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AGENDA REPORT 2022 1102 CCSA REG ITEM 08A
CITY OF MOORPARK, CALIFORNIA City Council Meeting of November 2, 2022 ACTION APPROVED STAFF RECOMMENDATION, INCLUDING ADOPTION OF RESOLUTION NO. 2022- 4142. (ROLL CALL VOTE: UNANIMOUS) BY A. Hurtado. A. Consider Resolution Adopting a Mitigated Negative Declaration, Pursuant to the California Environmental Quality Act and Approval of Industrial Planned Development No. 2022-01 and Conditional Use Permit No. 2022-01 to Allow the Development a 90,566 Square Foot Industrial Warehouse Building and Associated Site Work on 5.65 Acres of Property, Located at 10941 Los Angeles Avenue, on the Application of Amir Development on Behalf of Moorpark Lot A, LP. Planning Commission Recommendation: 1) Open the public hearing, receive public testimony, and close the public hearing; and 2) Adopt Resolution No. 2022-4142: a) adopting the Mitigated Negative Declaration and associated Mitigation Monitoring and Reporting Program (MMRP) and b) approving Industrial Planned Development No. 2022-01 and Conditional Use Permit No. 2022-01. (Staff: Shanna Farley, Principal Planner) (ROLL CALL VOTE REQUIRED) Item: 8.A. MOORPARK CITY COUNCIL AGENDA REPORT TO: Honorable City Council FROM: Shanna Farley, Principal Planner DATE: 11/02/2022 Regular Meeting SUBJECT: Consider Resolution Adopting a Mitigated Negative Declaration, Pursuant to the California Environmental Quality Act and Approval of Industrial Planned Development No. 2022-01 and Conditional Use Permit No. 2022-01 to Allow the Development a 90,566 Square-Foot Industrial Warehouse Building and Associated Site Work on 5.65 Acres of Property, Located at 10941 Los Angeles Avenue, on the Application of Amir Development on Behalf of Moorpark Lot A, LP PROJECT DESCRIPTION AND BACKGROUND On January 22, 2022, Keenan Wolens of Amir Development (Applicant) submitted an application for an Industrial Planned Development (IPD) to develop an industrial warehouse and office building, totaling 90,566 square feet. An IPD is required for new industrial developments exceeding 2,500 square feet of floor area. The request also includes a Conditional Use Permit (CUP) to allow a maximum building height of 44 feet, which exceeds the maximum height of 30 feet in the Limited Industrial (M-2) zone, thereby requiring a CUP pursuant to Moorpark Municipal Code (MMC) Section 17.24.035 (Proposed Project, Project). The Project Site includes 5.65 acres, located on an undeveloped and relatively flat lot, located at 10941 Los Angeles Avenue (Assessor Parcel No. 511-0-200-265) (Project Site, Site) as shown on Attachment 1. Detailed exhibits identifying the project area and conceptual improvements are included with Attachment 3 and as shown on Figure 1. Item: 8.A. Figure 1 Project Site Plan 1 Honorable City Council 11/02/2022 Regular Meeting Page 2 On September 27, 2022, the Planning Commission conducted a public hearing to consider the Project. The Planning Commission received a presentation from the applicant. One member of the public spoke during public comment, who suggested that an Environmental Impact Report should have been prepared as opposed to the Mitigated Negative Declaration (MND). A comment letter from the same speaker is attached for reference (Attachment 2) and described further in the Environmental Determination section below. Following deliberation, the Planning Commission unanimously recommended that the City Council approve the Project, consistent with the Recommendation Section of this Report. The Planning Commission’s action included the removal of Condition No. 98, which required undergrounding of utilities, which had previously been waived by the Community Development Director. The proposed Conditions have been included with the City Council Draft Resolution (Attachment 6, Exhibit A). Following the action of the Planning Commission, it was determined that Condition No. 18 inadvertently required payment of a fee that is not applicable to the Project Site. Therefore, Condition No. 18 has been intentionally omitted from the City Council Draft Resolution (Attachment 6, Exhibit A). EXISTING AND SURROUNDING LAND USES A summary of the land use, general plan, and zoning designations of the subject and adjacent properties is provided below in Table 1 and as shown on Attachment 1: Table 1 General Plan, Zoning and Existing Land Use Direction General Plan Zoning / Specific Plan Existing Land Use Project Site Medium Industrial (I-2) Limited Industrial (M-2) Undeveloped North Agricultural (County of Ventura) and Medium Industrial (I-2) Agricultural AE-40 ac (County of Ventura) and Rural Exclusive (RE) Agricultural and Railroad South Agricultural (County of Ventura) Agricultural AE-40 ac (County of Ventura) Agricultural East Medium Industrial (I-2) Development Agreement (DA) Development Agreement (Studio Project) West Medium Industrial (I-2) Limited Industrial (M-2) Industrial Building (Pentair) 2 Honorable City Council 11/02/2022 Regular Meeting Page 3 ANALYSIS General Discussion: The Project consists of the construction of a single-story, 90,566 square-foot industrial warehouse and office. The proposed occupant of the Project is Pentair, which designs, tests, and fabricates pumps, controllers and accessories for pools and spas. Pentair currently operates an existing facility to the west of the Project Site, located at 10951 Los Angeles Avenue. Pentair intends to lease the Project Site, to be used as a warehouse building in conjunction with the existing manufacturing building to the west. General Plan and Specific Plan Consistency: General Plan The General Plan land use designation for the Project Site is Medium Industrial (I-2). The I-2 designation allows for a variety of uses including light manufacturing, processing, fabrication, and other non-hazardous industrial uses. The proposed warehouse use is consistent with the I-2 designation. The Project is consistent with the following General Plan goals and policies: Land Use Element Goal 1: Attain a balanced City growth pattern which includes a full mix of land uses. Policy 1.1: New development and redevelopment shall be orderly with respect to location, timing, and density/intensity; consistent with the provision of local public services and facilities; and compatible with the overall suburban rural community character. Policy 1.4: New development and redevelopment shall be coordinated so that the existing and planned capacity of public facilities and services shall not be adversely impacted. Policy 1.5: A comprehensive planning approach for undeveloped areas of the community shall be followed, to prevent disjointed, incremental expansion of development. GOAL 10: Encourage a diversity of industrial uses which are located and designed in a compatible manner with surrounding land uses. Policy 10.1: New industrial development should be located adjacent to existing industrial uses and along major transportation corridors. Policy 10.2: Industrial uses shall incorporate design features, such as screen walls, landscaping, and setbacks, and include height and lighting restrictions, so as to minimize adverse impacts on adjacent uses and enhance the visual characteristics of the area. 3 Honorable City Council 11/02/2022 Regular Meeting Page 4 Policy 10.3: Industrial uses shall be well maintained to enhance the visual characteristics of the area. Policy 10.4: Industries which are considered to have limited emissions and which meet local, regional, and state air and water pollution control goals and standards should be encouraged to locate within the City. GOAL 12: Ensure that a full range of public facilities and services are provided to meet the needs of the community. Policy 12.6: Developers of new commercial and industrial buildings or expansion projects shall be required to pay the established fee for City park and recreation facilities and services. GOAL 13: Achieve a well-balanced and diversified economy within the City which provides a variety of economic and employment opportunities. Policy 13.1: A balanced job/housing ratio should be encouraged. Policy 13.2: New commercial and industrial uses which will generate long-term employment opportunities and diversify the community's employment base shall be encouraged. Policy 13.4: The City shall work with the business community in a cooperative manner to encourage desired businesses to locate and to remain in the City. GOAL 17: Enhance the physical and visual image of the community. Policy 17.5: New development should incorporate a variety of landscape architecture themes and techniques to help organize and delineate land uses and to enhance the overall visual quality of the City. Policy 17.6: Enhanced landscaping shall be used around residential, commercial and industrial buildings and parking areas as well as along easements of flood control channels, roadways, railroad right of ways, and other public and private areas, to soften the urban environment and enhance views from roadways and surrounding uses. Circulation Element Goal 2: Provide a circulation system which supports existing, approved, and planned land uses throughout the City while maintaining a desired level of service on all streets and at all intersections. 4 Honorable City Council 11/02/2022 Regular Meeting Page 5 Policy 2.1: Level of service “C” shall be the system performance objective for traffic volumes on the circulation system. For roadways and interchanges already operating at less than level of service “C”, the system performance objective shall be to maintain or improve the current level of service. Policy 2.2: Project phasing shall be coordinated with the construction of on-site and off-site circulation improvements to maintain the performance standards objectives specific in Policy 2.1 and to ensure that improvements are in place when needed. Policy 2.3: New development projects shall mitigate off-site traffic impacts to the maximum extent feasible. Policy 2.5: Driveway access points onto arterial roadways shall be limited in number and location in order to ensure the smooth and safe flow of vehicles and bicycles. Policy 2.7: Traffic signal or stop sign installation shall be required at intersections which, based on individual study, are shown to satisfy traffic signal or stop sign warrants. Policy 2.11: Adequate off-street parking shall be provided in all new or expanded projects as part of construction. Goal 5: Provide a citywide system for safe, efficient and attractive bicycle and pedestrian routes for commuter, school, and recreational use. Policy 5.6: Bicycle racks shall be required, and storage facilities shall be encouraged at new or modified public, commercial, and industrial building sites. Development Standards The Project’s compliance with the development standards is outlined in Table 1 below. Table 1 Development Standards Limited Industrial Development Standards *Per MMC 17.24.035 - Height may be increased (to maximum sixty (60) feet) with approval of a conditional use permit. Development Standard Zoning Code Proposed Height 30’* 44’ Floor Area Ratio 0.38 0.37 Setback - Front 20’ 113’ 7” Setback – Interior Side 5’ 61’ Setbacks - Rear 10’ 48’ Minimum Lot Size 10,000 square feet 246,114 square feet Parking 185 Spaces 185 spaces Loading Parking 4 spaces 21 spaces Landscaping 10% of parking area 16.9% of parking area 5 Honorable City Council 11/02/2022 Regular Meeting Page 6 Height The proposed height of 44 feet is generally consistent with the height of existing industrial developments in the City. The existing Pentair building directly to the west of the Project Site is approximately 40-feet high. In addition, the requested deviation from the 30-foot in the Limited Industrial (M-2) zone has been approved on other industrial buildings throughout the City, generally ranging from 30 to 45 feet in height. A similar exception was recently permitted at 5850 Condor Drive for a 41-foot-tall industrial office and warehouse building. In addition, several office and warehouse buildings located on Science Drive, and Patriot Drive have been constructed with heights exceeding 30 feet, ranging from 30 to 40 feet in height. The MMC limits maximum height with a CUP to 60 feet. Figure 3 Project Architecture Renderings 6 Honorable City Council 11/02/2022 Regular Meeting Page 7 Architecture and Building Design The Project includes a one-story tilt-up warehouse building, finished with a variety of materials, including concrete tilt-up panels finished in grey and white, wood siding details near the southwest entrance, metal canopies and window trim and glazed windows, surrounded by a driveway, landscaped areas, and parking. The Project incorporates a modern architectural style, with both horizontal and vertical linear features, and includes colors and materials (Attachment 3 and Figure 3) similar to the adjacent industrial building to the west. The building is primarily oriented towards the southwest corner of the site, where the secondary emergency driveway connects to Los Angeles Avenue/State Route 118 (SR 118). The Proposed building features windows along all elevations of the building, but are primarily focused towards the south facing corners of the building. Truck loading bays are oriented along the western side of the building and are set back 60 feet from the edge of the building to provide screening of the parked trucks and operations of the facility. Circulation The Project is located along SR 118. The Project would have one primary access driveway, along the northern side of the adjacent parcel to the west, to Montair Drive, via an access easement. The Project would also have a secondary emergency access route to the south to SR 118, via a new bridge crossing the Gabbert Channel. An existing access easement across the neighboring property to the west provides the primary access to the Project Site. A Condition of Approval is included to require that an updated easement be drafted to address the existing easement alignment and location of the new access route (Attachment 2). The Project Site includes a circular driveway which surrounds the building. Parking is located around the driveway on all sides. Pedestrian pathways are provided at the southwest corner of the building, primarily for access to handicapped parking. A traffic signal will be installed at the intersection of SR 118 and Montair Drive, as a Mitigation Measure (MM) required by the MND (Attachment 6, Exhibit B), which is further described in the Environmental Determination section below. Parking and Loading The Project includes 185 parking spaces, consisting of 137 standard stalls, 6 accessible stalls, 19 electric vehicle stalls, and 23 clean air or vanpool stalls. MMC Section 17.32.020 requires that the Project provide 185 parking spaces. The Project includes 21 truck loading bays, located on the western side of the building. MMC Section 17.32.030 requires that warehouse uses, over 80,000 square feet provide three loading spaces, plus one additional space for each additional 100,000 square feet. The Project proposes a total of 87,566 square feet of warehouse space and 3,000 square feet of office space. As such, the Project requires four loading spaces, where 21 spaces are provided, therefore the Project complies with the loading space requirement. 7 Honorable City Council 11/02/2022 Regular Meeting Page 8 Landscaping The Project proposes 26,295 square feet of landscaping of 10% of the Project Site and 16.9% of the parking area. The MMC requires that a minimum of 10% of the parking area to be landscaped, which the Project complies with. In addition, MMC Section 17.32.070 requires that at least 10% of the parking area be provided as landscaping, which the Project exceeds. The Project proposes a parking area of 155,548 square feet, which would require at least 15,555 square feet of landscaping. Therefore, the Project landscaping meets and exceeds the MMC parking lot landscape requirement. The Project’s landscape pallet includes a mix of trees, shrubs, and groundcover which include various flowering species, with both evergreen and deciduous plant types. Proposed tree types vary in height and width and would provide interest and variation along the street frontages and from a distance. A low hedge is proposed along the frontage to provide screening of the parking lot from SR 118. Many of the proposed landscape plants are drought tolerant and well suited to the local arid climate. The MMC also requires that a project comply with the City’s Landscape Standards and Guidelines. In addition, the Project is required to meet fire prevention requirements provided by the Ventura County Fire Department. As such, the proposed Project was reviewed by both City and Fire Department staff to ensure compatibility and compliance with both landscape standards. Slight deviation from the City’s Landscape Standards and Guidelines were found to be acceptable in consideration of more restrictive fuel modification standards required by the Ventura County Fire Department, due to the Project’s location near the High Fire Severity Zone. In addition, landscape planting along the Project frontage was limited by two existing easements for the County of Ventura Watershed Protection District and Waterworks District No. 1 related to the Gabbert Channel and water lines that run east to west along the front of the property. Such deviations include a reduced number of trees atop the easements, where only groundcover and small shrubs can be allowed. Although deviations were required to achieve landscape plan compliant with easements and fire safety requirements, the Project continues to provide adequate trees, shrubs, and ground cover to provide aesthetic screening and shade on the Project Site, consistent with other industrial buildings in the City and the adjacent Pentair site to the west. Grading and Drainage The Project Site is relatively flat and will require limited onsite grading, with cut and fill to be balanced onsite. The Project will require no import or export of soil to or from the site. The Project includes the installation of an underground storm water detention and infiltration system. Undergrounding Utilities Pursuant to MMC Section 17.36.050.A.1, projects located in an industrial zone are required to underground utilities on their sites. This requirement may be waived by the Community Development (CD) Director where it can be shown that the requirement would be an undue hardship or constitute an unreasonable requirement. As such, on August 30, 8 Honorable City Council 11/02/2022 Regular Meeting Page 9 2022, the Applicant requested that the CD Director waive the requirement for the undergrounding of one utility transmission pole, located on the southern side of the Project Site along the SR 118. Due to the location of the pole along the highway, the voltage, existing drainage channel and the number and scale of utilities located on the pole, the CD Director has approved a waiver of the requirement for undergrounding for this Project. ENVIRONMENTAL DETERMINATION In accordance with the City’s environmental review procedures adopted by Resolution No. 2004-2224, the Community Development Director or designee determines the level of review necessary for a project to comply with California Environmental Quality Act (CEQA). Some projects may be exempt from review based upon a specific category listed in CEQA. Other projects may be exempt under a general rule that environmental review is not necessary where it can be determined that there would be no possibility of a significant effect upon the environment. A project which does not qualify for an exemption requires the preparation of an Initial Study (IS) to assess the level of potential environmental impacts. An Initial Study and MND (State Clearinghouse Number 2022070289) was prepared by the City for the Project, which analyzed potential environmental factors that may be affected by the Project (Attachment 5). The Project’s environmental determination identifies potentially significant impacts associated with biological resources, cultural resources, land use and planning, and transportation as discussed below in more detail. Each of these impacts are reduced to a less than significant level with the inclusion of specific mitigation measures (MMs) included in the Mitigation Monitoring and Reporting Program (MMRP) (Attachment 6, Exhibit B). The MND analyzes the Project, existing conditions within the Project area, the potential environmental impacts of implementing the Project, the impacts of the Project alongside pending and approved development projects and identifies mitigation measures to minimize significant impacts. The appendices to the MND include documentation of the technical studies and site surveys that provide the basis for the findings described in the MND. A Notice of Intent to Adopt the MND was published on July 18, 2022. Pursuant to CEQA Section 15073, a public review period of not less than 30 days is provided when a proposed MND is submitted to the State Clearinghouse for review by state agencies, which concluded on August 17, 2022. The City received seven comments regarding the MND. Comments provided during the public review period were analyzed and responded to in the MND. The comments provided did not warrant further analysis. Notification of the publication of the MND was provided to the commenting agencies and individuals. The City Council is the approval body for the certification of the MND following recommendation by the Planning Commission. 