicker walls and did not have indications of trunk fibers buckling, therefore its structural integrity is likely stronger.

Tree Risk - I used the International Society of Arboriculture’s Basic Tree Risk Assessment Form to determine the risk. I used Matrix 1 the “Likelihood Matrix” on the form and entered the result into Matrix 2, the “Risk Rating Matrix” to get the overall risk rating.

I have highlighted the tables below to show how risk was determined for the part or parts of the tree that was being considered regarding failure potential.

Part Assessed - Root

In Matrix 1 the “Likelihood Matrix” I selected Likelihood of Failure of the roots as Possible.

The Likelihood of impacting a target in a built environment would be High. The resulting Likelihood of Impact was Somewhat Likely, which I entered into Matrix 2, the “Risk Rating Matrix” for the Likelihood of Failure and Impact section. Under Consequences of Failure in Matrix 2, I entered Severe. The Likelihood of Failure and Impact rating combined with the Consequences of Failure resulted in a risk rating of Moderate.

Part Assessed – Trunk
In Matrix 1 the “Likelihood Matrix” I selected Likelihood of Failure of the scaffold branches as Probable. The Likelihood of impacting a target in a built environment would be High. The resulting Likelihood of Impact was Likely, which I entered into Matrix 2, the “Risk Rating Matrix” for the Likelihood of Failure and Impact section. Under Consequences of Failure in Matrix 2, I entered Severe. The Likelihood of Failure and Impact rating combined with the Consequences of Failure resulted in a risk rating of High.

Exhibit E

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12 Part Assessed – Scaffold Branches
In Matrix 1 the “Likelihood Matrix” I selected Likelihood of Failure of the scaffold branches as Probable. The Likelihood of impacting a target in a built environment would be High. The resulting Likelihood of Impact was Likely, which I entered into Matrix 2, the “Risk Rating Matrix” for the Likelihood of Failure and Impact section. Under Consequences of Failure in Matrix 2, I entered Severe. The Likelihood of Failure and Impact rating combined with the Consequences of Failure resulted in a risk rating of High.

Combined Inspections Results and Risk AssessmentThe highest risk rating for this tree was High and was associated with scaffold and trunk failure. I found decay in one anchor root and significant decay was detected in the trunk, however no bulging of trunk fibers was evident. Based on shell strength measurements, the likelihood of trunk failure is probable due to lack of structural integrity. Scaffold failure was also probable.

Risk of root failure remained moderate.

Mitigation:

Mitigations are meant to reduce risk without compromising the health of the tree. Ultimately, the tree manager, owner or other controlling entity must decide if the residual risk assessed is reasonable.

Exhibit E

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13 Scaffolds - Reducing the canopy through end weight reduction and removing decayed and branches 2” diameter and larger will relieve some stress on remaining scaffold branches and reduce their risk to Moderate.

Roots - Reducing the canopy through end weight reduction will relieve some stress on roots, however due to the overall weight of the canopy and stem, the risk rating for root failure will remain Moderate.

Trunk - Canopy reduction will relieve some stress on the trunk of the tree, however it will not likely be enough to lower trunk failure risk to moderate. If this tree is to be retained, and the goal is to reduce the risk rating, the only reasonable way to achieve that goal will be to restrict access by installing a permanent fence around it. The fence shall be a minimum of 4.5’ tall and be set at least to the edge of the canopy dripline. Once access is restricted, the risk rating will be Moderate.

Respectfully Submitted,
Rodney D. Thurman
ISA Board Certified Master Arborist PN-2684BUM
ISA Municipal Specialist
ISA Utility Arborist
ISA Tree Risk Assessor Qualification
Appendices: Photographs, Tree Map
Exhibit E

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14 Appendix A - Photographs

Photo 1 - View of Tree 1 to south. Note
lean to east.

Exhibit E

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15 Photo 2 - Tree 1 with decayed anchor root on southwest side, indicated by arrow. Ink pen provided for scale
Exhibit E

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16 Photo 3 - Tree 1 with compression bulge east side of trunk indicated by arrow shows lack of structural support.

Exhibit E

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17 Photo 4 - Tree 1 with decay in scaffold branches. indicated by arrows.

Exhibit E

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18 Photo 5 - View of Tree 2 to north
Exhibit E

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19 Photo 6 - Tree 2 with decay cavity south side of trunk. Length is approximately 5.5’.

Exhibit E

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20 Photo 7 - Tree 2 with decay cavity at scaffold union approx. 8’ above ground on southwest side of tree.

Exhibit E

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21 Photo 8 - Tree 2 with fungal fruiting body circled and decay in south scaffold branch indicated by arrow.

Exhibit E

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22 Photo 9 - Tree 2 with decay cavity formed by failed scaffold circled at center of tree, approximately 14 feet above ground.

Exhibit E

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23 Photo 10 - Tree 2 perspective view of decay cavity formed by failed scaffold circled at center of tree. Cavity is circled. Other decay points below the open cavity are indicated by arrows.

Exhibit E

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24 Photo 11 - Tree 2 view of decay cavity formed by failed scaffold.

Opening measures 13”
Exhibit E

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25 Photo 12 - Tree 2 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.
#2
#1
Exhibit E

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26 Photo 13 - Tree 2 measurement of
interior depth of decay cavity formed by
failed scaffold. 13’ 2”
Photo 14 - Tree 2 measurement of
exterior depth of decay cavity formed by
failed scaffold. 14’ 3”
Exhibit E

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27 Photo 15 - View of Tree 3 to north. Overextended scaffold to west. Large decay cavity at connection to trunk.

Exhibit E

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28 Photo 16 - Tree 3 with large decay cavity at scaffold connection to trunk.

Exhibit E

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29 Photo 17 - View of Tree 4 with to northwest. Numerous failed scaffold branches due to overextension and internal decay.

Exhibit E

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30 Photo 18 - View of Tree 9 to north. Numerous failed scaffold branches due to overextension and internal decay.

Exhibit E

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31 Photo 19 - Tree 9 close-up of failed scaffold branch with internal decay.

Exhibit E

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32 Photo 20 - View of Tree 10 to south.

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33 Photo 21 - Tree 10 with decayed scaffold branch indicated by yellow arrows.

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34 Photo 22 - View of Tree 11 to north. At least 5 decayed scaffold branches would be removed which would reduce the tree at least 50%. Arrows indicate branch removal points.

Exhibit E

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35 Photo 23 - Tree 11 close up of declining canopy, decayed branches, and dead wood indicated by arrows.

Exhibit E

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36 Photo 24 - Tree 11 close up of root crown decay at southwest side of tree indicated by yellow arrow. Ant nest discovered here which indicates dead and rotting wood.

Exhibit E

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37 Photo 25 - View of Tree 13 to north. Note overextended scaffold branches indicated by arrows.

Exhibit E

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38 Photo 26 - Tree 13 with root decay cavity on south side of tree indicated by arrow.

Exhibit E

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39 Photo 27 - Tree 13 with bulging root-crown indicating possible butt-rot.

Exhibit E

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40 Photo 28- Tree 13 with decaying scaffold branch east side of canopy indicated by arrow. Line indicates locations for removal Exhibit E

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41 Photos 29 & 30 - Example of oak tree that failed due to root and butt-rot. Photo 29 shows failed roots. Photo 30 shows internal decay of trunk.

Exhibit E

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42 Appendix B – Tree Map
Tree Locations Map – Red = removals, Green = retain and protect, Dashed line delineates property boundaries.
2 1 9
10 13
3 11
4 Home

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PHASE I ARCHAEOLOGICAL STUDY,

NEW COMMERCIAL DEVELOPMENT,
2930 UNION ROAD (LOTS 6 AND 13,
APN 025-362-043)

PASO ROBLES, SAN LUIS OBISPO COUNTY,

CALIFORNIA
Project No. 2202-2481
Prepared for:

Covelop, Inc.

P.O. Box 12910
San Luis Obispo, California 93406
Prepared by:

Rachael J. Letter, M.S., RPA and Christopher J. Letter, B.A.

Padre Associates, Inc.
369 Pacific Street
San Luis Obispo, California 93401
(805) 786-2650
July 2022

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Phase I Archaeological Study, 2930 Union Road, Lots 6 & 13 Paso Robles, San Luis Obispo County
Project No. 2202-2481
-iNATIONAL ARCHAEOLOGICAL DATA BASE INFORMATION
Authors: Rachael J. Letter, M.S., RPA and Christopher J. Letter, B.A.

Consulting firm: Padre Associates, Inc.
369 Pacific Street
San Luis Obispo, California 93401
(805) 786-2650
Report Date: July 2022
Report Title: Phase I Archaeological Study, New Commercial Development, 2930 Union Road (Lots 6 and 13, APN 025-362-043), Paso Robles, San Luis Obispo County, California
Prepared for: Covelop, Inc.

P.O. 12910
San Luis Obispo, California 93406
Prepared by: Padre Associates, Inc.
369 Pacific Street
San Luis Obispo, California 93401
(805) 786-2650
Contract No: 2202-2481
U.S.G.S. Quads: Paso Robles, California
Project Size: 14.5 acres
Key words: San Luis Obispo County, Paso Robles, Phase I Archaeological Study

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Phase I Archaeological Study, 2930 Union Road, Lots 6 & 13 Paso Robles, San Luis Obispo County
Project No. 2202-2481
-iiMANAGEMENT SUMMARY
At the request of Covelop, Inc. (Client), Padre Associates, Inc. (Padre), has completed a Phase I archaeological study in support of a new commercial development (Project) at 2930 Union Road (Lots 6 and 13 of APN 025-362-043), in Paso Robles, San Luis Obispo County, California (Project site). The scope of this document includes an archaeological records search and a Phase I pedestrian survey.

The records search did not reveal any previously recorded resources within the Project site. Padre conducted a pedestrian survey of the Project site on July 1, 2022. No cultural resources were observed within the Project site.

Proposed Project impacts will not affect cultural resources and no further archaeological study or monitoring is warranted. Padre recommends that the Project proceed as planned. In the event cultural resources are encountered during the proposed Project, Padre recommends the County cease construction activities within a 100-foot radius. Work will resume once an archaeologist who meets the U.S. Secretary of the Interior’s Historic Preservation Professional Qualification Standards for Archaeology has assessed the find and identified and implemented appropriate mitigation measures.

One copy of this report will be submitted to the Central Coast Information Center (CCIC) at the Santa Barbara Museum of Natural History. A copy of all field notes is on file at Padre’s office in San Luis Obispo, California.

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Phase I Archaeological Study, 2930 Union Road, Lots 6 & 13 Paso Robles, San Luis Obispo County
Project No. 2202-2481
-iiiTABLE OF CONTENTS

1.0 INTRODUCTION ................................................................................................................ 1-1

1.1 PROJECT LOCATION AND DESCRIPTION................................................................. 1-1

2.0 REGULATORY FRAMEWORK ......................................................................................... 2-1

2.1 STATE REGULATIONS ................................................................................................ 2-1

2.1.1 California Environment Quality Act (CEQA)............................................................ 2-1

2.1.2 California Register of Historical Resources ............................................................ 2-1

2.2 REGULATIONS CONCERNING DISCOVERY OF HUMAN REMAINS ........................ 2-2

3.0 NATURAL AND CULTURAL OVERVIEW......................................................................... 3-1

3.1 ENVIRONMENTAL SETTING........................................................................................ 3-1

3.2 ARCHAEOLOGICAL CONTEXT.................................................................................... 3-1

3.2.1 Paleo-Indian Period (c. 25,000 – c. 9950 B.P.)....................................................... 3-1

3.2.2 Millingstone Period (c. 9950 – c. 5450 B.P.)........................................................... 3-1

3.2.3 Early Period (c. 5450 – c. 2550 B.P.)...................................................................... 3-2

3.2.4 Middle Period (c. 2550 – c. 950 B.P.) ..................................................................... 3-2

3.2.5 Middle to Late Transition Period (c. 950 – c. 700 B.P.) .......................................... 3-2

3.2.6 Late Period (c. 700 – c. 181 B.P.)........................................................................... 3-3

3.3 ETHNOGRAPHIC CONTEXT ........................................................................................ 3-3

3.4 HISTORIC PERIOD CONTEXT ..................................................................................... 3-4

3.4.1 Contact Period ........................................................................................................ 3-4

3.4.2 Mission Period ........................................................................................................ 3-4

3.4.3 Rancho and Anglo-Mexican Periods....................................................................... 3-4

3.4.4 Americanization Period........................................................................................... 3-5

4.0 RECORDS SEARCH METHODS AND RESULTS............................................................ 3-1

4.1 METHODS ..................................................................................................................... 3-1

4.2 RESULTS....................................................................................................................... 3-1

5.0 FIELD SURVEY METHODS AND RESULTS.................................................................... 5-1

6.0 CONCLUSIONS AND RECOMMENDATIONS.................................................................. 6-1

7.0 REFERENCES CITED ....................................................................................................... 7-1

LIST OF FIGURES
Figure 1-1. Project Location Map................................................................................................... 1-2 Figure 5-1. Overview of Project site, facing south......................................................................... 5-1 Figure 5-2. Overview north end of Project site, facing south......................................................... 5-2 Figure 5-3. Overview of Project site, facing south......................................................................... 5-2 Figure 5-4. Overview of south end of Project site, facing south.................................................... 5-3

APPENDICES
Appendix A. Confidential Records Search Results

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Phase I Archaeological Study, 2930 Union Road, Lots 6 & 13 Paso Robles, San Luis Obispo County
Project No. 2202-2481
- 1-1 -

1.0 INTRODUCTION
At the request of Covelop, Inc. (Client), Padre Associates, Inc. (Padre), has completed a Phase I archaeological study in support of a new commercial development (Project) at 2930 Union Road (Lots 6 and 13 of APN 025-362-043) in Paso Robles, San Luis Obispo County, California (Project site).

Padre completed the Phase I Archaeological Study pursuant to the California Environmental Quality Act (CEQA) Guidelines. CEQA requires lead agencies to evaluate proposed projects for their potential to impact archaeological resources (Public Resources Code Section 21082, 21083.2, and 21084.1, and California Code of Regulations 15064.5). According to the CEQA Guidelines, “historical resources” include buildings, structures, objects, districts, or sites that may possess prehistoric or historical archaeological, architectural, cultural, or scientific importance. CEQA states that if a project will have a significant effect on important cultural resources, then alternative plans or mitigation measures need to be developed. However, only important cultural resources need to be considered in the mitigation plans.

Padre Staff Archaeologist Christopher Letter completed the pedestrian survey on July 1, 2022 and was overseen by Padre Senior Archaeologist Rachael J. Letter, M.S., RPA. Ms. Letter exceeds the U.S. Secretary of the Interior’s Historic Preservation Professional Qualification Standards as outlined in 36 Code of Federal Regulations (CFR) 61.

The remainder of this section provides the Project description and location; Section 2.0 discusses the regulatory framework; Section 3.0 provides the environmental, ethnographic and archaeological overviews for the region; Section 4.0 describes the records search results; Section

5.0 presents the field methodology and survey results; Section 6.0 provides a summary and recommendations; and references are listed in Section 7.0. Appendix A provides the confidential records search results.

1.1 PROJECT LOCATION AND DESCRIPTION
The Project site is located within the Paso Robles, California United States Geological Survey (USGS) 7.5-Minute Series topographic quadrangle map. Specifically, the Project site is located within Section 26, Township 26 South, Range 12 East in Paso Robles, San Luis Obispo County, California (Figure 1-1). Elevation ranges from 811 to 834 feet above mean sea level, and Huer Huero Creek is located approximately 0.32-mile to the east of the Project site.

The Project site is bordered by Union Road to the north, Ardmore Street to the west, and pastureland/ rural properties to the east and south.

The proposed Project includes the construction of a 125,812 square foot warehouse and office building on lot 13 and four commercial, storage, manufacturing, and winemaking buildings totaling 114,650 square feet on lot 6 as well as associated parking lots.

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PROJECT LOCATION
Source: USGS Topo 7.5' Quad
Coordinate System: NAD 1983 StatePlane California V FIPS 0405 Feet Notes: This map was created for informational and display purposes only LEGEND:

Project Location
2202-2481 June 2022
FIGURE
1-1
2930 UNION ROAD, PASO ROBLES,
SAN LUIS OBISPO COUNTY, CA PROJECT NUMBER: DATE:

PROJECT NAME:
³
USGS 7.5' Quadrangle: Paso Robles
Legal Description: T26S, R12E Sec.26
Project
Location SAN LUIS
OBISPO
COUNTY
0 1,000 2,000
FEET
1:24,000
GIS Maps\Map Project\Archeology\2930 Union Road\Project Location.mxd 6/27/2022

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Phase I Archaeological Study, 2930 Union Road, Lots 6 & 13 Paso Robles, San Luis Obispo County
Project No. 2202-2481
- 2-1 -

2.0 REGULATORY FRAMEWORK
The following regulatory framework describes the applicable state and local statutes, ordinances, and policies pertaining to the protection of archaeological resources. These laws must be considered during the planning process for projects that have the potential to affect archaeological resources in San Luis Obispo County.

2.1 STATE REGULATIONS

2.1.1 California Environment Quality Act (CEQA)
CEQA statute and guidelines include procedures for identifying, analyzing, and disclosing potential adverse impacts to historical resources, which include all resources listed in or formally determined eligible for the California Register of Historical Resources (CRHR) or local registers.

CEQA further defines a “historical resource” as a resource that meets any of the following criteria:
• A resource listed in, or determined to be eligible for listing in, the CRHR; • A resource included in a local register of historical resources, as defined in Section 5020.1(k) of the Public Resources Code, unless the preponderance of evidence demonstrates that it is not historically or culturally significant; • A resource identified as significant (i.e., rated 1-5) in a historical resource survey meeting the requirements of Public Resource Code Section 5024.1(g) (Department of Parks and Recreation Form [DPR] 523), unless the preponderance of evidence demonstrates that it is not historically or culturally significant; or • Any object, building, structure, site, area, place, record or manuscript which a lead agency determines to be historically significant or significant in the architectural, engineering, scientific, economic, agricultural, educational, social, political, military or cultural annals of California, provided the determination is supported by substantial evidence in light of the whole record. Generally, a resource is considered “historically significant” if it meets the criteria for listing on the CRHR (CEQA Guidelines Section 15064.5).

2.1.2 California Register of Historical Resources
The CRHR is a listing of California resources that are significant within the context of California’s history. The CRHR is a state-wide program of similar scope to the National Register Historic Places (NRHP). In addition, properties designated under municipal or county ordinances are eligible for listing in the CRHR. A historic resource must be significant at the local, state, or national level under one or more of the following criteria that are defined in the California Code of Regulations Title 14, Chapter 11.5, Section 4850:
• It is associated with events or patterns of events that have made a significant contribution to the broad patterns of local or regional history, or the cultural heritage of California or the United States; or
• It is associated with the lives of persons important to local, California, or national history; or

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Phase I Archaeological Study, 2930 Union Road, Lots 6 & 13 Paso Robles, San Luis Obispo County
Project No. 2202-2481
- 2-2 -
• It embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of a master, or possesses high artistic values; or • It has yielded, or has the potential to yield, information important to the prehistory or history of the local area, California or the nation.

2.2 REGULATIONS CONCERNING DISCOVERY OF HUMAN REMAINS
California Public Resources Code §5097.98 (Notification of Native American human remains, descendants; disposition of human remains and associated grave goods) mandates that the lead agency adhere to the following regulations when a project results in the identification or disturbance of Native American human remains:
(a) Whenever the commission receives notification of a discovery of Native American human remains from a county coroner pursuant to subdivision (c) of Section 7050.5 of the Health and Safety Code, it shall immediately notify those persons it believes to be most likely descended from the deceased Native American. The descendants may, with the permission of the owner of the land, or his or her authorized representative, inspect the site of the discovery of the Native American remains and may recommend to the owner or the person responsible for the excavation work means for treating or disposing, with appropriate dignity, the human remains and any associated grave goods. The descendants shall complete their inspection and make their recommendation within 48 hours of their notification by the Native American Heritage Commission. The recommendation may include the scientific removal and nondestructive analysis of human remains and items associated with Native American burials.

