Agenda packet — Seal Beach City Council, December 8, 2025 (part 3 of 5)

Receptor Annual Green Glare Annual Yellow Glare
min hr min hr
OP 13 0 0.0 0 0.0
OP 14 0 0.0 0 0.0
OP 15 0 0.0 0 0.0
OP 16 0 0.0 0 0.0
OP 17 0 0.0 0 0.0
OP 18 0 0.0 0 0.0
OP 19 0 0.0 0 0.0
OP 20 1,185 19.8 0 0.0
OP 21 0 0.0 0 0.0
OP 22 0 0.0 0 0.0
OP 23 0 0.0 0 0.0
OP 24 0 0.0 0 0.0
OP 25 0 0.0 0 0.0
OP 26 0 0.0 0 0.0
OP 27 0 0.0 0 0.0
OP 28 0 0.0 0 0.0
OP 29 3,193 53.2 0 0.0
OP 30 0 0.0 0 0.0
OP 31 0 0.0 0 0.0
OP 32 0 0.0 0 0.0
OP 33 0 0.0 0 0.0
OP 34 0 0.0 0 0.0

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Component Data
PV Arrays
Name: Central Array
Axis tracking: Fixed (no rotation)
Tilt: 10.0°
Orientation: 180.0°
Rated power: -
Panel material: Smooth glass with AR coating
Reflectivity: Vary with sun
Slope error: correlate with material
Vertex Latitude (°) Longitude (°) Ground elevation (ft) Height above ground (ft) Total elevation (ft) 1 33.754039 -118.093793 4.00 1.00 5.00
2 33.753731 -118.093800 4.00 1.00 5.00
3 33.753726 -118.093545 4.00 1.00 5.00
4 33.753631 -118.093547 4.00 1.00 5.00
5 33.753627 -118.093275 4.00 1.00 5.00
6 33.753484 -118.093276 4.00 1.00 5.00
7 33.753483 -118.092995 4.00 1.00 5.00
8 33.753799 -118.092995 4.00 1.00 5.00
9 33.753800 -118.093269 4.00 1.00 5.00
10 33.753903 -118.093269 4.00 1.00 5.00
11 33.753908 -118.093539 4.00 1.00 5.00
12 33.754034 -118.093536 4.00 1.00 5.00
Name: Eastern Array 1
Axis tracking: Fixed (no rotation)
Tilt: 10.0°
Orientation: 180.0°
Rated power: -
Panel material: Smooth glass with AR coating
Reflectivity: Vary with sun
Slope error: correlate with material
Vertex Latitude (°) Longitude (°) Ground elevation (ft) Height above ground (ft) Total elevation (ft) 1 33.753167 -118.092573 3.00 1.00 4.00
2 33.753160 -118.092011 3.00 1.00 4.00
3 33.752949 -118.092015 3.00 1.00 4.00
4 33.752955 -118.092298 3.00 1.00 4.00
5 33.753005 -118.092296 3.00 1.00 4.00
6 33.753011 -118.092573 3.00 1.00 4.00

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Name: Eastern Array 2
Axis tracking: Fixed (no rotation)
Tilt: 10.0°
Orientation: 180.0°
Rated power: -
Panel material: Smooth glass with AR coating
Reflectivity: Vary with sun
Slope error: correlate with material
Vertex Latitude (°) Longitude (°) Ground elevation (ft) Height above ground (ft) Total elevation (ft) 1 33.752889 -118.092570 3.00 1.00 4.00
2 33.752886 -118.092302 3.00 1.00 4.00
3 33.752840 -118.092304 3.00 1.00 4.00
4 33.752840 -118.092023 3.00 1.00 4.00
5 33.752733 -118.092022 3.00 1.00 4.00
6 33.752736 -118.092302 3.00 1.00 4.00
7 33.752440 -118.092300 3.00 1.00 4.00
8 33.752436 -118.092569 3.00 1.00 4.00
Name: Western Array
Axis tracking: Fixed (no rotation)
Tilt: 10.0°
Orientation: 180.0°
Rated power: -
Panel material: Smooth glass with AR coating
Reflectivity: Vary with sun
Slope error: correlate with material
Vertex Latitude (°) Longitude (°) Ground elevation (ft) Height above ground (ft) Total elevation (ft) 1 33.754786 -118.094476 4.00 1.00 5.00
2 33.754214 -118.094492 4.00 1.00 5.00
3 33.754200 -118.094136 4.00 1.00 5.00
4 33.754055 -118.094141 4.00 1.00 5.00
5 33.754070 -118.094498 4.00 1.00 5.00
6 33.754171 -118.094494 4.00 1.00 5.00
7 33.754176 -118.094632 4.00 1.00 5.00
8 33.754220 -118.094630 4.00 1.00 5.00
9 33.754223 -118.094854 4.00 1.00 5.00
10 33.754388 -118.094847 4.00 1.00 5.00
11 33.754401 -118.095211 4.00 1.00 5.00
12 33.754987 -118.095183 4.00 1.00 5.00
13 33.754972 -118.094822 4.00 1.00 5.00
14 33.754800 -118.094827 4.00 1.00 5.00

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Discrete Observation Point Receptors
Name ID Latitude (°) Longitude (°) Elevation (ft) Height (ft) OP 1 1 33.752786 -118.090415 19.90 6.00
OP 2 2 33.752664 -118.090452 20.90 6.00
OP 3 3 33.752483 -118.090526 20.10 6.00
OP 4 4 33.752349 -118.090572 20.70 6.00
OP 5 5 33.752221 -118.090671 20.10 6.00
OP 6 6 33.752001 -118.090726 21.40 6.00
OP 7 7 33.751856 -118.090778 20.70 6.00
OP 8 8 33.751711 -118.090802 19.40 6.00
OP 9 9 33.751555 -118.090855 18.80 6.00
OP 10 10 33.751427 -118.090952 18.60 6.00
OP 11 11 33.751281 -118.091064 19.50 6.00
OP 12 12 33.751154 -118.091143 19.30 6.00
OP 13 13 33.750790 -118.091390 18.40 6.00
OP 14 14 33.750686 -118.091528 16.70 6.00
OP 15 15 33.750462 -118.091751 16.70 6.00
OP 16 16 33.750276 -118.091899 17.90 6.00
OP 17 17 33.750079 -118.091991 22.50 6.00
OP 18 18 33.750014 -118.092097 21.80 6.00
OP 19 19 33.755464 -118.097277 4.70 6.00
OP 20 20 33.754507 -118.097738 4.70 6.00
OP 21 21 33.758793 -118.099999 6.00 6.00
OP 22 22 33.757536 -118.101222 5.70 0.00
OP 23 23 33.756046 -118.103196 5.40 0.00
OP 24 24 33.755903 -118.098798 3.90 0.00
OP 25 25 33.754806 -118.100407 7.60 0.00
OP 26 26 33.752598 -118.091390 3.94 6.00
OP 27 27 33.751705 -118.091411 9.67 6.00
OP 28 28 33.752156 -118.092389 10.19 6.00
OP 29 29 33.752155 -118.095105 5.89 6.00
OP 30 30 33.751359 -118.093174 10.15 0.00
OP 31 31 33.750146 -118.094132 6.70 6.00
OP 32 32 33.749344 -118.093136 44.72 6.00
OP 33 33 33.749395 -118.095200 43.91 6.00
OP 34 34 33.749395 -118.097384 32.25 6.00

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Obstruction Components
Name: Bushes and Trees Along Fence Line
Top height: 7.0 ft
Vertex Latitude (°) Longitude (°) Ground elevation (ft) 1 33.752566 -118.091458 3.15
2 33.752753 -118.091404 3.96
3 33.752958 -118.091458 3.92
Name: Tree Line
Top height: 20.0 ft
Vertex Latitude (°) Longitude (°) Ground elevation (ft) 1 33.752920 -118.090578 7.16
2 33.752090 -118.090894 11.62
3 33.751769 -118.090927 13.51
4 33.751140 -118.091350 14.68

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Glare Analysis Results
Summary of Results Glare with low potential for temporary after-image predicted PV Array Tilt Orient Annual Green Glare Annual Yellow Glare Energy ° ° min hr min hr kWh
Central Array 10.0 180.0 0 0.0 0 0.0 -
Eastern Array 1 10.0 180.0 1,597 26.6 0 0.0 -
Eastern Array 2 10.0 180.0 1,596 26.6 0 0.0 -
Western Array 10.0 180.0 1,185 19.8 0 0.0 -
Total glare received by each receptor; may include duplicate times of glare from multiple reflective surfaces.

Receptor Annual Green Glare Annual Yellow Glare
min hr min hr
OP 1 0 0.0 0 0.0
OP 2 0 0.0 0 0.0
OP 3 0 0.0 0 0.0
OP 4 0 0.0 0 0.0
OP 5 0 0.0 0 0.0
OP 6 0 0.0 0 0.0
OP 7 0 0.0 0 0.0
OP 8 0 0.0 0 0.0
OP 9 0 0.0 0 0.0
OP 10 0 0.0 0 0.0
OP 11 0 0.0 0 0.0
OP 12 0 0.0 0 0.0
OP 13 0 0.0 0 0.0
OP 14 0 0.0 0 0.0
OP 15 0 0.0 0 0.0
OP 16 0 0.0 0 0.0
OP 17 0 0.0 0 0.0
OP 18 0 0.0 0 0.0
OP 19 0 0.0 0 0.0
OP 20 1,185 19.8 0 0.0
OP 21 0 0.0 0 0.0
OP 22 0 0.0 0 0.0
OP 23 0 0.0 0 0.0
OP 24 0 0.0 0 0.0
OP 25 0 0.0 0 0.0
OP 26 0 0.0 0 0.0
OP 27 0 0.0 0 0.0
OP 28 0 0.0 0 0.0
OP 29 3,193 53.2 0 0.0

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Receptor Annual Green Glare Annual Yellow Glare
min hr min hr
OP 30 0 0.0 0 0.0
OP 31 0 0.0 0 0.0
OP 32 0 0.0 0 0.0
OP 33 0 0.0 0 0.0
OP 34 0 0.0 0 0.0

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PV: Central Array no glare found
Receptor results ordered by category of glare
Receptor Annual Green Glare Annual Yellow Glare
min hr min hr
OP 1 0 0.0 0 0.0
OP 2 0 0.0 0 0.0
OP 3 0 0.0 0 0.0
OP 4 0 0.0 0 0.0
OP 5 0 0.0 0 0.0
OP 6 0 0.0 0 0.0
OP 7 0 0.0 0 0.0
OP 8 0 0.0 0 0.0
OP 9 0 0.0 0 0.0
OP 10 0 0.0 0 0.0
OP 11 0 0.0 0 0.0
OP 12 0 0.0 0 0.0
OP 13 0 0.0 0 0.0
OP 14 0 0.0 0 0.0
OP 15 0 0.0 0 0.0
OP 16 0 0.0 0 0.0
OP 17 0 0.0 0 0.0
OP 18 0 0.0 0 0.0
OP 19 0 0.0 0 0.0
OP 20 0 0.0 0 0.0
OP 21 0 0.0 0 0.0
OP 22 0 0.0 0 0.0
OP 23 0 0.0 0 0.0
OP 24 0 0.0 0 0.0
OP 25 0 0.0 0 0.0
OP 26 0 0.0 0 0.0
OP 27 0 0.0 0 0.0
OP 28 0 0.0 0 0.0
OP 29 0 0.0 0 0.0
OP 30 0 0.0 0 0.0
OP 31 0 0.0 0 0.0
OP 32 0 0.0 0 0.0
OP 33 0 0.0 0 0.0
OP 34 0 0.0 0 0.0

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Central Array and OP 1
No glare found
Central Array and OP 2
No glare found
Central Array and OP 3
No glare found
Central Array and OP 4
No glare found
Central Array and OP 5
No glare found
Central Array and OP 6
No glare found
Central Array and OP 7
No glare found
Central Array and OP 8
No glare found
Central Array and OP 9
No glare found
Central Array and OP 10
No glare found
Central Array and OP 11
No glare found
Central Array and OP 12
No glare found
Central Array and OP 13
No glare found
Central Array and OP 14
No glare found

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Central Array and OP 15
No glare found
Central Array and OP 16
No glare found
Central Array and OP 17
No glare found
Central Array and OP 18
No glare found
Central Array and OP 19
No glare found
Central Array and OP 20
No glare found
Central Array and OP 21
No glare found
Central Array and OP 22
No glare found
Central Array and OP 23
No glare found
Central Array and OP 24
No glare found
Central Array and OP 25
No glare found
Central Array and OP 26
No glare found
Central Array and OP 27
No glare found
Central Array and OP 28
No glare found

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Central Array and OP 29
No glare found
Central Array and OP 30
No glare found
Central Array and OP 31
No glare found
Central Array and OP 32
No glare found
Central Array and OP 33
No glare found
Central Array and OP 34
No glare found

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PV: Eastern Array 1 low potential for temporary after-image Receptor results ordered by category of glare
Receptor Annual Green Glare Annual Yellow Glare
min hr min hr
OP 29 1,597 26.6 0 0.0
OP 1 0 0.0 0 0.0
OP 2 0 0.0 0 0.0
OP 3 0 0.0 0 0.0
OP 4 0 0.0 0 0.0
OP 5 0 0.0 0 0.0
OP 6 0 0.0 0 0.0
OP 7 0 0.0 0 0.0
OP 8 0 0.0 0 0.0
OP 9 0 0.0 0 0.0
OP 10 0 0.0 0 0.0
OP 11 0 0.0 0 0.0
OP 12 0 0.0 0 0.0
OP 13 0 0.0 0 0.0
OP 14 0 0.0 0 0.0
OP 15 0 0.0 0 0.0
OP 16 0 0.0 0 0.0
OP 17 0 0.0 0 0.0
OP 18 0 0.0 0 0.0
OP 19 0 0.0 0 0.0
OP 20 0 0.0 0 0.0
OP 21 0 0.0 0 0.0
OP 22 0 0.0 0 0.0
OP 23 0 0.0 0 0.0
OP 24 0 0.0 0 0.0
OP 25 0 0.0 0 0.0
OP 26 0 0.0 0 0.0
OP 27 0 0.0 0 0.0
OP 28 0 0.0 0 0.0
OP 30 0 0.0 0 0.0
OP 31 0 0.0 0 0.0
OP 32 0 0.0 0 0.0
OP 33 0 0.0 0 0.0
OP 34 0 0.0 0 0.0

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Eastern Array 1 and OP 29
Yellow glare: none
Green glare: 1,597 min.

Eastern Array 1 and OP 1
No glare found
Eastern Array 1 and OP 2
No glare found
Eastern Array 1 and OP 3
No glare found
Eastern Array 1 and OP 4
No glare found
Eastern Array 1 and OP 5
No glare found

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Eastern Array 1 and OP 6
No glare found
Eastern Array 1 and OP 7
No glare found
Eastern Array 1 and OP 8
No glare found
Eastern Array 1 and OP 9
No glare found
Eastern Array 1 and OP 10
No glare found
Eastern Array 1 and OP 11
No glare found
Eastern Array 1 and OP 12
No glare found
Eastern Array 1 and OP 13
No glare found
Eastern Array 1 and OP 14
No glare found
Eastern Array 1 and OP 15
No glare found
Eastern Array 1 and OP 16
No glare found
Eastern Array 1 and OP 17
No glare found
Eastern Array 1 and OP 18
No glare found
Eastern Array 1 and OP 19
No glare found

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Eastern Array 1 and OP 20
No glare found
Eastern Array 1 and OP 21
No glare found
Eastern Array 1 and OP 22
No glare found
Eastern Array 1 and OP 23
No glare found
Eastern Array 1 and OP 24
No glare found
Eastern Array 1 and OP 25
No glare found
Eastern Array 1 and OP 26
No glare found
Eastern Array 1 and OP 27
No glare found
Eastern Array 1 and OP 28
No glare found
Eastern Array 1 and OP 30
No glare found
Eastern Array 1 and OP 31
No glare found
Eastern Array 1 and OP 32
No glare found
Eastern Array 1 and OP 33
No glare found
Eastern Array 1 and OP 34
No glare found

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PV: Eastern Array 2 low potential for temporary after-image Receptor results ordered by category of glare
Receptor Annual Green Glare Annual Yellow Glare
min hr min hr
OP 29 1,596 26.6 0 0.0
OP 1 0 0.0 0 0.0
OP 2 0 0.0 0 0.0
OP 3 0 0.0 0 0.0
OP 4 0 0.0 0 0.0
OP 5 0 0.0 0 0.0
OP 6 0 0.0 0 0.0
OP 7 0 0.0 0 0.0
OP 8 0 0.0 0 0.0
OP 9 0 0.0 0 0.0
OP 10 0 0.0 0 0.0
OP 11 0 0.0 0 0.0
OP 12 0 0.0 0 0.0
OP 13 0 0.0 0 0.0
OP 14 0 0.0 0 0.0
OP 15 0 0.0 0 0.0
OP 16 0 0.0 0 0.0
OP 17 0 0.0 0 0.0
OP 18 0 0.0 0 0.0
OP 19 0 0.0 0 0.0
OP 20 0 0.0 0 0.0
OP 21 0 0.0 0 0.0
OP 22 0 0.0 0 0.0
OP 23 0 0.0 0 0.0
OP 24 0 0.0 0 0.0
OP 25 0 0.0 0 0.0
OP 26 0 0.0 0 0.0
OP 27 0 0.0 0 0.0
OP 28 0 0.0 0 0.0
OP 30 0 0.0 0 0.0
OP 31 0 0.0 0 0.0
OP 32 0 0.0 0 0.0
OP 33 0 0.0 0 0.0
OP 34 0 0.0 0 0.0

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Eastern Array 2 and OP 29
Yellow glare: none
Green glare: 1,596 min.

Eastern Array 2 and OP 1
No glare found
Eastern Array 2 and OP 2
No glare found
Eastern Array 2 and OP 3
No glare found
Eastern Array 2 and OP 4
No glare found
Eastern Array 2 and OP 5
No glare found

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Eastern Array 2 and OP 6
No glare found
Eastern Array 2 and OP 7
No glare found
Eastern Array 2 and OP 8
No glare found
Eastern Array 2 and OP 9
No glare found
Eastern Array 2 and OP 10
No glare found
Eastern Array 2 and OP 11
No glare found
Eastern Array 2 and OP 12
No glare found
Eastern Array 2 and OP 13
No glare found
Eastern Array 2 and OP 14
No glare found
Eastern Array 2 and OP 15
No glare found
Eastern Array 2 and OP 16
No glare found
Eastern Array 2 and OP 17
No glare found
Eastern Array 2 and OP 18
No glare found
Eastern Array 2 and OP 19
No glare found

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Eastern Array 2 and OP 20
No glare found
Eastern Array 2 and OP 21
No glare found
Eastern Array 2 and OP 22
No glare found
Eastern Array 2 and OP 23
No glare found
Eastern Array 2 and OP 24
No glare found
Eastern Array 2 and OP 25
No glare found
Eastern Array 2 and OP 26
No glare found
Eastern Array 2 and OP 27
No glare found
Eastern Array 2 and OP 28
No glare found
Eastern Array 2 and OP 30
No glare found
Eastern Array 2 and OP 31
No glare found
Eastern Array 2 and OP 32
No glare found
Eastern Array 2 and OP 33
No glare found
Eastern Array 2 and OP 34
No glare found

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PV: Western Array low potential for temporary after-image Receptor results ordered by category of glare
Receptor Annual Green Glare Annual Yellow Glare
min hr min hr
OP 20 1,185 19.8 0 0.0
OP 1 0 0.0 0 0.0
OP 2 0 0.0 0 0.0
OP 3 0 0.0 0 0.0
OP 4 0 0.0 0 0.0
OP 5 0 0.0 0 0.0
OP 6 0 0.0 0 0.0
OP 7 0 0.0 0 0.0
OP 8 0 0.0 0 0.0
OP 9 0 0.0 0 0.0
OP 10 0 0.0 0 0.0
OP 11 0 0.0 0 0.0
OP 12 0 0.0 0 0.0
OP 13 0 0.0 0 0.0
OP 14 0 0.0 0 0.0
OP 15 0 0.0 0 0.0
OP 16 0 0.0 0 0.0
OP 17 0 0.0 0 0.0
OP 18 0 0.0 0 0.0
OP 19 0 0.0 0 0.0
OP 21 0 0.0 0 0.0
OP 22 0 0.0 0 0.0
OP 23 0 0.0 0 0.0
OP 24 0 0.0 0 0.0
OP 25 0 0.0 0 0.0
OP 26 0 0.0 0 0.0
OP 27 0 0.0 0 0.0
OP 28 0 0.0 0 0.0
OP 29 0 0.0 0 0.0
OP 30 0 0.0 0 0.0
OP 31 0 0.0 0 0.0
OP 32 0 0.0 0 0.0
OP 33 0 0.0 0 0.0
OP 34 0 0.0 0 0.0

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Western Array and OP 20
Yellow glare: none
Green glare: 1,185 min.

Western Array and OP 1
No glare found
Western Array and OP 2
No glare found
Western Array and OP 3
No glare found
Western Array and OP 4
No glare found
Western Array and OP 5
No glare found

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Western Array and OP 6
No glare found
Western Array and OP 7
No glare found
Western Array and OP 8
No glare found
Western Array and OP 9
No glare found
Western Array and OP 10
No glare found
Western Array and OP 11
No glare found
Western Array and OP 12
No glare found
Western Array and OP 13
No glare found
Western Array and OP 14
No glare found
Western Array and OP 15
No glare found
Western Array and OP 16
No glare found
Western Array and OP 17
No glare found
Western Array and OP 18
No glare found
Western Array and OP 19
No glare found

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Western Array and OP 21
No glare found
Western Array and OP 22
No glare found
Western Array and OP 23
No glare found
Western Array and OP 24
No glare found
Western Array and OP 25
No glare found
Western Array and OP 26
No glare found
Western Array and OP 27
No glare found
Western Array and OP 28
No glare found
Western Array and OP 29
No glare found
Western Array and OP 30
No glare found
Western Array and OP 31
No glare found
Western Array and OP 32
No glare found
Western Array and OP 33
No glare found
Western Array and OP 34
No glare found

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Assumptions
Default glare analysis parameters and observer eye characteristics (for reference only):
• Analysis time interval: 1 minute
• Ocular transmission coefficient: 0.5
• Pupil diameter: 0.002 meters
• Eye focal length: 0.017 meters
• Sun subtended angle: 9.3 milliradians
© Sims Industries d/b/a ForgeSolar, All Rights Reserved. "Green" glare is glare with low potential to cause an after-image (flash blindness) when observed prior to a typical blink response time. "Yellow" glare is glare with potential to cause an after-image (flash blindness) when observed prior to a typical blink response time.

Times associated with glare are denoted in Standard time. For Daylight Savings, add one hour.

The algorithm does not rigorously represent the detailed geometry of a system; detailed features such as gaps between modules, variable height of the PV array, and support structures may impact actual glare results. However, we have validated our models against several systems, including a PV array causing glare to the air-traffic control tower at Manchester-Boston Regional Airport and several sites in Albuquerque, and the tool accurately predicted the occurrence and intensity of glare at different times and days of the year.

Several V1 calculations utilize the PV array centroid, rather than the actual glare spot location, due to algorithm limitations. This may affect results for large PV footprints. Additional analyses of array sub-sections can provide additional information on expected glare. This primarily affects V1 analyses of path receptors.

Random number computations are utilized by various steps of the annual hazard analysis algorithm. Predicted minutes of glare can vary between runs as a result. This limitation primarily affects analyses of Observation Point receptors, including ATCTs. Note that the SGHAT/ ForgeSolar methodology has always relied on an analytical, qualitative approach to accurately determine the overall hazard (i.e. green vs. yellow) of expected glare on an annual basis.

The analysis does not automatically consider obstacles (either man-made or natural) between the observation points and the prescribed solar installation that may obstruct observed glare, such as trees, hills, buildings, etc.

The subtended source angle (glare spot size) is constrained by the PV array footprint size. Partitioning large arrays into smaller sections will reduce the maximum potential subtended angle, potentially impacting results if actual glare spots are larger than the sub-array size. Additional analyses of the combined area of adjacent sub-arrays can provide more information on potential glare hazards. (See previous point on related limitations.)
The variable direct normal irradiance (DNI) feature (if selected) scales the user-prescribed peak DNI using a typical clear-day irradiance profile.

This profile has a lower DNI in the mornings and evenings and a maximum at solar noon. The scaling uses a clear-day irradiance profile based on a normalized time relative to sunrise, solar noon, and sunset, which are prescribed by a sun-position algorithm and the latitude and longitude obtained from Google maps. The actual DNI on any given day can be affected by cloud cover, atmospheric attenuation, and other environmental factors.

The ocular hazard predicted by the tool depends on a number of environmental, optical, and human factors, which can be uncertain. We provide input fields and typical ranges of values for these factors so that the user can vary these parameters to see if they have an impact on the results. The speed of SGHAT allows expedited sensitivity and parametric analyses.

The system output calculation is a DNI-based approximation that assumes clear, sunny skies year-round. It should not be used in place of more rigorous modeling methods.

Hazard zone boundaries shown in the Glare Hazard plot are an approximation and visual aid based on aggregated research data. Actual ocular impact outcomes encompass a continuous, not discrete, spectrum.

Glare locations displayed on receptor plots are approximate. Actual glare-spot locations may differ.

Refer to the Help page at www.forgesolar.com/help/ for assumptions and limitations not listed here.

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Appendix E
CalEEMod Air Emission Output Files
Hellman Solar PV Project Detailed Report, 7/13/2025
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Hellman Solar PV Project Detailed Report
Table of Contents

1. Basic Project Information

1.1. Basic Project Information

1.2. Land Use Types

1.3. User-Selected Emission Reduction Measures by Emissions Sector

2. Emissions Summary

2.1. Construction Emissions Compared Against Thresholds

2.2. Construction Emissions by Year, Unmitigated

2.3. Construction Emissions by Year, Mitigated

2.4. Operations Emissions Compared Against Thresholds

2.5. Operations Emissions by Sector, Unmitigated

2.6. Operations Emissions by Sector, Mitigated

3. Construction Emissions Details

3.1. Site Preparation (2026) - Unmitigated

3.2. Site Preparation (2026) - Mitigated

3.3. Support Pile Installation (2026) - Unmitigated
Hellman Solar PV Project Detailed Report, 7/13/2025
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3.4. Support Pile Installation (2026) - Mitigated

3.5. Solar PV System, Equipment, and Conduit Installation (2026) - Unmitigated

3.6. Solar PV System, Equipment, and Conduit Installation (2026) - Mitigated

3.7. Testing and Commissioning (2026) - Unmitigated

3.8. Testing and Commissioning (2026) - Mitigated

4. Operations Emissions Details

4.1. Mobile Emissions by Land Use

4.1.1. Unmitigated

4.1.2. Mitigated

4.2. Energy

4.2.1. Electricity Emissions By Land Use - Unmitigated

4.2.2. Electricity Emissions By Land Use - Mitigated

4.2.3. Natural Gas Emissions By Land Use - Unmitigated

4.2.4. Natural Gas Emissions By Land Use - Mitigated

4.3. Area Emissions by Source

4.3.1. Unmitigated

4.3.2. Mitigated

4.4. Water Emissions by Land Use
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4.4.1. Unmitigated

4.4.2. Mitigated

4.5. Waste Emissions by Land Use

4.5.1. Unmitigated

4.5.2. Mitigated

4.6. Refrigerant Emissions by Land Use

4.6.1. Unmitigated

4.6.2. Mitigated

4.7. Offroad Emissions By Equipment Type

4.7.1. Unmitigated

4.7.2. Mitigated

4.8. Stationary Emissions By Equipment Type

4.8.1. Unmitigated

4.8.2. Mitigated

4.9. User Defined Emissions By Equipment Type

4.9.1. Unmitigated

4.9.2. Mitigated

4.10. Soil Carbon Accumulation By Vegetation Type
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4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated

4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated

4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated

4.10.4. Soil Carbon Accumulation By Vegetation Type - Mitigated

4.10.5. Above and Belowground Carbon Accumulation by Land Use Type - Mitigated

4.10.6. Avoided and Sequestered Emissions by Species - Mitigated

5. Activity Data

5.1. Construction Schedule

5.2. Off-Road Equipment

5.2.1. Unmitigated

5.2.2. Mitigated

5.3. Construction Vehicles

5.3.1. Unmitigated

5.3.2. Mitigated

5.4. Vehicles

5.4.1. Construction Vehicle Control Strategies

5.5. Architectural Coatings

5.6. Dust Mitigation
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5.6.1. Construction Earthmoving Activities

5.6.2. Construction Earthmoving Control Strategies

5.7. Construction Paving

5.8. Construction Electricity Consumption and Emissions Factors

5.9. Operational Mobile Sources

5.9.1. Unmitigated

5.9.2. Mitigated

5.10. Operational Area Sources

5.10.1. Hearths

5.10.1.1. Unmitigated

5.10.1.2. Mitigated

5.10.2. Architectural Coatings

5.10.3. Landscape Equipment

5.10.4. Landscape Equipment - Mitigated

5.11. Operational Energy Consumption

5.11.1. Unmitigated

5.11.2. Mitigated

5.12. Operational Water and Wastewater Consumption
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5.12.1. Unmitigated

5.12.2. Mitigated

5.13. Operational Waste Generation

5.13.1. Unmitigated

5.13.2. Mitigated

5.14. Operational Refrigeration and Air Conditioning Equipment

5.14.1. Unmitigated

5.14.2. Mitigated

5.15. Operational Off-Road Equipment

5.15.1. Unmitigated

5.15.2. Mitigated

5.16. Stationary Sources

5.16.1. Emergency Generators and Fire Pumps

5.16.2. Process Boilers

5.17. User Defined

5.18. Vegetation

5.18.1. Land Use Change

5.18.1.1. Unmitigated
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5.18.1.2. Mitigated

5.18.1. Biomass Cover Type

5.18.1.1. Unmitigated

5.18.1.2. Mitigated

5.18.2. Sequestration

5.18.2.1. Unmitigated

5.18.2.2. Mitigated

6. Climate Risk Detailed Report

6.1. Climate Risk Summary

6.2. Initial Climate Risk Scores

6.3. Adjusted Climate Risk Scores

6.4. Climate Risk Reduction Measures

7. Health and Equity Details

7.1. CalEnviroScreen 4.0 Scores

7.2. Healthy Places Index Scores

7.3. Overall Health & Equity Scores

7.4. Health & Equity Measures

7.5. Evaluation Scorecard
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7.6. Health & Equity Custom Measures

8. User Changes to Default Data
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1. Basic Project Information

1.1. Basic Project Information
Data Field Value
Project Name Hellman Solar PV Project
Construction Start Date 9/16/2026
Operational Year 2026
Lead Agency City of Seal Beach
Land Use Scale Project/site
Analysis Level for Defaults County
Windspeed (m/s) 2.30
Precipitation (days) 18.4
Location 33.755335875286136, -118.09590644683723
County Orange
City Seal Beach
Air District South Coast AQMD
Air Basin South Coast
TAZ 5856
EDFZ 7
Electric Utility Southern California Edison
Gas Utility Southern California Gas
App Version 2022.1.1.29

1.2. Land Use Types
Land Use Subtype Size Unit Lot Acreage Building Area (sq ft) Landscape Area (sq ft)
Special Landscape
Area (sq ft)
Population Description
User Defined
Industrial

0.00 User Defined Unit 5.00 0.00 0.00 0.00 — —
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1.3. User-Selected Emission Reduction Measures by Emissions Sector Sector # Measure Title
Construction C-2* Limit Heavy-Duty Diesel Vehicle Idling Construction C-10-A Water Exposed Surfaces
Construction C-10-C Water Unpaved Construction Roads
Construction C-11 Limit Vehicle Speeds on Unpaved Roads * Qualitative or supporting measure. Emission reductions not included in the mitigated emissions results.

