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Attachment E - Feasability Study

City Council and Concurrent Authorities
July 9, 2024

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Attachment E - Feasability Study
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July 9, 2024
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ATTACHMENT E
Amendment Feasibility Analysis
1 PREPARED BY

The City of Stockton Community Devel opment Department with assistance from PlaceWorks (Climate, Economics, CEQA).

INTRODUCTION

On December 6, 2022, the City Council approved separate settlement agreements with the State Attorney General and Sierra Club, in conjun ction with the approval of a warehouse development project. Both agreem ents obligated City staff to propose an ordinance to identify and apply feasible mitigation measures to qualifying warehouse and logistics facility projects to minimize their potentially signif icant environmental impacts.

Per the settlement agreements, including a Memorandum of Agreement (MOA), a warehouse ordinance was required to be consi dered by the City Council by December 31, 2023.

On December 12, 2024, the City Council adopted a new industrial warehouse ordinance in in relation to a specific industrial pr oject in compliance with the separate settlement agreements between the Cit y and the State Attorney Gener al’s Office (AG) and Sierra Club. During the adoption public hearing, in response to public comment, the Council directed staff to explore additional modifica tions to six development standards via an ordinance amendment for Council’s approval c onsideration no later than July 2024.

Those modifications include consideration of:

1. Increasing the warehouse size threshold for ordinance applicability.

2. Exempting projects located within the city limit as of 2023.

3. Adding a truck parking and driving setback.

4. Allowing future non-solar clean energy facilities.

5. Expanding electric truck charging infrastructure requirements.

6. Expanding electric automobile charging infrastructure requirements.

After outreach to local stakeholders, on March 6, 2024, the City hosted a public workshop on the proposed modifications at the Robert J. Cabral Agricultural Center from 5 p.m. to 7 p.m. The workshop was attended by 30 members of the publ ic, with approximately 20 attending virtually via Teams. At the meeting, staff described the proposed modifications and responded to comments and questions rais ed by attendees. All hearing and workshop materials for the Ordinance are av ailable on the Community Development Department “Zoning Update” webpage.

Project Description
The Project entails a City in itiated amendment of the Stockton Municipal Code, Title 16 (Development Code), Chapter 16.80 (Standards for Specific Land Uses) to modify Section 16.80.390 (Logistic Warehouse). Per Title 16.116, the City Council is the review authority for amendments to the Developm ent Code, based on the recommendation of the Planning Commission. The process for c onsideration entails providing public notice of and conducting public hearings, with any decisions needing to be supported by ATTACHMENT E
Amendment Feasibility Analysis
2 required findings of approval.

Project Objectives
The warehouse ordinance, curr ently or if modifi ed, applies to all qualifying logistics warehouse projects whether discretionary or ministerial and whether CEQA applies or not, to achieve the following objectives:

 Reduce potential environmental impacts through enhanced design standards.  Balance the need for high-quality and sust ainable design with project feasibility.  Continue to streamline reviews and prov ide clarity in the development review process.
 Create consistency through objective design standards.  Minimize future legal challenges through enhanced and objective design.

As stated at the December 12, 2023, City Council meeting, the City believes it has met all of the original obligations of the settlement agreements with the State Attorney General and Sierra Club, whether the ordinance is modified or not.

FEASIBILITY ANALYSIS

The following provides findings that incorporate feasibility analysis, explanations, responses to comments, and conclusions of staff’s review of all proposed standards that require feasibility consideration consistent with the California Environmental Quality Act (CEQA). This feasibility analysis was prepared by the City with the assistance of outside consultants (PlaceWorks) hired independently by the City.

Feasibility is defined by CEQA as being: “…capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, legal, social, and technological factors” (Guidelines Section 15364).

This analysis focuses on the six modifications, pursuant to Council direction on December 12, 2023. The following summarizes each of the requested modifications and offers considerations for the Commission’s review . These considerations are derived from potential impacts, or feedback received so far.

Modification #1: Increase Threshold from 100,000 to 400,000 square feet

Description
Consideration of the following change: These standards shall apply to all logistics warehouses 1400,000 square feet in size or greater.

Development Considerations
 Would increase the minimum applicability of logistics warehouse size from 100,000 to 400,000 square feet.
 Smaller warehouse facilities (100,000 to 399,999 square feet) would not be subject to the recently adopted warehouse standards.