(b) Whenever the commission is unable to identify a descendant, or the descendant identified fails to make a recommendation, or the landowner or his or her authorized representative rejects the recommendation of the descendant, and the mediation provided for in subdivision (k) of Section 5097.94 fails to provide measures acceptable to the landowner, the landowner or his or her authorized representative shall reinter the human remains and items associated with Native American burials with appropriate dignity on the property in a location not subject to further subsurface disturbance. (c) Notwithstanding the provisions of Section 5097.9, the provisions of this section (including those actions taken by the landowner or his or her authorized representative to implement this section), and any action taken to implement an agreement developed pursuant to subdivision (l) of Section 5097.94, shall be exempt from the requirements of the California Environmental Quality Act (Division 13, commencing with Section 21000). (d) Notwithstanding the provisions of Section 30244, the provisions of this section (including those actions taken by the landowner or his or her authorized representative to implement this section), and any action taken to implement an agreement developed pursuant to subdivision (1) of Section 5097.94 shall be exempt from the requirements of the California Coastal Act of 1976 (Division 20, commencing with Section 30000).

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3.0 NATURAL AND CULTURAL OVERVIEW

3.1 ENVIRONMENTAL SETTING
The Project site is located on a stream terrace within the southern portion of the Coast Ranges Geological Province within the Salinas Valley. The Project site is underlain by Holoceneaged younger fluvial and alluvial deposits associated with fan deposits associated with highlands immediately west of the Project site and the Salinas River consisting of mixtures of gravel, sand, silt, and clay (Dibblee, 2004). Specifically, the soil types within the Project site are Arbuckle and San Ysidro sandy loam, which are well-drained soils formed in alluvium derived from sedimentary and metamorphic rock. The area receives a mixture of coastal California and Mediterranean climates, but the primary climate is defined by long, hot, dry summers and brief, cool, sometimes rainy winters (Miles and Goudey, 1998).

3.2 ARCHAEOLOGICAL CONTEXT
Archaeologists working in central California have generally recognized six major prehistoric periods of cultural adaptation within the last 10,000 years. Previous research in San Luis Obispo County has tended to assume that the Santa Barbara sequence developed by Chester King (1982) would be largely replicated in this northern extension of ethnographic Chumash territory (Fitzgerald and Jones, 1998). Jones (1993) has suggested that, despite ethnographic affiliations with the Santa Barbara Channel, archaeologists should consider San Luis Obispo County a district within the central California Coastal Region that also includes Santa Cruz and Monterey counties. The presence of major offshore islands and rich Channel fisheries facilitated development of an intensive, populous maritime culture in the Santa Barbara Channel.

The absence of this resource base in San Luis Obispo County forced cultural elaborations along different trajectories (Fitzgerald and Jones, 1998).

3.2.1 Paleo-Indian Period (c. 25,000 – c. 9950 B.P.)
The Paleo-Indian period represents the earliest human occupation in North America, beginning no earlier than 40,000 years before present (B.P.) and perhaps as recently as 25,000 to 20,000 B.P. This period coincides with the entry of people into the Americas during the latter part of the Wisconsin glaciation. At the end of this glacial period, the sea level began rising, submerging and eroding the flat coastal terraces at a rate of up to two meters per year (Barter et al., 1995).

Conclusive evidence of human occupation during the Paleo-Indian Period has been found at several coastal sites dating to the early Holocene, prior to 8450 B.P. At Diablo Canyon, Greenwood (1972) reported two multi-component sites with basal dates of 9320 and 8410 BP.

The paucity of sites and materials from this time, termed the “Paleocoastal” by Moratto (1984), suggests that population density was low and settlements were impermanent. People used relatively simple technology to procure plant foods, shellfish, and a limited variety of vertebrate species (Greenwood, 1972; Jones and Waugh, 1995; Jones et al., 1994; King, 1982; 1990).

3.2.2 Millingstone Period (c. 9950 – c. 5450 B.P.)
Appropriately named, the Millingstone Period is defined by the predominance of hand stones and milling slabs in the archaeological record, indicating a reliance on hard seeds and

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other plant foods. A variety of flaked stone tools including leaf-shaped bifaces, oval bifacial knives, choppers, and scrapers is also present. This period was a time of rising sea levels that created additional lagoons and estuaries (Glassow et al., 2007). Although deer are represented in the archaeological record, hunting and fishing contributed little to the diet, with the faunal diet relying heavily on mussels and Pismo clams. Bone gorges occur and Olivella spp. spire-lopped shell beads appear in burials (Glassow et al., 2007). Residential bases are presumed to have been comprised of extended families during this period.

3.2.3 Early Period (c. 5450 – c. 2550 B.P.)
Cultural changes after 5450 B.P. are thought to be a response to environmental shifts, rising sea levels, and an increase in population. Diagnostic artifacts of the Early Period include large side-notched, square stem, and contracting stem projectile points, as well as Olivella spp. beads. Although milling slabs and hand stones continued as the primary plant processing tools, mortars and pestles were added to the tool kit, probably indicating the systematic use of acorns (Glassow et al., 1988). In response to climactic changes, local residential sites appear more settled, but not permanent, with an increase in logistical organization of economic activities (Jones et al., 1994). The greater diversity of site types during this period reflects an increasing number of short-term occupations near labor-intensive resources. Trade and exchange also increased in importance as population mobility decreased, as evidenced by exotic shell beads and obsidian materials in midden deposits (Jones et al., 1994).

3.2.4 Middle Period (c. 2550 – c. 950 B.P.)
Prehistoric technology and economy became markedly more complex after 2550 B.P. The artifact assemblage contains shellfish hooks and other fishing gear, saucer-type Olivella spp. beads, and contracting-stemmed projectile points. Subsistence practices emphasized fish and acorns, with a greater use of seasonal resources and the first attempts at food storage (Glassow et al., 1988; King, 1990). Continuation of trade relationships is evident in the increased number and diversity of obsidian items and beads associated with this period. Settlement patterns were similar to those of the prior period. Sites were occupied on an extensive basis, but not as permanent settlements. These residential bases functioned in conjunction with short-term, smaller occupations at specialized resource processing areas (Jones and Ferneau, 2002).

3.2.5 Middle to Late Transition Period (c. 950 – c. 700 B.P.) Around 950 B.P. the Medieval Climatic Anomaly, a 300-year period of warmer temperatures and drier climate, caused consequential, adverse environmental conditions, particularly intermittent droughts (Rabb et al., 1997). This transition period was a time of emergent political complexity, development of social ranking, and the rapid development of craft specialization. In San Luis Obispo County, settlement appears to have shifted away from the coast, perhaps reflecting adaptations to warmer temperatures and changes in available resources on the coast (Jones et al., 1994). Artifact assemblages contain a mixture of earlier artifact types such as stemmed projectile points, milling slabs, hand stones, bowl mortars, and Olivella spp. beads. Moreover, the absence of imported obsidian after 950 B.P. suggests a change in trade relationships, likely associated with the shift in settlement patterns (Jones et al., 1994). The prehistoric population in San Luis Obispo County may have decreased during this time, as villages became temporary hunting camps and native inhabitants increasingly relied on terrestrial mammals for subsistence.

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3.2.6 Late Period (c. 700 – c. 181 B.P.)
The Late Period is poorly understood in San Luis Obispo County as prehistoric occupations from this period do not exhibit well-defined cultural stratigraphy (Jones et al., 2007).

The few intact Late Period sites have produced artifact assemblages containing small sidenotched, triangular, contracting stem, and leaf shaped projectile points, some groundstone, and late prehistoric bead types (Hoover and Sawyer, 1977). The conversion to concave based projectile points led to the abandonment of asphaltum, which had been used for hafting. Shellfish remained the principal protein food. A ranked society with hereditary elite was established.

Population growth and socioeconomic complexity transpired along with environmental change (Glassow et al., 2007).

3.3 ETHNOGRAPHIC CONTEXT
The Project site is situated within the prehistoric territory of the Salinan tribe (Heizer and Whipple, 1971). The Salinans occupied a geographical area extending from present day San Luis Obispo in the south to King City in the north, and west to the coast (Breschini et al., 1983).

The Salinan people were seasonally migratory and, depending on food resources, would inhabit the coastal beaches to procure marine resources, and the interior Santa Lucia mountain ranges for acorn and land mammal resources. It is probable that the Project APE falls within the regional territory of the Migueleño group, which inhabited the upper course of the Salinas River.

The Salinan language is part of the Hokan language family, which has been in the American Southwest for around 9,000 years (Hoover, 1977). Moratto (1984) suggests the Salinans were descendants of early Hokan settlers in the South Coast Ranges. Salinan may have become a distinct language 6000 to 8000 B.P. or earlier. At the time of contact, there were at least two mutually intelligible Salinan dialects. The northern dialect is referred to as Antoniaño, due to its association with the Mission of San Antonio de Padua, and the southern dialect was associated with the San Miguel Mission, which lends the name Migueleño. A third dialect, Playano, is referred to in mission records but nothing is known of it with any certainty.

There are few details recognized about Salinan culture, and what is known survives because of ethnographic interviews conducted by Mason (1912) and Harrington (1942). Their subsistence largely derived from gathering nuts and seeds, particularly acorns. Acorns were stored in bent twig granaries before processing. Wild oats, fruit, sage seeds and berries were also collected. Both coastal and inland groups hunted wild game, such as deer and rabbit, and they used C-shaped fishhooks to fish (Hester, 1978).

Autonomous villages created the Salinan’s main sociopolitical structure. Families constructed domed houses of bent poles covered with tule or rye grass. There were communal structures as well, including dance houses and sweat lodges. Known ethnographic villages sites near the Project sites include him’-se-en’ between Paso Robles and Templeton on the west side of the Salinas River, and a major village at isolam near present-day Cholame (Hester, 1978).

The placement of Chumash and Salinan territorial boundaries is a complex issue. Cultural historic approaches have had limited success in tying ethnographic Salinan settlement with archaeological sites. Notable exceptions include a list of sites recorded in Monterey County that can be associated with recorded Salinan place names collected by Harrington in 1942 (Rivers and Jones, 1993). Early researchers have suggested a boundary at Morro Creek at the north

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end of Morro Bay (Kroeber, 1925), with a cultural boundary along the ridge dividing the Morro Valley from Toro Creek Valley. Subsequent studies moved this boundary inland to the San Miguel area and Ragged Point along the coastline (Gibson, 1983). In general, Salinan prehistory is poorly understood because of the limited number of sites excavated and the frequent lack of cultural stratigraphy and chronological control (Hester, 1978).

At the time of Spanish arrival in Central California, a pattern of small, bounded tribelets was observed. The date of contact in this area is usually set around 1650, although the first record of Spanish contact with the natives in the region is not until 1769, when Gaspar de Portola and Father Junipero Serra arrived. Native Americans residing in the region were moved into the missions first by their own will, and later by force (Heizer and Whipple, 1971). Migration to the missions and population decline emptied the land of its original inhabitants by around 1780 (Beck and Haase, 1974).

3.4 HISTORIC PERIOD CONTEXT

3.4.1 Contact Period
Gaspar de Portolá led the first Spanish land expedition in September 1769 through San Luis Obispo County, camping near the present site of the Coast Union High School (Bolton, 1926; Squibb, 1984). Several accounts of this expedition exist, including those of Juan Crespi (Bolton, 1926), Miguel Costansó (Browning, 1992), and Pedro Fages (Priestley, 1937). Costansó’s diary contains observations regarding the native inhabitants’ houses, settlement patterns, dress, and customs, as well as their attitudes toward the expedition (Browning, 1992).

In 1774, Juan Bautista de Anza passed over the same route as Portolá had five years before him (Hoover et al., 1990). This expedition made two stops in San Luis Obispo County, including one at the present Mission location on April 15, 1774, and a second at the Nacimiento River on April 16, 1774 (Hoover et al., 1990). In 1776, Anza made a second trip through the San Luis Obispo area as leader of the San Francisco colonists.

3.4.2 Mission Period
Fermin Francisco de Lasuen founded Mission San Miguel Arcángel, approximately eight miles north of the Project site, on July 25, 1797 (Hoover et al., 1990). The Franciscans chose the location for its proximity to the Salinan village, Vahca, and to close the gap between Mission San Antonio to the north and Mission San Luis Obispo to the south. Newly baptized Salinans provided almost all the labor to construct and maintain the missions, which soon produced surplus amounts of wheat, beans, corn, cattle, and sheep for trade (Barter et al. 1995). Most of the missions were similar in design and consisted of a church and living quarters for the priests, soldiers, and baptized Salinans (Hoover, 1990).

3.4.3 Rancho and Anglo-Mexican Periods
Mexico declared its independence from Spain in 1821 and the Secularization Act of 1833 ended the Catholic Church’s control of large estates associated with the missions and presidios in Alta California. The Mexican government granted ranchos to Mexican and foreign settlers, who mainly used the land for grazing sheep and cattle. Following the Bear Flag Revolt in 1846, California gained its independence from Mexico and the United States gained control of the territory. Across California, courts reviewed the legality of each land grant on an individual basis.

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While the Treaty of Hidalgo promised all property belonging to the Californios would be respected, the Land Act of 1851 required all land grant owners to prove their title and ownerships rights.

Because the Californios relied on vague surveys and land titles, it took an average of 17 years to receive their American land patents (Bean, 1968; Palmer, 1999).

Specifically, the present Project site is adjacent to the former Rancho Paso de Robles land grant. Rancho Paso de Robles was granted by Governor Manuel Micheltorena to Jose Pedro Narvarez in 1844, who sold the rancho to Petronilo Rios a year later in 1845. A claim for Rancho Paso de Robles was filed in 1852, although Rios did not receive the patent until 1886. By the time the patent had been issued, Rios had already sold the rancho to James H. Blackburn, Daniel Drew Blackburn, and Lazard Godchaux.

3.4.4 Americanization Period
During the mid-nineteenth century, the Paso Robles area was known for its mineral hot springs and was a popular rest stop along the Camino Real. The first El Paso de Robles Hotel, built in 1864, featured a bath house and attracted many tourists to the area. European settlers also came to the area to establish cattle ranches, apple and almond orchards, dairy farms, and vineyards (TravelPaso, 2015).

After the introduction of the Southern Pacific Railroad, the town of Paso Robles was laid out in 1886 and incorporated in 1889. Daniel and James Blackburn built the Hotel El Paso de Robles (now the Paso Robles Inn), including an extensive bathhouse in 1891. At this time, Paso Robles became known as “Almond City” because it contained the world’s largest concentration of almond orchards. Growth remained steady until the 1940s when the United States Army established Camp Roberts. The new military installation brought more people and encouraged new development in the city (TravelPaso, 2015).

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4.0 RECORDS SEARCH METHODS AND RESULTS

4.1 METHODS
Padre ordered an expedited records search from the Central Coast Information Center of the California Historical Resources Information System (CCIC-CHRIS) at the Santa Barbara Museum of Natural History on June 28, 2022. The records search included a review of all recorded historic-era and prehistoric archaeological sites within a 1/4-mile radius of the Project APE, as well as a review of known cultural resource surveys and technical reports. Padre received the results on June 28, 2022.

During the records search, the following sources were consulted:
• CCIC base maps, USGS 7.5-minute series topographic quadrangles for the Project APE, and other historic maps;
• Pertinent survey reports and archaeological site records were examined to identify recorded archaeological sites and historic-period built-environment resources (such as buildings, structures, and objects) within or immediately adjacent to the Project APE; and
• The California Department of Parks and Recreation’s California Inventory of Historic Resources (1991) and the Office of Historic Preservation’s Historic Properties Directory (2007), which combines cultural resources listed on the California Historical Landmarks, California Points of Historic Interest, and those that are listed in or determined eligible for listing in the NRHP or the CRHR.

4.2 RESULTS
The records search revealed that no cultural resources have been recorded within the Project site. A single prehistoric artifact (P-40-038008) was recorded approximately ¼ mile southwest of the Project site in 1988 (Singer and Atwood, 1988a).

The records search indicates that the Project site has not been previously examined for cultural resources; however, five cultural resource studies have been completed within a ¼ mile radius of the Project site. These studies included the parcels to the east, south, and northeast, and no cultural resources were observed (Singer and Atwood, 1988b; Conway, 2015).

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5.0 FIELD SURVEY METHODS AND RESULTS
Padre Staff Archaeologist Christopher J. Letter conducted a Phase I pedestrian survey of the Project site on July 1, 2022. The archaeologist examined the Project site with parallel transects spaced at 15-meter intervals where not constrained by steep slopes or dense vegetation. The survey areas were documented with color digital photographs. No cultural materials were observed.

The Project site is located on gently rolling terrain with the majority of the property used for pastureland (Figure 5-1 and Figure 5-2). Ground surface visibility was generally excellent, ranging from 60 to 95 percent, with discarded construction materials and accumulations of oak detritus accounting for areas of reduced visibility. Vegetation within the Project site was sparse and consisted of weeds and seasonal grasses. Several mature oak trees (Quercus spp.) are located throughout the Project site (Figure 5-3 and Figure 5-4). Soils consisted of a light-yellow brown sandy loam with less than 10 percent subrounded to subangular pebbles. Many small mammal burrows allowed for additional subsurface soil evaluations.

Figure 5-1. Overview of Project site, facing south

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Figure 5-2. Overview north end of Project site, facing south Figure 5-3. Overview of Project site, facing south

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Figure 5-4. Overview of south end of Project site, facing south

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6.0 CONCLUSIONS AND RECOMMENDATIONS
Padre has completed a Phase I Archaeological Study in support of the construction of a new commercial development at 2930 Union Road (Lots 6 and 13 of APN 025-362-043) in Paso Robles, San Luis Obispo County, California.

The records search did not identify any cultural resources within the Project site, and no cultural resources were identified within the Project site during the pedestrian survey.

In the event that cultural materials 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.

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7.0 REFERENCES CITED
Barter, E. R., Farris, G., and Rivers, B. J., 1995. Coastal Branch, Phase II, State Water Project Cultural Resources Survey, Reach 5A, San Luis Obispo County, California. Report prepared for State of California, Department of Water Resources, Division of Planning, Sacramento. Report on file, Department of Parks and Recreation, Cultural Heritage Section, Sacramento.

Bean, W., 1968. California: An Interpretive History. McGraw Hill Book Company, New York.

Beck, W.A. and Haase, Y.D. 1974. Historical Atlas of California. University of Oklahoma Press, Norman.

Bolton, H. E., 1926. Captain Portola in San Luis Obispo County 1769. Tabula Rasa Press, Morro Bay, California.

Breschini, G.S., Haversat, T., and Hampson, R.P., 1983. A Cultural Resources Overview of the Coast and Coast-Valley Study Areas. Unpublished technical report, Bureau of Land Management. On file at the Los Prietos Heritage Resource Center.

Browning, P. (Editor), 1992. The Discovery of San Francisco Bay -- The Portolá Expedition of 1769 – 1770: The Diary of Miguel Costansó. Great West Books, Lafayette, California.

California Office of Historic Preservation, 1991. Preservation Planning Bulletin 5: Guidelines for Archaeological Resource Management Reports (ARMR) Recommended Contents and Format. California Office of Historic Preservation, Department of Parks and Recreation, Sacramento, California.
, 2007. Historic Properties Directory. State of California, Department of Parks and Recreation, Sacramento, California.

Conway, T. 2015. An Archaeological Surface Survey for the Residence Inn Project, 2940 Union Road, Paso Robles, San Luis Obispo County, California. Prepared by Heritage Discoveries, Inc. SL-06920.

Dibblee, T. W. Jr., 2004, Geologic Map of the Templeton Quadrangle, Dibblee Geology Center Map #DF-135, Accessed July 2022.

Fitzgerald, R. T., and Jones, T. L., 1998. Interpretive Synthesis of Subsurface Archaeological Investigations for the Coastal Branch, Phase II, State Water Project. Appendix G in Final Report: Archaeological Data Recovery at CA-SLO-1797, the Cross Creek Site, San Luis Obispo County, California, Coastal Branch Phase II Project. Garcia and Associates.

Prepared for the California Department of Water Resources, Sacramento, California.

