HomeMy WebLinkAbout2026-06-24 - SupplementalsCITY OF RANCHO CUCAMONGA PLANNING DEPARTMENT 1
VINEYARD CAR WASH
DRC2025 -00118
June 2 4 , 2 0 2 6 Pla nning Commission Hea ring
CITY OF RANCHO CUCAMONGA PLANNING DEPARTMENT 2
PROJECT BACKGROUND
•Who - A&S Engineering on behalf of Andy Ali
•What - Conditional Use Permit, Minor Design
Review, Minor Exception, and Variance for a
proposed 4,910 square foot express carwash
facility
•Where - 8172 Vineyard Avenue, SE of
Intersection of Foothill Blvd and Vineyard Ave
CITY OF RANCHO CUCAMONGA PLANNING DEPARTMENT 3
Current Site Conditions
•1.05-acre project site
•Vacant
•Existing access to Vineyard Avenue
EXISTING CONDITIONS
N
Vi
n
e
y
a
r
d
A
v
e
n
u
e
CITY OF RANCHO CUCAMONGA PLANNING DEPARTMENT 4
CITY OF RANCHO CUCAMONGA PLANNING DEPARTMENT 5
CITY OF RANCHO CUCAMONGA PLANNING DEPARTMENT 6
Site Context
Surrounding Context
•North – Redeveloped Multi-Tenant
Commercial
•South – Multi-Family Residential
•West – Entitled future Mixed -Use
development
Project
Site
Multi-Tenant
Commercial
Multifamily
Residential
Entitled
Mixed-Use
N
CITY OF RANCHO CUCAMONGA PLANNING DEPARTMENT 7
Development Plan Review
•Proposed express car wash facility
with a combined square footage of
4,910 square feet
•18 Vacuum Stations
•Decorative masonry perimeter wall
PROPOSED PROJECT
CITY OF RANCHO CUCAMONGA PLANNING DEPARTMENT 8
Proposed Operations
•Walk-in and membership services
•Self-service model
o 2 employees on site
PROPOSED PROJECT
CITY OF RANCHO CUCAMONGA PLANNING DEPARTMENT 9
Proposed Hours of Operation
•Development Code:
o Mon -Sat 8:00 AM to 7:00 PM
o Sunday 9:00 AM to 6:00 PM
o Planning Condition 1
•Applicant Request
o Mon -Sat 7:00 AM to 8:00 PM
o Sunday 8:00 AM to 7:00 PM
PROPOSED PROJECT
Entitled
Mixed-Use
Multifamily
Residential
Project
Site
N
CITY OF RANCHO CUCAMONGA PLANNING DEPARTMENT 10
DEVELOPMENT STANDARDS
Corridor 2 (CO2) Zone Development Standards
Standard Required Proposed Compliant?
Dwelling Units 24/ Acre Minimum 0 Yes*
Build -to Line 15 Minimum 15 Yes
Minimum Percentage of
Frontage Width 80%43%Yes*
Minimum Ground Floor
Nonresidential Height 15 Feet 30 Feet Yes
Maximum Building Stories 4 1 Yes
Minimum Parking Setback 40 feet 85 feet Yes
Required Parking (Self-
Service Car Wash)2.5 Spaces per Wash Bay 3 Yes
*Subject of Variance
CITY OF RANCHO CUCAMONGA PLANNING DEPARTMENT 11
DEVELOPMENT STANDARDS
Mid -Rise Building Type Development Standards
Standard Required Proposed Compliant?
Site Width Min 150 feet
Max 400 feet 257 feet Yes
Site Depth Min 150 feet
Max 400 feet 174 feet Yes
Minimum Rear Yard
Setback 10 feet 10 feet Yes
Max Building Height 80 feet 30 feet Yes
Max Building Width 400 feet 110 feet Yes
Max Building Depth 390 feet 56 feet Yes
CITY OF RANCHO CUCAMONGA PLANNING DEPARTMENT 12
VARIANCE
Summary of Requested Variances
Condition Requested Deviation Constraint
Residential Requirement No Residential Element
Size of site does not allow for feasible residential
element, and project site is already a component
of horizontal mixed -use development.
Minimum Percentage of Frontage
Width >80% of Frontage Width The size of the project site would not allow for a
wider frontage while meeting circulation needs.
CITY OF RANCHO CUCAMONGA PLANNING DEPARTMENT 13
•Two -Foot increase to maximum wall height on
south property line.
•Maximizes noise attenuation and visual
screening for adjacent residential use.
•Recommended by Design Review Committee.
MINOR EXCEPTION
8 ft Decorative
Masonry Wall
CITY OF RANCHO CUCAMONGA PLANNING DEPARTMENT 14
•The applicant proposes a Spanish architectural style
to match adjacent commercial uses.
•Design includes Barrel Tile Roofing, Stucco Finish,
and Stone Veneer
•Additional Spanish elements recommended by
Design Review Committee.
ARCHITECTURAL DESIGN
CITY OF RANCHO CUCAMONGA PLANNING DEPARTMENT 15N
CITY OF RANCHO CUCAMONGA PLANNING DEPARTMENT 16
•Type 32 Infill Exemption
•Technical memo prepared supporting the
exemption.
•No substantial evidence that the project may
have a significant impact on the environment.
ENVIRONMENTAL REVIEW
CITY OF RANCHO CUCAMONGA PLANNING DEPARTMENT 17
•Neighborhood Meeting – February 24, 2026
•No attendance
•Design Review Committee – March 17, 2026
•Recommended approval with proposed changes
o ENG Condition 5 – Traffic/ Queuing Study
o PLN Condition 2 – Architectural Requirements
REVIEW PROCESS
CITY OF RANCHO CUCAMONGA PLANNING DEPARTMENT 18
•Notices mailed to all property owners within
660 feet (124 property owners) and
published in the Inland Valley Daily Bulletin
on June 9, 2026.
•To date, staff has received one inquiry
regarding this project.
NOTICING
CITY OF RANCHO CUCAMONGA PLANNING DEPARTMENT 19
RECOMMENDATION
CITY OF RANCHO CUCAMONGA PLANNING DEPARTMENT 20
RECOMMENDATION
Staff recommends approval of
Conditional Use Permit DRC2025 -00113,
Minor Design Review DRC2025 -00118,
Minor Exception DRC2026-00098, and
Variance DRC2026-00074 through the
adoption of the subject resolution and
Conditions of Approval.
Correspondence received
PC meeting 6/24/26
Item D2 - EA, MP, DA, TPM, DR, CUP
Received 6/22/2026 9:39PM
Green Jobs & Clean Communities
22 June 2026
Planning Commission
City of Rancho Cucamonga
10500 Civic Center Drive
Rancho Cucamonga, CA 91730
Delivered via email to: elizabeth.thornhill@cityofrc.us
planning@cityofrc.us
Re: Supplemental Comments on Arrow Commerce Center Project Final Environmental
Impact Report (SCH No. 2023110033)
Commissioners.
Golden State Environmental Justice Alliance (GSEJA) has previously submitted comments on
the Final Environmental Impact Report (Final EIR) for the proposed Arrow Commerce Center
Project by way of a Comment Letter dated November 13, 2025, which documented systematic
violations of the California Environmental Quality Act (CEQA), including failure to define the
whole of the action as required by CEQA's prohibition on piecemealing, an inaccurate and
incomplete project description that omits grading plans and withholds site coverage data,
deficient environmental justice analysis that ignores the Project's location within a SCAG
Priority Equity Community, failure to use Title 24-approved energy compliance software,
inadequate land use consistency analysis with PlanRC, the City's Climate Action Plan, and the
SCAG RTP/SCS, a GHG analysis that relies on unenforceable mitigation, an incomplete and
methodologically deficient VMT analysis, and a Transportation section riddled with internal
inconsistencies regarding RTP/SCS conformance.
GSEJA also provided technical review comments prepared by Soil Water Air Protection
Enterprise (SWAPE), concluding that the Project's air quality, health risk, and greenhouse gas
impacts were underestimated and improperly addressed.
The City of Rancho Cucamonga has since published the Final EIR containing responses to
GSEJA's comments (Comments 4-1 through 4-45). GSEJA has reviewed those responses and
submits this Supplemental Comment Letter to reiterate its opposition to the Project and to place
on record that the City's responses do not adequately resolve the deficiencies identified in
GSEJA's prior submissions. The City's responses largely fail to constitute the good-faith,
reasoned analysis required by CEQA Guidelines Section 15088.
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In several instances, the responses substitute procedural assertions and cross-references for
substantive environmental analysis, dismiss technical findings from SWAPE without meaningful
rebuttal, and defer resolution of significant concerns to post-approval permitting processes in a
manner inconsistent with CEQA's informational mandate. Unrefuted technical evidence from
SWAPE stands as fact in the record.
The proposed Project would construct five 2-story industrial buildings totaling 1,830,729 gross
square feet on a 94-acre site at 12451 Arrow Route Road, functioning as a warehouse
distribution complex with cold storage, high-cube fulfillment, and general warehouse uses. This
is not a modest infill project on an underutilized site; it is a large-scale logistics development
proposed for a census tract that already bears among the most severe pollution burdens in the
state. According to CalEnviroScreen 4.0, the Project's census tract (6071002207) ranks in the
93rd percentile for overall pollution burden, the 95th percentile for ozone burden, the 94th
percentile for PM2.5 burden, and the 95th percentile for hazardous waste facility impacts. The
surrounding community includes 53% Hispanic and 21% African-American residents, with 70%
of households below the poverty level and 85% of residents over age 25 without a high school
diploma. Rather than avoiding further harm to this already-burdened community, the City's
responses dismiss GSEJA's environmental justice concerns with little more than the assertion
that environmental justice analysis falls outside CEQA's purview. This is not adequate, and the
Planning Commission should not accept it as such.
I. The Fair Argument Standard and the Need for a Revised EIR
The City's responses invoke the substantial evidence standard throughout, but this Project was
reviewed under a Mitigated Negative Declaration process, which means the applicable threshold
is the fair argument standard, not substantial evidence. Under No Oil, Inc. v. City of Los Angeles
3
(1974) 13 Cal.3d 68, a lead agency must prepare an EIR whenever substantial evidence in the
record supports a fair argument that a project may have a significant effect on the environment,
even if other substantial evidence supports the contrary conclusion.
SWAPE's independent technical analysis, submitted with GSEJA's November 13, 2025 comment
letter, identified that the Project's construction-phase VOC emissions were modeled at zero
demolition hauling trips despite 555,664 ft2 of demolition debris entered in the Demolition
screen, that the construction model omitted 44 acres of parking lot space, and that Tier 4 Final
engine requirements were applied as a model input without being incorporated as binding
mitigation in the MMRP. These modeling deficiencies, individually and collectively, constitute
substantial evidence supporting a fair argument that the Project's air quality impacts were
underestimated and that the Final EIR's significance conclusions cannot be relied upon. The
City's responses to Comments 4-36 and 4-37 partially acknowledge these errors—Response 4-36
accepts the parking lot omission, but do not provide corrected modeling output for public review.
Unrefuted expert analysis establishing that the model inputs were incorrect stands as fact in the
record and compels preparation of a revised EIR.
II. Project Piecemealing
The City's Response 4-3 asserts that the Arrow Commerce Center has independent utility and
that all relevant cumulative projects are addressed in Chapter 4 of the Final EIR. This does not
resolve the piecemealing deficiency. CEQA Section 15378 defines "project" as the whole of an
action with the potential for direct or indirect physical change in the environment. The Arrow
Commerce Center (1,830,729 ft2, five buildings, DRC2021-004852) and the Etiwanda
Commerce Center (1,214,131 ft2, five buildings, DRC2021-004841) were submitted to the City
on the same day, December 29, 2021, by the same developer, for adjoining parcels separated
only by BNSF railroad tracks. A third project (DRC2016-00726) constructed a 611,573 ft2
distribution center at 12400 Arrow Route, immediately north of the project site across Arrow
Route. Cumulatively, the three projects total 3,648,153 ft2 across 11 buildings.
4
The California Supreme Court has held that a lead agency may not segment a single integrated
development to artificially reduce the apparent significance of environmental impacts. (Bozung
v. Local Agency Formation Commission (1975) 13 Cal.3d 263.) The City's characterization of
each Ares/Black Creek development as independently entitled does not sever the factual
connection between them. A project EIR must be prepared that evaluates the whole of the action,
including all three Ares/Black Creek developments, as a single project.
III. Project Description
The City's Response 4-4 argues that the project description satisfies CEQA Guidelines Section
15124. It does not address the specific deficiencies GSEJA identified. The EIR states that
approximately 255,000 yd3 of cut and fill would be balanced on site yet provides no grading plan
or earthwork quantity notes through which the public or decision-makers can verify this figure.
The site plan in Figure 2-11 has been edited to remove earthwork quantity notes, parking
requirements, site coverage calculations, and key notes. The elevations in Figures 2-12 through
2-16 omit building colors and materials.
These omissions matter because the grading data directly informs demolition hauling trip
generation, the same variable SWAPE demonstrated was set to zero in the CalEEMod model. An
RMND that states a grading balance without disclosing the underlying calculations, and a model
that uses zero demolition hauling trips without explanation, together provide no meaningful
opportunity for independent verification. This does not constitute adequate disclosure under
CEQA Guidelines Section 15121.
IV. Environmental Justice
The City's responses to Comments 4-7, 4-8, 4-17, 4-41, and 4-42 uniformly assert that
environmental justice analysis falls outside the purview of CEQA and is not identified as an
environmental issue area under Appendix G of the State CEQA Guidelines. This response
illustrates precisely the problem: by treating the environmental justice analysis as simply outside
its obligation, the City declines to perform it. CEQA Guidelines Section 15065(a)(4) requires a
finding of significance where a project may cause substantial adverse effects on human beings.
In a community ranking in the 93rd percentile for overall pollution burden and carrying a 70%
poverty rate, the Project's incremental contribution to diesel particulate matter, truck traffic, and
ozone precursor emissions cannot be dismissed as insignificant by reference to Appendix G
alone.
Poverty compounds pollution exposure: residents cannot afford the healthcare, nutritious food,
and quality living conditions needed to withstand additional environmental stress. The City's
responses do not analyze the disproportionate burden this Project imposes on this specific
community, do not identify enhanced mitigation commensurate with the community's
vulnerability, and do not address barriers to public participation. The City's own General Plan
requires more. PlanRC Policy RC-5.5 directs the City to ensure that new development does not
disproportionately burden residents based on race, ethnicity, or socioeconomic status with health
effects from air pollution. Policy RC-5.6 requires a community benefit plan for any land use
generating more than 100 trucks per day. This Project will generate 684 trucks per day. The Final
5
EIR requires neither. The record as currently constituted does not support the findings required
for project approval under CEQA.
V. Energy Analysis and Title 24 Compliance
The City's Response 4-9, echoed in Response 4-32, argues that the project will be required to
comply with whichever Building Energy Efficiency Standards are in effect at the time
construction begins, and that future codes will likely require more efficient buildings than
assumed in the EIR analysis. GSEJA does not dispute that the project will be required to comply
with Title 24 at the building permit stage. The issue is that the Final EIR's own energy
significance thresholds ask whether the Project would conflict with a state or local plan for
renewable energy or energy efficiency. Title 24 is that plan. The EIR concludes compliance
without using software the California Energy Commission has designated for that purpose,
CBECC-Com, EnergyPro, or IES VE. CalEEMod and spreadsheet-based modeling are not on
that list.
Deferring Title 24 verification to the building permit stage does not cure the CEQA disclosure
deficiency. The public and decision-makers are entitled to know, before project approval,
whether the Project will meet the state's energy efficiency standards, not merely that it will be
required to demonstrate compliance at a later stage.
VI. GHG: CAP Consistency and Enforceability of Reduction Measures
The City's responses to Comments 4-10 through 4-13 characterize the Project's GHG reduction
features as simultaneously project design features, regulatory requirements, and future mitigation
measures, depending on which argument is being made at the time. This inconsistency is
revealing. Mitigation Measure 3.7-1a requires 50% of construction equipment to be NZE/ZE but
includes an escape valve allowing the applicant to demonstrate commercial unavailability, which
courts have repeatedly found to be the case for heavy-duty drayage trucks. If the mitigation can
be avoided on a showing of commercial unavailability, it provides no enforceable commitment to
GHG reduction and cannot support a less-than-significant finding.
Response 4-13 asserts that the CAP-based mitigation measures, once implemented, will ensure
consistency with the City's CAP and CARB Scoping Plan. But the EIR itself acknowledges that
the Project does not comply with all relevant CAP and Scoping Plan strategies before mitigation.
6
Under CEQA Guidelines Section 15183.5(b)(1)(D), a CAP may only be used as the basis for a
less-than-significant cumulative GHG finding if it specifies measures that substantial evidence
demonstrates will collectively achieve the specified emissions level. The City has not made that
showing for mitigation measures conditioned on commercial availability of technology that
courts have found unavailable. The GHG impact must be declared significant and unavoidable,
and the City's commitment to incorporate CAP measures into conditions of approval in the future
does not cure the deficiency in the current Final EIR.
VII. VMT: Methodology and RTP/SCS Inconsistency
The City's Response 4-25 defends the VMT analysis's assumption that 100 percent of future
employees are eligible to participate in the rideshare, carpool, bicycle, and vanpool mitigation
programs. The EIR simultaneously acknowledges throughout the document that future tenants
are unknown. Asserting that the workforce cannot be characterized while assuming full
participation eligibility is logically inconsistent and contrary to the substantial evidence standard.
Response 4-26 declines to make a specific finding of significance based on the Project's
demonstrated inconsistency with the SCAG RTP/SCS. The EIR's own transportation appendix
states that the Project was determined to be inconsistent with the land use growth assumptions in
PlanRC and in the RTP/SCS by reviewing the regional travel model SBTAM+. Per the City's
own Resolution No. 2020-0056, a significant VMT impact occurs when a project is determined
to be inconsistent with the RTP/SCS. That determination has been made. The finding of
significance must be included in the EIR.
On onsite circulation, Response 4-27 defers the hazard analysis to the construction permitting
phase. CEQA does not permit deferral of environmental analysis to future permitting.
(Sundstrom v. County of Mendocino (1988) 202 Cal.App.3d 296.) Multiple locations on Figure
2-17 show truck/trailer movements requiring encroachment across the street centerline into
oncoming traffic lanes, and driveway configurations that cannot accommodate simultaneous
truck movements. These are present, identifiable impacts that must be analyzed now.
VIII. Health Risk Assessment
The City's Response 4-43 acknowledges that the FAH (Fraction of Time At Home) values
displayed in Draft EIR Table 3.2-9 were incorrect, and states that the corrected values appear in
the Final EIR Chapter 3 revisions. This is a concession that the public reviewed and commented
on an HRA containing incorrect exposure factors. A post-comment-period correction, provided
without recirculation, deprives the public of any opportunity to review the corrected
methodology and results before project approval. This is precisely the type of significant new
information that warrants recirculation under CEQA Guidelines Section 15088.5.
SWAPE identified three independent HRA deficiencies that remain unresolved: the Final EIR
failed to prepare a quantified construction-phase HRA; failed to evaluate the combined lifetime
cancer risk from construction and operation together; and presented incorrect FAH values now
acknowledged to be wrong. These deficiencies are compounded by the existing baseline
conditions. The SCAQMD MATES V study places the project census tract in the 92nd percentile
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for residential carcinogenic risk from air toxics, with a cancer risk of 785 in one million, among
the highest in the South Coast Air Basin. Adding an unquantified construction-phase risk and an
operational risk calculated with incorrect exposure factors to a community already at 785 in one
million does not constitute adequate health risk disclosure under CEQA. A complete,
transparent, and publicly reviewed health risk assessment covering both construction and
operation phases must be prepared and recirculated.
IX. Land Use Consistency
The City's Response 4-16, repeated in Response 4-31, asserts that the proposed large distribution
and fulfillment center uses are permitted on NI- and IE-zoned parcels through the CUP and
Master Plan process under RCMC Section 17.30.030. This response conflates the zoning code's
permitted use list with the General Plan's land use designations. The Neo-Industrial designation
in PlanRC expressly states that more intensive industrial uses with substantive impacts on
adjacent uses are not permitted, and that low-impact industrial uses that are context-sensitive and
calibrated to minimize impacts to adjacent residential uses are preferred. A 1.83-million-square-
foot warehouse complex generating 684 trucks per day, resulting in significant and unavoidable
air quality impacts and VMT inconsistent with the RTP/SCS, is an intensive industrial use with
substantive impacts on adjacent uses by any reasonable reading of that language. The Zoning
Code's permitted use list does not override the General Plan's express limitation.
Response 4-15 dismisses the Housing Crisis Act concern by noting that the City's Housing
Element does not identify parcels within the Southeast Industrial Area as residential sites. The
HCA's replacement housing requirements are not waived because a City's Housing Element
prefers other locations for residential development. They are triggered whenever land with
residential capacity is converted to an incompatible use. The EIR fails to analyze this impact, and
that failure is not cured by pointing to a Housing Element that shares the same omission.
X. Alternatives Analysis
The City's Response 4-29 concludes that the alternatives range is adequate because it includes
alternatives that achieve the project's objectives while resulting in similar or reduced
environmental impacts. This misreads the CEQA standard. CEQA Guidelines Section 15126.6
requires evaluation of alternatives that could feasibly accomplish most of the basic objectives of
the project and could avoid or substantially lessen one or more of the significant effects. The
obligation is not merely to evaluate alternatives with reduced impacts — it is to evaluate
alternatives capable of reducing significant and unavoidable impacts to less-than-significant
levels where feasible. Neither the Reduced Project Alternative nor the Inclusion of
Commercial/Retail Use Alternative does this for air quality or VMT. The alternatives analysis is
legally inadequate.
XI. Conclusion
For the foregoing reasons, GSEJA respectfully urges the Planning Commission to decline to
certify the Final EIR and deny approval of the proposed Project entitlements. The City's
responses do not cure the fundamental deficiencies in the Final EIR's environmental analysis.
8
Across every major impact category — including the fair argument threshold, environmental
justice, health risk, GHG enforceability, VMT disclosure, piecemealing, land use consistency,
and alternatives — the City's responses substitute procedural assertions for substantive analysis,
defer critical determinations to post-approval processes, or fail to provide meaningful rebuttal to
unrefuted expert findings from SWAPE. The record does not contain substantial evidence to
support the findings required for project approval under CEQA.
If this Project proceeds as proposed, it will add 684 trucks per day, 1,830,729 ft2 of warehouse
and cold storage activity, and significant and unavoidable air quality and VMT impacts to a
community already ranking in the 93rd percentile for overall pollution burden, without an honest
accounting of those impacts, without adequate mitigation, and without the environmental justice
analysis that California law and the City's own General Plan require.
The Planning Commission has both the authority and the obligation to demand a legally adequate
environmental review before approving a project of this scale and consequence.
Onwards.
Steven Piepkorn
Golden State Environmental Justice Alliance
765 N Main Street, Suite 151
Corona, CA 92880
+1 951 279 4697
BLUM, COLLINS & HO LLP
ATTORNEYS AT LAW
10250 CONSTELLATION BOULEVARD
SUITE 2300
LOS ANGELES, CALIFORNIA 90067
(213) 572-0400
November 13, 2025
Sean McPherson Via Email to:
Principal Planner Sean.McPherson@cityofrc.us
City of Rancho Cucamonga, Planning Department
10500 Civic Center Drive
Rancho Cucamonga, CA 91730
Subject: Comments on Arrow Commerce Center Project EIR (SCH NO. 2023110033)
Dear Mr. McPherson,
Thank you for the opportunity to comment on the Environmental Impact Report (EIR) for the
proposed Arrow Commerce Center Project. Please accept and consider these comments on behalf
of Golden State Environmental Justice Alliance. Also, Golden State Environmental Justice
Alliance formally requests to be added to the public interest list regarding any subsequent
environmental documents, public notices, public hearings, and notices of determination for this
project. Send all communications to Golden State Environmental Justice Alliance P.O. Box 79222
Corona, CA 92877.
1.0 Summary
The proposed project includes the demolition and site clearing of existing paved surface areas and
site grading, excavation, and the development of five 2-story industrial buildings. The five
industrial buildings consist of approximately 1,830,729 gross square feet of new building floor
area for warehouse distribution and associated office space. The project also includes loading
docks for truck trailers, 968 vehicle parking spaces, 444 truck trailer parking spaces, 6 new public
streets, water quality basins, utility infrastructure, and exterior lighting and signage. Of the five
Sean McPherson
November 13, 2025
Page
2
proposed buildings included in the proposed project, Buildings 1, 2, and 3 are anticipated to operate
Monday through Friday between 4:00 a.m. and 8:00 p.m. (16 hours per day, 80 hours per week),
and Buildings 4 and 5 are anticipated to operate 24 hours a day, seven days a week. The proposed
project would accommodate approximately 1,408 employees daily.
The proposed project requires the City ’s approval of the following entitlements for the proposed
project:
1. Zoning Map Amendment pursuant to Section 17.38.080 (Large Warehouse Overlay Zone) of
the RCMC to apply the overlay to the project site;
2. Design Review Application;
3. Conditional Use Permit (CUP) and Master Plan application pursuant to Section 17.30.030
(Allowed Land Uses and Permit Requirements) of the Rancho Cucamonga Municipal Code
(RCMC); and,
4. Development Agreement.
1.1 Project Piecemealing
The EIR does not accurately or adequately describe the project, meaning “the whole of an action,
which has a potential for resulting in either a direct physical change in the environment, or a
reasonably foreseeable indirect physical change in the environment” (CEQA § 15378). The
proposed project is a piecemealed portion of a larger overall project to be developed by Ares/Black
Creek within the City.
The EIR misleads the public and decision makers by circumventing adequate and accurate
environmental analysis for the whole of the action - construction and operation of all Ares/Black
Creek buildings as a whole. At minimum, piecemealed projects include the development of the
DRC2021-004841 known as Etiwanda Commerce Center (1,214,131 sf of warehouse/industrial
building area across 5 buildings), located adjacent to the south of the project site across the BNSF
railroad tracks at 8996 Etiwanda Avenue. According to public entitlement records, DRC2021-
1 https://aca-
prod.accela.com/CITYOFRC/Cap/CapDetail.aspx?Module=Planning&capID1=21PLN&capID2=00000&
capID3=00508&agencyCode=CITYOFRC
Sean McPherson
November 13, 2025
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00484 was submitted to the City on 12/29/2021. The proposed project (DRC2021-004852) was
also submitted to the City on 12/29/2021. A third project (DRC2016-007263) constructed a
611,573 square feet distribution center at 12400 Arrow Route4, located immediately adjacent to
the north of the project site across Arrow Route. Cumulatively, the proposed project and the two
piecemealed projects will construct 3,648,153 sf of warehouse/industrial building area across 11
buildings.
CEQA Section 15161 describes project EIRs as examining “the environmental impacts of a
specific development project. This type of EIR should focus primarily on the changes in the
environment that would result from the development project. The EIR shall examine all phases of
the project including planning, construction, and operation.” The specific development project is
the construction and operation of all Ares/Black Creek buildings as a whole, including at minimum
the projects listed above.
