April 23, 2025
SAFER Comment on Cal Box II Project
(d) Approval of the project would not result in any
significant effects relating to traffic, noise, air quality, or water quality.
(e) The site can be adequately served by all required
utilities and public services.
H
ere, staff has also recommended approval of the Project on the basis that the Project qualifies for CEQA’s Existing Facilities Exemption. Projects falling within the Existing Facilities Exemption are those that “consist[] of the operation, repair, maintenance, permitting, leasing, licensing, or minor alternation of existing public or private structures, facilities, mechanical equipment, or topographical features involving negligible or no expansion of existing or former use.” (14 Cal. Code Regs. § 15301.) Examples of the types of projects that qualify for the Existing Facilities Exemption include “[a]dditions to existing structures provided that the addition will not result in an increase of more than:
(1) 50 pe
rcent of the floor area of the structures before the
addition, or 2,500 square feet, whichever is less; or
(2) 10,000 square feet if: (A) [t]he project is in an area where all public services and facilities are available to allow for maximum development permissible in the General Plan
and (B) [t]he area in which the project is located is not environmentally sensitive.
(14 C
al Code Regs. § 15301(e).)
DISCUSSION
I. The
Project May Have a Significant Air Quality Impact, Precluding Reliance on the Infill Exemption.
The Project does not qualify for the Infill Exemption because it might result in significant, cumulative air quality impacts. According to the Office of Environmental Health Hazard Assessment’s (OEHHA) CalEnviroScreen Communities Environmental Health Screening Tool, the census tract where the Project is located has a pollution burden of 88, meaning residents in this tract bear a higher pollution burden than 88 percent of tracts in the state. (Exhibit A.)
1 For diesel particulate matter (“DPM”), a toxic air contaminant, the Project location is worse than 69 percent of other census tracts in the state. (Exhibit B.) Diesel trucks, like those to be used during the construction and operation of the Project, are a major source of DPM emissions. (Exhibit B.) Exposure to DPM is known to cause serious health problems, such as heart and lung disease and lung cancer. (Exhibit B.) These health impacts are important to consider given that the census tract where the site is located is in the 68th percentile for cardiovascular disease, meaning it is higher than 68 percent of the census tracts in California. (Exhibit C.)
1 CalEnviroScreen is available at:
https://experience.arcgis.com/experience/ed5953d89038431dbf4f22ab9abfe40d/
April 23, 2025
SAFER Comment on Cal Box II Project
Within this setting, the Project will contribute to the already harmful air quality conditions in the surround area. This is a potentially significant cumulative impact that disqualifies the Project from proceeding under the Infill Exemption. The Project must undergo CEQA review through the preparation of an initial study followed by an EIR or MND to adequately analyze this impact.
II. The P
roject Does Not Meet the Criteria for the Existing Facilities Exemption.
The P
roject does not qualify for the Existing Facilities Exemption because it does not consist of a “minor alteration” that involves a “negligible or no expansion of [an] existing or former use.” (14 Cal. Code Regs. § 15301(e).) The Project greatly exceeds what is permitted as an addition to an existing structure, which at most is a 10,000 square foot addition. Here, the Project is proposing a 45,993 square foot addition, more than four times the additional square footage allowed under the Existing Facilities Exemption. Thus, the Project is far too big to qualify for this exemption and must be analyzed in an EIR or MND.
CONCLUS
ION
SAF
ER respectfully requests that the Planning Commission find that the Project does not qualify for the Infill or Existing Facilities Exemption and recommend that staff prepare an initial study followed by an EIR or MND for the Project in order to analyze and mitigate significant impacts as well as ensure compliance with CEQA.
Sin
cerely,
Kyl
ah Staley
Lozeau | Drury LLP
EXHIB
IT A
CalEnviroScreen 4.0 Indicator Maps Results Map �
Pollution Burden Results
Census Tract 6071002110
Pollution Burden:
Population:
88 7460
CalEnviroScreen 4.0 Percentile: 7 4
Ozone:
PM 2.5:
Diesel PM:
Pesticides:
95 96
69 0
94 [D V X
EXHIBIT B
EXHIBIT C
EXHIBIT 2
1 | Page
May 12, 2025
Lozeau Drury LLP
1939 Harrison Street, Suite 150
Oakland, CA 94612
Attn: Ms. Kylah Staley
Subject: Comment Letter on Class 32 Infill Exemption For CAL Box II Expansion Project, 8949 Toronto Avenue, Rancho
Cucamonga, San Bernardino County, California
Dear Ms. Staley:
At the request of Lozeau Drury LLP (Lozeau Drury), Clark and Associates (Clark) has reviewed materials related to the above referenced project.