Gibson, R. O. 1983. Ethnogeography of the Salinan People: A Systems Approach. Master's thesis. California State University, Haywood.

Glassow, M., Wilcoxon, L., and Erlandson, J., 1988. Cultural and Environmental Change during the Early Period of Santa Barbara Channel Prehistory. In The Archaeology of HunterGatherer Subsistence Economics in Coastal Environments, edited by G. Parkington and B. Bailey. Cambridge University Press, New York.

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Glassow, Michael A., Gamble, Lynn H., Perry, Jennifer E., and Russell, Glenn S., 2007.

Prehistory of the Northern California Bight and the Adjacent Transverse Ranges.

California Prehistory. T. L. Jones and K. A. Klar, eds., AltaMira Press, Lantham, Maryland.

Greenwood, R.S., 1972. 9,000 Years of Prehistory at Diablo Canyon. San Luis Obispo County Archaeological Society Occasional Papers 7. Paso Robles, California.

Harrington, J. P. 1942. Cultural Element Distributions: XIX: Central California. University of California Anthropological Records 7(1):1-46. Berkeley.

Heizer, R.F., and Whipple, M.A., 1971. The California Indians, a Source Book. University of California Press, Berkeley, Los Angeles, London.

Hester, T. R., 1978. Salinan, in Handbook of North American Indians, Vol. 8, California, R. F.

Heizer, ed., pp. 500-504. Smithsonian Institution, Washington, D.C.

Hoover, R., 1977. Ethnohistoric Salinan Acculturation. Ethnohistory, 24(3):261-268. , 1990. Archaeological Resources of the Nipomo Dunes Preserve. Prepared for the Nature Conservancy, San Luis Obispo, California. Contract No. CAFO-0005.

Jones, T. L., 1993. Big Sur: A Keystone in Central California Culture History. Pacific Coast Archaeological Society Quarterly 29 (1): 1-77, Costa Mesa.

Jones, T. L. and Ferneau, J. A., 2002. Prehistory at San Simeon Reef: Archaeological Data Recovery at CA-SLO-179 and -267, San Luis Obispo County, California. San Luis Obispo County Archaeological Society Occasional Paper 16.

Jones, T. L. and Waugh, G., 1995. Central California Coastal Prehistory: A View from Little Pico Creek. Perspectives in California Archaeology 3, Institute of Archaeology, University of California, Los Angeles.

Jones, T. L., Davis, K., Farris, G., Grantham, S. D., Fung, T. W., and Rivers, B., 1994. Toward a Prehistory of Morro Bay: Phase II Archaeological Investigations for the Highway 41 Widening Project, San Luis Obispo County, California. Prepared for the Department of Transportation, District 05, San Luis Obispo, California.

Jones, T. L., Stevens, N. E., Jones, D. A., Fitzgerald, R. T., and Hylkema, M. G., 2007. The Central Coast: A Midlatitude Milieu. In California Prehistory. T. L. Jones and K. A. Klar, eds., AltaMira Press, Lantham, Maryland.

King, C., 1982. The Evolution of Chumash Society. Unpublished PhD. dissertation, University of California, Davis.
, 1990. The Evolution of Chumash Society: A Comparative Study of Artifacts Used in Social System Maintenance in the Santa Barbara Channel Region before A.D. 1804.

Garland, New York.

Kroeber, A. L., 1925. Handbook of the Indians of California. Bulletin 78 of the Bureau of American Ethnology of the Smithsonian Institution, Government Printing Office, Washington.

Republished in 1976 by Dover Publications, Inc., New York.

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Mason, J. A., 1912. The Ethnology of the Salinan Indians. University of California Publications in American Archaeology and Ethnology 10(4):97-240.

Miles, S. R., and Goudey, C. B., 1998. Ecological Subregions of California: Section and Subsection Descriptions. USDA, Forest Service Pacific Southwest Region, San Francisco. Electronic document, http://www.fs.fed.us/r5/projects/ecoregions/.

Moratto, M. J., 1984. California Archaeology. Academic Press, Inc., San Diego.

Palmer, K., 1999. Central Coast Continuum—From Ranchos to Rockets: A Historic Overview for an Inventory and Evaluation of Historic Sites, Buildings, and Structures, Vandenberg Air Force Base, California. Prepared under contract to BTG, Inc. Submitted to 30 CES/CEVPC, Vandenberg Air Force Base.

Priestley, H. I., 1937. A Historical, Political, and Natural Description of California by Pedro Fages, Written for the Viceroy in 1775. Translated by Herbert Ingram Priestley. University of California Press, Berkeley.

Rabb, L. M., and Larson, D. O., 1997. “Medieval Climatic Anomaly and Punctuated Cultural Evolution in Coastal Southern California.” American Antiquity 62: 319-336.

Rivers, B., and Jones, T. L., 1993. Walking Along Deer Trails: A Contribution to Salinan Ethnogeography Based on the Field Notes of John Peabody Harrington. Journal of California and Great Basin Anthropology 15(2):146-175.

Singer, C. A. and Atwood, J. E. 1988a. Archaeological Site Record: P-40-038008. Prepared by Singer and Associates.
1988b. Cultural Resources Survey and Impact Assessment for the Chandler Specific Plan Area, Near the City of El Paso de Robles, San Luis Obispo County, California. Prepared by Singer and Associates. SL-01601.

Squibb, P., 1984. Captain Portola in San Luis Obispo County in 1769. Tabula Rasa Press, Morro Bay, California.

TravelPaso, 2015. History of Paso Robles. http://www.travelpaso.com/about/history. Accessed on February 1, 2016.

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APPENDIX A
CONFIDENTIAL: RECORDS SEARCH RESULTS

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April 2023

AIR QUALITY AND GREENHOUSE GAS ANALYSIS

ARDMORE INDUSTRIAL PROJECT

PASO ROBLES, CALIFORNIA

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April 2023

AIR QUALITY AND GREENHOUSE GAS ANALYSIS

ARDMORE INDUSTRIAL PROJECT

PASO ROBLES, CALIFORNIA
Submitted to:

Kirk Consulting
8830 Morro Road
Atascadero, California 93422
Prepared by:

LSA
2565 Alluvial Avenue, Suite 172
Clovis, California 93611
(559) 490-1210
Project No. MDT2201

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AIR QUALITY AND GREENHOUSE GAS A NALYSIS
APRIL 2023

ARDMORE INDUSTRIAL P ROJECT

P ASO R OBLES , C ALIFORNIA
P:\MDT2201\Products\Ardmore Industrial Project AQ GHG Report - 041123.docx

TABLE OF CONTENTS
EXECUTIVE SUMMARY............................................................................................................................. i TABLE OF CONTENTS ............................................................................................................................. iii FIGURES AND TABLES ............................................................................................................................ iv LIST OF ABBREVIATIONS AND ACRONYMS............................................................................................. v PROJECT LOCATION AND DESCRIPTION ....................................................................... 1 Existing Sensitive Land Uses in the Project Area........................................................................... 5 AIR POLLUTANTS AND HEALTH EFFECTS ...................................................................... 6 Ozone ............................................................................................................................................ 7 Carbon Monoxide.......................................................................................................................... 7 Particulate Matter......................................................................................................................... 7 Nitrogen Dioxide ........................................................................................................................... 7 Sulfur Dioxide ................................................................................................................................ 7 Lead ............................................................................................................................................... 7 Volatile Organic Compounds......................................................................................................... 8 Toxic Air Contaminants ................................................................................................................. 8 GREENHOUSE GASES AND GLOBAL CLIMATE CHANGE ............................................... 12 Carbon Dioxide............................................................................................................................ 13 Methane...................................................................................................................................... 13 Nitrous Oxide............................................................................................................................... 14 Hydrofluorocarbons, Perfluorocarbons, and Sulfur Hexafluoride .............................................. 14 Black Carbon................................................................................................................................ 14 AIR QUALITY REGULATORY SETTING ......................................................................... 16 Federal Regulations..................................................................................................................... 16 Federal Clean Air Act........................................................................................................................16 State Regulations......................................................................................................................... 16 California Clean Air Act.....................................................................................................................16 California Air Resources Board .........................................................................................................16 Regional Regulations................................................................................................................... 17 CEQA Air Quality Handbook .............................................................................................................17 Clean Air Plan ...................................................................................................................................18 Ozone Emergency Episode Plan .......................................................................................................18 PM Report ........................................................................................................................................ 18 Local Regulations......................................................................................................................... 18 City of Paso Robles General Plan......................................................................................................18 GREENHOUSE GAS REGULATORY SETTING ................................................................ 19 Federal Regulations..................................................................................................................... 19 State Regulations......................................................................................................................... 20 Assembly Bill 1493 (2002) ................................................................................................................20 Executive Order S-3-05 (2005)..........................................................................................................20 Assembly Bill 32 (2006), California Global Warming Solutions Act..................................................21

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P:\MDT2201\Products\Ardmore Industrial Project AQ GHG Report - 041123.docx Senate Bill 97 (2007).........................................................................................................................23 Senate Bill 375 (2008).......................................................................................................................23 Executive Order B-30-15 (2015) .......................................................................................................24 Senate Bill 350 (2015) Clean Energy and Pollution Reduction Act...................................................24 Senate Bill 32, California Global Warming Solutions Act of 2016, and Assembly Bill 197................25 Senate Bill 100..................................................................................................................................25 Executive Order B-55-18...................................................................................................................25 Title 24, Building Standards Code and CALGreen Code....................................................................25 Cap and Trade...................................................................................................................................26 Executive Order N-79-20 ..................................................................................................................26 Low Carbon Fuel Standard ...............................................................................................................26 Advanced Clean Cars Program .........................................................................................................27 Executive Order B-48-18...................................................................................................................27 Local Regulations......................................................................................................................... 27 City of Paso Robles Climate Action Plan...................................................................................... 28 ATTAINMENT STATUS ............................................................................................... 29 EXISTING CLIMATE AND AIR QUALITY ....................................................................... 30 AIR QUALITY MONITORING RESULTS ......................................................................... 31 GREENHOUSE GAS EMISSIONS INVENTORY ............................................................... 31 Global Emissions.......................................................................................................................... 31 United States Emissions.............................................................................................................. 33 State of California Emissions....................................................................................................... 33 City of Paso Robles Emissions ..................................................................................................... 33 CONSTRUCTION EMISSIONS ...................................................................................... 35 OPERATIONAL EMISSIONS ........................................................................................ 35 GREENHOUSE GAS ANALYSIS .................................................................................... 36 REGIONAL EMISSIONS THRESHOLDS ......................................................................... 37 LOCAL MICROSCALE CONCENTRATION STANDARDS .................................................. 39 GREENHOUSE GAS EMISSIONS .................................................................................. 39 AIR QUALITY IMPACTS .............................................................................................. 40 Consistency with Applicable Air Quality Plans............................................................................ 40 Population Projections.....................................................................................................................40 Vehicle Trips and Vehicle Miles Traveled .........................................................................................41 Transportation and Land Use Control Measures..............................................................................41 Summary .......................................................................................................................................... 41 Criteria Pollutant Analysis........................................................................................................... 41 Construction Emissions ....................................................................................................................42 Operational Emissions......................................................................................................................43 Health Risk on Nearby Sensitive Receptors ................................................................................ 44 Odors........................................................................................................................................... 44 GREENHOUSE GAS EMISSION IMPACTS ..................................................................... 45 Generation of Greenhouse Gas Emissions.................................................................................. 45

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P:\MDT2201\Products\Ardmore Industrial Project AQ GHG Report - 041123.docx Construction Greenhouse Gas Emissions.........................................................................................45 Operational Greenhouse Gas Emissions ..........................................................................................45 Consistency with Greenhouse Gas Reduction Plans................................................................... 48 CONCLUSION ............................................................................................................ 49

APPENDIX
A: CALEEMOD OUTPUTS

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FIGURES AND TABLES

FIGURES
Figure 1: Project Location and Vicinity................................................................................................... 3 Figure 2: Project Site Plan....................................................................................................................... 4 TABLES
Table A: Sources and Health Effects of Air Pollutants............................................................................ 9 Table B: Federal and State Ambient Air Quality Standards.................................................................. 10 Table C: Global Warming Potential of Greenhouse Gases................................................................... 13 Table D: Senate Bill 375 Regional Greenhouse Gas Emissions Reduction Targets .............................. 24 Table E: San Luis Obispo County Attainment Status............................................................................ 29 Table F: Ambient Air Quality at Nearby Monitoring Stations .............................................................. 32 Table G: City of Paso Robles GHG Emissions........................................................................................ 34 Table H: Air Quality Thresholds of Significance for Construction Emissions........................................ 38 Table I: Air Quality Thresholds of Significance for Operational Emissions........................................... 38 Table J: Air Quality Construction Emissions ......................................................................................... 43 Table K: Air Quality Operational Emissions.......................................................................................... 44 Table L: GHG Emissions (Metric Tons Per Year) ................................................................................... 46

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LIST OF ABBREVIATIONS AND ACRONYMS
°C degrees Celsius
°F degrees Fahrenheit
µg/m3 micrograms per cubic meter
AAQS ambient air quality standards
AB Assembly Bill
CAA Federal Clean Air Act
CAFE Corporate Average Fuel Economy
CalEEMod California Emissions Estimator Model
CalEPA California Environmental Protection Agency
CALGreen Code California Green Building Standards Code
CAP Climate Action Plan
CARB California Air Resources Board
CAT California Climate Action Team
CCAA California Clean Air Act
CEQA California Environmental Quality Act
CH4 methane
City City of Paso Robles
CO carbon monoxide
CO2 carbon dioxide
CO2e carbon dioxide equivalent
County County of San Luis Obispo
DPM diesel particulate matter

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P:\MDT2201\Products\Ardmore Industrial Project AQ GHG Report - 041123.docx EIR Environmental Impact Report
EO Executive Order
GHG greenhouse gas
GWP global warming potential
HFCs hydrofluorocarbons
I-SIP California Infrastructure State Implementation Plan IPCC Intergovernmental Panel on Climate Change
LCFS Low Carbon Fuel Standard
mg/m3 milligrams per cubic meter
MMT million metric tons
MMT CO2e million metric tons of carbon dioxide equivalent MPO Metropolitan Planning Organization
MT metric tons
MT CO2e metric tons of carbon dioxide equivalent
N2O nitrous oxide
ND no data available
NHTSA National Highway Traffic Safety Administration
NO2 nitrogen dioxide
NOX nitrogen oxides
O3 ozone (or smog)
OPR Governor’s Office of Planning and Research
Pb lead
PFCs perfluorocarbons
PM particulate matter

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P:\MDT2201\Products\Ardmore Industrial Project AQ GHG Report - 041123.docx PM2.5 particulate matter less than 2.5 microns in size
PM10 particulate matter less than 10 microns in size
ppb parts per billion
ppm parts per million
project Ardmore Industrial Project
ROGs reactive organic gases
SB Senate Bill
SCS Sustainable Communities Strategy
SF6 sulfur hexafluoride
SLO County APCD San Luis Obispo County Air Pollution Control District SLOCOG San Luis Obispo Council of Governments
SO2 sulfur dioxide
SOX sulfur oxides
sq ft square foot/feet
TAC toxic air contaminant
TIA Transportation Impact Analysis
UNFCCC United Nations Framework Convention on Climate Change USEPA United States Environmental Protection Agency
VMT vehicle miles traveled
VOCs volatile organic compounds
ZEV zero-emission vehicle

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P:\MDT2201\Products\Ardmore Industrial Project AQ GHG Report - 041123.docx «04/11/23» 1

INTRODUCTION
This air quality and greenhouse gas (GHG) impact analysis has been prepared to evaluate the potential air quality and GHG emissions impacts associated with the proposed Ardmore Industrial Project (project) in the City of Paso Robles (City), California. This report provides a project-specific air quality and GHG emissions impact analysis by examining the impacts of the proposed uses on regional air quality and nearby sensitive uses. This air quality and GHG impact 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 , including an assessment
of criteria pollutant emissions and an assessment of the project’s greenhouse gas (GHG) emissions.

PROJECT LOCATION AND DESCRIPTION
The project site is located at 2930 Union Road in the City of Paso Robles, San Luis Obispo County, California. See Figure 1, Project Location and Vicinity, and Figure 2, Project Site Plan, below.

The proposed project would consist of an approximately 125,812 square-foot (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 site would have a total of 310 parking spaces, of which 154 spaces would be for Lot 13 and 156 spaces for Lot 6. The proposed project would not require a change to the General Plan land use designation or the current zoning and would be consistent with the City’s General Plan and Zoning Ordinance.

Typical operational characteristics include employees traveling to and from the site, delivery of products to the site, truck loading and unloading, and truck maintenance operations. The project is assumed to operate from 7:00 a.m. to 7:00 p.m., 7 days per week; however, these hours may shift depending on the tenant, as the hours of operation are unknown at this time. The proposed project is expected to generate approximately 250 employees and would generate approximately 1,194 average daily trips2
.

Construction of Buildings 1–4 is anticipated to begin in summer 2024 and occur for 12 to 16 months, and construction of Building 5 would commence in summer 2026 and would occur for 12 to 16 months. Based on the preliminary grading plans, earthwork would be balanced on site and no export or import of soil would be required. Construction would include demolition, excavation, grading, building construction, and installation of landscaping and irrigation, lighting, storm drain facilities, and underground utilities. Grading, and building activities would involve the use of 1 San Luis Obispo County Air Pollution Control District (SLO County APCD). 2012. CEQA Air Quality Handbook. April. 2
Central Coast Transportation Consulting (CCTC). 2022. Transportation Analysis for the Ardmore Industrial Project – Paso Robles. December 7.

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P:\MDT2201\Products\Ardmore Industrial Project AQ GHG Report - 041123.docx «04/11/23» 2 standard earthmoving equipment such as large excavators, cranes, and other related equipment.

This analysis also assumes the use of Tier 2 construction equipment.

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Service Layer Credits: Sources: Esri, HERE,
Garmin, Intermap, increment P Corp.,
SOURCE: USGS 7.5' Quad - San Luis Rey (1975), Oceanside (1975), CA J:\MDT2201\GIS\MXD\Project_Location.mxd (3/28/2023)
FIGURE 1
Ardmore Industrial Project
Project Location and Vicinity
LEGEND
Project Location
0 1000 2000
FEET
Monterey
County
San Luis
Obispo
County
£¤101
Ã46
Ã1
Ã229
Ã58
Ã41
Project
Location
Project Vicinity

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SOURCE: Arris Architects
FEET
0 75 150
FIGURE 2
Site Plan
I:\MDT2201\G\Site_Plan.ai (3/27/2023)
Ardmore Industrial Project

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P:\MDT2201\Products\Ardmore Industrial Project AQ GHG Report - 041123.docx «04/11/23» 5 Existing Sensitive Land Uses in the Project Area
For the purposes of this analysis, sensitive receptors are areas of population that have an increased sensitivity to air pollution or environmental contaminants. Sensitive receptor locations include residences, schools, day care centers, hospitals, parks, and similar uses that are sensitive to air quality. Impacts on sensitive receptors are of particular concern because they are the population most vulnerable to the effects of air pollution. The project site is bounded by open land to the east and south and by commercial uses to the north and the east. There are no nearby sensitive receptors within 1,000 feet of the project area.

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BACKGROUND
This section provides background information on air pollutants and their health effects. It also provides regulatory background information, including information from the California Air Resources Board’s (CARB) Air Quality and Land Use Handbook3
(CARB Handbook); a description of the general
health risks of toxics, and the significance criteria for project evaluation.

AIR POLLUTANTS AND HEALTH EFFECTS
Both State and federal governments have established health-based Ambient Air Quality Standards for six criteria air pollutants:4 carbon monoxide (CO), ozone (O3), nitrogen dioxide (NO2), sulfur dioxide (SO2), lead, and suspended particulate matter (PM). In addition, the State has set standards for sulfates, hydrogen sulfide, vinyl chloride, and visibility-reducing particles. These standards are designed to protect the health and welfare of the populace with a reasonable margin of safety.

Long-term exposure to elevated levels of criteria pollutants may result in adverse health effects.

