Apr 9-City Council Agenda Item 14 — Reedley City Council, April 9, 2024 (part 9 of 10)

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City of Reedley Page 2
CEQA Comments on East Huntsman Avenue Industrial Park Project February 27, 2024 10211 Sunland Blvd., Shadow Hills, CA 91040 (818) 650-0030 X101 [email protected] FivePoint Valencia), and Centennial (part of Tejon Ranch) decided to move forward as net-zero communities after losing CEQA lawsuits to environmental groups. The ability for these large projects to become net-zero indicates that it is achievable, even for large-scale developments. The Applicant for this Project should do the same.

We urge the City to adopt net-zero as the GHG significance threshold for this project. This threshold is well-supported by plans for the reduction of GHG emissions in California, and particularly the CARB Climate Change Scoping Plans. The CARB 2017 Scoping Plan states that “achieving no net additional increase in GHG emissions, resulting in no contribution to GHG impacts, is an appropriate overall objective for new development.” (CARB 2017 Scoping Plan, p. 101.) Additionally, the CARB 2022 Scoping Plan reaffirms the necessity of a net zero target by expressing:
“it is clear that California must transition away from fossil fuels to zero-emission technologies with all possible speed … in order to meet our GHG and air quality targets.” (CARB 2022 Scoping Plan, p. 184.) CARB further encourages a net-zero threshold in its strategies for local actions in Appendix D to the 2022 Scoping Plan. (CARB 2022 Scoping Plan, Appendix D p. 24-26.) Moving this Project forward as a net-zero project would not only be the right thing for the City to do, but also would also help protect the City and the Applicant from CEQA GHG litigation.

Inadequate and Unstable Project Description
CEQA requires a stable and consistent project description that properly discloses the necessary information for the public and decision-makers to understand fundamental aspects of the project.

Here, the Project description was inadequate or otherwise inconsistent with the body of the MND because the greenhouse gas analysis within the MND mentioned that the Project would include a pistachio processing facility which is discussed nowhere else in the MND. The project description and characteristics discussed 26 lots with various buildings of different sizes, primarily for office/warehouse or office/retail, which is inconsistent with the statement on page 3-49 that the Project would involve a pistachio processing facility. (MND, p. 3-49.) The City should not be able to rely on such information in the greenhouse gas analysis which is inconsistent with the rest of the MND, including the project description.

GHG Significance Analysis
The MND adopted two significance thresholds based on the CEQA Guidelines Appendix G.

Overall, the MND concluded that the Project’s GHG emissions are less than significant. Given the inadequacy of analysis under both sections, there is a fair argument for why the Project would have a significant impact under both of these thresholds. A significant impact under either threshold would require a finding of significant impact.
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City of Reedley Page 3
CEQA Comments on East Huntsman Avenue Industrial Park Project February 27, 2024 10211 Sunland Blvd., Shadow Hills, CA 91040 (818) 650-0030 X101 [email protected] The City’s Analysis of CAP Compliance is Not Supported by Substantial Evidence Threshold (a), asks whether the Project would “generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment.” (MND, p. 3-43.) Under this threshold, the City concluded that the Project would have a less-than-significant impact because, after quantifying the Project’s annual GHG emissions at approximately 4,703.3 metric tons carbon dioxide equivalent (MTCO2e) per year, the City indicated that the Project would adhere to the local Climate Action Plan (CAP) such that it would be deemed a less-than-significant GHG impact. (MND, p. 3-45.)
However, the Project would conflict with the local CAP, making the Project the source of a significant GHG impact. In particular, the CAP requires that projects in the City of Reedley meet a 20% reduction in GHG emissions, which the record was unable to demonstrate. The CAP lists GHG reduction measures, as well as an “average” suggested reduction. Yet, the requirement under the CAP is to demonstrate a 20% reduction of the project, and here the CALEEMod outputs demonstrate that the average reductions could not be achieved, even when the reduction measures are implemented.

Likewise, installing an energy star rated water heater would only amount to Project emission reductions of 4.5%, far below the average assumption of 12%.2 With these more accurate metrics in mind—that the City should have considered instead of the averages—all of the CAP GHG reduction 1 !"#$# &'()$*%*+*,-. */01102+1% 3 %45$4 6$478 9 :4# &'()$*%,*;<=>02+ :4# &'()$*%,*;<=>02+% ? %@"A4:5:%&'()$*%>2>BC D,2E*=> */01102+1 9 BDD,2F5 G5#7% Energy metric from CalEEMod Outputs p.14/66. The true reduction could be even lower, because only 778 MTCO2e would be emitted as a result of the Project’s unmitigated electricity use, and it is unclear whether the solar energy would also replace 20% of the natural gas usage, which amounts for nearly half of the total Project’s energy use. (CalEEMod Outputs, p. 39/66).
2 Water heating accounts for 20% of home energy use and energy star rated water heaters can save 70% of energy. https://www.energystar.gov/products/energy_star_home_upgrade/super_efficient_water_heater#:~:text=Water%20hea ters%20use%20about%2020,energy%20than%20a%20standard%20model. !"#$# &'()$*%*+*,-. H ,*CB>*; */01102+1 3 %45$4%6$47 2I *+*,-. <1*8 3 %45A4%6A47 ,*;<=>02+8 9 $!:5#%&'()$*%,*;<=>02+
$!:5#%&'()$*%,*;<=>02+% ? @"A4:5:%&'()$*%>2>BC D,2E*=> */01102+1 9 @5#7 Energy metric from CalEEMod Outputs p.14/66
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And this is assuming that the remaining reduction measures would achieve the purported reductions, which is unlikely because the particular impacts which they target (i.e., energy efficiency and water usage) are not large in comparison to the Project’s mobile emissions. EV charging stations is the only GHG Reduction Measures which could potentially address this source of emissions but would not address the emissions from heavy duty vehicles, which account for 2,468 MTCO2e. (See Appendix A, CalEEMod Output Sheets, Heavy Heavy Duty Truck Trips Custom Report.) Further, the City cannot sincerely rely on planting shade trees to reduce 2% of the Project’s emissions because the CalEEMod Output does not include vegetation-related emissions estimates.

Even if the Project is consistent with the requirement of 20% GHG reduction based on the CAP Compliance Checklist, this is not sufficient to demonstrate that the Project would not generate GHG emissions that may have a significant impact on the environment. In particular, even after a reduction of 20% of the Project’s emissions, the Project would still emit 3,762.64 MTCO2e.4 This
new source of emissions far exceeds the CO2e emissions from the entire City of Reedley in 2005, the baseline year from which the 2030 goal of 50% CO2e reduction is derived.5 Accordingly, there is no
evidence that adhering to the requirements of the CAP would adequately account for the goals therein. Furthermore, there is no evidence that adherence with the CAP would reduce the Project’s emissions to a less-than-significant level.

Consistency with Applicable Plans, Policies, and Regulations The City only considered only two applicable plans: the 2022 Scoping Plan from the California Air Resources Board (2022 Scoping Plan) and Fresno COG’s 2022 Regional Transportation Plan (Fresno RTP) when it concluded less-than-significant impact. (MND, p. 47-49.) This significance analysis violates CEQA by being deficient and misleading in several areas.

The Project does not comply with the Fresno RTP as the City contends. The City did not adequately analyze the Fresno RTP but summarily dismissed the potential for conflict with the Fresno RTP because the Project would purportedly include a pistachio processing facility. This would purportedly make the Project consistent with the growth assumptions in the Fresno RTP. Even if this were true, this assertion is insufficient to demonstrate that the Project would be consistent with the Fresno RTP as a whole. The RTP sets numerous goals and identifies implementing parties, as well as the timeframe in which those goals should be accomplished (short-term or long term). The RTP thus 3 G5#7 612CB, *+*,-. ,*;<=>02+8 J :5#7 6KB>*,%L*B>*, ,*;<=>02+8 J !7 6M0>=L*+ IB<=*>8 J !7 6NB>L,22/ IB<=*>8 J !7%6>20C*>8 J 45$7 60,,0-B>02+8 J 45!!7 OP%=LB,-0+- J $7 6CB+;1=BD0+-8 9 !#5:!7 4 @"A4:5:%&'()$* 3 %45Q%6Q478 9 %:"AG$5G@ &'()$* 5 2005 emissions were 2,360 MTCO2e (CAP, p. 15.) 1

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City of Reedley Page 5
CEQA Comments on East Huntsman Avenue Industrial Park Project February 27, 2024 10211 Sunland Blvd., Shadow Hills, CA 91040 (818) 650-0030 X101 [email protected] indicates which goals are to be accomplished, in part, by “cities,” which would include the City of Reedley. Such goals include encouraging alternatives to single-occupancy vehicle trips, reducing vehicle miles traveled (VMT), supporting electric vehicle infrastructure development, among other specific actions that should be taken by cities (RTP Chapter 4, p. 5-10).

Although information is lacking due to an inadequate discussion of consistency with the Fresno RTP, there is a fair argument that the Project would not adhere to the standards set by the Fresno RTP because there is no mention of aiming to reduce single-occupancy vehicle trips or supporting electric vehicle infrastructure anywhere in the MND.

In relation to the RTP’s goal of reducing VMT, the Project’s VMT analysis insufficient to demonstrate consistency with the RTP. In particular, the MND states that the Project’s 555 employees would create 2,652,707 VMT per year based on 691 vehicle trips. (MND, p. 3-36 (VMT); 3-76 (Employees); 3-13 (Vehicle Trips)). Yet, the MND does not provide evidence in the record that the project would only generate 691 average daily trips because it did not provide what factors went into that estimate, such as the number of working days each year and the amount of carpooling or alternative transportation anticipated (MND, p. 3-13). The discussion of VMT within the MND does not provide enough information to indicate that it would be consistent with the RTP as the City suggests.

Moreover, the MND does not discuss the truck trips in the context of VMT. The Project would involve about 174 truck trips,6 each 40 miles per day, amounting to an extra 6,960 VMT per day. (MND, p. 3-13.) Accordingly, the per-capita metric, including truck trips, would be 25.63, which demonstrates no reduction below the baseline regional average. (MND, p. 3-86). While this may not change the significance in the context of transportation impact, it has drastic implications in terms of assessing the air quality and GHG impact, which accounted for a default vehicle fleet assumption rather than the parameters of this project in which there are many heavy-duty truck trips. (MND, p. 3-36.) Conflict with a single applicable plan is sufficient to find that the chosen threshold is not met, and therefore the City should have found a significant GHG impact due to conflict with the Fresno RTP.

Further, although the MND included a discussion of consistency with the 2022 Scoping Plan, the Project would conflict with the 2022 Scoping Plan. The 2022 Scoping Plan sets a goal for 50% of all industrial energy demand to be electrified by 2045 (2022 CARB Scoping Plan, p. 77). The 2022 CARB Scoping Plan also places particular emphasis on decarbonizing industrial facilities by “displacing fossil fuel use with a mix of electrification, solar thermal heat, biomethane, low- or zerocarbon hydrogen, and other low-carbon fuels to provide energy for heat and reduce combustion emissions” (2022 CARB Scoping Plan, p. 208). And one of the principal goals of the 2022 Scoping Plan is to reduce statewide GHG emissions to 85% below 1990 levels by 2045. The Project is 6 GR! >,0D1 H #!A DB11*+-*, >,0D1 9 !A@ >,<=M >,0D1
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City of Reedley Page 6
CEQA Comments on East Huntsman Avenue Industrial Park Project February 27, 2024 10211 Sunland Blvd., Shadow Hills, CA 91040 (818) 650-0030 X101 [email protected] inconsistent with these goals because it would create an additional large source of emissions from nonrenewable sources, contrary to the statewide electrification and decarbonization contemplated by the 2022 Scoping Plan.

Therefore, by the City’s own adopted significance threshold and chosen plans, the Project would have a significant GHG impact.

The MND Did Not Analyze Other Applicable Plans
The City chose, as its second GHG threshold, Threshold (b), which asks whether the Project would “[c]onflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases.” (MND, p. 3-47.) This language requires that the MND analyze the Project’s consistency with all other applicable plans, not just the plans that the City prefers to analyze.

The MND accounted for a building lifespan of 30 years. (MND, p. 3-44) Due to construction anticipated from 2025 to 2026, (MND, p. 3-11) the Project will likely be operating well into 2056.

Accordingly, the Project must show consistency with long-term State GHG goals to comply with CEQA. In particular, the MND must also demonstrate consistency with Executive Order B-55-18 (EO B-55-18) and the 2017 CARB Scoping Plan.

EO B-55-18 requires the State of California to achieve carbon neutrality—net zero GHG emissions—by 2045. The Project is inconsistent with EO B-55-18 because it does not prohibit the use of gasoline, diesel, and natural gas, and burning such non-renewable fuels results in substantial GHG emissions. In particular, the trucks anticipated in this Project use diesel fuel—estimated at 24,824 gallons per year—which would emit high quantities of GHGs, preventing the Project from ever achieving carbon neutrality.

The 2017 Scoping Plan was developed to facilitate California’s compliance with SB 32, which requires statewide GHG emissions to be reduced to 40% below 1990 levels by 2030. (Health & Safety Code § 38566.) The MND did not discuss how the Project is consistent with any of the goals, including the 2050 goal of 80% below 1990 levels. The 2017 Scoping Plan also sets out statewide goals for total GHG emissions targets of 6 MTCO2e/capita by 2030, and 2 MTCO2e/capita by 2050 (CARB Scoping Plan, p. 99).

With the Project’s annual GHG emissions at 4,703.3 MTCO2e annually and 555 employees, the Project’s per-service population GHG emissions would be approximately 8.47 MTCO2e/capita, which exceeds the 2030 and is over four times the 2050 target, which would have to be achieved well within the Project’s lifespan to be consistent with the 2017 Scoping Plan.7 Thus, the Project’s GHG
impact is significant under the second threshold because it is inconsistent with applicable plans for the reduction of GHGs.
7 @"A4:5:%&'()$* ? ### */DC2.**1 9 Q5@A &'()$*%D*, 1*,S0=* D2D<CB>02+ 1

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City of Reedley Page 7
CEQA Comments on East Huntsman Avenue Industrial Park Project February 27, 2024 10211 Sunland Blvd., Shadow Hills, CA 91040 (818) 650-0030 X101 [email protected] The City Should Have Prepared an EIR
No mitigation measures were considered for GHGs due to the erroneous determination of lessthan-significant impact. However, because the City should have found significant impact for GHG emissions based on inconsistency with applicable plans, it should update its findings accordingly and would therefore be required to create a full Environmental Impact Report (EIR) and mitigate to the extent required by CEQA.

If the City had used appropriate significant thresholds and accurate analysis, it would have concluded that the Project’s GHG emissions are significant. Inconsistency with applicable plans for the reduction of GHG emissions supports a fair argument that the Project would have a significant environmental effect. Because the above discussion provides a fair argument that the Project may have significant GHG impacts, the City must prepare an EIR. Therefore, the City was mistaken in its choice to create an MND for a Project that would likely create such a considerable GHG impact.

Conclusion
For the reasons given in this letter, the MND is not in conformance with CEQA requirements. Notably, the MND failed as an informational document for decision makers and the public, the significance analysis was inadequate, and the City should have concluded that the Project would contribute to a significant GHG impact.

Please put Advocates for the Environment on the interest list to receive updates about the progress of this Project.

Sincerely,
Dean Wallraff, Attorney at Law
Executive Director, Advocates for the Environment
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1 CARLSBAD
CLOVIS
IRVINE

LOS ANGELES

PALM SPRINGS

POINT RICHMOND

RIVERSIDE

ROSEVILLE

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

MEMORANDUM
DATE: March 29, 2024
TO: Rodney L. Horton, Community Development Director, City of Reedley FROM: Kyle Simpson, Principal
SUBJECT: East Huntsman Avenue Industrial Park Project Initial Study/Mitigated Negative Declaration Response to Comments
In accordance with Section 15074 of the California Environmental Quality Act (CEQA) Guidelines, prior to approving a project, the decision-making body of the Lead Agency shall consider the proposed environmental document together with any comments received during the public review process. Although there is no legal requirement to formally respond to comments on a proposed Mitigated Negative Declaration (MND) as there is for an Environmental Impact Report (EIR), this memorandum provides responses to the written comments received on the proposed East Huntsman Avenue Industrial Park Project (project) Initial Study/Mitigated Negative Declaration (IS/MND) to aid the City of Reedley (City) decision-makers in their review of the proposed Project.

The Draft IS/MND was available for public review and comment from January 29, 2024, to February 27, 2024. A total of three comment letters on the IS/MND were received: one during the public review comment period, and an additional two comments letters outside the public review comment period for the IS/MND. The comment letter received during the comment period was addressed in a Response to Comments memorandum dated March 6, 2024.

This memorandum will address the two remaining comment letters for the IS/MND. The comment letters are attached to this memorandum. In the following pages, the topic sections addressed in the comments and associated responses are enumerated to allow for cross-referencing of CEQA-related comments. As noted above, CEQA does not require or provide guidance on responding to comments on MNDs; therefore, this memorandum follows CEQA Guidelines Section 15088, applicable to responses to comments on EIRs, which requires that agencies respond only to significant environmental issues raised in connection with the proposed Project. Therefore, this document focuses primarily on responding to comments that relate to the adequacy of the information and environmental analysis provided in the IS/MND.

Section A of this memorandum identifies the comment letters being addressed. Section B includes a reproduction of each enumerated comment followed by responses to each comment. Section C of this memorandum provides identifies all text changes to the IS/MND made in response to the comments received on the Draft IS/MND.
3/29/24 (P:\20231045.02 Huntsman\PRODUCTS\RTC\Admin\Huntsman_RTC_Memo-Draft_2.docx) 2 A. COMMENT LETTERS
This memorandum includes a reproduction of the comment letters received on the IS/MND after the comment period, and individual comments within the comment letters are numbered consecutively.

The comment letters listed below were submitted to the City regarding the IS/MND after the comment period.

LETTER 2
Blum, Collins & Ho LLP
Gary Ho
February 28, 2024
LETTER 3
Golden State Environmental Justice Alliance
Pete Sheehan
March 4, 2024
Please note that text within the comment letters that has not been numbered does not raise environmental issues or relate to the adequacy of the information or analysis within the IS/MND and, therefore, no comment is enumerated or response required, per CEQA Guidelines Section 15132.

Responses to the comments included below were prepared with the assistance from Cara Cunningham, an Associate/Senior Environmental Planner at LSA that specializes in air quality and energy technical analysis, and Ambarish Mukherjee, Principal and Senior Transportation Planner at LSA.

Ms. Cunningham is an Associate/Senior Environmental Planner with over 10 years of experience. At LSA, she provides project management and technical assistance on a variety of planning and environmental documents including Environmental Assessments, Initial Studies, and Environmental Impact Reports (EIR). Ms. Cunningham has a strong foundation in land use planning and is well versed in addressing impacts to air quality, greenhouse gas (GHG) emissions, and energy. Ms.

Cunningham is proficient in air quality models, including the California Emissions Estimator Model (CalEEMod) and the Roadway Emissions Estimator Model (RoadMod).

As a Principal and Senior Transportation Planner at LSA, Mr. Mukherjee specializes in travel demand modeling and public infrastructure projects, and conducts traffic impact analyses for a wide variety of large and small projects including transit projects, residential development, mixed-use development, commercial and office projects, parking structures, roadway and circulation improvements, and General Plans and Specific Plans.

B. COMMENTS AND RESPONSES
LETTER 2
Blum, Collins & Ho LLP
3/29/24 (P:\20231045.02 Huntsman\PRODUCTS\RTC\Admin\Huntsman_RTC_Memo-Draft_2.docx) 3 Gary Ho
February 28, 2024
Comment 2-1: Thank you for the opportunity to comment on the Mitigated Negative Declaration (MND) for the proposed East Huntsman Avenue Industrial Park Project. Please accept and consider these comments on behalf of Golden State Environmental Justice Alliance. Also, Golden State Environmental Justice Alliance formally requests to be added to the public interest list regarding any subsequent environmental documents, public notices, public hearings, and notices of determination for this project. Send all communications to Golden State Environmental Justice Alliance P.O. Box 79222 Corona, CA 92877.

Response 2-1: This comment provides an introduction to the comment letter, and requests the City to include Golden State Environmental Justice Alliance in the public interest list for the project, to be notified of all subsequent environmental documents, hearings and notices related to the project. This comment is noted. The City will include Golden State Environmental Justice Alliance in the public interest list for the project. No further response is necessary.

Comment 2-2: The proposed Project proposes the development of an approximately 42-acre site into a 26-lot light industrial park. The project site is currently used for growing agricultural crops and contains agricultural support buildings and one single-family residence. The proposed Project includes the annexation of the project site into the City of Reedley, after which the project site would be prezoned to the Light Industrial (ML) District and the Fresno County General Plan agricultural land use designation would change to Light Industrial as established in the City’s General Plan. The proposed project would require approval of an annexation application, Sphere of Influence Application to LAFCO, a rezone (pre-zone), and a Tentative Subdivision Map.

The project development includes construction and operation of approximately 340,000 square feet of warehousing buildings and 11,200 square foot building for a truck maintenance/truck wash. The proposed project would include 30 truck/trailer parking stalls, 595 passenger car parking stalls, and truck loading zones in the southern and eastern portions of the project site. Additionally, the proposed project would include an overnight parking lot with capacity for approximately 100 semitrucks in the project site.

Response 2-2: This comment includes a summary of the Project Description for the proposed project included in the IS/MND. This comment is noted but does not pertain to the analysis or conclusions of the IS/MND. No further response is required.

Comment 2-3: The MND does not include floor plans, a detailed site plan, building elevations, or a conceptual grading plan. The basic components of a Planning Application include a detailed site plan, floor plan, conceptual grading plan, written narrative, and detailed elevations. Providing the grading plan and earthwork quantity notes is vital as the MND states that, “The proposed project would not require any soil import/export” and there is no method for the public to verify this claim.

The quantity of import/exported materials and soils directly informs the quantity of necessary truck hauling trips due to soil import/export during the grading phase of construction. An EIR must be 3/29/24 (P:\20231045.02 Huntsman\PRODUCTS\RTC\Admin\Huntsman_RTC_Memo-Draft_2.docx) 4 prepared to include wholly accurate and adequate detailed site plan, floor plan, grading plan, elevations, and project narrative for public review.

Response 2-3: This comment states that the Project Description in the IS/MND does not include a detailed site plan, floor plan, conceptual grading plan, or building elevations for the proposed project. Further, the comment asserts that the provision of a grading plan and earthwork quantity notes is important to confirm the quantity of truck hauling trips needed for soil import and export during construction, and claims that there is no method available to verify that no soil import or export would be required during construction of the project.

Section 15124 of the CEQA Guidelines states that the description of a project shall contain the following information but should not supply extensive detail beyond that needed for evaluation and review of the environmental impact. Although these guidelines are meant to guide description of a project in an EIR document, they are being used as a baseline for the response to this comment:
(a) The precise location and boundaries of the proposed project shown on a detailed map, preferably topographic. The location of the project shall also appear on a regional map. (b) A statement of the objectives sought by the proposed project. A clearly written statement of objectives will help the lead agency develop a reasonable range of alternatives to evaluate in the EIR and will aid the decision makers in preparing findings or a statement of overriding considerations, if necessary. The statement of objectives should include the underlying purpose of the project and may discuss the project benefits.
(c) A general description of the project’s technical, economic, and environmental characteristics, considering the principal engineering proposals, if any, and supporting public service facilities.
(d) A statement briefly describing the intended uses of the EIR, including: a list of the agencies that are expected to use the EIR in their decision making; a list of permits and other approvals required to implement the project; and a list of related environmental review and consultation requirements of federal, State, or local laws, regulations, or policies. To the fullest extent possible, the lead agency should integrate CEQA review with these related environmental review and consultation requirements and decisions subject to CEQA should be listed, preferably in the order in which they will occur.

Chapter 1.0, Project Information, of the IS/MND is consistent with these requirements and describes the characteristics of the proposed project. Figure 1-1 shows the project site’s regional and local context and Figure 1-2 shows the project site and surrounding land uses, consistent with the requirements of Section 15124(a). Figure 1-3 shows the project’s site plan. In addition, although not specifically called out in project objectives, the underlying purpose of the project, which includes fulfilling the light industrial land use plan for the project parcel consistent with the City of Reedley’s General Plan, is implied in the analysis included in the IS/MND.
3/29/24 (P:\20231045.02 Huntsman\PRODUCTS\RTC\Admin\Huntsman_RTC_Memo-Draft_2.docx) 5 A description of the proposed project is included in Chapter 1.0, Project Information, consistent with the requirements of Section 15124(c). In addition, the list of agencies and potential permits and approvals that may be required is also included in this chapter, consistent with the requirements of Section 15124(d). As such, the Project Description is consistent with CEQA requirements.

As identified on page 1-4 of the IS/MND, the proposed project would not require any soil import or export. The project site is relatively flat; therefore, soil would be balanced on site without any requirement for soil import or export. Additionally, although specific building heights were not specified, the IS/MND indicates that the project would be subject to design specifications for the Light Industrial (ML) Zoning District of the City, which limits building elevations to up to 75 feet high.

The proposed project consists of developing the project site into a 26-lot light industrial park. Proposed lots would be occupied by office, warehouse, and retail uses, as well as a truck maintenance building. Given that future tenants for the proposed light industrial park have not been identified, detailed site plans outlining floor plans and elevations for proposed buildings have not been prepared. However, detailed floor plans and elevations would not provide additional details that would aid in evaluating project impacts as the proposed massing of the buildings and estimated heights are known and were considered in the IS/MND analysis.

As such, this comment is noted, but does not raise any significant environmental issues related to the project or the analysis contained in the IS/MND. No further response is required.

Comment 2-4: Please refer to attachments from SWAPE for a complete technical commentary and analysis.

The MND does not include for analysis relevant environmental justice issues in reviewing potential impacts, including cumulative impacts from the proposed project. According to CalEnviroScreen

4.01 , CalEPA’s screening tool that ranks each census tract in the state for pollution and socioeconomic vulnerability, the proposed project’s census tract (6019006300) is highly burdened by pollution and ranks in the 81st percentile for overall pollution burden. The surrounding community bears the impact of multiple sources of pollution and is more polluted than average on several pollution indicators measured by CalEnviroScreen. For example, the project census tract ranks in the 91st percentile for ozone burden and the 94th percentile for particulate matter (PM) 2.5 burden, both of which are attributed to heavy truck activity in the area. Ozone can cause lung irritation, inflammation, and worsening of existing chronic health conditions, even at low levels of exposure2
.