ATTACHMENT E
Amendment Feasibility Analysis
3  Size increase would lessen the unint ended impacts on smaller business owners and operators (i.e., non-fortune 500 companies).
 Minimum lot sizes for new facilities could be increased by 380% as the anticipated minimum lot sizes needed to develop a new warehouse could increase from 5.5 acres to 21 acres based on typical lot size needed for facilities of 100,000 versus 400,000 square feet in size.
 The last 10 entitled logist ics projects in Stockton measured an average total size range of 700,000 square feet to 1,000,000 square feet.
 Since 2016, 37 building permits have been approved for new warehouses 100,000 sf or greater (average size ±420,000 square feet) as shown on Exhibit 1- Warehouse Building Permits.

Environmental Considerations
The proposed modification would result in positive environmental effects on the environment by mitigating the effects of t he large majority of logistic warehouse operations, which are greater than 400,000 square feet The proposed threshold is consistent with statewide and local best management practices, including the original City of Fontana ordinance t hat has been recognized by the Attorney General for setting the bar for warehouse development regulations.

Feasibility
This amendment is not a development standard, but rather a threshold on the applicability of the adopted warehouse standards (SMC 16.80.390). Therefore, feasibility under CEQA is not applicable. However, this modification will continue to achieve the purposes of the adopted Ordinance (i.e. reduce potential environmental impacts of warehouse development) while insulating smaller warehouse operations from additional development standards that could render their projects/businesses financially impractical.

Currently adopted warehouse st andards could prevent sma ller businesses from being able to continue or locate in Stockton due to the scale of development costs. Further, the 10 most recent logistics projects in Stockton have averaged 850, 000 square feet, with individual operation size increasing consistently over the past decade. In the last 8 years, the average warehouse size has been approximately 420,000 square feet, indicating that the increased threshold is appropriate for Stockton.

Modification #2: Exempt Projects within the City Limit as of 2023

Description
Consideration of the following addition: Warehouse Ordinance standards shall not apply to any new building constructed on property that was incorporat ed into the City of Stockton prior to December 31, 2023.

Development Considerations
 The recently adopted Warehouse Ordinance (effective January 11, 2024) would not apply to new logistic warehouse facilities constructed on vacant properties that were located within the Stockton City Limits prior to December 31, 2023.

ATTACHMENT E
Amendment Feasibility Analysis
4  Ordinance Standards would only apply towards future warehouse logistics development projects that were not current ly in the Stockton City Limits as of December 31, 2023.
 SMC Section 16.04.050 already regulates project applicability and “vested” rights of completed applications when new C ode standards are adopted. The inclusion of the additional “vesting” option would limit the City’s use of the warehouse standards to future annexation projects that meet the size thresholds. Either at the time of the annexation or after.
 This request refers to policy determination as opposed to land use - how the City wishes to utilize the new warehouse standards, rather than an additional means to lock in development rights.

Environmental Considerations
This modification would limit ordinance miti gation to new projects on land annexed into the City starting in 2024. It would need to be determined whether the ordinance would apply to rezoning of land (including prior annexations amended to allow industrial uses).

Feasibility
SMC Section 16.04.050 already regulates project applicabil ity and “vested” rights of completed applications when new Code standar ds are adopted. It is not necessarily uncommon to identify certain exemptions from new Code standards, however language should clearly indicate that the exemption is specific to the issue at hand; in this case the applicability of SMC Section 16.80.390 on warehouse development projects located on lands annexed prior to December 31, 2023. Exempting adopted warehouse development standards on parcels currently in the City limits will increase t he feasibility of logistic warehouse development on said parcels.

Modification #3: Adjustments to minimum setback standards when adjacent to sensitive receptors

Description
When abutting sensitive receptors:
 Addition of a 2:1 building setback to build ing height ratio requirement (i.e. 2 feet of setback from property line for every 1 foot of building height);  Remove “physically impossible” consi deration for unique site constraints in complying with 300-foot loading dock setback requirement;  Remove the use of ‘EV only’ loading docks within the 300-foot loading dock setback area;
 Prohibit loading docks, truck entries and dr ive aisles within the 300-foot loading dock setback area;

Development Considerations
 Prohibition of all truck (Electric Vehicl e and Fuel) movement, parking, and access within 300-feet of any sensitive receptor defined by code will impact future site design including building placement, loca tion of parking, and access, with only landscaping allowed in the buffer area.