2. Emissions Summary

2.1. Construction Emissions Compared Against Thresholds Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Un/Mit. TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Unmit. 1.23 1.02 7.49 8.98 0.02 0.40 8.80 9.20 0.37 3.63 4.00 2,314 2,314 0.10 0.12 2.24 2,337 Mit. 1.23 1.02 7.49 8.98 0.02 0.40 3.38 3.77 0.37 1.43 1.80 2,314 2,314 0.10 0.12 2.24 2,337 %
Reduced
— — — — — — 62% 59% — 61% 55% — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Unmit. 1.35 1.05 9.18 12.1 0.03 0.29 6.76 7.04 0.26 0.81 1.07 3,756 3,756 0.18 0.25 0.12 3,834 Mit. 1.35 1.05 9.18 12.1 0.03 0.29 2.35 2.64 0.26 0.37 0.63 3,756 3,756 0.18 0.25 0.12 3,834 %
Reduced
— — — — — — 65% 63% — 54% 41% — — — — — —
Average
Daily
(Max)
— — — — — — — — — — — — — — — — —
Unmit. 0.09 0.07 0.59 0.78 < 0.005 0.02 0.44 0.46 0.02 0.08 0.09 249 249 0.01 0.02 0.14 254 Hellman Solar PV Project Detailed Report, 7/13/2025
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Mit. 0.09 0.07 0.59 0.78 < 0.005 0.02 0.16 0.18 0.02 0.03 0.05 249 249 0.01 0.02 0.14 254 %
Reduced
— — — — — — 63% 60% — 55% 44% — — — — — —
Annual
(Max)
— — — — — — — — — — — — — — — — —
Unmit. 0.02 0.01 0.11 0.14 < 0.005 < 0.005 0.08 0.08 < 0.005 0.01 0.02 41.2 41.2 < 0.005 < 0.005 0.02 42.1 Mit. 0.02 0.01 0.11 0.14 < 0.005 < 0.005 0.03 0.03 < 0.005 0.01 0.01 41.2 41.2 < 0.005 < 0.005 0.02 42.1 %
Reduced
— — — — — — 63% 60% — 55% 44% — — — — — —

2.2. Construction Emissions by Year, Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Year TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T NBCO2 CO2T CH4 N2O R CO2e Daily -
Summer
(Max)
— — — — — — — — — — — — — — — — —
2026 1.23 1.02 7.49 8.98 0.02 0.40 8.80 9.20 0.37 3.63 4.00 2,314 2,314 0.10 0.12 2.24 2,337 Daily -
Winter
(Max)
— — — — — — — — — — — — — — — — —
2026 1.35 1.05 9.18 12.1 0.03 0.29 6.76 7.04 0.26 0.81 1.07 3,756 3,756 0.18 0.25 0.12 3,834 Average
Daily
— — — — — — — — — — — — — — — — —
2026 0.09 0.07 0.59 0.78 < 0.005 0.02 0.44 0.46 0.02 0.08 0.09 249 249 0.01 0.02 0.14 254 Annual — — — — — — — — — — — — — — — — —
2026 0.02 0.01 0.11 0.14 < 0.005 < 0.005 0.08 0.08 < 0.005 0.01 0.02 41.2 41.2 < 0.005 < 0.005 0.02 42.1

2.3. Construction Emissions by Year, Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Year TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T NBCO2 CO2T CH4 N2O R CO2e Hellman Solar PV Project Detailed Report, 7/13/2025
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Daily - — — — — — — — — — — — — — — — — —
Summer
(Max)
2026 1.23 1.02 7.49 8.98 0.02 0.40 3.38 3.77 0.37 1.43 1.80 2,314 2,314 0.10 0.12 2.24 2,337 Daily -
Winter
(Max)
— — — — — — — — — — — — — — — — —
2026 1.35 1.05 9.18 12.1 0.03 0.29 2.35 2.64 0.26 0.37 0.63 3,756 3,756 0.18 0.25 0.12 3,834 Average
Daily
— — — — — — — — — — — — — — — — —
2026 0.09 0.07 0.59 0.78 < 0.005 0.02 0.16 0.18 0.02 0.03 0.05 249 249 0.01 0.02 0.14 254 Annual — — — — — — — — — — — — — — — — —
2026 0.02 0.01 0.11 0.14 < 0.005 < 0.005 0.03 0.03 < 0.005 0.01 0.01 41.2 41.2 < 0.005 < 0.005 0.02 42.1

2.4. Operations Emissions Compared Against Thresholds
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Un/Mit. TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Unmit. 0.12 0.11 0.04 2.50 < 0.005 < 0.005 0.04 0.04 < 0.005 0.01 0.01 51.2 51.2 < 0.005 < 0.005 0.16 51.8 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Unmit. 0.12 0.11 0.04 2.48 < 0.005 < 0.005 0.04 0.04 < 0.005 0.01 0.01 49.4 49.4 < 0.005 < 0.005 < 0.005 49.9 Average
Daily
(Max)
— — — — — — — — — — — — — — — — —
Unmit. < 0.005 < 0.005 < 0.005 0.02 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 1.00 1.00 < 0.005 < 0.005 < 0.005 1.01 Annual
(Max)
— — — — — — — — — — — — — — — — —
Unmit. < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.16 0.16 < 0.005 < 0.005 < 0.005 0.17 Hellman Solar PV Project Detailed Report, 7/13/2025
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2.5. Operations Emissions by Sector, Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Sector TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Mobile 0.01 0.01 0.01 0.14 < 0.005 < 0.005 0.04 0.04 < 0.005 0.01 0.01 44.8 44.8 < 0.005 < 0.005 0.16 45.4 Area 0.11 0.10 0.03 2.36 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 6.37 6.37 < 0.005 < 0.005 — 6.40 Energy 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 Water — — — — — — — — — — — 0.01 0.01 < 0.005 < 0.005 — 0.01 Waste — — — — — — — — — — — 0.00 0.00 0.00 0.00 — 0.00
Total 0.12 0.11 0.04 2.50 < 0.005 < 0.005 0.04 0.04 < 0.005 0.01 0.01 51.2 51.2 < 0.005 < 0.005 0.16 51.8 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Mobile 0.01 0.01 0.01 0.13 < 0.005 < 0.005 0.04 0.04 < 0.005 0.01 0.01 43.0 43.0 < 0.005 < 0.005 < 0.005 43.5 Area 0.11 0.10 0.03 2.36 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 6.37 6.37 < 0.005 < 0.005 — 6.40 Energy 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 Water — — — — — — — — — — — 0.01 0.01 < 0.005 < 0.005 — 0.01 Waste — — — — — — — — — — — 0.00 0.00 0.00 0.00 — 0.00
Total 0.12 0.11 0.04 2.48 < 0.005 < 0.005 0.04 0.04 < 0.005 0.01 0.01 49.4 49.4 < 0.005 < 0.005 < 0.005 49.9 Average
Daily
— — — — — — — — — — — — — — — — —
Mobile < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.95 0.95 < 0.005 < 0.005 < 0.005 0.97 Area < 0.005 < 0.005 < 0.005 0.01 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 0.03 0.03 < 0.005 < 0.005 — 0.04 Energy 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 Water — — — — — — — — — — — 0.01 0.01 < 0.005 < 0.005 — 0.01 Waste — — — — — — — — — — — 0.00 0.00 0.00 0.00 — 0.00
Total < 0.005 < 0.005 < 0.005 0.02 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 1.00 1.00 < 0.005 < 0.005 < 0.005 1.01 Annual — — — — — — — — — — — — — — — — —
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Mobile < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.16 0.16 < 0.005 < 0.005 < 0.005 0.16 Area < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 0.01 0.01 < 0.005 < 0.005 — 0.01 Energy 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 Water — — — — — — — — — — — < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 Waste — — — — — — — — — — — 0.00 0.00 0.00 0.00 — 0.00
Total < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.16 0.16 < 0.005 < 0.005 < 0.005 0.17

2.6. Operations Emissions by Sector, Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Sector TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Mobile 0.01 0.01 0.01 0.14 < 0.005 < 0.005 0.04 0.04 < 0.005 0.01 0.01 44.8 44.8 < 0.005 < 0.005 0.16 45.4 Area 0.11 0.10 0.03 2.36 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 6.37 6.37 < 0.005 < 0.005 — 6.40 Energy 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 Water — — — — — — — — — — — 0.01 0.01 < 0.005 < 0.005 — 0.01 Waste — — — — — — — — — — — 0.00 0.00 0.00 0.00 — 0.00
Total 0.12 0.11 0.04 2.50 < 0.005 < 0.005 0.04 0.04 < 0.005 0.01 0.01 51.2 51.2 < 0.005 < 0.005 0.16 51.8 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Mobile 0.01 0.01 0.01 0.13 < 0.005 < 0.005 0.04 0.04 < 0.005 0.01 0.01 43.0 43.0 < 0.005 < 0.005 < 0.005 43.5 Area 0.11 0.10 0.03 2.36 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 6.37 6.37 < 0.005 < 0.005 — 6.40 Energy 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 Water — — — — — — — — — — — 0.01 0.01 < 0.005 < 0.005 — 0.01 Waste — — — — — — — — — — — 0.00 0.00 0.00 0.00 — 0.00
Total 0.12 0.11 0.04 2.48 < 0.005 < 0.005 0.04 0.04 < 0.005 0.01 0.01 49.4 49.4 < 0.005 < 0.005 < 0.005 49.9 Average
Daily
— — — — — — — — — — — — — — — — —
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Mobile < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.95 0.95 < 0.005 < 0.005 < 0.005 0.97 Area < 0.005 < 0.005 < 0.005 0.01 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 0.03 0.03 < 0.005 < 0.005 — 0.04 Energy 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 Water — — — — — — — — — — — 0.01 0.01 < 0.005 < 0.005 — 0.01 Waste — — — — — — — — — — — 0.00 0.00 0.00 0.00 — 0.00
Total < 0.005 < 0.005 < 0.005 0.02 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 1.00 1.00 < 0.005 < 0.005 < 0.005 1.01 Annual — — — — — — — — — — — — — — — — —
Mobile < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.16 0.16 < 0.005 < 0.005 < 0.005 0.16 Area < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 0.01 0.01 < 0.005 < 0.005 — 0.01 Energy 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 Water — — — — — — — — — — — < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 Waste — — — — — — — — — — — 0.00 0.00 0.00 0.00 — 0.00
Total < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.16 0.16 < 0.005 < 0.005 < 0.005 0.17

3. Construction Emissions Details

3.1. Site Preparation (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Off-Road
Equipment

1.15 0.97 7.09 8.14 0.02 0.39 — 0.39 0.36 — 0.36 1,861 1,861 0.08 0.02 — 1,867 Dust
From
Material
Movement
— — — — — — 7.08 7.08 — 3.42 3.42 — — — — — —
Onsite
truck
< 0.005 < 0.005 0.03 0.02 < 0.005 < 0.005 1.47 1.47 < 0.005 0.15 0.15 9.88 9.88 < 0.005 < 0.005 0.01 10.4 Hellman Solar PV Project Detailed Report, 7/13/2025
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Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.01 0.01 0.06 0.07 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 15.3 15.3 < 0.005 < 0.005 — 15.3 Dust
From
Material
Movement
— — — — — — 0.06 0.06 — 0.03 0.03 — — — — — —
Onsite
truck
< 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 0.08 0.08 < 0.005 < 0.005 < 0.005 0.09 Annual — — — — — — — — — — — — — — — — —
Off-Road
Equipment
< 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 2.53 2.53 < 0.005 < 0.005 — 2.54 Dust
From
Material
Movement
— — — — — — 0.01 0.01 — 0.01 0.01 — — — — — —
Onsite
truck
< 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 0.01 Offsite — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Worker 0.04 0.04 0.04 0.68 0.00 0.00 0.17 0.17 0.00 0.04 0.04 169 169 < 0.005 0.01 0.59 171 Vendor 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 0.00 Hauling 0.03 < 0.005 0.33 0.14 < 0.005 < 0.005 0.07 0.08 < 0.005 0.02 0.02 274 274 0.02 0.04 0.55 288 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 1.34 1.34 < 0.005 < 0.005 < 0.005 1.36 Hellman Solar PV Project Detailed Report, 7/13/2025
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Vendor 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 0.00 Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 2.25 2.25 < 0.005 < 0.005 < 0.005 2.37 Annual — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.22 0.22 < 0.005 < 0.005 < 0.005 0.22 Vendor 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 0.00 Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.37 0.37 < 0.005 < 0.005 < 0.005 0.39

3.2. Site Preparation (2026) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Off-Road
Equipment

1.15 0.97 7.09 8.14 0.02 0.39 — 0.39 0.36 — 0.36 1,861 1,861 0.08 0.02 — 1,867 Dust
From
Material
Movement
— — — — — — 2.76 2.76 — 1.34 1.34 — — — — — —
Onsite
truck
< 0.005 < 0.005 0.03 0.02 < 0.005 < 0.005 0.37 0.37 < 0.005 0.04 0.04 9.88 9.88 < 0.005 < 0.005 0.01 10.4 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.01 0.01 0.06 0.07 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 15.3 15.3 < 0.005 < 0.005 — 15.3 Dust
From
Material
Movement
— — — — — — 0.02 0.02 — 0.01 0.01 — — — — — —
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Onsite
truck
< 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.08 0.08 < 0.005 < 0.005 < 0.005 0.09 Annual — — — — — — — — — — — — — — — — —
Off-Road
Equipment
< 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 2.53 2.53 < 0.005 < 0.005 — 2.54 Dust
From
Material
Movement
— — — — — — < 0.005 < 0.005 — < 0.005 < 0.005 — — — — — — Onsite
truck
< 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 0.01 Offsite — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Worker 0.04 0.04 0.04 0.68 0.00 0.00 0.17 0.17 0.00 0.04 0.04 169 169 < 0.005 0.01 0.59 171 Vendor 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 0.00 Hauling 0.03 < 0.005 0.33 0.14 < 0.005 < 0.005 0.07 0.08 < 0.005 0.02 0.02 274 274 0.02 0.04 0.55 288 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 1.34 1.34 < 0.005 < 0.005 < 0.005 1.36 Vendor 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 0.00 Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 2.25 2.25 < 0.005 < 0.005 < 0.005 2.37 Annual — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.22 0.22 < 0.005 < 0.005 < 0.005 0.22 Vendor 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 0.00 Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.37 0.37 < 0.005 < 0.005 < 0.005 0.39

3.3. Support Pile Installation (2026) - Unmitigated
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Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.44 0.37 3.01 3.97 0.01 0.12 — 0.12 0.11 — 0.11 844 844 0.03 0.01 — 847 Onsite
truck

0.01 < 0.005 0.07 0.05 < 0.005 < 0.005 2.95 2.95 < 0.005 0.29 0.29 19.8 19.8 < 0.005 < 0.005 0.03 20.8 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.44 0.37 3.01 3.97 0.01 0.12 — 0.12 0.11 — 0.11 844 844 0.03 0.01 — 847 Onsite
truck

0.01 < 0.005 0.07 0.05 < 0.005 < 0.005 2.95 2.95 < 0.005 0.29 0.29 19.9 19.9 < 0.005 < 0.005 < 0.005 20.9 Average
Daily
— — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.03 0.02 0.17 0.23 < 0.005 0.01 — 0.01 0.01 — 0.01 48.5 48.5 < 0.005 < 0.005 — 48.7 Onsite
truck
< 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.16 0.16 < 0.005 0.02 0.02 1.14 1.14 < 0.005 < 0.005 < 0.005 1.20 Annual — — — — — — — — — — — — — — — — —
Off-Road
Equipment
< 0.005 < 0.005 0.03 0.04 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 8.04 8.04 < 0.005 < 0.005 — 8.06 Onsite
truck
< 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.03 0.03 < 0.005 < 0.005 < 0.005 0.19 0.19 < 0.005 < 0.005 < 0.005 0.20 Offsite — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Worker 0.06 0.06 0.05 0.90 0.00 0.00 0.23 0.23 0.00 0.05 0.05 225 225 < 0.005 0.01 0.78 228 Vendor 0.01 < 0.005 0.11 0.05 < 0.005 < 0.005 0.03 0.03 < 0.005 0.01 0.01 121 121 0.01 0.02 0.32 127 Hellman Solar PV Project Detailed Report, 7/13/2025
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Hauling 0.05 0.01 0.66 0.29 < 0.005 0.01 0.14 0.15 0.01 0.04 0.05 548 548 0.04 0.09 1.11 576 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Worker 0.06 0.06 0.06 0.78 0.00 0.00 0.23 0.23 0.00 0.05 0.05 214 214 < 0.005 0.01 0.02 217 Vendor 0.01 < 0.005 0.11 0.05 < 0.005 < 0.005 0.03 0.03 < 0.005 0.01 0.01 121 121 0.01 0.02 0.01 126 Hauling 0.05 0.01 0.68 0.29 < 0.005 0.01 0.14 0.15 0.01 0.04 0.05 548 548 0.04 0.09 0.03 575 Average
Daily
— — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.05 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 12.5 12.5 < 0.005 < 0.005 0.02 12.7 Vendor < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 6.97 6.97 < 0.005 < 0.005 0.01 7.28 Hauling < 0.005 < 0.005 0.04 0.02 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 31.5 31.5 < 0.005 < 0.005 0.03 33.1 Annual — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 2.07 2.07 < 0.005 < 0.005 < 0.005 2.09 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 1.15 1.15 < 0.005 < 0.005 < 0.005 1.20 Hauling < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 5.22 5.22 < 0.005 < 0.005 < 0.005 5.48

3.4. Support Pile Installation (2026) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.44 0.37 3.01 3.97 0.01 0.12 — 0.12 0.11 — 0.11 844 844 0.03 0.01 — 847 Onsite
truck

0.01 < 0.005 0.07 0.05 < 0.005 < 0.005 0.74 0.74 < 0.005 0.07 0.07 19.8 19.8 < 0.005 < 0.005 0.03 20.8 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
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Off-Road
Equipment

0.44 0.37 3.01 3.97 0.01 0.12 — 0.12 0.11 — 0.11 844 844 0.03 0.01 — 847 Onsite
truck

0.01 < 0.005 0.07 0.05 < 0.005 < 0.005 0.74 0.74 < 0.005 0.07 0.07 19.9 19.9 < 0.005 < 0.005 < 0.005 20.9 Average
Daily
— — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.03 0.02 0.17 0.23 < 0.005 0.01 — 0.01 0.01 — 0.01 48.5 48.5 < 0.005 < 0.005 — 48.7 Onsite
truck
< 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.04 0.04 < 0.005 < 0.005 < 0.005 1.14 1.14 < 0.005 < 0.005 < 0.005 1.20 Annual — — — — — — — — — — — — — — — — —
Off-Road
Equipment
< 0.005 < 0.005 0.03 0.04 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 8.04 8.04 < 0.005 < 0.005 — 8.06 Onsite
truck
< 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 0.19 0.19 < 0.005 < 0.005 < 0.005 0.20 Offsite — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Worker 0.06 0.06 0.05 0.90 0.00 0.00 0.23 0.23 0.00 0.05 0.05 225 225 < 0.005 0.01 0.78 228 Vendor 0.01 < 0.005 0.11 0.05 < 0.005 < 0.005 0.03 0.03 < 0.005 0.01 0.01 121 121 0.01 0.02 0.32 127 Hauling 0.05 0.01 0.66 0.29 < 0.005 0.01 0.14 0.15 0.01 0.04 0.05 548 548 0.04 0.09 1.11 576 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Worker 0.06 0.06 0.06 0.78 0.00 0.00 0.23 0.23 0.00 0.05 0.05 214 214 < 0.005 0.01 0.02 217 Vendor 0.01 < 0.005 0.11 0.05 < 0.005 < 0.005 0.03 0.03 < 0.005 0.01 0.01 121 121 0.01 0.02 0.01 126 Hauling 0.05 0.01 0.68 0.29 < 0.005 0.01 0.14 0.15 0.01 0.04 0.05 548 548 0.04 0.09 0.03 575 Average
Daily
— — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.05 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 12.5 12.5 < 0.005 < 0.005 0.02 12.7 Vendor < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 6.97 6.97 < 0.005 < 0.005 0.01 7.28 Hauling < 0.005 < 0.005 0.04 0.02 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 31.5 31.5 < 0.005 < 0.005 0.03 33.1 Hellman Solar PV Project Detailed Report, 7/13/2025
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Annual — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 2.07 2.07 < 0.005 < 0.005 < 0.005 2.09 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 1.15 1.15 < 0.005 < 0.005 < 0.005 1.20 Hauling < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 5.22 5.22 < 0.005 < 0.005 < 0.005 5.48

3.5. Solar PV System, Equipment, and Conduit Installation (2026) - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.65 0.54 4.31 5.61 0.01 0.15 — 0.15 0.14 — 0.14 1,051 1,051 0.04 0.01 — 1,055 Onsite
truck

0.04 0.03 0.24 0.31 < 0.005 0.01 — 0.01 0.01 — 0.01 57.6 57.6 < 0.005 < 0.005 — 57.8 Onsite
truck
< 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.15 0.15 < 0.005 0.02 0.02 1.09 1.09 < 0.005 < 0.005 < 0.005 1.14 Annual — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.01 0.01 0.04 0.06 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 9.54 9.54 < 0.005 < 0.005 — 9.57 Onsite
truck
< 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.03 0.03 < 0.005 < 0.005 < 0.005 0.18 0.18 < 0.005 < 0.005 < 0.005 0.19 Offsite — — — — — — — — — — — — — — — — —
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Daily, — — — — — — — — — — — — — — — — —
Summer
(Max)
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Worker 0.07 0.07 0.07 0.97 0.00 0.00 0.28 0.28 0.00 0.07 0.07 268 268 < 0.005 0.01 0.03 271 Vendor 0.01 < 0.005 0.11 0.05 < 0.005 < 0.005 0.03 0.03 < 0.005 0.01 0.01 121 121 0.01 0.02 0.01 126 Hauling 0.05 0.01 0.68 0.29 < 0.005 0.01 0.14 0.15 0.01 0.04 0.05 548 548 0.04 0.09 0.03 575 Average
Daily
— — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.06 0.00 0.00 0.02 0.02 0.00 < 0.005 < 0.005 14.9 14.9 < 0.005 < 0.005 0.02 15.1 Vendor < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 6.64 6.64 < 0.005 < 0.005 0.01 6.93 Hauling < 0.005 < 0.005 0.04 0.02 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 30.0 30.0 < 0.005 < 0.005 0.03 31.5 Annual — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 2.46 2.46 < 0.005 < 0.005 < 0.005 2.49 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 1.10 1.10 < 0.005 < 0.005 < 0.005 1.15 Hauling < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 4.97 4.97 < 0.005 < 0.005 < 0.005 5.22

3.6. Solar PV System, Equipment, and Conduit Installation (2026) - Mitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.65 0.54 4.31 5.61 0.01 0.15 — 0.15 0.14 — 0.14 1,051 1,051 0.04 0.01 — 1,055 Hellman Solar PV Project Detailed Report, 7/13/2025
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Onsite 0.01 < 0.005 0.07 0.05 < 0.005 < 0.005 0.74 0.74 < 0.005 0.07 0.07 19.9 19.9 < 0.005 < 0.005 < 0.005 20.9 truck
Average
Daily
— — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.04 0.03 0.24 0.31 < 0.005 0.01 — 0.01 0.01 — 0.01 57.6 57.6 < 0.005 < 0.005 — 57.8 Onsite
truck
< 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.04 0.04 < 0.005 < 0.005 < 0.005 1.09 1.09 < 0.005 < 0.005 < 0.005 1.14 Annual — — — — — — — — — — — — — — — — —
Off-Road
Equipment

0.01 0.01 0.04 0.06 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 9.54 9.54 < 0.005 < 0.005 — 9.57 Onsite
truck
< 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 0.18 0.18 < 0.005 < 0.005 < 0.005 0.19 Offsite — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Worker 0.07 0.07 0.07 0.97 0.00 0.00 0.28 0.28 0.00 0.07 0.07 268 268 < 0.005 0.01 0.03 271 Vendor 0.01 < 0.005 0.11 0.05 < 0.005 < 0.005 0.03 0.03 < 0.005 0.01 0.01 121 121 0.01 0.02 0.01 126 Hauling 0.05 0.01 0.68 0.29 < 0.005 0.01 0.14 0.15 0.01 0.04 0.05 548 548 0.04 0.09 0.03 575 Average
Daily
— — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.06 0.00 0.00 0.02 0.02 0.00 < 0.005 < 0.005 14.9 14.9 < 0.005 < 0.005 0.02 15.1 Vendor < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 6.64 6.64 < 0.005 < 0.005 0.01 6.93 Hauling < 0.005 < 0.005 0.04 0.02 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 30.0 30.0 < 0.005 < 0.005 0.03 31.5 Annual — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 2.46 2.46 < 0.005 < 0.005 < 0.005 2.49 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 1.10 1.10 < 0.005 < 0.005 < 0.005 1.15 Hauling < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 4.97 4.97 < 0.005 < 0.005 < 0.005 5.22 Hellman Solar PV Project Detailed Report, 7/13/2025
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3.7. Testing and Commissioning (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Onsite
truck

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 0.00 Average
Daily
— — — — — — — — — — — — — — — — —
Onsite
truck

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 0.00 Annual — — — — — — — — — — — — — — — — —
Onsite
truck

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 0.00 Offsite — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Worker 0.03 0.03 0.03 0.39 0.00 0.00 0.11 0.11 0.00 0.03 0.03 107 107 < 0.005 < 0.005 0.01 108 Vendor 0.02 < 0.005 0.22 0.10 < 0.005 < 0.005 0.07 0.07 < 0.005 0.02 0.02 242 242 0.01 0.03 0.02 253 Hauling 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 0.00 Average
Daily
— — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.02 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 5.95 5.95 < 0.005 < 0.005 0.01 6.02 Vendor < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 13.3 13.3 < 0.005 < 0.005 0.02 13.9 Hellman Solar PV Project Detailed Report, 7/13/2025
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Hauling 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 0.00 Annual — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.98 0.98 < 0.005 < 0.005 < 0.005 1.00 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 2.20 2.20 < 0.005 < 0.005 < 0.005 2.29 Hauling 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 0.00

3.8. Testing and Commissioning (2026) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Onsite
truck

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 0.00 Average
Daily
— — — — — — — — — — — — — — — — —
Onsite
truck

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 0.00 Annual — — — — — — — — — — — — — — — — —
Onsite
truck

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 0.00 Offsite — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Hellman Solar PV Project Detailed Report, 7/13/2025
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Worker 0.03 0.03 0.03 0.39 0.00 0.00 0.11 0.11 0.00 0.03 0.03 107 107 < 0.005 < 0.005 0.01 108 Vendor 0.02 < 0.005 0.22 0.10 < 0.005 < 0.005 0.07 0.07 < 0.005 0.02 0.02 242 242 0.01 0.03 0.02 253 Hauling 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 0.00 Average
Daily
— — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.02 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 5.95 5.95 < 0.005 < 0.005 0.01 6.02 Vendor < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 13.3 13.3 < 0.005 < 0.005 0.02 13.9 Hauling 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 0.00 Annual — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.98 0.98 < 0.005 < 0.005 < 0.005 1.00 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 2.20 2.20 < 0.005 < 0.005 < 0.005 2.29 Hauling 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 0.00

4. Operations Emissions Details

4.1. Mobile Emissions by Land Use

4.1.1. Unmitigated
Mobile source emissions results are presented in Sections 2.6. No further detailed breakdown of emissions is available.

4.1.2. Mitigated
Mobile source emissions results are presented in Sections 2.5. No further detailed breakdown of emissions is available.