Response 2-4: This comment states that the IS/MND does not include a relevant analysis of environmental justice issues in reviewing potential impacts, including cumulative impacts such as air pollution. This comment also claims that the census tract where the project is located ranks in the 81st percentile, indicating that it is among the most polluted census tracts in the State. This comment also states that the surrounding community bears the 3/29/24 (P:\20231045.02 Huntsman\PRODUCTS\RTC\Admin\Huntsman_RTC_Memo-Draft_2.docx) 6 impact of multiple sources of pollution and is more polluted than average on several pollution indicators measured by the California Communities Environmental Health Screening Tool (CalEnviroScreen).

The OEHHA, on behalf of the California Environmental Protection Agency (CalEPA), released Version 4.0 of CalEnviroScreen in October 2021. CalEnviroScreen identifies California communities by census tract that are disproportionately burdened by, and vulnerable to, multiple sources of pollution. Pollution burden scores for each census tract are derived from the average percentiles of the seven Exposures indicators (ozone and PM2.5 concentrations, DPM emissions, drinking water contaminants, pesticide use, toxic releases from facilities, and traffic density) and the five Environmental Effects indicators (cleanup sites, impaired water bodies, groundwater threats, hazardous waste facilities and generators, and solid waste sites and facilities). According to the CalEnviroScreen 4.0 Map,1 the project site has a pollution burden percentile of 81. Surrounding areas have pollution burdens ranging from 20 to 94. In addition, according to the SB (Senate Bill) 535 Disadvantaged Communities Map,2 the project area is designated as an SB 535 disadvantaged community.

In addition, as described on page 3-10 of the IS/MND, the San Joaquin Valley Air Basin (SJVAB) is designated as non-attainment for ozone and PM2.5 for federal standards and nonattainment for ozone, PM10, and PM2.5 for State standards. The San Joaquin Valley Air Pollution Control District’s (SJVAPCD) non-attainment 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 nature, air pollution is largely a cumulative impact. No single project is sufficient in size to, by itself, result in nonattainment of ambient air quality standards. 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, the SJVAPCD considered the emission levels for which a project’s individual emissions would be cumulatively considerable. If a project exceeds the identified SJVAPCD significance thresholds, its emissions would be cumulatively considerable, resulting in significant adverse air quality impacts to the region’s existing air quality conditions. As shown in Table 3.3.B and Table 3.3.C of the IS/MND, the proposed project would generate construction and operational emissions that are below the SJVAPCD’s thresholds. As such, the proposed project would not result in a cumulative air quality impact and additional analysis to assess cumulative impacts is not required.

Additionally, as discussed in page 3-14 of the IS/MND, a health risk assessment (HRA) was prepared for the proposed project to evaluate the potential impact on sensitive receptors 1 Office of Environmental Health Hazard Assessment (OEHHA). 2021. CalEnviroScreen 4.0. Website:
https://oehha.ca.gov/calenviroscreen/report/calenviroscreen-40 (accessed May 2021). 2 OEHHA. 2022. SB 535 Disadvantaged Communities using CalEnviroScreen 4.0 results. Website:
https://experience.arcgis.com/experience/1c21c53da8de48f1b946f3402fbae55c/page/SB-535- Disadvantaged-Communities/.pdf (accessed October 2022). 3/29/24 (P:\20231045.02 Huntsman\PRODUCTS\RTC\Admin\Huntsman_RTC_Memo-Draft_2.docx) 7 (including those that may be disadvantaged people) from construction and operation of the proposed project. The HRA evaluates the potential health risk to all people living and working near the proposed project associated with project construction and the exhaust of diesel-powered trucks and equipment during project operation. The HRA analysis was performed consistent with the SJVAPCD Guidance for Air Dispersion Modeling3 and the Office of Environmental Health Hazard Assessment (OEHHA) Air Toxic Hot Spots Program Risk Assessment Guidelines4
, and was conducted using three models: (1) California Air Resources Board’s (CARB) California Emissions Factor Model, Version 2021 (EMFAC2021) for on-road vehicle emissions factors and percentages of fuel type within the overall vehicle fleet; (2) the U.S. Environmental Protection Agency’s (EPA) AERMOD air dispersion model to determine how the toxic air contaminants (TACs) would move through the atmosphere after release from sources both on site and on surrounding roadways; and (3) CARB’s HARP2 model to translate the pollutant concentrations from AERMOD into individual health risks at any sensitive receptor locations surrounding the project site. As shown in Table 3.3.D and Table 3.3.E of the IS/MND, and based on the results of the HRA, construction and operation of the proposed project would not exceed SJVAPCD thresholds and would not expose nearby sensitive receptors to substantial pollutant concentrations.

Although the project site has a pollution burden percentile of 81, is designated as an SB 535 disadvantaged community, and is considered a diverse community, there is no methodology to quantify the cumulative areawide or localized health risks within a community-wide area.

The SJVAPCD’s recommended thresholds of significance apply to individual development projects and evaluate the incremental increase in emissions from a proposed source. The SJVAPCD does not have a threshold related to environmental justice considerations. In developing thresholds of significance for individual projects, the SJVAPCD considered the emission levels for which a project’s individual emissions would be cumulatively considerable. Additionally, the HRA methodology used in the analysis and the SJVAPCD’s thresholds evaluating health risk to sensitive receptors is appropriate for evaluating potential health risks to sensitive population subgroups, including children, the elderly, and those with higher rates of respiratory disease. The City relies on the SJVAPCD’s recommended methodology to evaluate cumulative impacts, which is to conclude that an impact considered to be significant on a project-specific basis would also cause a significant cumulative impact.
3 San Joaquin Valley Air Pollution Control District (SJVAPCD). 2006. Guidance for Air Dispersion Modeling.

Website: www.valleyair.org/busind/pto/Tox_Resources/Modeling%20Guidance.pdf (accessed November 2023). 4 California Office of Environmental Health Hazard Assessment (OEHHA). 2015. Air Toxics Hot Spots Program Guidance Manual for Preparation of Health Risk Assessments. March. Website:
https://oehha.ca.gov/air/air-toxics-hot-spots (accessed November 2023). 3/29/24 (P:\20231045.02 Huntsman\PRODUCTS\RTC\Admin\Huntsman_RTC_Memo-Draft_2.docx) 8 Comment 2-5: The census tract ranks in the 97th percentile for drinking water, which indicates that it ranks with the worst quality drinking water in the state. Poor communities areas are exposed to contaminants in their drinking water more often than people in other parts of the state3 .

The census tract also ranks in the 64th percentile for solid waste facility impacts, which can expose people to hazardous chemicals, release toxic gases into the air (even after these facilites are closed), and chemicals can leach into soil around the facility and pose a health risk to nearby populations4 .

Response 2-5: This comment states that the census tract where the project is located ranks in the 97th percentile for contaminated drinking water, and in the 64th percentile for solid waste facility impacts.

Although the census tract ranks in the 97th percentile for contaminated drinking water, and the 64th percentile for solid waste facility impacts, as described in Section 3.10, Hydrology and Water Quality, and Section 3.19, Utilities and Service Systems, of the IS/MND, the proposed project would not violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality, and would comply with federal, State, and local statutes and regulations related to solid waste. As such, the proposed project would not contribute to significant cumulative water quality or solid waste facility impacts.

Comment 2-6: Further, the project’s census tract is a diverse community including 43% Hispanic and 6% Asian- American residents, whom are especially vulnerable to the impacts of pollution. The community has a high rate of low educational attainment, meaning 56% of the census tract over age 25 has not attained a high school diploma, which is an indication that they may lack health insurance or access to medical care. The community has a high rate of poverty, meaning 39% of the households in the census tract have a total income before taxes that is less than the poverty level.

Income can affect health when people cannot afford healthy living and working conditions, nutritious food and necessary medical care 5 . Poor communities are often located in areas with high levels of pollution6
. Poverty can cause stress that weakens the immune system and causes people to become ill from pollution7
. Living in poverty is also an indication that residents may lack health insurance or access to medical care. Medical care is vital for this census tract as it ranks in the 73rd percentile for incidence of cardiovascular disease and 74th percentile for incidence of asthma.

Additionally, the project census tract (6019006300) and census tracts adjacent to the project site (6019006501 (east), 6107000401 (south), 6019006602 (west), and 6019006604 (west)) are identified as SB 535 Disadvantaged Communities8
. This indicates that cumulative negative impacts
of development and environmental impacts in the area are disproportionately impacting these communities. The MND does not discuss that the surrounding area is a disadvantaged community and does not utilize this information in its analysis. The MND has not considered the environmental impacts in relation to the SB 535 status of the project census tract and surrounding area. The negative environmental, health, and quality of life impacts of the warehousing and logistics industry in the area have become distinctly inequitable. The severity of environmental impacts particularly on these Disadvantaged Communities must be included for analysis as part of an EIR 3/29/24 (P:\20231045.02 Huntsman\PRODUCTS\RTC\Admin\Huntsman_RTC_Memo-Draft_2.docx) 9 Response 2-6: This comment states that this census tract is a diverse community with a high rate of low educational attainment and a high rate of poverty, which can affect health when people cannot afford healthy living and working conditions, nutritious food, and necessary medical care. This comment also states that poor communities are often located in areas with high levels of pollution and that poverty is also an indication that residents may lack health insurance or access to medical care. Further, this comment states that the project census tract and adjacent tracts are identified as SB 535 Disadvantaged Communities, so an EIR is needed to include an analysis of impacts on the disadvantaged communities.

See Response 2-4. Although the project site is designated as an SB 535 disadvantaged community and is considered a diverse community, there is no methodology to quantify the cumulative areawide or localized health risks within a community-wide area. The SJVAPCD’s recommended thresholds of significance apply to individual development projects and evaluate the incremental increase in emissions from a proposed source. These thresholds do not apply to cumulative conditions. Neither the State CEQA Guidelines, the SJVAPCD, or the City have established CEQA thresholds or methodology for evaluating project impacts to disadvantaged communities. For air quality impacts, the City relies on the SJVAPCD’s recommended methodology to evaluate cumulative impacts, which is to conclude that an impact considered to be significant on a project-specific basis would also cause a significant cumulative impact. As shown in Table 3.3.B and Table 3.3.C of the IS/MND, the proposed project would generate construction and operational emissions that are below the SJVAPCD’s thresholds, and as such, would not contribute to a significant cumulative impact related to any criteria pollutant for which the project region is non-attainment under an applicable federal or State ambient air quality standards.

Additionally, as discussed in Response 2-4, an HRA was prepared for the proposed project to evaluate the potential impact on sensitive receptors (including those that may be disadvantaged people) from construction and operation of the proposed project. As shown in Table 3.3.D and Table 3.3.E of the IS/MND, and based on the results of the HRA, construction and operation of the proposed project would not exceed SJVAPCD thresholds and would not expose nearby sensitive receptors to substantial pollutant concentrations.

Based on these results, the IS/MND properly determined that the proposed project would not result in significant air quality or health risk impacts that would contribute to cumulative air quality or health risk impacts in the City.

Comment 2-7: The State of California lists three approved compliance modeling softwares9 for nonresidential buildings: CBECC-Com, EnergyPro, and IES VE. CalEEMod is not listed as an approved software. The CalEEMod modeling does not comply with the 2022 Building Energy Efficiency Standards and under-reports the project’s significant Energy impacts and fuel consumption to the public and decision makers. Since the MND did not accurately or adequately model the energy impacts in compliance with Title 24, it cannot conclude the project will generate less than significant impacts and a finding of significance must be made. An EIR with modeling using one of the approved software types must be prepared and circulated for public review in order to adequately analyze the project’s significant environmental impacts. This is vital as the MND utilizes CalEEMod as a source in its methodology and analysis, which is clearly not an approved software. 3/29/24 (P:\20231045.02 Huntsman\PRODUCTS\RTC\Admin\Huntsman_RTC_Memo-Draft_2.docx) 10 Response 2-7: This comment claims that California’s Building Energy Code Compliance Software (CBECC) is the State’s only approved energy compliance modeling software for non-residential buildings, in compliance with Title 24, and that the California Emissions Estimator Model (CalEEMod) is not the approved software.

As described in the SJVAPCD’s Guidance for Assessing and Mitigating Air Quality Impacts (GAMAQI),5 when quantifying project emissions, the latest approved models by the SJVAPCD should always be used for air quality analysis. The latest approved model available is CalEEMod, which is a statewide land use emissions computer model designed to provide a uniform platform for government agencies, land use planners, and environmental professionals to quantify potential criteria pollutant and greenhouse gas (GHG) emissions associated with both construction and operations from a variety of land use projects. The model quantifies direct emissions from construction and operations (including vehicle use), as well as indirect emissions, such as GHG emissions from energy use, solid waste disposal, vegetation planting and/or removal, and water use.6 The commenter asserts the use of CalEEMod to estimate the project’s energy demand was inappropriate and that CBECC should have been used instead. The compliance modeling software that is referenced by the commenter is used to confirm the final design of a development project and complies with applicable energy efficiency regulations based on detailed information included in construction drawings. As such, the purpose of the CBECC model is to evaluate compliance with the 2022 Title 24 standards, not to evaluate potential energy impacts under CEQA.

The information needed to demonstrate compliance with Title 24 using the CBECC model is not available at this time and is not typically prepared until after a project has been approved/entitled. After approval and preparation of detailed building plans, the project would be required to demonstrate compliance with Title 24 using the CBECC model. As described in the CalEEMod User’s Guide, CalEEMod utilizes widely accepted methodologies for estimating emissions combined with default data that can be used when site-specific information is not available. Sources of these methodologies and default data include, but are not limited to, the EPA AP-42 emission factors, CARB vehicle emission models, and studies commissioned by California agencies such as the California Energy Commission and CalRecycle. The User’s Guide also states that CalEEMod calculates construction and operations emissions from land use development projects which can be used to support preparation of air quality and GHG analyses in CEQA documents. In addition, the User’s Guide states that the emissions inventory modules also contain default values for estimating utility consumption (e.g., water, electricity, natural gas) that may be useful for preparing hydrology and energy analyses in other sections of a CEQA document. Additionally, it should also be noted that the energy use factors included in the CalEEMod model, which was used to estimate energy for the project, are based on the CEC-sponsored California Commercial End Use Survey (CEUS) and Residential Appliance Saturation Survey (RASS) studies, which 5 San Joaquin Air Pollution Control District. 2015. Guidance for Assessing and Mitigating Air Quality Impacts (GAMAQI). March 19. Website: http://www.valleyair.org/transportation/GAMAQI.pdf (accessed March 2024). 6 Ibid.
3/29/24 (P:\20231045.02 Huntsman\PRODUCTS\RTC\Admin\Huntsman_RTC_Memo-Draft_2.docx) 11 provide a more conservative assumption based on actual use surveys and are the best available information for purposes of this assessment. As such, CalEEMod is appropriate for use in energy analyses. Further, as identified on page 3-37 of the IS/MND, the proposed project would comply with the latest CALGreen building measures and 2022 Title 24 Standards. Therefore, use of the CBECC model would not change the findings identified in the IS/MND.

Comment 2-8: The MND analyzes the potentially significant impacts from Greenhouse Gas Emissions in a qualitative manner pursuant to CEQA Guidelines Section 15064.4. However, the consistency analysis provided is erroneous and does not demonstrate a good-faith effort, based to the extent possible on scientific and factual data, to describe, calculate or estimate the amount of greenhouse gas emissions resulting from the project and its significance. The MND quantitatively concludes that the proposed project will have an annual operational emissions of 4,703.3 MT CO2e annually. The MND includes MM GHG-1 to require that “The project applicant shall incorporate the following specifications into construction plans details and specifications to document implementation and compliance with the following applicable Climate Action Plan (CAP) greenhouse gas (GHG) reduction measures for review by the City of Reedley Community Development Department,” within the City’s CAP to achieve a 34% reduction in emissions.

Table 3.8.B: Project Compliance with the City’s Applicable CAP GHG Reduction Checklist Measures provides erroneous and misleading consistency analysis of the proposed project with the reduction measures in order to conclude the project will have less than significant impacts. For example, compliance with item “Landscaping for Energy Efficiency: Plant shade trees on a buildings ’south side,” is not supported with meaningful evidence such as a landscape plan/planting plan to demonstrate the quantity of shade trees provided and/or their locations on the south sides of buildings. Additionally, compliance with item “Photovoltaic solar energy provides 20‐49% of power needs (annual average),” is not supported with any meaningful evidence, such as a solar plan to depict the placement of panels and calculations of annual energy generated by the panels that would serve the project.

The efficacy of the proposed mitigation measures and reduction of GHG impacts below the applicable thresholds via percentages provided in Table 3.8.B cannot be assured and the project’s GHG impact is therefore considered significant and unavoidable. An EIR must be prepared to include a finding of significance because there is no possible assurance that the project will comply with the proposed CAP items, and the MND has utilized the CAP screening tables to mislead the public and decision makers by erroneously concluding that a qualitative assessment of the project will reduce the project’s 4,703.3 MT CO2e annual emissions to less than significant levels. Mitigation of the project’s GHG impact to less than significant is not feasible, whether via the CAP tables or otherwise.

A finding of significance must be included as part of a project EIR.

Response 2-8: The City, as the lead agency for the environmental review of the proposed project, has the discretion to select and develop appropriate thresholds of significance to analyze a project's environmental impacts, or rely on thresholds developed by other agencies that it deems applies to a project. In addition, the State’s CEQA Guidelines leaves the determination of the significance of greenhouse gas (GHG) emissions up to the lead agency and authorizes the lead agency to consider thresholds of significance previously 3/29/24 (P:\20231045.02 Huntsman\PRODUCTS\RTC\Admin\Huntsman_RTC_Memo-Draft_2.docx) 12 adopted or recommended by other public agencies or recommended by experts, provided the decision of the lead agency to adopt such thresholds is supported by substantial evidence (State CEQA Guidelines Sections 15064.4(a) and 15064.7(c)). The State CEQA Guidelines emphasize the lead agency’s discretion to determine the appropriate methodologies and thresholds of significance consistent with the manner in which other impact areas are handled in CEQA.7
As discussed on pages 3-45 and 3-46 of the IS/MND, per the State CEQA Guidelines, Section 15183.5, if a project is consistent with an adopted qualified Greenhouse Gas Reduction Strategy that meets the specified standards, it can be presumed that a project would not have significant GHG emission impacts. The City’s Climate Action Plan (CAP)8 was adopted in 2015 to reduce local community GHG emissions, consistent with the State objectives set forth in Assembly Bill (AB) 32. The City’s CAP was updated in 2020 to identify tools to meet the City’s 2020 and future 2030 reduction goals. As detailed on page 3-46 of the IS/MND, the City’s CAP meets the requirements for a Qualified Greenhouse Gas Reduction Strategy and is designed to streamline environmental review of future development projects in the city, consistent with State CEQA Guidelines Section 15183.5. Therefore, the analysis conducted for the IS/MND evaluates the GHG emissions based on the proposed project’s consistency with the City’s CAP.

As stated on page 17 of the City’s CAP, the City must reduce citywide GHG emissions by 50 percent to meet the State mandated 2030 near-term emission reduction goal. As stated in the City’s CAP, to maintain citywide growth and the attain the City’s GHG reduction goal of reducing GHG emissions by 50 percent by 2030, the City is requiring that all new proposed projects meet a 20 percent reduction in GHG emissions. To ensure that future developments within City limits also achieve the City’s GHG reduction goals, the City has compiled a Greenhouse Gas Reduction Compliance Checklist to enable projects within City limits to “self-certify” that their project meets the required 20 percent reduction. As stated in the CAP, project applicants must demonstrate through completion of this checklist, how projects will comply with the 20 percent reduction. The CAP Reduction Compliance Checklist (Appendix A of the CAP) includes recommended GHG reduction measures and average reductions (in percentage). For example, as demonstrated in the City’s CAP Reduction Compliance Checklist (Appendix A of the CAP), implementing photovoltaic systems that provide 20-49 percent of power needs would result in an average reduction of 17 percent of a project’s GHG emissions. As stated above, the City’s CAP provided the substantial evidence demonstrating the appropriateness of the CAP methodology. Therefore, it is appropriate to rely on the City’s CAP for the GHG analysis.
7 California Natural Resources Agency. 2009. California Environmental Quality Act (CEQA) Guidelines Update. 8 City of Reedley. 2019. City of Reedley Climate Action Plan. Website: https://reedley.ca.gov/wpcontent/uploads/reedleyweb/2019/12/City-of-Reedley-Climate-Action-Plan.pdf (accessed November 2023).
3/29/24 (P:\20231045.02 Huntsman\PRODUCTS\RTC\Admin\Huntsman_RTC_Memo-Draft_2.docx) 13 Table 3.8.B in the IS/MND shows the GHG reduction measures from the CAP GHG Reduction Checklist that the proposed project would incorporate to meet the 20 percent reduction necessary to demonstrate consistency with the CAP. As demonstrated in Table 3.8.B, the proposed project’s consistency with many of the CAP GHG reduction measures would be determined by design decisions that are currently not evident from the conceptual plans evaluated for the environmental analysis in this report. Implementation of Mitigation Measure GHG-1 would require the proposed project to include the applicable measures, as identified in the CAP GHG Reduction Checklist. With implementation of Mitigation Measure GHG-1, the proposed project’s reduction from the CAP reduction measures would be 34.31 percent, which is higher than the required 20 percent reduction. Therefore, the proposed project would be consistent with the City’s CAP. The proposed project would not generate GHG emissions, either directly or indirectly, that may have a significant effect on the environment and impacts would be less than significant with mitigation incorporated.

As such, since the proposed project has demonstrated consistency with the CAP’s requirements, consistent with the State CEQA Guidelines, Section 15183.5, the proposed project would not have significant GHG emission impact and no further analysis is necessary.

The commenter does not demonstrate a fair argument, based on substantial evidence, for a contrary conclusion. (See CEQA Guidelines, § 15064, subd. (f)(5).) Comment 2-9: The MND does not include a consistency analysis with any land use plans, policies, or regulations adopted for the purpose of avoiding or mitigating an environmental effect, such as the General Plan. The MND is inadequate as an informational document and an EIR must be prepared with a consistency analysis with all General Plan policies, including the following:

1. Land Use Element Guiding Principle (a): Protect the agricultural economic base of the Reedley area by encouraging the preservation of the maximum feasible amount of productive and potentially productive agricultural land.

2. Land Use Element Guiding Principle (b): Plan for urban growth in a manner that minimizes impacts on agriculture and the consumption of agricultural land.

3. Land Use Element Guiding Principle (e): Seek a balanced and compatible land use pattern which accommodates projected population growth and encourages alternative transportation such as walking, bicycling or transit.

4. Land Use Element Guiding Principle (f): Provide transitions between various land uses and intensities using high quality design.

5. Land Use Element Guiding Principle (h): Development in the planning area shall occur in a fashion that protects and enhances air quality and water quality.

6. Land Use Element Guiding Principle (i): Public open space shall be made an integral part of new development in the planning area.
3/29/24 (P:\20231045.02 Huntsman\PRODUCTS\RTC\Admin\Huntsman_RTC_Memo-Draft_2.docx) 14

7. Goal LU 2.5B - Minimize leap-frogging, low density, automobile dependent development beyond the edge of service and employment areas, or the creation of peninsula development greater than ¼ mile from existing urban uses.

8. Policy LU 2.5.7: Require contiguous development within the SOI unless it can be demonstrated that the development of contiguous property is infeasible. An analysis of the fiscal impacts on public utilities including water, surface transportation, and service shall be required as part of the application to annex new territory into the City.

9. Policy LU 2.7.51: During the review of development applications for proposed new light industry, the City shall determine whether pretreatment of industrial wastes shall be required.

10. 10. Goal CIR 3.2B: Maintain a level of service (LOS) of “C” or better.

11. Policy CIR 3.2.7: Subdivisions shall be designed to maximize connectivity between subdivisions and surrounding development. Use of a grid pattern with reasonable street lengths to maximize the number of connections to surrounding collector street system is encouraged.

12. Policy CIR 3.2.8: A walled-in subdivision shall be discouraged unless noise measurements exceed the threshold for residential development adjacent to roadways.

Response 2-9: This comment states that the IS/MND does not provide a consistency analysis with applicable Reedley General Plan goals and policies related to land use planning for the purpose of maximizing urban connectivity and avoiding environmental impacts regarding agricultural land conversion, air quality, water quality, hazardous materials, transportation, and utilities.

As discussed in Section 3.2, Agriculture and Forestry Resources, of the IS/MND, the project site is classified as “Prime Farmland” by the California Department of Conservation. The General Plan does contain policies to manage growth into agricultural areas in a measured way so that active agricultural land would remain viable until the time this land is annexed into the City and developed for non-agricultural use; however, the General Plan identifies that buildout of the General Plan would result in significant and unavoidable impacts related to conversion of agricultural land. The project site is planned for light industrial development under the General Plan, and is mapped in Figure 6 of the Agricultural Resources section of the General Plan EIR as one of the locations with Important Farmland in the City’s Planning Area planned to be converted to non-agricultural uses through buildout of the General Plan.9 As such, development of the project would not be inconsistent with any of the General Plan’s agricultural conservation goals or policies. 9 City of Reedley. 2013. Reedley General Plan 2030. Figure 6 – Important Farmlands Map. Website:
https://reedley.ca.gov/wp-content/uploads/reedleyweb/2019/12/Draft-Program-EIR-City-of-ReedleyGeneral-Plan-1-8-2013.pdf (accessed March 2024). 3/29/24 (P:\20231045.02 Huntsman\PRODUCTS\RTC\Admin\Huntsman_RTC_Memo-Draft_2.docx) 15 Also, as discussed throughout the IS/MND, the project site has been designated for Light Industrial use in the City’s General Plan. As such, development of the project site with the proposed light industrial park would be consistent with planned land use patterns for the City of Reedley, and population growth associated with project development would be within rates assumed for Light Industrial uses by the General Plan. Further, as described in Sections 3.3, Air Quality, 3.9, Hazards and Hazardous Materials, and 3.10, Hydrology and Water Quality, of the IS/MND, the proposed project would not result in significant impacts related to air quality, hazardous substances or water quality, and would not be inconsistent with any policies meant to reduce impacts related to air quality, hazardous substances, and water quality.