ATTACHMENT E
Amendment Feasibility Analysis
5  The Change would achieve the Environment al Justice Alliance’s desired result of completely prohibiting trucks within 300-feet of a defined sensitive receptor.  Could significantly impact site design for smaller projects where the project site does not have enough spaces to accommodate a total restriction of trucks within 300-feet. For example, a 5.5-acre site proposing a 100,000 square foot warehouse facility could have a project boundary of around 480 feet x 480 feet. A 300-foot buffer restriction would restrict truck movement to less than 25-percent of the site of the entire project site should it be boarded on one side by a sensitive receptor.  Could result in larger land annexati ons to accommodate the 300-foor buffer restriction.

Environmental Considerations
The proposed standard is consis tent with State, local, and best management practices.

The new loading standard maintains the intent of the existing 300-foot buffer requirement and increases the setback distance from the building to the sensitive receptors which will reduce noise, visibility, and possibly also odor impacts.

It is important to note that, absent adoption of the ordinance, ministerial projects would not be required to exceed minimum standards, therefore, these st andards will lessen environmental impacts for all future projec ts and align with the State’s objectives on reducing noise, visibility, and possible odor impacts to sensitive receptors.

The modification could increase air quality pr otection for adjacent sensitive receptors; however, an analysis would need to be performed, which would be difficult without project specific impacts to compare to.

This modification could also lead to the accelerated loss of farmland as future annexation projects may need to bring in additional acreage to accommodate the 300-foot buffer.

Feasibility
The adopted ordinance already includes a 300- foot setback for loading docks. This modification could significantly impact site design on parcels close to the current minimum lot size (5.5 acres for a 100,000 square foot warehouse). For example, truck movement on a 5.5-acre site proposing a >100,000 square feet facility would be restricted to less than 25% of the site, which is also where buildings would typically be located (see Attachment C - Workshop Presentation, “Setback Project Example” slide). Limitations on placement and size of buildings could seve rely reduce the feasib ility of warehousing operations on smaller parcels. The current ordinance allows a smaller setback if loading docks are limited to only EV trucks within the 300-foot buffer.

Since the total amount of warehouse space would be significantly reduced by the restriction of truck movement (EV and fossil fuel) within the 300-foot buffer, it is infeasible due to its impracticality, technological and economic factors.

An analysis conducted by staff using Geog raphic Information Systems (GIS) mapping indicated that a 300-foot buffer would have a significant impact, reducing buildable area ATTACHMENT E
Amendment Feasibility Analysis
6 by 60-80 percent for project sites 5-to-6 acres in size. Parcels that were large enough and not next to receptors that w ould trigger the buffer requirem ent were identified within the City’s sphere of influence, but not in a legally eligible position to be annexed into the City as they were not contiguous to the City limits (defined as “territory adjacent to an agency to which annexation is proposed”), a State (Local Government Reorganization Act) and local requirement for annexatio n consideration. Thus, reducing the availability of developable land options for future annexat ion and potentially discouraging economic investment in Stockton.

This requirement could also result in the effective loss of all viable use of some industrial parcels in Stockton. Generally, an industrial developer makes full use of a site, given the needs for truck movement onsite, employee parking, stormwater management, and other needs. The required setback area could necessitate the developer purchasing additional land area that would provide no economic benefit for the property owner or tenant.

PlaceWorks reviewed ten recent Stockton warehouse projects 1,four of which appear as
though a buffer would be required if dev eloped under the proposed language.

PlaceWorks estimates the total property line length for these four buffers would be 13,135 feet. Across the four sites, the 300-foot buffer would require the purchase of an additional

90.5 acres of land (assuming the developer builds similarly sized warehouses and simply purchases additional land to accommodate the buffer). Th is additional land area would be a 28 percent increase in site area for the four projects, with the individual sites requiring an increase in size ranging from 23 to 52 percent, without providing increased indoor operational capacity.