4.2. Energy

4.2.1. Electricity Emissions By Land Use - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
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User
Defined
Industrial
— — — — — — — — — — — 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — — 0.00 0.00 0.00 0.00 — 0.00
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
User
Defined
Industrial
— — — — — — — — — — — 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — — 0.00 0.00 0.00 0.00 — 0.00
Annual — — — — — — — — — — — — — — — — —
User
Defined
Industrial
— — — — — — — — — — — 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — — 0.00 0.00 0.00 0.00 — 0.00

4.2.2. Electricity Emissions By Land Use - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
User
Defined
Industrial
— — — — — — — — — — — 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — — 0.00 0.00 0.00 0.00 — 0.00
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
User
Defined
Industrial
— — — — — — — — — — — 0.00 0.00 0.00 0.00 — 0.00
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Total — — — — — — — — — — — 0.00 0.00 0.00 0.00 — 0.00
Annual — — — — — — — — — — — — — — — — —
User
Defined
Industrial
— — — — — — — — — — — 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — — 0.00 0.00 0.00 0.00 — 0.00

4.2.3. Natural Gas Emissions By Land Use - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
User
Defined
Industrial

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 Total 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 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
User
Defined
Industrial

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 Total 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 Annual — — — — — — — — — — — — — — — — —
User
Defined
Industrial

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 Total 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

4.2.4. Natural Gas Emissions By Land Use - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Hellman Solar PV Project Detailed Report, 7/13/2025
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Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
User
Defined
Industrial

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 Total 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

4.3. Area Emissions by Source

4.3.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Source TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Consum
er
Products

0.00 0.00 — — — — — — — — — — — — — — —
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Architect 0.00 0.00 — — — — — — — — — — — — — — —
ural
Landsca
pe
Equipme
nt

0.11 0.10 0.03 2.36 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 6.37 6.37 < 0.005 < 0.005 — 6.40 Total 0.11 0.10 0.03 2.36 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 6.37 6.37 < 0.005 < 0.005 — 6.40 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Consum
er
Products

0.00 0.00 — — — — — — — — — — — — — — —
Architect
ural
Coatings

0.00 0.00 — — — — — — — — — — — — — — —
Landsca
pe
Equipme
nt

0.11 0.10 0.03 2.36 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 6.37 6.37 < 0.005 < 0.005 — 6.40 Total 0.11 0.10 0.03 2.36 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 6.37 6.37 < 0.005 < 0.005 — 6.40 Annual — — — — — — — — — — — — — — — — —
Consum
er
Products

0.00 0.00 — — — — — — — — — — — — — — —
Architect
ural
Coatings

0.00 0.00 — — — — — — — — — — — — — — —
Landsca
pe
Equipme
nt
< 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 0.01 0.01 < 0.005 < 0.005 — 0.01 Total < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 0.01 0.01 < 0.005 < 0.005 — 0.01

4.3.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Hellman Solar PV Project Detailed Report, 7/13/2025
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Source TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Consum
er
Products

0.00 0.00 — — — — — — — — — — — — — — —
Architect
ural
Coatings

0.00 0.00 — — — — — — — — — — — — — — —
Landsca
pe
Equipme
nt

0.00 0.00 — — — — — — — — — — — — — — —
Architect
ural
Coatings

0.00 0.00 — — — — — — — — — — — — — — —
Landsca
pe
Equipme
nt

0.11 0.10 0.03 2.36 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 6.37 6.37 < 0.005 < 0.005 — 6.40 Total 0.11 0.10 0.03 2.36 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 6.37 6.37 < 0.005 < 0.005 — 6.40 Annual — — — — — — — — — — — — — — — — —
Consum
er
Products

0.00 0.00 — — — — — — — — — — — — — — —
Architect
ural
Coatings

0.00 0.00 — — — — — — — — — — — — — — —
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Landsca
Equipment
< 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 0.01 0.01 < 0.005 < 0.005 — 0.01 Total < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 0.01 0.01 < 0.005 < 0.005 — 0.01

4.4. Water Emissions by Land Use

4.4.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
User
Defined
Industrial
— — — — — — — — — — — 0.01 0.01 < 0.005 < 0.005 — 0.01
Total — — — — — — — — — — — 0.01 0.01 < 0.005 < 0.005 — 0.01 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
User
Defined
Industrial
— — — — — — — — — — — 0.01 0.01 < 0.005 < 0.005 — 0.01
Total — — — — — — — — — — — 0.01 0.01 < 0.005 < 0.005 — 0.01 Annual — — — — — — — — — — — — — — — — —
User
Defined
Industrial
— — — — — — — — — — — < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 Total — — — — — — — — — — — < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005

4.4.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Hellman Solar PV Project Detailed Report, 7/13/2025
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Land TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T NBCO2 CO2T CH4 N2O R CO2e Use
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
User
Defined
Industrial
— — — — — — — — — — — 0.01 0.01 < 0.005 < 0.005 — 0.01
Total — — — — — — — — — — — 0.01 0.01 < 0.005 < 0.005 — 0.01 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
User
Defined
Industrial
— — — — — — — — — — — 0.01 0.01 < 0.005 < 0.005 — 0.01
Total — — — — — — — — — — — 0.01 0.01 < 0.005 < 0.005 — 0.01 Annual — — — — — — — — — — — — — — — — —
User
Defined
Industrial
— — — — — — — — — — — < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 Total — — — — — — — — — — — < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005

4.5. Waste Emissions by Land Use

4.5.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
User
Defined
Industrial
— — — — — — — — — — — 0.00 0.00 0.00 0.00 — 0.00
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Total — — — — — — — — — — — 0.00 0.00 0.00 0.00 — 0.00
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
User
Defined
Industrial
— — — — — — — — — — — 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — — 0.00 0.00 0.00 0.00 — 0.00
Annual — — — — — — — — — — — — — — — — —
User
Defined
Industrial
— — — — — — — — — — — 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — — 0.00 0.00 0.00 0.00 — 0.00

4.5.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
User
Defined
Industrial
— — — — — — — — — — — 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — — 0.00 0.00 0.00 0.00 — 0.00
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
User
Defined
Industrial
— — — — — — — — — — — 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — — 0.00 0.00 0.00 0.00 — 0.00
Annual — — — — — — — — — — — — — — — — —
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User — — — — — — — — — — — 0.00 0.00 0.00 0.00 — 0.00
Defined
Industrial
Total — — — — — — — — — — — 0.00 0.00 0.00 0.00 — 0.00

4.6. Refrigerant Emissions by Land Use

4.6.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —

4.6.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
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Total — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —

4.7. Offroad Emissions By Equipment Type

4.7.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipme
nt
Type
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —

4.7.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipme
nt
Type
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —
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Daily, — — — — — — — — — — — — — — — — —
Winter
(Max)
Total — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —

4.8. Stationary Emissions By Equipment Type

4.8.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipme
nt
Type
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —

4.8.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipme
nt
Type
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
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Total — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —

4.9. User Defined Emissions By Equipment Type

4.9.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipme
nt
Type
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —

4.9.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipme
nt
Type
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T NBCO2 CO2T CH4 N2O R CO2e Hellman Solar PV Project Detailed Report, 7/13/2025
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Daily, — — — — — — — — — — — — — — — — —
Summer
(Max)
Total — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —

4.10. Soil Carbon Accumulation By Vegetation Type

4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Vegetatio
n
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —

4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T NBCO2 CO2T CH4 N2O R CO2e Hellman Solar PV Project Detailed Report, 7/13/2025
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Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —

4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Species TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — —
Sequest
ered
— — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — —
Remove
d
— — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — —
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — —
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Sequest — — — — — — — — — — — — — — — — —
ered
Subtotal — — — — — — — — — — — — — — — — —
Remove
d
— — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — —
— — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — —
Sequest
ered
— — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — —
Remove
d
— — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — —
— — — — — — — — — — — — — — — — — —

4.10.4. Soil Carbon Accumulation By Vegetation Type - Mitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Vegetatio
n
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — —
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Total — — — — — — — — — — — — — — — — —

4.10.5. Above and Belowground Carbon Accumulation by Land Use Type - Mitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —

4.10.6. Avoided and Sequestered Emissions by Species - Mitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Species TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — —
Sequest
ered
— — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — —
Remove
d
— — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — —
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— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — —
Sequest
ered
— — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — —
Remove
d
— — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — —
— — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — —
Sequest
ered
— — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — —
Remove
d
— — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — —
— — — — — — — — — — — — — — — — — —

5. Activity Data

5.1. Construction Schedule
Phase Name Phase Type Start Date End Date Days Per Week Work Days per Phase Phase Description Site Preparation Grading 9/16/2026 9/18/2026 5.00 3.00 Removal of Vegetation and Clearing Site
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Support Pile Installation Building Construction 9/21/2026 10/19/2026 5.00 21.0 Installation of Solar PV Table Supports
Solar PV System,
Equipment, and Conduit
Installation
Building Construction 10/19/2026 11/13/2026 5.00 20.0 Installation of Solar Equipment and Conduits
Testing and
Commissioning
Building Construction 11/16/2026 12/11/2026 5.00 20.0 Testing and Commissioning

5.2. Off-Road Equipment

5.2.1. Unmitigated
Phase Name Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor Site Preparation Rubber Tired Dozers Diesel Average 1.00 8.00 84.0 0.37 Site Preparation Graders Diesel Average 1.00 8.00 148 0.41 Site Preparation Off-Highway Trucks Diesel Average 1.00 3.00 376 0.38 Site Preparation Off-Highway Trucks Diesel Average 1.00 3.00 376 0.38 Support Pile
Installation
Forklifts Diesel Average 1.00 8.00 82.0 0.20
Support Pile
Installation
Generator Sets Diesel Average 1.00 8.00 14.0 0.74
Support Pile
Installation
Tractors/Loaders/Back
hoes
Diesel Average 1.00 7.00 84.0 0.37
Support Pile
Installation
Off-Highway Trucks Diesel Average 1.00 2.00 376 0.38
Solar PV System,
Equipment, and
Conduit Installation
Forklifts Diesel Average 1.00 8.00 82.0 0.20
Solar PV System,
Equipment, and
Conduit Installation
Generator Sets Diesel Average 1.00 8.00 14.0 0.74
Solar PV System,
Equipment, and
Conduit Installation
Welders Diesel Average 1.00 8.00 46.0 0.45
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Solar PV System,
Equipment, and
Conduit Installation
Tractors/Loaders/Back Diesel Average 1.00 7.00 84.0 0.37 Solar PV System,
Equipment, and
Conduit Installation
Off-Highway Trucks Diesel Average 1.00 2.00 376 0.38

5.2.2. Mitigated
Phase Name Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor Site Preparation Rubber Tired Dozers Diesel Average 1.00 8.00 84.0 0.37 Site Preparation Graders Diesel Average 1.00 8.00 148 0.41 Site Preparation Off-Highway Trucks Diesel Average 1.00 3.00 376 0.38 Site Preparation Off-Highway Trucks Diesel Average 1.00 3.00 376 0.38 Support Pile
Installation
Forklifts Diesel Average 1.00 8.00 82.0 0.20
Support Pile
Installation
Generator Sets Diesel Average 1.00 8.00 14.0 0.74
Support Pile
Installation
Tractors/Loaders/Back
hoes
Diesel Average 1.00 7.00 84.0 0.37
Support Pile
Installation
Off-Highway Trucks Diesel Average 1.00 2.00 376 0.38
Solar PV System,
Equipment, and
Conduit Installation
Forklifts Diesel Average 1.00 8.00 82.0 0.20
Solar PV System,
Equipment, and
Conduit Installation
Generator Sets Diesel Average 1.00 8.00 14.0 0.74
Solar PV System,
Equipment, and
Conduit Installation
Welders Diesel Average 1.00 8.00 46.0 0.45
Solar PV System,
Equipment, and
Conduit Installation
Tractors/Loaders/Back
hoes
Diesel Average 1.00 7.00 84.0 0.37
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Solar PV System, Off-Highway Trucks Diesel Average 1.00 2.00 376 0.38 Equipment, and
Conduit Installation

5.3. Construction Vehicles

5.3.1. Unmitigated
Phase Name Trip Type One-Way Trips per Day Miles per Trip Vehicle Mix Site Preparation — — — —
Site Preparation Worker 12.0 20.0 LDA,LDT1,LDT2
Site Preparation Vendor 0.00 20.0 HHDT,MHDT
Site Preparation Hauling 4.00 20.0 HHDT
Site Preparation Onsite truck 2.00 1.00 HHDT
Support Pile Installation — — — —
Support Pile Installation Worker 16.0 20.0 LDA,LDT1,LDT2 Support Pile Installation Vendor 2.00 20.0 HHDT,MHDT
Support Pile Installation Hauling 8.00 20.0 HHDT
Support Pile Installation Onsite truck 4.00 1.00 HHDT
Solar PV System, Equipment, and
Conduit Installation
— — — —
Solar PV System, Equipment, and
Conduit Installation
Worker 20.0 20.0 LDA,LDT1,LDT2
Solar PV System, Equipment, and
Conduit Installation
Vendor 2.00 20.0 HHDT,MHDT
Solar PV System, Equipment, and
Conduit Installation
Hauling 8.00 20.0 HHDT
Solar PV System, Equipment, and
Conduit Installation
Onsite truck 4.00 1.00 HHDT
Testing and Commissioning — — — —
Testing and Commissioning Worker 8.00 20.0 LDA,LDT1,LDT2 Testing and Commissioning Vendor 4.00 20.0 HHDT,MHDT
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Testing and Commissioning Hauling 0.00 20.0 HHDT
Testing and Commissioning Onsite truck 0.00 1.00 HHDT

5.3.2. Mitigated
Phase Name Trip Type One-Way Trips per Day Miles per Trip Vehicle Mix Site Preparation — — — —
Site Preparation Worker 12.0 20.0 LDA,LDT1,LDT2
Site Preparation Vendor 0.00 20.0 HHDT,MHDT
Site Preparation Hauling 4.00 20.0 HHDT
Site Preparation Onsite truck 2.00 1.00 HHDT
Support Pile Installation — — — —
Support Pile Installation Worker 16.0 20.0 LDA,LDT1,LDT2 Support Pile Installation Vendor 2.00 20.0 HHDT,MHDT
Support Pile Installation Hauling 8.00 20.0 HHDT
Support Pile Installation Onsite truck 4.00 1.00 HHDT
Solar PV System, Equipment, and
Conduit Installation
— — — —
Solar PV System, Equipment, and
Conduit Installation
Worker 20.0 20.0 LDA,LDT1,LDT2
Solar PV System, Equipment, and
Conduit Installation
Vendor 2.00 20.0 HHDT,MHDT
Solar PV System, Equipment, and
Conduit Installation
Hauling 8.00 20.0 HHDT
Solar PV System, Equipment, and
Conduit Installation
Onsite truck 4.00 1.00 HHDT
Testing and Commissioning — — — —
Testing and Commissioning Worker 8.00 20.0 LDA,LDT1,LDT2 Testing and Commissioning Vendor 4.00 20.0 HHDT,MHDT
Testing and Commissioning Hauling 0.00 20.0 HHDT
Testing and Commissioning Onsite truck 0.00 1.00 HHDT
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5.4. Vehicles

5.4.1. Construction Vehicle Control Strategies
Non-applicable. No control strategies activated by user.

5.5. Architectural Coatings
Phase Name Residential Interior Area
Coated (sq ft)
Residential Exterior Area
Coated (sq ft)
Non-Residential Interior Area
Coated (sq ft)
Non-Residential Exterior Area
Coated (sq ft)
Parking Area Coated (sq ft)

5.6. Dust Mitigation

5.6.1. Construction Earthmoving Activities
Phase Name Material Imported (Cubic
Yards)
Material Exported (Cubic
Yards)
Acres Graded (acres) Material Demolished (sq. ft.) Acres Paved (acres) Site Preparation 0.00 0.00 5.00 0.00 —

5.6.2. Construction Earthmoving Control Strategies
Non-applicable. No control strategies activated by user.

5.7. Construction Paving
Land Use Area Paved (acres) % Asphalt
User Defined Industrial 0.00 0%

5.8. Construction Electricity Consumption and Emissions Factors kWh per Year and Emission Factor (lb/MWh)
Year kWh per Year CO2 CH4 N2O
2026 0.00 346 0.03 < 0.005

5.9. Operational Mobile Sources
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5.9.1. Unmitigated
Land Use Type Trips/Weekday Trips/Saturday Trips/Sunday Trips/Year VMT/Weekday VMT/Saturday VMT/Sunday VMT/Year Total all Land Uses 1.00 0.00 0.00 8.00 60.0 0.00 0.00 480

5.9.2. Mitigated
Land Use Type Trips/Weekday Trips/Saturday Trips/Sunday Trips/Year VMT/Weekday VMT/Saturday VMT/Sunday VMT/Year Total all Land Uses NaN NaN NaN NaN NaN NaN NaN NaN

5.10. Operational Area Sources

5.10.1. Hearths

5.10.1.1. Unmitigated

5.10.1.2. Mitigated

5.10.2. Architectural Coatings
Residential Interior Area Coated (sq
ft)
Residential Exterior Area Coated (sq
ft)
Non-Residential Interior Area Coated
(sq ft)
Non-Residential Exterior Area
Coated (sq ft)
Parking Area Coated (sq ft)
0 0.00 0.00 0.00 —

5.10.3. Landscape Equipment
Equipment Type Fuel Type Number Per Day Hours per Day Hours per Year Horsepower Load Factor Lawn Mowers Gasoline 4-Stroke 1.00 3.00 6.00 3.86 0.36

5.10.4. Landscape Equipment - Mitigated
Equipment Type Fuel Type Number Per Day Hours per Day Hours per Year Horsepower Load Factor Lawn Mowers Gasoline 4-Stroke 1.00 3.00 6.00 3.86 0.36
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5.11. Operational Energy Consumption

5.11.1. Unmitigated
Electricity (kWh/yr) and CO2 and CH4 and N2O and Natural Gas (kBTU/yr) Land Use Electricity (kWh/yr) CO2 CH4 N2O Natural Gas (kBTU/yr) User Defined Industrial 0.00 346 0.0330 0.0040 0.00

5.11.2. Mitigated
Electricity (kWh/yr) and CO2 and CH4 and N2O and Natural Gas (kBTU/yr) Land Use Electricity (kWh/yr) CO2 CH4 N2O Natural Gas (kBTU/yr) User Defined Industrial 0.00 346 0.0330 0.0040 0.00

5.12. Operational Water and Wastewater Consumption

5.12.1. Unmitigated
Land Use Indoor Water (gal/year) Outdoor Water (gal/year) User Defined Industrial 0.00 1,500

5.12.2. Mitigated
Land Use Indoor Water (gal/year) Outdoor Water (gal/year) User Defined Industrial 0.00 1,500

5.13. Operational Waste Generation

5.13.1. Unmitigated
Land Use Waste (ton/year) Cogeneration (kWh/year)
User Defined Industrial 0.00 —
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5.13.2. Mitigated
Land Use Waste (ton/year) Cogeneration (kWh/year)
User Defined Industrial 0.00 —

5.14. Operational Refrigeration and Air Conditioning Equipment

5.14.1. Unmitigated
Land Use Type Equipment Type Refrigerant GWP Quantity (kg) Operations Leak Rate Service Leak Rate Times Serviced

5.14.2. Mitigated
Land Use Type Equipment Type Refrigerant GWP Quantity (kg) Operations Leak Rate Service Leak Rate Times Serviced

5.15. Operational Off-Road Equipment

5.15.1. Unmitigated
Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor

5.15.2. Mitigated
Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor

5.16. Stationary Sources

5.16.1. Emergency Generators and Fire Pumps
Equipment Type Fuel Type Number per Day Hours per Day Hours per Year Horsepower Load Factor

5.16.2. Process Boilers
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Equipment Type Fuel Type Number Boiler Rating (MMBtu/hr) Daily Heat Input (MMBtu/day) Annual Heat Input (MMBtu/yr)

5.17. User Defined
Equipment Type Fuel Type
— —

5.18. Vegetation

5.18.1. Land Use Change

5.18.1.1. Unmitigated
Vegetation Land Use Type Vegetation Soil Type Initial Acres Final Acres

5.18.1.2. Mitigated
Vegetation Land Use Type Vegetation Soil Type Initial Acres Final Acres

5.18.1. Biomass Cover Type

5.18.1.1. Unmitigated
Biomass Cover Type Initial Acres Final Acres

5.18.1.2. Mitigated
Biomass Cover Type Initial Acres Final Acres

5.18.2. Sequestration

5.18.2.1. Unmitigated
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Tree Type Number Electricity Saved (kWh/year) Natural Gas Saved (btu/year)

5.18.2.2. Mitigated
Tree Type Number Electricity Saved (kWh/year) Natural Gas Saved (btu/year)

6. Climate Risk Detailed Report

6.1. Climate Risk Summary
Cal-Adapt midcentury 2040–2059 average projections for four hazards are reported below for your project location. These are under Representation Concentration Pathway (RCP) 8.5 which assumes GHG emissions will continue to rise strongly through 2050 and then plateau around 2100.

Climate Hazard Result for Project Location Unit
Temperature and Extreme Heat 7.09 annual days of extreme heat Extreme Precipitation 3.75 annual days with precipitation above 20 mm Sea Level Rise 0.00 meters of inundation depth
Wildfire 0.40 annual hectares burned
Temperature and Extreme Heat data are for grid cell in which your project are located. The projection is based on the 98th historical percentile of daily maximum/minimum temperatures from observed historical data (32 climate model ensemble from Cal-Adapt, 2040–2059 average under RCP 8.5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.

Extreme Precipitation data are for the grid cell in which your project are located. The threshold of 20 mm is equivalent to about ¾ an inch of rain, which would be light to moderate rainfall if received over a full day or heavy rain if received over a period of 2 to 4 hours. Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.

Sea Level Rise data are for the grid cell in which your project are located. The projections are from Radke et al. (2017), as reported in Cal-Adapt (Radke et al., 2017, CEC-500-2017-008), and consider inundation location and depth for the San Francisco Bay, the Sacramento-San Joaquin River Delta and California coast resulting different increments of sea level rise coupled with extreme storm events. Users may select from four scenarios to view the range in potential inundation depth for the grid cell. The four scenarios are: No rise, 0.5 meter, 1.0 meter, 1.41 meters Wildfire data are for the grid cell in which your project are located. The projections are from UC Davis, as reported in Cal-Adapt (2040–2059 average under RCP 8.5), and consider historical data of climate, vegetation, population density, and large (> 400 ha) fire history. Users may select from four model simulations to view the range in potential wildfire probabilities for the grid cell. The four simulations make different assumptions about expected rainfall and temperature are: Warmer/drier (HadGEM2-ES), Cooler/wetter (CNRM-CM5), Average conditions (CanESM2), Range of different rainfall and temperature possibilities (MIROC5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.

6.2. Initial Climate Risk Scores
Climate Hazard Exposure Score Sensitivity Score Adaptive Capacity Score Vulnerability Score Temperature and Extreme Heat 1 0 0 N/A
Extreme Precipitation N/A N/A N/A N/A
Sea Level Rise 1 0 0 N/A
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Wildfire 1 0 0 N/A
Flooding N/A N/A N/A N/A
Drought N/A N/A N/A N/A
Snowpack Reduction N/A N/A N/A N/A
Air Quality Degradation 0 0 0 N/A
The sensitivity score reflects the extent to which a project would be adversely affected by exposure to a climate hazard. Exposure is rated on a scale of 1 to 5, with a score of 5 representing the greatest exposure.

The adaptive capacity of a project refers to its ability to manage and reduce vulnerabilities from projected climate hazards. Adaptive capacity is rated on a scale of 1 to 5, with a score of 5 representing the greatest ability to adapt.

The overall vulnerability scores are calculated based on the potential impacts and adaptive capacity assessments for each hazard. Scores do not include implementation of climate risk reduction measures.

6.3. Adjusted Climate Risk Scores
Climate Hazard Exposure Score Sensitivity Score Adaptive Capacity Score Vulnerability Score Temperature and Extreme Heat 1 1 1 2
Extreme Precipitation N/A N/A N/A N/A
Sea Level Rise 1 1 1 2
Wildfire 1 1 1 2
Flooding N/A N/A N/A N/A
Drought N/A N/A N/A N/A
Snowpack Reduction N/A N/A N/A N/A
Air Quality Degradation 1 1 1 2
The sensitivity score reflects the extent to which a project would be adversely affected by exposure to a climate hazard. Exposure is rated on a scale of 1 to 5, with a score of 5 representing the greatest exposure.

The overall vulnerability scores are calculated based on the potential impacts and adaptive capacity assessments for each hazard. Scores include implementation of climate risk reduction measures.

6.4. Climate Risk Reduction Measures

7. Health and Equity Details
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7.1. CalEnviroScreen 4.0 Scores
The maximum CalEnviroScreen score is 100. A high score (i.e., greater than 50) reflects a higher pollution burden compared to other census tracts in the state.

Indicator Result for Project Census Tract
Exposure Indicators —
AQ-Ozone 24.9
AQ-PM 60.5
AQ-DPM 40.5
Drinking Water 9.13
Lead Risk Housing 59.7
Pesticides 36.1
Toxic Releases 95.0
Traffic 53.4
Effect Indicators —
CleanUp Sites 90.0
Groundwater 88.5
Haz Waste Facilities/Generators 89.8
Impaired Water Bodies 91.9
Solid Waste 67.5
Sensitive Population —
Asthma 8.70
Cardio-vascular 22.7
Low Birth Weights 7.95
Socioeconomic Factor Indicators —
Education 21.7
Housing 58.8
Linguistic 5.64
Poverty 0.83
Unemployment 32.3
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7.2. Healthy Places Index Scores
The maximum Health Places Index score is 100. A high score (i.e., greater than 50) reflects healthier community conditions compared to other census tracts in the state.

Indicator Result for Project Census Tract
Economic —
Above Poverty 97.84421917
Employed 59.16848454
Median HI —
Education —
Bachelor's or higher 89.32375209
High school enrollment 12.79353266
Preschool enrollment 95.7141024
Transportation —
Auto Access 93.63531374
Active commuting 53.95868087
Social —
2-parent households 51.8285641
Voting 90.4016425
Neighborhood —
Alcohol availability 51.59758758
Park access 81.35506224
Retail density 52.62414988
Supermarket access 74.83639163
Tree canopy 28.25612729
Housing —
Homeownership 99.76902348
Housing habitability 85.98742461
Low-inc homeowner severe housing cost burden 37.05889901 Low-inc renter severe housing cost burden 54.20248941
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Uncrowded housing 83.16437829
Health Outcomes —
Insured adults 89.59322469
Arthritis 0.0
Asthma ER Admissions 89.7
High Blood Pressure 0.0
Cancer (excluding skin) 0.0
Asthma 0.0
Coronary Heart Disease 0.0
Chronic Obstructive Pulmonary Disease 0.0
Diagnosed Diabetes 0.0
Life Expectancy at Birth 87.6
Cognitively Disabled 60.3
Physically Disabled 86.7
Heart Attack ER Admissions 70.3
Mental Health Not Good 0.0
Chronic Kidney Disease 0.0
Obesity 0.0
Pedestrian Injuries 19.6
Physical Health Not Good 0.0
Stroke 0.0
Health Risk Behaviors —
Binge Drinking 0.0
Current Smoker 0.0
No Leisure Time for Physical Activity 0.0
Climate Change Exposures —
Wildfire Risk 0.0
SLR Inundation Area 19.2
Hellman Solar PV Project Detailed Report, 7/13/2025
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Children 95.4
Elderly 10.4
English Speaking 98.1
Foreign-born 4.6
Outdoor Workers 93.2
Climate Change Adaptive Capacity —
Impervious Surface Cover 30.4
Traffic Density 43.9
Traffic Access 23.0
Other Indices —
Hardship 11.8
Other Decision Support —
2016 Voting 93.7

7.3. Overall Health & Equity Scores
Metric Result for Project Census Tract
CalEnviroScreen 4.0 Score for Project Location (a) 23.0 Healthy Places Index Score for Project Location (b) 92.0 Project Located in a Designated Disadvantaged Community (Senate Bill 535) No Project Located in a Low-Income Community (Assembly Bill 1550) No Project Located in a Community Air Protection Program Community (Assembly Bill 617) No a: The maximum CalEnviroScreen score is 100. A high score (i.e., greater than 50) reflects a higher pollution burden compared to other census tracts in the state. b: The maximum Health Places Index score is 100. A high score (i.e., greater than 50) reflects healthier community conditions compared to other census tracts in the state.

7.4. Health & Equity Measures
No Health & Equity Measures selected.

7.5. Evaluation Scorecard
Health & Equity Evaluation Scorecard not completed.

Hellman Solar PV Project Detailed Report, 7/13/2025
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7.6. Health & Equity Custom Measures
No Health & Equity Custom Measures created.

8. User Changes to Default Data
Screen Justification
Characteristics: Utility Information This is the gas company that supplies gas to Hellman Property Land Use This is a solar PV Project that is on an 5-acre site. There are no buildings associated with the project.

Construction: Construction Phases For the solar PV Project these are the defined tasks.

Construction: Off-Road Equipment Equipment list and quantity of each type by task based upon data provided by contractor.

Construction: Dust From Material Movement Site has limited grading. Only needed for removal of vegetation. Site is level.

Construction: On-Road Fugitive Dust The main entrance road to the Hellman facility is paved. Estimated 50% of onsite travel on unpaved roads.

Construction: Architectural Coatings Project involves no architectural coating work.

Construction: Trips and VMT Number of workers and trucks based upon construction estimates for each phase. Increase worker and vendor trip length to 20 miles one way.

Operations: Vehicle Data Minimal operational support is needed. Daily checks of equipment would be done by existing Hellman staff. Occasional technical maintenance and washing of panels would be needed. A conservative estimate has been one weekday trip per day.

Operations: Water and Waste Water Estimated that about 1,500 gallons of water would be needed to wash the panels, which would be done once per year.

Operations: Architectural Coatings The project has no architectural coatings Appendix F
Biological Technical Report

BIOLOGICAL TECHNICAL REPORT
FOR

HELLMAN PROPERTY SOLAR PANEL ARRAY

LOCATED IN THE CITY OF SEAL BEACH,

ORANGE COUNTY, CALIFORNIA
Prepared For:

Hellman Properties LLC
P.O. Box 2398
Seal Beach, California 90740
Contact: Devon Shea
Phone: (562) 431-6022 ext. 101
Prepared By:

Glenn Lukos Associates, Inc.
1940 E. Deere Avenue, Suite 250
Santa Ana, California 92705
Phone: (949) 837-0404
Contacts: Tony Bomkamp, Erin Trung
OCTOBER 2023
ii

INFORMATION SUMMARY
A. Report Date: October 12, 2023
B. Report Title: Biological Technical Report for Hellman Property Solar Panel Array
C. Project Site
Location: Seal Beach, Orange County
D. Owner/Applicant: Hellman Properties LLC
Devon Shay, Business Manager
P.O. Box 2398
Seal Beach, California 90740
Phone: (562) 431-6022 ext. 101
Email: [email protected]
E. Principal
Investigator: Glenn Lukos Associates, Inc.
1940 E. Deere Avenue, Suite 250
Santa Ana, California 92705
Phone: (949) 837-0404
Report Preparer: Erin Trung
F. Individuals Conducting Fieldwork: Tony Bomkamp, Erin Trung, Brittany Gale, David Moskovitz
iii

TABLE OF CONTENTS
Page #

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

1.1 Background and Scope of Work ...................................................................................... 1

1.2 Project Location ............................................................................................................... 1

1.3 Project Description ........................................................................................................... 2

2.0 METHODOLOGY ...............................................................................................................2

2.1 Botanical Resources ......................................................................................................... 3

2.2 Wildlife Resources ........................................................................................................... 5

2.3 Jurisdictional Waters ........................................................................................................ 7

3.0 REGULATORY SETTING ..................................................................................................8

3.1 Endangered Species Acts ................................................................................................. 8

3.2 California Environmental Quality Act ........................................................................... 10

3.3 Jurisdictional Waters ...................................................................................................... 13

4.0 RESULTS ...........................................................................................................................18

4.1 Existing Conditions ........................................................................................................ 18

4.2 Vegetation Mapping ....................................................................................................... 19

4.3 Special-Status Vegetation Communities ........................................................................ 22

4.4 Special-Status Plants ...................................................................................................... 23

4.5 Special-Status Animals .................................................................................................. 28

4.6 Nesting Birds .................................................................................................................. 39

4.7 Wildlife Linkages/ Corridors and Nursery Sites ............................................................ 39

4.8 Critical Habitat ............................................................................................................... 40

4.9 Jurisdictional Waters ...................................................................................................... 40

5.0 IMPACT ANALYSIS .........................................................................................................41

5.1 California Environmental Quality Act (CEQA)............................................................. 41

5.2 Special-Status Species .................................................................................................... 43

5.3 Sensitive Vegetation Communities ................................................................................ 45

5.4 Wetlands ......................................................................................................................... 46

5.5 Wildlife Movement and Native Wildlife Nursery Sites ................................................. 46

5.6 Local Policies or Ordinances.......................................................................................... 47

5.7 Habitat Conservation Plans ............................................................................................ 47

5.8 Jurisdictional Waters ...................................................................................................... 47 iv

5.9 Indirect Impacts to Biological Resources....................................................................... 47

6.0 MITIGATION/AVOIDANCE MEASURES .....................................................................49

6.1 Nesting Birds.................................................................................................................. 49

6.2 Burrowing Owl............................................................................................................... 49

6.3 Special-Status Plants...................................................................................................... 49

6.4 Least Bell’s Vireo........................................................................................................... 51

7.0 REFERENCES ...................................................................................................................52

8.0 CERTIFICATION ..............................................................................................................54 TABLES
Table 2-1. Summary of Biological Surveys for the Project Site.....................................................3 Table 2-2. Summary of Wandering Skipper Surveys.....................................................................7 Table 3-1. CRPR Ranks 1, 2, 3, & 4, and Threat Code Extensions..............................................12 Table 4-1. Summary of Vegetation/Land Use Types for the Study Area.....................................19 Table 4-2. Special-Status Plants Evaluated for the Study Area....................................................23 Table 4-3. Special-Status Animals Evaluated for the Study Area ................................................29 Table 5-1. Summary of Permanent and Temporary Vegetation/Land Use Impacts.....................45

EXHIBITS
Exhibit 1 Regional Map
Exhibit 2 Vicinity Map
Exhibit 3 Site Plan
Exhibit 4 Jurisdictional Determination Map
Exhibit 5 Soils Map
Exhibit 6a Vegetation Map
Exhibit 6b Vegetation Impact Map
Exhibit 7 Site Photographs
Exhibit 8a Special-Status Species Map
Exhibit 8b Southern Tarplant Locations Map
Exhibit 9 Special-Status Species Impact Map

APPENDICES
Appendix A Floral Compendium
Appendix B Faunal Compendium
Appendix C Jurisdictional Delineation Report
Appendix D Southern Tarplant Mitigation and Monitoring Plan for Hellman Property Solar Panel Array
1 1.0 INTRODUCTION

1.1 Background and Scope of Work
This document provides the results of general biological surveys and focused biological surveys for the approximately 4.57-acre Solar Panel Array (the Project) located in the City of Seal Beach, Orange County, California. This report identifies and evaluates impacts to biological resources associated with the proposed Project in the context of the California Environmental Quality Act (CEQA), and State and Federal regulations such as the California Coastal Act (CCA), Endangered Species Act (ESA), Clean Water Act (CWA), and the California Fish and Game Code.