Additionally, as discussed in Section 3.17, Transportation, of the IS/MND, the addition of project traffic would not result in any roadways within the project’s circulation network operating at unsatisfactory LOS levels. Further, the project would result in less than significant VMT impacts. Also, the proposed project would not interfere with planning and construction of transit, bicycle and pedestrian facilities in the vicinity. As such, the project would not be inconsistent with the City’s transportation policies.

The proposed project would be constructed in compliance with applicable design requirements established by the City. The project site has been identified by the General Plan as being part of the City’s proposed SOI, and as such, potential impacts on the City’s public utilities including water, surface transportation, and other services as a result of development under the General Plan have been considered in the General Plan EIR. The project site is located adjacent to Reedley city limits, and the land use directly west of the project site consists of light industrial; as such, development of the project site would not result in discordant or disjointed development within or near the City. Finally, the proposed project does not consists of a residential subdivision; as such, policies meant for subdivisions are not applicable to the project.

Therefore, this comment is noted, but does not raise any significant environmental issues related to the project or the analysis contained in the IS/MND. No further response is required.

Comment 2-10: Table 9‐C: Recommended Improvements for Intersections and Fair Share within Appendix D: Traffic Impact Study concludes the following intersection outside the sole jurisdiction of the lead agency requires improvements to address the peak hour deficiencies per the applicable thresholds of significance. Table 9‐C also provides a fair-share calculation for improvements that will allegedly mitigate significant and unavoidable impacts to the intersections to less than significant levels.

1. #3: Englehart Avenue/Dinuba Avenue (County of Fresno) It must be noted that impacts to the intersection listed above are under jurisdiction of County of Fresno. Any improvements planned/constructed or in-lieu fees/fair share fees paid for County of Fresno facilities are beyond the control/scope of the lead agency. An assessment of fees is appropriate when linked to a specific mitigation program. (Anderson First Coalition v. City of 3/29/24 (P:\20231045.02 Huntsman\PRODUCTS\RTC\Admin\Huntsman_RTC_Memo-Draft_2.docx) 16 Anderson (2005) 130 Cal.App.4th 1173, Save our Peninsula Comm. v. Monterey County Bd. Of Supers. (2001) 87 Cal.App.4th 99, 141.) Payment of fees is not sufficient where there is no evidence mitigation will actually result. (Gray v. County of Madera (2008) 167 Cal.App.4th 1099,1122.) The assessment of fees here is not adequate as there is no evidence mitigation will actually result. The improvement listed is not part of an existing DIF/TUMF program and therefore are not planned to occur at all or by any certain date, whether by Reedley or County of Fresno. Any improvements recommended or fees paid to mitigate impacts for County of Fresno facilities are beyond the control of the lead agency and evidence that these improvements will be completed or approved by County of Fresno has not been provided. An EIR must be prepared to include the LOS analysis as cumulatively considerable significant impact as the project conflicts with Transportation Impact Threshold A and Land Use and Planning Impact Threshold B because it is not consistent with the following General Plan Goal:

1. Goal CIR 3.2B: Maintain a level of service (LOS) of “C” or better.

Response 2-10: This comment discusses the County of Fresno (County) General Plan Goal CIR 3.2B regarding Level of Service (LOS) standards. This comment also states that since the intersection of Englehart Avenue/Dinuba Avenue is under the jurisdiction of the County and not under City’s jurisdiction, fair share payment may not be an adequate mitigation measure for potential LOS impacts.

It should be noted that LOS is no longer a CEQA transportation metric. As such, any LOS related operational deficiency should not be the determinant of a CEQA Transportation Impact. Additionally, typically projects are conditioned by lead agencies to implement all onsite and project frontage circulation improvements, as determined through the preparation of traffic studies. However, there are a host of criteria reviewed to determine whether a project could be conditioned to directly implement circulation improvements at off-site locations. Following is a brief description of each of these criteria:

1. Deficiency at Analysis Location: In case a study intersection/roadway segment operates at an acceptable LOS, and the project contributes to deterioration of LOS to an unacceptable level, the project may be required to implement improvements to restore LOS to an acceptable level. However, if that study intersection/roadway segment is forecasted to operate at an unacceptable LOS and the project contributes to the forecasted deficiency, the project is deemed to have a cumulative deficiency at the respective location. In such cases, a project is typically required to pay its fair share.

2. Fair share/Essential Nexus/Rough Proportionality: As per the Nollan v. California Coastal Commission, 483 U.S. 825 (1987), and Dolan v. City of Tigard, 512 U.S. 374 (1994), “..A governmental exaction has to be substantially related to a legitimate government interest and there must be a nexus between the exaction and that interest”, and if a nexus exists, then it must be determined whether or not the degree of exactions required bears the required relationship to the projected impact. As such, to establish this nexus requirement, a project’s fair share requirements are identified at a study location. In case the fair share percentage is identified to be substantial, a project could potentially be required to directly implement the improvements upfront. While the 3/29/24 (P:\20231045.02 Huntsman\PRODUCTS\RTC\Admin\Huntsman_RTC_Memo-Draft_2.docx) 17 criteria that defines whether the fair share percentage is substantial varies between jurisdictions, typically, a fair share percentage of 30 percent or greater is considered substantial.

3. Improvements Already Conditioned Through Other Approved Development Projects:

In case some or all of the improvements identified in the traffic study at off-site locations are already identified and conditioned through other approved development projects, the subject project would only be required to contribute towards its fair share requirements that will be reimbursed towards the other project/s. Additionally, these other projects are required to implement these improvements because they have a substantial contribution towards adding new trips at those locations compared to the proposed project.

4. Improvements Already Covered Through Existing Fee Program: In case some or all of the improvements identified in the traffic study at any off-site location are covered through an existing fee program, payment into these fee programs is anticipated to address the implementation of the identified improvements. Therefore, in such cases, the project would only be required to contribute to these fee programs as applicable.

5. Feasibility of Improvements: At certain locations, where a traffic study identifies forecasted deficiency without or with the project, improvements may not be feasible due to right-of-way constraints (area already built out or a roadway is already constructed per respective General Plan standards).

The above-described criteria were generally applied to determine the appropriate mechanism to address project related operational deficiencies at all study analysis intersection and roadway segments. Following is an explanation for the intersection of Englehart Avenue/Dinuba Avenue regarding implementation of proposed improvements:

1. Deficiency at Analysis Location: As shown in the Traffic Impact Study (TIS) (included as Appendix D of the IS/MND), this intersection is forecast to operate at a deficient LOS under Cumulative without project conditions. As such, this intersection requires future improvements even without the addition of project traffic, and the project adds to the forecasted deficiency. As such, this intersection meets this criterion for a fair share contribution.

2. Fair share/Essential Nexus/Rough Proportionality: As shown in the TIS, the fair share percentage is to be 18.75 percent for this location. As such, the fair share percentage is not substantial enough for the project being directly responsible for implementation of this improvement. As such, this intersection meets this criterion for a fair share contribution.

3. Improvements Already Conditioned Through Other Approved Development Projects:

No other project is known to be directly responsible for the recommended improvements at this location. However, given the location of this intersection in relation to the proposed project, other major projects in the vicinity of this location may 3/29/24 (P:\20231045.02 Huntsman\PRODUCTS\RTC\Admin\Huntsman_RTC_Memo-Draft_2.docx) 18 be estimated to contribute significantly more traffic at this location. As such, this intersection meets this criterion for a fair share contribution.

4. Improvements Already Covered Through Existing Fee Program: The improvements identified in the traffic study at this location are not covered through an existing fee program. As such, this intersection meets this criterion for a fair share contribution.

5. Feasibility of Improvements: The recommended improvement at this location is feasible. As such, this intersection meets this criterion for a fair share contribution.

As described above, since this improvement meets all of the above criteria for fair share contribution, the project will be contributing its fair share for the recommended improvement at this location. Additionally, the Project Applicant will also be coordinating with the County staff to determine the appropriate methodology and timeline for implementation of the recommended improvements. As such, this comment is noted but does not raise any significant environmental issues related to the proposed project or the analysis contained in the IS/MND. No further response is required.

Comment 2-11: Additionally, the MND has not provided any information or analysis regarding the required annexation application to LAFCo. The MND states that, “After approval of annexation of the project site into the city of Reedley, the proposed project would be consistent with the City’s land use plans,” resulting in less than significant impacts. The MND relies upon approval of the annexation itself to demonstrate compliance, which circumvents the required analysis and does not provide any meaningful evidence to support the conclusion that the project will have less than significant impacts. Notably, the project site is within the City’s General Plan Sphere of Influence (SOI) but the full extent of the GP SOI has not been approved by LAFCo, including the project site.

The City’s 2020 Municipal Services Review10 (MSR) did not include analysis of the proposed project site, meaning that it is unknown if the City and the associated service providers can accommodate the growth proposed by the project. The requirement for service reviews arises from the identified need for a more coordinated and efficient public service structure to support California’s anticipated growth. The service review provides LAFCo with a tool to study existing and future public service conditions comprehensively and to evaluate organizational options for accommodating growth, preventing urban sprawl, and ensuring that critical services are provided efficiently. The MND cannot conclude that the proposed project is consistent with all land use plans, policies, or regulations adopted for the purpose of avoiding or mitigating an environmental effect, including LAFCo regulations, and/or thresholds A - E within the Utilities and Service Systems section, until and unless it provides a MSR document for review and analysis by the public and decision makers.

Additionally, since approval of the MSR lies with LAFCo and not the lead agency, an EIR cannot provide reasonable assurance that the MSR is adequate or will be approved and therefore the impact will remain significant and unavoidable necessitating a finding of significance in an EIR.

Response 2-11: The General Plan is the main environmental document guiding land use development in the City of Reedley. As shown in Figure 3 of the General Plan EIR, the project site is within the General Plan’s Study Area and within the City’s expanded Sphere of Influence (SOI). The City of Reedley General Plan identifies that the project site is planned for light industrial use (refer to Figure 4 of the General Plan EIR). Therefore, the light 3/29/24 (P:\20231045.02 Huntsman\PRODUCTS\RTC\Admin\Huntsman_RTC_Memo-Draft_2.docx) 19 industrial park that is being proposed in the project site is consistent with the City’s land use plans. The project’ consistency with the General Plan is not dependent on Fresno Local Agency Formation Commission (LAFCo) approval of annexing the site into the City. However, for development to occur at the project site, the City must first fulfill the following requirements: 1) submit a Sphere of Influence Application to Fresno LAFCo to update the City’s SOI to be consistent with the expanded SOI proposed and analyzed in the General Plan EIR, and 2) submit an Annexation Application with Fresno LAFCo to annex the project site into Reedley, as outlined in page 1-4 of the IS/MND.

Prior to, or in conjunction with an agency’s SOI update, LAFCo is required to conduct a Municipal Service Review (MSR) for the petitioning agency, aided by that agency’s input. The City would need to coordinate with Fresno LAFCo for the preparation of a MSR for the City’s expanded SOI, and would need to meet applicable requirements of the Fresno LAFCo’s SOI update process. After the SOI update is approved by LAFCo, the City would be required to coordinate with Fresno LAFCo to meet requirements of the LAFCo annexation process. If the project is approved prior to approval of the SOI update and annexation of the site into Reedley, issuance of building permits would still be subject to annexation of the project site into the City.

Additionally, as described in Section 3.15, Public Services, of the IS/MND, the City has identified that planned growth under the General Plan would increase demand for municipal services. The City’s General Plan EIR has already identified and covered potential impacts to municipal services resulting from buildout of the approved General Plan, including impacts resulting from development of planned light industrial uses in the project site. Therefore, the proposed project would not result in new impacts to municipal services that have not been evaluated in a previous environmental review document, impacts related to inconsistency with a land use plan, or any other new significant environmental impacts, and a less than significant impact would occur.

In response to this comment, the text on page 3-61 of the IS/MND has been revised as follows to clarify on the project’s consistency with the City’s General Plan:

The project site is currently zoned in Fresno County’s Exclusive Agriculture (AE-20) District and is designated Agriculture in the Fresno County General Plan. However, the project site is planned for light industrial development under the Reedley General Plan, and the proposed project would be consistent with the planned land use designation for the project site. The project would require annexation of the project site into the City of Reedley, after which the site would be pre-zoned to the Light Industrial (ML) District, and the General Plan land use designation would be changed to Light Industrial. An annexation application would be required to be submitted to the Fresno LAFCo. The Project Applicant would also be required to pay required processing fees for the annexation process. After approval of annexation of the project site into the city of Reedley, the proposed project would be developed with a light industrial use, consistent with the City’s land use plans. Therefore, the proposed project would not conflict with any land use plan, policy or regulation 3/29/24 (P:\20231045.02 Huntsman\PRODUCTS\RTC\Admin\Huntsman_RTC_Memo-Draft_2.docx) 20 adopted for the purpose of avoiding or mitigating an environmental effect, and the impact would be less than significant.

Comment 2-12: Table 9‐C: Recommended Improvements for Intersections and Fair Share within Appendix D: Traffic Impact Study concludes the following intersection outside the sole jurisdiction of the lead agency requires improvements to address the peak hour deficiencies per the applicable thresholds of significance. Table 9‐C also provides a fair-share calculation for improvements that will allegedly mitigate significant and unavoidable impacts to the intersections to less than significant levels.

1. #3: Englehart Avenue/Dinuba Avenue (County of Fresno).

It must be noted that impacts to the intersection listed above are under jurisdiction of County of Fresno. Any improvements planned/constructed or in-lieu fees/fair share fees paid for County of Fresno facilities are beyond the control/scope of the lead agency. An assessment of fees is appropriate when linked to a specific mitigation program. (Anderson First Coalition v. City of Anderson (2005) 130 Cal.App.4th 1173, Save our Peninsula Comm. v. Monterey County Bd. Of Supers. (2001) 87 Cal.App.4th 99, 141.) Payment of fees is not sufficient where there is no evidence mitigation will actually result. (Gray v. County of Madera (2008) 167 Cal.App.4th 1099,1122.) The assessment of fees here is not adequate as there is no evidence mitigation will actually result. The improvement listed is not part of an existing DIF/TUMF program and therefore are not planned to occur at all or by any certain date, whether by Reedley or County of Fresno. Any improvements recommended or fees paid to mitigate impacts for County of Fresno facilities are beyond the control of the lead agency and evidence that these improvements will be completed or approved by County of Fresno has not been provided. An EIR must be prepared to include the LOS analysis as cumulatively considerable significant impact as the project conflicts with Transportation Impact Threshold A and Land Use and Planning Impact Threshold B because it is not consistent with the following General Plan Goal:

1. Goal CIR 3.2B: Maintain a level of service (LOS) of “C” or better.

Response 2-12: Please refer to Response 2-10. An evaluation of the appropriate mechanism to address project related operational deficiencies for the intersection of Englehart Avenue/Dinuba Avenue determined that payment of fair share contributions towards improvements listed in the TIA for this intersection would be appropriate mitigating action to address potential project LOS impacts at this intersection. Further, the Project Applicant would also be coordinating with Fresno County staff to determine the appropriate methodology and timeline for implementation of the recommended improvements. As such, the payment of fair share contributions would be an adequate mitigation measure to address potential LOS impacts at the intersection of Englehart Avenue/Dinuba Avenue. This comment is noted but does not raise any significant environmental issues related to the proposed project or the analysis contained in the IS/MND. No further response is required.

Comment 2-13: Further, the MND has underreported the quantity VMT generated by the proposed project operations. The operational nature of industrial/warehouse uses involves high rates of truck/trailer/delivery van VMT due to traveling from large import hubs to regional distribution 3/29/24 (P:\20231045.02 Huntsman\PRODUCTS\RTC\Admin\Huntsman_RTC_Memo-Draft_2.docx) 21 centers to smaller industrial parks and then to their final delivery destinations. Once employees arrive at work at the proposed project, they will conduct their jobs by driving delivery vans across the region as part of the daily operations as a distribution facility, which will drastically increase project-generated VMT. The project’s truck/trailer and delivery van activity is unable to utilize public transit or active transportation and it is misleading to the public and decision makers to exclude this activity from VMT analysis. The project’s total operational VMT generated is not consistent with the screening threshold and legislative intent of SB 743 to reduce greenhouse gas emissions by reducing VMT. An EIR must be prepared to reflect a quantified VMT analysis that includes all truck/trailer and delivery van activity.

Response 2-13: As summarized in the TIS (Appendix D of the IS/MND), Fresno Council of Governments’ (Fresno COG) activity-based model (ABM) was used to estimate the project VMT and VMT metric. ABM is a tour-based model which captures travel behavior of the region comprehensively. As such, the project employee VMT value included VMT from all employee tours and sub-tours; this is comprised of employee commute tours, project related delivery tours within the region, and any other tours related to the project. Also, project VMT and VMT metric values in the TIS were estimated consistent with the City’s as well as Fresno COG’s adopted methodology/guidelines for preparation of VMT analysis.

These guidelines provide substantial evidence demonstrating the appropriateness of the VMT analysis methodology, consistent with the intended goals for SB 743. Therefore, preparation of an EIR is not required.

Comment 2-14: The MND has not adequately analyzed the project’s potential to substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses; or the project’s potential to result in inadequate emergency access. The MND has not provided any exhibits depicting the available truck/trailer turning radius at the intersection of the project driveways to determine if there is enough space available to accommodate heavy truck maneuvering. Further, there are no exhibits providing on-site analysis regarding available space on the property to accommodate heavy truck maneuvering. The MND states that, “Along the project frontage, currently there is no dedicated on‐street parking provision;” however, this does not equate to an on-street parking prohibition, meaning that street parking could be in use at any time and has not been analyzed in the MND.

The MND also states that, “the project design features would be required to comply with standards set by the City’s General Plan and City Engineer. In addition, the proposed project would also be required to submit plans to the RFD for review and approval prior to the issuance of building permits to ensure there are no substantial hazards associated with the project design.” The MND provides a similar statement regarding emergency access in stating that, “the proposed project’s site plan would be subject to review and approval by the RFD to ensure the project includes adequate emergency access.” This does not comply with CEQA’s requirements for adequate informational documents and meaningful disclosure (CEQA § 15121 and 21003(b)). Deferring this environmental analysis required by CEQA to the construction permitting phase is improper mitigation and does not comply with CEQA’s requirement for meaningful disclosure and adequate informational documents.

An EIR must be prepared to include the City/RFD determination/review of the project and the 3/29/24 (P:\20231045.02 Huntsman\PRODUCTS\RTC\Admin\Huntsman_RTC_Memo-Draft_2.docx) 22 complete Site Plan for review, analysis, and comment by the public and decision makers in order to provide an adequate and accurate environmental analysis.

Response 2-14: This comment claims that the IS/MND has not adequately analyzed the project’s potential to substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses, or the project’s potential to result in inadequate emergency access.

The TIS, included as Appendix D of the IS/MND, includes a Driveway Access Analysis on page 8-1 that shows the available turn‐pocket storage lengths and summarizes the 95th percentile back‐of‐queue lengths at the project driveways under existing, near‐term, and cumulative without project and plus project conditions. This analysis indicates that the project would result in nominal queues at project driveways, and would not create blockage for through traffic along Huntsman Avenue.

As discussed in page 3-86 of the IS/MND, the proposed project would not include any sharp curves or other roadway design elements that would create dangerous conditions. As shown in Figure 1-3 of the IS/MND, all internal roadways within the project would have a minimum right-of-way width of 42 feet. These internal roadways are perpendicularly connected to each other, avoiding any sharp curves, hazardous geometric feature, or any requirement for sharp maneuvers. Further, entrances to internal parking areas would occur through 28 and 34-feet-wide driveways, which would be sufficient to accommodate the circulation of trucks and passenger vehicles that would be present on the project site during hours of operation.

Additionally, as shown on the site plan, the project would include exclusive truck maneuvering spaces, like docking and parking areas, on the southern portion of the project site, near the project driveways along East Huntsman Avenue, to facilitate truck circulation in and out of the site, and reduce conflicts with passenger vehicles circulating on other office and warehouse areas within the project site. Additionally, as shown on the site plan, within the project site, there are multiple areas for vehicles (both cars and trucks) turning or backing up to avoid any conflicting movements, if required. All these measurements and design features shown on the site plan demonstrate that the project’s design does not create any hazardous conditions.

The project site plan has undergone preliminary review by the City. Additionally, as discussed in page 3-86 of the IS/MND, final project plans would be required to pass the review and be approved by both the City Engineer and the Reedley Fire Department (RFD), meaning that design of the project’s internal circulation system would be required to meet both the City’s and the RFD’s design specifications for road widths and turning radiuses to accommodate truck and fire department service vehicle access and circulation in the project site prior to issuance of building permits.

Additionally, the City of Reedley requires the issuance of a dedicated on‐street parking provision to allow parking on public streets as a way to regulate on-street parking.

Therefore, vehicles would not be allowed to park along Huntsman Avenue, and as such, this would not result in hazardous conditions along Huntsman Avenue 3/29/24 (P:\20231045.02 Huntsman\PRODUCTS\RTC\Admin\Huntsman_RTC_Memo-Draft_2.docx) 23 For the reasons described above, this comment does not identify any new significant environmental issues or impacts that were not already addressed in the IS/MND. No further response is required
Comment 2-15: The MND has not provided any information or analysis regarding the required annexation application to LAFCo. The MND concludes that because the proposed land use is consistent with the General Plan land use designation, it is therefore accounted for in utilities and service systems plans such as the Urban Water Master Plan, resulting in less than significant impacts. Notably, the project site is within the City’s General Plan Sphere of Influence (SOI) but the full extent of the GP SOI has not been approved by LAFCo, including the project site. The City’s 2020 Municipal Services Review11 (MSR) did not include analysis of the proposed project site, meaning that it is unknown if the City and the associated service providers can accommodate the growth proposed by the project. The requirement for service reviews arises from the identified need for a more coordinated and efficient public service structure to support California’s anticipated growth.

The service review provides LAFCo with a tool to study existing and future public service conditions comprehensively and to evaluate organizational options for accommodating growth, preventing urban sprawl, and ensuring that critical services are provided efficiently. The MND cannot conclude that the proposed project is consistent with all land use plans, policies, or regulations adopted for the purpose of avoiding or mitigating an environmental effect, including LAFCo regulations, and/or thresholds A - E within the Utilities and Service Systems section, until and unless it provides a MSR document for review and analysis by the public and decision makers. Additionally, since approval of the MSR lies with LAFCo and not the lead agency, an EIR cannot provide reasonable assurance that the MSR is adequate or will be approved and therefore the impact will remain significant and unavoidable necessitating a finding of significance in an EIR.

Response 2-15: Refer to Response 2-11. As previously noted, the Reedley General Plan is the primary planning document guiding development in the City. As such, a project’s consistency with the City’s land use plans is dependent on consistency with the General Plan, and is not dependent on Fresno LAFCo approval of an SOI update or annexation application. The proposed project would consist of a light industrial park, which would be consistent with the planned light industrial use designated to the project site in the General Plan. The City’s General Plan EIR has already identified and covered potential impacts to municipal services resulting from buildout of the approved General Plan, including impacts resulting from development of planned light industrial uses in the project site. Therefore, the proposed project would not result in new impacts to municipal services that have not been evaluated in a previous environmental review document. Additionally, the City of Reedley would be required to fulfill and obtain Fresno LAFCo approval for updating the City’s SOI and annexing the project site into the City prior to issuance of building permits for the project. Therefore, the proposed project would not result in new impacts to municipal services that have not been evaluated in a previous environmental review document, impacts related to inconsistency with a land use plan, or any other new significant environmental impacts, and a less than significant impact would occur.

In response to this comment, the text on page 3-61 of the IS/MND has been revised as follows to clarify on the project’s consistency with the City’s General Plan:
3/29/24 (P:\20231045.02 Huntsman\PRODUCTS\RTC\Admin\Huntsman_RTC_Memo-Draft_2.docx) 24 The project site is currently zoned in Fresno County’s Exclusive Agriculture (AE-20) District and is designated Agriculture in the Fresno County General Plan. However, the project site is planned for light industrial development under the Reedley General Plan, and the proposed project would be consistent with the planned land use designation for the project site. The project would require annexation of the project site into the City of Reedley, after which the site would be pre-zoned to the Light Industrial (ML) District, and the General Plan land use designation would be changed to Light Industrial. An annexation application would be required to be submitted to the Fresno LAFCo. The Project Applicant would also be required to pay required processing fees for the annexation process. After approval of annexation of the project site into the city of Reedley, the proposed project would be developed with a light industrial use, consistent with the City’s land use plans. Therefore, the proposed project would not conflict with any land use plan, policy or regulation adopted for the purpose of avoiding or mitigating an environmental effect, and the impact would be less than significant.

Comment 2-16: An EIR must be prepared to include a cumulative analysis discussion here to demonstrate the impact of the proposed project in a cumulative setting. The MND does not discuss or analyze the project’s compliance with the General Plan’s Land Use Buildout Scenario. Further, a MSR is required to be included as part of the environmental analysis to determine if the City and the associated service providers can accommodate the growth proposed by the project. An EIR must be prepared to include this information for analysis and also include a cumulative development analysis of projects approved since General Plan adoption and projects “in the pipeline” to determine if the proposed project exceeds the General Plan growth estimates.

Response 2-16: Refer to Response 2-11 and Response 2-15. The City of Reedley General Plan identifies that the project site is planned for light industrial use (refer to Figure 4 of the General Plan EIR). Therefore, development of the project site with the proposed light industrial park would be consistent with the General Plan’s vision for buildout of the City.

Additionally, as described in Section 3.15, Public Services, of the IS/MND, the City has identified that planned growth under the General Plan would increase demand for municipal services. The City’s General Plan EIR has already identified and covered potential impacts to municipal services resulting from buildout of the approved General Plan, including impacts resulting from development of planned light industrial uses in the project site. Therefore, the population growth associated with the proposed project would not result in a new impact to municipal services that has not been evaluated in a previous environmental review document.

Furthermore, as previously discussed, the preparation of an MSR is a process that LAFCo must undergo prior to or in conjunction with a petitioning agency’s SOI update. As such, the City would need to coordinate with Fresno LAFCo for the preparation of a MSR for the City’s expanded SOI, and would need to meet applicable requirements of the Fresno LAFCo’s SOI update process. After the SOI update is approved by LAFCo, the City would be required to coordinate with Fresno LAFCo to meet requirements of the LAFCo annexation process.