Clark’s review of the materials in no way constitutes a validation of the conclusions or materials contained within Project file from the City of Rancho Cucamonga. If we do not comment on a specific item, this does not constitute acceptance of the item.
The project site is located at 8949 Toronto Avenue and is developed with a 98,406 -square-foot industrial building constructed in 1995 by Cal Box. Cal Box manufactures and distributes custom designed corrugated boxes for businesses. They are proposing an expansion of their existing facility to store raw materials and finished goods manufactured on site. The parcel is approximately 532 feet from east to west and 613 feet from north to south, with an area of approximately 336,283 square feet (7.7 acres).
The applicant proposes constructing a 45,993- square-foot addition along the west elevation of the existing 98,406- square-foot industrial building. The addition will be used to store raw materials and finished goods related to the site's primary manufacturing use, which is Clark & Associates
Environmental Consulting, Inc.
OFFICE
12405 Venice Blvd
Suite 331
Los Angeles, CA 90066
PHONE
310-907-6165
FAX
310-398-7626
EMAIL
[email protected]
2 | Page
proposed to continue in relation to the subject request for entitlements.
Figure 1: Proposed Addition
The proposed building addition will be of concrete tilt-up construction and designed to match the existing building, including the use of form lines and high windows. A two- story design element with glazing has been added to the southwest corner of the addition to create an office-like appearance, along with new landscaping along the west and south elevations and decorative paving at the main vehicle entrance.
The landscaping in the existing parking lot area will be enhanced to meet current landscape
3 | Page
requirements, including the addition of trees, shrubs, and ground cover. The existing and new loading areas, dock doors, and trailer parking stalls will be located on the north and south elevations of the building and screened from public view by an existing wall and by the building.
Cal Box operates 24 hours a day, Monday through Friday, with up to 64 employees working in two shifts. During peak periods, up to two Saturday shifts may be added per month between 2:00 a.m. and 5:30 p.m. Office personnel work from 8:00 a.m. to 5:00 p.m., Monday through Friday. On average, 20 trucks access the site daily.
The expansion will not increase the number of employees or vehicles accessing the site but will relocate existing outdoor activities indoors. The site has sufficient parking to accommodate the current staff, trucks, and trailers.
After a careful review of the supporting document ation it is clear that a Class 32 Categorical Exemption is not warranted for the Project. The City should require the Proponent to prepare an environmental impact report (EIR) for the expansion project.
Specific Comments
1. The Project Does Not Warrant A Class 32 Categorical Exemption As is detailed in the CEQA Notice of Exemption: Memorandum of Findings 1 prepared by Universal Engineering Sciences, the Subject Property is an approximately 7.41-acre parcel developed with a single structure consisting of a manufacturing area and administrative offices. The findings of the UES memorandum concluded that the proposed project development involves a 45,993-square- foot addition to an existing warehouse building and will occupy no more than 1.5 acres of land. The addition will be adjoined to the current building within the same parcel, and therefore, no new land area will need to be developed or disturbed.
The parsing of the Project from the Project site is assumed to be the reason for the CE.
Section 15332 and 15301 of CEQA states that a CE is appropriate if • Section 15332 (Infill Development Projects): Covers infill developments on sites less than 5 acres, with no significant impact on traffic, noise, air quality, or water.
1 UES. 2025. CEQA Notice of Exemption: Memorandum of Findings – CAL Box II Warehouse Expansion Project.
4 | Page
• Section 15301 (Existing Facilities): Covers the Conditional Use Permit requirement for a Manufacturing Use (Large) over 50,000 square feet in the ME2 Zone.
As noted above the Project is situated on a 7.41 acre parcel , not just the 1.5 acres which the 45,993 square foot addition will be added. The reconfiguration will involve access all of the site to ensure that construction can proceed. The attempt to parse out the smaller parcel is clearly not supportable.
2. The Project Site Is Located In The Top 5% Of Zip Codes In California For Exposure To Ozone And PM 2.5, Adding Additional Sources Of Ozone Precursors and PM 2.5 Would Adversely Impact The Community
The Project Site is located in census tract 6071002110 (zipcode 91730). Using the Office of Environmental Health and Hazard Assessment’s (OEHHA’s) California Communities Environmental Health Screening Tool Version·4.0 (CalEnviroScreen) it is possible to assess the existing concerns for the census tract in which the P roject is located. The Project Site is also identified as an SB 535 Disadvantaged Community due to the high exposure of the community to criteria air pollutants.