The scope of this report includes a discussion of existing conditions for the approximately 4.57- acre Project site that is contained within a larger 12.46-acre Study Area, all methods employed regarding the general biological surveys and focused biological surveys, the documentation of botanical and wildlife resources identified (including special-status species), and an analysis of impacts to biological resources. Methods of the study include a review of relevant literature, field surveys, and a Geographical Information System (GIS)-based analysis of vegetation communities. As appropriate, this report is consistent with accepted scientific and technical standards and survey guideline requirements issued by the U.S. Fish and Wildlife Service (USFWS), the California Department of Fish and Wildlife (CDFW), the California Native Plant Society (CNPS), and other applicable agencies/organizations.

The field study focused on a number of primary objectives that would comply with CEQA, including (1) general reconnaissance survey and vegetation mapping; (2) general biological surveys; (3) habitat assessments and focused surveys for special-status plant species; (4) habitat assessments and focused surveys for special-status wildlife species; (5) assessment for the presence of wildlife migration and colonial nursery sites; (6) assessments for wetlands and environmentally sensitive habitat areas (ESHA) pursuant to the CCA; and (7) assessments for areas subject to the jurisdiction of the U.S. Army Corps of Engineers (Corps) jurisdiction pursuant to Section 404 of the Clean Water Act, State Water Quality Control Board pursuant to Section 401 of the Clean Water Act, and CDFW jurisdiction pursuant to Division 2, Chapter 6, Section 1600–1616 of the California Fish and Game Code. Observations of all plant and wildlife species were recorded during the biological studies and are included as Appendix A: Floral Compendium and Appendix B: Faunal Compendium.

1.2 Project Location
The Project site comprises approximately 4.57 acres in the City of Seal Beach, Orange County, California [Exhibit 1 – Regional Map] and is located within Sections 11 and 12 of Township 5 South, Range 12 West of the U.S. Geological Survey (USGS) 7.5-minute quadrangle map Los Alamitos, California [Exhibit 2 – Vicinity Map]. The Project site is located in the Hellman Property, which is an active oil field with a network of earthen roads, active oil wells, oil and gas storage tanks, and associated infrastructure. The Project site is located in the northeastern portion of the Hellman Property and is bordered by the Los Alamitos Retarding Basin to the north, a water quality basin associated with the Heron Pointe residential development to the east, and 2 active oil fields to the south and west. A portion of the Los Cerritos Wetlands, which was formerly part of the Hellman Property, is located to the south and west beyond the active oil field.

1.3 Project Description
The proposed project consists of the installation of a 1.5MW fixed-tilt ground mounted solar photovoltaic system. This system will interconnect with the Hellman Property's electrical infrastructure and operate in parallel with the utility grid to provide sustainable clean energy in support of the facilities operations. The system features 3 arrays with a total of 56 low profile table structures supported by piles with concrete foundations.

For this report, the term “Project site” is defined as that area proposed for direct impact by the proposed Project and totals 4.57 acres [Exhibit 3]. The 4.57-acre Project site includes a 2.66-acre permanent impact area and a 1.91-acre temporary impact area consisting of staging and temporary work areas. The term “Study Area” is defined as all portions of the Project site, a 100- foot buffer beyond the Project site that was included in the analysis in accordance with the requirements of the Coastal Act and the Seal Beach Local Coastal Program (LCP), and additional areas beyond the 100-foot buffer that support sensitive biological resources [Exhibit 3]. The Study Area totals 12.46 acres.

It should be noted that an access road for and a portion of the Los Alamitos Retarding Basin are located within the 100-foot buffer as depicted by Exhibit 3; however, the biological resources in these areas were not mapped or surveyed for this analysis, and these areas are not included in the Study Area.

2.0 METHODOLOGY
In order to adequately identify biological resources in accordance with the requirements of CEQA, Glenn Lukos Associates (GLA) assembled biological data consisting of the following main components:
• Delineation of aquatic resources (including wetlands and riparian habitat) subject to the jurisdiction of the U.S. Army Corps of Engineers (Corps), Regional Water Quality Control Board (Regional Board), CDFW, and also wetlands as defined by the California Coastal Act
• Performance of vegetation mapping for the Project site • Performance of habitat assessments and site-specific biological surveys to evaluate the potential presence/absence of special-status species in accordance with the requirements of CEQA
• Performance of focused surveys for rare plants and wildlife.

The focus of the biological surveys was determined through initial site reconnaissance, a review of the California Natural Diversity Database CNDDB (CDFW 2022), CNPS 9th edition online inventory (CNPS 2022), Natural Resource Conservation Service soil data (NRCS 2022), other 3 pertinent literature, knowledge of the region, and GLA’s extensive knowledge of the Hellman Property. Site-specific general surveys within the Project site and the surrounding buffer area were conducted on foot in the proposed development areas for each target plant or animal species identified below. Table 2-1 provides a summary list of survey dates, survey types and personnel.

Table 2-1. Summary of Biological Surveys for the Project Site Survey Type Survey Dates Biologist(s)
General Biological Survey July 29, August 4, 2022 TB, ET Vegetation Mapping July 29, August 4,
August 25, October 25 2022

TB, ET, BG
Focused Botanical Surveys July 29, August 4, 2022
February 17, March 7, 2023

TB, ET, DM
Survey for Least Bell’s Vireo July 29, August 4,
August 25, 2022
TB, ET
Wandering Skipper Focused
Surveys
July 29, August 4,
August 25, 2022
TB, ET
Assessment for Federal and
State Jurisdictional Waters and
Coastal Act Wetlands
August 25, October 25, 2022
March 6, 2023

TB, ET, BG
TB = Tony Bomkamp, ET = Erin Trung, BG = Brittany Gale, DM = David Moskovitz Individual plants and wildlife species were evaluated in this report based on their special status.

For this report, plants were considered special status based on one or more of the following criteria:
• Listing through the Federal and/or State Endangered Species Act (ESA); and/or • CNPS California Rare Plant Rank 1A, 1B, 2A, 2B, 3, or 4.

Wildlife species were considered special status based on one or more of the following criteria:
• Listing through the Federal and/or State ESA; and
• Designation by the State as a Species of Special Concern (SSC) or Fully Protected (FP) species.

Vegetation communities and habitats were considered special status based on one or more of the following criteria:
• Global (G) and/or State (S) ranking of category 3 or less based on CDFW (see Section

3.2.2 below for further explanation)/

2.1 Botanical Resources
A site-specific survey program was designed to accurately document the botanical resources within the Project site, and consisted of five components: (1) a literature search; (2) preparation 4 of a list of target special-status plant species and sensitive vegetation communities that could occur within the Project site; (3) general field reconnaissance survey(s); (4) vegetation mapping according to the List of Vegetation Alliances and Associations; and (5) habitat assessments and focused surveys for special-status plants.

2.1.1 Literature Search
Prior to conducting fieldwork, pertinent literature on the flora of the region was examined. A thorough archival review was conducted using available literature and other historical records.

These resources included the following:
• California Native Plant Society, Rare Plant Program. Inventory of Rare and Endangered Plants of California (online edition, v-9.5, CNPS 2023) • CNDDB for the Los Alamitos, California USGS 7.5-minute quadrangle and surrounding six quadrangles (CDFW 2023)
The literature review also included biological studies previously conducted for the Hellman Property and adjacent Los Cerritos Wetlands:
• Raptor Foraging Habitat Assessment at Hellman Ranch (GLA 2001) • Biological Technical Report, Hellman Ranch Tank Farm Relocation Project (GLA 2006) • Biological Technical Report for Proposed Hellman Gas Plant Project (GLA 2018) • Los Cerritos Wetlands Habitat Assessment Report: Habitat Types & Special Status Species (Tidal Influence 2012)

2.1.2 Vegetation Mapping
Vegetation communities within the Project site were mapped according to the “Membership Rules” of the List of Vegetation Alliances and Associations (or Natural Communities List). The list is based on A Manual of California Vegetation, Second Edition or MCVII, which is the California expression of the National Vegetation Classification. Where necessary, deviations were made when areas did not fit into exact vegetation descriptions (membership rules). Nonconforming vegetation alliances or cover types were named based on the dominant plant species present. Plant communities were mapped in the field directly onto a 100-scale (1″=100′) aerial photograph.

2.1.3 Special-Status Plant Species and Habitats Evaluated for the Project Site Based on the information compiled from the literature search, vegetation profiles and a list of target sensitive plant species and habitats that could occur within the Project site were developed and incorporated into a mapping and survey program to achieve the following goals: (1) characterize the vegetation associations and land use; (2) prepare a detailed floristic compendium; (3) identify the potential for any special-status plants that may occur within the Project site; and (4) prepare a map showing the distribution of any sensitive botanical resources associated with the Project site, if applicable.
5 2.1.4 Botanical Surveys
GLA biologists Tony Bomkamp and Erin Trung visited the site on July 29, and August 4, 2022, and Erin Trung and David Moskovitz visited the site on February 17 and March 6, 2023, to conduct general and focused plant survey(s). Southern tarplant was censused and mapped during 2022 surveys, and Coulter’s goldfields was mapped during 2023 surveys. Survey(s) were conducted in accordance with accepted botanical survey guidelines (Nelson 1984, USFWS 2000, CNPS 2001, CDFW 2018). As applicable, survey(s) were conducted at appropriate times based on precipitation and flowering periods. An aerial photograph, a soil map, and/or a topographic map were used to determine the community types and other physical features that may support sensitive and uncommon taxa or communities within the Project site. Survey(s) were conducted by following meandering transects within target areas of suitable habitat. All plant species encountered during the field survey(s) were identified and recorded following the abovereferenced guidelines. A complete list of the plant species observed is provided in Appendix A.

Scientific nomenclature and common names used in this report follow Baldwin et al. (2012) and Munz (1974).

2.2 Wildlife Resources
Wildlife species were evaluated and detected during the field survey(s) by sight, call, tracks, and scat. Site reconnaissance was conducted in such a manner as to allow inspection of the entire Project site by direct observation, including the use of binoculars. Observations of physical evidence and direct sightings of wildlife were recorded in field notes during the visit(s). A complete list of wildlife species observed within the Project site is provided in Appendix B.

Scientific nomenclature and common names for vertebrate species referred to in this report follow the Complete List of Amphibian, Reptile, Bird, and Mammal Species in California (CDFW 2016), Standard Common and Scientific Names for North American Amphibians, Turtles, Reptiles, and Crocodilians 6th Edition, Collins and Taggart (2009) for amphibians and reptiles, and the American Ornithological Society Checklist of Middle and North American Birds (Chesser et al. 2022) for birds. The methodology (including any applicable survey protocols) utilized to conduct general survey(s), habitat assessment(s), and/or focused surveys for special-status animals are included below.

2.2.1 General Surveys
Birds
During the general biological and reconnaissance survey within the Project site, birds were identified incidentally within each habitat type. Birds were detected by both direct observation and by vocalizations and were recorded in field notes.

Mammals
During general biological and reconnaissance survey within the Project site, mammals were identified incidentally within each habitat type. Mammals were detected both by direct observations and by the presence of diagnostic sign (i.e., tracks, burrows, scat, etc.). 6 Reptiles and Amphibians
During general biological and reconnaissance surveys within the Project site, reptiles and amphibians were identified incidentally during surveys within each habitat type. Habitats were examined for diagnostic reptile sign, which include shed skins, scat, tracks, snake prints, and lizard tail drag marks. All reptiles and amphibian species observed, as well as diagnostic sign, were recorded in field notes.

2.2.2 Special-Status Animal Species Evaluated for the Project Site A literature search was conducted to obtain a list of special-status wildlife species with the potential to occur within the Project site. Species were evaluated based on two factors: 1) species identified by the CNDDB as occurring (either currently or historically) on or in vicinity of the Project site, and 2) any other special-status animals that are known to occur within the vicinity of the Project site, or for which potentially suitable habitat occurs on the Project site.

2.2.3 Habitat Assessment for Special-Status Animal Species GLA biologist(s) Tony Bomkamp and Erin Trung conducted habitat assessments for specialstatus animal species on July 29, 2022. An aerial photograph, soil map and/or topographic map were used to determine the community types and other physical features that may support special-status and uncommon taxa within the Project site.

2.2.4 Focused Surveys for Special-Status Animals Species Wandering Skipper
GLA biologists Tony Bomkamp and Erin Trung conducted focused surveys for wandering skipper (Panoquina errans) within areas of potentially suitable habitat in the Study Area.

Focused surveys were conducted because this species is known from the Los Cerritos Wetlands (Tidal Influence 2012). There is no official survey protocol for wandering skipper, so surveys were conducted based on USFWS protocols for other skipper species. The Study Area was assessed for the presence of the larval host plant, salt grass (Distichlis spicata), and for nectar plants, which can include alkali heath (Frankenia salina), alkali heliotrope (Heliotropium curassivicum), and brassicas such as summer mustard (Hirschfeldia incana) and wild radish (Raphanus sativa). In areas of potentially suitable habitat, which consists of salt grass interspersed with or bordered by nectar plants, transects were slowly and methodically walked with frequent stops for observation, including with the use of binoculars. Three survey visits were conducted during the flight period, which begins as early as March and ends as late as November, but typically occurs June to September. Surveys were conducted between 9:00 am and 12:00 pm, with wind speeds less than 10 mph, and temperatures between 65° and 80°F. 7 Table 2-2. Summary of Wandering Skipper Surveys
Survey Date Biologist(s) Start/End Time Start/End
Temperature
(°F)
Start/End
Wind Speed
(mph)
Cloud Cover
07/29/22 TB, ET 0830/0950 70°/75° 0mph/5mph clear
08/04/22 TB 0800/1000 68°/70° 2mph/3mph clear
08/25/22 TB, ET 0800/0950 74°/78° 0mph/5mph clear
TB = Tony Bomkamp, ET = Erin Trung
Least Bell’s Vireo
GLA biologists Tony Bomkamp and Erin Trung conducted surveys for the least Bell’s vireo in the adjacent, offsite Heron Pointe detention basin, a portion of which is located in the 100-foot buffer. The basin supports a mix of willow forest, willow scrub and mulefat scrub that exhibits potential for supporting the state and federally listed migratory songbird. GLA previously observed this species within the willow and mulefat habitat during surveys in the basin for an unrelated maintenance project by the Heron Pointe HOA in 2019. Based on the previous observation, GLA biologists conducted informal surveys on July 29, August 4, and August 25, 2022, between 0700 and 0800 to determine potential presence/absence. As noted in Table 2-2 above, conditions were suitable for detection of this species. USFWS survey guidelines, which require eight survey visits during the time period from April 10 to July 31, were not followed because 1) presence/absence was able to be determined with a shortened, informal protocol, and 2) precise mapping of least Bell’s vireo breeding territories was not necessary because the Heron Pointe detention basin is not within the Project site and the Project will not result in take of least Bell’s vireo or impacts to its habitat.

2.3 Jurisdictional Waters
The Study area was evaluated to identify the limits of jurisdictional waters, including waters of the U.S. (including wetlands) subject to the jurisdiction of the Corps and Regional Board, waters of the State (including riparian vegetation) subject to the jurisdiction of CDFW, and wetlands as defined under the California Coastal Act. Prior to beginning the field delineation, a 100-scale color aerial photograph, a soils map, and the previously cited USGS topographic maps were examined to determine the locations of potential areas of Corps/CDFW jurisdiction. Suspected jurisdictional areas were field checked for the presence of definable channels and/or wetland vegetation, soils and hydrology. Potential wetland habitats at the subject site were evaluated using the methodology set forth in the U.S. Army Corps of Engineers 1987 Wetland Delineation Manual (Wetland Manual) and the 2008 Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Arid West Supplement (Arid West Supplement). Reference was also made to the 2019 State Wetland Definition and Procedures for Discharges of Dredged or Fill Material to Waters of the State (State Board Wetland Definition and Procedures) to identify suspected State wetland habitats as regulated by the Regional Board. While in the field, the locations where data was collected were recorded with a sub-meter Trimble GPS device in conjunction with a color aerial photograph using visible landmarks. 8 For purposes of the jurisdictional delineation, the site was separated into a “western field” and “eastern field” as depicted on Exhibit 4. In order to eliminate sampling bias, data collection points for potential wetland hydrology, soils, and vegetation in the western field were located along four transects in a rough grid pattern. The spacing between of each of the points and between the four transects was determined using a random numbers generator [Exhibit 4 – Jurisdictional Determination Map].

A portion of the 100-foot buffer adjacent to the eastern field extends into the water quality basin associated with the Heron Pointe residential development [Exhibit 4]. This basin is vegetated with riparian vegetation and may contain areas with wetland hydrology and/or hydric soil indicators. However, because it is a constructed water quality basin, is not part of the Hellman Property, and would not be impacted by the proposed project, it was not included in the jurisdictional assessment.

3.0 REGULATORY SETTING
The proposed Project is subject to state and federal laws and regulations associated with a number of regulatory programs. These programs often overlap and were developed to protect natural resources, including state and federally listed plants and animals; aquatic resources including rivers and creeks, ephemeral streambeds, wetlands, and areas of riparian habitat; special-status species which are not listed as threatened or endangered by the state or federal governments; and special-status vegetation communities.

3.1 Endangered Species Acts

3.1.1 California Endangered Species Act
California’s Endangered Species Act (CESA) defines an endangered species as “a native species or subspecies of a bird, mammal, fish, amphibian, reptile, or plant which is in serious danger of becoming extinct throughout all, or a significant portion, of its range due to one or more causes, including loss of habitat, change in habitat, overexploitation, predation, competition, or disease.” The State defines a threatened species as “a native species or subspecies of a bird, mammal, fish, amphibian, reptile, or plant that, although not presently threatened with extinction, is likely to become an endangered species in the foreseeable future in the absence of the special protection and management efforts required by this chapter. Any animal determined by the commission as rare on or before January 1, 1985 is a threatened species.” Candidate species are defined as “a native species or subspecies of a bird, mammal, fish, amphibian, reptile, or plant that the commission has formally noticed as being under review by the department for addition to either the list of endangered species or the list of threatened species, or a species for which the commission has published a notice of proposed regulation to add the species to either list.” Candidate species may be afforded temporary protection as though they were already listed as threatened or endangered at the discretion of the Fish and Game Commission.

Article 3, Sections 2080 through 2085, of the CESA addresses the taking of threatened, endangered, or candidate species by stating “No person shall import into this state, export out of this state, or take, possess, purchase, or sell within this state, any species, or any part or product 9 thereof, that the commission determines to be an endangered species or a threatened species, or attempt any of those acts, except as otherwise provided.” Under the CESA, “take” is defined as “hunt, pursue, catch, capture, or kill, or attempt to hunt, pursue, catch, capture, or kill.” Exceptions authorized by the state to allow “take” require permits or memoranda of understanding and can be authorized for endangered species, threatened species, or candidate species for scientific, educational, or management purposes and for take incidental to otherwise lawful activities. Sections 1901 and 1913 of the California Fish and Game Code provide that notification is required prior to disturbance.

3.1.2 Federal Endangered Species Act
The FESA of 1973 defines an endangered species as “any species that is in danger of extinction throughout all or a significant portion of its range.” A threatened species is defined as “any species that is likely to become an endangered species within the foreseeable future throughout all or a significant portion of its range.” Under provisions of Section 9(a)(1)(B) of the FESA it is unlawful to “take” any listed species. “Take” is defined in Section 3(18) of FESA: “...harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or to attempt to engage in any such conduct.” Further, the USFWS, through regulation, has interpreted the terms “harm” and “harass” to include certain types of habitat modification that result in injury to, or death of species as forms of “take.” These interpretations, however, are generally considered and applied on a case-by-case basis and often vary from species to species. In a case where a property owner seeks permission from a federal agency for an action that could affect a federally listed plant and animal species, the property owner and agency are required to consult with USFWS. Section 9(a)(2)(b) of the FESA addresses the protections afforded to listed plants.

3.1.3 State and Federal Take Authorizations
Federal or state authorizations of impacts to or incidental take of a listed species by a private individual or other private entity would be granted in one of the following ways:
• Section 7 of the FESA stipulates that any federal action that may affect a species listed as threatened or endangered requires a formal consultation with USFWS to ensure that the action is not likely to jeopardize the continued existence of the listed species or result in destruction or adverse modification of designated critical habitat. 16 U.S.C. 1536(a)(2). • In 1982, the FESA was amended to give private landowners the ability to develop Habitat Conservation Plans (HCP) pursuant to Section 10(a) of the FESA. Upon development of an HCP, the USFWS can issue incidental take permits for listed species where the HCP specifies at minimum, the following: (1) the level of impact that will result from the taking, (2) steps that will minimize and mitigate the impacts, (3) funding necessary to implement the plan, (4) alternative actions to the taking considered by the applicant and the reasons why such alternatives were not chosen, and (5) such other measures that the Secretary of the Interior may require as being necessary or appropriate for the plan. • In certain circumstances, Section 2080.1 of the California Fish and Game Code allows CDFW to adopt the federal incidental take statement or the 10(a) permit as its own based on its findings that the federal permit adequately protects the species under state law. 10 3.2 California Environmental Quality Act

3.2.1 CEQA Guidelines Section 15380
CEQA requires evaluation of a project’s impacts on biological resources and provides guidelines and thresholds for use by lead agencies for evaluating the significance of proposed impacts.

Sections 5.1.1 and 5.2.2 below set forth these thresholds and guidelines. Furthermore, pursuant to the CEQA Guidelines Section 15380, CEQA provides protection for non-listed species that could potentially meet the criteria for state listing. For plants, CDFW recognizes that plants with a California Rare Plant Rank (CRPR) of 1A, 1B, or 2 in the CNPS Inventory of Rare and Endangered Plants in California may meet the criteria for listing and should be considered under CEQA. CDFW also recommends protection of plants that are regionally important, such as locally rare species, disjunct populations of more common plants, or plants CNPS Ranked 3 or 4.

3.2.2 Special-Status Plants, Wildlife and Vegetation Communities Evaluated Under CEQA
Federally Designated Special-Status Species
Within recent years, the USFWS instituted changes in the listing status of candidate species.

Former C1 (candidate) species are now referred to simply as candidate species and represent the only candidates for listing. Former C2 species (for which the USFWS had insufficient evidence to warrant listing) and C3 species (either extinct, no longer a valid taxon or more abundant than was formerly believed) are no longer considered as candidate species. Therefore, these species are no longer maintained in list form by the USFWS, nor are they formally protected. This term is employed in this document but carries no official protections. All references to federally protected species in this report (whether listed, proposed for listing, or candidate) include the most current published status or candidate category to which each species has been assigned by USFWS.

For this report the following acronyms are used for federal special-status species:
• FE Federally listed as Endangered
• FT Federally listed as Threatened
• FPE Federally proposed for listing as Endangered
• FPT Federally proposed for listing as Threatened
• FC Federal Candidate Species (former C1 species)
State-Designated Special-Status Species
Some mammals and birds are protected by the state as Fully Protected (SFP) Mammals or Fully Protected Birds, as described in the California Fish and Game Code, Sections 4700 and 3511, respectively. California SSC are designated as vulnerable to extinction due to declining population levels, limited ranges, and/or continuing threats. This list is primarily a working document for the CDFW’s CNDDB project. Informally listed taxa are not protected but warrant 11 consideration in the preparation of biotic assessments. For some species, the CNDDB is only concerned with specific portions of the life history, such as roosts, rookeries, or nest sites.

For this report the following acronyms are used for State special-status species:
• SE State-listed as Endangered
• ST State-listed as Threatened
• SR State-listed as Rare
• SCE State Candidate for listing as Endangered
• SCT State Candidate for listing as Threatened
• FP State Fully Protected
• SSC State Species of Special Concern
CNDDB Global/State Rankings
The CNDDB provides global and state rankings for species and communities based on a system developed by The Nature Conservancy to measure rarity of a species. The ranking provides a shorthand formula about how rare a species/community is and is based on the best information available from multiple sources, including state and federal listings, and other groups that recognize species as sensitive (e.g., Bureau of Land Management, Audubon Society, etc.). State and global rankings are used to prioritize conservation and protection efforts so that the rarest species/communities receive immediate attention. In both cases, the lower ranking (i.e., G1 or S1) indicates extreme rarity. Rare species are given a ranking from 1 to 3. Species with a ranking of 4 or 5 is considered to be common. If the exact global/state ranking is undetermined, a range is generally provided. For example, a global ranking of “G1G3” indicates that a species/community global rarity is between G1 and G3. If the animal being considered is a subspecies of a broader species, a “T” ranking is attached to the global ranking. The following are descriptions of global and state rankings:

Global Rankings
• G1 – Critically imperiled globally because of extreme rarity (5 or fewer occurrences), or because of some factor(s) making it especially vulnerable to extinction. • G2 – Imperiled globally because of rarity (6-20 occurrences), or because of some other factor(s) making it very vulnerable to extinction throughout its range. • G3 – Either very rare and local throughout its range (21 to 100 occurrences) or found locally (even abundantly at some of its locations) in a restricted range (e.g., a physiographic region), or because of some other factor(s) making it vulnerable to extinction throughout its range.
• G4 – Uncommon but not rare; some cause for long-term concern due to declines or other factors.
• G5 – Common, widespread, and abundant.
12 State Rankings
• S1 – Extremely rare; typically 5 or fewer known occurrences in the state; or only a few remaining individuals; may be especially vulnerable to extirpation. • S2 – Very rare; typically between 6 and 20 known occurrences; may be susceptible to becoming extirpated.
• S3 – Rare to uncommon; typically 21 to 50 known occurrences; S3 ranked species are not yet susceptible to becoming extirpated in the state but may be if additional populations are destroyed.
• S4 – Uncommon but not rare; some cause for long-term concern due to declines or other factors.
• S5 – Common, widespread, and abundant in the state.

California Native Plant Society/CNDDB California Rare Plant Ranks CNPS is a private plant conservation organization dedicated to the monitoring and protection of sensitive species in California. In a collaborative effort with CDFW’s CNDDB Project, the CNPS Ninth Edition Inventory of Rare and Endangered Plants of California categorizes plants of interest into six California Rare Plant Ranks (CRPR) based on their geographic distribution and potential threats to existing populations. The CNPS Inventory is used by CDFW as the candidate species list for plants that may be listed as state Threatened and Endangered. The six categories of rarity are summarized in Table 3-1.

Table 3-1. CRPR Ranks 1, 2, 3, & 4, and Threat Code Extensions CRPR Rank Comments
Rank 1A – Plants Presumed
Extirpated in California and
Either Rare or Extinct
Elsewhere
Thought to be extinct in California based on a lack of observation or detection for many years.

Rank 1B – Plants Rare,
Threatened, or Endangered in
California and Elsewhere
Species, which are generally rare throughout their range that are also judged to be vulnerable to other threats such as declining habitat.

Rank 2A – Plants presumed
Extirpated in California, But
Common Elsewhere
Species that are presumed extinct in California but more common outside of California
Rank 2B – Plants Rare,
Threatened or Endangered in
California, But More
Common Elsewhere
Species that are rare in California but more common outside of California
Rank 3 – Plants About Which
More Information Is Needed
(A Review List)
Species that are thought to be rare or in decline but CNPS lacks the information needed to assign to the appropriate list. In most instances, the extent of surveys for these species is not sufficient to allow CNPS to accurately assess whether these species should be assigned to a specific rank. In addition, many of the Rank 3 species have associated taxonomic problems such that the validity of their current taxonomy is unclear.
13 CRPR Rank Comments
Rank 4 – Plants of Limited
Distribution (A Watch List)
Species that are currently thought to be limited in distribution or range whose vulnerability or susceptibility to threat is currently low. In some cases, as noted above for Rank 3 species, CNPS lacks survey data to accurately determine status in California. Many species have been placed on Rank 4 in previous editions of the “Inventory” and have been removed as survey data has indicated that the species are more common than previously thought. CNPS recommends that species currently included on this list should be monitored to ensure that future substantial declines are minimized.

Extension Comments
.1 – Seriously endangered in
California
Species with over 80% of occurrences threatened and/or have a high degree and immediacy of threat.
.2 – Fairly endangered in
California
Species with 20-80% of occurrences threatened.
.3 – Not very endangered in
California
Species with <20% of occurrences threatened or with no current threats known.

3.3 Jurisdictional Waters

3.3.1 Army Corps of Engineers
Pursuant to Section 404 of the Clean Water Act, the Corps regulates the discharge of dredged and/or fill material into waters of the United States. The term “waters of the United States” is defined in Corps regulations at 33 CFR Part 328.3(a) as:
(1) Waters which are:
(i) Currently used, or were used in the past, or may be susceptible to use in interstate or foreign commerce, including all waters which are subject to the ebb and flow of the tide;
(ii) The territorial seas; or
(iii) Interstate waters;
(2) Impoundments of waters otherwise defined as waters of the United States under this definition, other than impoundments of waters identified under paragraph (a)(5) of this section;
(3) Tributaries of waters identified in paragraphs (a)(1) or (2) of this section that are relatively permanent, standing or continuously flowing bodies of water; (4) Wetlands adjacent to the following waters:
(i) Waters identified in paragraph (a)(1) of this section; or (ii) Relatively permanent, standing or continuously flowing bodies of water identified in paragraph (a)(2) or (a)(3) of this section and with a continuous surface connection to those waters;
(5) Intrastate lakes and ponds not identified in paragraphs (a)(1) through (4) of this section that are relatively permanent, standing or continuously flowing bodies of water with a continuous surface connection to the waters identified in paragraph (a)(1) or (a)(3) of this section.
14 Corps regulations at 33 CFR Part 328.3(b) exclude the following from being “waters of the United States” even where they otherwise meet the terms of paragraphs (a)(2) through (5) above:
(1) Waste treatment systems, including treatment ponds or lagoons, designed to meet the requirements of the Clean Water Act;
(2) Prior converted cropland designated by the Secretary of Agriculture. The exclusion would cease upon a change of use, which means that the area is no longer available for the production of agricultural commodities.