However, as discussed above, the project is consistent with the General Plan, and impacts to 3/29/24 (P:\20231045.02 Huntsman\PRODUCTS\RTC\Admin\Huntsman_RTC_Memo-Draft_2.docx) 25 municipal services from the project have already been addressed in the General Plan EIR. As such, the MSR is not required to assess the impacts to municipal services resulting from the proposed project. The preparation of an EIR would not be triggered, as impacts to municipal services resulting from development of the proposed project are covered under previous analysis within the General Plan EIR. Further, as described in the IS/MND, the project would not result in significant impacts that would contribute to cumulative impacts with incorporation of Mitigation Measures AIR-1, BIO-1 through BIO-9, CUL-1, CUL-2, GEO-1, GHG-1, NOI-1 and NOI-2. As such, this comment is noted but is incorrect in stating that the IS/MND does not discuss the project’s compliance with the General Plan or include sufficient analysis of the project’s potential to result in cumulative impacts. No further response is required.

Comment 2-17: For the foregoing reasons, GSEJA believes the MND is flawed and an EIR must be prepared for the proposed project and circulated for public review. Golden State Environmental Justice Alliance requests to be added to the public interest list regarding any subsequent environmental documents, public notices, public hearings, and notices of determination for this project. Send all communications to Golden State Environmental Justice Alliance P.O. Box 79222 Corona, CA 92877.

Response 2-17: This comment provides a conclusion to the arguments raised in the comment letter, states the commenter’s opinion that the analysis in the IS/MND is inadequate, and that an EIR needs to be prepared and circulated for public review. This comment also requests that Golden State Environmental Justice Alliance be placed on the public interest list to receive updates on the proposed project. This comment does not provide specific comments on the adequacy of the analysis included in the IS/MND. No further response is necessary.

Comment 2-18: Attachment #1: Letter from SWAPE dated February 21, 2024, Comments of the East Huntsman Avenue Industrial Park Project (SCH No. 202410923).

Response 2-18: This comment is an attachment to Comment Letter 2 that includes supporting documentation to the points discussed in Letter 2 and addressed in Responses 2- 1 through 2-17 above. As such, this comment is noted, but has already been discussed and addressed in Responses 2-1 through 2-17 above. No further response is required.

LETTER 3
Golden State Environmental Justice Alliance
Pete Sheehan
March 4, 2024
Comment 3-1: CalEnviroScreen is a mapping tool that helps identify California communities that are most affected by many sources of pollution, and where people are often especially vulnerable to pollution’s effects. CalEnviroScreen uses environmental, health, and socioeconomic information to produce scores for every census tract in the state. The scores are mapped so that different communities can be compared. An area with a high score is one that experiences a much higher pollution burden than areas with low scores. CalEnviroScreen ranks communities based on data that 3/29/24 (P:\20231045.02 Huntsman\PRODUCTS\RTC\Admin\Huntsman_RTC_Memo-Draft_2.docx) 26 are available from state and federal government sources. CalEnviroScreen is updated and maintained by The Office of Environmental Health Hazard Assessment, on behalf of the California Environmental Protection Agency.

Response 3-1: This comment provides a description of CalEPA’s CalEnviroScreen tool, which identifies California communities by census tract that are disproportionately burdened by, and vulnerable to, multiple sources of pollution. This comment is noted, but does not address the adequacy or completeness of the IS/MND, raise environmental issues, or request the incorporation of additional information relevant to environmental issues. No further response is required.

Comment 3-2: The above listed project sits in census tract 6019006300. Overall, when compared to other census tracts, the project site census tract is in the 64th percentile regarding pollution. As far as pollution burden is concerned, this census tract is in the 81st percentile. In terms of Ozone, this census tract is in the 91st percentile, Particulate Matter 2.5 94th percentile, Diesel Particulate Matter 13th percentile, Toxic Releases 46th percentile and Traffic 4th percentile.

Response 3-2: This comment claims that the census tract where the project is located has an overall CalEnviroScreen score in the 64th percentile, and has the following rankings in the following CalEnviroScreen Pollution Burden indicators: 81st percentile in pollution burden, 91st percentile in ozone concentration, 94th percentile in Particulate Matter 2.5 concentration, 13th percentile in Diesel Particulate Matter emission, 46th percentile in Toxic Releases, and 4th percentile in Traffic density. This comment is noted, and a more detailed response concerning the project census tract’s rankings for the CalEnviroScreen Pollution Burden indicators outlined above is provided in Response 3-3. This comment does not raise any significant environmental issues related to the proposed project or the analysis contained in the IS/MND. No further response is required.

Comment 3-3: Consider the above referenced information when making this important decision.

Realize that you and the citizens of this area face some of the WORST POLLUTION in the entire state of California.

It is the responsibility of the City’s elected and appointed officials to make environmentally responsible development decisions. Based on the CalEnviroScreen data, this is more than sufficient evidence of the further air quality impacts that the citizenry of Reedley and its surrounding area will continue to encounter with further development of another warehouse/distribution center. We are not against development, as we believe it is necessary for further economic growth in our current society. Development needs to be conducted with the highest of expectations to ensure the local population does not suffer further air quality burdens.

We stand by our comments and believe the MND is flawed and full Environmental Impact report should be drafted and circulated for public review.

Response 3-3: This comment requests that the CalEnviroScreen rankings for the project census tract, provided in Comment 3-2, be considered when reviewing the project for 3/29/24 (P:\20231045.02 Huntsman\PRODUCTS\RTC\Admin\Huntsman_RTC_Memo-Draft_2.docx) 27 approval. This comment also claims that the community within the project census tract (6019006300) is subject to some of the worst pollution in the State.

See Response 2-4 and Response 2-6. As previously discussed, there is no methodology to quantify the cumulative areawide or localized health risks within a community-wide area.

The SJVAPCD’s recommended thresholds of significance apply to individual development projects and evaluate the incremental increase in emissions from a proposed source. In developing thresholds of significance for individual projects, the SJVAPCD considered the emission levels for which a project’s individual emissions would be cumulatively considerable. The City relies on the SJVAPCD’s recommended methodology to evaluate cumulative impacts, which is to conclude that an impact considered to be significant on a project-specific basis would also cause a significant cumulative impact.

As shown in Table 3.3.B and Table 3.3.C of the IS/MND, the proposed project would generate construction and operational emissions that are below the SJVAPCD’s thresholds, and as such, would not contribute to a significant cumulative impact related to any criteria pollutant for which the project region is non-attainment under an applicable federal or State ambient air quality standards. Additionally, as shown in Table 3.3.D and Table 3.3.E of the IS/MND, and based on the results of the HRA conducted for the proposed project, construction and operation of the proposed project would not exceed SJVAPCD thresholds and would not expose nearby sensitive receptors to substantial pollutant concentrations.

Therefore, the IS/MND properly determined that the proposed project would not result in significant impacts related to air quality, and the commenter has not presented evidence to the contrary.

C. TEXT CHANGES TO THE IS/MND
In response to the comments included above, this memorandum provides minor revisions to the IS/MND that are being made to clarify, correct, or amplify materials in the IS/MND. The text revisions identified below do not result in new information, a greater number of impacts, or impacts of a greater severity than those set forth in the IS/MND.

Double-underlined text represents language that has been added to the IS/MND, and text with strikethrough represents language that has been deleted from the IS/MND.

Section 3.11, Land Use and Planning
Impact discussion 3.11.1.b, on page 3-61 of the IS/MND, is amended as follows:

The project site is currently zoned in Fresno County’s Exclusive Agriculture (AE-20) District and is designated Agriculture in the Fresno County General Plan. However, the project site is planned for light industrial development under the Reedley General Plan, and the proposed project would be consistent with the planned land use designation for the project site. The project would require annexation of the project site into the City of Reedley, after which the site would be pre-zoned to the Light Industrial (ML) District, and the General Plan land use designation would be changed to Light Industrial. An annexation application would be 3/29/24 (P:\20231045.02 Huntsman\PRODUCTS\RTC\Admin\Huntsman_RTC_Memo-Draft_2.docx) 28 required to be submitted to the Fresno LAFCo. The Project Applicant would also be required to pay required processing fees for the annexation process. After approval of annexation of the project site into the city of Reedley, the proposed project would be developed with a light industrial use, consistent with the City’s land use plans. Therefore, the proposed project would not conflict with any land use plan, policy or regulation adopted for the purpose of avoiding or mitigating an environmental effect, and the impact would be less than significant.
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ATTACHMENT

PUBLIC COMMENT LETTERS
3/29/24 (P:\20231045.02 Huntsman\PRODUCTS\RTC\Admin\Huntsman_RTC_Memo-Draft_2.docx) 30 This page intentionally left blank
10211 Sunland Blvd., Shadow Hills, CA 91040 (818) 650-0030 X101 [email protected] February 27, 2024
Rodney Horton
Community Development Director
City of Reedley
1733 9th Street
Reedley, CA 93654
Via U.S. Mail and email to [email protected] re: Comments on Mitigated Negative Declaration for the East Huntsman Avenue Industrial Park Project, SCH No. 2024010923
Dear Mr. Horton:

Advocates for the Environment submits the comments in this letter regarding the Mitigated Negative Declaration (MND) for the East Huntsman Avenue Industrial Park Project (Project). The Project Site is located along the north side of East Huntsman Avenue in the City of Reedley (City).

The Project proposes to develop a 26-lot industrial park on the 42-acre project site.

Advocates for the Environment is a public interest law firm and advocacy organization with the mission to educate the public about the law as it pertains to the environment and provide legal services in support of environmental causes. We have reviewed the MND released in January 2024, and submit comments regarding the sufficiency of the MND’s Greenhouse-Gas (GHG) analysis under the California Environmental Quality Act (CEQA).

The City Should Require the Project to be Net-Zero
Given the current regulatory context and technological advancements, a net-zero significance threshold is feasible and extensively supportable. GHG emissions from buildings, including indirect emissions from offsite generation of electricity, direct emissions produced onsite, and from construction with cement and steel, amounted to 21% of global GHG emissions in 2019. (IPCC Sixth Assessment Report, Climate Change 2022, WGIII, Mitigation of Climate Change, p. 9-4.) This is a considerable portion of global GHG emissions. It is much more affordable to construct new building projects to be net-zero than to obtain the same level of GHG reductions by expensively retrofitting older buildings to comply with climate change regulations. Climate damages will keep increasing until we reach net zero GHG emissions, and there is a California state policy requiring the state to be netzero by 2045. It therefore is economically unsound to construct new buildings that are not net-zero.

Environmental groups have achieved tremendous outcomes by litigation under CEQA. Two of the largest mixed-use development projects in the history of California, Newhall Ranch (now Advocates for the Environment
A non-profit public-interest law firm
and environmental advocacy organization
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CEQA Comments on East Huntsman Avenue Industrial Park Project February 27, 2024 10211 Sunland Blvd., Shadow Hills, CA 91040 (818) 650-0030 X101 [email protected] FivePoint Valencia), and Centennial (part of Tejon Ranch) decided to move forward as net-zero communities after losing CEQA lawsuits to environmental groups. The ability for these large projects to become net-zero indicates that it is achievable, even for large-scale developments. The Applicant for this Project should do the same.

GHG Significance Analysis
The MND adopted two significance thresholds based on the CEQA Guidelines Appendix G.

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CEQA Comments on East Huntsman Avenue Industrial Park Project February 27, 2024 10211 Sunland Blvd., Shadow Hills, CA 91040 (818) 650-0030 X101 [email protected] The City’s Analysis of CAP Compliance is Not Supported by Substantial Evidence Threshold (a), asks whether the Project would “generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment.” (MND, p. 3-43.) Under this threshold, the City concluded that the Project would have a less-than-significant impact because, after quantifying the Project’s annual GHG emissions at approximately 4,703.3 metric tons carbon dioxide equivalent (MTCO2e) per year, the City indicated that the Project would adhere to the local Climate Action Plan (CAP) such that it would be deemed a less-than-significant GHG impact. (MND, p. 3-45.)
However, the Project would conflict with the local CAP, making the Project the source of a significant GHG impact. In particular, the CAP requires that projects in the City of Reedley meet a 20% reduction in GHG emissions, which the record was unable to demonstrate. The CAP lists GHG reduction measures, as well as an “average” suggested reduction. Yet, the requirement under the CAP is to demonstrate a 20% reduction of the project, and here the CALEEMod outputs demonstrate that the average reductions could not be achieved, even when the reduction measures are implemented.

Therefore, the Project cannot rely on the average reductions as listed in Table 3.8.B because there is evidence it would not be able to achieve these levels of reductions. The City claims that by implementing photovoltaic solar energy for at least 20% of the project’s energy needs, it would achieve a 17% reduction in overall Project emissions. Yet, the CalEEMod outputs belie this conclusion, because even if 20% of the 1,525 energy-related emissions were being reduced through solar power, it would only amount to 6.5% reduction of overall Project emissions. 1 Likewise, installing an energy star rated water heater would only amount to Project emission reductions of 4.5%, far below the average assumption of 12%.2 With these more accurate metrics in mind—that the City should have considered instead of the averages—all of the CAP GHG reduction 1 !"#$# &'()$* *+*,-. */01102+1 3 45$4 6$478 9 :4# &'()$* ,*;<=>02+ :4# &'()$* ,*;<=>02+ ? @"A4:5: &'()$* >2>BC D,2E*=> */01102+1 9 BDD,2F5 G5#7 Energy metric from CalEEMod Outputs p.14/66. The true reduction could be even lower, because only 778 MTCO2e would be emitted as a result of the Project’s unmitigated electricity use, and it is unclear whether the solar energy would also replace 20% of the natural gas usage, which amounts for nearly half of the total Project’s energy use. (CalEEMod Outputs, p. 39/66).
2 Water heating accounts for 20% of home energy use and energy star rated water heaters can save 70% of energy. https://www.energystar.gov/products/energy_star_home_upgrade/super_efficient_water_heater#:~:text=Water%20hea ters%20use%20about%2020,energy%20than%20a%20standard%20model. !"#$# &'()$* *+*,-. H ,*CB>*; */01102+1 3 45$4 6$47 2I *+*,-. <1*8 3 45A4 6A47 ,*;<=>02+8 9 $!:5# &'()$* ,*;<=>02+
$!:5# &'()$* ,*;<=>02+ ? @"A4:5: &'()$* >2>BC D,2E*=> */01102+1 9 @5#7 Energy metric from CalEEMod Outputs p.14/66
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CEQA Comments on East Huntsman Avenue Industrial Park Project February 27, 2024 10211 Sunland Blvd., Shadow Hills, CA 91040 (818) 650-0030 X101 [email protected] measures that the Project would implement combined would contribute to less than the 20% reductions required by the CAP.
3 And this is assuming that the remaining reduction measures would achieve the purported reductions, which is unlikely because the particular impacts which they target (i.e., energy efficiency and water usage) are not large in comparison to the Project’s mobile emissions. EV charging stations is the only GHG Reduction Measures which could potentially address this source of emissions but would not address the emissions from heavy duty vehicles, which account for 2,468 MTCO2e. (See Appendix A, CalEEMod Output Sheets, Heavy Heavy Duty Truck Trips Custom Report.) Further, the City cannot sincerely rely on planting shade trees to reduce 2% of the Project’s emissions because the CalEEMod Output does not include vegetation-related emissions estimates.

Even if the Project is consistent with the requirement of 20% GHG reduction based on the CAP Compliance Checklist, this is not sufficient to demonstrate that the Project would not generate GHG emissions that may have a significant impact on the environment. In particular, even after a reduction of 20% of the Project’s emissions, the Project would still emit 3,762.64 MTCO2e. 4 This
new source of emissions far exceeds the CO2e emissions from the entire City of Reedley in 2005, the baseline year from which the 2030 goal of 50% CO2e reduction is derived. 5 Accordingly, there is no
evidence that adhering to the requirements of the CAP would adequately account for the goals therein. Furthermore, there is no evidence that adherence with the CAP would reduce the Project’s emissions to a less-than-significant level.

The Project does not comply with the Fresno RTP as the City contends. The City did not adequately analyze the Fresno RTP but summarily dismissed the potential for conflict with the Fresno RTP because the Project would purportedly include a pistachio processing facility. This would purportedly make the Project consistent with the growth assumptions in the Fresno RTP. Even if this were true, this assertion is insufficient to demonstrate that the Project would be consistent with the Fresno RTP as a whole. The RTP sets numerous goals and identifies implementing parties, as well as the timeframe in which those goals should be accomplished (short-term or long term). The RTP thus 3 G5#7 612CB, *+*,-. ,*;<=>02+8 J :5#7 6KB>*, L*B>*, ,*;<=>02+8 J !7 6M0>=L*+ IB<=*>8 J !7 6NB>L,22/ IB<=*>8 J !7 6>20C*>8 J 45$7 60,,0-B>02+8 J 45!!7 OP =LB,-0+- J $7 6CB+;1=BD0+-8 9 !#5:!7 4 @"A4:5: &'()$* 3 45Q 6Q478 9 :"AG$5G@ &'()$* 5 2005 emissions were 2,360 MTCO2e (CAP, p. 15.) Le�er - 1

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CEQA Comments on East Huntsman Avenue Industrial Park Project February 27, 2024 10211 Sunland Blvd., Shadow Hills, CA 91040 (818) 650-0030 X101 [email protected] inconsistent with these goals because it would create an additional large source of emissions from nonrenewable sources, contrary to the statewide electrification and decarbonization contemplated by the 2022 Scoping Plan.

Therefore, by the City’s own adopted significance threshold and chosen plans, the Project would have a significant GHG impact.

The MND accounted for a building lifespan of 30 years. (MND, p. 3-44) Due to construction anticipated from 2025 to 2026, (MND, p. 3-11) the Project will likely be operating well into 2056.

With the Project’s annual GHG emissions at 4,703.3 MTCO2e annually and 555 employees, the Project’s per-service population GHG emissions would be approximately 8.47 MTCO2e/capita, which exceeds the 2030 and is over four times the 2050 target, which would have to be achieved well within the Project’s lifespan to be consistent with the 2017 Scoping Plan. 7 Thus, the Project’s GHG
impact is significant under the second threshold because it is inconsistent with applicable plans for the reduction of GHGs.
7 @"A4:5: &'()$* ? ### */DC2.**1 9 Q5@A &'()$* D*, 1*,S0=* D2D<CB>02+ Le�er - 1

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Please put Advocates for the Environment on the interest list to receive updates about the progress of this Project.

Sincerely,
Dean Wallraff, Attorney at Law
Executive Director, Advocates for the Environment
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BLUM, COLLINS & HO LLP

ATTORNEYS AT LAW

AON CENTER
707 WILSHIRE BOULEVARD
SUITE 4880
LOS ANGELES, CALIFORNIA 90017 (213) 572-
0400
February 27, 2024
Rodney L. Horton, VIA EMAIL TO:

Community Development Director [email protected] City of Reedley
1733 9th Street
Reedley, CA 93654
SUBJECT: COMMENTS ON EAST HUNTSMAN AVENUE INDUSTRIAL PARK PROJECT MND (SCH NO. 2024010923)
Dear Mr. Horton,
Thank you for the opportunity to comment on the Mitigated Negative Declaration (MND) for the proposed East Huntsman Avenue Industrial Park Project. Please accept and consider these comments on behalf of Golden State Environmental Justice Alliance. Also, Golden State Environmental Justice Alliance formally requests to be added to the public interest list regarding any subsequent environmental documents, public notices, public hearings, and notices of determination for this project. Send all communications to Golden State Environmental Justice Alliance P.O. Box 79222 Corona, CA 92877.

1.0 Summary
The proposed Project proposes the development of an approximately 42-acre site into a 26-lot light industrial park. The project site is currently used for growing agricultural crops and contains agricultural support buildings and one single-family residence. The proposed Project includes the annexation of the project site into the City of Reedley, after which the project site would be prezoned to the Light Industrial (ML) District and the Fresno County General Plan agricultural land use designation would change to Light Industrial as established in the City’s General Plan. The proposed project would require approval of an annexation application, Sphere of Influence Application to LAFCO, a rezone (pre-zone), and a Tentative Subdivision Map.

The project development includes construction and operation of approximately 340,000 square feet of warehousing buildings and 11,200 square foot building for a truck maintenance/truck wash.

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The proposed project would include 30 truck/trailer parking stalls, 595 passenger car parking stalls, and truck loading zones in the southern and eastern portions of the project site. Additionally, the proposed project would include an overnight parking lot with capacity for approximately 100 semitrucks in the project site.

Project Description
The MND does not include floor plans, a detailed site plan, building elevations, or a conceptual grading plan. The basic components of a Planning Application include a detailed site plan, floor plan, conceptual grading plan, written narrative, and detailed elevations. Providing the grading plan and earthwork quantity notes is vital as the MND states that, ³7KH proposed project would not require any soil LPSRUWH[SRUW´ and there is no method for the public to verify this claim. The quantity of import/exported materials and soils directly informs the quantity of necessary truck hauling trips due to soil import/export during the grading phase of construction. An EIR must be prepared to include wholly accurate and adequate detailed site plan, floor plan, grading plan, elevations, and project narrative for public review.

3.3 Air Quality, 3.6 Energy, and 3.8 Greenhouse Gas Emissions Please refer to attachments from SWAPE for a complete technical commentary and analysis.

The MND does not include for analysis relevant environmental justice issues in reviewing potential impacts, including cumulative impacts from the proposed project. According to CalEnviroScreen 4.01 , CalEPA’s screening tool that ranks each census tract in the state for pollution and socioeconomic vulnerability, the proposed project’s census tract (6019006300) is highly burdened by pollution and ranks in the 81st percentile for overall pollution burden. The surrounding community bears the impact of multiple sources of pollution and is more polluted than average on several pollution indicators measured by CalEnviroScreen. For example, the project census tract ranks in the 91st percentile for ozone burden and the 94th percentile for particulate matter (PM) 2.5 burden, both of which are attributed to heavy truck activity in the area.

Ozone can cause lung irritation, inflammation, and worsening of existing chronic health conditions, even at low levels of exposure2.
1 CalEnviroScreen
https://experience.arcgis.com/experience/11d2f52282a54ceebcac7428e6184203/page/CalEnviroScreen4_0/ 2 OEHHA Ozone https://oehha.ca.gov/calenviroscreen/indicator/air-quality-ozone Le�er - 2

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The census tract ranks in the 97th percentile for drinking water, which indicates that it ranks with the worst quality drinking water in the state. Poor communities areas are exposed to contaminants in their drinking water more often than people in other parts of the state3.

The census tract also ranks in the 64th percentile for solid waste facility impacts, which can expose people to hazardous chemicals, release toxic gasesinto the air (even after these facilites are closed), and chemicals can leach into soil around the facility and pose a health risk to nearby populations4.

Further, the project’s census tract is a diverse community including 43% Hispanic and 6% AsianAmerican residents, whom are especially vulnerable to the impacts of pollution. The community has a high rate of low educational attainment, meaning 56% of the census tract over age 25 has not attained a high school diploma, which is an indication that they may lack health insurance or access to medical care. The community has a high rate of poverty, meaning 39% of the households in the census tract have a total income before taxes that is less than the poverty level. Income can affect health when people cannot afford healthy living and working conditions, nutritious food and necessary medical care 5 . Poor communities are often located in areas with high levels of pollution6. Poverty can cause stress that weakens the immune system and causes people to become ill from pollution7. Living in poverty is also an indication that residents may lack health insurance or access to medical care. Medical care is vital for this censustract as it ranks in the 73rd percentile for incidence of cardiovascular disease and 74th percentile for incidence of asthma.

Additionally, the project census tract (6019006300) and census tracts adjacent to the project site (6019006501 (east), 6107000401 (south), 6019006602 (west), and 6019006604 (west)) are identified as SB 535 Disadvantaged Communities 8. This indicates that cumulative negative impacts of development and environmental impacts in the area are disproportionately impacting these communities. The MND does not discuss that the surrounding area is a disadvantaged community and does not utilize this information in its analysis. The MND has not considered the environmental impacts in relation to the SB 535 status of the project census tract and surrounding area. The negative environmental, health, and quality of life impacts of the warehousing and logistics industry in the area have become distinctly inequitable. The severity of environmental impacts particularly on these Disadvantaged Communities must be included for analysis as part of an EIR.
3 OEHHA Drinking Water https://oehha.ca.gov/calenviroscreen/drinking-water 4 OEHHA Solid Waste Facilities https://oehha.ca.gov/calenviroscreen/indicator/solid-waste-sites-andfacilities 5 OEHHA Poverty https://oehha.ca.gov/calenviroscreen/indicator/poverty 6 Ibid.
7 Ibid.
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The State of California lists three approved compliance modeling softwares9 for non-residential buildings: CBECC-Com, EnergyPro, and IES VE. CalEEMod is not listed as an approved software. The CalEEMod modeling does not comply with the 2022 Building Energy Efficiency Standards and under-reports the project’s significant Energy impacts and fuel consumption to the public and decision makers. Since the MND did not accurately or adequately model the energy impacts in compliance with Title 24, it cannot conclude the project will generate less than significant impacts and a finding of significance must be made. An EIR with modeling using one of the approved software types must be prepared and circulated for public review in order to adequately analyze the project’s significant environmental impacts. This is vital as the MND utilizes CalEEMod as a source in its methodology and analysis, which is clearly not an approved software.

The MND analyzes the potentially significant impacts from Greenhouse Gas Emissions in a qualitative manner pursuant to CEQA Guidelines Section 15064.4. However, the consistency analysis provided is erroneous and does not demonstrate a good-faith effort, based to the extent possible on scientific and factual data, to describe, calculate or estimate the amount of greenhouse gas emissions resulting from the project and its significance. The MND quantitatively concludes that the proposed project will have an annual operational emissions of 4,703.3 MT CO2e annually.

The MND includes MM GHG-1 to require that ³7KH project applicant shall incorporate the following specifications into construction plans details and specifications to document implementation and compliance with the following applicable Climate Action Plan (CAP) greenhouse gas (GHG) reduction measures for review by the City of Reedley Community Development 'HSDUWPHQW´ within the &LW\¶V CAP to achieve a 34% reduction in emissions.

