Roseville City Council
August 3, 2022

MARKETING AND COMMUNICATIONS
 Marketing & Communications should expand specialized intradepartmental teams to develop marketing strategies and plans by “cohort or interest groups.” Cohort groups could be youth, teens, or adults & seniors. Interest groups could be cultural arts, fitness & wellness, self-directed use of the park system, etc.
 Marketing & Communications should work with a consultant to develop a Marketing and Communications Plan. This plan should identify goals, strategies, and tactics to market and promote the PRL Department.
 Marketing & Communications should participate in soliciting, analyzing, and understanding the needs, wants, desires and satisfaction level of Roseville residents in relation to parks, facilities, program, and services. This information should be communicated to the various Divisions within PRL.
 Establish a parks, recreation and libraries app to inform users of upcoming PRL opportunities as well as giving users instant access to staff on elements in the system that need to be addressed/updated.

RECREATION DIVISION
 Combine Sports and Facilities under one new Section. The Sports and Facilities Section would be responsible for overseeing the maintenance and operation of major recreation facilities like the Maidu Community Center, the Roseville Sports Center and City pools. The Sports and Facilities 176
group should also oversee maintenance and operation of the City’s golf courses, as well as future facilities such as the Sports Complex.
 The Sports and Facilities Section would be responsible for Sports Leagues, Fitness Memberships & Drop in Fitness Use of the RSC & MSIP, and fitness classes included as a part of memberships.  The Sports and Facilities Section would coordinate use of City athletic fields and recreation facilities (such as the Roseville Aquatics Complex) by youth organizations and other user groups.  The Sports and Facilities Section would program and coordinate the City’s adult and youth sports leagues and schedule facilities used by those leagues.
 The Sports and Facilities Section would be responsible for monitoring the Department’s Joint Use Agreements with the various school districts to ensure compliance by both parties and coordinate use of school facilities for the Department.
 It is recommended that the current Strategic Support Superintendent be shared to oversee areas within the Recreation Division, such as golf. The Superintendent should continue overseeing designated functions within Strategic Support, like technology, until a new Management Analyst can be hired for Strategic Support.
 Combine Youth Instructional Sports with Youth & Teen Classes & Camps. New: Youth & Teen Activities
 Combine Adult Special Interest Classes & Activities with Senior Activities & Programs. New: Adult & Older Adult Activities
 Research and evaluate changes to the operating model for Adventure Club, considering the elimination of State licensing requirements, offering after school care only and exploring the option of providing the Adventure Club via contract at new schools and at existing sites as feasible.  Enhance core program offerings to consider adding outdoor recreation and education to the services PRL provides and activate natural areas.
 Consider adding a Cultural and Arts Division to promote the arts in the city via art related events and services.
 Develop the new sports complex to promote sports tourism while meeting the needs of the residents.
 Consider development of a new girls’ softball complex in the city.  Develop a new community center/library facility in the west area of Roseville to support the City’s growth and to serve new residents and future residents in the City.  Update existing recreation facilities including golf facilities.  Consider development of a Mountain Bike, Pump Track, or BMX Park in the City.

PARKS AND OPEN SPACE DIVISION
 Recruit and hire a full time Manager to oversee the Parks and Open Space Division. The size and complexity of the Roseville park system will grow from 80 developed parks to a projected buildout of 120 developed parks. The current operational model that has the Director of Parks, Recreation & Libraries overseeing this Division will only become more problematic with this growth.  Create a fourth geographical district in the City for the parks and open space areas in the West Plan/Sierra Vista specific plan areas with a new Supervisor. Assign park sites in the Creekview and Amoruso Ranch specific plan areas to the other geographic teams as they are developed to divide the work and maintain effective span of control.
 Consider having the park crews assigned to maintaining and/or overseeing contracts for developed parks with large open space areas to inspect those areas for open space maintenance Parks, Recreation & Libraries Strategic Master Plan
177
management needs, not to perform this work, but to notify the Open Space Supervisors of needs or problems in these areas.
 PRL should continually evaluate the mowing of school turf to ensure that equal value is provided to the Department through the JUA.
 Create a “Trails Crew” as an operational group within the Open Space Section of the Division to coordinate the inspection and maintenance of paved trails within City parks and open space areas, and natural trails in open spaces.
 Install additional interpretive and wayfinding signage in parks, open space areas, and along trails.  Research and evaluate adding the classification of Park Ranger Naturalist to the Parks and Open Space Division to increase park safety and supervision, and to provide outdoor education programs.

LIBRARIES AND CULTURE DIVISION
 Continue to designate Supervisors and Librarians to take the lead roles in system wide functions of the three libraries. These city-wide roles currently include Technology, Free Programs, FeeBased Programs, History, Literacy, Collection Development, Mobile Library, Friends & Bookstore, Marketing & Outreach.
 Increase full time staffing to assist the Interpretive Specialist in the management and operation of the Maidu Museum.
 Hire a full time Program Coordinator or Supervisor to work with the Libraries & Culture Manager to expand cultural arts programming in fiscal year 23/24. Expanding cultural arts programming will address the needs of the community as expressed in the City survey.  The Libraries & Culture Division should develop or expand partnerships with arts organizations like the Blue Line Gallery, Placer Arts and Performing Arts of Roseville to increase cultural arts program and activities.

PLANNING AND DEVELOPMENT DIVISION
 Create a stand-alone Planning and Development Division within the Parks, Recreation & Libraries Department versus the current model of it being a Section within Parks.  Reclassify the Park Planning and Development Superintendent to Park Planning and Development Manager. The size, scope and responsibilities of this position requires and justifies the “Manager” classification.
 Conduct a comprehensive and professional audit of park development expenditures to date in relation to the park development fees collected by specific plan. The purpose of the audit would be to determine the actual expenditures per acre per park in relation to the fees collected at building permit for both neighborhood and citywide parks, and to identify potential funding gaps.  Forecast both expenditures and park impact fees for neighborhood and citywide park fees for the parks remaining to be developed in all specific plans, comparing the residential units to be developed as assumed in the adoption of the specific plans to any land use changes that may have resulted in an increase or decrease in residential units and corresponding park fees.  Reconcile shortfalls by adjusting neighborhood park fees, identifying new park development funds, reducing park amenities, or reducing park acres to be developed.  Establish construction budgets for each neighborhood park based on the neighborhood park fees being collected.
 Consider separating work functions of the Planning and Development Division into four sections:

Planning, Design & Architecture, Construction Management, and Administration/Finance & 178
Funding, assigning lead and work functions to the Park Development Project Managers so as to best utilize their special skills and expertise.
 It is recommended that the Planning and Development Division have additional administrative support to assist the staff in managing the numerous planning activities and construction activities.

STRATEGIC SUPPORT DIVISION
 Responsibility for managing the collection and expenditures of development impact fees should be a responsibility of Strategic Support, working closely with City’s Development Services Department to monitor land use changes that result in an increase or decrease in residential units.  The Strategic Support Division needs an additional Management Analyst.  Growth in demands related to technology hardware and software systems within the Department will require additional technical staff with the knowledge and skills to manage these various systems and functions.
 It is recommended that Strategic Support assign “lead and support” functions based on the special knowledge and skill sets of the Management Analysts and Technicians.  Strategic Support should develop a Business Plan to help improve the systems and staffing to manage the various functions within the Division.

RECOMMENDED STAFFING CHANGES
 Reclassify current Park Planning and Development Superintendent to Planning and Development Manager.
o Timeline: Immediate
 Add a permanent Management Analyst to the Strategic Support Division. o Timeline: Immediate
 Share allocation of Strategic Support Superintendent with the Recreation Division. o Timeline Immediate
 Add a Parks and Open Space Manager to oversee the Parks and Open Space Division and relieve the Director’s responsibility of direct oversight of the largest operational unit of the Department. o Timeline: FY23-24
 Add a Program Coordinator or Supervisor to the Libraries and Cultural Arts Division to program cultural arts programs and activities.
o Timeline: FY 23-24
 Add a full time Marketing Technician to the Marketing & Communications group by converting 1,500-hour position to a permanent position.
o Timeline: FY 23-24
 Convert a limited term Park Development Project Manager to permanent. o Timeline: FY23-24
 Add a Sports Supervisor to the Sports and Facilities Section six to twelve months prior to the opening of the new Sports/Soccer Complex.
o Timeline: TBD
 Evaluate the practicality, costs & benefits, and risk vs. rewards of establishing a Park Ranger Naturalist position to provide ongoing supervision and security to the City’s parks and facilities, as well as a resource for public education on the City’s natural resources in parks and open space areas.
o Timeline: TBD
Parks, Recreation & Libraries Strategic Master Plan
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ADMINISTRATION DIVISION RECREATION DIVISION PARKS & OPEN SPACE DIVISION LIBRARIES & CULTURE DIVISION PLANNING & DEVELOPMENT

DIVISION

STRATEGIC SUPPORT DIVISION

DIVISION FUNCTIONAL SECTIONS DIVISION FUNCTIONAL SECTIONS DIVISION FUNCTIONAL SECTIONS DIVISION FUNCTIONAL SECTIONS DIVISION FUNCTIONAL SECTIONS DIVISION FUNCTIONAL SECTIONS Overall Department Administration Aquatics Parks Maintenance Maidu Library Operations Planning Budget Administration Governance Youth & Teen Activities Infrastructure Downtown Library Operations Design & Architecture Procurement/Purchasing Planning & Policies Special Events Aquatics Facilities Riley Library Operations Construction Management Funding & Financial Accounting Leadership & Workforce Facilities & Sports Irrigation & Agronomics Library Centralized Functions Finance & Funding Human Resources Management Business Development Adult & Senior Activities Contract Administration Maidu Museum & Historical Site Division Administration Technology & Systems Management Youth Development Open Space Cultural Arts Division Administration MARKETING & COMMUNICATIONS Golf Course Operations Urban Forestry Division Administration Division Administration Division Administration Streetscapes/CFD/LLD Contracts Communications & Community Engagement City Buildings & Schools Landscape Creative Services & Marketing Division Administration
BUDGET FY23 BUDGET FY23 BUDGET FY23 BUDGET FY23 BUDGET FY23 BUDGET FY23 $1.08M Budget $18.7M Budget $24.5M Budget $5.5 M Budget $38.45M Budget $4.4M Budget Funding Funding Funding Funding Funding Funding
$1.05M General Fund $4.4M General Fund $12.9M General Fund $5.4 General Fund $550K General Fund $4.4 General Fund $30K User Fees & Charges $3.6M User Fees & Charges $8.5M Community Facility Districts Funds $250K User Fees & Charges $37.9M CIP Funds $8.2M Youth Development (Enterprise Fund) $1.8M Lighting & Landscape District Funds $2.5M Golf (Special Revenue Fund) $855K Open Space Fund $350K Tree Fund

STAFFING STAFFING STAFFING STAFFING STAFFING STAFFING
Parks, Recreation & Libraries Director (1) Parks, Recreation & Libraries Manager (1) Park Maintenance Parks, Recreation & Libraries Manager (1) Park Planning & Dev Superintendent (1) Parks, Recreation & Libraries Manager (1) Administrative Assistant (1) Programs, Facilities & Events PRL Superintendent (1) Libraries & Culture Park Development Project Manager (3) PRL Superintendent (.5) Department Public Information Officer (1) PRL Superintendent (1.5) Parks Supervisor (3) Recreation & Library Supervisor (3) Park Project Technician (2) Management Analyst (2) Marketing & Communications Analyst (1) Recreation & Library Supervisor (3) Office Assistant (1) Librarian (5.5) Administrative Technician (5) PRL Coordinator (10) Irrigation Technician (2) Library Technician (3) 6 regular full-time employees Office Assistant (1) 4 regular full-time employees Recreation Leader (5) Aquatics Maintenance Technician (2) Library Assistant (4) 0 FTE part-time employees

1.44 FTE part-time employees Office Assistant (1) Park Project Technician (1) Maidu Museum & Historic Site 9.5 regular full-time employees Youth Development Agronomics Technician (1) Senior Interpretive Services Specialist (1) 2.14 FTE part-time employees PRL Superintendent (1) Senior Parks Maintenance Worker (5) Recreation Leader (1) Recreation & Library Supervisor (3) Parks Maintenance Worker (22) Administrative Technician (2) Open Space/Urban Forestry/CFD&LLD 18.5 regular full-time employees Office Assistant (1) PRL Superintendent (1) 18 Total FTE part-time employees Youth Development Program Coordinator (4) Urban Forester (1) 15.53 Library FTE part-time employees Child Care Site Coordinator (10) Arborist Technician (1) 2.47 MMHS FTE part-time employees Asst Child Care Site Coordinator (1) Senior Tree Trimmer (1) PRL Coordinator (1) Tree Trimmer (2)
Natural Resource Specialist (1)

44.5 regular full-time employees Senior Natural Resource Worker (1) 130.08 Total FTE part-time employees Natural Resource Worker (3)

44.65 Recreation FTE part-time employees Parks Supervisor (1)

85.43 Youth Development FTE part-time employees Park Project Technician (3) 53 regular full-time employees

34.06 Total FTE part-time employees

23.25 Park Operations FTE part-time employees

10.80 OS/Trees FTE part-time employees
Recommended Staffing Changes
Add Marketing & Communications Analyst Move .5 PRL Superintendent from Strategic Support to Recreation
Add PRL Manager Add Coordinator or Supervisor for
Cultural Arts programming
Reclassify Superintendent to Manager Add Management Analyst Add Supervisor and/or Coordinator for Sports
Complex
Evaluate adding Park Ranger Naturalist Convert Limited Term Park Development Project Manager to Regular Full-Time
Move .5 PRL Superintendent from Strategic
Support to Recreation

ROSEVILLE PARKS, RECREATION & LIBRARIES DEPARTMENT
180

COUNCIL COMMUNICATION
CC #: 2239
File #: 0400-04-02-1
Title:

Northeast Roseville Specific Plan Parcel 25 - Sutter Parking Garage Expansion Design Review Permit Appeal
Contact: Escarlet Mar 916-774-5247 [email protected] Meeting Date: 8/3/2022
Item #: 10.1.

RECOMMENDATION TO COUNCIL
Based on the May 12, 2022 Planning Commission hearing, staff recommends the City Council deny the appeal of the Planning Commission’s approval of entitlements related to the Sutter Parking Garage Expansion project and take the following actions:

1. Adopt the Sutter Parking Garage Expansion Initial Study/Negative Declaration; and

2. Adopt a resolution denying the appeal of the May 12, 2022 approval by the Planning Commission; adopting the four (4) findings of fact and approving the Design Review Permit subject to sixty-two (62) conditions of approval.

BACKGROUND
The project site is approximately 0.94 acres in size and is located at 12 Medical Plaza Drive, within the Sutter Roseville Medical Center (SRMC). The SRMC campus is approximately 49 acres in size and is located in the Northeast Roseville Specific Plan (NERSP). The SRMC site has a General Plan designation of Business Professional (BP). The NERSP land use designation for the SRMC is Medical Campus, and the zoning designation is Planned Development for Medical Campus (PD 457). On October 26, 2006, the Planning Commission - as the approving authority specified by the Roseville Municipal Code for such entitlements - approved a Conditional Use Permit (CUP) to allow an increase in square footage of the SRMC from 804,000 square feet to 1,100,000 square feet.

Project Description
The applicant requests approval of a Design Review Permit (DRP) to allow the construction of an approximately 192,000-square foot parking structure, which would create an additional 551 parking stalls for the SRMC. The applicant proposes expanding the existing parking garage to support the existing campus as well as a newly proposed Medical Office Building (MOB) 7. On June 23, 2022, the Planning Commission considered and approved the entitlements related to the MOB 7 project (File#PL22-0061). The MOB 7 project will ultimately result in the construction of a 100,000 square foot medical office building and a new graduate medical education program to occupy the first floor of the building. Based on the results of a parking study conducted by Fehr and Peers, MOB 7 will require 332 spaces. The new parking garage expansion will provide the necessary parking spaces for the new medical office building as well as an additional 219 spaces for the SRMC.

An Initial Study which led to a Negative Declaration was prepared to evaluate the potential environmental effects of the Sutter Parking Garage Expansion project. The same Initial Study/Negative Declaration (IS/ND) evaluated the effects of the MOB 7 project (File#PL22- 0061), which the Planning Commission approved on June 23, 2022. While the two projects were considered independently, it was determined that, in order to evaluate the combined environmental impacts of both projects, one comprehensive environmental document would be prepared. The IS/ND was released for a 20-day public review, from April 12, 2022 to May 2, 2022. During the public review period, no comments were received.

Prior to the May 12, 2022 Planning Commission hearing for the Sutter Parking Garage Expansion project, a comment letter was submitted by the Lozeau Drury law firm (dated May 11, 2022), on behalf of the Laborer’s International Union of North America. Lozeau Drury’s letter (see Attachment 2) alleged that the project may have unmitigated adverse environmental impacts related to indoor air quality, noise, air quality impacts from the emissions of reactive organic compounds (ROGs), and greenhouse gas, and the project did not consider renewable energy alternatives. The letter also alleged that a proposed Condition of Approval contained an environmental mitigation measure that was not discussed or incorporated in the IS/ND and that any reference to an environmental mitigation should have led to a Mitigated Negative Declaration.

The letter concluded with a request that the City prepare and circulate an Environmental Impact Report in lieu of the Negative Declaration. On May 12, 2022, staff prepared, and provided the Planning Commission, a response memorandum (see Attachment 3) that addressed the Lozeau Drury law firm comments and provided one minor correction to the Negative Declaration. The response memorandum concluded that the Negative Declaration adequately evaluated the environmental impacts for both the Sutter Parking Garage Expansion project and the MOB 7 project and the document could be relied upon for compliance with California Environmental Quality Act (CEQA).

Prior to the June 23
rd Planning Commission hearing for the Sutter MOB 7 project, the City received a letter from Thomas Law Group (see Attachment 4), representing Sutter Valley Hospitals, concurring with the City’s response to the Lozeau Drury letter and requesting the Planning Commission adopt the Negative Declaration for the MOB 7 project. The Planning Commission ultimately approved the MOB 7 project and no appeal was received related to that action.

Summary of May 12, 2022 Sutter Parking Garage Expansion Planning Commission Meeting The Sutter Parking Garage Expansion project was heard by the Planning Commission on May 12, 2022. At the conclusion of staff’s presentation, a Commissioner asked if the applicant had reviewed staff’s response to the Lozeau Drury letter. Staff informed the Commission that the applicant had reviewed and concurred with the response.

The only public comment received that evening was from the applicant who stated they were in agreement with staff’s recommendations. After closing public comment, the Planning Commission deliberated on the item and voted to adopt the IS/ND and the four (4) findings of fact and approved the Design Review Permit subject to sixty-two (62) conditions of approval. The motion passed with a vote of 5 ayes, 0 nays, and 2 absent.

Appeal
On May 20, 2022, the City Clerk’s office received a notice of appeal of the Planning Commission’s action on the Sutter Parking Garage Expansion project (see Attachment 5). The appeal was submitted by the Lozeau Drury law firm, representing the Laborers’ International Union of North America, Local Union No. 185. The appeal, dated May 20, 2022, did not raise any new issues not already analyzed and responded to by staff in the response memorandum considered by the Planning Commission. The Lozeau Drury law firm appeal included the May 11, 2022 letter which alleged the project analyzed in the Negative Declaration may have unmitigated adverse environmental impacts related to indoor air quality, noise, air quality impacts from the emissions of ROGs, and greenhouse gas, and the project did not consider renewable energy alternatives. It is important to note that the majority of issues identified in the May 11, 2022 letter relate to the development of MOB 7 and not to the Parking Garage expansion.

This Council Communication provides a summary of the issues raised in the appeal.

Condition of Approval
The appeal asserts Condition of Approval No. 3 contained an environmental mitigation measure from a previous project that was not discussed or incorporated in the Negative Declaration of the Sutter Parking Garage Expansion project (Project).

The Condition of Approval No. 3 was inadvertently and erroneously included in the staff report.

The conditions of approval for MOB 6 were used as a template to begin developing appropriate conditions for the proposed Project. Staff requested the Planning Commission adopt the Project with the removal of Condition of Approval No. 3.

Indoor air quality
The appeal asserts the Project may have potentially significant indoor air quality impacts from emissions of formaldehyde. The commenter alleges that the analysis of air quality is flawed because there is no discussion of formaldehyde impacts related to indoor air quality.

The appeal provided support to their assertion by including a letter from a Certified Industrial Hygienist, who asserts that people in the building will be exposed to high levels of off-gassed formaldehyde from the decomposition of composite wood products used to construct buildings, and that this will result in a cancer risk for employees of 17.7 per million. The two studies referenced in the appeal to determine that the Project’s indoor emissions of formaldehyde constitute a significant CEQA impact, even if the Project uses typical materials and construction methods which meet the California Air Resources Board (CARB) formaldehyde airborne toxics control measure, are not applicable to the Project for several reasons. In short, the examples used in the cited studies were constructed prior to the current mandatory regulations which reduce formaldehyde in construction materials. Examples of current mandatory regulations to reduce formaldehyde in construction materials include Federal Environmental Protection Agency final rule to reduce exposure to formaldehyde emissions from certain wood products produced domestically or imported into the United States (effective February 10, 2017), and the Composite Wood Products Regulation (CARB) which reduces public exposure to formaldehyde through the establishment of strict emission performance standards on composite wood products (e.g. particleboard, medium density fiberboard and hardwood plywood). With the current mandatory regulations and proposed construction start date of summer 2022, the project will not have significant impacts from formaldehyde emissions.

Noise
The appeal asserts the Project did not analyze and mitigate noise impacts from construction noise and the Project’s mechanical equipment.

The recently approved MOB 7 is located approximately 120 feet from the nearest apartment building and the Project is located approximately 390 feet away from the nearest apartment building. The appeal claims that mechanical equipment could result in substantial noise affecting sensitive receptors located approximately 120 feet away. However, the existing Sutter Medical Office Building 4 is located 45 feet away from the apartment complex and the existing mechanical equipment (same mechanical equipment proposed at MOB 7) and the existing conditions do not violate the City’s noise thresholds or standards. As a result, it can be seen with certainty that the Project does not have the potential to result in significant noise impacts related to mechanical equipment. Further, the Parking Garage Expansion, which is now before the Council, does not include any unenclosed mechanical equipment. The electrical equipment for the parking garage elevator is located within the concrete elevator shaft.

Pursuant to the City of Roseville Noise Ordinance, all construction noise is limited to daytime hours and shall be minimized to the extent which is practical, in order to prevent noise during sleeping or night time hours. All projects in the City are required to comply with the City’s Noise Ordinance and the City’s adopted California Environmental Quality Act Implementing Procedures findings, which indicate that compliance with the City Noise Ordinance is sufficient to protect nearby sensitive receptors from the negative health effects from construction noise. The Project does not pose any unique characteristics that would result in construction noise which is greater than typical construction, and as such it can be seen with certainty that the Project does not have the potential to result in construction noise impacts.

Air quality impact from ROGs
The appeal asserts the Project did not appropriately analyze the air quality impacts from emissions of ROGs.

The appeal provided an analysis completed by SWAPE Technical Consultation, Data Analysis and Litigation Support of the Environment, to review the air quality modeling of the Project.

SWAPE evaluated the City’s analysis and prepared its own California Emissions Estimator Model (CalEEMod). The analysis by SWAPE did find an error in the City’s model, but their amended model also contained incorrect data. City staff corrected the model and found the Project to be below the screening thresholds.

Greenhouse gas
The appeal asserts the City improperly relied on the General Plan Update Environmental Impact Report to conclude that impacts would be less than significant.

The Project’s vehicle trips and vehicle miles traveled (VMT) resulting from the full buildout of the SRMC were evaluated as part of the citywide analysis prepared for the General Plan Update EIR and as part of the citywide buildout analysis of non-mobile greenhouse gas emissions. As a result, the emissions from the Project are not a new project-specific impact requiring further analysis, and per the tiering provisions of CEQA Section 15152, additional environmental analysis is not required.

Renewable Energy
The appeal asserts the Project had an obligation to evaluate whether any renewable energy features could be incorporated into the Project.

There is no obligation for a project to evaluate whether any renewable energy features could be incorporated, instead, CEQA requires an analysis of whether a project would result in “inefficient, wasteful, and unnecessary consumption of energy” as part of an EIR. However, this Project did not result in an EIR and the evaluation of any renewable energy features is not required for the Project’s IS/ND. Furthermore, the Project will comply with the California Green Building Standards Code.

In conclusion, staff finds that the Initial Study/Negative Declaration remains the appropriate document to comply with CEQA. No new or substantially more severe impacts have been identified which would necessitate the preparation of a subsequent or supplemental EIR.

Public Outreach
The proposed project was distributed to all internal and external agencies and departments who have requested such notice, and all comments or recommended conditions of approval have been incorporated into the project, as appropriate. Notice of both the Planning Commission hearing and the City Council hearing was published in the Roseville Press Tribune and on the Roseville Coalition of Neighborhood Associations (RCONA) website, and mailed to all property owners and residents within a 300 foot radius of the project site. As of the writing of this report, staff has not received any public comment regarding the project.

FISCAL IMPACT
The development of the site with the six-story parking addition will not result in negative impacts to the City’s General Fund as it will expand an existing parking garage and will be a beneficial use to the SRMC campus.

ENVIRONMENTAL REVIEW
The City of Roseville, acting as Lead Agency, prepared an Initial Study/Negative Declaration (IS/ND) to evaluate the environmental effects of the Sutter Parking Garage Expansion. The IS/ND was released for a 20-day public review, from April 12, 2022 to May 2, 2022. This IS/ND is included as Exhibit A. In the May 11, 2022 letter and the appeal, Lozeau Drury challenges the determination that an Initial Study which led to a Negative Declaration was the appropriate environmental document for the Sutter Parking Garage Expansion project and that the City should prepare and circulate an Environmental Impact Report (EIR) in lieu of the Negative Declaration.

However, the appeal letter does not offer any substantial evidence to support the claim for an EIR. As mentioned above, in the analysis of the appeal, staff is confident that the Initial Study adequately evaluated the Project’s environmental impacts and the Negative Declaration is the appropriate environmental determination for this project.

Subsequent to the appeal, City staff and Sutter’s legal counsel concluded that the Sutter Parking Garage Expansion meets the criteria as an Infill Project exempt from CEQA pursuant to CEQA Guidelines section 15332. To augment this conclusion, Raney Planning prepared an expert analysis that further supports this conclusion (Attachment 6). As described in the Raney analysis, the Parking Garage Expansion meets the following conditions required for a Class 32 in-fill development project: (a) The project is consistent with the applicable general plan designation and all applicable general plan policies as well as with applicable zoning designation and regulations; (b) The proposed development occurs within city limits on a project site of no more than five acres substantially surrounded by urban uses; (c) The project site has no value as habitat for endangered, rare or threatened species; (d) Approval of the project would not result in any significant effects relating to traffic, noise, air quality, or water quality; and (e) The site can be adequately served by all required utilities and public services. In addition, the proposed Parking Garage Expansion would not be disqualified from utilizing Section 15332 (In-fill projects) of the CEQA Guidelines under CEQA Guidelines Section 15300.2 because none of the exceptions to the exemption apply.

The conclusion that the project meets the criteria as an Infill Project exempt from CEQA pursuant to CEQA Guidelines section 15332 is to provide the City Council additional evidence that the project will not result in any significant impacts on the environment. The preparation of the Initial Study/Negative Declaration is to provide a more robust environmental review in support of the conclusion that the project will not result in any significant impacts on the environment. Staff and the applicant are confident that the Initial Study adequately evaluated the Project’s environmental impacts and the Negative Declaration is the appropriate environmental determination for this project. Therefore, staff recommends the City Council consider and adopt the proposed Negative Declaration.

CITY COUNCIL STRATEGIC PLAN/OVERARCHING GOALS
Goal D - Enhance economic vitality
Goal F - Invest in well-planned infrastructure and growth Respectfully Submitted,
Escarlet Mar, Associate Planner
Mike Isom, Development Services Director
_____________________________
Dominick Casey, City Manager
ATTACHMENTS:

Description
Attachment 1 Planning Commission Staff Report
Attachment 2 Lozeau Drury LLP Letter, dated May 11, 2022 Attachment 3 Memorandum to the Planning Commission, dated May 12, 2022 Attachment 4 Thomas Law Group Letter on behalf of Sutter Valley Hospitals, dated June 16, 2022 Attachment 5Appeal
Attachment 6 Raney Planning Memorandum
Exhibit A Initial Study Negative Declaration
Exhibit B.1 Plans
Exhibit B.2 Plans
Exhibit C Visual impact analysis
Exhibit D Materials & Color Board
Resolution 22-307

PLANNING DIVISION STAFF REPORT
PLANNING COMMISSION MEETING May 12, 2022
Prepared by: Escarlet Mar, Associate Planner
ITEM 6.2: Design Review Permit – 12 Medical Plaza – NERSP PCL 25 – Sutter Parking Garage Expansion – File #PL22-0024

REQUEST
The applicant requests approval of a Design Review Permit (DRP) to allow construction of a six-story parking garage as an expansion to an existing five-story parking garage located on the Sutter Roseville Medical Center campus. The new 192,000 square foot, six-story parking garage would provide an additional 551 parking stalls to the campus.

Applicant – Tony Amato, Dreyfuss + Blackford Architecture Property Owner – Sutter Valley Hospitals

SUMMARY RECOMMENDATION
The Planning Division recommends the Planning Commission take the following actions:

1. Adopt the Sutter Parking Garage Expansion & Sutter MOB 7 Negative Declaration; and

2. Adopt the four (4) findings of fact and approve the Design Review Permit subject to sixty-three (63) conditions of approval.

SUMMARY OF OUTSTANDING ISSUES
There are no outstanding issues associated with this request. The applicant has reviewed and is in agreement with all recommended conditions of approval.

BACKGROUND
The Sutter Roseville Medical Center (SRMC) campus is approximately 49-acres in size and is located in the Northeast Roseville Specific Plan (NERSP). The project site is approximately 0.94 acres in size and is located at 12 Medical Plaza Drive (see Figure 1). The project would result in the construction of an approximately 192,000-square foot parking structure, which would create an additional 551 parking stalls for the SRMC. The applicant proposes expanding the existing parking garage to support the existing campus as well as a newly proposed Medical Office Building (MOB) 7 (see Figure 1). MOB 7 is located just north of the proposed parking garage expansion and the application (File#PL22-0061) is currently under review by City staff. MOB 7 will ultimately result in 100,000square feet of medical office use. Based on the results of a parking study conducted by Fehr and Peers (Attachment 3), MOB 7 will require 332 spaces. The new parking garage will provide a majority of the necessary parking spaces.

The SRMC site has a General Plan designation of Business Professional (BP). The NERSP land use designation for the SRMC is Medical Campus, and the zoning designation is Planned Development for Medical Campus (PD 457). On October 26, 2006, the Planning Commission approved a Conditional Use Permit (CUP) to allow an increase in square footage of the SRMC from 804,000 square feet to 1,100,000 square feet. The updated overall campus plan which illustrated the additional acute care facilities and medical office buildings, as well as the associated parking area which is included in this staff report for reference (see Attachment 1). On June 26, 2014, the Planning Commission approved a Design Review Permit (DRP) to allow the construction of the SRMC Medical Office Building 6 (MOB 6) and a new parking garage. That project included a new 60,000 square MOB and a 476 space five-story parking garage to be located adjacent to MOB 3 (see Attachment 2).

NERSP PCL 25 – Sutter Parking Garage Expansion, 12 Medical Plaza; File #PL22-0024 Planning Commission – May 12, 2022 – Page 2 of 14
Figure 1: Project Location
Historically the Planning Commission has been the approving authority for the Sutter Campus Master Plan. The proposed project seeks a DRP to allow construction of a six-story parking garage as an expansion to an existing five-story parking garage located near the entrance to the campus from Secret Ravine Parkway. This application will continue to follow the same process already established by the previous Sutter entitlements for the SRMC.

SITE INFORMATION
Location: 12 Medical Plaza (046-060-034-000)
Total Size: 0.94 acres
Topography and Setting: The overall SRMC center has been developed throughout the years with an acute hospital, a bed tower, an acute rehabilitation center, medical office buildings, surface parking, a parking garage with a helipad, and a five-story parking garage. The proposed project is located adjacent to the existing five-story parking garage at the northeast corner of the SRMC. The site is surrounded by an existing temporary modular building and sterilization trailer to the north, medical office buildings to the east and south, and the existing five-story parking garage to the west. Currently, the project site is developed with a surface parking lot, landscaping and lighting. The site is currently being used for surface parking and also contains formal landscaping.

EVALUATION
The NERSP and subsequent Use Permit approved in 1994 established development standards for the medical campus. The architectural style, colors and materials were established through the initial buildings constructed on the site. Through the Design Review Permit process the City reviews proposed projects on the medical campus for consistency with applicable development standards, architectural design, and consistency with the NERSP standards and Zoning Ordinance requirements.

The evaluation of the Design Review Permit has been based on the applicable development and design standards within the City’s Zoning Ordinance, the City’s Community Design Guidelines (CDG), and the NERSP. Section 19.78.060(B) of the City of Roseville Zoning Ordinance requires four findings of fact be made in order to approve a Design Review Permit. The four findings for approval of the Design Review Permit are listed below in italicized, bold text and are followed by an evaluation of the project in relation to each finding.

Project
Site
Future MOB 7
(Separate
entitlement)
NERSP PCL 25 – Sutter Parking Garage Expansion, 12 Medical Plaza; File #PL22-0024 Planning Commission – May 12, 2022 – Page 3 of 14

1. The project as approved preserves and accentuates the natural features of the property, such as open space, topography, trees, wetlands and water courses; provides adequate drainage for the project; and allows beneficial use to be made of the site for development.

2. The project site design as approved provides open space; access; vehicle parking; vehicle, pedestrian and bicycle circulation; pedestrian walks and links to alternative modes of transportation; loading areas; landscaping; irrigation; and lighting which results in a safe, efficient, and harmonious development and which is consistent with the applicable goals, policies and objectives set forth in the General Plan, the Community Design Guidelines and the Northeast Roseville Specific Plan (NERSP).

3. The building design, including the materials, colors, height, bulk, size and relief, and the arrangement of the structures on the site, as approved is harmonious with other development and buildings in the vicinity and which is consistent with the applicable goals, policies and objectives set forth in the General Plan, the Community Design Guidelines and the Northeast Roseville Specific Plan.

4. The design of the public services, as approved, including, but not limited to, trash enclosures and service equipment are located so as not to detract from the appearance of the site, and are screened appropriately and effectively using construction materials, colors and landscaping that are harmonious with the site and the building designs.

As previously mentioned, the site is developed with an existing surface parking lot, landscaping, and lighting. The project as approved would not alter the natural features of the site, such as open space, topography, trees, wetlands, or water courses since the site has been previously disturbed and no natural features exist on the site. The project has been reviewed by the City’s Engineering Division and has been designed consistent with City standards related to drainage improvements and stormwater quality facilities. The proposed parking garage expansion is consistent with the site’s Business Professional land use designation, and support the existing use of the site.

Site Planning and Building Siting: The six-story parking garage expansion is situated approximately 385- feet from Secret Ravine Parkway to the east and approximately 1,200-feet from East Roseville Parkway to the south. Further, the parking garage is also approximately 406-feet from the closest apartment building to the north of the project site. Pursuant to the Design Guidelines of the NERSP, the parking garage expansion meets the setback requirements of the NERSP. An early concern with the size and height of the proposed garage was the potential for visual impacts to the surrounding area. The proposed garage will be visible from Secret Ravine Parkway, Roseville Parkway and the nearby Phoenician Apartments. The applicant provided a visual impact analysis (Exhibit C) that illustrates the proposed garage from several different view sheds. The proposed garage is located behind an existing three-story MOB on the Sutter Campus as well as other office buildings along Secret Ravine Parkway. These buildings as well as existing landscaping will provide visual relief for surrounding uses. As depicted in the visual impact study, while the proposed garage will be visible from off-site locations, it will not cause any negative visual impacts or significantly increase the amount of light or glare on the Phoenician Apartments to the north.

Vehicle Access and Circulation: The main vehicle access point into the new parking garage would occur from the east side of the building along Medical Plaza Drive. Two secondary access points are provided as shown in Figure 2 below. The existing driveways along Medical Plaza Drive would provide entrances to the surface parking lot behind the parking garage, and the existing Medical Office Building 3 (Figure 2).

NERSP PCL 25 – Sutter Parking Garage Expansion, 12 Medical Plaza; File #PL22-0024 Planning Commission – May 12, 2022 – Page 4 of 14
Figure 2: Vehicle Entrances
Pedestrian Access and Circulation: As part of the site improvements, the applicant proposes to remove the existing asphalt paving around the perimeter of the project site, as well as the existing surface parking lot. Sidewalks around the perimeter of the parking garage expansion would match the existing pedestrian walkway found adjacent to the existing parking garage, which include a five-foot sidewalk along Medical Plaza Drive and landscaping. The new parking garage will construct a sidewalk around the perimeter of the building that will connect to the adjacent sidewalks and provide pedestrian access to the parking garage.

Pedestrian connection between the future MOB 7 and the new parking garage will occur on the northern side of the parking garage across Medical Plaza Drive. In anticipation of the increase of foot traffic between the future MOB 7 and the new parking garage, the applicant proposes two (2) raised pedestrian crosswalks (Figure 3). The raised crosswalk would act as traffic calming measure and provide enhanced safety and visibility for pedestrians crossing between the medical office buildings and the parking garage.

As proposed, the project is consistent with the CDG related to pedestrian access and circulation.