Notwithstanding the determination of an area’s status as prior converted cropland by any other Federal agency, for the purposes of the Clean Water Act, the final authority regarding Clean Water Act jurisdiction remains with EPA;
(3) Ditches (including roadside ditches) excavated wholly in and draining only dry land and that do not carry a relatively permanent flow of water; (4) Artificially irrigated areas that would revert to dry land if the irrigation ceased;
(5) Artificial lakes or ponds created by excavating or diking dry land to collect and retain water and which are used exclusively for such purposes as stock watering, irrigation, settling basins, or rice growing; (6) Artificial reflecting or swimming pools or other small ornamental bodies of water created by excavating or diking dry land to retain water for primarily aesthetic reasons;
(7) Waterfilled depressions created in dry land incidental to construction activity and pits excavated in dry land for the purpose of obtaining fill, sand, or gravel unless and until the construction or excavation operation is abandoned and the resulting body of water meets the definition of waters of the United States; and
(8) Swales and erosional features (e.g., gullies, small washes) characterized by low volume, infrequent, or short duration flow.

In the absence of wetlands, the limits of Corps jurisdiction in non-tidal waters, such as intermittent streams, extend to the OHWM which is defined at 33 CFR 328.3(c)(4) as:
...that line on the shore established by the fluctuation of water and indicated by physical characteristics such as clear, natural line impressed on the bank, shelving, changes in the character of soil, destruction of terrestrial vegetation, the presence of litter and debris, or other appropriate means that consider the characteristics of the surrounding areas.
“Adjacent” wetlands are defined by 33 CFR 328.3(c)(2) as those wetlands “having a continuous surface connection” to other waters of the United States.

Wetland Definition Pursuant to Section 404 of the Clean Water Act The term “wetlands” (a subset of “waters of the United States”) is defined at 33 CFR 328.3(c)(1) as “areas that are inundated or saturated by surface or ground water at a frequency and duration 15 sufficient to support, and that under normal circumstances do support, a prevalence of vegetation typically adapted for life in saturated soil conditions. Wetlands generally include swamps, marshes, bogs, and similar areas.” In 1987 the Corps published the Wetland Manual to guide its field personnel in determining jurisdictional wetland boundaries. The methodology set forth in the Wetland Manual and the Arid West Supplement generally require that, in order to be considered a wetland, the vegetation, soils, and hydrology of an area exhibit at least minimal hydric characteristics. While the Wetland Manual and Arid West Supplement provide great detail in methodology and allow for varying special conditions, a wetland should normally meet each of the following three criteria:
• More than 50 percent of the dominant plant species at the site must be hydrophytic in nature as published in the most current national wetland plant list; • Soils must exhibit physical and/or chemical characteristics indicative of permanent or periodic saturation (e.g., a gleyed color, or mottles with a matrix of low chroma indicating a relatively consistent fluctuation between aerobic and anaerobic conditions); and
• Whereas the Wetland Manual requires that hydrologic characteristics indicate that the ground is saturated to within 12 inches of the surface for at least five percent of the growing season during a normal rainfall year, the Arid West Supplement does not include a quantitative criteria with the exception for areas with “problematic hydrophytic vegetation”, which require a minimum of 14 days of ponding to be considered a wetland.

3.3.2 Regional Water Quality Control Board
The State Water Resource Control Board and each of its nine Regional Boards regulate the discharge of waste (dredged or fill material) into waters of the United States1 and waters of the state. Waters of the United States are defined above in Section II.A and waters of the state are defined as “any surface water or groundwater, including saline waters, within the boundaries of the state” (California Water Code 13050[e]).

Section 401 of the CWA requires certification for any federal permit or license authorizing impacts to waters of the U.S. (i.e., waters that are within federal jurisdiction), such as Section 404 of the CWA and Section 10 of the Safe Rivers and Harbors Act, to ensure that the impacts do not violate state water quality standards. When a project could impact waters outside of federal jurisdiction, the Regional Board has the authority under the Porter-Cologne Water 1 Therefore, wetlands that meet the current definition, or any historic definition, of waters of the U.S. are waters of the state. In 2000, the State Water Resources Control Board determined that all waters of the U.S. are also waters of the state by regulation, prior to any regulatory or judicial limitations on the federal definition of waters of the U.S. (California Code or Regulations title 23, section 3831(w)). This regulation has remained in effect despite subsequent changes to the federal definition. Therefore, waters of the state includes features that have been determined by the U.S. Environmental Protection Agency (U.S. EPA) or the U.S. Army Corps of Engineers (Corps) to be “waters of the U.S.” in an approved jurisdictional determination; “waters of the U.S.” identified in an aquatic resource report verified by the Corps upon which a permitting decision was based; and features that are consistent with any current or historic final judicial interpretation of “waters of the U.S.” or any current or historic federal regulation defining “waters of the U.S.” under the federal Clean Water Act. 16 Quality Control Act to issue Waste Discharge Requirements (WDRs) to ensure that impacts do not violate state water quality standards. Clean Water Act Section 401 Water Quality Certifications, WDRs, and waivers of WDRs are also referred to as orders or permits.

State Wetland Definition
The Water Boards define an area as wetland as follows: “An area is wetland if, under normal circumstances, (1) the area has continuous or recurrent saturation of the upper substrate caused by groundwater, or shallow surface water, or both; (2) the duration of such saturation is sufficient to cause anaerobic conditions in the upper substrate; and (3) the area’s vegetation is dominated by hydrophytes or the area lacks vegetation.” The following wetlands are waters of the state:

1. Natural wetlands;

2. Wetlands created by modification of a surface water of the state;2 and

3. Artificial wetlands3 that meet any of the following criteria:
a. Approved by an agency as compensatory mitigation for impacts to other waters of the state, except where the approving agency explicitly identifies the mitigation as being of limited duration;
b. Specifically identified in a water quality control plan as a wetland or other water of the state;
c. Resulted from historic human activity, is not subject to ongoing operation and maintenance, and has become a relatively permanent part of the natural landscape; or
d. Greater than or equal to one acre in size, unless the artificial wetland was constructed, and is currently used and maintained, primarily for one or more of the following purposes (i.e., the following artificial wetlands are not waters of the state unless they also satisfy the criteria set forth in 2, 3a, or 3b):
i. Industrial or municipal wastewater treatment or disposal, ii. Settling of sediment,
iii. Detention, retention, infiltration, or treatment of stormwater runoff and other pollutants or runoff subject to regulation under a municipal, construction, or industrial stormwater permitting program, iv. Treatment of surface waters,
v. Agricultural crop irrigation or stock watering,
vi. Fire suppression,
vii. Industrial processing or cooling,
2 “Created by modification of a surface water of the state” means that the wetland that is being evaluated was created by modifying an area that was a surface water of the state at the time of such modification. It does not include a wetland that is created in a location where a water of the state had existed historically, but had already been completely eliminated at some time prior to the creation of the wetland. The wetland being evaluated does not become a water of the state due solely to a diversion of water from a different water of the state. 3 Artificial wetlands are wetlands that result from human activity. 17 viii. Active surface mining – even if the site is managed for interim wetlands functions and values,
ix. Log storage,
x. Treatment, storage, or distribution of recycled water, or xi. Maximizing groundwater recharge (this does not include wetlands that have incidental groundwater recharge benefits); or
xii. Fields flooded for rice growing.4
All artificial wetlands that are less than an acre in size and do not satisfy the criteria set forth in 2, 3.a, 3.b, or 3.c are not waters of the state. If an aquatic feature meets the wetland definition, the burden is on the applicant to demonstrate that the wetland is not a water of the state.

3.3.3 California Department of Fish and Wildlife
Pursuant to Division 2, Chapter 6, Sections 1600-1603 of the California Fish and Game Code, the CDFW regulates all diversions, obstructions, or changes to the natural flow or bed, channel, or bank of any river, stream, or lake, which supports fish or wildlife.

CDFW defines a stream (including creeks and rivers) as “a body of water that flows at least periodically or intermittently through a bed or channel having banks and supports fish or other aquatic life. This includes watercourses having surface or subsurface flow that supports or has supported riparian vegetation.” CDFW's definition of “lake” includes “natural lakes or manmade reservoirs.” CDFW also defines a stream as “a body of water that flows, or has flowed, over a given course during the historic hydrologic regime, and where the width of its course can reasonably be identified by physical or biological indicators.” It is important to note that the Fish and Game Code defines wildlife to include “all wild animals, birds, plants, fish, amphibians, invertebrates, reptiles, and related ecological communities, including the habitat upon which they depend for continued viability” (FGC Division 0.5, Chapter 1, section 89.5. Furthermore, Division 2, Chapter 5, Article 6, Section 1600 et seq. of the California Fish and Game Code does not limit jurisdiction to areas defined by specific flow events, seasonal changes in water flow, or presence/absence of vegetation types or communities.

3.3.4 California Coastal Commission
The California Coastal Commission (CCC) regulates the diking, filling, or dredging of wetlands within the coastal zone. The Coastal Act Section 30121 defines “wetlands” as land “which may 4 Fields used for the cultivation of rice (including wild rice) that have not been abandoned due to five consecutive years of non-use for the cultivation of rice (including wild rice) that are determined to be a water of the state in accordance with these Procedures shall not have beneficial use designations applied to them through the Water Quality Control Plan for the Sacramento and San Joaquin River Basins, except as otherwise required by federal law for fields that are considered to be waters of the United States. Further, agricultural inputs legally applied to fields used for the cultivation of rice (including wild rice) shall not constitute a discharge of waste to a water of the state.

Agricultural inputs that migrate to a surface water or groundwater may be considered a discharge of waste and are subject to waste discharge requirements or waivers of such requirements pursuant to the Water Board’s authority to issue or waive waste discharge requirements or take other actions as applicable. 18 be covered periodically or permanently with shallow water.” The 1998 CCC Statewide Interpretive Guidelines state that hydric soils and hydrophytic vegetation “are useful indicators of wetland conditions, but the presence or absence of hydric soils and/or hydrophytes alone are not necessarily determinative when the Commission identifies wetlands under the Coastal Act.

In the past, the Commission has considered all relevant information in making such determinations and relied upon the advice and judgment of experts before reaching its own independent conclusion as to whether a particular area will be considered wetland under the Coastal Act. The Commission intends to continue to follow this policy.” Areas regulated by the Corps, RWQCB, CDFW and CCC are often not coincident due to the different goals of the respective regulatory programs and because these agencies use different definitions for determining the extent of wetland areas. The Corps requires that under normal circumstances, all three wetland parameters (i.e., hydrophytic vegetation, hydric soils, and wetland hydrology) be present for an area to be considered as a jurisdictional wetland; however, the CCC policy provides for a positive determination for the presence of wetlands based on the presence of any one of the three criteria.

4.0 RESULTS
This section provides the results of general biological surveys, vegetation mapping, habitat assessments and focused surveys for special-status plants, habitat assessments and focused surveys for special-status animals, and a jurisdictional assessment for Waters of the United States (including wetlands) subject to the jurisdiction of the Corps and Regional Board, streams (including riparian vegetation) and lakes subject to the jurisdiction of CDFW, and wetlands subject to the jurisdiction of the CCC.

4.1 Existing Conditions
The Study Area is located within the Hellman Property oil field and consists of disturbed land with existing oil wells, and pipes, and associated infrastructure, internal roads, and open fields.

The vegetation communities are generally disturbed with a substantial component of non-native species. The topography is flat, with elevations ranging from 2 feet above mean sea level (AMSL) in the southeast portion of the Study Area to 8 feet AMSL in the northwest portion of the study area. Soils within the Study Area consist of Bolsa silty clay loam [Exhibit 5 – Soil Map]. Annual average rainfall for the region totals about 12 inches, average annual high temperature is 74 degrees, and average annual low temperature is 56 degrees.5 Under existing conditions in the Study Area, areas within 100 feet of oil wells, electrical equipment, and associated facilities are subject to required maintenance/mowing due to fire risk.

Fuel modification areas are periodically maintained to remove any vegetation that presents a fire hazard, but these areas support annual grasses and forbs such as ripgut (Bromus diandrus), wild oats (Avena barbata), hare barley (Hordeum murinum ssp. leporinum), five-hook bassia (Bassia hyssopifolia), and southern tarplant (Centromadia parryi ssp. australis) that can reestablish 5 Data for Long Beach Daugherty Field for 1991–2020: https://www.ncei.noaa.gov/access/us-climatenormals/#dataset=normals-annualseasonal&timeframe=30&station=USW00023129 19 during the interval between maintenance events. Some of the fuel modification areas also include limited amounts of saltgrass and alkali heath. The 100-foot width of the fuel modification zones was determined in consultation with Orange County Fire Authority (OCFA) and California Geologic Energy Management Division (CalGEM).

In December 2022 and February 2023, Southern California Edison powerlines fell within and near the Study Area. Emergency repairs were completed without incident, including fire or damage to oil field facilities, but these events underscore the need for periodic fuel modification on the Hellman Property.

4.2 Vegetation Mapping
The Study Area supports 16 different land use and vegetation types with varying degrees of disturbance as summarized in Table 4-1 below. Where vegetation types are mapped to association, both the alliance and association are listed. Descriptions of each vegetation type follow the table. A Vegetation Map is attached as Exhibit 6a. Photographs depicting the Project site are shown in Exhibit 7.

Table 4-1. Summary of Vegetation/Land Use Types for the Study Area

VEGETATION/

LAND USE TYPE
Code Rank Total Study
Area (acres)
Alkali heliotrope fields -- -- 0.12
Annual grassland/ herbaceous
semi-natural stands
-- -- 1.20
Baccharis pilularis shrubland
alliance

32.060.23 S5 0.05
Disturbed Baccharis pilularis
shrubland alliance

63.510.00 S5 0.35
Bassia hyssopifolia association 42.015.02 -- 3.54
Castor bean stands -- -- 0.05
Cressa truxillensis-Distichlis
spicata herbaceous alliance

46.100.09 S2 0.20
Distichlis spicata – annual
grasses

41.200.13 S4 3.23
Disturbed/Developed -- -- 2.51
Malvella leprosa fields -- -- 0.11
Mixed shrub seminatural stands -- -- 0.04
Ornamental -- -- 0.01
Raphanus sativus association -- -- 0.18
Salix lasiolepis – Baccharis
salicifolia shrubland alliance

61.201.06 S4 0.58
Tree tobacco stands -- -- 0.27
Total 12.46
20 Alkali heliotrope fields
The Study Area supports approximately 1.11 acre of nearly monocultural alkali heliotrope (Heliotropium curassavicum). There is no corresponding alliance in the Natural Communities List for this vegetation type and no state rarity rank.

Annual grassland/herbaceous semi-natural stands
The Study Area supports approximately 1.20 acre of disturbed areas vegetated with a mix of five-hook bassia (Bassia hyssopifolia) and non-native annual grasses including Mediterranean barley (Hordeum marinum ssp. gussoneanum), ripgut (Bromus diandrus), wild oat (Avena barbata), and hare barley (Hordeum murinum ssp. leporinum). Southern tarplant (Centromadia parryi ssp. australis, CRPR 1B.1) is also present in this area. There is no corresponding alliance in the Natural Communities List for this vegetation type and no state rarity rank.

Baccharis pilularis shrubland alliance (coyote brush scrub) • Baccharis pilularis (32.060.23)
The Study Area supports an approximately 0.05-acre area along a pipeline consisting of dense coyote brush (Baccharis pilularis) with a few individuals of tree tobacco (Nicotiana glauca) and mulefat (Baccharis salicifolia). The membership rule for this alliance states that Baccharis pilularis must have greater than 50 percent absolute cover in the shrub layer. This alliance has a state rarity rank of S5.

Disturbed Baccharis pilularis shrubland alliance (coyote brush scrub) The Study Area supports approximately 0.35 acre of disturbed coyote brush scrub that is within the 100-foot buffer but located off site in the Los Cerritos Wetlands property. This area consists of coyote brush with roughly 30–40 percent cover, with other component species being nonnative invasives including including black mustard (Brassica nigra) and poison hemlock (Conium maculatum). The membership rule for this alliance states that Baccharis pilularis must have greater than 50 percent absolute cover in the shrub layer; nevertheless, this area is characterized as disturbed coyote brush scrub because it is the single most dominant species.

This alliance has a state rarity rank of S5.

Salsola tragus – Isatis tinctoria – Bassia spp. semi-natural alliance (Russian thistle – dyers woad – five-hook bassia fields)
• Bassia hyssopifolia (42.015.02)
The Study Area supports 3.54 acres in which five-hook bassia is either a dominant or codominant species. Other component species include crown daisy (Glebionis coronaria), summer mustard (Hirschfeldia incana), perennial pepperweed, stinkwort (Dittrichia graveolens), and alkali heliotrope. This alliance is listed in the Pending Additions to the Natural Community List, and therefore is not included in MCVII. CDFW states that “Vegetation scientists at NatureServe, the California Native Plant Society, and CDFW determine non-native stands based on a rule of at least 90% cover of non-native species without evenly distributed or diverse native forbs and grasses at any time in the growing season” (CDFW 2022d). These areas exhibit 90-percent cover 21 of non-native species overall, with alkali heliotrope being the only native species present with very limited cover. This alliance does not have a state rarity rank.

Castor Bean stands
The Study Area supports 0.05 acre of nearly monocultural castor bean (Ricinus communis).

There is no corresponding alliance in the Natural Communities List for this vegetation type and no state rarity rank.

Cressa truxillensis–Distichlis spicata herbaceous alliance (alkali weed – salt grass playas and sinks)
• Cressa truxillensis (46.100.09)
The Study Area supports 0.20 acre of monocultural alkali weed. The membership rules for this alliance state that Cressa truxillensis, Crypsis schoenoides, or Distichlis spicata are usually abundant in the herbaceous layer. The Cressa truxillensis association is a provisional designation with no rarity rating; however, the alliance has an S2 rarity rank, and as such CDFW identifies it as a sensitive natural community.

Distichlis spicata herbaceous alliance (salt grass flats) • Distichlis spicata – annual grasses (41.200.13)
The Study Area supports approximately 3.23 acres dominated by Distichlis spicata but with a substantial component of annual grasses ranging from 5 to 45 percent relative cover, including ripgut, wild oat, hare barley, and Mediterranean barley. Southern tarplant is also present. This area also has a few small, isolated patches of alkali heath that are not large enough to comprise a separate mapping unit. The membership rules for this alliance require that Distichlis spicata have greater than 50 percent relative cover in the herbaceous layer, and higher cover than any other grass species. The Distichlis spicata – annual grasses association has no state rarity rank; however, the alliance has an S4 rarity rank.

Disturbed/Developed
The Study Area includes 2.51 acres of disturbed/developed lands, which consist of vehicular access roads, oil wells and associated infrastructure, and bare ground. Some southern tarplant occurs on road margins and otherwise unvegetated areas.

Malvella leprosa fields
The Study Area includes a 0.11-acre area of nearly monocultural alkali mallow (Malvella leprosa). There is no corresponding alliance in the Natural Communities List for this vegetation type and no state rarity rank.
22 Mixed Shrub Seminatural Stands
This vegetation type is limited to a 0.04-acre disturbed area of stockpiled broken concrete and other debris. Component species consist of coyote brush, pampas grass (Cortaderia sp.), and tree tobacco in approximately equal proportions. There is no corresponding alliance in the Natural Communities List for this vegetation type and no state rarity rank.

Ornamental
This vegetation type consists of a single Canary Island date palm (Phoenix canariensis) covering

0.01 acre.

Brassica nigra – Centaurea semi-natural alliance (upland mustards or star-thistle fields) • Raphanus sativus (42.011.04)
The Study Area supports approximately 0.18 acre of nearly monocultural wild radish (Raphanus sativus). The membership rules for this alliance require that the mustard species be dominant in the herbaceous layer. There is no state rarity rank for this alliance.

Salix lasiolepis shrubland alliance (arroyo willow thickets) • Salix lasiolepis – Baccharis salicifolia (61.201.06)
The 100-foot buffer includes a 0.58-acre portion of the water quality basin associated with the Heron Pointe residential development, which is subject to periodic maintenance. Dominant species in the tree and shrub layers of the basin include Salix lasiolepis and Baccharis salicifolia.

The membership rules for this alliance state that Salix lasiolepis must have greater than 50 percent relative cover in the tree canopy. The state rarity rank for the alliance and association are both S4.

Tree Tobacco Stands
The Study Area supports 0.27 acre of nearly monocultural tree tobacco. There is no corresponding alliance in the Natural Communities List for this vegetation type, and no state rarity rank.

4.3 Special-Status Vegetation Communities
The CNDDB identifies the following five special-status vegetation communities for the Los Alamitos, Seal Beach, Long Beach, South Gate, Whittier, La Habra, Anaheim, and Newport Beach quadrangle maps: Southern Foredunes, Southern Dune Scrub, Southern Coastal Salt Marsh, Southern Cottonwood Willow Riparian Forest, California Walnut Woodland.

The Study Area contains one special-status vegetation type, the Cressa truxillensis–Distichlis spicata herbaceous alliance, which has an S2 rarity rating. 23 4.4 Special-Status Plants
One special-status plant species, southern tarplant (Centromadia parryi ssp. australis), was detected in the Study Area in 2022, and a second species, Coulter’s goldfields (Lasthenia glabrata ssp. coulteri) was detected in the Study Area in 2023. Both of these species were previously detected in the Study Area during focused surveys conducted in 2009 and 2010, and southern tarplant is also known historically from other locations on the Hellman Property and Los Cerritos Wetlands. Table 4-2 provides a list of special-status plants evaluated for the Project site through general biological surveys, habitat assessments, and focused surveys. Species were evaluated based on the following factors: 1) species identified by the CNDDB and CNPS as occurring (either currently or historically) on or in the vicinity of the Study Area, and 2) any other special-status plants that are known to occur within the vicinity of the Study Area, or for which potentially suitable habitat occurs within the site.

Table 4-2. Special-Status Plants Evaluated for the Study Area Species Status Habitat Potential for
Occurrence
Aphanisma
Aphanisma blitoides
Federal: None
State: None
CRPR: 1B.2
Sandy soils in coastal bluff
scrub, coastal dunes, and coastal
scrub.

Does not occur due to
a lack of suitable
habitat.

Brand’s star phacelia
Phacelia stellaris
Federal: None
State: 1B.1
CRPR: 1B.1
Coastal scrub, coastal dunes. Does not occur due to
a lack of suitable
habitat.

California box-thorn
Lycium californicum
Federal: None
State: None
CRPR: 4.2
Coastal bluff scrub, coastal
scrub.

Does not occur due to
a lack of suitable
habitat.

California Orcutt grass
Orcuttia californica
Federal: FE
State: SE
CRPR: 1B.1
Vernal pools Does not occur due to
a lack of suitable
habitat.

Catalina mariposa lily
Calochortus catalinae
Federal: None
State: None
CRPR: 4.2
Chaparral, cismontane
woodland, coastal sage scrub,
valley and foothill grassland.

Does not occur due to
a lack of suitable
habitat.

Chaparral sand verbena
Abronia villosa var. aurita
Federal: None
State: None
CRPR: 1B.1
Sandy soils in chaparral, coastal
sage scrub.

Does not occur due to
a lack of suitable
habitat.

Coast woolly-heads
Nemacaulis denudata var.
denudata
Federal: None
State: None
CRPR: 1B.2
Coastal dunes. Does not occur. This
species is known from
the vicinity of the
Project site; however,
no suitable habitat is
present in the Study
Area.

Coulter’s goldfields
Lasthenia glabrata ssp.
coulteri
Federal: None
State: None
CRPR:1B.1
Playas, vernal pools, marshes
and swamps (coastal salt).

Confirmed present in
the Study Area in
2009, 2010, and 2023.
24 Species Status Habitat Potential for
Occurrence
Coulter’s saltbush
Atriplex coulteri
Federal: None
State: None
CRPR: 1B.2
Coastal bluff scrub, coastal
dunes, coastal sage scrub, valley
and foothill grassland.

Occurring on alkaline or clay
soils.

Does not occur due to
a lack of suitable
habitat
Davidson’s saltscale
Atriplex serenana var.
davidsonii
Federal: None
State: None
CRPR: 1B.2
Alkaline soils in coastal sage
scrub, coastal bluff scrub.

Does not occur due to
a lack of suitable
habitat.

Decumbent goldenbush
Isocoma menziesii var.
decumbens
Federal: None
State: None
CRPR: 1B.2
Chaparral, coastal scrub (sandy,
often in disturbed areas)
Confirmed absent.

Estuary seablite
Suaeda esteroa
Federal: None
State: None
CRPR: 1B.2
Coastal salt marsh and swamps.

Occurs in sandy soils.

Does not occur due to
a lack of suitable
habitat r.

Gambel’s water cress
Nasturtium gambelii
Federal: FE
State: ST
CRPR: 1B.1
Marshes and swamps. Does not occur due to
a lack of suitable
habitat.

Horn's milk-vetch
Astragalus hornii var.
hornii
Federal: None
State: None
CRPR: 1B.1
Lake margins with alkaline
soils, meadows and seeps, and
playas.

Does not occur. This
species is known from
the vicinity of the
Project site; however,
the known populations
are assumed to be
extirpated and no
suitable habitat is
present in the Study
Area.

Intermediate mariposa-lily
Calochortus weedii var.
intermedius
Federal: None
State: None
CRPR: 1B.2
Coastal scrub, chaparral, valley
and foothill grassland.

Does not occur due to
a lack of suitable
habitat.

Lewis' evening-primrose
Camissoniopsis lewisii
Federal: None
State: None
CRPR: 3
Sandy or clay soils in coastal
bluff scrub, cismontane
woodland, coastal dunes,
coastal scrub, and valley and
foothill grassland.

Does not occur.

Los Angeles sunflower
Helianthus nuttallii ssp.
parishii
Federal: None
State: None
CRPR: 1A
Salt and freshwater marshes,
historically in Los Angeles,
Orange, Riverside and San
Bernardino Counties. Presumed
to be extinct. Plant discovered
in Santa Clarita most likely
hybrid between H. nuttallii and
H. californicus.

Does not occur and is
presumed to be
extinct.

Lucky morning-glory
Calystegia felix
Federal: None
State: None
CRPR: 1B.1
Meadows and seeps, riparian
scrub.

Does not occur due to
a lack of suitable
habitat.
25 Species Status Habitat Potential for
Occurrence
Lyon’s pentachaeta
Pentachaeta lyonii
Federal: FE
State: SE
CRPR: 1B.1
Chaparral (openings), coastal
sage scrub, valley and foothill
grassland.

Does not occur due to
a lack of suitable
habitat.

Many-stemmed dudleya
Dudleya multicaulis
Federal: None
State: None
CRPR: 1B.2
Chaparral, coastal sage scrub,
valley and foothill grassland.

Often occurring in clay soils.

Does not occur due to
a lack of suitable
habitat.

Mud nama
Nama stenocarpum
Federal: None
State: None
CRPR: 2B.2
Vernal pools and freshwater
seasonal ponds.

Does not occur due to
a lack of suitable
habitat.

Parish’s brittlescale
Atriplex parishii
Federal: None
State: None
CRPR: 1B.1
Chenopod scrub, playas, vernal
pools.

Does not occur due to
a lack of suitable
habitat.

Plummer's mariposa-lily
Calochortus plummerae
Federal: None
State: None
CRPR: 4.2
Coastal scrub, chaparral, valley
and foothill grassland,
cismontane woodland, lower
montane coniferous forest.

Does not occur due to
a lack of suitable
habitat.

Prostrate vernal pool
navarretia
Navarretia prostrata
Federal: None
State: None
CRPR: 1B.1
Coastal sage scrub, valley and
foothill grassland (alkaline),
vernal pools. Occurring in
mesic soils.

Does not occur due to
a lack of suitable
habitat.

Red sand-verbena
Abronia maritima
Federal: None
State: None
CRPR: Rank 4.2
Coastal dunes. Does not occur due to
a lack of suitable
habitat.

Salt marsh bird’s-beak
Chloropyron maritimus
ssp. maritimus
Federal: FE
State: SE
CRPR:1B.2
Coastal dune, coastal salt
marshes and swamps.

Does not occur due to
a lack of suitable
habitat.

Salt spring checkerbloom
Sidalcea neomexicana
Federal: None
State: None
CRPR:2B.2
Playas, chaparral, coastal scrub,
lower montane coniferous
forest, Mojavean desert scrub.

Does not occur due to
a lack of suitable
habitat.

San Bernardino aster
Symphyotrichum
defoliatum
Federal: None
State: None
CRPR:1B.2
Meadows and seeps, marshes
and swamps, coastal scrub,
cismontane woodland, lower
montane coniferous forest,
grassland. Vernally mesic
grassland or near ditches,
streams and springs; disturbed
areas.

Does not occur due to
a lack of suitable
habitat.

San Diego button-celery
Eryngium aristulatum var.
parishii
Federal: FE
State: SE
CRPR: 1B.1
Mesic soils in vernal pools,
valley and foothill grasslands,
coastal sage scrub.

Does not occur due to
a lack of suitable
habitat.

Sanford's arrowhead
Sagittaria sanfordii
Federal: None
State: None
CRPR: 1B.2
Marshes and swamps (assorted
shallow freshwater).

Does not occur due to
a lack of suitable
habitat.

Seaside cistanthe
Cistanthe maritima
Federal: None
State: None
CRPR: 4.2
Sandy soils in coastal bluff
scrub, coastal scrub, and valley
and foothill grassland.

Does not occur due to
a lack of suitable
habitat.
26 Species Status Habitat Potential for
Occurrence
Small-flowered morningglory
Convolvulus simulans
Federal: None
State: None
CRPR: 4.2
Chaparral (openings), coastal
sage scrub, valley and foothill
grassland. Occurring on clay
soils and serpentinite seeps.

Does not occur due to
a lack of suitable
habitat.

Small spikerush
Eleocharis parvula
Federal: None
State: None
CRPR: 4.3
Marshes and swamps. Does not occur due to
a lack of suitable
habitat.

South coast saltscale
Atriplex pacifica
Federal: None
State: None
CRPR: 1B.2
Coastal bluff scrub, coastal
dunes, coastal sage scrub,
playas.

Does not occur due to
a lack of suitable
habitat.