Based on an analysis of industrial property sa les in San Joaquin County from 2021 to 2023, PlaceWorks, estimates the cost to acqui re industrial zoned land at $699,000 per acre. At this land value, t he 300-foot buffer would increase the cost of development by $15.8 million based on a weighted average for t he four projects evaluated. If these projects were developed under the propos ed language and had to purchase additional land to accommodate a 300-foot buffer, lease rates would need to increase by $0.09 per square foot per month (based on a permanent loan for the full cost 2 of the additional land,
with an interest rate of 7.07 percent, and a debt service coverage ratio of 1.45, representing third quarter 2023 market conditions as reported by RealtyRates.com). This would represent a 13 percent increase in the average lease rate, $0.71 per square foot per month, as reported by CB Richard Ellis for Stockton in their Central Valley Industrial Figures Q3 2023 report. Currently, Stockton has the th ird highest lease rates in the Central Valley, and an increase of $0.09 woul d push it into second place, just behind Tracy, where the average lease rate is $0.82. However, this accounts just for the cost of the land; the cost of providing landscaping also needs to be considered.

1 Permit numbers: P19‐0189, P20‐0114, P20‐0115, P20‐0242, P20‐0395, P20‐0805, P21‐0277, P21‐0576, P21‐0980. 2 Typically, a construcƟon loan might provide half the cost of land acquisiƟon, with the developer’s equity investment making up the remainder . It is very unlikely that a warehouse would be financially feasible if the developer is required to invest an addiƟonal $7.9 million to purchase land that generates no economic acƟvity.

However, it is also not certain whether a developer would be able to finance the full buffer‐area acquisiƟon through the construcƟon loan or permanent loan.

ATTACHMENT E
Amendment Feasibility Analysis
7 An alternative result could be an increase in larger annexation pr oposals in order to develop warehouses in accordance with the adopted ordinance – accelerating the permanent elimination of fa rmland, in direct contradiction with San Joaquin County General Plan (SJC GP) 3, the San Joaquin County Multi-Species Habitat Conservation and Open Space Plan (SJMSCP), and Sierra Club California Urban Growth Management Policy Guidelines4. Further, the premature conversion of farmland could create pressure to develop on surrounding agricultural lands, conflicting with SJC GP Goal LU-7 Provide for the long-term preservation of productive farmland.

Modification #4: Solar Equipment Installation Requirements

Description
Consideration of the following addition: The solar system installation should be done by owners, operators, tenants, or a qualified solar system contractor.

Development Considerations
 Current permitting process already require s this for solar system construction permit approval.

Environmental Considerations
Solar is the only commercial-scale proven clean energy source to reduce GHG emissions typically associated with warehouse operati ons, but other clean energy sources are in development and realistically could emerge in the coming years. While the adopted warehouse ordinance includes new solar r equirements and definitions, the proposed modification does not increase or decrease the amount of solar used in the project. Only how they are installed.

Feasibility
This modification would have no effect on feasibility in comparison with the solar requirement in the current ordinance.

Modification #5: Expand Electric Truck Charging Facilities

Description
Facilitate future charging stations by ex panding the current electric vehicle charging station infrastructure requirement to in clude light-heavy duty (LHD) and medium-heavy duty (MHD) in addition to heavy-heavy duty (HHD) trucks. It also includes new Electric Vehicle Chargers Stations (EVCS) standards for EV truck conduits to be installed. This does not require charging stations, but instead, that truck docking stations provide EV ready hook-ups to meet future needs.  Conduit should be provided on the site to serve

3 Goal LU ‐1.7 Farmland PreservaƟon
4 hƩps://www.sierraclub.org/sites/default/files/sce/mother‐lode‐ chapter/Website/Growth%20Management%20Guidelines.pdf
ATTACHMENT E
Amendment Feasibility Analysis
8 50% of the number of truck docking stations. Location of conduit is at discretion of the developer (e.g., truck trailer parking spaces or docking stations).

Development Considerations
 Could potentially lead to more EV char ging stations and EV-ready facilities.  Potential added cost for additional spaces.
 Currently adopted California Green Buil ding Standards Code (CALGreen) generally already requires this. In addition to the conduit requirements, CALGreen currently requires upsizing of the elec trical service to accommodate future medium- and heavy-duty EVCS for warehouse uses.

CALGreen Code Section 5.106.5.4 requires installation of pow er supply equipment for medium- and heavy-duty electric vehicles in conjunction with new warehousing uses.