Project
Site
MOB 3
NERSP PCL 25 – Sutter Parking Garage Expansion, 12 Medical Plaza; File #PL22-0024 Planning Commission – May 12, 2022 – Page 5 of 14
Figure 3: Proposed Raised Pedestrian Crosswalks
Elevations and Visual Impact Analysis: The NERSP and Environmental Impact Report requires that a visual impact analysis be performed prior to approval of building elevations for the Sutter Medical Campus. This visual analysis is required through the Design Review Permit process. The applicant has prepared the required visual analysis as shown in Exhibit C.

As shown below (Figure 4), the applicant proposes the six-story parking garage expansion to emulate the existing five-story parking garage. This includes using the same finish materials as found on the existing parking garage, including exposed concrete and cement plaster colored to match the existing garage finish. A new elevator and stair tower is proposed along the north side of the parking garage and will serve as a focal point for the garage. An additional egress stair is located at the southeast corner of the building. The architectural features and finishes of the elevator and stair towers will match the architectural language of the existing structure, including a glazed curtain wall at the elevator tower.

Figure 4: North Building Elevation
Proposed Expansion Existing Garage
Proposed Pedestrian
Crosswalks
NERSP PCL 25 – Sutter Parking Garage Expansion, 12 Medical Plaza; File #PL22-0024 Planning Commission – May 12, 2022 – Page 6 of 14
The proposed parking garage expansion would have an overall height of approximately 75-feet to the top of the stairs and elevator tower. The light standards on the six-floor of the garage would also be at approximately the same height as the elevator tower. Due to the change in grade where the parking garage expansion is proposed, the first floor of the garage will be partially below the elevation of Medical Plaza Drive and the existing garage. However, the expansion will connect both garages at each level.

The floor height of the garage will be approximately 11-feet from finished floor to finished floor. The visual analysis submitted by the applicant provides photo simulation of the proposed parking garage expansion from Secret Ravine Parkway and Medical Plaza, and the Phoenician Apartments located north of the project site (Exhibit C). While the proposed building may be visible from Secret Ravine Parkway and the existing apartment complex, its visual impacts will be minor due to its location within the SRMC, its proximity to other buildings, and being designed consistent with the other buildings in the campus. The height and scale of the parking garage expansion is also consistent with the existing parking garage onsite. Therefore, staff supports the proposed parking garage expansion design and height.

Parking: The NERSP Guidelines for Medical Campuses allows for parking standards to be modified by the Planning Commission if justified through a parking study. The drive aisles and parking space dimensions will meet the City’s Zoning Ordinance standards. The City’s Zoning Ordinance allows up to 30% of the total parking spaces to be designed as compact parking stalls. The applicant is proposing to construct the parking garage with a total of 33% compact parking stalls. This request is consistent with the previously approved parking garage. Given the smaller turning dimensions inside a parking garage it is quite common to have a greater number of compact spaces than surface parking lots. Staff finds the proposed parking garage expansion to be similar to the previous entitlements and is in compliance with the City’s Zoning Ordinance.

The applicant has submitted a parking study that was completed by Fehr and Peers and dated January 31, 2022 (Attachment 3). The study identifies a medical office parking ratio of 3.31 spaces per 1,000 square feet of gross building area. This rate was derived by conducting parking surveys of the campus and utilizing the Institute of Transportation Engineers (ITE) Parking generation, 5th Edition, to separate the amount of parking required for medical office uses versus hospital uses. As previously mentioned, the applicant proposes the construction of MOB 7 (File#PL22-0061) which necessitated the parking garage expansion. As a result, the Fehr and Peers parking study analyzed both projects (i.e. the parking garage and MOB 7) and found that the new MOB 7 would require 332 new parking spaces to meet the parking ratio of 3.31 spaces per 1,000 square feet of gross building area. The parking garage expansion would create 551 new parking spaces and when added to the 477 parking spaces in the existing parking garage would provide for a total of 1,028 parking spaces. These spaces will continue to support the existing uses within the campus as well as the proposed 100,000 square foot MOB 7. Overall, the parking garage design complies with the City’s Zoning Ordinance and the Community Design Guidelines.

Landscaping: Landscaping for the project site consists of a similar landscape palette as that of the existing parking garage. Landscaping is proposed around the perimeter of the parking garage expansion, including large shade trees (Sweet Bay, Callery Pear, Red Oak, and Black Locust) and smaller shade trees (Chinese Pistache, Lacebark Elm, Norway Maple, Armstrong Red Maple, Italian Alder, Columnar Atlas Cedar, and Maidenhair Tree). Shrubs ranging from six (6) inches to four (4) feet in height will be planted along the driveway entrance and the back of the parking garage. Overall, the landscape design is consistent with the existing plant palette used for the parking garage and is consistent with the CDG, the NERSP, and the City’s Water Efficient Landscape Ordinance.

Lighting: The parking garage will include LED pole-mounted lights, on the top parking deck, with an overall height of approximately eighteen (18) feet. This height complies with CDG Policy CC-90, which requires pole mounted lighting to be no taller than 25 feet. Consistent with CDG Policy CC-86, the lighting sources will have cut off lenses and be located to avoid light spillage and glare on adjacent properties.

In addition, the photometric plan demonstrates compliance with the City’s minimum lighting level requirements (0.5 foot-candles in pedestrian areas and 1.0 foot-candles in vehicle areas). Further, the visual impact analysis submitted by the applicant illustrates a night time view from the apartments which NERSP PCL 25 – Sutter Parking Garage Expansion, 12 Medical Plaza; File #PL22-0024 Planning Commission – May 12, 2022 – Page 7 of 14
shows how the proposed garage, in comparison to the existing parking garage, would appear in the evening. Overall, the proposed lighting of the parking garage expansion is consistent with the City’s Zoning Ordinance, the NERSP, and CDG standards.

CONCLUSION
The proposed project is consistent with the City’s General Plan, Zoning Ordinance, CDG, and the NERSP.

Based on the analysis contained in this staff report and with the project conditions, staff finds that the required findings for approval can be made for the proposed Design Review Permit.

PUBLIC OUTREACH
The proposed project was distributed to all internal and external agencies and departments who have requested such notice, and all comments or recommended conditions of approval have been incorporated into the project, as appropriate.

The applicant held a virtual neighborhood meeting on April 5, 2022. The applicant answered questions from the audience regarding the view sheds of the proposed parking garage expansion and the new MOB 7.

Additionally, a business owner asked if Sutter would provide a shuttle service for employees and patients to use during construction. The applicant is planning on providing a shuttle service while the project is under construction.

Early notification of the project was posted on the Roseville Coalition of Neighborhood Associations (RCONA)’s website. A notice of the public hearing was published in the Roseville Press Tribune on April 29, 2022 and a notice of the hearing was also distributed to all property owners within 300 feet of the site and posted on the RCONA website. No comments have been received as of publication of the staff report.

ENVIRONMENTAL DETERMINATION
The City of Roseville, acting as Lead Agency, prepared an Initial Study/ Negative Declaration (IS/ND) to evaluate the environmental effects of the project. Staff recommends the Planning Commission consider and adopt the proposed Negative Declaration (Exhibit A). The public review period for the proposed Negative Declaration began on April 12, 2022 and ended on May 2, 2022. The IS/ND was made available for public review online at: https://www.roseville.ca.us/cms/One.aspx?portalId=7964922&pageId=8774505. To date, no comments have been received.

RECOMMENDATION
The Planning Division recommends the Planning Commission take the following actions:

1. Adopt the Sutter Parking Garage Expansion & Sutter MOB 7 Negative Declaration.

2. Adopt the four (4) findings of fact and approve the DESIGN REVIEW PERMIT – 12 Medical Plaza – NERSP PCL 25 – Sutter Parking Garage Expansion –PL22-0024 subject to sixty-three (63) conditions of approval.

CONDITIONS OF APPROVAL FOR THE DESIGN REVIEW PERMIT – FILE #PL22-0024

1. This Design Review Permit approval shall be effectuated within a period of two (2) years from May 12, 2022 and if not effectuated shall expire on May 12, 2024. Prior to said expiration date, the applicant may apply for an extension of time, provided this approval does not extend the expiration beyond May 12, 2025. (Planning)

2. The project is approved as shown in Exhibits A - C and as conditioned or modified below. (Planning) NERSP PCL 25 – Sutter Parking Garage Expansion, 12 Medical Plaza; File #PL22-0024 Planning Commission – May 12, 2022 – Page 8 of 14

3. The project shall comply with all required environmental mitigation identified in Sutter Roseville MOB 6 and Parking Garage Mitigated Negative Declaration, and shall include all applicable mitigation measures as notes on the grading plans. (All Departments)

4. The project shall be addressed as 12 Medical Plaza. All projects with multi-tenants or buildings must submit a site plan with building footprint(s) to the Development Services Department (Business Services – Addressing) for building/suite addressing. (Business Services)

5. The applicant shall pay City’s actual costs for providing plan check, mapping, GIS, and inspection services. This may be a combination of staff costs and direct billing for contract professional services.

Project billing may occur up to two (2) months after the end of warranty or the Notice of Termination date for the SWPPP, whichever occurs later. (Engineering, Environmental Utilities, Electric, Finance)

6. The design and construction of all improvements shall conform to the Design and Construction Standards of the City of Roseville, or as modified by these conditions of approval, or as directed by the City Engineer. (Engineering)

7. The applicant shall not commence with any on-site improvements or improvements within the rightof-way until such time as grading and/or improvement plans have been submitted for review and are approved with grading and/or encroachment permits issued by the Department of Development Services – Engineering Division. (Engineering)

8. The approval of this project does not constitute approval of proposed improvements as to size, design, materials, or location, unless specifically addressed in these conditions of approval. The Developer shall submit civil drawings to the Department of Development Services – Engineering Division for review and approval. (Engineering)

9. Parking lot design shall conform to the City’s design standards, including the following minimum standards for parking stalls:
a. All parking stalls shall be double-striped. Parking stalls adjacent to sidewalks, landscaped areas or light fixtures, and all Accessible stalls shall abut a 6-inch raised curb or concrete bumper. (Planning)
b. Standard – 9 feet x 18 feet; Compact – 9 feet x 16 feet; Accessible – 14 feet x 18 feet (a 9-footwide parking area plus a 5-foot-wide loading area) and a minimum of one (1) parking space shall be Accessible van accessible – 17 feet x 18 feet (9-foot-wide parking area plus an 8-foot-wide loading area). (Planning)
c. An 'exterior routes of travel' site accessibility plan incorporating slope, cross-slope, width, pedestrian ramps, curb ramps, handrails, signage, detectable warnings or speed limit signs or equivalent means shall comprise part of the site improvement plans submitted to City for review, prior to building plan check approvals. This site accessibility plan shall also include:
i. Accessible parking stalls shall be dispersed and located closest to accessible entrances. The total number of accessible parking spaces shall be established by Table 11B-208.2 of the CBC.
ii. Accessible Parking spaces and crosswalks shall be signed, marked and maintained as required by Chapter 11 of the CBC.
iii. Accessible parking and exterior route of travel shall comply with CBC, Sections 11B-206 and 11B-208. (Building)
NERSP PCL 25 – Sutter Parking Garage Expansion, 12 Medical Plaza; File #PL22-0024 Planning Commission – May 12, 2022 – Page 9 of 14

10. Signs and/or striping shall be provided on-site as required by the Planning Department to control onsite traffic movements. Parking lot striping and signage shall be maintained in a visible and legible manner. (Planning)

11. The plans submitted to the Building Division for permits shall indicate all approved revisions/alterations as approved by the Commission including all conditions of approval. (Planning)

12. The project Landscape Plans shall comply with the following:
a. The Landscape Plan shall indicate the location of, and be designed to avoid conflicts with, all pole-mounted light fixtures and utility equipment including (but not limited to) electric transformers, switchgear, and overhead lines; backflow preventers; fire department connections; and public water, sewer, and storm drain facilities. (Planning, Fire, Environmental Utilities, Electric, Engineering)
b. The tree plantings in the parking lot shall be designed to provide a minimum of 50% shade coverage after 15 years. (Planning)
c. At a minimum, landscaped areas not covered with live material shall be covered with a rock, (3") bark (no shredded bark) or (3") mulch covering. (Planning) d. The landscape plan shall comply with the Landscape Guidelines for Northeast Roseville Specific Plan and the City of Roseville Water Efficient Landscape Ordinance. (Planning, Environmental Utilities)
e. Landscaping adjacent to preserve areas shall consist of California native, drought-tolerant groundcover, shrubs, plants, and trees. (Open Space, Planning) f. All landscaping in areas containing electrical service equipment shall conform to the Electric Department's Landscape Requirements and Work Clearances as outlined in Section 10.00 of the Departments "Specification for Commercial Construction." (Electric) g. Slopes within landscape planters shall be no more than 3:1. A two-foot flat bench located at backof-walk shall be included in the landscape area to slow or allow absorption of nuisance run-off from the planters. (Parks, Recreation, and Libraries)
h. All landscaping shall conform to the standards of crime prevention through environmental design with the intent to create natural surveillance, controlling access, and territorial reinforcement to property boundaries. (Police)

13. Any roof-mounted equipment and satellite dishes proposed shall be shown on the building plans.

The equipment shall be fully screened from public streets and the surrounding properties. (Planning)

14. At the time of building permit application and plan submittal, the project applicant shall submit a proposed plan which shows the proposed suite addressing for individual tenant spaces within the building. The Building Official, or the designee, shall approve said plan prior to building permit approval. Refer to the City of Roseville Addressing Guidelines. (Building)

15. A separate Architectural Site Accessibility Plan which details the project's site accessibility information as required by California Title 24, Part 2 shall be submitted as part of the project Building Permit Plans. (Building)

16. For Multiple Building Complexes: As part of the required Architectural Site Accessibility Plan, the developer shall delineate the extent of the site accessibility improvements being installed as part of NERSP PCL 25 – Sutter Parking Garage Expansion, 12 Medical Plaza; File #PL22-0024 Planning Commission – May 12, 2022 – Page 10 of 14
the initial improvements for the project, and those that are planned to be developed as part of subsequent phases (i.e. around future pad buildings). (Building)

17. Building permit plans shall comply with all applicable code requirements (California Building Code – CBC – based on the International Building Code, California Green Building Standards Code–CGBSC, California Mechanical Code – CMC – based on the Uniform Mechanical Code, California Plumbing Code – CPC – based on the Uniform Plumbing Code, California Fire Code – CFC – based on the International Fire Code – with City of Roseville Amendments – RFC, California Electrical Code – CEC – based on the National Electrical Code, and California Energy Standards – CEC T-24 Part 6), California Title 24 and the American with Disabilities Act - ADA requirements, and all State and Federally mandated requirements in effect at the time of submittal for building permits (contact the Building Division for applicable Code editions). (Building)

18. For restaurants, other food services, or commercial swimming pools: The developer shall obtain all required approvals and permits from the Placer County Health Department and the City of Roseville Industrial Waste Division. (Building, Environmental Utilities)

19. Maintenance of copy of building plans: Health and Safety Code section 19850 requires the building department of every city or county to maintain an official copy of the building plans for the life of the building. As such, each individual building shall be submitted as a separate submittal package.

Building plan review, permit issuance and archiving is based on each individual building address. (Building)

20. For all work to be performed off-site, permission to enter and construct shall be obtained from the property owner, in the form of a notarized right-of-entry. Said notarized right-of-entry shall be provided to Public Works prior to approval of any plans. (Engineering)

21. The Improvement Plans shall include a complete set of Landscape Plans. The Landscape Plans shall be approved with the Improvement Plans. (Planning, Engineering, Fire, Environmental Utilities, Electric)

22. A note shall be added to the grading plans that states:
“Prior to the commencement of grading operations, the contractor shall identify the site where the excess/borrow earthen material shall be imported/deposited. If the borrow/deposit site is within the City of Roseville, the contractor shall produce a report issued by a geotechnical engineer to verify that the exported materials are suitable for the intended fill, and shall show proof of all approved grading plans. Haul routes to be used shall be specified.” (Engineering)

23. The applicant shall dedicate all necessary rights-of-way or Public Utility Easement for the widening of any streets or transfer of public utilities across and over any portion of the property as required with this entitlement. A separate document shall be drafted for approval and acceptance by the City of Roseville, and recorded at the County Recorder’s Office. (Engineering)

24. Bike parking and clean air vehicle spaces shall be provided per the California Green Building Standards. Bike rack/locker design and location shall be approved by Alternative Transportation. Clean Air spaces shall be marked “CLEAN AIR/CARPOOL/EV”. (Alternative Transportation, Building).

25. All storm drainage, including roof drains, shall be collected on site and treated with Best Management Practices (BMP’s) per the City’s Stormwater Quality Design Manual. All storm water shall be routed to the nearest existing storm drain system or natural drainage facility. Drain outfalls shall extend down to the receiving water and shall be constructed with adequate velocity attenuation devices. The grading/improvement plans for the site shall be accompanied with a shed map that defines that area tributary to this site and all drainage facilities shall be designed to accommodate the tributary flow. The NERSP PCL 25 – Sutter Parking Garage Expansion, 12 Medical Plaza; File #PL22-0024 Planning Commission – May 12, 2022 – Page 11 of 14
storm drain system and proposed BMP’s shall be privately owned and maintained by the property owner.

Prior to the issuance of any permits, the owner shall provide a plan for the maintenance of the proposed BMP’s. (Engineering)

26. Prior to the approval of the Improvement Plans, the project proponent shall provide proof of preparation and submittal of a Storm Water Pollution Prevention Plan (SWPPP) to the Regional Water Quality Control Board (RWQCB). Proof shall be in the form of the Waste Discharge Identification Number (WDID#), provided to the applicant from RWQCB, placed on the coversheet of the improvement plans. Upon approval of the improvement plans, a copy of the SWPPP shall be required onsite and available for viewing by City inspection staff upon request. (Engineering)

27. The developer shall be responsible for any necessary relocation of signal interconnect cables that may require re-location as a result of the construction of turn lanes and/or driveways. (Engineering)

28. To ensure that the design for any necessary widening, construction, or modifications of Public Streets does not conflict with existing dry utilities generally located behind the curb and gutter, and prior to the submittal of design drawings for those frontage improvements, the project proponent shall have the existing dry utilities pot holed for verification of location and depth. (Engineering)

29. Sight distances for all driveways shall be clearly shown on the improvement plans to verify that minimum standards are achieved. It will be the responsibility of the project proponent to provide appropriate landscaping and improvement plans, and to relocate and/or modify existing facilities as needed to meet these design objectives. (Engineering)

30. The applicant shall remove and reconstruct any existing damaged curb, gutter, and sidewalk along the property frontage. During plan check of the improvement plans and/or during inspection, Public Works will designate the exact areas to be reconstructed. Any existing public facilities damaged during the course of construction shall be repaired by the property owner and at the property owner’s expense, to the satisfaction of the City. (Public Works)

31. Prior to the approval of the improvement plans, it will be the project proponent’s responsibility to pay the standard City Trench Cut Recovery Fee for any cuts within the City streets that are required for the installation of underground utilities. (Engineering)

32. Prior to the issuance of building permits, the property owner shall pay into the following fee programs:

Citywide Drainage Fee, Citywide Traffic Mitigation Fee (TMF), Highway 65 Joint Partners Association (JPA), South Placer Regional Transportation Authority (SPRTA), and City/County Fee. (Engineering)

33. The applicant/developer shall update the Transportation Systems Management (TSM) Plan for Sutter Roseville to be reviewed and approved by the Transportation Commission. (Alternative Transportation)

34. Prior to the issuance of a grading permit or approval of Improvement Plans, the grading plans shall clearly identify all existing water, sewer and recycled water utilities within the boundaries of the project (including adjoining public right of way). Existing utilities shall be identified in plan-view and in profileview where grading activities will modify existing site elevations over top of or within 15 feet of the utility. Any utilities that could potentially be impacted by the project shall be clearly identified along with the proposed protection measures. The developer shall be responsible for taking measures and incurring costs associated with protecting the existing water, sewer and recycled water utilities to the satisfaction of the Environmental Utilities Director. (Environmental Utilities)

35. The design and installation of all fire protection equipment shall conform to the California Fire Code and the amendments adopted by the City of Roseville, along with all standards and policies implemented by the Roseville Fire Department. (Fire)
NERSP PCL 25 – Sutter Parking Garage Expansion, 12 Medical Plaza; File #PL22-0024 Planning Commission – May 12, 2022 – Page 12 of 14

36. The applicable codes and standards adopted by the City shall be enforced at the time construction plans have been submitted to the City for permitting. (Fire)

37. The Electric Department requires the submittal of the following information in order to complete the final electric design for the project:
a. one (1) set of improvement plans
b. load calculations
c. electrical panel one-line drawings

38. All on-site external lighting shall be installed and directed to have no off-site glare. Lighting within the parking areas and pedestrian walkways shall provide a maintained minimum of one (1) foot-candle, and 0.5 foot-candle of light, respectively. All exterior light fixtures shall be vandal resistant. (Planning, Police)

39. The parking lot shall have properly posted signs that state the use of the parking area is for the exclusive use of employees and customers of this project. (See California Vehicle Code Sections 22507.8, 22511.5, 22511.8, 22658(a), and the City of Roseville Municipal Code Section 11.20.110).

The location of the signs shall be shown on the approved site plan. (Planning, Police)

40. It is the developer's responsibility to notify PG&E of any work required on PG&E facilities. (PG&E) DURING CONSTRUCTION & PRIOR TO ISSUANCE OF OCCUPANCY PERMITS:

41. The following easements shall be provided by separate instrument and shown on the site plan, unless otherwise provided for in these conditions:
a. Additional internal easements will be required to cover primary electrical facilities to the project when the final electrical design is completed. (Electric) b. Other easements (please specify). (Electric, Engineering, Environmental Utilities)

42. Easement widths shall comply with the City's Improvement Standards and Construction Standards.

Separate document easements required by the City shall be prepared in accordance with the City's "Policy for Dedication of Easements to the City of Roseville". All legal descriptions shall be prepared by a licensed land Surveyor. All existing public utility, electric, water, sewer and reclaimed water easements shall be maintained unless otherwise authorized by these conditions of approval. (Engineering, Environmental Utilities, Electric)

43. All improvements being constructed in accordance with the approved grading and improvement plans shall be accepted as complete by the City. (Engineering)

44. The words "traffic control appurtenances" shall be included in the list of utilities allowed in public utilities easements (PUE's) located along public roadways. (Engineering)

45. The applicant/developer shall update the Transportation Systems Management (TSM) Agreement for Sutter Roseville to be reviewed and approved by the City Manager. (Engineering, Alternative Transportation)

46. All Electric Department facilities, including streetlights where applicable, shall be designed and built to the "City of Roseville Specifications for Commercial Construction." (Electric)

47. The City of Roseville Electric Department has electrical construction charges which are to be paid by the developer and which are explained in the City of Roseville "Specification for Commercial NERSP PCL 25 – Sutter Parking Garage Expansion, 12 Medical Plaza; File #PL22-0024 Planning Commission – May 12, 2022 – Page 13 of 14
Construction." These charges will be determined upon completion of the final electrical design. (Electric)

48. Any relocation, rearrangement, or change of existing electric facilities due to this development shall be at the developer's expense. (Electric)

49. Any facilities proposed for placement within public/electric utility easements shall be subject to review and approval by the Electric Department before any work commences in these areas. This includes, but is not limited to, landscaping, lighting, paving, signs, trees, walls, and structures of any type. (Electric)

50. All electric metering shall be directly outside accessible. This can be accomplished in any of the following ways:
a. Locate the metered service panel on the outside of the building. b. Locate the metered service panel in a service room with a door that opens directly to the outside.

The developer will be required to provide a key to the door for placement in a lock box to be installed on the outside of the door. Any doors leading from the service room to other areas of the building shall be secured to prohibit unauthorized entry. (Electric)

51. One ¾-inch conduit with a 2-pair phone line shall be installed from the building’s telephone service panel to the meter section of the customer's electrical switchgear or panel. (Electric)

52. It is the responsibility of the developer to ensure that all existing electric facilities remain free and clear of any obstruction during construction and when the project is complete. (Electric)

53. Signs shown on the elevations are not approved as part of the Design Review Permit. A Sign Permit is required for all project signs. (Planning)

54. Following the installation of the landscaping, all landscape material shall be maintained in a healthy and weed-free condition; dead plant material shall be replaced immediately. All trees shall be maintained and pruned in accordance with the accepted practices of the International Society of Arboriculture (ISA). (Planning)

55. The City reserves the right to restrict vehicle turning movements within the public right-of-way in the future if deemed necessary by the City Engineer. (Engineering)

56. The required width of fire apparatus access roads shall not be obstructed in any manner, including the parking of vehicles. Minimum required widths and vertical clearances established by the Fire Code shall be maintained at all times during construction. Closure of accesses for fire apparatus by gates, barricades and other devices shall be prohibited unless approved by the Fire Chief. (Fire)

57. Temporary aboveground storage tanks may be used at construction sites for diesel fuel only and shall not exceed 1,000 gallon capacity. Tanks shall comply with all provisions found within the Fire Code.

A Fire Department Permit shall be obtained prior to tank installation. The permit shall expire after 90 days from the date of issuance, unless extended by the Fire Chief. (Fire)

58. If site survey or earth moving work results in the discovery of hazardous materials in containers or what appears to be hazardous wastes released into the ground, the contractor or person responsible for the building permit must notify the Roseville Fire Department immediately. A representative from the Fire Department will make a determination as to whether the incident is reportable of not and if site remediation is required. (Fire)
NERSP PCL 25 – Sutter Parking Garage Expansion, 12 Medical Plaza; File #PL22-0024 Planning Commission – May 12, 2022 – Page 14 of 14

59. The location and design of the gas service shall be determined by PG&E. The design of the gas service for this project shall not begin until PG&E has received a full set of City approved improvement plans for the project. (PG&E)

60. The project is subject to the noise standards established in the City's Noise Ordinance. In accordance with the City's Noise Ordinance, project construction is exempt between the hours of seven a.m. and seven p.m. Monday through Friday, and between the hours of eight a.m. and eight p.m. Saturday and Sunday, provided that all construction equipment shall be fitted with factory installed muffling devices and be maintained in good working order. (Building)

61. The developer (or designated consultant) shall certify that the building foundation location has been placed according to all approved setback requirements shown on the approved site plan. The developer shall prepare a written statement confirming building placement and provide an original copy to the City Building Division Field Inspector at the time of or prior to the foundation inspection. (Building)

62. Prior to Certificate of Occupancy, the applicant may apply for a Temporary Certificate of Occupancy (TCO) of the building. If a TCO is desired, the applicant must submit a written request to the Building Division a minimum of thirty (30) days prior to the expected temporary occupancy date and shall include a schedule for occupancy and a description of the purpose for the Temporary Certificate of Occupancy. (Building)

63. Concurrent with submittal for plan check and prior to a request for final building inspection, the applicant may request City approval of an occupancy phasing plan to allow individual or multiple building occupancies. This request shall be made in writing to the Building Division and shall include of the following:
a. A description of measures that will be undertaken to minimize conflict between residents/building occupants and construction traffic (e.g. fencing, etc.); b. A phasing plan showing the proposed buildings, internal roads and access routes, landscaping, trash enclosure locations, and any other improvements planned for each phase; and c. An estimated time frame for each phase and a specific date for the first phase. (Planning, Building)

ATTACHMENTS

1. Approved 2006 Sutter Master Plan

2. Approved 2014 Overall Campus Site Plan

3. Fehr and Peers Parking Study for Sutter Roseville Medical Center

EXHIBITS
A. Initial Study/Negative Declaration
B. Plans
C. Visual impact analysis
Note to Applicant and/or Developer: Please contact Planning Division staff at (916) 774-5276 prior to the Commission meeting if you have any questions on any of the recommended conditions for your project. If you challenge the decision of the Commission in court, you may be limited to raising only those issues which you or someone else raised at the public hearing held for this project, or in written correspondence delivered to the Planning Manager at, or prior to, the public hearing.

VIA EMAIL ONLY
May 11, 2022
Robert Jense, Chair
Jonathan Martin, Vice Chair
Erich Brashears
Justin Caporusso
Tracy Covington
Clifford Haggenjos, Jr.

John Prior
Planning Commission
City of Roseville
311 Vernon Street
Roseville, CA 95678
[email protected]
Escarlet Mar, Associate Planner
Planning Division
City of Roseville
311 Vernon Street
Roseville, CA 95678
[email protected]
Re: Sutter Parking Garage Expansion and Medical Office Building 7 Negative Declaration (File Nos. PL22-0024, PL22-0061)
Planning Commission Agenda Item 6.2 (May 12, 2022)
Dear Chair Jense, Vice Chair Martin, Honorable Planning Commissioners, and Ms. Mar, I am writing on behalf of the Laborers International Union of North America, Local Union 185 and its members (“LIUNA”) living in and around the City of Roseville (“City”) regarding the Negative Declaration (“ND”) prepared for the Sutter Parking Garage Expansion and Medical Office Building 7 Project (“Project”) (File Nos. PL22-0024, PL22-0061) to be heard as Agenda Item 6.2 at the Planning Commission’s May 12, 2022 meeting.

LIUNA’s review of the ND was assisted by indoor air quality expert Francis Offermann, PE, CIH, noise expert Deborah Jue of Wildon Ihrig, and air quality experts Matt Hagemann, P.G., C.Hg., and Paul E. Rosenfeld, Ph.D., of the Soil/Water/Air Protection Enterprise (“SWAPE”). The written comments of Mr. Offermann, Ms. Jue, and SWAPE are attached hereto as Exhibit A, Exhibit B and Exhibit C, respectively. Based on their review, it appears that several of the MND’s conclusions are not supported by substantial evidence and, moreover, there is a “fair argument” that the Project may have unmitigated adverse environmental impacts. As required by CEQA, LIUNA requests that the City prepare an environmental impact report (“EIR”) rather than a ND prior to approving the Project.

LIUNA Comment
Sutter Parking Garage Expansion & MOB 7 (File Nos. PL22-0024, PL22-0061) May 11, 2022

PROJECT DESCRIPTION
The Project consists of two components: (1) the expansion of an existing five-story parking garage with a six-story parking addition (“Garage Expansion”) and (2) a new medical office building (“MOB”). Both components are located within the existing 49-acre Sutter Roseville Medical Center campus, specifically on the northeastern area of the campus. The Garage Expansion is proposed to be located immediately to the east of the existing five-story parking garage and be connected to the future parking garage at each level. The MOB would be located along the east edge of the campus, north of the existing five-story parking garage and east of the existing MOB4.

The Garage Expansion site is approximately 0.94 acres in size and contains an existing surface parking lot with lighting and landscaping. The MOB site is approximately 1.64 acres in size and is developed with surface parking, lighting, and landscaping. The MOB site is surrounded by an existing private dental clinic to the south and an apartment complex to the east.

The MOB is proposed to be constructed in two-phases: Phase 1 would consists of the four-story building and Phase 2 would consist of a two-story addition on the front of the building.

LEGAL STANDARD FOR NEGATIVE DECLARATIONS
As the California Supreme Court held, “[i]f no EIR has been prepared for a nonexempt project, but substantial evidence in the record supports a fair argument that the project may result in significant adverse impacts, the proper remedy is to order preparation of an EIR.” (Communities for a Better Env’t v. South Coast Air Quality Mgmt. Dist. (2010) 48 Cal.4th 310, 319-20.) “Significant environmental effect” is defined very broadly as “a substantial or potentially substantial adverse change in the environment.” (Pub. Res. Code [“PRC”] § 21068; see also 14 CCR § 15382.) An effect on the environment need not be “momentous” to meet the CEQA test for significance; it is enough that the impacts are “not trivial.” (No Oil, Inc. v. City of Los Angeles (1974) 13 Cal.3d 68, 83.) “The ‘foremost principle’ in interpreting CEQA is that the Legislature intended the act to be read so as to afford the fullest possible protection to the environment within the reasonable scope of the statutory language.” (Communities for a Better Env’t v. Cal. Res. Agency (2002) 103 Cal.App.4th 98, 109.) The EIR is the very heart of CEQA. (Bakersfield Citizens for Local Control v. City of Bakersfield (2004) 124 Cal.App.4th 1184, 1214 (Bakersfield Citizens); Pocket Protectors v. City of Sacramento (2004) 124 Cal.App.4th 903, 927.) The EIR is an “environmental ‘alarm bell’ whose purpose is to alert the public and its responsible officials to environmental changes before they have reached the ecological points of no return.” (Bakersfield Citizens, supra, 124 Cal.App.4th at 1220.) The EIR also functions as a “document of accountability,” intended to “demonstrate to an apprehensive citizenry that the agency has, in fact, analyzed and considered the ecological implications of its action.” (Laurel Heights Improvements Assn. v. Regents of Univ. of Cal. (1988) 47 Cal.3d 376, 392.) The EIR process “protects not only the environment but also informed self-government.” (Pocket Protectors, supra, 124 Cal.App.4th at 927.) LIUNA Comment
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An EIR is required if “there is substantial evidence, in light of the whole record before the lead agency, that the project may have a significant effect on the environment.” (PRC § 21080(d); see also Pocket Protectors, supra, 124 Cal.App.4th at 927.) In very limited circumstances, an agency may avoid preparing an EIR by issuing a negative declaration unless there is a “fair argument” that the project will have a significant environmental effect. (PRC, §§ 21100, 21064.) Since “[t]he adoption of a negative declaration . . . has a terminal effect on the environmental review process,” by allowing the agency “to dispense with the duty [to prepare an EIR],” negative declarations are allowed only in cases where “the proposed project will not affect the environment at all.” (Citizens of Lake Murray v. San Diego (1989) 129 Cal.App.3d 436, 440.) A mitigated negative declaration is proper only if the project revisions would avoid or mitigate the potentially significant effects identified in the initial study “to a point where clearly no significant effect on the environment would occur, and . . . there is no substantial evidence in light of the whole record before the public agency that the project, as revised, may have a significant effect on the environment.” (Mejia v. City of Los Angeles (2005) 130 Cal.App.4th 322, 331 [quoting PRC §§ 21064.5, 21080(c)(2)].) In that context, “may” means a reasonable possibility of a significant effect on the environment. (PRC §§ 21082.2(a), 21100, 21151(a); Pocket Protectors, supra, 124 Cal.App.4th at 927; League for Protection of Oakland's etc.

Historic Res. v. City of Oakland (1997) 52 Cal.App.4th 896, 904-05.) Under the “fair argument” standard, an EIR is required if any substantial evidence in the record indicates that a project may have an adverse environmental effect—even if contrary evidence exists to support the agency’s decision. (14 CCR § 15064(f)(1); Pocket Protectors, supra, 124 Cal.App.4th at 931; Stanislaus Audubon Society v. County of Stanislaus (1995) 33 Cal.App.4th 144, 150-51; Quail Botanical Gardens Found., Inc. v. City of Encinitas (1994) 29 Cal.App.4th 1597, 1602.) The “fair argument” standard creates a “low threshold” favoring environmental review through an EIR rather than through issuance of negative declarations or notices of exemption from CEQA. (Pocket Protectors, supra, 124 Cal.App.4th at 928.) The “fair argument” standard is virtually the opposite of the typical deferential standard accorded to agencies. As a leading CEQA treatise explains:

This ‘fair argument’ standard is very different from the standard normally followed by public agencies in making administrative determinations. Ordinarily, public agencies weigh the evidence in the record before them and reach a decision based on a preponderance of the evidence. [Citations]. The fair argument standard, by contrast, prevents the lead agency from weighing competing evidence to determine who has a better argument concerning the likelihood or extent of a potential environmental impact. The lead agency’s decision is thus largely legal rather than factual; it does not resolve conflicts in the evidence but determines only whether substantial evidence exists in the record to support the prescribed fair argument. (Kostka & Zishcke, Practice Under CEQA, §6.29, pp. 273-74.) The Courts have explained that “it is a question of law, not fact, whether a fair argument exists, and the courts owe no deference LIUNA Comment
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to the lead agency’s determination. Review is de novo, with a preference for resolving doubts in favor of environmental review.” (Pocket Protectors, supra, 124 Cal.App.4th at 928.)

DISCUSSION
I. The proposed Conditions of Approval contain environmental mitigation measures that are not discussed or incorporated in the ND’s analysis of the Project.

According to Staff’s proposed Conditions of Approval, “The project shall comply with all required environmental mitigation identified in Sutter Roseville MOB 6 and Parking Garage Mitigated Negative Declaration.” (Staff Report, p. 8.) However, there is no mention of the Sutter Roseville MOB 6 and Parking Garage Mitigated Negative Declaration (“MOB 6 MND”) or its mitigation measures in the ND. The ND lists three “environmental documents relied upon” for its analysis of the Project: (1) 2035 General Plan Update Final Environmental Impact Report; (2) Northeast Roseville Specific Plan Environmental Impact Report; and (3) Sutter Roseville Medical Center Master Plan Environmental Impact Report. The ND makes no mention of mitigation measures from those environmental documents or any other environmental document, including the MOB 6 MND.

Rather than discuss mitigation measures that may be applied to the Project from other EIRs and MNDs, the ND simply concluded that every single environmental impact of the Project would be less than significant without mitigation. (See, e.g., Initial Study, pp. 13 [Air Quality], 20 [Energy], 24 [Greenhouse gases], 26 [Hazards], 33 [Noise].) If the Project requires mitigation measures from the MOB 6 MND to ensure less-than-significant impacts, then those mitigation measures must be discussed and incorporated into the ND. Because the ND does not mention the MOB 6 MND at all, the ND’s conclusions are not supported by substantial evidence and it should be revised prior to further consideration of the Project.

II. An EIR is required to disclose and the Project’s significant indoor air quality impacts from emissions of formaldehyde.