South coast branching
phacelia
Phacelia ramosissima var.
austrolitoralis
Federal: None
State: None
CRPR: 3.2
Sandy, sometimes rocky soils in
chaparral, coastal dunes, coastal
scrub, and marshes and swamps
(coastal salt)
Does not occur due to
a lack of suitable
habitat.

Southern tarplant
Centromadia parryi ssp.
australis
Federal: None
State: None
CRPR: 1B.1
Disturbed habitats, margins of
marshes and swamps, vernally
mesic valley and foothill
grassland, vernal pools.

Confirmed present
within the Study Area
in 2009, 2010, and
2022.

Southwestern spiny rush
Juncus acutus ssp.
leopoldii
Federal: None
State: None
CRPR: 4.2
Coastal dunes (mesic),
meadows and seeps (alkaline
seeps), and marshes and
swamps (coastal salt).

Does not occur due to
a lack of suitable
habitat.

Ventura Marsh milk-vetch
Astragalus pycnostachyus
var. lanosissimus
Federal: FE
State: SE
CRPR: 1B.1
Coastal salt marsh. Within reach
of high tide or protected by
barrier beaches, more rarely
near seeps on sandy bluffs.

Does not occur due to
a lack of suitable
habitat.

Vernal barley
Hordeum intercedens
Federal: None
State: None
CRPR: 3.2
Coastal dunes, coastal sage
scrub, valley and foothill
grassland (saline flats and
depressions), vernal pools.

Does not occur due to
a lack of suitable
habitat.

Woolly seablite
Suaeda taxifolia
Federal: None
State: None
CRPR: 4.2
Coastal bluff scrub, coastal
dunes, marshes and swamps
(margins of coastal salt).

Does not occur due to
a lack of suitable
habitat.

STATUS
Federal State
FE – Federally Endangered SE – State Endangered
FT – Federally Threatened ST – State Threatened
FC – Federal Candidate
CRPR
Rank 1A – Plants presumed extirpated in California and either rare or extinct elsewhere.

Rank 1B – Plants rare, threatened, or endangered in California and elsewhere.

Rank 2A – Plants presumed extirpated in California, but common elsewhere.

Rank 2B – Plants rare, threatened, or endangered in California, but more common elsewhere.

Rank 3 – Plants about which more information is needed (a review list).

Rank 4 – Plants of limited distribution (a watch list). 27 Threat Code extension
.1 – Seriously endangered in California (over 80% occurrences threatened) .2 – Fairly endangered in California (20-80% occurrences threatened) .3 – Not very endangered in California (<20% of occurrences threatened or no current threats known)

OCCURRENCE
 Does not occur – The site does not contain habitat for the species and/or the site does not occur within the geographic range of the species.
 Confirmed absent – The site contains suitable habitat for the species, but the species has been confirmed absent through focused surveys.
 Not expected to occur – The species is not expected to occur onsite due to low habitat quality, however absence cannot be ruled out.
 Potential to occur – The species has a potential to occur based on suitable habitat, however its presence/absence has not been confirmed.
 Confirmed present – The species was detected onsite incidentally or through focused surveys

4.4.1 Special-Status Plants Detected at the Project Site Southern Tarplant (Centromadia parryi ssp. australis) is a CRPR 1B.1 species, indicating that it is rare, threatened, or endangered in California and elsewhere, and is seriously endangered in California. This species is an annual herb in the sunflower family that blooms from May to November. It is adapted to and thrives in disturbed areas, and it also occurs in vernal pools, alkali playas, alkali grasslands, and along the margins of salt marshes. This species is very distinctive and flowers as early as June and sometimes into October or November.

A population of approximately 1,072 individuals was detected during focused surveys in the Study Area in 2022, of which 457 were in areas subject to ongoing fuel modification and 615 were not in fuel modification areas. Exhibit 8a depicts the locations of southern tarplant within the Study Area, including the locations of southern tarplant observed in 2009 and 2010. Exhibit 8b depicts additional populations of southern tarplant detected outside the Study Area in 2022 and historic tarplant locations surveyed in the 2000s on the Hellman Property and in the portions of the Los Cerritos Wetlands previously under Hellman Property ownership.

It should be noted that rainfall in 2022 was below average. The National Weather Service cooperative observer station in Long Beach, CA recorded rainfall at 62 percent of average for the 2021-2022 water year.6 This may have resulted in reduced germination of the southern tarplant seedbank. However, in 2022 tarplant generally occurred in the same locations mapped in 2009 and 2010, when rainfall at the Long Beach station was at 73 and 121 percent of average, respectively.7 Tarplant data collected in 2009 and 2010 includes only general distributional polygons, and not a numerical census of the population, so a comparison of 2022 tarplant abundance to 2009 and 2010 tarplant abundance is not possible; however, given that the tarplant was mapped in 2022 in the same general locations on the extreme northwest end of the study 6 https://www.cnrfc.noaa.gov/monthly_precip_2022.php 7 2009 data: https://www.cnrfc.noaa.gov/monthly_precip_2009.php; 2010 data:
https://www.cnrfc.noaa.gov/monthly_precip_2010.php
28 area as previous years, and was also mapped in new locations in the eastern end of the western field, it is evident that tarplant germinated sufficiently in 2022 to evaluate Project-related impacts.

Coulter’s Goldfields (Lasthenia glabrata ssp. coulteri) is a CRPR 1B.1 species, indicating that it is rare, threatened, or endangered in California and elsewhere and is seriously endangered in California. This annual member of the sunflower family occurs in salt marsh areas near the coast at the extreme upper end of tidal inundation. It has also been noted on the periphery of vernal pools such as near Miramar Airfield and in alkali marshes and meadows in the inland valleys of western Riverside County.

Focused surveys conducted in 2023 detected Coulter’s goldfields in the Study Area in approximately the same location as previous focused surveys conducted by GLA in 2009 and 2010 [Exhibit 8a]. The Coulter’s goldfields nearest the proposed Project footprint are located between 36 and 73 feet away.

Rainfall preceding and between the two focused survey visits on February 17 and March 7, 2023, totaled 6.32 inches in January 2023 and 2.90 inches in February 2023. The average rainfall during 1991–2020 for January was 2.89 inches and February was 3.02 inches, indicating that rainfall for January and February 2023 combined was above the 30-year average.8 As such, the population of Coulter’s goldfields mapped during surveys likely represents the maximum extent of the population present in the Study Area.

4.4.2 Special-Status Plants Confirmed Absent Through Focused Surveys at the Project Site
Decumbent goldenbush (Isocoma menziesii var. decumbens) Decumbent goldenbush is a CRPR 1B.2 species, indicating that it is rare, threatened, or endangered in California and elsewhere, and is fairly endangered in California. This perennial member of the sunflower family occurs in coastal scrub and chaparral in sandy soils and is often in disturbed areas. This distinctive variety of goldenbush was included as a target species for focused surveys because it is known from disturbed areas in coastal southern California.

Decumbent goldenbush was not detected during focused surveys.

4.5 Special-Status Animals
One special-status animal species, least Bell’s vireo (Vireo bellii pusillus) was detected in the Study Area during general and focused surveys for the Project. Several other special-status animals are known to occur from past biological surveys in and around the Hellman Property.

Table 4-3 provides a list of special-status animals evaluated for the Project site through general biological surveys, habitat assessments, and focused surveys. Species were evaluated based on the following factors, including: 1) species identified by the CNDDB as occurring (either currently or historically) on or in the vicinity of the Study Area, and 2) any other special-status 8 https://www.ncei.noaa.gov/access/us-climate-normals/#dataset=normalsmonthly&timeframe=30&station=USW00023129 29 animals that are known to occur within the vicinity of the Study Area, for which potentially suitable habitat occurs on the site.

Table 4-3. Special-Status Animals Evaluated for the Study Area Species Name Status Habitat Requirements Potential for Occurrence

INVERTEBRATES
Crotch bumble bee
Bombus crotchii
Federal: None
State: SC
Relatively warm and dry sites,
including the inner Coast Range
of California and margins of the
Mojave Desert.

Does not occur due to a
lack of suitable habitat
and high degree of
disturbance in Study
Area.

Dorothy’s El Segundo Dune
weevil
Trigonoscuta dorothea
dorothea
Federal: None
State: None
Sand dunes in El Segundo, CA. Does not occur due to a
lack of suitable habitat.

Globose dune beetle
Coelus globosus
Federal: None
State: None
Inhabits foredunes and sand
hummocks; it burrows beneath
the sand surface and is most
common beneath dune
vegetation.

Does not occur due to a
lack of suitable habitat.

Mimic tryonia (California
brackish water snail)
Tryonia imitator
Federal: None
State: None
Coastal areas with brackish
waters.

Does not occur due to a
lack of suitable habitat.

Monarch – California
overwintering population
Danaus plexippus plexippus
pop. 1
Federal: FC
State: None
Roosts in winter in windprotected tree groves along the California coast from northern
Mendocino to Baja California,
Mexico.

Does not occur. Known
wintering population in
nearby Gum Grove Park,
but no wintering habitat
present in the Study Area.

Palos Verdes blue butterfly
Glaucopsyche lygdamus
palosverdesensis
Federal: FE
State: None
Locoweed and deerweed in the
Palos Verdes Peninsula.

Does not occur due to a
lack of suitable habitat
and larval host plants.

Riverside fairy shrimp
Streptocephalus wootoni
Federal: FE
State: None
Deep seasonal vernal pools, with
warm water, and low to
moderate dissolved solids, that
remained filled for extended
periods of time. Annual
grasslands or patches.

Does not occur due to a
lack of suitable vernal
pool habitat.

Salt marsh wandering skipper
Panoquina errans
Federal: None
State: None
ICUN: NT
(near
threatened)
Coastal salt marsh and coastal
strand areas dominated by
saltgrass.

Confirmed absent.

San Diego fairy shrimp
Branchinecta sandiegonensis
Federal: FE
State: None
Seasonal vernal pools. Does not occur due to a
lack of suitable vernal
pool habitat.
30 Species Name Status Habitat Requirements Potential for Occurrence Sandy beach tiger beetle
Cicindela hirticollis gravida
Federal: None
State: None
Coastal dunes. Does not occur due to a
lack of suitable habitat.

Senile tiger beetle
Cicindela senilis frosti
Federal: None
State: None
Forages in open unvegetated
areas such as marsh pans and
levees.

Does not occur due to a
lack of suitable habitat.

Western beach tiger beetle
Cicindela latesignata
Federal: None
State: None
Mudflats and beaches. Does not occur due to a
lack of suitable habitat.

Western tidal-flat tiger beetle
Habroscelimorpha gabbii
Federal: None
State: None
Open, unvegetated areas in or
near salt marshes.

Does not occur due to a
lack of suitable habitat.

AMPHIBIANS
Arroyo toad
Anaxyrus californicus
Federal: FE
State: SSC
Historically along length of
drainages; currently in
headwaters, sandy washes and
arroyos grown to willows,
cottonwoods or sycamores.

Does not occur due to a
lack of suitable habitat.

California red-legged frog
Rana draytonii
Federal: FT
State: SSC
Permanent flowing water
sources, including marshes,
streams, lakes ponds; woodland
or valley foothill grasslands;
sufficient vegetative cover
Does not occur due to a
lack of suitable habitat.

Western spadefoot toad
Spea hammondi
Federal: None
State: SSC
Coastal sage scrub, vernal pools,
and grasslands; breeds in
associated temporary pools and
riparian areas.

Does not occur due to a
lack of suitable habitat.

REPTILES
Coast horned lizard
Phrynosoma blainvillii
Federal: None
State: SSC
Occurs in a variety of vegetation
types including coastal sage
scrub, chaparral, annual
grassland, oak woodland, and
riparian woodlands.

Does not occur due to a
lack of suitable habitat.

Coast patch-nosed snake
Salvadora hexalepis virgultea
Federal: None
State: SSC
Open areas within coastal sage
scrub, chaparral, grassland,
desert scrub, washes, sand flats,
& rocky areas.

Does not occur due to a
lack of suitable habitat.

Coastal whiptail
Aspidoscelis tigris stejnegeri
Federal: None
State: SSC
Found in deserts and semi-arid
areas with sparse vegetation and
open areas. Also found in
woodland and riparian areas.

Does not occur due to a
lack of suitable habitat.
31 Species Name Status Habitat Requirements Potential for Occurrence Orange-throated whiptail
Aspidoscelis hyperythra
Federal: None
State: WL
Inhabits low-elevation coastal
scrub, chaparral, and valleyfoothill hardwood habitats.

Prefers washes & other sandy
areas with patches of brush &
rocks. Perennial plants
necessary for its major food –
termites.

Does not occur due to a
lack of suitable habitat.

Pacific green sea turtle
Chelonia mydas
Federal: FT
State: None
IUCN: EN
Green turtles are generally
found in fairly shallow waters
(except when migrating) inside
reefs, bays, and inlets. The
turtles are attracted to lagoons
and shoals with an abundance of
marine grass and algae.

Does not occur due to a
lack of suitable habitat.

Red diamond rattlesnake
Crotalus ruber
Federal: None
State: SSC
Chapparal, woodland, grassland,
& desert areas from coastal San
Diego county to the eastern
slopes of the mountains. Occurs
in rocky areas & dense
vegetation. Needs rodent
burrows, cracks in rocks or
surface cover objects.

Does not occur due to a
lack of suitable habitat.

Southern California legless
lizard
Anniella stebbinsi
Federal: None
State: SSC
Sparse coastal sage scrub,
chaparral, grassland, riparian
and woodland habitats within
moist sandy soil.

Does not occur due to a
lack of suitable habitat.

Western pond turtle
Emys marmorata
Federal: None
State: SSC
Slow-moving permanent or
intermittent streams, small ponds
and lakes, reservoirs, abandoned
gravel pits, permanent and
ephemeral shallow wetlands,
stock ponds, and treatment
lagoons. Abundant basking sites
and cover necessary, including
logs, rocks, submerged
vegetation, and undercut banks.

Does not occur due to a
lack of suitable habitat.

Two-striped garter snake
Thamnophis hammondii
Federal: None
State: SSC
Highly aquatic. Found in
freshwater marshes and riparian
habitats, in or near permanent
fresh water. Often along streams
with rocky beds and riparian
growth.

Does not occur due to a
lack of suitable habitat.
32 Species Name Status Habitat Requirements Potential for Occurrence BIRDS
American peregrine falcon
Falco peregrinus anatum
Federal: None
State: FP
Near wetlands, lakes, rivers or
other water, on cliffs, banks,
dunes, mounds, also humanmade structures.

Does not occur due to a
lack of suitable habitat.

Bank swallow
Riparia riparia
Federal: None
State: ST
Colonial nester; nests primarily
in riparian and other lowland
habitats west or the desert.

Requires vertical banks/cliffs
with fine-textured/sandy soils
near streams, rivers, lakes,
ocean to dig nesting hole.

Does not occur due to a
lack of suitable habitat.

Belding's savannah sparrow
Passerculus sandwichensis
beldingi
Federal: None
State: SE
Coastal salt marshes. Nests in
Salicornia sp. in and around
margins of tidal flats.

Does not occur. Known
from Los Cerritos
Wetlands but does not
occur in the Study Area
due to a lack of suitable
habitat.

Bell’s sage sparrow
Amphispiza belli belli
Federal: None
State: WL
Nests in chaparral dominated by
fairly dense stands of chamise.

Found in coastal sage scrub in
south of range. Nest located on
the ground beneath a shrub or in
a shrub 6-18 inches above the
ground.

Does not occur due to a
lack of suitable habitat.

Black skimmer
Rynchops niger
Federal: None
State: SSC
Nests on gravel bars, low islets
and sandy beaches, unvegetated
sites.

Does not occur due to a
lack of suitable habitat.

Burrowing owl
Athene cunicularia
Federal: None
State: SSC
Open, dry annual or perennial
grasslands, deserts & scrublands
characterized by low-growing
vegetation. Subterranean nester,
dependent upon burrowing
mammals, most notably, the
California ground squirrel.

Not expected to occur.

California black rail
Laterallus jamaicensis
coturniculus
Federal: None
State: ST, FP
Salt marshes bordering larger
bays, coastal spartina marshes,
inland in dense, shortgrass,
shallow marshes.

Does not occur due to a
lack of suitable habitat.

California Brown Pelican
Pelecanus occidentalis
californicus
Federal:

Delisted
State:

Delisted, FP
Coastal, salt bays, ocean,
beaches. Nests on coastal
islands of small to moderate size
that afford immunity from
attack by ground-dwelling
predators.

Does not occur due to a
lack of suitable habitat.
33 Species Name Status Habitat Requirements Potential for Occurrence California horned lark
Eremophila alpestris actia
Federal: None
State: WL
Coastal regions in Southern
California. Short-grass prairies
“bald” hills, mountain meadows,
open coastal plains, fallow grain
fields, alkali flats.

Not expected to occur due
to a lack of suitable
habitat.

California least tern
Sterna antillarum browni
Federal: FE
State: SE, FP
Flat, vegetated substrates near
the coast. Occurs near estuaries,
bays, or harbors where fish is
abundant.

Does not occur due to a
lack of suitable habitat.

Coastal cactus wren
Campylorhynchus
brunneicapillus sandiegensis
Federal: None
State: SSC
Southern California coastal sage
scrub. Wrens require tall opuntia
cactus for nesting and roosting.

Does not occur due to a
lack of suitable habitat.

Coastal California
gnatcatcher
Polioptila californica
californica
Federal: FT
State: SSC
Low elevation coastal sage
scrub and coastal bluff scrub.

Does not occur due to a
lack of suitable habitat.

Cooper’s hawk
Accipiter cooperii
Federal: None
State: WL
Primarily occurs in riparian
areas and oak woodlands, most
commonly in montane canyons.

Known to use urban areas,
occupying trees among
residential and commercial.

Low potential to occur for
foraging only
Ferruginous hawk (wintering)
Buteo regalis
Federal: None
State: WL
Only present as wintering
individuals. Prefers open
grasslands and agricultural
areas.

Low potential to occur for
foraging only.

Grasshopper sparrow
Ammodramus savannarum
Federal: None
State: SSC
Dense grasslands on rolling
hills, lowland plains, in valleys
and on hillsides on lower
mountain slopes.

Does not occur due to a
lack of suitable habitat.

Least Bell’s vireo
Vireo bellii pusillus
Federal: FE
State: SE
Summer resident of southern
California in low riparian in
vicinity of water or in dry river
bottoms. Nests placed along
margins of bushes or on twigs
projecting into pathways,
usually willow, Baccharis,
mesquite.

Does not occur in the
Project site. Confirmed
present in Heron Pointe
water quality basin in the
Study Area.

Light-footed Ridgway’s rail
Rallus obsoletus levipes
Federal: FE
State: SE, FP
Found in salt marshes where
cordgrass and pickleweed are
the dominant vegetation.

Requires dense growth of either
pickleweed or cordgrass for
nesting or escape cover, feeds
on mollusks and crustaceans.

Does not occur due to a
lack of suitable habitat.
34 Species Name Status Habitat Requirements Potential for Occurrence Loggerhead shrike (nesting)
Lanius ludovicianus
Federal: None
State: SSC
Broken woodlands, savannah,
pinyon-juniper, Joshua tree &
riparian woodlands, desert
oases, scrub & washes. Prefers
open country for hunting with
perches for scanning and fairly
dense shrubs and brush for
nesting.

Confirmed present west
of the Study Area within
the Hellman Property
during a 2008 survey.

Moderate potential to
occur for foraging only.

Long-eared owl
Asio otus
Federal: None
State: SSC
Riparian bottomlands grown to
tall willows & cottonwoods;
also belts of live oak paralleling
stream courses. Require
adjacent open land productive of
mice and presence of old nests
of crows.

Does not occur due to a
lack of suitable habitat.

Merlin (wintering)
Falco columbarius
Federal: None
State: WL
Only present as wintering
individuals. Forages in a variety
of habitats including riparian
areas such as present in the
Study Area adjacent to the
Project site.

Low potential to occur for
foraging only.

Northern harrier (nesting)
Circus hudsonius
Federal: None
State: SSC
A variety of habitats, including
open wetlands, grasslands, wet
pasture, old fields, dry uplands,
and croplands.

Low potential to occur for
foraging only.

Osprey (nesting)
Pandion haliaetus
Federal: None
State: WL
Ocean shore, bays, fresh-water
lakes, and larger streams. Large
nests built in treetops within one
mile of a good fish-producing
body of water.

Low potential to occur for
foraging only.

Short-eared owl (nesting)
Asio flammeus
Federal: None
State: SSC
Found in swamplands, both
fresh and salt; lowland
meadows; irrigated alfalfa
fields. Tule patches/tall grass
needed for nesting/daytime
seclusion. Nests on dry ground
in depression concealed in
vegetation.

Low potential to occur for
wintering only. Known
from Los Cerritos
Wetlands.

Southern California rufouscrowned sparrow
Aimophila ruficeps canescens
Federal: None
State: WL
Resident in Southern California
coastal sage scrub and sparse
mixed chaparral.

Not expected to occur due
to a lack of suitable
habitat.

Southwestern willow
flycatcher
Empidonax traillii extimus
Federal: FE
State: SE
Riparian woodlands in southern
California.

Does not occur due to a
lack of suitable habitat.
35 Species Name Status Habitat Requirements Potential for Occurrence Swainson’s Hawk (nesting)
Buteo swainsoni
Federal: None
State: ST
Breeding habitat consists of
grasslands with scattered trees,
juniper-sage flats, riparian areas,
savannahs, & agricultural or
ranch lands. Requires adjacent
suitable foraging areas such as
grasslands or alfalfa or grain
fields that support rodent
populations.

Does not occur due to a
lack of suitable habitat.

Tricolored blackbird (nesting
colony)
Agelaius tricolor
Federal: None
State: ST,
SSC
Requires open water, protected
nesting
& foraging area with insect prey
within a few km of the colony.

Does not occur due to a
lack of suitable habitat.

Western least bittern (nesting)
Ixobrychus exilis
Federal: None
State: SSC
Colonial nester in marshlands
and borders of ponds and
reservoirs that provide ample
cover. Nests usually placed low
in tules over water.

Does not occur due to a
lack of suitable habitat.

Western snowy plover
(nesting)
Charadrius nivosus nivosus
Federal: FT
State: SSC
Sandy or gravelly beaches along
the coast, estuarine salt ponds,
alkali lakes, and at the Salton
Sea.

Does not occur due to a
lack of suitable habitat.

Western yellow-billed cuckoo
(nesting)
Coccyzus americanus
occidentalis
Federal: FT
State: SE
Dense, wide riparian woodlands
with well-developed
understories.

Does not occur due to a
lack of suitable habitat.

White-tailed kite (nesting)
Elanus leucurus
Federal: None
State: FP
Low elevation open grasslands,
savannah-like habitats,
agricultural areas, wetlands, and
oak woodlands. Dense canopies
used for nesting and cover.

Low potential to occur for
foraging only.

Yellow-breasted chat
Icteria virens
Federal: None
State: SSC
Summer resident; inhabits
riparian thickets of willow &
other brushy tangles near
watercourses. Nests in low,
dense riparian, consisting of
willow, blackberry, wild grape;
forages and nests within 10 ft of
ground.

Does not occur due to a
lack of suitable habitat.

Yellow warbler (nesting)
Setophaga petechia
Federal: None
State: SSC
Riparian plant associations.

Prefers willows, cottonwoods,
aspens, sycamores & alders for
nesting & foraging. Also nests
in montane shrubbery in open
conifer forests.

Does not occur due to a
lack of suitable habitat.
36 Species Name Status Habitat Requirements Potential for Occurrence

MAMMALS
American badger
Taxidea taxus
Federal: None
State: SSC
Occurs in drier shrub, forest,
and herbaceous habitats. Needs
open, uncultivated ground and
friable soils for digging
burrows. Preys on burrowing
rodents.

Does not occur due to a
lack of suitable habitat.

Big free-tailed bat
Nyctinomops macrotis
Federal: None
State: SSC
WBWG: MH
Occurs in low-lying arid areas in
Southern California. Roosts in
high cliffs or rocky outcrops.

Does not occur due to a
lack of suitable habitat.

Hoary bat
Lasiurus cinereus
Federal: None
State: None
WBWG: M
Prefers open habitats or habitat
mosaics, with access to trees for
cover & open areas or habitat
edges for feeding. Roosts in
dense foliage of medium to
large trees. Feeds primarily on
moths. Requires water.

Does not occur due to a
lack of suitable habitat.

Pacific pocket mouse
Perognathus longimembris
pacificus
Federal: FE
State: SSC
Seems to prefer soils of fine
alluvial sands near the ocean.

Does not occur due to a
lack of suitable habitat.

San Diego desert woodrat
Neotoma lepida intermedia
Federal: None
State: SSC
Occurs in a variety of shrub and
desert habitats, primarily
associated with rock outcrops,
boulders, cacti, or areas of dense
undergrowth.

Does not occur due to a
lack of suitable habitat.

Silver-haired bat
Lasionycteris noctivagans
Federal: None
State: None
WBWG: M
Temperate, northern hardwoods
with ponds or streams nearby.

Roost in hollow snags and bird
nests.

Does not occur due to a
lack of suitable habitat.

South coast marsh vole
Microtus californicus
stephensi
Federal: None
State: SSC
Tidal marshes in Los Angeles,
Orange and southern Ventura
Counties.

Does not occur due to a
lack of suitable habitat.

Southern California salt
marsh shrew
Sorex ornatus salicornicus
Federal: None
State: SSC
Coastal marshes in Los Angeles,
Orange and southern Ventura
Counties. Requires dense
vegetation and woody debris for
cover.

Does not occur due to a
lack of suitable habitat.

Western mastiff bat
Eumops perotis californicus
Federal: None
State: SSC
WBWG: H
Many open, semi-arid to arid
habitats, including conifer &
deciduous woodlands, coastal
scrub, grasslands, chaparral, etc.

Roosts in crevices in cliff faces,
high buildings, trees, & tunnels.

Does not occur due to a
lack of suitable habitat.
37 STATUS
Federal State
FE – Federally Endangered SE – State Endangered
FT – Federally Threatened ST – State Threatened
FPT – Federally Proposed Threatened SC– State Candidate FC – Federal Candidate FP – State Fully-Protected Species SSC – Species of Special Concern
WL – Watch List
Western Bat Working Group (WBWG)
H – High Priority
LM – Low-Medium Priority
M – Medium Priority
MH – Medium-High Priority

OCCURRENCE
 Does not occur – The site does not contain habitat for the species and/or the site does not occur within the geographic range of the species.
 Confirmed absent – The site contains suitable habitat for the species, but the species has been confirmed absent through focused surveys.
 Not expected to occur – The species is not expected to occur onsite due to low habitat quality, however future occurrence cannot be ruled out.
 Potential to occur – The species has a potential to occur based on suitable habitat, however its presence/absence has not been confirmed.
 Confirmed present – The species was detected onsite incidentally or through focused surveys

4.5.1 Special-Status Wildlife Species Observed within the Study Area Least Bell’s Vireo (Vireo bellii pusillis) is a state and federally listed endangered songbird that is a summer resident of southern California riparian habitats. This species was detected during biological surveys within the 100-foot buffer portion of the Study Area that extends into the offsite water quality basin to the immediate east of the Study Area. The basin is not part of the Hellman Property, but rather collects runoff from the adjacent Heron Pointe development. Two individual males were detected by vocalization on July 29, August 4, and August 25, 2022.

The Project site and Study Area outside of the water quality basin do not support any riparian habitat suitable for least Bell’s vireo, and this species does not occur within the Project site.

4.5.2 Special-Status Wildlife Species Not Observed but Known to Historically Occur in the Immediate Vicinity of the Study Area
Burrowing Owl (Athene cunicularia) is a ground-dwelling and ground-nesting bird of prey that inhabits grassy fields, salt marshes, and other areas with flat or gentle topography with moderate to sparse cover. It does not excavate its own burrows, but rather uses rodent burrows and manmade structures such as culverts and pipes. Numerous rodent burrows were detected on the Hellman Property during past surveys; a wintering burrowing owl was reported during site visits conducted on December 9 and 19, 1996 and on January 16, 1997. Follow-up breeding season surveys in spring of 1997 confirmed that this wintering individual had departed the site. This 38 species was not detected during surveys in 2004 on the Hellman Property for the Tank Farm Relocation project.

As no suitable man-made structures or rodent burrows were observed in the Study Area in 2022, this species is not expected to occur. However, given the historic wintering burrowing owl occurrences in the Hellman Property, future occurrence cannot be ruled out.

4.5.3 Special-Status Wildlife Species Not Observed During Focused Surveys at the Project Site
Wandering Skipper (Panoquina errans) is a butterfly species with no state or federal status but is listed as “near threatened” by the International Union for the Conservation of Nature (IUCN).9

The largest known colony of this species is located at Upper Newport Bay in Orange County.

This species occurs in coastal salt marshes of southern California, where it uses saltgrass (Distichlis spicata) as a larval host plant. This species likely occurs in the Los Cerritos Wetlands south of the Hellman Property.

No wandering skipper individuals were detected during focused surveys of the Study Area; and this species is not expected to occur in the future based on lack of detection and the disturbed condition of the Study Area, including a low abundance of nectar plants in close proximity to salt grass.

4.5.4 Special-Status Wildlife Species that Occur in the Vicinity of the Study Area Belding’s savannah sparrow (Passerculus sandwichensis beldingi) is state listed as endangered and inhabits coastal salt marshes from Santa Barbara south through San Diego County. Belding’s Savannah sparrow nests in pickleweed on and around margins of tidal flats. No suitable habitat occurs within the Study Area. Three individuals were detected in pickleweed habitat during surveys conducted by GLA in 1996 in a former area of the Hellman Property that is now owned by Los Cerritos Wetland Authority (LCWA). At that time, it was concluded that the individuals were transient non-resident individuals. Surveys conducted in April 2015 by Richard Zembal identified 36 territories in portions of the Los Cerritos marsh that were previously part of the Hellman Property (Zembal et al. 2015).

Loggerhead shrike (Lanius ludovicianus) is an SSC but is a common resident and winter visitor in lowlands throughout California. Loggerhead shrikes prefer open habitats with scattered shrubs, trees, posts, fences, utility lines, and other perches and will eat mostly large insects, but will also take small birds, mammals, amphibians, reptiles, fish, carrion, and various other invertebrates. Shrikes usually fly directly to prey on ground or in a shrub; sometimes hovering.

Occasionally it will hawk aerial insects in mid-air. This species was previously observed perching but not actively foraging in the Hellman Property southwest of the Study Area.

Short-eared owl (Asio flammeus) is an SSC when nesting and is known from the nearby Los Cerritos Wetlands. This species nests on dry ground tucked amongst grasses and low vegetation, 9 See http://www.iucnredlist.org
39 including salt marsh vegetation. This species has not been observed within the Study Area, but it has low potential to occur for foraging only.

4.5.5 Raptor Use
The Study Area provides suitable foraging habitat for a number of raptor species, including special-status raptors.