However, emission thresholds established by an air district are used to manage total regional emissions within an air basin based on the air basin’s attainment status for criteria pollutants. These emission thresholds were established for individual projects that would contribute to regional emissions and pollutant concentrations and could adversely affect or delay the projected attainment target year for certain criteria pollutants.

Because of the conservative nature of the thresholds and the basin-wide context of individual project emissions, there is no known direct correlation between a single project and localized air quality-related health effects. One individual project that generates emissions exceeding a threshold does not necessarily result in adverse health effects for residents in the project vicinity. This condition is especially true when the criteria pollutants exceeding thresholds are those with regional effects, such as ozone precursors like nitrogen oxides (NOx) and volatile organic compounds (VOC).

Occupants of facilities such as schools, daycare centers, parks and playgrounds, hospitals, and nursing and convalescent homes are considered to be more sensitive than the general public to air pollutants because these population groups have increased susceptibility to respiratory disease.

Persons engaged in strenuous work or exercise also have increased sensitivity to poor air quality.

Residential areas are considered more sensitive to air quality conditions, compared to commercial and industrial areas, because people generally spend longer periods of time at their residences, with greater associated exposure to ambient air quality conditions. Recreational uses are also considered sensitive compared to commercial and industrial uses due to greater exposure to ambient air quality conditions associated with exercise.
3 California Air Resources Board (CARB). 2005. Air Quality and Land Use Handbook: A Community Health Perspective. May. 4
Criteria pollutants are defined as those pollutants for which the federal and State governments have established ambient air quality standards, or criteria, for outdoor concentrations in order to protect public health.

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P:\MDT2201\Products\Ardmore Industrial Project AQ GHG Report - 041123.docx «04/11/23» 7 Ozone
Rather than being directly emitted, O3 (smog) is formed by photochemical reactions between NOX and VOCs. Ozone is a pungent, colorless gas. Elevated O3 concentrations result in reduced lung function, particularly during vigorous physical activity. This health problem is particularly acute in sensitive receptors such as the sick, elderly, and young children. O3 levels peak during the summer and early fall months.

Carbon Monoxide
CO forms from the incomplete combustion of fossil fuels, almost entirely from automobiles. It is a colorless, odorless gas that can cause dizziness, fatigue, and impairments to central nervous system functions. CO passes through the lungs into the bloodstream, where it interferes with the transfer of oxygen to body tissues.

Particulate Matter
PM is the term used for a mixture of solid particles and liquid droplets found in the air. Coarse particles are those that are 10 microns or less in diameter, or PM10. Fine, suspended particulate matter with an aerodynamic diameter of 2.5 microns or less, or PM2.5, is not readily filtered out by the lungs. Nitrates, sulfates, dust, and combustion particulates are major components of PM10 and PM2.5. These small particles can be directly emitted into the atmosphere as byproducts of fuel combustion; through abrasion, such as tire or brake lining wear; or through fugitive dust (wind or mechanical erosion of soil). They can also be formed in the atmosphere through chemical reactions.

Particulates may transport carcinogens and other toxic compounds that adhere to the particle surfaces and can enter the human body through the lungs.

Nitrogen Dioxide
NO2 is a reddish-brown gas that is a byproduct of combustion processes. Automobiles and industrial operations are the main sources of NO2. Aside from its contribution to O3 formation, NO2 also contributes to other pollution problems, including a high concentration of fine particulate matter, poor visibility, and acid deposition. NO2 may be visible as a coloring component on high pollution days, especially in conjunction with high ozone levels. NO2 decreases lung function and may reduce resistance to infection.

Sulfur Dioxide
SO2 is a colorless, irritating gas formed primarily from incomplete combustion of fuels containing sulfur. Industrial facilities also contribute to gaseous SO2 levels in the region. SO2 irritates the respiratory tract, can injure lung tissue when combined with fine particulate matter, and reduces visibility and the level of sunlight.

Lead
Leaded gasoline (phased out in the United States beginning in 1973), paint (on older houses and cars), smelters (metal refineries), and the manufacture of lead storage batteries have been the primary sources of lead released into the atmosphere. Lead has multiple adverse neurotoxic health effects, and children are at special risk. Some lead-containing chemicals cause cancer in animals.

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P:\MDT2201\Products\Ardmore Industrial Project AQ GHG Report - 041123.docx «04/11/23» 8 Lead levels in the air have decreased substantially since leaded gasoline was eliminated. Ambient lead concentrations are only monitored on an as-warranted, site-specific basis in California. On October 15, 2008, the United States Environmental Protection Agency (USEPA) strengthened the national ambient air quality standard for lead by lowering it from 1.5 to 0.15 micrograms per cubic meter (µg/m3
). The USEPA revised the monitoring requirements for lead in December 2010. These requirements focus on airports and large urban areas, resulting in an increase in 76 monitors nationally.

Volatile Organic Compounds
VOCs (also known as reactive organic gases and reactive organic compounds) are formed from the combustion of fuels and the evaporation of organic solvents. VOCs are not defined as criteria pollutants, however, because VOCs accumulate in the atmosphere more quickly during the winter, when sunlight is limited and photochemical reactions are slower, they are a prime component of the photochemical smog reaction. There are no attainment designations for VOCs.

Toxic Air Contaminants
In addition to the criteria pollutants discussed above, toxic air contaminants (TACs) are another group of pollutants of concern. TACs are injurious in small quantities and are regulated by the USEPA and the CARB. Some examples of TACs include benzene, butadiene, formaldehyde, and hydrogen sulfide. The identification, regulation, and monitoring of TACs is relatively recent compared to that for criteria pollutants.

TACs do not have ambient air quality standards, but are regulated by the USEPA, CARB, and the SLO County APCD. In 1998, the CARB identified particulate matter from diesel-fueled engines as a TAC.

The CARB has completed a risk management process that identified potential cancer risks for a range of activities using diesel-fueled engines.5
High-volume freeways, stationary diesel engines,
and facilities attracting heavy and constant diesel vehicle traffic (e.g., distribution centers and truck stops) were identified as posing the highest risk to adjacent receptors. Other facilities associated with increased risk include warehouse distribution centers, large retail or industrial facilities, highvolume transit centers, and schools with a high volume of bus traffic. Health risks from TACs are a function of both concentration and duration of exposure.

Unlike TACs emitted from industrial and other stationary sources noted above, most diesel particulate matter is emitted from mobile sources—primarily “off-road” sources such as construction and mining equipment, agricultural equipment, and truck-mounted refrigeration units, as well as “on-road” sources such as trucks and buses traveling on freeways and local roadways.

Although not specifically monitored, recent studies indicate that exposure to diesel particulate matter may contribute significantly to a cancer risk (a risk of approximately 500 to 700 in 1,000,000) that is greater than all other measured TACs combined.6 The technology for reducing diesel particulate matter emissions from heavy-duty trucks is well established, and both State and federal 5 CARB. 2000. Stationary Source Division and Mobile Source Control Division. Risk Reduction Plan to Reduce Particulate Matter Emissions from Diesel-Fueled Engines and Vehicles. October. 6 Ibid.

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P:\MDT2201\Products\Ardmore Industrial Project AQ GHG Report - 041123.docx «04/11/23» 9 agencies are moving aggressively to regulate engines and emission control systems to reduce and remediate diesel emissions. The CARB anticipates that by 2020, average statewide diesel particulate matter concentrations will decrease by 85 percent from levels in 2000 with full implementation of the CARB’s Diesel Risk Reduction Plan,7 meaning that the statewide health risk from diesel particulate matter is expected to decrease from 540 cancer cases in 1,000,000 to 21.5 cancer cases in 1,000,000.

Table A summarizes the sources and health effects of air pollutants discussed in this section. Table B presents a summary of State and federal ambient air quality standards (AAQS).

Table A: Sources and Health Effects of Air Pollutants
Pollutants Sources Primary Effects
Carbon
Monoxide (CO)
 Incomplete combustion of fuels
and other carbon-containing
substances, such as motor exhaust
 Natural events, such as
decomposition of organic matter
 Reduced tolerance for exercise
 Impairment of mental function
 Impairment of fetal development
 Death at high levels of exposure
 Aggravation of some heart diseases (angina)
Nitrogen Dioxide
(NO2)
 Motor vehicle exhaust
 High temperature stationary
combustion
 Atmospheric reactions
 Aggravation of respiratory illness
 Reduced visibility
 Reduced plant growth
 Formation of acid rain
Ozone
(O3)
 Atmospheric reaction of organic
gases with nitrogen oxides in
sunlight
 Aggravation of respiratory and cardiovascular diseases  Irritation of eyes
 Impairment of cardiopulmonary function
 Plant leaf injury
Lead
(Pb)
 Contaminated soil  Impairment of blood functions and nerve construction  Behavioral and hearing problems in children
Suspended
Particulate
Matter
(PM2.5 and PM10)
 Stationary combustion of solid
fuels
 Construction activities
 Industrial processes
 Atmospheric chemical reactions
 Reduced lung function
 Aggravation of the effects of gaseous pollutants
 Aggravation of respiratory and cardiorespiratory diseases  Increased cough and chest discomfort
 Soiling
 Reduced visibility
Sulfur Dioxide
(SO2)
 Combustion of sulfur-containing
fossil fuels
 Smelting of sulfur-bearing metal
ores Industrial processes
 Aggravation of respiratory diseases (asthma, emphysema)  Reduced lung function
 Irritation of eyes
 Reduced visibility
 Plant injury
 Deterioration of metals, textiles, leather, finishes, coatings, etc.

Source: California Air Resources Board (2016).
7 CARB. 2000. Risk Reduction Plan to Reduce Particulate Matter Emissions from Diesel-Fueled Engines and Vehicles. October.

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P:\MDT2201\Products\Ardmore Industrial Project AQ GHG Report - 041123.docx «04/11/23» 10 Table B: Federal and State Ambient Air Quality Standards Pollutant
Averaging
Time
California Standardsa Federal Standardsb
Concentrationc Methodd Primaryc,e Secondaryc,f Methodg
Ozone
(O3)
h
1-Hour 0.09 ppm
(180 μg/m3) Ultraviolet
Photometry
– Same as
Primary
Standard
Ultraviolet
Photometry 8-Hour 0.07 ppm
(137 μg/m3)

0.070 ppm
(137 μg/m3)
Respirable
Particulate
Matter
(PM10)
i
24-Hour 50 μg/m3
Gravimetric or Beta
Attenuation
150 μg/m3
Same as
Primary
Standard
Inertial
Separation and
Gravimetric
Analysis
Annual
Arithmetic
Mean
20 μg/m3 –
Fine
Particulate
Matter
(PM2.5)
i
24-Hour - 35 μg/m3
Same as
Primary
Standard
Inertial
Separation and
Gravimetric
Analysis
Annual
Arithmetic
Mean
12 μg/m3 Gravimetric or Beta
Attenuation 12.0 μg/m3
Carbon
Monoxide
(CO)
8-Hour 9.0 ppm
(10 mg/m3) Non-Dispersive
Infrared
Photometry
(NDIR)
9 ppm
(10 mg/m3) – Non-Dispersive
Infrared
Photometry
(NDIR)
1-Hour 20 ppm
(23 mg/m3)
35 ppm
(40 mg/m3)
8-Hour
(Lake Tahoe)
6 ppm
(7 mg/m3) – –
Nitrogen
Dioxide
(NO2)
j
Annual
Arithmetic
Mean

0.03 ppm
(57 μg/m3
) Gas Phase
Chemi-luminescence
53 ppb
(100 μg/m3)
Same as
Primary
Standard
Gas Phase
Chemiluminescence 1-Hour 0.18 ppm
(339 μg/m3)
100 ppb
(188 μg/m3) -
Lead
(Pb)l,m
30-Day
Average 1.5 μg/m3
Atomic
Absorption
– –
High-Volume
Sampler and
Atomic
Absorption
Calendar
Quarter – 1.5 μg/m3(for certain areas)l Same as
Primary
Standard
Rolling 3-
Month
Averagei
– 0.15 μg/m3
Sulfur
Dioxide
(SO2)
k
24-Hour 0.04 ppm
(105 μg/m3)
Ultraviolet
Fluorescence

0.14 ppm
(for certain areas) –
Ultraviolet
Fluorescence;
Spectrophotometry
(Pararosaniline
Method)
3-Hour – – 0.5 ppm
(1300 μg/m3)
1-Hour 0.25 ppm
(655 μg/m3)
75 ppb
(196 μg/m3)
k –
Annual
Arithmetic
Mean
– 0.030 ppm
(for certain areas)k –
VisibilityReducing
Particlesl
8-Hour See footnote n
Beta Attenuation
and Transmittance
through Filter Tape.

No
Federal
Standards
Sulfates 24-Hour 25 μg/m3 Ion Chromatography
Hydrogen
Sulfide 1-Hour 0.03 ppm (42 μg/m3)
Ultraviolet
Fluorescence
Vinyl Chloridej 24-Hour 0.01 ppm
(26 μg/m3) Gas Chromatography
Source: California Air Resources Board (2016).

Table notes are provided on the following page.

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P:\MDT2201\Products\Ardmore Industrial Project AQ GHG Report - 041123.docx «04/11/23» 11 a California standards for ozone, carbon monoxide (except 8-hour Lake Tahoe), sulfur dioxide (1- and 24-hour), nitrogen dioxide, and particulate matter (PM10, PM2.5, and visibility reducing particles), are values that are not to be exceeded. All others are not to be equaled or exceeded. California ambient air quality standards are listed in the Table of Standards in Section 70200 of Title 17 of the California Code of Regulations.
b National standards (other than ozone, particulate matter, and those based on annual arithmetic mean) are not to be exceeded more than once a year. The ozone standard is attained when the fourth highest 8-hour concentration measured at each site in a year, averaged over three years, is equal to or less than the standard. For PM10, the 24-hour standard is attained when the expected number of days per calendar year with a 24-hour average concentration above 150 μg/m3 is equal to or less than one. For PM2.5, the 24-hour standard is attained when 98 percent of the daily concentrations, averaged over three years, are equal to or less than the standard.

Contact USEPA for further clarification and current national policies. c Concentration expressed first in units in which it was promulgated. Equivalent units given in parentheses are based upon a reference temperature of 25°C and a reference pressure of 760 torr. Most measurements of air quality are to be corrected to a reference temperature of 25°C and a reference pressure of 760 torr; ppm in this table refers to ppm by volume, or micromoles of pollutant per mole of gas.
d Any equivalent measurement method which can be shown to the satisfaction of the CARB to give equivalent results at or near the level of the air quality standard may be used.
e National Primary Standards: The levels of air quality necessary, with an adequate margin of safety to protect the public health. f National Secondary Standards: The levels of air quality necessary to protect the public welfare from any known or anticipated adverse effects of a pollutant.
g Reference method as described by the USEPA. An “equivalent method” of measurement may be used but must have a “consistent relationship to the reference method” and must be approved by the USEPA. h On October 1, 2015, the national 8-hour ozone primary and secondary standards were lowered from 0.075 to 0.070 ppm. i On December 14, 2012, the national annual PM2.5 primary standard was lowered from 15 μg/m3 to 12.0 μg/m3 . The existing national
24- hour PM2.5 standards (primary and secondary) were retained at 35 μg/m3 , as was the annual secondary standard of 15 μg/m3. The existing 24-hour PM10 standards (primary and secondary) of 150 μg/m3 also were retained. The form of the annual primary and secondary standards is the annual mean, averaged over 3 years. j To attain the 1-hour national standard, the 3-year average of the annual 98th percentile of the 1-hour daily maximum concentrations at each site must not exceed 100 ppb. Note that the national 1-hour standard is in units of parts per billion (ppb). California standards are in units of parts per million (ppm). To directly compare the national 1-hour standard to the California standards the units can be converted from ppb to ppm. In this case, the national standard of 100 ppb is identical to 0.100 ppm. k On June 2, 2010, a new 1-hour SO2 standard was established and the existing 24-hour and annual primary standards were revoked. To attain the 1-hour national standard, the 3-year average of the annual 99th percentile of the 1-hour daily maximum concentrations at each site must not exceed 75 ppb. The 1971 SO2 national standards (24-hour and annual) remain in effect until one year after an area is designated for the 2010 standard, except that in areas designated nonattainment for the 1971 standards, the 1971 standards remain in effect until implementation plans to attain or maintain the 2010 standards are approved.

Note that the 1-hour national standard is in units of parts per billion (ppb). California standards are in units of parts per million (ppm).

To directly compare the 1-hour national standard to the California standard the units can be converted to ppm. In this case, the national standard of 75 ppb is identical to 0.075 ppm.
l The CARB has identified lead and vinyl chloride as ‘toxic air contaminants’ with no threshold level of exposure for adverse health effects determined. These actions allow for the implementation of control measures at levels below the ambient concentrations specified for these pollutants.
m The national standard for lead was revised on October 15, 2008, to a rolling 3-month average. The 1978 lead standard (1.5 μg/m3 as a
quarterly average) remains in effect until one year after an area is designated for the 2008 standard, except that in areas designated nonattainment for the 1978 standard, the 1978 standard remains in effect until implementation plans to attain or maintain the 2008 standard are approved.
n
In 1989, the CARB converted both the general statewide 10-mile visibility standard and the Lake Tahoe 30-mile visibility standard to instrumental equivalents, which are “extinction of 0.23 per kilometer” and “extinction of 0.07 per kilometer” for the statewide and Lake Tahoe Air Basin standards, respectively.
°C = degrees Celsius
µg/m3 = micrograms per cubic meter
CARB = California Air Resources Board
mg/m3 = milligrams per cubic meter
ppb = parts per billion
ppm = parts per million
USEPA = United States Environmental Protection Agency

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GREENHOUSE GASES AND GLOBAL CLIMATE CHANGE
Global climate change is the observed increase in the average temperature of the Earth’s atmosphere and oceans in recent decades. The Earth’s average near-surface atmospheric temperature rose 0.6 ± 0.2° Celsius or 1.1 ± 0.4° Fahrenheit (°F) in the 20th century. The prevailing scientific opinion on climate change is that most of the warming observed over the last 50 years is attributable to human activities. The increased amounts of carbon dioxide (CO2) and other GHGs are the primary causes of the human-induced component of warming. GHGs are released by the burning of fossil fuels, land clearing, agriculture, and other activities, and lead to an increase in the greenhouse effect.8
GHGs are present in the atmosphere naturally, are released by natural sources, or are formed from secondary reactions taking place in the atmosphere. The gases that are widely seen as the principal contributors to human-induced global climate change are:
• CO2
• Methane (CH4)
• Nitrous oxide (N2O)
• Hydrofluorocarbons (HFC)
• Perfluorocarbons (PFC)
• Sulfur hexafluoride (SF6)
Over the last 200 years, humans have caused substantial quantities of GHGs to be released into the atmosphere. These extra emissions are increasing GHG concentrations in the atmosphere, and enhancing the natural greenhouse effect, which is believed to be causing global warming. While manmade GHGs include naturally occurring GHGs such as CO2, CH4, and N2O, some gases, like HFCs, PFCs, and SF6 are completely new to the atmosphere.

Certain gases, such as water vapor, are short-lived in the atmosphere. Others remain in the atmosphere for significant periods of time, contributing to climate change in the long term. Water vapor is excluded from the list of GHGs above because it is short-lived in the atmosphere and its atmospheric concentrations are largely determined by natural processes, such as oceanic evaporation. For the purposes of this air quality analysis, the term “GHGs” will refer collectively to the six gases listed above only.

These gases vary considerably in terms of global warming potential (GWP), which is a concept developed to compare the ability of each GHG to trap heat in the atmosphere relative to another gas. The global warming potential is based on several factors, including the relative effectiveness of a gas to absorb infrared radiation and length of time that the gas remains in the atmosphere 8 The temperature on Earth is regulated by a system commonly known as the “greenhouse effect.” Just as the glass in a greenhouse lets heat from sunlight in and reduces the heat escaping, greenhouse gases like carbon dioxide, methane, and nitrous oxide in the atmosphere keep the Earth at a relatively even temperature. Without the greenhouse effect, the Earth would be a frozen globe; thus, although an excess of greenhouse gas results in global warming, the naturally occurring greenhouse effect is necessary to keep our planet at a comfortable temperature.