The ND fails to address the significant health risks posed by the Project from formaldehyde, a toxic air contaminant (“TAC”). Certified Industrial Hygienist, Francis Offermann, PE, CIH, has conducted a review of the Project, the ND, and relevant documents regarding the Project’s indoor air emissions. Mr. Offermann is one of the world’s leading experts on indoor air quality, in particular emissions of formaldehyde, and has published extensively on the topic. As discussed below and set forth in Mr. Offermann’s comments, the Project’s emissions of formaldehyde to air in the MOB will result in very significant cancer risks to future employees. Mr. Offermann’s expert opinion and calculation present a “fair argument” that the Project may have significant health risk impacts as a result of these indoor air pollution emissions, which were not discussed, disclosed, or analyzed in the ND. These impacts must be addressed in an EIR. Mr. Offermann’s comment and CV are attached as Exhibit A.

LIUNA Comment
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Formaldehyde is a known human carcinogen and listed by the State as a TAC. The Placer County Air Pollution Control District (“PCAPCD”) has established a significance threshold of health risks for carcinogenic TACs of 10 in a million. (Ex. A, p. 2.) The ND fails to acknowledge the significant indoor air emissions that will result from the Project. Specifically, there is no discussion of impacts or health risks, no analysis, and no identification of mitigations for significant emissions of formaldehyde to air from the Project.

Mr. Offermann explains that many composite wood products typically used building construction contain formaldehyde-based glues which off-gas formaldehyde over a very long time period. He states, “The primary source of formaldehyde indoors is composite wood products manufactured with urea-formaldehyde resins, such as plywood, medium density fiberboard, and particle board. These materials are commonly used in residential, office, and retail building construction for flooring, cabinetry, baseboards, window shades, interior doors, and window and door trims.” (Ex. A, pp. 2-3.)
Mr. Offermann states that future employees of the MOB will be exposed to a cancer risk from formaldehyde of approximately 17.7 per million, even assuming that all materials are compliant with the California Air Resources Board’s formaldehyde airborne toxics control measure. (Ex. A, p. 4.) This exceeds PCAPCD’s CEQA significance thresholds for airborne cancer risk of 10 per million. (Id.) Mr. Offermann concludes that these significant environmental impacts must be analyzed in an EIR and mitigation measures should be imposed to reduce the risk of formaldehyde exposure. (Id. at pp. 4, 11-12.) He prescribes a methodology for estimating the Project’s formaldehyde emissions in order to do a more project-specific health risk assessment. (Id. at pp. 5-9.). Mr. Offermann also suggests several feasible mitigation measures, such as requiring the use of no-added-formaldehyde composite wood products, which are readily available. (Id. at pp. 11-12.) Mr. Offermann also suggests requiring air ventilation systems which would reduce formaldehyde levels. (Id. at p. 12.) Since the ND does not analyze this impact at all, none of these or other mitigation measures have been considered.

When a Project exceeds a duly adopted CEQA significance threshold, as here, this alone establishes substantial evidence that the project will have a significant adverse environmental impact. Indeed, in many instances, such air quality thresholds are the only criteria reviewed and treated as dispositive in evaluating the significance of a project’s air quality impacts. (See, e.g.

Schenck v. County of Sonoma (2011) 198 Cal.App.4th 949, 960 [County applies Air District’s “published CEQA quantitative criteria” and “threshold level of cumulative significance”]; Communities for a Better Environment v. California Resources Agency (2002) 103 Cal.App.4th 98, 110-111 [“A ‘threshold of significance’ for a given environmental effect is simply that level at which the lead agency finds the effects of the project to be significant”].) The California Supreme Court made clear the substantial importance that an air district significance threshold plays in providing substantial evidence of a significant adverse impact. (Communities for a Better Environment v. South Coast Air Quality Management Dist. (2010) 48 Cal.4th 310, 327 [“As the District’s established significance threshold for NOx is 55 pounds per day, these estimates [of NOx emissions of 201 to 456 pounds per day] constitute substantial evidence supporting a fair argument for a significant adverse impact.”].) Since expert evidence LIUNA Comment
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demonstrates that the Project will exceed the PCAPCD’s CEQA significance threshold, there is substantial evidence that an “unstudied, potentially significant environmental effect[]” exists. (See Friends of Coll. of San Mateo Gardens v. San Mateo Cty. Cmty. Coll. Dist. (2016) 1 Cal.5th 937, 958 [emphasis added].) As a result, the City must prepare an EIR for the Project to address this impact and identify enforceable mitigation measures.

The failure of the ND to address the Project’s formaldehyde emissions is contrary to the California Supreme Court’s decision in California Building Industry Ass’n v. Bay Area Air Quality Mgmt. Dist. (2015) 62 Cal.4th 369, 386 (CBIA). In that case, the Supreme Court expressly holds that potential adverse impacts to future users and residents from pollution generated by a proposed project must be addressed under CEQA. At issue in CBIA was whether the Air District could enact CEQA guidelines that advised lead agencies that they must analyze the impacts of adjacent environmental conditions on a project. The Supreme Court held that CEQA does not generally require lead agencies to consider the environment’s effects on a project. (CBIA, supra, 62 Cal.4th at 800-01.) However, to the extent a project may exacerbate existing environmental conditions at or near a project site, those would still have to be considered pursuant to CEQA. (Id. at 801.) In so holding, the Court expressly held that CEQA’s statutory language required lead agencies to disclose and analyze “impacts on a project’s users or residents that arise from the project’s effects on the environment.” (Id. at 800.) The carcinogenic formaldehyde emissions identified by Mr. Offermann are not an existing environmental condition. Those emissions to the air will be from the Project. People will be working inside the MOB once it is built and begins emitting formaldehyde. Once built, the MOB will begin to emit formaldehyde at levels that pose significant direct and cumulative health risks. The Supreme Court in CBIA expressly finds that this type of air emission and health impact by the project on the environment and a “project’s users and residents” must be addressed in the CEQA process. The existing TAC sources near the Project site would have to be considered in evaluating the cumulative effect on future residents of both the Project’s TAC emissions as well as those existing off-site emissions.

The Supreme Court’s reasoning is well-grounded in CEQA’s statutory language. CEQA expressly includes a project’s effects on human beings as an effect on the environment that must be addressed in an environmental review. “Section 21083(b)(3)’s express language, for example, requires a finding of a ‘significant effect on the environment’ (§ 21083(b)) whenever the ‘environmental effects of a project will cause substantial adverse effects on human beings, either directly or indirectly.’” (CBIA, supra, 62 Cal.4th at 800 [emphasis in original].) Likewise, “the Legislature has made clear—in declarations accompanying CEQA’s enactment—that public health and safety are of great importance in the statutory scheme.” (Id., citing e.g., §§ 21000, subds. (b), (c), (d), (g), 21001, subds. (b), (d).) It goes without saying that the thousands of future residents at the Project are human beings and the health and safety of those residents must be subjected to CEQA’s safeguards.

The City has a duty to investigate issues relating to a project’s potential environmental impacts. (See County Sanitation Dist. No. 2 v. County of Kern, (2005) 127 Cal.App.4th 1544, LIUNA Comment
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1597–98. [“[U]nder CEQA, the lead agency bears a burden to investigate potential environmental impacts.”].) The proposed office buildings will have significant impacts on air quality and health risks by emitting cancer-causing levels of formaldehyde into the air that will expose future residents to cancer risks potentially in excess of PCAPCD’s threshold of significance for cancer health risks of 10 in a million. Currently, outside of Mr. Offermann’s comments, the City does not have any idea what risks will be posed by formaldehyde emissions from the Project or the residences. As a result, the City must include an analysis and discussion in an EIR which discloses and analyzes the health risks that the Project’s formaldehyde emissions may have on future residents and identifies appropriate mitigation measures.

III. The ND inadequately analyzes and mitigates the Project’s noise impacts.

Noise expert Deborah Jue of the consulting firm Wilson Ihrig reviewed the MND’s analysis of the Project’s noise impacts. Ms. Jue’s comment letter is attached as Exhibit B. As discussed below, Ms. Jue concluded that the MND failed to properly analyze and mitigate the Project’s noise impacts and, as a result, the Project may cause significant impacts.

A. The ND fails to provide any context or analysis from the Sutter Roseville Medical Center Master Plan EIR.

Although the ND claims to incorporate prior environmental documents, including the Sutter Roseville Medical Center Master Plan EIR (Initial Study, pp. 7-8), there is no discussion of the information potentially used from the prior EIRs to evaluate the Project’s impacts, such as significance thresholds, impacts, and mitigation measures. (Ex. B, p. 1.) Furthermore, the prior EIRs are not all available from CEQANet or the City’s website. (Id.) Without making the prior documentation available or discussing how the information contained in those EIRs applies to this Project, the ND lacks the context and analysis necessary to determine that the Project’s impacts would be less than significant.

B. The ND fails to properly establish thresholds of significance for the Project’s noise impacts.

The ND failed to establish and apply proper significance thresholds for the Project’s noise impacts. (Ex. B, pp. 1-2.) Although the ND claims that the City’s CEQA Implementing Procedures determined that compliance with the City’s Noise Ordinance would be sufficient to to find that the Project’s noise impacts would be less than significant, Ms. Jue notes that the City’s CEQA Implementing Procedures “include[] no discussion about CEQA thresholds to use in CEQA analysis.” (Ex. B, p. 2.) As such, “there is no evidence to substantiate that the noise ordinance is sufficient to determine potential significance.” (Id.) Ms. Jue suggests a number of possible significance thresholds that the City could apply to this Project’s noise impacts. (Ex. B, pp. 2-3.) These thresholds include sleep disturbance (Ex. B, pp. 2-3), speech disturbance (Ex. B, p. 3), noise and vibration thresholds for construction (Ex. B, p. 3), and actual compliance with the Noise Ordinance (Ex. B, p. 3). Because the ND did not LIUNA Comment
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provide any quantitative analysis of the Project’s noise impacts, there is no evidence that the Project’s noise levels will not exceed these thresholds or any other thresholds the City may adopt.

C. The ND’s analysis of the Project’s noise impacts is incomplete.

Ms. Jue notes that the ND provided incomplete analyses of the noise impacts from mechanical equipment on the roof of the MOB and from construction noise. (Ex. B, p. 3-4.) For the mechanical equipment, “[t]he ND provides no evidence that the rooftop equipment for the MOB would comply with the Municipal code, and provides no evidence that the addition of such equipment would be less than significant at the nearest residential structure, which is only 120 ft away.) (Ex. B, p. 3.) The ND’s failure to provide any substantive information about the mechanical equipment obscures a potentially significant impact. If two commercial-use air handling cooling systems are in operation, “the resulting noise level at the nearest residence would be 49 to 65 dBA, exceeding the City’s daytime and nighttime noise limits. (Id.) In addition to the potentially significant impact from cooling systems, the ND also fails to discuss emergency/backup generators, which would only add to the Project’s significant noise levels. (Id.) By failing to fully analyze these impacts, the ND omits potentially significant impacts and fails to provide substantial evidence that the Project’s noise impacts will be less than significant without mitigation.

D. An EIR is required due to a fair argument that the Project’s construction noise may result in a significant impact.

Ms. Jue calculated sample noise levels for five pieces of construction equipment: hoe ram, excavator/dozer, crane, front end loader, and pneumatic tools. (Ex. B, Table 1, p. 4.) According to her calculations of noise levels during demolition and site preparation, “noise from a hoe ram, excavator, or dozer could generate noise as high as 72 to 86 dBA Lmax at the nearest residence, with on-going noise over several hours each day ranging from 68 to 79 dBA Leq.” (Ex. B, p. 4.) For construction, “the noise from a crane, front end loader or pneumatic tools would range from 67 to 77 dBA Lmax, with on-going noise levels of 63 to 74 dBA Leq. (Id.) Her calculations assumed that the equipment was not being used at the same time. If equipment use of different types overlapped, the noise impact would be even greater. According to Ms. Jue, these exterior noise levels would all cause speech interference at interior locations based on guidance from the World Health Organization. Due to Ms. Jue’s a fair argument that the Project may result in significant noise impacts, the ND is inappropriate and an EIR must be prepared.

E. The ND fails to adequately mitigate the Project’s noise impacts.

As noted above, the Project’s mechanical equipment and construction noise/vibrations could result in significant impacts to the nearby residences and offices. Ms. Jue suggests several mitigation measures to address these impacts, including (1) selection, siting and/or screening of the mechanical equipment, (2) sound barrier or blankets for construction noise, and (3) buffer LIUNA Comment
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distances for noisy activities and stationary equipment. (Ex. B, p. 4.) The City should revise the ND to fully analyze the Project’s noise impacts and apply the abov mitigation measures (or others) as appropriate.

IV. An EIR is Required to Disclose and Mitigate the Project’s Significant Air Quality Impacts from Emissions of ROGs.

A. The MND’s analysis of the Project’s air quality impacts is not supported by substantial evidence.

SWAPE found that the ND underestimated the Project’s emissions and therefore cannot be relied upon to determine the significant of the Project’s air quality impacts. (Ex. C, pp. 2-3.) The MND relies on emissions calculated from the California Emissions Estimator Model Version CalEEMod.2016.3.2 (“CalEEMod”). (Id. at p. 2.) This model, which is used to generate a project’s construction and operational emissions, relies on recommended default values based on site specific information related to a number of factors (Id.) CEQA requires that any changes to the default values must be justified by substantial evidence.

SWAPE reviewed the Project’s CalEEMod output files and found that the values input into the model were inconsistent with information provided in the ND. (Ex. C, p. 2.) This results in an underestimation of the Project’s emissions. (Id.) As a result, an EIR should be prepared that adequately evaluates the Project’s air quality impacts. (Id. at pp. 2-3.) Specifically, SWAPE found that the following values used in the MND’s air quality analysis were either inconsistent with information provided in the MND or otherwise unjustified:

1. Underestimated Land Use Size (Ex. C, p. 3.)

2. Underestimated Land Use Size (Ex. C, pp. 3-4.)
As a result of these errors, the ND underestimates the Project’s construction and operational emissions and cannot be relied upon to determine the significance of the Project’s air quality impacts.

B. SWAPE’s updated analysis of the Project’s air quality impacts establishes a fair argument that the Project may result in significant emissions of ROGs.

In an effort to accurately determine the proposed Project’s construction and operational emissions, SWAPE prepared an updated CalEEMod model that includes more site-specific information and correct input parameters. (Ex. C, p. 4.) SWAPE’s updated analysis accounted for the entire 100,000 square feet of the MOB. (Id.) SWAPE’s updated analysis found that the Project’s construction-related ROG emissions exceed the of 82 pounds per day (“lbs/day”) significance threshold set by PCAPCD, as shown below. (Id.) LIUNA Comment
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SWAPE’s expert analysis of the Project’s construction emissions establishes that the Project may result in significant ROG. Under CEQA, SWAPE’s fair argument requires that the City prepare an EIR to disclose and mitigate this impact.

VI. An EIR is required for the Project’s potentially significant greenhouse gas impacts.

The ND improperly concludes that the Project’s greenhouse gas (“GHG”) impacts would be less than significant. The ND relies on the City’s General Plan Update (“GPU”) EIR, which concluded that, even with mitigation, GHG impacts would be significant and unavoidable. The ND then jumps to the conclusion that the Project’s GHG impacts would be less than significant because “[t]he project complies with General Plan policy related to GHG and the project does not result in any new GHG impacts not previously analyzed in the GPU EIR.” (Initial Study, p.

26.) However, even if the project complies with the City’s General Plan policies, it does not follow that the Project’s impacts are necessarily less than significant. The GPU EIR concluded that GHG impacts would be significant and unavoidable, so compliance with the General Plan in no way indicates less-than-significant GHG impacts. Instead, the City needs to evaluate this Project’s GHG impacts to see if they remain significant and unavoidable.

Although the City may tier the Project’s GHG impacts from the GPU EIR, an ND is inappropriate where the Project will result in significant and unavoidable impacts. In the case Communities for a Better Environment v. Cal. Resources Agency (2002) 103 Cal.App.4th 98, 122-25, the court of appeal held that when a “first tier” EIR admits a significant, unavoidable environmental impact, then the agency must prepare second tier EIRs for later projects to ensure that those unmitigated impacts are “mitigated or avoided.” (Id.) The court reasoned that the unmitigated impacts were not “adequately addressed” in the first tier EIR since the impacts were not “mitigated or avoided.” (Id.) Thus, significant effects disclosed in first tier EIRs will trigger second tier EIRs unless such effects have been “adequately addressed,” in a way that ensures the effects will be “mitigated or avoided.” (Id.) When a project tiers from a prior EIR but still results in significant and unavoidable impacts, a second tier is required as well as a new Statement of Overriding Considerations. The court explained, “The requirement of a statement of overriding considerations is central to CEQA’s role as a public accountability statute; it requires public officials, in approving environmental detrimental projects, to justify their decisions based on LIUNA Comment
Sutter Parking Garage Expansion & MOB 7 (File Nos. PL22-0024, PL22-0061) May 11, 2022

counterbalancing social, economic or other benefits, and to point to substantial evidence in support.” (Id. at pp. 124-25.)
Here, the ND made no attempt to determine whether the Project’s individual GHG impacts would actually be less than significant. In order to evaluate the Project’s GHG impacts, SWAPE quantified the Project’s GHG emissions and compared them to the PCAPCD’s De Minimis Level operational threshold of 1,100 metric tons of carbon dioxide equivalents per year (“MT CO2e/year”). (Ex. C, p. 6.) As shown below, the Project’s GHG emissions exceed the PCAPCD threshold:

SWAPE’s calculation establish a fair argument that the Project may result in significant GHG impacts. Unless the City can ensure that the GUP EIR reduces this impact to a less-thansignificant level, an EIR and new Statement of Overriding Considerations is required under CEQA. SWAPE suggests numerous mitigation measures that could be applied to this Project to reduce the GHG impacts. (Ex. C, pp. 9-11.) The City should evaluate these feasible mitigation measures and incorporate them into a new EIR for the Project.

VII. The ND fails to consider renewable energy alternatives.

When analyzing a project's energy use to determine if it creates significant effects, CEQA requires a discussion of whether any renewable energy features could be incorporated into the project. (League to Save Lake Tahoe Mountain Area Preservation Foundation v. County of Placer (2022) 75 Cal.App.5th 63, 167 (League to Save Lake Tahoe).) Compliance with state and local regulatory programs is not sufficient to determine that a project will not result in a wasteful or inefficient use of energy. (Id. at p. 165.)
Although the ND discusses the Project’s consistency with the Northeast Roseville Specific Plan EIR (ND, pp. 21-22), there is no discussion of “whether any renewable energy features could be incorporated into the project as part of determining whether the project's impacts on energy resources were significant.” (See League to Save Lake Tahoe, supra, 75 Cal.App.5th at p. 168.) An updated energy analysis should be conducted and circulated in a revised ND or EIR in order to comply with CEQA.

LIUNA Comment
Sutter Parking Garage Expansion & MOB 7 (File Nos. PL22-0024, PL22-0061) May 11, 2022

CONCLUSION
LIUNA’s experts have established a fair argument that the Project may have significant impacts on related to formaldehyde, ROGs, GHGs, and noise. Furthermore, the ND’s analyses of these impacts as well as energy impacts, are not supported by substantial evidence. Therefore, LIUNA respectfully requests that the City prepare and circulate an EIR prior to further consideration of the Project.

Sincerely,
Brian B. Flynn
Lozeau Drury LLP

EXHIBIT A

INDOOR ENVIRONMENTAL ENGINEERING
1448 Pine Street, Suite 103 San Francisco, California 94109 Telephone: (415) 567-7700
E-mail: [email protected]
http://www.iee-sf.com
Date: May 11, 2022
To: Brian Flynn
Lozeau | Drury LLP
1939 Harrison Street, Suite 150
Oakland, California 94612
From: Francis J. Offermann PE CIH
Subject: Indoor Air Quality: Sutter Parking Garage and Medical Office Building 7 Project, Roseville, CA. (IEE File Reference: P-4575)
Pages: 18
Indoor Air Quality Impacts
Indoor air quality (IAQ) directly impacts the comfort and health of building occupants, and the achievement of acceptable IAQ in newly constructed and renovated buildings is a wellrecognized design objective. For example, IAQ is addressed by major high-performance building rating systems and building codes (California Building Standards Commission, 2014; USGBC, 2014). Indoor air quality in homes is particularly important because occupants, on average, spend approximately ninety percent of their time indoors with the majority of this time spent at home (EPA, 2011). Some segments of the population that are most susceptible to the effects of poor IAQ, such as the very young and the elderly, occupy their homes almost continuously. Additionally, an increasing number of adults are working from home at least some of the time during the workweek. Indoor air quality also is a serious concern for workers in hotels, offices and other business establishments.

The concentrations of many air pollutants often are elevated in homes and other buildings relative to outdoor air because many of the materials and products used indoors contain and release a variety of pollutants to air (Hodgson et al., 2002; Offermann and Hodgson, 2011). With respect to indoor air contaminants for which inhalation is the primary route of 2 of 18
exposure, the critical design and construction parameters are the provision of adequate ventilation and the reduction of indoor sources of the contaminants.

Indoor Formaldehyde Concentrations Impact. In the California New Home Study (CNHS) of 108 new homes in California (Offermann, 2009), 25 air contaminants were measured, and formaldehyde was identified as the indoor air contaminant with the highest cancer risk as determined by the California Proposition 65 Safe Harbor Levels (OEHHA, 2017a), No Significant Risk Levels (NSRL) for carcinogens. The NSRL is the daily intake level calculated to result in one excess case of cancer in an exposed population of 100,000 (i.e., ten in one million cancer risk) and for formaldehyde is 40 µg/day. The NSRL concentration of formaldehyde that represents a daily dose of 40 µg is 2 µg/m3, assuming a continuous 24-hour exposure, a total daily inhaled air volume of 20 m3, and 100% absorption by the respiratory system. All of the CNHS homes exceeded this NSRL concentration of 2 µg/m3. The median indoor formaldehyde concentration was 36 µg/m3, and ranged from 4.8 to 136 µg/m3, which corresponds to a median exceedance of the 2 µg/m3 NSRL concentration of 18 and a range of 2.3 to 68.

Therefore, the cancer risk of a resident living in a California home with the median indoor formaldehyde concentration of 36 µg/m3, is 180 per million as a result of formaldehyde alone. The CEQA significance threshold for airborne cancer risk is 10 per million, as established by the Placer County Air Pollution Control District (PCAPCD, 2017).

Besides being a human carcinogen, formaldehyde is also a potent eye and respiratory irritant. In the CNHS, many homes exceeded the non-cancer reference exposure levels (RELs) prescribed by California Office of Environmental Health Hazard Assessment (OEHHA, 2017b). The percentage of homes exceeding the RELs ranged from 98% for the Chronic REL of 9 µg/m3 to 28% for the Acute REL of 55 µg/m3.

The primary source of formaldehyde indoors is composite wood products manufactured with urea-formaldehyde resins, such as plywood, medium density fiberboard, and particleboard. These materials are commonly used in building construction for flooring, cabinetry, baseboards, window shades, interior doors, and window and door trims. 3 of 18
In January 2009, the California Air Resources Board (CARB) adopted an airborne toxics control measure (ATCM) to reduce formaldehyde emissions from composite wood products, including hardwood plywood, particleboard, medium density fiberboard, and also furniture and other finished products made with these wood products (California Air Resources Board 2009). While this formaldehyde ATCM has resulted in reduced emissions from composite wood products sold in California, they do not preclude that homes built with composite wood products meeting the CARB ATCM will have indoor formaldehyde concentrations below cancer and non-cancer exposure guidelines.

A follow up study to the California New Home Study (CNHS) was conducted in 2016-2018 (Singer et. al., 2019), and found that the median indoor formaldehyde in new homes built after 2009 with CARB Phase 2 Formaldehyde ATCM materials had lower indoor formaldehyde concentrations, with a median indoor concentration of 22.4 µg/m3 (18.2 ppb) as compared to a median of 36 µg/m3 found in the 2007 CNHS. Unlike in the CNHS study where formaldehyde concentrations were measured with pumped DNPH samplers, the formaldehyde concentrations in the HENGH study were measured with passive samplers, which were estimated to under-measure the true indoor formaldehyde concentrations by approximately 7.5%. Applying this correction to the HENGH indoor formaldehyde concentrations results in a median indoor concentration of 24.1 µg/m3, which is 33% lower than the 36 µg/m3 found in the 2007 CNHS.

Thus, while new homes built after the 2009 CARB formaldehyde ATCM have a 33% lower median indoor formaldehyde concentration and cancer risk, the median lifetime cancer risk is still 120 per million for homes built with CARB compliant composite wood products.

This median lifetime cancer risk is more than 12 times the OEHHA 10 in a million cancer risk threshold (OEHHA, 2017a).

With respect to the Sutter Parking Garage and Medical Office Building 7 Project, Roseville, CA, the buildings consist of a parking garage and a medical office building.

The employees of the medical office building are expected to experience significant indoor 4 of 18
exposures (e.g., 40 hours per week, 50 weeks per year). These exposures for employees are anticipated to result in significant cancer risks resulting from exposures to formaldehyde released by the building materials and furnishing commonly found in offices, warehouses, residences and hotels.

Because the medical office building spaces will be constructed with CARB Phase 2 Formaldehyde ATCM materials, and be ventilated with the minimum code required amount of outdoor air, the indoor formaldehyde concentrations are likely similar to those concentrations observed in residences built with CARB Phase 2 Formaldehyde ATCM materials, which is a median of 24.1 µg/m3 (Singer et. al., 2020) Assuming that the medical office building employees work 8 hours per day and inhale 20 m3 of air per day, the formaldehyde dose per work-day is 161 µg/day.

Assuming that these employees work 5 days per week and 50 weeks per year for 45 years (start at age 20 and retire at age 65) the average 70-year lifetime formaldehyde daily dose is 70.9 µg/day.

This is 1.77 times the NSRL (OEHHA, 2017a) of 40 µg/day and represents a cancer risk of 17.7 per million, which exceeds the CEQA cancer risk of 10 per million. This impact should be analyzed in an environmental impact report (“EIR”), and the agency should impose all feasible mitigation measures to reduce this impact. Several feasible mitigation measures are discussed below and these and other measures should be analyzed in an EIR.

Appendix A, Indoor Formaldehyde Concentrations and the CARB Formaldehyde ATCM, provides analyses that show utilization of CARB Phase 2 Formaldehyde ATCM materials will not ensure acceptable cancer risks with respect to formaldehyde emissions from composite wood products.

Even composite wood products manufactured with CARB certified ultra low emitting formaldehyde (ULEF) resins do not ensure that the indoor air will have concentrations of formaldehyde that substantially exceed 10 per million. The permissible emission rates for 5 of 18
ULEF composite wood products are only 11-15% lower than the CARB Phase 2 emission rates. Only use of composite wood products made with no-added formaldehyde resins (NAF), such as resins made from soy, polyvinyl acetate, or methylene diisocyanate can ensure that the OEHHA cancer risk of 10 per million is met.

The following describes a method that should be used, prior to construction in the environmental review under CEQA, for determining whether the indoor concentrations resulting from the formaldehyde emissions of specific building materials/furnishings selected exceed cancer and non-cancer guidelines. Such a design analyses can be used to identify those materials/furnishings prior to the completion of the City’s CEQA review and project approval, that have formaldehyde emission rates that contribute to indoor concentrations that exceed cancer and non-cancer guidelines, so that alternative lower emitting materials/furnishings may be selected and/or higher minimum outdoor air ventilation rates can be increased to achieve acceptable indoor concentrations and incorporated as mitigation measures for this project.

Pre-Construction Building Material/Furnishing Formaldehyde Emissions Assessment This formaldehyde emissions assessment should be used in the environmental review under CEQA to assess the indoor formaldehyde concentrations from the proposed loading of building materials/furnishings, the area-specific formaldehyde emission rate data for building materials/furnishings, and the design minimum outdoor air ventilation rates. This assessment allows the applicant (and the City) to determine, before the conclusion of the environmental review process and the building materials/furnishings are specified, purchased, and installed, if the total chemical emissions will exceed cancer and non-cancer guidelines, and if so, allow for changes in the selection of specific material/furnishings and/or the design minimum outdoor air ventilations rates such that cancer and non-cancer guidelines are not exceeded.

1.) Define Indoor Air Quality Zones. Divide the building into separate indoor air quality zones, (IAQ Zones). IAQ Zones are defined as areas of well-mixed air. Thus, each ventilation system with recirculating air is considered a single zone, and each room or group of rooms where air is not recirculated (e.g. 100% outdoor air) is considered a separate 6 of 18
zone. For IAQ Zones with the same construction material/furnishings and design minimum outdoor air ventilation rates. (e.g. hotel rooms, apartments, condominiums, etc.) the formaldehyde emission rates need only be assessed for a single IAQ Zone of that type.

2.) Calculate Material/Furnishing Loading. For each IAQ Zone, determine the building material and furnishing loadings (e.g., m2 of material/m2 floor area, units of furnishings/m2 floor area) from an inventory of all potential indoor formaldehyde sources, including flooring, ceiling tiles, furnishings, finishes, insulation, sealants, adhesives, and any products constructed with composite wood products containing urea-formaldehyde resins (e.g., plywood, medium density fiberboard, particleboard).

3.) Calculate the Formaldehyde Emission Rate. For each building material, calculate the formaldehyde emission rate (µg/h) from the product of the area-specific formaldehyde emission rate (µg/m2-h) and the area (m2) of material in the IAQ Zone, and from each furnishing (e.g. chairs, desks, etc.) from the unit-specific formaldehyde emission rate (µg/unit-h) and the number of units in the IAQ Zone.

NOTE: As a result of the high-performance building rating systems and building codes (California Building Standards Commission, 2014; USGBC, 2014), most manufacturers of building materials furnishings sold in the United States conduct chemical emission rate tests using the California Department of Health “Standard Method for the Testing and Evaluation of Volatile Organic Chemical Emissions for Indoor Sources Using Environmental Chambers,” (CDPH, 2017), or other equivalent chemical emission rate testing methods. Most manufacturers of building furnishings sold in the United States conduct chemical emission rate tests using ANSI/BIFMA M7.1 Standard Test Method for Determining VOC Emissions (BIFMA, 2018), or other equivalent chemical emission rate testing methods.

CDPH, BIFMA, and other chemical emission rate testing programs, typically certify that a material or furnishing does not create indoor chemical concentrations in excess of the maximum concentrations permitted by their certification. For instance, the CDPH emission rate testing requires that the measured emission rates when input into an office, school, or residential model do not exceed one-half of the OEHHA Chronic Exposure Guidelines 7 of 18
(OEHHA, 2017b) for the 35 specific VOCs, including formaldehyde, listed in Table 4-1 of the CDPH test method (CDPH, 2017). These certifications themselves do not provide the actual area-specific formaldehyde emission rate (i.e., µg/m2-h) of the product, but rather provide data that the formaldehyde emission rates do not exceed the maximum rate allowed for the certification. Thus, for example, the data for a certification of a specific type of flooring may be used to calculate that the area-specific emission rate of formaldehyde is less than 31 µg/m2-h, but not the actual measured specific emission rate, which may be 3, 18, or 30 µg/m2-h. These area-specific emission rates determined from the product certifications of CDPH, BIFA, and other certification programs can be used as an initial estimate of the formaldehyde emission rate.

If the actual area-specific emission rates of a building material or furnishing is needed (i.e. the initial emission rates estimates from the product certifications are higher than desired), then that data can be acquired by requesting from the manufacturer the complete chemical emission rate test report. For instance if the complete CDPH emission test report is requested for a CDHP certified product, that report will provide the actual area-specific emission rates for not only the 35 specific VOCs, including formaldehyde, listed in Table 4-1 of the CDPH test method (CDPH, 2017), but also all of the cancer and reproductive/developmental chemicals listed in the California Proposition 65 Safe Harbor Levels (OEHHA, 2017a), all of the toxic air contaminants (TACs) in the California Air Resources Board Toxic Air Contamination List (CARB, 2011), and the 10 chemicals with the greatest emission rates.

Alternatively, a sample of the building material or furnishing can be submitted to a chemical emission rate testing laboratory, such as Berkeley Analytical Laboratory (https://berkeleyanalytical.com), to measure the formaldehyde emission rate.

4.) Calculate the Total Formaldehyde Emission Rate. For each IAQ Zone, calculate the total formaldehyde emission rate (i.e. µg/h) from the individual formaldehyde emission rates from each of the building material/furnishings as determined in Step 3.

5.) Calculate the Indoor Formaldehyde Concentration. For each IAQ Zone, calculate the 8 of 18
indoor formaldehyde concentration (µg/m3) from Equation 1 by dividing the total formaldehyde emission rates (i.e. µg/h) as determined in Step 4, by the design minimum outdoor air ventilation rate (m3/h) for the IAQ Zone.

𝐶!" = #!"!#$
$"#
(Equation 1)
where:

Cin = indoor formaldehyde concentration (µg/m3)
Etotal = total formaldehyde emission rate (µg/h) into the IAQ Zone.

Qoa = design minimum outdoor air ventilation rate to the IAQ Zone (m3/h) The above Equation 1 is based upon mass balance theory, and is referenced in Section

3.10.2 “Calculation of Estimated Building Concentrations” of the California Department of Health “Standard Method for the Testing and Evaluation of Volatile Organic Chemical Emissions for Indoor Sources Using Environmental Chambers”, (CDPH, 2017).

6.) Calculate the Indoor Exposure Cancer and Non-Cancer Health Risks. For each IAQ Zone, calculate the cancer and non-cancer health risks from the indoor formaldehyde concentrations determined in Step 5 and as described in the OEHHA Air Toxics Hot Spots Program Risk Assessment Guidelines; Guidance Manual for Preparation of Health Risk Assessments (OEHHA, 2015).

7.) Mitigate Indoor Formaldehyde Exposures of exceeding the CEQA Cancer and/or NonCancer Health Risks. In each IAQ Zone, provide mitigation for any formaldehyde exposure risk as determined in Step 6, that exceeds the CEQA cancer risk of 10 per million or the CEQA non-cancer Hazard Quotient of 1.0.

Provide the source and/or ventilation mitigation required in all IAQ Zones to reduce the health risks of the chemical exposures below the CEQA cancer and non-cancer health risks.

Source mitigation for formaldehyde may include:

1.) reducing the amount materials and/or furnishings that emit formaldehyde

2.) substituting a different material with a lower area-specific emission rate of 9 of 18
formaldehyde

Ventilation mitigation for formaldehyde emitted from building materials and/or furnishings may include:

1.) increasing the design minimum outdoor air ventilation rate to the IAQ Zone.

NOTE: Mitigating the formaldehyde emissions through use of less material/furnishings, or use of lower emitting materials/furnishings, is the preferred mitigation option, as mitigation with increased outdoor air ventilation increases initial and operating costs associated with the heating/cooling systems.

Further, we are not asking that the builder “speculate” on what and how much composite materials be used, but rather at the design stage to select composite wood materials based on the formaldehyde emission rates that manufacturers routinely conduct using the California Department of Health “Standard Method for the Testing and Evaluation of Volatile Organic Chemical Emissions for Indoor Sources Using Environmental Chambers,” (CDPH, 2017), and use the procedure described earlier above (i.e. PreConstruction Building Material/Furnishing Formaldehyde Emissions Assessment) to ensure that the materials selected achieve acceptable cancer risks from material off gassing of formaldehyde.

Outdoor Air Ventilation Impact. Another important finding of the CNHS, was that the outdoor air ventilation rates in new homes without mechanical outdoor air ventilation were very low. Outdoor air ventilation is a very important factor influencing the indoor concentrations of air contaminants, as it is the primary removal mechanism of all indoor air generated contaminants. Lower outdoor air exchange rates cause indoor generated air contaminants to accumulate to higher indoor air concentrations. Many homeowners rarely open their windows or doors for ventilation as a result of their concerns for security/safety, noise, dust, and odor concerns (Price, 2007). In the CNHS field study, 32% of the homes did not use their windows during the 24‐hour Test Day, and 15% of the homes did not use their windows during the entire preceding week. Most of the homes with no window usage were homes in the winter field session. Thus, a substantial percentage of homeowners never 10 of 18
open their windows, especially in the winter season. The median 24‐hour measurement was

0.26 air changes per hour (ach), with a range of 0.09 ach to 5.3 ach. A total of 67% of the homes had outdoor air exchange rates below the minimum California Building Code (2001) requirement of 0.35 ach. Thus, the relatively tight envelope construction, combined with the fact that many people never open their windows for ventilation, results in homes with low outdoor air exchange rates and higher indoor air contaminant concentrations.

The Sutter Parking Garage and Medical Office Building 7 Project is close to roads with moderate to high traffic (e.g., I-80, CA-65, Secret Ravine Parkway, East Roseville Parkway, Medical Plaza Drive, etc.).

The Project noise assessment in the Negative Declaration and Initial Study (City of Roseville, 2022), contains no current or future assessment of the ambient noise levels resulting from the nearby roadway traffic. In my professional opinion the ambient noise levels resulting from the nearby roadway traffic will be significant and require specific mitigation measures. An acoustic assessment of the current or future ambient noise levels resulting from the nearby roadway traffic should be conducted.

As a result of the anticipated high outdoor noise levels, the Project will likely require a mechanical supply of outdoor air ventilation to allow for a habitable interior environment with closed windows and doors. Such a ventilation system would allow windows and doors to be kept closed at the occupant’s discretion to control exterior noise within building interiors.

PM10 and PM2.5 Outdoor Concentrations Impact. According to the Negative Declaration and Initial Study (City of Roseville, 2022), the Project is located in the Sacramento Valley Air Basin, which is a State non-attainment area for PM10 and a Federal non-attainment area for PM2.5.

An air quality analyses should to be conducted to determine the concentrations of PM10 and PM2.5 in the outdoor and indoor air that people inhale each day. This air quality analyses needs to consider the cumulative impacts of the project related emissions, existing and 11 of 18
projected future emissions from local sources upon the outdoor air concentrations at the Project site. If the outdoor concentrations are determined to exceed the State PM10 and Federal PM2.5 concentrations, then the buildings will need to have a mechanical supply of outdoor air that has air filtration with sufficient removal efficiency, such that the indoor concentrations of outdoor PM10 and PM2.5 are less than the State and Federal requirements.