GLA previously conducted detailed raptor surveys, including foraging studies, on the Hellman Property, encompassing the present Study Area (Glenn Lukos Associates 2001). The following raptors were identified during raptor surveys or general biological surveys conducted for the 1997 Draft Environmental Impact Report for the Hellman Property: red-tailed hawk (Buteo jamaicensis), red-shouldered hawk (Buteo lineatus), white-tailed kite (Elanus leucurus), Cooper’s hawk (Accipiter cooperi), northern harrier (Circus cyaneus), American kestrel (Falco sparverius), osprey (Pandion haliaetus), and turkey vulture (Cathartes aura). Also detected was loggerhead shrike (Lanius ludovicianus), which is a songbird that hunts like a raptor. The American kestrel, loggerhead shrike, and red-tailed hawk in particular comprise the three dominant raptor or raptor-like species observed on the Hellman Property. Surveys in 2001 for the Tank Farm Relocation site, which is immediately south of the present Study Area, identified loggerhead shrike and American kestrel.10 During surveys for the present Project, two raptor species, red-tailed hawk and American kestrel, were identified perching near or flying over the Study Area. Two other species, ferruginous hawk (Buteo regalis) and merlin (Falco columbarius), also have low potential to occur for foraging only.

The Study Area lacks potential nesting habitat (e.g., mature trees, shrubs) for those raptor species that breed in southern California, but is expected to provide foraging habitat for all of these species in the form of insects, spiders, lizards, snakes, small mammals, and other birds.

4.6 Nesting Birds
The Project site contains trees, shrubs, and ground cover that provide suitable habitat for nesting native birds. Mortality of native birds (including eggs) is prohibited under the Migratory Bird Treaty Act (MBTA) and California Fish and Game Code.11

4.7 Wildlife Linkages/ Corridors and Nursery Sites
Habitat linkages are areas which provide a connection between two or more habitat areas which are often larger or superior in quality to the linkage. Such linkage sites can be quite small or constricted, but may can be vital to the long-term health of connected habitats. Linkage values 10 There was one occurrence each of a perching loggerhead shrike and perching American kestrel. No foraging was detected within the proposed Tank Farm Relocation site. 11 The MBTA makes it unlawful to take, possess, buy, sell, purchase, or barter any migratory bird listed in 50 C.F.R.

Part 10, including feathers or other parts, nests, eggs, or products, except as allowed by implementing regulations (50 C.F.R.21). In addition, Sections 3505, 3503.5, and 3800 of the California Department of Fish and Game Code prohibit the take, possession, or destruction of birds, their nests or eggs. 40 are often addressed in terms of “gene flow” between populations, with movement taking potentially many generations.

Corridors are similar to linkages but provide specific opportunities for individual animals to disperse or migrate between areas, generally extensive but otherwise partially or wholly separated regions. Adequate cover and tolerably low levels of disturbance are common requirements for corridors. Habitat in corridors may be quite different than that in the connected areas, but if used by the wildlife species of interest, the corridor will still function as desired.

Wildlife nurseries are sites where wildlife concentrate for hatching and/or raising young, such as rookeries, spawning areas, and bat colonies. Nurseries can be important to both special-status species as well as commonly occurring species.

The Project site is located in an area with a patchwork of urban development and undeveloped open space, with residential development to the south and east, and commercial development to the northeast. The undeveloped areas are associated with the Los Cerritos wetlands complex to the south and northwest, the Seal Beach Naval Weapons Station, and Seal Beach National Wildlife Refuge to the east and southeast, and the Los Alamitos Retarding Basin to the north.

The Haynes Intake Channel and San Gabriel River are located to the northwest.

The Study Area may provide for local movement between the undeveloped areas discussed above for common, urban-adapted mammal species such as coyote, striped skunk, raccoon, and opossum. However, the Study Area is not located within a regionally significant wildlife linkage or corridor.

The Study Area does not contain any wildlife nursery habitat.

4.8 Critical Habitat
The Study Area is not located within any USFWS designated or proposed critical habitat areas.

4.9 Jurisdictional Waters
The Project site does not contain any jurisdictional waters that would be regulated by the Corps, Regional Board, or CDFW.

The Project site does not contain any wetlands that would be regulated by the CCC as defined by the California Coastal Act. The 100-foot buffer portion of the Study Area includes part of the Heron Pointe water quality basin that supports riparian vegetation and may have indicators of wetland hydrology and hydric soils; however, it was not evaluated for this Project [Appendix C – Jurisdictional Delineation Report].
41 5.0 IMPACT ANALYSIS
The following discussion examines the potential impacts to plant and wildlife resources that would occur as a result of the proposed project. Impacts (or effects) can occur in two forms, direct and indirect. Direct impacts are considered to be those that involve the loss, modification, or disturbance of plant communities, which in turn, directly affect the flora and fauna of those habitats. Direct impacts also include the destruction of individual plants or animals, which may also directly affect regional population numbers of a species or result in the physical isolation of populations thereby reducing genetic diversity and population stability.

Indirect impacts pertain to those impacts that result in a change to the physical environment, but which is not immediately related to a project. Indirect (or secondary) impacts are those that are reasonably foreseeable and caused by a project but occur at a different time or place. Indirect impacts can occur at the urban/wildland interface of projects, to biological resources located downstream from projects, and other offsite areas where the effects of the project may be experienced by plants and wildlife. Examples of indirect impacts include the effects of increases in ambient levels of noise or light; predation by domestic pets; competition with exotic plants and animals; introduction of toxics, including pesticides; and other human disturbances such as hiking, off-road vehicle use, unauthorized dumping, etc. Indirect impacts are often attributed to the subsequent day-to-day activities associated with project build-out, such as increased noise, the use of artificial light sources, and invasive ornamental plantings that may encroach into native areas. Indirect effects may be both short-term and long-term in their duration. These impacts are commonly referred to as “edge effects” and may result in a slow replacement of native plants by non-native invasive species, as well as changes in the behavioral patterns of wildlife and reduced wildlife diversity and abundance in habitats adjacent to project sites.

5.1 California Environmental Quality Act (CEQA)

5.1.1 Thresholds of Significance
Environmental impacts to biological resources are assessed using impact significance threshold criteria, which reflect the policy statement contained in CEQA, Section 21001(c) of the California Public Resources Code. Accordingly, the State Legislature has established it to be the policy of the State of California:
“Prevent the elimination of fish or wildlife species due to man’s activities, ensure that fish and wildlife populations do not drop below self-perpetuating levels, and preserve for future generations representations of all plant and animal communities...”
Determining whether a project may have a significant effect, or impact, plays a critical role in the CEQA process. According to CEQA, Section 15064.7 (Thresholds of Significance), each public agency is encouraged to develop and adopt (by ordinance, resolution, rule, or regulation) thresholds of significance that the agency uses in the determination of the significance of environmental effects. A threshold of significance is an identifiable quantitative, qualitative or performance level of a particular environmental effect, non-compliance with which means the 42 effect will normally be determined to be significant by the agency and compliance with which means the effect normally will be determined to be less than significant. In the development of thresholds of significance for impacts to biological resources CEQA provides guidance primarily in Section 15065, Mandatory Findings of Significance, and the CEQA Guidelines, Appendix G, Environmental Checklist Form. Section 15065(a) states that a project may have a significant effect where:
“The project has the potential to substantially degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or wildlife community, reduce the number or restrict the range of an endangered, rare, or threatened species...”
Therefore, for the purpose of this analysis, impacts to biological resources are considered potentially significant (before considering offsetting mitigation measures) if one or more of the following criteria discussed below would result from implementation of the proposed project.

5.1.2 Criteria for Determining Significance Pursuant to CEQA Appendix G of the 2018 State CEQA guidelines indicate that a project may be deemed to have a significant effect on the environment if the project is likely to:
a) Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service. b) Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Game or U.S. Fish and Wildlife Service.
c) Have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means. d) Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites. e) Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance.
f) Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan.
43 5.2 Special-Status Species
Appendix G(a) of the CEQA guidelines asks if a project is likely to “have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service.”

5.2.1 Special-Status Plants
The proposed Project will impact one special-status plant species, southern tarplant [Exhibit 9 – Special-Status Species Impact Map].

Southern Tarplant
A population of 1,072 southern tarplant individuals was detected within the 12.46-acre Study Area, of which 457 tarplant individuals were detected in areas subject to ongoing fuel modification, and 615 individuals were not in existing fuel modification zones). 12 Of the 615
individuals not located within existing fuel modification zones, 57 individuals would be subject to temporary impacts and 26 individuals would be permanently impacted by the proposed Project.

In the Project site, southern tarplant occurs in highly disturbed areas with a predominance of non-native species, at the edges of dirt roads, and on bare ground.

Southern tarplant is highly adapted to disturbance as evidenced by the occurrence of this species within the disturbed portions of the Study Area. However, the loss of 83 individuals in the temporary and permanent impact areas, which totals 13 percent of the population in the Study Area not subject to ongoing fuel modification, would be considered a significant impact under CEQA. A mitigation measure is included in Section 6.0 of this report that reduces impacts to southern tarplant to less than significant. The remaining tarplant in the Study Area will be avoided by the Project. A measure is included in Section 6.0 of this report to ensure avoidance of southern tarplant outside the Project impact area during construction.

With regards to potential ESHA, the Coastal Act Section 30107.5 defines an ESHA as:
…any area in which plant or animal life or their habitats are either rare or especially valuable because of their special nature or role in an ecosystem and which could be easily disturbed or degraded by human activities and developments.

When making a determination of ESHA for a rare plant population, the CCC considers multiple parameters including the number of individuals, size of the area occupied, degree of isolation, 12 The 457 southern tarplant individuals in ongoing fuel modification zones are not included in the impact totals for this Project as they are located in areas subject to periodic maintenance as part of oil field operations. Impacts to southern tarplant in the fuel modification zones occurs periodically and is not related to the project evaluated by this biological technical report.
44 fragmentation, and connectivity to suitable open space for the species, level of disturbance/degradation of the occupied area, adjacent development, level of invasion by nonnative species, and potential jeopardy to regional populations by loss of the subject population.

Coastal Commission Staff Senior Ecologist Jonna Engel previously evaluated southern tarplant populations for potential ESHA at several of the Synergy Oil consolidation sites in Long Beach, California, located a short distance from the Study Area. Dr. Engel determined that some of the southern tarplant subpopulations in areas of existing oil infrastructure did not rise to the level of ESHA based on the degree of disturbance, poor soils, and habitat fragmentation (Engel 2017).

Southern tarplant often occurs in areas that are highly disturbed and do not support native vegetation, such as cracks in concrete, disturbed roadsides, and areas with a gravel substrate. It can also occur with non-native halophytes such as small-flowered iceplant. Accordingly, as acknowledged by Dr. Engel in the above-referenced memorandum, a determination of ESHA for areas occupied by this species does not depend solely on the presence of southern tarplant.

Rather, the determination should consider the size and area of the population, isolation/fragmentation, degree of disturbance, and other parameters listed above.

Overall, the western portion of the Study Area that supports southern tarplant consists of a disturbed open field and active oil extraction facilities, including active wells, oil field infrastructure, staging and equipment storage areas, and associated fuel modification areas within a mosaic of non-native vegetation. Where southern tarplant occurs in the Project site, the predominant vegetation/land-cover types consist of disturbed habitat that either lacks a state rarity rank (Disturbed/Developed, Annual grassland/Herbaceous Semi-Natural Stands) or has a state rarity ranking greater than S3 and have a substantial component of non-native grasses and forbs (Distichlis spicata–Annual Grasses, S4). Given the highly disturbed nature of both the overall Study Area and the Project site where southern tarplant occurs, as well as the level of invasion by non-native species, the southern tarplant in the Study Area does not rise to the level of ESHA, and construction of the proposed Project would not directly affect or result in impacts to ESHA. It is also important to note that southern tarplant thrives in disturbed areas, and based on GLA’s experience, grows easily in an appropriately prepared restoration site. With the mitigation proposed in Section 6.3 below, impacts to southern tarplant in the Project site would not result in potential jeopardy to the regional population.

Coulter’s Goldfields
Three distinct population clusters of Coulter’s goldfields were mapped during surveys in 2023 and are located a minimum of 36 to 78 feet from the temporary project impact areas [Exhibit 9].

The Coulter’s goldfields will be fully avoided by the proposed Project. A measure is included in Section 6.0 of this report to ensure avoidance of Coulter’s goldfields during construction.

5.2.2 Special-Status Animals
The proposed Project will not impact special-status animals [Exhibit 9 – Special-Status Species Impact Map]. Least Bell’s vireo (FE, SE) occurs in the Heron Pointe water quality basin on the east end of the Study Area; however, the proposed Project will not impact the riparian vegetation in the water quality basin.
45 A wintering burrowing owl (SSC) was observed on the Hellman Property in 1996 and 1997. No burrowing owls, suitable structures or rodent burrows, or owl sign was observed during biological surveys for the proposed Project; therefore, no impacts to this species will occur as a result of development of the Project. Nevertheless, a measure is included in Section 6.0 of this report to ensure avoidance of impacts to burrowing owl.

Development of the proposed Project would preclude raptor foraging within the Project site; however, the permanent loss of 2.66 acres of raptor foraging area from the proposed Project would be less than significant given the extensive raptor foraging area immediately surrounding the Project site, including the remainder of the Hellman Property, the adjacent Los Cerritos Wetlands, and the Los Alamitos Retarding Basin.

5.3 Sensitive Vegetation Communities
Appendix G(a) of the CEQA guidelines asks if a project is likely to “have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Game or U.S. Fish and Wildlife Service.”
The proposed Project would not impact or have a substantial adverse effect on riparian vegetation or sensitive natural communities with a rarity rating of S3 or less. The proposed project would permanently impact approximately 2.66 acres of lands through installation of the solar panel array [Exhibit 6b – Vegetation Impact Map]. Of the 2.66 acres to be impacted, only a small portion of that area would be directly impacted through ground disturbance and vegetation removal. The majority of the impact area consists of the vegetated areas under and between the proposed solar panels. Shading from the proposed solar panels may result in loss of vegetation and diminished habitat value. Permanent impacts include approximately 0.04 acre of alkali heliotrope fields, 1.55 acre of Bassia hyssopfolia association, 1.05 acre of Distichlis spicataannual grassland association, and 0.02 acre of tree tobacco stands. The Project will avoid the entirety of the 0.02 acre of Cressa truxillensis association (S2 rarity rating). The project will also avoid the riparian vegetation associated with the Heron Pointe water quality basin.

The proposed Project will temporarily impact 1.91 acres of lands, none of which consist of sensitive vegetation communities, for trenching to bury utility lines and for temporary work and staging areas. The trenched areas will be restored to the original grade following construction and are expected to passively revegetate. Table 5-1 provides a summary of impacts to vegetation/land use types.

Table 5-1. Summary of Permanent and Temporary Vegetation/Land Use Impacts

VEGETATION/

LAND USE TYPE
Code Rank Permanent
Impacts
(acres)
Temporary
Impacts
(acres)
Avoided Total Study
Area (acres)
Alkali heliotrope fields -- -- 0.04 0.06 0.01 1.11
Annual grassland/ herbaceous
semi-natural stands
-- -- 0 0.02 1.18 1.20
Baccharis pilularis shrubland
alliance

32.060.23 S5 0 0.04 0.01 0.05
46 VEGETATION/

LAND USE TYPE
Code Rank Permanent
Impacts
(acres)
Temporary
Impacts
(acres)
Avoided Total Study
Area (acres)
Disturbed Baccharis pilularis
shrubland alliance

63.510.00 S5 0 0 0.35 0.35
Bassia hyssopifolia
association

42.015.02 -- 1.55 0.88 1.11 3.54
Castor bean stands -- -- 0 0.03 0.02 0.05
Cressa truxillensis-Distichlis
spicata herbaceous alliance

46.100.09 S2 0 0 0.20 0.20
Distichlis spicata – annual
grasses

41.200.13 S4 1.05 0.61 1.57 3.23
Disturbed/Developed -- -- 0 0.22 2.29 2.51
Malvella leprosa fields -- -- 0 0 0.11 0.11
Mixed shrub seminatural
stands
-- -- 0 0 0.04 0.04
Ornamental -- -- 0 0 0.01 0.01
Raphanus sativus association -- -- 0 0 0.18 0.18
Salix lasiolepis – Baccharis
salicifolia shrubland alliance

61.201.06 S4 0 0 0.58 0.58
Tree tobacco stands -- -- 0.02 0.05 0.20 0.27
Total 2.66 1.91 7.89 12.46

5.4 Wetlands
Appendix G(c) of the State CEQA guidelines asks if a project is likely to “have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means.”
The Project site does not contain and will not impact any state or federally protected wetlands, including wetlands as defined under the CCA.

5.5 Wildlife Movement and Native Wildlife Nursery Sites Appendix G(d) of the State CEQA guidelines asks if a project is likely to “interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors or impede the use of native wildlife nursery sites.”
The Study Area is not located within a regionally significant wildlife linkage or corridor.

Additionally, the development of the Project would not preclude the movement of wildlife through the Study Area. Thus, the proposed Project would not result in a significant impact to native resident or migratory wildlife corridors.

The Study Area does not contain any wildlife nursery sites. 47 The project has the potential to impact active bird nests if vegetation is removed during the nesting season (February 1 to September 15). Impacts to nesting birds are prohibited by the MBTA and California Fish and Game Code.

Although impacts to native birds are prohibited by MBTA and similar provisions of California Fish and Game Code, impacts to native birds by the proposed Project would not be a significant impact under CEQA. The native birds with potential to nest on the Project site would be those that are extremely common to the region and highly adapted to human landscapes (e.g., house finch, killdeer). The number of individuals potentially affected by the Project would not significantly affect regional, let alone local populations of such species. A measure is identified in Section 6.0 of this report to avoid impacts to nesting birds.

5.6 Local Policies or Ordinances
Appendix G(e) of the State CEQA guidelines asks if a project is likely to “conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance.” The Project will not conflict with any local policies or ordinances protecting biological resources.

5.7 Habitat Conservation Plans
Appendix G(f) of the State CEQA guidelines asks if a project is likely to “conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan.” The Study Area is not located within or subject to the provisions of any habitat conservation plans.

5.8 Jurisdictional Waters
The Project site does not contain and will not impact any jurisdictional waters.

5.9 Indirect Impacts to Biological Resources
In the context of biological resources, indirect effects are those effects associated with developing areas adjacent to native open space.

The Project is not expected to result in significant indirect impacts to special-status biological resources. The operation of the proposed solar panel array inherently lacks many potential sources of indirect impacts, including drainage, toxic materials, lighting, noise, and invasive species. To minimize temporary edge effects potentially associated with construction, Project will implement measure to address the following:
• Drainage
• Toxics
• Lighting
48 • Noise
• Human Use

5.9.1 Drainage
The Project’s contractor will develop a Stormwater Pollution Prevention Plan (SWPPP) to address runoff and water quality during construction. Following the completion of construction activities, the Project area will not contain any developed or paved areas and will not result in drainage to the surrounding area. As such, no measures would be required post-construction.

5.9.2 Toxics
Land uses that use chemicals or generate bioproducts that are potentially toxic may adversely affect wildlife species, habitat, or water quality. The proposed Project will implement a SWPPP that will address runoff during construction.

5.9.3 Lighting
No night lighting will be associated with the proposed Project. If temporary night lighting is required during construction, shielding shall be incorporated to ensure ambient lighting is not increased, and such lighting will be subject to the approval of the project biologist.

5.9.4 Noise
It is anticipated that noise levels from installation of solar panels will generally not exceed ambient noise levels associated with normal oil field operations, although there may be a temporary, unavoidable increase in noise levels during construction; however, noise will be minimized to the greatest extent practicable. The City’s standard construction regulations require all construction vehicles or equipment, fixed or mobile, to be equipped with properly operating and maintained mufflers to minimize noise. Furthermore, construction is limited to the hours of 7:00 a.m. to 8:00 p.m. on weekdays and 8:00 a.m. to 8:00 p.m. on weekends. Nevertheless, to ensure that there are no significant temporary noise impacts to least Bell’s vireo in the Heron Pointe water quality basin during breeding season (March 15 to September 15), a measure is identified in Section 6.0 of this report. There would be no other significant temporary or permanent noise impacts resulting from the proposed project.

No noise is associated with operation of the proposed Project.

5.9.5 Human Use
Currently, on-site human use is limited to employees tending to oil field operations. Typically, less than five people are on site at any given time. There will be no change in post-construction human use associated with the proposed project, as the solar array does not require any additional personnel except for periodic maintenance. The property will remain private and fenced, so there is no possibility of increased public access to the property. The proposed project would therefore not cause any significant human impacts. 49 6.0 MITIGATION/AVOIDANCE MEASURES
The following discussion provides project-specific mitigation/avoidance measures for actual or potential impacts to special-status resources.

6.1 Nesting Birds
The Project site contains vegetation with the potential to support native nesting birds. As discussed above, the California Fish and Game Code prohibits mortality of native birds, including eggs. The following measure is recommended to avoid mortality to nesting birds.

Potential impacts to native birds were not considered a biologically significant impact under CEQA; however to comply with state law, the following is recommended:
• As feasible, vegetation clearing and ground disturbance should be conducted outside of the nesting season, which is generally identified as February 1 through September 15. If avoidance of the nesting season is not feasible, then a qualified biologist shall conduct a nesting bird survey within three days prior to any disturbance of the site, including vegetation clearing and ground disturbance. If active nests are identified, the biologist shall establish suitable buffers around the nests, and the buffer areas shall be avoided until the nests are no longer occupied and the juvenile birds can survive independently from the nests.

6.2 Burrowing Owl
Although no burrowing owls, suitable burrows, or owl sign were detected during general biological surveys, wintering owls have historically occurred on the Hellman Property. Although unlikely, owls may occupy the site between the time of biological surveys and construction activities. Therefore, the following required actions would ensure compliance with the MBTA and California Fish and Game Code.
• A pre-construction (initial take avoidance) burrowing owl survey shall be conducted by a qualified biologist no less than 14 days prior to initiating ground disturbance activities using the recommended methods described in the 2012 Department of Fish and Game Staff Report on Burrowing Owl Mitigation. If the pre-construction survey is positive for owl presence, the project proponent will immediately inform the Wildlife Agencies (CDFW, USFWS) to acquire proper avoidance measures, including the possibility of preparing a Burrowing Owl Protection and Relocation Plan, prior to initiating ground disturbance. If the species is not found, no further action is needed.

6.3 Special-Status Plants
As noted above, the proposed Project will result in the loss of 83 individuals of southern tarplant, including 26 individuals in the permanent impact area and 57 individuals in the temporary impact area occupying approximately 0.03 acre. The following measure identifies mitigation for 50 impacts to southern tarplant as discussed in the Southern Tarplant Mitigation and Monitoring Plan [Appendix D]:
• Prior to impacts to the southern tarplant in the Project site, the project biologist will implement the measures contained in the Southern Tarplant Mitigation and Monitoring Plan, which provides for replacement of the impacted 83 individuals at a ratio of 4:1, for a total of 332 individuals. However, if pre-construction surveys are implemented as outlined in the measure below and the total numbers of impacted individuals changes, the number total number of replacement individuals shall be adjusted accordingly at a 4:1 ratio. The plan identifies a candidate area of the Hellman Property where southern tarplant may be established and preserved in perpetuity. The plan includes provisions for seed collection, planting, performance standards for a five-year monitoring period, and contingency plans if the performance standards are not met.

The proposed Project is located within 36–78 feet of Coulter’s goldfields populations in the Study Area. To ensure full avoidance of Coulter’s goldfields, the following measure shall be implemented:
• Prior to the initiation of construction activities and under the direction of the Project Biologist, the populations of Coulter’s goldfields in proximity to the Project site will be demarcated with construction fencing. No vegetation clearing, ground disturbance, or other construction activities shall occur in the fenced areas or within 30 feet of any Coulter’s goldfields.

The proposed Project is located immediately adjacent to some areas of avoided southern tarplant in the Study Area. To ensure full avoidance of southern tarplant outside of the impact area, the following measure shall be implemented:
• Prior to the initiation of construction activities and under the direction of the Project Biologist, any southern tarplant within 100 feet of the Project site will be demarcated with construction fencing or flagging. No vegetation clearing, ground disturbance, or other construction activities shall occur in the fenced areas.

The distribution of southern tarplant and Coulter’s goldfields in the Study Area and Project site is well understood based upon multiple years of focused survey data. However, the number and distribution of individuals may vary from year to year. Based on existing survey data, the project is expected to impact southern tarplant but not Coulter’s goldfields. To ensure that impacts are fully mitigated, the following measure shall be implemented:
• Prior to the initiation of construction activities, a qualified biologist shall conduct preconstruction surveys for southern tarplant and Coulter’s goldfields during the appropriate season for each species to determine final mitigation requirements. If Coulters goldfields are detected in the Project impact area, then the Southern Tarplant Mitigation and Monitoring Plan will be amended to include mitigation for Coulter’s goldfields at a 4:1 ratio at a location with suitable habitat for the species. 51 6.4 Least Bell’s Vireo
Two individual least Bell’s vireo were present in the Heron Pointe water quality basin adjacent to the Project site during the 2022 breeding season. No habitat for least Bell’s vireo, including in the Heron Pointe water quality basin, will be impacted by the Proposed project; however, to avoid indirect noise impacts to breeding least Bell’s vireo, the following measures will be implemented in consultation with the City of Seal Beach and USFWS if project construction activities will occur between March 15 and September 15:
• Surveys for least Bell's vireo should be conducted pursuant to the recommended protocol survey guidelines as established by the USFWS. If full protocol surveys cannot be conducted, then a qualified biologist shall survey suitable habitat in the Heron Pointe water quality bason for the least Bell's vireo weekly for a minimum of four weeks (within the breeding season) prior to the commencement of any construction. • If least Bell’s vireo is detected during surveys, and construction activities will occur between March 15 and September 15, the least Bell’s vireo breeding season, an analysis showing that noise generated by construction activities would not exceed 60 dB hourly average at the edge of occupied habitat must be completed by a qualified acoustician prior to commencement of construction activities. Where construction activities would result in noise levels exceeding 60 dB hourly average at the edge of occupied least Bell's vireo habitat, additional measures must be implemented. • At least two weeks prior to commencement of construction activities, under the direction of a qualified acoustician, noise attenuation measures (e.g., walls, panels) shall be implemented to ensure that noise levels resulting from construction activities will not exceed 60 dB hourly average at the edge of habitat occupied by least Bell's vireo.

Concurrent with the commencement of construction activities and the construction of necessary noise attenuation facilities, noise monitoring shall be conducted at the edge of the occupied habitat area to ensure that noise levels do not exceed 60dB hourly average.

If the noise attenuation techniques implemented are determined to be inadequate by the qualified acoustician or biologist, then construction activities shall cease until such time that adequate noise attenuation is achieved or until the end of the breeding season (September 16). Construction noise monitoring shall continue to be monitored at least once weekly on varying days, or more frequently depending on the construction activity, to verify that noise levels at the edge of occupied habitat are maintained below 60 dB hourly average or to the ambient noise level if it already exceeds 60 dB hourly average. If not, other measures shall be implemented in consultation with the project biologist and the City and USFWS, as necessary, to reduce noise levels to below 60 dB hourly average or to the ambient noise level if it already exceeds 60 dB hourly average. Such measures include, but are not limited to, limitations on the placement of construction equipment and the simultaneous use of equipment.
52 7.0 REFERENCES
Baldwin, B.G., D.H. Goldman, D.J. Keil, R. Patterson, T.J. Rosatti, and D.H. Wilken. 2012.

The Jepson Manual: Vascular Plants of California, Second Edition. University of California Press. 1,568 pp.

California Department of Fish and Wildlife. 2016. Complete List of Amphibian, Reptile, Bird and Mammal Species in California. California Wildlife Habitat Relationships Program, Sacramento.

California Department of Fish and Wildlife. 2018. Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Sensitive Natural Communities.

State of California, Natural Resources Agency, Department of Fish and Wildlife. March 20, 2018.

California Department of Fish and Wildlife. 2022a. Special Animals List. State of California Natural Resources Agency, April 2022.

California Department of Fish and Wildlife. 2022b. State and Federally Listed Endangered and Threatened Animals of California. State of California Natural Resources Agency.

Sacramento, California. April 2022.

California Department of Fish and Wildlife. 2022c. California Natural Community List.

California Natural Resources Agency, July 5, 2022.

California Department of Fish and Wildlife. 2022d. Natural Communities. Accessed October 10, 2022. https://wildlife.ca.gov/Data/VegCAMP/Natural-Communities.

California Native Plant Society. 2001. Inventory of Rare and Endangered Plants of California (sixth edition). Rare Plant Scientific Advisory Committee, David P. Tibor, Convening Editor. California Native Plant Society. Sacramento, CA. x + 388pp.

California Native Plant Society, Rare Plant Program. 2022. Inventory of Rare and Endangered Plants of California (online edition, v9-01 1.5). Accessed August 2022. http://www.rareplants.cnps.org.

California Natural Diversity Database (CNDDB). 2022. RareFind 5. Records of occurrence for USGS 7.5-minute quadrangle maps: Los Alamitos, Seal Beach, Long Beach, Anaheim, Whittier, South Gate, and Newport Beach. California Department of Fish and Wildlife, State of California Natural Resources Agency. Sacramento, California. Accessed August 2022. https://wildlife.ca.gov/Data/CNDDB/Maps-and-Data.

Chesser, R.T. et al. 2021. Check-list of North American Birds (online). American Ornithological Society. http://checklist.americanornithology.org/taxa. 53 Collins, Joseph T. and Travis W. Taggart. 2009. Standard Common and Current Scientific Names for North American Amphibians, Turtles, Reptiles, and Crocodilians, Sixth Edition. Publication of The Center for North American Herpetology, Lawrence, Kansas. iv+44p.

Engel, Jonna (California Coastal Commission). 2017. Memorandum: Synergy/BOMP: Los Cerritos Wetland Oil Consolidation and Restoration Project. July 25, 2017 Environmental Laboratory. 1987. Corps of Engineers Wetlands Delineation Manual, Technical Report Y-87-1, U.S. Army Engineer Waterways Experimental Station, Vicksburg, Mississippi.

Garrett, K. and J. Dunn. 1981. Birds of Southern California: Status and Distribution. Los Angeles Audubon Society. 407 pp.

Glenn Lukos Associates. 2001. Raptor Foraging Habitat Assessment at Hellman Ranch, Orange County, California. Letter report dated July 24, 2001 addressed to Joannie Madrid of John Laing Homes.

Glenn Lukos Associates. 2006. Biological Technical Report, Hellman Ranch Tank Farm Relocation Project, Orange County, California. August 2004, Revised March 2006.

Glenn Lukos Associates. 2018. Biological Technical Report for the Proposed Hellman Gas Plant Project, Seal Beach, Orange County. September 2018.

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

Munz, P.A. 1974. A Flora of Southern California. University of California Press. 1,086 pp.

Nelson, J. 1984. Rare plant survey guidelines. In: Inventory of Rare and Endangered Vascular Plants of California. J. Smith and R. York (eds.). Special Publication No. 1. California Native Plant Society.

National Resources Conservation Service. 2022. Soil Survey Staff, United States Department of Agriculture. Web Soil Survey. Accessed August 2022.
https://websoilsurvey.sc.egov.usda.gov/.