Table 3.8.B: Project Compliance with the City’s Applicable CAP GHG Reduction Checklist Measures provides erroneous and misleading consistency analysis of the proposed project with the reduction measures in order to conclude the project will have less than significant impacts. For example, compliance with item ³/DQGVFDSLQJ for Energy Efficiency: Plant shade trees on a buildings ’south side,´ is not supported with meaningful evidence such as a landscape plan/planting plan to demonstrate the quantity of shade trees provided and/or their locations on the south sides of buildings. Additionally, compliance with item ³3KRWRYROWDLF solar energy provides ဨ
of power needs (annual DYHUDJH
´ is not supported with any meaningful evidence, such
9 California Energy Commission 2022 Energy Code Compliance Software https://www.energy.ca.gov/programs-and-topics/programs/building-energy-efficiency-standards/2022- building-energy-efficiency-1
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as a solar plan to depict the placement of panels and calculations of annual energy generated by the panels that would serve the project.

The efficacy of the proposed mitigation measures and reduction of GHG impacts below the applicable thresholds via percentages provided in Table 3.8.B cannot be assured and the SURMHFW¶V GHG impact is therefore considered significant and unavoidable. An EIR must be prepared to include a finding of significance because there is no possible assurance that the project will comply with the proposed CAP items, and the MND has utilized the CAP screening tables to mislead the public and decision makers by erroneously concluding that a qualitative assessment of the project will reduce the SURMHFW¶V 4,703.3 MT CO2e annual emissions to less than significant levels.

Mitigation of the SURMHFW¶V GHG impact to less than significant is not feasible, whether via the CAP tables or otherwise. A finding of significance must be included as part of a project EIR.

3.11 Land Use and Planning
The MND does not include a consistency analysis with any land use plans, policies, or regulations adopted for the purpose of avoiding or mitigating an environmental effect, such as the General Plan. The MND is inadequate as an informational document and an EIR must be prepared with a consistency analysis with all General Plan policies, including the following:

2. Land Use Element Guiding Principle (b): Plan for urban growth in a manner that minimizes impacts on agriculture and the consumption of agricultural land.

4. Land Use Element Guiding Principle (f): Provide transitions between various land uses and intensities using high quality design.

5. Land Use Element Guiding Principle (h): Development in the planning area shall occur in a fashion that protects and enhances air quality and water quality.

6. Land Use Element Guiding Principle (i): Public open space shall be made an integral part of new development in the planning area.

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9. Policy LU 2.7.51: During the review of development applications for proposed new light industry, the City shall determine whether pretreatment of industrial wastes shall be required.

10. Goal CIR 3.2B: Maintain a level of service (LOS) of “C´ or better.

12. Policy CIR 3.2.8: A walled-in subdivision shall be discouraged unless noise measurements exceed the threshold for residential development adjacent to roadways.

Table
ဨ&
Recommended Improvements for Intersections and Fair Share within Appendix D:

Traffic Impact Study concludes the following intersection outside the sole jurisdiction of the lead agency requires improvements to address the peak hour deficiencies per the applicable thresholds of significance. Table
ဨ& also provides a fair-share calculation for improvements that will allegedly mitigate significant and unavoidable impacts to the intersections to less than significant levels.

Any improvements recommended or fees paid to mitigate impacts for County of Fresno facilities are beyond the control of the lead agency and evidence that these improvements will be completed or approved by County of Fresno has not been provided. An EIR must be prepared to include the LOS analysis as cumulatively considerable significant impact as the project conflicts with Transportation Impact Threshold A and Land Use and Planning Impact Threshold B because it is not consistent with the following General Plan Goal:

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1. Goal CIR 3.2B: Maintain a level of service (LOS) of “C´ or better.

Additionally, the MND has not provided any information or analysis regarding the required annexation application to LAFCo. The MND states that, ³$IWHU approval of annexation of the project site into the city of Reedley, the proposed project would be consistent with the &LW\¶V land use SODQV´ resulting in less than significant impacts. The MND relies upon approval of the annexation itself to demonstrate compliance, which circumvents the required analysis and does not provide any meaningful evidence to support the conclusion that the project will have less than significant impacts. Notably, the project site is within the &LW\¶V General Plan Sphere of Influence (SOI) but the full extent of the GP SOI has not been approved by LAFCo, including the project site. The &LW\¶V 2020 Municipal Services Review10 (MSR) did not include analysis of the proposed project site, meaning that it is unknown if the City and the associated service providers can accommodate the growth proposed by the project. The requirement forservice reviews arises from the identified need for a more coordinated and efficient public service structure to support &DOLIRUQLD¶V anticipated growth. The service review provides LAFCo with a tool to study existing and future public service conditions comprehensively and to evaluate organizational options for accommodating growth, preventing urban sprawl, and ensuring that critical services are provided efficiently. The MND cannot conclude that the proposed project is consistent with all land use plans, policies, or regulations adopted for the purpose of avoiding or mitigating an environmental effect, including LAFCo regulations, and/or thresholds A - E within the Utilities and Service Systems section, until and unless it provides a MSR document for review and analysis by the public and decision makers. Additionally, since approval of the MSR lies with LAFCo and not the lead agency, an EIR cannot provide reasonable assurance that the MSR is adequate or will be approved and therefore the impact will remain significant and unavoidable necessitating a finding of significance in an EIR.

3.17 Transportation
Table
ဨ&
Recommended Improvements for Intersections and Fair Share within Appendix D:

1. #3: Englehart Avenue/Dinuba Avenue (County of Fresno) 10 https://www.fresnolafco.org/files/dd4176f39/Final_MSR_City_of_Reedley_04082020.pdf Le�er - 2

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1. Goal CIR 3.2B: Maintain a level of service (LOS) of “C´ or better.

Further, the MND has underreported the quantity VMT generated by the proposed project operations. The operational nature of industrial/warehouse uses involves high rates of truck/trailer/delivery van VMT due to traveling from large import hubs to regional distribution centers to smaller industrial parks and then to their final delivery destinations. Once employees arrive at work at the proposed project, they will conduct their jobs by driving delivery vans across the region as part of the daily operations as a distribution facility, which will drastically increase project-generated VMT. The SURMHFW¶V truck/trailer and delivery van activity is unable to utilize public transit or active transportation and it is misleading to the public and decision makers to exclude this activity from VMT analysis. The SURMHFW¶V total operational VMT generated is not consistent with the screening threshold and legislative intent of SB 743 to reduce greenhouse gas emissions by reducing VMT. An EIR must be prepared to reflect a quantified VMT analysis that includes all truck/trailer and delivery van activity.

The MND has not adequately analyzed the SURMHFW¶V potential to substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses; or the SURMHFW¶V potential to result in inadequate emergency access. The MND has not provided any exhibits depicting the available truck/trailer turning radius at the intersection of the project driveways to determine if there is enough space available to accommodate heavy truck maneuvering. Further, there are no exhibits providing on-site analysis regarding available space Le�er - 2

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on the property to accommodate heavy truck maneuvering. The MND states that, ³$ORQJ the project frontage, currently there is no dedicated RQဨVWUHHW parking SURYLVLRQ ´ however, this does
not equate to an on-street parking prohibition, meaning that street parking could be in use at any time and has not been analyzed in the MND.

The MND also states that, ³WKH project design features would be required to comply with standards set by the City’s General Plan and City Engineer. In addition, the proposed project would also be required to submit plans to the RFD for review and approval prior to the issuance of building permits to ensure there are no substantial hazards associated with the project desLJQ´ The MND provides a similar statement regarding emergency access in stating that, ³the proposed project’s site plan would be subject to review and approval by the RFD to ensure the project includes adequate emergency DFFHVV´ This does not comply with &(4$¶V requirements for adequate informational documents and meaningful disclosure (CEQA § 15121 and 21003(b)). Deferring this environmental analysis required by CEQA to the construction permitting phase is improper mitigation and does not comply with C(4$¶V requirement for meaningful disclosure and adequate informational documents. An EIR must be prepared to include the City/RFD determination/review of the project and the complete Site Plan for review, analysis, and comment by the public and decision makers in order to provide an adequate and accurate environmental analysis.

3.19 Utilities and Service Systems
The MND has not provided any information or analysis regarding the required annexation application to LAFCo. The MND concludes that because the proposed land use is consistent with the General Plan land use designation, it is therefore accounted for in utilities and service systems plans such as the Urban Water Master Plan, resulting in less than significant impacts. Notably, the project site is within the &LW\¶V General Plan Sphere of Influence (SOI) but the full extent of the GP SOI has not been approved by LAFCo, including the project site. The &LW\¶V 2020 Municipal Services Review11 (MSR) did not include analysis of the proposed project site, meaning that it is unknown if the City and the associated service providers can accommodate the growth proposed by the project. The requirement for service reviews arises from the identified need for a more coordinated and efficient public service structure to support &DOLIRUQLD¶V anticipated growth.

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LAFCo regulations, and/or thresholds A - E within the Utilities and Service Systems section, until and unless it provides a MSR document for review and analysis by the public and decision makers.

3.21 Mandatory Findings of Significance
An EIR must be prepared to include a cumulative analysis discussion here to demonstrate the impact of the proposed project in a cumulative setting. The MND does not discuss or analyze the SURMHFW¶V compliance with the General 3ODQ¶V Land Use Buildout Scenario. Further, a MSR is required to be included as part of the environmental analysis to determine if the City and the associated service providers can accommodate the growth proposed by the project. An EIR must be prepared to include this information for analysis and also include a cumulative development analysis of projects approved since General Plan adoption and projects ³LQ the SLSHOLQH´ to determine if the proposed project exceeds the General Plan growth estimates.

Conclusion
For the foregoing reasons, GSEJA believes the MND is flawed and an EIR must be prepared for the proposed project and circulated for public review. Golden State Environmental Justice Alliance requests to be added to the public interest list regarding any subsequent environmental documents, public notices, public hearings, and notices of determination for this project. Send all communications to Golden State Environmental Justice Alliance P.O. Box 79222 Corona, CA 92877.

Sincerely,
Gary Ho
Blum, Collins & Ho LLP
Attachment: SWAPE Analysis
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2656 29th Street, Suite 201
Santa Monica, CA 90405
Matt Hagemann, P.G, C.Hg.
(949) 887-9013
[email protected]
Paul E. Rosenfeld, PhD
(310) 795-2335
[email protected]
February 2ϭ, 2024
Gary Ho
Blum, Collins & Ho LLP
707 Wilshire Blvd, Ste. 4880
Los Angeles, CA 90017
Subject: Comments on the East Huntsman Avenue Industrial Park Project (SCH No. 2024010923) Dear Mr. Ho,
We have reviewed the January 2024 Initial Study and Mitigated Negative Declaration (“IS/MND”) for the East Huntsman Avenue Industrial Park Project (“Project”) located in the City of Reedley (“City”). The Project proposes to construct 351,560-square-feet (“SF”) of industrial space and 2.23 acres of parking on the 42-acre site.

Our review concludes that the IS/MND fails to adequately evaluate the Project’s air quality and health risk impacts. As a result, emissions and health risk impacts associated with construction and operation of the proposed Project may be underestimated and inadequately addressed. An Environmental Impact Report (“EIR”) should be prepared to adequately assess and mitigate the potential air quality and health risk impacts that the project may have on the environment.

Air Quality
Failure to Provide Complete CalEEMod Output Files
Land use development projects under the California Environmental Quality Act (“CEQA”) typically evaluate air quality impacts and calculate potential criteria air pollutant emissions using the California Emissions Estimator Model (“CalEEMod”). 1 CalEEMod provides recommended default values based on site-specific information, such as land use type, meteorological data, total lot acreage, project type and typical equipment associated with project type. If more specific project information is known, the user can change the default values and input project-specific values, but CEQA requires that such changes be 1 “CalEEMod User’s Guide.” California Air Pollution Control Officers Association (CAPCOA), May 2021, available at:
https://www.aqmd.gov/caleemod/user's-guide.

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ATTACHMENT #1
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2 justified by substantial evidence. Once all of the values are inputted into the model, the Project’s construction and operational emissions are calculated, and “output files” are generated. These output files disclose to the reader what parameters are used in calculating the Project’s air pollutant emissions and demonstrate which default values are changed. Justifications are provided for the selected values.

According to the IS/MND, CalEEMod Version 2022.1 is relied upon to estimate Project emissions (p. 3- 11). However, this poses a problem as the version of CalEEMod 2022.1 currently available is described as a “soft release” which fails to provide complete output files.2 Specifically, the “User Changes to Default Data” table no longer provides the quantitative counterparts to the changes to the default values (see excerpt below) (Appendix A, pp. 68):

However, previous CalEEMod Versions, such as 2020.4.0, include the specific numeric changes to the model’s default values (see example excerpt below):

The output files associated with CalEEMod Version 2022.1 fail to present the exact parameters used to calculate Project emissions. To remedy this issue, the IS/MND should have provided access to the model’s “.JSON” output files, which allow third parties to review the model’s revised input parameters.3 2 “CalEEMod California Emissions Estimator Model Soft Release.” California Air Pollution Control Officers Association (CAPCOA), 2022, available at: https://caleemod.com/. 3 “Video Tutorials for CalEEMod Version 2022.1.” California Air Pollution Control Officers Association (CAPCOA), May 2022, available at: https://www.caleemod.com/tutorials.

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3 Without access to the complete output files, including the specific numeric changes to the default values, we cannot verify that the IS/MND’s air modeling and subsequent analysis is an accurate reflection of the proposed Project. An EIR should be prepared to include an updated air quality analysis that correctly provides the complete output files for CalEEMod Version 2022.1, or includes an updated air model using an older release of CalEEMod.4
Unsubstantiated Input Parameters Used to Estimate Project Emissions As discussed, the IS/MND relies on CalEEMod Version 2022.1 to estimate the Project’s air quality emissions and fails to provide the complete output files required to adequately evaluate model’s analysis (p. 20). Regardless, when reviewing the Project’s CalEEMod output files, provided in the CalEEMod Output Sheets as Appendix A to the IS/MND, we were able to identify several model inputs that are inconsistent with information disclosed in the IS/MND. Consequently, the Project’s construction and operational emissions may be underestimated. An EIR should be prepared to include an updated air quality analysis that adequately evaluates the impacts that construction and operation of the Project will have on local and regional air quality.

Unsubstantiated Changes to Individual Construction Phase Lengths Review of the CalEEMod output files demonstrates that the “East Huntsman Avenue Industrial Park Project” model includes changes to the default construction schedule (see excerpt below) (Appendix A, pp. 68).

The CalEEMod User’s Guide requires any changes to model defaults be justified.5 As demonstrated above in the “User Changes to Default Data” table, the justification provided for these changes is:
“Construction of the proposed project is anticipated to occur over a total 12-month period starting January 2025, and ending January 2026” (Appendix A, pp. 114). 4 “CalEEMod Version 2020.4.0.” California Air Pollution Control Officers Association (CAPCOA), May 2021, available at: http://www.aqmd.gov/caleemod/download-model. 5 “CalEEMod User’s Guide.” California Air Pollution Control Officers Association (CAPCOA), May 2021, available at:
https://www.aqmd.gov/caleemod/user's-guide, p. 1, 14.

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4 As a result of these changes, the model includes the following construction schedule (see excerpt below) (Appendix A, pp. 58):

Regarding the Project’s anticipated construction duration, the IS/MND restates:
“Construction of the proposed project is anticipated to occur over a total 12-month period starting January 2025, and ending January 2026” (p. 1-4).

However, the changes to the individual construction phase lengths remain unsubstantiated. While the IS/MND, and the included CalEEMod output files, demonstrate that the total length of Project construction would be 12 months, the IS/MND fails to substantiate the individual construction phase lengths. Until specific evidence is provided, the model should have included proportionately altered individual phase lengths to match the proposed construction duration of 12 months.

The construction schedule included in the model presents an issue, as the construction emissions are improperly spread out over a longer period of time for some phases, but not for others. According to the CalEEMod User’s Guide, each construction phase is associated with different emissions activities (see excerpt below).6
By disproportionately altering and extending some of the individual construction phase lengths without proper justification, the model assumes there are a greater number of days to complete the construction activities required by the prolonged phases. As a result, there will be less construction activities required per day and, consequently, less pollutants emitted per day. Until we are able to verify 6 “CalEEMod User’s Guide.” California Air Pollution Control Officers Association (CAPCOA), May 2021, available at:
https://www.aqmd.gov/caleemod/user's-guide, p. 32.

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5 the revised construction schedule, the model may underestimate the peak daily emissions associated with some phases of construction and should not be relied upon to determine Project significance.

Incorrect Application of Tier 4 Final Off-Road Equipment Mitigation Review of the CalEEMod output files demonstrates that the “East Huntsman Avenue Industrial Park Project” model includes changes to the default off-road equipment engine tiers (see excerpt below) (Appendix A, pp. 68).

As previously mentioned, the CalEEMod User’s Guide requires that any changes to model defaults be justified.7 According to the “User Entered Comments & Non-Default Data” table, the justification provided for these changes is:
“Assuming use of Tier 3 construction equipment consistent with information provided by Project Applicant” (Appendix A, pp. 199).

Regarding construction equipment, the IS/MND states:
“Additionally, Tier 3 equipment would be utilized during project construction” (p. 1-4).

As discussed, the IS/MND states Tier 3 equipment would be used for Project construction. However, review of the “East Huntsman Avenue Industrial Park Project” model demonstrates that much of the Project’s off-road construction equipment fleet would meet Tier 4 final emissions standards (see excerpt below) (Appendix A, pp. 59).
7 “CalEEMod User’s Guide Version 2020.4.0.” California Air Pollution Control Officers Association (CAPCOA), May 2021, available at: https://www.aqmd.gov/caleemod/user's-guide, p. 1, 14.

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6 Furthermore, the IS/MND and associated documents fail to mention Tier 4 final off-road equipment emissions standards whatsoever. This is incorrect since, as mentioned above, the CalEEMod User’s Guide requires any changes to model defaults be justified.8 Additionally, the assumption that the Project’s off-road construction equipment fleet would meet either Tier 3 or Tier 4 interim emissions standards remains unsupported as the IS/MND fails to explicitly require these standards through formal mitigation measures. This is incorrect, as according to the Association of Environmental Professionals (“AEP”) CEQA Portal Topic Paper on mitigation measures:
“While not ‘mitigation’, a good practice is to include those project design feature(s) that address environmental impacts in the mitigation monitoring and reporting program (MMRP). Often the MMRP is all that accompanies building and construction plans through the permit process. If the design features are not listed as important to addressing an environmental impact, it is easy for someone not involved in the original environmental process to approve a change to the project that could eliminate one or more of the design features without understanding the resulting environmental impact” (emphasis added).9

As discussed above, measures that are not formally included in the mitigation monitoring and reporting program (“MMRP”) may be eliminated from the Project’s design altogether.

As the use of construction equipment with Tier 4 final emissions standards is not substantiated by the IS/MND and associated documents or formally included as a mitigation measure, we cannot guarantee that these standards would be implemented, monitored, and enforced on the Project site. 8 “CalEEMod User’s Guide Version 2020.4.0.” California Air Pollution Control Officers Association (CAPCOA), May 2021, available at: https://www.aqmd.gov/caleemod/user's-guide, p. 1, 14. 9 “CEQA Portal Topic Paper Mitigation Measures.” AEP, February 2020, available at:
https://ceqaportal.org/tp/CEQA%20Mitigation%202020.pdf, p. 6.

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7 Consequently, until sufficient evidence is provided, the model’s assumption that the off-road construction equipment fleet would adhere to Tier 4 final emissions standards is incorrect.

Unsubstantiated Changes to Operational Fleet Mix Values Review of the CalEEMod output files demonstrates that the “East Huntsman Avenue Industrial Park Project” and “East Huntsman Avenue Industrial Park Project - Heavy Heavy Duty Truck Trips” models include changes to the default operational vehicle fleet mix percentages (see excerpt below) (Appendix A, pp. 68, 104).

Regarding the Project fleet mix, Traffic Impact Study (“TIS”) provided as Appendix D to the IS/MND, includes the following table (see excerpt below) (pp. 42, Table 5-A):

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8 However, these changes remain unsubstantiated. As previously discussed, the output files for CalEEMod 2022.1 do not present the numeric changes to any model defaults. Upon further review of the output files, the model’s fleet mix percentages are not provided whatsoever. Until the IS/MND verifies that the model includes the correct breakdown of every vehicle type that will access the Project site during operations, we cannot verify that the values included in the model are accurate.10 These unsubstantiated changes present an issue, as CalEEMod uses operational vehicle fleet mix percentages to calculate the Project’s operational emissions associated with on-road vehicles.11 By including several unsubstantiated changes to the default operational vehicle fleet mix percentages, the model may underestimate the Project’s mobile-source operational emissions and should not be relied upon to determine Project significance.
10 “CalEEMod User’s Guide.” California Air Pollution Control Officers Association (CAPCOA), May 2021, available at:
https://www.aqmd.gov/caleemod/user's-guide, p. 38. 11 “CalEEMod User’s Guide.” California Air Pollution Control Officers Association (CAPCOA), May 2021, available at:
https://www.aqmd.gov/caleemod/user's-guide, p. 36.

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9 Updated Analysis Indicates a Potentially Significant Air Quality Impact In an effort to more accurately estimate the Project’s construction-related emissions, we prepared an updated CalEEMod model, using the Project-specific information provided by the IS/MND. In our updated model, we omitted the incorrect application of Tier 4 Final off-road equipment mitigation and unsubstantiated changes to operational fleet mix values; we also proportionately altered the construction phase lengths to match the total construction duration of 12 months.12 Our updated analysis estimates that the Project’s construction-related reactive organic gasses (“ROG”) emissions exceed the applicable San Joaquin Valley Air Pollution Control District (“SJVAPCD”) threshold of 10 tons per year (“tons/year”), as referenced by the IS/MND (p. 3-11, Table 3.3.B) (see table below).13 SWAPE Criteria Air Pollutant Emissions
Construction ROG
(tons/year)
IS/MND 0.8
SWAPE 99.214
% Increase 12,300%
SJVAPCD Threshold 10
Exceeds? Yes
As demonstrated above, construction-related ROG emissions, as estimated by SWAPE, increase by approximately 12,300% and exceed the applicable SJVAPCD significance threshold. Our model demonstrates that the Project would result in a potentially significant air quality impact that was not previously identified or addressed by the IS/MND. As a result, an EIR should be prepared to adequately assess and mitigate the potential air quality impacts that the Project may have on the environment.

Diesel Particulate Matter Emissions Inadequately Evaluated The IS/MND concludes that the proposed Project would result in a less-than-significant health risk impact based on a quantified construction and mobile-source operational health risk assessment (“HRA”). Specifically, the IS/MND estimates that the maximum incremental cancer risk posed to nearby, existing residential sensitive receptors associated with exposure to diesel particulate matter (“DPM”) emissions during Project construction and operation would be 16.20 and 6.75 in one million, which would not exceed the SJAVPCD significance threshold of 20 in one million (see excerpts below) (p. 3-15, Table 3.3D; p. 3-18, Table 3.3E).
12 See Attachment A for updated CalEEMod model. 13 “San Joaquin Valley Unified Air Pollution Control District.” SJVAPCD, June 2012, available at:
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10 However, the IS/MND’s evaluation of the Project’s potential health risk impacts, as well as the subsequent less-than-significant impact conclusion, is incorrect for three reasons.

First, the IS/MND’s construction HRA is incorrect, as it relies upon emissions estimates from an unsubstantiated air model, as discussed above in section of this letter titled “Unsubstantiated Input Parameters Used to Estimate Project Emissions.” As a result, the HRA may rely on an underestimated DPM concentration to calculate the health risk associated with Project construction. The IS/MND’s construction HRA and the resulting cancer risk should not be relied upon to determine Project significance.

Second, the IS/MND fails to mention the exposure assumptions for the construction-related and operational HRAs, such as age sensitivity factors (“ASF”) or fraction of time at home (“FAH”) values whatsoever. Until the IS/MND substantiates the use of correct exposure assumptions, the HRAs may underestimate the cancer risk posed to nearby, existing sensitive receptors due to Project construction and operation. Furthermore, according to the Risk Assessment Guidelines provided by the Office of Environmental Health Hazard Assessment (“OEHHA”), the organization responsible for providing guidance on conducting HRAs in California, the IS/MND’s HRA should have used the following equation:15
15 “Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February 2015, available at: https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf, p. 8-7, Equation 8.2.4.

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11 However, the IS/MND fails to mention or provide a dose and risk equation to calculate the Project’s construction and operational cancer risks. As such, we cannot verify that the IS/MND’s HRA is accurate, and the Project’s cancer risks may be underestimated.

Third, while the IS/MND includes two HRAs evaluating the health risk impacts to nearby, existing receptors as a result of Project construction and operation, the IS/MND fails to evaluate the combined lifetime cancer risk to nearby receptors as a result of Project construction and operation together.

According to OEHHA guidance, “the excess cancer risk is calculated separately for each age grouping and then summed to yield cancer risk at the receptor location.”16 However, the IS/MND fails to sum the total cancer risks in order to evaluate the combined cancer risk over the course of the Project’s total construction and operation. When summing the construction-related and operational health risks, the total cancer risk sums to 22.95 in one million, which exceeds the SJVAPCD threshold of 20 in one million, as referenced by the IS/MND.
17 As the combined cancer risk demonstrates a significant impact, an updated EIR should be prepared to evaluate and adequately assess the potential health risk impacts that the Project will have on the environment.

Mitigation
Feasible Mitigation Measures Available to Reduce Emissions Our analysis demonstrates that the Project would result in potentially significant air quality and health risk impacts that should be mitigated further. In an effort to reduce emissions, the Project should consider the implementation of the following mitigation measures found in the California Department of Justice Warehouse Project Best Practices document.18
x Requiring off-road construction equipment to be hybrid electric-diesel or zero emission, where available, and all diesel-fueled off-road construction equipment to be equipped with CARB Tier 16 “Guidance Manual for preparation of Health Risk Assessments.” OEHHA, February 2015, available at:
https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf p. 8-4. 17 “Recommended Thresholds of Significant Impact.” SJVAPCD, available at:
https://www.valleyair.org/transportation/ceqaanalysislevels.htm. 18 “Warehouse Projects: Best Practices and Mitigation Measures to Comply with the California Environmental Quality Act.” State of California Department of Justice, September 2022, available at:
https://oag.ca.gov/system/files/media/warehouse-best-practices.pdf, p. 8 – 10.