Thus the Project will likely require installation of high efficiency air filters (i.e. MERV 13 or higher) in all mechanically supplied outdoor air ventilation systems.

Indoor Air Quality Impact Mitigation Measures
The following are recommended mitigation measures to minimize the impacts upon indoor quality:

Indoor Formaldehyde Concentrations Mitigation. Use only composite wood materials (e.g. hardwood plywood, medium density fiberboard, particleboard) for all interior finish systems that are made with CARB approved no-added formaldehyde (NAF) resins (CARB, 2009). CARB Phase 2 certified composite wood products, or ultra-low emitting formaldehyde (ULEF) resins, do not insure indoor formaldehyde concentrations that are below the CEQA cancer risk of 10 per million. Only composite wood products manufactured with CARB approved no-added formaldehyde (NAF) resins, such as resins made from soy, polyvinyl acetate, or methylene diisocyanate can insure that the OEHHA cancer risk of 10 per million is met.

Alternatively, conduct the previously described Pre-Construction Building Material/Furnishing Chemical Emissions Assessment, to determine that the combination of formaldehyde emissions from building materials and furnishings do not create indoor formaldehyde concentrations that exceed the CEQA cancer and non-cancer health risks.

It is important to note that we are not asking that the builder “speculate” on what and how much composite materials be used, but rather at the design stage to select composite wood materials based on the formaldehyde emission rates that manufacturers routinely conduct 12 of 18
using the California Department of Health “Standard Method for the Testing and Evaluation of Volatile Organic Chemical Emissions for Indoor Sources Using Environmental Chambers”, (CDPH, 2017), and use the procedure described above (i.e.

Pre-Construction Building Material/Furnishing Formaldehyde Emissions Assessment) to insure that the materials selected achieve acceptable cancer risks from material off gassing of formaldehyde.

Outdoor Air Ventilation Mitigation. Provide each habitable room with a continuous mechanical supply of outdoor air that meets or exceeds the California 2016 Building Energy Efficiency Standards (California Energy Commission, 2015) requirements of the greater of 15 cfm/occupant or 0.15 cfm/ft2 of floor area. Following installation of the system conduct testing and balancing to insure that required amount of outdoor air is entering each habitable room and provide a written report documenting the outdoor airflow rates. Do not use exhaust only mechanical outdoor air systems, use only balanced outdoor air supply and exhaust systems or outdoor air supply only systems. Provide a manual for the occupants or maintenance personnel, that describes the purpose of the mechanical outdoor air system and the operation and maintenance requirements of the system.

References
BIFA. 2018. BIFMA Product Safety and Performance Standards and Guidelines. www.bifma.org/page/standardsoverview
California Air Resources Board. 2009. Airborne Toxic Control Measure to Reduce Formaldehyde Emissions from Composite Wood Products. California Environmental Protection Agency, Sacramento, CA.
https://www.arb.ca.gov/regact/2007/compwood07/fro-final.pdf California Air Resources Board. 2011. Toxic Air Contaminant Identification List.

California Environmental Protection Agency, Sacramento, CA. https://www.arb.ca.gov/toxics/id/taclist.htm
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California Building Code. 2001. California Code of Regulations, Title 24, Part 2 Volume 1, Appendix Chapter 12, Interior Environment, Division 1, Ventilation, Section 1207: 2001 California Building Code, California Building Standards Commission. Sacramento, CA.

California Building Standards Commission (2014). 2013 California Green Building Standards Code. California Code of Regulations, Title 24, Part 11. California Building Standards Commission, Sacramento, CA http://www.bsc.ca.gov/Home/CALGreen.aspx.

California Energy Commission, PIER Program. CEC-500-2007-033. Final Report, ARB Contract 03-326. Available at: www.arb.ca.gov/research/apr/past/03-326.pdf.

California Energy Commission, 2015. 2016 Building Energy Efficiency Standards for Residential and Nonresidential Buildings, California Code of Regulations, Title 24, Part 6. http://www.energy.ca.gov/2015publications/CEC-400-2015-037/CEC-400-2015-037- CMF.pdf
CDPH. 2017. Standard Method for the Testing and Evaluation of Volatile Organic Chemical Emissions for Indoor Sources Using Environmental Chambers, Version 1.1.

California Department of Public Health, Richmond, CA.
https://www.cdph.ca.gov/Programs/CCDPHP/ DEODC/EHLB/IAQ/Pages/VOC.aspx.

City of Roseville. 2022. Negative Declaration and Initial Study - Sutter Parking Garage Expansion & Sutter MOB 7 Project.

EPA. 2011. Exposure Factors Handbook: 2011 Edition, Chapter 16 – Activity Factors.

Report EPA/600/R-09/052F, September 2011. U.S. Environmental Protection Agency, Washington, D.C.

Hodgson, A. T., D. Beal, J.E.R. McIlvaine. 2002. Sources of formaldehyde, other aldehydes and terpenes in a new manufactured house. Indoor Air 12: 235–242. 14 of 18
OEHHA (Office of Environmental Health Hazard Assessment). 2015. Air Toxics Hot Spots Program Risk Assessment Guidelines; Guidance Manual for Preparation of Health Risk Assessments.

OEHHA (Office of Environmental Health Hazard Assessment). 2017a. Proposition 65 Safe Harbor Levels. No Significant Risk Levels for Carcinogens and Maximum Allowable Dose Levels for Chemicals Causing Reproductive Toxicity. Available at:
http://www.oehha.ca.gov/prop65/pdf/safeharbor081513.pdf OEHHA - Office of Environmental Health Hazard Assessment. 2017b. All OEHHA Acute, 8-hour and Chronic Reference Exposure Levels. Available at:
http://oehha.ca.gov/air/allrels.html
Offermann, F. J. 2009. Ventilation and Indoor Air Quality in New Homes. California Air Resources Board and California Energy Commission, PIER Energy-Related Environmental Research Program. Collaborative Report. CEC-500-2009-085. https://www.arb.ca.gov/research/apr/past/04-310.pdf
Offermann, F. J. and A. T. Hodgson. 2011. Emission Rates of Volatile Organic Compounds in New Homes. Proceedings Indoor Air 2011 (12th International Conference on Indoor Air Quality and Climate 2011), June 5-10, 2011, Austin, TX.

Singer, B.C, Chan, W.R, Kim, Y., Offermann, F.J., and Walker I.S. 2020. Indoor Air Quality in California Homes with Code-Required Mechanical Ventilation. Indoor Air, Vol 30, Issue 5, 885-899.

Placer County Air Pollution Control District (PCAPCD). 2017. CEQA Handbook.

Appendix G. https://www.placer.ca.gov/DocumentCenter/View/2044/Appendix-GPreparing-a-Health-Risk-Assessment-for-Land-Use-Projects-PDF USGBC. 2014. LEED BD+C Homes v4. U.S. Green Building Council, Washington, D.C. http://www.usgbc.org/credits/homes/v4
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APPENDIX A

INDOOR FORMALDEHYDE CONCENTRATIONS

AND THE

CARB FORMALDEHYDE ATCM
With respect to formaldehyde emissions from composite wood products, the CARB ATCM regulations of formaldehyde emissions from composite wood products, do not assure healthful indoor air quality. The following is the stated purpose of the CARB ATCM regulation - The purpose of this airborne toxic control measure is to “reduce formaldehyde emissions from composite wood products, and finished goods that contain composite wood products, that are sold, offered for sale, supplied, used, or manufactured for sale in California”. In other words, the CARB ATCM regulations do not “assure healthful indoor air quality”, but rather “reduce formaldehyde emissions from composite wood products”.

Just how much protection do the CARB ATCM regulations provide building occupants from the formaldehyde emissions generated by composite wood products? Definitely some, but certainly the regulations do not “assure healthful indoor air quality” when CARB Phase 2 products are utilized. As shown in the Chan 2019 study of new California homes, the median indoor formaldehyde concentration was of 22.4 µg/m3 (18.2 ppb), which corresponds to a cancer risk of 112 per million for occupants with continuous exposure, which is more than 11 times the CEQA cancer risk of 10 per million.

Another way of looking at how much protection the CARB ATCM regulations provide building occupants from the formaldehyde emissions generated by composite wood products is to calculate the maximum number of square feet of composite wood product that can be in a residence without exceeding the CEQA cancer risk of 10 per million for occupants with continuous occupancy.

For this calculation I utilized the floor area (2,272 ft2), the ceiling height (8.5 ft), and the number of bedrooms (4) as defined in Appendix B (New Single-Family Residence Scenario) of the StandardMethod fortheTestingandEvaluation of Volatile Organic Chemical Emissionsfor Indoor Sources UsingEnvironmental Chambers,Version1.1, 2017, California Department of Public Health, 17 of 18
Richmond, CA. https://www.cdph.ca.gov/Programs/CCDPHP/
DEODC/EHLB/IAQ/Pages/VOC.aspx.

For the outdoor air ventilation rate I used the 2019 Title 24 code required mechanical ventilation rate (ASHRAE 62.2) of 106 cfm (180 m3/h) calculated for this model residence.

For the composite wood formaldehyde emission rates I used the CARB ATCM Phase 2 rates.

The calculated maximum number of square feet of composite wood product that can be in a residence, without exceeding the CEQA cancer risk of 10 per million for occupants with continuous occupancy are as follows for the different types of regulated composite wood products.

Medium Density Fiberboard (MDF) – 15 ft2 (0.7% of the floor area), or Particle Board – 30 ft2 (1.3% of the floor area), or
Hardwood Plywood – 54 ft2 (2.4% of the floor area), or
Thin MDF – 46 ft2 (2.0 % of the floor area).

For offices and hotels the calculated maximum amount of composite wood product (% of floor area) that can be used without exceeding the CEQA cancer risk of 10 per million for occupants, assuming 8 hours/day occupancy, and the California Mechanical Code minimum outdoor air ventilation rates are as follows for the different types of regulated composite wood products.

Medium Density Fiberboard (MDF) – 3.6 % (offices) and 4.6% (hotel rooms), or Particle Board – 7.2 % (offices) and 9.4% (hotel rooms), or Hardwood Plywood – 13 % (offices) and 17% (hotel rooms), or Thin MDF – 11 % (offices) and 14 % (hotel rooms)
Clearly the CARB ATCM does not regulate the formaldehyde emissions from composite wood products such that the potentially large areas of these products, such as for flooring, baseboards, interior doors, window and door trims, and kitchen and bathroom cabinetry, could be used without causing indoor formaldehyde concentrations that result in CEQA 18 of 18
cancer risks that substantially exceed 10 per million for occupants with continuous occupancy.

Even composite wood products manufactured with CARB certified ultra low emitting formaldehyde (ULEF) resins do not insure that the indoor air will have concentrations of formaldehyde the meet the OEHHA cancer risks that substantially exceed 10 per million.

The permissible emission rates for ULEF composite wood products are only 11-15% lower than the CARB Phase 2 emission rates. Only use of composite wood products made with no-added formaldehyde resins (NAF), such as resins made from soy, polyvinyl acetate, or methylene diisocyanate can insure that the OEHHA cancer risk of 10 per million is met.

If CARB Phase 2 compliant or ULEF composite wood products are utilized in construction, then the resulting indoor formaldehyde concentrations should be determined in the design phase using the specific amounts of each type of composite wood product, the specific formaldehyde emission rates, and the volume and outdoor air ventilation rates of the indoor spaces, and all feasible mitigation measures employed to reduce this impact (e.g. use less formaldehyde containing composite wood products and/or incorporate mechanical systems capable of higher outdoor air ventilation rates). See the procedure described earlier (i.e.

Pre-Construction Building Material/Furnishing Formaldehyde Emissions Assessment) to insure that the materials selected achieve acceptable cancer risks from material off gassing of formaldehyde.

Alternatively, and perhaps a simpler approach, is to use only composite wood products (e.g. hardwood plywood, medium density fiberboard, particleboard) for all interior finish systems that are made with CARB approved no-added formaldehyde (NAF) resins.

EXHIBIT B
Letter EMY
WI #22-004.12
May 10, 2022
Mr. Brian Flynn
Lozeau | Drury LLP
1939 Harrison Street, Suite 150
Oakland, California 94612
SUBJECT: Sutter Parking Garage Expansion and Medical Office Building Negative Declaration, Comments on the Noise Analysis
Dear Mr. Flynn,
Per your request, I have reviewed the subject matter document for the Sutter Parking Garage Expansion and Medical Office Building Negative Declaration (ND) in Roseville, California. The proposed Project would include expansion of an existing 5-story parking garage with a 6-story addition and a new medical office building (MOB) that would be constructed in two phases: initial 4- story structure, and a 2-story addition to be added later. The MOB would house a new Graduate Medical Education (GME) program.

Context and Analysis from the prior EIR are Omitted
The ND references the Sutter Roseville Medical Center Master Plan EIR1 (EIR) as documents relied upon for the preparation of the ND. These documents were not available online via CEQANet nor under the City’s Planning Department website. The ND omits any mention of key information it may have used in the noise analysis, such as significance thresholds, impacts, and mitigation measures.

Thus, it is difficult to determine whether the components of the project fall within the prior environmental analysis.

Thresholds of Significance are Not Properly Developed
Lacking access to the prior EIR, the ND lacks any discussion of the thresholds used to determine significance. Per CEQA2, the ND must clearly identify and mitigate eliminate potentially significant effects, as shown in Figure 1.
1 SCH #90020142 and #93092081
2 https://govt.westlaw.com/calregs/Document/IA1DEFD80D48811DEBC02831C6D6C108E?

WILSON IHRIG
Sutter Garage and MOB, Roseville, ND

Figure 1 CEQA Section 15070 (a) and (b)
The Roseville CEQA Implementing Procedures (Procedures) are referenced throughout the ND, and the ND states that Findings from these Procedures was that the City’s noise ordinance would be sufficient to determine significance of noise impacts. These Procedures3 available online do not appear to be the right document, as there are no “Findings”, and this Procedures document includes no discussion about CEQA thresholds to use in CEQA analysis. Thus, there is no evidence to substantiate that the noise ordinance is sufficient to determine potential significance.

The project includes a new private outdoor area. The ND does not appear to show where this outdoor area would be located, nor how it would be used. The hours of operation of this private outdoor area have not been provided, and if large gatherings (social or meetings) would be held, with amplified voice or music, this would be a new usage and potentially significant.

Thus, thresholds that could be considered to evaluate potentially significant noise impacts include:

Sleep disturbance and annoyance
The ND lacks any assessment of potentially significant noise impacts caused by activities in the private outdoor area. Although the health effects of noise are not taken as seriously in the United States as they are in other countries, they are real and, in many parts of the country, pervasive4. Noise can disturb sleep by making it more difficult to fall asleep, by waking someone after they are asleep, or by altering their sleep stage, e.g., reducing the amount of rapid eye movement (REM) sleep. Noise exposure for people who are sleeping has also been linked to increased blood pressure, increased heart rate, increase in body movements, and other physiological effects. Not surprisingly, people whose sleep is disturbed by noise often experience secondary effects such as increased fatigue, depressed mood, and decreased work performance.

Thus, excessive noise from amplified speech or music in the private outdoor area occurring between 10 PM and 7 AM could cause sleep disturbance and would be potentially significant. The World Health Organization5 (WHO) identifies a guidance of 45 dBA Leq (outdoors) to avoid sleep disturbance from 3 https://roseville.ca.us/government/departments/development_services/planning/citywide_planning_documents 4 More information on these and other adverse effects of noise may be found in Guidelines for Community Noise, eds B Berglund, T Lindvall, and D Schwela, World Health Organization, Geneva, Switzerland, 1999. https://www.who.int/docstore/peh/noise/Comnoise-1.pdf 5 Ibid.

WILSON IHRIG
Sutter Garage and MOB, Roseville, ND

a continuous source, and a limit of 60 dBA Lmax for intermittent sources6. However, it has been our experience that low frequency bass notes, commonly found in music played at social events, can be problematic even when the A-weighted level complies with applicable code. This is partly because the low frequencies pass through the exterior walls and closed windows with little reduction.

For annoyance, WHO identifies a guidance of 50 dBA Leq (outdoors) to avoid moderate annoyance during daytime and evening hours (7 AM to 10 PM).

Speech Interference
For intelligibility of speech, which could be substantially impacted for people in nearby offices or working from home, WHO identifies a guidance of 35 dBA Leq (indoors), which equates to 50 dBA Leq outdoors for building with open windows. If the windows can be shut (e.g., if sufficient ventilation is provided), then the outdoor noise limit would be 60 dBA Leq.

Construction Noise and Vibration
Similarly, the effect of construction noise and vibration has been minimized in the ND discussion. The ND characterizes construction as “temporary” and appears to rely on this fact to avoid evaluation of the construction noise and vibration. The ND provides no metrics to evaluate the significance of construction noise and vibration. Daytime construction could interfere with daytime activities, such as interfering with speech during conversations and phone calls.

Caltrans provides guidance to evaluate the effects of vibration from construction sources7.

Construction activities which generate vibration on the order of 0.04 in/sec PPV for continuous or frequent intermittent sources such as vibratory compaction and 0.25 in/sec PPV for transient sources such as trucks are “distinctly perceptible” and could be potentially significant.

Noise Ordinance Compliance
Table 1 of the Roseville Noise Regulation (Chapter 9/24)8 identifies a noise limits of 50 dBA during the daytime (7 AM to 10 PM) and 45 dBA during the nighttime (10 PM to 7 AM) from nontransportation or fixed sound sources. This information is lacking in the ND.

Impact Analyses are Incomplete
Mechanical equipment
The ND provides no evidence that the rooftop equipment for the MOB would comply with the Municipal code, and provides no evidence that the addition of such equipment would be less than significant at the nearest residential structure, which is only 120 ft away. Depending on the cooling needs, commercial-use air handling cooling systems can generate 78 to 94 dBA at 3 ft9. With two of these units in operation the resulting noise level at the nearest residence would be 49 to 65 dBA. This would be a potentially significant impact. If this equipment would operate into the nighttime hours, 6 These outdoor levels assume that the residence reduces noise by 15 dBA with windows open, which is typical for conventional construction.
7 https://dot.ca.gov/-/media/dot-media/programs/environmental-analysis/documents/env/tcvgm-apr2020- a11y.pdf
8 https://library.qcode.us/lib/roseville_ca/pub/municipal_code/item/title_9-chapter_9_24 9 Carrier N series generates 76 dBA at 25 ft distance, or about 94 dBA at 3 ft.

WILSON IHRIG
Sutter Garage and MOB, Roseville, ND

it would exceed the 45 dBA noise limit; during daytime hours, the largest of the potential equipment would also exceed the 50 dBA noise limit.

Emergency/standby generators are commonly used for essential buildings, and the ND appears to lack any discussion of such equipment in the noise analysis.

Construction Noise
Information from Caltrans10 and other sources can be used to estimate noise from construction.

Demolition of existing buildings, excavation, foundations, concrete and building erection will all require several months of activity. Even if this work would only be conducted during daytime hours, the interference on daytime activities such as talking on the phone, conducting meetings, etc. at nearby offices and residences could be potentially significant. The ND provides no evidence that the on-going construction noise and vibration would be less than significant. Table 1 provides sample calculations from five different types of construction equipment, some of which could combine. Thus, during demolition and site preparation, noise from a hoe ram, excavator, or dozer could generate noise as high as 72 to 86 dBA Lmax at the nearest residence, with on-going noise over several hours each day ranging from 68 to 79 dBA Leq. If several activities and/or equipment would be operating at the same time, the noise would be even higher. During building construction, the noise from a crane, front end loader or pneumatic tools would range from 67 to 77 dBA Lmax, with on-going noise levels of 63 to 74 dBA Leq. Based on the WHO guidance, these exterior noise levels would all cause speech interference at interior locations. This would be potentially significant at nearby noise sensitive receptors.

Table 1 Sample Calculations from Construction Noise
Equipment
Reference
Level at
50 ft
(dBA)
Usage
Factor
(%)
Distance to Nearest Residence Intermittent Level (dBA Lmax) On-going Level (dBA Leq) Near
distance
Building
edge
Center
distance
Near
distance
Building
edge
Center
distance
Near
distance
Building
edge
Center
distance
Mounted Impact
Hammer Hoe Ram 90 20 75 120 230 86 82 77 79 75 70
Excavator or Dozer 85 40 75 120 230 81 77 72 77 73 68
Crane 85 16 75 120 230 N/A 77 72 N/A 69 64
Front end loader 80 40 75 120 230 76 72 67 72 68 63
Pneumatic Tools 85 50 75 120 230 N/A 77 72 N/A 74 69
Noise Mitigations are Lacking
As noted above, the rooftop equipment on the MOB would potentially exceed the noise limits.

Mitigations include selection, siting and/or screening of the mechanical equipment to ensure that the combined mechanical equipment noise would be properly controlled to meet 50 dBA during the daytime and 45 dBA at nighttime.
10 https://dot.ca.gov/-/media/dot-media/programs/environmental-analysis/documents/env/tens-sep2013- a11y.pdf

WILSON IHRIG
Sutter Garage and MOB, Roseville, ND

To mitigate construction noise, mitigation measures should include the following, and the ND should include evidence that these measures would be sufficient to eliminate the (potentially) significant impacts below the thresholds of significance:
 Sound barrier or blankets that block line of sight from the noisiest construction equipment and activities to the noise sensitive neighbors.
 Buffer distances to keep noisy activities and stationary equipment away from noise sensitive neighbors.
 Notification is useful community outreach, but has no bearing on reducing noise.

Conclusions
The ND lacks evidence to support its conclusions regarding construction noise and vibration and operational noise. Thresholds of significance have been omitted from the document. The mechanical noise, generator noise and construction noise analyses in the ISMND also are not complete, and based on the analysis discussed above, mitigations are required.

Please feel free to contact me with any questions on this information.

Very truly yours,

WILSON IHRIG
Deborah A. Jue, INCE-USA
Principal
sutter garage mob nd_noise review_wilson ihrig_5-10-22.docx

EXHIBIT C
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]
May 11, 2022
Brian Flynn
Lozeau | Drury LLP
1939 Harrison Street, Suite 150
Oakland, CA 94618
Subject: Comments on the Sutter Parking Garage Expansion Project (SCH No. 2022040255) Dear Mr. Flynn,
We have reviewed the April 2022 Initial Study / Negative Declaration (“IS/ND”) for the Sutter Parking Garage Expansion & Sutter MOB Project (“Project”) located in the City of Roseville (“City”). The Project proposes to expand the existing 5-story parking structure with the addition of a 6-story parking structure on a 0.94-acre site, as well as construct of a 100,000-square-foot (“SF”) medical office building on a 1.64-acre site.

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

Air Quality
Failure to Adequately Evaluate Operational Criteria Air Pollutant Emissions The IS/ND fails to quantify the Project’s operational criteria air pollutant emissions. Specifically, the IS/ND states:
“The PCAPCD maintains screening thresholds to determine when modeling is required to evaluate impacts resulting from project operation. The screening thresholds indicates a General Office project must involve more than 648,000 square feet of building area before the PCAPCD significance thresholds for criteria pollutants are likely to be exceed. The proposed MOB includes 100,000 square feet of building area, and the parking garage expansion includes 2 approximately 200,000 square feet of building area, which is well below the screening thresholds; therefore, the project will not result in operational emissions which exceed established thresholds” (p. 14).

Review of the Placer County Air Pollution Control District (“PCAPCD”) demonstrates that the air district includes screening thresholds (see excerpt below):
1 As demonstrated above, the screening thresholds are associated with NOX emissions. Furthermore, the PCAPCD states that the above-mentioned thresholds are a “preliminary screening methodology and it does not include ROG operational emissions.”2 Thus, while the IS/ND is correct in concluding that the size of the proposed Project is below the “General Office” threshold of 648,661-SF, the IS/ND fails to acknowledge that the threshold is only applicable to operational NOX emissions. As such, the IS/ND fails to quantify the Project’s operational ROG emissions, which is incorrect per PCAPCD guidance. The Project should not be approved until an EIR is prepared to evaluate the ROG emissions associated with Project operation.

Unsubstantiated Input Parameters Used to Estimate Project Emissions The air quality analysis provided in the IS/ND relies on emissions calculated with the California Emissions Estimator Model (“CalEEMod”) Version 2020.4.0 (p. 14).3 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 the California Environmental Quality Act (“CEQA”) requires that such changes be 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 utilized in calculating the Project's air pollutant emissions and make known which default values are changed as well as provide justification for the values selected.

When reviewing the Project’s CalEEMod output files, provided in Attachment 3 to the IS/ND, we found that several model inputs are not consistent with information disclosed in the IS/ND. As a result, the Project’s construction-related emissions are underestimated. An EIR should be prepared to include an 1 “Chapter 2: Thresholds of Significance.” PCAPCD, available at:
https://www.placerair.org/DocumentCenter/View/2047/Chapter-2-Thresholds-of-Significance-PDF, p. 21, Table 2-2. 2 “Chapter 2: Thresholds of Significance.” PCAPCD, available at:
https://www.placerair.org/DocumentCenter/View/2047/Chapter-2-Thresholds-of-Significance-PDF, p. 21. 3 “CalEEMod Version 2020.4.0.” California Air Pollution Control Officers Association (CAPCOA), May 2021, available at: http://www.aqmd.gov/caleemod/download-model.
3 updated air quality analysis that adequately evaluates the impacts that construction of the Project will have on local and regional air quality.

Underestimated Land Use Size
According to the IS/ND:
“The second DRP is for the construction of a 100,000 square foot medical office building constructed in two phases; Phase 1 totaling 85,000 square feet would be constructed immediately after City approval and Phase 2 totaling 15,000 square feet in size would be constructed at a later date” (p. 1).

As such, the model should have included 100,000-SF of medical office space. However, review of the CalEEMod output files demonstrates that the “Sutter Parking Garage Expansion & MOB 10” model includes only 100-SF of medical office space (see excerpt below) (Attachment 3, pp. 68, 98, 124).

As demonstrated in the excerpt above, the proposed medical office space is underestimated by 99,900- SF.4 This underestimation presents an issue, as the land use size feature is used throughout CalEEMod to determine default variable and emission factors that go into the model’s calculations. The square footage of a land use is used for certain calculations, such as determining the wall space to be painted (i.e., VOC emissions from architectural coatings).5 As such, by underestimating the size of the proposed medical office land use, the model underestimates the Project’s construction-related emissions and should not be relied upon to determine Project significance.

Underestimated Parking Land Use Size
Review of the CalEEMod output files demonstrates that the “Sutter Parking Garage Expansion & MOB 10” model includes 191,957-SF of parking land use space (see excerpt below) (Attachment 3, pp. 68, 98, 124).

However, regarding the size of the proposed parking structure, the IS/ND simply states:
“The proposed expansion will consist of six-levels tied into the existing five-level parking garage” (p. 1).
4 Calculated: (100,000-SF proposed warehouse space) – (100-SF modeled warehouse space) = 99,900-SF underestimated warehouse space. 5 “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. 28. 4 As such, the IS/ND fails to substantiate the exact square-footage or the number of spaces to be provided by the proposed parking structure. This is incorrect, as according to the CalEEMod User’s Guide:
“CalEEMod was also designed to allow the user to change the defaults to reflect site- or projectspecific information, when available, provided that the information is supported by substantial evidence as required by CEQA.” 6

Here, as the IS/ND and associated documents fail to provide substantial evidence to support the land use size of the proposed parking structure, we cannot verify that the model is accurate.

This presents an issue, as the square footage of parking land uses is used for certain calculations, such as determining the area to be painted and stripped (i.e., VOC emissions from architectural coatings). 7 Thus,
by potentially underestimating the proposed parking land use size, the model may underestimate the Project’s construction-related emissions and should not be relied upon to determine Project significance.

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/ND. In our updated model, we accounted for the entire 100,000-SF medical office building. 8 Our updated analysis estimates that the Project’s construction-related ROG emissions would exceed the applicable PCAPCD threshold of 82 pounds per day (“lbs/day”), as referenced by the IS/ND (p. 14) (see table below).9

SWAPE Criteria Air Pollutant Emissions
Construction ROG
(lbs/day)
IS/ND 17
SWAPE 98
% Increase 476%
PCAPCD Threshold 82
Exceeds? Yes
As you can see in the table above, the Project’s construction-related ROG emissions, as estimated by SWAPE, increase by approximately 476% and exceed the PCAPCD significance threshold. Thus, our 6 “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. 13-14. 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. 29. 8 See Attachment A for updated air modeling. 9 “Chapter 2: Thresholds of Significance.” PCAPCD, available at:
https://www.placerair.org/DocumentCenter/View/2047/Chapter-2-Thresholds-of-Significance-PDF, p. 21, Table 2-1. 5 updated model demonstrates that the Project would result in a potentially significant air quality impact that was not previously identified or addressed in the IS/ND. As a result, an EIR should be prepared to adequately assess and mitigate the potential air quality impacts that the Project may have on environment.

Greenhouse Gas
Failure to Adequately Evaluate Greenhouse Gas Impacts
Regarding the Project’s potential greenhouse gas (“GHG”) impact, the IS/ND states:
“The City’s General Plan Update (GPU) EIR included an analysis of GHG emissions, which would result from buildout of the City’s General Plan. The EIR concluded that General Plan build out would exceed the City’s threshold of 2.25 MT CO2e per service population and that the affect was cumulatively considerable. Although mitigation measures were adopted as part of the General Plan, those measures would not reduce impacts to less-than-significant levels and impacts were considered significant and unavoidable. The proposed project is consistent with the land use assumptions in the GPU EIR and does not require further analysis per the tiering provisions of CEQA. The project includes reasonable and feasible design measures to reduce emissions, including implementation of the latest Cal-Green and energy efficiency code requirements. The medical office building will incorporate several alternative transportation measures like bike racks immediately in front of the medical office building. The project complies with General Plan policy related to GHG and the project does not result in any new GHG impacts not previously analyzed in the GPU EIR; therefore, impacts are less than significant” (p. 25-26).

However, the IS/ND fails to make any effort to quantify or evaluate the Project’s GHG emissions. As a result, the IS/ND’s analysis of the Project’s potential GHG impact, as well as the subsequent less-thansignificant impact conclusion, is incorrect for two reasons. (1) The IS/ND fails to quantify the Project’s potential GHG emissions; and (2) The IS/ND fails to indicate a potentially significant impact. 1) Failure to Quantify GHG Emissions
As previously stated, the IS/ND concludes that the Project would result in a significant-and-unavoidable GHG impact (p. 25-26). However, the IS/ND fails to estimate the Project’s net annual GHG emissions whatsoever. By failing to evaluate or quantify the Project’s potential GHG emissions, the Project is inconsistent with CEQA. Specifically, according to CEQA Guidelines § 15064.4(a):
“A lead agency shall make a good-faith effort, based on available information, to describe, calculate or estimate the amount of greenhouse gas emissions resulting from a project.” 10 10 “Final Adopted Text for Revisions to the CEQA Guidelines.” Governor’s Office of Planning and Research (“OPR”), available at: https://opr.ca.gov/ceqa/updates/guidelines/, p. 13. 6 As you can see in the excerpt above, CEQA Guidelines require a Project to “describe, calculate, or estimate” the GHG emissions that would be generated by the Project. Here, by failing to evaluate or quantify the Project’s GHG emissions, the IS/ND is inconsistent with CEQA Guidelines and lacks evidence to support its conclusion that the Project emissions would be less-than-significant. 2) Updated Analysis Indicates a Potentially Significant Impact In an effort to quantitatively evaluate the Project’s GHG emissions, we compared the Project’s GHG emissions, as estimated by SWAPE, to the PCAPCD De Minimis Level operational threshold of 1,100 metric tons of carbon dioxide equivalents per year (“MT CO2e/year”). 11 When applying this threshold,
SWAPE’s updated air model indicates a potentially significant GHG impact.

The updated CalEEMod output files indicate that the Project would generate approximately 2,933.32 MT CO2e/year of net annual GHG operational emissions (sum of area-, energy-, mobile-, waste-, and waterrelated emissions) (see table below).

SWAPE Annual Greenhouse Gas Emissions
Project Phase Proposed Project
(MT CO2e/year)
Area 0.00
Energy 519.71
Mobile 1,837.00
Waste 543.13
Water 33.48
Total Annual Emissions 2,933.32
PCAPCD De Minimis Level 1,100
Exceeds? Yes
As demonstrated above, the Project’s net annual operational GHG emissions, as estimated by SWAPE, exceed the PCAPCD’s De Minimis Level threshold of 1,100 MT CO2e/year. According to PCAPCD guidance:
“Projects with GHG emissions which exceed the De Minimis Level of 1,100 MT CO2e/yr, but less than 10,000 MTCO2e/yr can still be found less than cumulatively considerable when the result of project related efficiency analysis would meet one of conditions in the efficiency matrix for the applicable land use setting and land use type provided.” 12 11 “California Environmental Quality Act Thresholds of Significance.” Placer County Air Pollution Control District (“PCAPCD”), October 2016, available at: https://www.placer.ca.gov/DocumentCenter/View/2061/ThresholdJustification-Report-PDF, p. E-2. 12 “California Environmental Quality Act Thresholds of Significance.” Placer County Air Pollution Control District (“PCAPCD”), October 2016, available at: https://www.placer.ca.gov/DocumentCenter/View/2061/ThresholdJustification-Report-PDF, p. E-2. 7 As demonstrated above, for projects that exceed 1,100 MT CO2e/year, the PCAPCD requires additional GHG analysis to determine a less-than-significant impact. As such, the Project may result in a potentially significant GHG impact not previously identified or addressed by the IS/ND. An EIR should be prepared to include an updated GHG analysis per PCAPCD guidance and adequately mitigate potential GHG impacts, if necessary.

Feasible Mitigation Measures Available to Reduce Emissions Our analysis demonstrates that the Project would result in potentially significant air quality and GHG impacts that should be mitigated further. As such, in an effort to reduce the Project’s emissions, we identified several mitigation measures that are applicable to the proposed Project. Therefore, to reduce the Project’s emissions, we recommend consideration of SCAG’s 2020 RTP/SCS PEIR’s Air Quality Project Level Mitigation Measures (“PMM-AQ-1”) and Greenhouse Gas Project Level Mitigation Measures (“PMM-GHG-1”), as described below: 13
SCAG RTP/SCS 2020-2045
Air Quality Project Level Mitigation Measures – PMM-AQ-1:

In accordance with provisions of sections 15091(a)(2) and 15126.4(a)(1)(B) of the State CEQA Guidelines, a Lead Agency for a project can and should consider mitigation measures to reduce substantial adverse effects related to violating air quality standards. Such measures may include the following or other comparable measures identified by the Lead Agency:
a) Minimize land disturbance.
b) Suspend grading and earth moving when wind gusts exceed 25 miles per hour unless the soil is wet enough to prevent dust plumes.
c) Cover trucks when hauling dirt.
d) Stabilize the surface of dirt piles if not removed immediately. e) Limit vehicular paths on unpaved surfaces and stabilize any temporary roads. f) Minimize unnecessary vehicular and machinery activities. g) Sweep paved streets at least once per day where there is evidence of dirt that has been carried on to the roadway.
h) Revegetate disturbed land, including vehicular paths created during construction to avoid future off-road vehicular activities.
j) Require contractors to assemble a comprehensive inventory list (i.e., make, model, engine year, horsepower, emission rates) of all heavy-duty off-road (portable and mobile) equipment (50 horsepower and greater) that could be used an aggregate of 40 or more hours for the construction project. Prepare a plan for approval by the applicable air district demonstrating achievement of the applicable percent reduction for a CARB-approved fleet.
k) Ensure that all construction equipment is properly tuned and maintained. 13 “4.0 Mitigation Measures.” Connect SoCal Program Environmental Impact Report Addendum #1, September 2020, available at: https://scag.ca.gov/sites/main/files/fileattachments/fpeir_connectsocal_addendum_4_mitigationmeasures.pdf?1606004420, p. 4.0-2 – 4.0-10; 4.0-19 –

4.0-23; See also: “Certified Final Connect SoCal Program Environmental Impact Report.” Southern California Association of Governments (SCAG), May 2020, available at: https://scag.ca.gov/peir. 8 l) Minimize idling time to 5 minutes—saves fuel and reduces emissions. m) Provide an operational water truck on-site at all times. Use watering trucks to minimize dust; watering should be sufficient to confine dust plumes to the project work areas. Sweep paved streets at least once per day where there is evidence of dirt that has been carried on to the roadway. n) Utilize existing power sources (e.g., power poles) or clean fuel generators rather than temporary power generators.
o) Develop a traffic plan to minimize traffic flow interference from construction activities. The plan may include advance public notice of routing, use of public transportation, and satellite parking areas with a shuttle service.