5 | Page
Based on the CalEnviroScreen summary of zipcode 91730, it is clear that the area is in the top 26% of all communities in the State of California impacted by pollution. The Project Site is in the top 4% of communities in the State of California impacted by particulate matter less than 2.5 microns (PM2.5), a criteria pollutant regulated for by U.S EPA and the State of California. In addition, the Project Site is in the top 5% of communities in the State of California impacted by ozone. Increasing the number of sources of ozone precursors and PM2.5 within the community via the construction of the Project will exacerbate pollution levels and place a greater health burden on the community,
3. Using The CalEEMod Software From The California Air Pollution Control Offices Association (CAPCOA) It Is Clear That Emissions From A Warehouse Constructed Onsite Would Release Substantial Concentrations Of Criteria Pollutants And Toxic Air Contaminants To The Immediate Vicinity Of The Project Site.
6 | Page
Using the CAPCOA’s CalEEMod software I have prepared an analysis of the construction and operational emissions of the Project assuming it is operated in the manner described by the City. Using the default parameters from the CalEEMod the model (Exhibit to this letter) assumed a construction phase lasting approximately 14-months in duration.
Figure 2: Emissions From Construction Of Addition
Based on the CalEEMod analysis it is clear that daily PM 2.5 emissions would increase by as much as 11.3 lbs per day during the construction phase of the Project. The average daily increase during the first 12 months of construction would be 0.6 lbs per day. The 0.6 lbs per day would effectively double the PM 2.5 emissions from the Project Site that are normally seen from the Site’s operations.
7 | Page
Figure 3: CalEEMod Emissions For Operation
For a Project located in the top 5% of all census tracts in California for exposure to PM 2.5 this represents a substantial increase in the exposure of the community to the pollutant.
In addition, the construction phase would add as much as 1.24 lbs per day of diesel particulate matter (DPM) to the immediate vicinity of the Project Site. To determine whether the construction activities will exceed a significance threshold for construction activities , the City should perform a multistep, quantitative health risk analysis for toxic air contaminants ( TACs) from the construction and operational phases of the Project. TACs primarily associated with the construction phase are diesel particul ate matter (DPM) from off- road construction equipment. The impacts of those emissions will be greatest for the receptors nearest the Project Site (including the Cal Box II staff who will be present during all of the construction).
In addition to TACs from diesel exhaust (assumed to be diesel particulate matter or DPM), the California Air Resources Board’s (CARB’s) analysis of tailpipe emissions shows that in addition to simple alkane hydrocarbons, the emissions also contain benzene (human carcinogen), 1,3- butadiene (human carcinogen), ethylbenzene (human carcinogen), toluene (neurotoxin), acetaldehyde
8 | Page
(respiratory irritant), and formaldehyde (human carcinogen), and other air toxins. These air toxins make up approximately 22% of the total organic gases (TOGs) emitted from vehicles.
CARB
TOG Speciation Profile
Run Exhaust2
CAS# Chemical Name Fraction
75070 Acetaldehyde 0.0028
107028 Acrolein 0.0013
71432 Benzene 0.0247
106990 1,3-Butadiene 0.0055
100414 Ethylbenzene 0.0105
50000 Formaldehyde 0.0158
110543 Hexane 0.0160
67561 Methanol 0.0012
78933 Methyl Ethyl Ketone 0.0002
91203 Naphthalene 0.0005
115071 Propylene 0.0306
100425 Styrene 0.0012
108883 Toluene 0.0576
1330207 Xylenes 0.0480
Clearly the majority of emissions of these compounds from the surrounding sites to the Project site will be associated with passenger vehicles , resulting in significant exposure to benzene (human carcinogen), 1,3- butadiene (human carcinogen), ethylbenzene (human carcinogen), toluene (neurotoxin), acetaldehyde (respiratory irritant), and formaldehyde (human carcinogen), and other air toxins.
The inherent toxicity of TACs requires the City to first quantify the concentration of each TAC released into the environment at each of the sensitive receptor locations through air dispersion modeling, calculate the dose of each TAC at that location, and quantify the cancer risk and hazard index for each of the chemicals of concern. Following that analysis, then the City can make a determination of the relative significance of the emissions. The results should then be presented in an EIR prior to approving any agreements with the Proponent or issuing any permits for the Project.
2 https://ww2.arb.ca.gov/speciation-profiles-used-carb-modeling
9 | Page
Conclusion
The facts identified and referenced in this comment letter lead me to reasonably conclude that the Project will result in significant impacts if allowed to proceed.
Sincerely,