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P:\MDT2201\Products\Ardmore Industrial Project AQ GHG Report - 041123.docx «04/11/23» 13 (“atmospheric lifetime”). The GWP of each gas is measured relative to CO2, the most abundant GHG; the definition of GWP for a particular GHG is the ratio of heat trapped by one unit mass of the GHG to the ratio of heat trapped by one unit mass of CO2 over a specified time period. GHG emissions are typically measured in terms of pounds or tons of “CO2 equivalents” (CO2e). Table C shows the GWP for each type of GHG. For example, SF6 is 23,900 times more potent at contributing to global warming than carbon dioxide.

Table C: Global Warming Potential of Greenhouse Gases
Gas
Atmospheric Lifetime
(Years)
Global Warming Potential
(100-Year Time Horizon)
Carbon Dioxide 50-200 1
Methane 12 25
Nitrous Oxide 114 310
HFC-23 270 11,700
HFC-134a 14 140
HFC-152a 1.4 140
PFC: Tetrafluoromethane (CF4) 50,000 6,500
PFC: Hexafluoromethane (C2F6) 10,000 9,200
Sulfur Hexafluoride (SF6) 3,200 23,900
Source: Intergovernmental Panel on Climate Change (2007).

The following discussion summarizes the characteristics of the six GHGs and black carbon.

Carbon Dioxide
In the atmosphere, carbon generally exists in its oxidized form, as CO2. Natural sources of CO2 include the respiration (breathing) of humans, animals, and plants, volcanic out gassing, decomposition of organic matter and evaporation from the oceans. Human caused sources of CO2 include the combustion of fossil fuels and wood, waste incineration, mineral production, and deforestation. Natural sources release approximately 150 billion tons of CO2 each year, far outweighing the 7 billion tons of manmade emissions of CO2 each year. Nevertheless, natural removal processes, such as photosynthesis by land- and ocean-dwelling plant species, cannot keep pace with this extra input of manmade CO2, and consequently, the gas is building up in the atmosphere.

In 2020, total annual CO2 accounted for approximately 80.2 percent of California's overall GHG emissions.9 Transportation is the single largest source of CO2 in California, which is primarily comprised of on-road travel. Electricity production, industrial and residential sources also make important contributions to CO2 emissions in California.

Methane
CH4 is produced when organic matter decomposes in environments lacking sufficient oxygen.

Natural sources include wetlands, termites, and oceans. Decomposition in landfills accounts for the 9 CARB. 2021. GHGs Descriptions & Sources in California. Website: ww2.arb.ca.gov/ghg-descriptionssources (accessed December 2022).

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P:\MDT2201\Products\Ardmore Industrial Project AQ GHG Report - 041123.docx «04/11/23» 14 majority of human-generated CH4 emissions in California and in the United States as a whole.

Agricultural processes such as intestinal fermentation, manure management, and rice cultivation are also significant sources of CH4 in California. Total annual emissions of CH4 accounted for approximately 10.5 percent of GHG emissions in California in 2020. 10 Nitrous Oxide
N2O is produced naturally by a wide variety of biological sources, particularly microbial action in soils and water. Tropical soils and oceans account for the majority of natural source emissions. Nitrous oxide is a product of the reaction between nitrogen and oxygen during fuel combustion. Both mobile and stationary combustion emit N2O, and the quantity emitted varies according to the type of fuel, technology, and pollution control device used, as well as maintenance and operating practices. Agricultural soil management and fossil fuel combustion are the primary sources of human-generated N2O emissions in California. Nitrous oxide emissions accounted for approximately

3.5 percent of GHG emissions in California in 2020.
11 Hydrofluorocarbons, Perfluorocarbons, and Sulfur Hexafluoride HFCs are primarily used as substitutes for ozone-depleting substances regulated under the Montreal Protocol.12 PFCs and SF6 are emitted from various industrial processes, including aluminum smelting, semiconductor manufacturing, electric power transmission and distribution, and magnesium casting. There is no aluminum or magnesium production in California; however, the rapid growth in the semiconductor industry leads to greater use of PFCs. HFCs, PFCs, and SF6 accounted for about

5.5 percent of GHG emissions in California in 2020.
13 Black Carbon
Black carbon is the most strongly light-absorbing component of PM formed by burning fossil fuels such as coal, diesel, and biomass. Black carbon is emitted directly into the atmosphere in the form of PM2.5 and is the most effective form of PM, by mass, at absorbing solar energy. Per unit of mass in the atmosphere, black carbon can absorb 1 million times more energy than CO2. 14 Black carbon
contributes to climate change both directly, such as absorbing sunlight, and indirectly, such as affecting cloud formation. However, because black carbon is short-lived in the atmosphere, it can be difficult to quantify its effect on global-warming.

Most United States emissions of black carbon come from mobile sources (52 percent), particularly from diesel-fueled vehicles. The other major source of black carbon is open biomass burning, 10 CARB. 2021. GHGs Descriptions & Sources in California. Website: ww2.arb.ca.gov/ghg-descriptionssources (accessed December 2022). 11 Ibid. 12 The Montreal Protocol is an international treaty that was approved on January 1, 1989, and was designated to protect the ozone layer by phasing out the production of several groups of halogenated hydrocarbons believed to be responsible for ozone depletion. 13 CARB. 2021. op. cit. 14 United States Environmental Protection Agency (USEPA). 2015. Black Carbon, Basic Information. Last updated February 14, 2017. Website: 19january2017snapshot.epa.gov/www3/airquality/ blackcarbon/basic.html (accessed December 2022).

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P:\MDT2201\Products\Ardmore Industrial Project AQ GHG Report - 041123.docx «04/11/23» 15 including wildfires, although residential heating and industry also contribute. Black carbon emissions in the U.S. are projected to decline substantially by 2030, largely due to controls on new mobile diesel emissions.15
15 USEPA. 2017. Black Carbon, Basic Information. February 14, 2017. Website: 19january2017snapshot. epa.gov/www3/airquality/blackcarbon/basic.html (accessed December 2022).

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REGULATORY SETTING
This section provides regulatory background information for air quality and GHG.

AIR QUALITY REGULATORY SETTING
Federal Regulations
Federal Clean Air Act
The 1970 federal Clean Air Act authorized the establishment of national health-based air quality standards and also set deadlines for their attainment. The federal Clean Air Act Amendments of 1990 changed deadlines for attaining national standards as well as the remedial actions required of areas of the nation that exceed the standards. Under the Clean Air Act, State and local agencies in areas that exceed the national standards are required to develop State Implementation Plans to demonstrate how they will achieve the national standards by specified dates.

State Regulations
California Clean Air Act
In 1988, the California Clean Air Act (CCAA) required that all air districts in the State endeavor to achieve and maintain California ambient air quality standards (AAQS) for CO2, O3, SO2, and NO2 by the earliest practical date. The California Clean Air Act provides districts with authority to regulate indirect sources and mandates that air quality districts focus particular attention on reducing emissions from transportation and area-wide emission sources. Each nonattainment district is required to adopt a plan to achieve a 5 percent annual reduction, averaged over consecutive 3-year periods, in district-wide emissions of each nonattainment pollutant or its precursors. A Clean Air Plan shows how a district would reduce emissions to achieve air quality standards. Generally, the State standards for these pollutants are more stringent than the national standards.

California Air Resources Board
The CARB is the State’s “clean air agency.” The CARB’s goals are to attain and maintain healthy air quality, protect the public from exposure to toxic air contaminants, and oversee compliance with air pollution rules and regulations.

Assembly Bill 2588 Air Toxics “Hot Spots” Information and Assessment Act Under Assembly Bill (AB) 2588, stationary sources of air pollutants are required to report the types and quantities of certain substances their facilities routinely released into the air. The goals of the Air Toxics “Hot Spots” Act are to collect emission data, identify facilities having localized impacts, determine health risks, and notify nearby residents of significant risks.

The California Air Resources Board HandbookThe CARB has developed an Air Quality and Land Use Handbook16 intended to serve as a general reference guide for evaluating and reducing air pollution impacts associated with new projects that go through the land use decision-making process. 16 CARB. 2005. Air Quality and Land Use Handbook: A Community Health Perspective. April.

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P:\MDT2201\Products\Ardmore Industrial Project AQ GHG Report - 041123.docx «04/11/23» 17 According to the CARB Handbook, recent air pollution studies have shown an association between respiratory and other non-cancer health effects and proximity to high traffic roadways. Other studies have shown that diesel exhaust and other cancer-causing chemicals emitted from cars and trucks are responsible for much of the overall cancer risk from airborne toxics in California. The CARB Handbook recommends that county and city planning agencies strongly consider proximity to these sources when finding new locations for “sensitive” land uses such as homes, medical facilities, daycare centers, schools, and playgrounds.

Land use designations with air pollution sources of concern include freeways, rail yards, ports, refineries, distribution centers, chrome plating facilities, dry cleaners, and large gasoline service stations. Key recommendations in the CARB Handbook include taking steps to avoid siting new, sensitive land uses:
• Within 500 feet of a freeway, urban roads with 100,000 vehicles/day or rural roads with 50,000 vehicles/day.
• Within 1,000 feet of a major service and maintenance rail yard. • Immediately downwind of ports (in the most heavily impacted zones) and petroleum refineries. • Within 300 feet of any dry cleaning operation (for operations with two or more machines, provide 500 feet).
• Within 300 feet of a large gas station (defined as a facility with a throughput of 3.6 million gallons per year or greater).

The CARB Handbook specifically states that its recommendations are advisory and acknowledges land use agencies have to balance other considerations, including housing and transportation needs, economic development priorities, and other quality of life issues.

The recommendations are generalized and do not consider site-specific meteorology, freeway truck percentages, or other factors that influence risk for a particular project site. The purpose of this guidance is to further examine project sites for actual health risk associated with the location of new sensitive land uses.

Regional Regulations
The SLO County APCD has specific air quality-related planning documents, rules, and regulations.

This section summarizes the local planning documents and regulations that may be applicable to the proposed project as administered by the SLO County APCD with CARB oversight.

CEQA Air Quality Handbook
The SLO County APCD 2012 CEQA Air Quality Handbook defines the criteria used by the SLO County APCD when evaluating new development to determine when an air quality analysis is necessary, the type of analysis that should be performed, the significance of the impacts predicted by the analysis, and the mitigation measures to reduce overall air quality impacts. The 2017 Clarification Memo for

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P:\MDT2201\Products\Ardmore Industrial Project AQ GHG Report - 041123.docx «04/11/23» 18 the 2012 CEQA Air Quality Handbook provides administrative clarity on certain sections of the Handbook. In addition, in 2021, the SLO County APCD created a drop-down information guide and a CEQA Training Guided Question document to help answer the air quality and GHG questions from the Appendix G: Environmental Checklist Form.

Clean Air Plan
As part of the CCAA, the SLO County APCD is required to develop a plan to achieve and maintain the state ozone standard by the earliest practicable date. The 2001 Clean Air Plan, adopted on March 26, 2002, outlines SLO County APCD’s strategies to reduce ozone precursor emissions from a wide variety of stationary and mobile sources.

Ozone Emergency Episode Plan
The San Luis Obispo County Ozone Emergency Episode Plan provides the basis for taking actions when ambient ozone concentrations reach a level that could endanger public health in San Luis Obispo County. It identifies criteria for the four levels of emergency episodes and related components for public announcements whenever an episode has been identified. This document will be incorporated into the California Infrastructure State Implementation Plan (I-SIP).

PM Report
In 2003, the California Legislature enacted Senate Bill (SB) 656, to reduce public exposure to particulate matter. SB 656 required CARB in consultation with local air pollution control districts, to develop and adopt a list of PM reduction strategies. SLO County APCD adopted the PM Report and associated control measures in July 2005.

Local Regulations
City of Paso Robles General Plan
The City of Paso Robles adopted the Conservation Element of the General Plan in November 2014, which addresses air quality.17 The Conservation Element contains goals and policies that seek to maintain air quality by taking actions to reduce traffic congestion, vehicle miles traveled, and air pollutant emissions. The following policies are applicable to the proposed project • Policy C-2A: Traffic Congestion Reduction. Implement circulation systems improvements to reduce congestion and associated air contaminant emissions. • Policy C-2B: VMT Reduction. Implement programs to reduce the number of vehicle miles traveled (VMT), especially by single occupant vehicles, including providing opportunities for mixed-use projects.
17 City of Paso Robles. 2014. City of Paso Robles General Plan, Conservation Element. November 19. Website:
https://www.prcity.com/DocumentCenter/View/25852/20141119-Conservation-Element (accessed December 2022).

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P:\MDT2201\Products\Ardmore Industrial Project AQ GHG Report - 041123.docx «04/11/23» 19 ○ Provide bikeways, pedestrian paths, and transit turn-outs/stops as requirements of development applications.
○ Encourage the development of transit facilities.
○ Strive to recruit new industry as part of on-going efforts to create a balanced community where the majority of residents can live, work, shop, and play, thereby reducing the commute lengths for some city residents.
• Policy C-2C: Emissions Reduction. Take steps to reduce creation of air contaminant emissions.

GREENHOUSE GAS REGULATORY SETTING
This section describes regulations related to global climate change at the federal, State, and local level.

Federal Regulations
The United States has historically had a voluntary approach to reducing GHG emissions. However, on April 2, 2007, the United States Supreme Court ruled that the USEPA has the authority to regulate CO2 emissions under the federal Clean Air Act. While there currently are no adopted federal regulations for the control or reduction of GHG emissions, the USEPA commenced several actions in 2009 to implement a regulatory approach to global climate change.

This includes the 2009 USEPA final rule for mandatory reporting of GHGs from large GHG emission sources in the United States. Additionally, the USEPA Administrator signed an endangerment finding action in 2009 under the Clean Air Act, finding that six GHGs (CO2, CH4, N2O, HFCs, PFCs, SF6) constitute a threat to public health and welfare, and that the combined emissions from motor vehicles cause and contribute to global climate change, leading to national GHG emission standards.

In October 2012, the USEPA and the National Highway Traffic Safety Administration (NHTSA), on behalf of the United States Department of Transportation, issued final rules to further reduce GHG emissions and improve Corporate Average Fuel Economy (CAFE) standards for light-duty vehicles for model years 2017 and beyond (77 Federal Register 62624). The NHTSA’s CAFE standards have been enacted under the Energy Policy and Conservation Act since 1978. This national program requires automobile manufacturers to build a single light-duty national fleet that meets all requirements under both federal programs and the standards of California and other states. This program would increase fuel economy to the equivalent of 54.5 miles per gallon, limiting vehicle emissions to 163 grams of CO2 per mile for the fleet of cars and light-duty trucks by model year 2025 (77 Federal Register 62630).

On March 31, 2022, the NHTSA finalized the CAFE standards for Model Years 2024–2026 Passenger Cars and Light Trucks. The amended CAFE standards would require an industry wide fleet average of approximately 49 miles per gallon for passenger cars and light trucks in model year 2026, by increasing fuel efficiency by 8 percent annually for model years 2024–2025, and 10 percent annually for model year 2026. The final standards are estimated to save about 234 billion gallons of gas between model years 2030 to 2050.

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The CARB is the lead agency for implementing climate change regulations in the State. Since its formation, the CARB has worked with the public, the business sector, and local governments to find solutions to California’s air pollution problems. Key efforts by the State are described below.

Assembly Bill 1493 (2002)
In a response to the transportation sector’s significant contribution to California’s CO2 emissions, AB 1493 was enacted on July 22, 2002. AB 1493 requires the CARB to set GHG emission standards for passenger vehicles and light duty trucks (and other vehicles whose primary use is noncommercial personal transportation in the State) manufactured in 2009 and all subsequent model years. These standards (starting in model years 2009 to 2016) were approved by the CARB in 2004, but the needed waiver of CAA Preemption was not granted by the USEPA until June 30, 2009. The CARB responded by amending its original regulation, now referred to as Low Emission Vehicle III, to take effect for model years starting in 2017 to 2025. The Trump administration revoked California’s waiver in 2019, but the Biden administration restored California’s waiver in 2021 Executive Order S-3-05 (2005)
Governor Arnold Schwarzenegger signed Executive Order (EO) S-3-05 on June 1, 2005, which proclaimed that California is vulnerable to the impacts of climate change. To combat those concerns, this executive order established California’s GHG emissions reduction targets, which established the following goals.
• GHG emissions should be reduced to 2000 levels by 2010. • GHG emissions should be reduced to 1990 levels by 2020. • GHG emissions should be reduced to 80 percent below 1990 levels by 2050.

The Secretary of the California Environmental Protection Agency (CalEPA) is required to coordinate efforts of various State agencies in order to collectively and efficiently reduce GHGs. A biannual progress report must be submitted to the Governor and State Legislature disclosing the progress made toward greenhouse emission reduction targets. In addition, another biannual report must be submitted illustrating the impacts of global warming on California’s water supply, public health, agriculture, the coastline, and forestry, and report possible mitigation and adaptation plans to address these impacts.

The Secretary of CalEPA leads this CAT made up of representatives from State agencies as well as numerous other boards and departments. The CAT members work to coordinate statewide efforts to implement global warming emission reduction programs and the State’s Climate Adaptation Strategy. The CAT is also responsible for reporting on the progress made toward meeting the statewide GHG targets that were established in the executive order and further defined under AB 32, the “Global Warming Solutions Act of 2006.” The first CAT Report to the Governor and the Legislature was released in March 2006, which laid out 46 specific emission reduction strategies for reducing GHG emissions and reaching the targets established in the executive order. The most recent report was released in December 2020.

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P:\MDT2201\Products\Ardmore Industrial Project AQ GHG Report - 041123.docx «04/11/23» 21 Assembly Bill 32 (2006), California Global Warming Solutions Act California’s major initiative for reducing GHG emissions is AB 32, passed by the State legislature on August 31, 2006. This effort aims at reducing GHG emissions to 1990 levels by 2020. The CARB has established the level of GHG emissions in 1990 at 427 million metric tons (MMT) of CO2e. The emissions target of 427 MMT requires the reduction of 169 MMT from the State’s projected business-as-usual 2020 emissions of 596 MMT. AB 32 requires the CARB to prepare a Scoping Plan that outlines the main State strategies for meeting the 2020 deadline and to reduce GHGs that contribute to global climate change. The Scoping Plan was approved by the CARB on December 11, 2008, and contains the main strategies California will implement to achieve the reduction of approximately 169 MMT of CO2e, or approximately 30 percent, from the State’s projected 2020 emissions level of 596 MMT of CO2e under a business-as-usual scenario (this is a reduction of 42 MMT CO2e, or almost 10 percent from 2002–2004 average emissions). The Scoping Plan also includes CARB-recommended GHG reductions for each emissions sector of the State’s GHG inventory. The Scoping Plan calls for the largest reductions in GHG emissions to be achieved by implementing the following measures and standards.
• Improved emissions standards for light-duty vehicles (estimated reductions of 31.7 MMT CO2e); • The Low-Carbon Fuel Standard (15.0 MMT CO2e)
• Energy efficiency measures in buildings and appliances and the widespread development of combined heat and power systems (26.3 MMT CO2e)
• A renewable portfolio standard for electricity production (21.3 MMT CO2e) The Scoping Plan identifies 18 emission reduction measures that address cap-and-trade programs, vehicle gas standards, energy efficiency, low carbon fuel standards (LCFS), renewable energy, regional transportation-related GHG targets, vehicle efficiency measures, goods movement, solar roof programs, industrial emissions, high-speed rail, green building strategies, recycling, sustainable forests, water, and air. The measures would result in a total reduction of 174 MMT CO2e by 2020.

On August 24, 2011, the CARB unanimously approved both the new supplemental assessment and reapproved its Scoping Plan, which provides the overall roadmap and rule measures to carry out AB 32. The CARB also approved a more robust CEQA equivalent document supporting the supplemental analysis of the cap-and-trade program. The cap-and-trade took effect on January 1, 2012, with an enforceable compliance obligation that began January 1, 2013.