Schedule operations affecting traffic for off-peak hours. Minimize obstruction of through-traffic lanes. Provide a flag person to guide traffic properly and ensure safety at construction sites. p) As appropriate require that portable engines and portable engine-driven equipment units used at the project work site, with the exception of on-road and off-road motor vehicles, obtain CARB Portable Equipment Registration with the state or a local district permit. Arrange appropriate consultations with the CARB or the District to determine registration and permitting requirements prior to equipment operation at the site. q) Require projects within 500 feet of residences, hospitals, or schools to use Tier 4 equipment for all engines above 50 horsepower (hp) unless the individual project can demonstrate that Tier 4 engines would not be required to mitigate emissions below significance thresholds. s) Projects located within AB 617 communities should review the applicable Community Emissions Reduction Plan (CERP) for additional mitigation that can be applied to individual projects. t) Where applicable, projects should provide information about air quality related programs to schools, including the Environmental Justice Community Partnerships (EJCP), Clean Air Ranger Education (CARE), and Why Air Quality Matters programs.
u) Projects should work with local cities and counties to install adequate signage that prohibits truck idling in certain locations (e.g., near schools and sensitive receptors). z) Develop an ongoing monitoring, inspection, and maintenance program for the MERV filters. aa) Consult the SCAG Environmental Justice Toolbox for potential measures to address impacts to low-income and/or minority communities.
bb) The following criteria related to diesel emissions shall be implemented on by individual project sponsors as appropriate and feasible:
- Diesel nonroad vehicles on site for more than 10 total days shall have either (1) engines that meet EPA on road emissions standards or (2) emission control technology verified by EPA or CARB to reduce PM emissions by a minimum of 85%
- Diesel generators on site for more than 10 total days shall be equipped with emission control technology verified by EPA or CARB to reduce PM emissions by a minimum of 85%. - Nonroad diesel engines on site shall be Tier 2 or higher. - Diesel nonroad construction equipment on site for more than 10 total days shall have either (1) engines meeting EPA Tier 4 nonroad emissions standards or (2) emission control technology verified by EPA or CARB for use with nonroad engines to reduce PM emissions by a minimum of 85% for engines for 50 hp and greater and by a minimum of 20% for engines less than 50 hp. - Emission control technology shall be operated, maintained, and serviced as recommended by the emission control technology manufacturer.
- Diesel vehicles, construction equipment, and generators on site shall be fueled with ultra-low sulfur diesel fuel (ULSD) or a biodiesel blend approved by the original engine manufacturer with sulfur content of 15 ppm or less.
- The construction contractor shall maintain a list of all diesel vehicles, construction equipment, and generators to be used on site. The list shall include the following:
i. Contractor and subcontractor name and address, plus contact person responsible for the vehicles or equipment.
ii. Equipment type, equipment manufacturer, equipment serial number, engine manufacturer, engine model year, engine certification (Tier rating), horsepower, engine serial number, and expected fuel usage and hours of operation.
9 iii. For the emission control technology installed: technology type, serial number, make, model, manufacturer, EPA/CARB verification number/level, and installation date and hour-meter reading on installation date.
- The contractor shall establish generator sites and truck-staging zones for vehicles waiting to load or unload material on site. Such zones shall be located where diesel emissions have the least impact on abutters, the general public, and especially sensitive receptors such as hospitals, schools, daycare facilities, elderly housing, and convalescent facilities. - The contractor shall maintain a monthly report that, for each on road diesel vehicle, nonroad construction equipment, or generator onsite, includes:
i. Hour-meter readings on arrival on-site, the first and last day of every month, and on off-site date.
ii. Any problems with the equipment or emission controls. iii. Certified copies of fuel deliveries for the time period that identify:

1. Source of supply

2. Quantity of fuel

3. Quantity of fuel, including sulfur content (percent by weight) cc) Project should exceed Title-24 Building Envelope Energy Efficiency Standards (California Building Standards Code). The following measures can be used to increase energy efficiency:
- Provide pedestrian network improvements, such as interconnected street network, narrower roadways and shorter block lengths, sidewalks, accessibility to transit and transit shelters, traffic calming measures, parks and public spaces, minimize pedestrian barriers. - Provide traffic calming measures, such as:
i. Marked crosswalks
ii. Count-down signal timers
iii. Curb extensions iv. Speed tables
iv. Raised crosswalks
v. Raised intersections
vi. Median islands
vii. Tight corner radii
viii. Roundabouts or mini-circles
ix. On-street parking
x. Chicanes/chokers
- Create urban non-motorized zones
- Provide bike parking in non-residential and multi-unit residential projects - Dedicate land for bike trails
- Limit parking supply through:
i. Elimination (or reduction) of minimum parking requirements ii. Creation of maximum parking requirements
iii. Provision of shared parking
- Require residential area parking permit.
- Provide ride-sharing programs
i. Designate a certain percentage of parking spacing for ride sharing vehicles ii. Designating adequate passenger loading and unloading and waiting areas for ride-sharing vehicles
iii. Providing a web site or messaging board for coordinating rides iv. Permanent transportation management association membership and finding requirement.

Greenhouse Gas Project Level Mitigation Measures – PMM-GHG-1 10 In accordance with provisions of sections 15091(a)(2) and 15126.4(a)(1)(B) of the State CEQA Guidelines, a Lead Agency for a project can and should consider mitigation measures to reduce substantial adverse effects related to violating air quality standards. Such measures may include the following or other comparable measures identified by the Lead Agency:
b) Reduce emissions resulting from projects through implementation of project features, project design, or other measures, such as those described in Appendix F of the State CEQA Guidelines. c) Include off-site measures to mitigate a project’s emissions. d) Measures that consider incorporation of Best Available Control Technology (BACT) during design, construction and operation of projects to minimize GHG emissions, including but not limited to:
i. Use energy and fuel-efficient vehicles and equipment; ii. Deployment of zero- and/or near zero emission technologies; iii. Use lighting systems that are energy efficient, such as LED technology; iv. Use the minimum feasible amount of GHG-emitting construction materials; v. Use cement blended with the maximum feasible amount of flash or other materials that reduce GHG emissions from cement production;
vi. Incorporate design measures to reduce GHG emissions from solid waste management through encouraging solid waste recycling and reuse;
vii. Incorporate design measures to reduce energy consumption and increase use of renewable energy;
viii. Incorporate design measures to reduce water consumption; ix. Use lighter-colored pavement where feasible;
x. Recycle construction debris to maximum extent feasible; xi. Plant shade trees in or near construction projects where feasible; and xii. Solicit bids that include concepts listed above.
e) Measures that encourage transit use, carpooling, bike-share and car-share programs, active transportation, and parking strategies, including, but not limited to the following:
i. Promote transit-active transportation coordinated strategies; ii. Increase bicycle carrying capacity on transit and rail vehicles; iii. Improve or increase access to transit;
iv. Increase access to common goods and services, such as groceries, schools, and day care; v. Incorporate affordable housing into the project;
vi. Incorporate the neighborhood electric vehicle network; vii. Orient the project toward transit, bicycle and pedestrian facilities; viii. Improve pedestrian or bicycle networks, or transit service; ix. Provide traffic calming measures;
x. Provide bicycle parking;
xi. Limit or eliminate park supply;
xii. Unbundle parking costs;
xiii. Provide parking cash-out programs;
xiv. Implement or provide access to commute reduction program; f) Incorporate bicycle and pedestrian facilities into project designs, maintaining these facilities, and providing amenities incentivizing their use; and planning for and building local bicycle projects that connect with the regional network;
g) Improving transit access to rail and bus routes by incentives for construction and transit facilities within developments, and/or providing dedicated shuttle service to transit stations; and 11 h) Adopting employer trip reduction measures to reduce employee trips such as vanpool and carpool programs, providing end-of-trip facilities, and telecommuting programs including but not limited to measures that:
i. Provide car-sharing, bike sharing, and ride-sharing programs; ii. Provide transit passes;
iii. Shift single occupancy vehicle trips to carpooling or vanpooling, for example providing ridematching services; iv. Provide incentives or subsidies that increase that use of modes other than single-occupancy vehicle;
v. Provide on-site amenities at places of work, such as priority parking for carpools and vanpools, secure bike parking, and showers and locker rooms;
vi. Provide employee transportation coordinators at employment sites; vii. Provide a guaranteed ride home service to users of non-auto modes. i) Designate a percentage of parking spaces for ride-sharing vehicles or high-occupancy vehicles, and provide adequate passenger loading and unloading for those vehicles; j) Land use siting and design measures that reduce GHG emissions, including:
i. Developing on infill and brownfields sites;
ii. Building compact and mixed-use developments near transit; iii. Retaining on-site mature trees and vegetation, and planting new canopy trees; iv. Measures that increase vehicle efficiency, encourage use of zero and low emissions vehicles, or reduce the carbon content of fuels, including constructing or encouraging construction of electric vehicle charging stations or neighborhood electric vehicle networks, or charging for electric bicycles; and
v. Measures to reduce GHG emissions from solid waste management through encouraging solid waste recycling and reuse.
k) Consult the SCAG Environmental Justice Toolbox for potential measures to address impacts to low-income and/or minority communities. The measures provided above are also intended to be applied in low income and minority communities as applicable and feasible.
l) Require at least five percent of all vehicle parking spaces include electric vehicle charging stations, or at a minimum, require the appropriate infrastructure to facilitate sufficient electric charging for passenger vehicles and trucks to plug-in.
m) Encourage telecommuting and alternative work schedules, such as:
i. Staggered starting times
ii. Flexible schedules
iii. Compressed work weeks
n) Implement commute trip reduction marketing, such as:
i. New employee orientation of trip reduction and alternative mode options ii. Event promotions
iii. Publications
o) Implement preferential parking permit program
p) Implement school pool and bus programs
q) Price workplace parking, such as:
i. Explicitly charging for parking for its employees;
ii. Implementing above market rate pricing;
iii. Validating parking only for invited guests;
iv. Not providing employee parking and transportation allowances; and v. Educating employees about available alternatives.
12 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. An EIR should be prepared to include all feasible mitigation measures, as well as include updated air quality, health risk, and GHG analyses to ensure that the necessary mitigation measures are implemented to reduce emissions to below thresholds. The EIR should also demonstrate a commitment to the implementation of these measures prior to Project approval, to ensure that the Project’s 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.

Paul E. Rosenfeld, Ph.D.

Attachment A: CalEEMod Output Files
Attachment B: Matt Hagemann CV
Attachment C: Paul E. Rosenfeld CV
Sutter Parking Garage Expansion & MOB 10
Placer-Sacramento County, Annual
Project Characteristics - Consistent with the IS/ND's model.

Land Use - See SWAPE comment on "Underestimated Land Use Size"

1.1 Land Usage
Land Uses Size Metric Lot Acreage Floor Surface Area Population Medical Office Building 100.00 1000sqft 1.64 100,000.00 0 Enclosed Parking with Elevator 1.00 1000sqft 0.94 191,957.00 0

1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
2 Wind Speed (m/s) 2.2 Precipitation Freq (Days) 74

1.3 User Entered Comments & Non-Default Data

1.0 Project Characteristics

2.0 Emissions Summary
Utility Company Roseville Electric
Operational Year 2024
CO2 Intensity
(lb/MWhr)
471.98 CH4 Intensity 0.033
(lb/MWhr)
N2O Intensity 0.004
(lb/MWhr)
Table Name Column Name Default Value New Value
tblLandUse LandUseSquareFeet 1,000.00 191,957.00
tblLandUse LotAcreage 2.30 1.64
tblLandUse LotAcreage 0.02 0.94
CalEEMod Version: CalEEMod.2020.4.0 Page 1 of 30 Date: 5/9/2022 11:58 AM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied Attachment A

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
2022 0.2206 1.7553 1.7427 4.0800e0030.1295 0.0751 0.2045 0.0393 0.0716 0.1109 0.0000 358.0225 358.0225 0.0454 0.0145 363.4872 2023 0.5434 0.4187 0.4740 1.0900e0030.0291 0.0171 0.0462 7.9200e0030.0163 0.0242 0.0000 95.5395 95.5395 0.0121 3.7200e00396.9507 Maximum 0.5434 1.7553 1.7427 4.0800e0030.1295 0.0751 0.2045 0.0393 0.0716 0.1109 0.0000 358.0225 358.0225 0.0454 0.0145 363.4872 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
2022 0.2206 1.7553 1.7427 4.0800e0030.1295 0.0751 0.2045 0.0393 0.0716 0.1109 0.0000 358.0223 358.0223 0.0454 0.0145 363.4870 2023 0.5434 0.4187 0.4740 1.0900e0030.0291 0.0171 0.0462 7.9200e0030.0163 0.0242 0.0000 95.5394 95.5394 0.0121 3.7200e00396.9507 Maximum 0.5434 1.7553 1.7427 4.0800e0030.1295 0.0751 0.2045 0.0393 0.0716 0.1109 0.0000 358.0223 358.0223 0.0454 0.0145 363.4870 Mitigated Construction
CalEEMod Version: CalEEMod.2020.4.0 Page 2 of 30 Date: 5/9/2022 11:58 AM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 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 3-23-2022 6-22-2022 0.6247 0.6247
2 6-23-2022 9-22-2022 0.6427 0.6427
3 9-23-2022 12-22-2022 0.6415 0.6415
4 12-23-2022 3-22-2023 0.6046 0.6046
5 3-23-2023 6-22-2023 0.4270 0.4270
Highest 0.6427 0.6427

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 0.4521 1.0000e0059.3000e0040.0000 0.0000 0.0000 0.0000 0.0000 0.0000 1.8000e0031.8000e0030.0000 0.0000 1.9200e003 Energy 8.7900e0030.0799 0.0671 4.8000e0046.0700e0036.0700e0036.0700e0036.0700e0030.0000 517.3496 517.3496 0.0318 5.2400e003519.7057 Mobile 1.2146 1.6056 10.3109 0.0192 1.8926 0.0176 1.9102 0.5070 0.0165 0.5235 0.0000 1,803.082 0 1,803.082
0 0.1297 0.1030 1,837.003
5 Waste 0.0000 0.0000 0.0000 0.0000 219.2302 0.0000 219.2302 12.9561 0.0000 543.1336 Water 0.0000 0.0000 0.0000 0.0000 3.9809 16.3269 20.3078 0.4100 9.7900e00333.4766 Total 1.6754 1.6855 10.3790 0.0197 1.8926 0.0237 1.9162 0.5070 0.0226 0.5296 223.2112 2,336.760 3 2,559.971
4 13.5277 0.1180 2,933.321
3 Unmitigated Operational
CalEEMod Version: CalEEMod.2020.4.0 Page 3 of 30 Date: 5/9/2022 11:58 AM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

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 0.4521 1.0000e0059.3000e0040.0000 0.0000 0.0000 0.0000 0.0000 0.0000 1.8000e0031.8000e0030.0000 0.0000 1.9200e003 Energy 8.7900e0030.0799 0.0671 4.8000e0046.0700e0036.0700e0036.0700e0036.0700e0030.0000 517.3496 517.3496 0.0318 5.2400e003519.7057 Mobile 1.2146 1.6056 10.3109 0.0192 1.8926 0.0176 1.9102 0.5070 0.0165 0.5235 0.0000 1,803.082 0 1,803.082
0 0.1297 0.1030 1,837.003
5 Waste 0.0000 0.0000 0.0000 0.0000 219.2302 0.0000 219.2302 12.9561 0.0000 543.1336 Water 0.0000 0.0000 0.0000 0.0000 3.9809 16.3269 20.3078 0.4100 9.7900e00333.4766 Total 1.6754 1.6855 10.3790 0.0197 1.8926 0.0237 1.9162 0.5070 0.0226 0.5296 223.2112 2,336.760 3 2,559.971
4 13.5277 0.1180 2,933.321
3 Mitigated Operational

3.0 Construction Detail
Construction Phase
Phase
Number
Phase Name Phase Type Start Date End Date Num Days
Week
Num Days Phase Description
1 Demolition Demolition 3/23/2022 4/19/2022 5 20
2 Site Preparation Site Preparation 4/20/2022 4/22/2022 5 3 3 Grading Grading 4/23/2022 5/2/2022 5 6
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 30 Date: 5/9/2022 11:58 AM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 4 Building Construction Building Construction 5/3/2022 3/6/2023 5 220 5 Paving Paving 3/7/2023 3/20/2023 5 10
6 Architectural Coating Architectural Coating 3/21/2023 4/3/2023 5 10 OffRoad Equipment
Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor Architectural Coating Air Compressors 1 6.00 78 0.48
Paving Cement and Mortar Mixers 1 8.00 9 0.56
Demolition Concrete/Industrial Saws 1 8.00 81 0.73
Building Construction Cranes 1 8.00 231 0.29
Building Construction Forklifts 2 7.00 89 0.20
Building Construction Generator Sets 1 8.00 84 0.74
Grading Graders 1 8.00 187 0.41
Site Preparation Graders 1 8.00 187 0.41
Paving Pavers 1 8.00 130 0.42
Paving Paving Equipment 1 8.00 132 0.36
Paving Rollers 2 8.00 80 0.38
Demolition Rubber Tired Dozers 1 8.00 247 0.40
Grading Rubber Tired Dozers 1 8.00 247 0.40
Site Preparation Scrapers 1 8.00 367 0.48
Building Construction Tractors/Loaders/Backhoes 1 6.00 97 0.37 Demolition Tractors/Loaders/Backhoes 3 8.00 97 0.37
Grading Tractors/Loaders/Backhoes 2 7.00 97 0.37
Residential Indoor: 0; Residential Outdoor: 0; Non-Residential Indoor: 150,000; Non-Residential Outdoor: 50,000; Striped Parking Area: 11,517 (Architectural Coating – sqft)
Acres of Grading (Site Preparation Phase): 4.5
Acres of Grading (Grading Phase): 6
Acres of Paving: 0.94
CalEEMod Version: CalEEMod.2020.4.0 Page 5 of 30 Date: 5/9/2022 11:58 AM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

3.2 Demolition - 2022
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 0.0169 0.1662 0.1396 2.4000e0048.3800e0038.3800e0037.8300e0037.8300e0030.0000 21.0777 21.0777 5.3700e0030.0000 21.2120 Total 0.0169 0.1662 0.1396 2.4000e0048.3800e0038.3800e0037.8300e0037.8300e0030.0000 21.0777 21.0777 5.3700e0030.0000 21.2120 Unmitigated Construction On-Site

3.1 Mitigation Measures Construction
Paving Tractors/Loaders/Backhoes 1 8.00 97 0.37
Site Preparation Tractors/Loaders/Backhoes 1 7.00 97 0.37 Building Construction Welders 3 8.00 46 0.45
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
Demolition 5 13.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT Site Preparation 3 8.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT Grading 4 10.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT Building Construction 8 113.00 48.00 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 23.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT CalEEMod Version: CalEEMod.2020.4.0 Page 6 of 30 Date: 5/9/2022 11:58 AM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

3.2 Demolition - 2022
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 3.6000e0042.5000e0043.1800e0031.0000e0051.0200e0031.0000e0051.0300e0032.7000e0040.0000 2.8000e0040.0000 0.8276 0.8276 3.0000e0052.0000e0050.8354 Total 3.6000e0042.5000e0043.1800e0031.0000e0051.0200e0031.0000e0051.0300e0032.7000e0040.0000 2.8000e0040.0000 0.8276 0.8276 3.0000e0052.0000e0050.8354 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 0.0169 0.1662 0.1396 2.4000e0048.3800e0038.3800e0037.8300e0037.8300e0030.0000 21.0777 21.0777 5.3700e0030.0000 21.2119 Total 0.0169 0.1662 0.1396 2.4000e0048.3800e0038.3800e0037.8300e0037.8300e0030.0000 21.0777 21.0777 5.3700e0030.0000 21.2119 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 7 of 30 Date: 5/9/2022 11:58 AM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

3.2 Demolition - 2022
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 3.6000e0042.5000e0043.1800e0031.0000e0051.0200e0031.0000e0051.0300e0032.7000e0040.0000 2.8000e0040.0000 0.8276 0.8276 3.0000e0052.0000e0050.8354 Total 3.6000e0042.5000e0043.1800e0031.0000e0051.0200e0031.0000e0051.0300e0032.7000e0040.0000 2.8000e0040.0000 0.8276 0.8276 3.0000e0052.0000e0050.8354 Mitigated Construction Off-Site

3.3 Site Preparation - 2022
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 2.3900e0030.0000 2.3900e0032.6000e0040.0000 2.6000e0040.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 2.0700e0030.0235 0.0151 4.0000e0058.9000e0048.9000e0048.2000e0048.2000e0040.0000 3.2321 3.2321 1.0500e0030.0000 3.2582 Total 2.0700e0030.0235 0.0151 4.0000e0052.3900e0038.9000e0043.2800e0032.6000e0048.2000e0041.0800e0030.0000 3.2321 3.2321 1.0500e0030.0000 3.2582 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 8 of 30 Date: 5/9/2022 11:58 AM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

3.3 Site Preparation - 2022
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 3.0000e0052.0000e0052.9000e0040.0000 9.0000e0050.0000 9.0000e0053.0000e0050.0000 3.0000e0050.0000 0.0764 0.0764 0.0000 0.0000 0.0771 Total 3.0000e0052.0000e0052.9000e0040.0000 9.0000e0050.0000 9.0000e0053.0000e0050.0000 3.0000e0050.0000 0.0764 0.0764 0.0000 0.0000 0.0771 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 2.3900e0030.0000 2.3900e0032.6000e0040.0000 2.6000e0040.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 2.0700e0030.0235 0.0151 4.0000e0058.9000e0048.9000e0048.2000e0048.2000e0040.0000 3.2321 3.2321 1.0500e0030.0000 3.2582 Total 2.0700e0030.0235 0.0151 4.0000e0052.3900e0038.9000e0043.2800e0032.6000e0048.2000e0041.0800e0030.0000 3.2321 3.2321 1.0500e0030.0000 3.2582 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 9 of 30 Date: 5/9/2022 11:58 AM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

3.3 Site Preparation - 2022
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 3.0000e0052.0000e0052.9000e0040.0000 9.0000e0050.0000 9.0000e0053.0000e0050.0000 3.0000e0050.0000 0.0764 0.0764 0.0000 0.0000 0.0771 Total 3.0000e0052.0000e0052.9000e0040.0000 9.0000e0050.0000 9.0000e0053.0000e0050.0000 3.0000e0050.0000 0.0764 0.0764 0.0000 0.0000 0.0771 Mitigated Construction Off-Site

3.4 Grading - 2022
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 0.0213 0.0000 0.0213 0.0103 0.0000 0.0103 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 4.6200e0030.0510 0.0277 6.0000e0052.2300e0032.2300e0032.0500e0032.0500e0030.0000 5.4308 5.4308 1.7600e0030.0000 5.4747 Total 4.6200e0030.0510 0.0277 6.0000e0050.0213 2.2300e0030.0235 0.0103 2.0500e0030.0123 0.0000 5.4308 5.4308 1.7600e0030.0000 5.4747 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 10 of 30 Date: 5/9/2022 11:58 AM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

3.4 Grading - 2022
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 8.0000e0056.0000e0057.3000e0040.0000 2.4000e0040.0000 2.4000e0046.0000e0050.0000 6.0000e0050.0000 0.1910 0.1910 1.0000e0051.0000e0050.1928 Total 8.0000e0056.0000e0057.3000e0040.0000 2.4000e0040.0000 2.4000e0046.0000e0050.0000 6.0000e0050.0000 0.1910 0.1910 1.0000e0051.0000e0050.1928 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 0.0213 0.0000 0.0213 0.0103 0.0000 0.0103 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 4.6200e0030.0510 0.0277 6.0000e0052.2300e0032.2300e0032.0500e0032.0500e0030.0000 5.4308 5.4308 1.7600e0030.0000 5.4747 Total 4.6200e0030.0510 0.0277 6.0000e0050.0213 2.2300e0030.0235 0.0103 2.0500e0030.0123 0.0000 5.4308 5.4308 1.7600e0030.0000 5.4747 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 11 of 30 Date: 5/9/2022 11:58 AM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

3.4 Grading - 2022
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 8.0000e0056.0000e0057.3000e0040.0000 2.4000e0040.0000 2.4000e0046.0000e0050.0000 6.0000e0050.0000 0.1910 0.1910 1.0000e0051.0000e0050.1928 Total 8.0000e0056.0000e0057.3000e0040.0000 2.4000e0040.0000 2.4000e0046.0000e0050.0000 6.0000e0050.0000 0.1910 0.1910 1.0000e0051.0000e0050.1928 Mitigated Construction Off-Site

3.5 Building Construction - 2022
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 0.1614 1.2706 1.2487 2.1800e0030.0611 0.0611 0.0586 0.0586 0.0000 180.6817 180.6817 0.0349 0.0000 181.5532 Total 0.1614 1.2706 1.2487 2.1800e0030.0611 0.0611 0.0586 0.0586 0.0000 180.6817 180.6817 0.0349 0.0000 181.5532 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 12 of 30 Date: 5/9/2022 11:58 AM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

3.5 Building Construction - 2022
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 7.7800e0030.2246 0.0669 8.8000e0040.0273 2.0600e0030.0293 7.9000e0031.9700e0039.8600e0030.0000 83.9194 83.9194 3.6000e0040.0127 87.7117 Worker 0.0273 0.0192 0.2404 6.8000e0040.0772 4.1000e0040.0776 0.0206 3.8000e0040.0209 0.0000 62.5858 62.5858 1.9600e0031.8000e00363.1723 Total 0.0351 0.2438 0.3074 1.5600e0030.1045 2.4700e0030.1069 0.0285 2.3500e0030.0308 0.0000 146.5053 146.5053 2.3200e0030.0145 150.8839 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 0.1614 1.2706 1.2487 2.1800e0030.0611 0.0611 0.0586 0.0586 0.0000 180.6815 180.6815 0.0349 0.0000 181.5529 Total 0.1614 1.2706 1.2487 2.1800e0030.0611 0.0611 0.0586 0.0586 0.0000 180.6815 180.6815 0.0349 0.0000 181.5529 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 13 of 30 Date: 5/9/2022 11:58 AM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

3.5 Building Construction - 2022
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 7.7800e0030.2246 0.0669 8.8000e0040.0273 2.0600e0030.0293 7.9000e0031.9700e0039.8600e0030.0000 83.9194 83.9194 3.6000e0040.0127 87.7117 Worker 0.0273 0.0192 0.2404 6.8000e0040.0772 4.1000e0040.0776 0.0206 3.8000e0040.0209 0.0000 62.5858 62.5858 1.9600e0031.8000e00363.1723 Total 0.0351 0.2438 0.3074 1.5600e0030.1045 2.4700e0030.1069 0.0285 2.3500e0030.0308 0.0000 146.5053 146.5053 2.3200e0030.0145 150.8839 Mitigated Construction Off-Site

3.5 Building Construction - 2023
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 0.0394 0.3134 0.3269 5.8000e0040.0141 0.0141 0.0135 0.0135 0.0000 47.7715 47.7715 9.0300e0030.0000 47.9973 Total 0.0394 0.3134 0.3269 5.8000e0040.0141 0.0141 0.0135 0.0135 0.0000 47.7715 47.7715 9.0300e0030.0000 47.9973 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 14 of 30 Date: 5/9/2022 11:58 AM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

3.5 Building Construction - 2023
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 1.2700e0030.0510 0.0162 2.2000e0047.2100e0033.1000e0047.5200e0032.0900e0032.9000e0042.3800e0030.0000 21.4399 21.4399 6.0000e0053.2400e00322.4075 Worker 6.7100e0034.5000e0030.0591 1.7000e0040.0204 1.0000e0040.0205 5.4300e0039.0000e0055.5300e0030.0000 16.1169 16.1169 4.7000e0044.4000e00416.2608 Total 7.9800e0030.0555 0.0753 3.9000e0040.0276 4.1000e0040.0280 7.5200e0033.8000e0047.9100e0030.0000 37.5568 37.5568 5.3000e0043.6800e00338.6683 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 0.0394 0.3134 0.3269 5.8000e0040.0141 0.0141 0.0135 0.0135 0.0000 47.7714 47.7714 9.0300e0030.0000 47.9973 Total 0.0394 0.3134 0.3269 5.8000e0040.0141 0.0141 0.0135 0.0135 0.0000 47.7714 47.7714 9.0300e0030.0000 47.9973 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 15 of 30 Date: 5/9/2022 11:58 AM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

3.5 Building Construction - 2023
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 1.2700e0030.0510 0.0162 2.2000e0047.2100e0033.1000e0047.5200e0032.0900e0032.9000e0042.3800e0030.0000 21.4399 21.4399 6.0000e0053.2400e00322.4075 Worker 6.7100e0034.5000e0030.0591 1.7000e0040.0204 1.0000e0040.0205 5.4300e0039.0000e0055.5300e0030.0000 16.1169 16.1169 4.7000e0044.4000e00416.2608 Total 7.9800e0030.0555 0.0753 3.9000e0040.0276 4.1000e0040.0280 7.5200e0033.8000e0047.9100e0030.0000 37.5568 37.5568 5.3000e0043.6800e00338.6683 Mitigated Construction Off-Site

3.6 Paving - 2023
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 4.4000e0030.0431 0.0584 9.0000e0052.1700e0032.1700e0032.0000e0032.0000e0030.0000 7.7564 7.7564 2.4600e0030.0000 7.8179 Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 4.4000e0030.0431 0.0584 9.0000e0052.1700e0032.1700e0032.0000e0032.0000e0030.0000 7.7564 7.7564 2.4600e0030.0000 7.8179 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 16 of 30 Date: 5/9/2022 11:58 AM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

3.6 Paving - 2023
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 1.9000e0041.3000e0041.7100e0031.0000e0055.9000e0040.0000 5.9000e0041.6000e0040.0000 1.6000e0040.0000 0.4651 0.4651 1.0000e0051.0000e0050.4692 Total 1.9000e0041.3000e0041.7100e0031.0000e0055.9000e0040.0000 5.9000e0041.6000e0040.0000 1.6000e0040.0000 0.4651 0.4651 1.0000e0051.0000e0050.4692 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 4.4000e0030.0431 0.0584 9.0000e0052.1700e0032.1700e0032.0000e0032.0000e0030.0000 7.7564 7.7564 2.4600e0030.0000 7.8178 Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 4.4000e0030.0431 0.0584 9.0000e0052.1700e0032.1700e0032.0000e0032.0000e0030.0000 7.7564 7.7564 2.4600e0030.0000 7.8178 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 17 of 30 Date: 5/9/2022 11:58 AM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

3.6 Paving - 2023
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 1.9000e0041.3000e0041.7100e0031.0000e0055.9000e0040.0000 5.9000e0041.6000e0040.0000 1.6000e0040.0000 0.4651 0.4651 1.0000e0051.0000e0050.4692 Total 1.9000e0041.3000e0041.7100e0031.0000e0055.9000e0040.0000 5.9000e0041.6000e0040.0000 1.6000e0040.0000 0.4651 0.4651 1.0000e0051.0000e0050.4692 Mitigated Construction Off-Site

3.7 Architectural Coating - 2023
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 0.4902 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 9.6000e0046.5100e0039.0600e0031.0000e0053.5000e0043.5000e0043.5000e0043.5000e0040.0000 1.2766 1.2766 8.0000e0050.0000 1.2785 Total 0.4912 6.5100e0039.0600e0031.0000e0053.5000e0043.5000e0043.5000e0043.5000e0040.0000 1.2766 1.2766 8.0000e0050.0000 1.2785 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 18 of 30 Date: 5/9/2022 11:58 AM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

3.7 Architectural Coating - 2023
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 3.0000e0042.0000e0042.6200e0031.0000e0059.0000e0040.0000 9.1000e0042.4000e0040.0000 2.4000e0040.0000 0.7131 0.7131 2.0000e0052.0000e0050.7195 Total 3.0000e0042.0000e0042.6200e0031.0000e0059.0000e0040.0000 9.1000e0042.4000e0040.0000 2.4000e0040.0000 0.7131 0.7131 2.0000e0052.0000e0050.7195 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 0.4902 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 9.6000e0046.5100e0039.0600e0031.0000e0053.5000e0043.5000e0043.5000e0043.5000e0040.0000 1.2766 1.2766 8.0000e0050.0000 1.2785 Total 0.4912 6.5100e0039.0600e0031.0000e0053.5000e0043.5000e0043.5000e0043.5000e0040.0000 1.2766 1.2766 8.0000e0050.0000 1.2785 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 19 of 30 Date: 5/9/2022 11:58 AM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

3.7 Architectural Coating - 2023
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 3.0000e0042.0000e0042.6200e0031.0000e0059.0000e0040.0000 9.1000e0042.4000e0040.0000 2.4000e0040.0000 0.7131 0.7131 2.0000e0052.0000e0050.7195 Total 3.0000e0042.0000e0042.6200e0031.0000e0059.0000e0040.0000 9.1000e0042.4000e0040.0000 2.4000e0040.0000 0.7131 0.7131 2.0000e0052.0000e0050.7195 Mitigated Construction Off-Site

4.0 Operational Detail - Mobile

4.1 Mitigation Measures Mobile
CalEEMod Version: CalEEMod.2020.4.0 Page 20 of 30 Date: 5/9/2022 11:58 AM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 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 1.2146 1.6056 10.3109 0.0192 1.8926 0.0176 1.9102 0.5070 0.0165 0.5235 0.0000 1,803.082 0 1,803.082
0 0.1297 0.1030 1,837.003
5 Unmitigated 1.2146 1.6056 10.3109 0.0192 1.8926 0.0176 1.9102 0.5070 0.0165 0.5235 0.0000 1,803.082 0 1,803.082
0 0.1297 0.1030 1,837.003
5 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
Enclosed Parking with Elevator 0.00 0.00 0.00
Medical Office Building 3,480.00 857.00 142.00 5,144,491 5,144,491 Total 3,480.00 857.00 142.00 5,144,491 5,144,491
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 Enclosed Parking with Elevator 9.50 7.30 7.30 0.00 0.00 0.00 0 0 0 Medical Office Building 9.50 7.30 7.30 29.60 51.40 19.00 60 30 10

4.4 Fleet Mix
Land Use LDA LDT1 LDT2 MDV LHD1 LHD2 MHD HHD OBUS UBUS MCY SBUS MH Enclosed Parking with Elevator 0.466187 0.061512 0.210180 0.153350 0.034639 0.008391 0.014417 0.011935 0.000556 0.000412 0.031993 0.000977 0.005450 Medical Office Building 0.466187 0.061512 0.210180 0.153350 0.034639 0.008391 0.014417 0.011935 0.000556 0.000412 0.031993 0.000977 0.005450

5.0 Energy Detail
CalEEMod Version: CalEEMod.2020.4.0 Page 21 of 30 Date: 5/9/2022 11:58 AM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 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 430.3666 430.3666 0.0301 3.6500e003432.2058 Electricity
Unmitigated

0.0000 0.0000 0.0000 0.0000 0.0000 430.3666 430.3666 0.0301 3.6500e003432.2058 NaturalGas
Mitigated

8.7900e0030.0799 0.0671 4.8000e0046.0700e0036.0700e0036.0700e0036.0700e0030.0000 86.9830 86.9830 1.6700e0031.5900e00387.4999 NaturalGas
Unmitigated

8.7900e0030.0799 0.0671 4.8000e0046.0700e0036.0700e0036.0700e0036.0700e0030.0000 86.9830 86.9830 1.6700e0031.5900e00387.4999

5.1 Mitigation Measures Energy
Historical Energy Use: N
CalEEMod Version: CalEEMod.2020.4.0 Page 22 of 30 Date: 5/9/2022 11:58 AM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

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 tons/yr MT/yr
Enclosed Parking
with Elevator
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 Medical Office
Building

1.63e
+006

8.7900e0030.0799 0.0671 4.8000e0046.0700e0036.0700e0036.0700e0036.0700e0030.0000 86.9830 86.9830 1.6700e0031.5900e00387.4999 Total 8.7900e0030.0799 0.0671 4.8000e0046.0700e0036.0700e0036.0700e0036.0700e0030.0000 86.9830 86.9830 1.6700e0031.5900e00387.4999 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
Enclosed Parking
with Elevator
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 Medical Office
Building

1.63e
+006

8.7900e0030.0799 0.0671 4.8000e0046.0700e0036.0700e0036.0700e0036.0700e0030.0000 86.9830 86.9830 1.6700e0031.5900e00387.4999 Total 8.7900e0030.0799 0.0671 4.8000e0046.0700e0036.0700e0036.0700e0036.0700e0030.0000 86.9830 86.9830 1.6700e0031.5900e00387.4999 Mitigated
CalEEMod Version: CalEEMod.2020.4.0 Page 23 of 30 Date: 5/9/2022 11:58 AM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

6.0 Area Detail

5.3 Energy by Land Use - Electricity
Electricity
Use
Total CO2 CH4 N2O CO2e
Land Use kWh/yr MT/yr
Enclosed Parking
with Elevator

1.04425e
+006
223.5590 0.0156 1.8900e003224.5144
Medical Office
Building
966000 206.8076 0.0145 1.7500e003207.6914
Total 430.3666 0.0301 3.6400e003432.2058
Unmitigated
Electricity
Use
Total CO2 CH4 N2O CO2e
Land Use kWh/yr MT/yr
Enclosed Parking
with Elevator

1.04425e
+006
223.5590 0.0156 1.8900e003224.5144
Medical Office
Building
966000 206.8076 0.0145 1.7500e003207.6914
Total 430.3666 0.0301 3.6400e003432.2058
Mitigated
CalEEMod Version: CalEEMod.2020.4.0 Page 24 of 30 Date: 5/9/2022 11:58 AM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

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 0.4521 1.0000e0059.3000e0040.0000 0.0000 0.0000 0.0000 0.0000 0.0000 1.8000e0031.8000e0030.0000 0.0000 1.9200e003 Unmitigated 0.4521 1.0000e0059.3000e0040.0000 0.0000 0.0000 0.0000 0.0000 0.0000 1.8000e0031.8000e0030.0000 0.0000 1.9200e003

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

0.0490 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Consumer
Products

0.4030 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Landscaping 9.0000e0051.0000e0059.3000e0040.0000 0.0000 0.0000 0.0000 0.0000 0.0000 1.8000e0031.8000e0030.0000 0.0000 1.9200e003 Total 0.4521 1.0000e0059.3000e0040.0000 0.0000 0.0000 0.0000 0.0000 0.0000 1.8000e0031.8000e0030.0000 0.0000 1.9200e003 Unmitigated
CalEEMod Version: CalEEMod.2020.4.0 Page 25 of 30 Date: 5/9/2022 11:58 AM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

7.1 Mitigation Measures Water

7.0 Water Detail

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

0.0490 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Consumer
Products

0.4030 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Landscaping 9.0000e0051.0000e0059.3000e0040.0000 0.0000 0.0000 0.0000 0.0000 0.0000 1.8000e0031.8000e0030.0000 0.0000 1.9200e003 Total 0.4521 1.0000e0059.3000e0040.0000 0.0000 0.0000 0.0000 0.0000 0.0000 1.8000e0031.8000e0030.0000 0.0000 1.9200e003 Mitigated
CalEEMod Version: CalEEMod.2020.4.0 Page 26 of 30 Date: 5/9/2022 11:58 AM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied Total CO2 CH4 N2O CO2e
Category MT/yr
Mitigated 20.3078 0.4100 9.7900e00333.4766
Unmitigated 20.3078 0.4100 9.7900e00333.4766

7.2 Water by Land Use
Indoor/Out
door Use
Total CO2 CH4 N2O CO2e
Land Use Mgal MT/yr
Enclosed Parking
with Elevator
0 / 0 0.0000 0.0000 0.0000 0.0000
Medical Office
Building

12.5481 /

2.39011

20.3078 0.4100 9.7900e00333.4766
Total 20.3078 0.4100 9.7900e00333.4766
Unmitigated
CalEEMod Version: CalEEMod.2020.4.0 Page 27 of 30 Date: 5/9/2022 11:58 AM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

7.2 Water by Land Use
Indoor/Out
door Use
Total CO2 CH4 N2O CO2e
Land Use Mgal MT/yr
Enclosed Parking
with Elevator
0 / 0 0.0000 0.0000 0.0000 0.0000
Medical Office
Building

12.5481 /

2.39011

20.3078 0.4100 9.7900e00333.4766
Total 20.3078 0.4100 9.7900e00333.4766
Mitigated

8.1 Mitigation Measures Waste

8.0 Waste Detail
Total CO2 CH4 N2O CO2e
MT/yr
Mitigated 219.2302 12.9561 0.0000 543.1336
Unmitigated 219.2302 12.9561 0.0000 543.1336
Category/Year
CalEEMod Version: CalEEMod.2020.4.0 Page 28 of 30 Date: 5/9/2022 11:58 AM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

8.2 Waste by Land Use
Waste
Disposed
Total CO2 CH4 N2O CO2e
Land Use tons MT/yr
Enclosed Parking
with Elevator
0 0.0000 0.0000 0.0000 0.0000
Medical Office
Building
1080 219.2302 12.9561 0.0000 543.1336
Total 219.2302 12.9561 0.0000 543.1336
Unmitigated
Waste
Disposed
Total CO2 CH4 N2O CO2e
Land Use tons MT/yr
Enclosed Parking
with Elevator
0 0.0000 0.0000 0.0000 0.0000
Medical Office
Building
1080 219.2302 12.9561 0.0000 543.1336
Total 219.2302 12.9561 0.0000 543.1336
Mitigated

9.0 Operational Offroad
CalEEMod Version: CalEEMod.2020.4.0 Page 29 of 30 Date: 5/9/2022 11:58 AM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

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
CalEEMod Version: CalEEMod.2020.4.0 Page 30 of 30 Date: 5/9/2022 11:58 AM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied Sutter Parking Garage Expansion & MOB 10
Placer-Sacramento County, Summer
Project Characteristics - Consistent with the IS/ND's model.