Section 5.106.5.4.1 also requires electric vehicle charging readiness features, in part to avoid future demolition when adding EV s upply and distribution equipment, including spare raceway(s) or busway(s) and adequate capacity for transformer(s). Service panels or subpanel(s) shall be installed at the time of construction in accordance with the California Electrical Code. Construction plans and specifications shall include, but are not limited to, the following:

1. The transformer, main service equipm ent, and subpanels shall meet the minimum power requirement in Tabl e 5.106.5.4.1 to accommo date the dedicated branch circuits for the future installation of EV supply equipment.

2. The construction documents shall include one or more location(s) convenient to the planned off-street loading space(s) reserved for medium- and heavy-duty ZEV charging cabinets and charging dispensers, and a pathway reserved for routing of conduit from the termination of the race way(s) or busway(s) to the charging cabinet(s) and dispenser(s), as shown in Table 5.106.5.4.1.

3. Raceway(s) or busway(s) originating at a main service panel or a subpanel(s) serving the area where potential futu re medium- and heavy-duty EVSE will be located and shall terminate in close proximity to the potential future location of the charging equipment for medium- and heavy-duty vehicles.

4. The raceway(s) or busway(s) shall be of sufficient size to carry the minimum additional system load to the future lo cation of the charging for medium- and heavy-duty ZEVs as shown in Table 5.106.5.4.1.

5. CALGreen Table 5.106.5.4. 1: (shortened for clarity)

ATTACHMENT E
Amendment Feasibility Analysis
9 RACEWAY CONDUIT AND PANEL POWER RE QUIREMENTS FOR MEDIUM- AND

HEAVY-DUTY EVSE

BUILDING SIZE
(SQUARE FEET)

NUMBER OF

OFF-STREET

LOADING SPACES

ADDITIONAL CAPACITY REQUIRED
(KVA) FOR RACEWAY & BUSWAY

AND TRANSFORMER & PANEL
20,000 to 256,000
1 or 2 200
3 or Greater 400
Greater than 256,000 1 or Greate r 400

Environmental Considerations
This modification is current business as usual since California Green Building Standards Code (CALGreen) generally already requires these facilities for warehouse uses.

Feasibility
Given that CALGreen standards generally mirror this requirement, determining feasibility is a moot point. Infrastructure for both me dium duty and light duty EV trucks currently carries a substantial cost increase compared to that for diesel trucks; however, the extent of this added cost will vary depending on how many trucks in a fleet would meet the definition of being domiciled at the warehouse facility.

Due to the current market restrictions for pr oviding a full EV fleet, it can be difficult to assess at the time of building permit how many EV spaces or capacity will be needed, but this modification only requires the installation of conduit and therefore does not consume site coverage that might be needed for other uses until EV truck parking is needed in the future.

Modification #6: Expand Electric Automobile Charging Facilities

Description
Consideration of the following additions:
 At least 10% of all passenger vehicle parki ng spaces shall be electric vehicle (EV) ready, with all necessary conduit and related appurtenances installed.  At least 5% of all passenger vehicle parking spaces shall be equipped with working Level 2 Quick charge EV charging statio ns installed and operational, prior to building occupancy.
 Signage shall be installed indicating EV c harging stations and specifying that spaces are reserved for clean air/EV vehicles.

ATTACHMENT E
Amendment Feasibility Analysis
10  Unless superior technology is developed that would replace the EV charging units, facility operator and any successors in interest shall be responsible for maintaining the EV charging stations in working order for the life of the facility.

Development Considerations
 Potential additional EV c harging and quick charging spaces.  Potential added Cost for additional spaces.
 Current adopted California Green Buildi ng Standards Code (CALGreen) generally requires this. CALGreen currently has minimum requirements to provide EV capable spaces in quantit ies greater than the proposed amendment and substantially similar requirements for spaces provided with EV equipment.

CALGreen currently requires Level 2 chargers or the highest-level Direct Current Fast Charging type.

CALGreen Code Section 5.106.5.3 Electric vehicle (EV) charging: Construction to provide electric vehicle infrastructure and facilitat e electric vehicle charging shall comply with Section 5.106.5.3.1 and shall be provided in accordance with regulations in the California Building Code and the California Electric al Code. CALGreen Code Section 5.106.5.3.1 EV capable spaces: EV capable spaces s hall be provided in accordance with Table

5.106.5.3.1 and the following requirements:

1. Raceways complying with the Californi a Electrical Code and no less than 1- inch (25 mm) diameter shall be provided and shall originate at a service panel or a subpanel serving the area and shall terminate in close proximity to the proposed location of the EV capable space and into a suitable listed cabinet, box, enclosure or equivalent. A common raceway may be used to serve multiple EV capable spaces.