CARB has not yet determined what amount of GHG reductions it recommends from local government operations and local land use decisions; however, the Scoping Plan states that land use planning and urban growth decisions will play an important role in the State’s GHG reductions because local governments have primary authority to plan, zone, approve, and permit how land is developed to accommodate population growth and the changing needs of their jurisdictions (meanwhile, CARB is also developing an additional protocol for community emissions). CARB further acknowledges that decisions on how land is used will have large impacts on the GHG emissions that will result from the transportation, housing, industry, forestry, water, agriculture, electricity, and

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P:\MDT2201\Products\Ardmore Industrial Project AQ GHG Report - 041123.docx «04/11/23» 22 natural gas emission sectors. The Scoping Plan states that the ultimate GHG reduction assignment to local government operations is to be determined. With regard to land use planning, the Scoping Plan expects an approximately 5.0 MMT CO2e reduction due to implementation of SB 375.

In addition to reducing GHG emissions to 1990 levels by 2020, AB 32 directed the CARB and the CAT to identify a list of “discrete early action GHG reduction measures” that could be adopted and made enforceable by January 1, 2010. On January 18, 2007, Governor Schwarzenegger signed EO S-1-07, further solidifying California’s dedication to reducing GHGs by setting a new Low Carbon Fuel Standard (LCFS). This executive order sets a target to reduce the carbon intensity of California transportation fuels by at least 10 percent by 2020 and directs the CARB to consider the LCFS as a discrete early action measure. In 2011, United States District Court Judge Lawrence O’Neil issued an injunction preventing implementation of the LCFS, ruling that it is unconstitutional. In 2012, the Ninth Circuit Court of Appeal stayed the District Court’s injunction, allowing implementation of the LCFS. The Ninth Circuit decided to uphold the LCFS.

In June 2007, the CARB approved a list of 37 early action measures, including three discrete early action measures (LCFS, Restrictions on GWP Refrigerants, and Landfill CH4 Capture).18 Discrete early action measures are measures that were required to be adopted as regulations and made effective no later than January 1, 2010, the date established by Health and Safety Code Section 38560.5. The CARB adopted additional early action measures in October 2007 that tripled the number of discrete early action measures. These measures relate to truck efficiency, port electrification, reduction of PFCs from the semiconductor industry, reduction of propellants in consumer products, proper tire inflation, and SF6 reductions from the non-electricity sector. The combination of early action measures is estimated to reduce statewide GHG emissions by nearly 16 MMT.19 In June 2007, the CARB approved a list of 37 early action measures, including three discrete early action measures (LCFS, Restrictions on GWP Refrigerants, and Landfill CH4 Capture).20 Discrete early action measures are measures that were required to be adopted as regulations and made effective no later than January 1, 2010, the date established by Health and Safety Code Section 38560.5. The CARB adopted additional early action measures in October 2007 that tripled the number of discrete early action measures. These measures relate to truck efficiency, port electrification, reduction of PFCs from the semiconductor industry, reduction of propellants in consumer products, proper tire inflation, and SF6 reductions from the non-electricity sector. The combination of early action measures is estimated to reduce statewide GHG emissions by nearly 16 MMT.21 The CARB approved the First Update to the Climate Change Scoping Plan on May 22, 2014. The First Update identifies opportunities to leverage existing and new funds to further drive GHG emission reductions through strategic planning and targeted low carbon investments. The First Update defines CARB climate change priorities until 2020, and also sets the groundwork to reach long-term 18 California Air Resources Board (CARB). 2007a. Expanded List of Early Action Measures to Reduce Greenhouse Gas Emissions in California Recommended for Board Consideration. October. 19 CARB. 2007b. “ARB approves tripling of early action measures required under AB 32.” News Release 07-

46. October 25. 20 CARB. 2007a. op cit. 21 CARB. 2007b. op cit.

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P:\MDT2201\Products\Ardmore Industrial Project AQ GHG Report - 041123.docx «04/11/23» 23 goals set forth in EOs S-3-05 and B-16-2012. The Update highlights California’s progress toward meeting the “near-term” 2020 GHG emission reduction goals as defined in the initial Scoping Plan. It also evaluates how to align the State’s “longer-term” GHG reduction strategies with other State policy priorities for water, waste, natural resources, clean energy, transportation, and land use.

CARB released a second update to the Scoping Plan, the 2017 Scoping Plan, 22 to reflect the 2030
target set by EO B-30-15 and codified by SB 32.

The 2022 Scoping Plan23 assesses progress toward the statutory 2030 target, while laying out a path to achieving carbon neutrality no later than 2045. The 2022 Scoping Plan Update focuses on outcomes needed to achieve carbon neutrality by assessing paths for clean technology, energy deployment, natural and working lands, and others, and is designed to meet the State’s long-term climate objectives and support a range of economic, environmental, energy security, environmental justice, and public health priorities.

Senate Bill 97 (2007)
SB 97, signed by the Governor in August 2007 (Chapter 185, Statutes of 2007; Public Resources Code, Sections 21083.05 and 21097), acknowledges climate change is a prominent environmental issue that requires analysis under CEQA. This bill directed the Governor’s Office of Planning and Research to prepare, develop, and transmit to the California Resources Agency guidelines for mitigating GHG emissions or the effects of GHG emissions, as required by CEQA.

The California Natural Resources Agency adopted the amendments to the State CEQA Guidelines in November 2018, which went into effect in December 2018. The amendments do not identify a threshold of significance for GHG emissions, nor do they prescribe assessment methodologies or specific mitigation measures. The amendments encourage lead agencies to consider many factors in performing a CEQA analysis, but preserve the discretion granted by CEQA to lead agencies in making their own determinations based on substantial evidence. The amendments also encourage public agencies to make use of programmatic mitigation plans and programs when they perform individual project analyses.

Senate Bill 375 (2008)
SB 375, the Sustainable Communities and Climate Protection Act, which establishes mechanisms for the development of regional targets for reducing passenger vehicle GHG emissions, was adopted by the State on September 30, 2008. On September 23, 2010, the CARB adopted the vehicular GHG emissions reduction targets that had been developed in consultation with the MPO; the targets require a 6 to 15 percent reduction by 2020 and between 13 to 19 percent reduction by 2035 for each MPO. SB 375 recognizes the importance of achieving significant GHG reductions by working with cities and counties to change land use patterns and improve transportation alternatives.

Through the SB 375 process, MPOs such as the SCAG will work with local jurisdictions in the development of Sustainable Communities Strategy (SCS) designed to integrate development patterns and the transportation network in a way that reduces GHG emissions while meeting housing needs and other regional planning objectives. Pursuant to SB 375, the Los Angeles/Southern 22 CARB. 2017. California’s 2017 Climate Change Scoping Plan. November. 23 CARB. 2021. op. cit.

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P:\MDT2201\Products\Ardmore Industrial Project AQ GHG Report - 041123.docx «04/11/23» 24 California reduction targets for per capita vehicular emissions are 8 percent by 2020 and 19 percent by 2035, as shown in Table D.

Table D: Senate Bill 375 Regional Greenhouse Gas
Emissions Reduction Targets
Metropolitan Planning Organization By 2020 (percentage) By 2035 (percentage) San Francisco Bay Area 10 19
San Diego 15 19
Sacramento 7 19
Central Valley/San Joaquin 6-13 13-16
Los Angeles/Southern California 8 19
Source: California Air Resources Board (2018).

Executive Order B-30-15 (2015)
Governor Jerry Brown signed EO B-30-15 on April 29, 2015, which added the immediate target of:
• GHG emissions should be reduced to 40 percent below 1990 levels by 2030.

All State agencies with jurisdiction over sources of GHG emissions were directed to implement measures to achieve reductions of GHG emissions to meet the 2030 and 2050 targets. CARB was directed to update the AB 32 Scoping Plan to reflect the 2030 target, and therefore, is moving forward with the update process. The mid-term target is critical to help frame the suite of policy measures, regulations, planning efforts, and investments in clean technologies and infrastructure needed to continue reducing emissions.

Senate Bill 350 (2015) Clean Energy and Pollution Reduction Act SB 350, signed by Governor Jerry Brown on October 7, 2015, updates and enhances AB 32 by introducing the following set of objectives in clean energy, clean air, and pollution reduction for 2030.
• Raise California’s renewable portfolio standard from 33 percent to 50 percent. • Increasing energy efficiency in buildings by 50 percent by the year 2030.

The 50 percent renewable energy standard will be implemented by the California Public Utilities Commission for the private utilities and by the California Energy Commission for municipal utilities.

Each utility must submit a procurement plan showing it will purchase clean energy to displace other non-renewable resources. The 50 percent increase in energy efficiency in buildings must be achieved through the use of existing energy efficiency retrofit funding and regulatory tools already available to State energy agencies under existing law. The addition made by this legislation requires state energy agencies to plan for and implement those programs in a manner that achieves the energy efficiency target.

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P:\MDT2201\Products\Ardmore Industrial Project AQ GHG Report - 041123.docx «04/11/23» 25 Senate Bill 32, California Global Warming Solutions Act of 2016, and Assembly Bill 197 In summer 2016, the Legislature passed, and the Governor signed, SB 32 and AB 197. SB 32 affirms the importance of addressing climate change by codifying into statute the GHG emissions reductions target of at least 40 percent below 1990 levels by 2030 contained in Governor Jerry Brown’s April 2015 EO B-30-15. SB 32 builds on AB 32 and keeps California on the path toward achieving the State’s 2050 objective of reducing emissions to 80 percent below 1990 levels, consistent with an IPCC analysis of the emissions trajectory that would stabilize atmospheric GHG concentrations at 450 parts per million (ppm) CO2e and reduce the likelihood of catastrophic impacts from climate change.

The companion bill to SB 32, AB 197, provides additional direction to CARB related to the adoption of strategies to reduce GHG emissions. Additional direction in AB 197 meant to provide easier public access to air emissions data that are collected by CARB was posted in December 2016.

Senate Bill 100
On September 10, 2018, Governor Jerry Brown signed SB 100, which raises California’s renewables portfolio standard requirements to 60 percent by 2030, with interim targets, and 100 percent by 2045. The bill also establishes a State policy that eligible renewable energy resources and zerocarbon resources supply 100 percent of all retail sales of electricity to California end-use customers and 100 percent of electricity procured to serve all State agencies by December 31, 2045. Under the bill, the State cannot increase carbon emissions elsewhere in the Western grid or allow resource shuffling to achieve the 100 percent carbon-free electricity target.

Executive Order B-55-18
EO B-55-18, signed September 10, 2018, sets a goal “to achieve carbon neutrality as soon as possible, and no later than 2045, and achieve and maintain net negative emissions thereafter.” EO B-55-18 directs CARB to work with relevant State agencies to ensure future Scoping Plans identify and recommend measures to achieve the carbon neutrality goal. The goal of carbon neutrality by 2045 is in addition to other statewide goals, meaning not only should emissions be reduced to 80 percent below 1990 levels by 2050, but that, by no later than 2045, the remaining emissions be offset by equivalent net removals of CO2e from the atmosphere, including through sequestration in forests, soils, and other natural landscapes.

Title 24, Building Standards Code and CALGreen Code
In November 2008, the California Building Standards Commission established the California Green Building Standards (CALGreen) Code, which sets performance standards for residential and nonresidential development to reduce environmental impacts and encourage sustainable construction practices. The CALGreen Code addresses energy efficiency, water conservation, material conservation, planning and design, and overall environmental quality. The CALGreen Code is updated every 3 years and was most recently updated in 2022 to include new mandatory measures for residential as well as non-residential uses; the new measures will apply to projects seeking building permits on or after January 1, 2023.

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P:\MDT2201\Products\Ardmore Industrial Project AQ GHG Report - 041123.docx «04/11/23» 26 Cap and Trade
The development of a cap-and-trade program was included as a key reduction measure of the CARB AB 32 Climate Change Scoping Plan. The cap-and-trade program will help put California on the path to meet its goal of reducing GHG emissions to 1990 levels by 2020 and ultimately achieving an 80 percent reduction from 1990 levels by 2050. The cap-and-trade emissions trading program developed by the CARB took effect on January 1, 2012, with enforceable compliance obligations beginning January 1, 2013. The cap-and-trade program aims to regulate GHG emissions from the largest producers in the State by setting a statewide firm limit, or cap, on allowable annual GHG emissions. The cap was set in 2013 at approximately 2 percent below the emissions forecast for 2020. In 2014, the cap declined approximately 2 percent. Beginning in 2015 and continuing through 2020, the cap has been declining approximately 3 percent annually. The CARB administered the first auction on November 14, 2012, with many of the qualified bidders representing corporations or organizations that produce large amounts of GHG emissions, including energy companies, agriculture and food industries, steel mills, cement companies, and universities. On January 1, 2015, compliance obligation began for distributors of transportation fuels, natural gas, and other fuels.

The cap-and-trade program was initially slated to sunset in 2020, but the passage of SB 398 in 2017 extended the program through 2030.

Executive Order N-79-20
EO N-79-20, signed by Governor Gavin Newsom on September 23, 2020, sets the following goals for the State: 100 percent of in-state sales of new passenger cars and trucks shall be zero-emission by 2035; 100 percent of medium- and heavy-duty vehicles in the State shall be zero-emission by 2045 for all operations where feasible and by 2035 for drayage trucks; and 100 percent of off-road vehicles and equipment in the State shall be zero-emission by 2035, where feasible.

Low Carbon Fuel Standard
In January 2007, EO S-01-07 established a low carbon fuel standard (LCFS). This executive order calls for a statewide goal to be established to reduce the carbon intensity of California’s transportation fuels by at least 10 percent by 2020, and that an LCFS for transportation fuels be established for California. The LCFS applies to all refiners, blenders, producers, or importers (“Providers”) of transportation fuels in California, including fuels used by off-road construction equipment. In June 2007, CARB adopted the LCFS under AB 32 pursuant to Health and Safety Code Section 38560.5, and, in April 2009, CARB approved the new rules and carbon intensity reference values with new regulatory requirements taking effect in January 2011. The standards require providers of transportation fuels to report on the mix of fuels they provide and demonstrate they meet the LCFS intensity standards annually. This is accomplished by ensuring that the number of “credits” earned by providing fuels with a lower carbon intensity than the established baseline (or obtained from another party) is equal to or greater than the “deficits” earned from selling higher intensity fuels. In response to certain court rulings, CARB re-adopted the LCFS regulation in September 2015, and the LCFS went into effect on January 1, 2016. In 2018, CARB approved amendments to the regulation to readjust carbon intensity benchmarks to meet California’s 2030 GHG reductions targets under SB 32.

These amendments include opportunities to promote zero-emission vehicle (ZEV) adoption, carbon capture and sequestration, and advanced technologies for decarbonization of the transportation sector.

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P:\MDT2201\Products\Ardmore Industrial Project AQ GHG Report - 041123.docx «04/11/23» 27 Advanced Clean Cars Program
In January 2012, CARB approved the Advanced Clean Cars program, which combines the control of GHG emissions and criteria air pollutants, as well as requirements for greater numbers of ZEVs, into a single package of regulatory standards for vehicle model years 2017 through 2025. The new regulations strengthen the GHG standard for 2017 models and beyond. This will be achieved through existing technologies, the use of stronger and lighter materials, and more efficient drivetrains and engines. The program’s ZEVs regulation requires battery, fuel cell, and/or plug-in hybrid electric vehicles to account for up to 15 percent of California’s new vehicle sales by 2025. The program also includes a clean fuels outlet regulation designed to support the commercialization of zero-emission hydrogen fuel cell vehicles planned by vehicle manufacturers by 2015 by requiring increased numbers of hydrogen fueling stations throughout the State. The number of stations will grow as vehicle manufacturers sell more fuel cell vehicles. By 2025, when the rules will be fully implemented, the statewide fleet of new cars and light trucks will emit 40 percent fewer GHGs and 75 percent fewer smog-forming emissions than 2012 model year vehicles.

Executive Order B-48-18
In January 2018, Governor Jerry Brown signed EO B-48-18 requiring all State entities to work with the private sector to have at least 5 million ZEVs on the road by 2030 and install 200 hydrogen fueling stations and 250,000 electric vehicle charging stations by 2025. It specifies that 10,000 of the electric vehicle charging stations should be direct current fast chargers. This order also requires all State entities to continue to partner with local and regional governments to streamline the installation of ZEV infrastructure. The Governor’s Office of Business and Economic Development is required to publish a Plug-in Charging Station Design Guidebook and update the 2015 Hydrogen Station Permitting Guidebook to aid in these efforts. All State entities are required to participate in updating the 2016 Zero-Emissions Vehicle Action Plan to help expand private investment in ZEV infrastructure with a focus on serving low-income and disadvantaged communities. Additionally, all State entities are to support and recommend policies and actions to expand ZEV infrastructure at residential land uses, through the LCFS Program, and recommend how to ensure affordability and accessibility for all drivers.

Local Regulations
The County adopted the EnergyWise Plan in November 2011 to demonstrate the County’s continued commitment to addressing the challenges of climate change by reducing local GHG emissions and preparing the County to adapt to a changing climate.24 The EnergyWise Plan outlines the County’s approach to reducing GHG emissions through a number of goals, measures, and actions that provide a road map to achieving the County’s GHG reduction target of 15 percent below baseline levels by 2020. In addition, the EnergyWise Plan 2016 Update summarizes the progress toward implementing measures in the EnergyWise Plan and outlines the overall trends in energy use and emissions since the baseline year of the EnergyWise Plan.
24 San Luis Obispo, County of, 2011. County of San Luis Obispo EnergyWise Plan. November.

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P:\MDT2201\Products\Ardmore Industrial Project AQ GHG Report - 041123.docx «04/11/23» 28 City of Paso Robles Climate Action Plan
The City adopted a comprehensive Climate Action Plan (CAP)25 in November 2013, which provides goals and policies for reducing GHG emissions. The CAP is a comprehensive planning document outlining the City’s proposed approach both to address climate impacts on Paso Robles and to reduce the City’s impact on the climate by reducing GHG emissions. The CAP provides a framework to reduce the City's GHG footprint (climate action) and ensure the community and physical assets are better protected from the impacts of climate change (climate adaptation). The vision of the CAP is to create a more sustainable, resilient, and equitable city by addressing climate change in a way that remedies existing environmental health disparities while also improving health, quality of life, and enhancing economic vitality throughout Paso Robles. The CAP includes a roadmap for implementing new polices, programs, incentives, requirements, projects, and initiatives in the immediate future, as well as longer-term actions that will need to be studied further while monitoring how the climate continues to change and evaluating the effectiveness of actions taken.

The following implementing actions from the CAP are applicable to the proposed project:
• C-4.1: Develop a program to meet City employee commute trip VMT reduction targets by offering one or more services from a menu of options, including: encourage the use of carpools; provide ride matching services and assistance; allow flexible work schedules and telecommuting; provide end of trip facilities (parking, showers, lockers); provide subsidized transit passes; hire a transportation coordination to manage TDM programs; or others at the employer’s discretion.
• W-1.3: Adopt CALGreen Tier 1 or Tier 2 standards for water efficiency and conservation in new development. To meet Tier 1 or Tier 2, designers, builders, or property owners must increase the number of green building measures and further reduce percentages of water use in order to meet the threshold levels for each tier.
• S-1.1: Adopt a solid waste diversion rate that exceeds the state-mandated rate by 25 percent (e.g., California’s AB 341 identifies a 75 percent diversion goal for 2020). • S-1.5: Adopt an ordinance requiring that 65 percent of construction and demolition debris from development project be diverted from landfills.
25 City of Paso Robles. 2013. City of Paso Robles Climate Action Plan. November 19. Website:
https://www.prcity.com/DocumentCenter/View/14729/Climate-Action-Plan-PDF?bidId= (accessed December 2022)

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SETTING

ATTAINMENT STATUS
The CARB is required to designate areas of the state as attainment, nonattainment, or unclassified for all State standards. An attainment designation for an area signifies that pollutant concentrations did not violate the standard for that pollutant in that area. A nonattainment designation indicates that a pollutant concentration violated the standard at least once, excluding those occasions when a violation was caused by an exceptional event, as defined in the criteria. An unclassified designation signifies that data do not support either an attainment or nonattainment status. The CCAA divides districts into moderate, serious, and severe air pollution categories, with increasingly stringent control requirements mandated for each category.