Land Use - See SWAPE comment on "Underestimated Land Use Size"

1.1 Land Usage
Land Uses Size Metric Lot Acreage Floor Surface Area Population Medical Office Building 100.00 1000sqft 1.64 100,000.00 0 Enclosed Parking with Elevator 1.00 1000sqft 0.94 191,957.00 0

1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
2 Wind Speed (m/s) 2.2 Precipitation Freq (Days) 74

1.3 User Entered Comments & Non-Default Data

1.0 Project Characteristics

2.0 Emissions Summary
Utility Company Roseville Electric
Operational Year 2024
CO2 Intensity
(lb/MWhr)
471.98 CH4 Intensity 0.033
(lb/MWhr)
N2O Intensity 0.004
(lb/MWhr)
Table Name Column Name Default Value New Value
tblLandUse LandUseSquareFeet 1,000.00 191,957.00
tblLandUse LotAcreage 2.30 1.64
tblLandUse LotAcreage 0.02 0.94
CalEEMod Version: CalEEMod.2020.4.0 Page 1 of 26 Date: 5/9/2022 12:04 PM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

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
2022 2.3035 17.2564 18.2093 0.0435 7.1647 0.8384 7.9074 3.4465 0.7834 4.1298 0.0000 4,213.123 9 4,213.123
9 0.7698 0.1818 4,279.032
2 2023 98.2973 15.9070 17.7852 0.0429 1.2535 0.6314 1.8849 0.3399 0.6049 0.9447 0.0000 4,154.700 7 4,154.700
7 0.5447 0.1748 4,218.208
8 Maximum 98.2973 17.2564 18.2093 0.0435 7.1647 0.8384 7.9074 3.4465 0.7834 4.1298 0.0000 4,213.123 9 4,213.123
9 0.7698 0.1818 4,279.032
2 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
2022 2.3035 17.2564 18.2093 0.0435 7.1647 0.8384 7.9074 3.4465 0.7834 4.1298 0.0000 4,213.123 9 4,213.123
9 0.7698 0.1818 4,279.032
2 2023 98.2973 15.9070 17.7852 0.0429 1.2535 0.6314 1.8849 0.3399 0.6049 0.9447 0.0000 4,154.700 7 4,154.700
7 0.5447 0.1748 4,218.208
8 Maximum 98.2973 17.2564 18.2093 0.0435 7.1647 0.8384 7.9074 3.4465 0.7834 4.1298 0.0000 4,213.123 9 4,213.123
9 0.7698 0.1818 4,279.032
2 Mitigated Construction
CalEEMod Version: CalEEMod.2020.4.0 Page 2 of 26 Date: 5/9/2022 12:04 PM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 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 3 of 26 Date: 5/9/2022 12:04 PM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

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 2.4775 9.0000e0050.0103 0.0000 4.0000e0054.0000e0054.0000e0054.0000e0050.0221 0.0221 6.0000e0050.0236 Energy 0.0482 0.4378 0.3678 2.6300e0030.0333 0.0333 0.0333 0.0333 525.3828 525.3828 0.0101 9.6300e003528.5048 Mobile 10.6656 10.7165 75.3683 0.1484 14.3949 0.1280 14.5229 3.8422 0.1201 3.9623 15,337.54 69 15,337.54
69 0.9500 0.7871 15,595.84
54 Total 13.1913 11.1544 75.7464 0.1510 14.3949 0.1613 14.5562 3.8422 0.1534 3.9956 15,862.95 18 15,862.95
18 0.9601 0.7967 16,124.37
38 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 2.4775 9.0000e0050.0103 0.0000 4.0000e0054.0000e0054.0000e0054.0000e0050.0221 0.0221 6.0000e0050.0236 Energy 0.0482 0.4378 0.3678 2.6300e0030.0333 0.0333 0.0333 0.0333 525.3828 525.3828 0.0101 9.6300e003528.5048 Mobile 10.6656 10.7165 75.3683 0.1484 14.3949 0.1280 14.5229 3.8422 0.1201 3.9623 15,337.54 69 15,337.54
69 0.9500 0.7871 15,595.84
54 Total 13.1913 11.1544 75.7464 0.1510 14.3949 0.1613 14.5562 3.8422 0.1534 3.9956 15,862.95 18 15,862.95
18 0.9601 0.7967 16,124.37
38 Mitigated Operational
CalEEMod Version: CalEEMod.2020.4.0 Page 4 of 26 Date: 5/9/2022 12:04 PM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

3.0 Construction Detail
Construction Phase
Phase
Number
Phase Name Phase Type Start Date End Date Num Days
Week
Num Days Phase Description
1 Demolition Demolition 3/23/2022 4/19/2022 5 20
2 Site Preparation Site Preparation 4/20/2022 4/22/2022 5 3 3 Grading Grading 4/23/2022 5/2/2022 5 6
4 Building Construction Building Construction 5/3/2022 3/6/2023 5 220 5 Paving Paving 3/7/2023 3/20/2023 5 10
6 Architectural Coating Architectural Coating 3/21/2023 4/3/2023 5 10 OffRoad Equipment
Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor Architectural Coating Air Compressors 1 6.00 78 0.48
Paving Cement and Mortar Mixers 1 8.00 9 0.56
Demolition Concrete/Industrial Saws 1 8.00 81 0.73
Building Construction Cranes 1 8.00 231 0.29
Building Construction Forklifts 2 7.00 89 0.20
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: 150,000; Non-Residential Outdoor: 50,000; Striped Parking Area: 11,517 (Architectural Coating – sqft)
Acres of Grading (Site Preparation Phase): 4.5
Acres of Grading (Grading Phase): 6
Acres of Paving: 0.94
CalEEMod Version: CalEEMod.2020.4.0 Page 5 of 26 Date: 5/9/2022 12:04 PM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

3.1 Mitigation Measures Construction
Building Construction Generator Sets 1 8.00 84 0.74
Grading Graders 1 8.00 187 0.41
Site Preparation Graders 1 8.00 187 0.41
Paving Pavers 1 8.00 130 0.42
Paving Paving Equipment 1 8.00 132 0.36
Paving Rollers 2 8.00 80 0.38
Demolition Rubber Tired Dozers 1 8.00 247 0.40
Grading Rubber Tired Dozers 1 8.00 247 0.40
Site Preparation Scrapers 1 8.00 367 0.48
Building Construction Tractors/Loaders/Backhoes 1 6.00 97 0.37 Demolition Tractors/Loaders/Backhoes 3 8.00 97 0.37
Grading Tractors/Loaders/Backhoes 2 7.00 97 0.37
Paving Tractors/Loaders/Backhoes 1 8.00 97 0.37
Site Preparation Tractors/Loaders/Backhoes 1 7.00 97 0.37 Building Construction Welders 3 8.00 46 0.45
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
Demolition 5 13.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT Site Preparation 3 8.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT Grading 4 10.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT Building Construction 8 113.00 48.00 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 23.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT CalEEMod Version: CalEEMod.2020.4.0 Page 6 of 26 Date: 5/9/2022 12:04 PM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

3.2 Demolition - 2022
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 1.6889 16.6217 13.9605 0.0241 0.8379 0.8379 0.7829 0.7829 2,323.416 8 2,323.416
8 0.5921 2,338.219
1 Total 1.6889 16.6217 13.9605 0.0241 0.8379 0.8379 0.7829 0.7829 2,323.416 8 2,323.416
8 0.5921 2,338.219
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 0.0000 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 0.0411 0.0224 0.3567 9.7000e0040.1068 5.4000e0040.1073 0.0283 5.0000e0040.0288 99.0622 99.0622 2.6400e0032.4300e00399.8520 Total 0.0411 0.0224 0.3567 9.7000e0040.1068 5.4000e0040.1073 0.0283 5.0000e0040.0288 99.0622 99.0622 2.6400e0032.4300e00399.8520 Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 7 of 26 Date: 5/9/2022 12:04 PM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

3.2 Demolition - 2022
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 1.6889 16.6217 13.9605 0.0241 0.8379 0.8379 0.7829 0.7829 0.0000 2,323.416 8 2,323.416
8 0.5921 2,338.219
1 Total 1.6889 16.6217 13.9605 0.0241 0.8379 0.8379 0.7829 0.7829 0.0000 2,323.416 8 2,323.416
8 0.5921 2,338.219
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 0.0000 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 0.0411 0.0224 0.3567 9.7000e0040.1068 5.4000e0040.1073 0.0283 5.0000e0040.0288 99.0622 99.0622 2.6400e0032.4300e00399.8520 Total 0.0411 0.0224 0.3567 9.7000e0040.1068 5.4000e0040.1073 0.0283 5.0000e0040.0288 99.0622 99.0622 2.6400e0032.4300e00399.8520 Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 8 of 26 Date: 5/9/2022 12:04 PM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

3.3 Site Preparation - 2022
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 1.5908 0.0000 1.5908 0.1718 0.0000 0.1718 0.0000 0.0000 Off-Road 1.3784 15.6673 10.0558 0.0245 0.5952 0.5952 0.5476 0.5476 2,375.156 9 2,375.156
9 0.7682 2,394.361
3 Total 1.3784 15.6673 10.0558 0.0245 1.5908 0.5952 2.1859 0.1718 0.5476 0.7193 2,375.156 9 2,375.156
9 0.7682 2,394.361
3 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 0.0253 0.0138 0.2195 6.0000e0040.0657 3.3000e0040.0661 0.0174 3.1000e0040.0177 60.9614 60.9614 1.6200e0031.4900e00361.4474 Total 0.0253 0.0138 0.2195 6.0000e0040.0657 3.3000e0040.0661 0.0174 3.1000e0040.0177 60.9614 60.9614 1.6200e0031.4900e00361.4474 Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 9 of 26 Date: 5/9/2022 12:04 PM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

3.3 Site Preparation - 2022
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 1.5908 0.0000 1.5908 0.1718 0.0000 0.1718 0.0000 0.0000 Off-Road 1.3784 15.6673 10.0558 0.0245 0.5952 0.5952 0.5476 0.5476 0.0000 2,375.156 9 2,375.156
9 0.7682 2,394.361
3 Total 1.3784 15.6673 10.0558 0.0245 1.5908 0.5952 2.1859 0.1718 0.5476 0.7193 0.0000 2,375.156 9 2,375.156
9 0.7682 2,394.361
3 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 0.0253 0.0138 0.2195 6.0000e0040.0657 3.3000e0040.0661 0.0174 3.1000e0040.0177 60.9614 60.9614 1.6200e0031.4900e00361.4474 Total 0.0253 0.0138 0.2195 6.0000e0040.0657 3.3000e0040.0661 0.0174 3.1000e0040.0177 60.9614 60.9614 1.6200e0031.4900e00361.4474 Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 10 of 26 Date: 5/9/2022 12:04 PM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

3.4 Grading - 2022
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 7.0826 0.0000 7.0826 3.4247 0.0000 3.4247 0.0000 0.0000 Off-Road 1.5403 16.9836 9.2202 0.0206 0.7423 0.7423 0.6829 0.6829 1,995.482 5 1,995.482
5 0.6454 2,011.616
9 Total 1.5403 16.9836 9.2202 0.0206 7.0826 0.7423 7.8249 3.4247 0.6829 4.1076 1,995.482 5 1,995.482
5 0.6454 2,011.616
9 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 0.0316 0.0173 0.2744 7.5000e0040.0822 4.2000e0040.0826 0.0218 3.8000e0040.0222 76.2017 76.2017 2.0300e0031.8700e00376.8092 Total 0.0316 0.0173 0.2744 7.5000e0040.0822 4.2000e0040.0826 0.0218 3.8000e0040.0222 76.2017 76.2017 2.0300e0031.8700e00376.8092 Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 11 of 26 Date: 5/9/2022 12:04 PM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

3.4 Grading - 2022
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 7.0826 0.0000 7.0826 3.4247 0.0000 3.4247 0.0000 0.0000 Off-Road 1.5403 16.9836 9.2202 0.0206 0.7423 0.7423 0.6829 0.6829 0.0000 1,995.482 5 1,995.482
5 0.6454 2,011.616
9 Total 1.5403 16.9836 9.2202 0.0206 7.0826 0.7423 7.8249 3.4247 0.6829 4.1076 0.0000 1,995.482 5 1,995.482
5 0.6454 2,011.616
9 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 0.0316 0.0173 0.2744 7.5000e0040.0822 4.2000e0040.0826 0.0218 3.8000e0040.0222 76.2017 76.2017 2.0300e0031.8700e00376.8092 Total 0.0316 0.0173 0.2744 7.5000e0040.0822 4.2000e0040.0826 0.0218 3.8000e0040.0222 76.2017 76.2017 2.0300e0031.8700e00376.8092 Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 12 of 26 Date: 5/9/2022 12:04 PM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

3.5 Building Construction - 2022
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 1.8555 14.6040 14.3533 0.0250 0.7022 0.7022 0.6731 0.6731 2,289.281 3 2,289.281
3 0.4417 2,300.323
0 Total 1.8555 14.6040 14.3533 0.0250 0.7022 0.7022 0.6731 0.6731 2,289.281 3 2,289.281
3 0.4417 2,300.323
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 0.0912 2.4574 0.7559 0.0101 0.3253 0.0236 0.3489 0.0937 0.0226 0.1162 1,062.763 4 1,062.763
4 4.6300e0030.1607 1,110.765
1 Worker 0.3568 0.1950 3.1002 8.4600e0030.9283 4.6900e0030.9330 0.2462 4.3200e0030.2505 861.0793 861.0793 0.0229 0.0211 867.9441 Total 0.4480 2.6524 3.8560 0.0185 1.2535 0.0283 1.2818 0.3399 0.0269 0.3668 1,923.842 6 1,923.842
6 0.0276 0.1818 1,978.709
2 Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 13 of 26 Date: 5/9/2022 12:04 PM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

3.5 Building Construction - 2022
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 1.8555 14.6040 14.3533 0.0250 0.7022 0.7022 0.6731 0.6731 0.0000 2,289.281 3 2,289.281
3 0.4417 2,300.323
0 Total 1.8555 14.6040 14.3533 0.0250 0.7022 0.7022 0.6731 0.6731 0.0000 2,289.281 3 2,289.281
3 0.4417 2,300.323
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 0.0912 2.4574 0.7559 0.0101 0.3253 0.0236 0.3489 0.0937 0.0226 0.1162 1,062.763 4 1,062.763
4 4.6300e0030.1607 1,110.765
1 Worker 0.3568 0.1950 3.1002 8.4600e0030.9283 4.6900e0030.9330 0.2462 4.3200e0030.2505 861.0793 861.0793 0.0229 0.0211 867.9441 Total 0.4480 2.6524 3.8560 0.0185 1.2535 0.0283 1.2818 0.3399 0.0269 0.3668 1,923.842 6 1,923.842
6 0.0276 0.1818 1,978.709
2 Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 14 of 26 Date: 5/9/2022 12:04 PM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

3.5 Building Construction - 2023
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 1.7136 13.6239 14.2145 0.0250 0.6136 0.6136 0.5880 0.5880 2,289.523 3 2,289.523
3 0.4330 2,300.347
9 Total 1.7136 13.6239 14.2145 0.0250 0.6136 0.6136 0.5880 0.5880 2,289.523 3 2,289.523
3 0.4330 2,300.347
9 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 0.0571 2.1098 0.6915 9.7200e0030.3253 0.0133 0.3386 0.0937 0.0127 0.1064 1,026.589 4 1,026.589
4 3.0100e0030.1552 1,072.899
7 Worker 0.3316 0.1733 2.8792 8.1900e0030.9283 4.4500e0030.9327 0.2462 4.1000e0030.2503 838.5880 838.5880 0.0208 0.0197 844.9612 Total 0.3887 2.2830 3.5707 0.0179 1.2535 0.0178 1.2713 0.3399 0.0168 0.3567 1,865.177 4 1,865.177
4 0.0238 0.1748 1,917.860
9 Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 15 of 26 Date: 5/9/2022 12:04 PM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

3.5 Building Construction - 2023
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 1.7136 13.6239 14.2145 0.0250 0.6136 0.6136 0.5880 0.5880 0.0000 2,289.523 3 2,289.523
3 0.4330 2,300.347
9 Total 1.7136 13.6239 14.2145 0.0250 0.6136 0.6136 0.5880 0.5880 0.0000 2,289.523 3 2,289.523
3 0.4330 2,300.347
9 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 0.0571 2.1098 0.6915 9.7200e0030.3253 0.0133 0.3386 0.0937 0.0127 0.1064 1,026.589 4 1,026.589
4 3.0100e0030.1552 1,072.899
7 Worker 0.3316 0.1733 2.8792 8.1900e0030.9283 4.4500e0030.9327 0.2462 4.1000e0030.2503 838.5880 838.5880 0.0208 0.0197 844.9612 Total 0.3887 2.2830 3.5707 0.0179 1.2535 0.0178 1.2713 0.3399 0.0168 0.3567 1,865.177 4 1,865.177
4 0.0238 0.1748 1,917.860
9 Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 16 of 26 Date: 5/9/2022 12:04 PM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

3.6 Paving - 2023
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 0.8802 8.6098 11.6840 0.0179 0.4338 0.4338 0.4003 0.4003 1,709.992 6 1,709.992
6 0.5420 1,723.541
4 Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.8802 8.6098 11.6840 0.0179 0.4338 0.4338 0.4003 0.4003 1,709.992 6 1,709.992
6 0.5420 1,723.541
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 0.0440 0.0230 0.3822 1.0900e0030.1232 5.9000e0040.1238 0.0327 5.4000e0040.0332 111.3170 111.3170 2.7500e0032.6100e003112.1630 Total 0.0440 0.0230 0.3822 1.0900e0030.1232 5.9000e0040.1238 0.0327 5.4000e0040.0332 111.3170 111.3170 2.7500e0032.6100e003112.1630 Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 17 of 26 Date: 5/9/2022 12:04 PM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

3.6 Paving - 2023
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 0.8802 8.6098 11.6840 0.0179 0.4338 0.4338 0.4003 0.4003 0.0000 1,709.992 6 1,709.992
6 0.5420 1,723.541
4 Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.8802 8.6098 11.6840 0.0179 0.4338 0.4338 0.4003 0.4003 0.0000 1,709.992 6 1,709.992
6 0.5420 1,723.541
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 0.0440 0.0230 0.3822 1.0900e0030.1232 5.9000e0040.1238 0.0327 5.4000e0040.0332 111.3170 111.3170 2.7500e0032.6100e003112.1630 Total 0.0440 0.0230 0.3822 1.0900e0030.1232 5.9000e0040.1238 0.0327 5.4000e0040.0332 111.3170 111.3170 2.7500e0032.6100e003112.1630 Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 18 of 26 Date: 5/9/2022 12:04 PM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

3.7 Architectural Coating - 2023
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 98.0381 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.1917 1.3030 1.8111 2.9700e0030.0708 0.0708 0.0708 0.0708 281.4481 281.4481 0.0168 281.8690 Total 98.2298 1.3030 1.8111 2.9700e0030.0708 0.0708 0.0708 0.0708 281.4481 281.4481 0.0168 281.8690 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 0.0675 0.0353 0.5860 1.6700e0030.1889 9.1000e0040.1899 0.0501 8.3000e0040.0510 170.6861 170.6861 4.2200e0034.0000e003171.9833 Total 0.0675 0.0353 0.5860 1.6700e0030.1889 9.1000e0040.1899 0.0501 8.3000e0040.0510 170.6861 170.6861 4.2200e0034.0000e003171.9833 Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 19 of 26 Date: 5/9/2022 12:04 PM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

3.7 Architectural Coating - 2023
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 98.0381 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.1917 1.3030 1.8111 2.9700e0030.0708 0.0708 0.0708 0.0708 0.0000 281.4481 281.4481 0.0168 281.8690 Total 98.2298 1.3030 1.8111 2.9700e0030.0708 0.0708 0.0708 0.0708 0.0000 281.4481 281.4481 0.0168 281.8690 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 0.0675 0.0353 0.5860 1.6700e0030.1889 9.1000e0040.1899 0.0501 8.3000e0040.0510 170.6861 170.6861 4.2200e0034.0000e003171.9833 Total 0.0675 0.0353 0.5860 1.6700e0030.1889 9.1000e0040.1899 0.0501 8.3000e0040.0510 170.6861 170.6861 4.2200e0034.0000e003171.9833 Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 20 of 26 Date: 5/9/2022 12:04 PM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

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 10.6656 10.7165 75.3683 0.1484 14.3949 0.1280 14.5229 3.8422 0.1201 3.9623 15,337.54 69 15,337.54
69 0.9500 0.7871 15,595.84
54 Unmitigated 10.6656 10.7165 75.3683 0.1484 14.3949 0.1280 14.5229 3.8422 0.1201 3.9623 15,337.54 69 15,337.54
69 0.9500 0.7871 15,595.84
54 4.1 Mitigation Measures Mobile

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
Enclosed Parking with Elevator 0.00 0.00 0.00
Medical Office Building 3,480.00 857.00 142.00 5,144,491 5,144,491 Total 3,480.00 857.00 142.00 5,144,491 5,144,491
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 Enclosed Parking with Elevator 9.50 7.30 7.30 0.00 0.00 0.00 0 0 0 Medical Office Building 9.50 7.30 7.30 29.60 51.40 19.00 60 30 10

4.4 Fleet Mix
CalEEMod Version: CalEEMod.2020.4.0 Page 21 of 26 Date: 5/9/2022 12:04 PM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied Land Use LDA LDT1 LDT2 MDV LHD1 LHD2 MHD HHD OBUS UBUS MCY SBUS MH Enclosed Parking with Elevator 0.466187 0.061512 0.210180 0.153350 0.034639 0.008391 0.014417 0.011935 0.000556 0.000412 0.031993 0.000977 0.005450 Medical Office Building 0.466187 0.061512 0.210180 0.153350 0.034639 0.008391 0.014417 0.011935 0.000556 0.000412 0.031993 0.000977 0.005450

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

0.0482 0.4378 0.3678 2.6300e0030.0333 0.0333 0.0333 0.0333 525.3828 525.3828 0.0101 9.6300e003528.5048 NaturalGas
Unmitigated

0.0482 0.4378 0.3678 2.6300e0030.0333 0.0333 0.0333 0.0333 525.3828 525.3828 0.0101 9.6300e003528.5048

5.1 Mitigation Measures Energy
Historical Energy Use: N
CalEEMod Version: CalEEMod.2020.4.0 Page 22 of 26 Date: 5/9/2022 12:04 PM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

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
Enclosed Parking
with Elevator
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 Medical Office
Building
4465.75 0.0482 0.4378 0.3678 2.6300e0030.0333 0.0333 0.0333 0.0333 525.3828 525.3828 0.0101 9.6300e003528.5048 Total 0.0482 0.4378 0.3678 2.6300e0030.0333 0.0333 0.0333 0.0333 525.3828 525.3828 0.0101 9.6300e003528.5048 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
Enclosed Parking
with Elevator
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 Medical Office
Building

4.46575 0.0482 0.4378 0.3678 2.6300e0030.0333 0.0333 0.0333 0.0333 525.3828 525.3828 0.0101 9.6300e003528.5048 Total 0.0482 0.4378 0.3678 2.6300e0030.0333 0.0333 0.0333 0.0333 525.3828 525.3828 0.0101 9.6300e003528.5048 Mitigated
CalEEMod Version: CalEEMod.2020.4.0 Page 23 of 26 Date: 5/9/2022 12:04 PM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

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 2.4775 9.0000e0050.0103 0.0000 4.0000e0054.0000e0054.0000e0054.0000e0050.0221 0.0221 6.0000e0050.0236 Unmitigated 2.4775 9.0000e0050.0103 0.0000 4.0000e0054.0000e0054.0000e0054.0000e0050.0221 0.0221 6.0000e0050.0236

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

0.2686 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products

2.2080 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Landscaping 9.5000e0049.0000e0050.0103 0.0000 4.0000e0054.0000e0054.0000e0054.0000e0050.0221 0.0221 6.0000e0050.0236 Total 2.4775 9.0000e0050.0103 0.0000 4.0000e0054.0000e0054.0000e0054.0000e0050.0221 0.0221 6.0000e0050.0236 Unmitigated
CalEEMod Version: CalEEMod.2020.4.0 Page 24 of 26 Date: 5/9/2022 12:04 PM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

7.1 Mitigation Measures Water

7.0 Water Detail

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

0.2686 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products

2.2080 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Landscaping 9.5000e0049.0000e0050.0103 0.0000 4.0000e0054.0000e0054.0000e0054.0000e0050.0221 0.0221 6.0000e0050.0236 Total 2.4775 9.0000e0050.0103 0.0000 4.0000e0054.0000e0054.0000e0054.0000e0050.0221 0.0221 6.0000e0050.0236 Mitigated
CalEEMod Version: CalEEMod.2020.4.0 Page 25 of 26 Date: 5/9/2022 12:04 PM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

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
CalEEMod Version: CalEEMod.2020.4.0 Page 26 of 26 Date: 5/9/2022 12:04 PM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied Sutter Parking Garage Expansion & MOB 10
Placer-Sacramento County, Winter
Project Characteristics - Consistent with the IS/ND's model.

Land Use - See SWAPE comment on "Underestimated Land Use Size"

1.1 Land Usage
Land Uses Size Metric Lot Acreage Floor Surface Area Population Medical Office Building 100.00 1000sqft 1.64 100,000.00 0 Enclosed Parking with Elevator 1.00 1000sqft 0.94 191,957.00 0

1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
2 Wind Speed (m/s) 2.2 Precipitation Freq (Days) 74

1.3 User Entered Comments & Non-Default Data

1.0 Project Characteristics

2.0 Emissions Summary
Utility Company Roseville Electric
Operational Year 2024
CO2 Intensity
(lb/MWhr)
471.98 CH4 Intensity 0.033
(lb/MWhr)
N2O Intensity 0.004
(lb/MWhr)
Table Name Column Name Default Value New Value
tblLandUse LandUseSquareFeet 1,000.00 191,957.00
tblLandUse LotAcreage 2.30 1.64
tblLandUse LotAcreage 0.02 0.94
CalEEMod Version: CalEEMod.2020.4.0 Page 1 of 26 Date: 5/9/2022 11:43 AM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

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
2022 2.2748 17.4815 17.9573 0.0427 7.1647 0.8384 7.9074 3.4465 0.7834 4.1298 0.0000 4,129.128 9 4,129.128
9 0.7701 0.1855 4,196.224
3 2023 98.2926 16.1083 17.5568 0.0422 1.2535 0.6314 1.8850 0.3399 0.6049 0.9448 0.0000 4,074.159 1 4,074.159
1 0.5452 0.1784 4,138.816
1 Maximum 98.2926 17.4815 17.9573 0.0427 7.1647 0.8384 7.9074 3.4465 0.7834 4.1298 0.0000 4,129.128 9 4,129.128
9 0.7701 0.1855 4,196.224
3 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
2022 2.2748 17.4815 17.9573 0.0427 7.1647 0.8384 7.9074 3.4465 0.7834 4.1298 0.0000 4,129.128 9 4,129.128
9 0.7701 0.1855 4,196.224
3 2023 98.2926 16.1083 17.5568 0.0422 1.2535 0.6314 1.8850 0.3399 0.6049 0.9448 0.0000 4,074.159 1 4,074.159
1 0.5452 0.1784 4,138.816
1 Maximum 98.2926 17.4815 17.9573 0.0427 7.1647 0.8384 7.9074 3.4465 0.7834 4.1298 0.0000 4,129.128 9 4,129.128
9 0.7701 0.1855 4,196.224
3 Mitigated Construction
CalEEMod Version: CalEEMod.2020.4.0 Page 2 of 26 Date: 5/9/2022 11:43 AM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 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 3 of 26 Date: 5/9/2022 11:43 AM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

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 2.4775 9.0000e0050.0103 0.0000 4.0000e0054.0000e0054.0000e0054.0000e0050.0221 0.0221 6.0000e0050.0236 Energy 0.0482 0.4378 0.3678 2.6300e0030.0333 0.0333 0.0333 0.0333 525.3828 525.3828 0.0101 9.6300e003528.5048 Mobile 8.6062 12.3269 80.7797 0.1380 14.3949 0.1281 14.5230 3.8422 0.1202 3.9624 14,268.42 04 14,268.42
04 1.1285 0.8600 14,552.89
74 Total 11.1319 12.7648 81.1578 0.1407 14.3949 0.1614 14.5563 3.8422 0.1535 3.9957 14,793.82 53 14,793.82
53 1.1386 0.8696 15,081.42
58 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 2.4775 9.0000e0050.0103 0.0000 4.0000e0054.0000e0054.0000e0054.0000e0050.0221 0.0221 6.0000e0050.0236 Energy 0.0482 0.4378 0.3678 2.6300e0030.0333 0.0333 0.0333 0.0333 525.3828 525.3828 0.0101 9.6300e003528.5048 Mobile 8.6062 12.3269 80.7797 0.1380 14.3949 0.1281 14.5230 3.8422 0.1202 3.9624 14,268.42 04 14,268.42
04 1.1285 0.8600 14,552.89
74 Total 11.1319 12.7648 81.1578 0.1407 14.3949 0.1614 14.5563 3.8422 0.1535 3.9957 14,793.82 53 14,793.82
53 1.1386 0.8696 15,081.42
58 Mitigated Operational
CalEEMod Version: CalEEMod.2020.4.0 Page 4 of 26 Date: 5/9/2022 11:43 AM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

3.0 Construction Detail
Construction Phase
Phase
Number
Phase Name Phase Type Start Date End Date Num Days
Week
Num Days Phase Description
1 Demolition Demolition 3/23/2022 4/19/2022 5 20
2 Site Preparation Site Preparation 4/20/2022 4/22/2022 5 3 3 Grading Grading 4/23/2022 5/2/2022 5 6
4 Building Construction Building Construction 5/3/2022 3/6/2023 5 220 5 Paving Paving 3/7/2023 3/20/2023 5 10
6 Architectural Coating Architectural Coating 3/21/2023 4/3/2023 5 10 OffRoad Equipment
Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor Architectural Coating Air Compressors 1 6.00 78 0.48
Paving Cement and Mortar Mixers 1 8.00 9 0.56
Demolition Concrete/Industrial Saws 1 8.00 81 0.73
Building Construction Cranes 1 8.00 231 0.29
Building Construction Forklifts 2 7.00 89 0.20
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: 150,000; Non-Residential Outdoor: 50,000; Striped Parking Area: 11,517 (Architectural Coating – sqft)
Acres of Grading (Site Preparation Phase): 4.5
Acres of Grading (Grading Phase): 6
Acres of Paving: 0.94
CalEEMod Version: CalEEMod.2020.4.0 Page 5 of 26 Date: 5/9/2022 11:43 AM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

3.1 Mitigation Measures Construction
Building Construction Generator Sets 1 8.00 84 0.74
Grading Graders 1 8.00 187 0.41
Site Preparation Graders 1 8.00 187 0.41
Paving Pavers 1 8.00 130 0.42
Paving Paving Equipment 1 8.00 132 0.36
Paving Rollers 2 8.00 80 0.38
Demolition Rubber Tired Dozers 1 8.00 247 0.40
Grading Rubber Tired Dozers 1 8.00 247 0.40
Site Preparation Scrapers 1 8.00 367 0.48
Building Construction Tractors/Loaders/Backhoes 1 6.00 97 0.37 Demolition Tractors/Loaders/Backhoes 3 8.00 97 0.37
Grading Tractors/Loaders/Backhoes 2 7.00 97 0.37
Paving Tractors/Loaders/Backhoes 1 8.00 97 0.37
Site Preparation Tractors/Loaders/Backhoes 1 7.00 97 0.37 Building Construction Welders 3 8.00 46 0.45
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
Demolition 5 13.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT Site Preparation 3 8.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT Grading 4 10.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT Building Construction 8 113.00 48.00 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 23.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT CalEEMod Version: CalEEMod.2020.4.0 Page 6 of 26 Date: 5/9/2022 11:43 AM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

3.2 Demolition - 2022
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 1.6889 16.6217 13.9605 0.0241 0.8379 0.8379 0.7829 0.7829 2,323.416 8 2,323.416
8 0.5921 2,338.219
1 Total 1.6889 16.6217 13.9605 0.0241 0.8379 0.8379 0.7829 0.7829 2,323.416 8 2,323.416
8 0.5921 2,338.219
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 0.0000 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 0.0381 0.0280 0.3242 8.8000e0040.1068 5.4000e0040.1073 0.0283 5.0000e0040.0288 89.2573 89.2573 3.0900e0032.8100e00390.1730 Total 0.0381 0.0280 0.3242 8.8000e0040.1068 5.4000e0040.1073 0.0283 5.0000e0040.0288 89.2573 89.2573 3.0900e0032.8100e00390.1730 Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 7 of 26 Date: 5/9/2022 11:43 AM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

3.2 Demolition - 2022
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 1.6889 16.6217 13.9605 0.0241 0.8379 0.8379 0.7829 0.7829 0.0000 2,323.416 8 2,323.416
8 0.5921 2,338.219
1 Total 1.6889 16.6217 13.9605 0.0241 0.8379 0.8379 0.7829 0.7829 0.0000 2,323.416 8 2,323.416
8 0.5921 2,338.219
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 0.0000 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 0.0381 0.0280 0.3242 8.8000e0040.1068 5.4000e0040.1073 0.0283 5.0000e0040.0288 89.2573 89.2573 3.0900e0032.8100e00390.1730 Total 0.0381 0.0280 0.3242 8.8000e0040.1068 5.4000e0040.1073 0.0283 5.0000e0040.0288 89.2573 89.2573 3.0900e0032.8100e00390.1730 Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 8 of 26 Date: 5/9/2022 11:43 AM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

3.3 Site Preparation - 2022
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 1.5908 0.0000 1.5908 0.1718 0.0000 0.1718 0.0000 0.0000 Off-Road 1.3784 15.6673 10.0558 0.0245 0.5952 0.5952 0.5476 0.5476 2,375.156 9 2,375.156
9 0.7682 2,394.361
3 Total 1.3784 15.6673 10.0558 0.0245 1.5908 0.5952 2.1859 0.1718 0.5476 0.7193 2,375.156 9 2,375.156
9 0.7682 2,394.361
3 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 0.0235 0.0172 0.1995 5.4000e0040.0657 3.3000e0040.0661 0.0174 3.1000e0040.0177 54.9275 54.9275 1.9000e0031.7300e00355.4911 Total 0.0235 0.0172 0.1995 5.4000e0040.0657 3.3000e0040.0661 0.0174 3.1000e0040.0177 54.9275 54.9275 1.9000e0031.7300e00355.4911 Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 9 of 26 Date: 5/9/2022 11:43 AM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