Sawyer, J.O, T. Keeler-Wolf, and J.M. Evens. 2009. A Manual of California Vegetation.

Second Edition. California Native Plant Society Press. Sacramento, California. 1,300 pp.

Sogge, M.K., Ahlers, D., and Sferra, S.J. 2010. A Natural History Summary and Survey Protocol for the Southwestern Willow Flycatcher. U.S Geological Survey Techniques and Methods 2A-10
54 State Water Resources Control Board. 2019. State Wetland Definition and Procedures for Discharges of Dredged or Fill Material to Waters of the State. [For Inclusion in the Water Quality Control Plans for Inland Surface Waters and Enclosed Bays and Estuaries and Ocean Waters of California].

Stebbins, R. C. 1954. Amphibians and Reptiles of Western North America. McGraw-Hill, New York. 536pp.

Stebbins, R.C. 1985. A Field Guide to Western Reptiles and Amphibians, 2nd ed. Houghton Mifflin Co., Boston, Massachusetts.

Tidal Influence. 2012. Los Cerritos Wetlands Habitat Assessment Report: Habitat Types and Special Status Species. Submitted March 1, 2012, Revised June 21, 2012.

U.S. Army Corps of Engineers. 2008. Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Arid West Supplement (Version 2.0). Ed. J.S. Wakeley, R.W.

Lichvar, and C.V. Noble. ERDC/EL TR-06-16. Vicksburg, MS: U.S. Army Engineer Research and Development Center.

U.S. Army Corps of Engineers 2020. National Wetland Plant List, version 3.5 U.S. Fish and Wildlife Service. 2000. Guidelines for Conducting and Reporting Botanical Inventories for Federally Listed, Proposed and Candidate Plants. Sacramento, CA: U.S.

Fish and Wildlife Service. Unpublished memorandum; January 2000.

Zembal R. and S.M. Hoffman, and R.T. Patton. 2015. A survey of the Belding’s Savannah sparrow (Passerculus sandwichensis beldingi) in California, 2015. California Department of Fish and Game, Habitat Conservation Planning Branch, Nongame Wildlife Program, 2015-02.

8.0 CERTIFICATION
I hereby certify that the statements furnished above and in the attached exhibits present data and information required for this biological evaluation, and that the facts, statements, and information presented are true and correct to the best of my knowledge and belief.

Signed:______________________________ Date: October 12, 2023 s:0200-8c.biotech.docx
Source: ESRI World Street Map 0 2 4 8
Miles
Regional Map
^_
Exhibit 1
±

HELLMAN PROPERTY

SOLAR PANEL ARRAY

PROJECT LOCATION
Adapted from USGS Los Alamitos, CA quadrangle
Vicinity Map
0 1,000 2,000 4,000
Feet ±

HELLMAN PROPERTY

SOLAR PANEL ARRAY
Exhibit 2

PROJECT LOCATION
X:\00 - 0362 ONLY\0200-08SOLA\GIS\200-8_SitePlan.mxd
0 62.5 125 250
Feet
±

HELLMAN PROPERTY

SOLAR PANEL ARRAY
Site Plan
Exhibit 3
Coordinate System: State Plane 6 NAD 83
Projection: Lambert Conformal Conic
Datum: NAD 1983 2011
Map Prepared by: B. Gale, GLA
Date Prepared: January 4, 2023
1 inch = 125 feet
Key Map
Not to Scale
E 2nd St
San Gabriel River
Pacific Coast Highway
Study Area
Permanent Impacts
Temporary Impacts
100' Buffer of
Permanent Impacts
X:\00 - 0362 ONLY\0200-08SOLA\GIS\DelineationGIS\200-8_JD_SoilPits.mxd 0 62.5 125 250
Feet
±

HELLMAN PROPERTY

SOLAR PANEL ARRAY
Jurisdictional Determination Map
Exhibit 4
Coordinate System: State Plane 6 NAD 83
Projection: Lambert Conformal Conic
Datum: NAD 1983 2011
Map Prepared by: B. Gale, GLA
Date Prepared: March 15, 2023
1 inch = 125 feet
Key Map
Not to Scale
E 2nd St
San Gabriel River
Pacific Coast Highway
Study Area
Western Field
Eastern Field
Heron Pointe
Water Quality Basin
Non-Wetland Ponded Area
Data Point
X:\00 - 0362 ONLY\0200-08SOLA\GIS\SoilsGIS\200-8_Soils.mxd 0 62.5 125 250
Feet
±

HELLMAN PROPERTY

SOLAR PANEL ARRAY
Soils Map
Exhibit 5
Coordinate System: State Plane 6 NAD 83
Projection: Lambert Conformal Conic
Datum: NAD 1983 2011
Map Prepared by: B. Gale, GLA
Date Prepared: January 4, 2023
1 inch = 125 feet
Key Map
Not to Scale
E 2nd St
San Gabriel River
Pacific Coast Highway
Study Area
Bolsa Silt Loam, Drained
Bolsa Silty Clay Loam,
Drained
123
125
X:\00 - 0362ONLY\0200-08SOLA\GISV eg etationGIS\200-8_V eg etation.m xd 0 62.5 125 250 Feet±

HELLMAN PROPERTY

SOLAR PANEL ARRAY
V eg etation Map
Exh ibit 6A
Coordinate System : State Plane 6 NAD 83
Projection: Lam bert Conform al Conic
Datum : NAD 1983201
Map Prepared by: B. Gale, GLA
Date Prepared: March 28, 2023
1 inch = 125 feet
Key Map
Not to Scale
E 2nd St
San Gabriel River Pacific Coast Highway
Study Area
! ! ! ! ! ! ! ! !
! ! ! ! ! ! ! ! !
! ! ! ! ! ! ! ! !
! ! ! ! ! ! ! ! !
! ! ! ! ! ! ! ! ! Existing
Fuel Modification Zones
Vegetation Type
Alkali h eliotrope Fields
Annual Grasland/
Herbaceous Sem i-Natural Stands
Bach aris pilularis Sh rubland Alliance
Disturbed
Bach aris pilularis Sh rubland Alliance
Bach aris salicifolia Sh rubland Alliance
Basia h ysopifolia Asociation
Castor Bean Stands
Cresa truxillensis –
Distich lis spicata Herbaceous Alliance
Distich lis spicata – Annual Grases
Disturbed/Dev eloped
Malv ella leprosa Fields
Mixed Nativ e and
Non-Nativ e Herbaceous Fields
Mixed Sh rub Sem inatural Stands
Ornam ental
Raph anus sativ us Asociation
Salix asiolepis –
Bach aris salicifolia Sh rubland Alliance
Tree Tobaco Stands
X:\00 - 0362ONLY\0200-08SOLA\GISIm pactsGIS\200-8_V eg etation_Im pacts.m xd 0 62.5 125 250 Feet±

HELLMAN PROPERTY

SOLAR PANEL ARRAY
V eg etation Im pact Map
Exh ibit 6B
Coordinate System : State Plane 6 NAD 83
Projection: Lam bert Conform al Conic
Datum : NAD 1983201
Map Prepared by: B. Gale, GLA
Date Prepared: March 28, 2023
1 inch = 125 feet
Key Map
Not to Scale
E 2nd St
San Gabriel River Pacific Coast Highway
Study Area
Perm anent Im pacts
Tem porary Im pacts
! ! ! ! ! ! ! ! !
! ! ! ! ! ! ! ! !
! ! ! ! ! ! ! ! !
! ! ! ! ! ! ! ! !
! ! ! ! ! ! ! ! ! Existing
Fuel Modification Zones
Vegetation Type
Alkali h eliotrope Fields
Annual Grasland/
Herbaceous Sem i-Natural Stands
Bach aris pilularis Sh rubland Alliance
Disturbed
Bach aris pilularis Sh rubland Alliance
Bach aris salicifolia Sh rubland Alliance
Basia h ysopifolia Asociation
Castor Bean Stands
Cresa truxillensis –
Distich lis spicata Herbaceous Alliance
Distich lis spicata – Annual Grases
Disturbed/Dev eloped
Malv ella leprosa Fields
Mixed Nativ e and
Non-Nativ e Herbaceous Fields
Mixed Sh rub Sem inatural Stands
Ornam ental
Raph anus sativ us Asociation
Salix asiolepis –
Bach aris salicifolia Sh rubland Alliance
Tree Tobaco Stands
Photograph 1: West-facing view of easternmost area of the Project site. Note the high level of disturbance. Plant species in this area include alkali heliotrope, five-hook bassia, summer mustard, and perennial pepperweed. August 25, 2022.

Photograph 3:West-facing view of central portion of the Project site. Note the general lack of vegetation. August 25, 2022
Exhibit 7
– Page 1

HELLMAN PROPERTY SOLAR PANEL ARRAY
Site Photographs
Photograph 2: West-facing view of easternmost area of the Project site showing coyote brush growing along an oilfield pipeline. August 25, 2022.

Photograph 4: North-facing view of the easternmost portion of the Project site. The large patch of vegetation in the center of the photo is alkali heliotrope (Heliotropium curassavicum). August 25, 2022.

Photograph 5: West-facing view of western portion of the Project. This area is vegetated with the Distichlis spicata-annual grasses association, with a few small isolated patches of alkali heath (Frankenia salina) that do are not large enough to comprise a mapping unit. July 29, 2022.

Photograph 7: Southern tarplant growing in the Distichlis spicata – annual grasses alliance in the westernmost portion of the Project site. Note the high level of disturbance and lack of vegetatative cover. July 29, 2022 Exhibit 7
– Page
2 HELLMAN PROPERTY SOLAR PANEL ARRAY
Site Photographs
Photograph 6:View of Cressa truxillensis association in the northwest portion of the Study Area. This area will not be impacted by the proposed Project. August 25, 2022 Photograph 8: West-facing view of southern tarplant growing on the edge of a road.

July 29, 2022
X:\00 - 0362ONLY\0200-08SOLA\GIS\Spe c ialStatus Spe c ie s GIS\200-8_ Spe c ialStatus Spe c ie s .m xd 0 62.5 125 250
Fe e t
±

HELLMAN PROPERTY

SOLAR PANEL ARRAY
Spe c ial-Status Spe c ie s Map
Exhibit 8A
Coord inate Sys te m : State Plane 6 NAD 83
Proje c tion: Lam be rt Conform al Conic
Datum : NAD 1983201
Map Pre pare d by: B. Gale , GLA
Date Pre pare d : Marc h 28, 2023
1 inch = 125 feet
Key Map
Not to Scale
E 2nd St
San Gabriel River
Pacific Coast Highway
Stud y Are a
! ! ! ! ! ! !
! ! ! ! ! ! !
! ! ! ! ! ! !
! ! ! ! ! ! !
Exis ting Fue lMod ific ation Z one s
He ron Pointe Wate r Q uality Bas in
^_ Le as t Be ll’s Vire o Loc ation
2009 Rare Plants
2010 Rare Plants
2022 Rare Plants
2023 Rare Plants
Coulte r's Gold fie ld s Southe rn Tarplant
Coulte r's Gold fie ld s Southe rn Tarplant
Coulte r's Gold fie ld s
Southe rn Tarplant (1,072)
X:\00 - 0362 ONLY\0200-08SOLA\GIS\SpecialStatusSpeciesGIS\200-8_SouthernTarplantLocations.mxd 0 112.5 225 450 Feet
±

HELLMAN PROPERTY

SOLAR PANEL ARRAY
Southern Tarplant Locations Map
Exhibit 8B
Coordinate System: State Plane 6 NAD 83
Projection: Lambert Conformal Conic
Datum: NAD 1983 2011
Map Prepared by: B. Gale, GLA
Date Prepared: April 3, 2023
1 inch = 225 feet
Key Map
Not to Scale
E 2nd St
San Gabriel River Pacific Coast Highway
Study Area
Southern Tarplant (2022)
Historical Southern
Tarplant (2006-2010)
San Gabriel River
X:\00 - 0362ONLY\0200-08SOLA\GIS\Im pac ts GIS\200-8_ Spe c ialStatus Spe c ie s _ Im pac ts .m xd 0 62.5 125 250
Fe e t
±

HELLMAN PROPERTY

SOLAR PANEL ARRAY
Spe c ial-Status Spe c ie s Im pac ts Map
Exhibit 9
Coord inate Sys te m : State Plane 6 NAD 83
Proje c tion: Lam be rt Conform al Conic
Datum : NAD 1983201
Map Pre pare d by: B. Gale , GLA
Date Pre pare d : April 3, 2023
1 inch = 125 feet
Key Map
Not to Scale
E 2nd St
San Gabriel River
Pacific Coast Highway
Stud y Are a
Pe rm ane nt Im pac ts
Te m porary Im pac ts
! ! ! ! ! !
! ! ! ! ! !
! ! ! ! ! !
! ! ! ! ! ! Exis ting Fue lMod ific ation Z one s
He ron Pointe Wate r Q uality Bas in
^_ Le as t Be ll’s Vire o Loc ation
2009 Rare Plants
2010 Rare Plants
Coulte r's Gold fie ld s Southe rn Tarplant
Coulte r's Gold fie ld s Southe rn Tarplant
2023 Rare Plants: Coulte r's Gold fie ld s
2022 Rare Plants: Southe rn Tarplant (1,072)

APPENDIX A

FLORAL COMPENDIUM
The floral compendium lists species identified within the Study Area. Taxonomy follows Jepson (Baldwin et al. 2012) and, for sensitive species, the California Native Plant Society's Rare Plant Online Inventory (CNPS 2022). Common names are taken from Baldwin et al. (2012), Munz (1974), and Roberts (1998). An asterisk (*) denotes a non-native species. Also included are species that were observed by GLA in the Study Area in previous years for other biological surveys on the Hellman Property.

SCIENTIFIC NAME COMMON NAME

MONOCOTS

ARACACEAE PALM FAMILY
Phoenix canariensis Canary Island date palm

EUDICOTS

AMARANTHACEAE AMARANTH FAMILY
*Amaranthus albus tumbling pigweed

ASTERACEAE SUNFLOWER FAMILY
Baccharis pilularis coyote brush
Baccharis salicifolia mule fat
* Centaurea melitensis tocalote
Centromadia parryi ssp. australis southern tarplant
Conyza canadensis common horseweed
* Dittrichea graveolens stinkwort
* Glebionis coronaria crown daisy
Helianthus annuus western sunflower
Heterotheca grandiflora telegraph weed
*Lactuca serriola prickly lettuce
Lasthenia glabrata ssp. coulteri Coulter’s goldfields
*Pulicaria paludosa Spanish sunflower
*Silybum marianum milk thistle
*Sonchus oleraceus common sow-thistle
Stephanomeria virgata ssp. virgata tall wreath-plant

AIZOACEAE FIG-MARIGOLD FAMILY
* Mesembryanthemum crystallinum crystalline iceplant

BORAGINACEAE BORAGE FAMILY
Heliotropium curassavicum alkali heliotrope

BRASSICACEAE MUSTARD FAMILY
* Brassica nigra black mustard
* Brassica rapa field mustard
* Hirschfeldia incana summer mustard
* Lepidium latifolium broad-leaved peppergrass
* Raphanus sativus wild radish
* Sisymbrium irio London rocket

CHENOPODIACEAE GOOSEFOOT FAMILY
* Atriplex suberecta serrate-leaved saltbush
* Bassia hyssopifolia five-hook bassia
* Chenopodium album lamb’s quarters
* Salsola tragus Russian thistle

CONCOLVULACEAE MORNING GLORY FAMILY
Cressa truxillensis Alkali weed

EUPHORBIACEAE SPURGE FAMILY
* Ricinus communis castor bean

FABACEAE PEA FAMILY
* Melilotus albus white sweet clover
* Melilotus indica yellow sweet clover
* Medicago polymorpha bur-clover

FRANKENIACEAE FRANKENIA FAMILY
Frankenia salina alkali heath

GERANIACEAE GERANIUM FAMILY
* Erodium botrys long-beaked filaree
* Erodium cicutarium red-stemmed filaree
* Erodium moschatum white-stemmed filaree

LAMIACEAE MINT FAMILY
* Marrubium vulgare horehound

MALVACEAE MALLOW FAMILY
* Malva parviflora cheeseweed
Malvella leprosa alkali-mallow

POACEAE GRASS FAMILY
* Cortaderia selloana pampas grass
Distichlis spicata salt grass
* Avena barbata slender wild oat
* Bromus diandrus ripgut brome
* Hordeum marinum ssp. gussoneanum Mediterranean barley * Hordeum murinum ssp. leporinum hare barley
* Festuca perennis Italian rye grass

POLYGONACEAE BUCKWHEAT FAMILY
* Polygonum arenastrum common knotweed
* Rumex crispus curly dock

SOLANACEAE NIGHTSHADE FAMILY
Datura wrightii jimsonweed
*Nicotiana glauca tree tobacco

URTICACEAE NETTLE FAMILY
Urtica urens annual stinging nettle

APPENDIX B

FAUNAL COMPENDIUM
The faunal compendium lists species that were either observed within or adjacent to the Study Area. Also included are species that were observed by GLA in previous years for other biological surveys on the Hellman Property. Taxonomy and common names are taken from AOS (2022) for birds; Collins and Taggart (2009) and CDFW (2016) for reptiles and amphibians; and CDFG (2016) for mammals. Also included are species that were observed by GLA in and around the Study Area in previous years for other biological surveys on the Hellman Property.

SCIENTIFIC NAME COMMON NAME
BIRDS

COLUMBIDAE PIGEONS AND DOVES
Columbia livia rock dove
Zenaida macroura mourning dove

TROCHILIDAE HUMMINGBIRDS
Calypte anna Anna’s hummingbird
Selasphorus sasin Allen’s hummingbird

CHARADRIIDAE PLOVERS AND RELATIVES
Charadrius vociferus killdeer

CATHARTIDAE NEW WORLD VULTURES
Cathartes aura turkey vulture

PANDIONIDAE OSPREYS
Pandion haliaetus Osprey

ACCIPITRIDAE HAWKS AND HARRIERS
Accipiter cooperii Cooper’s hawk
Buteo jamaicensis red-tailed hawk
Circus cyaneus northern harrier
Elanus leucurus white-tailed kite

FALCONIDAE FALCONS
Falco sparverius American kestrel

TYRANNIDAE TYRANT FLYCATCHERS
Sayornis nigricans black phoebe
Sayornis saya Say’s phoebe
Tyrannus verticalis western kingbird

LANIIDAE SHRIKES
Lanius ludovicianus loggerhead shrike

VIREONIDAE VIREOS AND RELATIVES
Vireo bellii pusillis1 least Bell’s vireo

CORVIDAE JAYS, MAGPIES, AND CROWS
Corvus brachyrhynchos American crow
Corvus corax common raven

HIRUNDINIDAE SWALLOWS
Hirundo rustica barn swallow

MIMIDAE MOCKINGBIRDS AND TRASHERS
Mimus polyglottos northern mockingbird

STURNIDAE STARLINGS
Sturnus vulgaris European starling

PASSERELLIDAE NEW WORLD SPARROWS
Passerculus sandwichensis savannah sparrow
Melozone crissalis California towhee
Zonotrichia leucophrys white-crowned sparrow

FRINGILLIDAE FINCHES
Carduelis psaltria lesser goldfinch
Haemorhous mexicanus house finch

MAMMALS

GEOMYIDAE POCKET GOPHERS
Thomomys bottae Botta’s pocket gopher

CANIDAE FOXES, WOLVES, AND RELATIVES
Canis familiaris feral dog
Canis latrans coyote

PROCYONIDAE RACOONS
Procyon lotor raccoon
1 Observed in the Heron Pointe Water Quality Basin only. Does not occur in the Project site. 1940 E Deere Avenue, Suite 250 ● Santa Ana, California 92705 ● 949.837.0404 October 11, 2023
Devon Shay
Business Manager
Hellman Properties LLC
P.O. Box 2398
Seal Beach, California 90740
SUBJECT: Jurisdictional Delineation for the 12.46-Acre Hellman Property Solar Panel Array Study Area, Seal Beach, Orange County, California
Dear Ms. Shay:

This letter report summarizes our preliminary findings of U.S. Army Corps of Engineers (Corps), Regional Water Quality Control Board (Regional Board), California Department of Fish and Wildlife (CDFW) jurisdiction for the above-referenced property.1 The report also addresses the
potential presence of wetlands as defined under the California Coastal Act (CCA).

The Solar Panel Array Site (Project site) at the Hellman Property, Orange County [Exhibit 1] contains no blue-line streams as depicted on the U.S. Geological Survey (USGS) topographic map Los Alamitos, California [Exhibit 2]. On July 29, August 25, and October 25, 2022, and March 6, 2023, regulatory specialists of Glenn Lukos Associates, Inc. (GLA) examined the Project site and a 100-foot buffer area surrounding the Project site, which comprise a 12.46 acre Study Area, to determine the presence and limits of (1) Corps jurisdiction pursuant to Section 404 of the Clean Water Act (CWA), (2) Regional Board jurisdiction pursuant to Section 401 of the CWA and Section 13260 of the California Water Code (CWC), and (3) CDFW jurisdiction pursuant to Division 2, Chapter 6, Section 1600 of the Fish and Game Code. Enclosed is an 80- scale map [Exhibit 3] that depicts the areas evaluated for Corps, Regional Board and CDFW jurisdiction and wetlands defined by the CCA. A soil map is attached as Exhibit 4. For purposes of this report, the Study Area is separated into a western field and eastern field, which are depicted on Exhibit 3. Photographs to document the topography, vegetative communities, and areas evaluated for jurisdiction are provided as Exhibit 5. A map depicting the results of the National Wetland Inventory database search is enclosed as Exhibit 6. Data sheets are attached as Appendix A.
1 This report presents our best effort at estimating the subject jurisdictional boundaries using the most up-to-date regulations, written policy, and guidance from the regulatory agencies. Only the regulatory agencies can make a final determination of jurisdictional boundaries.

APPENDIX C
Devon Shay
Hellman Properties LLC
October 11, 2023

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There are no areas of Corps jurisdiction at the site, including wetlands as defined under Section 404 of the Clean Water Act.

There are no areas of Regional Board jurisdiction at the site, including wetlands as defined under the Porter Cologne Act as set forth in the State Board Wetland Definition and Procedures.

There are no areas of CDFW jurisdiction at the site, including streams, lakes, wetlands, or riparian habitat pursuant to Section 1602 of the Fish and Game Code.

The site contains no areas of potential wetlands as defined under the California Coastal Act. The site does not contain indicators for hydric soils, nor does it contain indicators for wetland hydrology. The site does have small, localized areas with a predominance of wetland indicator plants; however, the overall composition of vegetation does not support a finding of hydrophytic vegetation. The site also has areas that exhibited localized ponding for greater than 14 days in Spring 2023; however, this ponding was due to well above average rainfall and frequent storms that constantly refilled the ponded areas, which does not support a finding of wetland hydrology, as discussed in the Results section below.

I. METHODOLOGY
Prior to beginning the field delineation, a color aerial photograph, a topographic base map of the property, the previously cited USGS topographic map, a soils map, and National Wetland Inventory “Wetland Mapper” website2 were examined to determine the locations of potential areas of Corps, Regional Board, and CDFW jurisdiction and wetlands defined under the CCA.

Suspected jurisdictional and/or wetland areas were field checked for evidence of stream activity and/or wetland vegetation, soils and hydrology. Potential wetland areas were evaluated using the methodology set forth in the U.S. Army Corps of Engineers 1987 Wetland Delineation Manual3 (Wetland Manual) and the 2008 Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Arid West Supplement (Arid West Supplement).4 Reference was also made to the 2019 State Wetland Definition and Procedures for Discharges of Dredged or Fill Material to Waters of the State (State Board Wetland Definition and Procedures) to identify suspected State wetland habitats as regulated by the Regional Board. 5 While in the field, the
2 https://fwsprimary.wim.usgs.gov/wetlands/apps/wetlands-mapper/ 3 Environmental Laboratory. 1987. Corps of Engineers Wetlands Delineation Manual, Technical Report Y-87-1, U.S. Army Engineer Waterways Experimental Station, Vicksburg, Mississippi. 4 U.S. Army Corps of Engineers. 2008. Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Arid West Region (Version 2.0), ed. J. S. Wakeley, R. W. Lichvar, and C. V. Noble. ERDC/EL TR-08-28.

Vicksburg, MS: U.S. Army Engineer Research and Development Center. 5 State Water Resources Control Board. 2019. State Wetland Definition and Procedures for Discharges of Dredged or Fill Material to Waters of the State.

Devon Shay
Hellman Properties LLC
October 11, 2023

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locations where data was collected were recorded with a sub-meter Trimble GPS device in conjunction with a color aerial photograph using visible landmarks.

In order to eliminate sampling bias, data collection points for potential wetland hydrology, soils, and vegetation in the western field were located along four transects in a rough grid pattern. The spacing between of each of the points and between the four transects was determined using a random numbers generator [Exhibit 3].

The National Cooperative Soil Survey (NCSS) has mapped the following soil types as occurring in the general vicinity of the project site:

Bolsa Silty Clay Loam
The Bolsa series consists of somewhat poorly drained soils on alluvial fans. These soils formed in mixed alluvium. Slopes are from 0 to 2 percent. In a typical profile, soil from 0 to 12 inches consists of light brownish gray (10YR 6/2) silty clay loam that becomes dark grayish brown (10YR 4/2) when moist. Soil from 12 to 18 inches consists of light brownish gray (10YR 6/2) silty clay loam, which becomes dark grayish brown (10YR 4/2) when moist and exhibits few, faint mottles. These soils are typically used for row and field crops, as well as urban development.

The Bolsa series is not identified as hydric in the SCS's publication, Hydric Soils of the United States or in the Hydric Soil List for Orange County and Western Part of Riverside County, California.

II. JURISDICTION
A. Army Corps of Engineers
Pursuant to Section 404 of the Clean Water Act, the Corps regulates the discharge of dredged and/or fill material into waters of the United States. The term “waters of the United States” is defined in Corps regulations at 33 CFR Part 328.3(a) as:
(1) Waters which are:
(i) Currently used, or were used in the past, or may be susceptible to use in interstate or foreign commerce, including all waters which are subject to the ebb and flow of the tide;
(ii) The territorial seas; or
(iii) Interstate waters;
Devon Shay
Hellman Properties LLC
October 11, 2023

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(2) Impoundments of waters otherwise defined as waters of the United States under this definition, other than impoundments of waters identified under paragraph (a)(5) of this section;
(3) Tributaries of waters identified in paragraphs (a)(1) or (2) of this section that are relatively permanent, standing or continuously flowing bodies of water; (4) Wetlands adjacent to the following waters:
(i) Waters identified in paragraph (a)(1) of this section; or (ii) Relatively permanent, standing or continuously flowing bodies of water identified in paragraph (a)(2) or (a)(3) of this section and with a continuous surface connection to those waters;
(5) Intrastate lakes and ponds not identified in paragraphs (a)(1) through (4) of this section that are relatively permanent, standing or continuously flowing bodies of water with a continuous surface connection to the waters identified in paragraph (a)(1) or (a)(3) of this section.

Corps regulations at 33 CFR Part 328.3(b) exclude the following from being “waters of the United States” even where they otherwise meet the terms of paragraphs (a)(2) through (5) above:
(1) Waste treatment systems, including treatment ponds or lagoons, designed to meet the requirements of the Clean Water Act;
(2) Prior converted cropland designated by the Secretary of Agriculture. The exclusion would cease upon a change of use, which means that the area is no longer available for the production of agricultural commodities.

Page 5 ends

(7) Waterfilled depressions created in dry land incidental to construction activity and pits excavated in dry land for the purpose of obtaining fill, sand, or gravel unless and until the construction or excavation operation is abandoned and the resulting body of water meets the definition of waters of the United States; and
(8) Swales and erosional features (e.g., gullies, small washes) characterized by low volume, infrequent, or short duration flow.

1. Wetland Definition Pursuant to Section 404 of the Clean Water Act The term “wetlands” (a subset of “waters of the United States”) is defined at 33 CFR 328.3(c)(1) as “areas that are inundated or saturated by surface or ground water at a frequency and duration sufficient to support, and that under normal circumstances do support, a prevalence of vegetation typically adapted for life in saturated soil conditions. Wetlands generally include swamps, marshes, bogs, and similar areas.” In 1987 the Corps published the Wetland Manual to guide its field personnel in determining jurisdictional wetland boundaries. The methodology set forth in the Wetland Manual and the Arid West Supplement generally require that, in order to be considered a wetland, the vegetation, soils, and hydrology of an area exhibit at least minimal hydric characteristics. While the Wetland Manual and Arid West Supplement provide great detail in methodology and allow for varying special conditions, a wetland should normally meet each of the following three criteria:
• More than 50 percent of the dominant plant species at the site must be hydrophytic in nature as published in the most current national wetland plant list; • Soils must exhibit physical and/or chemical characteristics indicative of permanent or periodic saturation (e.g., a gleyed color, or mottles with a matrix of low chroma indicating a relatively consistent fluctuation between aerobic and anaerobic conditions); and
Devon Shay
Hellman Properties LLC
October 11, 2023

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• Whereas the Wetland Manual requires that hydrologic characteristics indicate that the ground is saturated to within 12 inches of the surface for at least five percent of the growing season during a normal rainfall year, the Arid West Supplement does not include quantitative criteria with the exception for areas with “problematic hydrophytic vegetation”, which require a minimum of 14 days of ponding to be considered a wetland.

B. Regional Water Quality Control Board
The State Water Resource Control Board and each of its nine Regional Boards regulate the discharge of waste (dredged or fill material) into waters of the United States6 and waters of the State. Waters of the United States are defined above in Section II.A and waters of the State are defined as “any surface water or groundwater, including saline waters, within the boundaries of the state” (California Water Code 13050[e]).

1. State Wetland Definition
The State Board Wetland Definition and Procedures define an area as wetland as follows: “An area is wetland if, under normal circumstances, (1) the area has continuous or recurrent saturation of the upper substrate caused by groundwater, or shallow surface water, or both; (2) 6 Therefore, wetlands that meet the current definition, or any historic definition, of waters of the U.S. are waters of the state. In 2000, the State Water Resources Control Board determined that all waters of the U.S. are also waters of the state by regulation, prior to any regulatory or judicial limitations on the federal definition of waters of the U.S. (California Code or Regulations title 23, section 3831(w)). This regulation has remained in effect despite subsequent changes to the federal definition. Therefore, waters of the state includes features that have been determined by the U.S. Environmental Protection Agency (U.S. EPA) or the U.S. Army Corps of Engineers (Corps) to be “waters of the U.S.” in an approved jurisdictional determination; “waters of the U.S.” identified in an aquatic resource report verified by the Corps upon which a permitting decision was based; and features that are consistent with any current or historic final judicial interpretation of “waters of the U.S.” or any current or historic federal regulation defining “waters of the U.S.” under the federal Clean Water Act.

Devon Shay
Hellman Properties LLC
October 11, 2023

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Seal Beach City CouncilDecember 8, 2025

Seal Beach City Council
December 8, 2025