2. A service panel or subpanel(s) shall be provided with panel space and electrical load capacity for a dedicated 208/240 volt, 40-ampere minimum branch circuit for each EV capable space, with delivery of 30-ampere minimum to an installed EVSE at each Electric Vehicle Charging Station (EVCS).

3. The electrical system and any on-site distribution transformers shall have sufficient capacity to supply full rated amperage at each EV capable space.

4. The service panel or subpanel circuit directory shall identify the reserved overcurrent protective device space( s) as “EV CAPABLE”. The raceway termination location shall be permanently and visibly marked as “EV CAPABLE.”

ATTACHMENT E
Amendment Feasibility Analysis
11 CALGreen Table 5.106.5.3.1

TOTAL NUMBER

OF ACTUAL

PARKING
SPACES

NUMBER OF

REQUIRED

EVCAPABLE
SPACES

NUMBER OF EVCS (EV CAPABLE
SPACES PROVIDED WITH EVSE)2
0–9 0 0
10-25 4 0
26–50 8 2
51–75 13 3
76–100 17 4
101–150 25 6
151–200 35 9
201 and over 20 percent of total 1 25 percent of EV capable spaces 1

CALGreen Code Section 5.106.5.3.2 Electric vehicle charging stations (EVCS):

EV capable spaces shall be provided with EVSE to create EVCS in the number indicated in Table 5.106.5.3.1. The EVCS required by Table 5.106.5.3.1 may be provided with EVSE in any combination of Level 2 and Direct Current Fast Chargi ng (DCFC), except that at least one Level 2 EVSE shall be provided. One EV charger with multiple connectors capable of charging multiple EVs simultaneously shall be permitted if the electrical load capacity required by Section 5.106.5.3.1 for each EV capable space is accumulatively supplied to the EV charger.

The installation of each DCFC EVSE shall be permitted to reduce the minimum number of required EV capable spac es without EVSE by five and reduce proportionally the required electrical load capacity to the service panel or subpanel.

Environmental Considerations
This modification is current business as usual since California Green Building Standards Code (CALGreen) generally already requires thes e facilities, including Level 2 chargers or the highest-level Direct Current Fast Charging type.

Feasibility
It can be very difficult to assess at the time of building permit how many extra EV spaces or capacity will be needed, and an initial esti mate below actual demand could render future tenants in violation of this or dinance and lead to undue effort and cost to supplementing EV areas beyond the parking needed.

The California Green Building Standard C ode (CALGreen) currently has minimum requirements to provide EV capable spaces in quantities greater than the proposed amendment and substantially similar requi rements for spaces provided with EV equipment. CALGreen is curr ently adopted and enforceable in the City of Stockton per ATTACHMENT E
Amendment Feasibility Analysis
12 Ordinance No. 2022-11-15-1203. The amendment requests 10% of all passenger vehicle spaces are EV capable spaces with 5% of all passenger vehicle spaces provided with EV equipment. For a typically sized warehouse development (row 5 or greater in the table above), CALGreen will require 16-20% EV capable spaces and 4-5% of spaces provided with EV equipment. Further, the amendment requests Level 2 chargers in EV equipped spaces. CALGreen already requires Level 2 chargers or the highest-level Direct Current Fast Charging type. This part of the request is not a higher standard than current minimum code. The 5% EV equipped requirement in the amendment may be slightly higher than current minimum code in some cases depending on number of spaces in the development, and current minimum code does not address the maintenance of EV equipment for the life of the facility as requested in the amendment. Given that CALGreen standards generally exceed this requirement, determining feasibility is a moot point.

SUMMARY
The City finds that the modifications wo uld have the following environmental and economic benefits:

Feasibility Findings
 The proposed are consistent with statewide and local best management practices and will automatically correspond with changes in minimum building requirements (CALGreen) and air quality standards adopted by the State to meet State Carbon Neutrality objectives, including projec t reviews, construction standards and practices, and monitoring by regional and State agencies.  The proposed measures are consistent with many General Plan policies for environmental review, and enhanced design standards.
 The proposed standards are consistent with the provisions of the Municipal Code and do not conflict with other industrial and zoning standards and would supersede any conflicting measure as they are specific to logistic warehouses of a certain size.
 The modifications have been designed to be objective and applied to all applicable projects.

Alternative Standards Findings
 Absent adoption of the ordinance modifications, discretionary and ministerial projects would still be subject to the existing warehouse ordinance. Discretionary projects are also subject to CEQA to mitigate any project related impact.  The proposed modifications may result in added costs, but larger projects could offset the revenue loss from exempting projects less than 400,000 square feet.

Reduction of Environmental Impacts Findings
 The modifications provide some enhanced mitigation (buffer) fo r future project review that could lead to air quality through greater pr oximity from receptors to ATTACHMENT E
Amendment Feasibility Analysis
13 trucks; area; however, many of the modifications seem to already be required per Building Code (EV auto and trucks) or current development practices (solar installation). While some of the active warehouse projects seeking entitlements are exempt from the warehouse standards, their environmental review includes analysis utilizing similar mitigation requirements.
 State and Regional Agencies will continue to enforce stricter climate change requirements regarding air quality, water quality, and building standards. All future projects will have to comply with state and local air quality and climate standards.

This includes ministerial projects not subject to CEQA.

Exhibit 1- Warehouse Building Permits
DATE OPENED STATUS STATUS DATE RECORD ID ADDR FULL LINE# Category Sub Category Total Sq Ft Current STATUS DATE STATUS 12/29/2016 Issued 5/11/2017 BP16-08352 3534 IMPERIAL WY, STOCKTON, CA 95215 Warehouse New Construction 187,644 Finaled 6/14/2018 1/19/2017 Issued 6/22/2017 BP17-00300 4532 NEWCASTLE RD, STOCKTON, CA 95215 Warehouse New Construction 1,122,341 Finaled 5/18/2018 1/19/2017 Issued 7/5/2017 BP17-00302 4601 NEWCASTLE RD, STOCKTON, CA 95215 Warehouse New Construction 388,183 Finaled 5/18/2018 1/19/2017 Issued 7/5/2017 BP17-00303 4733 NEWCASTLE RD, STOCKTON, CA 95215 Warehouse New Construction 186,944 Finaled 5/18/2018 4/6/2017 Issued 9/7/2017 BP17-01999 6868 ARCH RD, STOCKTON, CA 95215 Warehouse New Construction 506,844 Finaled 12/20/2018 2/28/2017 Issued 9/22/2017 BP17-01048 1052 PERFORMANCE DR, #100, STOCKTON, CA 95206 Warehouse New Construction 164,000 Finaled 9/21/2018 8/7/2017 Issued 10/25/2017 BP17-05061 3923 S B ST, STOCKTON, CA 95206 Warehouse New Construction 615,440 Finaled 7/18/2018 7/14/2017 Issued 4/3/2018 BP17-04391 1440 PERFORMANCE DR, STOCKTON, CA 95206 Warehouse New Construction 185,193 Finaled 3/6/2019 4/17/2018 Issued 8/13/2018 BP18-03378 4747 LOGISTICS DR, STOCKTON, CA 95215 Warehouse New Construction 285,480 Finaled 8/28/2019 8/10/2018 Issued 10/11/2018 BP18-06413 2829 W WASHINGTON ST, STOCKTON, CA 95203 Industrial New Construction 124,695 Finaled 9/17/2019 9/12/2018 Issued 1/11/2019 BP18-07162 4580 LOGISTICS DR, STOCKTON, CA 95215 Warehouse New Construction 709,556 Finaled 12/12/2019 1/23/2018 Issued 4/3/2019 BP18-01430 4239 POCK LN, STOCKTON, CA 95206 Industrial New Construction 198,976 Finaled 5/4/2020 10/5/2018 Issued 4/25/2019 BP18-07696 6440 AVIATION DR, STOCKTON, CA 95206 Warehouse New Construction 419,608 Final Pending 8/20/2020 11/5/2018 Issued 9/9/2019 BP18-08291 6444 ARCH RD, STOCKTON, CA 95215 Warehouse New Construction 383,382 Finaled 10/15/2020 6/13/2019 Issued 1/15/2020 BP19-04141 2018 ZEPHYR ST, STOCKTON, CA 95206 Warehouse New Construction 573,216 Finaled 6/30/2021 7/8/2019 Issued 6/8/2020 BP19-04757 4466 POCK LN, STOCKTON, CA 95206 Warehouse New Construction 143,448 Finaled 8/18/2021 8/5/2020 Issued 12/9/2020 BP20-04778 6001 AUSTIN RD, STOCKTON, CA 95215 Warehouse New Construction 638,985 Finaled 7/18/2022 12/9/2020 Issued 6/17/2021 BP20-08136 4441 ALITALIA AV, STOCKTON, CA 95206 Warehouse New Construction 118,262 Finaled 7/22/2022 3/22/2021 Issued 7/28/2021 BP21-01936 4800 LOGISTICS DR, STOCKTON, CA 95215 Warehouse New Construction 707,154 Re-Issued 3/22/2023 4/16/2021 Issued 11/8/2021 BP21-02651 8527 S AIRPORT WY, STOCKTON, CA 95206 Warehouse New Construction 223,262 Finaled 8/23/2023 4/16/2021 Issued 11/8/2021 BP21-02652 8497 S AIRPORT WY, STOCKTON, CA 95206 Warehouse New Construction 172,262 Finaled 9/13/2023 4/16/2021 Issued 11/8/2021 BP21-02650 8547 S AIRPORT WY, STOCKTON, CA 95206 Warehouse New Construction 213,035 Finaled 8/22/2023 9/14/2021 Issued 12/22/2021 BP21-07103 3632 PETERSEN RD, STOCKTON, CA 95215 Warehouse Addition 190,182 Finaled 9/26/2022 7/21/2021 Issued 2/9/2022 BP21-05443 2228 S SINCLAIR AV, STOCKTON, CA 95215 Warehouse New Construction 197,876 Finaled 7/13/2023 7/21/2021 Issued 2/9/2022 BP21-05440 2216 S SINCLAIR AV, STOCKTON, CA 95215 Warehouse New Construction 265,496 Finaled 8/3/2023 11/22/2021 Issued 4/28/2022 BP21-09155 5959 ARCH RD, STOCKTON, CA 95215 Warehouse New Construction 599,668 Re-Issued 4/14/2023 9/28/2021 Issued 5/5/2022 BP21-07487 1021 INDUSTRIAL DR, STOCKTON, CA 95206 Warehouse New Construction 833,220 Re-Issued 8/3/2022 9/27/2021 Issued 5/5/2022 BP21-07458 1021 INDUSTRIAL DR, STOCKTON, CA 95206 Warehouse New Construction 121,660 Re-Issued 9/3/2022 9/27/2021 Issued 5/5/2022 BP21-07452 1021 INDUSTRIAL DR, STOCKTON, CA 95206 Warehouse New Construction 176,285 Re-Issued 8/3/2022 12/6/2021 Issued 6/6/2022 BP21-09518 6440 E MARIPOSA RD, STOCKTON, CA 95215 Industrial New Construction 922,894 Re-Issued 11/8/2022 4/29/2021 Issued 6/7/2022 BP21-02961 4810 FITE CT, STOCKTON, CA 95215 Warehouse New Construction 122,146 Finaled 6/9/2023 2/10/2022 Issued 7/25/2022 BP22-01236 6401 S AUSTIN RD, STOCKTON, CA 95215 Warehouse New Construction 654,304 Re-Issued 11/7/2022 1/31/2022 Issued 11/16/2022 BP22-00862 5150 ARCH RD, STOCKTON, CA 95215 Warehouse New Construction 1,015,791 Re-Issued 10/3/2023 2/7/2023 Issued 6/29/2023 BP23-00919 1513 BOEING WY, STOCKTON, CA 95206 Warehouse New Construction 104,514 Re-Issued 11/13/2023 2/7/2023 Issued 6/29/2023 BP23-00920 1619 BOEING WY, STOCKTON, CA 95206 Warehouse New Construction 112,941 Re-Issued 11/13/2023 12/21/2022 Issued 12/21/2023 BP22-11833 5150 E MARIPOSA RD, STOCKTON, CA 95215 Warehouse New Construction 1,422,961 Issued 12/21/2023 Exhibit 1-Warehouse Building Permits
ATTACHMENT E

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