3.3 Site Preparation - 2022
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 1.5908 0.0000 1.5908 0.1718 0.0000 0.1718 0.0000 0.0000 Off-Road 1.3784 15.6673 10.0558 0.0245 0.5952 0.5952 0.5476 0.5476 0.0000 2,375.156 9 2,375.156
9 0.7682 2,394.361
3 Total 1.3784 15.6673 10.0558 0.0245 1.5908 0.5952 2.1859 0.1718 0.5476 0.7193 0.0000 2,375.156 9 2,375.156
9 0.7682 2,394.361
3 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 0.0235 0.0172 0.1995 5.4000e0040.0657 3.3000e0040.0661 0.0174 3.1000e0040.0177 54.9275 54.9275 1.9000e0031.7300e00355.4911 Total 0.0235 0.0172 0.1995 5.4000e0040.0657 3.3000e0040.0661 0.0174 3.1000e0040.0177 54.9275 54.9275 1.9000e0031.7300e00355.4911 Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 10 of 26 Date: 5/9/2022 11:43 AM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

3.4 Grading - 2022
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 7.0826 0.0000 7.0826 3.4247 0.0000 3.4247 0.0000 0.0000 Off-Road 1.5403 16.9836 9.2202 0.0206 0.7423 0.7423 0.6829 0.6829 1,995.482 5 1,995.482
5 0.6454 2,011.616
9 Total 1.5403 16.9836 9.2202 0.0206 7.0826 0.7423 7.8249 3.4247 0.6829 4.1076 1,995.482 5 1,995.482
5 0.6454 2,011.616
9 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 0.0293 0.0215 0.2494 6.7000e0040.0822 4.2000e0040.0826 0.0218 3.8000e0040.0222 68.6594 68.6594 2.3800e0032.1600e00369.3639 Total 0.0293 0.0215 0.2494 6.7000e0040.0822 4.2000e0040.0826 0.0218 3.8000e0040.0222 68.6594 68.6594 2.3800e0032.1600e00369.3639 Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 11 of 26 Date: 5/9/2022 11:43 AM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

3.4 Grading - 2022
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 7.0826 0.0000 7.0826 3.4247 0.0000 3.4247 0.0000 0.0000 Off-Road 1.5403 16.9836 9.2202 0.0206 0.7423 0.7423 0.6829 0.6829 0.0000 1,995.482 5 1,995.482
5 0.6454 2,011.616
9 Total 1.5403 16.9836 9.2202 0.0206 7.0826 0.7423 7.8249 3.4247 0.6829 4.1076 0.0000 1,995.482 5 1,995.482
5 0.6454 2,011.616
9 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 0.0293 0.0215 0.2494 6.7000e0040.0822 4.2000e0040.0826 0.0218 3.8000e0040.0222 68.6594 68.6594 2.3800e0032.1600e00369.3639 Total 0.0293 0.0215 0.2494 6.7000e0040.0822 4.2000e0040.0826 0.0218 3.8000e0040.0222 68.6594 68.6594 2.3800e0032.1600e00369.3639 Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 12 of 26 Date: 5/9/2022 11:43 AM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

3.5 Building Construction - 2022
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 1.8555 14.6040 14.3533 0.0250 0.7022 0.7022 0.6731 0.6731 2,289.281 3 2,289.281
3 0.4417 2,300.323
0 Total 1.8555 14.6040 14.3533 0.0250 0.7022 0.7022 0.6731 0.6731 2,289.281 3 2,289.281
3 0.4417 2,300.323
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 0.0878 2.6341 0.7860 0.0101 0.3253 0.0237 0.3490 0.0937 0.0227 0.1163 1,063.996 1 1,063.996
1 4.4800e0030.1610 1,112.089
9 Worker 0.3315 0.2434 2.8181 7.6300e0030.9283 4.6900e0030.9330 0.2462 4.3200e0030.2505 775.8515 775.8515 0.0269 0.0245 783.8115 Total 0.4193 2.8775 3.6041 0.0177 1.2535 0.0284 1.2819 0.3399 0.0270 0.3669 1,839.847 7 1,839.847
7 0.0313 0.1855 1,895.901
4 Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 13 of 26 Date: 5/9/2022 11:43 AM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

3.5 Building Construction - 2022
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 1.8555 14.6040 14.3533 0.0250 0.7022 0.7022 0.6731 0.6731 0.0000 2,289.281 3 2,289.281
3 0.4417 2,300.323
0 Total 1.8555 14.6040 14.3533 0.0250 0.7022 0.7022 0.6731 0.6731 0.0000 2,289.281 3 2,289.281
3 0.4417 2,300.323
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 0.0878 2.6341 0.7860 0.0101 0.3253 0.0237 0.3490 0.0937 0.0227 0.1163 1,063.996 1 1,063.996
1 4.4800e0030.1610 1,112.089
9 Worker 0.3315 0.2434 2.8181 7.6300e0030.9283 4.6900e0030.9330 0.2462 4.3200e0030.2505 775.8515 775.8515 0.0269 0.0245 783.8115 Total 0.4193 2.8775 3.6041 0.0177 1.2535 0.0284 1.2819 0.3399 0.0270 0.3669 1,839.847 7 1,839.847
7 0.0313 0.1855 1,895.901
4 Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 14 of 26 Date: 5/9/2022 11:43 AM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

3.5 Building Construction - 2023
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 1.7136 13.6239 14.2145 0.0250 0.6136 0.6136 0.5880 0.5880 2,289.523 3 2,289.523
3 0.4330 2,300.347
9 Total 1.7136 13.6239 14.2145 0.0250 0.6136 0.6136 0.5880 0.5880 2,289.523 3 2,289.523
3 0.4330 2,300.347
9 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 0.0531 2.2683 0.7168 9.7400e0030.3253 0.0134 0.3386 0.0937 0.0128 0.1064 1,028.852 6 1,028.852
6 2.8200e0030.1556 1,075.298
2 Worker 0.3085 0.2161 2.6255 7.3800e0030.9283 4.4500e0030.9327 0.2462 4.1000e0030.2503 755.7832 755.7832 0.0244 0.0227 763.1700 Total 0.3616 2.4844 3.3423 0.0171 1.2535 0.0178 1.2713 0.3399 0.0169 0.3568 1,784.635 8 1,784.635
8 0.0272 0.1784 1,838.468
3 Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 15 of 26 Date: 5/9/2022 11:43 AM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

3.5 Building Construction - 2023
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 1.7136 13.6239 14.2145 0.0250 0.6136 0.6136 0.5880 0.5880 0.0000 2,289.523 3 2,289.523
3 0.4330 2,300.347
9 Total 1.7136 13.6239 14.2145 0.0250 0.6136 0.6136 0.5880 0.5880 0.0000 2,289.523 3 2,289.523
3 0.4330 2,300.347
9 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 0.0531 2.2683 0.7168 9.7400e0030.3253 0.0134 0.3386 0.0937 0.0128 0.1064 1,028.852 6 1,028.852
6 2.8200e0030.1556 1,075.298
2 Worker 0.3085 0.2161 2.6255 7.3800e0030.9283 4.4500e0030.9327 0.2462 4.1000e0030.2503 755.7832 755.7832 0.0244 0.0227 763.1700 Total 0.3616 2.4844 3.3423 0.0171 1.2535 0.0178 1.2713 0.3399 0.0169 0.3568 1,784.635 8 1,784.635
8 0.0272 0.1784 1,838.468
3 Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 16 of 26 Date: 5/9/2022 11:43 AM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

3.6 Paving - 2023
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 0.8802 8.6098 11.6840 0.0179 0.4338 0.4338 0.4003 0.4003 1,709.992 6 1,709.992
6 0.5420 1,723.541
4 Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.8802 8.6098 11.6840 0.0179 0.4338 0.4338 0.4003 0.4003 1,709.992 6 1,709.992
6 0.5420 1,723.541
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 0.0410 0.0287 0.3485 9.8000e0040.1232 5.9000e0040.1238 0.0327 5.4000e0040.0332 100.3252 100.3252 3.2400e0033.0200e003101.3058 Total 0.0410 0.0287 0.3485 9.8000e0040.1232 5.9000e0040.1238 0.0327 5.4000e0040.0332 100.3252 100.3252 3.2400e0033.0200e003101.3058 Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 17 of 26 Date: 5/9/2022 11:43 AM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

3.6 Paving - 2023
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 0.8802 8.6098 11.6840 0.0179 0.4338 0.4338 0.4003 0.4003 0.0000 1,709.992 6 1,709.992
6 0.5420 1,723.541
4 Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.8802 8.6098 11.6840 0.0179 0.4338 0.4338 0.4003 0.4003 0.0000 1,709.992 6 1,709.992
6 0.5420 1,723.541
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 0.0410 0.0287 0.3485 9.8000e0040.1232 5.9000e0040.1238 0.0327 5.4000e0040.0332 100.3252 100.3252 3.2400e0033.0200e003101.3058 Total 0.0410 0.0287 0.3485 9.8000e0040.1232 5.9000e0040.1238 0.0327 5.4000e0040.0332 100.3252 100.3252 3.2400e0033.0200e003101.3058 Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 18 of 26 Date: 5/9/2022 11:43 AM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

3.7 Architectural Coating - 2023
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 98.0381 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.1917 1.3030 1.8111 2.9700e0030.0708 0.0708 0.0708 0.0708 281.4481 281.4481 0.0168 281.8690 Total 98.2298 1.3030 1.8111 2.9700e0030.0708 0.0708 0.0708 0.0708 281.4481 281.4481 0.0168 281.8690 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 0.0628 0.0440 0.5344 1.5000e0030.1889 9.1000e0040.1899 0.0501 8.3000e0040.0510 153.8320 153.8320 4.9700e0034.6300e003155.3355 Total 0.0628 0.0440 0.5344 1.5000e0030.1889 9.1000e0040.1899 0.0501 8.3000e0040.0510 153.8320 153.8320 4.9700e0034.6300e003155.3355 Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 19 of 26 Date: 5/9/2022 11:43 AM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

3.7 Architectural Coating - 2023
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 98.0381 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.1917 1.3030 1.8111 2.9700e0030.0708 0.0708 0.0708 0.0708 0.0000 281.4481 281.4481 0.0168 281.8690 Total 98.2298 1.3030 1.8111 2.9700e0030.0708 0.0708 0.0708 0.0708 0.0000 281.4481 281.4481 0.0168 281.8690 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 0.0628 0.0440 0.5344 1.5000e0030.1889 9.1000e0040.1899 0.0501 8.3000e0040.0510 153.8320 153.8320 4.9700e0034.6300e003155.3355 Total 0.0628 0.0440 0.5344 1.5000e0030.1889 9.1000e0040.1899 0.0501 8.3000e0040.0510 153.8320 153.8320 4.9700e0034.6300e003155.3355 Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 20 of 26 Date: 5/9/2022 11:43 AM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

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 8.6062 12.3269 80.7797 0.1380 14.3949 0.1281 14.5230 3.8422 0.1202 3.9624 14,268.42 04 14,268.42
04 1.1285 0.8600 14,552.89
74 Unmitigated 8.6062 12.3269 80.7797 0.1380 14.3949 0.1281 14.5230 3.8422 0.1202 3.9624 14,268.42 04 14,268.42
04 1.1285 0.8600 14,552.89
74 4.1 Mitigation Measures Mobile

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
Enclosed Parking with Elevator 0.00 0.00 0.00
Medical Office Building 3,480.00 857.00 142.00 5,144,491 5,144,491 Total 3,480.00 857.00 142.00 5,144,491 5,144,491
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 Enclosed Parking with Elevator 9.50 7.30 7.30 0.00 0.00 0.00 0 0 0 Medical Office Building 9.50 7.30 7.30 29.60 51.40 19.00 60 30 10

4.4 Fleet Mix
CalEEMod Version: CalEEMod.2020.4.0 Page 21 of 26 Date: 5/9/2022 11:43 AM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied Land Use LDA LDT1 LDT2 MDV LHD1 LHD2 MHD HHD OBUS UBUS MCY SBUS MH Enclosed Parking with Elevator 0.466187 0.061512 0.210180 0.153350 0.034639 0.008391 0.014417 0.011935 0.000556 0.000412 0.031993 0.000977 0.005450 Medical Office Building 0.466187 0.061512 0.210180 0.153350 0.034639 0.008391 0.014417 0.011935 0.000556 0.000412 0.031993 0.000977 0.005450

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

0.0482 0.4378 0.3678 2.6300e0030.0333 0.0333 0.0333 0.0333 525.3828 525.3828 0.0101 9.6300e003528.5048 NaturalGas
Unmitigated

0.0482 0.4378 0.3678 2.6300e0030.0333 0.0333 0.0333 0.0333 525.3828 525.3828 0.0101 9.6300e003528.5048

5.1 Mitigation Measures Energy
Historical Energy Use: N
CalEEMod Version: CalEEMod.2020.4.0 Page 22 of 26 Date: 5/9/2022 11:43 AM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

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
Enclosed Parking
with Elevator
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 Medical Office
Building
4465.75 0.0482 0.4378 0.3678 2.6300e0030.0333 0.0333 0.0333 0.0333 525.3828 525.3828 0.0101 9.6300e003528.5048 Total 0.0482 0.4378 0.3678 2.6300e0030.0333 0.0333 0.0333 0.0333 525.3828 525.3828 0.0101 9.6300e003528.5048 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
Enclosed Parking
with Elevator
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 Medical Office
Building

4.46575 0.0482 0.4378 0.3678 2.6300e0030.0333 0.0333 0.0333 0.0333 525.3828 525.3828 0.0101 9.6300e003528.5048 Total 0.0482 0.4378 0.3678 2.6300e0030.0333 0.0333 0.0333 0.0333 525.3828 525.3828 0.0101 9.6300e003528.5048 Mitigated
CalEEMod Version: CalEEMod.2020.4.0 Page 23 of 26 Date: 5/9/2022 11:43 AM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

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 2.4775 9.0000e0050.0103 0.0000 4.0000e0054.0000e0054.0000e0054.0000e0050.0221 0.0221 6.0000e0050.0236 Unmitigated 2.4775 9.0000e0050.0103 0.0000 4.0000e0054.0000e0054.0000e0054.0000e0050.0221 0.0221 6.0000e0050.0236

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

0.2686 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products

2.2080 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Landscaping 9.5000e0049.0000e0050.0103 0.0000 4.0000e0054.0000e0054.0000e0054.0000e0050.0221 0.0221 6.0000e0050.0236 Total 2.4775 9.0000e0050.0103 0.0000 4.0000e0054.0000e0054.0000e0054.0000e0050.0221 0.0221 6.0000e0050.0236 Unmitigated
CalEEMod Version: CalEEMod.2020.4.0 Page 24 of 26 Date: 5/9/2022 11:43 AM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

7.1 Mitigation Measures Water

7.0 Water Detail

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

0.2686 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products

2.2080 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Landscaping 9.5000e0049.0000e0050.0103 0.0000 4.0000e0054.0000e0054.0000e0054.0000e0050.0221 0.0221 6.0000e0050.0236 Total 2.4775 9.0000e0050.0103 0.0000 4.0000e0054.0000e0054.0000e0054.0000e0050.0221 0.0221 6.0000e0050.0236 Mitigated
CalEEMod Version: CalEEMod.2020.4.0 Page 25 of 26 Date: 5/9/2022 11:43 AM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied

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
CalEEMod Version: CalEEMod.2020.4.0 Page 26 of 26 Date: 5/9/2022 11:43 AM Sutter Parking Garage Expansion & MOB 10 - Placer-Sacramento County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 2656 29th Street, Suite 201
Santa Monica, CA 90405
Matt Hagemann, P.G, C.Hg.
(949) 887-9013
[email protected]
Matthew F. Hagemann, P.G., C.Hg., QSD, QSP
Geologic and Hydrogeologic Characterization
Investigationand RemediationStrategies
LitigationSupport and Testifying Expert
IndustrialStormwaterCompliance
CEQAReview
Education:

M.S. Degree, Geology, California State University Los Angeles, Los Angeles, CA, 1984.

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:
• Founding Partner, Soil/Water/Air Protection Enterprise (SWAPE) (2003 – present); • Geology Instructor, Golden West College, 2010 – 2104, 2017; • Senior Environmental Analyst, Komex H2O Science, Inc. (2000 ‐‐ 2003); Attachment B
2 • Executive Director, Orange Coast Watch (2001 – 2004); • Senior Science Policy Advisor and Hydrogeologist, U.S. Environmental Protection Agency (1989– 1998);
• Hydrogeologist, National Park Service, Water Resources Division (1998 – 2000); • Adjunct Faculty Member, San Francisco State University, Department of Geosciences (1993 – 1998);
• Instructor, College of Marin, Department of Science (1990 – 1995); • Geologist, U.S. Forest Service (1986 – 1998); and
• Geologist, Dames & Moore (1984 – 1986).

Senior Regulatory and Litigation Support Analyst:

With SWAPE, Matt’s responsibilities have included:
• Lead analyst and testifying expert in the review of over 300 environmental impact reports and negative declarations since 2003 under CEQA that identify significant issues with regard to hazardous waste, water resources, water quality, air quality, greenhouse gas emissions, and geologic hazards. Make recommendations for additional mitigation measures to lead agencies at the local and county level to include additional characterization of health risks and implementation of protective measures to reduce worker exposure to hazards from toxins and Valley Fever.
• Stormwater analysis, sampling and best management practice evaluation at more than 100 industrial facilities.
• Expert witness on numerous cases including, for example, perfluorooctanoic acid (PFOA) contamination of groundwater, MTBE litigation, air toxins at hazards at a school, CERCLA compliance in assessment and remediation, and industrial stormwater contamination. • Technical assistance and litigation support for vaporintrusion concerns. • Lead analyst and testifying expert in the review of environmental issues in license applications forlarge solar power plants before the California Energy Commission. • Manager of a project to evaluate numerous formerly used military sites in the western U.S. • Manager of a comprehensive evaluation of potential sources of perchlorate contamination in Southern California drinking water wells.
• Manager and designated expert for litigation support under provisions of Proposition 65 in the review of releases of gasoline to sources drinking water at major refineries and hundreds of gas stations throughout California.

With Komex H2O Science Inc., Matt’s duties included the following:
• Senior author of a report on the extent of perchlorate contamination that was used in testimony by the former U.S. EPA Administrator and General Counsel. • Seniorresearcher in the development of a comprehensive, electronically interactive chronology of MTBE use, research, and regulation.
• Seniorresearcher in the development of a comprehensive, electronically interactive chronology of perchlorate use, research, and regulation.
• Senior researcher in a study that estimates nationwide costs for MTBE remediation and drinking water treatment, results of which were published in newspapers nationwide and in testimony against provisions of an energy bill that would limit liability for oil companies. • Research to support litigation to restore drinking water supplies that have been contaminated by MTBE in California and New York.
3 • Expert witness testimony in a case of oil production‐related contamination in Mississippi. • Lead author for a multi‐volume remedial investigation report for an operating school in Los Angeles that met strict regulatory requirements and rigorous deadlines. • Development of strategic approaches for cleanup of contaminated sites in consultation with clients and regulators.

Executive Director:

As Executive Director with Orange Coast Watch, Matt led efforts to restore water quality at Orange County beaches from multiple sources of contamination including urban runoff and the discharge of wastewater. In reporting to a Board of Directors that included representatives from leading Orange County universities and businesses, Matt prepared issue papers in the areas of treatment and disinfection of wastewater and control of the discharge of grease to sewer systems. Matt actively participated in the development of countywide water quality permits for the control of urban runoff and permits for the discharge of wastewater. Matt worked with other nonprofits to protect and restore water quality, including Surfrider, Natural Resources Defense Council and Orange County CoastKeeper as well as with business institutions including the Orange County Business Council.

Hydrogeology:

As a Senior Hydrogeologist with the U.S. Environmental Protection Agency, Matt led investigations to characterize and cleanup closing military bases, including Mare Island Naval Shipyard, Hunters Point Naval Shipyard, Treasure Island Naval Station, Alameda Naval Station, Moffett Field, Mather Army Airfield, and Sacramento Army Depot. Specific activities were as follows:
• Led efforts to model groundwater flow and contaminant transport, ensured adequacy of monitoring networks, and assessed cleanup alternatives for contaminated sediment, soil, and groundwater.
• Initiated a regional program for evaluation of groundwater sampling practices and laboratory analysis at military bases.
• Identified emerging issues, wrote technical guidance, and assisted in policy and regulation development through work on four national U.S. EPA workgroups, including the Superfund Groundwater Technical Forum and the Federal Facilities Forum.

At the request of the State of Hawaii, Matt developed a methodology to determine the vulnerability of groundwater to contamination on the islands of Maui and Oahu. He used analytical models and a GIS to show zones of vulnerability, and the results were adopted and published by the State of Hawaii and County of Maui.

As a hydrogeologist with the EPA Groundwater Protection Section, Matt worked with provisions of the Safe Drinking Water Act and NEPA to prevent drinking water contamination. Specific activities included the following:
• Received an EPA Bronze Medal for his contribution to the development of national guidance for the protection of drinking water.
• Managed the Sole Source Aquifer Program and protected the drinking water of two communities through designation under the Safe Drinking Water Act. He prepared geologic reports, conducted 4 public hearings, and responded to public comments from residents who were very concerned about the impact of designation.
• Reviewed a number of Environmental Impact Statements for planned major developments, including large hazardous and solid waste disposal facilities, mine reclamation, and water transfer.

Matt served as a hydrogeologist with the RCRA Hazardous Waste program. Duties were as follows:
• Supervised the hydrogeologic investigation of hazardous waste sites to determine compliance with Subtitle C requirements.
• Reviewed and wrote ʺpart Bʺ permits for the disposal of hazardous waste. • Conducted RCRA Corrective Action investigations of waste sites and led inspections that formed the basis for significant enforcement actions that were developed in close coordination with U.S.

EPA legal counsel.
• Wrote contract specifications and supervised contractor’s investigations of waste sites.

With the National Park Service, Matt directed service‐wide investigations of contaminant sources to prevent degradation of water quality, including the following tasks:
• Applied pertinent laws and regulations including CERCLA, RCRA, NEPA, NRDA, and the Clean Water Act to control military, mining, and landfill contaminants. • Conducted watershed‐scale investigations of contaminants at parks, including Yellowstone and Olympic National Park.
• Identified high‐levels of perchlorate in soil adjacent to a national park in New Mexico and advised park superintendent on appropriate response actions under CERCLA. • Served as a Park Service representative on the Interagency Perchlorate Steering Committee, a national workgroup.
• Developed a program to conduct environmental compliance audits of all National Parks while serving on a national workgroup.
• Co‐authored two papers on the potential for water contamination from the operation of personal watercraft and snowmobiles, these papers serving as the basis for the development of nation‐ wide policy on the use of these vehicles in National Parks. • Contributed to the Federal Multi‐Agency Source Water Agreement under the Clean Water Action Plan.

Policy:

Served senior management as the Senior Science Policy Advisor with the U.S. Environmental Protection Agency, Region 9.

Activities included the following:
• Advised the Regional Administrator and senior management on emerging issues such as the potential for the gasoline additive MTBE and ammonium perchlorate to contaminate drinking water supplies.
• Shaped EPA’s national response to these threats by serving on workgroups and by contributing to guidance, including the Office of Research and Development publication, Oxygenates in Water: Critical Information and Research Needs.
• Improved the technical training of EPAʹs scientific and engineering staff. • Earned an EPA Bronze Medal for representing the region’s 300 scientists and engineers in negotiations with the Administrator and senior management to better integrate scientific 5 principles into the policy‐making process.
• Established national protocol for the peerreview of scientific documents.

Geology:

With the U.S. Forest Service, Matt led investigations to determine hillslope stability of areas proposed for timber harvest in the central Oregon Coast Range. Specific activities were as follows:
• Mapped geology in the field, and used aerial photographic interpretation and mathematical models to determine slope stability.
• Coordinated his research with community members who were concerned with natural resource protection.
• Characterized the geology of an aquifer that serves as the sole source of drinking water for the city of Medford, Oregon.

As a consultant with Dames and Moore, Matt led geologic investigations of two contaminated sites (later listed on the Superfund NPL) in the Portland, Oregon, area and a large hazardous waste site in eastern Oregon. Duties included the following:
• Supervised year‐long effort for soil and groundwater sampling. • Conducted aquifer tests.
• Investigated active faults beneath sites proposed for hazardous waste disposal.

Teaching:

From 1990 to 1998, Matt taught at least one course per semester at the community college and university levels:
• At San Francisco State University, held an adjunct faculty position and taught courses in environmental geology, oceanography (lab and lecture), hydrogeology, and groundwater contamination.
• Served as a committee member for graduate and undergraduate students. • Taught courses in environmental geology and oceanography at the College of Marin.

Matt is currently a part time geology instructor at Golden West College in Huntington Beach, California where he taught from 2010 to 2014 and in 2017.

Invited Testimony, Reports, Papers and Presentations:

Hagemann, M.F., 2008. Disclosure of Hazardous Waste Issues under CEQA. Presentation to the Public Environmental Law Conference, Eugene, Oregon.

Hagemann, M.F., 2008. Disclosure of Hazardous Waste Issues under CEQA. Invited presentation to U.S.

EPA Region 9, San Francisco, California.

Hagemann, M.F., 2005. Use of Electronic Databases in Environmental Regulation, Policy Making and Public Participation. Brownfields 2005, Denver, Coloradao.

Hagemann, M.F., 2004. Perchlorate Contamination of the Colorado River and Impacts to Drinking Water in Nevada and the Southwestern U.S. Presentation to a meeting of the American Groundwater Trust, Las Vegas, NV (served on conference organizing committee).
6 Hagemann, M.F., 2004. Invited testimony to a California Senate committee hearing on air toxins at schools in Southern California, Los Angeles.

Brown, A., Farrow, J., Gray, A. and Hagemann, M., 2004. An Estimate of Costs to Address MTBE Releases from Underground Storage Tanks and the Resulting Impact to Drinking Water Wells.

Presentation to the Ground Water and Environmental Law Conference, National Groundwater Association.

Hagemann, M.F., 2004. Perchlorate Contamination of the Colorado River and Impacts to Drinking Water in Arizona and the Southwestern U.S. Presentation to a meeting of the American Groundwater Trust, Phoenix, AZ (served on conference organizing committee).

Hagemann, M.F., 2003. Perchlorate Contamination of the Colorado River and Impacts to Drinking Water in the Southwestern U.S. Invited presentation to a special committee meeting of the National Academy of Sciences, Irvine, CA.

Hagemann, M.F., 2003. Perchlorate Contamination of the Colorado River. Invited presentation to a tribal EPA meeting, Pechanga, CA.

Hagemann, M.F., 2003. Perchlorate Contamination of the Colorado River. Invited presentation to a meeting of tribal repesentatives, Parker, AZ.

Hagemann, M.F., 2003. Impact of Perchlorate on the Colorado River and Associated Drinking Water Supplies. Invited presentation to the Inter‐Tribal Meeting, Torres Martinez Tribe.

Hagemann, M.F., 2003. The Emergence of Perchlorate as a Widespread Drinking Water Contaminant.

Invited presentation to the U.S. EPA Region 9.

Hagemann, M.F., 2003. A Deductive Approach to the Assessment of Perchlorate Contamination. Invited presentation to the California Assembly Natural Resources Committee.

Hagemann, M.F., 2003. Perchlorate: A Cold War Legacy in Drinking Water. Presentation to a meeting of the National Groundwater Association.

Hagemann, M.F., 2002. From Tank to Tap: A Chronology of MTBE in Groundwater. Presentation to a meeting of the National Groundwater Association.

Hagemann, M.F., 2002. A Chronology of MTBE in Groundwater and an Estimate of Costs to Address Impacts to Groundwater. Presentation to the annual meeting of the Society of Environmental Journalists.

Hagemann, M.F., 2002. An Estimate of the Cost to Address MTBE Contamination in Groundwater (and Who Will Pay). Presentation to a meeting of the National Groundwater Association.

Hagemann, M.F., 2002. An Estimate of Costs to Address MTBE Releases from Underground Storage Tanks and the Resulting Impact to Drinking Water Wells. Presentation to a meeting of the U.S. EPA and State Underground Storage Tank Program managers.
7 Hagemann, M.F., 2001. From Tank to Tap: A Chronology of MTBE in Groundwater. Unpublished report.

Hagemann, M.F., 2001. Estimated Cleanup Cost for MTBE in Groundwater Used as Drinking Water.

Unpublished report.

Hagemann, M.F., 2001. Estimated Costs to Address MTBE Releases from Leaking Underground Storage Tanks. Unpublished report.

Hagemann, M.F., and VanMouwerik, M., 1999. Potential W a t e r Quality Concerns Related to Snowmobile Usage. Water Resources Division, National Park Service, Technical Report.

VanMouwerik, M. and Hagemann, M.F. 1999, Water Quality Concerns Related to Personal Watercraft Usage. Water Resources Division, National Park Service, Technical Report.

Hagemann, M.F., 1999, Is Dilution the Solution to Pollution in National Parks? The George Wright Society Biannual Meeting, Asheville, North Carolina.

Hagemann, M.F., 1997, The Potential for MTBE to Contaminate Groundwater. U.S. EPA Superfund Groundwater Technical Forum Annual Meeting, Las Vegas, Nevada.

Hagemann, M.F., and Gill, M., 1996, Impediments to Intrinsic Remediation, Moffett Field Naval Air Station, Conference on Intrinsic Remediation of Chlorinated Hydrocarbons, Salt Lake City.

Hagemann, M.F., Fukunaga, G.L., 1996, The Vulnerability of Groundwater to Anthropogenic Contaminants on the Island of Maui, Hawaii. Hawaii Water Works Association Annual Meeting, Maui, October 1996.

Hagemann, M. F., Fukanaga, G. L., 1996, Ranking Groundwater Vulnerability in Central Oahu, Hawaii. Proceedings, Geographic Information Systems in Environmental Resources Management, Air and Waste Management Association Publication VIP‐61.

Hagemann, M.F., 1994. Groundwater Ch ar ac te ri zati on and Cl ean up at Closing Military Bases in California. Proceedings, California Groundwater Resources Association Meeting.

Hagemann, M.F. and Sabol, M.A., 1993. Role of the U.S. EPA in the High Plains States Groundwater Recharge Demonstration Program. Proceedings, Sixth Biennial Symposium on the Artificial Recharge of Groundwater.

Hagemann, M.F., 1993. U.S. EPA Policy on the Technical Impracticability of the Cleanup of DNAPL‐ contaminated Groundwater. California Groundwater Resources Association Meeting. 8 Hagemann, M.F., 1992. Dense Nonaqueous Phase Liquid Contamination of Groundwater: An Ounce of Prevention... Proceedings, Association of Engineering Geologists Annual Meeting, v. 35.

Other Experience:

Selected as subject matter expert for the California Professional Geologist licensing examinations, 2009‐2011.

SOIL WATER AIR PROTECTION ENTERPRISE
2656 29th Street, Suite 201
Santa Monica, California 90405
Attn: Paul Rosenfeld, Ph.D.

Mobil: (310) 795-2335
Office: (310) 452-5555
Fax: (310) 452-5550
Email: [email protected]
Paul E. Rosenfeld, Ph.D. Page 1 of 10 October 2021
Paul Rosenfeld, Ph.D. Chemical Fate and Transport & Air Dispersion Modeling Principal Environmental Chemist Risk Assessment & Remediation Specialist Education
Ph.D. Soil Chemistry, University of Washington, 1999. Dissertation on volatile organic compound filtration.

M.S. Environmental Science, U.C. Berkeley, 1995. Thesis on organic waste economics.

B.A. Environmental Studies, U.C. Santa Barbara, 1991. Thesis on wastewater treatment.

Professional Experience
Dr. Rosenfeld has over 25 years’ experience conducting environmental investigations and risk assessments for evaluating impacts to human health, property, and ecological receptors. His expertise focuses on the fate and transport of environmental contaminants, human health risk, exposure assessment, and ecological restoration. Dr.

Rosenfeld has evaluated and modeled emissions from oil spills, landfills, boilers and incinerators, process stacks, storage tanks, confined animal feeding operations, industrial, military and agricultural sources, unconventional oil drilling operations, and locomotive and construction engines. His project experience ranges from monitoring and modeling of pollution sources to evaluating impacts of pollution on workers at industrial facilities and residents in surrounding communities. Dr. Rosenfeld has also successfully modeled exposure to contaminants distributed by water systems and via vapor intrusion.

Dr. Rosenfeld has investigated and designed remediation programs and risk assessments for contaminated sites containing lead, heavy metals, mold, bacteria, particulate matter, petroleum hydrocarbons, chlorinated solvents, pesticides, radioactive waste, dioxins and furans, semi- and volatile organic compounds, PCBs, PAHs, creosote, perchlorate, asbestos, per- and poly-fluoroalkyl substances (PFOA/PFOS), unusual polymers, fuel oxygenates (MTBE), among other pollutants. Dr. Rosenfeld also has experience evaluating greenhouse gas emissions from various projects and is an expert on the assessment of odors from industrial and agricultural sites, as well as the evaluation of odor nuisance impacts and technologies for abatement of odorous emissions. As a principal scientist at SWAPE, Dr. Rosenfeld directs air dispersion modeling and exposure assessments. He has served as an expert witness and testified about pollution sources causing nuisance and/or personal injury at sites and has testified as an expert witness on numerous cases involving exposure to soil, water and air contaminants from industrial, railroad, agricultural, and military sources.

Attachment C

Paul E. Rosenfeld, Ph.D. Page 2 of 10 October 2021
Professional History:

Soil Water Air Protection Enterprise (SWAPE); 2003 to present; Principal and Founding Partner UCLA School of Public Health; 2007 to 2011; Lecturer (Assistant Researcher) UCLA School of Public Health; 2003 to 2006; Adjunct Professor UCLA Environmental Science and Engineering Program; 2002-2004; Doctoral Intern Coordinator UCLA Institute of the Environment, 2001-2002; Research Associate Komex H2O Science, 2001 to 2003; Senior Remediation Scientist National Groundwater Association, 2002-2004; Lecturer
San Diego State University, 1999-2001; Adjunct Professor Anteon Corp., San Diego, 2000-2001; Remediation Project Manager Ogden (now Amec), San Diego, 2000-2000; Remediation Project Manager Bechtel, San Diego, California, 1999 – 2000; Risk Assessor King County, Seattle, 1996 – 1999; Scientist
James River Corp., Washington, 1995-96; Scientist
Big Creek Lumber, Davenport, California, 1995; Scientist Plumas Corp., California and USFS, Tahoe 1993-1995; Scientist Peace Corps and World Wildlife Fund, St. Kitts, West Indies, 1991-1993; Scientist Publications:

Remy, L.L., Clay T., Byers, V., Rosenfeld P. E. (2019) Hospital, Health, and Community Burden After Oil Refinery Fires, Richmond, California 2007 and 2012. Environmental Health. 18:48 Simons, R.A., Seo, Y. Rosenfeld, P., (2015) Modeling the Effect of Refinery Emission On Residential Property Value. Journal of Real Estate Research. 27(3):321-342
Chen, J. A, Zapata A. R., Sutherland A. J., Molmen, D.R., Chow, B. S., Wu, L. E., Rosenfeld, P. E., Hesse, R. C., (2012) Sulfur Dioxide and Volatile Organic Compound Exposure To A Community In Texas City Texas Evaluated Using Aermod and Empirical Data. American Journal of Environmental Science, 8(6), 622-632.

Rosenfeld, P.E. & Feng, L. (2011). The Risks of Hazardous Waste. Amsterdam: Elsevier Publishing.

Cheremisinoff, N.P., & Rosenfeld, P.E. (2011). Handbook of Pollution Prevention and Cleaner Production: Best Practices in the Agrochemical Industry, Amsterdam: Elsevier Publishing.

Gonzalez, J., Feng, L., Sutherland, A., Waller, C., Sok, H., Hesse, R., Rosenfeld, P. (2010). PCBs and Dioxins/Furans in Attic Dust Collected Near Former PCB Production and Secondary Copper Facilities in Sauget, IL.

Procedia Environmental Sciences. 113–125.

Feng, L., Wu, C., Tam, L., Sutherland, A.J., Clark, J.J., Rosenfeld, P.E. (2010). Dioxin and Furan Blood Lipid and Attic Dust Concentrations in Populations Living Near Four Wood Treatment Facilities in the United States. Journal of Environmental Health. 73(6), 34-46.

Cheremisinoff, N.P., & Rosenfeld, P.E. (2010). Handbook of Pollution Prevention and Cleaner Production: Best Practices in the Wood and Paper Industries. Amsterdam: Elsevier Publishing.

Cheremisinoff, N.P., & Rosenfeld, P.E. (2009). Handbook of Pollution Prevention and Cleaner Production: Best Practices in the Petroleum Industry. Amsterdam: Elsevier Publishing.

Wu, C., Tam, L., Clark, J., Rosenfeld, P. (2009). Dioxin and furan blood lipid concentrations in populations living near four wood treatment facilities in the United States. WIT Transactions on Ecology and the Environment, Air Pollution, 123 (17), 319-327.

Paul E. Rosenfeld, Ph.D. Page 3 of 10 October 2021
Tam L. K.., Wu C. D., Clark J. J. and Rosenfeld, P.E. (2008). A Statistical Analysis Of Attic Dust And Blood Lipid Concentrations Of Tetrachloro-p-Dibenzodioxin (TCDD) Toxicity Equivalency Quotients (TEQ) In Two Populations Near Wood Treatment Facilities. Organohalogen Compounds, 70, 002252-002255.

Tam L. K.., Wu C. D., Clark J. J. and Rosenfeld, P.E. (2008). Methods For Collect Samples For Assessing Dioxins And Other Environmental Contaminants In Attic Dust: A Review. Organohalogen Compounds, 70, 000527- 000530.

Hensley, A.R. A. Scott, J. J. J. Clark, Rosenfeld, P.E. (2007). Attic Dust and Human Blood Samples Collected near a Former Wood Treatment Facility. Environmental Research. 105, 194-197.

Rosenfeld, P.E., J. J. J. Clark, A. R. Hensley, M. Suffet. (2007). The Use of an Odor Wheel Classification for Evaluation of Human Health Risk Criteria for Compost Facilities. Water Science & Technology 55(5), 345-357.

Rosenfeld, P. E., M. Suffet. (2007). The Anatomy Of Odour Wheels For Odours Of Drinking Water, Wastewater, Compost And The Urban Environment. Water Science & Technology 55(5), 335-344.

Sullivan, P. J. Clark, J.J.J., Agardy, F. J., Rosenfeld, P.E. (2007). Toxic Legacy, Synthetic Toxins in the Food, Water, and Air in American Cities. Boston Massachusetts: Elsevier Publishing Rosenfeld, P.E., and Suffet I.H. (2004). Control of Compost Odor Using High Carbon Wood Ash. Water Science and Technology. 49(9),171-178.

Rosenfeld P. E., J.J. Clark, I.H. (Mel) Suffet (2004). The Value of An Odor-Quality-Wheel Classification Scheme For The Urban Environment. Water Environment Federation’s Technical Exhibition and Conference (WEFTEC) 2004. New Orleans, October 2-6, 2004.

Rosenfeld, P.E., and Suffet, I.H. (2004). Understanding Odorants Associated With Compost, Biomass Facilities, and the Land Application of Biosolids. Water Science and Technology. 49(9), 193-199.

Rosenfeld, P.E., and Suffet I.H. (2004). Control of Compost Odor Using High Carbon Wood Ash, Water Science and Technology, 49( 9), 171-178.

Rosenfeld, P. E., Grey, M. A., Sellew, P. (2004). Measurement of Biosolids Odor and Odorant Emissions from Windrows, Static Pile and Biofilter. Water Environment Research. 76(4), 310-315.

Rosenfeld, P.E., Grey, M and Suffet, M. (2002). Compost Demonstration Project, Sacramento California Using High-Carbon Wood Ash to Control Odor at a Green Materials Composting Facility. Integrated Waste Management Board Public Affairs Office, Publications Clearinghouse (MS–6), Sacramento, CA Publication #442-02-008.

Rosenfeld, P.E., and C.L. Henry. (2001). Characterization of odor emissions from three different biosolids. Water Soil and Air Pollution. 127(1-4), 173-191.

Rosenfeld, P.E., and Henry C. L., (2000). Wood ash control of odor emissions from biosolids application. Journal of Environmental Quality. 29, 1662-1668.

Rosenfeld, P.E., C.L. Henry and D. Bennett. (2001). Wastewater dewatering polymer affect on biosolids odor emissions and microbial activity. Water Environment Research. 73(4), 363-367.

Rosenfeld, P.E., and C.L. Henry. (2001). Activated Carbon and Wood Ash Sorption of Wastewater, Compost, and Biosolids Odorants. Water Environment Research, 73, 388-393.

Rosenfeld, P.E., and Henry C. L., (2001). High carbon wood ash effect on biosolids microbial activity and odor.

Water Environment Research. 131(1-4), 247-262.

Paul E. Rosenfeld, Ph.D. Page 4 of 10 October 2021
Chollack, T. and P. Rosenfeld. (1998). Compost Amendment Handbook For Landscaping. Prepared for and distributed by the City of Redmond, Washington State.

Rosenfeld, P. E. (1992). The Mount Liamuiga Crater Trail. Heritage Magazine of St. Kitts, 3(2).

Rosenfeld, P. E. (1993). High School Biogas Project to Prevent Deforestation On St. Kitts. Biomass Users Network, 7(1).

Rosenfeld, P. E. (1998). Characterization, Quantification, and Control of Odor Emissions From Biosolids Application To Forest Soil. Doctoral Thesis. University of Washington College of Forest Resources.

Rosenfeld, P. E. (1994). Potential Utilization of Small Diameter Trees on Sierra County Public Land. Masters thesis reprinted by the Sierra County Economic Council. Sierra County, California.

Rosenfeld, P. E. (1991). How to Build a Small Rural Anaerobic Digester & Uses Of Biogas In The First And Third World. Bachelors Thesis. University of California.

Presentations:

Rosenfeld, P.E., "The science for Perfluorinated Chemicals (PFAS): What makes remediation so hard?" Law Seminars International, (May 9-10, 2018) 800 Fifth Avenue, Suite 101 Seattle, WA.

Rosenfeld, P.E., Sutherland, A; Hesse, R.; Zapata, A. (October 3-6, 2013). Air dispersion modeling of volatile organic emissions from multiple natural gas wells in Decatur, TX. 44th Western Regional Meeting, American Chemical Society. Lecture conducted from Santa Clara, CA.

Sok, H.L.; Waller, C.C.; Feng, L.; Gonzalez, J.; Sutherland, A.J.; Wisdom-Stack, T.; Sahai, R.K.; Hesse, R.C.; Rosenfeld, P.E. (June 20-23, 2010). Atrazine: A Persistent Pesticide in Urban Drinking Water.

Urban Environmental Pollution. Lecture conducted from Boston, MA.

Feng, L.; Gonzalez, J.; Sok, H.L.; Sutherland, A.J.; Waller, C.C.; Wisdom-Stack, T.; Sahai, R.K.; La, M.; Hesse, R.C.; Rosenfeld, P.E. (June 20-23, 2010). Bringing Environmental Justice to East St. Louis, Illinois. Urban Environmental Pollution. Lecture conducted from Boston, MA.

Rosenfeld, P.E. (April 19-23, 2009). Perfluoroctanoic Acid (PFOA) and Perfluoroactane Sulfonate (PFOS) Contamination in Drinking Water From the Use of Aqueous Film Forming Foams (AFFF) at Airports in the United States. 2009 Ground Water Summit and 2009 Ground Water Protection Council Spring Meeting, Lecture conducted from Tuscon, AZ.

Rosenfeld, P.E. (April 19-23, 2009). Cost to Filter Atrazine Contamination from Drinking Water in the United States” Contamination in Drinking Water From the Use of Aqueous Film Forming Foams (AFFF) at Airports in the United States. 2009 Ground Water Summit and 2009 Ground Water Protection Council Spring Meeting. Lecture conducted from Tuscon, AZ.

Wu, C., Tam, L., Clark, J., Rosenfeld, P. (20-22 July, 2009). Dioxin and furan blood lipid concentrations in populations living near four wood treatment facilities in the United States. Brebbia, C.A. and Popov, V., eds., Air Pollution XVII: Proceedings of the Seventeenth International Conference on Modeling, Monitoring and Management of Air Pollution. Lecture conducted from Tallinn, Estonia.

Rosenfeld, P. E. (October 15-18, 2007). Moss Point Community Exposure To Contaminants From A Releasing Facility. The 23rd Annual International Conferences on Soils Sediment and Water. Platform lecture conducted from University of Massachusetts, Amherst MA.

Rosenfeld, P. E. (October 15-18, 2007). The Repeated Trespass of Tritium-Contaminated Water Into A Surrounding Community Form Repeated Waste Spills From A Nuclear Power Plant. The 23rd Annual International

Paul E. Rosenfeld, Ph.D. Page 5 of 10 October 2021
Conferences on Soils Sediment and Water. Platform lecture conducted from University of Massachusetts, Amherst MA.

Rosenfeld, P. E. (October 15-18, 2007). Somerville Community Exposure To Contaminants From Wood Treatment Facility Emissions. The 23rd Annual International Conferences on Soils Sediment and Water. Lecture conducted from University of Massachusetts, Amherst MA.

Rosenfeld P. E. (March 2007). Production, Chemical Properties, Toxicology, & Treatment Case Studies of 1,2,3- Trichloropropane (TCP). The Association for Environmental Health and Sciences (AEHS) Annual Meeting. Lecture conducted from San Diego, CA.

Rosenfeld P. E. (March 2007). Blood and Attic Sampling for Dioxin/Furan, PAH, and Metal Exposure in Florala, Alabama. The AEHS Annual Meeting. Lecture conducted from San Diego, CA.

Hensley A.R., Scott, A., Rosenfeld P.E., Clark, J.J.J. (August 21 – 25, 2006). Dioxin Containing Attic Dust And Human Blood Samples Collected Near A Former Wood Treatment Facility. The 26th International Symposium on Halogenated Persistent Organic Pollutants – DIOXIN2006. Lecture conducted from Radisson SAS Scandinavia Hotel in Oslo Norway.

Hensley A.R., Scott, A., Rosenfeld P.E., Clark, J.J.J. (November 4-8, 2006). Dioxin Containing Attic Dust And Human Blood Samples Collected Near A Former Wood Treatment Facility. APHA 134 Annual Meeting & Exposition. Lecture conducted from Boston Massachusetts.

Paul Rosenfeld Ph.D. (October 24-25, 2005). Fate, Transport and Persistence of PFOA and Related Chemicals.

Mealey’s C8/PFOA. Science, Risk & Litigation Conference. Lecture conducted from The Rittenhouse Hotel, Philadelphia, PA.

Paul Rosenfeld Ph.D. (September 19, 2005). Brominated Flame Retardants in Groundwater: Pathways to Human Ingestion, Toxicology and Remediation PEMA Emerging Contaminant Conference. Lecture conducted from Hilton Hotel, Irvine California.

Paul Rosenfeld Ph.D. (September 19, 2005). Fate, Transport, Toxicity, And Persistence of 1,2,3-TCP. PEMA Emerging Contaminant Conference. Lecture conducted from Hilton Hotel in Irvine, California.

Paul Rosenfeld Ph.D. (September 26-27, 2005). Fate, Transport and Persistence of PDBEs. Mealey’s Groundwater Conference. Lecture conducted from Ritz Carlton Hotel, Marina Del Ray, California.

Paul Rosenfeld Ph.D. (June 7-8, 2005). Fate, Transport and Persistence of PFOA and Related Chemicals.

International Society of Environmental Forensics: Focus On Emerging Contaminants. Lecture conducted from Sheraton Oceanfront Hotel, Virginia Beach, Virginia.

Paul Rosenfeld Ph.D. (July 21-22, 2005). Fate Transport, Persistence and Toxicology of PFOA and Related Perfluorochemicals. 2005 National Groundwater Association Ground Water And Environmental Law Conference.

Lecture conducted from Wyndham Baltimore Inner Harbor, Baltimore Maryland.

Paul Rosenfeld Ph.D. (July 21-22, 2005). Brominated Flame Retardants in Groundwater: Pathways to Human Ingestion, Toxicology and Remediation. 2005 National Groundwater Association Ground Water and Environmental Law Conference. Lecture conducted from Wyndham Baltimore Inner Harbor, Baltimore Maryland.

Paul Rosenfeld, Ph.D. and James Clark Ph.D. and Rob Hesse R.G. (May 5-6, 2004). Tert-butyl Alcohol Liability and Toxicology, A National Problem and Unquantified Liability. National Groundwater Association. Environmental Law Conference. Lecture conducted from Congress Plaza Hotel, Chicago Illinois.

Paul Rosenfeld, Ph.D. (March 2004). Perchlorate Toxicology. Meeting of the American Groundwater Trust.

Lecture conducted from Phoenix Arizona.

Paul E. Rosenfeld, Ph.D. Page 6 of 10 October 2021
Hagemann, M.F., Paul Rosenfeld, Ph.D. and Rob Hesse (2004). Perchlorate Contamination of the Colorado River.

Meeting of tribal representatives. Lecture conducted from Parker, AZ.

Paul Rosenfeld, Ph.D. (April 7, 2004). A National Damage Assessment Model For PCE and Dry Cleaners.

Drycleaner Symposium. California Ground Water Association. Lecture conducted from Radison Hotel, Sacramento, California.

Rosenfeld, P. E., Grey, M., (June 2003) Two stage biofilter for biosolids composting odor control. Seventh International In Situ And On Site Bioremediation Symposium Battelle Conference Orlando, FL.

Paul Rosenfeld, Ph.D. and James Clark Ph.D. (February 20-21, 2003) Understanding Historical Use, Chemical Properties, Toxicity and Regulatory Guidance of 1,4 Dioxane. National Groundwater Association. Southwest Focus Conference. Water Supply and Emerging Contaminants.. Lecture conducted from Hyatt Regency Phoenix Arizona.

Paul Rosenfeld, Ph.D. (February 6-7, 2003). Underground Storage Tank Litigation and Remediation. California CUPA Forum. Lecture conducted from Marriott Hotel, Anaheim California.

Paul Rosenfeld, Ph.D. (October 23, 2002) Underground Storage Tank Litigation and Remediation. EPA Underground Storage Tank Roundtable. Lecture conducted from Sacramento California.

Rosenfeld, P.E. and Suffet, M. (October 7- 10, 2002). Understanding Odor from Compost, Wastewater and Industrial Processes. Sixth Annual Symposium On Off Flavors in the Aquatic Environment. International Water Association. Lecture conducted from Barcelona Spain.

Rosenfeld, P.E. and Suffet, M. (October 7- 10, 2002). Using High Carbon Wood Ash to Control Compost Odor.

Sixth Annual Symposium On Off Flavors in the Aquatic Environment. International Water Association. Lecture conducted from Barcelona Spain.

Rosenfeld, P.E. and Grey, M. A. (September 22-24, 2002). Biocycle Composting For Coastal Sage Restoration.

Northwest Biosolids Management Association. Lecture conducted from Vancouver Washington..

Rosenfeld, P.E. and Grey, M. A. (November 11-14, 2002). Using High-Carbon Wood Ash to Control Odor at a Green Materials Composting Facility. Soil Science Society Annual Conference. Lecture conducted from Indianapolis, Maryland.

Rosenfeld. P.E. (September 16, 2000). Two stage biofilter for biosolids composting odor control. Water Environment Federation. Lecture conducted from Anaheim California.

Rosenfeld. P.E. (October 16, 2000). Wood ash and biofilter control of compost odor. Biofest. Lecture conducted from Ocean Shores, California.

Rosenfeld, P.E. (2000). Bioremediation Using Organic Soil Amendments. California Resource Recovery Association. Lecture conducted from Sacramento California.

Rosenfeld, P.E., C.L. Henry, R. Harrison. (1998). Oat and Grass Seed Germination and Nitrogen and Sulfur Emissions Following Biosolids Incorporation With High-Carbon Wood-Ash. Water Environment Federation 12th Annual Residuals and Biosolids Management Conference Proceedings. Lecture conducted from Bellevue Washington.

Rosenfeld, P.E., and C.L. Henry. (1999). An evaluation of ash incorporation with biosolids for odor reduction. Soil Science Society of America. Lecture conducted from Salt Lake City Utah.

Rosenfeld, P.E., C.L. Henry, R. Harrison. (1998). Comparison of Microbial Activity and Odor Emissions from Three Different Biosolids Applied to Forest Soil. Brown and Caldwell. Lecture conducted from Seattle Washington.

Paul E. Rosenfeld, Ph.D. Page 7 of 10 October 2021
Rosenfeld, P.E., C.L. Henry. (1998). Characterization, Quantification, and Control of Odor Emissions from Biosolids Application To Forest Soil. Biofest. Lecture conducted from Lake Chelan, Washington.

Rosenfeld, P.E, C.L. Henry, R. Harrison. (1998). Oat and Grass Seed Germination and Nitrogen and Sulfur Emissions Following Biosolids Incorporation With High-Carbon Wood-Ash. Water Environment Federation 12th Annual Residuals and Biosolids Management Conference Proceedings. Lecture conducted from Bellevue Washington.

Rosenfeld, P.E., C.L. Henry, R. B. Harrison, and R. Dills. (1997). Comparison of Odor Emissions From Three Different Biosolids Applied to Forest Soil. Soil Science Society of America. Lecture conducted from Anaheim California.

Teaching Experience:

UCLA Department of Environmental Health (Summer 2003 through 20010) Taught Environmental Health Science 100 to students, including undergrad, medical doctors, public health professionals and nurses. Course focused on the health effects of environmental contaminants.

National Ground Water Association, Successful Remediation Technologies. Custom Course in Sante Fe, New Mexico. May 21, 2002. Focused on fate and transport of fuel contaminants associated with underground storage tanks.

National Ground Water Association; Successful Remediation Technologies Course in Chicago Illinois. April 1, 2002. Focused on fate and transport of contaminants associated with Superfund and RCRA sites.

California Integrated Waste Management Board, April and May, 2001. Alternative Landfill Caps Seminar in San Diego, Ventura, and San Francisco. Focused on both prescriptive and innovative landfill cover design.

UCLA Department of Environmental Engineering, February 5, 2002. Seminar on Successful Remediation Technologies focusing on Groundwater Remediation.

University Of Washington, Soil Science Program, Teaching Assistant for several courses including: Soil Chemistry, Organic Soil Amendments, and Soil Stability.

U.C. Berkeley, Environmental Science Program Teaching Assistant for Environmental Science 10.

Academic Grants Awarded:

California Integrated Waste Management Board. $41,000 grant awarded to UCLA Institute of the Environment.

Goal: To investigate effect of high carbon wood ash on volatile organic emissions from compost. 2001.

Synagro Technologies, Corona California: $10,000 grant awarded to San Diego State University.

Goal: investigate effect of biosolids for restoration and remediation of degraded coastal sage soils. 2000.

King County, Department of Research and Technology, Washington State. $100,000 grant awarded to University of Washington: Goal: To investigate odor emissions from biosolids application and the effect of polymers and ash on VOC emissions. 1998.

Northwest Biosolids Management Association, Washington State. $20,000 grant awarded to investigate effect of polymers and ash on VOC emissions from biosolids. 1997.

James River Corporation, Oregon: $10,000 grant was awarded to investigate the success of genetically engineered Poplar trees with resistance to round-up. 1996.

Paul E. Rosenfeld, Ph.D. Page 8 of 10 October 2021
United State Forest Service, Tahoe National Forest: $15,000 grant was awarded to investigating fire ecology of the Tahoe National Forest. 1995.

Kellogg Foundation, Washington D.C. $500 grant was awarded to construct a large anaerobic digester on St. Kitts in West Indies. 1993
Deposition and/or Trial Testimony:

In the Circuit Court Of The Twentieth Judicial Circuit, St Clair County, Illinois Martha Custer et al., Plaintiff vs. Cerro Flow Products, Inc., Defendants Case No.: No. 0i9-L-2295
Rosenfeld Deposition, 5-14-2021
Trial, October 8-4-2021
In the Circuit Court of Cook County Illinois
Joseph Rafferty, Plaintiff vs. Consolidated Rail Corporation and National Railroad Passenger Corporation d/b/a AMTRAK,
Case No.: No. 18-L-6845
Rosenfeld Deposition, 6-28-2021
In the United States District Court For the Northern District of Illinois Theresa Romcoe, Plaintiff vs. Northeast Illinois Regional Commuter Railroad Corporation d/b/a METRA Rail, Defendants
Case No.: No. 17-cv-8517
Rosenfeld Deposition, 5-25-2021
In the Superior Court of the State of Arizona In and For the Cunty of Maricopa Mary Tryon et al., Plaintiff vs. The City of Pheonix v. Cox Cactus Farm, L.L.C., Utah Shelter Systems, Inc.

Case Number CV20127-094749
Rosenfeld Deposition: 5-7-2021
In the United States District Court for the Eastern District of Texas Beaumont Division Robinson, Jeremy et al Plaintiffs, vs. CNA Insurance Company et al.

Case Number 1:17-cv-000508
Rosenfeld Deposition: 3-25-2021
In the Superior Court of the State of California, County of San Bernardino Gary Garner, Personal Representative for the Estate of Melvin Garner vs. BNSF Railway Company.

Case No. 1720288
Rosenfeld Deposition 2-23-2021
In the Superior Court of the State of California, County of Los Angeles, Spring Street Courthouse Benny M Rodriguez vs. Union Pacific Railroad, A Corporation, et al.

Case No. 18STCV01162
Rosenfeld Deposition 12-23-2020
In the Circuit Court of Jackson County, Missouri
Karen Cornwell, Plaintiff, vs. Marathon Petroleum, LP, Defendant.

Case No.: 1716-CV10006
Rosenfeld Deposition. 8-30-2019
In the United States District Court For The District of New Jersey Duarte et al, Plaintiffs, vs. United States Metals Refining Company et. al. Defendant.

Case No.: 2:17-cv-01624-ES-SCM
Rosenfeld Deposition. 6-7-2019

Paul E. Rosenfeld, Ph.D. Page 9 of 10 October 2021
In the United States District Court of Southern District of Texas Galveston Division M/T Carla Maersk, Plaintiffs, vs. Conti 168., Schiffahrts-GMBH & Co. Bulker KG MS “Conti Perdido” Defendant.

Case No.: 3:15-CV-00106 consolidated with 3:15-CV-00237 Rosenfeld Deposition. 5-9-2019
In The Superior Court of the State of California In And For The County Of Los Angeles – Santa Monica Carole-Taddeo-Bates et al., vs. Ifran Khan et al., Defendants Case No.: No. BC615636
Rosenfeld Deposition, 1-26-2019
In The Superior Court of the State of California In And For The County Of Los Angeles – Santa Monica The San Gabriel Valley Council of Governments et al. vs El Adobe Apts. Inc. et al., Defendants Case No.: No. BC646857
Rosenfeld Deposition, 10-6-2018; Trial 3-7-19

In United States District Court For The District of Colorado Bells et al. Plaintiff vs. The 3M Company et al., Defendants Case No.: 1:16-cv-02531-RBJ
Rosenfeld Deposition, 3-15-2018 and 4-3-2018
In The District Court Of Regan County, Texas, 112th Judicial District Phillip Bales et al., Plaintiff vs. Dow Agrosciences, LLC, et al., Defendants Cause No.: 1923
Rosenfeld Deposition, 11-17-2017
In The Superior Court of the State of California In And For The County Of Contra Costa Simons et al., Plaintiffs vs. Chevron Corporation, et al., Defendants Cause No C12-01481
Rosenfeld Deposition, 11-20-2017
In The Circuit Court Of The Twentieth Judicial Circuit, St Clair County, Illinois Martha Custer et al., Plaintiff vs. Cerro Flow Products, Inc., Defendants Case No.: No. 0i9-L-2295
Rosenfeld Deposition, 8-23-2017
In United States District Court For The Southern District of Mississippi Guy Manuel vs. The BP Exploration et al., Defendants
Case: No 1:19-cv-00315-RHW
Rosenfeld Deposition, 4-22-2020
In The Superior Court of the State of California, For The County of Los Angeles Warrn Gilbert and Penny Gilber, Plaintiff vs. BMW of North America LLC Case No.: LC102019 (c/w BC582154)
Rosenfeld Deposition, 8-16-2017, Trail 8-28-2018
In the Northern District Court of Mississippi, Greenville Division Brenda J. Cooper, et al., Plaintiffs, vs. Meritor Inc., et al., Defendants Case Number: 4:16-cv-52-DMB-JVM
Rosenfeld Deposition: July 2017

Paul E. Rosenfeld, Ph.D. Page 10 of 10 October 2021
In The Superior Court of the State of Washington, County of Snohomish Michael Davis and Julie Davis et al., Plaintiff vs. Cedar Grove Composting Inc., Defendants Case No.: No. 13-2-03987-5
Rosenfeld Deposition, February 2017
Trial, March 2017
In The Superior Court of the State of California, County of Alameda Charles Spain., Plaintiff vs. Thermo Fisher Scientific, et al., Defendants Case No.: RG14711115
Rosenfeld Deposition, September 2015
In The Iowa District Court In And For Poweshiek County
Russell D. Winburn, et al., Plaintiffs vs. Doug Hoksbergen, et al., Defendants Case No.: LALA002187
Rosenfeld Deposition, August 2015
In The Circuit Court of Ohio County, West Virginia
Robert Andrews, et al. v. Antero, et al.

Civil Action N0. 14-C-30000
Rosenfeld Deposition, June 2015
In The Iowa District Court For Muscatine County
Laurie Freeman et. al. Plaintiffs vs. Grain Processing Corporation, Defendant Case No 4980
Rosenfeld Deposition: May 2015
In the Circuit Court of the 17th Judicial Circuit, in and For Broward County, Florida Walter Hinton, et. al. Plaintiff, vs. City of Fort Lauderdale, Florida, a Municipality, Defendant.

Case Number CACE07030358 (26)
Rosenfeld Deposition: December 2014
In the County Court of Dallas County Texas
Lisa Parr et al, Plaintiff, vs. Aruba et al, Defendant.

Case Number cc-11-01650-E
Rosenfeld Deposition: March and September 2013
Rosenfeld Trial: April 2014
In the Court of Common Pleas of Tuscarawas County Ohio
John Michael Abicht, et al., Plaintiffs, vs. Republic Services, Inc., et al., Defendants Case Number: 2008 CT 10 0741 (Cons. w/ 2009 CV 10 0987) Rosenfeld Deposition: October 2012
In the United States District Court for the Middle District of Alabama, Northern Division James K. Benefield, et al., Plaintiffs, vs. International Paper Company, Defendant.

Civil Action Number 2:09-cv-232-WHA-TFM
Rosenfeld Deposition: July 2010, June 2011
In the Circuit Court of Jefferson County Alabama
Jaeanette Moss Anthony, et al., Plaintiffs, vs. Drummond Company Inc., et al., Defendants Civil Action No. CV 2008-2076
Rosenfeld Deposition: September 2010
In the United States District Court, Western District Lafayette Division Ackle et al., Plaintiffs, vs. Citgo Petroleum Corporation, et al., Defendants.

Case Number 2:07CV1052
Rosenfeld Deposition: July 2009

MEMORANDUM
To: Planning Commission
From: Escarlet Mar, Associate Planner
Date: May 12, 2022
Re: NERSP PCL 25 – Sutter Parking Garage Expansion – Response to Comments, File #PL22-0024
Planning staff received a letter from Lozeau Drury on May 11, 2022 challenging the determination that an Initial Study which led to a Negative Declaration was not the appropriate environmental document for the NERSP PCL 25 – Sutter Parking Garage Expansion project at 12 Medical Plaza.

The following memorandum discusses the major points presented in the Lozeau Drury letter and staff’s response. The letter is included as Attachment 1 of this Memorandum.

Assertion: The proposed Conditions of Approval contained an environmental mitigation measure that was not discussed or incorporated in the Negative Declaration of the Project.

Response: The commenter references proposed Condition of Approval 3 from the Planning Commission staff report, and alleges that if the project must comply with mitigation from the Mitigated Negative Declaration prepared for Medical Office Building 6 (MOB 6), then a Negative Declaration for the proposed project is incorrect. However, the Mitigated Negative Declaration for MOB 6 is inapplicable to the proposed project, and this condition of approval was included in the staff report as an error, resulting from using the MOB 6 conditions as a template to begin developing appropriate conditions for the proposed project. Therefore, staff proposes to remove condition of approval #3 from the Design Review Permit as shown in strikeout text below.

3. The project shall comply with all required environmental mitigation identified in Sutter Roseville MOB 6 and Parking Garage Mitigated Negative Declaration, and shall include all applicable mitigation measures as notes on the grading plans. (All Departments) Assertion: The Project may have potentially significant indoor air quality impacts from emissions of formaldehyde.

Response: The commenter alleges that the analysis of air quality is flawed because there is no discussion of formaldehyde impacts related to indoor air quality. To support this the letter supplies comments from a Certified Industrial Hygienist. The letter asserts that people in the building will be exposed to high levels of off-gassed formaldehyde from the decomposition of composite wood products used to construct buildings, and that this will result in a cancer risk for employees of 17.7 per million. The commenter alleges that its expert, Mr. Offermann, has determined that the Project’s indoor emissions of formaldehyde constitute a significant CEQA impact, even if it uses typical materials and construction methods which meet the California Air DEVELOPMENT SERVICES DEPARTMENT – PLANNING DIVISION
311 Vernon Street, Roseville, CA 95678 (916) 774-5276
Resources Board (CARB) formaldehyde airborne toxics control measure. Mr. Offermann cites his own 2009 study (the California New Home Study) and a 2020 study (Indoor Air Quality in new California Homes with Mechanical Ventilation by Singer et al) in arriving at his estimated cancer risk value.

These studies are not applicable to the proposed project for several reasons. The homes in the cited studies were constructed prior to many current mandatory regulations which reduce formaldehyde in construction materials. These include the following:
• Effective February 10, 2017 the Federal Environmental Protection Agency (EPA) final rule to reduce exposure to formaldehyde emissions from certain wood products produced domestically or imported into the United States became effective. EPA worked with CARB to help ensure the final national rule was consistent with California’s requirements for similar composite wood products.
• The Composite Wood Products Regulation is a California Air Resources Board (CARB) regulation that reduces public exposure to formaldehyde through the establishment of strict emission performance standards on particleboard, medium density fiberboard and hardwood plywood (collectively known as composite wood products). The regulation requires all finished goods, such as flooring, destined for sale or use in California to be made using complying composite wood products. The most stringent (Phase 2) standards became effective in January 2014, ensuring that only compliant products are legal for sale in California. Moreover, the state’s Title 24 Building Code improves indoor air quality through ventilation and air filtration requirements, which became more stringent with the adoption of the current 2019 Title 24 Building Code.

While the second study cited by Mr. Offermann was published in 2020, it assessed homes built in 2011 to 2017, which covers the period before the newest CARB formaldehyde standards (Phase 2 standards) were put into place (2014), before the EPA final rule, and before the 2019 Building Code. Thus, these studies do not provide evidence that the project, which will be built in phases beginning in 2022, will have significant impacts from formaldehyde emissions. In addition, both studies cited by Mr. Offermann was based on residential construction and residential grade mechanical ventilation, not based on the enhanced ventilation systems used by hospitals and other medical facilities. For these reasons, the project can be distinguished from the homes studied in the cited studies.

Mr. Offermann’s claim that the project would result in significant impacts is speculative, based on assumptions about project construction and materials, regarding health risk modeling of formaldehyde, regarding the applicability of residential ventilation systems to medical office systems, and regarding application of a significance threshold that is not specific to formaldehyde.

Assertion: The Project did not adequately analyze and mitigate noise impacts.

Response: The commenter makes several claims related to noise: the prior environmental documents referenced in the Initial Study are not available for review, the Initial Study does not establish thresholds of significance, the Initial Study does not adequately address noise from mechanical equipment, and the Initial Study does not adequately address construction noise.

The commenter relies on information provided by Ms. Deborah Jue of Wilson Ihrig Acoustics, Noise, and Vibration to support these claims.

The General Plan Final EIR and the Northeast Roseville Specific Plan EIR are both available on the City’s website. The Sutter Roseville Medical Center Master Plan EIR is available for review in hard copy. Thus, all three referenced environmental documents are available for review.

As described on Initial Study page 33, the City’s noise thresholds used for environmental analysis are established within the General Plan Noise Element and the City’s Noise Ordinance.

The Initial Study states that the Noise Ordinance standards are used to regulate nontransportation (also known as fixed) noise sources, and that compliance with these standards ensures less than significant impacts. Thus, Ms. Jue is not correct that the Initial Study does not discuss or disclose the City’s noise thresholds.

Ms. Jue alleges that mechanical equipment could result in substantial noise (citing the City’s noise thresholds to do so) affecting sensitive receptors at the nearest residential building, described as being 120 feet away. However, the existing Sutter Medical Office Building 4 is located just 45 feet away from apartment buildings in this same apartment complex, includes the same mechanical equipment as the proposed project, and yet existing conditions do not violate the City’s noise thresholds or standards. It can be seen with certainty that the project does not have the potential to result in significant noise impacts related to mechanical equipment. The analysis Ms. Jue provides is speculative, as it makes assumptions about the type of equipment that will be used and the manner in which it will be used, and also does not take into account any of the screening or noise attenuation provided by the masonry wall, standard exterior-to-interior noise reductions, or equipment cabinets or screening.

As discussed in the Initial Study on page 34, construction noise is regulated by the City of Roseville Noise Ordinance. The Ordinance requires construction noise be limited to daytime hours, in order to prevent noise during typical sleeping or rest hours, and that equipment noise be minimized. The City’s adopted CEQA Implementing Procedures findings indicate that compliance with the City Noise Ordinance is sufficient to protect nearby sensitive receptors from the negative health effects from construction noise. There are no unique characteristics of the project that would result in construction noise which is greater than typical construction. Time-ofday restrictions are typical of City and County noise ordinances and reflect the recognition that construction-related noise is temporary in character, is generally acceptable when limited to daytime hours, and is part of what residents of urban areas expect as part of a typical urban noise environment (along with sirens, etc.).

Assertion: The Project did not appropriately analyze the air quality impacts from emissions of ROGs.

Response: The commenter retained a consulting firm, SWAPE Technical Consultation, Data Analysis and Litigation Support of the Environment to review the air quality modeling for the project. SWAPE evaluated the City’s analysis and prepared its own California Emissions Estimator Model (CalEEMod). The analysis by SWAPE did find a size error in the model, but their amended model also contains incorrect data, such as an incorrect size for the parking structure. The City corrected its model to determine whether impacts would remain below the significance thresholds (Attachment 2). The model adjustments ensured the project was accurately described, as follows: a medical office building of 100,000 square feet involving 1.59 acres of land area and a 191,957 (rounded to 192,000) square-foot enclosed parking structure with an elevator involving 0.94 acres of land area. Two model defaults were changed (and are documented in the model outputs), including adjusting the model’s default assumptions about the site acreage to match the actual acreage and adjusting the building construction and finishes timelines because the medical office building will be constructed in two phases (an approximately 85,000 square-foot building followed by an approximately 15,000 square-foot addition at a later date, as described in the Project Description on Initial Study page 1). The corrected model continues to result in less than significant construction impacts: 68 lbs/day of ROG, 25 lbs/day of NOx, and 7.9 lbs/day of PM10. The model outputs are included as Attachment 1 of this memorandum.

Although the commenter alleges the City did not calculate operational emissions, this is not correct. While the project is below the screening threshold as reported within the Initial Study, the CalEEMod results attached to the Initial Study as Attachment 3 includes operational emissions. The modeling results attached to the Initial Study as well as the corrected model results both show that emissions are below thresholds, validating the screening determination.

Assertion: The Project did not appropriately analyze the greenhouse gas (GHG) impacts. (Note:

There was no section V in the letter)
Response: The commenter asserts the City improperly relied on the General Plan Update EIR to conclude that impacts would be less than significant. While the commenter states that the City merely stated that the impacts were less than significant because of compliance with General Plan policies, this is not an accurate representation of the analysis. As stated on Initial Study page 26, the vehicle trips and vehicle miles traveled (VMT) resulting from full buildout of the Sutter Hospital campus was evaluated as part of the citywide analysis prepared for the General Plan Update EIR. Similarly, full buildout of the Sutter Hospital campus was evaluated as part of the citywide buildout analysis of non-mobile greenhouse gas emissions. Thus, emissions from the project are not a new, project-specific impact requiring analysis, and per the tiering provisions of CEQA additional environmental analysis is not required. It is explicitly stated in the General Plan Update EIR that the EIR will be used by future projects for this tiering.

Assertion: The Project did not consider renewal energy alternatives.

Response: The commenter alleges the Initial Study had an obligation to evaluate whether any renewable energy features could be incorporated into the project. There is no such obligation; instead, CEQA requires an analysis of whether a project would result in “inefficient, wasteful, and unnecessary consumption of energy” as part of an EIR. This could certainly include assessment of the applicability of renewable energy features, as it did in the court case cited by the commenter, but since this is not an EIR it is a moot point. The relevant section is Public Resources Code §21100(b)(3), which states “The environmental impact report shall include a detailed statement setting forth all of the following,” after which is listed the requirement to assess the wasteful use of energy. The cited court case also relied heavily on CEQA Guidelines Section 15126.2, which is part of Article 9 Contents of Environmental Impact Reports.

In conclusion, staff finds that the Initial Study/Negative Declaration remains the appropriate document to comply with CEQA. No new or substantially more severe impacts have been identified which would necessitate the preparation of a subsequent or supplemental EIR.

Attachments

1. Lozeau Drury LLP letter, Received via email on May 11, 2022

2. Revised CalEEMod Report

VIA EMAIL ONLY
May 11, 2022
Robert Jense, Chair
Jonathan Martin, Vice Chair
Erich Brashears
Justin Caporusso
Tracy Covington
Clifford Haggenjos, Jr.

John Prior
Planning Commission
City of Roseville
311 Vernon Street
Roseville, CA 95678
[email protected]
Escarlet Mar, Associate Planner
Planning Division
City of Roseville
311 Vernon Street
Roseville, CA 95678
[email protected]
Re: Sutter Parking Garage Expansion and Medical Office Building 7 Negative Declaration (File Nos. PL22-0024, PL22-0061)
Planning Commission Agenda Item 6.2 (May 12, 2022)
Dear Chair Jense, Vice Chair Martin, Honorable Planning Commissioners, and Ms. Mar, I am writing on behalf of the Laborers International Union of North America, Local Union 185 and its members (“LIUNA”) living in and around the City of Roseville (“City”) regarding the Negative Declaration (“ND”) prepared for the Sutter Parking Garage Expansion and Medical Office Building 7 Project (“Project”) (File Nos. PL22-0024, PL22-0061) to be heard as Agenda Item 6.2 at the Planning Commission’s May 12, 2022 meeting.

LIUNA’s review of the ND was assisted by indoor air quality expert Francis Offermann, PE, CIH, noise expert Deborah Jue of Wildon Ihrig, and air quality experts Matt Hagemann, P.G., C.Hg., and Paul E. Rosenfeld, Ph.D., of the Soil/Water/Air Protection Enterprise (“SWAPE”). The written comments of Mr. Offermann, Ms. Jue, and SWAPE are attached hereto as Exhibit A, Exhibit B and Exhibit C, respectively. Based on their review, it appears that several of the MND’s conclusions are not supported by substantial evidence and, moreover, there is a “fair argument” that the Project may have unmitigated adverse environmental impacts. As required by CEQA, LIUNA requests that the City prepare an environmental impact report (“EIR”) rather than a ND prior to approving the Project.

ATTACHMENT 1
LIUNA Comment
Sutter Parking Garage Expansion & MOB 7 (File Nos. PL22-0024, PL22-0061) May 11, 2022