9 Honorable City Council 11/02/2022 Regular Meeting Page 10 Biological Resources One potential significant impact was identified associated with the potential adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife. The MMs proposed below would minimize potential impacts to biological resources to less than significant. The MMs proposed below would minimize potential impacts to nesting birds protected under the Migratory Bird Act and any special status species or wildlife to a less than significant level. • MM Bio-1 requires that if construction activities are to occur between February 1 and September 15, the applicant would be required to conduct a nesting bird survey by a biologist to ensure that if nesting birds exist on the site, they are avoided and protected by a 500-foot buffer. • MM Bio-2 requires that a qualified biologist shall be onsite prior to and during ground disturbing activities to move out of harm’s way any special status species or other wildlife that have low mobility and would be injured or killed during construction activities. • MM Bio-3 also requires that grubbing be conducted so as to avoid habitat that may a refuge for certain wildlife, can be avoided or relocated to avoid hard to such wildlife. Cultural Resources One potential significant impact was identified associated with the potential adverse effect on an archaeological resource. The MMs proposed below would minimize potential impacts to cultural resources to less than significant. • MM Cul-1 requires the applicant to have a qualified archeologist on call should the ground disturbing activities on the site unearth cultural or archeological resources. MM Cul-1 also requires that all construction personnel be provided a training about procedures to follow should cultural or archeological resources be found. In addition, a tribal monitor will be provided the opportunity to attend the pre- construction training. • MM Cul-2 requires that the Project’s archeologist prepare an Archaeological Resources Monitoring Report summarizing all monitoring efforts and observations, as performed, and any and all prehistoric or historic archaeological finds. Lastly, as a Condition of Approval, should inadvertent discovery of human remains be found during ground disturbing activities, procedures to stop work and contact the appropriate agencies is outlined. Land Use and Planning One potential significant impact was identified associated with the potential adverse effect related to conflicts with land use plan, policy or regulation adopted for the purpose of 10 Honorable City Council 11/02/2022 Regular Meeting Page 11 avoiding or mitigating environmental impacts. In this case, the Project would generate traffic impacts which are inconsistent with traffic standards identified by the City. Per the City of Moorpark Guidelines for Preparing Traffic and Circulation Studies and General Plan Circulation element Policy 2.1, a Level of Service (LOS) degradation of one level or greater below LOS C attributable to the Project will be considered significant enough to require MMs. In addition, depending on the circumstances, less than one level of LOS degradation may be considered significant as well. A traffic study was prepared to analyze 12 intersections in the Project’s vicinity to consider potential impacts generated by the Project to operations of the roadways. Based on these criteria, levels of service (LOS) degradation were identified at the SR 118 and Montair Drive and SR 118 and State Route 23 (SR 23) Southbound Ramps. The Traffic Study included mitigation for the Proposed Project that included a new traffic signal at the intersection of SR 118 and Montair Drive, which would improve the LOS to LOS D or higher for all scenarios. For the SR 118 and SR 23 Southbound Ramps intersection, the Traffic Study found that the Proposed Project would contribute less than 0.001 to the volume to capacity ratio. With the implementation of MM LU-1 and MM LU-2 (below), LOS impacts at the intersection of SR 118 and Montair Drive would be reduced to a level less than significant. • MM LU-1 requires that the Project install a signal at the intersection of SR 118 and Montair Drive. • MM LU-2 restricts the use of the driveway on SR 118 to emergency vehicles only and design to accommodate emergency vehicle turning requirements. Transportation Two potential significant impacts were identified associated with the potential adverse effects related to; first, conflicts with a program, plan, ordinance or policy addressing the circulation system, including transit, roadways, bicycle and pedestrian facilities and second to conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b). Both related potential impacts are associated with air quality and traffic related impacts associated with Vehicle Miles Traveled (VMT) standards. The MM noted below would reduce the two potential impacts to less than significant. • MM TRA-1 requires that the Project provide an employee vanpool program that requires at least 12 percent employee participation. As part of this program, the employer will provide vehicles, labor costs associated with the driver and other incentives to encourage employee participation. As an alternative, resulting in the same reduction in VMT, the Project could select from the following trip reduction measures: rideshare incentive programs, ride matching services, discounted transit expense program, end of trip facilities, or telecommuting/alternative work schedules. Environmental Determination Comment Letter On September 27, 2022, a comment letter from Lozeau Drury, LLP was submitted to the City regarding the Project and associated MND (Attachment 2). The letter contests that the MND inadequately addresses environmental impacts and, in their opinion, should 11 Honorable City Council 11/02/2022 Regular Meeting Page 12 have required the preparation of an Environmental Impact Report (EIR). The letter claims that there are potential significant impacts associated with biological and air quality resources due to the Project. Biological Resources The comment letter includes information regarding a site visit conducted by the Lozeau Drury, LLP’s biologist on August 8, 2022. The letter includes a description of the biologist’s site visit and indicates their observations at that time. Although the letter suggests that possible special-status species have a potential for occurring on the site, based on the California Natural Diversity Database (CNDDB), the biologist also did not find any of the identified species residing or nesting on the site. Rather, the report indicates that two types of raptors (Cooper’s hawk and American kestrel) were identified as hunting or flying on or near the site. The letter notes that the kestrel’s were nesting nearby but does not note where the nests were specifically observed. The Project Site has no onsite trees and very limited brush on the site, as the site in nearly free of vegetation. Although nesting may occur offsite, the Project would not have a direct impact on those offsite nests. The letter claims that biological survey conducted to prepare the MND was insufficient and although their resulting survey also did not indicate onsite protected animal or plant species, they suggest that a more thorough and lengthier inventory be conducted and that assumptions be made about possible wildlife that may or may not visit a site, to be more precautionary and thereby include additional mitigation measures and compensation. The letter suggests that only one such mitigation is included “MM Bio-1”, although the MMRP includes the following three MMs to address onsite wildlife prior to construction. Although the letter suggests that additional mitigations and compensation be provided, evidence supporting the need to mitigate such impacts has not been identified through the preparation of the MND nor as provided in the subject letter as being observed or documented on or adjacent to the Project Site. Nesting Bird Survey MM Bio-1 requires that if construction activities are to occur between February 1 and September 15, the applicant would be required to conduct a nesting bird survey by a biologist to ensure that if nesting birds exist on the site, they are avoided and protected by a 500-foot buffer. Biological Monitor MM Bio-2 requires that a qualified biologist shall be onsite prior to and during ground disturbing activities to move out of harm’s way any special status species or other wildlife that have low mobility and would be injured or killed during construction activities. Grubbing / Wildlife Relocation MM Bio-3 also requires that grubbing be conducted so as to avoid habitat that may a refuge for certain wildlife, can be avoided or relocated to avoid hard to such wildlife. 12 Honorable City Council 11/02/2022 Regular Meeting Page 13 Air Quality Resources The comment letter also includes a claim that the MND fails to adequately assess potential air pollution emissions associated with thresholds for emissions generated by architectural coatings (ROC/VOC). The letter claims that the MND inaccurately determined that the Project would have less than a significant impact based on the provided construction related emissions standards. The letter fails to note that a similar concern was addressed in the MND, as identified in the response to comments to the Ventura County Air Pollution Control District (VCAPCD) letter dated August 10, 2022. The MND response to comments, referenced on page 19-22 of the MND, notes that the initial estimates provided in the emissions calculations included an over estimate for emissions related to construction coatings and that the modeling was subsequently rerun with the model adjusted to the appropriate VCAPCD standard and that the resulting calculations lead to an emission level of less than the threshold of 25 pounds per day and therefore the project would result in less than significant impact for the associated air quality standard. The MND and its appendices were updated to address the corrected calculations. Although the letter suggests that additional mitigation measures are warranted should a significant impact be accounted for, the adjusted analysis indicates that no such impact occurs as a result of the Project. Therefore, no further analysis or mitigation is warranted. The letter also suggests that diesel particulate matter (DPM) emissions generated by diesel-powered equipment was insufficiently analyzed in the MND. As noted on pages 71-72 of the MND, the Project would use a limited number of heavy-duty construction equipment during a short-term construction schedule, which would generate limited emissions during such work. The Project Site is also not located adjacent to or near any sensitive receptors, the nearest residence is located over 1,300 feet to the east. In addition, the MND notes that the Project’s estimated truck delivery schedule would fall well below the threshold of vehicle emissions impacts related to a truck distribution facility that would otherwise warrant a health risk analysis per California Air Pollution Control Officers Association (CAPCOA). In conclusion, although the comment letter raises important concerns related to the application of the CEQA, the MND prepared for the Project addresses the requirements of CEQA through a substantive and evidence-based analysis of the Project and the potential impacts which it may generate. In addition, the MND was circulated to various agencies with expertise and regulatory authority to consider the MND and their related comments were addressed and incorporated in the MND after a 30-day review process. Therefore, staff concludes that the MND adequately addresses the legal obligations under CEQA and no revisions or changes to the Project, MND or MMRP are proposed. PROCESSING TIME LIMITS Time limits have been established for the processing of development projects under the Permit Streamlining Act (Government Code Title 7, Division 1, Chapter 4.5), the Subdivision Map Act (Government Code Title 7, Division 2), and the California 13 Honorable City Council 11/02/2022 Regular Meeting Page 14 Environmental Quality Act (CEQA) Statutes and Guidelines (Public Resources Code Division 13, and California Code of Regulations, Title 14, Chapter 3). Under the applicable provisions of these regulations, the following timelines have been established for action on this Project: Date Application Filed: January 22, 2022 Date Application Determined Complete: February 1, 2022 Original City Council Action Deadline: July 31, 2022 Extended1 City Council Action Deadline: October 29, 2022 Extended2 City Council Action Deadline: November 2, 2022 NOTICING Public Notice for this meeting was provided in accordance with Chapter 17.44.070 of the Zoning Ordinance, as follows: 1. Publication. The notice of the public hearing was published in the Ventura County Star on October 21, 2022. 2. Mailing. The notice of the public hearing was mailed on October 21, 2022, to owners of real property, as identified on the latest adjusted Ventura County Tax Assessor Rolls, within 1,000 feet of the exterior boundaries of the assessor’s parcel(s) subject to the hearing. 3. Sign. One 32 square-foot sign was placed on the street frontage on October 10, 2022. FISCAL IMPACT There are no direct fiscal impacts associated with this request. COUNCIL GOAL COMPLIANCE This action does not support a current strategic directive. 1 On May 11, 2022, the Applicant granted a 90-day extension to the timelines outlined in the Permit Streamlining Act to complete the CEQA review of the Project and proceed to hearing. 2 On September 30, 2022, the Applicant requested further extension of the timelines outlined in the Permit Streamlining Act to accommodate the applicant’s availability to participate in the hearing. 