Additionally, CEQA Section 15146 requires that the degree of specificity in an EIR “will
correspond to the degree of specificity involved in the underlying activity which is described in
the EIR. (a) An EIR on a construction project will necessarily be more detailed in the specific
effects of the project than will be an EIR on the adoption of a local general plan or comprehensive
zoning ordinance because the effects of the construction can be predicted with greater accuracy.”
Because there are at least three developments as part of a single construction project, the project
EIR must be more detailed in the specific effects of the project.
2 https://aca-
prod.accela.com/CITYOFRC/Cap/CapDetail.aspx?Module=Planning&TabName=Planning&capID1=21P
LN&capID2=00000&capID3=00509&agencyCode=CITYOFRC&IsToShowInspection=
3 https://aca-
prod.accela.com/CITYOFRC/Cap/CapDetail.aspx?Module=Planning&TabName=Planning&capID1=16P
LN&capID2=00000&capID3=01569&agencyCode=CITYOFRC&IsToShowInspection=
4
https://www.loopnet.com/viewer/pdf?file=https%3a%2f%2fimages1.loopnet.com%2fd2%2fr4fT6QQdAe
d6ab-
jawz29bxsNI_xsw7SZFhwEBRRiBA%2f611573%2520SF%2520Arrow%2520Route%2520DC%2520Br
ochure.pdf
Sean McPherson
November 13, 2025
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4
A project EIR must be prepared which accurately represents the whole of the action without
piecemealing the project into separate, smaller development projects to present unduly low
environmental impacts. This is vital as the EIR for the proposed project concludes the project will
result in significant and unavoidable cumulatively considerable Air Quality and VMT impacts,
and is inconsistent with PlanRC (General Plan) and the RTP/SCS. The area of all three projects is
within a SCAG Priority Equity Community and adjacent to a SB 535 Disadvantaged Community,
meaning that the significance of the environmental impacts are felt in the most vulnerable areas of
the SCAG region and State. The EIR must be revised to comply with CEQA § 15161 by preparing
a Project EIR to adequately and accurately disclose the project-specific and cumulative impacts of
all proposed Ares/Black Creek projects.
2.0 Project Description
The EIR does not include floor plans, grading plans, detailed site plans, or detailed elevations. The
basic components of a Planning Application include a site plan, floor plan, grading plan, and
elevations. The site plan provided in Figures 2-11 has been edited for public review and does not
provide any detailed information such as the earthwork quantity notes, parking requirements, site
coverage, floor area ratio, legend, or key notes. The elevations in Figure 2-12 through 2-16 do not
include the building colors or materials. The EIR states that, “During the grading stage
approximately 255,000 cubic yards of cut and fill would be balanced on site,” but does not provide
any method for the public or decision makers to verify this information, such as a grading plan.
Providing the grading plan and earthwork quantity notes is vital as this directly informs the
quantity of necessary truck hauling trips due to soil import/export during the grading phase of
construction. A revised EIR must be prepared to include wholly accurate and unedited detailed
floor plan, grading plan, site plan, elevations, and project narrative for public review.
3.0 Environmental Setting, Impacts, and Mitigation Measures. Effects Found Not to be
Significant: Population and Housing
The IS/NOP states that, “The industrial land uses proposed would be consistent with the zoning
and General Plan land use designations in adopted planning documents, such as the city ’s General
Plan, and the RCMC. As such, the proposed project would not induce substantial unplanned
population growth in an area directly or indirectly due to the proposed project ’s introduction of
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new business, employees, and roads and infrastructure. This is because growth associated with
proposed land uses that are consistent with the zoning and land use designations of the city are
accounted for in the growth projections of the General Plan.” However, there is no quantified
discussion regarding the growth projections of the City’s General Plan or SCAG’s RTP/SCS. The
EIR has not provided any substantial evidence to support the conclusion that the project is within
these growth projections. Notably, the EIR also concludes in the Transportation section that the
project exceeds the RTP/SCS growth projections and is inconsistent with PlanRC (General Plan).
A finding of significance must be provided in a revised EIR.
SCAG’s Connect SoCal Demographics and Growth Forecast5 notes that the City will add 12,900
jobs from 2019 to 2035. Based on the EIR’s calculation of 1,408 jobs, the project represents 10.9%
of the City’s job growth over 16 years. A single project accounting for this amount of the projected
employment growth over 16 years represents a significant amount of growth. The EIR has not
provided a cumulative analysis discussion of projects approved since 2019 (SCAG), General Plan
adoption, and/or projects “in the pipeline” to determine if the project will exceed SCAG’s
employment growth forecast or the General Plan growth projections.
For example, other recent industrial projects such as 9th and Vineyard6 (823 employees) and El
Camino Project7 (474 employees) combined with the proposed project will cumulatively generate
2,705 employees, which is 20.9% of the City’s employment growth forecast through 2035
accounted for only by three recent industrial projects. This total increases exponentially when other
industrial and commercial development activity is added to the calculation. A revised EIR must be
prepared to include this information for analysis, and also provide a cumulative analysis discussion
of projects approved since 2019 (SCAG), General Plan adoption, and projects “in the pipeline” to
determine the City’s cumulative progress towards employment/population growth forecasts by
SCAG and/or the General Plan.
5 SCAG Connect SoCal Demographics and Growth Forecast
https://www.scag.ca.gov/sites/default/files/2024-05/23-2987-tr-demographics-growth-forecast-final-
040424.pdf
6 9th and Vineyard Development Project https://ceqanet.opr.ca.gov/2019110456/4
7 El Camino Project https://ceqanet.lci.ca.gov/2023080369/4
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The EIR does not provide any quantified analysis to demonstrate if the proposed project is within
the employment forecasts of the General Plan. The project site is located within Focus Area 8:
Southeast Industrial Area of the General Plan EIR8. Table 5.14-6: Buildout Projections From
Proposed Land Use Plan of the General Plan EIR demonstrates that the City will add 5,122 jobs
in Industrial land use designations from 2020-2040. Table 1-1: Land Use Development Projections
By Focus Area and Remainder of City for Buildout demonstrates that the Remainder of the City
(includes Focus Area 8: Southeast Industrial Area) will add 4,927 jobs from 2020-2040. The EIR’s
calculation of the project’s 1,408 net new jobs accounts for 27.4% of all jobs in the Remainder of
the City. A single project accounting for this amount of the projected employment growth over 20
years represents a significant amount of growth. The proposed project represents a significant
amount of employment growth for the entire City and Focus Area 8 accounted for by the General
Plan EIR. A revised EIR must be prepared to provide this information for analysis and include a
finding of significance because the project would directly induce substantial unplanned growth in
an area.
3.2 Air Quality, 3.5 Energy, and 3.7 Greenhouse Gas Emissions
The EIR concludes that the project does not meet SCAQMD emissions thresholds and will result
in significant and unavoidable cumulatively considerable air quality impacts due to exceeding
emissions thresholds for VOC. The EIR states that, “The project and its features are consistent
with SCAQMD efforts to reduce emissions Basin-wide,” and that, “…because the proposed
project would be consistent with the land use designations in the General Plan and other relevant
policies and goals, the proposed project is consistent with the region ’s AQMP. As such, project-
related emissions are accounted for in the AQMP, which has been crafted to bring the Basin into
attainment status for all nonattainment pollutants and precursors thereof.” However, the EIR is
internally inconsistent as it concludes in the Transportation section that the project is not consistent
with the buildout of PlanRC (General Plan) nor the SCAG RTP/SCS land use scenario. As
discussed at length in the Land Use and Planning section below, the proposed distribution center
use is not permitted in the Neo-Industrial land use designation of the General Plan. The project
8 https://www.cityofrc.us/sites/default/files/2021-
09/City%20of%20Rancho%20Cucamonga_GP%20Update%20and%20CAP_Draft%20EIR_September%
202021.pdf
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also requires a Zoning Map Amendment to apply the Large Warehouse Overlay to the project site
to allow more than 400,000 square feet of warehouse space. This indicates that the site was clearly
not planned to accommodate the proposed project. For the foregoing reasons, the project is clearly
inconsistent with the AQMP and a finding of significance must be included in a revised EIR. See
also the attached air quality comments and analysis from SWAPE.
The EIR briefly states the project site census tract CalEnviroscreen scores, but does not
meaningfully discuss their relation to the project’s impacts. The EIR does not include for analysis
relevant environmental justice issues in reviewing potential impacts, including cumulative impacts
from the proposed project. This is in conflict with CEQA Guidelines Section 15131 (c), which
requires that “Economic, social, and particularly housing factors shall be considered by public
agencies together with technological and environmental factors in deciding whether changes in a
project are feasible to reduce or avoid the significant effects on the environment identified in the
EIR. If information on these factors is not contained in the EIR, the information must be added to
the record in some other manner to allow the agency to consider the factors in reaching a decision
on the project.” This is especially significant as the surrounding community is highly burdened by
pollution.
According to CalEnviroScreen 4.09, CalEPA’s screening tool that ranks each census tract in the
state for pollution and socioeconomic vulnerability, the proposed project ’s census tract
(6071002207) ranks in the 93rd percentile for overall pollution burden, meaning that it is among
the communities that are most severely burdened by pollution in the state. The surrounding
community bears the impact of multiple sources of pollution and is more polluted than average on
several pollution indicator measured by CalEnviroScreen. For example, the project census tract
ranks in the 95th percentile for ozone burden, the 94th percentile for particulate matter (PM) 2.5
burden, the 63rd percentile for diesel PM burden, and 87th percentile for traffic burden. All of
these environmental factors are attributed to heavy truck activity in the area. While California has
strict vehicle-emissions standards, exhaust from cars and trucks is the main source of air pollution
in much of the state10. Ozone can cause lung irritation, inflammation, and worsening of existing
9 https://experience.arcgis.com/experience/11d2f52282a54ceebcac7428e6184203/page/CalEnviroScreen-
4_0/
10 OEHHA Traffic https://oehha.ca.gov/calenviroscreen/indicator/traffic-density
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chronic health conditions, even at low levels of exposure11. Exhaust fumes contain toxic chemicals
that can damage DNA, cause cancer, make breathing difficult, and cause low weight and premature
births12.
The census tract also ranks in the 95th percentile for hazardous waste facility impacts and 94th
percentile for solid waste facility impacts. Hazardous waste generators and facilities contribute to
the contamination of air, water and soil near waste generators and facilities can harm the
environment as well as people13. Solid waste facilities can expose people to hazardous chemicals,
release toxic gases into the air (even after these facilities are closed), and chemicals can leach into
soil around the facility and pose a health risk to nearby populations14.
The census tract also bears more impacts from cleanup sites than 71% of the state. Chemicals in
the buildings, soil, or water at cleanup sites can move into nearby communities through the air or
movement of water15. The census tract ranks in the 84th percentile for toxic releases. People living
near facilities that emit toxic releases may breathe contaminated air regularly or if contaminants
are released during an accident16.
Further, the census tract is a diverse community including 53% Hispanic, 21% African-American,
and 5% Asian-American residents, whom are especially vulnerable to the impacts of pollution.
The community has a high rate of low educational attainment, meaning 85% of the census tract
residents over age 25 has not attained a high school diploma. The community also has a high rate
of poverty, meaning 70% of the households in the census tract have a total income before taxes
that is less than the poverty level. Income can affect health when people cannot afford healthy
living and working conditions, nutritious food and necessary medical care17. Poor communities
are often located in areas with high levels of pollution18. Poverty can cause stress that weakens the
11 OEHHA Ozone https://oehha.ca.gov/calenviroscreen/indicator/air-quality-ozone
12 OEHHA Traffic https://oehha.ca.gov/calenviroscreen/indicator/traffic-density
13 OEHHA Hazardous Waste Generators and Facilities
https://oehha.ca.gov/calenviroscreen/indicator/hazardous-waste-generators-and-facilities
14 OEHHA Solid Waste Facilities https://oehha.ca.gov/calenviroscreen/indicator/solid-waste-sites-and-
facilities
15 OEHHA Cleanup Sites https://oehha.ca.gov/calenviroscreen/indicator/cleanup-sites
16 OEHHA Toxic Releases https://oehha.ca.gov/calenviroscreen/indicator/toxic-releases-facilities
17 OEHHA Poverty https://oehha.ca.gov/calenviroscreen/indicator/poverty
18 Ibid.
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immune system and causes people to become ill from pollution19. The community also has a high
rate of linguistic isolation, meaning 59% of the census tract speaks little to no English and faces
further inequities as a result.
The project site is within a SCAG Priority Equity Community20 (SCAG Census Tract
06071002207). Additionally, the census tract adjacent to the project site (6071002301 (east) is
identified as a SB 535 Disadvantaged Community21. This indicates that cumulative impacts of
development and environmental impacts in the City are disproportionately impacting these
communities. The EIR does not discuss that the project site and surrounding area are disadvantaged
communities, does not utilize this information in its analysis, and has not considered the project’s
significant environmental impacts in relation to the SCAG Priority Equity Community and SB 535
status of the project census tract and surrounding area. A revised EIR must be prepared to disclose
this information and utilize it for threshold analysis throughout the document to comply with
CEQA Guidelines Section 15131 (c).
The EIR states that, “the project would be subject to the energy conservation requirements of the
California Energy Code (Title 24, Part 6, of the California Code of Regulations, California’s
Energy Efficiency Standards for Residential and Nonresidential Buildings) and the California
Green Building Standards Code (Title 24, Part 11 of the California Code of Regulations). The
California Energy Code provides energy conservation standards for all new and renovated
nonresidential buildings constructed in California, and the Green Building Standards Code
requires solar access, natural ventilation, and stormwater capture.” The State of California lists
three approved compliance modeling softwares22 for non-residential buildings: CBECC-Com,
EnergyPro, and IES VE. CalEEMod and EMFAC are not listed as approved softwares. The
19 Ibid.
20
https://hub.scag.ca.gov/datasets/daa7cbaf5b064399800f3426cbb64270_0/explore?location=33.814985%2
C-117.221261%2C14.86
21 OEHHA SB 535 Census Tracts
https://experience.arcgis.com/experience/1c21c53da8de48f1b946f3402fbae55c/page/SB-535-Disadvantaged-
Communities
22 California Energy Commission 2022 Energy Code Compliance Software
https://www.energy.ca.gov/programs-and-topics/programs/building-energy-efficiency-standards/2022-
building-energy-efficiency-1
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CalEEMod and spreadsheet-based modeling in Appendix B does not comply with the 2022
Building Energy Efficiency Standards and under-reports the project ’s significant Energy impacts
and fuel consumption to the public and decision makers. If the project applies for a building permit
on or after January 1, 2026, it must comply with the 2025 Building Energy Efficiency Standards,
and only CBECC is currently listed as an approved software for the updated standards23. Since the
EIR did not accurately or adequately model the energy impacts in compliance with Title 24, it
cannot conclude the project will generate less than significant impacts and a finding of significance
must be made in a revised EIR.
The EIR relies upon Mitigation Measures 3.7-1a and 3.7-1b in the Greenhouse Gas Emissions
analysis to reduce the project’s energy consumption. Mitigation Measure 3.7-1a requires that, “At
least 50 percent of the equipment used onsite to construct the project shall be powered by near-
zero emission (NZE) or zero emission (ZE) technology. Examples of NZE and ZE technologies
include battery electric, renewable diesel, hydrogen, or biomethane. This requirement applies to
all construction equipment greater than or equal to 50 horsepower. If NZE or ZE equipment and/or
fuel options are not commercially available for the project ’s construction equipment needs, the
applicant shall demonstrate that a minimum of three off-road equipment fleet
owners/operators/fuel providers in the San Bernardino County or adjacent counties were contacted
and responded that NZE or ZE equipment and/or fuel options are not commercially available for
the project ’s heavy-duty off-road equipment needs.” This indicates that compliance with this
requirement is not feasible and therefore no reduction in Energy consumption can be achieved
through this mitigation. Additionally, courts have upheld agency conclusions that electric drayage
trucks are not yet commercially viable. (Natural Resources Defense Council, Inc. v. City of Los
Angeles (2023) 98 Cal.App.5th 1176, 1223.) Since electric equipment specified to achieve
reduction in Energy consumption is not commercially available, there is no possible reduction in
Energy consumption associated with these mitigation measures. The efficacy of the proposed
mitigation and reduction of Energy consumption associated with the CAP to achieve statewide
GHG reduction goals (AB 1279 and SB 32) cannot be assured, and the project’s Energy impact is
23 California Energy Commission 2025 Energy Code Compliance Software
https://www.energy.ca.gov/programs-and-topics/programs/building-energy-efficiency-standards/2025-
energy-code-compliance-software
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therefore considered significant and unavoidable. A revised EIR must be prepared to include a
finding of significance because there is no possible assurance of the quantity of Energy
consumption reduced via implementation of the CAP and mitigation of the project’s Energy impact
to less than significant is not feasible.
The EIR concludes that the project will generate 27,981 MTCO2e annually, which exceeds the
SCAQMD threshold of 10,000 MTCO2e annually by 2.7 times. This is a significant and
unavoidable impact that the EIR attempts to circumvent by qualitatively analyzing the project in
accordance with the City’s CAP. The EIR concludes that, “The project would implement features
that would reduce emissions and would be generally consistent with the City’s CAP as well as the
2022 Scoping Plan. However, the project would not implement all relevant CAP and Scoping Plan
strategies. Therefore, the proposed project would generate GHG emissions, either directly or
indirectly, that may have a significant impact on the environment or conflict with state GHG plans.
This impact would be significant,” and implements Mitigation Measures 3.7-1a, 3.7-1b, 3.7-1c in
addition to the Mitigation Measures from the Air Quality and Transportation sections.
The City’s CAP was approved as a plan for the reduction of Greenhouse Gas Emissions pursuant
to State CEQA Guidelines Section 15183.5(b). Pursuant to State CEQA Guidelines Sections
15064(h)(3) and 15130(d), a lead agency may determine that a project’s “incremental contribution
to a cumulative effect is not cumulatively considerable if the project complies with the
requirements in a previously adopted plan or mitigation program,” in order to conclude the
project’s significant and unavoidable cumulatively considerable impacts are less than significant.
However, as stated in the EIR, the project does not comply with requirements of the CAP and
ultimately the CAP does not comply with CEQA Guidelines Section 15183.5(b)(1)(D) to, “Specify
measures or a group of measures, including performance standards, that substantial evidence
demonstrates, if implemented on a project-by-project basis, would collectively achieve the
specified emissions level.”
The CAP is insufficient in achieving reductions in GHG emissions and mitigating significant GHG
emissions. As an example, analysis in Table 3.7-4 with, “2. Off-Road Equipment (Strategy 1.4)”
concludes the project is, “Consistent After Mitigation. Mitigation Measure 3.2-2b, in Section 3.2,
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“Air Quality,” prescribes requirements to ensure 100% operational off-road equipment exceeding
50 hp is zero emissions or evidence is provided to the City that specific pieces are not commercially
available.” This indicates that compliance with this requirement is not feasible and therefore no
community benefits or reduction in GHG emissions can be achieved through implementation of
the CAP. Additionally, courts have upheld agency conclusions that electric drayage trucks are not
yet commercially viable. (Natural Resources Defense Council, Inc. v. City of Los Angeles (2023)
98 Cal.App.5th 1176, 1223.) Since electric equipment specified to achieve GHG reduction goals
is not commercially available, there is no possible community benefit or reduction of GHG
emissions associated with these measures in the CAP. The efficacy of the proposed mitigation and
reduction of GHG emissions associated with the CAP to achieve statewide GHG reduction goals
(AB 1279 and SB 32) cannot be assured, and the project’s GHG impact is therefore considered
significant and unavoidable. A revised EIR must be prepared to include a finding of significance
because there is no possible assurance of the quantity of GHG emissions reduced via
implementation of the CAP and mitigation of the project’s GHG impact to less than significant is
not feasible.
Further, Table 3.7-4 concludes the project is consistent with CAP consistency checklist item, “6.
Transportation Demand Management (Strategy 12.1) For Multi-Family Residential and
NonResidential: will the project include all of the following strategies? ‘Do not exceed the
minimum code requirement for parking capacity,’” because, “The proposed project would meet
the parking requirements of the Rancho Cucamonga Municipal Code (Chapter 17.64, Parking and
Loading Standards; 17.64.100 D.1, Trailer Parking Required).” The EIR is misleading and
internally inconsistent. Table 2-2: Summary of Proposed Automobile and Truck Trailer Parking
demonstrates the following:
Required Passenger Car Parking Stalls: 916
Provided Passenger Car Parking Stalls: 968
Required Trailer Parking Stalls: 282
Provided Trailer Parking Stalls: 444
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Exceeds Passenger Car: 52 stalls
Exceeds Trailer: 162 stalls
Exceeds Total: 214 stalls
As shown above, the project exceeds the minimum code requirement for parking capacity for
passenger cars by 52 stalls and for trailer parking by 162 stalls, 214 stalls total. The project is not
consistent with the CAP and a finding of significance must be included in a revised EIR.
CEQA Guidelines Section 15183.5(b)(2) requires that, “An environmental document that relies on
a greenhouse gas reduction plan for a cumulative impacts analysis must identify those
requirements specified in the plan that apply to the project, and, if those requirements are not
otherwise binding and enforceable, incorporate those requirements as mitigation measures
applicable to the project.” The project does not comply with the CAP’s GHG reduction plan
requirements and attempts to implement additional mitigation to produce a less than significant
finding. This does not comply with CEQA Guidelines Section 15183.5, which relies solely upon
the reduction strategies of the CAP and project compliance with the CAP to achieve a less than
significant impact. The strategies within the CAP are also infeasible/nonexistent technology and
will not result in GHG reductions required by AB 1279 and SB 32 and therefore cannot support a
less than significant finding. A revised EIR must be prepared to include a finding of significance.
3.8 Hazards and Hazardous Materials
The EIR identifies that the project site, “…is located within the Airport Influence Area (AIA) of
the Ontario International Airport,” and that it, “…is located within the FAA Height Notification
Surface Zone, which, per Federal Aviation Regulations (FAR) Part 77, Subpar B, requires that the
FAA be notified of any proposed construction or alteration having a height greater than a surface
extending outward and upward at a slope of 100 to 1 for a horizontal distance of 20,000 feet from
the airport runways.” Therefore, the Project will need to obtain clearance from the Federal Aviation
Administration (FAA) and comply with its lighting/signage restrictions and warning
improvements. The EIR does not provide substantial evidence that the FAA has reviewed the
project or their determination regarding hazards to flight.
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The EIR states that, “The proposed warehouse complex would include new buildings ranging in
height from 39 to 47 feet above ground level, which are of similar height to existing buildings in
the surrounding area. Therefore, construction and operation of the proposed project would not have
the potential to subject people residing or working in the project area to excess levels of aircraft
noise or airport-related hazards.” However, Figure 2-15: Building 4 Elevations shows the building
is 54 feet 6 inches tall and Figure 2-16: Building 5 Elevations shows the building is 50 feet 6 inches
tall. The EIR is internally inconsistent and has not provided any substantial evidence to support a
less than significant finding, such as the FAA’s review of the project and their Determination of
No Hazard to Flight document. A revised EIR must be prepared to include a finding of
significance.
The California Airport Land Use Planning Handbook24 states that Airport Land Use Commission
review is required “Prior to the amendment of a general plan or specific plan, or the adoption of a
zoning ordinance or building regulation within the ALUCP planning boundary, the ALUC shall
review the plan, ordinance, or regulation for consistency with the ALUCP (PUC Section
21676(b)).” The proposed project requires a Zoning Map Amendment pursuant to Section
17.38.080 (Large Warehouse Overlay Zone) of the RCMC to include the site in the Large
Warehouse Overlay Zone to proceed. RC Municipal Code Section 17.22.040(B)(2) requires that
when reviewing Development Code/Zoning Map Amendments the City Council, “…approves by
ordinance or denies the zoning code/map amendment in accordance with the requirements of this
title.” Airport Land Use Commission (ALUC) review is required and has not been conducted.
Delaying the ALUC review until after the EIR has been published for public comment is
implementation of the project prior to CEQA review and deferred mitigation in violation of CEQA.
Since the ALUC has not reviewed the project, a revised EIR must be prepared to include a finding
of significance as there is no meaningful evidence presented to support a less than significant
finding.
24 California Airport Land Use Planning Handbook https://dot.ca.gov/-/media/dot-
media/programs/aeronautics/documents/californiaairportlanduseplanninghandbook-a11y.pdf
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3.10 Land Use and Planning
The project faces significant inconsistencies with statutory requirements of the Housing Crisis Act
(HCA) of 2019/Senate Bill (SB) 33025/SB 826. The HCA/SB 330/SB 8 require replacement
housing sites when land designated for housing development experience changes to ensure no net
loss of housing capacity. Approximately 64 acres of the project site has a General Plan land use
designation of Neo-Industrial27 that has a maximum density of 24 dwelling units per acre28. The
approximately 64 acre area of the project site can accommodate the development of up to 1,545
dwelling units. Project implementation will result in exclusively industrial development. The site
would not be used for the development of any residential dwelling units and replacement sites
must be proposed and analyzed as part of the project. The EIR does not act in conformance with
these laws and has not identified replacement sites for housing. Specifically, the existing General
Plan designation permits the development of up to 1,545 residential dwelling units. The lost
capacity of 1,545 dwelling units is a significant environmental impact in violation of the HCA/SB
330/SB 8. The EIR must be revised to include a finding of significance due to this inconsistency.
APN 0229-121-33
30.12 acres
Residential capacity: 722 dwelling units
APN 0229-121-34
19.03 acres
Residential capacity: 456 dwelling units
APN 0229-121-35
15.32 acres
Residential capacity: 367 dwelling units
25 Housing Crisis Act of 2019/SB 330
https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=201920200SB330
26 SB 8 https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=202120220SB8
27 San Bernardino County Map My County
https://experience.arcgis.com/experience/8c4f806654654ba689fa7ab842d57352
28 https://www.cityofrc.us/sites/default/files/2022-01/PlanRC_Volume%202_Final_pages.pdf
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Approval of the EIR and the proposed project will result in a net loss of housing capacity of 1,545
dwelling units. This is a significant environmental impact in violation of the HCA/SB 330/SB 8.
The EIR must be revised to include a finding of significance due to this inconsistency.
Additionally, deferring the identification of replacement sites to a later date is project piecemealing
in violation of CEQA. The EIR does not accurately or adequately describe the project, meaning
“the whole of an action, which has a potential for resulting in either a direct physical change in the
environment, or a reasonably foreseeable indirect physical change in the environment” (CEQA §
15378). The whole of the action must statutorily and legally include identified replacement sites
to accommodate the lost capacity of 1,545 dwelling units. This is a significant and unavoidable
environmental impact and a finding of significance must be made in a revised EIR.
Further, the significant and unavoidable impacts of the project and the project’s operational
characteristics prohibit residential development within 1,000 feet of the project site. This is
required in the General Plan as stated by, “Policy RC-5.7 New Sensitive Receptors Near Existing
Industrial Uses. Avoid placing homes, schools, hospitals, and childcare facilities within 1,000 feet
of a land use that accommodates more than 100 trucks per day, more than 40 trucks with operating
transport refrigeration units (TRUs) per day, or where TRU unit operations exceed 300 hours per
week.” Appendix J states that the project will generate approximately 684 trucks per day and
therefore Policy RC 5.7 applies to all properties within 1,000 feet of the project site. The EIR has
not provided the residential capacity of all sites within 1,000 feet of the project site and
replacement sites as required by The Housing Crisis Act (HCA) of 2019/Senate Bill (SB) 330/SB
8. A finding of significance must be made in a revised EIR.
The project site is primarily located in the Neo-Industrial Employment District of the General Plan,
with only Building 5 (APN 022913119) within the Industrial Employment District. The EIR
mischaracterizes the intent and permitted uses within the Neo-Industrial Employment District of
the General Plan and the proposed project.
The General Plan states that in the Neo-Industrial land use designation, “More intensive industrial
uses with substantive impacts on adjacent uses are not permitted;” and that, “Low impact industrial
uses, such as incubator spaces and small warehouses, that are context-sensitive and calibrated to
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minimize impacts to adjacent residential uses are preferred.” The Industrial Employment District
of the General Plan permits uses that are, “a broad range of light and medium industrial uses,
including light industrial research parks, logistics centers, low impact manufacturing, and
machining operations.”
The EIR states that, “The proposed industrial distribution facilities, including high-cube fulfillment
center (non-sorting), general warehouse, high-cube cold storage warehouse, and accessory office
space, are allowable uses within these land use designations.” Distribution centers and warehouses
are a component of the overall logistics center business chain. Logistics facilitates the overall
movement of goods within supply chain management (upstream, downstream, raw materials,
finished products, etc.). Distribution is a point on the logistics center business chain as the
movement of finished gods for final delivery to the end consumer at their home or commercial
stores. Overall, distribution centers are logistics centers and a component of the overall logistics
process. Therefore, the proposed project is not permitted within the existing Neo-Industrial
Employment District land use designation because it is not a small warehouse and it is not context-
sensitive or calibrated to minimize impacts. The project requests a Zoning Map Amendment to be
located within the Large Warehouse Overlay, which clearly indicates that it is not a small
warehouse. The project will result in significant and unavoidable impacts to Air Quality and
increase VMT, indicating that it is an intense industrial use with substantive impacts on adjacent
uses. The proposed distribution center use is clearly permitted and intended to be located within
the Industrial Employment District as it expressly lists logistics centers as a permitted use. A
finding of significance must be included as part of a revised EIR due to this inconsistency.
Table 3.10-1: Potential to Conflict with PlanRC 2040 Land Use Policies concludes that the project
is consistent with Policy “LC-1.16 Healthy Development. Ensure that the design and development
of our communities supports the health and well-being of our residents. Use the Healthy
Development Checklist, or similar assessment tool, to assess the overall health performance and
supportiveness of new development projects,” because, “The proposed project includes measures
to reduce environmental impacts on human health and safety from air pollutants, hazardous
materials, noise, and transportation hazards. Refer to Section 3.2, “Air Quality,” Section 3.8,
“Hazards and Hazardous Materials,” Section 3.11, “Noise and Vibration,” and Section 3.13,
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“Transportation” for additional discussion. Therefore, no conflict with Policy LC-1.16 would
occur that would result in an adverse environmental effect.” The analysis excludes that the project
will result in significant and unavoidable cumulatively considerable impacts to Air Quality and
VMT. The project conflicts with several items in the Healthy Development Checklist29 for active
transportation since it does not construct Whittram Avenue in accordance with the Southeast Area
street network and therefore does not provide the associated active transportation infrastructure.
The project also conflicts with, “17. Environmental Justice. How well does the project mitigate
any impacts that would disproportionately affect disadvantaged communities?” The project will
result in significant and unavoidable cumulatively considerable impacts to Air Quality and VMT
within a SCAG Priority Equity Community and the site is adjacent to a SB 535 Disadvantaged
Community, meaning that it does not successfully mitigate impacts that disproportionately affect
disadvantaged communities.
The EIR concludes the project is consistent with Policy “LC-7.6 Loading Docks. Require that
parking lots, loading docks, outdoor storage, and processing, be located behind or beside
buildings, not in front, and be screened from public views,” because, “loading docks would be
oriented away from existing and proposed public streets or screened with walls, fences, and
landscaping. The consistency analysis excludes any statements regarding the siting of loading
docks and parking lots in front of the proposed buildings. Figure 2-11: Proposed Site Plan depicts
several loading dock and parking lot areas that are in front of buildings and visible from public
streets (Arrow Route, Yellow Wood Road, and New Public Streets A, B, C, D E, and F):
29 https://cheac.org/wp-content/uploads/2017/10/RUHS-HDC_FINAL09142017.pdf
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The EIR must be revised to include a finding of significance due to the project’s inconsistency
with Policy LC-7.6.
Further, Table 3.10-1: Potential to Conflict with PlanRC 2040 Land Use Policies does not provide
a consistency analysis with the following applicable General Plan policies and must be revised to
include this analysis:
1. Policy LC-1.5 Master Planning. When planning a site, there must be meaningful efforts to
master plan the site so as to ensure a well-structured network and block pattern with sufficient
access and connectivity to achieve the placemaking goals of this General Plan.
2. Policy LC-1.6 Disadvantaged Communities. Prioritize development appropriate to the needs
of disadvantaged communities, particularly south of Foothill Boulevard.
3. Policy LC-1.7 Design for Safety. Require the use of Crime Prevention Through Environmental
Design (CPTED) techniques such as providing clear lines of sight, appropriate lighting, and
wayfinding signs to ensure that new development is visible from public areas and easy to
navigate.
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4. Policy LC-1-8 Public Art. Require new construction to integrate public art in accordance with
the City Public Arts Program.
5. Policy LC-1.13 Improved Public Realm. Require that new development extend the “walkable
public realm” into previously vacant and/or parking lot dominant large single-use parcels of
land.
6. Goal LC-2 Human Scaled. A city planned and designed for people fostering social and
economic interaction, an active and vital public realm, and high levels of public safety and
comfort.
7. Policy LC-2.1 Building Orientation. Require that buildings be sited near the street and
organized with the more active functions—entries, lobbies, bike parking, offices, employee
break rooms and outdoor lunch areas—facing toward and prominently visible from the street
and visitor parking areas.
8. Policy LC-2.5 Gradual Transitions. Where adjacent to existing and planned residential
housing, require that new development of a larger form or intensity, transition gradually to a
complement the adjacent residential uses.
9. Goal LC-3 Fiscally Sustainable. A fiscally sound and sustainable City.
10. Policy LC-3.1 Community Value. Actively manage growth and investments in the community
to maximize the value of new development, seeking value-per-acre outcomes of up to six times
higher.
11. Policy LC-3.2 Community Benefit. Require a community benefit and economic analysis for
large projects that abut existing neighborhoods or for any project at the maximum density,
with a focus on resolving physical, economic, long-term fiscal, and aesthetic impacts.
12. Policy LC-3.3 Community Amenities. Balance the impacts of new development, density, and
urbanization through the provision of a high-level of neighborhood and community amenities
and design features.
13. Policy LC-3.5 Efficient Growth. Manage growth in a manner that is fiscally sustainable, paced
with the availability of infrastructure, and protects and/or enhances community value.
Discourage growth and development that will impact the City ’s ability to sustainably maintain
infrastructure and services.
14. Policy LC-7.3 Campus Design. Encourage employment areas to be developed like a college
campus with buildings oriented toward an internal roadway, buffer landscaping along the
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perimeter, and ample opportunities for paths and trails connecting to the City system, as well
as relaxation areas for employees.
15. Policy MA-2.10 Block Pattern. Require development projects to arrange streets in an
interconnected block pattern, so that pedestrians, bicyclists, and drivers are not forced onto
arterial streets for inter- or intra- neighborhood travel.
16. Policy MA-3.3 Vulnerable User Safety. Prioritize pedestrian improvements in the Pedestrian
Priority Area shown on Figure 8 to promote safety in the southwest area of the city.
17. Goal H-1 Housing Opportunities. A diverse community with a broad range of housing types
and opportunities to accommodate expected new households.
18. Policy H-1.1 RHNA Requirement. Encourage the development of a wide range of housing
options, types, and prices that will enable the City to achieve its share of the RHNA.
19. Goal RC-5 Local Air Quality. Healthy air quality for all residents.
20. Policy RC-5.1 Pollutant Sources. Minimize increases of new air pollutant emissions in the city
and encourage the use of advance control technologies and clean manufacturing techniques.
21. Policy RC-5.2 Air Quality Land Use Compatibility. Avoid siting of homes, schools, hospitals,
and childcare facilities and land uses within 500 feet of land uses that are considered large
emitters.
22. Policy RC-5.3 Barriers and Buffers. Require design features such as site and building
orientation, trees or other landscaped barriers, artificial barriers, ventilation and filtration,
construction, and operational practices to reduce air quality impacts during construction and
operation of large stationary and mobile sources.
23. Policy RC-5.5 Impacts to Air Quality. Ensure new development does not disproportionately
burden residents, due to age, culture, ethnicity, gender, race, socioeconomic status, or
geographic location, with health effects from air pollution. Prioritize resource allocation,
investments, and decision making that improves air quality for residents disproportionately
burdened by air pollution because of historical land use planning decisions and overarching
institutional and structural inequities.
24. Policy RC-5.6 Community Benefit Plan. Require that any land use generating or
accommodating more than 100 trucks per day, more than 40 trucks with operating transport
refrigeration units (TRUs) per day, or where TRU unit operations exceed 300 hours per week,
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provide a community benefit plan demonstrating an offset to community impacts of the truck
traffic.
25. Policy RC-5.9 Truck Hook-Ups at New Industrial or Commercial Developments. Require new
industrial or commercial developments at which heavy-duty diesel trucks idle on-site to install
electric truck hook-ups in docks, bays, and parking areas.
26. Goal RC-6 Climate Change. A resilient community that reduces its contributions to a changing
climate and is prepared for the health and safety risks of climate change.
27. Policy RC-6.1 Climate Action Plan. Maintain and implement a Climate Action Plan (CAP)
that provides best management practices for reducing greenhouse gas emissions.
28. Policy RC-6.5 GHG Reduction Goal. Reduce emissions to 80 percent below 1990 levels by
2050 and achieve carbon neutrality by 2045.
29. Policy RC-6.12 Reduced Water Supplies. When reviewing development proposals, consider
the possibility of constrained future water supplies and require enhanced water conservation
measures.
30. Policy RC-6.13 Designing for Warming Temperatures. When reviewing development
proposals, encourage applicants and designers to consider warming temperatures in the design
of cooling systems.
31. Policy RC-6.14 Designing for Changing Precipitation Patterns. When reviewing development
proposals, encourage applicants to consider stormwater control strategies and systems for
sensitivity to changes in precipitation regimes and consider adjusting those strategies to
accommodate future precipitation regimes.
32. Policy RC-6.15 Heat Island Reductions. Require heat island reduction strategies in new
developments such as light-colored paving, permeable paving, right-sized parking
requirements, vegetative cover and planting, substantial tree canopy coverage, and south and
west side tree planting.
33. Policy RC-6.16 Public Realm Shading. Strive to improve shading in public spaces, such as
bus stops, sidewalks and public parks and plazas, through the use of trees, shelters, awnings,
gazebos, fabric shading and other creative cooling strategies.
34. Policy RC-7.9 Passive Solar Design. Require new buildings to incorporate energy efficient
building and site design strategies for the arid environment that include appropriate solar
orientation, thermal mass, use of natural daylight and ventilation, and shading.
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35. Policy RC-7.12 Solar Access. Prohibit new development and renovations that impair adjacent
buildings ’solar access, unless it can be demonstrated that the shading benefits substantially
offset the impacts of solar energy generation potential.
36. Goal S-5 Emerging Hazards. A built environment that incorporates new data and
understanding about changing hazard conditions and climate stressors.
37. Policy S-5.4 Extreme Heat Vulnerabilities. Require that new developments, major remodels,
and redevelopments address urban heat island issues and reduce urban heat island effects for
the proposed project site and adjacent properties.
38. Policy S-5.5 Resilience Resources. Require new developments and redevelopments to
incorporate resilience amenities such as, but not limited to community cooling centers,
emergency supplies, and backup power that can be used by residents and businesses within a
1/4-mile radius of the location.
39. Policy S-5.6 Underground Utilities. Promote the under-grounding of utilities for new
development, major remodels, and redevelopment.
40. Policy S-5.8 Climate Resiliency. Address climate resiliency and inequities through the
planning and development process.
41. Policy S-5.9 Address High Winds. Require buildings and developments exposed to high wind
conditions to incorporate design elements and features that minimize or reduce damage to
people, structures, and the community.
42. Policy S-6.5 Height Restrictions. Require proposed developments within the Ontario Airport
Influence Area meet the height requirements associated with FAR Part 77 standards.
43. Policy S-6.6 Development Near Airport. New development within the Ontario Airport
Influence Area shall be consistent with the approved Airspace Protection Zones identified in
the latest version of the Airport Land Use Compatibility Plan.
Further, the EIR is internally inconsistent as it concludes in the Transportation section that the
project is not consistent with the buildout of PlanRC (General Plan) nor the SCAG RTP/SCS land
use scenario and it does not discuss this information here. The EIR must be revised to include this
information here in order to provide an adequate and accurate environmental document and include
a finding of significance due to this direct inconsistency.
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Table 3.10-2 Potential to Conflict with Connect SoCal 2024 Policies does not specifically list any
of the Connect SoCal 2024 Policies. The EIR groups together a few sequential policies and
provides a general summary of the items. Given the EIR’s conclusion that the project will result
in significant and unavoidable impacts to Air Quality and increase VMT, and the project site is
within a SCAG Priority Equity Community30 (SCAG Census Tract 06071002207), the project is
directly inconsistent with the following policies and will impede the SCAG region’s ability to
achieve statewide GHG reduction and climate goals:
1. Equitable Engagement and Decision-Making Policy 45. Advance community-centered
interventions, resources and programming that serve the most disadvantaged communities and
people in the region, like Priority Equity Communities, with strategies that can be
implemented in the short-to-long-term.
2. Equitable Engagement and Decision-Making Policy 46. Promote racial equity that is grounded
in the recognition of the past and current harms of systemic racism and one that advances
restorative justice.
3. Equitable Engagement and Decision-Making Policy 47. Increase equitable, inclusive, and
meaningful representation and participation of people of color and disadvantaged communities
in planning processes.
4. Sustainable Development Policy 48. Promote sustainable development and best practices that
enhance resource conservation, reduce resource consumption and promote resilience.
5. Sustainable Development Policy 49. Support communities across the region to advance
innovative sustainable development practices.
6. Sustainable Development Policy 50. Recognize and support the diversity of communities
across the region by promoting local place-making, planning and development efforts that
advance equity, mobility, resilience and sustainability.
7. Air Quality Policy 51. Reduce hazardous air pollutants and greenhouse gas emissions and
improve air quality throughout the region through planning and implementation efforts.
30
https://hub.scag.ca.gov/datasets/daa7cbaf5b064399800f3426cbb64270_0/explore?location=33.814985%2
C-117.221261%2C14.86
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8. Air Quality Policy 52. Support investments that reduce hazardous air pollutants and
greenhouse gas emissions.
9. Air Quality Policy 53. Reduce the exposure and impacts of emissions and pollutants and
promote local and regional efforts that improve air quality for vulnerable populations,
including but not limited to Priority Equity Communities and the AB 617 Communities.
10. Climate Resilience Policy 64. Prioritize the most vulnerable populations and communities
subject to climate hazards to help the people, places and infrastructure that are most at risk for
climate change impacts. In doing so, recognize that disadvantaged communities are often
overburdened.
11. Climate Resilience Policy 65. Support local and regional climate and hazard planning and
implementation efforts for transportation, land use, and other factors.
12. Climate Resilience Policy 66. Support nature-based solutions to increase regional resilience
of the natural and built environment.
A revised EIR must be prepared to disclose the project’s inconsistency with these policies and
include a finding of significance. This is especially notable as the project site (SCAG Census Tract
06071002207) is identified as a Priority Equity Community in the RTP/SCS31 and the project will
result in significant and unavoidable impacts to Air Quality and increase VMT. Additionally, the
EIR concludes that the project is inconsistent with the RTP/SCS growth projections and buildout
scenario. The EIR must be revised to include a finding of significance.
The EIR has not discussed or analyzed the project in accordance with all Rancho Cucamonga
Municipal Code requirements. Rancho Cucamonga Municipal Code Section 17.22.040(C)
provides the required findings for approval of a Zoning Map Amendment:
“17.22.040(C): Findings. Development code/zoning map amendments may be approved only
when the city council finds that the Development Code/zoning map amendment is consistent with
the general plan goals, policies, and implementation programs.”
31
https://hub.scag.ca.gov/datasets/daa7cbaf5b064399800f3426cbb64270_0/explore?location=33.814985%2
C-117.221261%2C14.86
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The project will result in significant and unavoidable impacts to Air Quality and increase VMT.
As discussed throughout this comment letter, the project is directly inconsistent with several
General Plan goals and policies. A finding of significance must be provided in a revised EIR.
3.13 Transportation
The EIR has not adequately or accurately analyzed the project in accordance with all programs,
plans, ordinances, or policies addressing the Circulation System, including transit, roadway,
bicycle, and pedestrian facilities. Figure M-8: Proposed Street Network in Southeast Area lists the
following requirements for the project site:
“Requirement 3: Extend Whittram Avenue from Etiwanda Avenue to Rochester Avenue and under
the I-15 to provide better access to the Southeast Area.
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Requirement 5: Develop a more complete, modern, multi-modal street network for improved
circulation and access. The street network in this area is at or near capacity. If the legacy heavy
industrial uses redevelop, additional east-west street capacity between Rochester Avenue and
Etiwanda Avenue and north-south street capacity between Arrow and 6th Street will be needed.”
The required street network bisects the Building 4 site. The EIR states that, “…the construction of
new public street F would partially achieve a roadway connection envisioned in PlanRC, which
considered the extension of Whittram Avenue from Etiwanda Avenue to Rochester Avenue and
under the I-15 to provide better access to the Southeast Industrial Area (City of Rancho
Cucamonga 2021: Figure M-8). Therefore, the proposed project would not conflict with any
planned or programmed roadway improvements in the vicinity of the project site.” The
requirement is clear - construct Whittram Avenue in accordance with Requirement 3 to complete
street network in the Southeast Area. The project does not comply with Requirement 3 and
therefore a finding of significance must be included in a revised EIR.
The EIR also does not discuss or analyze several other requirements from the Circulation Element
of the General Plan. For example, Figure FA-1: Focus Areas Map depicts Arrow Route as a Transit
Priority Street. Figure FA-2:Focus Area 1: Downtown Rancho Cucamonga depicts Arrow Route
east of Rochester Avenue as a Bike Priority Street and includes, “Requirement 2: Improve Church
Street, Arrow Route and Rochester Avenue with buffered bike lanes.” Figure M-6: Pedestrian
Focus Areas depicts the entirety of the project site within a pedestrian focus area. The complete
streets network in the Southeast Area will not be constructed in accordance with the Circulation
Element as the project will not construct Whittram Avenue and therefore not provide the associated
active transportation improvements. A finding of significance must be included in a revised EIR.
Table 3.13-7: Project-Generated VMT shows that the project will exceed the VMT threshold for
both the 2019 Baseline Year Plus Project and the 2050 Future Year Plus Project scenarios. The
EIR provides Mitigation Measures 3.13-2a, 3.13-2b, 3.13-2c, and 3.13-2d to justify mitigating
impacts to less than significant levels:
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“Mitigation Measure 3.13-2a: Implement Commute Trip Reduction Marketing: The
implementation of commute trip reduction marketing would result in an estimated up to 4-percent
employee VMT reduction (CAPCOA 2021). Information sharing and marketing promote and
educate employees about their travel choices to the employment location beyond driving such as
carpooling, taking transit, walking, and biking, thereby reducing VMT.
Mitigation Measure 3.13-2b: Provide Employee Rideshare Program: The implementation of a
ridesharing program would result in an estimated up to 4-percent employee VMT reduction
(CAPCOA 2021). Ridesharing encourages carpooled vehicle trips in place of single-occupied
vehicle trips, thereby reducing the number of trips and, therefore, VMT.
Mitigation Measure 3.13-2c: Provide End-of-Trip Bicycle Facilities: Providing end-of-trip
facilities would result in an estimated up to 0.3-percent employee VMT reduction (CAPCOA
2021). The provision and maintenance of secure bike parking and related facilities encourages
commuting by bicycle, thereby reducing VMT.
Mitigation Measure 3.13-2d: Provide Employer-Sponsored Vanpool: Providing employer-
sponsored vanpool would result in an estimated up to 1.6-percent employee VMT reduction
(CAPCOA 2021). Vanpooling is a flexible form of public transportation that provides groups of 5
to 15 people with a cost-effective and convenient rideshare option for commuting. The mode shift
from long distance, single-occupied vehicles to shared vehicles reduces overall commute VMT.
The analysis assumes that up to 2 percent of employees would participate in the vanpool program.”
Notably, the EIR has not provided substantial evidence to support the conclusion that Mitigation
Measures 3.13-2a through 2d will reduce VMT to below the significance threshold throughout the
life of the project. Mitigation Measures 3.13-2a through 2d are unenforceable mitigation in
violation of CEQA § 21081.6 (b). Appendix I employs the assumption that 100% of the future
employees are eligible to participate, which cannot be feasibly ascertained as the EIR
simultaneously asserts throughout the document that the future tenants are unknown.
Further, it is not possible for the lead agency to ensure that Mitigation Measures 3.13-2a through
2d will result in reduced VMT by project employees and be implemented continuously, at all times,
throughout the life of the project and maintain a VMT reduction to less than significant levels at
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all times. The efficacy of the proposed mitigation measures and reduction of VMT impacts below
the applicable thresholds cannot be assured, and the project’s VMT impact therefore remains
significant and unavoidable. A revised EIR must be prepared to include a finding of significance
because there is no possible assurance of the percentage of project employees that would utilize
non-automobile or non-single occupant vehicle travel associated with the mitigation measures and
mitigation of the project’s VMT impact to less than significant is not feasible.
Additionally, Table 1: VMT Impact Thresholds of Exhibit A to Resolution No. 2020-05632 states
that for Land Use Projects, “A significant impact would occur if the project is determined to be
inconsistent with the RTP/SCS.” Appendix I states that, “The Project was determined to be
inconsistent with the land use growth assumptions in Plan RC and in the RTP/SCS by reviewing
the regional travel model, SBTAM+. As shown in Table 3 and Figures 2 and 3, the manufacturing
and transportation employment growth generated by the Project is more than the total growth
assumed in SBTAM+.” Therefore, the project results in a significant impact due to inconsistency
with the RTP/SCS, and a finding of significance for this specific reason must be included in a
revised EIR.
Further, the EIR has underreported the quantity VMT generated by the proposed project
operations. The operational nature of industrial/warehouse uses involves high rates of
truck/trailer/delivery van VMT due to traveling from large import hubs to distribution centers or
smaller industrial parks and then to their final delivery destinations. Once employees arrive at work
at the proposed project, they will conduct their jobs by driving delivery vans across the region as
part of the daily operations as distribution warehouses, which will drastically increase project-
generated VMT. The project’s truck/trailer and delivery van activity is unable to utilize public
transit or active transportation and it is misleading to the public and decision makers to exclude
this activity from VMT analysis. The project’s actual VMT generated by all aspects of project
operation is not consistent with the significance threshold and legislative intent of SB 743 to reduce
greenhouse gas emissions by reducing VMT. A revised EIR must be prepared to reflect a
quantified VMT analysis that includes all truck/trailer and delivery van activity.
32 https://rcdocs.cityofrc.us/WebLink/PDF10/fbcc90aa-27bf-455c-9838-e4a085ad0278/570716
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The EIR has not adequately analyzed the project’s potential to substantially increase hazards due
to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses;
or the project’s potential to result in inadequate emergency access. The EIR states that, “All
roadway and facility improvements would be subject to and constructed in accordance with
applicable City and industry standard roadway design and safety guidelines, including the City of
Rancho Cucamonga Standard Drawings and design guidelines provided in Chapter 17.120 and
Section 17.122.030 of the Municipal Code. Furthermore, the proposed project would be subject to
City review processes, which would ensure that the proposed project design, including new
roadway improvements and tie-ins to the existing transportation network, would comply with all
applicable design standards related to transportation safety.” This does not comply with CEQA’s
requirements for adequate informational documents and meaningful disclosure (CEQA § 15121
and 21003(b)). The EIR has not provided any details regarding the requirements for emergency
access or meaningful analysis of the project’s compliance or noncompliance with these
requirements. Deferring this environmental analysis required by CEQA to the construction
permitting phase is improper mitigation and does not comply with CEQA’s requirement for
meaningful disclosure and adequate informational documents. A revised EIR must be prepared to
include a finding of significance as the EIR has not provided any meaningful evidence to support
a less than significant finding.
The EIR does not discuss Figure 2-17: Proposed Onsite Circulation, which depicts several areas
of conflict between vehicles, as shown below.
West side of Building 1 at New Public Street B: Trucks/trailers entering and exiting the sites
require additional maneuvering space across the centerline of each street, meaning that the trucks
will need to drive on the “wrong side” of the street into oncoming traffic in order to enter or exit
the site. A finding of significance is required in a revised EIR.
Additionally, the overlapping lines along the internal driveway indicate that it is not wide enough
to accommodate more than one truck/trailer movement at a time. Truck/trailer parking stalls are
also configured within the truck/trailer loading dock courts and adjacent to the project driveway.
This layout and design is not conducive to vehicular maneuvering. These parking stalls may be in
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use at any time and further restrict truck/trailer movement, particularly while trucks/trailers attempt
to utilize the loading docks and maneuver throughout the site. Queuing/storage space is required
on New Public Street B and the EIR has not analyzed these significant impacts. A finding of
significance is required in a revised EIR.
North side of Building 2 and Building 3 at Arrow Route: The overlapping lines along the internal
driveway indicate that it is not wide enough to accommodate more than one truck/trailer movement
at a time. Additionally, passenger car parking stalls are configured adjacent to the truck/trailer
loading dock courts and the project driveway. This layout and design is not conducive to vehicular
maneuvering. These parking stalls may be in use at any time and further restrict truck/trailer
movement, particularly while trucks/trailers attempt to maneuver throughout the site.
Queuing/storage space is required on Arrow Route and the EIR has not analyzed these significant
impacts. A finding of significance is required in a revised EIR.
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South side of Building 2 and Building 3 at New Public Street C: Trucks/trailers entering and exiting
the sites require additional maneuvering space across the centerline of each street, meaning that
the trucks will need to drive on the “wrong side” of the street into oncoming traffic in order to
enter or exit the site. A finding of significance is required in a revised EIR.
Additionally, the overlapping lines along the internal driveway indicate that it is not wide enough
to accommodate more than one truck/trailer movement at a time. Passenger car parking stalls are
also configured adjacent to the truck/trailer loading dock courts and the project driveway. This
layout and design is not conducive to vehicular maneuvering. These parking stalls may be in use
at any time and further restrict truck/trailer movement, particularly while trucks/trailers attempt to
maneuver throughout the site. Queuing/storage space is required on New Public Street C and the
EIR has not analyzed these significant impacts. A finding of significance is required in a revised
EIR.
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Northeast side of Building 4 at New Public Street C and Yellow Wood Road: Trucks/trailers
entering and exiting the sites require additional maneuvering space across the centerline of each
street, meaning that the trucks will need to drive on the “wrong side” of the street into oncoming
traffic in order to enter or exit the site. A finding of significance is required in a revised EIR.
Additionally, the overlapping lines along the internal driveway indicate that it is not wide enough
to accommodate more than one truck/trailer movement at a time. Queuing/storage space is required
on New Public Street C and the EIR has not analyzed these significant impacts. A finding of
significance is required in a revised EIR.
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Driveways at Northwest side of Building 4/Southwest side of Building 1 at New Public Street B
and New Public Street C: Trucks/trailers entering and exiting the sites require additional
maneuvering space across the centerline of each street, meaning that the trucks will need to drive
on the “wrong side” of the street into oncoming traffic in order to enter or exit the site. A finding
of significance is required in a revised EIR.
Additionally, the overlapping lines along the internal driveway indicate that it is not wide enough
to accommodate more than one truck/trailer movement at a time. Passenger car parking stalls are
also configured adjacent to the truck/trailer loading dock courts and the project driveway. This
layout and design is not conducive to vehicular maneuvering. These parking stalls may be in use
at any time and further restrict truck/trailer movement, particularly while trucks/trailers attempt to
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maneuver throughout the site. Queuing/storage space is required on New Public Street B and New
Public Street C and the EIR has not analyzed these significant impacts. A finding of significance
is required in a revised EIR.
West side of Building 4 Mid-Block driveway at New Public Street B: Trucks/trailers entering and
exiting the site require additional maneuvering space across the centerline of each street, meaning
that the trucks will need to drive on the “wrong side” of the street into oncoming traffic in order to
enter or exit the site. A finding of significance is required in a revised EIR.
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Additionally, the overlapping lines along the internal driveway indicate that it is not wide enough
to accommodate more than one truck/trailer movement at a time. Truck/trailer parking stalls are
within the truck/trailer loading dock courts in a tandem configuration. This layout and design is
not conducive to vehicular maneuvering. These parking stalls that may be in use at any time and
further restrict truck/trailer movement, including increasing truck idling as tandem parked trucks
require additional time to maneuver, which will also result in increased queuing duration and
associated queuing area for trucks/trailer. Queuing/storage space is required on New Public Street
B and the EIR has not analyzed these significant impacts. A finding of significance is required in
a revised EIR.
Southwest side of Building 4 driveway at New Public Street A: Trucks/trailers entering and exiting
the site require additional maneuvering space across the centerline of each street, meaning that the
trucks will need to drive on the “wrong side” of the street into oncoming traffic in order to enter
or exit the site. A finding of significance is required in a revised EIR.
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Additionally, the overlapping lines along the internal driveway indicate that it is not wide enough
to accommodate more than one truck/trailer movement at a time. Queuing/storage space is required
on New Public Street A and the EIR has not analyzed these significant impacts. A finding of
significance is required in a revised EIR.
Southeast side of Building 4 driveway at New Public Street A and Southwest side of Building 5
driveway at Yellow Wood Road/New Public Street A: Trucks/trailers entering and exiting the sites
require additional maneuvering space across the centerline of each street, meaning that the trucks
will need to drive on the “wrong side” of the street into oncoming traffic in order to enter or exit
the site. A finding of significance is required in a revised EIR.
Additionally, the overlapping lines along the internal driveway indicate that it is not wide enough
to accommodate more than one truck/trailer movement at a time. Queuing/storage space is required
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on Yellow Wood Road and New Public Street A and the EIR has not analyzed these significant
impacts. A finding of significance is required in a revised EIR.
Driveway on East side of Building 4 at intersection of Yellow Wood Road and New Public Street
D: Trucks/trailers entering and exiting the site require additional maneuvering space across the
centerline of each street, meaning that the trucks will need to drive on the “wrong side” of the
street into oncoming traffic in order to enter or exit the site. A finding of significance is required
in a revised EIR.
Additionally, the overlapping lines along the internal driveway indicate that it is not wide enough
to accommodate more than one truck/trailer movement at a time. Truck/trailer parking stalls are
within the truck/trailer loading dock courts in a tandem configuration. This layout and design is
not conducive to vehicular maneuvering. These parking stalls that may be in use at any time and
further restrict truck/trailer movement, including increasing truck idling as tandem parked trucks
require additional time to maneuver, which will also result in increased queuing duration and
associated queuing area for trucks/trailer. Queuing/storage space is required on Yellow Wood
Road and New Public Street D and the EIR has not analyzed these significant impacts. A finding
of significance is required in a revised EIR.
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Driveway on Northwest side of Building 5 at Yellow Wood Road and New Public Street D:
Trucks/trailers entering and exiting the site require additional maneuvering space across the
centerline of each street, meaning that the trucks will need to drive on the “wrong side” of the
street into oncoming traffic in order to enter or exit the site. A finding of significance is required
in a revised EIR.
Additionally, the overlapping lines along the internal driveway indicate that it is not wide enough
to accommodate more than one truck/trailer movement at a time. Queuing/storage space is required
on Yellow Wood Road and New Public Street D and the EIR has not analyzed these significant
impacts. A finding of significance is required in a revised EIR.
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Driveway on Northeast side of Building 5 at New Public Street D/New Public Street E/New Public
Street F: Trucks/trailers entering and exiting the site require additional maneuvering space across
the centerline of each street, meaning that the trucks will need to drive on the “wrong side” of the
street into oncoming traffic in order to enter or exit the site. A finding of significance is required
in a revised EIR.
Additionally, the overlapping lines along the internal driveway indicate that it is not wide enough
to accommodate more than one truck/trailer movement at a time. Queuing/storage space is required
on New Public Street E and New Public Street D and the EIR has not analyzed these significant
impacts. A finding of significance is required in a revised EIR.
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Driveway on Southeast side of Building 5 at New Public Street A and New Public Street E:
Trucks/trailers entering and exiting the site require additional maneuvering space across the
centerline of each street, meaning that the trucks will need to drive on the “wrong side” of the
street into oncoming traffic in order to enter or exit the site. A finding of significance is required
in a revised EIR.
Additionally, the overlapping lines along the internal driveway indicate that it is not wide enough
to accommodate more than one truck/trailer movement at a time. Queuing/storage space is required
on New Public Street A and New Public Street E and the EIR has not analyzed these significant
impacts. A finding of significance is required in a revised EIR.
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The EIR states that, “Additionally, clear sight distance would be maintained at all intersections in
accordance with City standards.” This does not comply with CEQA’s requirements for adequate
informational documents and meaningful disclosure (CEQA § 15121 and 21003(b)). The EIR has
not provided any details regarding the City standards for items related to sight distance, or
meaningful analysis of the project’s compliance or noncompliance with these requirements.
Deferring this environmental analysis required by CEQA to the construction permitting phase is
improper mitigation and does not comply with CEQA’s requirement for meaningful disclosure
and adequate informational documents. A revised EIR must be prepared to include a finding of
significance as the EIR has not provided any meaningful evidence to support a less than significant
finding.
The EIR states regarding emergency access that, “Additionally, the proposed project would be
required to comply with the 2022 California Fire Code as adopted by reference in Rancho
Cucamonga Fire Protection District Ordinance No. FD 58. Appendix D of the Ordinance provides
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November 13, 2025
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additional requirements for fire apparatus access roads, including minimum dimensions to allow
for adequate access and turning radii for emergency vehicles accessing the project site during
operations. Further, the proposed project would be subject to review by the City and responsible
emergency service agencies, thus ensuring that the proposed project would be equipped to provide
adequate access for emergency responders.” This does not comply with CEQA’s requirements for
adequate informational documents and meaningful disclosure (CEQA § 15121 and 21003(b)). The
EIR has not provided any details regarding the requirements for emergency access or meaningful
analysis of the project’s compliance or noncompliance with these requirements. Deferring this
environmental analysis required by CEQA to the construction permitting phase is improper
mitigation and does not comply with CEQA’s requirement for meaningful disclosure and adequate
informational documents. A revised EIR must be prepared to include a finding of significance as
the EIR has not provided any meaningful evidence to support a less than significant finding.
5.0 Alternatives
The EIR is required to evaluate a reasonable range of alternatives to the proposed project which
will avoid or substantially lessen any of the significant effects of the project (CEQA § 15126.6.)
The alternatives chosen for analysis include the CEQA required “No Project/No Development”
alternative and only two others - Reduced Project Alternative and Inclusion of Commercial/Retail
Use Alternative. The EIR must be revised to include analysis of a reasonable range of alternatives
and foster informed decision making (CEQA § 15126.6). This should include alternatives such as
development of the site with a project that reduces all of the proposed project’s significant and
unavoidable impacts to a less than significant level, and a mixed-use project that provides
affordable housing and exclusively local-serving commercial uses that may reduce VMT, GHG
emissions, and simultaneously improve Air Quality.
6.1 Growth Inducement and 6.3 Significant and Irreversible Environmental Changes
A revised EIR must be prepared to include an accurate cumulative analysis discussion here to
demonstrate the impact of the proposed project in a cumulative setting. The EIR does not include
any information regarding the buildout conditions of the City’s General Plan in order to provide
an adequate and accurate environmental analysis. The EIR must be revised to provide the horizon
year of the City’s current adopted General Plan, the total developable building floor area analyzed
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within the Neo Industrial Employment and Industrial Employment District land use designations,
and cumulative development since adoption of the General Plan to ensure that the proposed project
is within the General Plan EIR’s analysis, particularly since the EIR tiers from the General Plan
EIR.
As noted throughout this comment letter, the project represents a significant amount of growth in
the City. SCAG ’s Connect SoCal Demographics and Growth Forecast33 notes that the City will
add 12,900 jobs from 2019 to 2035. Based on the EIR’s calculation of 1,408 jobs, the project
represents 10.9% of the City’s job growth over 16 years. A single project accounting for this
amount of the projected employment growth over 16 years represents a significant amount of
growth. The EIR has not provided a cumulative analysis discussion of projects approved since
2019 (SCAG), General Plan adoption, and/or projects “in the pipeline” to determine the City’s
progress towards SCAG ’s employment growth forecast or the General Plan buildout scenario. The
EIR also concludes that the project exceeds the growth projections of the RTP/SCS and does not
consider this information in this analysis. The EIR must be revised to include a finding of
significance.
For example, other recent industrial projects such as 9th and Vineyard34 (823 employees) and El
Camino Project35 (474 employees) combined with the proposed project will cumulatively generate
2,705 employees, which is 20.9% of the City’s employment growth forecast through 2035
accounted for only by three recent industrial projects. This total increases exponentially when other
industrial and commercial development activity is added to the calculation. A revised EIR must be
prepared to include this information for analysis, and also provide a cumulative analysis discussion
of projects approved since 2019 (SCAG), General Plan adoption, and projects “in the pipeline” to
determine the City’s cumulative progress towards employment/population growth forecasts by
SCAG and/or the General Plan. The EIR also concludes that the project exceeds the growth
33 SCAG Connect SoCal Demographics and Growth Forecast
https://www.scag.ca.gov/sites/default/files/2024-05/23-2987-tr-demographics-growth-forecast-final-
040424.pdf
34 9th and Vineyard Development Project https://ceqanet.opr.ca.gov/2019110456/4
35 El Camino Project https://ceqanet.lci.ca.gov/2023080369/4
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projections of the RTP/SCS and is inconsistent with PlanRC (General Plan) and does not consider
this information in this analysis. The EIR must be revised to include a finding of significance.
The EIR attempts to artificially skew the project’s significant growth inducing impacts downwards
in stating that, “According to the City ’s General Plan, approximately 35,000 new jobs are
anticipated to be created within the City through the 20-year planning horizon, or roughly through
2040 (City of Rancho Cucamonga 2021). When considering the number of new jobs associated
with the proposed project, it would account for 5 percent of the City ’s projected job growth over
the next 20 years.” A single project accounting for 5% of the entire City’s job growth over a 20
year period is a significant amount of growth. The EIR excludes analyzing the project within its
specific land use context of the EIR and generalizes the growth across the entire City buildout
scenario. The project site is located within Focus Area 8: Southeast Industrial Area of the General
Plan EIR36. Table 5.14-6: Buildout Projections From Proposed Land Use Plan of the General Plan
EIR demonstrates that the City will add 5,122 jobs in Industrial land use designations from 2020-
2040. Table 1-1: Land Use Development Projections By Focus Area and Remainder of City for
Buildout demonstrates that the Remainder of the City (includes Focus Area 8: Southeast Industrial
Area) will add 4,927 jobs from 2020-2040. The EIR’s calculation of the project’s 1,408 new jobs
accounts for 27.4% of all jobs in the Remainder of the City. A single project accounting for this
amount of the projected employment growth over 20 years represents a significant amount of
growth. The proposed project represents a significant amount of employment growth for the entire
City and Focus Area 8 accounted for by the General Plan EIR. A revised EIR must be prepared to
provide this information for analysis and include a finding of significance because the project
would directly induce substantial unplanned growth in an area.
The EIR states that, “…while the project would create economic opportunities by introducing new
job opportunities to the project site, it is anticipated that the employment base for the operational
phase of the project would come from the existing population within the City and surrounding
area. As such, because it is anticipated that most of the future employees of the proposed project
would already be living in the City or in nearby areas, introduction of new employment
36 https://www.cityofrc.us/sites/default/files/2021-
09/City%20of%20Rancho%20Cucamonga_GP%20Update%20and%20CAP_Draft%20EIR_September%
202021.pdf
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opportunities by the proposed project on the project site would not induce substantial unplanned
growth in the area,” and concludes impacts are less than significant. This conclusion directly
contradicts other significant and unavoidable impacts in the EIR. The EIR concludes that the
project exceeds the growth projections of the RTP/SCS and is inconsistent with PlanRC (General
Plan) and does not consider this information in this analysis. The EIR also concludes that the
project-generated baseline and future year VMT for employees will exceed the applicable
thresholds, resulting in significant and unavoidable cumulatively considerable impacts to VMT.
The EIR does not define the geographic boundaries of the, “surrounding area,” or “nearby areas,”
but the SU VMT impacts indicate that project employees will commute from further distances than
existing employees in the City. The EIR also has not presented any substantial evidence that the
City’s unemployed workforce or that of the surrounding/nearby areas are qualified or interested in
work in the industrial sector. The EIR has not provided any substantial evidence to support a less
than significant finding and a finding of significance must be included in a revised EIR.
The EIR also utilizes language that is misleading to the public and decision makers in stating that,
“…direct economic growth associated with implementation of the proposed project would be
aligned with the City ’s General Plan and would not result in significant long-term physical
environmental effects.” The term “aligned” was chosen carefully to evoke a connotation that the
project is consistent with the General Plan and SCAG growth forecasts. However, as discussed
above, the project represents a significant amount of growth in the City and an accurate buildout
scenario analysis has not been provided. The EIR concludes that the project exceeds the growth
projections of the RTP/SCS and does not consider this information in this analysis. This misleading
language must be removed in a revised EIR and replaced with discussion of the project’s true
growth-inducing impacts and a finding of significance.
Further, the EIR does not address that the project is not a permitted use within the Neo-Industrial
Employment District of the General Plan. The General Plan states that in the Neo-Industrial land
use designation, “More intensive industrial uses with substantive impacts on adjacent uses are not
permitted;” and that, “Low impact industrial uses, such as incubator spaces and small warehouses,
that are context-sensitive and calibrated to minimize impacts to adjacent residential uses are
preferred.” The Industrial Employment District of the General Plan permits uses that are, “a broad
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November 13, 2025
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range of light and medium industrial uses, including light industrial research parks, logistics
centers, low impact manufacturing, and machining operations.”
The EIR states that, “The proposed industrial distribution facilities, including high-cube fulfillment
center (non-sorting), general warehouse, high-cube cold storage warehouse, and accessory office
space, are allowable uses within these land use designations.” Distribution centers and warehouses
are a component of the overall logistics center business chain. Logistics facilitates the overall
movement of goods within supply chain management (upstream, downstream, raw materials,
finished products, etc.). Distribution is a point on the logistics center business chain as the
movement of finished gods for final delivery to the end consumer at their home or commercial
stores. Overall, distribution centers are logistics centers and a component of the overall logistics
process. Therefore, the proposed project is not permitted within the existing Neo-Industrial
Employment District land use designation because it is not a small warehouse and it is not context-
sensitive or calibrated to minimize impacts. The project requests a Zoning Map Amendment to be
located within the Large Warehouse Overlay, which clearly indicates that it is not a small
warehouse. The EIR concludes the project will result in significant and unavoidable cumulatively
considerable impacts to Air Quality and VMT, indicating that it is an intense industrial use with
substantive impacts on adjacent uses. The proposed distribution center use is clearly permitted and
intended to be located within the Industrial Employment District as it expressly lists logistics
centers as a permitted use. A finding of significance must be included as part of a revised EIR due
to this inconsistency.
The EIR states that, “the project would be subject to the energy conservation requirements of the
California Energy Code (Title 24, Part 6, of the California Code of Regulations, California’s
Energy Efficiency Standards for Residential and Nonresidential Buildings) and the California
Green Building Standards Code (Title 24, Part 11 of the California Code of Regulations). The
California Energy Code provides energy conservation standards for all new and renovated
nonresidential buildings constructed in California, and the Green Building Standards Code
requires solar access, natural ventilation, and stormwater capture.” The State of California lists
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November 13, 2025
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three approved compliance modeling softwares37 for non-residential buildings: CBECC-Com,
EnergyPro, and IES VE. CalEEMod and EMFAC are not listed as approved softwares. The
CalEEMod and spreadsheet-based modeling in Appendix B does not comply with the 2022
Building Energy Efficiency Standards and under-reports the project ’s significant Energy impacts
and fuel consumption to the public and decision makers. If the project applies for a building permit
on or after January 1, 2026, it must comply with the 2025 Building Energy Efficiency Standards,
and only CBECC is currently listed as an approved software for the updated standards38. Since the
EIR did not accurately or adequately model the energy impacts in compliance with Title 24, it
cannot conclude the project will generate less than significant impacts and a finding of significance
must be made in a revised EIR.
Conclusion
For the foregoing reasons, GSEJA believes the EIR is flawed and a revised EIR must be prepared
for the proposed project and recirculated for public review. Golden State Environmental Justice
Alliance requests to be added to the public interest list regarding any subsequent environmental
documents, public notices, public hearings, and notices of determination for this project. Send all
communications to Golden State Environmental Justice Alliance P.O. Box 79222 Corona, CA
92877.
Sincerely,
Vashon Simien
Blum, Collins & Ho, LLP
37 California Energy Commission 2022 Energy Code Compliance Software
https://www.energy.ca.gov/programs-and-topics/programs/building-energy-efficiency-standards/2022-
building-energy-efficiency-1
38 California Energy Commission 2025 Energy Code Compliance Software
https://www.energy.ca.gov/programs-and-topics/programs/building-energy-efficiency-standards/2025-
energy-code-compliance-software
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November 13, 2025
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Attachments:
1. SWAPE Technical Analysis
2656 29th Street, Suite 201
Santa Monica, CA 90405
Matt Hagemann, P.G, C.Hg.
(949) 887-9013
mhagemann@swape.com
November 10, 2025
Gary Ho
Blum, Collins & Ho LLP
10250 Constellation Boulevard, Ste. 2300
Los Angeles, CA 90067
Subject: Comments on the Arrow Commerce Center Project (SCH No. 2023110033)
Dear Mr. Ho,
We have reviewed the October 2025 Draft Environmental Impact Report (“DEIR”) for the Arrow
Commerce Center (“Project”) located in the City of Rancho Cucamonga (“City”). The Project proposes to
construct 1,830,729-square-feet (“SF”) of warehouse and office space and 968 parking spaces on the 94-
acre site.
Our review concludes that the DEIR fails to adequately evaluate the Project’s air quality and health risk
impacts. As a result, emissions and health risk impacts associated with construction and operation of the
proposed Project may be underestimated and inadequately addressed. A revised Environmental Impact
Report (“EIR”) should be prepared to adequately assess and mitigate the potential air quality and health
risk impacts that the project may have on the environment.
Air Quality Unsubstantiated Input Parameters Used to Estimate Project Emissions
When reviewing the Project’s CalEEMod output files, provided in the Air Quality, Greenhouse Gas
Emissions, and Health Risk Assessment Modeling Results (“AQ Report”) provided as Appendix B to the
DEIR, we identified several model inputs related to Project construction and operation that are
inconsistent with information disclosed in the DEIR. The impacts of these changes are quantified in the
section of this letter titled “Updated Analysis Indicates a Potentially Significant Air Quality Impact." A
revised EIR should be prepared to include an updated air quality analysis that provides a more detailed
evaluation of the impact Project construction and operation may have on local and regional air quality.
Failure to Include Parking Land Use
The DEIR proposes to construct 968 vehicle parking spaces and 444 truck trailer parking spaces, stating:
2
“The project also includes loading docks for truck trailers, 968 vehicle parking spaces, 444 truck
trailer parking spaces, 6 new public streets, water quality basins, utility infrastructure, and
exterior lighting and signage. The proposed project would develop the project site with 44 acres
of paved or other impervious surface area and provide approximately 10 percent landscape
coverage” (p. ES-2).
Review of the CalEEMod output files demonstrates that the “Rancho Arrow Route Construction Detailed
Report” model does not include any parking lot space (see screenshot below) (Appendix B, pp. 24, 25).
However, further review of the CalEEMod output files demonstrates that the “Arrow Commerce Center
Detailed Report” operational model includes 44 acres of parking lot space (see screenshot below)
(Appendix B, pp. 77, 78).
The “Rancho Arrow Route Construction Detailed Report” construction model therefore underestimates
the proposed parking lot space by 44 acres. This underestimation presents an issue, as the land use size
feature is used throughout CalEEMod to determine default variable and emission factors that affect the
model’s construction calculations.1 By underestimating the size of the proposed mixed-use space, the
model underestimates the Project’s construction emissions and should not be relied upon to determine
Project significance.
Underestimated Number of Demolition Hauling Trips
The DEIR indicates that the Project “includes the demolition and site clearing of existing paved surface
areas” (p. ES-2). Review of the CalEEMod output files demonstrates that the “Rancho Arrow Route
Construction Detailed Report” model includes 555,664-SF of tons of demolition debris (see screenshot
below) (Appendix B, pp. 62).
1 “CalEEMod User Guide.” CAPCOA, April 2022, available at: https://www.caleemod.com/documents/user-
guide/01_User%20Guide.pdf, p. 19.
3
However, further review of the model demonstrates that there are zero hauling trips for the
construction demolition phase (see screenshot below) (Appendix B, pp. 60).
Note: the above screenshot does not capture the entire table.
This is incorrect, as according to the CalEEMod User’s Guide:
“Hauling trips are based on the amount of material that is demolished (as defined in the
Demolition screen) or imported or exported (as defined in the Dust from Material Movement
screen) assuming a truck can handle 16 cubic yards of material.”2
Therefore, CalEEMod calculates a default number of hauling trips based upon the amount of demolition
material inputted into the model. As the model includes only zero demolition hauling trips, we can
assume that the default number of hauling trips was erroneously changed from the default calculation
to zero. As such, the model fails to adequately account for the demolition inputted into the model and
required for Project construction.
This omission presents an issue, as CalEEMod uses the number of hauling trips to estimate construction-
related emissions associated with on-road vehicles and truck traffic.3 By excluding the hauling trips
required for demolition, the model underestimates the Project’s construction-related emissions and
should not be relied upon to determine Project significance.
Incorrect Application of Construction Engine Tier 4 Final Mitigation
The “Rancho Arrow Route Construction Detailed Report” model includes the following construction
mitigation measure (see screenshot below) (Appendix B, pp. 25).
2 CalEEMod User Guide.” CalEEMod 2022.1, April 2022, available at: https://www.caleemod.com/documents/user-
guide/CalEEMod_User_Guide_v2022.1.pdf, p. C-19.
3 CalEEMod User Guide.” CalEEMod 2022.1, April 2022, available at: https://www.caleemod.com/documents/user-
guide/CalEEMod_User_Guide_v2022.1.pdf, p. 36.
4
Accordingly, the “Rancho Arrow Route Construction Detailed Report” model also includes changes to
the off-road construction equipment input parameters and assumes that the Project’s off-road
equipment fleet would meet Tier 4 Final emissions standards (see screenshot below) (Appendix B, pp.
58, 59).
Regarding the use of advanced engine tiers, the DEIR includes the following construction equipment list
(see excerpt below) (p. 3.2-17).
5
However, the inclusion of more stringent emissions standards remains unsupported as the DEIR does
not explicitly require advanced engine tiers, specifically Tier 4 Final, through a formal mitigation
measure. According to the Association of Environmental Professionals (“AEP”) CEQA Portal Topic Paper
on mitigation measures:
“While not ‘mitigation’, a good practice is to include those project design feature(s) that address
environmental impacts in the mitigation monitoring and reporting program (MMRP). Often the
MMRP is all that accompanies building and construction plans through the permit process. If the
design features are not listed as important to addressing an environmental impact, it is easy for
someone not involved in the original environmental process to approve a change to the project
that could eliminate one or more of the design features without understanding the resulting
environmental impact.”4
As the inclusion of Tier 4 Final emissions standards on the Project site is not formally included as a
mitigation measure, we cannot guarantee that it would be implemented, monitored, and enforced on
the Project site. By including Tier 4 Final emissions standards without properly committing to its
implementation, the model may underestimate the Project’s construction emissions and should not be
relied upon to determine Project significance. Updated Analysis Indicates a Potentially Significant Air Quality Impact
To more accurately estimate the Project’s construction-related emissions, we prepared a construction
CalEEMod model, using the Project-specific information provided by the DEIR. We included the parking
land use, omitted the reduction to demolition hauling trips, and excluded the construction-related
mitigation and incorrect application of Tier 4 Final emissions standards. All other inputs remain
consistent with the DEIR’s model.
Our updated analysis estimates that the Project’s construction-related volatile organic compounds
(“VOC”) emissions exceed the South Coast Air Quality Management District (“SCAQMD”) daily threshold
of 75 pounds per day (“lbs/day”) (see table below).
4 “CEQA Portal Topic Paper Mitigation Measures.” AEP, February 2020, available at:
https://ceqaportal.org/tp/CEQA%20Mitigation%202020.pdf, p. 6.
6
SWAPE Criteria Air Pollutant Emissions Estimates
Construction VOC
(lbs/day)
DEIR 31
SWAPE 320
SCAQMD Threshold 75
Exceeds? Yes
According to our analysis, the construction-related VOC emissions are estimated to be approximately
320 lbs/day, exceeding the SCAQMD daily threshold. This finding indicates a potentially significant air
quality impact that the DEIR did not identify or address. In our opinion, a revised EIR should be
conducted to provide a more accurate evaluation of the potential air quality impact from the Project on
the environment and mitigate significant impacts accordingly. Failure to Implement All Feasible Mitigation to Reduce Emissions
The DEIR estimates that the Project’s operational VOC emissions would exceed the applicable SCAQMD
threshold (see screenshot below) (p. 3.2-32, Table 3.2-14).
The DEIR concludes that the impacts associated with operation of the Project would be significant-and-
unavoidable, stating:
“After the implementation of Mitigation Measure 3.2-2b, through 3.2-2d, VOC emissions would
not be reduced to below thresholds, but NOx and CO emissions would be reduced below the
7
thresholds with mitigation (Table 3.2 - 14). Therefore, even with implementation of mitigation,
operational impact s related to VOC emissions would be significant and unavoidable” (p. 3.2-32).
While we agree that the Project would result in significant air quality impacts, the DEIR’s assertion that
this impact is significant-and-unavoidable is unreliable. According to CEQA Guidelines §15096(g)(2):
“When an updated EIR has been prepared for a project, the Responsible Agency shall not
approve the project as proposed if the agency finds any feasible alternative or feasible
mitigation measures within its powers that would substantially lessen or avoid any significant
effect the project would have on the environment.”5
As such, the DEIR is required under CEQA to implement all feasible mitigation to reduce impacts to a
less-than-significant level. To reduce the Project’s air quality impacts to the maximum extent possible,
additional feasible mitigation measures should be incorporated, such as those suggested in the section
of this letter titled “Feasible Mitigation Measures Available to Reduce Emissions.” The Project should not
be approved until a revised EIR is prepared, incorporating all feasible mitigation to reduce emissions to
the maximum extent possible. Disproportionate Health Risk Impacts of Warehouses on Surrounding Communities
The development of the proposed Project may contribute to the disproportionate health risk impact
that warehouses already pose on community members living, working, and going to school within the
immediate area of the Project site. According to the SCAQMD, communities of color living within a half
mile of warehouses face higher health risks, including increased rates of asthma and heart attacks, along
with a greater environmental burden.6
Specifically, the SCAQMD found that more than 2.4 million people live within a half mile radius of at
least one warehouse, and that those areas not only experience increased rates of asthma and heart
attacks, but are also disproportionately Black and Latino communities below the poverty line.7 Another
study indicates “neighborhoods with lower household income levels and higher percentages of
minorities are expected to have higher probabilities of containing warehousing facilities.”8 Furthermore,
a report authored by the Inland Empire-based People’s Collective for Environmental Justice and
5 “Cal. Code Regs. tit. 14 § 15096.” California Legislature, available at: https://casetext.com/regulation/california-
code-of-regulations/title-14-natural-resources/division-6-resources-agency/chapter-3-guidelines-for-
implementation-of-the-california-environmental-quality-act/article-7-eir-process/section-15096-process-for-a-
responsible-agency.
6 “South Coast AQMD Governing Board Adopts Warehouse Indirect Source Rule.” SCAQMD, May 2021, available
at: http://www.aqmd.gov/docs/default-source/news-archive/2021/board-adopts-waisr-may7-2021.pdf?sfvrsn=9.
7 “Southern California warehouse boom a huge source of pollution. Regulators are fighting back.” Los Angeles
Times, May 2021, available at: https://www.latimes.com/california/story/2021-05-05/air-quality-officials-target-
warehouses-bid-to-curb-health-damaging-truck-pollution.
8 “Location of warehouses and environmental justice: Evidence from four metros in California.” Metro Freight
Center of Excellence, January 2018, available at:
https://www.metrans.org/assets/research/MF%201.1g_Location%20of%20warehouses%20and%20environmental
%20justice_Final%20Report_021618.pdf, p. 21.
8
University of Redlands explains that the warehouse and logistics industry is expanding rapidly, with
many new projects being built in low-income communities of color. These projects attract high volumes
of polluting truck traffic, which emits harmful nitrogen oxide and particulate matter, contributing to
severe health issues like asthma, COPD, cancer, and premature death.9 Despite these public health
impacts, warehouse development continues to accelerate, with the Inland Empire adding 10 to 25
million square feet of new industrial space annually.10
The Data Visualization Tool for Mates V, a monitoring and evaluation study conducted by SCAQMD,
demonstrates that the County already exhibits a heightened residential carcinogenic risk from exposure
to air toxics.11 Specifically, the location of the Project site is in the 92nd percentile of highest cancer risks
in the South Coast Air Basin (“SCAB”), with a cancer risk of 785 in one million (see screenshot below).12
9 “Warehouses, Pollution, and Social Disparities: An analytical view of the logistics industry’s impacts
on environmental justice communities across Southern California.” People’s Collective for Environmental Justice,
April 2021, available at:
https://earthjustice.org/sites/default/files/files/warehouse_research_report_4.15.2021.pdf, p. 4.
10 “2020 North America Industrial Big Box Review & Outlook.” CBRE, 2020, available at: https://www.cbre.com/-
/media/project/cbre/shared-site/insights/local-responses/industrial-big-box-report-inland-empire/local-response-
2020-ibb-inland-empire-overview.pdf, p. 2.
11 “Residential Air Toxics Cancer Risk Calculated from Model Data in Grid Cells.” MATES V, 2018, available at:
https://experience.arcgis.com/experience/79d3b6304912414bb21ebdde80100b23/page/Main-Page/?views=Click-
tabs-for-other-data%2CGridded-Cancer-Risk; see also: “MATES V Multiple Air Toxics Exposure Study.” SCAQMD,
available at: http://www.aqmd.gov/home/air-quality/air-quality-studies/health-studies/mates-v.
12 “Gridded Cancer Risk.” SCAQMD, available at:
https://experience.arcgis.com/experience/79d3b6304912414bb21ebdde80100b23/page/Main-
Page/?data_id=dataSource_112-7c8f2a4db79b4a918d46b4e8985a112b%3A20315&views=Click-tabs-for-other-
data%2CGridded-Cancer-Risk.
9
Additionally, according to CalEnviroScreen’s Senate Bill (“SB”) 535 Disadvantaged Communities Map, the
Project site is identified as a designated disadvantaged community (see screenshot below).13
SB 535 provides funding for development projects that provide a benefit to disadvantaged communities.
CalEPA has been given the responsibility for identifying those communities based on “geographic,
socioeconomic, public health, and environmental hazard criteria.”14 The Project may therefore worsen
disproportionate health risks for community members within the immediate area, a concern
underscored by the mandates of SB 1000. SB 1000, enacted to address environmental justice concerns,
requires local governments to integrate environmental justice elements into their planning processes,
particularly focusing on reducing health risks for disadvantaged communities.15 As the DEIR indicates
that the proposed Project site is located approximately 0.4 miles from residential receptors (p. 3.2-20),
the Project should comply with the objectives of SB 1000.
In accordance with the California Department of Justice (“CA DOJ”) guidelines, the effects of greenhouse
gas emissions and air pollutants from warehouses should be evaluated cumulatively. The CA DOJ states
that cumulative impacts should be evaluated by considering the project's incremental effects alongside
past, present, and future projects, even if the project alone does not exceed significance
13 “SB 535 Disadvantaged Communities (2022 Update).” California Environmental Protection Agency, available at:
https://experience.arcgis.com/experience/1c21c53da8de48f1b946f3402fbae55c/page/SB-535-Disadvantaged-
Communities/
14 “Final Designation of Disadvantaged Communities.” CalEPA, available at: https://calepa.ca.gov/wp-
content/uploads/2022/05/Updated-Disadvantaged-Communities-Designation-DAC-May-2022-Eng.a.hp_-1.pdf, p.
1.
15 “Environmental Justice in Local Land Use Planning.” CA DOJ, available at:
https://oag.ca.gov/environment/sb1000.
10
thresholds.16 To more adequately assess the Project’s impact on disadvantaged communities, both
existing and future warehouse developments should be considered during the environmental review
process.
As the Project site is in an SB 535 disadvantaged community that experiences disproportionately high
levels of pollution, we recommend the DEIR reevaluate the Project's cumulative health risks to more
sufficiently align with CA DOJ guidelines and SB 1000 environmental justice requirements.
Lastly, the Warehouse Cumulative Impact Tool for Community dashboard (“Warehouse CITY”),
developed by the Redford Conservancy at Pitzer College and Radical Research LLC, is a tool that
visualizes and quantifies existing, potential, and approved warehouse locations across Southern
California. Review of Warehouse CITY reveals that there are 252 existing warehouses currently in
Rancho Cu, 2 more that have been approved, and 5 that are currently under CEQA review (see
screenshot below).17
The presence of numerous existing warehouses in the City underscores the need to reassess the
Project's cumulative health risks pursuant to CA DOJ guidelines and SB 1000 environmental justice
requirements. Diesel Particulate Matter Emissions Inadequately Evaluated
The DEIR concludes that the proposed Project would result in a less-than-significant health risk impact
based on a quantified operational health risk assessment (“HRA”). Specifically, the DEIR estimates that
16 “Warehouse Projects: Best Practices and Mitigation Measures to Comply with the California Environmental
Quality Act.” CA DOJ, available at: https://oag.ca.gov/sites/all/files/agweb/pdfs/environment/warehouse-best-
practices.pdf, p. 6.
17 “Warehouse and Air Quality Mapping.” Pitzer College & Radical Research LLC, available at:
https://radicalresearch.shinyapps.io/WarehouseCITY/.
11
the maximum incremental cancer risk posed to nearby, existing residential sensitive receptors
associated with exposure to diesel particulate matter (“DPM”) emissions during Project operation would
be 2-in one million after mitigation, which would not exceed the SCAQMD significance threshold of 10 in
one million (see excerpt below) (p. 3.2-35, Table 3.2-18).
However, the DEIR’s evaluation of the Project’s potential health risk impacts, as well as the subsequent
less-than-significant impact conclusion, is insufficient for three reasons.
First, the DEIR’s operational HRA underestimates Fraction of Time At Home ("FAH") values for third
trimester, infant, and child receptors. It uses an FAH value of 0.85 for third trimester (age -0.25 to 0) and
infant (age 0 to 2) receptors, and 0.72 for child receptors (age 2 to 16) (see excerpt below) (p. 3.2-23,
Table 3.2-9).
12
The FAH values for third trimester, infant, and child receptors in the HRA are incorrect. SCAQMD
guidance states that for screening purposes, “the FAH is set to 1 for individuals from the third trimester
to age 16, assuming children stay near home for school or daycare with no time discount.”18 Per
SCAQMD guidance, the HRA Report should have followed this guidance and used an FAH of 1 for third
trimester, infant, and child receptors. By using unsupported FAH values, the DEIR may underestimate
the cancer risk to nearby sensitive receptors from Project operation.
Second, by failing to prepare a quantified construction HRA, the DEIR is inconsistent with CEQA’s
requirement to correlate the increase in emissions generated by the Project to the adverse impacts on
human health caused by those emissions. Under CEQA, agencies must make a “reasonable effort to
substantively connect a project’s air quality impacts to likely health consequences.”19 The DEIR also fails
to align with the CA DOJ guidelines for warehouse best practices, which recommends that all potential
warehouse projects prepare a quantitative HRA in accordance with the Office of Environmental Health
Hazard Assessment (“OEHHA”), the organization responsible for providing guidance on conducting HRAs
in California.20 To comply with these requirements, an HRA should have been prepared to assess the
potential health risks to nearby sensitive receptors from DPM emissions generated during both
construction and operation.
Third, while the DEIR includes an HRA evaluating the health risk impacts to nearby, existing receptors as
a result of Project operation, the DEIR fails to evaluate the combined lifetime cancer risk to nearby
receptors as a result of Project construction and operation together. This is incorrect and, as a result, the
DEIR’s evaluation cannot be relied upon to determine Project significance. According to OEHHA
guidance, “the excess cancer risk is calculated separately for each age grouping and then summed to
yield cancer risk at the receptor location.”21 The DEIR should have quantified the Project’s construction
and operational health risks, as well as compared the combined construction and operational cancer risk
to the SCAQMD threshold of 10 in one million.
Mitigation Feasible Mitigation Measures Available to Reduce Emissions
The DEIR is required under CEQA to implement all feasible mitigation to reduce the Project’s potential
impacts. As demonstrated above, the Project would result in potentially significant air quality impact
that should be mitigated further.
18 “Risk Assessment Procedures.” SCAQMD, August 2017, available at: http://www.aqmd.gov/docs/default-
source/rule-book/Proposed-Rules/1401/riskassessmentprocedures_2017_080717.pdf, p. 7.
19 “Sierra Club v. County of Fresno.” Supreme Court of California, December 2018, available at:
https://law.justia.com/cases/california/supreme-court/2018/s219783a.html
20 “Warehouse Projects: Best Practices and Mitigation Measures to Comply with the California Environmental
Quality Act.” CA DOJ, available at: https://oag.ca.gov/sites/all/files/agweb/pdfs/environment/warehouse-best-
practices.pdf, p. 6.
21 “Guidance Manual for preparation of Health Risk Assessments.” OEHHA, February 2015,available at:
https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf p. 8-4.
13
To reduce the VOC emissions associated with Project construction and operation, we recommend the
DEIR consider incorporating the following mitigation measures:22
• Recycle leftover paint. Take any leftover paint to a hazardous waste center; do not mix leftover
water-based and oil-based paints.
• Keep lids closed on all paint containers when not in use to prevent VOC emissions and excessive
odors.
• For water-based paints, clean up with water only. Whenever possible, do not rinse the cleanup
water down the drain or pour it directly into the ground or the storm drain
• Use compliant low-VOC cleaning solvents to clean paint application equipment.
• Keep all paint- and solvent-laden rags in sealed containers to prevent VOC emissions.
• Contractors shall construct/build with materials that do not require painting and use pre-
painted construction materials to the extent practicable.
• Use high-pressure/low-volume paint applicators with a minimum transfer efficiency of at least
50 percent or other application techniques with equivalent or higher transfer efficiency.
The United States Environmental Protection Agency recommends conducting calculations for coverage
area and thinning ratios prior to purchasing paints. By applying these calculations, the appropriate
quantity of paint can be acquired, thereby helping to minimize waste and optimize resource use.23
To reduce construction VOC emissions, the California Department of Public Health (“CDPH”)
recommends the use of:24
• Natural materials such as solid wood products (e.g., hard wood flooring and wood paneling),
natural stone (e.g., granite and marble), ceramic tile, and glass.
• Composite wood products that comply with the California Air Resources Board's (“CARB”)
Airborne Toxic Control Measure for formaldehyde.
• Interior paints, coatings, adhesives, and sealants that comply with South Coast AQMD Rule 1168
or CARB’s Suggested Control Measure for Architectural Coatings.
• Flooring materials that are certified as low emitting under the CDPH Standard Method v1.2 or
equivalent.
• Sealer on the surface of spray-on fireproofing to reduce adsorption of VOCs using a low-VOC
sealer, if necessary.
22 “Banning Commerce Center Project.” Kimley-Horn and Associates, Inc., June 2024, available at:
https://ceqanet.opr.ca.gov/2022090102/2; Draft Environmental Impact Report, p. 1-7.
23 “Industrial Surface Coating.” Emissions Inventory Improvement Program, September 1997, available at:
https://www.epa.gov/sites/default/files/2015-08/documents/iii08.pdf, Volume III, Chapter 8, p. 8.3-1.
24 “Reducing occupant exposure to volatile organic compounds (VOCs) from indoor sources: Guidelines for building
occupants.” California Department of Public Health, July 1996, available at:
https://www.cdph.ca.gov/Programs/CCDPHP/DEODC/EHLB/IAQ/CDPH%20Document%20Library/reducing_occupa
nt_exposure_vocs_guidelines_ADA.pdf.
14
An additional mitigation measure that may reduce the impact from operational ROG/VOC emissions is
to implement a mechanical ventilation system meeting ASHRAE Standards 62.1 and 62.2. 25 HVAC
systems should include MERV 13 or higher filters to reduce indoor pollutant exposure. Prior to
occupancy, the building should undergo a flush-out period with HVAC systems operating at full capacity
for at least 48 hours to remove residual VOCs and improve indoor air quality.
Provided above are several mitigation measures that would reduce Project-related VOC emissions.
These measures offer a cost-effective, feasible way to incorporate lower-emitting design features into
the proposed Project, which subsequently reduces emissions released during Project construction and
operation.
A revised EIR should be prepared that includes all feasible mitigation measures, as well as an updated air
quality analysis to ensure that the necessary mitigation measures are implemented to reduce emissions
to the maximum extent feasible. The revised EIR should also demonstrate a commitment to the
implementation of these measures prior to Project approval, to ensure that the Project’s potentially
significant emissions are reduced to the maximum extent possible.
Disclaimer
SWAPE has received limited documentation regarding this project. Additional information may become
available in the future; thus, we retain the right to revise or amend this report when additional
information becomes available. Our professional services have been performed using that degree of
care and skill ordinarily exercised, under similar circumstances, by reputable environmental consultants
practicing in this or similar localities at the time of service. No other warranty, expressed or implied, is
made as to the scope of work, work methodologies and protocols, site conditions, analytical testing
results, and findings presented. This report reflects efforts which were limited to information that was
reasonably accessible at the time of the work, and may contain informational gaps, inconsistencies, or
otherwise be incomplete due to the unavailability or uncertainty of information obtained or provided by
third parties.
Sincerely,
Matt Hagemann, P.G., C.Hg.
Paul E. Rosenfeld, Ph.D.
25 Ibid., p. xii.
Attachment A: CalEEMod Output FilesAttachment B: Matt Hagemann CVAttachment C: Paul Rosenfeld CV
Arrow Commerce Center Detailed Report, 11/7/2025
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Arrow Commerce Center 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
3. Construction Emissions Details
3.1. Demolition (2026) - Unmitigated
3.3. Grading (2026) - Unmitigated
3.5. Building Construction (2026) - Unmitigated
3.7. Building Construction (2027) - Unmitigated
3.9. Concrete Imports (2026) - Unmitigated
3.11. Paving (2027) - Unmitigated
3.13. Architectural Coating (2027) - Unmitigated
Attachment A
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4. Operations Emissions Details
4.10. Soil Carbon Accumulation By Vegetation Type
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
5. Activity Data
5.1. Construction Schedule
5.2. Off-Road Equipment
5.2.1. Unmitigated
5.3. Construction Vehicles
5.3.1. Unmitigated
5.4. Vehicles
5.4.1. Construction Vehicle Control Strategies
5.5. Architectural Coatings
5.6. Dust Mitigation
5.6.1. Construction Earthmoving Activities
5.6.2. Construction Earthmoving Control Strategies
5.7. Construction Paving
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5.8. Construction Electricity Consumption and Emissions Factors
5.18. Vegetation
5.18.1. Land Use Change
5.18.1.1. Unmitigated
5.18.1. Biomass Cover Type
5.18.1.1. Unmitigated
5.18.2. Sequestration
5.18.2.1. Unmitigated
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
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7.5. Evaluation Scorecard
7.6. Health & Equity Custom Measures
8. User Changes to Default Data
8.1. Justifications
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1. Basic Project Information
1.1. Basic Project Information
Data Field Value
Project Name Arrow Commerce Center
Construction Start Date 1/5/2026
Lead Agency —
Land Use Scale Project/site
Analysis Level for Defaults County
Windspeed (m/s)2.8
Precipitation (days)6.4
Location 12541 Arrow Route, Rancho Cucamonga, CA 91739, USA
County San Bernardino-South Coast
City Rancho Cucamonga
Air District South Coast AQMD
Air Basin South Coast
TAZ 5283
EDFZ 10
Electric Utility Southern California Edison
Gas Utility Southern California Gas
App Version 2022.1.1.31
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
Unrefrigerated
Warehouse-No Rail
1,561 1000sqft 36 1,561,256 275,585 ———
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———39,746173,0004.01000sqft173Refrigerated
Warehouse-No Rail
General Office
Building
96 1000sqft 2.2 96,000 37,431 ———
Parking Lot 44 Acre 44 0.00 0.00 ———
1.3. User-Selected Emission Reduction Measures by Emissions Sector
No measures selected
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 BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,
Summer
(Max)
——————————————————
Unmit.320 320 23 73 0.09 0.51 12 13 0.48 3.0 3.5 —21,974 21,974 1.2 1.8 60 22,595
Daily,
Winter
(Max)
——————————————————
Unmit.320 320 80 106 0.27 2.3 45 47 2.1 9.9 12 —39,824 39,824 3.0 4.3 3.1 40,935
Average
Daily
(Max)
——————————————————
Unmit.50 50 21 47 0.08 0.49 11 12 0.46 2.8 3.2 —16,958 16,958 0.80 1.5 19 17,447
Annual
(Max)
——————————————————
Unmit.9.1 9.1 3.9 8.5 0.01 0.09 2.1 2.2 0.08 0.50 0.59 —2,808 2,808 0.13 0.25 3.2 2,889
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)
Arrow Commerce Center Detailed Report, 11/7/2025
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Year TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily -
Summer
(Max)
——————————————————
2026 5.8 4.5 23 73 0.09 0.51 12 13 0.48 3.0 3.5 —21,974 21,974 1.2 1.8 60 22,595
2027 320 320 21 69 0.09 0.47 12 13 0.44 3.0 3.5 —21,593 21,593 0.85 1.7 54 22,179
Daily -
Winter
(Max)
——————————————————
2026 10.0 7.5 80 106 0.27 2.3 45 47 2.1 9.9 12 —39,824 39,824 3.0 4.3 3.1 40,935
2027 320 320 22 56 0.09 0.47 12 13 0.44 3.0 3.5 —20,749 20,749 0.87 1.7 1.4 21,283
Average
Daily
——————————————————
2026 4.5 3.3 21 47 0.08 0.49 11 12 0.46 2.8 3.2 —16,958 16,958 0.80 1.5 19 17,447
2027 50 50 7.0 19 0.02 0.16 3.7 3.9 0.15 0.90 1.1 —6,041 6,041 0.23 0.45 6.6 6,188
Annual ——————————————————
2026 0.82 0.61 3.9 8.5 0.01 0.09 2.1 2.2 0.08 0.50 0.59 —2,808 2,808 0.13 0.25 3.2 2,889
2027 9.1 9.1 1.3 3.4 < 0.005 0.03 0.68 0.71 0.03 0.16 0.19 —1,000 1,000 0.04 0.07 1.1 1,024
3. Construction Emissions Details
3.1. Demolition (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 BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Daily,
Winter
(Max)
——————————————————
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Off-Roa
Equipment
2.7 2.3 21 19 0.03 0.84 —0.84 0.78 —0.78 —3,427 3,427 0.14 0.03 —3,438
Demoliti
on
——————28 28 —4.2 4.2 ———————
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
——————————————————
Off-Roa
d
Equipm
ent
0.15 0.13 1.1 1.0 < 0.005 0.05 —0.05 0.04 —0.04 —188 188 0.01 < 0.005 —188
Demoliti
on
——————1.5 1.5 —0.23 0.23 ———————
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 ——————————————————
Off-Roa
d
Equipm
ent
0.03 0.02 0.21 0.19 < 0.005 0.01 —0.01 0.01 —0.01 —31 31 < 0.005 < 0.005 —31
Demoliti
on
——————0.28 0.28 —0.04 0.04 ———————
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 0.07 0.06 0.07 0.82 0.00 0.00 0.20 0.20 0.00 0.05 0.05 —190 190 < 0.005 0.01 0.02 192
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 2.6 0.31 27 15 0.15 0.28 5.9 6.2 0.28 1.6 1.9 —21,702 21,702 2.2 3.5 1.1 22,793
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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 —11 11 < 0.005 < 0.005 0.02 11
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 0.15 0.02 1.5 0.80 0.01 0.02 0.32 0.34 0.02 0.09 0.10 —1,189 1,189 0.12 0.19 1.0 1,250
Annual ——————————————————
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 —1.7 1.7 < 0.005 < 0.005 < 0.005 1.8
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 0.27 0.15 < 0.005 < 0.005 0.06 0.06 < 0.005 0.02 0.02 —197 197 0.02 0.03 0.17 207
3.3. Grading (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 BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Daily,
Winter
(Max)
——————————————————
Off-Roa
d
Equipm
ent
3.6 3.0 27 28 0.06 1.1 —1.1 1.0 —1.0 —6,599 6,599 0.27 0.05 —6,621
Dust
From
Material
Movement
——————9.2 9.2 —3.7 3.7 ———————
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
——————————————————
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544—< 0.0050.02542542—0.08—0.080.09—0.090.012.32.20.250.30Off-Roa
d
Dust
From
Material
Movement
——————0.76 0.76 —0.30 0.30 ———————
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 ——————————————————
Off-Roa
d
Equipm
ent
0.05 0.05 0.41 0.41 < 0.005 0.02 —0.02 0.02 —0.02 —90 90 < 0.005 < 0.005 —90
Dust
From
Material
Movement
——————0.14 0.14 —0.05 0.05 ———————
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 0.09 0.08 0.09 1.1 0.00 0.00 0.26 0.26 0.00 0.06 0.06 —253 253 < 0.005 0.01 0.02 256
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 0.55 0.06 5.6 3.1 0.03 0.06 1.2 1.3 0.06 0.34 0.40 —4,530 4,530 0.45 0.72 0.24 4,758
Average
Daily
——————————————————
Worker 0.01 0.01 0.01 0.09 0.00 0.00 0.02 0.02 0.00 0.01 0.01 —21 21 < 0.005 < 0.005 0.03 21
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 0.05 0.01 0.46 0.25 < 0.005 < 0.005 0.10 0.11 < 0.005 0.03 0.03 —372 372 0.04 0.06 0.33 391
Annual ——————————————————
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Worker < 0.005 < 0.005 < 0.005 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 —3.5 3.5 < 0.005 < 0.005 0.01 3.5
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 0.01 < 0.005 0.08 0.05 < 0.005 < 0.005 0.02 0.02 < 0.005 0.01 0.01 —62 62 0.01 0.01 0.05 65
3.5. Building Construction (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 BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Off-Roa
d
Equipm
ent
1.3 1.1 9.9 13 0.02 0.38 —0.38 0.35 —0.35 —2,397 2,397 0.10 0.02 —2,405
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
Daily,
Winter
(Max)
——————————————————
Off-Roa
d
Equipm
ent
1.3 1.1 9.9 13 0.02 0.38 —0.38 0.35 —0.35 —2,397 2,397 0.10 0.02 —2,405
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
——————————————————
Off-Roa
d
Equipm
ent
0.80 0.67 6.2 8.1 0.01 0.24 —0.24 0.22 —0.22 —1,506 1,506 0.06 0.01 —1,511
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
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Annual ——————————————————
Off-Roa
d
Equipm
ent
0.15 0.12 1.1 1.5 < 0.005 0.04 —0.04 0.04 —0.04 —249 249 0.01 < 0.005 —250
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)
——————————————————
Worker 3.6 3.3 3.0 55 0.00 0.00 9.9 9.9 0.00 2.3 2.3 —10,478 10,478 0.44 0.36 36 10,632
Vendor 0.91 0.19 9.8 5.3 0.07 0.13 2.6 2.7 0.13 0.71 0.84 —9,099 9,099 0.64 1.4 24 9,557
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
Daily,
Winter
(Max)
——————————————————
Worker 3.4 3.1 3.3 41 0.00 0.00 9.9 9.9 0.00 2.3 2.3 —9,609 9,609 0.15 0.38 0.93 9,726
Vendor 0.90 0.17 10 5.4 0.07 0.13 2.6 2.7 0.13 0.71 0.84 —9,104 9,104 0.64 1.4 0.62 9,539
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 2.2 1.9 2.3 27 0.00 0.00 6.2 6.2 0.00 1.5 1.5 —6,121 6,121 0.09 0.24 9.7 6,203
Vendor 0.57 0.11 6.5 3.4 0.04 0.08 1.6 1.7 0.08 0.44 0.53 —5,717 5,717 0.40 0.88 6.5 5,996
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 0.39 0.35 0.42 5.0 0.00 0.00 1.1 1.1 0.00 0.27 0.27 —1,013 1,013 0.02 0.04 1.6 1,027
Vendor 0.10 0.02 1.2 0.62 0.01 0.02 0.29 0.31 0.02 0.08 0.10 —947 947 0.07 0.15 1.1 993
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
3.7. Building Construction (2027) - 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 BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Off-Roa
d
Equipm
ent
1.2 1.0 9.4 13 0.02 0.34 —0.34 0.31 —0.31 —2,397 2,397 0.10 0.02 —2,405
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
Daily,
Winter
(Max)
——————————————————
Off-Roa
d
Equipm
ent
1.2 1.0 9.4 13 0.02 0.34 —0.34 0.31 —0.31 —2,397 2,397 0.10 0.02 —2,405
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
——————————————————
Off-Roa
d
Equipm
ent
0.31 0.26 2.3 3.2 0.01 0.08 —0.08 0.08 —0.08 —596 596 0.02 < 0.005 —598
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 ——————————————————
Off-Roa
d
Equipm
ent
0.06 0.05 0.43 0.59 < 0.005 0.02 —0.02 0.01 —0.01 —99 99 < 0.005 < 0.005 —99
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
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Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 3.5 3.1 2.7 51 0.00 0.00 9.9 9.9 0.00 2.3 2.3 —10,267 10,267 0.12 0.36 32 10,410
Vendor 0.83 0.19 9.4 5.1 0.07 0.13 2.6 2.7 0.13 0.71 0.84 —8,929 8,929 0.64 1.3 21 9,364
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
Daily,
Winter
(Max)
——————————————————
Worker 3.3 2.9 3.0 38 0.00 0.00 9.9 9.9 0.00 2.3 2.3 —9,418 9,418 0.13 0.36 0.84 9,529
Vendor 0.82 0.17 9.9 5.2 0.07 0.13 2.6 2.7 0.13 0.71 0.84 —8,934 8,934 0.64 1.3 0.55 9,349
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 0.83 0.73 0.82 10.0 0.00 0.00 2.5 2.5 0.00 0.58 0.58 —2,373 2,373 0.03 0.09 3.5 2,404
Vendor 0.20 0.04 2.4 1.3 0.02 0.03 0.64 0.67 0.03 0.18 0.21 —2,220 2,220 0.16 0.33 2.3 2,325
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 0.15 0.13 0.15 1.8 0.00 0.00 0.45 0.45 0.00 0.11 0.11 —393 393 0.01 0.01 0.57 398
Vendor 0.04 0.01 0.45 0.23 < 0.005 0.01 0.12 0.12 0.01 0.03 0.04 —368 368 0.03 0.05 0.38 385
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
3.9. Concrete Imports (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 BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
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——————————————————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 3.4 3.1 3.3 41 0.00 0.00 9.9 9.9 0.00 2.3 2.3 —9,609 9,609 0.15 0.38 0.93 9,726
Vendor 0.90 0.17 10 5.4 0.07 0.13 2.6 2.7 0.13 0.71 0.84 —9,104 9,104 0.64 1.4 0.62 9,539
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 0.24 0.21 0.25 3.0 0.00 0.00 0.68 0.68 0.00 0.16 0.16 —667 667 0.01 0.03 1.1 676
Vendor 0.06 0.01 0.71 0.37 < 0.005 0.01 0.18 0.18 0.01 0.05 0.06 —623 623 0.04 0.10 0.71 654
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 0.04 0.04 0.05 0.54 0.00 0.00 0.12 0.12 0.00 0.03 0.03 —110 110 < 0.005 < 0.005 0.18 112
Vendor 0.01 < 0.005 0.13 0.07 < 0.005 < 0.005 0.03 0.03 < 0.005 0.01 0.01 —103 103 0.01 0.02 0.12 108
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
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3.11. Paving (2027) - 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 BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Off-Roa
d
Equipm
ent
0.88 0.74 6.9 10.0 0.01 0.30 —0.30 0.27 —0.27 —1,511 1,511 0.06 0.01 —1,516
Paving 2.1 2.1 ————————————————
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
Daily,
Winter
(Max)
——————————————————
Average
Daily
——————————————————
Off-Roa
d
Equipm
ent
0.13 0.11 1.0 1.5 < 0.005 0.04 —0.04 0.04 —0.04 —228 228 0.01 < 0.005 —228
Paving 0.32 0.32 ————————————————
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 ——————————————————
Off-Roa
d
Equipm
ent
0.02 0.02 0.19 0.27 < 0.005 0.01 —0.01 0.01 —0.01 —38 38 < 0.005 < 0.005 —38
Paving 0.06 0.06 ————————————————
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
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Offsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Worker 0.07 0.06 0.05 1.0 0.00 0.00 0.20 0.20 0.00 0.05 0.05 —203 203 < 0.005 0.01 0.64 206
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 0.00 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
Daily,
Winter
(Max)
——————————————————
Average
Daily
——————————————————
Worker 0.01 0.01 0.01 0.12 0.00 0.00 0.03 0.03 0.00 0.01 0.01 —28 28 < 0.005 < 0.005 0.04 29
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 0.00 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 0.02 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 —4.7 4.7 < 0.005 < 0.005 0.01 4.8
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 0.00 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
3.13. Architectural Coating (2027) - 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 BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite ——————————————————
Daily,
Summer
(Max)
——————————————————
Off-Roa
d
Equipm
ent
0.14 0.11 0.83 1.1 < 0.005 0.02 —0.02 0.02 —0.02 —134 134 0.01 < 0.005 —134
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————————————————318318Architect
ural
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
Daily,
Winter
(Max)
——————————————————
Off-Roa
d
Equipm
ent
0.14 0.11 0.83 1.1 < 0.005 0.02 —0.02 0.02 —0.02 —134 134 0.01 < 0.005 —134
Architect
ural
Coating
s
318 318 ————————————————
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
——————————————————
Off-Roa
d
Equipm
ent
0.02 0.02 0.13 0.17 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —20 20 < 0.005 < 0.005 —20
Architect
ural
Coating
s
48 48 ————————————————
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 ——————————————————
Off-Roa
d
Equipm
ent
< 0.005 < 0.005 0.02 0.03 < 0.005 < 0.005 —< 0.005 < 0.005 —< 0.005 —3.3 3.3 < 0.005 < 0.005 —3.3
Architect
ural
Coating
s
8.8 8.8 ————————————————
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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)
——————————————————
Worker 1.4 1.3 1.1 20 0.00 0.00 4.0 4.0 0.00 0.93 0.93 —4,107 4,107 0.05 0.14 13 4,164
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 0.00 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
Daily,
Winter
(Max)
——————————————————
Worker 1.3 1.2 1.2 15 0.00 0.00 4.0 4.0 0.00 0.93 0.93 —3,767 3,767 0.05 0.14 0.33 3,812
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 0.00 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 0.20 0.18 0.20 2.4 0.00 0.00 0.60 0.60 0.00 0.14 0.14 —576 576 0.01 0.02 0.84 583
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 0.00 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 0.04 0.03 0.04 0.44 0.00 0.00 0.11 0.11 0.00 0.03 0.03 —95 95 < 0.005 < 0.005 0.14 97
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 0.00 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
4.10. 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)
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Vegetati TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 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 BCO2 NBCO2 CO2T CH4 N2O R CO2e
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 BCO2 NBCO2 CO2T CH4 N2O R CO2e
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——————————————————Daily,
Summer
(Max)
Avoided ——————————————————
Subtotal ——————————————————
Sequest
ered
——————————————————
Subtotal ——————————————————
Remove
d
——————————————————
Subtotal ——————————————————
———————————————————
Daily,
Winter
(Max)
——————————————————
Avoided ——————————————————
Subtotal ——————————————————
Sequest
ered
——————————————————
Subtotal ——————————————————
Remove
d
——————————————————
Subtotal ——————————————————
———————————————————
Annual ——————————————————
Avoided ——————————————————
Subtotal ——————————————————
Sequest
ered
——————————————————
Subtotal ——————————————————
Remove
d
——————————————————
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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
Demolition Demolition 1/5/2026 1/30/2026 5.0 20 —
Grading Grading 1/5/2026 2/13/2026 5.0 30 —
Building Construction Building Construction 2/14/2026 5/7/2027 5.0 320 —
Concrete Imports Building Construction 2/14/2026 3/20/2026 5.0 25 —
Paving Paving 5/8/2027 7/23/2027 5.0 55 —
Architectural Coating Architectural Coating 7/24/2027 10/8/2027 5.0 55 —
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
Demolition Rubber Tired Dozers Diesel Average 2.0 8.0 367 0.40
Demolition Excavators Diesel Average 3.0 8.0 36 0.38
Demolition Concrete/Industrial
Saws
Diesel Average 1.00 8.0 33 0.73
Grading Rubber Tired Dozers Diesel Average 1.00 8.0 367 0.40
Grading Tractors/Loaders/Back
hoes
Diesel Average 2.0 8.0 84 0.37
Grading Graders Diesel Average 1.00 8.0 148 0.41
Grading Excavators Diesel Average 2.0 8.0 36 0.38
Grading Scrapers Diesel Average 2.0 8.0 423 0.48
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Building Construction Tractors/Loaders/Back Diesel Average 3.0 7.0 84 0.37
Building Construction Forklifts Diesel Average 3.0 8.0 82 0.20
Building Construction Generator Sets Diesel Average 1.00 8.0 14 0.74
Building Construction Cranes Diesel Average 1.00 7.0 367 0.29
Building Construction Welders Diesel Average 1.00 8.0 46 0.45
Paving Pavers Diesel Average 2.0 8.0 81 0.42
Paving Paving Equipment Diesel Average 2.0 8.0 89 0.36
Paving Rollers Diesel Average 2.0 8.0 36 0.38
Architectural Coating Air Compressors Diesel Average 1.00 6.0 37 0.48
5.3. Construction Vehicles
5.3.1. Unmitigated
Phase Name Trip Type One-Way Trips per Day Miles per Trip Vehicle Mix
Demolition Worker 15 19 LDA,LDT1,LDT2
Demolition Vendor —10 HHDT,MHDT
Demolition Hauling 320 20 HHDT
Demolition Onsite truck ——HHDT
Grading Worker 20 19 LDA,LDT1,LDT2
Grading Vendor —10 HHDT,MHDT
Grading Hauling 67 20 HHDT
Grading Onsite truck ——HHDT
Building Construction Worker 759 19 LDA,LDT1,LDT2
Building Construction Vendor 300 10 HHDT,MHDT
Building Construction Hauling 0.00 20 HHDT
Building Construction Onsite truck ——HHDT
Concrete Imports Worker 759 19 LDA,LDT1,LDT2
Concrete Imports Vendor 300 10 HHDT,MHDT
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Concrete Imports Hauling 0.00 20 HHDT
Concrete Imports Onsite truck ——HHDT
Paving Worker 15 19 LDA,LDT1,LDT2
Paving Vendor —10 HHDT,MHDT
Paving Hauling 0.00 20 HHDT
Paving Onsite truck ——HHDT
Architectural Coating Worker 304 19 LDA,LDT1,LDT2
Architectural Coating Vendor —10 HHDT,MHDT
Architectural Coating Hauling 0.00 20 HHDT
Architectural Coating Onsite truck ——HHDT
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)
Architectural Coating 0.00 0.00 2,745,384 915,128 114,998
5.6. Dust Mitigation
5.6.1. Construction Earthmoving Activities
Phase Name Material Imported (Ton of
Debris)
Material Exported (Ton of
Debris)
Acres Graded (acres)Material Demolished (Building
Square Footage)
Acres Paved (acres)
Demolition 0.00 0.00 0.00 555,664 0.00
Grading —10,000 90 0.00 0.00
Paving 0.00 0.00 0.00 0.00 44
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5.6.2. Construction Earthmoving Control Strategies
Non-applicable. No control strategies activated by user.
5.7. Construction Paving
Phase Name Land Use Area Paved (acres)% Asphalt
Paving Unrefrigerated Warehouse-No Rail 0.00 0%
Paving Refrigerated Warehouse-No Rail 0.00 0%
Paving General Office Building 0.00 0%
Paving Parking Lot 44 100%
5.8. Construction Electricity Consumption and Emissions Factors
kWh per Year and Emission Factor (lb/MWh)
Year kWh per Year CO2 CH4 N2O
2026 0.00 532 0.03 < 0.005
2027 0.00 532 0.03 < 0.005
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. Biomass Cover Type
5.18.1.1. Unmitigated
Biomass Cover Type Initial Acres Final Acres
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5.18.2. Sequestration
5.18.2.1. Unmitigated
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 19 annual days of extreme heat
Extreme Precipitation 5.3 annual days with precipitation above 20 mm
Sea Level Rise —meters of inundation depth
Wildfire 0.00 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 2 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 2 1 1 3
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 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 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 95
AQ-PM 94
AQ-DPM 63
Drinking Water 74
Lead Risk Housing 37
Pesticides 0.00
Toxic Releases 84
Traffic 87
Effect Indicators —
CleanUp Sites 71
Groundwater 0.00
Haz Waste Facilities/Generators 95
Impaired Water Bodies 0.00
Solid Waste 94
Sensitive Population —
Asthma 9.3
Cardio-vascular 14
Low Birth Weights 32
Socioeconomic Factor Indicators —
Education 85
Housing 80
Linguistic 59
Poverty 70
Unemployment 44
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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 —
Employed —
Median HI —
Education —
Bachelor's or higher —
High school enrollment —
Preschool enrollment —
Transportation —
Auto Access —
Active commuting —
Social —
2-parent households —
Voting —
Neighborhood —
Alcohol availability —
Park access —
Retail density —
Supermarket access —
Tree canopy —
Housing —
Homeownership —
Housing habitability —
Low-inc homeowner severe housing cost burden —
Low-inc renter severe housing cost burden —
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Uncrowded housing —
Health Outcomes —
Insured adults —
Arthritis 95.7
Asthma ER Admissions 94.5
High Blood Pressure 91.4
Cancer (excluding skin)98.2
Asthma 30.0
Coronary Heart Disease 90.3
Chronic Obstructive Pulmonary Disease 53.7
Diagnosed Diabetes 79.4
Life Expectancy at Birth 0.0
Cognitively Disabled 26.7
Physically Disabled 95.7
Heart Attack ER Admissions 97.1
Mental Health Not Good 21.2
Chronic Kidney Disease 90.3
Obesity 21.5
Pedestrian Injuries 0.0
Physical Health Not Good 40.7
Stroke 80.6
Health Risk Behaviors —
Binge Drinking 1.4
Current Smoker 4.4
No Leisure Time for Physical Activity 39.4
Climate Change Exposures —
Wildfire Risk 0.0
SLR Inundation Area 0.0
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Children 91.6
Elderly 99.1
English Speaking 0.0
Foreign-born 0.0
Outdoor Workers 39.1
Climate Change Adaptive Capacity —
Impervious Surface Cover 76.0
Traffic Density 0.0
Traffic Access 62.4
Other Indices —
Hardship 0.0
Other Decision Support —
2016 Voting 0.0
7.3. Overall Health & Equity Scores
Metric Result for Project Census Tract
CalEnviroScreen 4.0 Score for Project Location (a)66
Healthy Places Index Score for Project Location (b)—
Project Located in a Designated Disadvantaged Community (Senate Bill 535)Yes
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.
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7.6. Health & Equity Custom Measures
No Health & Equity Custom Measures created.
8. User Changes to Default Data
8.1. Justifications
Screen Justification
Characteristics: Utility Information Consistent with DEIR.
Land Use See comment on: "Failure to Include Parking Land Use".
Construction: Construction Phases Consistent with DEIR.
Construction: Off-Road Equipment Consistent with DEIR.
Construction: Trips and VMT 1,000 total truck trips for material export during grading consistent with the DEIR.
1
2656 29th Street, Suite 201
Santa Monica, CA 90405
(949) 887-9013
mhagemann@swape.com
Matthew F. Hagemann, P.G., C.Hg.
•Geologic and Hydrogeologic Characterization, Investigation and Remediation Strategies
•Industrial Stormwater Compliance
•CEQA Review
• Expert Testimony
Professional Certifications:
California Professional Geologist, P.G.
California Certified Hydrogeologist, C.Hg.
Education:
M.S. Degree, Geology, California State University Los Angeles, Los Angeles, CA, 1984.
B.A. Degree, Geology, Humboldt State University, Arcata, CA, 1982.
Professional Experience:
30 years of experience in environmental policy, contaminant assessment and remediation, stormwater
compliance, and CEQA review. Spent nine years with the U.S. EPA in the Resource Conservation
Recovery Act (RCRA) and Superfund programs and served as EPA’s Senior Science Policy Advisor in
the Western Regional Office where I identified emerging threats to groundwater. While with EPA, I
served as a Senior Hydrogeologist in the oversight of the assessment of seven major military facilities
undergoing base closure. Led numerous enforcement actions under provisions of the Resource
Conservation and Recovery Act (RCRA) and directed efforts to improve hydrogeologic characterization
and water quality monitoring. For the past 15 years, as a founding partner with SWAPE, I developed
extensive client relationships and has managed complex projects that include consultations as an expert
witness and a regulatory specialist, and managing projects ranging from industrial stormwater
compliance to CEQA review of impacts from hazardous waste, air quality and greenhouse gas
emissions.
Positions held include:
Government:
Attachment B
Senior Science Policy Advisor and Hydrogeologist, U.S. Environmental Protection Agency (1989– 1998);
2
Geologist, U.S. Forest Service (1986 – 1998).
Educational:
Geology Instructor, Golden West College, 2010 – 2104, 2017;
Adjunct Faculty Member, San Francisco State University, Department of Geosciences (1993 – 1998);
Instructor, College of Marin, Department of Science (1990 – 1995).
Private Sector:
Founding Partner, Soil/Water/Air Protection Enterprise (SWAPE) (2003 – present);
Senior Environmental Analyst, Komex H2O Science, Inc. (2000 -- 2003);
Executive Director, Orange Coast Watch (2001 – 2004);
Geologist, Dames & Moore (1984 – 1986).
Senior Regulatory and Litigation Support Analyst:
With SWAPE, responsibilities have included:
•Lead analyst and testifying expert, for both plaintiffs and defendants, in the review of over 300
environmental impact reports and negative declarations since 2003 under CEQA that identify
significant issues with regard to hazardous waste, water resources, water quality, air quality,
greenhouse gas emissions, and geologic hazards.
•Recommending additional mitigation measures to lead agencies at the local and county level to
include additional characterization of health risks and implementation of protective measures to
reduce exposure to hazards from toxins.
•Stormwater analysis, sampling and best management practice evaluation, for both government
agencies and corporate clients, at more than 150 industrial facilities.
•Serving as expert witness for both plaintiffs and defendants in cases including contamination of
groundwater, CERCLA compliance in assessment and remediation, and industrial stormwater
contamination.
•Technical assistance and litigation support for vapor intrusion concerns, for both government
agencies and corporate clients.
•Lead analyst and testifying expert in the review of environmental issues in license applications for
large solar power plants before the California Energy Commission.
•Manager of a project to evaluate numerous formerly used military sites in the western U.S.
•Manager of a comprehensive evaluation of potential sources of perchlorate contamination in
Southern California drinking water wells.
•Manager and designated expert for litigation support under provisions of Proposition 65 in the
review of releases of gasoline to sources drinking water at major refineries and hundreds of gas
stations throughout California.
With Komex H2O Science Inc., duties included the following:
Hydrogeologist, National Park Service, Water Resources Division (1998 – 2000);
•Senior author of a report on the extent of perchlorate contamination that was used in testimony by
the former U.S. EPA Administrator and General Counsel.
•Senior researcher in the development of a comprehensive, electronically interactive chronology of
MTBE use, research, and regulation.
•Senior researcher in the development of a comprehensive, electronically interactive chronology of
perchlorate use, research, and regulation.
•Senior researcher in a study that estimates nationwide costs for MTBE remediation and drinking
3
Hydrogeology:
As a Senior Hydrogeologist with the U.S. Environmental Protection Agency, led investigations to characterize
and cleanup closing military bases, including Mare Island Naval Shipyard, Hunters Point Naval Shipyard,
Treasure Island Naval Station, Alameda Naval Station, Moffett Field, Mather Army Airfield, and Sacramento
Army Depot. Specific activities included:
•Leading efforts to model groundwater flow and contaminant transport, ensured adequacy of
monitoring networks, and assessed cleanup alternatives for contaminated sediment, soil, and
groundwater.
•Initiating a regional program for evaluation of groundwater sampling practices and laboratory
analysis at military bases.
•Identifying emerging issues, wrote technical guidance, and assisted in policy and regulation
development through work on four national U.S. EPA workgroups, including the Superfund
Groundwater Technical Forum and the Federal Facilities Forum.
At the request of the State of Hawaii, developed a methodology to determine the vulnerability of groundwater
to contamination on the islands of Maui and Oahu. Used analytical models and a GIS to show zones of
vulnerability, and the results were adopted and published by the State of Hawaii and County of Maui.
As a hydrogeologist with the EPA Groundwater Protection Section, worked with provisions of the Safe
Drinking Water Act and NEPA to prevent drinking water contamination. Specific activities included the
following:
•Received an EPA Bronze Medal for contribution to the development of national guidance for the
protection of drinking water.
•Managed the Sole Source Aquifer Program and protected the drinking water of two communities
through designation under the Safe Drinking Water Act. Prepared geologic reports, conducted
hearings, and responded to public comments from residents who were very concerned about the
impact of designation.
•Reviewed a number of Environmental Impact Statements for planned major developments, including
large hazardous and solid waste disposal facilities, mine reclamation, and water transfer.
Served as a hydrogeologist with the RCRA Hazardous Waste program. Duties included:
water treatment, results of which were published in newspapers nationwide and in testimony
against provisions of an energy bill that would limit liability for oil companies.
•Research to support litigation to restore drinking water supplies that have been contaminated by
MTBE in California and New York.
•Lead author for a multi-volume remedial investigation report for an operating school in Los Angeles
that met strict Sate of California regulatory requirements.
•Development of strategic approaches for cleanup of contaminated sites in consultation with clients
and regulators.
•Supervised the hydrogeologic investigation of hazardous waste sites to determine compliance with
Subtitle C requirements.
•Reviewed and wrote ʺpart Bʺ permits for the disposal of hazardous waste.
•Conducted RCRA Corrective Action investigations of waste sites and led inspections that formed the
basis for significant enforcement actions that were developed in close coordination with U.S. EPA
legal counsel.
4
With the National Park Service, directed service-wide investigations of contaminant sources to prevent
degradation of water quality, including the following:
•Applied pertinent laws and regulations including CERCLA, RCRA, NEPA, NRDA, and the Clean
Water Act to control military, mining, and landfill contaminants.
•Conducted watershed-scale investigations of contaminants at parks, including Yellowstone and
Olympic National Park.
•Identified high-levels of perchlorate in soil adjacent to a national park in New Mexico and advised
park superintendent on appropriate response actions under CERCLA.
•Served as a Park Service representative on the Interagency Perchlorate Steering Committee, a
national workgroup.
•Developed a program to conduct environmental compliance audits of all National Parks while
serving on a national workgroup.
•Co-authored two papers on the potential for water contamination from the operation of personal
watercraft and snowmobiles, these papers serving as the basis for the development of nation- wide
policy on the use of these vehicles in National Parks.
•Contributed to the Federal Multi-Agency Source Water Agreement under the Clean Water Action
Plan.
Policy:
Served as senior management as the Senior Science Policy Advisor with the U.S. Environmental Protection
Agency, Region 9. Activities included the following:
•Advising the Regional Administrator and senior management on emerging issues such as the
potential for the gasoline additive MTBE and ammonium perchlorate to contaminate drinking water
supplies.
•Shaping EPA’s national response to these threats by serving on workgroups and by contributing to
guidance, including the Office of Research and Development publication, Oxygenates in Water:
Critical Information and Research Needs.
•Improving the technical training of EPAʹs scientific and engineering staff.
•Earning an EPA Bronze Medal for representing the region’s 300 scientists and engineers in
negotiations with the Administrator and senior management to better integrate scientific principles
into the policy-making process.
•Establishing national protocol for the peer review of scientific documents.
Geology:
With the U.S. Forest Service, led investigations to determine hillslope stability of areas proposed for timber
harvest in the central Oregon Coast Range. Specific activities included:
•Mapping geology in the field, and used aerial photographic interpretation and mathematical models
to determine slope stability.
•Coordinating research with community stakeholders who were concerned with natural resource
protection.
•Characterizing the geology of an aquifer that serves as the sole source of drinking water for the city
of Medford, Oregon.
•Wrote contract specifications and supervised contractor’s investigations of waste sites.
5
Duties included the following:
•Supervising year-long effort for soil and groundwater sampling.
•Conducting aquifer tests.
•Investigating active faults beneath sites proposed for hazardous waste disposal.
Teaching:
From 1990 to 1998, taught at least one course per semester at the community college and university levels:
•At San Francisco State University, held an adjunct faculty position and taught courses in
environmental geology, oceanography (lab and lecture), hydrogeology, and groundwater
contamination.
•Served as a committee member for graduate and undergraduate students.
•Taught courses in environmental geology and oceanography at the College of Marin.
•Part time geology instructor at Golden West College in Huntington Beach, California from 2010 to
2014 and in 2017.
Summary of Testimony Experience Over Past Four Years
In Re New Jersey Department of Environmental Protection et al. vs. E.I. DuPont de Nemours and Company, in the
United States District Court, District of New Jersey, Civil Action No. 1:19-cv-14766-RMB-JBC. Deposition in 2025.
Representing Plaintiffs in matters regarding contamination of groundwater, wastewater, soil, and air with per- and poly-
fluoroalkyl substances.
In Re Edmond Asher, et al., vs. RTX Corporation (f/k/a Raytheon Technologies Corporation, et al.) in the County of
Huntington Superior Court, Indiana, Cause number 35D01-2006-CT-000338. Deposition in 2024. Representing
Plaintiffs in matters regarding contamination of groundwater and soil vapor with trichlorethylene.
In Re Wright vs Consolidated Rail Corporation In the Circuit Court of Cook County, Illinois, Case No: 21L3966.
Deposition in 2023, Representing Plaintiff in matters involving groundwater and drinking water contamination of
perchloroethylene, trichlorethylene, 1,2-dichloroethane, and carbon tetrachloride.
In Re Behr Dayton Thermal Products LLC In the United States District Court for the Southern District of Ohio Western
Division at Dayton, Case No: 08-cv-326. Deposition in 2022. Representing Plaintiff in matters regarding contamination
of groundwater and indoor air with perchloroethylene and trichloethelene.
Orange County Water District vs. Sabic Innovative Plastics US, LLC, et al. In the Court of Appeal, Fourth District,
As a consultant with Dames and Moore, led geologic investigations of two contaminated sites (later listed on
the Superfund NPL) in the Portland, Oregon, area and a large RCRA hazardous waste site in eastern Oregon.
6
Los Angeles Waterkeeper vs. AAA Plating and Inspection, Inc. In the United States District Court for the Central
District of California, Case No: No. CV 18-5916 PA (GJSx). Deposition in 2019. Expert witness representing Plaintiff in
matters involving contaminated stormwater runoff at an industrial facility in Compton, California.
Californians for Alternatives to Toxics vs. Schneider Dock and Intermodal Facility. In the United States District Court for
the Northern District of California, Case No: 3:17-cv-05287-JST. Deposition in 2019. Expert witness representing Plaintiff
in matters involving contaminated stormwater runoff at an industrial facility in Eureka, California.
Bells et al. vs. The 3M Company et al. In the United States District Court for the District of Colorado, Case No: 1:16-CV-
02531-RBJ. Deposition in 2018. Expert witness representing Plaintiff on matters regarding the general hydrogeological
conditions present in an area impacted by per- and poly-fluoroalkyl substances.
Ungar vs. Foundation for Affordable Housing. In the Superior Court, State of California, Los Angeles County, Case No.
BC628890 Deposition in 2017. Expert witness representing defendant on matters involving alleged drinking water
contamination.
Invited Testimony, Reports, Papers and Presentations:
Hagemann, M.F., 2008. Disclosure of Hazardous Waste Issues under CEQA. Presentation to the Public
Environmental Law Conference, Eugene, Oregon.
Hagemann, M.F., 2008. Disclosure of Hazardous Waste Issues under CEQA. Invited presentation to U.S. EPA
Region 9, San Francisco, California.
Hagemann, M.F., 2005. Use of Electronic Databases in Environmental Regulation, Policy Making and Public
Participation. Brownfields 2005, Denver, Coloradao.
Hagemann, M.F., 2004. Perchlorate Contamination of the Colorado River and Impacts to Drinking Water in
Nevada and the Southwestern U.S. Presentation to a meeting of the American Groundwater Trust, Las Vegas,
NV (served on conference organizing committee).
Hagemann, M.F., 2004. Invited testimony to a California Senate committee hearing on air toxins at schools in
Southern California, Los Angeles.
Brown, A., Farrow, J., Gray, A. and Hagemann, M., 2004. An Estimate of Costs to Address MTBE Releases from
Underground Storage Tanks and the Resulting Impact to Drinking Water Wells.
Division 1, California, Case No: D070553. Deposition in 2020. Representing Plaintiff in matters involving compliance
with The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA).
7
Arizona and the Southwestern U.S. Presentation to a meeting of the American Groundwater Trust, Phoenix, AZ
(served on conference organizing committee).
Hagemann, M.F., 2003. Perchlorate Contamination of the Colorado River and Impacts to Drinking Water in the
Southwestern U.S. Invited presentation to a special committee meeting of the National Academy of Sciences,
Irvine, CA.
Hagemann, M.F., 2003. Perchlorate Contamination of the Colorado River. Invited presentation to a tribal EPA
meeting, Pechanga, CA.
Hagemann, M.F., 2003. Perchlorate Contamination of the Colorado River. Invited presentation to a meeting of
tribal representatives, Parker, AZ.
Hagemann, M.F., 2003. Impact of Perchlorate on the Colorado River and Associated Drinking Water Supplies.
Invited presentation to the Inter-Tribal Meeting, Torres Martinez Tribe.
Hagemann, M.F., 2003. The Emergence of Perchlorate as a Widespread Drinking Water Contaminant. Invited
presentation to the U.S. EPA Region 9.
Hagemann, M.F., 2003. A Deductive Approach to the Assessment of Perchlorate Contamination. Invited
presentation to the California Assembly Natural Resources Committee.
Hagemann, M.F., 2003. Perchlorate: A Cold War Legacy in Drinking Water. Presentation to a meeting of the
National Groundwater Association.
Hagemann, M.F., 2002. From Tank to Tap: A Chronology of MTBE in Groundwater. Presentation to a meeting
of the National Groundwater Association.
Hagemann, M.F., 2002. A Chronology of MTBE in Groundwater and an Estimate of Costs to Address Impacts to
Groundwater. Presentation to the annual meeting of the Society of Environmental Journalists.
Hagemann, M.F., 2002. An Estimate of the Cost to Address MTBE Contamination in Groundwater (and Who
Will Pay). Presentation to a meeting of the National Groundwater Association.
Hagemann, M.F., 2002. An Estimate of Costs to Address MTBE Releases from Underground Storage Tanks
and the Resulting Impact to Drinking Water Wells. Presentation to a meeting of the U.S. EPA and State
Underground Storage Tank Program managers.
Hagemann, M.F., 2001. From Tank to Tap: A Chronology of MTBE in Groundwater. Unpublished report.
Hagemann, M.F., 2001. Estimated Cleanup Cost for MTBE in Groundwater Used as Drinking Water.
Unpublished report.
Hagemann, M.F., 2001. Estimated Costs to Address MTBE Releases from Leaking Underground Storage Tanks.
Presentation to the Ground Water and Environmental Law Conference, National Groundwater Association.
Hagemann, M.F., 2004. Perchlorate Contamination of the Colorado River and Impacts to Drinking Water in
8
Water Resources Division, National Park Service, Technical Report.
VanMouwerik, M. and Hagemann, M.F. 1999, Water Quality Concerns Related to Personal Watercraft Usage.
Water Resources Division, National Park Service, Technical Report.
Hagemann, M.F., 1999, Is Dilution the Solution to Pollution in National Parks? The George Wright Society
Biannual Meeting, Asheville, North Carolina.
Hagemann, M.F., 1997, The Potential for MTBE to Contaminate Groundwater. U.S. EPA Superfund
Groundwater Technical Forum Annual Meeting, Las Vegas, Nevada.
Hagemann, M.F., and Gill, M., 1996, Impediments to Intrinsic Remediation, Moffett Field Naval Air Station,
Conference on Intrinsic Remediation of Chlorinated Hydrocarbons, Salt Lake City.
Hagemann, M.F., Fukunaga, G.L., 1996, The Vulnerability of Groundwater to Anthropogenic Contaminants on
the Island of Maui, Hawaii. Hawaii Water Works Association Annual Meeting, Maui, October 1996.
Hagemann, M. F., Fukanaga, G. L., 1996, Ranking Groundwater Vulnerability in Central Oahu,
Hawaii. Proceedings, Geographic Information Systems in Environmental Resources Management, Air and
Waste Management Association Publication VIP-61.
Hagemann, M.F., 1994. Groundwater Ch ar ac te r i z a t i o n and Cl ean up a t Closing Military Bases in
California. Proceedings, California Groundwater Resources Association Meeting.
Hagemann, M.F. and Sabol, M.A., 1993. Role of the U.S. EPA in the High Plains States Groundwater Recharge
Demonstration Program. Proceedings, Sixth Biennial Symposium on the Artificial Recharge of Groundwater.
Hagemann, M.F., 1993. U.S. EPA Policy on the Technical Impracticability of the Cleanup of DNAPL-
contaminated Groundwater. California Groundwater Resources Association Meeting.
Hagemann, M.F., 1992. Dense Nonaqueous Phase Liquid Contamination of Groundwater: An Ounce of
Prevention... Proceedings, Association of Engineering Geologists Annual Meeting, v. 35.
Other Experience:
Selected as subject matter expert for the California Professional Geologist licensing examinations, 2009-2011.
Unpublished report.
Hagemann, M.F., and VanMouwerik, M., 1999. Potential Water Concerns Related to Snowmobile Usage.
SOIL WATER AIR PROTECTION ENTERPRISE
2656 29th Street, Suite 201
Santa Monica, California 90405
Attn: Paul Rosenfeld, Ph.D.
Mobil: (310) 795-2335
Office: (310) 452-5555
Fax: (310) 452-5550
Email: prosenfeld@swape.com
Paul E. Rosenfeld, Ph.D. Page 1 of 17 March2025
Paul Rosenfeld, Ph.D.Chemical Fate and Transport & Air Dispersion Modeling
Principal Environmental Chemist Risk Assessment & Remediation Specialist
Education
Ph.D. Soil Chemistry, University of Washington, 1999. Dissertation on volatile organic compound filtration.
M.S. Environmental Science, U.C. Berkeley, 1995. Thesis on organic waste economics.
B.A. Environmental Studies, U.C. Santa Barbara, 1991. Focus on wastewater treatment.
Professional Experience
Dr. Rosenfeld has over 25 years of experience conducting environmental investigations and risk assessments for
evaluating impacts to human health, property, and ecological receptors. His expertise focuses on the fate and
transport of environmental contaminants, human health risk, exposure assessment, and ecological restoration. Dr.
Rosenfeld has evaluated and modeled emissions from oil spills, landfills, boilers and incinerators, process stacks,
storage tanks, confined animal feeding operations, industrial, military and agricultural sources, unconventional oil
drilling operations, and locomotive and construction engines. His project experience ranges from monitoring and
modeling of pollution sources to evaluating impacts of pollution on workers at industrial facilities and residents in
surrounding communities. Dr. Rosenfeld has also successfully modeled exposure to contaminants distributed by
water systems and via vapor intrusion.
Dr. Rosenfeld has investigated and designed remediation programs and risk assessments for contaminated sites
containing lead, heavy metals, mold, bacteria, particulate matter, petroleum hydrocarbons, chlorinated solvents,
pesticides, radioactive waste, dioxins and furans, semi- and volatile organic compounds, PCBs, PAHs, creosote,
perchlorate, asbestos, per- and poly-fluoroalkyl substances (PFOA/PFOS), unusual polymers, fuel oxygenates
(MTBE), among other pollutants. Dr. Rosenfeld also has experience evaluating greenhouse gas emissions from
various projects and is an expert on the assessment of odors from industrial and agricultural sites, as well as the
evaluation of odor nuisance impacts and technologies for abatement of odorous emissions. As a principal scientist
at SWAPE, Dr. Rosenfeld directs air dispersion modeling and exposure assessments. He has served as an expert
witness and testified about pollution sources causing nuisance and/or personal injury at sites and has testified as an
expert witness on numerous cases involving exposure to soil, water and air contaminants from industrial, railroad,
agricultural, and military sources.
Attachment C
Paul E. Rosenfeld, Ph.D. Page 2 of 17 March 2025
Professional History:
Soil Water Air Protection Enterprise (SWAPE); 2003 to present; Principal and Founding Partner
UCLA School of Public Health; 2007 to 2011; Lecturer (Assistant Researcher)
UCLA School of Public Health; 2003 to 2006; Adjunct Professor
UCLA Environmental Science and Engineering Program; 2002-2004; Doctoral Intern Coordinator
UCLA Institute of the Environment, 2001-2002; Research Associate
Komex H2O Science, 2001 to 2003; Senior Remediation Scientist
National Groundwater Association, 2002-2004; Lecturer
San Diego State University, 1999-2001; Adjunct Professor
Anteon Corp., San Diego, 2000-2001; Remediation Project Manager
Ogden (now Amec), San Diego, 2000-2000; Remediation Project Manager
Bechtel, San Diego, California, 1999 – 2000; Risk Assessor
King County, Seattle, 1996 – 1999; Scientist
James River Corp., Washington, 1995-96; Scientist
Big Creek Lumber, Davenport, California, 1995; Scientist
Plumas Corp., California and USFS, Tahoe 1993-1995; Scientist
Peace Corps and World Wildlife Fund, St. Kitts, West Indies, 1991-1993; Scientist
Publications:
Rosenfeld, P.E., Spaeth, K.R., McCarthy, S.J. et al. Camp Lejeune Marine Cancer Risk Assessment for Exposure to
Contaminated Drinking Water From 1955 to 1987. Water Air Soil Pollut 235, 124 (2024).
https://doi.org/10.1007/s11270-023-06863-y.
Rosenfeld P.E., Spaeth K.R., Remy L.L., Byers V., Muerth S.A., Hallman R,C., Summers-Evans J., Barker S.
(2023) Perfluoroalkyl substances exposure in firefighters: Sources and implications, Environmental Research,
Volume 220, https://doi.org/10.1016/j.envres.2022.115164.
Rosenfeld P.E. and Spaeth K.R., (2023) Authors’ Response to Letter to the Editor from Bullock and Ramacciotti,
Water Air Soil Pollution Volume 234, https://doi.org/10.1007/s11270-023-06165-3
Rosenfeld P. E., Spaeth K., Hallman R., Bressler R., Smith, G., (2022) Cancer Risk and Diesel Exhaust Exposure
Among Railroad Workers. Water Air Soil Pollution. 233, 171.
Remy, L.L., Clay T., Byers, V., Rosenfeld P. E. (2019) Hospital, Health, and Community Burden After Oil
Refinery Fires, Richmond, California 2007 and 2012. Environmental Health. 18:48
Simons, R.A., Seo, Y. Rosenfeld, P., (2015) Modeling the Effect of Refinery Emission On Residential Property
Value. Journal of Real Estate Research. 27(3):321-342
Chen, J. A, Zapata A. R., Sutherland A. J., Molmen, D.R., Chow, B. S., Wu, L. E., Rosenfeld, P. E., Hesse, R. C.,
(2012) Sulfur Dioxide and Volatile Organic Compound Exposure To A Community In Texas City Texas Evaluated
Using Aermod and Empirical Data. American Journal of Environmental Science, 8(6), 622-632.
Rosenfeld, P.E. & Feng, L. (2011). The Risks of Hazardous Waste. Amsterdam: Elsevier Publishing.
Cheremisinoff, N.P., & Rosenfeld, P.E. (2011). Handbook of Pollution Prevention and Cleaner Production: Best
Practices in the Agrochemical Industry, Amsterdam: Elsevier Publishing.
Gonzalez, J., Feng, L., Sutherland, A., Waller, C., Sok, H., Hesse, R., Rosenfeld, P. (2010). PCBs and
Dioxins/Furans in Attic Dust Collected Near Former PCB Production and Secondary Copper Facilities in Sauget, IL.
Procedia Environmental Sciences. 113–125.
Paul E. Rosenfeld, Ph.D. Page 3 of 17 March 2025
Feng, L., Wu, C., Tam, L., Sutherland, A.J., Clark, J.J., Rosenfeld, P.E. (2010). Dioxin and Furan Blood Lipid and
Attic Dust Concentrations in Populations Living Near Four Wood Treatment Facilities in the United States. Journal
of Environmental Health. 73(6), 34-46.
Cheremisinoff, N.P., & Rosenfeld, P.E. (2010). Handbook of Pollution Prevention and Cleaner Production: Best
Practices in the Wood and Paper Industries. Amsterdam: Elsevier Publishing.
Cheremisinoff, N.P., & Rosenfeld, P.E., (2009). Handbook of Pollution Prevention and Cleaner Production: Best
Practices in the Petroleum Industry. Amsterdam: Elsevier Publishing.
Wu, C., Tam, L., Clark, J., Rosenfeld, P. (2009). Dioxin and furan blood lipid concentrations in populations living
near four wood treatment facilities in the United States. WIT Transactions on Ecology and the Environment, Air
Pollution, 123 (17), 319-327.
Cheremisinoff, N.P., Rosenfeld, P.E. Davletshin, A.R. (2008). Responsible Care. Gulf Publishing. Texas.
Tam L. K., Wu C. D., Clark J. J. and Rosenfeld, P.E. (2008). A Statistical Analysis Of Attic Dust And Blood Lipid
Concentrations Of Tetrachloro-p-Dibenzodioxin (TCDD) Toxicity Equivalency Quotients (TEQ) In Two
Populations Near Wood Treatment Facilities. Organohalogen Compounds, 70, 002252-002255.
Tam L. K., Wu C. D., Clark J. J. and Rosenfeld, P.E. (2008). Methods For Collect Samples For Assessing Dioxins
And Other Environmental Contaminants In Attic Dust: A Review. Organohalogen Compounds, 70, 000527-
000530.
Hensley, A.R. A. Scott, J. J. J. Clark, Rosenfeld, P.E. (2007). Attic Dust and Human Blood Samples Collected near
a Former Wood Treatment Facility. Environmental Research. 105, 194-197.
Rosenfeld, P.E., J. J. J. Clark, A. R. Hensley, M. Suffet. (2007). The Use of an Odor Wheel Classification for
Evaluation of Human Health Risk Criteria for Compost Facilities. Water Science & Technology 55(5), 345-357.
Rosenfeld, P. E., M. Suffet. (2007). The Anatomy of Odour Wheels for Odours of Drinking Water, Wastewater,
Compost And The Urban Environment. Water Science & Technology 55(5), 335-344.
Sullivan, P. J. Clark, J.J.J., Agardy, F. J., Rosenfeld, P.E. (2007). Toxic Legacy, Synthetic Toxins in the Food,
Water, and Air in American Cities. Boston Massachusetts: Elsevier Publishing
Rosenfeld, P.E., and Suffet I.H. (2004). Control of Compost Odor Using High Carbon Wood Ash. Water Science
and Technology. 49(9),171-178.
Rosenfeld P. E., J.J. Clark, I.H. (Mel) Suffet (2004). The Value of An Odor-Quality-Wheel Classification Scheme
for The Urban Environment. Water Environment Federation’s Technical Exhibition and Conference (WEFTEC)
2004. New Orleans, October 2-6, 2004.
Rosenfeld, P.E., and Suffet, I.H. (2004). Understanding Odorants Associated with Compost, Biomass Facilities, and
the Land Application of Biosolids. Water Science and Technology. 49(9), 193-199.
Rosenfeld, P.E., and Suffet I.H. (2004). Control of Compost Odor Using High Carbon Wood Ash, Water Science
and Technology, 49(9), 171-178.
Rosenfeld, P. E., Grey, M. A., Sellew, P. (2004). Measurement of Biosolids Odor and Odorant Emissions from
Windrows, Static Pile and Biofilter. Water Environment Research. 76(4), 310-315.
Rosenfeld, P.E., Grey, M and Suffet, M. (2002). Compost Demonstration Project, Sacramento California Using
High-Carbon Wood Ash to Control Odor at a Green Materials Composting Facility. Integrated Waste Management
Board Public Affairs Office, Publications Clearinghouse (MS–6), Sacramento, CA Publication #442-02-008.
Paul E. Rosenfeld, Ph.D. Page 4 of 17 March 2025
Rosenfeld, P.E., and C.L. Henry. (2001). Characterization of odor emissions from three different biosolids. Water
Soil and Air Pollution. 127(1-4), 173-191.
Rosenfeld, P.E., and Henry C. L., (2000). Wood ash control of odor emissions from biosolids application. Journal
of Environmental Quality. 29, 1662-1668.
Rosenfeld, P.E., C.L. Henry and D. Bennett. (2001). Wastewater dewatering polymer affects on biosolids odor
emissions and microbial activity. Water Environment Research. 73(4), 363-367.
Rosenfeld, P.E., and C.L. Henry. (2001). Activated Carbon and Wood Ash Sorption of Wastewater, Compost, and
Biosolids Odorants. Water Environment Research, 73, 388-393.
Rosenfeld, P.E., and Henry C. L., (2001). High carbon wood ash effect on biosolids microbial activity and odor.
Water Environment Research. 131(1-4), 247-262.
Chollack, T. and P. Rosenfeld. (1998). Compost Amendment Handbook for Landscaping. Prepared for and
distributed by the City of Redmond, Washington State.
Rosenfeld, P. E. (1992). The Mount Liamuiga Crater Trail. Heritage Magazine of St. Kitts, 3(2).
Rosenfeld, P. E. (1993). High School Biogas Project to Prevent Deforestation on St. Kitts. Biomass Users
Network, 7(1).
Rosenfeld, P. E. (1998). Characterization, Quantification, and Control of Odor Emissions from Biosolids
Application To Forest Soil. Doctoral Thesis. University of Washington College of Forest Resources.
Rosenfeld, P. E. (1994). Potential Utilization of Small Diameter Trees on Sierra County Public Land. Master’s
thesis reprinted by the Sierra County Economic Council. Sierra County, California.
Rosenfeld, P. E. (1991). How to Build a Small Rural Anaerobic Digester & Uses Of Biogas In The First And Third
World. Bachelor’s Thesis. University of California.
Presentations:
Rosenfeld, P.E., "The science for Perfluorinated Chemicals (PFAS): What makes remediation so hard?" Law
Seminars International, (May 9-10, 2018) 800 Fifth Avenue, Suite 101 Seattle, WA.
Rosenfeld, P.E., Sutherland, A; Hesse, R.; Zapata, A. (October 3-6, 2013). Air dispersion modeling of volatile
organic emissions from multiple natural gas wells in Decatur, TX. 44th Western Regional Meeting, American
Chemical Society. Lecture conducted from Santa Clara, CA.
Sok, H.L.; Waller, C.C.; Feng, L.; Gonzalez, J.; Sutherland, A.J.; Wisdom-Stack, T.; Sahai, R.K.; Hesse, R.C.;
Rosenfeld, P.E. (June 20-23, 2010). Atrazine: A Persistent Pesticide in Urban Drinking Water.
Urban Environmental Pollution. Lecture conducted from Boston, MA.
Feng, L.; Gonzalez, J.; Sok, H.L.; Sutherland, A.J.; Waller, C.C.; Wisdom-Stack, T.; Sahai, R.K.; La, M.; Hesse,
R.C.; Rosenfeld, P.E. (June 20-23, 2010). Bringing Environmental Justice to East St. Louis,
Illinois. Urban Environmental Pollution. Lecture conducted from Boston, MA.
Rosenfeld, P.E. (April 19-23, 2009). Perfluoroctanoic Acid (PFOA) and Perfluoroactane Sulfonate (PFOS)
Contamination in Drinking Water From the Use of Aqueous Film Forming Foams (AFFF) at Airports in the United
States. 2009 Ground Water Summit and 2009 Ground Water Protection Council Spring Meeting, Lecture conducted
from Tuscon, AZ.
Paul E. Rosenfeld, Ph.D. Page 5 of 17 March 2025
Rosenfeld, P.E. (April 19-23, 2009). Cost to Filter Atrazine Contamination from Drinking Water in the United
States” Contamination in Drinking Water From the Use of Aqueous Film Forming Foams (AFFF) at Airports in the
United States. 2009 Ground Water Summit and 2009 Ground Water Protection Council Spring Meeting. Lecture
conducted from Tuscon, AZ.
Wu, C., Tam, L., Clark, J., Rosenfeld, P. (20-22 July (2009). Dioxin and furan blood lipid concentrations in
populations living near four wood treatment facilities in the United States. Brebbia, C.A. and Popov, V., eds., Air
Pollution XVII: Proceedings of the Seventeenth International Conference on Modeling, Monitoring and
Management of Air Pollution. Lecture conducted from Tallinn, Estonia.
Rosenfeld, P. E. (October 15-18, 2007). Moss Point Community Exposure To Contaminants From A Releasing
Facility. The 23rd Annual International Conferences on Soils Sediment and Water. Platform lecture conducted at
University of Massachusetts, Amherst MA.
Rosenfeld, P. E. (October 15-18, 2007). The Repeated Trespass of Tritium-Contaminated Water Into A
Surrounding Community Form Repeated Waste Spills From A Nuclear Power Plant. The 23rd Annual International
Conferences on Soils Sediment and Water. Platform lecture conducted from University of Massachusetts, Amherst
MA.
Rosenfeld, P. E. (October 15-18, 2007). Somerville Community Exposure To Contaminants From Wood Treatment
Facility Emissions. The 23rd Annual International Conferences on Soils Sediment and Water. Lecture conducted
from University of Massachusetts, Amherst MA.
Rosenfeld P. E. (March 2007). Production, Chemical Properties, Toxicology, & Treatment Case Studies of 1,2,3-
Trichloropropane (TCP). The Association for Environmental Health and Sciences (AEHS) Annual Meeting. Lecture
conducted from San Diego, CA.
Rosenfeld P. E. (March 2007). Blood and Attic Sampling for Dioxin/Furan, PAH, and Metal Exposure in Florala,
Alabama. The AEHS Annual Meeting. Lecture conducted from San Diego, CA.
Hensley A.R., Scott, A., Rosenfeld P.E., Clark, J.J.J. (August 21 – 25, 2006). Dioxin Containing Attic Dust And
Human Blood Samples Collected Near A Former Wood Treatment Facility. The 26th International Symposium on
Halogenated Persistent Organic Pollutants – DIOXIN2006. Lecture conducted from Radisson SAS Scandinavia
Hotel in Oslo Norway.
Hensley A.R., Scott, A., Rosenfeld P.E., Clark, J.J.J. (November 4-8, 2006). Dioxin Containing Attic Dust And
Human Blood Samples Collected Near A Former Wood Treatment Facility. APHA 134 Annual Meeting &
Exposition. Lecture conducted from Boston Massachusetts.
Paul Rosenfeld Ph.D. (October 24-25, 2005). Fate, Transport and Persistence of PFOA and Related Chemicals.
Mealey’s C8/PFOA. Science, Risk & Litigation Conference. Lecture conducted from The Rittenhouse Hotel,
Philadelphia, PA.
Paul Rosenfeld Ph.D. (September 19, 2005). Brominated Flame Retardants in Groundwater: Pathways to Human
Ingestion, Toxicology and Remediation PEMA Emerging Contaminant Conference. Lecture conducted from Hilton
Hotel, Irvine California.
Paul Rosenfeld Ph.D. (September 19, 2005). Fate, Transport, Toxicity, And Persistence of 1,2,3-TCP. PEMA
Emerging Contaminant Conference. Lecture conducted from Hilton Hotel in Irvine, California.
Paul Rosenfeld Ph.D. (September 26-27, 2005). Fate, Transport and Persistence of PDBEs. Mealey’s Groundwater
Conference. Lecture conducted from Ritz Carlton Hotel, Marina Del Ray, California.
Paul Rosenfeld Ph.D. (June 7-8, 2005). Fate, Transport and Persistence of PFOA and Related Chemicals.
International Society of Environmental Forensics: Focus on Emerging Contaminants. Lecture conducted from
Sheraton Oceanfront Hotel, Virginia Beach, Virginia.
Paul E. Rosenfeld, Ph.D. Page 6 of 17 March 2025
Paul Rosenfeld Ph.D. (July 21-22, 2005). Fate Transport, Persistence and Toxicology of PFOA and Related
Perfluorochemicals. 2005 National Groundwater Association Ground Water and Environmental Law Conference.
Lecture conducted from Wyndham Baltimore Inner Harbor, Baltimore Maryland.
Paul Rosenfeld Ph.D. (July 21-22, 2005). Brominated Flame Retardants in Groundwater: Pathways to Human
Ingestion, Toxicology and Remediation. 2005 National Groundwater Association Ground Water and
Environmental Law Conference. Lecture conducted from Wyndham Baltimore Inner Harbor, Baltimore Maryland.
Paul Rosenfeld, Ph.D. and James Clark Ph.D. and Rob Hesse R.G. (May 5-6, 2004). Tert-butyl Alcohol Liability
and Toxicology, A National Problem and Unquantified Liability. National Groundwater Association. Environmental
Law Conference. Lecture conducted from Congress Plaza Hotel, Chicago Illinois.
Paul Rosenfeld, Ph.D. (March 2004). Perchlorate Toxicology. Meeting of the American Groundwater Trust.
Lecture conducted from Phoenix Arizona.
Hagemann, M.F., Paul Rosenfeld, Ph.D. and Rob Hesse (2004). Perchlorate Contamination of the Colorado River.
Meeting of tribal representatives. Lecture conducted from Parker, AZ.
Paul Rosenfeld, Ph.D. (April 7, 2004). A National Damage Assessment Model for PCE and Dry Cleaners.
Drycleaner Symposium. California Ground Water Association. Lecture conducted from Radison Hotel, Sacramento,
California.
Rosenfeld, P. E., Grey, M., (June 2003) Two stage biofilter for biosolids composting odor control. Seventh
International In Situ And On Site Bioremediation Symposium Battelle Conference Orlando, FL.
Paul Rosenfeld, Ph.D. and James Clark Ph.D. (February 20-21, 2003) Understanding Historical Use, Chemical
Properties, Toxicity and Regulatory Guidance of 1,4 Dioxane. National Groundwater Association. Southwest Focus
Conference. Water Supply and Emerging Contaminants. Lecture conducted from Hyatt Regency Phoenix Arizona.
Paul Rosenfeld, Ph.D. (February 6-7, 2003). Underground Storage Tank Litigation and Remediation. California
CUPA Forum. Lecture conducted from Marriott Hotel, Anaheim California.
Paul Rosenfeld, Ph.D. (October 23, 2002) Underground Storage Tank Litigation and Remediation. EPA
Underground Storage Tank Roundtable. Lecture conducted from Sacramento California.
Rosenfeld, P.E. and Suffet, M. (October 7- 10, 2002). Understanding Odor from Compost, Wastewater and
Industrial Processes. Sixth Annual Symposium on Off Flavors in the Aquatic Environment. International Water
Association. Lecture conducted from Barcelona Spain.
Rosenfeld, P.E. and Suffet, M. (October 7- 10, 2002). Using High Carbon Wood Ash to Control Compost Odor.
Sixth Annual Symposium on Off Flavors in the Aquatic Environment. International Water Association. Lecture
conducted from Barcelona Spain.
Rosenfeld, P.E. and Grey, M. A. (September 22-24, 2002). Biocycle Composting for Coastal Sage Restoration.
Northwest Biosolids Management Association. Lecture conducted from Vancouver Washington.
Rosenfeld, P.E. and Grey, M. A. (November 11-14, 2002). Using High-Carbon Wood Ash to Control Odor at a
Green Materials Composting Facility. Soil Science Society Annual Conference. Lecture conducted from
Indianapolis, Maryland.
Rosenfeld. P.E. (September 16, 2000). Two stage biofilter for biosolids composting odor control. Water
Environment Federation. Lecture conducted from Anaheim California.
Rosenfeld. P.E. (October 16, 2000). Wood ash and biofilter control of compost odor. Biofest. Lecture conducted
from Ocean Shores, California.
Paul E. Rosenfeld, Ph.D. Page 7 of 17 March 2025
Rosenfeld, P.E. (2000). Bioremediation Using Organic Soil Amendments. California Resource Recovery
Association. Lecture conducted from Sacramento California.
Rosenfeld, P.E., C.L. Henry, R. Harrison. (1998). Oat and Grass Seed Germination and Nitrogen and Sulfur
Emissions Following Biosolids Incorporation with High-Carbon Wood-Ash. Water Environment Federation 12th
Annual Residuals and Biosolids Management Conference Proceedings. Lecture conducted from Bellevue
Washington.
Rosenfeld, P.E., and C.L. Henry. (1999). An evaluation of ash incorporation with biosolids for odor reduction. Soil
Science Society of America. Lecture conducted from Salt Lake City Utah.
Rosenfeld, P.E., C.L. Henry, R. Harrison. (1998). Comparison of Microbial Activity and Odor Emissions from
Three Different Biosolids Applied to Forest Soil. Brown and Caldwell. Lecture conducted from Seattle Washington.
Rosenfeld, P.E., C.L. Henry. (1998). Characterization, Quantification, and Control of Odor Emissions from
Biosolids Application To Forest Soil. Biofest. Lecture conducted from Lake Chelan, Washington.
Rosenfeld, P.E, C.L. Henry, R. Harrison. (1998). Oat and Grass Seed Germination and Nitrogen and Sulfur
Emissions Following Biosolids Incorporation with High-Carbon Wood-Ash. Water Environment Federation 12th
Annual Residuals and Biosolids Management Conference Proceedings. Lecture conducted from Bellevue
Washington.
Rosenfeld, P.E., C.L. Henry, R. B. Harrison, and R. Dills. (1997). Comparison of Odor Emissions from Three
Different Biosolids Applied to Forest Soil. Soil Science Society of America. Lecture conducted from Anaheim
California.
Teaching Experience:
UCLA Department of Environmental Health (Summer 2003 through 20010) Taught Environmental Health Science
100 to students, including undergrad, medical doctors, public health professionals and nurses. The course focused
on the health effects of environmental contaminants.
National Ground Water Association, Successful Remediation Technologies. Custom Course in Sante Fe, New
Mexico. May 21, 2002. Focused on fate and transport of fuel contaminants associated with underground storage
tanks.
National Ground Water Association; Successful Remediation Technologies Course in Chicago Illinois. April 1,
2002. Focused on fate and transport of contaminants associated with Superfund and RCRA sites.
California Integrated Waste Management Board, April and May 2001. Alternative Landfill Caps Seminar in San
Diego, Ventura, and San Francisco. Focused on both prescriptive and innovative landfill cover design.
UCLA Department of Environmental Engineering, February 5, 2002. Seminar on Successful Remediation
Technologies focusing on Groundwater Remediation.
University Of Washington, Soil Science Program, Teaching Assistant for several courses including Soil Chemistry,
Organic Soil Amendments, and Soil Stability.
U.C. Berkeley, Environmental Science Program Teaching Assistant for Environmental Science 10.
Academic Grants Awarded:
California Integrated Waste Management Board. $41,000 grant awarded to UCLA Institute of the Environment.
Goal: To investigate the effect of high carbon wood ash on volatile organic emissions from compost. 2001.
Paul E. Rosenfeld, Ph.D. Page 8 of 17 March 2025
Synagro Technologies, Corona California: $10,000 grant awarded to San Diego State University.
Goal: investigate the effect of biosolids for restoration and remediation of degraded coastal sage soils. 2000.
King County, Department of Research and Technology, Washington State. $100,000 grant awarded to University of
Washington: Goal: To investigate odor emissions from biosolids application and the effect of polymers and ash on
VOC emissions. 1998.
Northwest Biosolids Management Association, Washington State. $20,000 grant awarded to investigate the effect
of polymers and ash on VOC emissions from biosolids. 1997.
James River Corporation, Oregon: $10,000 grant was awarded to investigate the success of genetically engineered
Poplar trees with resistance to round-up. 1996.
United State Forest Service, Tahoe National Forest: $15,000 grant was awarded to investigating fire ecology of the
Tahoe National Forest. 1995.
Kellogg Foundation, Washington D.C. $500 grant was awarded to construct a large anaerobic digester on St. Kitts
in West Indies. 1993
Deposition and/or Trial Testimony:
In the District Court of Harris County Texas
Mt Davis Interest, Inc v Sesco Cement Corp
Cause No 2023-26512
Trial 6-6-2-25
In the United States Southern District of New York
Gallo vs Avon Products Inc., et al
Civil Action No.: 1:23-cv-2023
Deposition 4-24-2025
In Vanderburgh Superior Court 5, County of Vanderburgh, Indiana
Markello v CSX
Civil Action No 82D05-2011-CT-004962
Deposition 3-26-25
Iin the Circuit Court of Cook County Illinois
Jarosiewicz v Northeast Regional Railroad
Case No 2023 L 002290
Deposition 2-27-25
In the District Court 191st Judicial District Dallas County
Acklin v Poly America International
Cause No DC-22-08610
Deposition 1-8-2025
United States District Court, Norther District of California
Asustin Vs Monsanto
Case No 2:23-cv-272
Deposition 12-20-25
In Jefferson Circuit Court Division One, Louisville, Kentucky
Stafford vs, CSX
Case No. 18-CI-001790
Paul E. Rosenfeld, Ph.D. Page 9 of 17 March 2025
Deposition: 8-27-24
In the Twenty-Second Judicial Circuit of St. Louis. State of Missouri
Patricia Godfrey vs, Amtrak
Case No. 2122-CC-00525
Deposition: 7-17-24
In the Circuit Court of Jefferson County Alabama
Linda Early Vs. CSX
Case number CV-2021-00241
Deposition 6-24-24
In the Court of Common Please Lucas County, Ohio
Brenda Conkright vs. CSX
Case No. G-4801-CI-0202102664-000
Deposition: 6-4-24
In the Commonwealth of Kentucky, Greenup Circuit Court
Patsy Sue Napier vs. CSX
Case No. 19-CI-0012
Deposition: 5-8-2-24
In United States District Court of Hawaii
Patrick Feindt, Jr. et al. vs. The United States of America
Case No. 1:22-cv-LEK-KJM
Trial 3-29-24 and 4-5-24
In the District Court of Hood County State of Texas
Artie Gray vs. Exxon Mobil
Case No. C-2018047
Rosenfeld Deposition:4-22-2024
In the Elkhart Superior Court State of Indiana
Estate of Clark Stacy vs. Penn Central Corporation
Cause No 2D01-2001-CT-00007
Rosenfeld Deposition 1-25-2024 and 3-7-2024
In the Circuit Court of Trempealeau County, State of Wisconsin
Michael J. Sylla et al. vs. High-Crush Whitehall LLC
Case No. 2019-CV-63, 2019-CV-64, 2019-CV-65, 2019-CV-66
Rosenfeld Deposition: 3-5-2024
In the Circuit Court of Trempealeau County, State of Wisconsin
Leland Drangstveit vs. High-Crush Blair LLC
Case No. 19-CV-66
Rosenfeld Deposition 3-5-2024
In the Circuit Court of Jefferson County Alabama
Donald Lee Ashworth vs. CSX Transportation Inc.
Case No CV-2021-901261
Rosenfeld Deposition 1-23-2024
In the United States District Court for the Eastern District of Wisconsin
Gary L Siepe vs. Soo Line Railroad
Case No. 2:21-cv-00919
Rosenfeld Deposition 1-19-2024
Paul E. Rosenfeld, Ph.D. Page 10 of 17 March 2025
In the United States District Court for the Western District of Louisiana
Ricky Bush v. Clean Harbors Colfax LLC
Case No. 1:22-cv-02026-DDD-JPM
Rosenfeld Deposition 12-18-2023 and 1-15-2024
In United States District Court of Hawaii
Patrick Feindt, Jr. et al. vs. The United States of America
Case No. 1:22-cv-LEK-KJM
Rosenfeld Deposition 11-29-2023
In the Circuit Court for the Twentieth Judicial Circuit St. Clair County, Illinois
Timothy Gray vs. Rural King et al.
Case No 2022-LA-355
Rosenfeld Deposition 9-26-2023
In United States District Court Eastern District of Wisconsin
Gary L. Siepe vs. Soo Line Railroad Company
Case No. 2:21-cv-00919
Rosenfeld Deposition 9-15-2023
In the Circuit Court of Cook County Illinois
Donald Fox vs. BNSF
Case No. 2021 L12
Rosenfeld Deposition 9-12-2023
In the Court of Common Please Cuyahoga County, Ohio
Thomas Schleich vs. Penn Central Corporation
Lead Case No. CV-20-939184
Rosenfeld Deposition 8-27-2023
In the Circuit Court of Jackson County Missouri at Kansas City
Timothy Dalsing vs. BNSF
Case No. No. 2216-cv06539
Rosenfeld Deposition 7-28-2023
In the United States District Court for the Southern District of Texas Houston Division
International Terminals Company LLC Deer Park Fire Litigation
Lead Case No. 4:19-cv-01460
Rosenfeld Deposition 7-25-2023
In the Circuit Court of Livingston County Missouri
Shirley Ralls vs. Canadian Pacific Railway and Soo Lind Railroad
Case No. 28LV-CV0020
Rosenfeld Daubert Hearing 7-18-2023 Trial Testimony 7-19-2023
In the Circuit Court of Cook County Illinois
Brenda Wright vs. Penn Central and Conrail
Case No. No. 2032L003966
Rosenfeld Deposition 6-13-2023
In the Circuit Court Common Please Philadelphia of Jefferson County Alabama
Frank Belle vs. Birmingham Southern Railroad Company et al.
Case No. 01-cv-2021-900901.00
Rosenfeld Deposition 4-6-2023
Paul E. Rosenfeld, Ph.D. Page 11 of 17 March 2025
In the Circuit Court of Jefferson County Alabama
Linda De Gregorio vs. Penn Central
Case No. 002278
Rosenfeld Deposition 3-27-20203
In the United States District Court Eastern District of New York
Rosalie Romano et al. vs. Northrup Grumman Corporation
Case No. 16-cv-5760
Rosenfeld Deposition 3-16-2023
In the Superior Court of Washington, Spokane County
Judy Cundy vs. BNSF
Case No. 21-2-03718-32
Rosenfeld Deposition 3-9-2023
In The Court of Common Pleas of Philadelphia County, PA Civil Trial Division
Feaster v Conrail
Case No. 001075
Rosenfeld Deposition 2-1-2023
In United States District Court for the Central District of Illinois
Sherman vs. BNSF
Case No. 3:17-cv-01192
Rosenfeld Deposition 1-18-2023
In United States District Court District of Colorado
Gonzales vs. BNSF
Case No. 1:21-cv-01690
Rosenfeld Deposition 1-17-2023
In United States District Court District of Colorado
Abeyta vs. BNSF
Case No. 1:21-cv-01689-KMT
Rosenfeld Deposition 1-3-2023
In United States District Court For The Easter District of Louisiana
Nathaniel Smith vs. Illinois Central Railroad
Case No. 2:21-cv-01235
Rosenfeld Deposition 11-30-2022
In the Superior Court of the State of California, County of San Bernardino
Billy Wildrick, Plaintiff vs. BNSF Railway Company
Case No. CIVDS1711810
Rosenfeld Deposition 10-17-2022
In the State Court of Bibb County, State of Georgia
Richard Hutcherson, Plaintiff vs Norfolk Southern Railway Company
Case No. 10-SCCV-092007
Rosenfeld Deposition 10-6-2022
In the Civil District Court of the Parish of Orleans, State of Louisiana
Millard Clark, Plaintiff vs. Dixie Carriers, Inc. et al.
Case No. 2020-03891
Rosenfeld Deposition 9-15-2022
In The Circuit Court of Livingston County, State of Missouri, Circuit Civil Division
Paul E. Rosenfeld, Ph.D. Page 12 of 17 March 2025
Shirley Ralls, Plaintiff vs. Canadian Pacific Railway and Soo Line Railroad
Case No. 18-LV-CC0020
Rosenfeld Deposition 9-7-2022
In The Circuit Court of the 13th Judicial Circuit Court, Hillsborough County, Florida Civil Division
Jonny C. Daniels, Plaintiff vs. CSX Transportation Inc.
Case No. 20-CA-5502
Rosenfeld Deposition 9-1-2022
In The Circuit Court of St. Louis County, State of Missouri
Kieth Luke et. al. Plaintiff vs. Monsanto Company et. al.
Case No. 19SL-CC03191
Rosenfeld Deposition 8-25-2022
In The Circuit Court of the 13th Judicial Circuit Court, Hillsborough County, Florida Civil Division
Jeffery S. Lamotte, Plaintiff vs. CSX Transportation Inc.
Case No. NO. 20-CA-0049
Rosenfeld Deposition 8-22-2022
In State of Minnesota District Court, County of St. Louis Sixth Judicial District
Greg Bean, Plaintiff vs. Soo Line Railroad Company
Case No. 69-DU-CV-21-760
Rosenfeld Deposition 8-17-2022
In United States District Court Western District of Washington at Tacoma, Washington
John D. Fitzgerald Plaintiff vs. BNSF
Case No. 3:21-cv-05288-RJB
Rosenfeld Deposition 8-11-2022
In Circuit Court of the Sixth Judicial Circuit, Macon Illinois
Rocky Bennyhoff Plaintiff vs. Norfolk Southern
Case No. 20-L-56
Rosenfeld Deposition 8-3-2022, Trial 1-10-2023
In Court of Common Pleas, Hamilton County Ohio
Joe Briggins Plaintiff vs. CSX
Case No. A2004464
Rosenfeld Deposition 6-17-2022
In the Superior Court of the State of California, County of Kern
George LaFazia vs. BNSF Railway Company.
Case No. BCV-19-103087
Rosenfeld Deposition 5-17-2022
In the Circuit Court of Cook County Illinois
Bobby Earles vs. Penn Central et. al.
Case No. 2020-L-000550
Rosenfeld Deposition 4-16-2022
In United States District Court Easter District of Florida
Albert Hartman Plaintiff vs. Illinois Central
Case No. 2:20-cv-1633
Rosenfeld Deposition 4-4-2022
In the Circuit Court of the 4th Judicial Circuit, in and For Duval County, Florida
Barbara Steele vs. CSX Transportation
Paul E. Rosenfeld, Ph.D. Page 13 of 17 March 2025
Case No.16-219-Ca-008796
Rosenfeld Deposition 3-15-2022
In United States District Court Easter District of New York
Romano et al. vs. Northrup Grumman Corporation
Case No. 16-cv-5760
Rosenfeld Deposition 3-10-2022
In the Circuit Court of Cook County Illinois
Linda Benjamin vs. Illinois Central
Case No. No. 2019 L 007599
Rosenfeld Deposition 1-26-2022
In the Circuit Court of Cook County Illinois
Donald Smith vs. Illinois Central
Case No. No. 2019 L 003426
Rosenfeld Deposition 1-24-2022
In the Circuit Court of Cook County Illinois
Jan Holeman vs. BNSF
Case No. 2019 L 000675
Rosenfeld Deposition 1-18-2022
In the State Court of Bibb County State of Georgia
Dwayne B. Garrett vs. Norfolk Southern
Case No. 20-SCCV-091232
Rosenfeld Deposition 11-10-2021
In the Circuit Court of Cook County Illinois
Joseph Ruepke vs. BNSF
Case No. 2019 L 007730
Rosenfeld Deposition 11-5-2021
In the United States District Court For the District of Nebraska
Steven Gillett vs. BNSF
Case No. 4:20-cv-03120
Rosenfeld Deposition 10-28-2021
In the Montana Thirteenth District Court of Yellowstone County
James Eadus vs. Soo Line Railroad and BNSF
Case No. DV 19-1056
Rosenfeld Deposition 10-21-2021
In the Circuit Court Of The Twentieth Judicial Circuit, St Clair County, Illinois
Martha Custer et al. vs Cerro Flow Products, Inc.
Case No. 0i9-L-2295
Rosenfeld Deposition 5-14-2021
Trial October 8-4-2021
In the Circuit Court of Cook County Illinois
Joseph Rafferty vs. Consolidated Rail Corporation and National Railroad Passenger Corporation d/b/a
AMTRAK,
Case No. 18-L-6845
Rosenfeld Deposition 6-28-2021
In the United States District Court For the Northern District of Illinois
Paul E. Rosenfeld, Ph.D. Page 14 of 17 March 2025
Theresa Romcoe vs. Northeast Illinois Regional Commuter Railroad Corporation d/b/a METRA Rail
Case No. 17-cv-8517
Rosenfeld Deposition 5-25-2021
In the Superior Court of the State of Arizona In and For the Cunty of Maricopa
Mary Tryon et al. vs. The City of Pheonix v. Cox Cactus Farm, L.L.C., Utah Shelter Systems, Inc.
Case No. CV20127-094749
Rosenfeld Deposition 5-7-2021
In the United States District Court for the Eastern District of Texas Beaumont Division
Robinson, Jeremy et al vs. CNA Insurance Company et al.
Case No. 1:17-cv-000508
Rosenfeld Deposition 3-25-2021
In the Superior Court of the State of California, County of San Bernardino
Gary Garner, Personal Representative for the Estate of Melvin Garner vs. BNSF Railway Company.
Case No. 1720288
Rosenfeld Deposition 2-23-2021
In the Superior Court of the State of California, County of Los Angeles, Spring Street Courthouse
Benny M Rodriguez vs. Union Pacific Railroad, A Corporation, et al.
Case No. 18STCV01162
Rosenfeld Deposition 12-23-2020
In the Circuit Court of Jackson County, Missouri
Karen Cornwell, Plaintiff, vs. Marathon Petroleum, LP, Defendant.
Case No. 1716-CV10006
Rosenfeld Deposition 8-30-2019
In the United States District Court For The District of New Jersey
Duarte et al, Plaintiffs, vs. United States Metals Refining Company et. al. Defendant.
Case No. 2:17-cv-01624-ES-SCM
Rosenfeld Deposition 6-7-2019
In the United States District Court of Southern District of Texas Galveston Division
M/T Carla Maersk vs. Conti 168., Schiffahrts-GMBH & Co. Bulker KG MS “Conti Perdido” Defendant.
Case No. 3:15-CV-00106 consolidated with 3:15-CV-00237
Rosenfeld Deposition 5-9-2019
In The Superior Court of the State of California In And For The County Of Los Angeles – Santa Monica
Carole-Taddeo-Bates et al., vs. Ifran Khan et al., Defendants
Case No. BC615636
Rosenfeld Deposition 1-26-2019
In The Superior Court of the State of California In And For The County Of Los Angeles – Santa Monica
The San Gabriel Valley Council of Governments et al. vs El Adobe Apts. Inc. et al., Defendants
Case No. BC646857
Rosenfeld Deposition 10-6-2018; Trial 3-7-19
In United States District Court For The District of Colorado
Bells et al. Plaintiffs vs. The 3M Company et al., Defendants
Case No. 1:16-cv-02531-RBJ
Rosenfeld Deposition 3-15-2018 and 4-3-2018
In The District Court Of Regan County, Texas, 112th Judicial District
Phillip Bales et al., Plaintiff vs. Dow Agrosciences, LLC, et al., Defendants
Paul E. Rosenfeld, Ph.D. Page 15 of 17 March 2025
Cause No. 1923
Rosenfeld Deposition 11-17-2017
In The Superior Court of the State of California In And For The County Of Contra Costa
Simons et al., Plaintifs vs. Chevron Corporation, et al., Defendants
Cause No. C12-01481
Rosenfeld Deposition 11-20-2017
In The Circuit Court of The Twentieth Judicial Circuit, St Clair County, Illinois
Martha Custer et al., Plaintiff vs. Cerro Flow Products, Inc., Defendants
Case No.: No. 0i9-L-2295
Rosenfeld Deposition 8-23-2017
In United States District Court For The Southern District of Mississippi
Guy Manuel vs. The BP Exploration et al., Defendants
Case No. 1:19-cv-00315-RHW
Rosenfeld Deposition 4-22-2020
In The Superior Court of the State of California, For The County of Los Angeles
Warrn Gilbert and Penny Gilber, Plaintiff vs. BMW of North America LLC
Case No. LC102019 (c/w BC582154)
Rosenfeld Deposition 8-16-2017, Trail 8-28-2018
In the Northern District Court of Mississippi, Greenville Division
Brenda J. Cooper, et al., Plaintifs, vs. Meritor Inc., et al., Defendants
Case No. 4:16-cv-52-DMB-JVM
Rosenfeld Deposition July 2017
In The Superior Court of the State of Washington, County of Snohomish
Michael Davis and Julie Davis et al., Plaintiff vs. Cedar Grove Composting Inc., Defendants
Case No. 13-2-03987-5
Rosenfeld Deposition, February 2017
Trial March 2017
In The Superior Court of the State of California, County of Alameda
Charles Spain., Plaintiff vs. Thermo Fisher Scientific, et al., Defendants
Case No. RG14711115
Rosenfeld Deposition September 2015
In The Iowa District Court In And For Poweshiek County
Russell D. Winburn, et al., Plaintiffs vs. Doug Hoksbergen, et al., Defendants
Case No. LALA002187
Rosenfeld Deposition August 2015
In The Circuit Court of Ohio County, West Virginia
Robert Andrews, et al. vs. Antero, et al.
Civil Action No. 14-C-30000
Rosenfeld Deposition June 2015
In The Iowa District Court for Muscatine County
Laurie Freeman et. al. Plaintiffs vs. Grain Processing Corporation, Defendant
Case No. 4980
Rosenfeld Deposition May 2015
In the Circuit Court of the 17th Judicial Circuit, in and For Broward County, Florida
Walter Hinton, et. al. Plaintiff, vs. City of Fort Lauderdale, Florida, a Municipality, Defendant.
Paul E. Rosenfeld, Ph.D. Page 16 of 17 March 2025
Case No. CACE07030358 (26)
Rosenfeld Deposition December 2014
In the United States District Court Western District of Oklahoma
Tommy McCarty, et al., Plaintiffs, vs. Oklahoma City Landfill, LLC d/b/a Southeast Oklahoma City
Landfill, et al. Defendants.
Case No. 5:12-cv-01152-C
Rosenfeld Deposition: July 2014
In the County Court of Dallas County Texas
Lisa Parr et al, Plaintiff, vs. Aruba et al, Defendant.
Case Number cc-11-01650-E
Rosenfeld Deposition: March and September 2013
Rosenfeld Trial: April 2014
In the County of Kern, Unlimited Jurisdiction
Rose Propagation Services vs. Heppe Enterprises
Case No. S-1500-CV-278190, LHB
Rosenfeld Deposition: May 2014
In the Circuit Court of Baltimore County Maryland
Philip E. Cvach, II et al., Plaintiffs vs. Two Farms, Inc. d/b/a Royal Farms, Defendants
Case Number: 03-C-12-012487 OT
Rosenfeld Deposition: September 2013
In the Court of Galveston County, Texas 56th Judicial District
MDL Litigation Regarding Texas City Refinery Ultracracker Emission Event Litigation
Cause No. 10-UC-0001
Rosenfeld Deposition: March 2013
Rosenfeld Trial: September 2013
In the United States District Court of Southern District of Texas Galveston Division
Kyle Cannon, Eugene Donovan, Genaro Ramirez, Carol Sassler, and Harvey Walton, each Individually and
on behalf of those similarly situated, Plaintiffs, vs. BP Products North America, Inc., Defendant.
Case 3:10-cv-00622
Rosenfeld Deposition: February 2012
Rosenfeld Trial: April 2013
In the United States District court of Southern District of California
United States of America, Plaintiff vs. 2,560 Acres of Land, more or less, located in Imperial County, State
of California; and Donald L. Crawford, et. al.
Civil No. 3:11-cv-02258-IEG-RBB
Rosenfeld Deposition: December 2012, January 2013
In the Court of Common Pleas of Tuscarawas County Ohio
John Michael Abicht, et al., Plaintiffs, vs. Republic Services, Inc., et al., Defendants
Case No. 2008 CT 10 0741 (Cons. w/ 2009 CV 10 0987)
Rosenfeld Deposition October 2012
In the Court of Common Pleas of Tuscarawas County Ohio
John Michael Abicht, et al., Plaintiffs, vs. Republic Services, Inc., et al., Defendants
Case Number: 2008 CT 10 0741 (Cons. w/ 2009 CV 10 0987)
Rosenfeld Deposition: October 2012
In the United States District Court for the Middle District of Alabama, Northern Division
James K. Benefield, et al., Plaintiffs, vs. International Paper Company, Defendant.
Paul E. Rosenfeld, Ph.D. Page 17 of 17 March 2025
Civil Action No. 2:09-cv-232-WHA-TFM
Rosenfeld Deposition July 2010, June 2011