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12 IV-compliant engines or better, and including this requirement in applicable bid documents, purchase orders, and contracts, with successful contractors demonstrating the ability to supply the compliant construction equipment for use prior to any ground-disturbing and construction activities.
x Prohibiting off-road diesel-powered equipment from being in the “on” position for more than 10 hours per day.
x Using electric-powered hand tools, forklifts, and pressure washers, and providing electrical hook ups to the power grid rather than use of diesel-fueled generators to supply their power. x Designating an area in the construction site where electric-powered construction vehicles and equipment can charge.
x Limiting the amount of daily grading disturbance area. x Prohibiting grading on days with an Air Quality Index forecast of greater than 100 for particulates or ozone for the project area.
x Forbidding idling of heavy equipment for more than three minutes. x Keeping onsite and furnishing to the lead agency or other regulators upon request, all equipment maintenance records and data sheets, including design specifications and emission control tier classifications.
x Conducting an on-site inspection to verify compliance with construction mitigation and to identify other opportunities to further reduce construction impacts. x Providing information on transit and ridesharing programs and services to construction employees.
x Providing meal options onsite or shuttles between the facility and nearby meal destinations for construction employees.
x Requiring all heavy-duty vehicles engaged in drayage to or from the project site to be zeroemission beginning in 2030. x Requiring all on-site motorized operational equipment, such as forklifts and yard trucks, to be zero-emission with the necessary charging or fueling stations provided. x Requiring tenants to use zero-emission light- and medium-duty vehicles as part of business operations.
x Forbidding trucks from idling for more than three minutes and requiring operators to turn off engines when not in use.
x Posting both interior- and exterior-facing signs, including signs directed at all dock and delivery areas, identifying idling restrictions and contact information to report violations to CARB, the local air district, and the building manager.
x Installing solar photovoltaic systems on the project site of a specified electrical generation capacity that is equal to or greater than the building’s projected energy needs, including all electrical chargers.
x Designing all project building roofs to accommodate the maximum future coverage of solar panels and installing the maximum solar power generation capacity feasible. x Constructing zero-emission truck charging/fueling stations proportional to the number of dock doors at the project.

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13 x Running conduit to designated locations for future electric truck charging stations. x Unless the owner of the facility records a covenant on the title of the underlying property ensuring that the property cannot be used to provide refrigerated warehouse space, constructing electric plugs for electric transport refrigeration units at every dock door and requiring truck operators with transport refrigeration units to use the electric plugs when at loading docks.
x Oversizing electrical rooms by 25 percent or providing a secondary electrical room to accommodate future expansion of electric vehicle charging capability. x Constructing and maintaining electric light-duty vehicle charging stations proportional to the number of employee parking spaces (for example, requiring at least 10% of all employee parking spaces to be equipped with electric vehicle charging stations of at least Level 2 charging performance)
x Running conduit to an additional proportion of employee parking spaces for a future increase in the number of electric light-duty charging stations.
x Installing and maintaining, at the manufacturer’s recommended maintenance intervals, air filtration systems at sensitive receptors within a certain radius of facility for the life of the project.
x Installing and maintaining, at the manufacturer’s recommended maintenance intervals, an air monitoring station proximate to sensitive receptors and the facility for the life of the project, and making the resulting data publicly available in real time. While air monitoring does not mitigate the air quality or greenhouse gas impacts of a facility, it nonetheless benefits the affected community by providing information that can be used to improve air quality or avoid exposure to unhealthy air.
x Requiring all stand-by emergency generators to be powered by a non-diesel fuel. x Requiring facility operators to train managers and employees on efficient scheduling and load management to eliminate unnecessary queuing and idling of trucks. x Requiring operators to establish and promote a rideshare program that discourages singleoccupancy vehicle trips and provides financial incentives for alternate modes of transportation, including carpooling, public transit, and biking.
x Meeting CalGreen Tier 2 green building standards, including all provisions related to designated parking for clean air vehicles, electric vehicle charging, and bicycle parking. x Designing to LEED green building certification standards. x Providing meal options onsite or shuttles between the facility and nearby meal destinations. x Posting signs at every truck exit driveway providing directional information to the truck route. x Improving and maintaining vegetation and tree canopy for residents in and around the project area.
x Requiring that every tenant train its staff in charge of keeping vehicle records in diesel technologies and compliance with CARB regulations, by attending CARB-approved courses. Also require facility operators to maintain records on-site demonstrating compliance and make records available for inspection by the local jurisdiction, air district, and state upon request.

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14 x Requiring tenants to enroll in the United States Environmental Protection Agency’s SmartWay program, and requiring tenants who own, operate, or hire trucking carriers with more than 100 trucks to use carriers that are SmartWay carriers.
x Providing tenants with information on incentive programs, such as the Carl Moyer Program and Voucher Incentive Program, to upgrade their fleets.

These measures offer a cost-effective, feasible way to incorporate lower-emitting design features into the proposed Project, which subsequently, reduce emissions released during Project construction and operation.

As it is policy of the State that eligible renewable energy resources and zero-carbon resources supply 100% of retail sales of electricity to California end-use customers by December 31, 2045, we emphasize that the energy mix that will charge the batteries and power electrical equipment must be 100% renewable energy resources. Until the feasibility of charging the batteries with renewable energy resources only is evaluated, the Project should not be approved.

A n EIR should be prepared to include all feasible mitigation measures, as well as include updated air quality and health risk analyses to ensure that the necessary mitigation measures are implemented to reduce emissions to the maximum extent feasible. The EIR should also demonstrate a commitment to the implementation of these measures prior to Project approval, to ensure that the Project’s potentially significant emissions are reduced to the maximum extent possible.

Disclaimer
SWAPE has received limited discovery regarding this project. Additional information may become available in the future; thus, we retain the right to revise or amend this report when additional information becomes available. Our professional services have been performed using that degree of care and skill ordinarily exercised, under similar circumstances, by reputable environmental consultants practicing in this or similar localities at the time of service. No other warranty, expressed or implied, is made as to the scope of work, work methodologies and protocols, site conditions, analytical testing results, and findings presented. This report reflects efforts which were limited to information that was reasonably accessible at the time of the work, and may contain informational gaps, inconsistencies, or otherwise be incomplete due to the unavailability or uncertainty of information obtained or provided by third parties.

Sincerely,
Matt Hagemann, P.G., C.Hg.

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Phase
Default Phase
Length
Construction
Duration %
Construction
Duration
Revised Phase
Length
Site Preparation 30 1335 0.0225 215 5
Grading 75 1335 0.0562 215 12
Construction 740 1335 0.5543 215 119
Paving 55 1335 0.0412 215 9
Architectural Coating 55 1335 0.0412 215 9
Total Default
Construction
Duration
Revised
Construction
Duration
Start Date 6/1/2025 6/1/2025
End Date 1/26/2029 1/2/2026
Total Days 1335 215
Construction Schedule Calculations
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East Huntsman Avenue Industrial Park Project
Fresno County, Annual
Project Characteristics - Consistent with the IS/MND's model.

Land Use - Consistent with the IS/MND's model.

Construction Phase - See SWAPE's comment on "Unsubstantiated Changes to Individual Construction Phase Lengths." Off-road Equipment -
Grading - Consistent with the IS/MND's model.

Fleet Mix - See SWAPE's comment on "Unsubstantiated Changes to Operational Fleet Mix Values." Vehicle Trips - Consistent with the IS/MND's model.

Construction Off-road Equipment Mitigation - See SWAPES's comment on "Incorrect Application of Tier 4 Final Off-Road Equipment Mitigation."

1.1 Land Usage
Land Uses Size Metric Lot Acreage Floor Surface Area Population Industrial Park 351.56 1000sqft 39.80 351,560.00 0
Parking Lot 705.00 Space 2.23 0.00 0

1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
3 Wind Speed (m/s) 1.9 Precipitation Freq (Days) 31

1.3 User Entered Comments & Non-Default Data

1.0 Project Characteristics
Utility Company Pacific Gas and Electric Company
Operational Year 2026
CO2 Intensity
(lb/MWhr)
203.98 CH4 Intensity 0.033
(lb/MWhr)
N2O Intensity 0.004
(lb/MWhr)
Table Name Column Name Default Value New Value
tblConstructionPhase NumDays 55.00 9.00
CalEEMod Version: CalEEMod.2020.4.0 Page 1 of 30 Date: 2/15/2024 10:26 AM East Huntsman Avenue Industrial Park Project - Fresno County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied $WWDFKPHQW%
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2.0 Emissions Summary
tblConstructionPhase NumDays 740.00 119.00
tblConstructionPhase NumDays 75.00 12.00
tblConstructionPhase NumDays 55.00 9.00
tblConstructionPhase NumDays 30.00 5.00
tblConstructionPhase PhaseEndDate 1/26/2029 11/23/2028
tblConstructionPhase PhaseEndDate 8/25/2028 4/9/2026
tblConstructionPhase PhaseEndDate 10/24/2025 7/29/2025
tblConstructionPhase PhaseEndDate 11/10/2028 9/7/2028
tblConstructionPhase PhaseEndDate 7/11/2025 6/6/2025
tblGrading AcresOfGrading 36.00 60.00
tblGrading AcresOfGrading 7.50 15.00
tblLandUse LandUseSquareFeet 282,000.00 0.00
tblLandUse LotAcreage 8.07 39.80
tblLandUse LotAcreage 6.34 2.23
tblProjectCharacteristics PrecipitationFrequency 45 31
tblProjectCharacteristics WindSpeed 2.2 1.9
tblVehicleTrips ST_TR 2.54 1.97
tblVehicleTrips SU_TR 1.24 1.97
tblVehicleTrips WD_TR 3.37 1.97
CalEEMod Version: CalEEMod.2020.4.0 Page 2 of 30 Date: 2/15/2024 10:26 AM East Huntsman Avenue Industrial Park Project - Fresno County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied Le�er - 2

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2.1 Overall Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year tons/yr MT/yr
2025 0.0677 0.5968 0.6813 1.6200e0030.1603 0.0227 0.1830 0.0596 0.0212 0.0808 0.0000 144.3787 144.3787 0.0271 4.4700e003146.3869 2026 0.0637 0.5397 0.6965 1.6700e0030.0561 0.0195 0.0756 0.0152 0.0183 0.0336 0.0000 149.7260 149.7260 0.0203 6.4100e003152.1420 2028 2.4525 0.0440 0.0772 1.3000e0041.6300e0032.1200e0033.7500e0034.3000e0041.9700e0032.4000e0030.0000 11.2480 11.2480 3.0000e0033.0000e00511.3310 Maximum 2.4525 0.5968 0.6965 1.6700e0030.1603 0.0227 0.1830 0.0596 0.0212 0.0808 0.0000 149.7260 149.7260 0.0271 6.4100e003152.1420 Unmitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year tons/yr MT/yr
2025 0.0677 0.5968 0.6813 1.6200e0030.1603 0.0227 0.1830 0.0596 0.0212 0.0808 0.0000 144.3786 144.3786 0.0271 4.4700e003146.3868 2026 0.0637 0.5397 0.6965 1.6700e0030.0561 0.0195 0.0756 0.0152 0.0183 0.0336 0.0000 149.7259 149.7259 0.0203 6.4100e003152.1419 2028 2.4525 0.0440 0.0772 1.3000e0041.6300e0032.1200e0033.7500e0034.3000e0041.9700e0032.4000e0030.0000 11.2480 11.2480 3.0000e0033.0000e00511.3310 Maximum 2.4525 0.5968 0.6965 1.6700e0030.1603 0.0227 0.1830 0.0596 0.0212 0.0808 0.0000 149.7259 149.7259 0.0271 6.4100e003152.1419 Mitigated Construction
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ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Quarter Start Date End Date Maximum Unmitigated ROG + NOX (tons/quarter) Maximum Mitigated ROG + NOX (tons/quarter) 1 6-1-2025 8-31-2025 0.2584 0.2584
2 9-1-2025 11-30-2025 0.2267 0.2267
3 12-1-2025 2-28-2026 0.5499 0.5499
4 3-1-2026 5-31-2026 0.2436 0.2436
13 6-1-2028 8-31-2028 0.0219 0.0219
14 9-1-2028 9-30-2028 0.0255 0.0255
Highest 0.5499 0.5499
CalEEMod Version: CalEEMod.2020.4.0 Page 4 of 30 Date: 2/15/2024 10:26 AM East Huntsman Avenue Industrial Park Project - Fresno County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied Le�er - 2

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2.2 Overall Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Area 1.6183 9.0000e0059.6800e0030.0000 3.0000e0053.0000e0053.0000e0053.0000e0050.0000 0.0189 0.0189 5.0000e0050.0000 0.0201 Energy 0.0245 0.2227 0.1870 1.3400e0030.0169 0.0169 0.0169 0.0169 0.0000 529.9312 529.9312 0.0512 0.0101 534.2149 Mobile 0.2934 0.4773 2.6791 6.4700e0030.6848 5.3100e0030.6902 0.1831 4.9800e0030.1881 0.0000 599.1200 599.1200 0.0316 0.0333 609.8284 Waste 0.0000 0.0000 0.0000 0.0000 88.4899 0.0000 88.4899 5.2296 0.0000 219.2299 Water 0.0000 0.0000 0.0000 0.0000 25.7922 40.7017 66.4938 2.6557 0.0634 151.7642 Total 1.9363 0.7001 2.8758 7.8100e0030.6848 0.0223 0.7071 0.1831 0.0219 0.2050 114.2820 1,169.771 7 1,284.053
7 7.9681 0.1067 1,515.057
4 Unmitigated Operational
CalEEMod Version: CalEEMod.2020.4.0 Page 5 of 30 Date: 2/15/2024 10:26 AM East Huntsman Avenue Industrial Park Project - Fresno County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied Le�er - 2

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0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 CalEEMod Version: CalEEMod.2020.4.0 Page 6 of 30 Date: 2/15/2024 10:26 AM East Huntsman Avenue Industrial Park Project - Fresno County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied Le�er - 2

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4 Paving Paving 8/26/2028 9/7/2028 5 9
5 Architectural Coating Architectural Coating 11/11/2028 11/23/2028 5 9 OffRoad Equipment
Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor Site Preparation Rubber Tired Dozers 3 8.00 247 0.40
Site Preparation Tractors/Loaders/Backhoes 4 8.00 97 0.37 Grading Excavators 2 8.00 158 0.38
Grading Graders 1 8.00 187 0.41
Grading Rubber Tired Dozers 1 8.00 247 0.40
Grading Scrapers 2 8.00 367 0.48
Grading Tractors/Loaders/Backhoes 2 8.00 97 0.37
Building Construction Cranes 1 7.00 231 0.29
Building Construction Forklifts 3 8.00 89 0.20
Building Construction Generator Sets 1 8.00 84 0.74
Building Construction Tractors/Loaders/Backhoes 3 7.00 97 0.37 Building Construction Welders 1 8.00 46 0.45
Paving Pavers 2 8.00 130 0.42
Paving Paving Equipment 2 8.00 132 0.36
Paving Rollers 2 8.00 80 0.38
Architectural Coating Air Compressors 1 6.00 78 0.48
Trips and VMT
Residential Indoor: 0; Residential Outdoor: 0; Non-Residential Indoor: 527,340; Non-Residential Outdoor: 175,780; Striped Parking Area: 0 (Architectural Coating – sqft)
Acres of Grading (Site Preparation Phase): 15
Acres of Grading (Grading Phase): 60
Acres of Paving: 2.23
CalEEMod Version: CalEEMod.2020.4.0 Page 7 of 30 Date: 2/15/2024 10:26 AM East Huntsman Avenue Industrial Park Project - Fresno County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied Le�er - 2

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3.1 Mitigation Measures Construction
Phase Name Offroad Equipment
Count
Worker Trip
Number
Vendor Trip
Number
Hauling Trip
Number
Worker Trip
Length
Vendor Trip
Length
Hauling Trip
Length
Worker Vehicle
Class
Vendor
Vehicle Class
Hauling
Vehicle Class
Site Preparation 7 18.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT Grading 8 20.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT Building Construction 9 148.00 58.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT Paving 6 15.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT Architectural Coating 1 30.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT CalEEMod Version: CalEEMod.2020.4.0 Page 8 of 30 Date: 2/15/2024 10:26 AM East Huntsman Avenue Industrial Park Project - Fresno County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied Le�er - 2

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3.2 Site Preparation - 2025
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 1.2000e0047.0000e0059.1000e0040.0000 3.6000e0040.0000 3.6000e0041.0000e0040.0000 1.0000e0040.0000 0.2644 0.2644 1.0000e0051.0000e0050.2667 Total 1.2000e0047.0000e0059.1000e0040.0000 3.6000e0040.0000 3.6000e0041.0000e0040.0000 1.0000e0040.0000 0.2644 0.2644 1.0000e0051.0000e0050.2667 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 0.0531 0.0000 0.0531 0.0257 0.0000 0.0257 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 6.1800e0030.0631 0.0448 1.0000e0042.7200e0032.7200e0032.5000e0032.5000e0030.0000 8.3667 8.3667 2.7100e0030.0000 8.4344 Total 6.1800e0030.0631 0.0448 1.0000e0040.0531 2.7200e0030.0558 0.0257 2.5000e0030.0282 0.0000 8.3667 8.3667 2.7100e0030.0000 8.4344 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 9 of 30 Date: 2/15/2024 10:26 AM East Huntsman Avenue Industrial Park Project - Fresno County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied Le�er - 2

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3.3 Grading - 2025
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 0.0680 0.0000 0.0680 0.0233 0.0000 0.0233 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0174 0.1677 0.1580 3.7000e0046.7900e0036.7900e0036.2400e0036.2400e0030.0000 32.7037 32.7037 0.0106 0.0000 32.9682 Total 0.0174 0.1677 0.1580 3.7000e0040.0680 6.7900e0030.0747 0.0233 6.2400e0030.0295 0.0000 32.7037 32.7037 0.0106 0.0000 32.9682 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 10 of 30 Date: 2/15/2024 10:26 AM East Huntsman Avenue Industrial Park Project - Fresno County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied Le�er - 2

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3.3 Grading - 2025
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 3.2000e0041.9000e0042.4200e0031.0000e0059.7000e0040.0000 9.7000e0042.6000e0040.0000 2.6000e0040.0000 0.7050 0.7050 2.0000e0052.0000e0050.7111 Total 3.2000e0041.9000e0042.4200e0031.0000e0059.7000e0040.0000 9.7000e0042.6000e0040.0000 2.6000e0040.0000 0.7050 0.7050 2.0000e0052.0000e0050.7111 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 0.0680 0.0000 0.0680 0.0233 0.0000 0.0233 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0174 0.1677 0.1580 3.7000e0046.7900e0036.7900e0036.2400e0036.2400e0030.0000 32.7037 32.7037 0.0106 0.0000 32.9681 Total 0.0174 0.1677 0.1580 3.7000e0040.0680 6.7900e0030.0747 0.0233 6.2400e0030.0295 0.0000 32.7037 32.7037 0.0106 0.0000 32.9681 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 11 of 30 Date: 2/15/2024 10:26 AM East Huntsman Avenue Industrial Park Project - Fresno County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied Le�er - 2

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3.4 Building Construction - 2025
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.0328 0.2993 0.3860 6.5000e0040.0127 0.0127 0.0119 0.0119 0.0000 55.6607 55.6607 0.0131 0.0000 55.9878 Total 0.0328 0.2993 0.3860 6.5000e0040.0127 0.0127 0.0119 0.0119 0.0000 55.6607 55.6607 0.0131 0.0000 55.9878 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 12 of 30 Date: 2/15/2024 10:26 AM East Huntsman Avenue Industrial Park Project - Fresno County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied Le�er - 2

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3.4 Building Construction - 2025
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 1.4200e0030.0609 0.0175 2.7000e0049.2900e0033.9000e0049.6900e0032.6800e0033.8000e0043.0600e0030.0000 25.8090 25.8090 1.3000e0043.8800e00326.9698 Worker 9.4500e0035.5800e0030.0717 2.3000e0040.0286 1.2000e0040.0288 7.6100e0031.1000e0047.7200e0030.0000 20.8691 20.8691 5.5000e0045.6000e00421.0490 Total 0.0109 0.0665 0.0892 5.0000e0040.0379 5.1000e0040.0385 0.0103 4.9000e0040.0108 0.0000 46.6781 46.6781 6.8000e0044.4400e00348.0188 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.0328 0.2993 0.3860 6.5000e0040.0127 0.0127 0.0119 0.0119 0.0000 55.6606 55.6606 0.0131 0.0000 55.9877 Total 0.0328 0.2993 0.3860 6.5000e0040.0127 0.0127 0.0119 0.0119 0.0000 55.6606 55.6606 0.0131 0.0000 55.9877 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 13 of 30 Date: 2/15/2024 10:26 AM East Huntsman Avenue Industrial Park Project - Fresno County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied Le�er - 2

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3.4 Building Construction - 2026
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.0485 0.4427 0.5710 9.6000e0040.0187 0.0187 0.0176 0.0176 0.0000 82.3314 82.3314 0.0194 0.0000 82.8153 Total 0.0485 0.4427 0.5710 9.6000e0040.0187 0.0187 0.0176 0.0176 0.0000 82.3314 82.3314 0.0194 0.0000 82.8153 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 14 of 30 Date: 2/15/2024 10:26 AM East Huntsman Avenue Industrial Park Project - Fresno County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied Le�er - 2

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3.4 Building Construction - 2026
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 2.0500e0030.0896 0.0255 3.9000e0040.0138 5.8000e0040.0143 3.9700e0035.6000e0044.5200e0030.0000 37.4239 37.4239 1.8000e0045.6300e00339.1065 Worker 0.0131 7.4300e0030.1000 3.3000e0040.0424 1.8000e0040.0425 0.0113 1.6000e0040.0114 0.0000 29.9707 29.9707 7.4000e0047.8000e00430.2203 Total 0.0151 0.0970 0.1255 7.2000e0040.0561 7.6000e0040.0569 0.0152 7.2000e0040.0159 0.0000 67.3946 67.3946 9.2000e0046.4100e00369.3267 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.0485 0.4427 0.5710 9.6000e0040.0187 0.0187 0.0176 0.0176 0.0000 82.3313 82.3313 0.0194 0.0000 82.8152 Total 0.0485 0.4427 0.5710 9.6000e0040.0187 0.0187 0.0176 0.0176 0.0000 82.3313 82.3313 0.0194 0.0000 82.8152 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 15 of 30 Date: 2/15/2024 10:26 AM East Huntsman Avenue Industrial Park Project - Fresno County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied Le�er - 2

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3.5 Paving - 2028
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 4.1200e0030.0386 0.0656 1.0000e0041.8800e0031.8800e0031.7300e0031.7300e0030.0000 9.0087 9.0087 2.9100e0030.0000 9.0815 Paving 2.9200e0030.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 7.0400e0030.0386 0.0656 1.0000e0041.8800e0031.8800e0031.7300e0031.7300e0030.0000 9.0087 9.0087 2.9100e0030.0000 9.0815 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 16 of 30 Date: 2/15/2024 10:26 AM East Huntsman Avenue Industrial Park Project - Fresno County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied Le�er - 2

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3.5 Paving - 2028
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 1.5000e0048.0000e0051.1500e0030.0000 5.4000e0040.0000 5.5000e0041.4000e0040.0000 1.5000e0040.0000 0.3634 0.3634 1.0000e0051.0000e0050.3663 Total 1.5000e0048.0000e0051.1500e0030.0000 5.4000e0040.0000 5.5000e0041.4000e0040.0000 1.5000e0040.0000 0.3634 0.3634 1.0000e0051.0000e0050.3663 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 4.1200e0030.0386 0.0656 1.0000e0041.8800e0031.8800e0031.7300e0031.7300e0030.0000 9.0087 9.0087 2.9100e0030.0000 9.0815 Paving 2.9200e0030.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 7.0400e0030.0386 0.0656 1.0000e0041.8800e0031.8800e0031.7300e0031.7300e0030.0000 9.0087 9.0087 2.9100e0030.0000 9.0815 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 17 of 30 Date: 2/15/2024 10:26 AM East Huntsman Avenue Industrial Park Project - Fresno County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied Le�er - 2

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3.6 Architectural Coating - 2028
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 3.0000e0041.6000e0042.3000e0031.0000e0051.0900e0030.0000 1.0900e0032.9000e0040.0000 2.9000e0040.0000 0.7269 0.7269 2.0000e0052.0000e0050.7326 Total 3.0000e0041.6000e0042.3000e0031.0000e0051.0900e0030.0000 1.0900e0032.9000e0040.0000 2.9000e0040.0000 0.7269 0.7269 2.0000e0052.0000e0050.7326 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Archit. Coating 2.4442 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 7.7000e0045.1500e0038.1400e0031.0000e0052.3000e0042.3000e0042.3000e0042.3000e0040.0000 1.1490 1.1490 6.0000e0050.0000 1.1505 Total 2.4450 5.1500e0038.1400e0031.0000e0052.3000e0042.3000e0042.3000e0042.3000e0040.0000 1.1490 1.1490 6.0000e0050.0000 1.1505 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 19 of 30 Date: 2/15/2024 10:26 AM East Huntsman Avenue Industrial Park Project - Fresno County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied Le�er - 2

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4.0 Operational Detail - Mobile

4.1 Mitigation Measures Mobile
CalEEMod Version: CalEEMod.2020.4.0 Page 20 of 30 Date: 2/15/2024 10:26 AM East Huntsman Avenue Industrial Park Project - Fresno County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied Le�er - 2

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ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Mitigated 0.2934 0.4773 2.6791 6.4700e0030.6848 5.3100e0030.6902 0.1831 4.9800e0030.1881 0.0000 599.1200 599.1200 0.0316 0.0333 609.8284 Unmitigated 0.2934 0.4773 2.6791 6.4700e0030.6848 5.3100e0030.6902 0.1831 4.9800e0030.1881 0.0000 599.1200 599.1200 0.0316 0.0333 609.8284

4.2 Trip Summary Information

4.3 Trip Type Information
Average Daily Trip Rate Unmitigated Mitigated
Land Use Weekday Saturday Sunday Annual VMT Annual VMT
Industrial Park 690.99 690.99 690.99 1,811,660 1,811,660 Parking Lot 0.00 0.00 0.00
Total 690.99 690.99 690.99 1,811,660 1,811,660
Miles Trip % Trip Purpose %
Land Use H-W or C-W H-S or C-C H-O or C-NW H-W or C-W H-S or C-C H-O or C-NW Primary Diverted Pass-by Industrial Park 9.50 7.30 7.30 59.00 28.00 13.00 79 19 2 Parking Lot 9.50 7.30 7.30 0.00 0.00 0.00 0 0 0