14 Honorable City Council 11/02/2022 Regular Meeting Page 15 PLANNING COMMISSION RECOMMENDATION (ROLL CALL VOTE REQUIRED) Planning Commission recommends that the City Council: 1. Open the public hearing, receive public testimony, and close the public hearing; and 2. Adopt Resolution No. 2022-____: a) adopting the Mitigated Negative Declaration and associated Mitigation Monitoring and Reporting Program (MMRP) and b) approving Industrial Planned Development No. 2022-01 and Conditional Use Permit No. 2022-01. Attachment 1: Project Maps (Project Vicinity Map, Aerial Photo, General Plan, and Zoning Maps) Attachment 2: Public Comments Received Prior to October 27, 2022 Attachment 3: Project Plans – Architectural, Civil, and Landscaping Attachment 4: Planning Commission Resolution No. PC-2022-680, without Exhibits included below in Attachment 6 Attachment 5: Initial Study/Mitigated Negative Declaration and Mitigation Monitoring and Reporting Program (State Clearinghouse No. 2022070289) incorporated by reference: www.moorparkca.gov/1070/Pentair- Expansion Attachment 6: Draft Resolution No. 2022-____, including: Exhibit A: Conditions of Approval Exhibit B: Mitigation Monitoring and Reporting Program 15 Location Map - 10941 Los Angeles Avenue ATTACHMENT 1 16 Aerial Map 17 General Plan 18 Zoning 19 September 27, 2022 Via E-mail Leanne Alva, Commissioner Chris Barrett, Commissioner Jeff Brodsly, Commissioner Kipp Landis, Commissioner Bruce Rokos, Commissioner Planning Commission City of Moorpark 799 Moorpark Ave. Moorpark, CA 93021 planning@moorparkca.gov Freddy A. Carrillo, Associate Planner II City of Moorpark 799 Moorpark Avenue Moorpark, CA 93021 fcarrillo@moorparkca.gov Shanna Farley, Principal Planner City of Moorpark 799 Moorpark Avenue Moorpark, CA 93021 sfarley@moorparkca.gov Re: Comment on the Mitigated Negative Declaration (MND) for the Pentair Warehouse Expansion Project, Planning Commission September 27, 2022 Meeting Agenda Item 8.A Dear Honorable Planning Commissioners Alva, Barrett, Brodsly, Landis, and Rokos, Ms. Farley, and Mr. Carrillo: I am writing on behalf of Supporters Alliance for Environmental Responsibility (“SAFER”) regarding the Initial Study and Mitigated Negative Declaration (“IS/MND”), SCH No. 2022070289, prepared for the Pentair Warehouse Expansion Project, including all actions related or referring to the proposed construction of a 90,566-square-foot industrial building for Pentair Pool Products located at 10941 Los Angeles Avenue, Moorpark, California (Assessor’s Parcel Number 511-0-200-265) (“Project”), to be heard as Agenda Item 8.A at the September 27, 2022 Planning Commission Meeting. After reviewing the IS/MND, we conclude the IS/MND fails as an informational document, and that there is a fair argument that the Project may have adverse environmental impacts. Therefore, we request that the City of Moorpark prepare an environmental impact report (“EIR”) for the Project pursuant to the California Environmental Quality Act (“CEQA”), Public Resources Code (“PRC”) section 21000, et seq. ATTACHMENT 2 20 Comment on MND, Pentair Warehouse Expansion Project Planning Commission Meeting Agenda Item 8.A September 27, 2022 Page 8 of 18 This comment has been prepared with the assistance of expert wildlife biologist Dr. Shawn Smallwood, Ph.D., and environmental consulting firm Soil/Water/Air Protection Enterprise (“SWAPE”). Dr. Smallwood’s comment and curriculum vitae are attached as Exhibit A hereto and is incorporated herein by reference in its entirety. SWAPE’s comment and curriculum vitae are attached as Exhibit B hereto and is incorporated herein by reference in its entirety. I. PROJECT DESCRIPTION The proposed Pentair Warehouse Expansion Project involves an Industrial Planned Development Permit (IPD) and Conditional Use Permit (CUP) to develop a 90,566 square-foot industrial building and associated site improvements on 5.65 acres of vacant land adjacent and directly to the east of the existing facility located at 10951 Los Angeles Avenue in Moorpark, Ventura County, California. (IS/MND, p. 1.) The Amir Development Company is the developer and has submitted applications for the IPD and CUP for the proposed Project on behalf of the applicant Moorpark Lot A, LP. (Id.) Of the 90,566 square footage, 3,000 square feet is planned for office space and 87,566 square feet for warehousing. The building is proposed to be a one-story building, approximately 44 feet in height, as a Type III-B concrete tilt-up structure. (Id., p. 5.) The Applicant is proposing 21 truck-loading spaces with 3 grade-level doors and 185 parking spaces, including 6 accessible stalls, 137 standard stalls, 19 electric vehicle (EV) stalls, and 23 clean air/van pool stalls. (Id.) According to the IS/MND, Pentair Pool Products (“Pentair”) is the intended occupant of the Project. (Id., p. 1.) Pentair is the largest producer of consumer and commercial pool equipment within the United States and has conducted business in the city of Moorpark since 1987. (Id.) The IS/MND states that Pentair is also the largest employer for the city, providing approximately 700 jobs at the time that the draft IS/MND was published in July 2022. (IS/MND, p. 1.) According to the IS/MND, the reasoning for the Project is due to Pentair having outgrown its 234,000-square-foot existing building and is seeking to expand its operation with an additional building within Moorpark. (Id.) The proposed industrial building will be occupied by Pentair for warehousing and storage of raw material and distribution of finished goods including pool equipment and accessories. The Project site is located on the north side of California State Route 118 (Los Angeles Avenue) and east of Montair Drive. (Id.) The site is adjacent to an industrial building operated by Pentair, a vacant lot to the east, and agricultural uses to the south and north of the Project site. (Id.) The Union Pacific Railroad right-of-way is also located to the north of the subject property. (Id.) The City of Moorpark (“City”) is the lead agency for the Proposed Project. The City finds that the IS has been prepared in accordance with CEQA (PRC § 21000 et seq.) and CEQA Guidelines (Title 14, California Code of Regulations [“CCR”], § 15000 et seq.), and has 21 Comment on MND, Pentair Warehouse Expansion Project Planning Commission Meeting Agenda Item 8.A September 27, 2022 Page 8 of 18 determined that preparation of an MND would be appropriate under CEQA. We believe the City’s findings are incorrect and that an EIR should be prepared. II. LEGAL STANDARD As the California Supreme Court has held, “[i]f no EIR has been prepared for a nonexempt project, but substantial evidence in the record supports a fair argument that the project may result in significant adverse impacts, the proper remedy is to order preparation of an EIR.” (Communities for a Better Env’t v. South Coast Air Quality Mgmt. Dist. (2010) 48 Cal.4th 310, 319–20 [“CBE v. SCAQMD”] [citing No Oil, Inc. v. City of Los Angeles (1974) 13 Cal.3d 68, 75, 88; Brentwood Assn. for No Drilling, Inc. v. City of Los Angeles (1982) 134 Cal.App.3d 491, 504-505].) “Significant environmental effect” is defined very broadly as “a substantial or potentially substantial adverse change in the environment.” (Pub. Res. Code (“PRC”) § 21068; see also, 14 CCR § 15382.) An effect on the environment need not be “momentous” to meet the CEQA test for significance; it is enough that the impacts are “not trivial.” (No Oil, Inc., 13 Cal.3d at 83.) “The ‘foremost principle’ in interpreting CEQA is that the Legislature intended the act to be read so as to afford the fullest possible protection to the environment within the reasonable scope of the statutory language.” (Communities for a Better Env’t v. Cal. Res. Agency (2002) 103 Cal.App.4th 98, 109 [“CBE v. CRA”].) The EIR is the very heart of CEQA. (Bakersfield Citizens for Local Control v. City of Bakersfield (2004) 124 Cal.App.4th 1184, 1214 [“Bakersfield Citizens”]; Pocket Protectors v. City of Sacramento (2004) 124 Cal.App.4th 903, 927.) The EIR is an “environmental ‘alarm bell’ whose purpose is to alert the public and its responsible officials to environmental changes before they have reached the ecological points of no return.” (Bakersfield Citizens, 124 Cal.App.4th at 1220.) The EIR also functions as a “document of accountability,” intended to “demonstrate to an apprehensive citizenry that the agency has, in fact, analyzed and considered the ecological implications of its action.” (Laurel Heights Improvements Assn. v. Regents of Univ. of Cal. (1988) 47 Cal.3d 376, 392.) The EIR process “protects not only the environment but also informed self-government.” (Pocket Protectors, 124 Cal.App.4th at 927.) An EIR is required if “there is substantial evidence, in light of the whole record before the lead agency, that the project may have a significant effect on the environment.” (PRC § 21080(d); see also, Pocket Protectors, 124 Cal.App.4th at 927.) In very limited circumstances, an agency may avoid preparing an EIR by issuing a negative declaration, a written statement briefly indicating that a project will have no significant impact thus requiring no EIR (14 CCR § 15371), only if there is not even a “fair argument” that the project will have a significant environmental effect. (PRC §§ 21100, 21064.) Since “[t]he adoption of a negative declaration . . . has a terminal effect on the environmental review process,” by allowing the agency “to dispense with the duty [to prepare an EIR],” negative declarations are allowed only in cases where “the proposed project will not affect the environment at all.” (Citizens of Lake Murray v. San Diego (1989) 129 Cal.App.3d 436, 440.) Mitigation measures may not be construed as project design elements or features in an 22 Comment on MND, Pentair Warehouse Expansion Project Planning Commission Meeting Agenda Item 8.A September 27, 2022 Page 8 of 18 environmental document under CEQA. The MND must “separately identify and analyze the significance of the impacts … before proposing mitigation measures….” (Lotus vs. Department of Transportation (2014) 223 Cal.App.4th 645, 658.) A “mitigation measure” is a measure designed to minimize a project’s significant environmental impacts, (PRC § 21002.1(a)), while a “project” is defined as including “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 Guidelines § 15378(a).) Unlike mitigation measures, project elements are considered prior to making a significance determination. Measures are not technically “mitigation” under CEQA unless they are incorporated to avoid or minimize “significant” impacts. (PRC § 21100(b)(3).) To ensure that the project’s potential environmental impacts are fully analyzed and disclosed, and that the adequacy of proposed mitigation measures is considered in depth, mitigation measures that are not included in the project’s design should not be treated as part of the project description. (Lotus, 223 Cal.App.4th at 654-55, 656 fn.8.) Mischaracterization of a mitigation measure as a project design element or feature is “significant,” and therefore amounts to a material error, “when it precludes or obfuscates required disclosure of the project’s environmental impacts and analysis of potential mitigation measures.” (Mission Bay Alliance v. Office of Community Investment & Infrastructure (2016) 6 Cal.App.5th 160, 185.) Where an initial study shows that the project may have a significant effect on the environment, a mitigated negative declaration may be appropriate. However, a mitigated negative declaration is proper only if the project revisions would avoid or mitigate the potentially significant effects identified in the initial study “to a point where clearly no significant effect on the environment would occur, and…there is no substantial evidence in light of the whole record before the public agency that the project, as revised, may have a significant effect on the environment.” (PRC §§ 21064.5, 21080(c)(2); Mejia v. City of Los Angeles (2005) 130 Cal.App.4th 322, 331.) In that context, “may” means a reasonable possibility of a significant effect on the environment. (PRC §§ 21082.2(a), 21100, 21151(a); Pocket Protectors, 124 Cal.App.4th at 927; League for Protection of Oakland’s etc. Historic Res. v. City of Oakland (1997) 52 Cal.App.4th 896, 904–05.) Under the “fair argument” standard, an EIR is required if any substantial evidence in the record indicates that a project may have an adverse environmental effect—even if contrary evidence exists to support the agency’s decision. (14 CCR § 15064(f)(1); Pocket Protectors, 124 Cal.App.4th at 931; Stanislaus Audubon Society v. County of Stanislaus (1995) 33 Cal.App.4th 144, 150-51; Quail Botanical Gardens Found., Inc. v. City of Encinitas (1994) 29 Cal.App.4th 1597, 1602.) The “fair argument” standard creates a “low threshold” favoring environmental review through an EIR rather than through issuance of negative declarations or notices of exemption from CEQA. (Pocket Protectors, 124 Cal.App.4th at 928.) The “fair argument” standard is virtually the opposite of the typical deferential standard accorded to agencies. As a leading CEQA treatise explains: 23 Comment on MND, Pentair Warehouse Expansion Project Planning Commission Meeting Agenda Item 8.A September 27, 2022 Page 8 of 18 This ‘fair argument’ standard is very different from the standard normally followed by public agencies in their decision making. Ordinarily, public agencies weigh the evidence in the record and reach a decision based on a preponderance of the evidence. [Citation]. The fair argument standard, by contrast, prevents the lead agency from weighing competing evidence to determine who has a better argument concerning the likelihood or extent of a potential environmental impact. (Kostka & Zishcke, Practice Under the CEQA, §6.37 (2d ed. Cal. CEB 2021).) The Courts have explained that “it is a question of law, not fact, whether a fair argument exists, and the courts owe no deference to the lead agency’s determination. Review is de novo, with a preference for resolving doubts in favor of environmental review.” (Pocket Protectors, 124 Cal.App.4th at 928 [emphasis in original].) CEQA requires that an environmental document include a description of the project’s environmental setting or “baseline.” (CEQA Guidelines § 15063(d)(2).) The CEQA “baseline” is the set of environmental conditions against which to compare a project’s anticipated impacts. (CBE v. SCAQMD, 48 Cal.4th at 321.) CEQA Guidelines section 15125(a) states, in pertinent part, that a lead agency’s environmental review under CEQA: …must include a description of the physical environmental conditions in the vicinity of the project, as they exist at the time [environmental analysis] is commenced, from both a local and regional perspective. This environmental setting will normally constitute the baseline physical conditions by which a Lead Agency determines whether an impact is significant. (See Save Our Peninsula Committee v. County of Monterey (2001) 87 Cal.App.4th 99, 124-25 (“Save Our Peninsula”).) As the court of appeal has explained, “the impacts of the project must be measured against the ‘real conditions on the ground,’” and not against hypothetical permitted levels. (Id. at 121-23.) III. DISCUSSION A. THERE IS SUBSTANTIAL EVIDENCE THAT THE PROJECT WILL HAVE SIGNIFICANT BIOLOGICAL RESOURCE IMPACTS REQUIRING AN EIR. Expert wildlife biologist Dr. Shawn Smallwood, Ph.D., concluded that the Project may have significant impacts on several special-status species. An EIR is required to mitigate these impacts. Dr. Smallwood’s conclusions were informed by the site visit he conducted with wildlife biologist Noriko Smallwood in August 2022. Dr. Smallwood and Noriko Smallwood visited the site of the proposed Project for 2.5 hours from 06:09 to 08:39 hours on August 8, 2022. Dr. Smallwood’s expert comments and curriculum vitae are attached hereto as Exhibit A. 24 Comment on MND, Pentair Warehouse Expansion Project Planning Commission Meeting Agenda Item 8.A September 27, 2022 Page 8 of 18 1. The Wildlife Baseline Relied upon by the IS/MND is Woefully Inadequate. Wildlife biologist Dr. Smallwood’s review of the impacts to wildlife from the Project concluded that the Project may have significant impacts on several special-status species. An EIR is required to analyze these impacts. According to the IS/MND and the Biological Resources Reconnaissance Assessment (“BRRA”), included as Appendix B to the IS/MND, a search of the California Natural Diversity Database (“CNDDB”) identified 38 special-status species as having the potential to occur within the Project site. (IS/MND, p. 23.) Regardless, the IS/MND and BRRA incorrectly concluded that the Project’s impacts to protected species will be less than significant because: “none of the [38 special-status] species were found on site, and necessary habitat does not occur on site. Therefore, all potential special status plant and animal species are considered absent from the survey area.” (Id. [emphasis added].) However, as Dr. Smallwood points out, the IS/MND fails to adequately analyze and mitigate Project impacts to special-status species. (See, e.g., Ex. A, pp. 1-20.) Dr. Smallwood concludes that “[a] fair argument can be made for the need to prepare an EIR that is better informed by biological resources surveys and by appropriate interpretation of survey outcomes for the purpose of characterizing the wildlife community as part of the current environmental setting.” (Id., p. 10.) The IS/MND’s baseline for biological impacts is inadequate, incomplete, and understates the biological values at the Project site for several reasons. (See, Ex. A, pp. 10-20.) First, the IS/MND improperly relies on a single reconnaissance-level survey that was insufficient and conducted using minimal effort. According to the IS/MND and BRRA, a reconnaissance-level survey was conducted by Chambers Group in December 2021. (IS/MND, Appendix B, p. 2.) Two biologists walked over the site for 2 hours, from 10:30 to 12:30, on December 16, 2021. (Id.) Chambers Group (2022) performed wildlife surveys “to document existing vegetation communities, identify special status species with a potential for occurrence, and map habitats that could support special status wildlife species….” (Id., p. 1.) The IS/MND reports that “none of the [38 special-status] species were found on site.” (IS/MND, p. 23.) However, Dr. Smallwood notes that Chambers Group’s reported finding is inadequate because it was “reported out of context” and based on an “insufficient survey effort committed to the site.” (Ex. A, p. 13.) As Dr. Smallwood notes, “Chambers Group reports no standards related to how special-status species are identified with potential for occurrence, nor how habitats are mapped nor how mapped habitats are assessed for their potential to support special-status species of wildlife.” (Ex. A, p. 13.) Therefore, Dr. Smallwood states that “it should be of no surprise that special- status species were undetected during a brief reconnaissance-level survey. Chambers Group reports a factual survey outcome of little if any informative value.” (Id.) Consequently, whether the BRA is substantial evidence is not apparent from the face of the document or the IS/MND. Second, the IS/MND and BRRA misuse the CNDDB. (Ex. A, pp. 13-15.) When discussing that the CNDDB search yielded 38 special-status species with occurrences that overlapped the biological survey area, “[t]he IS/MND inappropriately uses [CNDDB] to determine which species have potential to occur in the project area.” (Id., p. 14; see also, 25 Comment on MND, Pentair Warehouse Expansion Project Planning Commission Meeting Agenda Item 8.A September 27, 2022 Page 8 of 18 IS/MND, p. 23.) As Dr. Smallwood notes, “[b]y including only species whose documented occurrences within 5 miles of the project site can be found in CNDDB, the IS/MND screens out many special-status species from further consideration in its characterization of the wildlife community as a component of the baseline biological setting. CNDDB was not designed to support absence determinations or to screen out species from characterization of a site’s wildlife community.” (Ex. A, p. 14.) Furthermore, Chambers Group also misuses the “CNDDB records by incorporating them into an assignment of occurrence likelihoods, specifically Low, Moderate and High occurrence likelihoods,” which “are partially based on whether CNDDB records exist within 5 miles of the project site.” (Id.) According to Dr. Smallwood, “CNDDB is not designed to support any occurrence likelihood other than confirmation of presence of a species.” (Id.) Given the paucity of several potential special-status species identified by Dr. Smallwood in Ventura County, the Project’s baseline should be informed by protocol level surveys that can determine the presence or absence of these species at the Project site. Third, the surveys conducted for the Project do not provide substantial evidence of the presence or absence of special-status species that are known in the vicinity. The IS/MND asserts that “necessary habitat does not occur on site.”( IS/MND, p. 23.) This assertion, however, lacks evidence in the form of detection survey results. According to Dr. Smallwood, “No reconnaissance-level survey is capable of detecting enough of the wildlife species that occur at a site to realistically characterize the site’s wildlife community, including the site’s special-status species.” (Ex. A, pp. 10-11.) As a result, neither the IS/MND nor the BRA was justified in asserting that the Project site lacks special-status species of wildlife. Hence, Dr. Smallwood recommends that detection surveys should be performed, and subsequently assessed and reported in an EIR. (Id., p. 25.) Only with an accurate baseline could the IS/MND purport to assess the impacts on these special- status species. Fourth, in addition to these inadequate survey methods and unidentified baselines, the IS/MND and its BRRA understate the range of animal species that are likely present on the Project site. Dr. Smallwood concluded, based on his review of databases of species occurrences and his and Noriko Smallwood’s August 8, 2022 site visit, that the Project site “supports many species of wildlife, including many more than [he and Noriko and Chambers Group] could detect during a couple of brief reconnaissance-level surveys.” (Ex. A, p. 8.) Contrary to the IS/MND and BRRA’s reports, Dr. Smallwood’s review of eBird and iNaturalist found that “108 special-status species of wildlife potentially use the site or its overlying airspace at one time or another.” And, of these 108 special-status species, “2 were confirmed onsite or immediately next to the site by survey visits, and 37 (34%) have been documented in data bases within 1.5 miles of the site (‘Very close’), 21 (19%) within 1.5 and 4 miles (‘Nearby’), and another 38 (35%) within 4 to 30 miles (‘In region’).” (Ex. A, p. 15.) According to Dr. Smallwood, “[m]ore than half (56%) of the special-status species,” he identified “have been recorded within only 4 miles of the project site, which means the site carries a lot of potential for supporting special-status species of wildlife.” (Id.; see also, id., pp. 16-20, Table 2.) Moreover, Dr. Smallwood notes: 26 Comment on MND, Pentair Warehouse Expansion Project Planning Commission Meeting Agenda Item 8.A September 27, 2022 Page 8 of 18 Of the 20 species that Chambers Group (2022) addresses and which appear in… Table 2 [of Dr. Smallwood’s Comments], 7 have been documented within 1.5 miles of the site, and 5 have been documented within 1.5 and 4 miles of the site. The remainder have been documented within 4 and 30 miles of the site. These distances are not great, putting 20 species in close proximity to a site where Chambers Group (2022) concludes they are all of them absent. The absence determinations that Chambers Group (2022) applies to these species are premature and unfounded, given the short distances these species are known to occur relative to the project site. (Id., p. 15 [emphasis added] [citing Ex. A, pp. 16-20, Table 2).) Thus, given the close proximity of these special-status species, the IS/MND fails as a matter of law to analyze the impacts to these species and their habitat. In addition, Dr. Smallwood and Noriko Smallwood detected 20 species of vertebrate wildlife during a 2.5-hour site visit, 2 of which were special-status species. (Ex. A, p. 3.) Dr. Smallwood and Noriko saw harvester ants (Pogonomermyx californicus), which, according to Dr. Smallwood, “are significant ecological keystone species for their roles in soil bioturbation and as prey to Blainville’s horned lizards and other species.” (Id.) Noriko and he observed “ground squirrel burrows along the site’s perimeter, raising the possibility of use of the site by burrowing owls.” (Id.) They also saw “American kestrel and greater roadrunner (Photos 4 and 5), Cassin’s kingbirds and house finches (Photos 6 and 7), at least two families of killdeer (Photos 8 and 9), black phoebe (Photo 10), many American crows and many European starlings (Photos 11 and 12), among other species.” (Id. [citing Ex. A, pp. 4-6, Photos 4-12].) In addition, they reported watching “a Cooper’s hawk attempt several times to capture killdeer on site, but…were unable to photograph it.” (Id., p. 3.) Additionally, Dr. Smallwood writes: Evidence of breeding on and around the site was abundant. We saw a pair of American kestrels making food deliveries from the site and its surround[ings] to their nest site in an elderberry adjacent to the site. We saw Cassin’s kingbirds and northern mockingbirds feeding fledglings on elderberries adjacent to the site. We also saw numerous juvenile house finches on and next to the site. Many American crows flew over the site, and some stopped over on the site. Common ravens foraged on site, as did flocks of Brewer’s blackbirds, house finches, European starlings, and many mourning doves. (Id.) As Dr. Smallwood points out, the Chambers Group only “detected 7 species of wildlife, which was 43% of the number of species/hour that Noriko and [Dr. Smallwood] detected from the perimeter of the same site.” (Ex. A, p. 13.) Dr. Smallwood explains that “[t]his disparity of detection is important, because detecting members of a species at a site is the surest way to 27 Comment on MND, Pentair Warehouse Expansion Project Planning Commission Meeting Agenda Item 8.A September 27, 2022 Page 8 of 18 identify the species’ habitat. Not seeing members of the species when they were in fact present contributes to the type of habitat association error discussed above.” (Id.) In conclusion, the IS/MND’s failure to adequately evaluate the significance of the impacts to special-status species of wildlife violates CEQA. Thus, the Project requires an EIR to properly mitigate wildlife impacts of the Project. 2. The IS/MND Fails to Analyze the Project’s Potential Significant Impact on Loss of Breeding Capacity. Neither the IS/MND nor the BRRA assess the lost breeding capacity of birds that would result from the Project. (See, Ex. A, pp. 21, 26.) In so doing, the IS/MND fails to analyze the impact of habitat loss, or the loss of productive capacity on bird species likely to nest on the ground and in trees within the biological survey area. (Id.) While habitat loss results in the immediate numerical decline of birds and other animals, it also results in a permanent loss of productive capacity. (Id.) Dr. Smallwood cites a recent study that documented a “29% decline in overall bird abundance across North America over the last 48 years,” a decline which is driven by multiple factors, but principally attributed to habitat loss and habitat fragmentation. (Id. [citing Rosenberg et al. 2019].) Dr. Smallwood cites two studies that show bird nesting densities that were between 32.8 and 35.8 bird nests per acre, for an average of 34.3 bird nests per acre. (Id. [citing Young (1948) and Yahner (1982), respectively].) Assuming nesting density at the Project site is a tenth of the 34.3 average reported, then 3.43 bird nests per acre multiplied by the Project’s 5.66 acres of habit, Dr. Smallwood predicts that 19 bird nests produce new birds at the site annually. (Id.) Based on an average of 2.9 fledglings per nest, the Project would prevent the production of 63 new birds per year. (Ex. A, p. 21 [citing Young (1948)].) Based on Dr. Smallwood’s calculations, “[a]fter 100 years and further assuming an average bird generation time of 5 years, the lost capacity of both breeders and annual fledgling production would total 6,260 birds.” (Id., p. 21 [emphasis added].) The potential loss of 6,260 birds in California over the first century following construction of this Project easily qualifies as a significant and substantial impact that has not been analyzed. An EIR is required to fully analyze the Project’s impact on lost breeding capacity, and to mitigate that impact. At minimum, Dr. Smallwood recommends that compensatory mitigation is needed in response to the Project’s impacts from habitat loss. (Id., pp. 21, 26.) Dr. Smallwood also recommends that “[a]n equal area of land should be protected in perpetuity as close to the project site as possible.” (Id., p. 26.) 3. The IS/MND Fails to Adequately Analyze the Project’s Potential Significant Impacts on Wildlife Movement. The IS/MND fails to address impacts to wildlife movement, and instead looks for impacts to a wildlife corridor. (See, Ex. A, pp. 21-22.) In doing so, the IS/MND improperly dismisses the 28 Comment on MND, Pentair Warehouse Expansion Project Planning Commission Meeting Agenda Item 8.A September 27, 2022 Page 8 of 18 Project’s potential to significantly impact wildlife movement reasoning that “[n]o other potential wildlife corridors have been identified in the Project vicinity.” (IS/MND, p. 24; Ex. A, p. 21.) These conclusions rely on a false CEQA standard. (Ex. A, p. 21.) As Dr. Smallwood states, “[t]he primary phrase of the CEQA standard goes to wildlife movement regardless of whether the movement is channeled by a corridor.” (Id., pp. 21-22; see also, CEQA Guidelines, App. G, pp. 333-34 (stating that the CEQA significance threshold is whether, among other things, a project will “[i]nterfere substantially with the movement of any native resident or migratory fish or wildlife species....”). Impacts to wildlife movement may occur with or without the presence of a wildlife corridor. (Ex. A, p. 21.) Dr. Smallwood writes: A site such as the proposed project site is critically important for wildlife movement because it composes an increasingly diminishing area of open space within a growing expanse of anthropogenic uses, forcing more species of volant wildlife to use the site for stopover and staging during migration, dispersal, and home range patrol (Warnock 2010, Taylor et al. 2011, Runge et al. 2014). (Ex. A, p. 22.) Hence, the Project “would cut wildlife off from stopover and staging opportunities, forcing volant wildlife to travel even farther between remaining stopover sites.” (Id.) Because the Project would interfere with wildlife movement in the region, an EIR should be prepared to address the Project’s impacts on wildlife movement in the region. 4. The IS/MND Fails to Analyze the Project’s Potential Significant Impacts on Wildlife from Additional Traffic Generated by the Project. Dr. Smallwood identifies the serious impacts that increased traffic has on wildlife. (Ex. A, pp. 22-24.) Analyzing the potential impact on wildlife due to vehicle collisions is especially important because “traffic impacts have taken devastating tolls on wildlife,” across North America. (Id., p. 22 [citing Forman et al. 2003].) In the United States alone, estimates for “avian mortality on roads is 2,200 to 8,405 deaths per 100 km per year, or 89 million to 340 million total per year.” (Id. [citing Loss et al. 2014].) As Dr. Smallwood explains: The IS/MND neglects to address one of the project’s most obvious, substantial impacts to wildlife, and that is wildlife mortality and injuries caused by project- generated traffic. Project-generated traffic would endanger wildlife that must, for various reasons, cross roads used by the project’s traffic (Photos 15-18), including along roads far from the project footprint. Vehicle collisions have accounted for the deaths of many thousands of amphibian, reptile, mammal, bird, and arthropod fauna, and the impacts have often been found to be significant at the population level (Forman et al. 2003). (Id., pp. 22 & 23 [Photos 15-18].) Furthermore, a recent study conducted on traffic-caused wildlife mortality “found 1,275 carcasses of 49 species of mammals, birds, amphibians and reptiles over 15 months of searches” along a 2.5 mile stretch of Vasco Road in Contra Costa 29 Comment on MND, Pentair Warehouse Expansion Project Planning Commission Meeting Agenda Item 8.A September 27, 2022 Page 8 of 18 County, California. (Id., p. 22 [citing Mendelsohn et al. 2009].) Hence, as Dr. Smallwood points out, an analysis is needed to determine whether increased traffic generated by the Project would result in impacts to local wildlife. (Id.) The IS/MND anticipates that the proposed Project would generate an average of 16,382 daily miles traveled, which translates to 571,398 annual vehicle miles traveled (VMT). (Ex. A, p. 24.) To predict the road mortality of wildlife vulnerable to front-end collisions and crushing under tires, Dr. Smallwood analyzed the data from the study of traffic-caused wildlife mortality in Contra Costa County. (Id. [citing Mendelsohn et al. 2009].) By inputting estimates of vehicle miles per wildlife fatalities calculated using the Contra Costa County study, i.e. 1,825 vehicle miles per fatality, and the IS/MND’s prediction of 571,398 annual VMT due to the Project, Dr. Smallwood predicts “313 vertebrate wildlife fatalities per year” with “[o]perations over 50 years would accumulate 15,650 wildlife fatalities.” (Id.) Based on Dr. Smallwood’s assumptions and calculations, the traffic generated by the Project would cause substantial, significant impacts to wildlife. (Id.) Dr. Smallwood notes that “[m]itigation measures to improve wildlife safety along roads are available and are feasible,” and therefore, “need exploration for their suitability with the proposed project.”(Id.) Specifically, Dr. Smallwood suggests compensatory mitigation in the form of “funding research to identify fatality patterns and effective impact reduction measures such as reduced speed limits and wildlife under-crossings or overcrossings of particularly dangerous road segments,” and “donations to wildlife rehabilitation facilities.” (Id., p. 26.) The IS/MND fails to recognize at all this potential significant impact of the Project. Because a fair argument exists that the Project may have a significant impact on wildlife in the vicinity, an EIR must be prepared to assess this impact and identify appropriate mitigation. 5. The IS/MND Fails to Adequately Analyze the Project’s Potential Cumulative Impacts on Wildlife. The IS/MND fails to adequately analyze the cumulative impacts to wildlife from the Project by improperly implying that cumulative impacts are in reality only residual impacts as a result of incomplete mitigation from project-level impacts. (Ex. A, pp. 24-25.) It provides no analysis of cumulative impacts specific to biological resources. Instead, the IS/MND incorrectly concludes that the Project “would cause no project-level significant impacts specific to any environmental issues addressed by the IS/MND.” (Id., p. 24.) However, the IS/MND’s implied standard is not the standard of cumulative effects required under CEQA. (Id.) CEQA defines cumulative impacts, and it outlines two general approaches for performing the required cumulative analysis. (See, 14 CCR § 15130; PRC § 21083(b)(2).) As Dr. Smallwood explains: This notion is inconsistent with CEQA’s definition of cumulative impacts and how to analyze them. If this was CEQA’s standard, then cumulative effects analysis would be merely an analysis of mitigation efficacy. The IS’s analysis is based on an assumption that other projects in the area adequately mitigated 30 Comment on MND, Pentair Warehouse Expansion Project Planning Commission Meeting Agenda Item 8.A September 27, 2022 Page 8 of 18 their impacts to wildlife, thereby leaving no impacts to accumulate. Again, this is not how CEQA defines cumulative impacts and it is inconsistent with the Precautionary Principle in risk analysis directed to rare or precious resources. Even where impacts may be individually limited, their “incremental effects of an individual project are significant when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects.” (CEQA Guidelines §15064(h)(1)). (Ex. A, pp. 24-25 [emphasis added].) Hence, the IS/MND misrepresented the standard and failed to perform an appropriate analysis. An EIR must be prepared to include an adequate, serious analysis of the Project’s cumulative impacts on wildlife. 6. Preconstruction Nesting Bird Surveys Identified in the IS/MND are not Sufficient to Mitigate Potential Impacts to Bats and Birds that may be Present at the Site. Dr. Smallwood has reviewed the proposed wildlife impact mitigation identified in the IS/MND related to preconstruction surveys for nesting birds, i.e., Mitigation Measure BIO-1 (“MM-BIO-1”). (See, e.g., IS/MND, p. 23; Ex. A, pp. 25-26.) Although Dr. Smallwood agrees that preconstruction surveys need to be performed for nesting birds, he notes that preconstruction surveys will come too late either to disclose the Project’s anticipated impacts or to fully mitigate impacts to nesting birds at the Project site. (Ex. A, p. 25.) As Dr. Smallwood explains: Preconstruction surveys should be performed for nesting birds, but not as a substitute for detection surveys. Preconstruction surveys are not designed or intended to reduce project impacts. Preconstruction surveys are only intended as last-minute, one-time salvage and rescue operations targeting readily detectable nests or individuals before they are crushed under heavy construction machinery. Because most special-status species are rare and cryptic, and because most bird species are expert at hiding their nests lest they get predated, most of their nests will not be detected by preconstruction surveys without prior support of detection surveys. Locating all of the nests on site would require more effort than is committed during preconstruction surveys. (Id.) Hence, Dr. Smallwood recommends that detection surveys be conducted for nesting birds on the site. Dr. Smallwood states: Detection surveys are needed to inform preconstruction take-avoidance surveys by mapping out where biologists performing preconstruction surveys are most likely to find animals or their breeding sites. Detection surveys are needed to assess impacts and to inform the formulation of appropriate mitigation measures, because preconstruction surveys are not intended for these roles either. (Id., pp. 25-26.) 31 Comment on MND, Pentair Warehouse Expansion Project Planning Commission Meeting Agenda Item 8.A September 27, 2022 Page 8 of 18 In addition, the IS/MND completely fails to mitigate impacts to potential nesting bats that could be present at the site. According to Dr. Smallwood, “[m]ultiple special-status species of bats likely occur on and around the project site.” (Id., p. 26.) Therefore, “[a] qualified bat biologist should be tasked with completing protocol-level detection surveys for bats,” to learn “whether bats roost in the adjacent row of trees along the west border and within the elderberry shrubs along the south and east borders” and “[w]hether bats forage on site also needs to be learned.” (Id.) By failing to determine the actual baseline of bird’s and bat’s reliance on the site for roosting, nesting, and foraging and instead waiting within three days prior to the start of construction to determine what roosts, nests, birds, and bats may suffer impacts from the Project, the IS/MND fails to evaluate and mitigate the Project’s potential significant impacts to nesting birds and bats. Dr. Smallwood also recommends that detection surveys be implemented for the Project before preconstruction surveys are performed. (Ex. A, pp. 25-26.) In addition to detection surveys and preconstruction surveys being performed, an EIR should be prepared detailing how the results of preconstruction surveys will be reported. (Id.) Dr. Smallwood also recommends compensatory mitigation for habitat loss or losses to project-generated traffic, and provides several other mitigation measures that should be considered in an EIR. (See, e.g., id., pp. 25-27.) In conclusion, a fair argument can be made for the need to prepare an EIR to adequately analyze and formulate appropriate measures to mitigate project impacts to wildlife. B. THE IS/MND FAILS TO ADEQUATELY ANALYZE AND MITIGATE THE PROJECT’S POTENTIAL SIGNIFICANT AIR QUALITY IMPACTS. Air quality experts Matt Hagemann, P.G., C.Hg., and Paul E. Rosenfeld, Ph.D., of the Soil/Water/Air Protection Enterprise (“SWAPE”) reviewed the IS/MND and related appendices and found that the IS/MND’s conclusions as to the Project’s air quality impacts were not supported by substantial evidence. Instead, SWAPE analysis found that there is substantial evidence of a fair argument that the Project could result in significant adverse air quality impacts from construction and operation. An EIR is therefore required. SWAPE’s comment and CVs are attached as Exhibit B. 1. The IS/MND Fails to Adequately Mitigate Construction-Related Criteria Air Pollutant Emissions. The IS/MND erroneously claims that the Ventura County Air Pollution Control District (“VCAPCD”) significant thresholds do not apply to construction emissions, and that the VCAPCD only requires adherence to Rules 55, requiring all projects to minimize construction emissions through adherence to fugitive dust control measures, and Rule 74, requiring all projects to minimize ROG through adherence to architectural coating VOC content limits. (See, e.g., Ex. B, pp. 1-2 [citing IS/MND, p. 24].) This is incorrect, however. (See, id., pp. 2-3.) SWAPE explains that VCAPCD Air Quality Assessment Guidelines state: 32 Comment on MND, Pentair Warehouse Expansion Project Planning Commission Meeting Agenda Item 8.A September 27, 2022 Page 8 of 18 Construction-related emissions (including portable engines and portable engine- driven equipment subject to the ARB’s Statewide Portable Equipment Registration Program, and used for construction operations or repair and maintenance activities) of ROC and NOx are not counted towards the two significance thresholds, since these emissions are temporary. However, construction-related emissions should be mitigated if estimates of ROC and NOx emissions from the heavy-duty construction equipment anticipated to be used for a particular project exceed the 5 pounds per day threshold in the Ojai Planning Area, or the 25 pounds per day threshold in the remainder of the county. Mitigation measures to reduce such emissions are listed in Section 7.4.3, “ROC and NOx Construction Mitigation Measures” and in the mitigation module of URBEMIS (emphasis added).1 (Ex. B, p. 2.) Here, the IS/MND estimates that the VOC and NOx emissions associated with Project construction are greater than 25 pounds per day (“lbs/day”), (IS/MND, p. 18, Table 4): According to SWAPE, these estimates demonstrate “that the Project’s construction- related VOC and NOx emissions exceed the applicable VCAPCD threshold.” (Ex. B, p. 3.) Therefore, as SWAPE notes, the IS/MND is required to incorporate the following measures pursuant to VCAPCD Guidelines Section 7.4.3: As discussed in Chapter 5, Estimating Ozone Precursor Emissions, ozone precursor emissions from construction vehicles can be substantial. However, there are very few feasible measures available to reduce these emissions. APCD recommends the following measures to mitigate ozone precursor emissions from construction motor vehicles: 1. Minimize equipment idling time. 2. Maintain equipment engines in good condition and in proper tune as per manufacturers’ specifications. 1 “Ventura County Air Quality Assessment Guidelines.” October 2003, available at: http://www.vcapcd.org/pubs/Planning/VCAQGuidelines.pdf, p. 5-3 – 5-4. 33 Comment on MND, Pentair Warehouse Expansion Project Planning Commission Meeting Agenda Item 8.A September 27, 2022 Page 8 of 18 3. Lengthen the construction period during smog season (May through October), to minimize the number of vehicles and equipment operating at the same time. 4. Use alternatively fueled construction equipment, such as compressed natural gas (CNG), liquefied natural gas (LNG), or electric, if feasible.2 (Ex. B, p. 3.) Thus, until the IS/MND incorporates the above-mentioned mitigation, the IS/MND’s air quality analysis, and subsequent less-than-significant impact conclusion, should not be relied upon. 2. There is Substantial Evidence of a fair Argument that the Project may have Significant Health Impacts as a Result of Diesel Particulate Emissions. A subsequent EIR is required to evaluate the significant health impacts to individuals and workers from the Project’s operational and construction-related diesel particulate matter (“DPM”) emissions as a result of the proposed Project. SWAPE’s analysis of health risks related to the Project concludes that the IS/MND failed to adequately analyze the health impacts related to the Project’s operational and construction DPM emissions, and provides substantial evidence of a fair argument that the Project will have significant health impacts as a result of such emissions. (See, Ex. B, pp. 3-10). i. The IS/MND fails to adequately evaluate health risks from DPM emissions. According to SWAPE, the IS/MND incorrectly concludes that the proposed Project would have a less-than-significant health risk impact, without conducting an adequate quantified construction or operational health risk analysis (“HRA”). (Ex. B, pp. 3-6.) Specifically, the IS/MND concludes that the Project would result in a less-than-significant construction-related health risk impact “because the short-term construction duration, limited amount of heavy-duty equipment, distance from sensitive receptors, and compliance with applicable regulations would not result in substantial toxic air contaminant (“TAC”) emissions.” (Id., pp. 3-4 (citing IS/MND, p. 20).) The IS/MND also incorrectly concludes that “the Project would result in a less-than- significant operational health risk impact because the Project would not generate more than 100 truck trips per day.” (Id., p. 4 (citing IS/MND, p. 21).) However, as SWAPE points out, the IS/MND’s evaluation of the Project’s potential health risk impacts, as well as the subsequent less-than-significant impact conclusion, is incorrect for several reasons. (See, id., pp. 4-6.) First, IS/MND wrongly assumes that the Project is exempt from the preparation of an HRA according to California Air Pollution Control Officers Associated (“CAPCOA”) because the proposed warehouse building would not generate more than 100 truck deliveries per day. (Ex. B, pp. 4-5.) However, SWAPE states that “this is incorrect, as the above-referenced 2 “Ventura County Air Quality Assessment Guidelines.” October 2003, available at: http://www.vcapcd.org/pubs/Planning/VCAQGuidelines.pdf, p. 7-8. 34 Comment on MND, Pentair Warehouse Expansion Project Planning Commission Meeting Agenda Item 8.A September 27, 2022 Page 8 of 18 CAPCOA guidance is in reference to the recommended preparation of an HRA for the development of a new receptor, not for a new source.” (Id., p. 4.) Specifically, SWAPE notes that CAPCOA states: Avoid siting new sensitive land uses within 1,000 feet of a distribution center (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).3 (Id.) Because the correct use of this guidance would be to avoid locating new residential developments within 1,000-feet of an existing distribution center, SWAPE concludes that “the IS/MND’s conclusion that the Project is exempt from the preparation of an HRA is based on an incorrect interpretation of CAPCOA guidance and should not be relied upon.” (Id., pp. 4-5.) Second, by failing to prepare a quantified construction and operational HRA, the IS/MND fails to quantitatively evaluate TACs related to Project construction or operation, or make a reasonable effort to connect emissions to health impacts posed to nearby existing sensitive receptors from the Project. (Ex. B, p. 5.) SWAPE identifies potential emissions from both the exhaust stacks of construction equipment and the additional 216 daily vehicle trips related to project operation. (Id. [citing IS/MND, p. 6; IS/MND, Appendix K, p. 9, Table 3 (Traffic and Circulation Study)].) As such, the IS/MND fails to meet the CEQA requirement that projects correlate increases in project-generated emissions to adverse impacts on human health caused by those emissions. Third, the IS/MND’s conclusion is also inconsistent with the most recent guidance published by the Office of Health Hazard Assessment (“OEHHA”), the organization responsible for providing guidance on conducting HRAs in California, as well as local air district guidelines.4 (Ex. B, pp. 5-6.) OEHHA recommends that projects lasting at least 2 months be evaluated for cancer risks to nearby sensitive receptors, a time period which this Project easily exceeds. (Id., p. 5.) The OEHHA document also recommends that if a project is expected to last over 6 months, the exposure should be evaluated throughout the project using a 30-year exposure duration to estimate individual cancer risks. (Id., pp. 5-6.) Based on its extensive experience, SWAPE reasonably assumes that the Project will last at least 30 years, and therefore recommends that health risk impacts from the project be evaluated. (Id., p. 5.) An EIR is therefore required to analyze these impacts. (Id.) Fourth, by claiming a less-than-significant impact without conducting a quantified construction or operational HRA for nearby, existing sensitive receptors or evaluating the combined lifetime cancer risk to nearby sensitive receptors as a result of Project construction and operation together, SWAPE found that the IS/MND fails to compare the excess health risk 3 “Health Risk Assessments for Proposed Land Use Projects.” CAPCOA, July 2009, available at: http://www.capcoa.org/wp-content/uploads/2012/03/CAPCOA_HRA_LU_Guidelines_8 -6-09.pdf, p. 9, Table 2. 4 “Risk Assessment Guidelines: Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February 2015, available at: https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf. 35 Comment on MND, Pentair Warehouse Expansion Project Planning Commission Meeting Agenda Item 8.A September 27, 2022 Page 8 of 18 impact to the Ventura County Air Pollution Control District’s (“VCAPCD”) specific numeric threshold of 10 in one million. (Ex. A, p. 6.) Thus, in accordance with the most relevant guidance, an updated assessment of the health risk posed to nearby existing receptors from Project construction and operation should be conducted. ii. There is substantial evidence that the Project may have a significant health risk impact. Correcting the above errors, SWAPE prepared a screening-level HRA to evaluate potential impacts from the construction and operation of the Project. (Ex. B, pp. 6-10.) SWAPE prepared a screening-level HRA to evaluate potential health risk impacts posed to residential sensitive receptors as a result of the Project’s construction and operational TAC emissions. SWAPE used AERSCREEN, the leading screening-level air quality dispersion model. SWAPE applied a sensitive receptor distance of 100 meters and analyzed impacts to individuals at different stages of life based on OEHHA, CAPCOA, and VCAPCD guidance utilizing age sensitivity factors. SWAPE found that the excess cancer risks at a sensitive receptor located approximately 100 meters away over the course of Project construction and operation, while utilizing the recommended age sensitivity factors, is approximately 50.3 in one million for infants. (Id., p. 10.) SWAPE also concluded that the total excess lifetime cancer risk over the course of Project construction and operation is approximately 59.7 in one million. (Id.) Therefore, the cancer risk for infants and lifetime residents exceeds the VCAPCD’s threshold of 10 in one million, thus resulting in a potentially significant impact not previously addressed or identified by the IS/MND. Hence, an EIR is required for the Project. CEQA requires an agency to include an analysis of health risks that connects the Project’s air emissions with the health risk posed by those emissions. SWAPE’s screening-level HRA demonstrates that the Project’s construction and operation may have a significant health risk impact, when correct exposure assumptions and up-to-date, applicable guidance are used. Because SWAPE’s screening-level HRA indicates a potentially significant impact, the City must prepare an EIR. This EIR should also include an HRA which makes a reasonable effort to connect the Project’s air quality emissions and the potential health risks posed to nearby receptors. Thus, as SWAPE recommends, “an EIR should be prepared to include a refined health risk analysis which adequately and accurately evaluates health risk impacts associated with both Project construction and operation.” (Id.) Lastly, since the IS/MND’s analysis demonstrates that the Project would result in potentially significant air quality and health risk impacts that should be mitigated further, in an effort to reduce emissions, SWAPE identified several, feasible mitigation measures that are applicable to the proposed Project. (Ex. B, pp 10-12.) In conclusion, an EIR should be prepared to include all feasible mitigation measures, as well as include updated air quality and health risk analyses to ensure that the necessary mitigation measures are implemented to reduce emissions to below thresholds. (Id., p. 12.) 36 Comment on MND, Pentair Warehouse Expansion Project Planning Commission Meeting Agenda Item 8.A September 27, 2022 Page 8 of 18 IV. CONCLUSION For the foregoing reasons, the IS/MND for the Project should be withdrawn, an EIR should be prepared, and the draft EIR should be circulated for public review and comment in accordance with CEQA. We reserve the right to supplement these comments, including but not limited to at public hearings concerning the Project. (Galante Vineyards v. Monterey Peninsula Water Management Dist., 60 Cal. App. 4th 1109, 1121 (1997).) Thank you for considering these comments. Sincerely, Victoria Yundt LOZEAU | DRURY LLP 37 EXHIBIT A 38 1 Shawn Smallwood, PhD 3108 Finch Street Davis, CA 95616 Shanna Farley, Principal Planner City of Moorpark 799 Moorpark Avenue Moorpark, California 93021 14 August 2022 RE: Pentair Warehouse Expansion Dear Ms. Farley, I write to comment on the Initial Study and Mitigated Negative Declaration (IS/MND) prepared for the proposed Pentair Warehouse Expansion Project, which I understand would add a warehouse with 90,566 sf of floor space on 5.65 acres at 10941 Los Angeles Avenue (APN 511-0-200-265) (City of Moorpark 2022). In support of my comments, I reviewed a biological resources reconnaissance assessment prepared by Chambers Group (2022). My qualifications for preparing expert comments are the following. I hold a Ph.D. degree in Ecology from University of California at Davis, where I also worked as a post- graduate researcher in the Department of Agronomy and Range Sciences. My research has been on animal density and distribution, habitat selection, wildlife interactions with the anthrosphere, and conservation of rare and endangered species. I authored many papers on these and other topics. I served as Chair of the Conservation Affairs Committee for The Wildlife Society – Western Section. I am a member of The Wildlife Society and Raptor Research Foundation, and I’ve lectured part-time at California State University, Sacramento. I was Associate Editor of wildlife biology’s premier scientific journal, The Journal of Wildlife Management, as well as of Biological Conservation, and I was on the Editorial Board of Environmental Management. I have performed wildlife surveys in California for thirty-seven years. My CV is attached. SITE VISIT I visited the proposed project site with Noriko Smallwood, who is a wildlife ecologist who received her Master’s Degree from California State University Los Angeles. We surveyed the site 06:09―08:39 hours on 8 August 2022. We used binoculars to scan for wildlife from the roadside periphery, and we listened for calls and looked for sign of animal presence. The sky was clear with no significant wind and temperatures ranged 63―72° F. The site had been disked to remove nearly all vegetation, and certainly had the effect of suppressing wildlife (Photos 1 ― 3). However, some species of wildlife thrive on the open space provided by efforts to suppress vegetation. Other species thrive in the neighboring trees and mature elderberry shrubs. 39 2 Photos 1 ― 3. Views of the site (top and middle) and east side of site (bottom) of the proposed project, 8 August 2022. Visible in the middle photo are ground squirrel burrows in foreground, and in bottom photo is northern mockingbird atop an elderberry. The mockingbirds were nesting. 40 3 We detected 20 species of vertebrate wildlife at the site (Table 1), 2 of which were special-status species. We saw harvester ants (Pogonomermyx californicus), which are significant ecological keystone species for their roles in soil bioturbation and as prey to Blainville’s horned lizards and other species. We saw ground squirrel burrows along the site’s perimeter, raising the possibility of use of the site by burrowing owls. We also saw American kestrel and greater roadrunner (Photos 4 and 5), Cassin’s kingbirds and house finches (Photos 6 and 7), at least two families of killdeer (Photos 8 and 9), black phoebe (Photo 10), many American crows and many European starlings (Photos 11 and 12), among other species. We watched a Cooper’s hawk attempt several times to capture killdeer on site, but we were unable to photograph it. Table 1. Species of wildlife Noriko and I observed during 2.5 hours of survey on 8 August 2022. Common name Species name Status1 Notes Duck spp. Flyover Eurasian collared-dove Streptopelia decaocto Non-native Mourning dove Zenaida macroura Greater roadrunner Geococcyx californianus Perched on railroad tracks Anna’s hummingbird Calypte anna Killdeer Charadrius vociferus Nest site with adult pair Cooper’s hawk Accipiter cooperii TWL, BOP Hunted killdeer on site American kestrel Falco sparverius BOP Nest site on site border Cassin’s kingbird Tyrannus vociferans Fledgling being fed Black phoebe Sayornis nigricans Just offsite American crow Corvus brachyrhynchos Common raven Corvus corax Barn swallow Hirundo rustica Northern mockingbird Mimus polyglottos Nest site adjacent; fledgling European starling Sturnus vulgaris Non-native Foraging on site in flocks House finch Haemorphous mexicanus California towhee Pipilo crissalis Brewer’s blackbird Euphagus cyanocephalus Foraging on site in flocks Desert cottontail Sylvilagus audubonii Just offsite California ground squirrel Otospermophilus beecheyi Burrows along border of site 1 Listed as TWL = Taxa to Watch List (Shuford and Gardali 2008), and BOP = Birds of Prey (California Fish and Game Code 3503.5). Evidence of breeding on and around the site was abundant. We saw a pair of American kestrels making food deliveries from the site and its surrounds to their nest site in an elderberry adjacent to the site. We saw Cassin’s kingbirds and northern mockingbirds feeding fledglings on elderberries adjacent to the site. We also saw numerous juvenile house finches on and next to the site. Many American crows flew over the site, and some stopped over on the site. Common ravens foraged on site, as did flocks of Brewer’s blackbirds, house finches, European starlings, and many mourning doves. 41 4 Photos 4 and 5. American kestrel over the project site (left) and greater roadrunner at north edge of the project site (right), 8 August 2022. Photos 6 and 7. Cassin’s kingbird (left) and house finch (right) on the edge of the project site, 8 August 2022. 42 5 Photos 8 and 9. Killdeer on the project site, 8 August 2022. At least 2 families of killdeer occupied the site. 43 6 Photo 10. Black phoebe next to the project site, 8 August 2022. Photos 11 and 12. American crow (left) and European starling (right) on the project site, 8 August 2022. 44 7 Noriko Smallwood certifies that the foregoing survey results are true and accurate. Reconnaissance-level surveys can be useful for confirming presence of species that were detected, but they can also be useful for estimating the number of species that were not detected. One can model the pattern in species detections during a survey as a means to estimate the number of species that used the site but were undetected during the survey. To support such a modeling effort, the observer needs to record the times into the survey when each species was first detected. The cumulative number of species’ detections increases with increasing survey time, but eventually with diminishing returns (Figure 1). In the case of our survey, the pattern in the data (Figure 1) predicts that had we spent more time on site, or had we help from additional biologists, we would have detected 22 species of vertebrate wildlife, which is only 2 more than we detected. The pattern in the data indicates that the site’s richness of wildlife species started off early in the survey greater than the upper bound of the 95% confidence interval estimated from other project sites we have surveyed in the region, but richness dropped below the lower bound of the 95% CI after the first hour of survey. The site is not as rich in wildlife species as other sites we have visited in the area, but it is nevertheless amply used by wildlife and it supports at least 2 special-status species of wildlife (Figure 1). Efforts to suppress vegetation on the site has taken a substantial toll on wildlife, but they did not eliminate wildlife altogether. Figure 1. Actual (red circles) and predicted (red line) relationships between the number of vertebrate wildlife species detected and the elapsed survey time based on our visual-scan survey on 8 August 2022, and compared to the mean and 95% CI of surveys at 9 sites she and I performed at proposed project sites in the south-central coast region. Note that the relationship would differ if the survey was based on another method or during another season. 0 50 100 150 200 250 300 0 5 10 15 20 25 30 35 40 Minutes into survey Cu m u l a t i v e n u m b e r o f w i l d l i f e s p e c i e s d e t e c te d Actual count of species Model prediction r2 = 0.98, loss = 10.4 95% CI of 9 visual- scan surveys 2019-2022 Y 45 8 The site supports many species of wildlife, including many more than we could detect during a couple of brief reconnaissance-level surveys. However, although this modeling approach is useful for more realistically representing the species richness of the site at the time of a survey, it cannot represent the species richness throughout the year or across multiple years because many species are seasonal or even multi-annual in their movement patterns and in their occupancy of habitat. By use of an analytical bridge, a modeling effort applied to data collected elsewhere can predict the number of vertebrate wildlife species likely making use of the site over the longer term. As part of my research, I completed a much larger survey effort across 167 km2 of annual grasslands of the Altamont Pass Wind Resource Area, where from 2015 through 2019 I performed 721 1-hour visual-scan surveys, or 721 hours of surveys, at 46 stations. I used binoculars and otherwise the methods were the same as the methods Noriko and I and other consulting biologists use for surveys at proposed project sites. At each of the 46 survey stations, I tallied new species detected with each sequential survey at that station, and then related the cumulative species detected to the hours (number of surveys, as each survey lasted 1 hour) used to accumulate my counts of species detected. I used combined quadratic and simplex methods of estimation in Statistica to estimate least-squares, best-fit nonlinear models of the number of cumulative species detected regressed on hours of survey (number of surveys) at the station: 𝑅̂=1 1 𝑎⁄+𝑎×(𝐻𝑜𝑢𝑟𝑟)𝑐 , where 𝑅̂ represented cumulative species richness detected. The coefficients of determination, r2, of the models ranged 0.88 to 1.00, with a mean of 0.97 (95% CI: 0.96, 0.98); or in other words, the models were excellent fits to the data. I projected the predictions of each model to thousands of hours to find predicted asymptotes of wildlife species richness. The mean model-predicted asymptote of species richness was 57 after 11,857 hours of visual-scan surveys among the 46 stations. I also averaged model predictions of species richness at each incremental increase of number of surveys, i.e., number of hours (Figure 2). On average I detected 11.2 species over the first 2.5 hours of surveys in the Altamont Pass (2.5 hours to match the number of hours I surveyed at the project site), which composed 19.6% of the total predicted species I would detect with a much larger survey effort. Given the example illustrated in Figure 2, the 20 species we detected after our 2.5 hours of survey at the project site likely represented 19.6% of the species to be detected after many more visual-scan surveys over another year or longer. With many more repeat surveys through the year, we would likely detect 20 0.196⁄=102 species of vertebrate wildlife at the site. Assuming our ratio of special-status to non-special-status species was to hold with through the detections of all 102 predicted species, then continued surveys would eventually detect 10 special-status species of wildlife. Again, however, my prediction of 102 species of vertebrate wildlife, including 10 special- status species of wildlife, is derived from a visual-scan survey during the daytime, and would not detect nocturnal mammals. The true number of species composing the wildlife community of the site must be larger. One or two reconnaissance-level surveys 46 9 should serve only as a starting point toward characterization of a site’s wildlife community, but they certainly cannot alone inform of the inventory of species that use the site. Figure 2. Mean (95% CI) predicted wildlife species richness, 𝑅̂, as a nonlinear function of hour-long survey increments across 46 visual-scan survey stations across the Altamont Pass Wind Resource Area, Alameda and Contra Costa Counties, 2015‒2019. Additionally, the likelihood of detecting special-status species is typically lower than that of more common species. This difference can be explained by the fact that special- status species tend to be rarer and thus less detectable than common species. Special- status species also tend to be more cryptic, fossorial, or active during nocturnal periods when reconnaissance surveys are not performed. Another useful relationship from careful recording of species detections and subsequent comparative analysis is the probability of detection of listed species as a function of an increasing number of vertebrate wildlife species detected (Figure 3). (Note that listed species number fewer than special-status species, which are inclusive of listed species. Also note that I include California Fully Protected species and federal Candidate species as “listed” species.) 0 20 40 60 80 1000 10 20 30 40 50 Cumulative number of surveys (hours) (9 5 % C I ) 47 10 Figure 3. Probability of detecting ≥1 Candidate, Threatened or Endangered Species of wildlife listed under California or federal Endangered Species Acts, based on survey outcomes logit-regressed on the number of wildlife species Noriko Smallwood and I detected during surveys at 199 project sites in California, 1999-2022. The solid vertical line represents the number of species Noriko and I detected, and the dashed vertical line represents the number of species detected by Chambers Group (2022). As demonstrated in Figures 1 and 2, the number of species detected is largely a function of survey effort. Greater survey effort also increases the likelihood that listed species will be detected (which is the first tenet of detection surveys for special-status species). Based on the outcomes of surveys earlier completed at 199 project sites, our survey effort at the project site carried an 19% chance of detecting a listed species, whereas the survey effort of Chambers Group (2022) carried a 5% chance. Listed species of vertebrate wildlife likely use the site, but conclusively documenting their use would take more survey effort to achieve a reasonable likelihood of detection. No reconnaissance- level survey is capable of detecting enough of the wildlife species that occur at a site to realistically characterize the site’s wildlife community, including the site’s special-status species. A fair argument can be made for the need to prepare an EIR that is better informed by biological resources surveys and by appropriate interpretation of survey outcomes for the purpose of characterizing the wildlife community as part of the current environmental setting. EXISTING ENVIRONMENTAL SETTING The first step in analysis of potential project impacts to biological resources is to accurately characterize the existing environmental setting, including the biological species that use the site, their relative abundances, how they use the site, key ecological relationships, and known and ongoing threats to those species with special status. A reasonably accurate characterization of the environmental setting can provide the basis for determining whether the site holds habitat value to wildlife, as well as a baseline against which to analyze potential project impacts. For these reasons, characterization of the environmental setting, including the project’s site’s regional setting, is one of CEQA’s essential analytical steps (§15125). Methods to achieve this first step typically include (1) surveys of the site for biological resources, an d (2) reviews of literature, 0 20 40 60 80 100 120 0.0 0.2 0.4 0.6 0.8 1.0 Number of species detected Pr o b a b i l i t y o f d e t e c t i n g F u l l y P r o t e c t e d , Ca n d i d a t e , T h r e a t e n e d o r E n d a n g e r e d S p e c i e s Hosmer Lemeshow =3.48, P = 0.90 95% CI 199 sites 48 11 databases and local experts for documented occurrences of special-status species. In the case of this project, these essential steps remain incomplete and misleading. Environmental Setting informed by Field Surveys Ideally, the purpose of field survey in support of environmental review is to identify which species use a project site, how they use it, and in what numbers. Identifying the presence of certain species – special-status species – is more important than the presence of others. Analysts need this information to identify what is at stake, and as a basis for predicting project impacts. In reality, biological survey to inventory species is costly in time and effort, and its product uncertain. Some species are large or loud, and can be seen during diurnal surveys, whereas others are tiny and quiet and are detectable only by night, by trapping or by remote-sensing technology. Membership on an inventory can also carry different meanings based on how each species occurs at the site. Whereas some species are resident year-round, others can be seasonal or ephemeral in their occurrences at a site. Should a species be included on an inventory depends on the investigator’s standard of what counts as presence. Does a single 5-minute occurrence over a decade qualify a species as present? And if such a record was made, who can know whether many other brief occurrences truly occurred without having been documented? The dilemma is that environmental review really needs species inventory, but biologists are imperfect observers of wildlife at any given site. Obtaining a true species inventory is unlikely, given the brief windows of time and budget that project applicants and their permitting authorities allow for biologists to surveil the site. The wildlife species that are detected by reconnaissance-level survey represent only a sampling of the species that truly use the site. This is because biologists vary in their skill at detecting wildlife species, and because species of wildlife vary in their detection probabilities during a typical reconnaissance-level survey, ranging from near 0% among rare or nocturnal species to 100% among species that consulting biologists often refer to as “common.” In truth, “common” species can number fewer than the “rare” or cryptic species that are more difficult to detect. Rare or cryptic species often require specialized survey methods, begging the question of whether reconnaissance-level surveys can reveal any reliable information to consumers of the environmental review. Reconnaissance-level surveys occasionally reveal the presence of special-status species, sometimes due to the skill of the observer but often due to luck of survey timing. What these surveys cannot reveal is the absences of any species whose geographic ranges overlap the site and whose habitat associations at all resemble conditions of the site. And it is habitat associations that consulting biologists often rely upon to determine likelihoods of occurrence of special-status species. Unfortunately, habitat associations poorly comport with the habitat concept, which is that habitat is that part of the environment that is used by a species (Hall et al. 1997, Smallwood 2002). Habitat associations defined by consulting biologists typically lack foundation in actual measurements of habitat use, and are therefore speculative and prone to abuse. One form of abuse is pigeon-holing species into unrealistically narrow portions of the environment which can then be said not to exist on the project site. Another form of 49 12 abuse is to assign functions to habitat for the purpose of dividing habitat into functional parts, such as between breeding habitat versus foraging habitat. This functional assignment gives consultants the opportunity to prioritize habitat by function, and again with the aim of concluding breeding habitat is unavailable and thus the species at issue is absent. But there is no scientific basis for this practice. This type of functional assignment fundamentally conflicts with the habitat concept. Reconnaissance-level surveys occasionally reveal the presence of special-status species, sometimes due to the skill of the observer but often due to luck of survey timing. What these surveys cannot reveal is the absences of any species whose geographic ranges overlap the site and whose known habitat associations at all resemble conditions of the site. And it is habitat associations that consulting biologists often rely upon to determine likelihoods of occurrence of special-status species. Unfortunately, the habitat associations relied upon by consulting biologists rarely comport with true habitat, which is decided by members of each species. Habitat is that part of the environment that is used by a species (Hall et al. 1997), and is most accurately charact erized through scientific measurement (Smallwood 2002). However, scientific measurement of habitat use is prone to substantial measurement and interpretive biases (Smallwood 2002), which means that habitat associations are often uncertain and unfinished. Habitat associations defined by consulting biologists typically lack foundation in actual measurements of habitat use, and are therefore speculative and prone to abuse.1 Given the true cost of species inventory, the temptation to shortcut the analysis of occurrence likelihoods is understandable. In the spirit and intent of CEQA, a reasonably feasible species inventory should be the first objective of reconnaissance-level surveys. But a reasonably feasible inventory is only a sampling of the inventory and not a true inventory. What, then, is the appropriate approach for informing a CEQA review? One is to commit to a survey effort that results in the detection of a sufficient number of species to accurately estimate the number of species yet to be detected. Another is to honestly report the uncertainties of the characterizations of the species inventory and of the likelihoods of occurrence of special-status species. The analyst can also assume species are present until suitable evidence is acquired in support of an absence determination. This last approach would be consistent with the precautionary principle 1 One form of abuse of habitat associations applied to CEQA review is pigeon -holing species into unrealistically narrow portions of the environment, which can more readily be said not to exist on the project site. With this approach, the analyst selects a convenient habitat association from the literature or the internet while neglecting to include other documented habitat associations. Another form of abuse is to assign functions to habitat for the purpose of dividing habitat into functional parts, such as between breeding habitat versus foraging habitat. This functional assignment gives consultants the opportunity to prioritize habitat by function, with the aim of concluding breeding habitat is unavailable and thus the species at issue is absent. But this type of functional assignment fundamentally conflicts with the habitat concept. Animals unable to find sufficient forage, refugia, or travel opportunities are just as unable to reproduce as those unable to find sufficient nest -site opportunities. Per the precautionary principle in risk analysis and consistent with the habitat concep t, CEQA review should be based on the broadest of available habitat characterizations, which should be interpreted on the whole of habitat rather than contrived functional parts. Any detections of a species on or over a site, regardless of time of year, s hould be interpreted as that species’ use of habitat, any part of which is critical to breeding success. 50 13 is risk analysis directed toward rare and precious resources (National Research Council 1986). How did the consulting biologists address the wildlife species inventory and special-status species occurrence likelihoods at the project site? Chambers Group (2022) performed wildlife surveys “to document existing vegetation communities, identify special status species with a potential for occ urrence, and map habitats that could support special status wildlife species...” Chambers Group reports no standards related to how special-status species are identified with potential for occurrence, nor how habitats are mapped nor how mapped habitats are assessed for their potential to support special-status species of wildlife. The implied level of knowledge over habitat and occurrence potential is unrealistic. Even those of us who measure habitat use to better characterize habitat of any given species remain surprisingly ignorant of habitat. Except for certain species in certain environmental settings, the notion that a consulting biologist can walk around a site over a couple of hours and declare this over there as habitat for that species, or not, is a pseudoscientific notion at best. Two biologists walked over the site for 2 hours beginning at 10:30 on 16 December 2021. They detected 7 species of wildlife, which was 43% of the number of species/hour that Noriko and I detected from the perimeter of the same site. Chambers Group (2022) did not see much -- certainly not as much as we did. This disparity of detection is important, because detecting members of a species at a site is the surest way to identify the species’ habitat. Not seeing members of the species when they were in fact present contributes to the type of habitat association error discussed in the preceding paragraph. According to Chambers Group (2022:23), “none of the [38 special-status] species were found on site.” But this reported finding is also pseudoscientific, because it is factual while at the same time reported out of context of insufficient survey effort committed to the site. As demonstrated in Figures 1 through 3, it should be of no surprise that special-status species were undetected during a brief reconnaissance-level survey. Chambers Group reports a factual survey outcome of little if any informative value. Environmental Setting informed by Desktop Review The purpose of literature and database review, and of consulting with local experts, is to inform the reconnaissance-level survey, to augment it, and to help determine which protocol-level detection surveys should be implemented. Analysts need this information to identify which species are known to have occurred at or near the project site, and to identify which other special-status species could conceivably occur at the site due to geographic range overlap and site conditions. This step is important because the reconnaissance-level survey is not going to detect all of the species of wildlife that make use of the site. This step can identity those species yet to be detected at the site but 51 14 which have been documented to occur nearby or whose available habitat associations are consistent with site conditions. Some special-status species can be ruled out of further analysis, but only if compelling evidence is available in support of such determinations (see below). The IS/MND is inadequately informed by a literature and data base review. The IS/MND inappropriately uses California Natural Diversity Data Base (CNDDB) to determine which species have potential to occur in the project area. By including only species whose documented occurrences within 5 miles of the project site can be found in CNDDB, the IS/MND screens out many special-status species from further consideration in its characterization of the wildlife community as a component of the baseline biological setting. CNDDB was not designed to support absence determinations or to screen out species from characterization of a site’s wildlife community. The IS/MND misuses CNDDB. Chambers Group (2021) further misuses CNDDB records by incorporating them into an assignment of occurrence likelihoods, specifically Low, Moderate and High occurrence likelihoods. These assignments are partially based on whether CNDDB records exist within 5 miles of the project site. CNDDB is not designed to support any occurrence likelihood other than confirmation of presence of a species. As noted by CNDDB, “The CNDDB is a positive sighting database. It does not predict where something may be found. We map occurrences only where we have documentation that the species was found at the site. There are many areas of the state where no surveys have been conducted and therefore there is nothing on the map. That does not mean that there are no special status species present.” CNDDB relies entirely on volunteer reporting from biologists who were allowed access to whatever real properties they report from. Many real properties have never been surveyed by biologists. Many real properties have been surveyed, but the survey outcomes never reported to CNDDB. Many real properties have been surveyed multiple times, but not all survey outcomes reported to CNDDB. Furthermore, CNDDB is interested only in the findings of special-status species, which means that species more recently assigned special status will have been reported many fewer times to CNDDB than were species assigned special status since the inception of CNDDB. Because Bullock’s oriole and multiple other species were not assigned special status until 2021, these species would have lacked records in CNDDB when Hagan (2021) prepared his analysis. This lack of CNDDB records had nothing to do with true geographic distributions. And because negative findings are not reported to CNDDB, CNDDB cannot provide the basis for estimating occurrence likelihoods, either. Negative findings from CNDDB queries are inappropriate as a basis for narrowing a list of potentially occurring species. The limitations of CNDDB are well-known, and summarized by California Department of Fish and Wildlife in a warning presented on its CNDDB web site (https://wildlife.ca.gov/Data/CNDDB/Maps-and-Data): “CNDDB staff work very hard to keep the database as current and up-to-date as possible given our capabilities and resources. However, we cannot and do not portray the CNDDB as an exhaustive and comprehensive inventory of all rare species statewide. Field 52 15 verification for the presence or absence of sensitive species will always be an important obligation of our users.” The IS/MND’s use of CNDDB records to filter out species from its characterization of the baseline biological setting is therefore inconsistent with CNDDB’s purpose. And in fact, if CNDDB was appropriate to the task to which Chambers Group (2022) applies it, then there would be no need for implementation of protocol-level detection surveys for special-status species. But this is not the case. For the above-stated reasons, Chambers Group’s (2022) list of special- status species assessed for occurrence likelihoods is misleading and unsupported. Assuming absence of any special-status species based on absence of CNDDB records is inappropriate. In my assessment based on database reviews and our site visits, 108 special-status species of wildlife potentially use the site or its overlying airspace at one time or another (Table 2). Of these, 2 were confirmed onsite or immediately next to the site by survey visits, and 37 (34%) have been documented in data bases within 1.5 miles of the site (‘Very close’), 21 (19%) within 1.5 and 4 miles (‘Nearby’), and another 38 (35%) within 4 to 30 miles (‘In region’). More than half (56%) of the special-status species in Table 2 have been recorded within only 4 miles of the project site, which means the site carries a lot of potential for supporting special-status species of wildlife. On any given day, one or more of these species like make use of the project site, but being there to document that use probably requires multiple surveys (see Figures 1 through 3). On the day Chambers Group surveyed, none were detected. On the day we surveyed, two were detected. If biologists were to survey on another day, one to several additional special- status species might be detected. The occurrence databases inform us that many special-status species occur near the project site, which means these species likely make use of the project site, and sufficient survey effort should be directed to the site to either confirm these species use the site or to support absence determinations. But a single survey cannot support the absence determination of any of these species. Of the 20 species that Chambers Group (2022) addresses and which appear in my Table 2, 7 have been documented within 1.5 miles of the site, and 5 have been documented within 1.5 and 4 miles of the site. The remainder have been documented within 4 and 30 miles of the site. These distances are not great, putting 20 species in close proximity to a site where Chambers Group (2022) concludes they are all of them absent. The absence determinations that Chambers Group (2022) applies to these species are premature and unfounded, given the short distances these species are known to occur relative to the project site. The environmental baseline needs to be better informed by both on-site surveys and occurrence database review. Absence determinations need to be founded on substantial evidence. Without such evidence, the precautionary principle in risk analysis calls for erring on the side of caution, which in this application means assuming presence of each potentially occurring special-status species. What little I have done to survey the site and to review occurrence databases reveals numerous special-status species at risk of significant impacts caused by the proposed project. A fair argument can be made for the need to prepare an EIR to appropriately characterize existing conditions so that impacts analysis can proceed from a sound footing. 53 16 Table 2. Occurrence likelihoods of special-status bird species at or near the proposed project site, according to eBird/iNaturalist records (https://eBird.org, https://www.inaturalist.org) and on-site survey findings. ‘Very close’ indicates within 1.5 miles of the site, “nearby” indicates within 4 miles, and “in region” indicates within 30 miles or so. Common name Species name Status1 Occurrence likelihood IS/NMD Data base records, Site visits Monarch Danaus plexippus FC Very close Crotch’s bumble bee Bombus crotchii CCE In region Western spadefoot Spea hammondii SSC Absent In region Western pond turtle Emys marmorata SSC Absent Very close Coast horned lizard Phrynosoma blainvillii SSC Absent Very close Coastal whiptail Aspidoscelis tigris stejnegeri SSC Absent Nearby Southern California legless lizard Anniella stebbinsi SSC Absent Very close California glossy snake Arizona elegans occidentalis SSC Absent In region Coast patch-nosed snake Salvadora hexalepis virgultea SSC Absent In region Two-striped gartersnake Thamnophis hammondii SSC Absent Very close South coast gartersnake Thamnophis sirtalis pop. 1 SSC Absent In region Western yellow-billed cuckoo Coccyzus americanus occidentalis FT, CE, BCC Absent In region Black swift Cypseloides niger SSC, BCC In region Vaux’s swift Chaetura vauxi SSC2 Very close Costa’s hummingbird Calypte costae BCC Very close Rufous hummingbird Selasphorus rufus BCC Very close Allen’s hummingbird Selasphorus sasin BCC Very close Mountain plover Charadrius montanus SSC, BCC In region Snowy plover Charadrius nivosus BCC In region Western snowy plover Charadrius nivosus nivosus FT, SSC, BCC In region Long-billed curlew Numenius americanus BCC, WL Nearby Marbled godwit Limosa fedoa BCC In region Heermann’s gull Larus heermanni BCC In region Western gull Larus occidentalis BCC Very close California gull Larus californicus WL, BCC Very close 54 17 Common name Species name Status1 Occurrence likelihood IS/NMD Data base records, Site visits California least tern Sternula antillarum browni FE, CE, FP In region Caspian tern Hydroprogne caspia BCC Nearby Double-crested cormorant Phalacrocorax auritus WL Very close American white pelican Pelacanus erythrorhynchos SSC1 Very close Least bittern Ixobrychus exilis SSC, BCC In region White-faced ibis Plegadis chihi WL Very close Turkey vulture Cathartes aura BOP Very close Osprey Pandion haliaetus WL, BOP In region White-tailed kite Elanus luecurus CFP, BOP Very close Golden eagle Aquila chrysaetos BGEPA, CFP, BOP, BCC Nearby Northern harrier Circus cyaneus SSC3, BOP Nearby Sharp-shinned hawk Accipiter striatus WL, BOP Very close Cooper’s hawk Accipiter cooperii WL, BOP On site Bald eagle Haliaeetus leucocephalus BGEPA, BCC, CFP Very close Red-shouldered hawk Buteo lineatus BOP Very close Swainson’s hawk Buteo swainsoni CT, BOP, BCC In region Red-tailed hawk Buteo jamaicensis BOP Very close Ferruginous hawk Buteo regalis WL, BOP Nearby Barn owl Tyto alba BOP Very close Western screech-owl Megascops kennicotti BOP Nearby Great horned owl Bubo virginianus BOP Very close Burrowing owl Athene cunicularia BCC, SSC2, BOP Absent Nearby Long-eared owl Asio Otis SSC3, BCC, BOP In region Short-eared owl Asia flammeus SSC3, BOP In region Lewis’s woodpecker Melanerpes lewis BCC Nearby Nuttall’s woodpecker Picoides nuttallii BCC Very close American kestrel Falco sparverius BOP On site 55 18 Common name Species name Status1 Occurrence likelihood IS/NMD Data base records, Site visits Merlin Falco columbarius WL, BOP Very close Peregrine falcon Falco peregrinus CFP, BOP, BCC Very close Prairie falcon Falco mexicanus BCC, WL, BOP Very close Olive-sided flycatcher Contopus cooperi BCC, SSC2 Nearby Willow flycatcher Empidonax trailii CE, BCC Very close Southwestern willow flycatcher Empidonax traillii extimus FE, CE Absent In region Vermilion flycatcher Pyrocephalus rubinus SSC2 Very close Least Bell’s vireo Vireo bellii pusillus FE, CE Absent Very close Loggerhead shrike Lanius ludovicianus BCC, SSC2 Nearby Oak titmouse Baeolophus inornatus BCC Very close California horned lark Eremophila alpestris actia WL Nearby Bank swallow Riparia riparia CT Absent Nearby Purple martin Progne subis SSC2 In region Wrentit Chamaea fasciata BCC Very close California gnatcatcher Polioptila c. californica CT, SSC Absent Very close California thrasher Toxostoma redivivum BCC Very close Cassin’s finch Haemorhous cassinii BCC In region Lawrence’s goldfinch Spinus lawrencei BCC Very close Grasshopper sparrow Ammodramus savannarum SSC2 Nearby Black-chinned sparrow Spizella atrogularis BCC Nearby Brewer’s sparrow Spizella breweri BCC Very close Bell’s sparrow Amphispiza b. belli WL, BCC In region Oregon vesper sparrow Pooecetes gramineus affinis SSC2, BCC Nearby Belding’s savannah sparrow 2 Passerculus sandwichensis beldingi CE In region Large-billed savannah sparrow 2 Passerculus sandwichensis rostratus SSC2 In region Southern California rufous- crowned sparrow Aimophila ruficeps canescens WL Nearby Yellow-breasted chat Icteria virens SSC3 Nearby 56 19 Common name Species name Status1 Occurrence likelihood IS/NMD Data base records, Site visits Yellow-headed blackbird Xanthocephalus xanthocephalus SSC3 Nearby Bullock’s oriole Icterus bullockii BCC Very close Tricolored blackbird Agelaius tricolor CT, BCC, SSC Absent Nearby Lucy’s warbler Leiothlypis luciae SSC, BCC In region Virginia’s warbler Leiothlypis virginiae WL, BCC In region Yellow warbler Dendroica petechia BCC, SSC2 Absent Very close Summer tanager Piranga rubra SSC1 In region Pallid bat Antrozous pallidus SSC, WBWG:H Absent In region Townsend’s big-eared bat Corynorhinus townsendii SSC, WBWG:H In range Spotted bat Euderma maculatum SSC, WBWG:H In range Western red bat Lasiurus blossevillii SSC, WBWG:H In region Hoary bat Lasiurus cinereus WBWG:M In region Western yellow bat Lasiurus xanthinus SSC, WBWG:H In range Western small-footed myotis Myotis cililabrum WBWG:M In range Miller’s myotis Myotis evotis WBWG:M In region Fringed myotis Myotis thysanodes WBWG:H In range Long-legged myotis Myotis volans WBWG:H In range Yuma myotis Myotis yumanensis WBWG:LM In region Little brown myotis Myotis lucifugus WBWG:M In range Western mastiff bat Eumops perotis SSC, WBWG:H Absent In region Western red bat Lasiurus blossevillii SSC, WBWG:H In region Big brown bat Episticus fuscus WBWG:L In region California myotis Myotis californicus WBWG:L In region Canyon bat Parastrellus hesperus WBWG:M In region Big free-tailed bat Nyctinomops macrotis SSC, WBWG:MH In region San Diego black-tailed jackrabbit Lepus californicus bennettii SSC In range Los Angeles pocket mouse Perognathus longimembris brevinasus SSC In range 57 20 Common name Species name Status1 Occurrence likelihood IS/NMD Data base records, Site visits Southern California salt marsh shrew Sorex ornatus salicornicus SSC In range American badger Taxidea taxus SSC Absent Nearby 1 Listed as FE = federal endangered, BCC = U.S. Fish and Wildlife Service Bird of Conservation Concern, CE = California endangered, CT = California threatened, CCE & CCT = Candidate California Endangered & Threatened, CFP = California Fully Protected (CFG Code 3511), SSC = California species of special concern (not threatened with extinction, but rare, very restricted in range, declining throughout range, peripheral portion of species' range, associated with habitat that is declining in extent), SSC1, SSC2 and SSC3 = California Bird Species of Special Concern priorities 1, 2 and 3, respectively (Shuford and Gardali 2008), WL = Taxa to Watch List (Shuford and Gardali 2008), and BOP = Birds of Prey (California Fish and Game Code 3503.5), and WBWG = Western Bat Working Group with priority rankings, of low, moderate, and high. 58 21 BIOLOGICAL IMPACTS ASSESSMENT Determination of occurrence likelihoods of special-status species is not, in and of itself, an analysis of potential project impacts. An impacts analysis should consider whether and how a proposed project would affect members of a species, larger demograp hic units of the species, or the whole of a species. In the following, I analyze several types of impacts likely to result from the project, one of which is unsoundly analyzed and the others not analyzed in the IS/MND. HABITAT LOSS The IS/MND does not address potential impacts of habitat loss to breeding birds. Habitat loss has been recognized as the most likely leading cause of a documented 29% decline in overall bird abundance across North America over the last 48 years (Rosenberg et al. 2019). Habitat loss not only results in the immediate numerical decline of wildlife, but it also results in permanent loss of productive capacity. two study sites in grassland/wetland/woodland complexes had total bird nesting densities of 32.8 and 35.8 nests per acre (Young 1948, Yahner 1982) for an average 34.3 nests per acre. Assuming the project site supports a tenth of the total nesting density of the above-referenced study sites, and applying this adjusted density to the 5.66 acres of the project site would predict a loss of 19 bird nests. The loss of192 nest sites of birds would qualify as a significant project