The USEPA designates areas for O3, CO, and NO2 as either does not meet the primary standards, cannot be classified, or better than national standards. For SO2, areas are designated as does not meet the primary standards, does not meet the secondary standards, cannot be classified, or better than national standards.

Table E provides a summary of the attainment status for the South Central Coast Air Basin (SCC Air Basin) with respect to federal and State AAQS.

Table E: San Luis Obispo County Attainment Status
Pollutant State Federal
O3 1-hour Nonattainment Nonattainment - Eastern San Luis Obispo County/ Attainment - Western San Luis Obispo County2 O3 8-hour Nonattainment PM10 Nonattainment Unclassified1/ Attainment
PM2.5 Attainment Unclassified1/ Attainment
CO Attainment Unclassified1
NO2 Attainment Unclassified1
SO2 Attainment Unclassified1
Lead Attainment No Attainment Information
Visibility Reducing Particles Attainment No Federal Standards Sulfates Attainment
Hydrogen Sulfide Attainment
Vinyl Chloride1 No Attainment Information
Source: SLO County APCD (2019). Website: https://storage.googleapis.com/slocleanairorg/images/cms/upload/files/AttainmentStatus29January2019.pdf Notes:
1 Unclassified (USEPA/Federal definition): Any area that cannot be classified on the basis of available information as meeting or not meeting the national primary or secondary ambient air quality standard for that pollutant. 2 San Luis Obispo County has been designated non-attainment east of the -120.4 degree Longitude line, in areas of San Luis Obispo County that are south of latitude 35.45 degrees, and east of the -120.3 degree Longitude line, in areas of San Luis Obispo County that are north of latitude 35.45 degrees. Map of non-attainment area is available upon request from the SLO County APCD.

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EXISTING CLIMATE AND AIR QUALITY
Air quality in the planning area is not only affected by various emission sources (e.g., mobile and industry), but also by atmospheric conditions (e.g., wind speed, wind direction, temperature, and rainfall).

The annual average temperature varies little throughout the SCC Air Basin, ranging from the low to middle 60s°F. With a more pronounced oceanic influence, coastal areas show less variability in annual minimum and maximum temperatures than inland areas. The climatological station closest to the site is the Paso Robles Station.
26 The monthly average maximum temperature recorded at this station ranged from 59.6°F in January to 93.8°F in July, with an annual average maximum of 76.1°F.

The monthly average minimum temperature recorded at this station ranged from 33.3°F in December to 53.7°F in July, with an annual average minimum of 43.3°F. These levels are still representative of the project area.

The majority of annual rainfall in the SCC Air Basin occurs between November and March. Summer rainfall is minimal and is generally limited to scattered thundershowers in coastal regions and slightly heavier showers in the eastern portion of the SCC Air Basin and along the coastal side of the mountains. Average monthly rainfall at the Paso Robles station varied from 2.46 inches in February to 0.02 inch in June and July, with an annual total of 12.53 inches. Patterns in monthly and yearly rainfall totals are unpredictable due to fluctuations in the weather.

The SCC Air Basin experiences a persistent temperature inversion (increasing temperature with increasing altitude) as a result of the Pacific high. This inversion limits the vertical dispersion of air contaminants, holding them relatively near the ground. As the sun warms the ground and the lower air layer, the temperature of the lower air layer approaches the temperature of the base of the inversion (upper) layer until the inversion layer finally breaks, allowing vertical mixing with the lower layer. This phenomenon is observed in mid-afternoon to late afternoon on hot summer days when the air appears to clear up suddenly. Winter inversions frequently break by midmorning.

Winds in the project area blow predominantly from the south-southwest, with relatively low velocities. Wind speeds in the project area average about 5 miles per hour. Summer wind speeds average slightly higher than winter wind speeds. Low average wind speeds, together with a persistent temperature inversion, limit the vertical dispersion of air pollutants throughout the SCC Air Basin.

Strong, dry, north, or northeasterly winds occur during the fall and winter months, dispersing air contaminants. The Santa Ana conditions tend to last for several days at a time.

The combination of stagnant wind conditions and low inversions produces the greatest pollutant concentrations. On days of no inversion or high wind speeds, ambient air pollutant concentrations are the lowest. During periods of low inversions and low wind speeds, air pollutants generated in urbanized areas are transported predominantly on shore into Riverside and San Bernardino Counties. In the winter, the greatest pollution problems are CO and NOx because of extremely low inversions and air stagnation during the night and early morning hours. In the summer, the longer 26 Western Regional Climate Center. n.d. Recent Climate in the West. Website: http://www.wrcc.dri.edu, (accessed December 2022).

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P:\MDT2201\Products\Ardmore Industrial Project AQ GHG Report - 041123.docx «04/11/23» 31 daylight hours and brighter sunshine combine to cause a reaction between hydrocarbons and NOX to form photochemical smog. Smog is a general term that is naturally occurring fog that has become mixed with smoke or pollution. In this context it is better described as a form of air pollution produced by the photochemical reaction of sunlight with pollutants that have been released into the atmosphere, especially by automotive emissions.

AIR QUALITY MONITORING RESULTS
Air quality monitoring stations are located throughout the nation and are maintained by the local air pollution control district and State air quality regulating agencies. The SCC Air Basin, together with the CARB, maintains ambient air quality monitoring stations in the basin. The air quality monitoring stations closest to the project site are at 235 Santa Fe Avenue in Paso Robles, 5599 Traffic Way in Atascadero, and 1300 Guadalupe Road in Nipomo, California Pollutant monitoring results for years 2019 to 2021 at the Paso Robles, Atascadero, and Nipomo air quality monitoring stations, shown in Table F, indicate that air quality in the area has generally been good. As indicated in the monitoring results, the federal PM10 standard was exceeded four times in 2020 only, with no exceedances for the years 2019 and 2021. The State PM10 standard was exceeded nine times in 2019, 35 times in 2020, and an unknown number of times in 2021. The federal PM2.5 levels had 11 exceedances in 2020 only, with no exceedances for the years 2019 and 2021. The State 1-hour ozone standards were exceeded during the 3-year period. The 8-hour ozone State standards were exceeded three times in 2020 only, with no exceedances in 2019 and 2020.

Similarly, the 8-hour federal Standards were exceeded two times in 2020 only, with no exceedances in the years 2019 and 2021. The SO2 and NO2 standards were not exceeded in this area during the 3- year period. Lastly, there was no available data for either the State or federal standards for CO in the county of San Luis Obispo.

GREENHOUSE GAS EMISSIONS INVENTORY
An emissions inventory that identifies and quantifies the primary human-generated sources and sinks of GHGs is a well-recognized and useful tool for addressing climate change. This section summarizes the latest information on global, United States, and California GHG emission inventories.

Global Emissions
Worldwide emissions of GHGs in 2020 totaled 22.9 billion metric tons (MT) of CO2e. Global estimates are based on country inventories developed as part of the programs of the United Nations Framework Convention on Climate Change.
27 27 United Nations Framework Convention on Climate Change (UNFCCC). 2021. GHG Data from UNFCCC.

Website: unfccc.int/process-and-meetings/transparency-and-reporting/greenhouse-gas-data/ghg-dataunfccc/ghg-data-from-unfccc (accessed December 2022).

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P:\MDT2201\Products\Ardmore Industrial Project AQ GHG Report - 041123.docx «04/11/23» 32 Table F: Ambient Air Quality at Nearby Monitoring Stations Pollutant Standard 2019 2020 2021
Carbon Monoxide (CO)1
Maximum 1-hour concentration (ppm) ND ND ND
Number of days exceeded: State: > 20 ppm ND ND ND
Federal: > 35 ppm ND ND ND
Maximum 8-hour concentration (ppm) ND ND ND
Number of days exceeded: State: > 9 ppm ND ND ND
Federal: > 9 ppm ND ND ND
Ozone (O3)
2 Maximum 1-hour concentration (ppm) 0.077 0.092 0.07
Number of days exceeded: State: > 0.09 ppm 0 0 0
Maximum 8-hour concentration (ppm) 0.065 0.073 0.064
Number of days exceeded: State: > 0.07 ppm 0 3 0
Federal: > 0.07 ppm 0 2 0
Coarse Particulates (PM10)
2 Maximum 24-hour concentration (µg/m3) 138.0 357.2 74
Number of days exceeded: State: > 50 µg/m3 9 35 ND
Federal: > 150 µg/m3 0 4 0
Annual arithmetic average concentration (µg/m3) ND 24.4 ND Exceeded for the year: State: > 20 µg/m3 ND Yes ND
Federal: > 50 µg/m3 ND No ND
Fine Particulates (PM2.5)
3 Maximum 24-hour concentration (µg/m3) 17.3 242.1 19.1 Number of days exceeded: Federal: > 35 µg/m3 0 11 0
Annual arithmetic average concentration (µg/m3) ND ND 6.7 Exceeded for the year: State: > 12 µg/m3 ND No No
Federal: > 15 µg/m3 ND No No
Nitrogen Dioxide (NO2)
3 Maximum 1-hour concentration (ppm) 34 33 44
Number of days exceeded: State: > 250 ppb 0 0 0
Annual arithmetic average concentration (ppm) 4 4 3.9
Exceeded for the year: Federal: > 53 ppb No No No
Sulfur Dioxide (SO2)
4 Maximum 1-hour concentration (ppm) 0.002 0.002 0.004
Number of days exceeded: State: > 0.25 ppm 0 0 0
Maximum 24-hour concentration (ppm) 0.0007 0.0012 0.0015 Number of days exceeded: State: > 0.04 ppm 0 0 0
Federal: > 0.14 ppm 0 0 0
Annual arithmetic average concentration (ppm) 0.00002 0.00026 0.00051 Exceeded for the year: Federal: > 0.030 ppm No No No
Sources: CARB (2022) and USEPA (2022).
1 There were no available stations for CO2.
2 Data were taken from the 235 Santa Fe Avenue, Paso Robles Monitoring Station. 3 Data were taken from the 5599 Traffic Way, Atascadero Monitoring Station. 4 Data were taken from 1300 Guadalupe Road, Nipomo Monitoring Station. µg/m3 = micrograms per cubic meter
CARB = California Air Resources Board
ND = No data. There were insufficient (or no) data to determine the value. ppb = parts per billion
ppm = parts per million
USEPA = United States Environmental Protection Agency

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P:\MDT2201\Products\Ardmore Industrial Project AQ GHG Report - 041123.docx «04/11/23» 33 United States Emissions
In 2020, the year for which the most recent data are available, the United States emitted about 5,222 million metric tons of CO2e (MMT CO2e). Overall, emissions in 2020 decreased by 11 percent since 2019 and were 21 percent lower than 2005 levels. The primary driver for the decrease was an 11 percent decrease in CO2 emissions from fossil fuel combustion. This decrease was primarily due to a 13 percent decrease in transportation emissions driven by decreased demand due to the ongoing COVID-19 pandemic. Electric power sector emissions also decreased 10 percent, reflecting both a slight decrease in demand from the COVID-19 pandemic and a continued shift from coal to less carbon intensive natural gas and renewables. Of the five major sectors – residential and commercial, agricultural, industry, transportation, and electricity generation – transportation accounted for the highest amount of GHG emissions in 2020 (approximately 27 percent), with electricity generation second at 27 percent and emissions from industry third at 24 percent.28 State of California Emissions
The State emitted approximately 369.2 MMT CO2e emissions in 2020, 35.3 MMT CO2e lower than 2019 levels and 61.8 MMT CO2e below the 2020 GHG limit of 431 MMT CO2e.29 The California Air Resources Board (CARB) estimates that transportation was the source of approximately 37 percent of the State’s GHG emissions in 2020, which is a smaller share than recent years, as the transportation sector saw a significant decrease of 26.6 MMT CO2e in 2020, likely due in large part to the impact of the COVID-19 pandemic. The next largest sources included industrial sources at approximately 20 percent and electricity generation at 16 percent. The remaining sources of GHG emissions were commercial and residential activities at 10 percent, agriculture at 9 percent, high GWP at 6 percent, and waste at 2 percent.
30 City of Paso Robles Emissions
The City of Paso Robles 2005 greenhouse gas emissions inventory update was prepared to identify the major sources and quantities of GHG emissions produced in Paso Robles in 2005 and forecast how these emissions may change over time. Paso Robles’ GHG emissions are projected to grow approximately 20 percent above 2005 GHG emissions levels by the year 2020. Table G shows the GHG emissions by sector for 2005 and the forecasted emissions for 2020. 28 USEPA. 2022. Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2020. Website: https://www. epa.gov/ghgemissions/inventory-us-greenhouse-gas-emissions-and-sinks (accessed December 2022). 29 CARB. 2022. California Greenhouse Gas Emissions for 2000 to 2020, Trends of Emissions and Other Indicators Report. Website: https://ww2.arb.ca.gov/sites/default/files/classic/cc/inventory/2000-2020_ ghg_inventory_trends.pdf (accessed December 2022). 30 Ibid.

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P:\MDT2201\Products\Ardmore Industrial Project AQ GHG Report - 041123.docx «04/11/23» 34 Table G: City of Paso Robles GHG Emissions
Sector MT CO2e Percent Percent Change
Residential 40,188 46,828 17
Commercial/ Industrial 33,536 30,551 -9
Transportation 67,801 92,913 37
Off-Road 13,205 15,878 20
Solid Waste 13,433 15,653 17
Wastewater 70 82 17
Aircraft 1,324 1,543 17
Total 169,557 203,448 20
Source: City of Paso Robles Climate Action Plan (City of Paso Robles 2013).

GHG = greenhouse gas
MT CO2e = metric tons carbon dioxide equivalent

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METHODOLOGY
The methodology used to estimate air quality and GHG impacts is described below.

CONSTRUCTION EMISSIONS
Construction activities can generate a substantial amount of air pollution. Construction activities are considered temporary; however, short term impacts can contribute to exceedances of air quality standards. Construction activities include site preparation, earthmoving, and general construction.

The emissions generated from these common construction activities include fugitive dust from soil disturbance, fuel combustion from mobile heavy-duty diesel and gasoline powered equipment, portable auxiliary equipment, and worker commute trips.

The California Emission Estimator Model version 2022.1 (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 of Buildings 1–4 is anticipated to begin in summer 2024 and occur for 12 to 16 months, and construction of Building 5 would commence in summer 2026 and would occur for 12 to 16 months.
31 This analysis also assumes the use of Tier 2
construction equipment. All other construction details are not yet known; therefore, default assumptions (e.g., construction worker and truck trips and fleet activities) from CalEEMod were used.

OPERATIONAL EMISSIONS
The air quality analysis includes estimating emissions associated with long-term operation of the proposed project. Indirect emissions of criteria pollutants with regional impacts would be emitted by project-generated vehicle trips. In addition, localized air quality impacts (i.e., higher carbon monoxide concentrations or “hot-spots”) near intersections or roadway segments in the project vicinity would also potentially occur due to project-generated vehicle trips.

Consistent with the SCCAB 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 Unrefrigerated Warehouse No-Rail, Manufacturing, Regional Shopping Center, and Parking Lot. In addition, this analysis assumes the proposed project would generate new vehicle trips, consistent with the project’s trip generation, which estimates the proposed project would result in approximately 1,194 average daily trips32. In addition, the proposed project would not include any woodburning hearths and only natural gas would be used, which was assumed in CalEEMod. When 31 The CalEEMod analysis evaluated project construction emissions with a start date of August 2023. The proposed project’s construction schedule has since been modified that project construction would begin summer 2024 and would still occur over the same duration. This modification to the project construction start date was reviewed by LSA and it was determined that it would not result in any new or more severe air quality or GHG impacts than what is described within. 32 Central Coast Transportation Consulting (CCTC). 2022. Ardmore Industrial, Paso Robles- Transportation Analysis. December 7.

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GREENHOUSE GAS ANALYSIS
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 project.

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THRESHOLDS OF SIGNIFICANCE
The State CEQA Guidelines indicate that a project would normally have a significant adverse air quality impact if project-generated pollutant emissions would:
• Conflict with or obstruct implementation of the applicable air quality plan; • Result in a cumulatively considerable net increase of any criteria pollutant for which the project is nonattainment under applicable federal or state ambient air quality standards; • Expose sensitive receptors to substantial pollutant concentrations; or • Result in other emissions (such as those leading to odors) affecting a substantial number of people.

The State CEQA Guidelines indicate that a project would normally have a significant adverse greenhouse gas emission impact if the project would:
• Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment; or
• Conflict with an applicable plan, policy or regulation adopted for the purpose of reduction the emissions of greenhouse gases.

Certain air districts (e.g., SLO County APCD) have created guidelines and requirements to conduct air quality analysis. SLO County APCD’s current guidelines, the CEQA Air Quality Handbook with associated updates, were followed in this assessment of air quality and GHG impacts for the proposed project.

REGIONAL EMISSIONS THRESHOLDS
The SLO County APCD sets emissions thresholds in its CEQA Air Quality Handbook, which were established based on the attainment status of the air basin in regard to air quality standards for specific criteria pollutants. Because the concentration standards were set at a level that protects public health with an adequate margin of safety, these emission thresholds are regarded as conservative and would overstate an individual project’s contribution to health risks. The thresholds of significance for emissions from construction activities are shown in Table H and the thresholds of significance for operational emissions impacts are presented in Table I.

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P:\MDT2201\Products\Ardmore Industrial Project AQ GHG Report - 041123.docx «04/11/23» 38 Table H: Air Quality Thresholds of Significance for Construction Emissions Pollutant Threshold1
Daily Quarterly Tier 1 Quarterly Tier 2
ROG + NOx (combined) 137 lbs 2.5 tons 6.3 tons
Diesel Particulate Matter
(DPM) 7 lbs 0.13 tons 0.32 tons
Fugitive Particulate Matter
(PM10), Dust2 2.5 tons
Greenhouse Gases (CO2e) 1,150 tons per year
Amortized and Combined with Operational Emissions3
Source: CEQA Air Quality Handbook. (SLO County APCD, April 2012). 1 Daily and quarterly emission thresholds are based on the California Health & Safety Code and the CARB Carl Moyer Guidelines. 2 Any project with a grading area greater than 4.0 acres of worked area can exceed the 2.5 ton PM10 quarterly threshold. 3 The amortization of GHG emissions over the life of the project is based on the total greenhouse gas emissions for construction activities divided by the project life (i.e., 50 years for residential projects and 25 years for commercial projects) then add that number to the annual operational phase GHG emissions.

CARB = California Air Resources Board
CO2e = carbon dioxide equivalent
DPM = diesel particulate matter
GHG = greenhouse gas
Lbs = pounds
NOx = nitrogen oxides
PM10= particulate matter less than 10 microns in size
SLO County APCD = San Luis Obispo County Air Pollution Control District Table I: Air Quality Thresholds of Significance for Operational Emissions Pollutant Threshold1
Daily Annual
ROG + NOx (combined)1 25 lbs 25 tons
Diesel Particulate Matter (DPM)1 1.25 lbs
Fugitive Particulate Matter (PM10),
Dust 25 lbs 25 tons
CO 550 lbs
Source: CEQA Air Quality Handbook. (SLO County APCD, April 2012). 1 Daily and annual emission thresholds are based on the California Health & Safety Code Division 26, Part 3, Chapter 10, Section 40918 and the CARB Carl Moyer Guidelines for DPM.
2 CalEEMod – use winter operational emissions data to compare to operational thresholds.

CalEEMod = California Emissions Estimator Model
CARB = California Air Resources Board
CO = carbon monoxide
DPM = diesel particulate matter
lbs = pounds
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

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LOCAL MICROSCALE CONCENTRATION STANDARDS
The significance of localized project impacts under CEQA depends on whether ambient CO levels in the vicinity of the project are above or below State and federal CO standards. Because ambient CO levels are below the standards throughout the SCC Air Basin, a project would be considered to have a significant CO impact if project emissions result in an exceedance of one or more of the 1-hour or 8-hour standards. The following are applicable local emission concentration standards for CO:
• California State 1-hour CO standard of 20 ppm
• California State 8-hour CO standard of 9 ppm

GREENHOUSE GAS EMISSIONS
The significance of GHG emissions may be evaluated based on locally adopted quantitative thresholds or consistency with a regional GHG reduction plan (such as a Climate Action Plan). The SLO County APCD’s bright-line threshold of 1,150 metric tons of CO2e per year and the efficiency threshold of 4.9 metric tons of CO2e per year service population were applicable to residential and commercial projects. These thresholds were based on a gap analysis and were used in CEQA evaluations for projects to demonstrate their consistency with the State’s 2020 GHG emission reduction goal from AB 32 and CARB’s 2008 Climate Change Scoping Plan. In 2015, the California Supreme Court issued an opinion in the Center for Biological Diversity vs. California Department of Fish and Wildlife (Newhall Ranch) which determined that AB 32 based thresholds derived from a gap analysis are invalid for projects with a planning horizon beyond 2020. As such, the SLO County APCD does not recommend the use of these thresholds in CEQA Evaluations.33 However, since the SLO County APCD has yet to publish a quantified GHG efficiency threshold for the 2030 target, for informational purposes, the proposed project is compared to the numerical screening threshold of 1,150 metric tons of CO2e per year and the efficiency target of 4.9 metric tons of CO2e per year per service population. In addition, the proposed project was analyzed for consistency with the City’s CAP and the 2022 Scoping Plan.
33 SLO County APCD, 2021. Interim GHG Guidance for APCD CEQA Air Quality Handbook 2012. January 28.

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IMPACT ANALYSIS
This section identifies the air quality and GHG emissions impacts associated with implementation of the proposed project. The results of the impact analyses are then compared to applicable thresholds of significance. As noted below, no thresholds were met or exceeded, therefore no mitigation measures are required for the proposed project.

AIR QUALITY IMPACTS
Air pollutant emissions associated with the project would occur over the short term from construction activities and over the long term from operational activities associated with the proposed land uses
Consistency with Applicable Air Quality Plans
The air quality plan applicable to the project area is the SLO County APCD’s 2001 Clean Air Plan, which was adopted on March 26, 2002.34 The CAP outlines the SLO County APCD’s strategies to reduce ozone precursor emissions from a wide variety of stationary and mobile sources.

According to the SLO County APCD, a Clean Air Plan consistency analysis is generally required for a Program Level Environmental Impact Report (EIR), and may be necessary for a Project Level EIR, depending on the project being considered. Examples of projects and programs requiring a consistency analysis include: General Plan Updates and Amendments, Specific Plans, Area Plans, large residential developments and large commercial or industrial developments.

Consistency with the Clean Air Plan can be determined if: (1) the population projections for the project are less than or equal to those identified in the 2050 Regional Growth Forecast population data; (2) the rate of increase in vehicle trips and vehicle miles traveled (VMT) are less than or equal to the rate of population growth; and (3) all applicable Transportation and Land Use Control Measures from the Clean Air Plan have been included in the project to the maximum extent feasible. The following is an evaluation of the proposed project’s consistency with each of these criteria.

Population Projections
According to the 2050 Regional Growth Forecast for San Luis Obispo County, the forecasted population in Paso Robles in 2020 was 32,755 residents and in 2050 is anticipated to have a population of 38,858 residents.35 Therefore, the forecasted population for Paso Robles will grow by approximately 6,103 residents between 2020 and 2050. The proposed project would consist of an approximately 125,812 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 34 SLO County APCD. 2001. 2001 Clean Air Plan San Luis Obispo County. December. 35 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 December 2022).

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P:\MDT2201\Products\Ardmore Industrial Project AQ GHG Report - 041123.docx «04/11/23» 41 on Lot 6 (Buildings 2–5). Therefore, the proposed project would not include new residences and would not increase population growth.

Vehicle Trips and Vehicle Miles Traveled
Based on the project’s Transportation Analysis36, the proposed project’s VMT were analyzed consistent with the Governor’s Office of Planning and Research (OPR) guidance. The City’s 2022 Transportation Impact Analysis (TIA) Guidelines Supplement provide VMT and safety thresholds consistent with OPR guidance. Office and industrial projects may have a significant impact if the work VMT per employee exceeds 85 percent of the regional average. Work VMT captures homebased-work attractions (trips from homes to workplaces). In addition, projects may have a significant impact if they exacerbate an existing high-priority or similar safety location, introduces a design feature that substantially increases hazards, or propose features that do not meet City design standards. As demonstrated in the project’s Transportation Analysis, the addition of the project would reduce regional work VMT due to the provision of jobs in a housing-rich area. Therefore, the project would have a less-than-significant impact to VMT.

Transportation and Land Use Control Measures
The SLO County APCD identifies Transportation Control Measures as part of the Clean Air Plan to decrease emissions of criteria pollutants by reducing demand for motor vehicle travel and commuting, improving the local and regional transit system, enhancing bicycle and bikeway facilities, and improving traffic flow. In addition, the SLO County APCD identifies Land Use Control Measures that are designed to reduce emissions of criteria air pollutants by planning compact communities, providing for mixed land uses, balancing jobs and housing, and circulation management. As discussed above, the addition of the project would reduce regional work VMT due to the provision of jobs in a housing-rich area. As such, the proposed project would not conflict with the Transportation and Land Use Control Measures.

Summary
As discussed above, the proposed project would not conflict with the Clean Air Plan. Furthermore, as demonstrated below, the proposed project would result in short-term construction and longterm operational pollutant emissions that are all less than the CEQA significance emissions thresholds established by the SLO County APCD. Therefore, the project would not result in an increase in the frequency or severity of an air quality standards violation or cause a new air quality standards violation. Therefore, the proposed project would not conflict with or obstruct implementation of the Clean Air Plan.

Criteria Pollutant Analysis
The SCCAB is currently designated as nonattainment for the federal and State standards for O3. In addition, the SCCAB is in nonattainment for the State PM10 standard. The SCCAB’s nonattainment status is attributed to the region’s development history. Past, present, and future development projects contribute to the region’s adverse air quality impacts on a cumulative basis. By its very 36 Central Coast Transportation Consulting (CCTC). 2022. Ardmore Industrial, Paso Robles- Transportation Analysis. December 7.

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P:\MDT2201\Products\Ardmore Industrial Project AQ GHG Report - 041123.docx «04/11/23» 42 nature, air pollution is largely a cumulative impact. No single project is sufficient in size to, by itself, result in nonattainment of an ambient air quality standard. Instead, a project’s individual emissions contribute to existing cumulatively significant adverse air quality impacts. If a project’s contribution to the cumulative impact is considerable, then the project’s impact on air quality would be considered significant.

In developing thresholds of significance for air pollutants, SLO County APCD considered the emissions levels for which a project’s individual emissions would be cumulatively considerable. If a project exceeds the identified significance thresholds, its emissions would be cumulatively considerable, resulting in significant adverse air quality impacts to the region’s existing air quality conditions. Therefore, additional analysis to assess cumulative impacts is not necessary. The following analysis assesses the potential project-level air quality impacts associated with construction and operation of the proposed project.

Construction Emissions
During construction, short-term degradation of air quality may occur due to the release of particulate matter emissions (i.e., fugitive dust) generated by site preparation, grading, construction, paving, and other activities. Emissions from construction equipment are also anticipated and would include CO, NOx, reactive organic gases (ROGs), directly emitted PM2.5 or PM10, and TACs such as diesel exhaust particulate matter.

Project construction activities would include site preparation, grading, construction, architectural coating, and paving activities. Construction-related effects on air quality from the proposed project would be greatest during the site preparation and grading phases due to the disturbance of soils. If not properly controlled, these activities would temporarily generate particulate emissions. Sources of fugitive dust would include disturbed soils at the construction site. Unless properly controlled, vehicles leaving the site would deposit dirt and mud on local streets, which could be an additional source of airborne dust after it dries. PM10 emissions would vary from day to day, depending on the nature and magnitude of construction activity and local weather conditions. PM10 emissions would depend on soil moisture, silt content of soil, wind speed, and amount of operating equipment.

Larger dust particles would settle near the source, whereas fine particles would be dispersed over greater distances from the construction site. Water or other soil stabilizers can be used to control fugitive dust, resulting in emission reductions of 50 percent or more.

In addition to dust-related PM10 emissions, heavy trucks and construction equipment powered by gasoline and diesel engines would generate CO, sulfur oxides (SOx), NOx, ROGs and some soot particulate (PM2.5 and PM10) in exhaust emissions. If construction activities were to increase traffic congestion in the area, CO and other emissions from traffic would increase slightly while those vehicles idle in traffic. These emissions would be temporary in nature and limited to the immediate area surrounding the construction site.

Construction emissions were estimated for the project using CalEEMod and summarized in Table J.

Attachment A provides CalEEMod output sheets.

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P:\MDT2201\Products\Ardmore Industrial Project AQ GHG Report - 041123.docx «04/11/23» 43 Table J: Air Quality Construction Emissions
ROG + NOx
(combined)
Diesel Particulate Matter
(DPM)
Fugitive Dust2
(PM10)
pounds/day tons/quarter pounds/day tons/quarter tons/quarter Project Construction
Emissions 86.1 1.2 1.1 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 (December 2022). 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 J, construction emissions associated with the project would be below the significance thresholds set by the SLO County APCD. Therefore, construction 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.

Operational Emissions
Long-term air pollutant emission impacts are those associated with 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.

PM10 emissions result from running exhaust, tire and brake wear, and the entrainment of dust into the atmosphere from vehicles traveling on paved roadways. Entrainment of PM10 occurs when vehicle tires pulverize small rocks and pavement and the vehicle wakes generate airborne dust.

Gasoline-powered engines have small rates of particulate matter emissions compared with dieselpowered vehicles. Since much of the project traffic fleet would be made up of light-duty gasolinepowered vehicles, a majority of the PM10 emissions would result from entrainment of roadway dust from vehicle travel.

Energy source emissions result from activities in buildings for which natural gas is used. The quantity of emissions is the product of usage intensity (i.e., the amount of natural gas) and the emission factor of the fuel source.

Area source emissions associated with the project would include emissions from water heating and the use of landscaping equipment.

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P:\MDT2201\Products\Ardmore Industrial Project AQ GHG Report - 041123.docx «04/11/23» 44 Long-term operation emissions associated with the proposed project were calculated using CalEEMod. Table K provides the proposed project’s estimated operational emissions. Attachment A provides CalEEMod output sheets.

Table K: Air Quality Operational Emissions
ROG + NOx
(combined)
Diesel
Particulate
Matter(DPM)
Fugitive Dust2 (PM10)
pounds/day tons/year pounds/day pounds/day tons/year
Project Operational
Emissions 16.9 3.1 0.1 1.0 0.2
SLO County APCD’s
Significance Threshold1 252 25 1.252 25 25
Exceeds Threshold? No No No No No
Source: LSA (December 2022). 1 Daily and annual emission thresholds are based on the California Health & Safety Code Division 26, Part 3, Chapter 10, Section 40918 2 CalEEMod winter report should be used to compare with these thresholds.

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 As shown in Table K, 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.

Health Risk on Nearby Sensitive Receptors
Sensitive receptors are defined as people that have an increased sensitivity to air pollution or environmental contaminants. Sensitive receptor locations include schools, parks and playgrounds, daycare centers, nursing homes, hospitals, and residential dwelling units. The project site is surrounded primarily by commercial and residential land uses. As discussed, there are no sensitive receptors located within 1,000 feet of the project site. Therefore, it is not anticipated that sensitive receptors would be exposed to airborne particulates and construction equipment pollutants (i.e., usually diesel-fueled vehicles and equipment). In addition, as shown in Table J above, 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, sensitive receptors are not expected to be exposed to substantial pollutant concentrations during project construction and operation.

Odors
During construction, the various diesel-powered vehicles and equipment in use on site would create localized odors. These odors would be temporary and are not likely to be noticeable for extended

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P:\MDT2201\Products\Ardmore Industrial Project AQ GHG Report - 041123.docx «04/11/23» 45 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. The proposed project would not include sensitive receptors; therefore, odor impacts on the project do not require further evaluation.

GREENHOUSE GAS EMISSION IMPACTS
This section identifies the GHG impacts associated with implementation of the proposed project.

Generation of Greenhouse Gas Emissions
The following sections describe the proposed project’s construction- and operation-related GHG impacts and consistency with applicable GHG reduction plans.

Construction Greenhouse Gas Emissions
Construction activities associated with the proposed project would produce combustion emissions from various sources. During construction, GHGs would be emitted through the operation of construction equipment and from worker and builder supply vendor vehicles, each of which typically use fossil-based fuels to operate. The combustion of fossil-based fuels creates GHGs such as CO2, CH4, and N2O. Furthermore, CH4 is emitted during the fueling of heavy equipment. Exhaust emissions from on-site construction activities would vary daily as construction activity levels change.

The SLO County APCD does not have an adopted threshold of significance for construction-related GHG emissions. However, lead agencies are encouraged to quantify and disclose GHG emissions that would occur during construction. Using CalEEMod, it is estimated that construction of the proposed project would generate a total of approximately 1,875.0 MT CO2e during construction of the proposed project. When amortized over the 30-year life of the project, annual emissions would be

62.5 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. Mobilesource GHG emissions would include project-generated vehicle trips to and from the project. Areasource emissions would be associated with activities such as landscaping and maintenance on the project site. Energy source emissions would be generated at off-site utility providers as a result of increased electricity demand generated by the project. Waste source emissions generated by the proposed project include energy generated by land filling and other methods of disposal related to transporting and managing project generated waste. In addition, water source emissions associated with the proposed project are generated by water supply and conveyance, water treatment, water distribution, and wastewater treatment.

Following guidance from the SLO County APCD, GHG emissions were estimated using CalEEMod. As shown in Table L, mobile source emissions are the largest source of emissions, at approximately 45 percent of total CO2e emissions, followed by energy source emissions at approximately 39 percent of the total. In addition, water source emissions are approximately 9 percent, and waste source

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P:\MDT2201\Products\Ardmore Industrial Project AQ GHG Report - 041123.docx «04/11/23» 46 emissions are approximately 7 percent. Area source emissions account for less than 1 percent of the total emissions.

Table L: GHG Emissions (Metric Tons Per Year)
Types of Emissions
Operational Emissions
CO2 CH4 N2O CO2e Percentage of Total
Mobile Source Emissions 495.0 <0.1 <0.1 507.0 45
Area Source Emissions 6.4 <0.1 <0.1 6.5 <1
Energy Source Emissions 445.0 0.1 <0.1 448.0 39
Water Source Emissions 44.3 1.8 <0.1 101.0 9
Waste Source Emissions 21.9 2.2 0.0 76.6 7
Total Operational Emissions 1,139.1 100
Amortized Construction Emissions 62.5 —
Total Annual Emissions 1,201.6 —
SLO County APCD Operational Year Numeric Threshold 1,150 — Exceed? Yes —
Service Population Emissions 4.8
SLO County APCD Scaled 2031 Service Population Threshold 4.9 Exceeds Threshold? No
Source: LSA (March 2023).

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
As discussed above and based on the project-specific thresholds developed for this analysis, GHG emissions generated by the proposed 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).

As shown in Table L, the proposed project would generate approximately 1,176.1 MT CO2e per year, which would be exceed the numeric threshold of 1,150 MT CO2e. Therefore, the following discussion evaluates the proposed project to the 4.9 MT CO2e per year per service population threshold.

As discussed above, the proposed project would consist of an approximately 125,812 square-foot 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). Therefore, the proposed project would not include new residences and would not increase population growth. The proposed project would employ approximately 250 workers. As such, the proposed project would result in a per service population emission of 4.8 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.

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ARDMORE INDUSTRIAL P ROJECT

P ASO R OBLES , C ALIFORNIA
P:\MDT2201\Products\Ardmore Industrial Project AQ GHG Report - 041123.docx «04/11/23» 47 In addition, since the SLO County APCD has yet to publish a quantified GHG efficiency threshold for the 2030 target, the proposed project was also analyzed for consistency with the goals of the 2022 Scoping Plan, EO B-30-15, SB 32, and AB 197.

EO B-30-15 added the immediate target of reducing GHG emissions to 40 percent below 1990 levels by 2030. Additionally, SB 32 affirms the importance of addressing climate change by codifying into statute the GHG emissions reduction target of at least 40 percent below 1990 levels by 2030 contained in EO B-30-15. SB 32 builds on AB 32 and keeps us on the path toward achieving the State’s 2050 objective of reducing emissions to 80 percent below 1990 levels. The companion bill to SB 32, AB 197, provides additional direction to CARB related to the adoption of strategies to reduce GHG emissions. Additional direction in AB 197 that is intended to provide easier public access to air emission data collected by the CARB was posted in December 2016.

In addition, the 2022 Scoping Plan assesses progress toward the statutory 2030 target, while laying out a path to achieving carbon neutrality no later than 2045. The 2022 Scoping Plan focuses on outcomes needed to achieve carbon neutrality by assessing paths for clean technology, energy deployment, natural and working lands, and others, and is designed to meet the State’s long-term climate objectives and support a range of economic, environmental, energy security, environmental justice, and public health priorities.

The 2022 Scoping Plan focuses on building clean energy production and distribution infrastructure for a carbon-neutral future, including transitioning existing energy production and transmission infrastructure to produce zero-carbon electricity and hydrogen, and utilizing biogas resulting from wildfire management or landfill and dairy operations, among other substitutes. The 2022 Scoping Plan states that in almost all sectors, electrification will play an important role. The 2022 Scoping Plan evaluates clean energy and technology options and the transition away from fossil fuels, including adding four times the solar and wind capacity by 2045 and about 1,700 times the amount of current hydrogen supply. As discussed in the 2022 Scoping Plan, EO N-79-20 requires that all new passenger vehicles sold in California will be zero-emission by 2035, and all other fleets will have transitioned to zero-emission as fully possible by 2045, which will reduce the percentage of fossil fuel combustion vehicles.

Energy-efficient measures are intended to maximize energy-efficiency building and appliance standards, pursue additional efficiency efforts including new technologies and new policy and implementation mechanisms, and pursue comparable investment in energy efficiency from all retail providers of electricity in California. In addition, these measures are designed to expand the use of green building practices to reduce the carbon footprint of California’s new and existing inventory of buildings. As identified above, the proposed project would comply with the latest CALGreen Code standards, regarding energy conservation and green building standards. Therefore, the proposed project would comply with applicable energy measures.

Water conservation and efficiency measures are intended to continue efficiency programs and use cleaner energy sources to move and treat water. Increasing the efficiency of water transport and reducing water use would reduce GHG emissions. As noted above, the project would be required to comply with the latest CALGreen Code standards, which include a variety of different measures, including reduction of wastewater and water use. In addition, the proposed project would be

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ARDMORE INDUSTRIAL P ROJECT

P ASO R OBLES , C ALIFORNIA
P:\MDT2201\Products\Ardmore Industrial Project AQ GHG Report - 041123.docx «04/11/23» 48 required to comply with the California Model Water Efficient Landscape Ordinance. Therefore, the proposed project would not conflict with any water conservation and efficiency measures.

The goal of transportation and motor vehicle measures is to develop regional GHG emission reduction targets for passenger vehicles. Specific regional emissions targets for transportation emissions would not directly apply to the proposed project. The second phase of Pavley standards will reduce GHG emissions from new cars by 34 percent from 2016 levels by 2025, resulting in a 3 percent decrease in average vehicle emissions for all vehicles by 2020. Vehicles traveling to the project site would comply with the Pavley II (LEV III) Advanced Clean Cars Program. In addition, as discussed above, the addition of the project would reduce regional work VMT due to the provision of jobs in a housing-rich area. Therefore, the proposed project would not conflict with the identified transportation and motor vehicle measures.

Therefore, the proposed project would comply with existing State regulations adopted to achieve the overall GHG emissions reduction goals identified in AB 32, the AB 32 Scoping Plan, EO B-30-15, SB 32, and AB 197. As such, the proposed project would not generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment.

Consistency with Greenhouse Gas Reduction Plans
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

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APRIL 2023

ARDMORE INDUSTRIAL P ROJECT

P ASO R OBLES , C ALIFORNIA
P:\MDT2201\Products\Ardmore Industrial Project AQ GHG Report - 041123.docx «04/11/23» 49 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.

CONCLUSION
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.

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Paso Robles City CouncilApril 21, 2026

Paso Robles City Council
April 21, 2026