4.4 Fleet Mix
Land Use LDA LDT1 LDT2 MDV LHD1 LHD2 MHD HHD OBUS UBUS MCY SBUS MH Industrial Park 0.526576 0.053500 0.175633 0.147803 0.024189 0.006487 0.014618 0.022827 0.000697 0.000286 0.023187 0.001433 0.002764 Parking Lot 0.526576 0.053500 0.175633 0.147803 0.024189 0.006487 0.014618 0.022827 0.000697 0.000286 0.023187 0.001433 0.002764

5.0 Energy Detail
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ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Electricity
Mitigated

0.0000 0.0000 0.0000 0.0000 0.0000 287.5445 287.5445 0.0465 5.6400e003290.3878 Electricity
Unmitigated

0.0000 0.0000 0.0000 0.0000 0.0000 287.5445 287.5445 0.0465 5.6400e003290.3878 NaturalGas
Mitigated

0.0245 0.2227 0.1870 1.3400e0030.0169 0.0169 0.0169 0.0169 0.0000 242.3867 242.3867 4.6500e0034.4400e003243.8271 NaturalGas
Unmitigated

0.0245 0.2227 0.1870 1.3400e0030.0169 0.0169 0.0169 0.0169 0.0000 242.3867 242.3867 4.6500e0034.4400e003243.8271

5.1 Mitigation Measures Energy
Historical Energy Use: N
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0.0245 0.2227 0.1870 1.3400e0030.0169 0.0169 0.0169 0.0169 0.0000 242.3867 242.3867 4.6500e0034.4400e003243.8271 Parking Lot 0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0245 0.2227 0.1870 1.3400e0030.0169 0.0169 0.0169 0.0169 0.0000 242.3867 242.3867 4.6500e0034.4400e003243.8271 Unmitigated
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr tons/yr MT/yr
Industrial Park 4.54216e
+006

0.0245 0.2227 0.1870 1.3400e0030.0169 0.0169 0.0169 0.0169 0.0000 242.3867 242.3867 4.6500e0034.4400e003243.8271 Parking Lot 0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0245 0.2227 0.1870 1.3400e0030.0169 0.0169 0.0169 0.0169 0.0000 242.3867 242.3867 4.6500e0034.4400e003243.8271 Mitigated
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6.0 Area Detail

5.3 Energy by Land Use - Electricity
Electricity
Use
Total CO2 CH4 N2O CO2e
Land Use kWh/yr MT/yr
Industrial Park 3.10779e
+006
287.5445 0.0465 5.6400e003290.3878
Parking Lot 0 0.0000 0.0000 0.0000 0.0000
Total 287.5445 0.0465 5.6400e003290.3878
Unmitigated
Electricity
Use
Total CO2 CH4 N2O CO2e
Land Use kWh/yr MT/yr
Industrial Park 3.10779e
+006
287.5445 0.0465 5.6400e003290.3878
Parking Lot 0 0.0000 0.0000 0.0000 0.0000
Total 287.5445 0.0465 5.6400e003290.3878
Mitigated
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6.1 Mitigation Measures Area
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Mitigated 1.6183 9.0000e0059.6800e0030.0000 3.0000e0053.0000e0053.0000e0053.0000e0050.0000 0.0189 0.0189 5.0000e0050.0000 0.0201 Unmitigated 1.6183 9.0000e0059.6800e0030.0000 3.0000e0053.0000e0053.0000e0053.0000e0050.0000 0.0189 0.0189 5.0000e0050.0000 0.0201

6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory tons/yr MT/yr
Architectural
Coating

0.2444 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Consumer
Products

1.3730 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Landscaping 8.9000e0049.0000e0059.6800e0030.0000 3.0000e0053.0000e0053.0000e0053.0000e0050.0000 0.0189 0.0189 5.0000e0050.0000 0.0201 Total 1.6183 9.0000e0059.6800e0030.0000 3.0000e0053.0000e0053.0000e0053.0000e0050.0000 0.0189 0.0189 5.0000e0050.0000 0.0201 Unmitigated
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7.1 Mitigation Measures Water

7.0 Water Detail

0.2444 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Consumer
Products

1.3730 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Landscaping 8.9000e0049.0000e0059.6800e0030.0000 3.0000e0053.0000e0053.0000e0053.0000e0050.0000 0.0189 0.0189 5.0000e0050.0000 0.0201 Total 1.6183 9.0000e0059.6800e0030.0000 3.0000e0053.0000e0053.0000e0053.0000e0050.0000 0.0189 0.0189 5.0000e0050.0000 0.0201 Mitigated
CalEEMod Version: CalEEMod.2020.4.0 Page 26 of 30 Date: 2/15/2024 10:26 AM East Huntsman Avenue Industrial Park Project - Fresno County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied Le�er - 2

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Total CO2 CH4 N2O CO2e
Category MT/yr
Mitigated 66.4938 2.6557 0.0634 151.7642
Unmitigated 66.4938 2.6557 0.0634 151.7642

7.2 Water by Land Use
Indoor/Out
door Use
Total CO2 CH4 N2O CO2e
Land Use Mgal MT/yr
Industrial Park 81.2982 /
0 66.4938 2.6557 0.0634 151.7642
Parking Lot 0 / 0 0.0000 0.0000 0.0000 0.0000
Total 66.4938 2.6557 0.0634 151.7642
Unmitigated
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8.1 Mitigation Measures Waste

8.0 Waste Detail
Total CO2 CH4 N2O CO2e
MT/yr
Mitigated 88.4899 5.2296 0.0000 219.2299
Unmitigated 88.4899 5.2296 0.0000 219.2299
Category/Year
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8.2 Waste by Land Use
Waste
Disposed
Total CO2 CH4 N2O CO2e
Land Use tons MT/yr
Industrial Park 435.93 88.4899 5.2296 0.0000 219.2299
Parking Lot 0 0.0000 0.0000 0.0000 0.0000
Total 88.4899 5.2296 0.0000 219.2299
Unmitigated
Waste
Disposed
Total CO2 CH4 N2O CO2e
Land Use tons MT/yr
Industrial Park 435.93 88.4899 5.2296 0.0000 219.2299
Parking Lot 0 0.0000 0.0000 0.0000 0.0000
Total 88.4899 5.2296 0.0000 219.2299
Mitigated

9.0 Operational Offroad
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11.0 Vegetation
Equipment Type Number Hours/Day Days/Year Horse Power Load Factor Fuel Type

10.0 Stationary Equipment
Fire Pumps and Emergency Generators
Equipment Type Number Hours/Day Hours/Year Horse Power Load Factor Fuel Type Boilers
Equipment Type Number Heat Input/Day Heat Input/Year Boiler Rating Fuel Type User Defined Equipment
Equipment Type Number
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East Huntsman Avenue Industrial Park Project
Fresno County, Summer
Project Characteristics - Consistent with the IS/MND's model.

Land Use - Consistent with the IS/MND's model.

Construction Phase - See SWAPE's comment on "Unsubstantiated Changes to Individual Construction Phase Lengths." Off-road Equipment -
Grading - Consistent with the IS/MND's model.

Fleet Mix - See SWAPE's comment on "Unsubstantiated Changes to Operational Fleet Mix Values." Vehicle Trips - Consistent with the IS/MND's model.

Construction Off-road Equipment Mitigation - See SWAPES's comment on "Incorrect Application of Tier 4 Final Off-Road Equipment Mitigation."

1.1 Land Usage
Land Uses Size Metric Lot Acreage Floor Surface Area Population Industrial Park 351.56 1000sqft 39.80 351,560.00 0
Parking Lot 705.00 Space 2.23 0.00 0

1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
3 Wind Speed (m/s) 1.9 Precipitation Freq (Days) 31

1.3 User Entered Comments & Non-Default Data

1.0 Project Characteristics
Utility Company Pacific Gas and Electric Company
Operational Year 2026
CO2 Intensity
(lb/MWhr)
203.98 CH4 Intensity 0.033
(lb/MWhr)
N2O Intensity 0.004
(lb/MWhr)
Table Name Column Name Default Value New Value
tblConstructionPhase NumDays 55.00 9.00
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2.0 Emissions Summary
tblConstructionPhase NumDays 740.00 119.00
tblConstructionPhase NumDays 75.00 12.00
tblConstructionPhase NumDays 55.00 9.00
tblConstructionPhase NumDays 30.00 5.00
tblConstructionPhase PhaseEndDate 1/26/2029 11/23/2028
tblConstructionPhase PhaseEndDate 8/25/2028 4/9/2026
tblConstructionPhase PhaseEndDate 10/24/2025 7/29/2025
tblConstructionPhase PhaseEndDate 11/10/2028 9/7/2028
tblConstructionPhase PhaseEndDate 7/11/2025 6/6/2025
tblGrading AcresOfGrading 36.00 60.00
tblGrading AcresOfGrading 7.50 15.00
tblLandUse LandUseSquareFeet 282,000.00 0.00
tblLandUse LotAcreage 8.07 39.80
tblLandUse LotAcreage 6.34 2.23
tblProjectCharacteristics PrecipitationFrequency 45 31
tblProjectCharacteristics WindSpeed 2.2 1.9
tblVehicleTrips ST_TR 2.54 1.97
tblVehicleTrips SU_TR 1.24 1.97
tblVehicleTrips WD_TR 3.37 1.97
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2.1 Overall Construction (Maximum Daily Emission)
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year lb/day lb/day
2025 2.9625 27.9723 26.7948 0.0635 21.3956 1.1316 22.4830 10.3134 1.0411 11.3139 0.0000 6,149.063 5 6,149.063
5 1.9465 0.2027 6,198.711
6 2026 1.8508 15.0800 20.0246 0.0480 1.6090 0.5489 2.1578 0.4357 0.5164 0.9521 0.0000 4,728.893 5 4,728.893
5 0.6286 0.1977 4,803.517
2 2028 543.4063 8.5981 14.8700 0.0238 0.2464 0.4190 0.5422 0.0654 0.3855 0.4181 0.0000 2,303.470 4 2,303.470
4 0.7156 4.2100e0032,321.986
5 Maximum 543.4063 27.9723 26.7948 0.0635 21.3956 1.1316 22.4830 10.3134 1.0411 11.3139 0.0000 6,149.063 5 6,149.063
5 1.9465 0.2027 6,198.711
6 Unmitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year lb/day lb/day
2025 2.9625 27.9723 26.7948 0.0635 21.3956 1.1316 22.4830 10.3134 1.0411 11.3139 0.0000 6,149.063 5 6,149.063
5 1.9465 0.2027 6,198.711
6 2026 1.8508 15.0800 20.0246 0.0480 1.6090 0.5489 2.1578 0.4357 0.5164 0.9521 0.0000 4,728.893 5 4,728.893
5 0.6286 0.1977 4,803.517
2 2028 543.4063 8.5981 14.8700 0.0238 0.2464 0.4190 0.5422 0.0654 0.3855 0.4181 0.0000 2,303.470 4 2,303.470
4 0.7156 4.2100e0032,321.986
5 Maximum 543.4063 27.9723 26.7948 0.0635 21.3956 1.1316 22.4830 10.3134 1.0411 11.3139 0.0000 6,149.063 5 6,149.063
5 1.9465 0.2027 6,198.711
6 Mitigated Construction
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ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 CalEEMod Version: CalEEMod.2020.4.0 Page 4 of 25 Date: 2/15/2024 10:10 AM East Huntsman Avenue Industrial Park Project - Fresno County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied Le�er - 2

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2.2 Overall Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Area 8.8726 9.7000e0040.1076 1.0000e0053.8000e0043.8000e0043.8000e0043.8000e0040.2312 0.2312 6.0000e0040.2463 Energy 0.1342 1.2200 1.0248 7.3200e0030.0927 0.0927 0.0927 0.0927 1,464.030 7 1,464.030
7 0.0281 0.0268 1,472.730
7 Mobile 1.9609 2.4698 15.6975 0.0378 3.8327 0.0292 3.8619 1.0231 0.0274 1.0505 3,857.022 6 3,857.022
6 0.1820 0.1967 3,920.172
8 Total 10.9676 3.6908 16.8299 0.0452 3.8327 0.1223 3.9550 1.0231 0.1205 1.1436 5,321.284 5 5,321.284
5 0.2106 0.2235 5,393.149
7 Unmitigated Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Area 8.8726 9.7000e0040.1076 1.0000e0053.8000e0043.8000e0043.8000e0043.8000e0040.2312 0.2312 6.0000e0040.2463 Energy 0.1342 1.2200 1.0248 7.3200e0030.0927 0.0927 0.0927 0.0927 1,464.030 7 1,464.030
7 0.0281 0.0268 1,472.730
7 Mobile 1.9609 2.4698 15.6975 0.0378 3.8327 0.0292 3.8619 1.0231 0.0274 1.0505 3,857.022 6 3,857.022
6 0.1820 0.1967 3,920.172
8 Total 10.9676 3.6908 16.8299 0.0452 3.8327 0.1223 3.9550 1.0231 0.1205 1.1436 5,321.284 5 5,321.284
5 0.2106 0.2235 5,393.149
7 Mitigated Operational
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3.0 Construction Detail
Construction Phase
Phase
Number
Phase Name Phase Type Start Date End Date Num Days
Week
Num Days Phase Description
1 Site Preparation Site Preparation 6/1/2025 6/6/2025 5 5 2 Grading Grading 7/12/2025 7/29/2025 5 12
3 Building Construction Building Construction 10/25/2025 4/9/2026 5 119 4 Paving Paving 8/26/2028 9/7/2028 5 9
5 Architectural Coating Architectural Coating 11/11/2028 11/23/2028 5 9 OffRoad Equipment
Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor Site Preparation Rubber Tired Dozers 3 8.00 247 0.40
Site Preparation Tractors/Loaders/Backhoes 4 8.00 97 0.37 Grading Excavators 2 8.00 158 0.38
Grading Graders 1 8.00 187 0.41
Grading Rubber Tired Dozers 1 8.00 247 0.40
Grading Scrapers 2 8.00 367 0.48
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Residential Indoor: 0; Residential Outdoor: 0; Non-Residential Indoor: 527,340; Non-Residential Outdoor: 175,780; Striped Parking Area: 0 (Architectural Coating – sqft)
Acres of Grading (Site Preparation Phase): 15
Acres of Grading (Grading Phase): 60
Acres of Paving: 2.23
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3.1 Mitigation Measures Construction
Grading Tractors/Loaders/Backhoes 2 8.00 97 0.37
Building Construction Cranes 1 7.00 231 0.29
Building Construction Forklifts 3 8.00 89 0.20
Building Construction Generator Sets 1 8.00 84 0.74
Building Construction Tractors/Loaders/Backhoes 3 7.00 97 0.37 Building Construction Welders 1 8.00 46 0.45
Paving Pavers 2 8.00 130 0.42
Paving Paving Equipment 2 8.00 132 0.36
Paving Rollers 2 8.00 80 0.38
Architectural Coating Air Compressors 1 6.00 78 0.48
Trips and VMT
Phase Name Offroad Equipment
Count
Worker Trip
Number
Vendor Trip
Number
Hauling Trip
Number
Worker Trip
Length
Vendor Trip
Length
Hauling Trip
Length
Worker Vehicle
Class
Vendor
Vehicle Class
Hauling
Vehicle Class
Site Preparation 7 18.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT Grading 8 20.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT Building Construction 9 148.00 58.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT Paving 6 15.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT Architectural Coating 1 30.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT CalEEMod Version: CalEEMod.2020.4.0 Page 7 of 25 Date: 2/15/2024 10:10 AM East Huntsman Avenue Industrial Park Project - Fresno County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied Le�er - 2

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3.2 Site Preparation - 2025
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 21.2478 0.0000 21.2478 10.2742 0.0000 10.2742 0.0000 0.0000 Off-Road 2.4727 25.2339 17.9118 0.0381 1.0868 1.0868 0.9999 0.9999 3,689.103 7 3,689.103
7 1.1931 3,718.932
0 Total 2.4727 25.2339 17.9118 0.0381 21.2478 1.0868 22.3346 10.2742 0.9999 11.2741 3,689.103 7 3,689.103
7 1.1931 3,718.932
0 Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0552 0.0265 0.4173 1.2500e0030.1479 6.2000e0040.1485 0.0392 5.7000e0040.0398 126.7039 126.7039 2.9300e0032.9800e003127.6652 Total 0.0552 0.0265 0.4173 1.2500e0030.1479 6.2000e0040.1485 0.0392 5.7000e0040.0398 126.7039 126.7039 2.9300e0032.9800e003127.6652 Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 8 of 25 Date: 2/15/2024 10:10 AM East Huntsman Avenue Industrial Park Project - Fresno County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied Le�er - 2

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2-18

3.2 Site Preparation - 2025
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 21.2478 0.0000 21.2478 10.2742 0.0000 10.2742 0.0000 0.0000 Off-Road 2.4727 25.2339 17.9118 0.0381 1.0868 1.0868 0.9999 0.9999 0.0000 3,689.103 7 3,689.103
7 1.1931 3,718.932
0 Total 2.4727 25.2339 17.9118 0.0381 21.2478 1.0868 22.3346 10.2742 0.9999 11.2741 0.0000 3,689.103 7 3,689.103
7 1.1931 3,718.932
0 Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0552 0.0265 0.4173 1.2500e0030.1479 6.2000e0040.1485 0.0392 5.7000e0040.0398 126.7039 126.7039 2.9300e0032.9800e003127.6652 Total 0.0552 0.0265 0.4173 1.2500e0030.1479 6.2000e0040.1485 0.0392 5.7000e0040.0398 126.7039 126.7039 2.9300e0032.9800e003127.6652 Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 9 of 25 Date: 2/15/2024 10:10 AM East Huntsman Avenue Industrial Park Project - Fresno County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied Le�er - 2

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2-18

3.3 Grading - 2025
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 11.3246 0.0000 11.3246 3.8828 0.0000 3.8828 0.0000 0.0000 Off-Road 2.9012 27.9429 26.3311 0.0621 1.1309 1.1309 1.0404 1.0404 6,008.281 4 6,008.281
4 1.9432 6,056.861
4 Total 2.9012 27.9429 26.3311 0.0621 11.3246 1.1309 12.4555 3.8828 1.0404 4.9232 6,008.281 4 6,008.281
4 1.9432 6,056.861
4 Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0613 0.0294 0.4637 1.3900e0030.1643 6.9000e0040.1650 0.0436 6.4000e0040.0442 140.7821 140.7821 3.2600e0033.3100e003141.8502 Total 0.0613 0.0294 0.4637 1.3900e0030.1643 6.9000e0040.1650 0.0436 6.4000e0040.0442 140.7821 140.7821 3.2600e0033.3100e003141.8502 Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 10 of 25 Date: 2/15/2024 10:10 AM East Huntsman Avenue Industrial Park Project - Fresno County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied Le�er - 2

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2-18

3.3 Grading - 2025
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 11.3246 0.0000 11.3246 3.8828 0.0000 3.8828 0.0000 0.0000 Off-Road 2.9012 27.9429 26.3311 0.0621 1.1309 1.1309 1.0404 1.0404 0.0000 6,008.281 4 6,008.281
4 1.9432 6,056.861
4 Total 2.9012 27.9429 26.3311 0.0621 11.3246 1.1309 12.4555 3.8828 1.0404 4.9232 0.0000 6,008.281 4 6,008.281
4 1.9432 6,056.861
4 Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0613 0.0294 0.4637 1.3900e0030.1643 6.9000e0040.1650 0.0436 6.4000e0040.0442 140.7821 140.7821 3.2600e0033.3100e003141.8502 Total 0.0613 0.0294 0.4637 1.3900e0030.1643 6.9000e0040.1650 0.0436 6.4000e0040.0442 140.7821 140.7821 3.2600e0033.3100e003141.8502 Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 11 of 25 Date: 2/15/2024 10:10 AM East Huntsman Avenue Industrial Park Project - Fresno County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied Le�er - 2

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2-18

3.4 Building Construction - 2025
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 1.3674 12.4697 16.0847 0.0270 0.5276 0.5276 0.4963 0.4963 2,556.474 4 2,556.474
4 0.6010 2,571.498
1 Total 1.3674 12.4697 16.0847 0.0270 0.5276 0.5276 0.4963 0.4963 2,556.474 4 2,556.474
4 0.6010 2,571.498
1 Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0612 2.4286 0.7196 0.0112 0.3932 0.0164 0.4096 0.1132 0.0157 0.1289 1,184.434 4 1,184.434
4 6.0500e0030.1782 1,237.685
3 Worker 0.4537 0.2175 3.4314 0.0103 1.2158 5.1400e0031.2209 0.3225 4.7300e0030.3272 1,041.787 4 1,041.787
4 0.0241 0.0245 1,049.691
3 Total 0.5149 2.6460 4.1510 0.0215 1.6090 0.0216 1.6305 0.4357 0.0204 0.4561 2,226.221 8 2,226.221
8 0.0301 0.2027 2,287.376
6 Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 12 of 25 Date: 2/15/2024 10:10 AM East Huntsman Avenue Industrial Park Project - Fresno County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied Le�er - 2

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2-18

3.4 Building Construction - 2025
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 1.3674 12.4697 16.0847 0.0270 0.5276 0.5276 0.4963 0.4963 0.0000 2,556.474 4 2,556.474
4 0.6010 2,571.498
1 Total 1.3674 12.4697 16.0847 0.0270 0.5276 0.5276 0.4963 0.4963 0.0000 2,556.474 4 2,556.474
4 0.6010 2,571.498
1 Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0612 2.4286 0.7196 0.0112 0.3932 0.0164 0.4096 0.1132 0.0157 0.1289 1,184.434 4 1,184.434
4 6.0500e0030.1782 1,237.685
3 Worker 0.4537 0.2175 3.4314 0.0103 1.2158 5.1400e0031.2209 0.3225 4.7300e0030.3272 1,041.787 4 1,041.787
4 0.0241 0.0245 1,049.691
3 Total 0.5149 2.6460 4.1510 0.0215 1.6090 0.0216 1.6305 0.4357 0.0204 0.4561 2,226.221 8 2,226.221
8 0.0301 0.2027 2,287.376
6 Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 13 of 25 Date: 2/15/2024 10:10 AM East Huntsman Avenue Industrial Park Project - Fresno County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied Le�er - 2

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2-18

3.4 Building Construction - 2026
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 1.3674 12.4697 16.0847 0.0270 0.5276 0.5276 0.4963 0.4963 2,556.474 4 2,556.474
4 0.6010 2,571.498
1 Total 1.3674 12.4697 16.0847 0.0270 0.5276 0.5276 0.4963 0.4963 2,556.474 4 2,556.474
4 0.6010 2,571.498
1 Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0599 2.4144 0.7071 0.0110 0.3932 0.0163 0.4095 0.1132 0.0156 0.1289 1,161.101 3 1,161.101
3 5.7700e0030.1746 1,213.286
0 Worker 0.4236 0.1959 3.2328 0.0100 1.2158 4.9400e0031.2207 0.3225 4.5500e0030.3270 1,011.317 8 1,011.317
8 0.0219 0.0230 1,018.733
1 Total 0.4834 2.6103 3.9399 0.0210 1.6090 0.0213 1.6303 0.4357 0.0202 0.4559 2,172.419 1 2,172.419
1 0.0277 0.1977 2,232.019
1 Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 14 of 25 Date: 2/15/2024 10:10 AM East Huntsman Avenue Industrial Park Project - Fresno County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied Le�er - 2

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2-18

3.4 Building Construction - 2026
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 1.3674 12.4697 16.0847 0.0270 0.5276 0.5276 0.4963 0.4963 0.0000 2,556.474 4 2,556.474
4 0.6010 2,571.498
1 Total 1.3674 12.4697 16.0847 0.0270 0.5276 0.5276 0.4963 0.4963 0.0000 2,556.474 4 2,556.474
4 0.6010 2,571.498
1 Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0599 2.4144 0.7071 0.0110 0.3932 0.0163 0.4095 0.1132 0.0156 0.1289 1,161.101 3 1,161.101
3 5.7700e0030.1746 1,213.286
0 Worker 0.4236 0.1959 3.2328 0.0100 1.2158 4.9400e0031.2207 0.3225 4.5500e0030.3270 1,011.317 8 1,011.317
8 0.0219 0.0230 1,018.733
1 Total 0.4834 2.6103 3.9399 0.0210 1.6090 0.0213 1.6303 0.4357 0.0202 0.4559 2,172.419 1 2,172.419
1 0.0277 0.1977 2,232.019
1 Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 15 of 25 Date: 2/15/2024 10:10 AM East Huntsman Avenue Industrial Park Project - Fresno County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied Le�er - 2

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2-18

3.5 Paving - 2028
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 0.9152 8.5816 14.5780 0.0228 0.4185 0.4185 0.3850 0.3850 2,206.745 2 2,206.745
2 0.7137 2,224.587
8 Paving 0.6492 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 1.5643 8.5816 14.5780 0.0228 0.4185 0.4185 0.3850 0.3850 2,206.745 2 2,206.745
2 0.7137 2,224.587
8 Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0376 0.0165 0.2921 9.6000e0040.1232 4.4000e0040.1237 0.0327 4.1000e0040.0331 96.7252 96.7252 1.8500e0032.1000e00397.3987 Total 0.0376 0.0165 0.2921 9.6000e0040.1232 4.4000e0040.1237 0.0327 4.1000e0040.0331 96.7252 96.7252 1.8500e0032.1000e00397.3987 Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 16 of 25 Date: 2/15/2024 10:10 AM East Huntsman Avenue Industrial Park Project - Fresno County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied Le�er - 2

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2-18

3.5 Paving - 2028
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 0.9152 8.5816 14.5780 0.0228 0.4185 0.4185 0.3850 0.3850 0.0000 2,206.745 2 2,206.745
2 0.7137 2,224.587
8 Paving 0.6492 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 1.5643 8.5816 14.5780 0.0228 0.4185 0.4185 0.3850 0.3850 0.0000 2,206.745 2 2,206.745
2 0.7137 2,224.587
8 Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0376 0.0165 0.2921 9.6000e0040.1232 4.4000e0040.1237 0.0327 4.1000e0040.0331 96.7252 96.7252 1.8500e0032.1000e00397.3987 Total 0.0376 0.0165 0.2921 9.6000e0040.1232 4.4000e0040.1237 0.0327 4.1000e0040.0331 96.7252 96.7252 1.8500e0032.1000e00397.3987 Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 17 of 25 Date: 2/15/2024 10:10 AM East Huntsman Avenue Industrial Park Project - Fresno County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied Le�er - 2

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2-18

3.6 Architectural Coating - 2028
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Archit. Coating 543.1602 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.1709 1.1455 1.8091 2.9700e0030.0515 0.0515 0.0515 0.0515 281.4481 281.4481 0.0154 281.8319 Total 543.3311 1.1455 1.8091 2.9700e0030.0515 0.0515 0.0515 0.0515 281.4481 281.4481 0.0154 281.8319 Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0753 0.0330 0.5842 1.9100e0030.2464 8.9000e0040.2473 0.0654 8.2000e0040.0662 193.4504 193.4504 3.7100e0034.2100e003194.7975 Total 0.0753 0.0330 0.5842 1.9100e0030.2464 8.9000e0040.2473 0.0654 8.2000e0040.0662 193.4504 193.4504 3.7100e0034.2100e003194.7975 Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 18 of 25 Date: 2/15/2024 10:10 AM East Huntsman Avenue Industrial Park Project - Fresno County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied Le�er - 2

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2-18

3.6 Architectural Coating - 2028
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Archit. Coating 543.1602 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.1709 1.1455 1.8091 2.9700e0030.0515 0.0515 0.0515 0.0515 0.0000 281.4481 281.4481 0.0154 281.8319 Total 543.3311 1.1455 1.8091 2.9700e0030.0515 0.0515 0.0515 0.0515 0.0000 281.4481 281.4481 0.0154 281.8319 Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0753 0.0330 0.5842 1.9100e0030.2464 8.9000e0040.2473 0.0654 8.2000e0040.0662 193.4504 193.4504 3.7100e0034.2100e003194.7975 Total 0.0753 0.0330 0.5842 1.9100e0030.2464 8.9000e0040.2473 0.0654 8.2000e0040.0662 193.4504 193.4504 3.7100e0034.2100e003194.7975 Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 19 of 25 Date: 2/15/2024 10:10 AM East Huntsman Avenue Industrial Park Project - Fresno County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied Le�er - 2

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2-18

4.0 Operational Detail - Mobile
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Mitigated 1.9609 2.4698 15.6975 0.0378 3.8327 0.0292 3.8619 1.0231 0.0274 1.0505 3,857.022 6 3,857.022
6 0.1820 0.1967 3,920.172
8 Unmitigated 1.9609 2.4698 15.6975 0.0378 3.8327 0.0292 3.8619 1.0231 0.0274 1.0505 3,857.022 6 3,857.022
6 0.1820 0.1967 3,920.172
8 4.1 Mitigation Measures Mobile

4.2 Trip Summary Information

4.4 Fleet Mix
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Land Use LDA LDT1 LDT2 MDV LHD1 LHD2 MHD HHD OBUS UBUS MCY SBUS MH Industrial Park 0.526576 0.053500 0.175633 0.147803 0.024189 0.006487 0.014618 0.022827 0.000697 0.000286 0.023187 0.001433 0.002764 Parking Lot 0.526576 0.053500 0.175633 0.147803 0.024189 0.006487 0.014618 0.022827 0.000697 0.000286 0.023187 0.001433 0.002764

5.0 Energy Detail
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
NaturalGas
Mitigated

0.1342 1.2200 1.0248 7.3200e0030.0927 0.0927 0.0927 0.0927 1,464.030 7 1,464.030
7 0.0281 0.0268 1,472.730
7 NaturalGas
Unmitigated

0.1342 1.2200 1.0248 7.3200e0030.0927 0.0927 0.0927 0.0927 1,464.030 7 1,464.030
7 0.0281 0.0268 1,472.730
7 5.1 Mitigation Measures Energy
Historical Energy Use: N
CalEEMod Version: CalEEMod.2020.4.0 Page 21 of 25 Date: 2/15/2024 10:10 AM East Huntsman Avenue Industrial Park Project - Fresno County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied Le�er - 2

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6.0 Area Detail

5.2 Energy by Land Use - NaturalGas
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr lb/day lb/day
Industrial Park 12444.3 0.1342 1.2200 1.0248 7.3200e0030.0927 0.0927 0.0927 0.0927 1,464.030 7 1,464.030
7 0.0281 0.0268 1,472.730
7 Parking Lot 0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.1342 1.2200 1.0248 7.3200e0030.0927 0.0927 0.0927 0.0927 1,464.030 7 1,464.030
7 0.0281 0.0268 1,472.730
7 Unmitigated
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr lb/day lb/day
Industrial Park 12.4443 0.1342 1.2200 1.0248 7.3200e0030.0927 0.0927 0.0927 0.0927 1,464.030 7 1,464.030
7 0.0281 0.0268 1,472.730
7 Parking Lot 0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.1342 1.2200 1.0248 7.3200e0030.0927 0.0927 0.0927 0.0927 1,464.030 7 1,464.030
7 0.0281 0.0268 1,472.730
7 Mitigated
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6.1 Mitigation Measures Area
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Mitigated 8.8726 9.7000e0040.1076 1.0000e0053.8000e0043.8000e0043.8000e0043.8000e0040.2312 0.2312 6.0000e0040.2463 Unmitigated 8.8726 9.7000e0040.1076 1.0000e0053.8000e0043.8000e0043.8000e0043.8000e0040.2312 0.2312 6.0000e0040.2463

6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory lb/day lb/day
Architectural
Coating

1.3393 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products

7.5234 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Landscaping 9.9100e0039.7000e0040.1076 1.0000e0053.8000e0043.8000e0043.8000e0043.8000e0040.2312 0.2312 6.0000e0040.2463 Total 8.8726 9.7000e0040.1076 1.0000e0053.8000e0043.8000e0043.8000e0043.8000e0040.2312 0.2312 6.0000e0040.2463 Unmitigated
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7.1 Mitigation Measures Water

7.0 Water Detail

1.3393 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products

7.5234 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Landscaping 9.9100e0039.7000e0040.1076 1.0000e0053.8000e0043.8000e0043.8000e0043.8000e0040.2312 0.2312 6.0000e0040.2463 Total 8.8726 9.7000e0040.1076 1.0000e0053.8000e0043.8000e0043.8000e0043.8000e0040.2312 0.2312 6.0000e0040.2463 Mitigated
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11.0 Vegetation

8.1 Mitigation Measures Waste

8.0 Waste Detail

9.0 Operational Offroad
Equipment Type Number Hours/Day Days/Year Horse Power Load Factor Fuel Type

10.0 Stationary Equipment
Fire Pumps and Emergency Generators
Equipment Type Number Hours/Day Hours/Year Horse Power Load Factor Fuel Type Boilers
Equipment Type Number Heat Input/Day Heat Input/Year Boiler Rating Fuel Type User Defined Equipment
Equipment Type Number
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East Huntsman Avenue Industrial Park Project
Fresno County, Winter
Project Characteristics - Consistent with the IS/MND's model.

Land Use - Consistent with the IS/MND's model.

Construction Phase - See SWAPE's comment on "Unsubstantiated Changes to Individual Construction Phase Lengths." Off-road Equipment -
Grading - Consistent with the IS/MND's model.

Fleet Mix - See SWAPE's comment on "Unsubstantiated Changes to Operational Fleet Mix Values." Vehicle Trips - Consistent with the IS/MND's model.

Construction Off-road Equipment Mitigation - See SWAPES's comment on "Incorrect Application of Tier 4 Final Off-Road Equipment Mitigation."

1.1 Land Usage
Land Uses Size Metric Lot Acreage Floor Surface Area Population Industrial Park 351.56 1000sqft 39.80 351,560.00 0
Parking Lot 705.00 Space 2.23 0.00 0

1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
3 Wind Speed (m/s) 1.9 Precipitation Freq (Days) 31

1.3 User Entered Comments & Non-Default Data

1.0 Project Characteristics
Utility Company Pacific Gas and Electric Company
Operational Year 2026
CO2 Intensity
(lb/MWhr)
203.98 CH4 Intensity 0.033
(lb/MWhr)
N2O Intensity 0.004
(lb/MWhr)
Table Name Column Name Default Value New Value
tblConstructionPhase NumDays 55.00 9.00
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2.0 Emissions Summary
tblConstructionPhase NumDays 740.00 119.00
tblConstructionPhase NumDays 75.00 12.00
tblConstructionPhase NumDays 55.00 9.00
tblConstructionPhase NumDays 30.00 5.00
tblConstructionPhase PhaseEndDate 1/26/2029 11/23/2028
tblConstructionPhase PhaseEndDate 8/25/2028 4/9/2026
tblConstructionPhase PhaseEndDate 10/24/2025 7/29/2025
tblConstructionPhase PhaseEndDate 11/10/2028 9/7/2028
tblConstructionPhase PhaseEndDate 7/11/2025 6/6/2025
tblGrading AcresOfGrading 36.00 60.00
tblGrading AcresOfGrading 7.50 15.00
tblLandUse LandUseSquareFeet 282,000.00 0.00
tblLandUse LotAcreage 8.07 39.80
tblLandUse LotAcreage 6.34 2.23
tblProjectCharacteristics PrecipitationFrequency 45 31
tblProjectCharacteristics WindSpeed 2.2 1.9
tblVehicleTrips ST_TR 2.54 1.97
tblVehicleTrips SU_TR 1.24 1.97
tblVehicleTrips WD_TR 3.37 1.97
CalEEMod Version: CalEEMod.2020.4.0 Page 2 of 25 Date: 2/15/2024 10:27 AM East Huntsman Avenue Industrial Park Project - Fresno County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied Le�er - 2

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2.1 Overall Construction (Maximum Daily Emission)
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year lb/day lb/day
2025 2.9560 27.9773 26.7314 0.0633 21.3956 1.1316 22.4830 10.3134 1.0411 11.3139 0.0000 6,133.328 1 6,133.328
1 1.9469 0.2059 6,183.097
0 2026 1.8025 15.2818 19.6117 0.0469 1.6090 0.5489 2.1579 0.4357 0.5165 0.9522 0.0000 4,618.305 2 4,618.305
2 0.6315 0.2007 4,693.897
5 2028 543.3988 8.6009 14.8317 0.0237 0.2464 0.4190 0.5422 0.0654 0.3855 0.4181 0.0000 2,292.705 8 2,292.705
8 0.7158 4.6700e0032,311.297
7 Maximum 543.3988 27.9773 26.7314 0.0633 21.3956 1.1316 22.4830 10.3134 1.0411 11.3139 0.0000 6,133.328 1 6,133.328
1 1.9469 0.2059 6,183.097
0 Unmitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year lb/day lb/day
2025 2.9560 27.9773 26.7314 0.0633 21.3956 1.1316 22.4830 10.3134 1.0411 11.3139 0.0000 6,133.328 1 6,133.328
1 1.9469 0.2059 6,183.097
0 2026 1.8025 15.2818 19.6117 0.0469 1.6090 0.5489 2.1579 0.4357 0.5165 0.9522 0.0000 4,618.305 2 4,618.305
2 0.6315 0.2007 4,693.897
5 2028 543.3988 8.6009 14.8317 0.0237 0.2464 0.4190 0.5422 0.0654 0.3855 0.4181 0.0000 2,292.705 8 2,292.705
8 0.7158 4.6700e0032,311.297
7 Maximum 543.3988 27.9773 26.7314 0.0633 21.3956 1.1316 22.4830 10.3134 1.0411 11.3139 0.0000 6,133.328 1 6,133.328
1 1.9469 0.2059 6,183.097
0 Mitigated Construction
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ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 CalEEMod Version: CalEEMod.2020.4.0 Page 4 of 25 Date: 2/15/2024 10:27 AM East Huntsman Avenue Industrial Park Project - Fresno County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied Le�er - 2

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2.2 Overall Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Area 8.8726 9.7000e0040.1076 1.0000e0053.8000e0043.8000e0043.8000e0043.8000e0040.2312 0.2312 6.0000e0040.2463 Energy 0.1342 1.2200 1.0248 7.3200e0030.0927 0.0927 0.0927 0.0927 1,464.030 7 1,464.030
7 0.0281 0.0268 1,472.730
7 Mobile 1.5118 2.7554 15.3688 0.0348 3.8327 0.0292 3.8619 1.0231 0.0274 1.0505 3,545.299 2 3,545.299
2 0.2046 0.2082 3,612.471
5 Total 10.5186 3.9764 16.5012 0.0421 3.8327 0.1223 3.9550 1.0231 0.1205 1.1436 5,009.561 1 5,009.561
1 0.2333 0.2351 5,085.448
5 Unmitigated Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Area 8.8726 9.7000e0040.1076 1.0000e0053.8000e0043.8000e0043.8000e0043.8000e0040.2312 0.2312 6.0000e0040.2463 Energy 0.1342 1.2200 1.0248 7.3200e0030.0927 0.0927 0.0927 0.0927 1,464.030 7 1,464.030
7 0.0281 0.0268 1,472.730
7 Mobile 1.5118 2.7554 15.3688 0.0348 3.8327 0.0292 3.8619 1.0231 0.0274 1.0505 3,545.299 2 3,545.299
2 0.2046 0.2082 3,612.471
5 Total 10.5186 3.9764 16.5012 0.0421 3.8327 0.1223 3.9550 1.0231 0.1205 1.1436 5,009.561 1 5,009.561
1 0.2333 0.2351 5,085.448
5 Mitigated Operational
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0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Residential Indoor: 0; Residential Outdoor: 0; Non-Residential Indoor: 527,340; Non-Residential Outdoor: 175,780; Striped Parking Area: 0 (Architectural Coating – sqft)
Acres of Grading (Site Preparation Phase): 15
Acres of Grading (Grading Phase): 60
Acres of Paving: 2.23
CalEEMod Version: CalEEMod.2020.4.0 Page 6 of 25 Date: 2/15/2024 10:27 AM East Huntsman Avenue Industrial Park Project - Fresno County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 2656 29th Street, Suite 201
Santa Monica, CA 90405
MHPGCH
ƚƚĂĐŚŵĞŶƚ
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3.1 Mitigation Measures Construction
Grading Tractors/Loaders/Backhoes 2 8.00 97 0.37
Building Construction Cranes 1 7.00 231 0.29
Building Construction Forklifts 3 8.00 89 0.20
Building Construction Generator Sets 1 8.00 84 0.74
Building Construction Tractors/Loaders/Backhoes 3 7.00 97 0.37 Building Construction Welders 1 8.00 46 0.45
Paving Pavers 2 8.00 130 0.42
Paving Paving Equipment 2 8.00 132 0.36
Paving Rollers 2 8.00 80 0.38
Architectural Coating Air Compressors 1 6.00 78 0.48
Trips and VMT
Phase Name Offroad Equipment
Count
Worker Trip
Number
Vendor Trip
Number
Hauling Trip
Number
Worker Trip
Length
Vendor Trip
Length
Hauling Trip
Length
Worker Vehicle
Class
Vendor
Vehicle Class
Hauling
Vehicle Class
Site Preparation 7 18.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT Grading 8 20.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT Building Construction 9 148.00 58.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT Paving 6 15.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT Architectural Coating 1 30.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT CalEEMod Version: CalEEMod.2020.4.0 Page 7 of 25 Date: 2/15/2024 10:27 AM East Huntsman Avenue Industrial Park Project - Fresno County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied Le�er - 2

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3.2 Site Preparation - 2025
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 21.2478 0.0000 21.2478 10.2742 0.0000 10.2742 0.0000 0.0000 Off-Road 2.4727 25.2339 17.9118 0.0381 1.0868 1.0868 0.9999 0.9999 3,689.103 7 3,689.103
7 1.1931 3,718.932
0 Total 2.4727 25.2339 17.9118 0.0381 21.2478 1.0868 22.3346 10.2742 0.9999 11.2741 3,689.103 7 3,689.103
7 1.1931 3,718.932
0 Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0492 0.0310 0.3603 1.1100e0030.1479 6.2000e0040.1485 0.0392 5.7000e0040.0398 112.5420 112.5420 3.3300e0033.3100e003113.6120 Total 0.0492 0.0310 0.3603 1.1100e0030.1479 6.2000e0040.1485 0.0392 5.7000e0040.0398 112.5420 112.5420 3.3300e0033.3100e003113.6120 Unmitigated Construction Off-Site
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3.2 Site Preparation - 2025
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 21.2478 0.0000 21.2478 10.2742 0.0000 10.2742 0.0000 0.0000 Off-Road 2.4727 25.2339 17.9118 0.0381 1.0868 1.0868 0.9999 0.9999 0.0000 3,689.103 7 3,689.103
7 1.1931 3,718.932
0 Total 2.4727 25.2339 17.9118 0.0381 21.2478 1.0868 22.3346 10.2742 0.9999 11.2741 0.0000 3,689.103 7 3,689.103
7 1.1931 3,718.932
0 Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0492 0.0310 0.3603 1.1100e0030.1479 6.2000e0040.1485 0.0392 5.7000e0040.0398 112.5420 112.5420 3.3300e0033.3100e003113.6120 Total 0.0492 0.0310 0.3603 1.1100e0030.1479 6.2000e0040.1485 0.0392 5.7000e0040.0398 112.5420 112.5420 3.3300e0033.3100e003113.6120 Mitigated Construction Off-Site
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3.3 Grading - 2025
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 11.3246 0.0000 11.3246 3.8828 0.0000 3.8828 0.0000 0.0000 Off-Road 2.9012 27.9429 26.3311 0.0621 1.1309 1.1309 1.0404 1.0404 6,008.281 4 6,008.281
4 1.9432 6,056.861
4 Total 2.9012 27.9429 26.3311 0.0621 11.3246 1.1309 12.4555 3.8828 1.0404 4.9232 6,008.281 4 6,008.281
4 1.9432 6,056.861
4 Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0547 0.0344 0.4003 1.2400e0030.1643 6.9000e0040.1650 0.0436 6.4000e0040.0442 125.0467 125.0467 3.7000e0033.6800e003126.2356 Total 0.0547 0.0344 0.4003 1.2400e0030.1643 6.9000e0040.1650 0.0436 6.4000e0040.0442 125.0467 125.0467 3.7000e0033.6800e003126.2356 Unmitigated Construction Off-Site
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3.3 Grading - 2025
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 11.3246 0.0000 11.3246 3.8828 0.0000 3.8828 0.0000 0.0000 Off-Road 2.9012 27.9429 26.3311 0.0621 1.1309 1.1309 1.0404 1.0404 0.0000 6,008.281 4 6,008.281
4 1.9432 6,056.861
4 Total 2.9012 27.9429 26.3311 0.0621 11.3246 1.1309 12.4555 3.8828 1.0404 4.9232 0.0000 6,008.281 4 6,008.281
4 1.9432 6,056.861
4 Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0547 0.0344 0.4003 1.2400e0030.1643 6.9000e0040.1650 0.0436 6.4000e0040.0442 125.0467 125.0467 3.7000e0033.6800e003126.2356 Total 0.0547 0.0344 0.4003 1.2400e0030.1643 6.9000e0040.1650 0.0436 6.4000e0040.0442 125.0467 125.0467 3.7000e0033.6800e003126.2356 Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 11 of 25 Date: 2/15/2024 10:27 AM East Huntsman Avenue Industrial Park Project - Fresno County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied Le�er - 2

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2-18

3.4 Building Construction - 2025
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 1.3674 12.4697 16.0847 0.0270 0.5276 0.5276 0.4963 0.4963 2,556.474 4 2,556.474
4 0.6010 2,571.498
1 Total 1.3674 12.4697 16.0847 0.0270 0.5276 0.5276 0.4963 0.4963 2,556.474 4 2,556.474
4 0.6010 2,571.498
1 Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0572 2.5979 0.7444 0.0112 0.3932 0.0165 0.4097 0.1132 0.0158 0.1290 1,186.734 1 1,186.734
1 5.8700e0030.1787 1,240.122
3 Worker 0.4049 0.2549 2.9622 9.1500e0031.2158 5.1400e0031.2209 0.3225 4.7300e0030.3272 925.3456 925.3456 0.0274 0.0272 934.1433 Total 0.4621 2.8528 3.7066 0.0204 1.6090 0.0216 1.6306 0.4357 0.0205 0.4562 2,112.079 7 2,112.079
7 0.0333 0.2059 2,174.265
6 Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 12 of 25 Date: 2/15/2024 10:27 AM East Huntsman Avenue Industrial Park Project - Fresno County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied Le�er - 2

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2-18

3.4 Building Construction - 2025
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 1.3674 12.4697 16.0847 0.0270 0.5276 0.5276 0.4963 0.4963 0.0000 2,556.474 4 2,556.474
4 0.6010 2,571.498
1 Total 1.3674 12.4697 16.0847 0.0270 0.5276 0.5276 0.4963 0.4963 0.0000 2,556.474 4 2,556.474
4 0.6010 2,571.498
1 Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0572 2.5979 0.7444 0.0112 0.3932 0.0165 0.4097 0.1132 0.0158 0.1290 1,186.734 1 1,186.734
1 5.8700e0030.1787 1,240.122
3 Worker 0.4049 0.2549 2.9622 9.1500e0031.2158 5.1400e0031.2209 0.3225 4.7300e0030.3272 925.3456 925.3456 0.0274 0.0272 934.1433 Total 0.4621 2.8528 3.7066 0.0204 1.6090 0.0216 1.6306 0.4357 0.0205 0.4562 2,112.079 7 2,112.079
7 0.0333 0.2059 2,174.265
6 Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 13 of 25 Date: 2/15/2024 10:27 AM East Huntsman Avenue Industrial Park Project - Fresno County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied Le�er - 2

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2-18

3.4 Building Construction - 2026
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 1.3674 12.4697 16.0847 0.0270 0.5276 0.5276 0.4963 0.4963 2,556.474 4 2,556.474
4 0.6010 2,571.498
1 Total 1.3674 12.4697 16.0847 0.0270 0.5276 0.5276 0.4963 0.4963 2,556.474 4 2,556.474
4 0.6010 2,571.498
1 Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0559 2.5826 0.7317 0.0110 0.3932 0.0164 0.4096 0.1132 0.0157 0.1289 1,163.365 8 1,163.365
8 5.5900e0030.1751 1,215.683
3 Worker 0.3792 0.2295 2.7954 8.8900e0031.2158 4.9400e0031.2207 0.3225 4.5500e0030.3270 898.4651 898.4651 0.0250 0.0256 906.7161 Total 0.4351 2.8121 3.5271 0.0199 1.6090 0.0213 1.6303 0.4357 0.0202 0.4559 2,061.830 8 2,061.830
8 0.0306 0.2007 2,122.399
4 Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 14 of 25 Date: 2/15/2024 10:27 AM East Huntsman Avenue Industrial Park Project - Fresno County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied Le�er - 2

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2-18

3.4 Building Construction - 2026
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 1.3674 12.4697 16.0847 0.0270 0.5276 0.5276 0.4963 0.4963 0.0000 2,556.474 4 2,556.474
4 0.6010 2,571.498
1 Total 1.3674 12.4697 16.0847 0.0270 0.5276 0.5276 0.4963 0.4963 0.0000 2,556.474 4 2,556.474
4 0.6010 2,571.498
1 Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0559 2.5826 0.7317 0.0110 0.3932 0.0164 0.4096 0.1132 0.0157 0.1289 1,163.365 8 1,163.365
8 5.5900e0030.1751 1,215.683
3 Worker 0.3792 0.2295 2.7954 8.8900e0031.2158 4.9400e0031.2207 0.3225 4.5500e0030.3270 898.4651 898.4651 0.0250 0.0256 906.7161 Total 0.4351 2.8121 3.5271 0.0199 1.6090 0.0213 1.6303 0.4357 0.0202 0.4559 2,061.830 8 2,061.830
8 0.0306 0.2007 2,122.399
4 Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 15 of 25 Date: 2/15/2024 10:27 AM East Huntsman Avenue Industrial Park Project - Fresno County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied Le�er - 2

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2-18

3.5 Paving - 2028
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 0.9152 8.5816 14.5780 0.0228 0.4185 0.4185 0.3850 0.3850 2,206.745 2 2,206.745
2 0.7137 2,224.587
8 Paving 0.6492 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 1.5643 8.5816 14.5780 0.0228 0.4185 0.4185 0.3850 0.3850 2,206.745 2 2,206.745
2 0.7137 2,224.587
8 Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0339 0.0193 0.2537 8.5000e0040.1232 4.4000e0040.1237 0.0327 4.1000e0040.0331 85.9607 85.9607 2.1300e0032.3400e00386.7099 Total 0.0339 0.0193 0.2537 8.5000e0040.1232 4.4000e0040.1237 0.0327 4.1000e0040.0331 85.9607 85.9607 2.1300e0032.3400e00386.7099 Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 16 of 25 Date: 2/15/2024 10:27 AM East Huntsman Avenue Industrial Park Project - Fresno County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied B.A. Degree, Geology, Humboldt State University, Arcata, CA, 1982.

ProfessionalCertifications:

California Professional Geologist
California Certified Hydrogeologist
Qualified SWPPP Developer and Practitioner
ProfessionalExperience:

Matt has 30 years of experience in environmental policy, contaminant assessment and remediation, stormwater compliance, and CEQA review. He spent nine years with the U.S. EPA in the RCRA and Superfund programs and served as EPA’s Senior Science Policy Advisor in the Western Regional Office where he identified emerging threats to groundwater from perchlorate and MTBE. While with EPA, Matt also served as a Senior Hydrogeologist in the oversight of the assessment of seven major military facilities undergoing base closure. He led numerous enforcement actions under provisions of the Resource Conservation and Recovery Act (RCRA) and directed efforts to improve hydrogeologic characterization and water quality monitoring. For the past 15 years, as a founding partner with SWAPE, Matt has developed extensive client relationships and has managed complex projects that include consultation as an expert witness and a regulatory specialist, and a manager of projects ranging from industrial stormwater compliance to CEQA review of impacts from hazardous waste, air quality and greenhouse gas emissions.

Positions Matt has held include:
x Founding Partner, Soil/Water/Air Protection Enterprise (SWAPE) (2003 – present); x Geology Instructor, Golden West College, 2010 – 2104, 2017; x Senior Environmental Analyst, Komex H2O Science, Inc. (2000 -- 2003); Le�er - 2

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Reedley City CouncilApril 9, 2024

Reedley City Council
April 9, 2024