impact that has not been addressed in the IS/MND. But the impact does not end with the immediate loss of nest sites as the site is graded in preparation for impervious surfaces. The reproductive capacity of the site would be lost. The average number of fledglings per nest in Young’s (1948) study was 2.9. Assuming Young’s (1948) study site typifies bird productivity, the project would prevent the production of 55 fledglings per year. After 100 years and further assuming an average bird generation time of 5 years, the lost capacity of both breeders and annual fledgling production would total 6,260 birds {(nests/year × chicks/nest × number of years) + (2 adults/nest × nests/year) × (number of years ÷ years/generation)}. The project’s denial to California of 63 birds per year has not been analyzed as a potential impact in the IS/MND, nor does the IS/MND provide any compensatory mitigation for this impact. A fair argument can be made for the need to prepare an EIR to appropriately analyze the project’s impacts to wildlife caused by habitat loss and habitat fragmentation. WILDLIFE MOVEMENT The IS/MND’s analysis of whether the project would interfere with wildlife movement in the region is fundamentally flawed. According to the IS/MND (page 24), “No other potential wildlife corridors have been identified in the Project vicinity.” The implied premise is that only disruption of the function of a wildlife corridor can interfere with wildlife movement in the region. This premise, however, represents a false CEQA standard, and is therefore inappropriate to the analysis. The primary phrase of the CEQA standard goes to wildlife movement regardless of whether the movement is 59 22 channeled by a corridor. A site such as the proposed project site is critically important for wildlife movement because it composes an increasingly diminishing area of open space within a growing expanse of anthropogenic uses, forcing more species of volant wildlife to use the site for stopover and staging during migration, dispersal, and home range patrol (Warnock 2010, Taylor et al. 2011, Runge et al. 2014). The project would cut wildlife off from stopover and staging opportunities, forcing volant wildlife to travel even farther between remaining stopover sites. TRAFFIC IMPACTS TO WILDLIFE The IS/MND neglects to address one of the project’s most obvious, substantial impacts to wildlife, and that is wildlife mortality and injuries caused by project -generated traffic. Project-generated traffic would endanger wildlife that must, for various reasons, cross roads used by the project’s traffic (Photos 15-18), including along roads far from the project footprint. Vehicle collisions have accounted for the deaths of many thousands of amphibian, reptile, mammal, bird, and arthropod fauna, and the impacts have often been found to be significant at the population level (Forman et al. 2003). Across North America traffic impacts have taken devastating tolls on wildlife (Forman et al. 2003). In Canada, 3,562 birds were estimated killed per 100 km of road per year (Bishop and Brogan 2013), and the US estimate of avian mortality on roads is 2,200 to 8,405 deaths per 100 km per year, or 89 million to 340 million total per year (Loss et al. 2014). Local impacts can be more intense than nationally. The nearest study of traffic-caused wildlife mortality was performed along a 2.5-mile stretch of Vasco Road in Contra Costa County, California. Fatality searches in this study found 1,275 carcasses of 49 species of mammals, birds, amphibians and reptiles over 15 months of searches (Mendelsohn et al. 2009). This fatality number needs to be adjusted for the proportion of fatalities that were not found due to scavenger removal and searcher error. This adjustment is typically made by placing carcasses for searchers to find (or not find) during their routine periodic fatality searches. This step was not taken at Vasco Road (Mendelsohn et al. 2009), but it was taken as part of another study right next to Vasco Road (Brown et al. 2016). The Brown et al. (2016) adjustment factors were similar to those for carcass persistence of road fatalities (Santos et al. 2011). Applying searcher detection rates estimated from carcass detection trials performed at a wind energy project immediately adjacent to this same stretch of road (Brown et al. 2016), the adjusted total number of fatalities was estimated at 12,187 animals killed by traffic on the road. This fatality number translates to a rate of 3,900 wild animals per mile per year killed along 2.5 miles of road in 1.25 years. In terms comparable to the national estimates, the estimates from the Mendelsohn et al. (2009) study would translate to 243,740 animals killed per 100 km of road per year, or 29 times that of Loss et al.’s (2014) upper bound estimate and 68 times the Canadian estimate. An analysis is needed of whether increased traffic generated by the project site would similarly result in local impacts on wildlife. 60 23 Photo 15. A Gambel’s quail dashes across a road on 3 April 2021. Such road crossings are usually successful, but too often prove fatal to the animal. Photo by Noriko Smallwood. Photo 16. Great-tailed grackle walks onto a rural road in Imperial County, 4 February 2022. Photo 17. Mourning dove killed by vehicle on a California road. Photo by Noriko Smallwood, 21 June 2020. Photo 18. Raccoon killed on Road 31 just east of Highway 505 in Solano County. Photo taken on 10 November 2018. 61 24 For wildlife vulnerable to front-end collisions and crushing under tires, road mortality can be predicted from the study of Mendelsohn et al. (2009) as a basis, although it would be helpful to have the availability of more studies like that of Mendelsohn et al. (2009) at additional locations. My analysis of the Mendelsohn et al. (2009) data resulted in an estimated 3,900 animals killed per mile along a county road in Contra Costa County. Two percent of the estimated number of fatalities were birds, and the balance was composed of 34% mammals (many mice and pocket mice, but also ground squirrels, desert cottontails, striped skunks, American badgers, raccoons, and others), 52.3% amphibians (large numbers of California tiger salamanders and California red - legged frogs, but also Sierran treefrogs, western toads, arboreal salamanders, slender salamanders and others), and 11.7% reptiles (many western fence lizards, but also skinks, alligator lizards, and snakes of various species). VMT is useful for predicting wildlife mortality because I was able to quantify miles traveled along the studied reach of Vasco Road during the time period of the Mendelsohn et al. (2009), hence enabling a rate of fatalities per VMT that can be projected to other sites, assuming similar collision fatality rates. Predicting project-generated traffic impacts to wildlife The IS/MND predicts 571,398 annual vehicle miles traveled (VMT). During the Mendelsohn et al. (2009) study, 19,500 cars traveled Vasco Road daily, so the vehicle miles that contributed to my estimate of non-volant fatalities was 19,500 cars and trucks × 2.5 miles × 365 days/year × 1.25 years = 22,242,187.5 vehicle miles per 12,187 wildlife fatalities, or 1,825 vehicle miles per fatality. This rate divided into the IS/MND’s prediction of 571,398 annual VMT due to the project predicts 313 vertebrate wildlife fatalities per year. Operations over 50 years would accumulate 15,650 wildlife fatalities. It remains unknown whether and to what degree vehicle tires contribute to carcass removals from the roadway, thereby contributing a negative bias to the fatality estimates I made from the Mendelsohn et al. (2009) fatality counts. Based on my assumptions and simple calculations, the project-generated traffic would cause substantial, significant impacts to wildlife. The IS/MND does not address this potential impact, let alone propose to mitigate it. There is at least a fair argument that can be made for the need to prepare an EIR to analyze this impact. Mitigation measures to improve wildlife safety along roads are available and are feasible, and they need exploration for their suitability with the proposed project. CUMULATIVE IMPACTS The IS/MND provides a flawed analysis. It provides no analysis of cumulative impacts specific to biological resources. According to the IS/MND, the project would cause no project-level significant impacts specific to any environmental issues addressed by the IS/MND. The IS/MND implies that cumulative effects are simply residual impacts of incomplete mitigation of project-level impacts. This notion is inconsistent with CEQA’s definition of cumulative impacts and how to analyze them. If this was CEQA’s standard, 62 25 then cumulative effects analysis would be merely an analysis of mitigation efficacy. The IS's analysis is based on an assumption that other projects in the area adequately mitigated their impacts to wildlife, thereby leaving no impacts to accumulate. Again, this is not how CEQA defines cumulative impacts and it is inconsistent with the Precautionary Principle in risk analysis directed to rare or precious resources. Even where impacts may be individually limited, their “incremental effects of an individual project are significant when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects.” (CEQA Guidelines §15064(h)(1)). MITIGATION MEASURES The IS/MND proposes only one mitigation measure for biological resources adversely affected by the project. MM-BIO-1: Pre-Construction Nesting Bird Survey Preconstruction surveys should be performed for nesting birds, but not as a substitute for detection surveys. Preconstruction surveys are not designed or intended to reduce project impacts. Preconstruction surveys are only intended as last-minute, one-time salvage and rescue operations targeting readily detectable nests or individuals before they are crushed under heavy construction machinery. Because most special-status species are rare and cryptic, and because most bird species are expert at hiding their nests lest they get predated, most of their nests will not be detected by preconstruction surveys without prior support of detection surveys. Locating all of the nests on site would require more effort than is committed during preconstruction surveys. Detection surveys are needed to inform preconstruction take-avoidance surveys by mapping out where biologists performing preconstruction surveys are most likely to find animals or their breeding sites. Detection surveys are needed to assess impacts and to inform the formulation of appropriate mitigation measures, because preconstruction surveys are not intended for these roles either. Following detection surveys, preconstruction surveys should be performed. However, an EIR should be prepared, and it should detail how the results of preconstruction surveys would be reported. Without reporting the results, preconstruction surveys are vulnerable to serving as an empty gesture rather than a mitigation measure. For these reasons, and because the salvage of readily detectable animals or their nests would not prevent the permanent loss of habitat, the proposed mitigation measure is not sufficient to reduce the project’s impacts to nesting birds to less than significant levels. RECOMMENDED MEASURES The IS/MND proposes only preconstruction surveys, but no compensatory mitigation for habitat loss or losses to project-generated traffic. A fair argument can be made for the need to prepare an EIR to formulate appropriate measures to mitigate project 63 26 impacts to wildlife. Below are few suggestions of measures that ought to be considered in an EIR. Detection Surveys: If the project goes forward, species detection surveys are needed to (1) support negative findings of species when appropriate, (2) inform preconstruction surveys to improve their efficacy, (3) estimate project impacts, and (4) inform compensatory mitigation and other forms of mitigation. Detection survey protocols and guidelines are available from resource agencies for most special-status species. Otherwise, professional standards can be learned from the scientific literature and species’ experts. An example of a survey protocol that needs to be implemented is the CDFW (2012) survey guidelines for burrowing owl. Ground squirrels occur all around the site, so burrows and squirrels are available in support of burrowing owls. The space of the site is also open, which provides burrowing owls the field of view they need to avoid predation. The survey guidelines should be implemented, including within the recommended buffer space around the project site. The guidelines call for multiple surveys throughout the breeding season. Detection Surveys for Bats: Multiple special-status species of bats likely occur on and around the project site. A qualified bat biologist should be tasked with completing protocol-level detection surveys for bats. It needs to be learned whether bats roost in the adjacent row of trees along the west border and within the elderberry shrubs along the south and east borders. Whether bats forage on site also needs to be learned. Preconstruction surveys: Reports of the methods and outcomes of preconstruction surveys should be required. The reports should be made available to the public. Construction Monitoring: If the project goes forward, two or more qualified biologists need to serve as construction monitors. They should have the authority to stop construction when construction poses a threat to wildlife, and they should have the authority to rectify situations that pose threats to wildlife. The events associated with construction monitoring, such as efforts to avoid impacts and findings of dead and injured wildlife, need to be summarized in a report that is subsequently made available to the public. Habitat Loss: If the project goes forward, compensatory mitigation would be warranted for habitat loss. An equal area of land should be protected in perpetuity as close to the project site as possible. Additional compensatory mitigation should be linked to impacts identified in construction monitoring. Road Mortality: Compensatory mitigation is needed for the increased wildlife mortality that would be caused by the project-generated road traffic in the region. I suggest that this mitigation can be directed toward funding research to identify fatality patterns and effective impact reduction measures such as reduced speed limits and wildlife under-crossings or overcrossings of particularly dangerous road segments. Compensatory mitigation can also be provided in the form of donations to wildlife rehabilitation facilities (see below). 64 27 Pest Control: The project should commit to minimal use of rodenticides and avicides. It should commit to no placement of poison bait stations outside the buildings. Fund Wildlife Rehabilitation Facilities: Compensatory mitigation ought also to include funding contributions to wildlife rehabilitation facilities to cover the costs of injured animals that will be delivered to these facilities for care. Many animals would likely be injured by collisions with automobiles. Thank you for your attention, ______________________ Shawn Smallwood, Ph.D. REFERENCES CITED Bishop, C. A. and J. M. Brogan. 2013. Estimates of avian mortality attributed to vehicle collisions in Canada. Avian Conservation and Ecology 8:2. http://dx.doi.org/ 10.5751/ACE-00604-080202. Brown, K., K. S. Smallwood, J. Szewczak, and B. Karas. 2016. Final 2012-2015 Report Avian and Bat Monitoring Project Vasco Winds, LLC. Prepared for NextEra Energy Resources, Livermore, California. CDFW (California Department of Fish and Wildlife). 2012. Staff Report on Burrowing Owl Mitigation. Sacramento, California. Chambers Group. 2022. Biological Resources Reconnaissance Assessment for the Pentair Expansion Project. Letter to City of Moorpark. City of Moorpark. 2022. Pentair Warehouse Expansion Draft Initial Study/ Mitigated Negative Declaration, Moorpark, CA. Prepared by Chambers Group for City of Lancaster, California. Forman, T. T., D. Sperling, J. A. Bisonette, A. P. Clevenger, C. D. Cutshall, V. H. Dale, L. Fahrig, R. France, C. R. Goldman, K. Heanue, J. A. Jones, F. J. Swanson, T. Turrentine, and T. C. Winter. 2003. Road Ecology. Island Press, Covello, California. Hall, L. S., P. R. Krausman, and M. L. Morrison. 1997. “The habitat concept and a plea for standard terminology.” Wildlife Society Bulletin 25:173-82. Loss, S. R., T. Will, and P. P. Marra. 2014. Estimation of Bird-Vehicle Collision Mortality on U.S. Roads. Journal of Wildlife Management 78:763-771. 65 28 Mendelsohn, M., W. Dexter, E. Olson, and S. Weber. 2009. Vasco Road wildlife movement study report. Report to Contra Costa County Public Works Department, Martinez, California. National Research Council. 1986. Ecological knowledge and environmental problem- solving: concepts and case studies. National Academy Press, Washington, D.C. Rosenberg, K. V., A. M. Dokter, P. J. Blancher, J. R. Sauer, A. C. Smith, P. A. Smith, J. C. Stanton, A. Panjabi , L. Helft , M. Parr, and P. P. Marra. 2019. Decline of the North American avifauna. Science 10.1126/science.aaw1313 (2019). Runge, C. A., T. G. Martin, H. P. Possingham, S. G. Willis, and R. A. Fuller. 2014. Conserving mobile species. Frontiers in Ecology and Environment 12(7): 395–402, doi:10.1890/130237. Santos, S. M., F. Carvalho, and A. Mira. 2011. How long do the dead survive on the road? Carcass persistence probability and implications for road-kill monitoring surveys. PLoS ONE 6(9): e25383. doi:10.1371/journal.pone.0025383 Shuford, W. D., and T. Gardali, [eds.]. 2008. California bird species of special concern: a ranked assessment of species, subspecies, and distinct populations of birds of immediate conservation concern in California. Studies of Western Birds 1. Western Field Ornithologists, Camarillo, California. Smallwood, K.S. 2002. Habitat models based on numerical comparisons. Pages 83-95 in Predicting species occurrences: Issues of scale and accuracy, J. M. Scott, P. J. Heglund, M. Morrison, M. Raphael, J. Haufler, and B. Wall, editors. Island Press, Covello, California. Taylor, P. D., S. A. Mackenzie, B. G. Thurber, A. M. Calvert, A. M. Mills, L. P. McGuire, and C. G. Guglielmo. 2011. Landscape movements of migratory birds and bats reveal an expanded scale of stopover. PlosOne 6(11): e27054. doi:10.1371/journal.pone.0027054. Warnock, N. 2010. Stopping vs. staging: the difference between a hop and a jump. Journal of Avian Biology 41:621-626. Yahner, R. H. 1982. Avian nest densities and nest-site selection in farmstead shelterbelts. The Wilson Bulletin 94:156-175. Young, H. 1948. A comparative study of nesting birds in a five-acre park. The Wilson Bulletin 61:36-47. 66 EXHIBIT B 67 2656 29th Street, Suite 201 Santa Monica, CA 90405 Matt Hagemann, P.G, C.Hg. (949) 887-9013 mhagemann@swape.com Paul E. Rosenfeld, PhD (310) 795-2335 prosenfeld@swape.com August 16, 2022 Victoria Yundt Lozeau | Drury LLP 1939 Harrison Street, