D - Attach 1 Ex B FEIR — San Leandro City Council, May 5, 2025 (part 1 of 3)

880 Doolittle Drive Industrial Project
Final Environmental Impact Report
PLN22-0039
State Clearinghouse No. 2023110597
prepared by
City of San Leandro
835 East 14th Street
San Leandro, California 94577
Contact: Cindy Lemaire, AICP, CNU-A, Senior Planner
prepared with the assistance of
Rincon Consultants, Inc.
66 Franklin Street, Suite 300
Oakland, California 94607
December 2024
880 Doolittle Drive Industrial Project
Final Environmental Impact Report
PLN22-0039
State Clearinghouse No. 2023110597
prepared by
City of San Leandro
835 East 14th Street
San Leandro, California 94577
Contact: Cindy Lemaire, AICP, CNU-A, Senior Planner
prepared with the assistance of
Rincon Consultants, Inc.
66 Franklin Street, Suite 300
Oakland, California 94607
December 2024
This page intentionally left blank.

Table of Contents
Final Environmental Impact Report i
Table of Contents
1 Introduction .................................................................................................................................... 1

1.1 Purpose of the Response to Comments Document ............................................................ 1

1.2 Environmental Review Process ........................................................................................... 1

1.3 Document Organization ...................................................................................................... 2 2 List of Commenters ......................................................................................................................... 3

2.1 Organization of Comment Letters and Responses ............................................................. 3

2.2 Comments Received ........................................................................................................... 3 3 Comments and Responses .............................................................................................................. 4 4 Revisions to the Draft EIR ...........................................................................................................517 City of San Leandro
880 Doolittle Drive Industrial Project
ii
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Final Environmental Impact Report
Response to Comments Document
1 Introduction

1.1 Purpose of the Response to Comments Document
This Response to Comments (RTC) document provides responses to public and agency written comments received by the City of San Leandro on the Draft Environmental Impact Report (EIR) for the proposed 880 Doolittle Drive Industrial Project (project). The Draft EIR identifies the likely environmental consequences associated with development of the proposed project and recommends mitigation measures to reduce potentially significant impacts. In addition to providing responses to public and agency comments received on the Draft EIR, this RTC document also makes revisions to the Draft EIR, as necessary, in response to those comments or to make clarifications to information presented in the Draft EIR. This document, together with the Draft EIR, constitutes the Final EIR for the proposed project.

1.2 Environmental Review Process
Pursuant to the California Environmental Quality Act (CEQA), lead agencies are required to consult with public agencies having jurisdiction over a proposed project and to provide the general public with an opportunity to comment on the Draft EIR.

On November 21, 2023, the City of San Leandro circulated a Notice of Preparation (NOP) for a 30- day period to identify environmental issue areas potentially affected if the proposed project were to be implemented. The NOP was mailed or otherwise provided to public agencies, the State Clearinghouse, organizations, and individuals considered likely to be interested in the proposed project and its potential impacts. Comments received by the City of San Leandro on the NOP are provided in Appendix B of the Draft EIR and are summarized in Table 1-1 of the Draft EIR. These comments were taken into account during the preparation of the Draft EIR and the Initial Study, which is provided as Appendix A to the Draft EIR.

The Draft EIR was made available for public review on June 21, 2024. Copies of the Notice of Availability of the Draft EIR were mailed to a list of interested parties, groups and public agencies.

The Draft EIR was posted with the State Clearinghouse for distribution to applicable state agencies.

The Draft EIR and an announcement of its availability were posted electronically on the City’s website, and a paper copy of the Draft EIR was available for public review at the San Leandro Community Development Department and at the San Leandro Community Library. The Notice of Availability of the Draft EIR was published in the East Bay Times on June 21, 2024, and also posted at the office of the Alameda County Clerk.

The City of San Leandro received seven comment letters on the Draft EIR during the 45-day comment period, which began on June 21, 2024 and ended on August 5, 2024. Following August 5, 2024, the City was informed that it used outdated contact information when sending notification of the Draft EIR to Pacific Gas & Electric (PG&E). The City subsequently forwarded the notification to PG&E and accepted a late comment letter from PG&E for this reason. Likewise, one of the commenters provided a supplemental comment letter after the closure of the comment period, which the City chose to accept. Therefore, a total of nine comment letters were received and 1 City of San Leandro
880 Doolittle Drive Industrial Project
Final Environmental Impact Report
Response to Comments Document
accepted on the Draft EIR. Copies of the nine written comments on the Draft EIR, as well as responses to those comments, are included in Section 3 of this document.

1.3 Document Organization
This RTC document consists of the following sections:
 Section 1: Introduction. This section discusses the purpose and organization of this RTC Document and the Final EIR, and summarizes the environmental review process for the project.
 Section 2: List of Commenters. This section contains a list of the agencies and private groups and organizations that submitted written comments during the public review period on the Draft EIR. No comments were received from individuals.
 Section 3: Comments and Responses. This section contains reproductions of all comment letters received on the Draft EIR. A written response for each CEQA-related comment received during the public review period is provided. Each response is keyed to the corresponding comment.
 Section 4: Draft EIR Revisions. Revisions to the Draft EIR that are necessary in light of the comments received and responses provided, or necessary to amplify or clarify material in the Draft EIR, are contained in this section. Underlined text represents language that has been added to the Draft EIR; text with strikeout formatting has been deleted from the Draft EIR.
2 Final Environmental Impact Report
Response to Comments Document
2 List of Commenters
This section presents a list of comment letters received during the public review period and describes the organization of the letters and comments that are provided in Section 3, Comments and Responses, of this document.

2.1 Organization of Comment Letters and Responses
The nine letters are presented in the following order: state agencies (1), regional and local public agencies (3, including a supplemental letter), and private groups and organizations (5). No federal agencies and no individuals provided written comments. Each comment letter has been numbered sequentially and each separate issue raised by the commenter has been assigned a number. The responses to each comment identify first the number of the comment letter, and then the number assigned to each issue. For example, Response 1.1 indicates that the response is for the first issue raised in comment Letter 1.

2.2 Comments Received
The following letters were submitted to the City during the public review period:

Letter Number and Commenter Agency/ Group/ Organization Page
Number

3. Colleen Liang, Director of Environmental Programs and Planning
Port of Oakland
3b. Colleen Liang, Director of Environmental Programs
and Planning
Port of Oakland

7. Claudia Tarpin, Director of Development Prologis

8. Vince Fazzi, Land Agent Pacific Gas & Electric Company (PG&E) State Agencies

1. Yunsheng Luo, District Branch Chief California Department of Transportation 5 Regional and Local Agencies

2. David J. Rehnstrom, Manager of Water Distribution East Bay Municipal Utility District 10 Planning
18 25
Private Groups and Organizations

4. Dean Wallraff, Executive Director Advocates for the Environment 31

5. Gary Ho Blum Collins & Ho LLP 47

6. Jeremy Herwitt Mitchell M. Tsai Law Firm 216
510
514
3 Final Environmental Impact Report
Response to Comments Document
3 Comments and Responses
Written responses to each comment letter received on the Draft EIR are provided in this section. All letters received during the public review period on the Draft EIR are provided in their entirety.

Text within individual letters that has not been numbered for reference in the responses does not specifically raise environmental issues nor relate directly to the adequacy of the information or analysis within the Draft EIR, and therefore no comment is enumerated or response required, pursuant to State CEQA Guidelines sections 15088 and 15132.

Revisions to the Draft EIR necessary in light of the comments received and responses provided, or necessary to amplify or clarify material in the Draft EIR, are included in the responses. Underlined text represents language that has been added to the Draft EIR; text with strikeout has been deleted from the Draft EIR. All revisions are then compiled in the order in which they would appear in the Draft EIR (by page number) in Section 4, Draft EIR Text Revisions, of this document. Page numbers cited in this section correspond to the page numbers of the Draft EIR. When mitigation measure language has been changed, it has been changed in both the text on the stated Draft EIR page and the summary table (Table 1) in the Executive Summary of the Draft EIR. 4 “Provide a safe and reliable transportation network that serves all people and respects the environment.” DISTRICT 4

OFFICE OF REGIONAL AND COMMUNITY PLANNING
P.O. BOX 23660, MS–10D | OAKLAND, CA 94623-0660
www.dot.ca.gov
August 5, 2024 SCH #: 2023110597
GTS #: 04-ALA-2023-00830
GTS ID: 31377
Co/Rt/Pm: ALA/61/R15.21
Cindy Lemaire AICP, CNU-A, Senior Planner
City of San Leandro
835 East 14th Street
San Leandro, CA 94577
Re: 880 Doolittle Drive Industrial Project ─ Draft Environmental Impact Report (DEIR) Dear Cindy Lemaire:

Thank you for including the California Department of Transportation (Caltrans) in the environmental review process for the 880 Doolittle Drive Industrial Project. The Local Development Review (LDR) Program reviews land use projects and plans to ensure consistency with our mission and state planning priorities. The following comments are based on our review of the June 2024 DEIR.

Please note this correspondence does not indicate an official position by Caltrans on this project and is for informational purposes only.

Project Understanding
The proposed project involves the demolition of existing vacant warehouse buildings and associated surface parking to construct a new warehouse with supporting office space, site improvements, and landscaping. This project site is in vicinity of State Route (SR)-61 and SR-112.

Hydrology
Some of the project lies in the 0.2% Annual Chance Flood Hazard per 06001C0252H 12/21/2018 Federal Emergency Management Agency (FEMA) Flood Plain Map. Please provide a floodplain analysis report for any documented and mitigated floodplain impacts. Any additional floodplain impacts on existing adjacent properties must be explained.

Please ensure that any increase in storm water runoff to State Drainage Systems or Facilities be treated, contained on project site, and metered to preconstruction levels. 5 Cindy Lemaire AICP, CNU-A, Senior Planner
August 5, 2024

Page 2 ends

“Provide a safe and reliable transportation network that serves all people and respects the environment.” If the project involves drainage work that flows into the State Drainage System, please provide a drainage design memo and show how the proposed drainage system flows on the Plans. The drainage design memo should include pre- and post- project flows to the existing drainage system. The Drainage Plan and Profile Sheets should include lengths, size, and types of new and existing pipes, inlets, outlets, and systems showing any utility conflicts. Please include drainage details and profiles for connection to the existing drainage system. Any assumptions and calculations used in designing the drainage system should be shown.

Freight
Please specify the number of legal trucking spots that would be made available in the area. Given that there are sixty-four loading docks proposed, there should be a specific number of legal truck parking spots as well as identifying potential areas that may be utilized as unauthorized truck parking to mitigate potential truck idling that may occur from the proposed project.

Construction-Related Impacts
Project work that requires movement of oversized or excessive load vehicles on State roadways requires a transportation permit that is issued by Caltrans. To apply, please visit Caltrans Transportation Permits (link). Prior to construction, coordination may be required with Caltrans to develop a Transportation Management Plan (TMP) to reduce construction traffic impacts to the State Transportation Network (STN).

Thank you again for including Caltrans in the environmental review process. Should you have any questions regarding this letter, please contact Melissa Hernandez, Associate Transportation Planner via [email protected]. For future early coordination opportunities or project referrals, please visit Caltrans LDR website (link) or contact LDR[email protected].

Sincerely,

YUNSHENG LUO
Branch Chief, Local Development Review
Office of Regional and Community Planning
c: State Clearinghouse
6 Final Environmental Impact Report
Response to Comments Document
Letter 1
COMMENTER: Yunsheng Luo, District Branch Chief, California Department of Transportation DATE: August 5, 2024
Response 1.1
The commenter notes their appreciation for inclusion in the CEQA process and states their understanding of the proposed project in the form of a summary.

The commenter’s understanding of the proposed project is an accurate summary of the project as proposed and evaluated in the Draft EIR. This comment is noted and does not require revisions to the Draft EIR.

Response 1.2
The commenter states that the proposed project is within the 0.2 percent annual chance floodplain as mapped by the Federal Emergency Management Agency and requests that documentation of floodplain impacts be provided, including impacts on adjacent properties.

The commenter is correct that the proposed project is within the 0.2 percent annual chance floodplain. As described on page 88 of the Initial Study, which is included as Appendix A to the Draft EIR, the eastern most area of the project site is mapped as an area of minimal flood hazard and having a 0.2 percent annual chance to be inundated by flood waters as a result of a storm event, also known as the 500-year flood event. Potential impacts related to the project site’s location within the 0.2 percent annual chance floodplain are evaluated on page 93 of the Initial Study. As described therein, the proposed project would include bioretention areas on-site. Compared with existing conditions, the bioretention areas would increase flood storage on the project site, which currently provides no areas to capture stormwater flows. Commercial warehouse structures, like the proposed project, typically do not routinely use or store large quantities of hazardous materials and pollutants other than those typically used for office cleaning, maintenance, and landscaping.

Thus, as described on page 93 of the Initial Study, inundation of the project site from a flood (or tsunami) would not result in substantial release of pollutants into the environment. Additionally, existing conditions on the site are subject to inundation, and thus the project would not substantially alter existing conditions. For these reasons, flood-related impacts were determined to be less than significant, and no mitigation measures are required. This comment does not question the analysis or conclusions of the Draft EIR, and no revisions to the Draft EIR are necessary in response.

Response 1.3
The commenter requests that increases in stormwater runoff to State Drainage Systems or Facilities resulting from the project be treated, contained on project site, and metered to preconstruction levels.

As described on page 8 of the Initial Study, which is included as Appendix A to the Draft EIR, stormwater runoff on the project site would be treated on site to meet the current Alameda County C.3 stormwater regulations before being discharged to the existing storm drain system. As described on page 93 of the Initial Study, the proposed project would alter the existing drainage pattern of the site. However, the alterations would increase infiltration of precipitation and stormwater runoff 7 City of San Leandro
880 Doolittle Drive Industrial Project
Final Environmental Impact Report
Response to Comments Document
through the addition of pervious landscaping that function as bioretention areas that do not exist under current conditions. Vegetated bioretention systems, like those included in the proposed project, are designed to slow down the velocity and reduce the volume of stormwater runoff using a combination of plants and filter media such as sand, gravel, compost, and soil. Additionally, as discussed on page 93 of the Initial Study, the project would be required to incorporate stormwater control measures and NPDES permit requirements to reduce the amount of runoff that would enter the storm drain system compared to existing conditions. The bioretention areas would be vegetated to prevent erosion or mobilization of soil within the bioretention areas. Vegetated bioretention areas also filter stormwater to reduce the concentration of pollutants mobilized in runoff, thereby reducing pollution in runoff that is discharged into receiving waters via the City’s storm drain system. Accordingly, the proposed project has been designed to treat stormwater runoff and reduce runoff volume compared to existing (i.e., preconstruction) levels. No revisions to the Draft EIR are necessary in response to this comment
Response 1.4
The commenter requests that a drainage design memorandum be provided if the project would involve drainage work flowing into the State Drainage System.

This comment does not question the analysis or conclusions of the Draft EIR. Therefore, no revisions to the Draft EIR are necessary in response to this comment. However, for informational purposes, as described on page 8 of the Initial Study, stormwater runoff would be treated on site to meet the current Alameda County C.3 stormwater regulations before being discharged to the existing storm drain system. On-site treatment would occur with a series of bioswales. After entering on-site bioswales, treated runoff that infiltrates the soil would enter storm drain inlets installed in each bioswale. The inlets would connect to a storm drain pipeline installed beneath new surface parking areas and connect to an existing storm drain through the Doolittle Drive driveway. The existing storm drain beneath the Doolittle Drive driveway is a City facility. Drainage work would not flow into the State Drainage System from the proposed project.

Response 1.5
The commenter requests that the Draft EIR specify the number of legal trucking spots that would be made available in the area and identify potential areas that may be utilized as unauthorized truck parking to mitigate potential truck idling that may occur from the proposed project.

Parking included in the proposed project is described on page 2-13 of the Draft EIR. As described therein, the proposed project would include a surface parking area would be on the north side of the proposed warehouse that provides 59 spaces sized for tractor trailers. Additionally, as described on page 2-4 of the Draft EIR, 64 loading docks are proposed. These loading docks would have a depth of 74 feet. The average length of a tractor-trailer (the semi-truck and trailer combined) is about 72 feet long. Therefore, each loading dock door would also serve as a truck parking space, as needed. The 59 spaces in the surface parking lot and the 64 spaces that would be provided at loading docks would accommodate truck traffic on the project site. No unauthorized truck parking is proposed. Additionally, trucks parking on-site or waiting to park would not be permitted to idle for more than 5 minutes pursuant to Title 13, Section 2480 and 2485 of the California Code of Regulations (13 CCR 2480 & 2485).

The Draft EIR, including the Initial Study that is Appendix A to the Draft EIR, evaluates potential impacts of the project consistent with Appendix G of the State CEQA Guidelines. Appendix G of the State CEQA Guidelines identifies 21 environmental topics for evaluation in CEQA documents and 8 Final Environmental Impact Report
Response to Comments Document
provides a series of impact checklist questions to consider for each topic. Unauthorized parking, as well as legal parking, is not a topic or checklist question included in Appendix G of the State CEQA Guidelines, and parking supply and demand in and of themselves is not an environmental impact topic requiring study under CEQA. Therefore, the Draft EIR is not required to evaluate parking impacts of the project. Appendix G of the State CEQA Guidelines does include a checklist question about a substantial increase in transportation hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible use (e.g., farm equipment) resulting from a project. Unauthorized parking could result in such a hazard depending on where the vehicle was parked. However, as described in the previous paragraph, unauthorized parking is not proposed or anticipated given the project would provide capacity to park approximately 123 tractor trailers. As described on page 4.4-7 of the Draft EIR, impacts related to transportation hazards would be less than significant without mitigation.

As the Draft EIR does specify the number of truck parking spaces and the project would not result in unauthorized truck parking, no revisions to the Draft EIR are required in responses to this comment.

Additionally, the proposed project has been designed to provide the amount of parking required by the San Leandro Municipal Code.

Response 1.6
The commenter states that movement of oversized or excessive load vehicles on State roadways requires a transportation permit issued by Caltrans. The commenter states that prior to construction, coordination may be required with Caltrans to develop a Transportation Management Plan to reduce construction traffic impacts to the State Transportation Network.

This comment does not question the adequacy of the transportation impact analysis in the Draft EIR or suggest revisions to the Draft EIR. Therefore, no additional revisions to the Draft EIR are necessary in response to this comment. However, the City is aware of the regulations for operating on State highways. The project applicant would be responsible for obtaining all regulatory permits and approvals, including permits from Caltrans for the use of oversized or excessive load vehicles on State roadways. Caltrans retains the ability to require the applicant to develop a Transportation Management Plan during the permitting process.

Response 1.7
The commenter provides a point-of-contact if the City has questions regarding their comment letter.

This information is noted.
9 <I[> EAST BAY

MUNICIPAL UTILITY DISTRICT
July 19, 2024
Cindy Lemaire, AUCP, CNU-A, Senior Planner
Community Development Department
City of San Leandro
835 East 14th Street
San Leandro, CA 94577
Re: Notice of Availability of a Draft Environmental Impact Report-880 Doolittle Drive Industrial Project, San Leandro
Dear Ms. Lemaire:

East Bay Municipal Utility District (EBMUD) appreciates the opportunity to comment on the Draft Environmental Impact Report (EIR) for the 880 Doolittle Drive Industrial Project located at 880 Doolittle Drive in the City of San Leandro (City). EBMUD commented on the Notice of Preparation of a Draft EIR for the project on December 18, 2023. EBMUD’s original comments (see enclosure) still apply regarding water service and water conservation.

If you have any questions concerning this response, please contact Timothy R. McGowan, Senior Civil Engineer, Major Facilities Planning Section at (510) 287-1981.

Sincerely,
David J. Rehnstrom
Manager of Water Distribution Planning
DJR:AT:kn
wdpd24_l 18 880 Doolittle Drive Industrial Project.doc
Enclosure: EBMUD’s December 18, 2023 comment letter
375 ELEVENTH STREET . OAKLAND . CA 94607-4240 . TOLL FREE 1-866-40-EBMUD Recycled Paper
<L/_>
10 EAST BAY
<jO MUNICIPAL UTILITY DISTRICT
December 18, 2023
Cindy Lemaire, AICP, CNU-A, Senior Planner
Community Development Department
City of San Leandro
835 East 14th Street
San Leandro, CA 94577
Re: Notice of Preparation for a Draft Environmental Impact Report for the 880 Doolittle Drive Industrial Project (PLN22-0039), San Leandro Dear Ms. Lemaire:

East Bay Municipal Utility District (EBMUD) appreciates the opportunity to comment on the Notice of Preparation (NOP) of a Draft Environmental Impact Report (EIR) for the 880 Doolittle Drive Industrial Project located in the City of San Leandro (City). EBMUD has the following comments.

WATER SERVICE
EBMUD’s Central Pressure Zone, with a service elevation range between 0 and 100 feet, will serve the proposed development. Individual units in a newly built multi-occupancy commercial/industrial premises shall be individually metered. A main extension, at the project sponsor’s expense, may be required to serve the proposed development depending on water and private fire service metering locations and fire flow requirements set by the local fire agency. Please see the attached EBMUD documents for California (Waterworks Standards) Code of Regulations, Title 22, Section 64572 (Water Main Separation) and EBMUD requirements for placement of water mains. When the development plans are finalized, the project sponsor should contact EBMUD’s New Business Office and request a water service estimate to determine costs and conditions for providing water service to the project. Engineering and installation of water mains and services require substantial lead time, which should be provided for in the project sponsor’s development schedule.

EBMUD’s Standard Site Assessment indicates the potential for contaminated soils or groundwater to be present within the project site boundaries. The project sponsor should be aware that EBMUD will not install piping or services in contaminated soil or groundwater (if groundwater is present at any time during the year at the depth piping is to be installed) that must be handled as a hazardous waste or that may be hazardous to the health and safety of construction and maintenance personnel wearing Level D personal protective equipment. Nor will EBMUD install piping or services in areas where groundwater contaminant concentrations exceed specified limits for discharge to the sanitary sewer system and sewage treatment plants. The project sponsor must submit copies to EBMUD of all known information regarding soil and groundwater quality within or adjacent to the 375 ELEVENTH STREET . OAKLAND . CA 94607-4240 . TOLL FREE V866-40-EBMUD 11 project boundary and a legally sufficient, complete, and specific written remediation plan establishing the methodology, planning and design of all necessary systems for the removal, treatment, and disposal of contaminated soil and groundwater.

EBMUD will not design piping or services until soil and groundwater quality data and remediation plans have been received and reviewed and will not start underground work until remediation has been carried out and documentation of the effectiveness of the remediation has been received and reviewed. If no soil or groundwater quality data exists, or the information supplied by the project sponsor is insufficient, EBMUD may require the project sponsor to perform sampling and analysis to characterize the soil and groundwater that may be encountered during excavation. Alternatively, EBMUD may perform such sampling and analysis at the project sponsor’s expense. If evidence of contamination is discovered during EBMUD’s work on the project site, work may be suspended until such contamination is adequately characterized and remediated to EBMUD’s standards.

WATER CONSERVATION
The project presents an opportunity to incorporate water conservation measures. EBMUD requests that the City include in its conditions of approval a requirement that the project sponsor comply with Assembly Bill 325, “Model Water Efficient Landscape Ordinance,” (Division 2, Title 23, California Code of Regulations, Chapter 2.7, Sections 490 through 495). The project sponsor should be aware that Section 31 of EBMUD’s Water Service Regulations requires that water service shall not be furnished for new or expanded service unless all the applicable water-efficiency measures described in the regulation are installed at the project sponsor’s expense.

If you have any questions concerning this response, please contact Timothy R. McGowan, Senior Civil Engineer, Major Facilities Planning Section at (510) 287-1981.

Sincerely,
David J. Rehnstrom
Manager of Water Distribution Planning
DJR:EZ:kn
wdpd23_241 880 Doolittle Drive Industrial Project
Attachment Applicant Pipeline Design Criteria
12 Attachment 1

EAST BAY

MUNICIPAL UTILITY DISTRICT
Applicant Pipeline Design Criteria
EBMUD values applicant pipeline projects and is committedto providing a thorough and efficient design.

To ensure an efficient design process and to avoid significant delays the design criteria below should be adhered to when submitting improvement plans.

Design Criteria
• Watermains shall be seven (7) feet from face of curb. • Watermains shall maintain a minimum one (1) foot vertical and five (5) foot horizontal clearance from other utilities.
• Gas mains shall meetthe one (1) foot vertical separation requirement by installing the gas main below the water main only.
• Watermains shall maintain a minimum ten (10) foot horizontal clearance (O.D. toO.DJand be located a minimum one (1) foot above any sewer main. Title 22 CCR • Watermains shall maintain a minimum four (4) feet horizontal clearance (O.D. toO.D.) and be located a minimum one (1) foot above any storm drain. Title 22 CCR • Watermains shall have a 36-inch cover to final grade and 24-inch cover to pavement subgrade. • Joint trenches that are in conflict with the criteria above may delay the project. Submit to EBMUD final joint trench plans (no intent plans) which include the size of the joint trench and the utilities located inside.
• Watermains shall not be installed under pervious pavement. • Watermains installed under decorative pavement, pavers, or stamped concrete will require an additional paving agreement.
• Hydrants shall not be located on curved sections of street, street corners, or within five feet of a driveway.
• Right of ways for 6-inch and 8-inch water mains shall be a minimum of 20 feet wide and extend five (5) feet past the water main centerline.
• Right of ways for 12-inch to 24-inch water mains shall be a minimum of 20 feet wide and extend eight (8) feet past the water main centerline.

Please contact the New Business Office representative assigned to your project if there are any questions regarding the requirements listed above. Meeting this criteria will enable the most efficient design possible.

March 2021
13 APPLICANT PIPELINE

EBMUD DESIGN CRITERIA
FC FC
grade}
(no pervious PAVEMENT )
subgrade)-
u
[l2"min]
£
{ 5'min ]
I
[l2"min]
{lO'min}
FC= FACE OF CURB

RIGHT OF WAY EXTENDS
«—5' BEYOND APPURTENCES

NO HYDRANTS ON CURVES,

STREET CORNERS, OR
WITHIN 5’ OF DRIVEWAY

JOINT TRENCHES

SHALL NOT

CONFLICT WITH

THE CRITERIA IN

THE DIAGRAM

RIGHT OFWAY
MIN 20'
SD = STORM DRAIN
min 12" below water
min 4' horizontal clearance
SS = SANITARY SEWER
min 12" below water
min 10' horizontal clearance
U = UTILITY
min 12" vertical clearance
min 5' horizontal clearance
W = WATER
24" cover to subgrade
36" cover to final grade
7' inset from face of curb
4203•5/21
14 City of San Leandro
880 Doolittle Drive Industrial Project
Final Environmental Impact Report
Response to Comments Document
Letter 2
COMMENTER: David J Rehnstrom, Manager of Water Distribution Planning, East Bay Municipal Utility District
DATE: July 19, 2024
Response 2.1
The commenter notes their appreciation for the opportunity to comment on the Draft EIR and mentions having submitted comments on the NOP. The commenter indicates that the comments they provided on the NOP continue to apply to the Draft EIR.

This comment does not question the analysis or conclusions of the Draft EIR. Therefore, no revisions to the Draft EIR are necessary in response to this comment. This comment does state that comments provided in response to the NOP also apply to the Draft EIR. Comments received by the City of San Leandro on the NOP are provided in Appendix B of the Draft EIR and are summarized in Table 1-1 of the Draft EIR. These comments were taken into account during the preparation of the Draft EIR and Initial Study, which is provided as Appendix A to the Draft EIR.

Response 2.2
The commenter states that the East Bay Municipal Utility District will provide water service to the project, and individual units in a newly built commercial/industrial building that will be individually metered. The commenter states that a new water main may be required at the project applicant’s expense, and the project applicant should contact East Bay Municipal Utility District when development plans are finalized to obtain a water service estimate and determine the conditions for providing water service to the project.

Proposed utility connections and service for the proposed project are described on page 8 of the Initial Study, which is Appendix A to the Draft EIR. As described on Initial Study page 8, potable water service for the project would be provided by the East Bay Municipal Utility District, the City of San Leandro potable water service provider. A new water connection would be constructed on site and connect to an existing water main that is beneath the surface of the existing driveway at Doolittle Drive. Generally, the new water connection would be located beneath the new surface parking area on the west side of the proposed warehouse. A new fire hydrant pipeline would also connect to the existing water main in the project area in accordance with City code and requirements.

Because the East Bay Municipal Utility District would be the potable water service provider, the project applicant must by default work and coordinate with the East Bay Municipal Utility District on the final design and approval of the potable water service connections and mains. Additionally, the City is not responsible for development costs of the project, including costs that may be associated with the provision of potable water to the project. The applicant must provide payment of costs associated with potable water service directly to the East Bay Municipal Utility District.

This comment does not question the analysis or conclusions of the Draft EIR. Therefore, no revisions to the Draft EIR are necessary in response to this comment. 15 Final Environmental Impact Report
Response to Comments Document
Response 2.3
The commenter states that there is potential for contaminated soils or groundwater to be present at the project site, and that East Bay Municipal Utility District will not install piping or water services in contaminated soil or groundwater that is considered hazardous.

The Draft EIR describes the potential for hazardous materials to exist on the project site in the form of contaminated soil and groundwater. Specifically, page 4.2-2 of the Draft EIR states that the project site is considered a hazardous site due to subsurface contamination with chlorinated volatile organic compounds. As described on page 4.2-4 of the Draft EIR, a Land Use Covenant (LUC) for the project site was filed with Alameda County in 2012 that requires DTSC approval of planned future use of groundwater at the project site and a Soil Management Plan prior to planned disturbance of subsurface soil in two limited areas of the site.

The City understands that East Bay Municipal Utility District will not install piping or water services in contaminated soil or groundwater that is considered hazardous. As shown on Figure 2-7 on page 2-15 of the Draft EIR, the proposed water connections would be installed in the western area of the project site, extending from a main within Doolittle Drive. As shown on Figure 4.2-2 on page 4.2-5 of the Draft EIR, the area where chlorinated volatile organic compounds in soils exceeds health screening levels in in the eastern area of the site. The project does not include installing a water main or connections within the contaminated soils area. Additionally, pursuant to Mitigation Measure HAZ-2, field screening of soils must be conducted continuously during ground disturbing activities, which would prevent excavation and installation of water connections in contaminated soils if present elsewhere on the project site but not yet known. No further revisions to the Draft EIR are required in response to this comment.

Response 2.4
The commenter states that the project applicant must provide the East Bay Municipal Utility District with all known information regarding soil and groundwater quality at and adjacent to the project site, as well as a legally sufficient and specific written remediation plan for the removal, treatment, and disposal of contaminated soil and groundwater. The commenter states that East Bay Municipal Utility District will not design piping or services until soil and groundwater quality data and remediation plans have been received and will not start underground work until remediation has been carried out and documentation of the effectiveness of the remediation has been received. 16 City of San Leandro
880 Doolittle Drive Industrial Project
Final Environmental Impact Report
Response to Comments Document
This comment pertains to construction protocol and coordination that must occur between the project applicant and East Bay Municipal Utility District in order for water services to be provided to the project. This comment does not question the analysis or conclusions of the Draft EIR. Therefore, no revisions to the Draft EIR are necessary in response to this comment. However, for informational purposes, the Draft EIR includes mitigation measures that require ongoing remediation during project construction, such as Mitigation Measure HAZ-2 (see Response 2.3, above). As described on page 4.2-16 of the Draft EIR, Mitigation Measure HAZ-2 requires the project applicant to continue to utilize Department of Toxic Substances Control for agency oversight of assessment and remediation of the project site through completion of construction activities. The project applicant may choose to submit Department of Toxic Substances Control documentation to East Bay Municipal Utilities District or other documentation as requested.

Response 2.5
The commenter states that if no soil or groundwater quality data exists, or the information supplied to East Bay Municipal Utility District by the project sponsor is insufficient, East Bay Municipal Utility District may require the project applicant to perform soil and groundwater sampling and analysis.

Alternatively, the commenter states that East Bay Municipal Utility District may perform such sampling and analysis at the project sponsor’s expense. If evidence of contamination is discovered, work may be suspended until such contamination is adequately characterized and remediated to East Bay Municipal Utility District standards.

This comment pertains to construction protocol and coordination that must occur between the project applicant and East Bay Municipal Utility District in order for water services to be provided to the project. This comment does not question the analysis or conclusions of the Draft EIR. Therefore, no revisions to the Draft EIR are necessary in response to this comment. Because the East Bay Municipal Utility District would be the potable water service provider, the project applicant must by default provided the East Bay Municipal Utility District with requested materials and fees in order for potable water provisions.

Response 2.6
The commenter requests that the City include in its conditions of approval a requirement that the project comply with Assembly Bill 325, “Model Water Efficient Landscape Ordinance,” (Division 2, Title 23, California Code of Regulations, Chapter 2.7, Sections 490 through 495). The commenter states that East Bay Municipal Utility District cannot provide new or expanded water service unless all applicable water-efficiency measures described in the regulations are installed by the applicant.

This comment pertains to coordination of project design and landscaping that must occur between the project applicant and East Bay Municipal Utility District in order for water services to be provided to the project. This comment does not question the analysis or conclusions of the Draft EIR. Therefore, no revisions to the Draft EIR are necessary in response to this comment. However, for informational purposes, as described on page 2-13 of the Draft EIR, the proposed project would comply with water efficient landscape requirements and would plant species appropriate for the local climate that contribute to conserving outdoor water use. Additionally, like all projects in San Leandro, the proposed project must comply with federal, state, and local laws and regulatory requirements, including the California Code of Regulations. 17 530 Water Street  P.O. Box 2064  Oakland, California 94604-2064 www.portofoakland.com
August 5, 2024
Ms. Cindy Lemaire
City of San Leandro
835 East 14th Street
San Leandro, California 94577
Transmitted via email: [email protected]
Subject: Draft Environmental Impact Report (DEIR) for Project PLN22-0039 (880 Doolittle Drive) Comments
Dear Ms. Lemaire:

The Port of Oakland (Port) appreciates this opportunity to comment on the Proposed Draft Environmental Impact Report (DEIR) for Project PLN22-0039 at 880 Doolittle Drive (Proposed Project). The Port provides the following comments for the city of San Leandro’s (the City) consideration on the DEIR.

Renamed Metropolitan Oakland International Airport
The Port generates vital economic activity, community benefits and environmental innovation, as the Port decarbonizes its operations for a cleaner and greener future. Along with its partners, the Port supports 98,345 jobs in the region and $174 billion in annual economic activity. The Port oversees San Francisco Bay Oakland International Airport (OAK or Airport), the Oakland Seaport and nearly 20 miles of waterfront including Jack London Square and is a publicly owned utility.

On May 9, 2024, the Board of Port Commissioners renamed the “Metropolitan Oakland International Airport” to “San Francisco Bay Oakland International Airport”. OAK is the main airport for the greater East Bay. Incorporation of the Airport’s location on the “San Francisco Bay” into its formal name increases awareness of its geography while retaining the Airport’s existing brand. The Port requests the new OAK name be reflected throughout the DEIR.

The ALUC did not hold a hearing or provide a determination for the Proposed Project; therefore, no comments were issued by the ALUC. The Port requests removal of any references in the DEIR 18 Cindy Lemaire August 5, 2024
Re: Project PLN22-0039 DEIR
2 document that imply the ALUC approved or commented on this Proposed Project. The Port recommends the City coordinate with ALUC for a formal determination on the Proposed Project.

Additionally, the Port recommends the City coordinate with the Alameda County Community Development Agency, Planning Department, as an administrative department of the County on the Proposed Project.

OAK Airport Land Use Compatibility Planning (ALUCP)
The Airport Land Use Compatibility Plan (ALUCP) is the primary document used by the ALUC to promote compatibility between OAK and its environs. The intent of the ALUCP is to encourage compatibility between airports and the various land uses that surround them.  There are four primary criteria for evaluating the compatibility of proposed land use in the Airport Influence Area (AIA): Airspace Protection Zones, Overflight Zones, Noise, and Safety.

Airspace Protection Zones
According to the OAK ALUCP, the Proposed Project must comply with safety zone guidelines and height restrictions to prevent any interference with airport operations. This includes ensuring that structures do not penetrate navigable airspace as defined by Federal Aviation Regulation (FAR) Part 77.

The Port conducted a preliminary airspace impact analysis of the proposed permanent structure height of 50 feet and the construction crawler crane with a maximum height of 161 feet as outlined in the DEIR. Our analysis indicates that the proposed height of the crawler crane would have adverse impacts on airport operations, specifically decreasing the capabilities of the North Field runways. This could affect OAK's ability to operate effectively.

These impacts will be present during the construction phase when cranes are in use. To mitigate these issues, the Port recommends limiting the height of construction equipment to a maximum of 80 feet. Additionally, the crane boom should be lowered when not in operation, during inclement weather, or upon request from the Airport.

The Port recommends continuous coordination between the City and the Port throughout the planning and development process to address any potential conflicts and interference with navigable airspace.

Overflight Zones
The Proposed Project is within the Airport Influence Area (AIA). The avigation easements required for the projects located within the AIA serve the purpose of Overflight Notifications and real estate disclosures. The Port recommends that a buyer notification plan be implemented so buyers are well informed of the overflights and associated noise prior to purchase.

As a condition of approval for development, the Port requests that the developer be required to record an avigation easement and grant notice, and that all developers and property managers be required to include disclosures to future buyers and lessees.

19 Cindy Lemaire August 5, 2024
Re: Project PLN22-0039 DEIR
3 Safety
Land use safety compatibility criteria are developed to minimize the risks to people and property on the ground, as well as those people in an aircraft in the event of an accident or emergency landing occurring outside the airport boundary. The seven safety zones identified in the ALUCP are based on those depicted in the California Airport Land Use Compatibility Handbook (Handbook). The ALUCP lists compatible land uses within each safety zone. The safety zone criteria developed for a particular zone is largely a function of risk acceptability. Land uses (e.g., schools and hospitals) which, for a given proximity to the airport, are determined to represent unacceptable risks must be prohibited. Where the risks of a particular land use are considered significant but tolerable, establishment of restrictions may reduce the risk to an acceptable level.

The Proposed Project is in Airport Safety Zone 4 (Outer Approach / Departure Zones) and Zone 6 (Traffic Pattern Zone). The Port requests that the safety zones referenced in the DEIR are amended to these two safety zones and recommends the City review the ALUCP to determine the land use risks for both safety zones.

Hazardous Wildlife Attractants
FAA Advisory Circular 1550/5200/33B, Hazardous Wildlife Attractants on or Near Airports provides a comprehensive discussion of the land use practices that potentially attract hazardous wildlife and wildlife hazard management procedures. This Advisory Circular recommends that the FAA be notified as early as possible in the planning process of any land use changes that may attract wildlife within 5 statute miles of an airport. This will allow the FAA to perform a brief examination to determine if further investigation is warranted.   The Port recommends the City notify FAA of the Proposed Project.

The Port appreciates the opportunity to comment on the City’s DEIR and looks forward to working with the City to address the Port’s comments. Please contact me with any follow-up questions and responses at [email protected] or 510-627-1198.

Sincerely,
Colleen Liang
Director of Environmental Programs and Planning
CC:

This comment does not question the analysis or conclusions of the Draft EIR. Therefore, no revisions to the Draft EIR are necessary in response to this comment.

Response 3.2
The commenter briefly describes some of its benefits and duties and requests that the Draft EIR be revised to change the name of the Oakland International Airport to the San Francisco Bay Oakland International Airport.

The name of the airport used in the Draft EIR is not consequential or relevant to the analysis of the environmental impacts of the project. Likewise, the name of the airport is not relevant to mitigation measures identified in the Draft EIR to reduce potentially significant impacts of the proposed project. Therefore, no revisions to the Draft EIR are required in response to this comment.

Response 3.3
The commenter briefly describes the role of the Alameda County Airport Land Use Commission (ALUC) and states that the ALUC has held no hearings or provided no determinations for the proposed project. The commenter requests that the Draft EIR be revised to remove references implying the ALUC approved or commented on the proposed project. The commenter also recommends the City coordinate with the ALUC for a formal determination on the project.

The Draft EIR does not reference ALUC hearings on the project and does not imply approval by the ALUC. The City received a comment letter from the Alameda County Community Development Agency Planning Department in response to the Notice of Preparation of the Draft EIR. Comment letters on the Notice of Preparation are included in their entirety in Appendix A to the Draft EIR and summarized in Table 1-1 of the Draft EIR, which begins on page 1-2 of the Draft EIR. One role of the Alameda County Community Development Agency is the ALUC. In this way, with submittal of the comment on the Notice of Preparation of the Draft EIR, the ALUC has commented on the project.

The recommendation that the City coordinate with the ALUC for a formal determination on the project does not pertain to CEQA or the scope of analysis in the Draft EIR. However, for informational purposes, the project plans will be submitted to the ALUC for review. Additionally, the City has continued coordination with the commenter following receipt of this comment letter (see Response 3.5). Additionally, as described on page 84 of the Initial Study, which is Appendix A of the Draft EIR, the project is primarily within Airport Safety Zone 4. As discussed on page 84 of the Initial Study, warehouses and distribution facilities are compatible uses assuming employment does not exceed 100 employees per acre.
21 City of San Leandro
880 Doolittle Drive Industrial Project
Final Environmental Impact Report
Response to Comments Document
Because the Alameda County Community Development Agency did provide a comment to the City and mentioned their role as ALUC in the comment, no revisions to the Draft EIR are required in response to this comment.

Response 3.4
The commenter describes the Airport Land Use Compatibility Plan and summarizes its intent as encouraging compatibility between airports and the various land uses that surround them.

This comment does not question the analysis or conclusions of the Draft EIR. Therefore, no revisions to the Draft EIR are necessary in response to this comment. For informational purposes, the project site is within Airport Safety Zone 4 (Outer Approach/Departure Zone) and Airport Safety Zone 6 (Traffic Pattern Zone), based on Figure 3-4 of the Oakland International Airport Land Use Compatibility Plan. Page 84 of the Initial Study, which is Appendix A of the Draft EIR, states that the project is primarily within Airport Safety Zone 4. As discussed on page 84 of the Initial Study, warehouses and distribution facilities are compatible uses assuming employment does not exceed 100 employees per acre. Additionally, the project applicant submitted the project to the FAA, which determined that a proposed building height of 50 feet does not present a hazard to air navigation.

Response 3.5
The commenter states that project construction would require a crawler crane with a maximum height of 161 feet, which would have adverse impacts on airport operations. The commenter recommends limiting the height of construction equipment to a maximum of 80 feet and lowering the crane boom when not in operation, during inclement weather, or upon request from the Oakland International Airport.

The commenter correctly describes the maximum height of the crawl crane that would be required for construction of the proposed project. As described on page 2-14 of the Draft EIR, a crawler crane with a boom height of up to approximately 161 feet would be required for project construction. page 2-17 of the Draft EIR states that a ‘No Hazard Determination’ from the Federal Aviation Administration may be necessary for the use of project construction equipment exceeding 43 feet in height, which would include the crawler crane with a maximum height of 161 feet. The project applicant must obtain the necessary determinations from the Federal Aviation Administration pursuant to Federal Aviation Regulations Part 77. The project applicant must abide by all conditions of the determination, including equipment height limitations specified in the determination, as applicable.

No revisions to the Draft EIR are necessary in response to this comment. Please note, that the commenter provided a supplemental letter that addresses some of the topics described in Comment 3.5. This supplemental letter has been included as Letter 3b in this Final EIR. Please refer to Letter 3b for more information on project modifications the applicant has agreed to in response to coordination that occurred between the Port of Oakland, City of San Leandro, and project applicant following the end of the public comment period on the Draft EIR.

Response 3.6
The commenter states that the project site is within the Airport Influence Area (AIA) and that avigation easements are required for the purpose of overflight notifications and real estate disclosures. The commenter requests that the applicant be required to record an avigation 22 Final Environmental Impact Report
Response to Comments Document
easement and recommends that a buyer notification plan be implemented to inform buyers of the overflights and associated noise prior to purchase.

An avigation easement is a legal document granted by the property owner, signifying that notification was given regarding the airport in the vicinity, that the airport produces noise and annoyances, and that it is accepted. The easement is recorded with the County Clerk-Recorder and is attached to a property deed. According to Figure 3-6 of the Oakland International Airport Land Use Compatibility Plan (Alameda County Community Development Agency 2010), the project site is within the avigation easement zone of the Oakland International Airport. As stated on page 3-23 of the Airport Land Use Compatibility Plan, avigation easements should be dedicated to the airport owner as a condition for any discretionary local approval of any residential or non-residential development within the area indicated on Figure 3-6. Accordingly, although not required as CEQA mitigation, the City will include a condition of approval that the project applicant dedicate an avigation easement to the owner of the Oakland International Airport.

Neither the City nor the project applicant are responsible for the actions of potential future buyers or tenants of the project site. Potential future buyers are responsible for conducting due diligence at their discretion before purchasing property, including the project site. The avigation easement for the project site would be public information recorded at the Alameda County Clerk and attached to the property deed. According to the Oakland International Airport Land Use Compatibility Plan, neither a separate overflight easement nor a separate real estate disclosure is required for properties for which an avigation easement is required.

Response 3.7
The commenter requests that the Draft EIR be revised to describe the project site as within Airport Safety Zone 4 and Airport Safety Zone 6. The commenter also recommends the City review the Airport Land Use Compatibility Plan to determine land use risks for these two zones.

The commenter is correct that the project site is within Airport Safety Zone 4 (Outer Approach/Departure Zone) and Airport Safety Zone 6 (Traffic Pattern Zone), based on Figure 3-4 of the Oakland International Airport Land Use Compatibility Plan. Page 84 of the Initial Study, which is Appendix A of the Draft EIR, states that the project is primarily within Airport Safety Zone 4. As discussed on page 84 of the Initial Study, warehouses and distribution facilities are compatible uses assuming employment does not exceed 100 employees per acre. Additionally, the project applicant submitted the project to the FAA, who determined that a proposed building height of 50 feet does not present a hazard to air navigation. Therefore, the Initial Study determined that the project would not result in a safety hazard or excessive noise for people working in the project area as a result of airport operations, and impacts would be less than significant.

Safety risks associated with Airport Safety Zone 6 are not discussed specifically in the Draft EIR (including the Initial Study) because Airport Safety Zone 6 is generally less restrictive than Airport Safety Zone 4, and the project would be compatible with Zone 4. However, for informational purposes, Airport Safety Zone 6 has no limit on maximum nonresidential intensity (i.e., people per acre), as shown in Table 3-2 of the Oakland International Airport Land Use Compatibility Plan. Table 3-2 indicates that warehouses, like the proposed project, are a fully compatible land use within Airport Safety Zone 4.

To provide clarification as requested by the commenter, page 84 of the Initial Study is revised as follows:
23 City of San Leandro
880 Doolittle Drive Industrial Project
Final Environmental Impact Report
Response to Comments Document
The project site is approximately 2.5 miles east of Oakland International Airport and 6.6 miles north of the Hayward Executive Airport. The project site is within the Oakland Airport Influence Area but is not within a noise or safety compatibility zone of the Oakland Airport.

The project site and is located primarily in the Outer Approach/Departure Zone (Zone 4), where warehouses and distribution facilities are a compatible use assuming employment does not exceed 100 employees per acre (Alameda County Community Development Agency 2010; Alameda County Airport Land Use Commission 2010). The project site is also partially within the Traffic Pattern Zone (Zone 6). Warehouses are a compatible land use within Zone 6 with no limits on employment density.

This clarification does not change the less than significant determination for airport safety impacts on page 84 of the Initial Study. No further revisions to the Draft EIR are required in response to this comment.

Response 3.8
The commenter cites a Federal Aviation Administration Advisory Circular recommending that the Federal Aviation Administration be notified of land use changes that may attract wildlife within 5 statute miles of an airport. The commenter recommends the City notify the Federal Aviation Administration of the proposed project.

As described on page 2-8 of the Draft EIR, the proposed project would include construction of a new warehouse with supporting office space. These uses are consistent with land uses that have occurred on the project site in the past. Additionally, warehouse and office uses generally do not attract wildlife because they do not generate substantial amounts of food waste, but this can vary depending on specific tenants of the warehouse. Nonetheless, the Federal Aviation Administrative has been informed of the project. For example, as described on page 2-17 of the Draft EIR, the project applicant submitted the project to the Federal Aviation Administration as part of their request for a No Hazard Determination on the maximum building height. The City has documentation of this submittal in the form of the No Hazard Determination, which is on file at City Hall. For convenience, the Draft EIR is revised to include the No Hazard Determination as an appendix. Specifically, the Draft EIR is revised to add Appendix G, Federal Aviation Administration No Hazard Determination, which contains a copy of the No Hazard Determination. The inclusion of the No Hazard Determination as an appendix is not new information, because the No Hazard Determination has been available to the public through the Federal Aviation Administration No Hazard Determination Database throughout the project CEQA process. Accordingly, no further revisions to the Draft EIR are required in response to this comment.

Response 3.9
The commenter provides a point-of-contact if the City has questions regarding their comment letter.

This comment is noted.
24 530 Water Street  P.O. Box 2064  Oakland, California 94604-2064 www.portofoakland.com
October 21, 2024
Ms. Cindy Lemaire, AICP, CNU-A
Senior Planner
City of San Leandro
835 East 14th Street
San Leandro, California 94577
Transmitted via email: [email protected]
Subject: Draft Environmental Impact Report (DEIR) for Project PLN22-0039 (880 Doolittle Drive) – Port Revised Comments
Dear Ms. Lemaire:

The Port of Oakland (Port) appreciates this opportunity to comment on the Draft Environmental Impact Report (EIR) for Project PLN22-0039 at 880 Doolittle Drive (proposed project). On August 5, 2024, the Port submitted comments on the DEIR. Subsequently, the Port and the City met to address the Port’s comments and the Port provides the following revised comments for the City’s consideration. This letter supersedes the letter submitted on August 5, 2024 and conditions emailed on September 27, 2024.

Renamed Metropolitan Oakland International Airport
The Port generates vital economic activity, community benefits, and environmental innovation, as the Port decarbonizes its operations for a cleaner and greener future. Along with its partners, the Port supports 98,345 jobs in the region and $174 billion in annual economic activity. The Port oversees San Francisco Bay Oakland International Airport (OAK or Airport), the Oakland Seaport and nearly 20 miles of waterfront including Jack London Square and is a publicly owned utility.

Alameda County Airport Land Use Commission (ALUC)
The Alameda County Airport Land Use Commission (ALUC) is a commission authorized under the provisions of the California Public Utilities Code, Sections 21670 et seq., and established to promote compatibility between airports and the land uses surrounding them. 25 2
The ALUC did not hold a hearing for the proposed project; however, an administrative review was performed on a similar project description and comments were provided to the applicant on November 13, 2020 by Alameda County.

The Port recommends the City coordinate with the Alameda County Community Development Agency, Planning Department, as an administrative department of Alameda County on the proposed project.

OAK Airport Land Use Compatibility Planning (ALUCP)
The Airport Land Use Compatibility Plan (ALUCP) is the primary document used by the ALUC to promote compatibility between OAK and its environs. The intent of the ALUCP is to encourage compatibility between airports and the various land uses that surround them. There are four primary criteria for evaluating the compatibility of proposed land use in the Airport Influence Area (AIA): Airspace Protection Zones, Overflight Zones, Noise, and Safety. The proposed project is within the AIA.

Airspace Protection Zones
According to the OAK ALUCP, the proposed project must comply with safety zone guidelines and height restrictions to prevent any interference with airport operations. This includes ensuring that structures do not penetrate navigable airspace as defined by Federal Aviation Administration (FAA) Federal Aviation Regulation (FAR) Part 77.

The Port conducted a preliminary airspace impact analysis of the proposed permanent structure height of 50 feet and the construction equipment/crane with a maximum height of 161 feet as outlined in the DEIR. The Port’s analysis indicated that the proposed height of the construction equipment/crane would have adverse impacts on airport operations, specifically decreasing the capabilities of the North Field runways, which could limit OAK's ability to operate.

After the Port submitted the August 24, 2024 DEIR comments, the Port, City, and applicant discussed the construction equipment/crane height and the approximate project schedule. The applicant refined the maximum construction equipment/crane height to 140 feet for a duration of approximately three (3) weeks. The reference height and duration are acceptable to the Port subject to FAR Part 77 and the conditions outlined below.

FAA determination on whether the proposed project would be a hazard to air navigation is required to assess permanent impacts from the structure as well as for temporary impacts during construction. The applicant is required to submit a completed FAA Form 7460–1, Notice of Proposed Construction or Alteration, to the FAA for temporary construction and permanent structure. The Port is available to review Form 7460-1 before the applicant/contractor submits to the FAA for its determination. The applicant/contractor will be required to meet all resulting conditions and requirements in the FAA’s determination stating whether the proposed project would be a hazard to air navigation, which may include, but not be limited to, the following:
• The applicant/contractor is required to notify the OAK Airport Operations Manager and FAA Airport Traffic Control Tower (ATCT) at least five (5) business days prior to bringing the construction equipment/crane to the site. Contact OAK Airport Operations at 510-563-3361 to notify the Airport Operations Manager and ATCT. 26 Cindy Lemaire, AICP, CNU-A October 21, 2024
Re: Project PLN22-0039 DEIR
3 • The applicant/contractor is required to coordinate all associated activities with the Airport Operations Manager and ATCT to ensure the appropriate local NOTAM's are issued.
• At the Airport Operation Manager or ATCT direction, the applicant/contractor is required to lower the construction equipment/crane when not in operation or when weather is below FAA Visual Flight Rules (VFR) minimums. • Additional coordination with and mitigation by the applicant/contractor may be required if it is determined that construction equipment/crane activity is impacting the Airport’s radar system.
• Applicant/contractor must notify the OAK Airport Operations Manager and ATCT at least five (5) business days before the construction equipment/crane is permanently lowered and removed from the site.
• The applicant/contractor is required to lower and/or illuminate the crane during nighttime hours (between sunset and sunrise), in accordance with applicable FAA Advisory Circulars.

In addition to conditions and requirements in the FAA’s determination of air navigation hazards, the Port requests the applicant/contractor implement the following additional measures:
• At the Airport Operations Manager or ATCT direction, the applicant/contractor to lower the construction equipment/crane during adverse weather conditions or below VFR minimums that impact airport operations.
• Applicant/contractor to provide to the Port a primary and secondary contact person who is available 24-hours/day and is authorized to address any issue regarding construction equipment/crane height, during period(s) of construction equipment/crane deployment.

• Applicant/contractor to deploy construction equipment/crane only as needed and preferably during periods of good visibility, above VFR minimums, as determined by the Airport Operations Manager or ATCT, at a height not to exceed 140’ to avoid any impacts to airport operations.

The Port requests continuous coordination between the City and the Port throughout the planning and development process to address any potential conflicts and interference with navigable airspace.

Overflight Zones
Avigation easements are required for projects located within the AIA and serve the purpose of Overflight Notifications and real estate disclosures. The Port recommends that a buyer notification plan be implemented so buyers are well informed of the overflights and associated noise prior to purchase.
27 4
As a condition of approval for development, the Port requests that the developer be required to record an avigation easement and grant notice, and that all developers and property managers be required to include disclosures to future buyers and lessees.

Safety
Land use safety compatibility criteria are developed to minimize the risks to people and property on the ground, as well as those people in an aircraft in the event of an accident or emergency landing occurring outside the airport boundary. The seven safety zones identified in the ALUCP are based on those depicted in the California Airport Land Use Compatibility Handbook (Handbook). The ALUCP lists compatible land uses within each safety zone. The safety zone criteria developed for a particular zone is largely a function of risk acceptability. Land uses (e.g., schools and hospitals) which, for a given proximity to the airport, are determined to represent unacceptable risks must be prohibited. Where the risks of a particular land use are considered significant but tolerable, establishment of restrictions may reduce the risk to an acceptable level.

The proposed project is in Airport Safety Zone 4 (Outer Approach / Departure Zones) and Zone 6 (Traffic Pattern Zone). The Port requests that the safety zones referenced in the DEIR be amended to Safety Zones 4 and 6, and recommends the City review the ALUCP to determine the land use risks for both safety zones.

Hazardous Wildlife Attractants
FAA Advisory Circular 150/5200-33C, Hazardous Wildlife Attractants on or Near Airports provides a comprehensive discussion of the land use practices that potentially attract hazardous wildlife and wildlife hazard management procedures. This Advisory Circular recommends that the FAA be notified as early as possible in the planning process of any land use changes that may attract wildlife within 5 statute miles of an airport. This will allow the FAA to perform a brief examination to determine if further investigation is warranted. The Port recommends the City notify FAA of the proposed project.

Sincerely,
Colleen Liang
Director of Environmental Programs and Planning
CC:

Kristi McKenney, Chief Operating Officer
Matt Davis, Chief Public Engagement Officer
Craig Simon, Aviation Director
Joan Zatopek, Aviation Planning and Development Manager Matt Davis, Airport Operations Manager, Airside
Susan Fizzell, Senior Aviation Project Manager
Sharon Grewal, AICP, PMP, Associate Aviation Project Manager Diego Gonzalez, Governmental Affairs Manager
Radiah Victor, Senior Port Strategic Planner
28 Final Environmental Impact Report
Response to Comments Document
Letter 3b
COMMENTER: Colleen Liang, Director of Environmental Programs and Planning, Port of Oakland DATE: October 21, 2024
The commenter submitted Letter 3b in response to coordination between the Port of Oakland, City of San Leandro, and the project applicant that occurred following closure of the comment period on the Draft EIR. The commenter requests that Letter 3b supersede Letter 3 and an email the commenter sent to the City on September 27, 2024. Rather than having Letter 3b supersede Letter 3 or other input from the commenter, the City has elected to consider Letter 3b a supplement to Letter 3.

Much of Letter 3b is identical or nearly identical to Letter 3. For example, Letter 3b contains Comment 3.2 from Letter 3. Therefore, Response 3.2 is an applicable response to Letter 3b, also.

This is the case for most of the comments in Letter 3b and earlier responses to Letter 3. Therefore, the remainder of this response to Letter 3b addresses only comments that are new or different from those provided in Letter 3.

The new or revised comments in Letter 3b pertain to the coordination that occurred between the Port of Oakland, City of San Leandro, and the project applicant after the closure of the public comment period on the Draft EIR. Specifically, Letter 3b contains a description or list of construction practices that project applicant has agreed to implement as part of the proposed project. These practices that the project applicant have agreed to implement include:
 Reducing the maximum height of the crane from 161 feet to 140 feet.  Limiting the use of the crane to approximately 3 weeks.  Notifying the Operations Manager of the Oakland International Airport and the FAA Airport Traffic Control Tower at least five days in advance of bringing the construction crane to the project site.
 Coordinating all associated activities with the Airport Operations Manager and Airport Traffic Control Tower to ensure the appropriate local Notice to Air Missions are issued.  Lowering the construction equipment/crane when not in operation or when weather is below FAA Visual Flight Rules (VFR) minimums, as directed by the Airport Operations Manager or Airport Traffic Control Tower.
 Implementing additional coordination and crane modifications as determined by either the Airport Operations Manager or Airport Traffic Control Tower should either determine the crane is impacting the airport’s radar system.
 Notifying the Airport Operations Manager and Airport Traffic Control Tower at least five business days before the construction equipment/crane is permanently lowered and removed from the site.
 Lowering and/or illuminating the crane during nighttime hours (between sunset and sunrise), in accordance with applicable FAA Advisory Circulars.
 At the Airport Operations Manager or Airport Traffic Control Tower direction, lowering the construction equipment/crane during adverse weather conditions or below VFR minimums that impact airport operations.
 Providing the Port of Oakland with a primary and secondary contact person who is available 24- hours/day and is authorized to address any issue regarding construction equipment/crane height, during the construction period/crane deployment. 29 City of San Leandro
880 Doolittle Drive Industrial Project
Final Environmental Impact Report
Response to Comments Document
 Deploying the construction equipment/crane only as needed and preferably during periods of good visibility, above VFR minimums, as determined by the Airport Operations Manager or Air Traffic Control Tower, at a height not to exceed 140 feet.

The applicant has agreed to implement the construction and crane operations listed above into the project. These modifications to construction activities would result in no new physical impacts to the environment. Therefore, no revisions to the Draft EIR are required in response to this comment, other than revisions that may be described in responses to Letter 3. 30 10211 Sunland Blvd., Shadow Hills, CA 91040 (818) 650-0030 X101 [email protected] Advocates for the Environment
A non-profit public-interest law firm
and environmental advocacy organization
July 29, 2024
Cindy Lemaire
Senior Planner
City of San Leandro
835 East 14th Street
San Leandro, CA 94577

Via U.S. Mail and email to [email protected]
Re: Comments on Draft Environmental Impact Report for 800 Doolittle Drive Industrial Project, SCH No. 2023110597
Dear Ms. Lemaire:

Advocates for the Environment submits the comments in this letter regarding the Draft Environmental Impact Report (DEIR) for the 800 Doolittle Drive Industrial Project (Project).

The Project Site is located near Davis Street and Doolittle Drive in the City of San Leandro (City). The Project proposes to develop the 14.14-acre Project Site by constructing a 244,573 square-foot warehouse. We have reviewed the DEIR prepared in June 2024 and submit comments regarding the sufficiency of the DEIR’s Greenhouse-Gas (GHG) analysis under the California Environmental Quality Act (CEQA).

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

Environmental groups have achieved tremendous outcomes by litigation under CEQA.

Two of the largest mixed-use development projects in the history of California, Newhall Ranch (now FivePoint Valencia), and Centennial (part of Tejon Ranch) decided to move forward as net-zero communities after losing CEQA lawsuits to environmental groups. The ability for 31 City of San Leandro Page 2
CEQA Comments on 800 Doolittle Drive Industrial Project July 29, 2024 10211 Sunland Blvd., Shadow Hills, CA 91040 (818) 650-0030 X101 [email protected] these large projects to become net-zero indicates that it is achievable, even for large-scale developments. The Applicant for this Project should do the same.

We urge the City to adopt net-zero as the GHG significance threshold for this project.

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

GHG Mitigation is Insufficient under CEQA
The City did not quantify the projects emissions. The City adopted a significance threshold based on Appendix G of the CEQA Guidelines. Based on this threshold, the City concluded the Project would have significant GHG emissions. The City did not suggest any mitigation measures to reduce this significant GHG impact, claiming “Because there is no feasible mitigation to reduce significant impacts resulting from GHG emissions of the project, impacts would remain significant and unavoidable.” (DEIR, p. 4.1-13.) Despite the availability of feasible GHG mitigation measures, the DEIR declared that not a single mitigation measure would be feasible, without analyzing or rejecting particular measures. The DEIR also declared that the Project’s mitigated emissions were unavoidable, claiming the City is unable to implement mitigation to reduce this significant impact because it cannot require the project applicant to eliminate natural gas from the proposed project. (DEIR, p. 4.1-9.) However, because this conclusion is not supported by substantial evidence, the DEIR should have included more mitigation to reduce the Project’s GHG emissions to the extent required by CEQA. While the Energy Policy and Conservation Act (EPCA) may preempt state law that conflicts with it, it doesn’t prevent the City from requiring the applicant to omit natural gas infrastructure as a mitigation measure. Even if the elimination of natural gas from the Project were not available as a mitigation measure, other mitigation measures are available.

CEQA does not require that mitigation targets the specific source of GHG emissions, only that the project’s cumulative impact is fully mitigated.
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CEQA Comments on 800 Doolittle Drive Industrial Project July 29, 2024 10211 Sunland Blvd., Shadow Hills, CA 91040 (818) 650-0030 X101 [email protected] Infeasibility Finding Lacks Substantial Evidence
The conclusion that the Project will not be able to achieve any mitigation is not supported with substantial evidence. The DEIR should have proposed mitigation measures to be applied to the maximum-feasible extent in order to justify the conclusion that the Project’s GHG impact would be unavoidable due to lack of feasibility of mitigation. The DEIR does not identify a single mitigation measure, beyond the Project features, nor explain why any mitigation whatsoever would be infeasible.

It Is Feasible to Adopt Mitigation Measures
CEQA places the burden of proof of the infeasibility of mitigation on the City when it concludes the Project will have a significant and unavoidable impact. The City did not analyze any mitigation measures when concluding that the Project’s GHG impact would be unavoidable. This not only fails to analyze and disclose adequate reasoning, to the detriment of the public and decision-makers, but also does not amount to substantial evidence to support the conclusion that the Project’s impact would be significant and unavoidable.

The City and Applicant together can commit to design and technology specifications that reduce emissions, especially in the heavy-duty truck and transportation vehicle fleet. Further, the City can require the applicant to enter a contract with future tenants to use zero-emission commercial vehicles upon reasonable availability and maintain a charging system for the vehicle fleet that is powered by solar panels on the Project site. Thus, the conclusion that further mitigation is infeasible was not supported by substantial evidence.

The Project’s GHG Impacts Must be Fully Mitigated
CEQA requires that the Project include fair-share mitigation for all significant cumulative impacts. (Napa Citizens for Honest Gov’t v. Napa County Board of Supervisors (2001) 91 Cal.App.4th 342, 364.) Here, this means mitigation of the full extent of the Project’s GHG impacts. The DEIR claims that no mitigation measures are feasible. But that conclusion is incorrect, and not supported by substantial evidence.

The amount of GHG emissions that comprises the Project’s fair share is unclear. The DEIR acknowledges that the Project would result in a significant and unavoidable impact on GHG emissions. However, it did not quantify the Projects MTCO2e emissions, nor did it identify the projects reasonable life span. As a result, the starting point from which to subtract the effect of additional non-offset mitigation measures, before implementing offset purchases is unknown.
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CEQA Comments on 800 Doolittle Drive Industrial Project July 29, 2024 10211 Sunland Blvd., Shadow Hills, CA 91040 (818) 650-0030 X101 [email protected] Operational Emissions Reductions are Feasible
There are several mitigation measures that are feasible, including renewable energy systems and batteries to power the facility during non-peak hours, solar water heaters, automatic light switches, among many other mitigation strategies that can be incorporated in the project as design features or as mitigation measures. Such features could be adopted individually or as part of a comprehensive goal of sustainable building certification, such as Leadership and Energy and Environmental Design (LEED), that extends further beyond CALGreen requirements.

Solar panel installation or incorporating renewable energy production on-site is also a feasible mitigation measure. The DEIR indicates that the Project will comply with Title 24 requirements. (DEIR, p. 4.1-11.) However, Title 24 mandates only that a minimum of 15 percent of the roof area be solar-ready. Extending this requirement to cover the maximum available surface area, rather than just the minimum 15 percent required would be feasible.

Additionally, installing solar panels across the entire available roof surface would also be a feasible measure. Having solar panels capable of offsetting 100% of the buildings’ energy demands would enhance the effectiveness and decrease GHG emissions overall.

Likewise, the DEIR specifies the installation of charging stations required by Title 24, in this case, 21 electric vehicle (EV) charging stations. (DEIR, p. 4.1-11.) There is no evidence that it would be infeasible to install more charging stations beyond the proposed 21 stations.

Overall, there are more options available to mitigate emissions to the full extent of project emissions.

Offsets Are Feasible
After requiring operational emissions reductions to the maximum feasible extent, the City could also require the Applicant to purchase offsets for the Project’s remaining GHG emissions.

The City did not provide any evidence for why offsets would be infeasible. Offsets are acceptable mitigation measures under CEQA (See CEQA Guidelines § 15126.4 (c)(3).) Overall, there are more options available to mitigate emissions to the full extent of project emissions, and the City failed to acknowledge or implement many mitigation measures that are feasible and could help reduce the Project’s GHG impact to the fair share extent.

Conclusion
The DEIR fails to require all feasible mitigation, despite concluding that the significant GHG impact will be unavoidable. The lead agency has not met its burden of showing that such measures are infeasible, and therefore the DEIR should be amended to reflect all feasible 34 City of San Leandro Page 5
CEQA Comments on 800 Doolittle Drive Industrial Project July 29, 2024 10211 Sunland Blvd., Shadow Hills, CA 91040 (818) 650-0030 X101 [email protected] mitigation to the fair-share extent. Please put me on the interest list to receive updates about the progress of this Project. We make this request under Public Resources Code, section 21092.2.

Sincerely,
Dean Wallraff, Attorney at Law
Executive Director, Advocates for the Environment
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Letter 4
COMMENTER: Dean Wallraff, Executive Director, Advocates for the Environment DATE: July 29, 2024
Response 4.1
The commenter states their understanding of the proposed project in the form of a summary and indicates that it is providing comments pertaining to the analysis of greenhouse gas (GHG) impacts in the Draft EIR.

Response 4.2
The commenter suggests that the City should adopt net-zero as the GHG significance threshold for the project. The commenter references documents and policies that they suggest support net-zero as the significance threshold, including the California Air Resources Board (CARB) 2017 Scoping Plan, CARB 2022 Scoping Plan, and an unspecified California state policy.

As described on page 32 of the Initial Study, which is included as Appendix A to the Draft EIR, the project site is located in the San Francisco Bay Area Air Basin, which is under the jurisdiction of the Bay Area Air Quality Management District (BAAQMD). As described on page 4.1-5 of the Draft EIR, the BAAQMD Board of Directors adopted its Bay California Environmental Quality Act Air Quality Guidelines in 2022. The adopted document is commonly referred to as the BAAQMD 2022 CEQA Guidelines, including throughout the Draft EIR. As described on page 4.1-5 of the Draft EIR, the BAAQMD 2022 CEQA Guidelines include nonbinding recommendations for how a lead agency can evaluate, measure, and mitigate air quality and climate impacts generated from land use construction and operational activities. Chapter 6 of the BAAQMD 2022 CEQA Guidelines provides guidance on applying the BAAQMD thresholds of significance for climate impacts from GHG emissions to projects, including land use and stationary source projects. Because the project site is in the San Francisco Bay Area Air Basin, the City elected to use the BAAQMD 2022 CEQA Guidelines guidance on applying the BAAQMD thresholds of significance, as described on pages 4.1-6 and 4.1-7 of the Draft EIR.

As described in detail on pages 6-3 and 6-4 of the BAAQMD 2022 CEQA Guidelines and summarized on pages 4.1-6 and 4.1-7 of the Draft EIR, for a project to have a less-than-significant impact related to operational GHG emissions, it must, at a minimum, incorporate certain project design elements or be consistent with a local GHG reduction strategy that meets State CEQA Guidelines Section 15183.5(b) requirements. As described on page 4.1-7 of the Draft EIR, while the City has a qualified GHG reduction strategy, it chose to evaluate the significance of impacts based on whether the project incorporates the project design elements specified by BAAQMD. Pursuant to the BAAQMD 2022 CEQA Guidelines, the project design elements required for operational GHG impacts to be considered less than consistent are listed on page 4.1-7 of the Draft EIR, and include Buildings
 The project will not include natural gas appliances or natural gas plumbing (in both residential and non-residential development).
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 The project will not result in any wasteful, inefficient, or unnecessary energy usage as determined by the analysis required under CEQA Section 21100(b)(3) and Section 15126.2(b) of the State CEQA Guidelines.

Transportation
 Achieve a reduction in project-generated vehicle miles traveled (VMT) below the regional average consistent with the current version of the California Climate Change Scoping Plan (currently 15 percent) or meet a locally adopted Senate Bill 743 VMT target, reflecting the recommendations provided in the Governor’s Office of Planning and Research's Technical Advisory on Evaluating Transportation Impacts in CEQA:
o Residential projects: 15 percent below the existing VMT per capita o Office projects: 15 percent below the existing VMT per employee o Retail projects: no net increase in existing VMT
 Achieve compliance with off-street electric vehicle requirements in the most recently adopted version of CALGreen Tier 2.

These design criteria do not specify that projects must be designed to be net-zero GHG emissions in order for operational GHG emissions impacts to be determined less than significant. Instead, as specified on page 6-4 of the BAAQMD 2022 CEQA Guidelines, if the project includes, at a minimum, these design elements, there would be a less-than-significant climate impact related to GHG emissions, and the project would not be likely to conflict with applicable initiatives to reduce GHG emissions, including CARB scoping plans and Executive Order B-55-18. The rationale, justification, and substantial evidence supporting this conclusion can be found in Appendix B of the BAAQMD 2022 CEQA Guidelines. Briefly, as described therein, the BAAQMD is now focused on achieving the state’s longer-term goals of carbon neutrality by 2045, consistent with Executive Order B-55-18.

Moreover, the Supreme Court of California has recognized the necessity and appropriateness of using these longer-term goals as the touchstone for the CEQA analysis. As it held in Cleveland National Forest Foundation v. SANDAG, these longer-term goals express “what scientific research has determined to be the level of emissions reductions necessary to stabilize the climate by midcentury and thereby avoid catastrophic effects of climate change” (Cleveland National Forest Foundation v. SANDAG [2017] 3 Cal.5th 497, 513).

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neutrality (i.e. net-zero), natural gas usage will need to be phased out and replaced with electricity usage, and electrical generation will need to shift to 100-percent carbon-free sources. Therefore, using the project design criteria above, which includes evaluating whether the project would use natural gas, is an appropriate method of assessing if the project is helping the state achieve carbon neutrality. The City need not adopt a specific net-zero GHG emission significance threshold for the proposed project and Draft EIR, because the BAAQMD already provides GHG significance thresholds that are aligned with the state’s carbon neutrality goals and these thresholds are used in the Draft EIR. For this reason, no revisions to the Draft EIR are required in response to this comment.

Nevertheless, the commenter’s suggestion that the City adopt a new or different CEQA threshold for GHG emissions for review of future projects is noted and will be forwarded to the decision makers for their consideration.
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Response 4.3
The commenter states that the City did not quantify the GHG emissions of the project and determined that GHG impacts of the project would be significant based on thresholds provided in Appendix G of the State CEQA Guidelines. The commenter suggests that the Draft EIR provides no mitigation measures to reduce this impact, which would remain significant and unavoidable.

The commenter’s summary of the analysis of project impacts related to GHG emissions in the Draft EIR is mostly accurate. However, as described on page 4.1-7 of the Draft EIR, the City used significance thresholds adopted by the BAAQMD to evaluate GHG impacts as they relate to checklist questions provided in Appendix G of the State CEQA Guidelines (see Response 4.2).

The commenter is correct in stating that the City did not quantify the GHG emissions of the project.

The BAAQMD significance thresholds do not require or call for the quantification of GHG emissions.

Instead, as detailed in Response 4.2 above, the significance thresholds state that for a project to have a less-than-significant impact related to operational GHG emissions, it must, at a minimum, incorporate certain project design elements or be consistent with a local GHG reduction strategy that meets State CEQA Guidelines Section 15183.5(b) requirements. For this reason, consistent with BAAQMD 2022 CEQA Guidelines, the City did not quantify the GHG emissions of the project. Instead, the City evaluated the potential GHG impacts of the project using the BAAQMD significance thresholds for determining if the project incorporates the required design elements.

The commenter is correct that the proposed project would have significant and unavoidable GHG impacts. As stated in bold text on page 4.1-8 of the Draft EIR, the proposed project would have potential to contribute to the long-term generation of GHG emissions due to the provision of natural gas plumbing, and impacts would be significant and unavoidable. Page 4.1-9 of the Draft EIR states that there is no feasible mitigation to reduce this potentially significant impact. Accordingly, no revisions to the Draft EIR are required in response to this comment.

Response 4.4
The commenter opines that there are feasible mitigation measures available to reduce the significant GHG impacts of the project, but the EIR states that no mitigation would be feasible without analyzing or rejecting particular measures.

The commenter does not suggest specific mitigation measures to reduce the GHG impacts of the project in this comment. The commenter does suggest mitigation measures later in the comment letter and individual responses are provided to those in later responses. Specifically, please refer to Response 4.7, Response 4.8, and Response 4.9.

The commenter’s suggestion that the EIR states that no mitigation would be feasible to reduce the GHG impacts of the project without analyzing or rejecting measures is not accurate. As described on page 4.1-8, the potentially significant GHG impact of the project is the result of new natural gas plumbing within the proposed building (see Response 4.2 and Response 4.6). The most straightforward measure to reduce the significance of this impact is to eliminate the natural gas plumbing from the project. The infeasibility of mandating such a mitigation measure is discussed on page 4.1-9 of the Draft EIR. No other known mitigation is available. The Draft EIR concludes that no other mitigation is available to eliminate the use of natural gas in the proposed project. “CEQA does not require analysis of every imaginable alternative or mitigation measure; its concern is with feasible means of reducing environmental effects.” (San Diego Citizenry Group v. County of San Diego (2013) 219 Cal.App.4th 1, 16).
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.

Because this comment does not specify additional mitigation measures to eliminate natural gas plumbing from the project and reduce the resultant significant GHG impact from provision of this plumbing, no revisions to the Draft EIR are required in response to this comment.

Response 4.5
The commenter opines that the Draft EIR concludes the City is unable to eliminate natural gas from the project through mitigation measures without providing substantial evidence supporting this conclusion. The commenter suggests that the Energy Policy and Conservation Act (EPCA) may preempt state law conflicting with it, but it does not prevent the City from including mitigation measures requiring the applicant to omit natural gas from the project.

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from the project through a mitigation measure or otherwise. This discussion on page 4.1-8 lays out the legal framework for why such mitigation is not possible, and therefore constitutes substantial evidence supporting the conclusion that the City cannot eliminate natural gas as mitigation measures. As described on page 4.1-8 of the Draft EIR, the City is unable to implement this type of mitigation based on a recent court case titled California Restaurant Association v. City of Berkeley.

Briefly, in this case, the California Restaurant Association sued Berkeley in the U.S. District Court for the Northern District of California, arguing among other things that the federal EPCA preempted the City’s ordinance banning natural gas in new buildings. The District Court dismissed the California Restaurant Association’s challenge. However, the Ninth Circuit reversed the District Court, holding that EPCA expressly preempts state and local regulations concerning the energy use of many natural gas appliances. The Ninth Circuit concluded that EPCA preempted Berkeley’s ban of natural gas, because it prohibited the onsite installation of natural gas infrastructure necessary to support natural gas appliances covered under the EPCA.

Though the commenter appears to disagree with the City’s legal interpretation of the California Restaurant Association case, the City is not required to impose mitigation that it believes may not be legally enforceable. “Mitigation measures that cannot be legally imposed or enforced need not be proposed or analyzed.” (San Diego Citizenry Group v. County of San Diego (2013) 219 Cal.App.4th 1, 16). The City of San Leandro cannot require the project applicant to eliminate natural gas from the proposed project because this would also prohibit the onsite installation of natural gas infrastructure necessary to support natural gas appliances covered under the EPCA.

The commenter provides no further detail on or explanation of why they feel mitigation measures eliminating natural gas from the project would be feasible despite the Ninth Circuit conclusions regarding the EPCA. Accordingly, no revisions to the Draft EIR are required in response to this comment.

Response 4.6
The commenter suggests there are other mitigation measures available to reduce the significant GHG impacts of the project besides eliminating natural gas, indicating that CEQA does not require mitigation to target the specific source of GHG emissions, only that the project’s cumulative impact is fully mitigated.

As discussed in Response 4.2, above, the Draft EIR uses significance thresholds adopted by the BAAQMD in 2022 that require projects to incorporate certain project design elements for GHG impacts to be less than significant. One of these design elements is that the project must not include 39 Final Environmental Impact Report
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natural gas appliances or natural gas plumbing (see Draft EIR page 4.1-7 and Response 4.2). As described on page 4.1-8 of the Draft EIR, the project would result in a potentially significant GHG impact associated with new natural gas plumbing, consistent with the BAAQMD significance threshold.

The threshold related to natural gas is explained on page 6-4 of the BAAQMD 2022 CEQA Guidelines. As described therein, for the building sector to achieve carbon neutrality and meet the State’s climate goals of carbon neutrality by 2045, natural gas usage needs to be phased out and replaced with electricity usage, and electrical generation will need to shift to 100-percent carbonfree sources. To support these shifts, new projects need to be built without natural gas and with no inefficient or wasteful energy usage. As further described on page 6-4 of the BAAQMD 2022 CEQA Guidelines:
“…the “no natural gas” design element applies to all building types (i.e., residential and nonresidential). If the project includes appliances or equipment on-site that combust natural gas supplied by natural gas infrastructure, then the GHG emissions from the project would cause a significant and unavoidable impact. This design element is specific to natural gas being supplied by piped infrastructure, as extending the natural gas infrastructure for such projects “locks in” GHG emissions for decades to come and is therefore inconsistent with achieving carbon neutrality.”
Appendix B to the BAAQMD 2022 CEQA Guidelines provides more explanation on how the GHG significance thresholds were developed. Briefly, as described therein, the BAAQMD is now focused on achieving the state’s longer-term goals of carbon neutrality by 2045. Moreover, the Supreme Court has recognized the necessity and appropriateness of using these longer-term goals as the touchstone for the CEQA analysis. As it held in Cleveland National Forest Foundation v. SANDAG, these longer-term goals express “what scientific research has determined to be the level of emissions reductions necessary to stabilize the climate by midcentury and thereby avoid catastrophic effects of climate change” (Cleveland National Forest Foundation v. SANDAG [2017] 3 Cal.5th 497, 513). As discussed on page B-9 of Appendix B to the BAAQMD 2022 CEQA Guidelines, with respect to building energy use, meeting carbon neutrality by 2024 can be achieved by replacing natural gas with electric power and by eliminating inefficient or wasteful energy usage. This will support California’s transition away from fossil fuel–based energy sources and will bring the project’s GHG emissions associated with building energy use down to zero as the state’s electric supply becomes 100 percent carbon free.

Here, the GHG emissions are considered a significant impact, not because of potential emissions if future tenants utilize the natural gas infrastructure for appliances, but because the BAAQMD has adopted a threshold that finds that any inclusion of natural gas infrastructure in the project is a significant impact, regardless of use. The inclusion of natural gas infrastructure for this project, therefore, automatically creates a significant impact. As discussed previously, the City cannot legally prohibit the project from including natural gas infrastructure. The commenter does not provide mitigation measures that would eliminate natural gas infrastructure from the project in a way that the City can legally implement or enforce.

The commenter also does not provide a quantified threshold to which the GHG emissions of the project should be reduced below through measures other than removing natural gas from the project. The BAAQMD 2022 CEQA Guidelines do not require quantification of the GHG emissions of land-use projects, like the proposed project. The BAAQMD 2022 CEQA Guidelines also do not provide a quantified emissions threshold, such as a limit of metric tons of carbon dioxide equivalent per year emitted by a project. Instead, as mentioned earlier in this response, the BAAQMD 40 City of San Leandro
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thresholds are based on long-term goals of achieving carbon neutrality by 2045 by eliminating natural gas from new buildings, among other things. Specifically, as described on page 8-4 of the BAAQMD 2022 CEQA Guidelines, the thresholds for climate impacts from GHG emissions are not quantitative, and therefore have no bright-line threshold under which there can be an option to mitigate. The climate impact thresholds of significance for land use projects are specific design elements to be included in the project.

As explained earlier in Response 4.2 and Response 4.4, the City knows of no feasible mitigation measures to reduce the significant and unavoidable GHG emissions of the project to levels that would be less than significant. This is because the only known way to reduce the impact of provision of natural gas plumbing is to eliminate that plumbing, which is not feasible or enforceable. As explained in this response, the commenter’s suggestion to target other sources of GHG emissions of the project would also not mitigate the impact. However, the City has developed Mitigation Measure GHG-1 to reduce or minimize use of natural gas in the proposed building to the extent possible while also complying with its interpretation of a decision from the Ninth Circuit that prevents cities and local agencies from prohibiting natural gas in projects (see Page 4.1-9 of the Draft EIR). Specifically, page 4.1-9 of the Draft EIR is revised as follows:

Mitigation Measures
The City is unable to implement mitigation to reduce this significant impact to levels that would be less than significant based on a recent court case titled California Restaurant Association v. City of Berkeley. Briefly, in this case, the California Restaurant Association sued Berkeley in the U.S. District Court for the Northern District of California, arguing among other things that the federal Energy Policy and Conservation Act (EPCA) preempted the City’s ordinance banning natural gas in new buildings. The District Court dismissed the California Restaurant Association’s challenge. However, the Ninth Circuit reversed the District Court, holding that EPCA expressly preempts state and local regulations concerning the energy use of many natural gas appliances. The Ninth Circuit concluded that EPCA preempted Berkeley’s ban of natural gas, because it prohibited the onsite installation of natural gas infrastructure necessary to support natural gas appliances covered under the EPCA. Accordingly, based on the decision of the Ninth Circuit in California Restaurant Association v. City of Berkeley, the City of San Leandro cannot require the project applicant to eliminate natural gas from the proposed project. No other mitigation is available to eliminate the use of natural gas in the proposed project. See Section 6, Alternatives, which includes project alternatives that do not include natural gas connections.

While the City is unable to require mitigation eliminating natural gas, this City has developed Mitigation Measure GHG-1 to reduce the use of natural gas to the extent possible.

GHG-1 Natural Gas Use Reduction
The building and its appliances (space heating, hot water heating, office cooking facilities, etc.) shall be all electric. Natural gas plumbing shall be permitted, activated and operated only for specific industrial or manufacturing processes that require natural gas as a critical component to that process or processes. The final site plans shall note that building appliances must be all electric. Building tenants shall be made aware of the restricted use of natural gas through language in the leasing and/or deed documentation.
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Significance After Mitigation
Implementation of Mitigation Measure GHG-1 would reduce the natural gas consumption as routine part of building operations, but it would not eliminate natural gas infrastructure from the project. Because the proposed project would include natural gas plumbing and there is no feasible mitigation to reduce potentially significant impacts resulting from the provision of this natural gas plumbing GHG emissions of the project, impacts would remain significant and unavoidable.

No further revisions to the Draft EIR are required in response to this comment.

Response 4.7
The commenter opines that the Draft EIR concludes that the City is unable to eliminate natural gas from the project through mitigation measures without providing substantial evidence supporting this conclusion. The commenter suggests that the Draft EIR should have analyzed mitigation measures to determine feasibility.

This comment is similar to comments 4.4 and 4.5. Please see Response 4.4 and Response 4.5.

Briefly, as discussed in Response 4.4 and Response 4.5, the potentially significant GHG impacts of the project is the result of new natural gas plumbing within the proposed building. The only measure the City is able to develop that would reduce the significance of this impact is to eliminate the natural gas plumbing from the project. The feasibility of implementing such a mitigation measure is discussed on page 4.1-9 of the Draft EIR, effectively describing how the Ninth Circuit prevents the City from eliminating natural gas from the project. This serves as substantial evidence as to why the mitigation cannot be implemented or enforced and impacts would remain significant and unavoidable. As stated in Response 4.4 and Response 4.5, no revisions to the Draft EIR are required in response to this comment.

Response 4.8
The commenter opines that the City did not analyze mitigation measures when concluding that the project’s GHG impact would be unavoidable. The commenter suggests that does not amount to substantial evidence to support the conclusion that the project’s impact would be significant and unavoidable.

This comment is similar to comments 4.4, 4.5, and 4.7. Please see Response 4.4, Response 4.5, and Response 4.7. Briefly, as described in those responses, the only mitigation to reduce the significant GHG impacts of the project that the City is able to develop is to eliminate natural gas from the project. This is because the potentially significant GHG impact of the project is related to the provision of natural gas in the proposed building and not related to the GHG emissions of the project exceeding a quantified threshold. The City is unable to eliminate natural gas from the building through mitigation (or through Ordinance) due to a decision of the Ninth Circuit. Page 4.1-9 of the Draft EIR discusses the elimination of natural gas as mitigation and describes why it is not feasible due to the Ninth Circuit decision, thereby providing substantial evidence to support the conclusion that the project’s GHG impacts would be significant and unavoidable. No revisions to the Draft EIR are required in response to this comment.

Response 4.9
The commenter suggests that the City can work with the project applicant to reduce GHG emissions through technological specifications, such as committing to using zero-emission commercial vehicles 42 City of San Leandro
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and maintaining a charging system for the vehicle fleet that is energized with on-site solar panels.

The commenter suggests that such measures demonstrate that the Draft EIR fails to provide substantial evidence that there is not mitigation for the significant and unavoidable GHG impacts of the project.

This comment is similar to comments 4.5 and 4.6. Please see Response 4.5 and Response 4.6.

Briefly, as described therein, the potentially significant GHG impact of the project is related to the provision of natural gas in the proposed building. The potentially significant GHG emissions of the project are not related to commercial vehicle fleets that could be used for operation of the project or to the GHG emissions of the project exceeding a quantified threshold. The City is unable to eliminate natural gas from the building through mitigation (or through Ordinance) due to a decision of the Ninth Circuit. Page 4.1-9 of the Draft EIR discusses the elimination of natural gas as mitigation and describes why it is not feasible due to the Ninth Circuit, thereby providing substantial evidence to support the conclusion that project impacts would be significant and unavoidable.

The potential GHG impacts associated with vehicle operations of the project are evaluated in the Draft EIR. As discussed on page 4.1-8 of the Draft EIR, VMT generated by the project would be at least 15 percent below the average VMT per employee in the region. Additionally, the proposed project would include 21 electric-vehicle ready parking spaces for cars, which would meet and exceed the CalGreen Code requirement. Accordingly, as concluded on page 4.1-8 of the Draft EIR, the proposed project would satisfy the transportation design elements of the BAAQMD 2022 CEQA Guidelines significance threshold, which are listed on page 4.1-7 of the Draft EIR. Therefore, it is unnecessary for the City to require further mitigation pertaining to the potential vehicle fleet of the project, as the potential vehicle fleet does not contribute to the potentially significant GHG impacts of the project.

For informative purposes, the proposed project does include technological specifications and infrastructure that could result in reduced GHG emissions in the future. For example, electric charging infrastructure would be provided beneath the proposed truck parking area. In the future, depending on availability of technology and tenant preferences, charging stations could be installed in the truck parking area, and an all-electric vehicle fleet could be employed. However, as previously described, despite these types of zero- or low-carbon technological installations, the potentially significant GHG impact of the project would not be mitigated or reduced, because the potentially significant impact is due solely to the provision of natural gas plumbing in the proposed building.

No revisions to the Draft EIR are required in response to this comment.

Response 4.10
Citing a 2001 case from the California Court of Appeals, the commenter asserts that CEQA requires the project to include fair-share mitigation for significant cumulative impacts. The commenter states that the Draft EIR indicates no feasible mitigation measures are available to reduce the potentially significant cumulative GHG impacts of the project but suggests this is incorrect and not supported by substantial evidence.

As discussed in Response 4.2, above, the City elected to use the BAAQMD 2022 CEQA Guidelines significance thresholds to evaluate to the potential GHG impacts of the proposed project in the Draft EIR. As described in detail on pages 6-3 and 6-4 of the BAAQMD 2022 CEQA Guidelines and summarized on pages 4.1-6 and 4.1-7 of the Draft EIR, for a project to have a less-than-significant impact related to operational GHG emissions, it must include, at a minimum, incorporate certain project design elements or be consistent with a local GHG reduction strategy that meets State CEQA 43 Final Environmental Impact Report
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Guidelines Section 15183.5(b) requirements. As described on page 4.1-7 of the Draft EIR, while the City has a qualified GHG reduction strategy, it chose to evaluate the significance of impacts based on whether the project incorporates the project design elements specified by BAAMD. These design elements are listed above in Response 4.2.

As described on page 6-2 of the BAAQMD 2022 CEQA Guidelines, the BAAQMD recommends that lead agencies use a “fair share” approach for determining whether an individual project’s GHG emissions would be cumulatively considerable. As stated on page 6-3 of the BAAQMD 2022 CEQA Guidelines:
“For a land use project to do its fair share to address the climate crisis and thus for its GHG emissions to be less than significant, a project cannot include sources that will “lock in” GHG emissions for decades into the future. A project that locks in GHG sources, without a clear path to reduce the emissions from those sources, prevents the State from achieving the climate goals. For this reason, the climate impact thresholds of significance…specify that certain design elements must be incorporated into the project…, or the project must be consistent with a local GHG reduction strategy that meets the criteria under CEQA Guidelines Section 15183.5(b)…”
Thus, because the City uses the design elements specified in the BAAQMD 2022 CEQA Guidelines significance thresholds to evaluate the GHG impacts of the project in the Draft EIR, the City has evaluated the cumulative impacts of the project using a fair-share approach.

As described on page 4.1-13 of the Draft EIR, the proposed project’s contribution to significant cumulative GHG impacts would be cumulatively considerable. As discussed in detail in Response 4.5 and Response 4.6, above there is no feasible mitigation measures to reduce the GHG impact of the project because the impact is due solely to the provision of natural gas plumbing in the proposed building and a decision from the Ninth Circuit prevents the City from prohibiting natural gas in the project. Page 4.1-9 of the Draft EIR explains how and why the Ninth Circuit decision prevents the City from eliminating natural gas from the project, thereby providing substantial evidence of the City’s conclusion that GHG impacts, including cumulative impacts, would be significant and unavoidable. This comment does not provide or suggest mitigation that would both eliminate natural gas plumbing from the proposed project while also being feasible to implement and enforce.

Therefore, no revisions to the Draft EIR are required in response to this comment.

Response 4.11
The commenter asserts that the amount of GHG emissions that comprises the project’s fair share is unclear, and the Draft EIR does not quantify the GHG emissions of the project or the lifespan of the project. The commenter asserts the omission of quantified emissions and project lifespan make it unknown how to determine how much off-set carbon credits and non-offset measures are needed to mitigate the significant GHG impacts of the project.

This portion of this comment pertaining to the quantification of project GHG emissions is similar to comment 4.3. Please see Response 4.3. Briefly, as described therein, the City did not quantify the GHG emissions of the project in the Draft EIR or otherwise. The BAAQMD significance thresholds used in the Draft EIR do not require or call for the quantification of GHG emissions. Instead, as detailed in Response 4.2 above, the thresholds state that for a project to have a less-than-significant impact related to operational GHG emissions, it must include, at a minimum, incorporate certain project design elements or be consistent with a local GHG reduction strategy that meets State CEQA 44 City of San Leandro
880 Doolittle Drive Industrial Project
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Response to Comments Document
Guidelines Section 15183.5(b) requirements. For this reason, consistent with BAAQMD 2022 CEQA Guidelines, the City did not quantify the GHG emissions of the project.

The remainder of this comment pertains to suggesting that the potentially significant GHG impacts of the project could be mitigated through measures other than the elimination of natural gas from the project. This portion of the comment is related to earlier comments, including 4.1, 4.2, 4.3, 4.4, and 4.6. Please refer to Response 4.1, Response 4.2, Response 4.3, Response 4.4, and Response 4.6.

Briefly, as described in those responses, the potentially significant GHG impact of the project is related to the provision of natural gas in the proposed building. The provision of the natural gas is a significant impact pursuant to the BAAQMD 2022 CEQA Guidelines significance thresholds. The potentially significant GHG impacts of the projects are not related to quantified GHG emissions. The commenters suggestion that reducing the GHG emissions of the project would mitigate the potentially significant impacts of the project is not accurate. This is because reducing the GHG emissions of the project would not eliminate natural gas from the project.

No revisions to the Draft EIR are required in response to this comment.

Response 4.12
The commenter suggests there are feasible ways to mitigate the GHG emissions of the project and provides several examples or suggestions, such as achieving Leadership and Energy and Environmental Design (LEED) certification, installing or incorporating renewable energy sources onsite, and increasing the number of elective-vehicle charging stations on-site.

This comment is related to earlier comments, including 4.1, 4.2, 4.3, 4.4, and 4.6. Please refer to Response 4.1, Response 4.2, Response 4.3, Response 4.4, and Response 4.6. Briefly, as described in those responses, the potentially significant GHG impact of the project is related to the provision of natural gas in the proposed building. The provision of the natural gas is a significant impact pursuant to the BAAQMD 2022 CEQA Guidelines significance thresholds. The potentially significant GHG impacts of the projects are not related to quantified GHG emissions. The commenters suggestion that reducing the GHG emissions of the project would mitigate the potentially significant impacts of the project is not accurate. This is because reducing the GHG emissions of the project would not eliminate natural gas from the project.

No revisions to the Draft EIR are required in response to this comment. For informational purposes, the applicant proposes to achieve a minimum of LEED Silver Certification for the project.

Response 4.13
The commenter suggests that the City could reduce the significant GHG impacts of the project by including mitigation measures to reduce the GHG emissions of the project with a combination of onsite activities and off-site carbon credits. The commenter suggests that the City failed to acknowledge or implement these types of mitigation measures.

This comment is related to earlier comments, including 4.1, 4.2, 4.3, 4.4, and 4.6. Please refer to Response 4.1, Response 4.2, Response 4.3, Response 4.4, and Response 4.6. Briefly, as described in those responses, the potentially significant GHG impact of the project is related to the provision of natural gas in the proposed building. The provision of the natural gas plumbing is a significant impact pursuant to the BAAQMD 2022 CEQA Guidelines significance thresholds. The potentially significant GHG impacts of the projects are not related to quantified GHG emissions. The commenters suggestion that reducing the GHG emissions of the project would mitigate the potentially significant impacts of the project is not accurate. This is because reducing the GHG 45 Final Environmental Impact Report
Response to Comments Document
emissions of the project would not eliminate natural gas from the project. Because measures to reduce the GHG emissions of the project would not address the potentially significant impact of the inclusion of natural gas plumbing in the proposed project, the City did not consider or include the measures like carbon credits in the Draft EIR.

No revisions to the Draft EIR are required in response to this comment.

Response 4.14
The commenter opines that the Draft EIR fails to require feasible mitigation, despite concluding that the significant GHG impact would be unavoidable. The commenter suggests that the lead agency has not met its burden of showing that such measures are infeasible, and therefore the DEIR should be amended to reflect all feasible.

This comment is similar to numerous earlier comments in this letter, such as comments 4.2, 4.4, and

4.6. As explained earlier in Response 4.2 and Response 4.4, the City knows of no feasible mitigation measures to reduce the significant and unavoidable GHG emissions of the project. As explained in Response 4.6, the commenter’s suggestion to target other sources of GHG emissions of the project to reduce the significant GHG impact would not reduce the significant GHG impact of the project.

This is because the mitigation measures suggested by commenter do not provide feasible or enforceable means by which the City could eliminate natural gas plumbing from the proposed project. Accordingly, no revisions to the Draft EIR are required in response to this comment.

Response 4.15
The commenter requests to be added to the project mailing and notification list. The City will add the commenter to the project mailing list. No revisions to the Draft EIR are required in response to this comment.
46 BLUM, COLLINS & HO LLP

ATTORNEYS AT LAW

AON CENTER
707 WILSHIRE BOULEVARD
SUITE 4880
LOS ANGELES, CALIFORNIA 90017 (213) 572-
0400
August 2, 2024
Cindy Lemaire, AICP, CNU-A
Senior Planner
VIA EMAIL TO:
[email protected]
City of San Leandro
835 East 14th Street
San Leandro, California 94577
SUBJECT: COMMENTS ON THE 880 DOOLITTLE DRIVE INDUSTRIAL PROJECT. (SCH NO. 2023110597)
Dear Ms. Lemaire,
Thank you for the opportunity to comment on the Environmental Impact Report (EIR) for the proposed 880 Doolittle Drive Industrial Project. Please accept and consider these comments on behalf of Golden State Environmental Justice Alliance. Also, Golden State Environmental Justice Alliance formally requests to be added to the public interest list regarding any subsequent environmental documents, public notices, public hearings, and notices of determination for this project. Send all communications to Golden State Environmental Justice Alliance P.O. Box 79222 Corona, CA 92877.

1.0 Summary
The project involves the demolition of existing vacant warehouse buildings and associated surface parking on the site. Following demolition of existing structures and a lot merger, the proposed project would include construction of a new warehouse with supporting office space, site improvements, and landscaping. The proposed warehouse would be approximately 244,573 square feet, comprised of a 229,573 square-foot of warehouse area and 15,000 square feet of associated office space. Approximately 10,000 square feet of office space would be provided on the ground floor alongside the warehouse use. The remaining 5,000 square feet of office space would be on a mezzanine level of the warehouse. The building is designed as a cross-dock fulfillment center with 64 truck/trailer loading dock doors (27 truck/trailer loading dock doors on the north side of the building, 37 truck/trailer loading dock doors on the south side of the building), and 59 truck/trailer parking stalls.
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1.1 Project Piecemealing
The EIR does not accurately or adequately describe the project, meaning “the whole of an action, which has a potential for resulting in either a direct physical change in the environment, or a reasonably foreseeable indirect physical change in the environment” (CEQA § 15378). The proposed project is a piecemealed portion of a larger overall project to be developed within the larger Prologis development in the City. At minimum, this includes PLN20-00441located at 1919 Williams Street2(221,495 sf warehouse). The two piecemealed projects total 466,068 sf of warehousing space.

A project EIR must be prepared that accurately represents the whole of the action without piecemealing the project into separate, smaller development projects to present unduly low environmental impacts. CEQA Section 15161 describes project EIRs as examining “the environmental impacts of a specific development project. This type of EIR should focus primarily on the changes in the environment that would result from the development project. The EIR shall examine all phases of the project including planning, construction, and operation.” The specific development project is the construction and operation of all Prologis buildings.

Additionally, CEQA Section 15146 requires that the degree of specificity in an EIR “will correspond to the degree of specificity involved in the underlying activity which is described in the EIR. (a) An EIR on a construction project will necessarily be more detailed in the specific effects of the project than will be an EIR on the adoption of a local general plan or comprehensive zoning ordinance because the effects of the construction can be predicted with greater accuracy.” Because there are multiple proposed buildings as part of a single project, the project EIR must be more detailed in the specific effects of the project. A project EIR must be prepared which accurately represents the whole of the action without piecemealing the project into separate, smaller development projects, phases, or development areas to present unduly low environmental impacts.

1.4 Issues Not Studied in Detail in the EIR: Land Use and Planning The Initial Study concludes that the proposed project is consistent with the General Plan without considering the EIR’s conclusion that the project will result in significant and unavoidable cumulatively considerable impacts to Greenhouse Gas Emissions. The EIR is inadequate as an informational document and a revised EIR must be prepared with a consistency analysis that 1 https://aca-prod.accela.com/SANLEANDRO/Default.aspx
2 https://ceqanet.opr.ca.gov/Project/2021080547
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considersthe project’ssignificant and unavoidable impactsin its analysis, including but not limited to the following goals and policies that were adopted for the purposes of avoiding or mitigating an environmental effect:

1. Goal LU-11 Manage the city’s growth in a way that maintains the quality of life and reflects the capacity of infrastructure and public services. Policy LU-11.1 Use of the General Plan Environmental Impact Report. Use the 2035 household and employment forecasts in this General Plan as parameters for environmental analysis for future development projects within the San Leandro city limits. The General Plan and its associated Environmental Impact Report presumed an incremental increase of 5,600 housing units and 12,130 jobs between 2015 and 2035. In the event that proposed development in the city would exceed these amounts, the Director of Community Development shall require that environmental review for any subsequent development address growth impacts that would occur as a result of development exceeding the General Plan projections. This does not preclude the City, as lead agency, from determining that an EIR would be required for any development to the extent required under the relevant provisions of CEQA (e.g. Section 21166 and related guidelines).

2. Policy ED-1.3 Industrial Land Use Efficiency. Encourage more efficient use of the City’s industrial land supply, creating higher employment densities and high quality jobs, while discouraging the use of large sites and buildings for storage and other low intensity uses.

Ensure that zoning and other development regulations support higher utilization of sites zoned for commercial and industrial activities.

3. Goal EJ-1 Reduce Pollution Exposure and Improve Air Quality.

4. Policy EH-3.3 Land Use Compatibility. Discourage new uses with potential adverse air quality impacts, including the emission of toxic air contaminants and fine particulates, near residential neighborhoods, schools, hospitals, nursing homes, and other locations where public health could potentially be affected.

5. Policy EH-3.4 Design, Construction, and Operation. Require new development to be designed and constructed in a way that reduces the potential for future air quality problems, such as odors and the emission of any and all air pollutants. This should be done by: (a) Requiring construction and grading practices that minimize airborne dust and particulate matter; (b) Ensuring that best available control technology is used for operations that could generate air pollutants; (c) Encouraging energy conservation and low-polluting energy sources; (d) Promoting landscaping and tree planting to absorb carbon monoxide and other pollutants; and (e) Implementing the complementary strategies to reduce greenhouse gases identified in the Climate Action Plan.
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6. Policy EH-9.6 Airport Safety Zones. Regulate land uses within designated airportsafety zones, height referral areas, and noise compatibility zones to minimize the possibility of future noise conflicts and accident hazards.

7. Policy T-1.5 Land Use Strategies. Promote land use concepts that reduce the necessity of driving, encourage public transit use, and reduce trip lengths. These concepts include livework development, mixed use development, higher densities along public transit corridors, and the provision of commercial services close to residential areas and employment centers.

8. Action T-5.2.A: New Evaluation Methodologies Consistent with SB 743, implement new methodologies for evaluating and mitigating transportation impacts which are based on VMT rather than level of service (LOS). Until such methodologies are developed and adopted, the City will use the following minimum acceptable peak hour service standards for streets and intersections: LOS "D" for streets and intersections located outside of the designated Priority Development Areas (PDAs) in Downtown, Bay Fair, and East 14th Street; and LOS “E” for streets and intersections located within the designated Priority Development Areas (PDAs) for Downtown, Bay Fair, and East 14th Street. The LOS “E” standard for the PDAs recognizes the emphasis on other modes of travel in these areas, in particular public transit, bicycling, and walking. It also recognizes the desire for slower vehicle speeds to improve the safety of these other modes, as well as the character of these areas as places of concentrated economic activity and high-density housing. The standard does not preclude the City, developers, and private property owners from voluntarily implementing improvements and programs to improve levels of service.

Further, the EIR states that approval an application for a height exception is required to implement the project, but details of the request are not provided in the EIR or the Initial Study. A revised EIR must be prepared to include this information for analysis to comply with CEQA’s requirements for adequate informational documents and meaningful disclosure (CEQA § 15121).

1.4 Issues Not Studied in Detail in the EIR: Population and Housing The IS excludes a quantified analysis of the project’s construction and/or operational workforce in this section. The U.S. Energy Information Administration3 provides the following applicable employment generation rate for warehouses:

No Refrigeration: 1 employee per 1,226 square feet
3 US EIA Commercial Buildings Energy Consumption Survey, Table B1: Summary table: total and means of floorspace, number of workers, and hours of operation, 2018 https://www.eia.gov/consumption/commercial/data/2018/bc/html/b1.php 50 Cindy Lemaire
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Applying this ratio results in the following calculation:

Non-Refrigerated: 244,573 sf/ 1,226 = 200 employees
The General Plan EIR4 notes that the City will add approximately 3,735 jobs in the Wholesale trade between 2015 - 2035. Utilizing the U.S. EIA calculation of 200 employees, the project represents 5.3% of the City’s employment growth from 2015 - 2035. A single project accounting for this amount of the projected employment growth over 20 years represents a significant amount of growth. A revised EIR must be prepared to include this analysis, and also provide a cumulative analysis discussion of projects approved since 2015 and projects “in the pipeline” to determine if the project will exceed the General Plan employment growth forecast for the City. For example, the piecemealed industrial project at 1919 Williams (221,495 sf warehouse; 181 employees) combined with the proposed project will cumulatively generate 381 employees, which is 10.2% of the City’s employment growth forecast over 2 years accounted for by only two recent industrial projects. The amount of growth accounted for by cumulative projects multiplies exponentially when other development activity approved since 2015 are added to the calculation. A revised EIR must be prepared to include this information for analysis and also include a cumulative development analysis of projects approved since 2015 and projects “in the pipeline” to determine if the proposed project exceeds the City’s growth forecasts. Additionally, a revised EIR must also provide demographic and geographic information on the location of qualified workers to fill these positions in order to provide an accurate environmental analysis.

2.0 Project Description
The EIR does not include a floor plan, detailed site plan, detailed building elevations or a complete conceptual grading plan. The basic components of a Planning Application include a detailed site plan, floor plan, conceptual grading plan, written narrative, and detailed elevations. The site plan provided in Figure 2-4 has been edited for public review to remove meaningful information such as the floor area ratio, site coverage, and key notes. All of these basic items are necessary to conduct any type of analysis, and the EIR is inadequate as an informational document as it is not possible to ascertain any meaningful analysis based upon the information provided. Further, the elevations provided in Figure 2-5 are completely blurry and illegible; no meaningful information (such as the height of the buildings, colors, or materials) is provided as a result.

The EIR has also excluded a detailed grading plan from public review. Figure 2-8 does not provide any standard items found on a grading plan, such as the earthwork quantity notes or grading 4 https://www.sanleandro.org/DocumentCenter/View/1256/Chapter-3-Project-Design-PDF 51 Cindy Lemaire
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contour lines. The EIR states that, “The site is relatively level, which minimizes the amount of grading included in the proposed project.” There is no detailed information or quantification of the earthwork movement required to construct the project. There is no method for the public to verify this claim that “the site is relatively level” and that grading will be “minimized.” Providing the complete grading plan and earthwork quantity notes is vital as this directly informs the quantity of necessary truck hauling trips due to soil import/export during the grading phase of construction.

A revised EIR must be prepared to include wholly accurate and unedited detailed floor plan, grading plan, site plan, elevations, and project narrative for public review.

Additionally, the EIR states that approval an application for a height exception is required to implement the project, but details of the request are not provided in the EIR or the Initial Study.

A revised EIR must be prepared to include this information for analysis to comply with CEQA’s requirements for adequate informational documents and meaningful disclosure (CEQA § 15121).

1.4 Issues Not Studied in Detail in the EIR: Air Quality and Energy and 4.1 Greenhouse Gas Emissions
Please see the attachment for a full technical commentary and analysis from SWAPE.

The EIR does not include for analysis relevant environmental justice issues in reviewing potential impacts, including cumulative impacts from the proposed project. The EIR provides general information about the census tract’s Calenviroscreen scores but does not provide meaningful analysis regarding the health impacts and effects of severe pollution rates. This is in conflict with CEQA Guidelines Section 15131 (c), which requires that “Economic, social, and particularly housing factors shall be considered by public agencies together with technological and environmental factors in deciding whether changes in a project are feasible to reduce or avoid the significant effects on the environment identified in the EIR. If information on these factors is not contained in the EIR, the information must be added to the record in some other manner to allow the agency to consider the factors in reaching a decision on the project.” This is especially significant as the surrounding community is highly burdened by pollution. The EIR also excludes that the project site is listed as a Disadvantaged Community in Figure 12-1: San Leandro Environmental Justice Communities in the General Plan Environmental Justice Element 5.

According to CalEnviroScreen 4.06, CalEPA’s screening tool that ranks each census tract in the 5 https://www.sanleandro.org/DocumentCenter/View/8893/Chapter12---Environmental-Justice-Element120522?bidId= 6 CalEnviroScreen 4.0 https://oehha.ca.gov/calenviroscreen/report/calenviroscreen-40 52 Cindy Lemaire
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state for pollution and socioeconomic vulnerability, the proposed project’s census tract (6001432400) ranks worse than 92% of the rest of the state in overall pollution burden and 71% of the state overall in socioeconomic impacts.

The proposed project’s census tract and surrounding community bears the impact of multiple sources of pollution and is more polluted than average on several pollution indicators measured by CalEnviroScreen. For example, the project census tract ranks in the 94th percentile for diesel particulate matter (PM) burden and 84th percentile for traffic burdens. All of these environmental factors are attributed to heavy traffic (including truck activity) in the area. While California has strict vehicle-emissions standards, exhaust from cars and trucks is the main source of air pollution in much of the state7. Exhaust fumes contain toxic chemicals that can damage DNA, cause cancer, make breathing difficult, and cause low weight and premature births8. The very small particles of diesel PM can reach deep into the lung, where they can contribute to a range of health problems.

These include irritation to the eyes, throat and nose, heart and lung disease, and lung cancer9.

The censustract ranks among the mostseverely impacted in several areasthat impact water quality.

The census tract ranks in the 97th percentile for groundwater threats. People who live near contaminated groundwater may be exposed to chemicals moving from the soil into the air inside their homes10. Accordingly, the census tract ranks in the 87th percentile for drinking water impacts, which indicates that it ranks with the worst quality drinking water in the state. Poor communities and people in rural areas are exposed to contaminants in their drinking water more often than people in other parts of the state11.

The census tract also ranks in the 99th percentile for solid waste facility impacts. Solid waste facilities can expose people to hazardous chemicals, release toxic gases into the air (even after these facilites are closed), and chemicals can leach into soil around the facility and pose a health risk to nearby populations12.
7 OEHHA Traffic https://oehha.ca.gov/calenviroscreen/indicator/traffic-density 8 OEHHA Traffic https://oehha.ca.gov/calenviroscreen/indicator/traffic-density 9 OEHHA Diesel Particulate Matter https://oehha.ca.gov/calenviroscreen/indicator/diesel-particulatematter 10 OEHHA Groundwater Threats https://oehha.ca.gov/calenviroscreen/indicator/groundwater-threats 11 OEHHA Drinking Water https://oehha.ca.gov/calenviroscreen/drinking-water 12 OEHHA Solid Waste Facilities https://oehha.ca.gov/calenviroscreen/indicator/solid-waste-sites-andfacilities 53 Cindy Lemaire
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The census tract also bears more impacts from cleanup sites than 90% of the state. Chemicals in the buildings, soil, or water at cleanup sites can move into nearby communities through the air or movement of water13.

The census tract ranks in the 62nd percentile for toxic releases. People living near facilities that emit toxic releases may breathe contaminated air regularly or if contaminants are released during an accident14.

Further, the project’s census tract is a diverse community including 42% Hispanic, 31% AsianAmerican, and 6% African-American residents, whom are especially vulnerable to the impacts of pollution. The community has a high rate of low educational attainment, meaning 66% of the census tract over age 25 has not attained a high school diploma, which is an indication that they may lack health insurance or access to medical care. The community also has a high rate of poverty, meaning 49% of the households in the census tract have a total income before taxes that is less than the poverty level. Income can affect health when people cannot afford healthy living and working conditions, nutritious food and necessary medical care15. Poor communities are often located in areas with high levels of pollution16. Poverty can cause stress that weakens the immune system and causes people to become ill from pollution17. Living in poverty is also an indication that residents may lack health insurance or access to medical care. Medical care is vital for this census tract as it ranks in the 58th percentile for incidence of cardiovascular disease and 82nd percentile for incidence of asthma. The community also has a high rate of linguistic isolation, meaning 57% of the census tract speaks little to no English and faces further inequities as a result.

Additionally, the project census tract (6001432400) and the census tracts adjacent to the project site (6001409000 (north/west), 6001409100 (east), and (6001409200) east) are identified as SB 535 Disadvantaged Communities 18. This indicates that cumulative negative impacts of development and environmental impacts in the area are disproportionately impacting these communities. The EIR does not discuss that the surrounding area is a disadvantaged community and does not utilize this information in its analysis. The EIR has not considered the environmental impacts in relation to the SB 535 status of the project census tract and surrounding area. The negative environmental, health, and quality of life impacts of the warehousing and logistics industry in the area have become distinctly inequitable. The severity of environmental impacts 13 OEHHA Cleanup Sites https://oehha.ca.gov/calenviroscreen/indicator/cleanup-sites 14 OEHHA Toxic Releases https://oehha.ca.gov/calenviroscreen/indicator/toxic-releases-facilities 15 OEHHA Poverty https://oehha.ca.gov/calenviroscreen/indicator/poverty 16 Ibid.
17 Ibid.
18 OEHHA SB 535 Census Tracts https://oehha.ca.gov/calenviroscreen/sb535 54 Cindy Lemaire
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particularly on these Disadvantaged Communities must be included for analysis as part of a revised EIR.

The State of California lists three approved compliance modeling softwares19 for non-residential buildings: CBECC-Com, EnergyPro, and IES VE. CalEEMod is not listed as an approved software. The CalEEMod modeling does not comply with the 2022 Building Energy Efficiency Standards and under-reports the project’s significant Energy impacts and fuel consumption to the public and decision makers. Since the EIR did not accurately or adequately model the energy impacts in compliance with Title 24, it cannot conclude the project will generate less than significant impacts and a finding of significance must be made. A revised EIR with modeling using one of the approved software types must be prepared and circulated for public review in order to adequately analyze the project’s significant environmental impacts. This is vital as the EIR utilizes CalEEMod as a source in its methodology and analysis, which is clearly not an approved software.

4.2 Hazards and Hazardous Materials
The project site is located within the Outer Approach Zone (Zone 4) of the Oakland Airport Influence Area. The IS states that, “the project applicant submitted the project to the FAA, who determined that a proposed building height of 50 feet does not present a hazard to air navigation.

Therefore, the project would not result in a safety hazard or excessive noise for people working in the project area as a result of airport operations,” and the EIR states that, "pursuant to Federal Aviation Regulations Part 77, a No Hazard Determination for the warehouse was issued from the Federal Aviation Administration pursuant to Federal Aviation Regulations Part 77, because the proposed warehouse would have a maximum height of 50 feet, exceeding the 43 feet maximum permitted at this distance from the airport runway. The applicant submitted the project to the FAA, who determined that a building height of 50 feet does not present a hazard to air navigation. An additional No Hazard Determination may also be needed for the use of project construction equipment exceeding 43 feet in height.”
However, the EIR and IS exclude the FAA determination from public review. This does not comply with CEQA’s requirements for adequate informational documents and meaningful disclosure (CEQA § 15121 and 21003(b)). Incorporation by reference (CEQA § 15150 (f)) is not appropriate as the FAA determination contributes directly to analysis of the problem at hand. A revised EIR must be prepared to include the FAA determination for review, analysis, and comment 19 California Energy Commission 2022 Energy Code Compliance Software https://www.energy.ca.gov/programs-and-topics/programs/building-energy-efficiency-standards/2022- building-energy-efficiency-1
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by the public and decision makers. The EIR must also include revised building elevations that are legible to the public, and clearly (not blurry) depict the height of the building to its highest point in order for the public and decision makers to verify building height in accordance with the FAA’s review.

Further, the EIR must be revised to include a finding of significance as it has not provided meaningful evidence to support the conclusion that equipment utilized to construct the project will not result in a safety hazard or excessive noise for people working in the project area as a result of airport operations.

4.4 Transportation
the EIR has underreported the quantity VMT generated by the proposed project operations. The operational nature of industrial/warehouse uses involves high rates of truck/trailer/delivery van VMT due to traveling from large import hubs to regional distribution centers to smaller industrial parks and then to their final delivery destinations. Once employees arrive at work at the proposed project, they will conduct their jobs by driving delivery vans across the region as part of the daily operations as a fulfillment center, which will drastically increase project-generated VMT. The project’s truck/trailer and delivery van activity is unable to utilize public transit or active transportation and it is misleading to the public and decision makers to exclude this activity from VMT analysis. The project’s total operational VMT generated is further inconsistent with the significance threshold and legislative intent of SB 743 to reduce greenhouse gas emissions by reducing VMT. A revised EIR must be prepared to reflect a quantified VMT analysis that includes all truck/trailer and delivery van activity.

The EIR has not adequately analyzed the project’s potential to substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses; or the project’s potential to result in inadequate emergency access. The EIR excludes any analysis or discussion of the available maneuvering and queueing space for trucks/trailers at the intersection of the project driveways and the adjacent streets, or throughout the site. Figure 2: Site Plan within Appendix C is overlaid with a truck/trailer turning template that depicts several areas of conflict between trucks/trailer as they access and maneuver throughout the site. For example, there are several areas of modeling “overlap,” which indicates there is not sufficient available maneuvering space for more than one truck/trailer and the vehicles will collide. This occurs at the entrance to the southern truck/trailer loading dock and the driveway on Doolittle Drive. 56 Cindy Lemaire
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This also occurs on the north side of the project site, including at the driveway access point on Hester Street, the internal driveway providing access to the southern portion of the site, within the truck/trailer loading dock and parking stall areas. A revised EIR must be prepared to include a finding of significance due to these significant and unavoidable impacts. 57 Cindy Lemaire
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5.1 Growth Inducement and 5.2 Irreversible Environmental Effects A revised EIR must be prepared to include an accurate cumulative analysis discussion here to demonstrate the impact of the proposed project in a cumulative setting. The EIR does not include any information regarding the buildout conditions of the City’s General Plan in order to provide an adequate and accurate environmental analysis. The EIR must be revised to provide the horizon year of the City’s current adopted General Plan, the total developable building floor area analyzed within the General Industrial land use designation, and cumulative development since adoption of the General Plan to ensure that the proposed project is within the General Plan EIR’s analysis, particularly since the EIR tiers from the General Plan EIR. 58 Cindy Lemaire
August 2, 2024

Page 13 ends

Further, the EIR has not provided a cumulative analysis of growth in the City. The General Plan EIR20 notes that the City will add approximately 3,735 jobs in the Wholesale trade between 2015 - 2035. Utilizing the U.S. EIA calculation of 200 employees, the project represents 5.3% of the City’s employment growth from 2015 - 2035. A single project accounting for this amount of the projected employment growth over 20 years represents a significant amount of growth. A revised EIR must be prepared to include this analysis, and also provide a cumulative analysis discussion of projects approved since 2015 and projects “in the pipeline” to determine if the project will exceed the General Plan employment growth forecast for the City. For example, the piecemealed industrial project at 1919 Williams (221,495 sf warehouse; 181 employees) combined with the proposed project will cumulatively generate 381 employees, which is 10.2% of the City’s employment growth forecast over 2 years accounted for by only two recent industrial projects. The amount of growth accounted for by cumulative projects multiplies exponentially when other development activity approved since 2015 are added to the calculation. A revised EIR must be prepared to include this information for analysis and also include a cumulative development analysis of projects approved since 2015 and projects “in the pipeline” to determine if the proposed project exceeds the City’s growth forecasts.

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

Sincerely,
Gary Ho
Blum, Collins & Ho LLP
Attachment: SWAPE Analysis
20 https://www.sanleandro.org/DocumentCenter/View/1256/Chapter-3-Project-Design-PDF 59 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]
July 30, 2024
Gary Ho
Blum, Collins & Ho LLP
707 Wilshire Blvd, Ste. 4880
Los Angeles, CA 90017
Subject: Comments on the 880 Doolittle Drive Industrial Project (SCH No. 2023110597) Dear Mr. Ho,
We have reviewed the June 2024 Draft Environmental Impact Report (“DEIR”) for the 880 Doolittle Drive Industrial Project (“Project”) located in the City of San Leandro (“City”). The Project proposes to construct 229,573-square-feet (“SF”) of warehouse space, 15,000-SF of office space, and 204 parking spaces on the 14.14-acre site.

Our review concludes that the DEIR fails to adequately evaluate the Project’s air quality and greenhouse gas impacts. As a result, emissions and health risk impacts associated with construction and operation of the proposed Project may be underestimated and inadequately addressed. A revised 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 environment.

Air Quality
Unsubstantiated Input Parameters Used to Estimate Project Emissions The DEIR’s air quality analysis relies on emissions calculated with the California Emissions Estimator Model (“CalEEMod”) Version 2020.4.0 (p. 40).1 CalEEMod provides recommended default values based on site-specific information, such as land use type, meteorological data, total lot acreage, project type and typical equipment associated with project type. If more specific project information is known, the user can change the default values and input project-specific values, but the California Environmental Quality Act (“CEQA”) requires that such changes be justified by substantial evidence. Once all of the 1 “CalEEMod Version 2020.4.0.” California Air Pollution Control Officers Association (CAPCOA), May 2021, available at: https://www.aqmd.gov/caleemod/download-model.
60 2
values are inputted into the model, the Project's construction and operational emissions are calculated, and "output files" are generated. These output files disclose which parameters are used in calculating the Project's air pollutant emissions by identifying any changes to default values. Justifications are provided for each altered value.

When reviewing the Project’s CalEEMod output files, provided in the Air Quality Assessment (“AQ Assessment”) as Appendix A to the DEIR, we found that several model inputs were inconsistent with information disclosed in the DEIR. As a result, model inputs were unsubstantiated to apply to the Project and the Project’s construction emissions may be underestimated. A revised EIR should be prepared to include an updated air quality analysis that adequately evaluates the impacts that construction of the Project will have on local and regional air quality.

Unsubstantiated Changes to Individual Construction Phase Lengths Review of the CalEEMod output files demonstrates that the “880 Doolittle Project” model includes several changes to the default individual construction phase lengths (see excerpt below) (Appendix A, pp. 193, 225, 252).

The models consequently include the following construction schedule (see excerpt below) (Appendix A, pp. 198, 229, 230, 256, 257).
61 3
The demolition phase is increased by 230%, from the default value of 20 to 66 days; the site preparation phase is increased by 320%, from the default value of 10 to 42 days; the grading phase is increased by 53%, from the default value of 30 to 46 days; the building construction phase is decreased by 35%, from the default value of 300 to 195 days; the paving phase is increased by 115%, from the default value of 20 to 43 days; and the architectural coating phase is increased by 230%, from the default value of 20 to 66 days. As previously mentioned, the CalEEMod User’s Guide requires any changes to model defaults be justified.2 According to the “User Entered Comments & Non-Default Data” table, the justification provided for these changes is:
“Anticipated Construction Schedule” (Appendix A, pp. 192, 224, 250).

Regarding construction activities, the AQ Assessment states:
“Assuming construction of the project is continuous, construction would occur over approximately 18 months, with 6 of those months being a period of inactivity following demolition that is associated with construction contracting” (p. 2-14).

The DEIR also states:
“Demolition would last approximately 2 months” (p. 2-8).

While the DEIR justifies the duration of both the demolition phase length of 2 months and the total construction duration of 18 months, the changes to the individual construction phase lengths remain unsubstantiated. The DEIR fails to substantiate the changes to the site preparation, grading, building construction, paving, and architectural coating phase lengths. Until adequate information is provided that justifies the changes to each individual construction phase length, the model should have included proportionately altered individual phase lengths to match the proposed construction duration of 18 months.
2 “CalEEMod User’s Guide Version 2020.4.0.” California Air Pollution Control Officers Association (CAPCOA), May 2021, available at: https://www.aqmd.gov/caleemod/user's-guide, p. 1, 14. 62 4
The construction emissions are improperly spread out over a longer period of time for some phases, but not for others. According to the CalEEMod User’s Guide, each construction phase is associated with different emissions activities (see excerpt below).3
By disproportionately altering and extending some of the individual construction phase lengths without proper justification, the model assumes there are a greater number of days to complete the construction activities required by the prolonged phases. There will be less construction activities required per day and, consequently, less pollutants emitted per day. Until we are able to verify the revised construction schedule, the model may underestimate the peak daily emissions associated with some phases of construction and should not be relied upon to determine Project significance.

Updated Analysis Indicates a Potentially Significant Air Quality Impact To more accurately estimate the Project’s construction-related emissions, we prepared an updated CalEEMod model, using the Project-specific information provided by the DEIR. In our updated model, we proportionately altered the construction phase lengths to match the total construction duration of 18 months.4 All other values were consistent with the DEIR’s model.

Our updated analysis estimates that the Project’s construction-related volatile organic compound (“VOC”) emissions exceed the applicable BAAQMD thresholds of 54-pounds per day (“lbs/day”), respectively, as referenced by the DEIR (p. 4.2-23, Table 4.2-8) (see table below). 3 “CalEEMod User’s Guide.” California Air Pollution Control Officers Association (CAPCOA), May 2021, available at:
https://www.aqmd.gov/caleemod/user's-guide, p. 32. 4 See Attachment A for construction calculations and Attachment B for the updated CalEEMod model. 63 5
Construction VOC
(lbs/day)
DEIR 43.72
SWAPE 136.54
% Increase 212%
BAAQMD Threshold 54
Exceeds? Yes
Construction-related VOC emissions, as estimated by SWAPE, increase by approximately 212%, and exceed the applicable BAAQMD significance threshold. Our model demonstrates that the Project would result in a potentially significant air quality impact that was not previously identified or addressed by the DEIR. A revised EIR should be prepared to adequately assess and mitigate the potential air quality impacts that the Project may have on the environment.

Greenhouse Gas
Failure to Adequately Evaluate Greenhouse Gas Impacts
The DEIR concludes that the Project will result in a significant-and-unavoidable GHG impact, stating:
“Because there is no feasible mitigation to reduce potentially significant impacts resulting from GHG emissions of the project, impacts would remain significant and unavoidable” (DEIR, p. 4.1 - 9).

The DEIR specifically states that because the City cannot require the elimination of natural gas from the Project, no other mitigation is available:
“The City is unable to implement mitigation to reduce this significant impact based on a recent court case titled California Restaurant Association v. City of Berkeley. Briefly, in this case, the California Restaurant Association sued Berkeley in the U.S. District Court for the Northern District of California, arguing among other things that the federal Energy Policy and Conservation Act (EPCA) preempted the City’s ordinance banning natural gas in new buildings.

The District Court dismissed the California Restaurant Association’s challenge. However, the Ninth Circuit reversed the District Court, holding that EPCA expressly preempts state and local regulations concerning the energy use of many natural gas appliances. The Ninth Circuit concluded that EPCA preempted Berkeley’s ban of natural gas, because it prohibited the onsite installation of natural gas infrastructure necessary to support natural gas appliances covered under the EPCA. Accordingly, based on the decision of the Ninth Circuit in California Restaurant Association v. City of Berkeley, the City of San Leandro cannot require the project applicant to eliminate natural gas from the proposed project. No other mitigation is available to eliminate the use of natural gas in the proposed project” (p. 4.1-9). 64 6
While we understand the City may not be able to require the elimination of natural gas from the Project, other feasible mitigation measures exist that would lessen Project emissions. To reduce the Project’s GHG impacts to the maximum extent possible, additional feasible mitigation measures should be incorporated, such as those suggested in the section of this letter titled “Feasible Mitigation Measures Available to Reduce Emissions.” The Project should not be approved until a revised EIR is prepared, incorporating all feasible mitigation to reduce emissions to the maximum extent possible.

Mitigation
Feasible Mitigation Measures Available to Reduce Emissions According to CEQA Guidelines § 15096(g)(2):
“When an updated EIR has been prepared for a project, the Responsible Agency shall not approve the project as proposed if the agency finds any feasible alternative or feasible mitigation measures within its powers that would substantially lessen or avoid any significant effect the project would have on the environment.”
The DEIR is consequently required under CEQA to implement all feasible mitigation to reduce the Project’s potential impacts. As demonstrated in the sections above, the Project would result in potentially significant air quality and GHG impacts that should be mitigated further.

First, in order to reduce the VOC emissions associated with Project construction, we recommend the DEIR consider incorporating the following mitigation measure from the California Department of Justice (“DOJ”):
5 • Require the use of super compliant, low-VOC paints less than 10 g/L during the architectural coating construction phase and during Project maintenance.

SCAQMD staff recommends: 6
• Use of water-based or low VOC cleaning products that go beyond the requirements of South Coast AQMD Rule 1113.

Furthermore, Los Angeles County recommends:7
• If paints and coatings with VOC content of 0 grams/liter to less than 10 grams/liter cannot be utilized, the developer shall avoid application of architectural coatings during the peak smog season: July, August, and September.
5 “Warehouse Projects: Best Practices and Mitigation Measures to Comply with the California Environmental Quality Act.” State of California Department of Justice, September 2022, available at:
https://oag.ca.gov/system/files/media/warehouse-best-practices.pdf, p. 8 – 10. 6 “Notice of Preparation of a Draft Environmental Impact Report for the Banning Commerce Center Project (Proposed Project).” SCAQMD, September 2022, available at: https://ceqanet.opr.ca.gov/2022090102. 7 “Mitigation Monitoring and Reporting Program.” Los Angeles County Housing Element Update Program EIR.

August 2021, available at: https://planning.lacounty.gov/wp-content/uploads/2023/07/Housing_final-peirmitigation-monitoring.pdf. 65 7
While the Project is not located in Los Angeles County, the use of low-VOC paints would nonetheless decrease the Project’s significant VOC emissions.

Second, in order to reduce the GHG emissions associated with the Project, we recommend several mitigation measures (see list below).

Southern California Association of Governments (“SCAG”)’s 2020 RTP/SCS Program Environmental Impact Report’s Greenhouse Gas Project Level Mitigation Measures recommends:
• Measures that encourage transit use, carpooling, bike-share and car-share programs, active transportation, and parking strategies, including, but not limited to the following:
o Promote transit-active transportation coordinated strategies, o Increase bicycle carrying capacity on transit and rail vehicles, o Improve or increase access to transit,
o Increase access to common goods and services, such as groceries, schools, and day care, o Incorporate the neighborhood electric vehicle network, o Orient the project toward transit, bicycle and pedestrian facilities, o Improve pedestrian or bicycle networks, or transit service, o Provide traffic calming measures,
o Provide bicycle parking,
o Limit or eliminate park supply,
o Unbundle parking costs,
o Provide parking cash-out programs, and
o Implement or provide access to commute reduction program; • 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;
• 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; • Designate a percentage of parking spaces for ride-sharing vehicles or high-occupancy vehicles, and provide adequate passenger loading and unloading for those vehicles; • 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;
• Implement preferential parking permit program;
• 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:
o Provide car-sharing, bike sharing, and ride-sharing programs, o Provide transit passes,
o Shift single occupancy vehicle trips to carpooling or vanpooling, for example providing ride-matching services,
66 8
o Provide incentives or subsidies that increase that use of modes other than singleoccupancy vehicle, and o Provide on-site amenities at places of work, such as priority parking for carpools and vanpools, secure bike parking, and showers and locker rooms.

The California Air Resources Board (“CARB”) recommends: 8 • Ensuring the cleanest possible construction practices and equipment are used. This includes eliminating the idling of diesel-powered equipment and providing the necessary infrastructure (e.g., electrical hookups) to support zero and near-zero equipment and tools; • Requiring all off-road diesel-powered equipment used during construction to be equipped with Tier 4 or cleaner engines, except for specialized construction equipment in which Tier 4 engines are not available. In place of Tier 4 engines, off-road equipment can incorporate retrofits, such that, emission reductions achieved are equal to or exceed that of a Tier 4 engine; • Requiring all heavy-duty trucks entering the construction site during the grading and building construction phases be model year 2014 or later. All heavy-duty haul trucks should also meet CARB’s lowest optional low-oxides of nitrogen (NOx) standard starting in the year 2022; • Require all construction equipment and fleets to be in compliance with all current air quality regulations;
• Requiring all loading/unloading docks and trailer spaces be equipped with electrical hookups for trucks with transport refrigeration units (TRU) or auxiliary power units; • Requiring all TRUs entering the project-site be plug-in capable; • Requiring all service equipment (e.g., yard hostlers, yard equipment, forklifts, and pallet jacks) used within the project site to be zero-emission;
• Requiring future tenants to exclusively use zero-emission light and medium-duty delivery trucks and vans;
• Including contractual language in tenant lease agreements restricting trucks and support equipment from idling longer than two minutes while on site; and • Requiring the installing of vegetative walls or other effective barriers that separate loading docks and people living or working nearby.

The DOJ recommends: 9
• Installing solar photovoltaic systems on the project site of a specified electrical generation capacity that is equal to or greater than the building’s projected energy needs, including all electrical chargers;
• Designing all project building roofs to accommodate the maximum future coverage of solar panels and installing the maximum solar power generation capacity feasible; 8 “Recommended Air Pollution Emission Reduction Measures for Warehouses and Distribution Centers.” CARB, August 2023, available at: https://ww2.arb.ca.gov/sites/default/files/2023-08/CARB%20Comments%20- %20NOP%20for%20the%20%20Oak%20Valley%20North%20Project%20DEIR.pdf; Attachment A, p. 5 – 8. 9 Ibid. p. 9 – 10. 67 9
• Oversizing electrical rooms by 25 percent or providing a secondary electrical room to accommodate future expansion of electric vehicle charging capability; • Requiring all stand-by emergency generators to be powered by a non-diesel fuel; • Meeting CalGreen Tier 2 green building standards, including all provisions related to designated parking for clean air vehicles, electric vehicle charging, and bicycle parking; • Designing to LEED green building certification standards; • Constructing zero-emission truck charging/fueling stations proportional to the number of dock doors at the project;
• Running conduit to designated locations for future electric truck charging stations; • Constructing and maintaining electric light-duty vehicle charging stations proportional to the number of employee parking spaces;
• Running conduit to an additional proportion of employee parking spaces for a future increase in the number of electric light-duty charging stations;
• Requiring facility operators to train managers and employees on efficient scheduling and load management to eliminate unnecessary queuing and idling of trucks; • Providing meal options onsite or shuttles between the facility and nearby meal destinations. • Posting signs at every truck exit driveway providing directional information to the truck route; • Requiring that every tenant train its staff in charge of keeping vehicle records in diesel technologies and compliance with CARB regulations, by attending CARB-approved courses. Also require facility operators to maintain records on-site demonstrating compliance and make records available for inspection by the local jurisdiction, air district, and state upon request; • Requiring tenants to enroll in the United States Environmental Protection Agency’s SmartWay program, and requiring tenants who own, operate, or hire trucking carriers with more than 100 trucks to use carriers that are SmartWay carriers; and
• Providing tenants with information on incentive programs, such as the Carl Moyer Program and Voucher Incentive Program, to upgrade their fleets.

SCAQMD staff recommends: 10
• Maximizing the use of solar energy by installing solar energy arrays; • Using light-colored paving and roofing materials; and • Utilizing only Energy Star heating, cooling, and lighting devices and appliances.

CEQA Guidelines 15126.4 (c)(3) include “[o]ffsite measures, including offsets that are not otherwise required, to mitigate a project’s emissions” as an option for GHG mitigation. 11 An example of this was in
10 “Draft Environmental Impact Report (EIR) for the Proposed CADO Menifee Industrial Warehouse Project (Proposed Project).” SCAQMD, April 2024, available at: https://www.aqmd.gov/docs/defaultsource/ceqa/comment-letters/2024/april-2024/RVC240313-05.pdf?sfvrsn=8, p. 3. 11 “Cal. Code Regs. tit. 14 § 15126.4.” CEQA Guidelines, May 2024, available at:
https://casetext.com/regulation/california-code-of-regulations/title-14-natural-resources/division-6-resourcesagency/chapter-3-guidelines-for-implementation-of-the-california-environmental-quality-act/article-9-contents-ofenvironmental-impact-reports/section-151264-consideration-and-discussion-of-mitigation-measures-proposed-tominimize-significant-effects. 68 10
the case of the Oakland Sports and Mixed-Use Project, where off-site reduction measures in the neighboring communities were recommended.12 We recommend consideration of local carbon offset programs to reduce the Project’s GHG impacts as a measure of last result.

As demonstrated above, we have provided several mitigation measures that would reduce Projectrelated ROG and GHG emissions developed from sources including SCAG, the DOJ and others. 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.

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

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

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

Paul E. Rosenfeld, Ph.D.
12 “Cal. Pub. Resources Code § 21168.6.7.” 2023, available at: https://casetext.com/statute/californiacodes/california-public-resources-code/division-13-environmental-quality/chapter-6-limitations/section-2116867- oakland-sports-and-mixed-use-project-conditions-for-approval-certification-of-project-for-streamlining. 69 Attachment A: Construction Calculations
Attachment B: CalEEMod Output Files
Attachment C: Matt Hagemann CV
Attachment D: Paul Rosenfeld CV
70 Phase
Default Phase
Length
Construction
Duration %
Construction
Duration
Revised Phase
Length
Demolition 20 559 0.0358 549 20
Site Preparation 10 559 0.0179 549 10
Grading 30 559 0.0537 549 29
Construction 300 559 0.5367 549 295
Paving 20 559 0.0358 549 20
Architectural Coating 20 559 0.0358 549 20
Total Default
Construction
Duration
Revised
Construction
Duration
Start Date 3/1/2024 3/1/2024
End Date 9/11/2025 9/1/2025
Total Days 559 549
Construction Schedule Calculations
Attachment A
71 880 Doolittle Drive Industrial Project
Alameda County, Annual
Project Characteristics - Consistent with the DEIR's model Land Use - Consistent with DEIR's model
Construction Phase - See SWAPE's comment on "Unsubstantiated Changes to Individual Construction Phase Lengths" Off-road Equipment - Consistent with the DEIR's model.

Grading - Consistent with the DEIR's model
Vehicle Trips - Consistent with the DEIR's model
Construction Off-road Equipment Mitigation - Consistent with DEIR's model.

Fleet Mix - Consistent with the DEIR's model.

1.1 Land Usage
Land Uses Size Metric Lot Acreage Floor Surface Area Population Manufacturing 245.20 1000sqft 5.63 245,200.00 0
Parking Lot 401.79 1000sqft 9.22 401,790.00 0

1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
4 Wind Speed (m/s) 2.2 Precipitation Freq (Days) 63

1.3 User Entered Comments & Non-Default Data

1.0 Project Characteristics
Utility Company Pacific Gas and Electric Company
Operational Year 2025
CO2 Intensity
(lb/MWhr)
203.98 CH4 Intensity 0.033
(lb/MWhr)
N2O Intensity 0.004
(lb/MWhr)
Table Name Column Name Default Value New Value
tblConstDustMitigation CleanPavedRoadPercentReduction 0 6 CalEEMod Version: CalEEMod.2020.4.0 Page 1 of 33 Date: 7/31/2024 9:08 AM 880 Doolittle Drive Industrial Project - Alameda County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied Attachment B
72 tblConstDustMitigation WaterUnpavedRoadMoistureContent 0 12 tblConstDustMitigation WaterUnpavedRoadVehicleSpeed 0 15 tblConstructionPhase NumDays 300.00 295.00
tblConstructionPhase NumDays 30.00 29.00
tblFleetMix HHD 0.01 0.00
tblFleetMix HHD 0.01 1.00
tblFleetMix LDA 0.57 1.00
tblFleetMix LDA 0.57 0.00
tblFleetMix LDT1 0.06 0.00
tblFleetMix LDT1 0.06 0.00
tblFleetMix LDT2 0.18 0.00
tblFleetMix LDT2 0.18 0.00
tblFleetMix LHD1 0.02 0.00
tblFleetMix LHD1 0.02 0.00
tblFleetMix LHD2 5.2110e-003 0.00
tblFleetMix LHD2 5.2110e-003 0.00
tblFleetMix MCY 0.02 0.00
tblFleetMix MCY 0.02 0.00
tblFleetMix MDV 0.11 0.00
tblFleetMix MDV 0.11 0.00
tblFleetMix MH 2.4230e-003 0.00
tblFleetMix MH 2.4230e-003 0.00
tblFleetMix MHD 0.01 0.00
tblFleetMix MHD 0.01 0.00
tblFleetMix OBUS 7.9000e-004 0.00
tblFleetMix OBUS 7.9000e-004 0.00
tblFleetMix SBUS 3.4300e-004 0.00
tblFleetMix SBUS 3.4300e-004 0.00
tblFleetMix UBUS 5.6000e-004 0.00
CalEEMod Version: CalEEMod.2020.4.0 Page 2 of 33 Date: 7/31/2024 9:08 AM 880 Doolittle Drive Industrial Project - Alameda County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 73 2.0 Emissions Summary
tblFleetMix UBUS 5.6000e-004 0.00
tblGrading MaterialExported 0.00 15,000.00
tblVehicleTrips CC_TL 7.30 0.00
tblVehicleTrips CC_TTP 28.00 0.00
tblVehicleTrips CNW_TL 7.30 65.50
tblVehicleTrips CNW_TTP 13.00 0.00
tblVehicleTrips CW_TL 9.50 0.00
tblVehicleTrips CW_TTP 59.00 100.00
tblVehicleTrips DV_TP 5.00 0.00
tblVehicleTrips PB_TP 3.00 0.00
tblVehicleTrips PR_TP 92.00 100.00
tblVehicleTrips PR_TP 0.00 100.00
tblVehicleTrips ST_TR 6.42 6.25
tblVehicleTrips ST_TR 0.00 0.12
tblVehicleTrips SU_TR 5.09 6.25
tblVehicleTrips SU_TR 0.00 0.12
tblVehicleTrips WD_TR 3.93 6.25
tblVehicleTrips WD_TR 0.00 0.12
CalEEMod Version: CalEEMod.2020.4.0 Page 3 of 33 Date: 7/31/2024 9:08 AM 880 Doolittle Drive Industrial Project - Alameda County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 74 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
2024 0.2716 2.4842 2.6755 7.4300e0030.4796 0.0915 0.5711 0.1708 0.0855 0.2562 0.0000 677.4208 677.4208 0.0940 0.0361 690.5409 2025 1.5293 1.2890 1.7248 4.6900e0030.1991 0.0432 0.2423 0.0541 0.0406 0.0947 0.0000 428.9692 428.9692 0.0485 0.0231 437.0687 Maximum 1.5293 2.4842 2.6755 7.4300e0030.4796 0.0915 0.5711 0.1708 0.0855 0.2562 0.0000 677.4208 677.4208 0.0940 0.0361 690.5409 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
2024 0.2716 2.4842 2.6755 7.4300e0030.4675 0.0915 0.5589 0.1678 0.0855 0.2533 0.0000 677.4204 677.4204 0.0940 0.0361 690.5405 2025 1.5293 1.2890 1.7248 4.6900e0030.1892 0.0432 0.2324 0.0516 0.0406 0.0922 0.0000 428.9690 428.9690 0.0485 0.0231 437.0685 Maximum 1.5293 2.4842 2.6755 7.4300e0030.4675 0.0915 0.5589 0.1678 0.0855 0.2533 0.0000 677.4204 677.4204 0.0940 0.0361 690.5405 Mitigated Construction
CalEEMod Version: CalEEMod.2020.4.0 Page 4 of 33 Date: 7/31/2024 9:08 AM 880 Doolittle Drive Industrial Project - Alameda County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 75 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 3.24 0.00 2.71 2.40 0.00 1.54 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 3-1-2024 5-31-2024 1.1724 1.1724
2 6-1-2024 8-31-2024 0.6769 0.6769
3 9-1-2024 11-30-2024 0.6775 0.6775
4 12-1-2024 2-28-2025 0.6492 0.6492
5 3-1-2025 5-31-2025 0.6425 0.6425
6 6-1-2025 8-31-2025 1.6082 1.6082
7 9-1-2025 9-30-2025 0.1476 0.1476
Highest 1.6082 1.6082
CalEEMod Version: CalEEMod.2020.4.0 Page 5 of 33 Date: 7/31/2024 9:08 AM 880 Doolittle Drive Industrial Project - Alameda County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 76 2.2 Overall Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Area 1.1204 5.0000e0055.9300e0030.0000 2.0000e0052.0000e0052.0000e0052.0000e0050.0000 0.0116 0.0116 3.0000e0050.0000 0.0123 Energy 0.0346 0.3147 0.2643 1.8900e0030.0239 0.0239 0.0239 0.0239 0.0000 539.3348 539.3348 0.0384 0.0101 543.3162 Mobile 0.2280 0.1014 1.2836 3.0000e0040.0000 1.0100e0031.0100e0030.0000 9.3000e0049.3000e0040.0000 28.2398 28.2398 0.0240 0.0130 32.7025 Waste 0.0000 0.0000 0.0000 0.0000 61.7194 0.0000 61.7194 3.6475 0.0000 152.9072 Water 0.0000 0.0000 0.0000 0.0000 17.9891 28.3879 46.3770 1.8522 0.0442 105.8498 Total 1.3830 0.4161 1.5539 2.1900e0030.0000 0.0250 0.0250 0.0000 0.0249 0.0249 79.7085 595.9741 675.6826 5.5622 0.0673 834.7881 Unmitigated Operational
CalEEMod Version: CalEEMod.2020.4.0 Page 6 of 33 Date: 7/31/2024 9:08 AM 880 Doolittle Drive Industrial Project - Alameda County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 77 2.2 Overall Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Area 1.1204 5.0000e0055.9300e0030.0000 2.0000e0052.0000e0052.0000e0052.0000e0050.0000 0.0116 0.0116 3.0000e0050.0000 0.0123 Energy 0.0346 0.3147 0.2643 1.8900e0030.0239 0.0239 0.0239 0.0239 0.0000 539.3348 539.3348 0.0384 0.0101 543.3162 Mobile 0.2280 0.1014 1.2836 3.0000e0040.0000 1.0100e0031.0100e0030.0000 9.3000e0049.3000e0040.0000 28.2398 28.2398 0.0240 0.0130 32.7025 Waste 0.0000 0.0000 0.0000 0.0000 61.7194 0.0000 61.7194 3.6475 0.0000 152.9072 Water 0.0000 0.0000 0.0000 0.0000 17.9891 28.3879 46.3770 1.8522 0.0442 105.8498 Total 1.3830 0.4161 1.5539 2.1900e0030.0000 0.0250 0.0250 0.0000 0.0249 0.0249 79.7085 595.9741 675.6826 5.5622 0.0673 834.7881 Mitigated Operational

0.00 0.00 0.00 0.00 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 7 of 33 Date: 7/31/2024 9:08 AM 880 Doolittle Drive Industrial Project - Alameda County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 78 4 Building Construction Building Construction 5/23/2024 7/9/2025 5 295 5 Paving Paving 7/10/2025 8/6/2025 5 20
6 Architectural Coating Architectural Coating 8/7/2025 9/3/2025 5 20 OffRoad Equipment
Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor Demolition Concrete/Industrial Saws 1 8.00 81 0.73
Demolition Excavators 3 8.00 158 0.38
Demolition Generator Sets 1 8.00 84 0.74
Demolition Other Construction Equipment 1 8.00 172 0.42 Demolition Rubber Tired Dozers 2 8.00 247 0.40
Demolition Tractors/Loaders/Backhoes 1 8.00 97 0.37
Site Preparation Rubber Tired Dozers 3 8.00 247 0.40
Site Preparation Tractors/Loaders/Backhoes 4 8.00 97 0.37 Grading Excavators 2 8.00 158 0.38
Grading Graders 1 8.00 187 0.41
Grading Rubber Tired Dozers 1 8.00 247 0.40
Grading Scrapers 2 8.00 367 0.48
Grading Tractors/Loaders/Backhoes 2 8.00 97 0.37
Building Construction Cranes 1 7.00 231 0.29
Building Construction Forklifts 3 8.00 89 0.20
Building Construction Generator Sets 1 8.00 84 0.74
Building Construction Tractors/Loaders/Backhoes 3 7.00 97 0.37 Residential Indoor: 0; Residential Outdoor: 0; Non-Residential Indoor: 367,800; Non-Residential Outdoor: 122,600; Striped Parking Area:
24,107 (Architectural Coating – sqft)
Acres of Grading (Site Preparation Phase): 15
Acres of Grading (Grading Phase): 87
Acres of Paving: 9.22
CalEEMod Version: CalEEMod.2020.4.0 Page 8 of 33 Date: 7/31/2024 9:08 AM 880 Doolittle Drive Industrial Project - Alameda County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 79 3.1 Mitigation Measures Construction
Water Unpaved Roads
Reduce Vehicle Speed on Unpaved Roads
Clean Paved Roads
Building Construction Welders 1 8.00 46 0.45
Paving Pavers 2 8.00 130 0.42
Paving Paving Equipment 2 8.00 132 0.36
Paving Rollers 2 8.00 80 0.38
Architectural Coating Air Compressors 1 6.00 78 0.48
Trips and VMT
Phase Name Offroad Equipment
Count
Worker Trip
Number
Vendor Trip
Number
Hauling Trip
Number
Worker Trip
Length
Vendor Trip
Length
Hauling Trip
Length
Worker Vehicle
Class
Vendor
Vehicle Class
Hauling
Vehicle Class
Demolition 9 23.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT Site Preparation 7 18.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT Grading 8 20.00 0.00 1,875.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT Building Construction 9 272.00 106.00 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 54.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT CalEEMod Version: CalEEMod.2020.4.0 Page 9 of 33 Date: 7/31/2024 9:08 AM 880 Doolittle Drive Industrial Project - Alameda County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 80 3.2 Demolition - 2024
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 0.0301 0.2808 0.2962 5.5000e0040.0130 0.0130 0.0122 0.0122 0.0000 47.8129 47.8129 0.0124 0.0000 48.1224 Total 0.0301 0.2808 0.2962 5.5000e0040.0130 0.0130 0.0122 0.0122 0.0000 47.8129 47.8129 0.0124 0.0000 48.1224 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 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 5.6000e0043.7000e0044.7900e0031.0000e0051.8200e0031.0000e0051.8300e0034.8000e0041.0000e0054.9000e0040.0000 1.3984 1.3984 4.0000e0054.0000e0051.4104 Total 5.6000e0043.7000e0044.7900e0031.0000e0051.8200e0031.0000e0051.8300e0034.8000e0041.0000e0054.9000e0040.0000 1.3984 1.3984 4.0000e0054.0000e0051.4104 Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 10 of 33 Date: 7/31/2024 9:08 AM 880 Doolittle Drive Industrial Project - Alameda County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 81 3.2 Demolition - 2024
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 0.0301 0.2808 0.2962 5.5000e0040.0130 0.0130 0.0122 0.0122 0.0000 47.8128 47.8128 0.0124 0.0000 48.1224 Total 0.0301 0.2808 0.2962 5.5000e0040.0130 0.0130 0.0122 0.0122 0.0000 47.8128 47.8128 0.0124 0.0000 48.1224 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 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 5.6000e0043.7000e0044.7900e0031.0000e0051.7200e0031.0000e0051.7300e0034.6000e0041.0000e0054.7000e0040.0000 1.3984 1.3984 4.0000e0054.0000e0051.4104 Total 5.6000e0043.7000e0044.7900e0031.0000e0051.7200e0031.0000e0051.7300e0034.6000e0041.0000e0054.7000e0040.0000 1.3984 1.3984 4.0000e0054.0000e0051.4104 Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 11 of 33 Date: 7/31/2024 9:08 AM 880 Doolittle Drive Industrial Project - Alameda County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 82 3.3 Site Preparation - 2024
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 0.0983 0.0000 0.0983 0.0505 0.0000 0.0505 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0133 0.1359 0.0917 1.9000e0046.1500e0036.1500e0035.6600e0035.6600e0030.0000 16.7285 16.7285 5.4100e0030.0000 16.8638 Total 0.0133 0.1359 0.0917 1.9000e0040.0983 6.1500e0030.1044 0.0505 5.6600e0030.0562 0.0000 16.7285 16.7285 5.4100e0030.0000 16.8638 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 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 2.2000e0041.4000e0041.8700e0031.0000e0057.1000e0040.0000 7.2000e0041.9000e0040.0000 1.9000e0040.0000 0.5472 0.5472 1.0000e0051.0000e0050.5519 Total 2.2000e0041.4000e0041.8700e0031.0000e0057.1000e0040.0000 7.2000e0041.9000e0040.0000 1.9000e0040.0000 0.5472 0.5472 1.0000e0051.0000e0050.5519 Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 12 of 33 Date: 7/31/2024 9:08 AM 880 Doolittle Drive Industrial Project - Alameda County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 83 3.3 Site Preparation - 2024
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 0.0983 0.0000 0.0983 0.0505 0.0000 0.0505 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0133 0.1359 0.0917 1.9000e0046.1500e0036.1500e0035.6500e0035.6500e0030.0000 16.7285 16.7285 5.4100e0030.0000 16.8638 Total 0.0133 0.1359 0.0917 1.9000e0040.0983 6.1500e0030.1044 0.0505 5.6500e0030.0562 0.0000 16.7285 16.7285 5.4100e0030.0000 16.8638 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 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 2.2000e0041.4000e0041.8700e0031.0000e0056.7000e0040.0000 6.8000e0041.8000e0040.0000 1.8000e0040.0000 0.5472 0.5472 1.0000e0051.0000e0050.5519 Total 2.2000e0041.4000e0041.8700e0031.0000e0056.7000e0040.0000 6.8000e0041.8000e0040.0000 1.8000e0040.0000 0.5472 0.5472 1.0000e0051.0000e0050.5519 Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 13 of 33 Date: 7/31/2024 9:08 AM 880 Doolittle Drive Industrial Project - Alameda County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 84 3.4 Grading - 2024
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 0.1343 0.0000 0.1343 0.0531 0.0000 0.0531 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0467 0.4695 0.4020 9.0000e0040.0194 0.0194 0.0178 0.0178 0.0000 79.0533 79.0533 0.0256 0.0000 79.6925 Total 0.0467 0.4695 0.4020 9.0000e0040.1343 0.0194 0.1537 0.0531 0.0178 0.0709 0.0000 79.0533 79.0533 0.0256 0.0000 79.6925 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 tons/yr MT/yr
Hauling 1.9300e0030.1237 0.0281 5.5000e0040.0159 1.0600e0030.0170 4.3700e0031.0100e0035.3900e0030.0000 53.8271 53.8271 1.1700e0038.5100e00356.3909 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 7.1000e0044.6000e0046.0400e0032.0000e0052.2900e0031.0000e0052.3000e0036.1000e0041.0000e0056.2000e0040.0000 1.7632 1.7632 5.0000e0055.0000e0051.7783 Total 2.6400e0030.1242 0.0341 5.7000e0040.0182 1.0700e0030.0193 4.9800e0031.0200e0036.0100e0030.0000 55.5902 55.5902 1.2200e0038.5600e00358.1692 Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 14 of 33 Date: 7/31/2024 9:08 AM 880 Doolittle Drive Industrial Project - Alameda County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 85 3.4 Grading - 2024
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 0.1343 0.0000 0.1343 0.0531 0.0000 0.0531 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0467 0.4695 0.4020 9.0000e0040.0194 0.0194 0.0178 0.0178 0.0000 79.0532 79.0532 0.0256 0.0000 79.6924 Total 0.0467 0.4695 0.4020 9.0000e0040.1343 0.0194 0.1537 0.0531 0.0178 0.0709 0.0000 79.0532 79.0532 0.0256 0.0000 79.6924 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 tons/yr MT/yr
Hauling 1.9300e0030.1237 0.0281 5.5000e0040.0152 1.0600e0030.0162 4.2000e0031.0100e0035.2100e0030.0000 53.8271 53.8271 1.1700e0038.5100e00356.3909 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 7.1000e0044.6000e0046.0400e0032.0000e0052.1700e0031.0000e0052.1900e0035.8000e0041.0000e0055.9000e0040.0000 1.7632 1.7632 5.0000e0055.0000e0051.7783 Total 2.6400e0030.1242 0.0341 5.7000e0040.0174 1.0700e0030.0184 4.7800e0031.0200e0035.8000e0030.0000 55.5902 55.5902 1.2200e0038.5600e00358.1692 Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 15 of 33 Date: 7/31/2024 9:08 AM 880 Doolittle Drive Industrial Project - Alameda County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 86 3.5 Building Construction - 2024
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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 0.1170 1.0688 1.2853 2.1400e0030.0488 0.0488 0.0459 0.0459 0.0000 184.3200 184.3200 0.0436 0.0000 185.4097 Total 0.1170 1.0688 1.2853 2.1400e0030.0488 0.0488 0.0459 0.0459 0.0000 184.3200 184.3200 0.0436 0.0000 185.4097 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 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 8.3100e0030.3699 0.1093 1.6600e0030.0554 2.2400e0030.0576 0.0160 2.1500e0030.0182 0.0000 160.4992 160.4992 2.2200e0030.0241 167.7208 Worker 0.0529 0.0347 0.4503 1.4000e0030.1710 8.5000e0040.1718 0.0455 7.8000e0040.0463 0.0000 131.4710 131.4710 3.6000e0033.4900e003132.6003 Total 0.0612 0.4046 0.5597 3.0600e0030.2263 3.0900e0030.2294 0.0615 2.9300e0030.0644 0.0000 291.9702 291.9702 5.8200e0030.0275 300.3211 Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 16 of 33 Date: 7/31/2024 9:08 AM 880 Doolittle Drive Industrial Project - Alameda County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 87 3.5 Building Construction - 2024
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 0.1170 1.0688 1.2853 2.1400e0030.0488 0.0488 0.0459 0.0459 0.0000 184.3198 184.3198 0.0436 0.0000 185.4095 Total 0.1170 1.0688 1.2853 2.1400e0030.0488 0.0488 0.0459 0.0459 0.0000 184.3198 184.3198 0.0436 0.0000 185.4095 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 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 8.3100e0030.3699 0.1093 1.6600e0030.0530 2.2400e0030.0553 0.0154 2.1500e0030.0176 0.0000 160.4992 160.4992 2.2200e0030.0241 167.7208 Worker 0.0529 0.0347 0.4503 1.4000e0030.1621 8.5000e0040.1630 0.0433 7.8000e0040.0441 0.0000 131.4710 131.4710 3.6000e0033.4900e003132.6003 Total 0.0612 0.4046 0.5597 3.0600e0030.2151 3.0900e0030.2182 0.0588 2.9300e0030.0617 0.0000 291.9702 291.9702 5.8200e0030.0275 300.3211 Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 17 of 33 Date: 7/31/2024 9:08 AM 880 Doolittle Drive Industrial Project - Alameda County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 88 3.5 Building Construction - 2025
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.0930 0.8479 1.0938 1.8300e0030.0359 0.0359 0.0338 0.0338 0.0000 157.7052 157.7052 0.0371 0.0000 158.6320 Total 0.0930 0.8479 1.0938 1.8300e0030.0359 0.0359 0.0338 0.0338 0.0000 157.7052 157.7052 0.0371 0.0000 158.6320 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 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 6.9600e0030.3161 0.0920 1.3900e0030.0474 1.9200e0030.0493 0.0137 1.8400e0030.0155 0.0000 134.8364 134.8364 1.9000e0030.0202 140.9065 Worker 0.0425 0.0267 0.3617 1.1600e0030.1462 6.9000e0040.1469 0.0389 6.4000e0040.0395 0.0000 109.7604 109.7604 2.8000e0032.8000e003110.6640 Total 0.0494 0.3428 0.4537 2.5500e0030.1936 2.6100e0030.1962 0.0526 2.4800e0030.0551 0.0000 244.5968 244.5968 4.7000e0030.0230 251.5705 Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 18 of 33 Date: 7/31/2024 9:08 AM 880 Doolittle Drive Industrial Project - Alameda County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 89 3.5 Building Construction - 2025
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.0930 0.8479 1.0938 1.8300e0030.0359 0.0359 0.0338 0.0338 0.0000 157.7050 157.7050 0.0371 0.0000 158.6318 Total 0.0930 0.8479 1.0938 1.8300e0030.0359 0.0359 0.0338 0.0338 0.0000 157.7050 157.7050 0.0371 0.0000 158.6318 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 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 6.9600e0030.3161 0.0920 1.3900e0030.0454 1.9200e0030.0473 0.0132 1.8400e0030.0151 0.0000 134.8364 134.8364 1.9000e0030.0202 140.9065 Worker 0.0425 0.0267 0.3617 1.1600e0030.1387 6.9000e0040.1394 0.0370 6.4000e0040.0377 0.0000 109.7604 109.7604 2.8000e0032.8000e003110.6640 Total 0.0494 0.3428 0.4537 2.5500e0030.1840 2.6100e0030.1866 0.0503 2.4800e0030.0527 0.0000 244.5968 244.5968 4.7000e0030.0230 251.5705 Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 19 of 33 Date: 7/31/2024 9:08 AM 880 Doolittle Drive Industrial Project - Alameda County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 90 3.6 Paving - 2025
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 9.1500e0030.0858 0.1458 2.3000e0044.1900e0034.1900e0033.8500e0033.8500e0030.0000 20.0193 20.0193 6.4700e0030.0000 20.1811 Paving 0.0121 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0212 0.0858 0.1458 2.3000e0044.1900e0034.1900e0033.8500e0033.8500e0030.0000 20.0193 20.0193 6.4700e0030.0000 20.1811 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 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 3.4000e0042.2000e0042.9300e0031.0000e0051.1900e0031.0000e0051.1900e0033.2000e0041.0000e0053.2000e0040.0000 0.8901 0.8901 2.0000e0052.0000e0050.8975 Total 3.4000e0042.2000e0042.9300e0031.0000e0051.1900e0031.0000e0051.1900e0033.2000e0041.0000e0053.2000e0040.0000 0.8901 0.8901 2.0000e0052.0000e0050.8975 Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 20 of 33 Date: 7/31/2024 9:08 AM 880 Doolittle Drive Industrial Project - Alameda County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 91 3.6 Paving - 2025
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 9.1500e0030.0858 0.1458 2.3000e0044.1900e0034.1900e0033.8500e0033.8500e0030.0000 20.0192 20.0192 6.4700e0030.0000 20.1811 Paving 0.0121 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0212 0.0858 0.1458 2.3000e0044.1900e0034.1900e0033.8500e0033.8500e0030.0000 20.0192 20.0192 6.4700e0030.0000 20.1811 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 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 3.4000e0042.2000e0042.9300e0031.0000e0051.1200e0031.0000e0051.1300e0033.0000e0041.0000e0053.1000e0040.0000 0.8901 0.8901 2.0000e0052.0000e0050.8975 Total 3.4000e0042.2000e0042.9300e0031.0000e0051.1200e0031.0000e0051.1300e0033.0000e0041.0000e0053.1000e0040.0000 0.8901 0.8901 2.0000e0052.0000e0050.8975 Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 21 of 33 Date: 7/31/2024 9:08 AM 880 Doolittle Drive Industrial Project - Alameda County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 92 3.7 Architectural Coating - 2025
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Archit. Coating 1.3624 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 1.7100e0030.0115 0.0181 3.0000e0055.2000e0045.2000e0045.2000e0045.2000e0040.0000 2.5533 2.5533 1.4000e0040.0000 2.5567 Total 1.3641 0.0115 0.0181 3.0000e0055.2000e0045.2000e0045.2000e0045.2000e0040.0000 2.5533 2.5533 1.4000e0040.0000 2.5567 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 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 1.2400e0037.8000e0040.0106 3.0000e0054.2700e0032.0000e0054.2900e0031.1400e0032.0000e0051.1500e0030.0000 3.2045 3.2045 8.0000e0058.0000e0053.2309 Total 1.2400e0037.8000e0040.0106 3.0000e0054.2700e0032.0000e0054.2900e0031.1400e0032.0000e0051.1500e0030.0000 3.2045 3.2045 8.0000e0058.0000e0053.2309 Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 22 of 33 Date: 7/31/2024 9:08 AM 880 Doolittle Drive Industrial Project - Alameda County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 93 3.7 Architectural Coating - 2025
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Archit. Coating 1.3624 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 1.7100e0030.0115 0.0181 3.0000e0055.2000e0045.2000e0045.2000e0045.2000e0040.0000 2.5533 2.5533 1.4000e0040.0000 2.5567 Total 1.3641 0.0115 0.0181 3.0000e0055.2000e0045.2000e0045.2000e0045.2000e0040.0000 2.5533 2.5533 1.4000e0040.0000 2.5567 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 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 1.2400e0037.8000e0040.0106 3.0000e0054.0500e0032.0000e0054.0700e0031.0800e0032.0000e0051.1000e0030.0000 3.2045 3.2045 8.0000e0058.0000e0053.2309 Total 1.2400e0037.8000e0040.0106 3.0000e0054.0500e0032.0000e0054.0700e0031.0800e0032.0000e0051.1000e0030.0000 3.2045 3.2045 8.0000e0058.0000e0053.2309 Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 23 of 33 Date: 7/31/2024 9:08 AM 880 Doolittle Drive Industrial Project - Alameda County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 94 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 tons/yr MT/yr
Mitigated 0.2280 0.1014 1.2836 3.0000e0040.0000 1.0100e0031.0100e0030.0000 9.3000e0049.3000e0040.0000 28.2398 28.2398 0.0240 0.0130 32.7025 Unmitigated 0.2280 0.1014 1.2836 3.0000e0040.0000 1.0100e0031.0100e0030.0000 9.3000e0049.3000e0040.0000 28.2398 28.2398 0.0240 0.0130 32.7025

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
Manufacturing 1,532.50 1,532.50 1532.50
Parking Lot 0.00 0.00 0.00
Total 1,532.50 1,532.50 1,532.50
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 Manufacturing 0.00 0.00 65.50 100.00 0.00 0.00 100 0 0
Parking Lot 9.50 7.30 7.30 0.00 0.00 0.00 100 0 0

4.4 Fleet Mix
CalEEMod Version: CalEEMod.2020.4.0 Page 24 of 33 Date: 7/31/2024 9:08 AM 880 Doolittle Drive Industrial Project - Alameda County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 95 Land Use LDA LDT1 LDT2 MDV LHD1 LHD2 MHD HHD OBUS UBUS MCY SBUS MH Manufacturing 1.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 Parking Lot 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 1.000000 0.000000 0.000000 0.000000 0.000000 0.000000

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 tons/yr MT/yr
Electricity
Mitigated

0.0000 0.0000 0.0000 0.0000 0.0000 196.7746 196.7746 0.0318 3.8600e003198.7204 Electricity
Unmitigated

0.0000 0.0000 0.0000 0.0000 0.0000 196.7746 196.7746 0.0318 3.8600e003198.7204 NaturalGas
Mitigated

0.0346 0.3147 0.2643 1.8900e0030.0239 0.0239 0.0239 0.0239 0.0000 342.5602 342.5602 6.5700e0036.2800e003344.5959 NaturalGas
Unmitigated

0.0346 0.3147 0.2643 1.8900e0030.0239 0.0239 0.0239 0.0239 0.0000 342.5602 342.5602 6.5700e0036.2800e003344.5959

5.1 Mitigation Measures Energy
Historical Energy Use: N
CalEEMod Version: CalEEMod.2020.4.0 Page 25 of 33 Date: 7/31/2024 9:08 AM 880 Doolittle Drive Industrial Project - Alameda County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 96 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
Manufacturing 6.41934e
+006

0.0346 0.3147 0.2643 1.8900e0030.0239 0.0239 0.0239 0.0239 0.0000 342.5602 342.5602 6.5700e0036.2800e003344.5959 Parking Lot 0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0346 0.3147 0.2643 1.8900e0030.0239 0.0239 0.0239 0.0239 0.0000 342.5602 342.5602 6.5700e0036.2800e003344.5959 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
Manufacturing 6.41934e
+006

0.0346 0.3147 0.2643 1.8900e0030.0239 0.0239 0.0239 0.0239 0.0000 342.5602 342.5602 6.5700e0036.2800e003344.5959 Parking Lot 0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0346 0.3147 0.2643 1.8900e0030.0239 0.0239 0.0239 0.0239 0.0000 342.5602 342.5602 6.5700e0036.2800e003344.5959 Mitigated
CalEEMod Version: CalEEMod.2020.4.0 Page 26 of 33 Date: 7/31/2024 9:08 AM 880 Doolittle Drive Industrial Project - Alameda County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 97 6.0 Area Detail

5.3 Energy by Land Use - Electricity
Electricity
Use
Total CO2 CH4 N2O CO2e
Land Use kWh/yr MT/yr
Manufacturing 1.98612e
+006
183.7633 0.0297 3.6000e003185.5804
Parking Lot 140627 13.0113 2.1000e0032.6000e00413.1400 Total 196.7746 0.0318 3.8600e003198.7204
Unmitigated
Electricity
Use
Total CO2 CH4 N2O CO2e
Land Use kWh/yr MT/yr
Manufacturing 1.98612e
+006
183.7633 0.0297 3.6000e003185.5804
Parking Lot 140627 13.0113 2.1000e0032.6000e00413.1400 Total 196.7746 0.0318 3.8600e003198.7204
Mitigated
CalEEMod Version: CalEEMod.2020.4.0 Page 27 of 33 Date: 7/31/2024 9:08 AM 880 Doolittle Drive Industrial Project - Alameda County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 98 6.1 Mitigation Measures Area
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Mitigated 1.1204 5.0000e0055.9300e0030.0000 2.0000e0052.0000e0052.0000e0052.0000e0050.0000 0.0116 0.0116 3.0000e0050.0000 0.0123 Unmitigated 1.1204 5.0000e0055.9300e0030.0000 2.0000e0052.0000e0052.0000e0052.0000e0050.0000 0.0116 0.0116 3.0000e0050.0000 0.0123

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

0.1362 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Consumer
Products

0.9836 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Landscaping 5.5000e0045.0000e0055.9300e0030.0000 2.0000e0052.0000e0052.0000e0052.0000e0050.0000 0.0116 0.0116 3.0000e0050.0000 0.0123 Total 1.1204 5.0000e0055.9300e0030.0000 2.0000e0052.0000e0052.0000e0052.0000e0050.0000 0.0116 0.0116 3.0000e0050.0000 0.0123 Unmitigated
CalEEMod Version: CalEEMod.2020.4.0 Page 28 of 33 Date: 7/31/2024 9:08 AM 880 Doolittle Drive Industrial Project - Alameda County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 99 7.1 Mitigation Measures Water

7.0 Water Detail

0.1362 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Consumer
Products

0.9836 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Landscaping 5.5000e0045.0000e0055.9300e0030.0000 2.0000e0052.0000e0052.0000e0052.0000e0050.0000 0.0116 0.0116 3.0000e0050.0000 0.0123 Total 1.1204 5.0000e0055.9300e0030.0000 2.0000e0052.0000e0052.0000e0052.0000e0050.0000 0.0116 0.0116 3.0000e0050.0000 0.0123 Mitigated
CalEEMod Version: CalEEMod.2020.4.0 Page 29 of 33 Date: 7/31/2024 9:08 AM 880 Doolittle Drive Industrial Project - Alameda County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 100
Total CO2 CH4 N2O CO2e
Category MT/yr
Mitigated 46.3770 1.8522 0.0442 105.8498
Unmitigated 46.3770 1.8522 0.0442 105.8498

7.2 Water by Land Use
Indoor/Out
door Use
Total CO2 CH4 N2O CO2e
Land Use Mgal MT/yr
Manufacturing 56.7025 /
0 46.3770 1.8522 0.0442 105.8498
Parking Lot 0 / 0 0.0000 0.0000 0.0000 0.0000
Total 46.3770 1.8522 0.0442 105.8498
Unmitigated
CalEEMod Version: CalEEMod.2020.4.0 Page 30 of 33 Date: 7/31/2024 9:08 AM 880 Doolittle Drive Industrial Project - Alameda County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 101

8.1 Mitigation Measures Waste

8.0 Waste Detail
Total CO2 CH4 N2O CO2e
MT/yr
Mitigated 61.7194 3.6475 0.0000 152.9072
Unmitigated 61.7194 3.6475 0.0000 152.9072
Category/Year
CalEEMod Version: CalEEMod.2020.4.0 Page 31 of 33 Date: 7/31/2024 9:08 AM 880 Doolittle Drive Industrial Project - Alameda County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 102

8.2 Waste by Land Use
Waste
Disposed
Total CO2 CH4 N2O CO2e
Land Use tons MT/yr
Manufacturing 304.05 61.7194 3.6475 0.0000 152.9072
Parking Lot 0 0.0000 0.0000 0.0000 0.0000
Total 61.7194 3.6475 0.0000 152.9072
Unmitigated
Waste
Disposed
Total CO2 CH4 N2O CO2e
Land Use tons MT/yr
Manufacturing 304.05 61.7194 3.6475 0.0000 152.9072
Parking Lot 0 0.0000 0.0000 0.0000 0.0000
Total 61.7194 3.6475 0.0000 152.9072
Mitigated

9.0 Operational Offroad
CalEEMod Version: CalEEMod.2020.4.0 Page 32 of 33 Date: 7/31/2024 9:08 AM 880 Doolittle Drive Industrial Project - Alameda County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 103

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 33 of 33 Date: 7/31/2024 9:08 AM 880 Doolittle Drive Industrial Project - Alameda County, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 104
880 Doolittle Drive Industrial Project
Alameda County, Summer
Project Characteristics - Consistent with the DEIR's model Land Use - Consistent with DEIR's model
Construction Phase - See SWAPE's comment on "Unsubstantiated Changes to Individual Construction Phase Lengths" Off-road Equipment - Consistent with the DEIR's model.

Grading - Consistent with the DEIR's model
Vehicle Trips - Consistent with the DEIR's model
Construction Off-road Equipment Mitigation - Consistent with DEIR's model.

Fleet Mix - Consistent with the DEIR's model.

1.1 Land Usage
Land Uses Size Metric Lot Acreage Floor Surface Area Population Manufacturing 245.20 1000sqft 5.63 245,200.00 0
Parking Lot 401.79 1000sqft 9.22 401,790.00 0

1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
4 Wind Speed (m/s) 2.2 Precipitation Freq (Days) 63

1.3 User Entered Comments & Non-Default Data

2.0 Emissions Summary
tblFleetMix UBUS 5.6000e-004 0.00
tblGrading MaterialExported 0.00 15,000.00
tblVehicleTrips CC_TL 7.30 0.00
tblVehicleTrips CC_TTP 28.00 0.00
tblVehicleTrips CNW_TL 7.30 65.50
tblVehicleTrips CNW_TTP 13.00 0.00
tblVehicleTrips CW_TL 9.50 0.00
tblVehicleTrips CW_TTP 59.00 100.00
tblVehicleTrips DV_TP 5.00 0.00
tblVehicleTrips PB_TP 3.00 0.00
tblVehicleTrips PR_TP 92.00 100.00
tblVehicleTrips PR_TP 0.00 100.00
tblVehicleTrips ST_TR 6.42 6.25
tblVehicleTrips ST_TR 0.00 0.12
tblVehicleTrips SU_TR 5.09 6.25
tblVehicleTrips SU_TR 0.00 0.12
tblVehicleTrips WD_TR 3.93 6.25
tblVehicleTrips WD_TR 0.00 0.12
CalEEMod Version: CalEEMod.2020.4.0 Page 3 of 29 Date: 7/31/2024 9:09 AM 880 Doolittle Drive Industrial Project - Alameda County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 107

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
2024 3.4070 40.6252 30.1344 0.1014 19.8049 1.4092 21.0349 10.1417 1.2992 11.2733 0.0000 10,243.26 72 10,243.26
72 2.0359 0.6496 10,487.73
44 2025 136.5390 17.2997 23.1216 0.0657 2.9529 0.5660 3.5188 0.7995 0.5326 1.3322 0.0000 6,643.897 0 6,643.897
0 0.7160 0.3690 6,770.691
6 Maximum 136.5390 40.6252 30.1344 0.1014 19.8049 1.4092 21.0349 10.1417 1.2992 11.2733 0.0000 10,243.26 72 10,243.26
72 2.0359 0.6496 10,487.73
44 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
2024 3.4070 40.6252 30.1344 0.1014 19.7972 1.4092 21.0272 10.1398 1.2992 11.2714 0.0000 10,243.26 72 10,243.26
72 2.0359 0.6496 10,487.73
44 2025 136.5390 17.2997 23.1216 0.0657 2.8057 0.5660 3.3716 0.7634 0.5326 1.2961 0.0000 6,643.897 0 6,643.897
0 0.7160 0.3690 6,770.691
6 Maximum 136.5390 40.6252 30.1344 0.1014 19.7972 1.4092 21.0272 10.1398 1.2992 11.2714 0.0000 10,243.26 72 10,243.26
72 2.0359 0.6496 10,487.73
44 Mitigated Construction
CalEEMod Version: CalEEMod.2020.4.0 Page 4 of 29 Date: 7/31/2024 9:09 AM 880 Doolittle Drive Industrial Project - Alameda County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 108
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 0.68 0.00 0.63 0.35 0.00 0.30 0.00 0.00 0.00 0.00 0.00 0.00 CalEEMod Version: CalEEMod.2020.4.0 Page 5 of 29 Date: 7/31/2024 9:09 AM 880 Doolittle Drive Industrial Project - Alameda County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 109

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 6.1422 6.0000e0040.0659 0.0000 2.3000e0042.3000e0042.3000e0042.3000e0040.1416 0.1416 3.7000e0040.1508 Energy 0.1897 1.7242 1.4484 0.0104 0.1310 0.1310 0.1310 0.1310 2,069.084 9 2,069.084
9 0.0397 0.0379 2,081.380
5 Mobile 1.4432 0.4882 5.4081 1.6100e0030.0000 5.5800e0035.5800e0030.0000 5.1300e0035.1300e003168.1517 168.1517 0.1210 0.0714 192.4669 Total 7.7750 2.2130 6.9224 0.0120 0.0000 0.1369 0.1369 0.0000 0.1364 0.1364 2,237.378 2 2,237.378
2 0.1610 0.1094 2,273.998
2 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 6.1422 6.0000e0040.0659 0.0000 2.3000e0042.3000e0042.3000e0042.3000e0040.1416 0.1416 3.7000e0040.1508 Energy 0.1897 1.7242 1.4484 0.0104 0.1310 0.1310 0.1310 0.1310 2,069.084 9 2,069.084
9 0.0397 0.0379 2,081.380
5 Mobile 1.4432 0.4882 5.4081 1.6100e0030.0000 5.5800e0035.5800e0030.0000 5.1300e0035.1300e003168.1517 168.1517 0.1210 0.0714 192.4669 Total 7.7750 2.2130 6.9224 0.0120 0.0000 0.1369 0.1369 0.0000 0.1364 0.1364 2,237.378 2 2,237.378
2 0.1610 0.1094 2,273.998
2 Mitigated Operational
CalEEMod Version: CalEEMod.2020.4.0 Page 6 of 29 Date: 7/31/2024 9:09 AM 880 Doolittle Drive Industrial Project - Alameda County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 110

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 3/1/2024 3/28/2024 5 20
2 Site Preparation Site Preparation 3/29/2024 4/11/2024 5 10 3 Grading Grading 4/12/2024 5/22/2024 5 29
4 Building Construction Building Construction 5/23/2024 7/9/2025 5 295 5 Paving Paving 7/10/2025 8/6/2025 5 20
6 Architectural Coating Architectural Coating 8/7/2025 9/3/2025 5 20 OffRoad Equipment
Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor Demolition Concrete/Industrial Saws 1 8.00 81 0.73
Demolition Excavators 3 8.00 158 0.38
Demolition Generator Sets 1 8.00 84 0.74
Demolition Other Construction Equipment 1 8.00 172 0.42 Demolition Rubber Tired Dozers 2 8.00 247 0.40
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: 367,800; Non-Residential Outdoor: 122,600; Striped Parking Area:
24,107 (Architectural Coating – sqft)
Acres of Grading (Site Preparation Phase): 15
Acres of Grading (Grading Phase): 87
Acres of Paving: 9.22
CalEEMod Version: CalEEMod.2020.4.0 Page 7 of 29 Date: 7/31/2024 9:09 AM 880 Doolittle Drive Industrial Project - Alameda County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 111

3.1 Mitigation Measures Construction
Demolition Tractors/Loaders/Backhoes 1 8.00 97 0.37
Site Preparation Rubber Tired Dozers 3 8.00 247 0.40
Site Preparation Tractors/Loaders/Backhoes 4 8.00 97 0.37 Grading Excavators 2 8.00 158 0.38
Grading Graders 1 8.00 187 0.41
Grading Rubber Tired Dozers 1 8.00 247 0.40
Grading Scrapers 2 8.00 367 0.48
Grading Tractors/Loaders/Backhoes 2 8.00 97 0.37
Building Construction Cranes 1 7.00 231 0.29
Building Construction Forklifts 3 8.00 89 0.20
Building Construction Generator Sets 1 8.00 84 0.74
Building Construction Tractors/Loaders/Backhoes 3 7.00 97 0.37 Building Construction Welders 1 8.00 46 0.45
Paving Pavers 2 8.00 130 0.42
Paving Paving Equipment 2 8.00 132 0.36
Paving Rollers 2 8.00 80 0.38
Architectural Coating Air Compressors 1 6.00 78 0.48
Trips and VMT
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 9 23.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT Site Preparation 7 18.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT Grading 8 20.00 0.00 1,875.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT Building Construction 9 272.00 106.00 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 54.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT CalEEMod Version: CalEEMod.2020.4.0 Page 8 of 29 Date: 7/31/2024 9:09 AM 880 Doolittle Drive Industrial Project - Alameda County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 112

3.2 Demolition - 2024
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 3.0046 28.0819 29.6196 0.0547 1.3030 1.3030 1.2165 1.2165 5,270.468 6 5,270.468
6 1.3648 5,304.587
8 Total 3.0046 28.0819 29.6196 0.0547 1.3030 1.3030 1.2165 1.2165 5,270.468 6 5,270.468
6 1.3648 5,304.587
8 Unmitigated Construction On-Site
Water Unpaved Roads
Reduce Vehicle Speed on Unpaved Roads
Clean Paved Roads
CalEEMod Version: CalEEMod.2020.4.0 Page 9 of 29 Date: 7/31/2024 9:09 AM 880 Doolittle Drive Industrial Project - Alameda County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 113

3.2 Demolition - 2024
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 0.0597 0.0325 0.5148 1.6000e0030.1889 9.0000e0040.1898 0.0501 8.3000e0040.0510 164.9056 164.9056 3.9200e0033.7600e003166.1244 Total 0.0597 0.0325 0.5148 1.6000e0030.1889 9.0000e0040.1898 0.0501 8.3000e0040.0510 164.9056 164.9056 3.9200e0033.7600e003166.1244 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 lb/day lb/day
Off-Road 3.0046 28.0819 29.6196 0.0547 1.3030 1.3030 1.2165 1.2165 0.0000 5,270.468 6 5,270.468
6 1.3648 5,304.587
8 Total 3.0046 28.0819 29.6196 0.0547 1.3030 1.3030 1.2165 1.2165 0.0000 5,270.468 6 5,270.468
6 1.3648 5,304.587
8 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 10 of 29 Date: 7/31/2024 9:09 AM 880 Doolittle Drive Industrial Project - Alameda County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 114

3.3 Site Preparation - 2024
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 19.6570 0.0000 19.6570 10.1025 0.0000 10.1025 0.0000 0.0000 Off-Road 2.6609 27.1760 18.3356 0.0381 1.2294 1.2294 1.1310 1.1310 3,688.010 0 3,688.010
0 1.1928 3,717.829
4 Total 2.6609 27.1760 18.3356 0.0381 19.6570 1.2294 20.8864 10.1025 1.1310 11.2335 3,688.010 0 3,688.010
0 1.1928 3,717.829
4 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 11 of 29 Date: 7/31/2024 9:09 AM 880 Doolittle Drive Industrial Project - Alameda County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 115

3.3 Site Preparation - 2024
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 0.0467 0.0254 0.4029 1.2500e0030.1479 7.1000e0040.1486 0.0392 6.5000e0040.0399 129.0566 129.0566 3.0700e0032.9400e003130.0104 Total 0.0467 0.0254 0.4029 1.2500e0030.1479 7.1000e0040.1486 0.0392 6.5000e0040.0399 129.0566 129.0566 3.0700e0032.9400e003130.0104 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 lb/day lb/day
Fugitive Dust 19.6570 0.0000 19.6570 10.1025 0.0000 10.1025 0.0000 0.0000 Off-Road 2.6609 27.1760 18.3356 0.0381 1.2294 1.2294 1.1310 1.1310 0.0000 3,688.010 0 3,688.010
0 1.1928 3,717.829
4 Total 2.6609 27.1760 18.3356 0.0381 19.6570 1.2294 20.8864 10.1025 1.1310 11.2335 0.0000 3,688.010 0 3,688.010
0 1.1928 3,717.829
4 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 12 of 29 Date: 7/31/2024 9:09 AM 880 Doolittle Drive Industrial Project - Alameda County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 116

3.4 Grading - 2024
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 9.2621 0.0000 9.2621 3.6626 0.0000 3.6626 0.0000 0.0000 Off-Road 3.2181 32.3770 27.7228 0.0621 1.3354 1.3354 1.2286 1.2286 6,009.748 7 6,009.748
7 1.9437 6,058.340
5 Total 3.2181 32.3770 27.7228 0.0621 9.2621 1.3354 10.5975 3.6626 1.2286 4.8912 6,009.748 7 6,009.748
7 1.9437 6,058.340
5 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 13 of 29 Date: 7/31/2024 9:09 AM 880 Doolittle Drive Industrial Project - Alameda County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 117

3.4 Grading - 2024
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 0.1370 8.2200 1.9250 0.0379 1.1326 0.0730 1.2056 0.3106 0.0699 0.3805 4,090.122 4 4,090.122
4 0.0889 0.6463 4,284.937
8 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 0.0519 0.0283 0.4476 1.3900e0030.1643 7.8000e0040.1651 0.0436 7.2000e0040.0443 143.3962 143.3962 3.4100e0033.2700e003144.4560 Total 0.1889 8.2482 2.3726 0.0393 1.2969 0.0738 1.3707 0.3542 0.0706 0.4248 4,233.518 5 4,233.518
5 0.0923 0.6496 4,429.393
9 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 lb/day lb/day
Fugitive Dust 9.2621 0.0000 9.2621 3.6626 0.0000 3.6626 0.0000 0.0000 Off-Road 3.2181 32.3770 27.7228 0.0621 1.3354 1.3354 1.2286 1.2286 0.0000 6,009.748 7 6,009.748
7 1.9437 6,058.340
5 Total 3.2181 32.3770 27.7228 0.0621 9.2621 1.3354 10.5975 3.6626 1.2286 4.8912 0.0000 6,009.748 7 6,009.748
7 1.9437 6,058.340
5 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 14 of 29 Date: 7/31/2024 9:09 AM 880 Doolittle Drive Industrial Project - Alameda County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 118

3.5 Building Construction - 2024
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 1.4716 13.4438 16.1668 0.0270 0.6133 0.6133 0.5769 0.5769 2,555.698 9 2,555.698
9 0.6044 2,570.807
7 Total 1.4716 13.4438 16.1668 0.0270 0.6133 0.6133 0.5769 0.5769 2,555.698 9 2,555.698
9 0.6044 2,570.807
7 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 15 of 29 Date: 7/31/2024 9:09 AM 880 Doolittle Drive Industrial Project - Alameda County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 119

3.5 Building Construction - 2024
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 0.1072 4.4874 1.3544 0.0208 0.7184 0.0282 0.7466 0.2069 0.0270 0.2338 2,223.825 0 2,223.825
0 0.0309 0.3330 2,323.839
3 Worker 0.7058 0.3845 6.0877 0.0189 2.2344 0.0107 2.2451 0.5927 9.8200e0030.6025 1,950.188 0 1,950.188
0 0.0464 0.0445 1,964.602
1 Total 0.8130 4.8719 7.4422 0.0397 2.9528 0.0389 2.9917 0.7995 0.0368 0.8363 4,174.013 0 4,174.013
0 0.0773 0.3775 4,288.441
4 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 lb/day lb/day
Off-Road 1.4716 13.4438 16.1668 0.0270 0.6133 0.6133 0.5769 0.5769 0.0000 2,555.698 9 2,555.698
9 0.6044 2,570.807
7 Total 1.4716 13.4438 16.1668 0.0270 0.6133 0.6133 0.5769 0.5769 0.0000 2,555.698 9 2,555.698
9 0.6044 2,570.807
7 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 16 of 29 Date: 7/31/2024 9:09 AM 880 Doolittle Drive Industrial Project - Alameda County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 120

3.5 Building Construction - 2025
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 1.3674 12.4697 16.0847 0.0270 0.5276 0.5276 0.4963 0.4963 2,556.474 4 2,556.474
4 0.6010 2,571.498
1 Total 1.3674 12.4697 16.0847 0.0270 0.5276 0.5276 0.4963 0.4963 2,556.474 4 2,556.474
4 0.6010 2,571.498
1 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 17 of 29 Date: 7/31/2024 9:09 AM 880 Doolittle Drive Industrial Project - Alameda County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 121

3.5 Building Construction - 2025
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
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 0.1050 4.4835 1.3324 0.0205 0.7184 0.0282 0.7467 0.2069 0.0270 0.2339 2,184.188 6 2,184.188
6 0.0309 0.3272 2,282.475
2 Worker 0.6620 0.3465 5.7045 0.0183 2.2344 0.0102 2.2446 0.5927 9.4000e0030.6021 1,903.234 0 1,903.234
0 0.0421 0.0417 1,916.718
3 Total 0.7669 4.8300 7.0369 0.0387 2.9529 0.0384 2.9913 0.7995 0.0364 0.8359 4,087.422 6 4,087.422
6 0.0730 0.3690 4,199.193
5 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 lb/day lb/day
Off-Road 1.3674 12.4697 16.0847 0.0270 0.5276 0.5276 0.4963 0.4963 0.0000 2,556.474 4 2,556.474
4 0.6010 2,571.498
1 Total 1.3674 12.4697 16.0847 0.0270 0.5276 0.5276 0.4963 0.4963 0.0000 2,556.474 4 2,556.474
4 0.6010 2,571.498
1 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 18 of 29 Date: 7/31/2024 9:09 AM 880 Doolittle Drive Industrial Project - Alameda County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 122

3.6 Paving - 2025
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 0.9152 8.5816 14.5780 0.0228 0.4185 0.4185 0.3850 0.3850 2,206.745 2 2,206.745
2 0.7137 2,224.587
8 Paving 1.2078 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 2.1230 8.5816 14.5780 0.0228 0.4185 0.4185 0.3850 0.3850 2,206.745 2 2,206.745
2 0.7137 2,224.587
8 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 19 of 29 Date: 7/31/2024 9:09 AM 880 Doolittle Drive Industrial Project - Alameda County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 123

3.6 Paving - 2025
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
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 0.0365 0.0191 0.3146 1.0100e0030.1232 5.6000e0040.1238 0.0327 5.2000e0040.0332 104.9578 104.9578 2.3200e0032.3000e003105.7014 Total 0.0365 0.0191 0.3146 1.0100e0030.1232 5.6000e0040.1238 0.0327 5.2000e0040.0332 104.9578 104.9578 2.3200e0032.3000e003105.7014 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 lb/day lb/day
Off-Road 0.9152 8.5816 14.5780 0.0228 0.4185 0.4185 0.3850 0.3850 0.0000 2,206.745 2 2,206.745
2 0.7137 2,224.587
8 Paving 1.2078 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 2.1230 8.5816 14.5780 0.0228 0.4185 0.4185 0.3850 0.3850 0.0000 2,206.745 2 2,206.745
2 0.7137 2,224.587
8 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 20 of 29 Date: 7/31/2024 9:09 AM 880 Doolittle Drive Industrial Project - Alameda County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 124

3.7 Architectural Coating - 2025
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Archit. Coating 136.2367 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.1709 1.1455 1.8091 2.9700e0030.0515 0.0515 0.0515 0.0515 281.4481 281.4481 0.0154 281.8319 Total 136.4075 1.1455 1.8091 2.9700e0030.0515 0.0515 0.0515 0.0515 281.4481 281.4481 0.0154 281.8319 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 21 of 29 Date: 7/31/2024 9:09 AM 880 Doolittle Drive Industrial Project - Alameda County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 125

3.7 Architectural Coating - 2025
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
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 0.1314 0.0688 1.1325 3.6300e0030.4436 2.0300e0030.4456 0.1177 1.8700e0030.1195 377.8479 377.8479 8.3600e0038.2800e003380.5250 Total 0.1314 0.0688 1.1325 3.6300e0030.4436 2.0300e0030.4456 0.1177 1.8700e0030.1195 377.8479 377.8479 8.3600e0038.2800e003380.5250 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 lb/day lb/day
Archit. Coating 136.2367 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.1709 1.1455 1.8091 2.9700e0030.0515 0.0515 0.0515 0.0515 0.0000 281.4481 281.4481 0.0154 281.8319 Total 136.4075 1.1455 1.8091 2.9700e0030.0515 0.0515 0.0515 0.0515 0.0000 281.4481 281.4481 0.0154 281.8319 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 22 of 29 Date: 7/31/2024 9:09 AM 880 Doolittle Drive Industrial Project - Alameda County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 126

4.0 Operational Detail - Mobile

4.1 Mitigation Measures Mobile
CalEEMod Version: CalEEMod.2020.4.0 Page 23 of 29 Date: 7/31/2024 9:09 AM 880 Doolittle Drive Industrial Project - Alameda County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 127
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Mitigated 1.4432 0.4882 5.4081 1.6100e0030.0000 5.5800e0035.5800e0030.0000 5.1300e0035.1300e003168.1517 168.1517 0.1210 0.0714 192.4669 Unmitigated 1.4432 0.4882 5.4081 1.6100e0030.0000 5.5800e0035.5800e0030.0000 5.1300e0035.1300e003168.1517 168.1517 0.1210 0.0714 192.4669

4.2 Trip Summary Information

4.4 Fleet Mix
Land Use LDA LDT1 LDT2 MDV LHD1 LHD2 MHD HHD OBUS UBUS MCY SBUS MH Manufacturing 1.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 Parking Lot 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 1.000000 0.000000 0.000000 0.000000 0.000000 0.000000

5.0 Energy Detail
CalEEMod Version: CalEEMod.2020.4.0 Page 24 of 29 Date: 7/31/2024 9:09 AM 880 Doolittle Drive Industrial Project - Alameda County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 128
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

0.1897 1.7242 1.4484 0.0104 0.1310 0.1310 0.1310 0.1310 2,069.084 9 2,069.084
9 0.0397 0.0379 2,081.380
5 NaturalGas
Unmitigated

0.1897 1.7242 1.4484 0.0104 0.1310 0.1310 0.1310 0.1310 2,069.084 9 2,069.084
9 0.0397 0.0379 2,081.380
5 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
Manufacturing 17587.2 0.1897 1.7242 1.4484 0.0104 0.1310 0.1310 0.1310 0.1310 2,069.084 9 2,069.084
9 0.0397 0.0379 2,081.380
5 Parking Lot 0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.1897 1.7242 1.4484 0.0104 0.1310 0.1310 0.1310 0.1310 2,069.084 9 2,069.084
9 0.0397 0.0379 2,081.380
5 Unmitigated

5.1 Mitigation Measures Energy
Historical Energy Use: N
CalEEMod Version: CalEEMod.2020.4.0 Page 25 of 29 Date: 7/31/2024 9:09 AM 880 Doolittle Drive Industrial Project - Alameda County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 129

6.1 Mitigation Measures Area

6.0 Area 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
Mitigated 6.1422 6.0000e0040.0659 0.0000 2.3000e0042.3000e0042.3000e0042.3000e0040.1416 0.1416 3.7000e0040.1508 Unmitigated 6.1422 6.0000e0040.0659 0.0000 2.3000e0042.3000e0042.3000e0042.3000e0040.1416 0.1416 3.7000e0040.1508

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
Manufacturing 17.5872 0.1897 1.7242 1.4484 0.0104 0.1310 0.1310 0.1310 0.1310 2,069.084 9 2,069.084
9 0.0397 0.0379 2,081.380
5 Parking Lot 0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.1897 1.7242 1.4484 0.0104 0.1310 0.1310 0.1310 0.1310 2,069.084 9 2,069.084
9 0.0397 0.0379 2,081.380
5 Mitigated
CalEEMod Version: CalEEMod.2020.4.0 Page 26 of 29 Date: 7/31/2024 9:09 AM 880 Doolittle Drive Industrial Project - Alameda County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 130

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

0.7465 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products

5.3896 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Landscaping 6.0700e0036.0000e0040.0659 0.0000 2.3000e0042.3000e0042.3000e0042.3000e0040.1416 0.1416 3.7000e0040.1508 Total 6.1422 6.0000e0040.0659 0.0000 2.3000e0042.3000e0042.3000e0042.3000e0040.1416 0.1416 3.7000e0040.1508 Unmitigated
CalEEMod Version: CalEEMod.2020.4.0 Page 27 of 29 Date: 7/31/2024 9:09 AM 880 Doolittle Drive Industrial Project - Alameda County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 131

7.1 Mitigation Measures Water

7.0 Water Detail

0.7465 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products

5.3896 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Landscaping 6.0700e0036.0000e0040.0659 0.0000 2.3000e0042.3000e0042.3000e0042.3000e0040.1416 0.1416 3.7000e0040.1508 Total 6.1422 6.0000e0040.0659 0.0000 2.3000e0042.3000e0042.3000e0042.3000e0040.1416 0.1416 3.7000e0040.1508 Mitigated
CalEEMod Version: CalEEMod.2020.4.0 Page 28 of 29 Date: 7/31/2024 9:09 AM 880 Doolittle Drive Industrial Project - Alameda County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 132

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 29 of 29 Date: 7/31/2024 9:09 AM 880 Doolittle Drive Industrial Project - Alameda County, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 133
880 Doolittle Drive Industrial Project
Alameda County, Winter
Project Characteristics - Consistent with the DEIR's model Land Use - Consistent with DEIR's model
Construction Phase - See SWAPE's comment on "Unsubstantiated Changes to Individual Construction Phase Lengths" Off-road Equipment - Consistent with the DEIR's model.

Grading - Consistent with the DEIR's model
Vehicle Trips - Consistent with the DEIR's model
Construction Off-road Equipment Mitigation - Consistent with DEIR's model.

Fleet Mix - Consistent with the DEIR's model.

1.1 Land Usage
Land Uses Size Metric Lot Acreage Floor Surface Area Population Manufacturing 245.20 1000sqft 5.63 245,200.00 0
Parking Lot 401.79 1000sqft 9.22 401,790.00 0

1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
4 Wind Speed (m/s) 2.2 Precipitation Freq (Days) 63

1.3 User Entered Comments & Non-Default Data

2.0 Emissions Summary
tblFleetMix UBUS 5.6000e-004 0.00
tblGrading MaterialExported 0.00 15,000.00
tblVehicleTrips CC_TL 7.30 0.00
tblVehicleTrips CC_TTP 28.00 0.00
tblVehicleTrips CNW_TL 7.30 65.50
tblVehicleTrips CNW_TTP 13.00 0.00
tblVehicleTrips CW_TL 9.50 0.00
tblVehicleTrips CW_TTP 59.00 100.00
tblVehicleTrips DV_TP 5.00 0.00
tblVehicleTrips PB_TP 3.00 0.00
tblVehicleTrips PR_TP 92.00 100.00
tblVehicleTrips PR_TP 0.00 100.00
tblVehicleTrips ST_TR 6.42 6.25
tblVehicleTrips ST_TR 0.00 0.12
tblVehicleTrips SU_TR 5.09 6.25
tblVehicleTrips SU_TR 0.00 0.12
tblVehicleTrips WD_TR 3.93 6.25
tblVehicleTrips WD_TR 0.00 0.12
CalEEMod Version: CalEEMod.2020.4.0 Page 3 of 29 Date: 7/31/2024 9:11 AM 880 Doolittle Drive Industrial Project - Alameda County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 136

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
2024 3.3991 41.1154 30.1160 0.1013 19.8049 1.4093 21.0349 10.1417 1.2993 11.2733 0.0000 10,237.51 21 10,237.51
21 2.0360 0.6508 10,482.35
04 2025 136.5419 17.6495 22.9795 0.0644 2.9529 0.5661 3.5189 0.7995 0.5327 1.3323 0.0000 6,511.715 2 6,511.715
2 0.7164 0.3762 6,640.834
3 Maximum 136.5419 41.1154 30.1160 0.1013 19.8049 1.4093 21.0349 10.1417 1.2993 11.2733 0.0000 10,237.51 21 10,237.51
21 2.0360 0.6508 10,482.35
04 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
2024 3.3991 41.1154 30.1160 0.1013 19.7972 1.4093 21.0272 10.1398 1.2993 11.2714 0.0000 10,237.51 21 10,237.51
21 2.0360 0.6508 10,482.35
04 2025 136.5419 17.6495 22.9795 0.0644 2.8057 0.5661 3.3717 0.7634 0.5327 1.2961 0.0000 6,511.715 2 6,511.715
2 0.7164 0.3762 6,640.834
3 Maximum 136.5419 41.1154 30.1160 0.1013 19.7972 1.4093 21.0272 10.1398 1.2993 11.2714 0.0000 10,237.51 21 10,237.51
21 2.0360 0.6508 10,482.35
04 Mitigated Construction
CalEEMod Version: CalEEMod.2020.4.0 Page 4 of 29 Date: 7/31/2024 9:11 AM 880 Doolittle Drive Industrial Project - Alameda County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 137
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 0.68 0.00 0.63 0.35 0.00 0.30 0.00 0.00 0.00 0.00 0.00 0.00 CalEEMod Version: CalEEMod.2020.4.0 Page 5 of 29 Date: 7/31/2024 9:11 AM 880 Doolittle Drive Industrial Project - Alameda County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 138

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 6.1422 6.0000e0040.0659 0.0000 2.3000e0042.3000e0042.3000e0042.3000e0040.1416 0.1416 3.7000e0040.1508 Energy 0.1897 1.7242 1.4484 0.0104 0.1310 0.1310 0.1310 0.1310 2,069.084 9 2,069.084
9 0.0397 0.0379 2,081.380
5 Mobile 1.2389 0.6062 8.2611 1.6700e0030.0000 5.5800e0035.5800e0030.0000 5.1300e0035.1300e003173.4718 173.4718 0.1622 0.0832 202.3059 Total 7.5707 2.3310 9.7754 0.0120 0.0000 0.1369 0.1369 0.0000 0.1364 0.1364 2,242.698 4 2,242.698
4 0.2022 0.1211 2,283.837
1 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 6.1422 6.0000e0040.0659 0.0000 2.3000e0042.3000e0042.3000e0042.3000e0040.1416 0.1416 3.7000e0040.1508 Energy 0.1897 1.7242 1.4484 0.0104 0.1310 0.1310 0.1310 0.1310 2,069.084 9 2,069.084
9 0.0397 0.0379 2,081.380
5 Mobile 1.2389 0.6062 8.2611 1.6700e0030.0000 5.5800e0035.5800e0030.0000 5.1300e0035.1300e003173.4718 173.4718 0.1622 0.0832 202.3059 Total 7.5707 2.3310 9.7754 0.0120 0.0000 0.1369 0.1369 0.0000 0.1364 0.1364 2,242.698 4 2,242.698
4 0.2022 0.1211 2,283.837
1 Mitigated Operational
CalEEMod Version: CalEEMod.2020.4.0 Page 6 of 29 Date: 7/31/2024 9:11 AM 880 Doolittle Drive Industrial Project - Alameda County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 139

0.00 0.00 0.00 0.00 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: 367,800; Non-Residential Outdoor: 122,600; Striped Parking Area:
24,107 (Architectural Coating – sqft)
Acres of Grading (Site Preparation Phase): 15
Acres of Grading (Grading Phase): 87
Acres of Paving: 9.22
CalEEMod Version: CalEEMod.2020.4.0 Page 7 of 29 Date: 7/31/2024 9:11 AM 880 Doolittle Drive Industrial Project - Alameda County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 140

3.1 Mitigation Measures Construction
Demolition Tractors/Loaders/Backhoes 1 8.00 97 0.37
Site Preparation Rubber Tired Dozers 3 8.00 247 0.40
Site Preparation Tractors/Loaders/Backhoes 4 8.00 97 0.37 Grading Excavators 2 8.00 158 0.38
Grading Graders 1 8.00 187 0.41
Grading Rubber Tired Dozers 1 8.00 247 0.40
Grading Scrapers 2 8.00 367 0.48
Grading Tractors/Loaders/Backhoes 2 8.00 97 0.37
Building Construction Cranes 1 7.00 231 0.29
Building Construction Forklifts 3 8.00 89 0.20
Building Construction Generator Sets 1 8.00 84 0.74
Building Construction Tractors/Loaders/Backhoes 3 7.00 97 0.37 Building Construction Welders 1 8.00 46 0.45
Paving Pavers 2 8.00 130 0.42
Paving Paving Equipment 2 8.00 132 0.36
Paving Rollers 2 8.00 80 0.38
Architectural Coating Air Compressors 1 6.00 78 0.48
Trips and VMT
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 9 23.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT Site Preparation 7 18.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT Grading 8 20.00 0.00 1,875.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT Building Construction 9 272.00 106.00 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 54.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT CalEEMod Version: CalEEMod.2020.4.0 Page 8 of 29 Date: 7/31/2024 9:11 AM 880 Doolittle Drive Industrial Project - Alameda County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 141

3.2 Demolition - 2024
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 3.0046 28.0819 29.6196 0.0547 1.3030 1.3030 1.2165 1.2165 5,270.468 6 5,270.468
6 1.3648 5,304.587
8 Total 3.0046 28.0819 29.6196 0.0547 1.3030 1.3030 1.2165 1.2165 5,270.468 6 5,270.468
6 1.3648 5,304.587
8 Unmitigated Construction On-Site
Water Unpaved Roads
Reduce Vehicle Speed on Unpaved Roads
Clean Paved Roads
CalEEMod Version: CalEEMod.2020.4.0 Page 9 of 29 Date: 7/31/2024 9:11 AM 880 Doolittle Drive Industrial Project - Alameda County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 142

3.2 Demolition - 2024
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 0.0609 0.0404 0.4964 1.4800e0030.1889 9.0000e0040.1898 0.0501 8.3000e0040.0510 153.1060 153.1060 4.5000e0034.3500e003154.5138 Total 0.0609 0.0404 0.4964 1.4800e0030.1889 9.0000e0040.1898 0.0501 8.3000e0040.0510 153.1060 153.1060 4.5000e0034.3500e003154.5138 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 lb/day lb/day
Off-Road 3.0046 28.0819 29.6196 0.0547 1.3030 1.3030 1.2165 1.2165 0.0000 5,270.468 6 5,270.468
6 1.3648 5,304.587
8 Total 3.0046 28.0819 29.6196 0.0547 1.3030 1.3030 1.2165 1.2165 0.0000 5,270.468 6 5,270.468
6 1.3648 5,304.587
8 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 10 of 29 Date: 7/31/2024 9:11 AM 880 Doolittle Drive Industrial Project - Alameda County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 143

3.3 Site Preparation - 2024
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 19.6570 0.0000 19.6570 10.1025 0.0000 10.1025 0.0000 0.0000 Off-Road 2.6609 27.1760 18.3356 0.0381 1.2294 1.2294 1.1310 1.1310 3,688.010 0 3,688.010
0 1.1928 3,717.829
4 Total 2.6609 27.1760 18.3356 0.0381 19.6570 1.2294 20.8864 10.1025 1.1310 11.2335 3,688.010 0 3,688.010
0 1.1928 3,717.829
4 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 11 of 29 Date: 7/31/2024 9:11 AM 880 Doolittle Drive Industrial Project - Alameda County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 144

3.3 Site Preparation - 2024
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 0.0476 0.0316 0.3885 1.1600e0030.1479 7.1000e0040.1486 0.0392 6.5000e0040.0399 119.8221 119.8221 3.5200e0033.4000e003120.9239 Total 0.0476 0.0316 0.3885 1.1600e0030.1479 7.1000e0040.1486 0.0392 6.5000e0040.0399 119.8221 119.8221 3.5200e0033.4000e003120.9239 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 lb/day lb/day
Fugitive Dust 19.6570 0.0000 19.6570 10.1025 0.0000 10.1025 0.0000 0.0000 Off-Road 2.6609 27.1760 18.3356 0.0381 1.2294 1.2294 1.1310 1.1310 0.0000 3,688.010 0 3,688.010
0 1.1928 3,717.829
4 Total 2.6609 27.1760 18.3356 0.0381 19.6570 1.2294 20.8864 10.1025 1.1310 11.2335 0.0000 3,688.010 0 3,688.010
0 1.1928 3,717.829
4 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 12 of 29 Date: 7/31/2024 9:11 AM 880 Doolittle Drive Industrial Project - Alameda County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 145

3.4 Grading - 2024
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 9.2621 0.0000 9.2621 3.6626 0.0000 3.6626 0.0000 0.0000 Off-Road 3.2181 32.3770 27.7228 0.0621 1.3354 1.3354 1.2286 1.2286 6,009.748 7 6,009.748
7 1.9437 6,058.340
5 Total 3.2181 32.3770 27.7228 0.0621 9.2621 1.3354 10.5975 3.6626 1.2286 4.8912 6,009.748 7 6,009.748
7 1.9437 6,058.340
5 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 13 of 29 Date: 7/31/2024 9:11 AM 880 Doolittle Drive Industrial Project - Alameda County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 146

3.4 Grading - 2024
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 0.1280 8.7033 1.9529 0.0380 1.1326 0.0731 1.2057 0.3106 0.0700 0.3806 4,094.627 8 4,094.627
8 0.0884 0.6470 4,289.650
0 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 0.0529 0.0351 0.4317 1.2900e0030.1643 7.8000e0040.1651 0.0436 7.2000e0040.0443 133.1356 133.1356 3.9100e0033.7800e003134.3599 Total 0.1809 8.7384 2.3846 0.0392 1.2969 0.0739 1.3708 0.3542 0.0707 0.4249 4,227.763 4 4,227.763
4 0.0923 0.6508 4,424.009
9 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 lb/day lb/day
Fugitive Dust 9.2621 0.0000 9.2621 3.6626 0.0000 3.6626 0.0000 0.0000 Off-Road 3.2181 32.3770 27.7228 0.0621 1.3354 1.3354 1.2286 1.2286 0.0000 6,009.748 7 6,009.748
7 1.9437 6,058.340
5 Total 3.2181 32.3770 27.7228 0.0621 9.2621 1.3354 10.5975 3.6626 1.2286 4.8912 0.0000 6,009.748 7 6,009.748
7 1.9437 6,058.340
5 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 14 of 29 Date: 7/31/2024 9:11 AM 880 Doolittle Drive Industrial Project - Alameda County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 147

3.5 Building Construction - 2024
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 1.4716 13.4438 16.1668 0.0270 0.6133 0.6133 0.5769 0.5769 2,555.698 9 2,555.698
9 0.6044 2,570.807
7 Total 1.4716 13.4438 16.1668 0.0270 0.6133 0.6133 0.5769 0.5769 2,555.698 9 2,555.698
9 0.6044 2,570.807
7 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 15 of 29 Date: 7/31/2024 9:11 AM 880 Doolittle Drive Industrial Project - Alameda County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 148

3.5 Building Construction - 2024
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 0.1020 4.7541 1.3998 0.0209 0.7184 0.0283 0.7467 0.2069 0.0271 0.2339 2,227.606 4 2,227.606
4 0.0306 0.3339 2,327.863
6 Worker 0.7196 0.4773 5.8709 0.0176 2.2344 0.0107 2.2451 0.5927 9.8200e0030.6025 1,810.644 5 1,810.644
5 0.0532 0.0514 1,827.294
2 Total 0.8217 5.2314 7.2707 0.0384 2.9528 0.0390 2.9918 0.7995 0.0369 0.8364 4,038.250 9 4,038.250
9 0.0838 0.3853 4,155.157
7 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 lb/day lb/day
Off-Road 1.4716 13.4438 16.1668 0.0270 0.6133 0.6133 0.5769 0.5769 0.0000 2,555.698 9 2,555.698
9 0.6044 2,570.807
7 Total 1.4716 13.4438 16.1668 0.0270 0.6133 0.6133 0.5769 0.5769 0.0000 2,555.698 9 2,555.698
9 0.6044 2,570.807
7 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 16 of 29 Date: 7/31/2024 9:11 AM 880 Doolittle Drive Industrial Project - Alameda County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 149

3.5 Building Construction - 2025
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 1.3674 12.4697 16.0847 0.0270 0.5276 0.5276 0.4963 0.4963 2,556.474 4 2,556.474
4 0.6010 2,571.498
1 Total 1.3674 12.4697 16.0847 0.0270 0.5276 0.5276 0.4963 0.4963 2,556.474 4 2,556.474
4 0.6010 2,571.498
1 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 17 of 29 Date: 7/31/2024 9:11 AM 880 Doolittle Drive Industrial Project - Alameda County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 150

3.5 Building Construction - 2025
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
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 0.0997 4.7497 1.3771 0.0205 0.7184 0.0283 0.7467 0.2069 0.0271 0.2339 2,187.936 5 2,187.936
5 0.0306 0.3280 2,286.457
7 Worker 0.6767 0.4301 5.5177 0.0170 2.2344 0.0102 2.2446 0.5927 9.4000e0030.6021 1,767.304 3 1,767.304
3 0.0484 0.0482 1,782.878
6 Total 0.7764 5.1798 6.8948 0.0375 2.9529 0.0385 2.9914 0.7995 0.0365 0.8360 3,955.240 8 3,955.240
8 0.0790 0.3762 4,069.336
3 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 lb/day lb/day
Off-Road 1.3674 12.4697 16.0847 0.0270 0.5276 0.5276 0.4963 0.4963 0.0000 2,556.474 4 2,556.474
4 0.6010 2,571.498
1 Total 1.3674 12.4697 16.0847 0.0270 0.5276 0.5276 0.4963 0.4963 0.0000 2,556.474 4 2,556.474
4 0.6010 2,571.498
1 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 18 of 29 Date: 7/31/2024 9:11 AM 880 Doolittle Drive Industrial Project - Alameda County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 151

3.6 Paving - 2025
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 0.9152 8.5816 14.5780 0.0228 0.4185 0.4185 0.3850 0.3850 2,206.745 2 2,206.745
2 0.7137 2,224.587
8 Paving 1.2078 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 2.1230 8.5816 14.5780 0.0228 0.4185 0.4185 0.3850 0.3850 2,206.745 2 2,206.745
2 0.7137 2,224.587
8 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 19 of 29 Date: 7/31/2024 9:11 AM 880 Doolittle Drive Industrial Project - Alameda County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 152

3.6 Paving - 2025
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
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 0.0373 0.0237 0.3043 9.4000e0040.1232 5.6000e0040.1238 0.0327 5.2000e0040.0332 97.4616 97.4616 2.6700e0032.6600e00398.3205 Total 0.0373 0.0237 0.3043 9.4000e0040.1232 5.6000e0040.1238 0.0327 5.2000e0040.0332 97.4616 97.4616 2.6700e0032.6600e00398.3205 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 lb/day lb/day
Off-Road 0.9152 8.5816 14.5780 0.0228 0.4185 0.4185 0.3850 0.3850 0.0000 2,206.745 2 2,206.745
2 0.7137 2,224.587
8 Paving 1.2078 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 2.1230 8.5816 14.5780 0.0228 0.4185 0.4185 0.3850 0.3850 0.0000 2,206.745 2 2,206.745
2 0.7137 2,224.587
8 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 20 of 29 Date: 7/31/2024 9:11 AM 880 Doolittle Drive Industrial Project - Alameda County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 153

3.7 Architectural Coating - 2025
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Archit. Coating 136.2367 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.1709 1.1455 1.8091 2.9700e0030.0515 0.0515 0.0515 0.0515 281.4481 281.4481 0.0154 281.8319 Total 136.4075 1.1455 1.8091 2.9700e0030.0515 0.0515 0.0515 0.0515 281.4481 281.4481 0.0154 281.8319 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 21 of 29 Date: 7/31/2024 9:11 AM 880 Doolittle Drive Industrial Project - Alameda County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 154

3.7 Architectural Coating - 2025
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
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 0.1344 0.0854 1.0954 3.3700e0030.4436 2.0300e0030.4456 0.1177 1.8700e0030.1195 350.8619 350.8619 9.6100e0039.5700e003353.9538 Total 0.1344 0.0854 1.0954 3.3700e0030.4436 2.0300e0030.4456 0.1177 1.8700e0030.1195 350.8619 350.8619 9.6100e0039.5700e003353.9538 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 lb/day lb/day
Archit. Coating 136.2367 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.1709 1.1455 1.8091 2.9700e0030.0515 0.0515 0.0515 0.0515 0.0000 281.4481 281.4481 0.0154 281.8319 Total 136.4075 1.1455 1.8091 2.9700e0030.0515 0.0515 0.0515 0.0515 0.0000 281.4481 281.4481 0.0154 281.8319 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 22 of 29 Date: 7/31/2024 9:11 AM 880 Doolittle Drive Industrial Project - Alameda County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 155

4.0 Operational Detail - Mobile

4.1 Mitigation Measures Mobile
CalEEMod Version: CalEEMod.2020.4.0 Page 23 of 29 Date: 7/31/2024 9:11 AM 880 Doolittle Drive Industrial Project - Alameda County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 156
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Mitigated 1.2389 0.6062 8.2611 1.6700e0030.0000 5.5800e0035.5800e0030.0000 5.1300e0035.1300e003173.4718 173.4718 0.1622 0.0832 202.3059 Unmitigated 1.2389 0.6062 8.2611 1.6700e0030.0000 5.5800e0035.5800e0030.0000 5.1300e0035.1300e003173.4718 173.4718 0.1622 0.0832 202.3059

4.2 Trip Summary Information

5.0 Energy Detail
CalEEMod Version: CalEEMod.2020.4.0 Page 24 of 29 Date: 7/31/2024 9:11 AM 880 Doolittle Drive Industrial Project - Alameda County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 157
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

0.1897 1.7242 1.4484 0.0104 0.1310 0.1310 0.1310 0.1310 2,069.084 9 2,069.084
9 0.0397 0.0379 2,081.380
5 NaturalGas
Unmitigated

5.1 Mitigation Measures Energy
Historical Energy Use: N
CalEEMod Version: CalEEMod.2020.4.0 Page 25 of 29 Date: 7/31/2024 9:11 AM 880 Doolittle Drive Industrial Project - Alameda County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 158

6.1 Mitigation Measures Area

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
Manufacturing 17.5872 0.1897 1.7242 1.4484 0.0104 0.1310 0.1310 0.1310 0.1310 2,069.084 9 2,069.084
9 0.0397 0.0379 2,081.380
5 Parking Lot 0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.1897 1.7242 1.4484 0.0104 0.1310 0.1310 0.1310 0.1310 2,069.084 9 2,069.084
9 0.0397 0.0379 2,081.380
5 Mitigated
CalEEMod Version: CalEEMod.2020.4.0 Page 26 of 29 Date: 7/31/2024 9:11 AM 880 Doolittle Drive Industrial Project - Alameda County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 159

0.7465 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products

5.3896 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Landscaping 6.0700e0036.0000e0040.0659 0.0000 2.3000e0042.3000e0042.3000e0042.3000e0040.1416 0.1416 3.7000e0040.1508 Total 6.1422 6.0000e0040.0659 0.0000 2.3000e0042.3000e0042.3000e0042.3000e0040.1416 0.1416 3.7000e0040.1508 Unmitigated
CalEEMod Version: CalEEMod.2020.4.0 Page 27 of 29 Date: 7/31/2024 9:11 AM 880 Doolittle Drive Industrial Project - Alameda County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 160

7.1 Mitigation Measures Water

7.0 Water Detail

0.7465 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products

5.3896 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Landscaping 6.0700e0036.0000e0040.0659 0.0000 2.3000e0042.3000e0042.3000e0042.3000e0040.1416 0.1416 3.7000e0040.1508 Total 6.1422 6.0000e0040.0659 0.0000 2.3000e0042.3000e0042.3000e0042.3000e0040.1416 0.1416 3.7000e0040.1508 Mitigated
CalEEMod Version: CalEEMod.2020.4.0 Page 28 of 29 Date: 7/31/2024 9:11 AM 880 Doolittle Drive Industrial Project - Alameda County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 161

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 29 of 29 Date: 7/31/2024 9:11 AM 880 Doolittle Drive Industrial Project - Alameda County, Winter EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Applied 162
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 C
163
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.
164
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 165
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 166
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).
167
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.
168
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 r i z a t i o n and Cl ean up a t 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. 169
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.
170

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 12 October 2022
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. Focus on wastewater treatment.

Professional Experience
Dr. Rosenfeld has over 25 years of 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 D
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Paul E. Rosenfeld, Ph.D. Page 2 of 12 October 2022
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:

Rosenfeld P. E., Spaeth K., Hallman R., Bressler R., Smith, G., (2022) Cancer Risk and Diesel Exhaust Exposure Among Railroad Workers. Water Air Soil Pollution. 233, 171.

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. 172
Paul E. Rosenfeld, Ph.D. Page 3 of 12 October 2022
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.

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. 173
Paul E. Rosenfeld, Ph.D. Page 4 of 12 October 2022
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.

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.
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Paul E. Rosenfeld, Ph.D. Page 5 of 12 October 2022
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 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. 175
Paul E. Rosenfeld, Ph.D. Page 6 of 12 October 2022
Paul Rosenfeld, Ph.D. (March 2004). Perchlorate Toxicology. Meeting of the American Groundwater Trust.

Lecture conducted from Phoenix Arizona.

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. 176
Paul E. Rosenfeld, Ph.D. Page 7 of 12 October 2022
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.

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. 177
Paul E. Rosenfeld, Ph.D. Page 8 of 12 October 2022
James River Corporation, Oregon: $10,000 grant was awarded to investigate the success of genetically engineered Poplar trees with resistance to round-up. 1996.

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 Superior Court of the State of California, County of San Bernardino Billy Wildrick, Plaintiff vs. BNSF Railway Company
Case No. CIVDS1711810
Rosenfeld Deposition 10-17-2022
In the State Court of Bibb County, State of Georgia
Richard Hutcherson, Plaintiff vs Norfolk Southern Railway Company Case No. 10-SCCV-092007
Rosenfeld Deposition 10-6-2022
In the Civil District Court of the Parish of Orleans, State of Louisiana Millard Clark, Plaintiff vs. Dixie Carriers, Inc. et al.

Case No. 2020-03891
Rosenfeld Deposition 9-15-2022
In The Circuit Court of Livingston County, State of Missouri, Circuit Civil Division Shirley Ralls, Plaintiff vs. Canadian Pacific Railway and Soo Line Railroad Case No. 18-LV-CC0020
Rosenfeld Deposition 9-7-2022
In The Circuit Court of the 13th Judicial Circuit Court, Hillsborough County, Florida Civil Division Jonny C. Daniels, Plaintiff vs. CSX Transportation Inc.

Case No. 20-CA-5502
Rosenfeld Deposition 9-1-2022
In The Circuit Court of St. Louis County, State of Missouri Kieth Luke et. al. Plaintiff vs. Monsanto Company et. al.

Case No. 19SL-CC03191
Rosenfeld Deposition 8-25-2022
In The Circuit Court of the 13th Judicial Circuit Court, Hillsborough County, Florida Civil Division Jeffery S. Lamotte, Plaintiff vs. CSX Transportation Inc.

Case No. NO. 20-CA-0049
Rosenfeld Deposition 8-22-2022
In State of Minnesota District Court, County of St. Louis Sixth Judicial District Greg Bean, Plaintiff vs. Soo Line Railroad Company
Case No. 69-DU-CV-21-760
Rosenfeld Deposition 8-17-2022
In United States District Court Western District of Washington at Tacoma, Washington John D. Fitzgerald Plaintiff vs. BNSF
Case No. 3:21-cv-05288-RJB
Rosenfeld Deposition 8-11-2022
178
Paul E. Rosenfeld, Ph.D. Page 9 of 12 October 2022
In Circuit Court of the Sixth Judicial Circuit, Macon Illinois Rocky Bennyhoff Plaintiff vs. Norfolk Southern
Case No. 20-L-56
Rosenfeld Deposition 8-3-2022
In Court of Common Pleas, Hamilton County Ohio
Joe Briggins Plaintiff vs. CSX
Case No. A2004464
Rosenfeld Deposition 6-17-2022
In the Superior Court of the State of California, County of Kern George LaFazia vs. BNSF Railway Company.

Case No. BCV-19-103087
Rosenfeld Deposition 5-17-2022
In the Circuit Court of Cook County Illinois
Bobby Earles vs. Penn Central et. al.

Case No. 2020-L-000550
Rosenfeld Deposition 4-16-2022
In United States District Court Easter District of Florida Albert Hartman Plaintiff vs. Illinois Central
Case No. 2:20-cv-1633
Rosenfeld Deposition 4-4-2022
In the Circuit Court of the 4th Judicial Circuit, in and For Duval County, Florida Barbara Steele vs. CSX Transportation
Case No.16-219-Ca-008796
Rosenfeld Deposition 3-15-2022
In United States District Court Easter District of New York Romano et al. vs. Northrup Grumman Corporation
Case No. 16-cv-5760
Rosenfeld Deposition 3-10-2022
In the Circuit Court of Cook County Illinois
Linda Benjamin vs. Illinois Central
Case No. No. 2019 L 007599
Rosenfeld Deposition 1-26-2022
In the Circuit Court of Cook County Illinois
Donald Smith vs. Illinois Central
Case No. No. 2019 L 003426
Rosenfeld Deposition 1-24-2022
In the Circuit Court of Cook County Illinois
Jan Holeman vs. BNSF
Case No. 2019 L 000675
Rosenfeld Deposition 1-18-2022
In the State Court of Bibb County State of Georgia
Dwayne B. Garrett vs. Norfolk Southern
Case No. 20-SCCV-091232
Rosenfeld Deposition 11-10-2021
179
Paul E. Rosenfeld, Ph.D. Page 10 of 12 October 2022
In the Circuit Court of Cook County Illinois
Joseph Ruepke vs. BNSF
Case No. 2019 L 007730
Rosenfeld Deposition 11-5-2021
In the United States District Court For the District of Nebraska Steven Gillett vs. BNSF
Case No. 4:20-cv-03120
Rosenfeld Deposition 10-28-2021
In the Montana Thirteenth District Court of Yellowstone County James Eadus vs. Soo Line Railroad and BNSF
Case No. DV 19-1056
Rosenfeld Deposition 10-21-2021
In the Circuit Court Of The Twentieth Judicial Circuit, St Clair County, Illinois Martha Custer et al.cvs. Cerro Flow Products, Inc.

Case No. 0i9-L-2295
Rosenfeld Deposition 5-14-2021
Trial October 8-4-2021
In the Circuit Court of Cook County Illinois
Joseph Rafferty vs. Consolidated Rail Corporation and National Railroad Passenger Corporation d/b/a

AMTRAK,
Case No. 18-L-6845
Rosenfeld Deposition 6-28-2021
In the United States District Court For the Northern District of Illinois Theresa Romcoe vs. Northeast Illinois Regional Commuter Railroad Corporation d/b/a METRA Rail Case 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. vs. The City of Pheonix v. Cox Cactus Farm, L.L.C., Utah Shelter Systems, Inc.

Case No. 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 vs. CNA Insurance Company et al.

Case No. 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
180
Paul E. Rosenfeld, Ph.D. Page 11 of 12 October 2022
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
In the United States District Court of Southern District of Texas Galveston Division M/T Carla Maersk 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. 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. BC646857
Rosenfeld Deposition 10-6-2018; Trial 3-7-19
In United States District Court For The District of Colorado Bells et al. Plaintiffs 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., Plaintifs 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 No. 4:16-cv-52-DMB-JVM
Rosenfeld Deposition July 2017
181
Paul E. Rosenfeld, Ph.D. Page 12 of 12 October 2022
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. 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 No. 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 No. 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 No. 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 No. 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 No. 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 No. 2:07CV1052
Rosenfeld Deposition July 2009
182
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880 Doolittle Drive Industrial Project
Final Environmental Impact Report
Response to Comments Document
Letter 5
COMMENTER: Gary Ho, Blum Collins & Ho LLP
DATE: August 2, 2024
Response 5.1
The commenter thanks the City for the opportunity to comment on the Draft EIR and requests to be added to the project mailing list.

This comment does not question the analysis or conclusions of the Draft EIR. Therefore, no revisions to the Draft EIR are necessary in response to this comment. At the request of the commenter, the City has updated its mailing list to include this commenter.

Response 5.2
The commenter states their understanding of the proposed project in the form of a summary.

Response 5.3
The commenter asserts that the EIR does not accurately or adequately describe the proposed project because it does not describe other projects owned or proposed by the project applicant that are located in San Leandro. The commenter cites State CEQA Guidelines sections pertaining to the scope of analysis for EIRs and suggests the proposed project is the construction and operation of all buildings associated with the project applicant.

The project applicant owns multiple properties in San Leandro, including the property described by the commenter at 1919 Williams Street. However, the applicant constructs and operates its properties independent of one another. For example, the warehouse proposed at 1919 Williams Street would be constructed and operated regardless of the potential construction and operation of the proposed project at 880 Doolittle Drive. Likewise, the proposed project, if approved, would be constructed and operated regardless of activities on other properties in San Leandro that the applicant owns or operates. The construction and operation of the proposed project is a separate action unrelated to activities on other property owned by the applicant. There is no link or connection between the proposed project and other properties owned by the applicant other than the applicant retains ownership and the properties are in San Leandro. Therefore, the comment is inaccurate in asserting that the proposed project is the construction and operation of all buildings associated with the project applicant. The proposed project is the project at 880 Doolittle Drive, as described in Section 2, Project Description, beginning on page 2-1 of the Draft EIR.

Defining the proposed project as the project at 880 Doolittle Drive in Section 2, Project Description, of the EIR is consistent with the State CEQA Guidelines. Section 15378.a.3 of the State CEQA Guidelines, provides the following definition of a project: “An activity involving the issuance to a person of a lease, permit, license, certificate, or other entitlement for use by one or more public agencies.” The proposed project would require issuance of several permits and or entitlements, which are listed in Section 2.7, Lead, Responsible, and Trustee Agencies, and Section 2.8, Required Approvals, on pages 2-17 and 2.18 of the Draft EIR. The proposed project would require permits 183
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Response to Comments Document
specific to it and not dependent on permits or entitlements associated with other projects or properties the applicant owns or operates in San Leandro.

Additionally, while the proposed project consists solely of the project at 880 Doolittle Drive and described in Section 2, Project Description, of the EIR, the cumulative impacts of the proposed project were considered in the Draft EIR. As stated on page 3-2 of the Draft EIR, the State CEQA Guidelines define “cumulative impacts” as two or more individual impacts that, when considered together, are substantial or will compound other environmental impacts (State CEQA Guidelines Sections 15065 and 15355). Cumulative impacts are the combined changes in the environment that result from the incremental impact of development of the proposed project and other nearby past, pending, and planned projects. The list of other projects considered together with the proposed project in the cumulative impacts assessment is provided in Table 3-1, on page 3-3 of the Draft EIR.

As shown on Table 3-1, the project at 1919 William Street was considered in the cumulative impacts assessment. Accordingly, other proposed projects near the proposed project, including some projects owned or proposed by the project applicant were evaluated in conjunction with the proposed project in determining cumulative impacts.

As the Draft EIR accurately and adequately describes the proposed project, revisions to the Draft EIR are not necessary in response to this comment.

Response 5.4
The commenter provides a summary of their interpretation of the State CEQA Guidelines Section 15146 regarding the level of specificity required in EIRs. The commenter asserts that project EIRs require more specificity than program EIRs, and that EIRs must evaluate a project as a whole rather than piecemealing it into smaller separate projects.

The City concurs with the general concept that project-level EIRs should have more specificity than program EIRs because typically more details are known about specific projects than program-level actions. For example, conceptual site plans and conceptual grading plans are often available when preparing project EIRs, allowing the lead agency to see the limits of construction disturbance, length of construction activities, and utility connections. Program-level actions often do not have these types of details available at the time of preparation of the EIR. This inherently leads to project EIRs being more specific than program EIRs.

In the case of the proposed project, the City has prepared a project-level EIR evaluating the potential environmental impacts of the project as a whole. The whole or entirety of the proposed project is described in Section 2, Project Description, of the Draft EIR. Potential environmental impacts of the project are evaluated in Section 4, Environmental Impact Analysis, and Section 5, Other CEQA Required Discussions, of the Draft EIR. Additionally, potential environmental impacts of the project are also evaluated in the Initial Study, which is provided as Appendix A to the Draft EIR.

As the Draft EIR accurately and adequately describes and evaluates the potential environmental impacts of the proposed project as a whole, revisions to the Draft EIR are not necessary in response to this comment.

Response 5.5
The commenter asserts that the Draft EIR is inadequate because it does not provide an analysis of consistency with the General Plan as it pertains to the potentially significant and unavoidable GHG impact of the project. The commenter suggests the Draft EIR must be revised to include a 184
City of San Leandro
880 Doolittle Drive Industrial Project
Final Environmental Impact Report
Response to Comments Document
consistency analysis with applicable General Plan goals and policies, including some that the commenter specifically lists.

In response to this comment, the City has evaluated project consistency with each of the policies listed in the comment. Following this consistency analysis, the City provides its determination on whether or not the Draft EIR must be revised to include the consistency analysis suggested by the commenter.

Goal LU-11. Manage the city’s growth in a way that maintains the quality of life and reflects the capacity of infrastructure and public services.

The proposed project would be managed growth in that it is consistent with the existing General Plan land use designation and zoning district of the project site. As discussed on page 2-4 of the Draft EIR, the project site is designated as General Industrial (IG) in the San Leandro 2035 General Plan. According to the Land Use Element of the 2035 General Plan, areas designated as General Industrial may contain a wide range of manufacturing, transportation, food and beverage processing, technology, warehousing, and other related or similar uses. Page 2-4 of the Draft EIR also describes the existing zoning of the project site as Industrial General District.

The project site is adequately served by existing infrastructure and public services. As described on page 2-14 of the Draft EIR, the project would include new connections to existing utilities that are present in the project area. As described in Section 19, Utilities and Service Systems, of the Initial Study (see Draft EIR Appendix A), the capacity of existing utilities would be adequate for the proposed project. As stated on page 107 of the Initial Study, the project would not involve the extension of roads or other infrastructure that would lead to unplanned growth; the new warehouse would be constructed within City limits and connected to existing infrastructure systems and would not lead to unplanned indirect growth in the area.

Public services, such as fire and police protection already serve the project site and are available to serve the project. As discussed in Section 15, Public Services, of Initial Study, the project would not result in substantia increased demand on public services. Therefore, the proposed project would be consistent with Goal LU-11 of the General Plan.

Policy LU-11.1. Use of the General Plan Environmental Impact Report.

In summary, this policy directs the environmental review for any subsequent development to the General Plan to address growth impacts that would occur as a result of development exceeding the General Plan projections.

The potential growth impacts of the proposed project are evaluated in Section 14, Population and Housing, of the Initial Study. As described therein, the proposed project is consistent with the General Plan’s IG land use designation and would not induce substantial growth beyond what was considered in the General Plan assumptions for the area. The project would be within the growth envisioned under the City’s General Plan and would not result in substantial population growth. As discussed on page 107 of the Initial Study, the proposed warehouse would create jobs, which could indirectly cause population growth through employee relocations to the project area. However, the project also includes demolishing existing industrial buildings, eliminating the potential jobs provided by business that could operate within them. Additionally, the project site is located in a dense urban area and most of these employees would likely be drawn from the local population 185
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Response to Comments Document
regardless of the job creation potential of existing on-site vacant buildings. For these reasons, the Initial Study determined the growth impacts of the project would be less than significant.

In addition to the Initial Study, Section 5.1, Growth Inducement, of the Draft EIR also evaluates the proposed project’s growth inducing potential to result in physical environmental effects. The analysis provided in Section 5.1 of the Draft EIR does not rely upon the General Plan. Instead, it provides a project-specific analysis of the growth inducing potential of the project. This type of analysis is consistent with General Plan Policy LU-11.1 because it addresses the growth inducing impacts of the proposed project specifically, regardless of whether or not the growth would exceed projections in the General Plan. As described in Section 5.1, Growth Inducement, of the Draft EIR the proposed project’s growth inducing potential would not result in significant physical environmental effects. Therefore, the proposed project would be consistent with Policy LU-11.1 of the General Plan.

Policy ED-1.3. Industrial Land Use Efficiency.

This General Plan policy encourages more efficient use of the industrial land supply in San Leandro and discourages the use of large sites and buildings for storage and other low intensity uses.

The Draft EIR, including the Initial Study that is Appendix A to the Draft EIR, evaluates potential impacts of the project consistent with Appendix G of the State CEQA Guidelines.

Appendix G of the State CEQA Guidelines requires the lead agency to evaluate the potential for significant environmental impacts due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect. Policy ED-1.3 was not adopted for the purpose of avoiding or mitigating an environmental effect.

Therefore, analysis of consistency with this policy is not required in the Draft EIR.

For informational purposes, the proposed project has no identified tenant. Therefore, it is not possible to determine if the proposed building would be used for low-intensity uses, such as storage. However, the proposed building includes office space and sixty-four loading docks plus space for employee parking and additional truck parking, as described in Section 2, Project Description, of the Draft EIR. The provision of spaces for truck activity and offices suggests that the building would likely be utilized for more than storage, a low-intensity use specifically mentioned in Policy ED-1.3.

Goal EJ-1. Reduce Pollution Exposure and Improve Air Quality.

Goal EJ-1 of the General Plan does not specify what constitutes pollution. However, based on policies and actions listed under Goal EJ-1 in General Plan, pollution could include air pollution, exposure to hazardous contamination and materials, and noise pollution.

The potential air quality impacts of the proposed project are evaluated in Section 3, Air Quality, of the Initial Study, which begins on page 31 of the Initial Study. The Initial Study is included as Appendix A to the Draft EIR. As described on page 31 of the Initial Study, Kimley Horn and Associates prepared an Air Quality Assessment for the proposed project in November 2023. Kimley Horn and Associates also prepared a Health Risk Assessment for the project in November 2023. Both documents were peer reviewed by Rincon Consultants, Inc. on behalf of the City. Both documents are included as appendices to the Initial Study and were used to inform Section 3, Air Quality, of the Initial Study. 186
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As discussed on pages 40 and 41, the proposed project would be consistent with the criteria of the 2017 Clean Air Plan, which is the most current clean air plan adopted by the Bay Area Air Quality Management District. The proposed project would not obstruct implementation of the 2017 Clean Air Plan, and the Initial Study determined impacts would be less than significant.

As shown in Table 7 on page 42 of the Initial Study, the estimated operational emissions of the project would not exceed BAAQMD thresholds for criteria pollutants. As shown in Table 6 on page 41 of the Initial Study, project-construction related emissions would not exceed BAAQMD thresholds. Therefore, project construction would not result in a cumulatively considerable net increase of a criteria pollutant for which the project region is nonattainment under an applicable federal or state ambient air quality standard. Additionally, the applicant would be required to implement Mitigation Measure AQ-1 on pages 42 and 43 of the Initial Study. Mitigation Measure AQ-1 requires the project applicant to implement basic construction mitigation measures recommended by BAAQMD to reduce fugitive dust emissions. The Initial Study determined that impacts related to a cumulatively considerable net increase of a criteria pollutant for which the project region is non-attainment would be less than significant with implementation of mitigation.

Construction and operation of the project would generate toxic air contaminants, such as the exhaust from diesel construction equipment and diesel tractor trailers. The potential health risks of exposure to these contaminants at the nearest sensitive receptor to the project are evaluated in detail in the Health Risk Assessment that Kimley Horn and Associates prepared for the project in November 2023. The results of the Health Risk Assessment are discussed on pages 43 through 47 of the Initial Study. As described therein, the project’s health risk would not exceed applicable thresholds. The proposed project would not expose sensitive receptors to substantial pollutant concentrations and impacts would be less than significant (see Initial Study page 47).

As discussed in Section 9, Hazards and Hazardous Materials, beginning on page 79 of the Initial Study, the proposed project would result in less than significant impacts related hazards to the public or the environment through the routine transport, use, or disposal of hazardous materials. The proposed would also have less than significant impacts related to the potential to emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within 0.25 mile of an existing or proposed school.

The potential for the project to result in impacts related to a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment is evaluated in the Draft EIR. As described on page 4.2-2 of the Draft EIR, the project site is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5, otherwise known as the “Cortese List.” The project site is considered a hazardous site due to subsurface contamination with chlorinated volatile organic compounds associated with the Kaiser Aerotech operation that formerly operated on-site.

As described on page 4.2-13 of the Draft EIR, construction of the project would have the potential to mobilize or release existing hazardous contamination. Additionally, as described on page 4.2-14 of the Draft EIR, operation of the project would have the potential to expose building occupants to hazardous materials, as well as result in further groundwater contamination through improper stormwater management treatment. The release of existing on-site contamination is identified as a potentially significant impact on pages 4.2- 187
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13 and 4.2-14 of the Draft EIR. However, as discussed on pages 4.2-14 through 4.2-18 of the Draft EIR, mitigation measures HAZ-1 through HAZ-6 must be implemented. With implementation of these measures, impacts related to release of hazardous contamination would be less than significant, as discussed on pages 4.2-18 and 4.2-19 of the Draft EIR.

The potential noise impacts of the project are evaluated and discussed in Section 4.3, Noise and Vibration, of the Draft EIR. As summarized on page 4.3-11 of the Draft EIR, construction and operation of the proposed project would generate noise, increasing ambient noise levels near the project site. However, construction noise would be temporary and below thresholds of significance. Traffic noise during operation would also be below significance thresholds; however, on-site operational noise would exceed thresholds established for the nearest sensitive receptor. Impacts would be potentially significant but mitigatable.

Required mitigation measure NOI-1, described on page 4.3-18 of the Draft EIR, consists of a permanent noise barrier along the property boundary that is oriented in a northwestsoutheast direction. As summarized on page 4.3-18 of the Draft EIR, with a sound barrier in this location, on-site noise levels at the nearest sensitive receptor would be reduced to 50 dBA. Noise levels of 50 dBA would be below the significance threshold of 55 dBA.

Accordingly, with implementation of Mitigation Measure NOI-1, project noise impacts would be less than significant.

As the project would not expose people or the environment to potentially significant impacts associated with air pollution, exposure to hazardous contamination and materials, or noise pollution, the proposed project would be consistent with Goal EJ-1 of the General Plan.

Policy EH-3.3. Land Use Compatibility.

This General Plan policy discourages new land uses with potential adverse air quality impacts, including the emission of toxic air contaminants and fine particulates, near residential neighborhoods, schools, hospitals, nursing homes, and other locations where public health could potentially be affected.

As discussed in detail above in the analysis of consistency with General Plan Goal EJ-1, The proposed project would not obstruct implementation of the BAAQMD 2017 Clean Air Plan.

Operational emissions of criteria air pollutants would not exceed BAAQMD thresholds for criteria pollutants. The project applicant must implement Mitigation Measure AQ-1 requiring dust control measures during construction. With implementation of this mitigation measure, project-construction related emissions would not exceed BAAQMD thresholds.

Also discussed above in the analysis of consistency with General Plan Goal EJ-1, Kimley Horn and Associates also prepared a Health Risk Assessment for the project in November 2023, which is included as Appendix B to the Initial Study. The Health Risk Assessment evaluated the potential for toxic air contaminants to impact health at the nearest sensitive receptor to the project site, which it identifies as single-family residences approximately 500 feet from the project site. There are no schools, hospitals, nursing homes, and other similar locations within closer distance to the site than the single-family residences identified in the Health Risk Assessment. For example, the nearest school to the project site is approximately 2,800 feet away from the site. As discussed in the Health Risk Assessment and summarized on pages on pages 43 through 47 of the Initial Study, the project’s health risk would not exceed applicable thresholds. The proposed project would not expose sensitive receptors to substantial pollutant concentrations and impacts would be less than significant (see Initial 188
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Study page 47). Accordingly, the proposed project would not conflict with General Plan Policy EH-3.3.

Policy EH-3.4. Design, Construction, and Operation.

This General Plan policy requires new development to reduce the potential for future air quality problems through design features such as: minimizing construction dust; ensuring best available technology is used for operations that could generate emissions; encouraging energy conservation; promoting landscaping and tree planting; and reducing GHG emissions consistent with City’s Climate Action Plan.

As discussed in detail above in the analysis of consistency with General Plan Goal EJ-1, the project applicant must implement mitigation measure AQ-1 requiring BAAQMD dust control measures during construction. With implementation of this mitigation measure, projectconstruction related emissions would not exceed BAAQMD thresholds. Operational emissions of criteria air pollutants would not exceed BAAQMD thresholds for criteria pollutants. The potential energy impacts of the project are evaluated in Section 6, Energy, of the Initial Study, which begins on page 59 of the Initial Study. As described on page 63 of the Initial Study, project operation would not result in potentially significant environmental effects due to the wasteful, inefficient, or unnecessary consumption of energy, and impacts would be less than significant. As described on page 2-13 of the Draft EIR, the proposed project would involve landscaping and tree planting.

Project consistency with the City’s Climate Action Plan is evaluated in Table 4.1-3 of the Draft EIR, which begins on page 4.1-11. As shown in Table 4.1-3, the proposed project would generally be consistent with the Climate Action Plan because it would be consistent with most of the applicable measures identified in the Climate Action Plan. As on As discussed on page 4.1-12 of the Draft EIR, the proposed project would be inconsistent with Measure WR-1 pertaining to waste reuse and measures BE-1 and BE-2 of the Climate Action Plan, which pertain to replacing natural gas with electricity. Inconsistency with Measure WR-1 would not result in physical environmental impacts because the policy encourages maker spaces, and tool-lending libraries for example. The absence of these features from the project would not result in physical environmental effects. The proposed project would be inconsistent with measures BE-1 and BE-2 because the proposed project would include new natural gas connections. The City is unable to implement feasible or enforceable mitigation to eliminate natural gas from the proposed project (see page 4.1-9 of the Draft EIR and Response 4.4 for a full explanation). Accordingly, the proposed project would be potentially inconsistent with General Plan Policy EH-3.4 because the proposed project would not implement all applicable strategies of the Climate Action Plan intended to reduce GHG emissions.

Policy EH-9.6. Airport Safety Zones.

This General Plan Policy encourages the City to regulate land uses within designated airport safety zones, height referral areas, and noise compatibility zones to minimize the possibility of future noise conflicts and accident hazards.

The City does regulate land uses within designated airport safety zones. The regulation of uses within airport safety zones is accomplished several ways. Examples include the City’s General Plan and Zoning Ordinance, both of which restrict certain land uses, such as residential uses, within applicable airport safety zones. Regarding the proposed project, as 189
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described on page 84 of the Initial Study, the project site is located primarily in the Outer Approach Zone (Zone 4) of the Oakland International Airport, where warehouses and distribution facilities are a compatible use assuming employment does not exceed 100 employees per acre. Additionally, the project applicant submitted the project to the FAA, who determined that a proposed building height of 50 feet does not present a hazard to air navigation. Therefore, the project would not result in a safety hazard or excessive noise for people working in the project area as a result of airport operations. Impacts would be less than significant. Therefore, the proposed project would be consistent with General Plan Policy EH-9.6.

Additionally, this General Plan action is not applicable to the proposed project because it pertains to an action taken by the City that would apply city-wide, rather than for a specific project.

Policy T-1.5. Land Use Strategies.

This General Plan policy promotes land use concepts that reduce the necessity of driving, encourage public transit use, and reduce trip lengths. These concepts include live-work development, mixed use development, higher densities along public transit corridors, and the provision of commercial services close to residential areas and employment centers This policy does not apply to the proposed project because it encourages land uses that are not compatible with the project or existing zoning of the project site, such as residential uses. Additionally, this General Plan policy is not applicable to proposed project because it pertains to an action taken by the City that would apply city-wide rather than a specific project.

Action T-5.2.A: New Evaluation Methodologies Consistent with SB 743.

This General Plan action encourages the City to implement new methodologies for evaluating and mitigating transportation impacts which are based on VMT rather than level of service (LOS).

The potential transportation impacts of the project were evaluated using VMT rather LOS.

As discussed on pages 4.4-6 and 4.4-7 of the Draft EIR, the VMT impacts of the project would be less than significant. The proposed project would be consistent with General Plan Action T-5.2.A. Additionally, this General Plan action is not applicable to proposed project because it pertains to an action taken by the City that would apply city-wide rather than a specific project. Nonetheless, the City has adopted a VMT policy, consistent with General Plan Action T-5.2A.

As discussed in the consistency analysis above, the proposed project would be consistent with all but one of the General Plan goals and policies listed by the commenter. The proposed project would be potentially inconsistent with General Plan Policy EH-3.4 because the project would include natural gas, which is inconsistent with one or more measures of the Climate Action Plan. However, this does not constitute new information because the Draft EIR already identifies and discusses this inconsistency. Specifically, on pages 4.1-12 and 4.1-13 of the Draft EIR, the proposed project is described as conflicting with an applicable plan, policy, or regulation adopted for the purpose of reducing GHG emissions. Impacts are identified as significant and unavoidable. However, to provide additional clarification, page 4.1-12 of the Draft EIR is revised as follows:
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The proposed project would be inconsistent with policies measures BE-1 and BE-2 because the proposed project would include new natural gas connections. Accordingly, the proposed project would conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing GHG emissions, such as General Plan Policy EH-3.4 and the City’s Climate Action Plan. Impacts would be potentially significant, and mitigation is required.

No further revisions to the Draft EIR are required in response to this comment.

Response 5.6
The commenter opines that the Draft EIR does not contain details about required approvals for a height exception, and a revised EIR should be prepared to include this information pursuant to State CEQA Guidelines Section 15121.

The Draft EIR does describe both the height of the proposed building and the approvals required for the height. As described on pages 2-8 and 2-9 of the Draft EIR, the maximum building height would be 50 feet with an interior clear height of 40 feet. As discussed on page 2-17 of the Draft EIR, the project site is approximately 4,050 feet away from the nearest runways at Oakland International Airport. Due to this proximity a No Hazard Determination for the warehouse was issued from the Federal Aviation Administration pursuant to Federal Aviation Regulations Part 77, because the proposed warehouse would have a maximum height of 50 feet, exceeding the 43 feet maximum permitted at this distance from the airport runway. The applicant submitted the project to the FAA, who determined that a building height of 50 feet does not present a hazard to air navigation. An additional No Hazard Determination may also be needed for the use of project construction equipment exceeding 43 feet in height. Page 2-18 of the Draft EIR provides list of approvals and permits that are required for the project, including a height exception. The effects of the height exception are analyzed as part of the proposed project throughout the Draft EIR and Initial Study because impacts and analyzed for a building with a 50-foot maximum height. Including the application for the proposed height exception within the Draft EIR is unnecessary to adequately analyze and disclose the potential environmental effects of the project. Although a specific permit is not required for the crane that would be used for project construction, its height was also included in the analysis of potential environmental impacts. Section 15121 of the State CEQA Guidelines does not require the inclusion of detailed contents of permit applications in an EIR. Therefore, no revisions to the Draft EIR are required in response to this comment.

Response 5.7
The commenter asserts that the Initial Study does not quantify the project workforce size, provides an estimation of the workforce size based on a rate from the federal government, and suggests the project workforce, by itself and when combined with other projects, would exceed employment growth forecasts in the City’s General Plan. The commenter suggests that a revised EIR should be prepared to determine if growth forecasts would be exceeded.

The Draft EIR, including the Initial Study that is Appendix A to the Draft EIR, evaluates potential impacts of the project consistent with Appendix G of the State CEQA Guidelines. Appendix G of the State CEQA Guidelines identifies 21 environmental topics for evaluation in CEQA documents and provides a series of impact checklist questions to consider for each topic. Appendix G of the State CEQA Guidelines contains a checklist question asking if the project would induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure). This checklist question is addressed in Section 14, Population and Housing, of the Initial Study, which is 191
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provided as Appendix A to the Draft EIR. Specifically, the potential for employment opportunities resulting from the proposed project to induce substantial population growth are evaluated on pages 107 and 108 of the Initial Study. As discussed therein, the project would involve the construction of a new warehouse which would create an estimated 152 jobs (see page 2-9 of the Draft EIR). Job creation could indirectly cause population growth through employee relocations to the project area.

However, the project also includes demolishing existing industrial buildings, eliminating the potential jobs provided by business that could operate within them. Additionally, the project site is in a dense urban area and many of these employees would likely be drawn from the local population regardless of the job creation potential of existing on-site vacant buildings. Some employees may relocate to the area as a result of job opportunities resulting from the proposed project; however, a substantial change in employment growth in the area would not occur, relative to the General Plan. The proposed project is consistent with the General Plan’s IG land use designation and would not induce substantial growth beyond what was considered in the General Plan assumptions for the area. The project would be within the growth envisioned under the City’s General Plan and would not result in substantial population growth. Impacts would be less than significant.

The growth inducement potential of the project is also discussed in Section 5, Other CEQA Required Discussions, of the Draft EIR. Specifically, Section 5.1, Growth Inducement, of the Draft EIR evaluates the growth inducing potential of the project to result in physical environmental effects. As described on page 5-1 of the Draft EIR the growth inducing potential of proposed project’s would not result in significant physical environmental effects.

An analysis of the potential growth inducing impacts of the project is provided in both the Initial Study and Draft EIR, as described in the response to this comment. Therefore, it is unnecessary to prepare a revised EIR to determine if growth forecasts would be exceeded. Additionally, the commenter does not specify physical environmental effects that should be analyzed in context with employment growth. As further discussed under State CEQA Guidelines Section 15126.2(e), “[I]t must not be assumed that growth in any area is necessarily beneficial, detrimental, or of little significance to the environment.” The purpose behind looking at growth is to determine whether “increases in the population may tax existing community service facilities, requiring construction of new facilities that could cause significant environmental effects.” The commenter makes no assertion that growth resulting from the project would result in construction of new facilities that could cause significant environmental effects. Accordingly, no revisions to the Draft EIR are required in response to this comment.

Response 5.8
The commenter opines that a revised EIR should be prepared to provide demographic and geographic information on the location of the project workforce in order to inform an accurate environmental analysis.

As described on page 2-8 of the Draft EIR, there is no specific known land use and/or tenant proposed at this time. Therefore, there is no proposed workforce and no known way to determine the demographic makeup. Regardless, the Draft EIR has been prepared to evaluate and disclose the potential physical environmental impacts of the project and provide mitigation measure to avoid or reduce the potentially significant impacts to the extent feasible (see State CEQA Guidelines Section 15002). The demographics of the workforce are irrelevant to the physical environmental impacts of the project. For example, it is irrelevant the percentage of the workforce that is male or female, as 192
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these demographic details have no bearing on environmental impacts. Accordingly, the Draft EIR need not be revised to disclose the demographics of the workforce.

As described in the previous paragraph, there is no tenant or identified workforce at this time.

Therefore, the specific location of this workforce is also not known. For example, it is impossible to know the specific street address of every person who may eventually be employed at the project site should the project be approved. However, this level of detail is unnecessary to evaluate the potential environmental effects of the project. The Draft EIR makes supported assumptions on the location of the workforce in enough detail to provide an adequate evaluation of potential environmental effects. As described on page 5-1 of the Draft EIR, the proposed project would not generate substantial population growth. Most employment opportunities resulting from the project would be filled by people already in the San Francisco Bay Area.

The basis for the assumption that the workforce would be primarily from the San Francisco Bay Area is described on page 5-1 of the Draft EIR. As described therein, the project also includes demolishing existing industrial buildings, eliminating the potential local jobs provided by businesses that could operate within them. Additionally, the project site is located in a dense urban area and many of the warehouse employees would likely be drawn from the local population regardless of the job creation potential of existing on-site vacant buildings. Some employees may relocate to the area as a result of job opportunities resulting from operation of the proposed project; however, a substantial change in population growth in the area would not occur.

Finally, the commenter does not specify additional environmental effects or mitigation measures that could be made more accurate or be informed by specific demographic and location data for the project workforce. Therefore, it is unclear what the inclusion of this data, even if it were known and available, would be applied to the Draft EIR or a revised EIR. Accordingly, no revisions to the Draft EIR are required in response to this comment.

Response 5.9
The commenter asserts that the Draft EIR contains no floor plan, detailed site plan, building elevations, or complete conceptual grading plan, all of which they opine are needed for an adequate impact analysis in the Draft EIR.

The Draft EIR does provide a detailed site plan, building elevations, and a conceptual grading plan. A conceptual site plan is provided as Figure 2-4, Conceptual Site Plan, on page 2-10 of the Draft EIR.

Figure 2-4 contains typical conceptual site plan details, including the building footprint and approximate size, surface parking and internal circulation roads, driveways, and bioretention and stormwater treatment areas. Conceptual building elevations are provided as Figure 2-5, Conceptual Building Elevations, on page 2-11 of the Draft EIR. Figure 2-6, Conceptual Rendering of Project, on page 2-12 of the Draft EIR also provides elevation views of the proposed building. Figure 2-5 provides details on the materials that would be used for the building exterior, such as the facade.

Figure 2-6 is provided a full-color figure showing the potential color palette that would be used for the exterior of the building.

Conceptual grading is shown on Figure 2-4, Conceptual Site Plan, on page 2-10 of the Draft EIR. A conceptual grading plan is also included as Figure 6, Conceptual Grading Plan, on page 11 of the Initial Study, which is included as Appendix A to the Draft EIR. Proposed grading is also described on page 2-14 of the Draft EIR. As described therein, the project site is relatively level, which would minimize the amount of grading included in the proposed project. Generally, grading would be designed to slope in a west-southwest direction across the site, which would allow stormwater 193
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runoff to flow into bioswale areas and then into the City’s storm drain system. Elevations on the project site following grading would vary between approximately 10 feet and 17 feet above mean sea level. Preliminary grading design shows a balanced site. Nonetheless, the Air Quality Assessment prepared for the project (see Appendix A to the Initial Study) evaluated the potential air quality impacts of the project assuming that up to 15,000 cubic yards of material would be imported to the site during project construction. As described in Section 3, Air Quality, of the Initial Study, the proposed project would not result in significant environmental impacts related to air quality.

A detailed floor plan of the building is not provided in the Draft EIR because the proposed project would be a warehouse with approximately 15,000 square feet of associated office space, as described on page 2-8 of the Draft EIR. These features of the project are shown on Figure 2-4, Conceptual Site Plan. The location of rooms or spaces internal to the building are not necessary to analyze the potential environmental effects of the project. Therefore, it is unnecessary to provide a detailed floor plan beyond that which is shown on Figure 2-4, Conceptual Site Plan, of the Draft EIR.

The commenter does not provide information or analysis to indicate that the Draft EIR is missing information based on additional project details.

Because the Draft EIR does provide detailed site plan, building elevations, and a conceptual grading plan, no revisions to the Draft EIR are required in response to this comment.

Response 5.10
The commenter asserts that Figure 2-4 in the Draft EIR has been edited for public review to remove meaningful information such as the floor area ratio, site coverage, and key notes, and that this information is needed to conduct an adequate analysis.

As discussed in Response 5.9, a conceptual site plan is provided as Figure 2-4, Conceptual Site Plan, on page 2-10 of the Draft EIR. Figure 2-4 contains typical conceptual site plan details, including the building footprint and approximate size, surface parking and internal circulation roads, driveways, and bioretention and stormwater treatment areas. Figure 2-4 contains numerous notes and labels, such as final grading elevations, dimensions of internal circulation roads, and the approximate size of the proposed building. Figure 2-4 does not contain the specific notes described by the commenter, such as floor area ratio and site coverage. However, the proposed floor area ratio is described as 0.40 on page 2-8 of the Draft EIR.

The commenter does not specify how or why site coverage is necessary for adequate analyses of environmental impacts. Therefore, it is unnecessary to revise the Draft EIR, including Figure 2-4, to include a note describing the site coverage of the building. The Draft EIR evaluates potential environmental effects of the project on existing conditions. In the case of site coverage, the proposed project would reduce impervious site coverage compared to existing conditions, as described on page 91 of the Initial Study. The reduction of impervious site coverage compared to existing conditions is sufficient for evaluating the potential environmental impacts of the project.

The commenter does not provide information or analysis to indicate that the Draft EIR is missing information based on additional project details. As the Draft EIR provides a conceptual site plan with typical detail and describes the characteristics of the project in sufficient detail to adequately evaluate its impacts on the environment, no revisions to Figure 2-4 or the Draft EIR are required in response to this comment.
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Response 5.11
The commenter asserts that Figure 2-5 in the Draft EIR is blurry and illegible, resulting in no meaningful information such as the height of the buildings, colors, or materials being made available.

The City is unaware of why this commenter asserts that Figure 2-5, Conceptual Building Elevations, on page 2-11 of the Draft EIR appears blurry or illegible. Figure 2-5 is legible when the City views the figure in both print and electronic (computer monitor) formats. Regardless, the details that commenter states they cannot see or read on Figure 2-5 are provided as text elsewhere in the Draft EIR, making Figure 2-5 unnecessary or optional. As described on pages 2-8 and 2-9 of the Draft EIR, the maximum building height would be 50 feet with an interior clear height of 40 feet. Page 2-9 of the Draft EIR also describes the materials that would be used for building exterior. As described therein, the exterior of the proposed warehouse would be constructed of a mix of materials, including concrete panels, corrugated and noncorrugated metal panels, wood finish/trim, and glazing. Glazing would be a mix of insulated glass installed over concrete and other materials, and glass installed over openings to serve as traditional windows. Figure 2-6, Conceptual Rendering of Project, on page 2-12 of the Draft EIR also provides elevation views of the proposed building. Figure 2-6 is provided a full-color figure showing the potential color palette that would be used for the exterior of the building. Therefore, the Draft EIR includes the details the commenter requests, including building height, materials, and color palette. No revisions to the Draft EIR are required in response to this comment.

Response 5.12
The commenter asserts that the Draft EIR does not include a detailed grading plan, and that Figure 2-8 in the Draft EIR does not provide details typical of a grading plan, such as earthwork quantity notes and proposed contours. The commenter opines that without these details, statements in the Draft EIR pertaining to the site being relatively level and requiring minimal grading cannot be verified. The commenter asserts these details are needed to evaluate haul trips during project construction.

This comment is similar to Comment 5.9. Please see Response 5.9. Briefly, as described therein, conceptual grading contours are shown on Figure 2-4, Conceptual Site Plan, on page 2-10 of the Draft EIR. Figure 2-4 also shows the existing topography of the project site. A conceptual grading plan is also included as Figure 6, Conceptual Grading Plan, on page 11 of the Initial Study, which is included as Appendix A to the Draft EIR. Proposed grading is also described on page 2-14 of the Draft EIR. As described therein, the project site is relatively level, which would minimize the amount of grading included in the proposed project. Preliminary grading design shows a balanced site, with no import/export of material. Additionally, the relatively level conditions at the project site are documented in site photographs, which are provided as Figure 2-3, Existing Site Conditions:

Representative Photographs, on pages 2-5 through 2-7 of the Draft EIR.

Because the Draft EIR, including the Initial Study, does provide conceptual grading plans and show grading contours, describe grading, and include both existing topography and site photographs that document the relatively level conditions at the project site, no revisions to the Draft EIR are required in response to this comment. The commenter does not provide information or analysis to indicate that the Draft EIR is missing information based on proposed grading details. Additionally, the Air Quality Assessment prepared for the project (see Appendix A to the Initial Study) evaluated the potential air quality impacts of the project assuming up to 15,000 cubic yards of material would 195
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be imported to the site during project grading. As described in Section 3, Air Quality, of the Initial Study, the proposed project would not result in significant environmental impacts related to air quality.

Response 5.13
The commenter asserts that a revised EIR must be prepared to include a complete and unedited floor plan, detailed site plan, building elevations, conceptual grading plan, and project narrative.

This comment is similar to Comment 5.9. Please see Response 5.9. As described therein, the plans and narrative the commenter describes are included in the Draft EIR with enough detail to adequately evaluate the potential environmental impacts of the project. The commenter does not provide information or analysis to indicate that the Draft EIR is missing information based on additional project details. No revisions to the Draft EIR are required in response to this comment.

Response 5.14
The commenter opines that the Draft EIR does not contain details about required approvals for a height exception, and a revised EIR should be prepared to include this information pursuant to State CEQA Guidelines Section 15121.

This comment is nearly identical to Comment 5.6. Please see Response 5.6. As described therein, briefly, the Draft EIR does describe the required approvals and permits for the project, including height exceptions. No revisions to the Draft EIR are required in response to this comment.

Response 5.15
The commenter states they have provided an attachment to their comment letter providing a full technical commentary and analysis from a consultant.

Responses to this attachment are provided later in the continued response to letter 5.

Response 5.16
The commenter asserts that the Draft EIR does not include the analysis of project impacts relevant to environmental justice issues.

There are currently no formal requirements or procedures to evaluate potential environmental justice impacts under CEQA. While the physical environmental impacts of discretionary projects must be examined under CEQA, “the economic and social effects of proposed projects are outside CEQA’s purview.” (Guidelines, section 15131(a); Bakersfield Citizens for Local Control v. City of Bakersfield (2004) 124 Cal.App.4th 1184, 1205). Therefore, formal analysis of economic or social impacts is not required, which includes impacts related to an individual or group of individuals’ demographics or economic status through the context of environmental justice. Accordingly, no revisions to the Draft EIR are required in response to this comment.

Outside the context of CEQA, the City does consider if projects would be generally consistent with its General Plan, which does include an Environmental Justice Element. Environmental justice pertains to disproportionate adverse environmental impacts on certain populations or groups of people, including areas the City has identified as a Disadvantaged Community in its General Plan. As described in Response 5.18, the project site is identified as part of a Disadvantaged Community in the City’s General Plan (see Figure 12-1 on page 12-4 of the General Plan). The environmental impacts of the proposed project with the potential to impact people comprising this Disadvantaged 196
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Community include those related to air quality, hazardous materials, and noise, because these impacts can travel or move off-site and impact nearby receptors, such as residents. There are no members of the Disadvantage Community on the project site because the site is vacant.

As described in detail in Response 5.17, the potential adverse health impacts of project air pollutant emissions were evaluated at the nearest sensitive receptor to the project site, which is also part of the Disadvantaged Community, and the project’s health risk would not exceed applicable thresholds. As described in more detail in Response 5.23, the Draft EIR includes the incorporation of Mitigation Measure HAZ-2 and Mitigation Measure HAZ-3. These measures would reduce release of existing soil and groundwater contamination into the project area, including the Disadvantaged Community, during project construction. Additionally, the applicant would be required to implement Mitigation Measure AQ-1 on pages 42 and 43 of the Initial Study. Mitigation Measure AQ-1 requires the project applicant to implement basic construction mitigation measures recommended by BAAQMD to reduce fugitive dust emissions, thereby preventing contaminated soil from becoming airborne dust and reaching the nearest sensitive receptor to the project site.

The potential noise impacts of the project are evaluated in Section 4.3, Noise and Vibration, of the Draft EIR, which begins on page 4.3-1. As shown in Table 4.3-2 on page 4.3-12 of the Draft EIR, project construction equipment would generate noise levels of up to 64 dBA Leq at the nearest sensitive receptor, which is a residence within the Disadvantaged Community. The modeled noise level of 64 dBA Leq is below the significance threshold of 80 dBA Leq. Project operational noise of the project was also evaluated at the nearest sensitive receptor to the project site. As described on page 4.3-13 of the Draft EIR, most operational noise would be below significance thresholds at the receptor, but when trucks operate along the northern side of the proposed building, significance thresholds could be exceeded. Incorporation of Mitigation Measure NOI-1, described on page 4.3-18 of the Draft EIR, requires installation of permanent noise barrier along the property boundary that is oriented in a northwest-southeast direction. This noise barrier would reduce project operational noise at the nearest sensitive receptor to below significance thresholds. Therefore, noise impacts at the nearest sensitive receptor would be less than significant with implementation of mitigation (see page 4.3-18 of the Draft EIR).

Because the Draft EIR evaluates the potential air quality and health risk, hazard material exposure, and noise impacts of the project at the nearest sensitive receptor, and that receptor is part of a Disadvantaged Community, the EIR analysis has evaluated impacts on an environmental justice community. As described earlier in this response, these impacts would be less than significant either with or without mitigation, depending on the specific impact. The proposed project would not have disproportionate or significant impacts on a Disadvantaged Community.

The City has also evaluated the consistency of the project with its General Plan, outside the context of CEQA. The following table provides a brief summary of the project consistency analysis with the applicable policies of the Environmental Justice Element (Chapter 12):

General Plan Policy – Environmental Justice Element Consistency Analysis Policy EH-3.3: Land Use Compatibility. Discourage new
uses with potential adverse air quality impacts,
including the emission of toxic air contaminants and
fine particulates, near residential neighborhoods,
schools, hospitals, nursing homes, and other locations
where public health could potentially be affected
Consistent. Please see Response 5.5, above, for the analysis of consistency with this policy.
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General Plan Policy – Environmental Justice Element Consistency Analysis Policy EH-5.1: Regulatory Compliance. Work with the
appropriate county, regional, state, and federal
agencies to develop and implement programs for
hazardous waste reduction, hazardous material facility
siting, hazardous waste handling and disposal, public
education, and regulatory compliance.

Consistent. The applicant has not proposed a hazardous
material facility at the project site. The project applicant must comply with regulations pertaining to the handling and disposal of hazardous materials, which are described in Section 4.2.2, Regulatory Setting, beginning on page 4.2-6 of the Draft EIR. As described on page 4.2-12 through 4.2-13 of the Draft EIR, project construction activities would have potential to release or mobilize existing contamination on the project site. However, the Draft EIR includes mitigation to reduce the risk of this hazardous contamination from
reaching the nearest sensitive receptors to the project site (see Response 5.23).

Policy EH-5.2: Clean-Up of Contaminated Sites. Ensure
that the necessary steps are taken to clean up residual hazardous wastes on any contaminated sites proposed
for redevelopment or reuse. Require soil evaluations as needed to ensure that risks are assessed and
appropriate remediation is provided.

Consistent. Pages 4.2-15 through 4.2-17 of the Draft EIR describe Mitigation Measure HAZ-2. Mitigation Measure
HAZ-2 requires the project applicant to continue to utilize Department of Toxic Substances Control for agency oversight of assessment and remediation of the project site through completion of construction activities. HAZ-2 requires
implementation of the Revised Soil and Groundwater
Management Plan during construction. The Revised Soil and Groundwater Management Plan is approved by the
Department of Toxic Substances Control and contains
measures and practices that must be implemented to ensure hazardous materials are not released into the environment.

Mitigation Measure HAZ-2 also requires field screening of site soil continuously during ground disturbing activities using a calibrated handheld photoionization detector or other organic vapor meter. Soils identified as contaminated must be removed, transported, and disposed of in
accordance with federal and state regulations.

Policy EH-10: Downwind Impacts. Consider the
direction of prevailing winds in the siting of facilities likely to generate smoke, dust, and odors. Ensure that
such facilities are sited to minimize the impacts on
downwind residential areas and other sensitive uses.

Consistent. The proposed project would does not include stacks, furnaces, incinerators, or other equipment that would generate substantial amounts of smoke. As described on
page 47 of the Initial Study (Appendix A of the Draft EIR), operation of the project would not generate odors affecting a substantial number of people. Additionally, the applicant would be required to implement Mitigation Measure AQ-1
on pages 42 and 43 of the Initial Study. Mitigation Measure AQ-1 requires the project applicant to implement basic
construction mitigation measures recommended by
BAAQMD to reduce fugitive dust emissions, thereby
preventing contaminated soil from becoming airborne dust and reaching the nearest sensitive receptor to the site.

Policy T-6.7. Siting of Businesses with Truck Traffic. To the extent feasible, locate businesses projected to
generate large amounts of truck traffic away from
residential areas. Ingress and egress for such businesses should be designed to minimize the possibility of truck traffic impacting residential streets.

Consistent. Consistency with this policy is evaluated in Table 20 on pages 121 and 122 of the Initial Study. The Initial Study is provided as Appendix A to the Draft EIR.

Policy EJ-1.4: Cleanup Sites. Continue to work closely
with jurisdictionally approved cleanup oversight
agencies and collaborate on past, current, and
emerging cleanup cases.

Consistent. Please see consistency analysis for Policy EH-5.2, earlier in this table.
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General Plan Policy – Environmental Justice Element Consistency Analysis Policy EJ-1.9: Alternative Fuel Vehicles. Promote the
development of infrastructure that supports the use of
alternative fuel (i.e., electric) vehicles in Environmental Justice Communities by requiring electric vehicle
infrastructure be incorporated into new residential
development. (See Environmental Hazards Element
Policy EH-3.9 for additional guidance on alternative fuel vehicles).

Consistent. The proposed project is not a residential
development. Nonetheless, the proposed project would
include 21 electric-vehicle ready parking spaces, which would meet and exceed the CalGreen Code requirement.

Policy OSC-2.12: Open Spaces in New Development.

Promote the inclusion of plazas, courtyards, landscaped commons, rooftop gardens/green space, and other
publicly accessible open spaces within new commercial,
industrial, and public facility development.

Consistent/Not Applicable. The project applicant has chosen not to provide publicly accessible open space on the project site, and although the policy calls to “promote” open space in new development, it does not require it. The City has
determined that the project site, due to its distance from residences, and the project itself, which is anticipated to include large truck traffic, are not suitable candidates for public open space.

Policy T-3.6: Pedestrian Environment. Improve the
walkability of all streets in San Leandro through the
planning, implementing, and maintaining of pedestrian
supportive infrastructure.

Consistent. As described on page 121 of the Initial Study (Appendix A to the Draft EIR), the project would include several pedestrian improvements to the site including
lighting, internal sidewalks, improved landscaping, and pedestrian amenities. New sidewalks would also be
constructed as part of the project along the project site frontage on Hester Street.

The determination of General Plan consistency is within the discretion of the City of San Leandro City Council. In making this determination, the applicable law requires the decision makers to view the proposed project against the General Plan as a whole and does not permit the elevation of certain specific General Plan policies over others. Nonetheless, as shown in the table above, the proposed project would be generally consistent with most of the relevant policies of the Environmental Justice Element of the City’s General Plan.

Response 5.17
The commenter states that the Draft EIR provides general information about the census tract’s CalEnviroScreen scores, but opines that the Draft EIR does not provide meaningful analysis regarding the health impacts and effects of severe pollution rates as they relate to environmental justice. The commenter asserts that the omission of this analysis conflicts with State CEQA Guidelines Section 15131(c).

The commenter is correct that the Draft EIR provides information describing the CalEnviroScreen scores for the census tract in which the project site is located. Specifically, this information is described in a Health Risk Assessment that Kimley Horn and Associates prepared for the project in November 2023. The Health Risk Assessment is provided as Appendix B to the Initial Study, which is provided as Appendix A to the Draft EIR. Page 11 of the Health Risk Assessment describes the project site as located within Census Tract 6001441503, which is within the 40-45 percentile CalEnviroScreen score. The Health Risk Assessment describes the nearest sensitive receptors to the east within the 25-30 percentile (Census Tract 6001443321) and 15-20 percentile (Census Tract 6001443322). The census tracts described in the Health Risk Assessment seem to be incorrect.

According to CalEnviroScreen, the project site and the nearest sensitive receptors, to the east, are both in Census Tract 6001432400. Census Tract 6001432400 is >80-90th percentile. This error in census tract descriptions in the Health Risk Assessment does not affect the analysis or impact 199
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determination because air quality impacts of the project were evaluated at the closest sensitive receptor to the project site regardless of what census tract the receptor or project site are located.

However, for informational purposes, page 11 of the Health Risk Assessment is revised as follows:

According to CalEnviroScreen, the Project site is located within Census Tract 6001441503, which is within the 40-45 percentile. However, and the nearest sensitive receptors to the east are located within the 25-30 >80-90 percentile (Census Tract 6001443321) and 15-20 percentile (Census Tract 6001443322 6001432400).

The commenter does not specify what type of pollution they believe the Draft EIR omits. However, this comment is under a heading titled “1.4 Issues Not Studied in Detail in the EIR: Air Quality and Energy and 4.1 Greenhouse Gas Emissions.” Therefore, the City assumes the commenter is suggesting that the Draft EIR has omitted an analysis of air pollution impacts resulting from the project. Based on this assumption, the part of this comment about health impacts and pollution rates is similar to Comment 5.5. Please see Response 5.5. Briefly, as described therein, the proposed project would not exceed BAAQMD thresholds for emissions of criteria pollutants. Implementation of Mitigation Measure AQ-1 on pages 42 and 43 of the Initial Study would reduce fugitive dust emissions during project construction. A complete Health Risk Assessment was completed for the project at the nearest sensitive receptor (residence), and the project’s health risk would not exceed applicable thresholds. The proposed project would not expose sensitive receptors to substantial pollutant concentrations. Impacts were determined to be less than significant (see Section 3, Air Quality, of the Initial Study).

The second part of this comment pertaining to omission of the health impacts and effects of severe pollution rates as they relate to environmental justice are not accurate. As stated in the previous paragraph, the Draft EIR does provide an analysis of the potential air quality impacts of the project, as well as potential health risk impacts. Additionally, while physical environmental impacts must be examined under CEQA, “the economic and social effects of proposed projects are outside CEQA’s purview.” (Guidelines, section 15131(a); Bakersfield Citizens for Local Control v. City of Bakersfield (2004) 124 Cal.App.4th 1184, 1205). Therefore, formal analysis of economic or social impacts is not required, which includes impacts related to an individual or group of individuals’ demographics or economic status through the context of environmental justice.

State CEQA Guidelines Section 15131(c) pertains to modifying a project to reduce its potentially significant effects. The potentially significant impacts of the project are related to greenhouse gases and due to the provision of natural gas plumbing in the proposed building. As stated in bold text on page 4.1-8 of the Draft EIR, the proposed project would have potential to contribute to the longterm generation of GHG emissions due to the provision of natural gas plumbing, and impacts would be significant and unavoidable. Page 4.1-9 of the Draft EIR states that there is no feasible mitigation to reduce this potentially significant impact. Page 4.1-9 of the Draft provides a thorough explanation of why there is no feasible mitigation, including modifying the project, to reduce the potentially significant GHG impacts of the project. Therefore, the Draft EIR has been prepared pursuant to State CEQA Guidelines Section 15131(c).

No further revisions to the Draft EIR are required in response to this comment.

Response 5.18
The commenter states that the Draft EIR excludes that the project site is listed as a Disadvantaged Community in the City’s General Plan.
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The commenter is correct that the project site is within a Disadvantaged Community identified in the General Plan, but the Draft EIR does not describe this existing condition. The Draft EIR does not describe the Disadvantaged Community status of the project site because that status is related to environmental justice. Please see Response 5.16 above for a detailed explanation of why environmental justice is not evaluated as a physical environmental impact in the Draft EIR.

Accordingly, no revisions to the Draft EIR are required in response to this comment. However, please see Response 5.16 above for an analysis of project consistency with applicable policies of the Environmental Justice Element of the City’s General Plan.

Response 5.19
The commenter states that CalEnviroScreen ranks the census tract in which the project site is located as worse than 92 percent of the rest of the state in overall pollution burden and 71 percent of the state overall in socioeconomic impacts.

The commenter is correct. According to CalEnviroScreen, the project site is in a census tract that is ranked in the 92nd percentile for overall pollution burden and 71st percentile for population characteristics (socioeconomic). The CalEnviroScreen rankings of the census tract do not pertain to the analysis of environmental impacts provided in the Draft EIR. Therefore, no revisions to the Draft EIR are required in response to this comment.

Response 5.20
The commenter suggests that the project site’s census tract and surrounding community bears the impact of multiple sources of pollution and is more polluted than average on several pollution indicators measured by CalEnviroScreen. The commenter describes the exposure to diesel particulate matter (PM) and vehicle exhaust an example of the air pollution and associated health impacts that burden the census tract.

As discussed above in Response 5.17, Kimley Horn and Associates prepared a Health Risk Assessment for the project in November 2023. The Health Risk Assessment, which is included as Appendix B to the Initial Study, evaluates the potential for toxic air contaminant emissions from the project to have unacceptable health risks at the nearest sensitive receptor. Toxic air contaminants considered in the Health Risk Assessment include diesel particulate matter and other sources of particulate matter, such as dust from construction. The nearest sensitive receptor is a single-family residence northeast of the project site, which is in the same census tract as the project site (see page 7 of the Health Risk Assessment). The Health Risk Assessment includes an evaluation of the cumulative health risks, which are the health risks at the nearest sensitive receptor resulting from the project toxic air contaminant emissions combined with other existing toxic air contaminant emissions in the area. The Health Risk Assessment uses threshold established by the BAAQMD to determine the significance of cumulative health risks (see page 14 of the Health Risk Assessment).

The results of the assessment are detailed in Chapter 5, Potential Health Risk Impacts, which begins on page 20 of the Health Risk Assessment. The results of the Health Risk Assessment are also summarized on pages 43 through 47 of the Initial Study. Specifically, as presented in Table 10, 2020 Cumulative Health Risk, on page 46 of the Initial Study, the cumulative health risks to the nearest sensitive receptor would be below applicable BAAQMD significance thresholds. Cumulative health risks were determined to be less than significant, as described on page 47 of the Initial Study.

In context with the overall comment letter, this comment was provided in regard to an environmental justice issue or impact. There are currently no formal requirements or procedures to evaluate potential environmental justice impacts under CEQA. Nonetheless, the Draft EIR evaluated 201
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health risk impacts from toxic air contaminants on the Disadvantaged Community because it evaluates impacts at a receptor site within the same census tract/community as the project site and related toxic air contaminant emissions. Accordingly, no revisions to the Draft EIR are required in response to this comment.

Response 5.21
The commenter describes how the project census tract ranks in 97th percentile for groundwater threats based on CalEnviroScreen and explains how disadvantaged community are exposed to drinking water contaminants more often compared to communities that are not disadvantaged.

Additionally, potable water supply is discussed in the Draft EIR. As discussed on page 129 of the Initial Study, water service to the City of San Leandro is provided by the East Bay Municipal Utility District (EBMUD), a public utility. As further described on page 129 of the Initial Study, approximately 90 percent of the EBMUD water supply originates from the Sierra Nevada via the Mokelumne River watershed, with the other 10 percent sourced from runoff on East Bay Area watershed lands. Water delivered to San Leandro customers is treated at the Orinda or Upper San Leandro water treatment plants. Potable water is not from groundwater aquifers underlying the census tract in which the project is located. Further, this comment appears to discuss existing conditions and does not question the impact analysis in the Draft EIR. Additionally, the proposed project would include bioretention areas to treat stormwater runoff, which do not currently exist at the project site. This would potentially reduce contaminants in stormwater runoff from the project site compared to existing conditions. As previously mentioned, drinking water for San Leandro is not from runoff on the project site or from sources down gradient of the project site. Accordingly, no revisions to the Draft EIR are required in response to this comment.

Response 5.22
The commenter describes the project census tract as within CalEnviroScreen’s 99th percentile for solid waste impacts and explains ways solid waste facilities can adversely affect the health of nearby populations.

The proposed project is a new warehouse, as described in Section 2, Project Description, of the Draft EIR. The proposed project does not include the construction or permitting of a new solid waste facility on the project site, in the surrounding census tract, or elsewhere. Additionally, the solid waste impacts of the project were evaluated on pages 135 and 136 of the Initial Study, which is included as Appendix A to the Draft EIR. As discussed on these pages of the Initial Study, project impacts related to solid waste would be less than significant. This comment also describes existing conditions characterizing health risks in the census tract and does not question the impact analysis in the Draft EIR. Additionally, in context with the overall comment letter, this comment was provided with regards to an environmental justice issue. There are currently no formal requirements or procedures to evaluate potential environmental justice impacts under CEQA (see Response 5.16).

Therefore, no revisions to the Draft EIR are required in response to this comment. 202
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Response 5.23
The commenter describes the project’s census tract as bearing more impacts from cleanup sites than 90 percent of the state and describes how chemicals can mobilize and affect nearby communities.

For informational purposes, the Draft EIR does evaluate the potential impacts associated with the release of or exposure to hazardous materials on the environment and people, regardless of whether the people are part of a disadvantaged community. Specifically, the Draft EIR describes the potential for hazardous materials to exist on the project site in the form of contaminated soil and groundwater. Specifically, page 4.2-2 of the Draft EIR states that the project site is considered a hazardous site due to subsurface contamination with chlorinated volatile organic compounds. As described on page 4.2-4 of the Draft EIR, a Land Use Covenant (LUC) for the project site was filed with Alameda County in 2012 that requires DTSC approval of planned future use of groundwater at the project site and a Soil Management Plan prior to planned disturbance of subsurface soil in two limited areas of the site.

Impact HAZ-1, beginning on page 4.2-11 of the Draft EIR, describes how project construction, including the installation of buried utilities, could results in significant impacts related to worker exposure to contaminated soil or groundwater. As described on page 4.2-13 of the Draft EIR, implementation of Mitigation Measure HAZ-2 and Mitigation Measure HAZ 3 is required to reduce risks to construction workers and reduce the impacts to less than significant. Mitigation Measure HAZ-2 requires implementation of the approved Revised Soil and Groundwater Management Plan during construction. Mitigation Measure HAZ-3 requires containment of dewatering effluent and obtaining a discharge permit if released from containment. As described on page 4.2-18 of the Draft EIR, with incorporation of Mitigation Measure HAZ-2, the provisions of the approved Soil and Groundwater Management Plan for the site would reduce potential hazardous materials impacts associated with the past on-site contamination during project construction. Additionally, implementation of Mitigation Measure HAZ-3 would protect the health of construction workers and the environment during construction dewatering activities. As the Draft EIR indicates that impacts related to contaminated soils or groundwater would be less than significant with implementation of these mitigation measures. Additionally, the applicant would be required to implement Mitigation Measure AQ-1 on pages 42 and 43 of the Initial Study. Mitigation Measure AQ-1 requires the project applicant to implement basic construction mitigation measures recommended by BAAQMD to reduce fugitive dust emissions. This would further prevent contaminated soils from becoming mobilized in the air during construction.

Response 5.24
The commenter describes that the project’s census tract ranks in the 62nd percentile for toxic releases and describes that people residing near emissions of toxic releases may breathe contaminated air regularly or if contaminants are released during an accident.

In context with the overall comment letter, this comment was provided with regards to an environmental justice issue or impact. There are currently no formal requirements or procedures to 203
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evaluate potential environmental justice impacts under CEQA. This comment also appears to describe existing conditions and does not question the analysis of impacts in the Draft EIR.

Therefore, no revisions to the Draft EIR are required in response to this comment.

This comment pertains to toxic air contaminants and is similar to Comment 5.5. For informative purposes, as described in Response 5.5, construction and operation of the project would generate toxic air contaminants, such as the exhaust from diesel construction equipment and diesel tractor trailers. The potential health risks of exposure to these contaminants at the nearest sensitive receptor to the project are evaluated in detail in the Health Risk Assessment that Kimley Horn and Associates prepared for the project in November 2023, which is Appendix B to the Initial Study. The results of the Health Risk Assessment are discussed on pages 43 through 47 of the Initial Study. As described therein, the project’s health risk would not exceed applicable thresholds. The proposed project would not expose sensitive receptors to substantial pollutant concentrations and impacts would be less than significant (see Initial Study page 47).

Response 5.25
The commenter describes demographic characteristics of the population residing within the project’s census tract. Examples of demographic characteristics the commenter describes include race and ethnicity, educational attainment, poverty status, and languages spoken.

In context with the overall comment letter, this comment was provided with regards to an environmental justice issue or impact. Please see Response 5.16 above for a detailed explanation of why environmental justice is not evaluated as a physical environmental impact in the Draft EIR. This comment pertains to the existing demographic composition of the population residing within the census tract of the project site, and does not question the analysis or impact determinations in the Draft EIR. Because the demographic composition is not related to the analysis of environmental impacts in the Draft EIR, the City has not confirmed if the demographic information reported by the commenter is accurate. No revisions to the Draft EIR are required in response to this comment.

Response 5.26
The commenter states that the project site is in a census tract identified as Disadvantage Community under Senate Bill 535 and asserts that the Draft EIR has not considered the project’s environmental impacts in relation to the Senate Bill 535 status of the census tract. The commenter asserts that a revised EIR should be prepared to include the severity of environmental impacts particularly on these Disadvantaged Communities.

The commenter’s statement that the project site is in a census tract identified as a Disadvantaged Community is similar to Comment 5.18. Please refer to Response 5.16 and Response 5.18. Briefly, as described therein, the project site is within a Disadvantaged Community, but the Draft EIR does not describe this existing condition. The Draft EIR does not describe the Disadvantaged Community status of the project site because that status is related to environmental justice. There are currently no formal requirements or procedures to evaluate potential environmental justice impacts under CEQA.

Senate Bill 535 establishes minimum funding levels allocated to Disadvantage Communities, primarily funding from the state’s Cap-and-Trade Program. Senate Bill 535 does not pertain to impact analysis methodology or determinations in CEQA documents. Accordingly, the Draft EIR does not discuss Senate Bill 535. Accordingly, no revisions to the Draft EIR are required in response to this comment.
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For informational purposes, the Draft EIR does evaluate environmental impacts of the project that could result in adverse impacts to the population residing within the same census tract as the project site. For example, as described in Response 5.20, the potential for substantial adverse health effects resulting from toxic air contaminant emissions of the project were evaluated at the nearest sensitive receptor. The nearest sensitive receptor is the nearest residence to the project site, which is a residence located within the same census tract/community as the project site.

Response 5.27
The commenter opines that a revised EIR must be prepared because the Draft EIR utilizes the California Emissions Estimator Model (CalEEMod) for determining the energy impacts of the project, but the State has not approved CalEEMod for this purpose. The commenter suggests the state has approved only three modeling software applications for non-residential energy use, none of which are CalEEMod.

The commenters assertion that CalEEMod was used in the Draft EIR to determine the significance of the potential energy impacts of the project is not completely accurate. The potential energy impacts of the project are evaluated in Section 6, Energy, of the Initial Study, which is included as Appendix A to the Draft EIR. As described therein, specifically on pages 62 and 63 on the Initial Study, the potential impacts of the project as they relate to wasteful, inefficient, or unnecessary consumption of energy resources was determined to be less than significant. The less than significant determination is not based on quantification of energy use compared to a numerical threshold.

Instead, as discussed on pages 62 and 63 of the Initial Study, the significance determination of the impact relies primarily on mandatory regulations and codes that must be implemented during construction and operation of the project that are designed to reduce energy consumption.

Examples of the regulations and codes described on pages 62 and 63 of the Initial Study include:

California Air Resources Board’s In-Use Off-Road Diesel-Fueled Fleets Regulation; California Building Standards Code (California Code of Regulations Title 24); California’s CalGreen standards (California Code of Regulations Title 24, Part 11); and the 2022 Building Energy Efficiency Standards (California Code of Regulations Title 24, Part 6). While the less-than-significant energy impacts of the project identified in Section 6, Energy, of the Initial Study are not quantitative and do not rely upon CalEEMod, the potential energy consumption of the project was estimated using CalEEMod. The estimated energy use generated by CalEEMod was referred to in the preparation of the Draft EIR as supporting information in the determination of less than significant energy impacts. The CalEEMod datasheets are provided in Appendix A to the Initial Study.

Additionally, Section 6, Energy, of the Initial Study also provides an analysis of the consistency of the proposed project with the state and local renewable energy and energy efficiency plans. The analysis is presented in tabular format consisting of Table 12 and Table 13, beginning on page 63 and page 64, respectively. As described in these two tables, the proposed project would be consistent with State plans and the City’s adopted energy conservation and efficiency strategies.

This consistency analysis also informed the less than significant impact determination of energy impacts. This approach is consistent with the State CEQA Guidelines. Specifically, Appendix F of the State CEQA Guidelines states that environmental impacts related to energy may include “the degree to which the project complies with existing energy standards.” The three modeling software applications the commenter lists as approved by the state for modeling non-residential energy include CBECC-Com, EnergyPro, and IES VE. The commenter’s assertion that the Draft EIR must use this modeling software or prepare a revised EIR using these applications to model energy use and determine the significance of impacts is not correct. According 205
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to the California Energy Commissions, CBECC-Com, EnergyPro, and IES VE are the approved models for demonstrating compliance with the 2022 Building Energy Efficiency Standards (Energy Code) in accordance with the California Code of Regulations: Title 24, Part 1, Article 1, Section 10-109 (California Energy Commission 2024).1 Compliance with federal, state, and local regulations and code are mandatory as legal requirements. It is unnecessary to demonstrate compliance with Energy Code in the Draft EIR as compliance would be achieved through the implementation of uniformly applied development standards and state law. Accordingly, no revisions to the Draft EIR are required in response to this comment.

Response 5.28
The commenter states that the project site is in the Outer Approach Zone of the Oakland International Airport.

This comment is similar to Comment 3.7 provided in Letter 3. Therefore, please refer to Response

3.7 for a response to this comment.

Response 5.29
The commenter references text in both the Initial Study and Draft EIR describing how the project requires No Hazard Determinations from the Federal Aviation Administration. The commenter opines that a revised EIR must be prepared to include the Federal Aviation Administration documentation pursuant to State CEQA Guidelines Section 15121 and Section 15150(f), as well as Public Resources Code (PRC) 21003(b).

The commenter is correct that the project would require a No Hazard Determination from the Federal Aviation Administration. This portion of this comment pertaining to the project requiring a No Hazard Determination from the Federal Aviation Administration is similar to Comment 5.6.

Please refer to Response 5.6. Briefly, as described therein, a No Hazard Determination for the warehouse was issued from the Federal Aviation Administration pursuant to Federal Aviation Regulations Part 77, because the proposed warehouse would have a maximum height of 50 feet. An additional No Hazard Determination may also be needed for the use of project construction equipment exceeding 43 feet in height.

Including the No Hazard Determinations for the proposed project in the Draft EIR is not necessary to adequately analyze and disclose the potential environmental effects of the project. Obtaining the applicable No Hazard Determinations from the Federal Aviation Administration is a legal requirement pursuant to Federal Aviation Regulations Part 77. Therefore, it is understood that the project applicant either has or would obtain the No Hazard Determinations or the project would otherwise not proceed, even if planning entitlements were approved by the City. Additionally, the No Hazard Determination for the proposed building has been issued and is on file at City Hall, available upon request.

State CEQA Guidelines Section 15121 does not require the inclusion of permits or permit applications in an EIR. Section 15121 of the State CEQA Guidelines describes the informational intent of EIRs and requires the lead agency to make findings for each significant effect in the EIR and prepare a statement of overriding consideration, as applicable. 1 California Energy Commission. 2024. 2022 Energy Code Compliance Software. Retrieved on August 22, 2024, from https://www.energy.ca.gov/programs-and-topics/programs/building-energy-efficiency-standards/2022-building-energy-efficiency-1 206
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Section 15150 of the State CEQA Guidelines pertains to incorporation of documents by reference within an EIR. Section 15150 (f), specifically, states that incorporation by reference is most appropriate for including long, descriptive, or technical materials that provide general background but do not contribute directly to the analysis of the problem at hand. The Draft EIR is prepared consistent with Section 15150(f) because the No Hazard Determination only needs to be incorporated by reference because it is a regulatory requirement and does not affect the impact analysis or determinations in the Draft EIR. Consistent with State CEQA Guidelines Section 15150(b), the No Hazard Determination for the proposed warehouse is available for public inspection at City Hall, which is a public building.

Public Resources Code (PRC) 21003(b) states that CEQA documents should be organized and written in a manner that will be meaningful and useful to decision makers and the public. The Draft EIR is prepared in an organized manner. The Draft EIR is arranged to approximately correspond the contents of an EIR described in Article 9, Contents of Environmental Impact Reports, of the State CEQA Guidelines. The Draft EIR is written in a way that is useful to decision makers and the public in that it presents a summary of each impact in bold text, followed by a detailed analysis of the potential impact. The Draft EIR avoids extensive use of jargon and complex terminology, and instead attempts to use common language to the maximum extent feasible to increase its meaningfulness to the public and decision makers. The Draft EIR need not include the Federal Aviation Administration No Hazard Determination in order for it to be meaningful or useful. As described in earlier paragraphs of this response, obtaining the No Hazard Determinations is required and mandated by federal law. For this reason, decision makers and the public are able to assume that No Hazard Determinations have or will be issued if the project proceeds. Therefore, no revisions to the Draft EIR are required in response to this comment.

Response 5.30
The commenter asserts that the Draft EIR must include revised building elevations that are legible to the public, not blurry, and depict the height of the building to verify it is consistent with the Federal Aviation Administration review.

This comment is similar to Comment 5.11. Please refer to Response 5.11. Briefly, as described therein, the Draft EIR includes the details the commenter requests be shown on building elevations, including building height, materials, and color palette. The Draft EIR also contains a building elevation as Figure 2-5, which does not appear blurry when viewed by City staff. No revisions to the Draft EIR are required in response to this comment.

Response 5.31
The commenter opines that a revised EIR must be prepared that identifies a significant impact associated with project construction resulting in safety hazards or excessive noise in combination with airport operations.

As described on page 2-14 of the Draft EIR, a crawler crane with a boom height of up to approximately 161 feet (reduced to 140 feet as explained in the response to Letter 3b) would be required for project construction. Page 2-17 of the Draft EIR states that a ‘No Hazard Determination’ from the Federal Aviation Administration may be necessary for the use of project construction equipment exceeding 43 feet in height, which would include the crawler crane with a maximum height of 140 feet (see Letter 3b). The project applicant must obtain the necessary determinations from the Federal Aviation Administration pursuant to Federal Aviation Regulations Part 77. The project applicant must abide by all conditions of the determination, including equipment height 207
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limitations specified in the determination, as applicable. Because the applicant must abide by federal regulations and obtain required No Hazard Determinations from the Federal Aviation Administration, as applicable, the project would not expose project construction workers to safety hazards associated with airport operations.

Potential noise impacts of the project are evaluated in Section 4.3, Noise and Vibration, of the Draft EIR, which begins on page 4.3-1. As shown in Table 4.3-2 on page 4.3-12 of the Draft EIR, project construction equipment would generate noise levels of up to approximately 84 dDBA Leq measured 50 feet from the equipment. Therefore, project construction workers would be potentially exposed to noise levels of approximately 84 dDBA, not accounting for hearing protection that may be required by workplace safety practices and regulations, such as OSHA regulations. As described on page 4.3-20 of the Draft EIR, the easternmost portion of the project site is within the 60 dBA CNEL contour of the Oakland International Airport (Alameda County Community Development Department 2010). Due to the logarithmic nature of decibels, when one sound source is at least 10 dBA less than another sound source, the quieter sound source will have a negligible effect on the overall sound level. In the case of the proposed project, the airport noise is estimated at 24 dBA less than construction noise (84 dBA – 60 dBA = 24 dBA). Accordingly, noise from airport operations would have negligible effects on the construction noise levels within the project site. In other words, during project construction, construction noise levels at the site would either be equivalent to noise produced by the construction equipment or by ambient noise levels when construction equipment is not operational. For this reason, project construction would not expose people working in the project area to excessive noise levels.

As demonstrated in the prior two paragraphs, while the project site is proximate to the Oakland International Airport, the project would not result in a safety hazard or excessive noise for people working in the project area during construction. Impacts would be less than significant with mandatory adherence to Federal Aviation Regulations Part 77 and the construction practices the applicant has agreed to in coordination with the Port of Oakland (see Letter 3b). Accordingly, no revisions to the Draft EIR are required in response to this comment.

Response 5.32
The commenter suggests that the that Draft EIR underreports the vehicle miles traveled (VMT) generated from project operations, explaining how trucks and vans would depart the project site and travel across the region at high rates.

As described on page 4.4-5 of the Draft EIR, the analysis of VMT impacts is based on a Transportation Analysis prepared by Kimley-Horn for the proposed project, which is included as Appendix C to the Draft EIR. As summarized on page 4.4-5 of the Draft EIR and discussed in the Transportation Analysis, the VMT generated by the proposed project was estimated by referring to VMT estimates produced by the Alameda County Transportation Commission for 2020 and 2040.

The Alameda County Transportation Commission developed their VMT estimates on a TAZ basis using the Alameda Countywide Travel Model.

According to the Transportation Analysis (Appendix C) and the Alameda County Transportation Commission (2019), the project site is in a TAZ with a VMT of 15.34 per employee in 2020 (see Draft EIR page 4.4-6). Therefore, as described on Draft EIR page 4.4-6, the Transportation Analysis determined that the proposed project would also generate 15.34 VMT per employee, consistent with the 2020 VMT of the TAZ. This is a reasonable assumption because the TAZ covers a limited area surrounding the project site that is characterized by warehouses and industrial land uses, consistent with the proposed project. In other words, the proposed project would be in a TAZ that 208
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the Alameda County Transportation Commission indicates has an average VMT per employee of

15.34, and because the project would be a warehouse use similar to much of the other land uses in the TAZ, would be consistent with the average VMT per employee of 15.34. As noted on page 4.4-6 of the Draft EIR, the Alameda County Transportation Commission VMT maps are consistent with methodology specified by the Governor’s Office of Planning and Research.

As described on page 2-8 of the Draft EIR, there is no specific known land use and/or tenant proposed at this time. Therefore, the comment may be inaccurate in assuming that project operations would involve high rates of truck and van departures from the project site. For example, potential tenants of the building may not include routine delivery, resulting in fewer truck and van trips. However, the proposed building includes office space and sixty-four loading docks plus space for employee parking and additional truck parking, as described in Section 2, Project Description, of the Draft EIR. The provision of spaces for truck activity and offices suggests that the building would likely be utilized for more than storage. Therefore, project operations could involve routine truck and van trips to offsite locations, such as for deliveries to final destinations. However, the methodology used for the VMT analysis in the Transportation Analysis and thus the Draft EIR accounts for VMT per employee, consistent with existing land uses in same TAZ, which include various warehouses.

The commenter provides no additional explanation or information on why they suggest the project would result in substantially high rates of vehicle trips compared to other similar industrial and warehouse land uses in the area. Therefore, it is reasonable for the Transportation Analysis and Draft EIR to rely upon the average VMT of these existing similar uses in a similar location to estimate project VMT. As described on pages 4.4-6 and 4.4-7 of the Draft EIR, the project VMT of 15.34 miles per employee is below the 2020 VMT threshold of 16.3 miles per employee. Therefore, the proposed project would not conflict or be inconsistent with State CEQA Guidelines Section 15064.3, subdivision (b), as it pertains to VMT. Impacts would be less than significant. No revisions to the Draft EIR are required in response to this comment.

Response 5.33
The commenter opines that operation of the project would generate VMT that is inconsistent with the significance threshold and legislative intent of Senate Bill 743 to reduce greenhouse gas (GHG) emissions by reducing VMT.

As described on page 15 of the Transportation Analysis prepared by Kimley-Horn for the proposed project, which is included as Appendix C to the Draft EIR, the Project’s VMT evaluation relied on guidance provided by the Governor’s Office of Planning and Research (OPR) Technical Advisory on Evaluating Transportation Impacts in CEQA to determine potential impacts under Senate Bill 743. It should be noted that the ACTC VMT tools and maps are consistent with OPR methodology and the recommended 15 percent below regional average significance threshold.

The significance thresholds used to analyze the GHG impacts of the project are those adopted by the BAAQMD, as detailed in Response 4.2. The thresholds include several parameters relating to building design and transportation. With regard to transportation, for GHG impacts to be less than significant, the project must achieve a reduction in project-generated VMT below the regional average consistent with the current version of the California Climate Change Scoping Plan (currently 15 percent) or meet a locally adopted Senate Bill 743 VMT target, reflecting the recommendations provided in the Governor’s Office of Planning and Research's Technical Advisory on Evaluating Transportation Impacts in CEQA. The entire BAAQMD significance threshold is discussed on page

4.1-7 of the Draft EIR.
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Both the Transportation Analysis and the analysis of GHG impacts in the Draft EIR rely upon a reduction of project-generate VMT to levels at least 15 percent the regional average. Guidance from the OPR for compliance with Senate Bill 743 also recommends 15 percent below average as the significance threshold for VMT. Accordingly, the Draft EIR does utilize significance thresholds consistent with Senate Bill 743 for determining both transportation and GHG impacts.

As discussed on page 4.1-8 of the Draft EIR, the project VMT per capita would be at least 15 percent below regional VMT per capita and sufficient electric-vehicle ready parking spaces would be provided, and the proposed project would satisfy the transportation component of BAAQMD GHG significance criteria. However, as described in Response 5.17, the proposed project would have a potentially significant and unavoidable impact on GHG due to the provision of natural gas plumbing in the proposed building, which is unrelated to transportation/mobile source GHG emissions.

Because the Draft EIR evaluates both transportation and GHG impacts using thresholds consistent with Senate Bill 743, it is unnecessary to revise the Draft EIR to include another or different significance threshold aligned with the legislative intent suggested by the commenter. No revisions to the Draft EIR are required in response to this comment.

Response 5.34
The commenter opines that a revised EIR must be prepared to reflect a quantified VMT analysis that includes all truck/trailer and delivery van activity of the project.

This comment is similar to Comment 5.32. Please refer to Response 5.2. Briefly, as described therein, project VMT is based on average VMT from existing land uses in the same TAZ as the project site. The TAZ includes warehouses and industrial buildings similar to the proposed building, with truck parking and truck docks. Therefore, it is reasonable for the Transportation Analysis and Draft EIR to rely upon the average VMT of these existing similar uses in a similar location to estimate project VMT. No revisions to the Draft EIR are required in response to this comment.

Response 5.35
The commenter opines that the Draft EIR provides an inadequate analysis of transportation hazards due to geometric design features or the potential for the project to result in inadequate emergency access. The commenter asserts that the Draft EIR excludes analysis or discussion of the available maneuvering and queueing space for trucks/trailers at the intersection of the project driveways and the adjacent streets, or throughout the site.

Tractor trailers on the project site would be travelling at low speeds and performing maneuvers that require low-speed travel, such as operating in reverse to align with dock doors and parking in striped spaces. Tractor trailers would not be traveling at speeds such that they would collide with oncoming trucks operating on the project site. Tractor trailers routinely maneuver around warehouses and other developed areas without colliding, such as narrow streets in downtown areas. Therefore, there would be no significant impacts related to truck circulation hazards. No revisions to the Draft EIR are required in response to this comment.

Response 5.36
The commenter suggests that a revised EIR must be prepared to include an accurate cumulative analysis discussion to demonstrate the impact of the proposed project in a cumulative setting. 210
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The Draft EIR evaluates the potential cumulative impacts of the proposed project. As described on page 3-2 of the Draft EIR, consistent with State CEQA Guidelines Section 15130, the discussion in the Draft EIR focuses on the identification of significant cumulative impacts and, where present, the extent to which the proposed project would constitute a considerable contribution to the cumulative impact. As stated on page 3-2, CEQA requires cumulative impact analysis in EIRs to consider either a list of past, planned, and pending projects that may contribute to cumulative effects or a forecast of future development potential. The past, currently planned and pending projects in San Leandro used in the analysis of cumulative impacts in the Draft EIR are listed in Table 3-1 on page 3-3.

The commenter’s suggestion that either Section 5.1, Growth Inducement, or Section 5.2, Irreversible Environmental Effects, of the Draft EIR must include a cumulative analysis discussion is factually incorrect. The State CEQA Guidelines do not require either of these EIR sections to include a cumulative analysis. The analysis of cumulative impacts in the Draft EIR is presented in each resource topic within Section 4, Environmental Impact Analysis, beginning on page 4-1 of the Draft EIR. The cumulative GHG impacts of the project are described in Section 4.1.4, Cumulative Impacts, on page 4.1-13 of the Draft EIR. As described therein, cumulative projects have results in significant cumulative impacts related to GHG. The cumulative GHG impacts of the proposed project would be significant. The cumulative hazards and hazardous materials impacts of the project are described in Section 4.2.4, Cumulative Impacts, on page 4.2-19 of the Draft EIR. As described therein, the would be no significant cumulative impacts related to hazards and hazardous materials. The cumulative noise and vibration impacts of the project are described in Section 4.3.4, Cumulative Impacts, on pages 4.3-20 and 4.3-21 of the Draft EIR. As described therein, there would be no significant cumulative noise and vibration impacts. The cumulative transportation impacts of the project are described in Section 4.4.4, Cumulative Impacts, on pages 4.4-7 and 4.4-8 of the Draft EIR. As described therein, the transportation impacts of the project, including VMT and transportation hazard impacts, would be less than significant.

Impacts that were not evaluated in detail in the Draft EIR are evaluated in the Initial Study, which is provided as Appendix A to the Draft EIR. Impacts evaluated in the Initial Study but not in detail in the EIR are less than significant, including cumulative impacts. Specifically, as described on page 140 of the Initial Study, most of the potential impacts of the proposed project would be less than significant, either with or without mitigation, depending on the specific impact. These less than significant impacts would not have considerable contributions to a significant cumulative impact because they’re either site specific, such as impacts to paleontological resources, or because the project is consistent with standards and programs, such as zoning standards established in the San Leandro Municipal Code pertaining to aesthetics. Other less than significant impacts would not contribute to potentially significant impacts because they have negligible impacts to existing conditions, such as impacts to population and housing, public services, and recreation.

As the Draft EIR, including the Initial Study, does provide an analysis of potential cumulative impacts consistent with State CEQA Guidelines Section 15130, no revisions to the Draft EIR are required in response to this comment.

Response 5.37
The commenter suggests that Section 5.1, Growth Inducement, and 5.2, Irreversible Environmental Effects, of the Draft EIR do not include buildout conditions of the City’s General Plan and should be revised to include this information so that the proposed project can be compared for consistency 211
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with the General Plan EIR impact determinations. The commenter also suggests the Draft EIR tiers from the General Plan EIR.

The commenter’s suggestion that the Draft EIR tiers from the City’s General Plan EIR is incorrect.

The Draft EIR does include information from the General Plan, such as policies for example, but does not tier from the EIR that was completed and certified for the General Plan. The Draft EIR is a project-level EIR that evaluates the environmental effects of the proposed project, separate and independent from the impacts analysis completed for the General Plan EIR. Because the Draft EIR does not tier from the City’s General Plan EIR, it is unnecessary to determine if project impacts would be more severe than the impacts identified in the General Plan EIR. Instead, the Draft EIR evaluates and discloses the potential environmental impacts of the project, including its potential impacts related to growth inducement and irreversible effects, regardless and separate from impacts of implementing the General Plan. Therefore, no revisions to the Draft EIR are required in response to this comment.

Response 5.38
The commenter suggests that the project would generate 200 employees, which would be a significant amount of growth. The commenter suggests that the employment growth of the project should be added to other jobs created by nearby industrial projects to determine if cumulative growth would exceed the City’s growth forecast.

This comment is similar to Comment 5.5 and Comment 5.7. Please refer to responses 5.5 and 5.7 for a detailed response on the growth inducement impact analysis of the project. Briefly, as described therein, the proposed project would rely primarily on local workforce, would be in an area with existing infrastructure, and would demolish a building previously used for employment. For these reasons, Draft EIR concludes the proposed project would not result in substantial growth resulting in significant environmental impacts. Additionally, as described on page 2-9 of the Draft EIR, the proposed project would generate an estimated 152 employees. An estimated 152 employees would not represent substantial population growth in the San Francisco Bay or San Leandro, even if the workforce were not expected to be local. No revisions to the Draft EIR are required in response to this comment.

Additionally, the commenter does not provide an explanation of how or why growth would result in potentially significant environmental effects. The commenter does not suggest or list potentially significant impacts resulting from growth in this comment. Therefore, it is unclear why a cumulative growth analysis would be required in the Draft EIR as the commenter suggests, because it would not inform an environmental impact determination. Accordingly, no revisions to the Draft EIR are required in response to this comment.

Response 5.39
The commenter suggests that the Draft EIR is flawed, and a revised EIR must be prepared for the proposed project based on the earlier comments in the comment letter.

As discussed in response 5.1 through 5.38, above, no revisions to the EIR are required in response to this comment letter.

Response 5.40
The commenter requests to be added to the project mailing list. 212
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This comment does not question the analysis or conclusions of the Draft EIR. Therefore, no revisions to the Draft EIR are necessary in response to this comment. At the request of the commenter, the City has updated its mailing list to include this commenter.

Response 5.Exhibit A
The commenter includes a letter report written by SWAPE, reviewing the Draft EIR and providing opinions to the adequacy of the Draft EIR with regards to air quality, health risk assessment, and GHG emissions. Exhibit A contains several comments which have not been directly addressed in the earlier responses to this comment letter. These comments are addressed below.

Response 5A.1
The commenter summarizes the process by which CalEEMod can be adjusted to incorporate details specific to a project, and that these adjustments must be supposed by substantial evidence when used for CEQA. The commenter asserts that the CalEEMod output files in the Air Quality Assessment for the project are inconsistent with project information in the Draft EIR and therefore unsubstantiated. The commenter opines that for this reason, the construction emissions of the project may be underestimated in the Draft EIR.

The commenter does not provide details in this comment pertaining to what project-specific adjustments used in the Air Quality Assessment differ from the project description provided in the Draft EIR. Therefore, no further response to this comment is possible. However, later comments provided in Exhibit A do provide more details. Please refer to those comments for detailed responses.

Response 5A.2
The commenter asserts that the default construction schedule and phasing lengths provided in CalEEMod were adjusted for the proposed project without providing substantiated evidence for the adjustment. The commenter opines that the adjusted phasing lengths used for the project CalEEMod would result in more construction days, thereby resulting in less construction emissions per day, and therefore cannot be relied upon for determining impact severity.

The commenter is correct that the default construction schedule and phasing lengths provided in CalEEMod were adjusted for the proposed project. However, the commenter is factually incorrect in suggesting that the modified rate is unsubstantiated. The CalEEMod datasheets for the proposed project are provided as Appendix A to the Air Quality Assessment, which is provided as Appendix A to the Initial Study. Page 1 of the CalEEMod datasheets notes that construction phasing is based on the anticipated construction schedule of the project. In other words, project specific construction phasing was used in CalEEMod instead of the default phasing. This is further explained on page 39 of the Initial Study, stating that the project construction emissions were analyzed based on the applicant-provided information regarding the construction schedule and types of construction equipment used. Adjusting CalEEMod defaults to use project-specific information, such as anticipated construction phasing, provides a more accurate model result of the project emissions, as the results are based on the proposed activities rather than generic assumptions built into CalEEMod.

As described on page 41 of the Initial Study, construction-related emissions would not exceed BAAQMD thresholds. Therefore, project construction would not result in a cumulatively considerable net increase of a criteria pollutant for which the project region is non-attainment 213
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under an applicable federal or state ambient air quality standard. Implementation of Mitigation Measure AQ-1, found on pages 42 and 43 of the Initial Study, is required to reduce impacts associated with fugitive dust emissions during project construction. As described on page 43, with implementation of Mitigation Measure AQ-1, air quality impacts of the project would be less than significant.

As the Draft EIR, including the Initial Study and the Air Quality Assessment, do provide an explanation of why CalEEMod defaults were adjusted for project construction phasing and activities, no revisions to the Draft EIR are required in response to this comment.

Response 5A.3
The commenter suggests that when CalEEMod default values for construction phasing lengths are used for the proposed project, construction emissions would exceed regulatory thresholds of significance. The commenter provides CalEEMod output datasheets showing emissions that exceed thresholds based on default construction phasing lengths.

This comment is similar to Comment 5A.2. Please see Response 5A.2. Briefly, as described therein, the CalEEMod default values for construction phasing were adjusted to match the anticipated construction for proposed project. Because the construction phasing used in the Air Quality Assessment in the Draft EIR is project specific, the construction emissions estimated from CalEEMod are more accurate than the CalEEMod default, which do not closely align with the anticipated project construction schedule. Therefore, the commenter’s assertion that project construction would have significant air quality impacts based on default construction phasing values is not accurate, because the default values are not as representative of the proposed project as the actual phasing information. As described in Response 5A.2, when project-specific adjustments are made to the defaults, construction emissions would be below regulatory thresholds. Impacts would be less than significant. No revisions to the Draft EIR are required in response to this comment.

Response 5A.4
The commenter asserts that the proposed project would result in significant and unavoidable impacts related to GHG and suggests there are mitigation measures that would reduce potential GHG emissions of the project. The commenter provides a list of measures that they suggest would reduce GHG emissions.

This comment is similar to comments 4.2 through 4.14, which were provided in Comment Letter 4.

Please see responses 4.2 through 4.14 for a detailed response. Briefly, as stated therein, the Draft EIR was prepared using the BAAQMD 2022 CEQA Guidelines significance thresholds for GHG impacts. The threshold states that a project would have a potentially significant impacts if new natural gas plumbing is proposed. The BAAQMD threshold does not require or direct lead agencies to attempt to quantify GHG emissions and reduce them below a target amount. Instead, the threshold is about reducing depending on natural gas by avoiding the long-term commitment to its use in new construction. The mitigation measures recommended in Comment Letter 4 and in this comment attempt to reduce GHG emissions of the project but do not eliminate natural gas from the proposed project. Therefore, the recommended mitigation measures would not reduce or avoid the potentially significant GHG impacts of the project, which are related to long-term commitment to natural gas. As described in responses 4.2 through 4.14, no revisions to the Draft EIR are required. 214
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Response 5A.5
The commenter states that they may revise their comment letter in the future, and that the comment letter may contain informational gaps and inconsistencies.

This comment does not question the analysis or conclusions of the Draft EIR. Therefore, no revisions to the Draft EIR are necessary in response to this comment. The public comment period for the Draft EIR ended on August 5, 2024.
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P: (626) 314-3821
F: (626) 389-5414
E: [email protected]
Mitchell M. Tsai
Law Firm
139 South Hudson Avenue
Suite 200
Pasadena, California 91101

VIA E-MAIL
August 5, 2024
Cindy Lemaire, AICP, CNU-A, Senior Planner
Community Development Department
City of San Leandro
835 East 14th Street
San Leandro, California 94577
Ph: (510) 577-3325
Em: [email protected]
RE: City of San Leandro’s 880 Doolittle Drive Project – Draft Environmental Impact Report (SCH# 2023110597)
Dear Cindy Lemaire,
On behalf of the Carpenters Union Local 713 (“Local 713”), our firm is submitting these comments for the City of San Leandro’s (“City”) Draft Environmental Impact Report (“DEIR”) for the 880 Doolittle Drive Project (“Project”).

The Project’s Notice of Availability (“NOA”) for the DEIR contains the following Project Description:

The proposed project consists of consolidating the two parcels comprising the project site into a single parcel, demolishing existing vacant structures, and developing a new industrial shell building on the site. The proposed project also includes a new surface parking lot, internal circulation roadways, landscaping, and new utility connections, including natural gas. The proposed warehouse would be approximately 244,573 square feet, comprised of a 229,573 square-foot of warehouse and 15,000 square feet of associated office space. Approximately 10,000 square feet of office space would be provided on the ground floor, and approximately 5,000 square feet of office space would be on a mezzanine level. The maximum building height would be 50 feet with an interior clear height of 40 feet. Sixty-four loading docks are proposed. Traditional doors for egress and ingress to the building would also be provided. 216
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San Leandro City Council
May 5, 2025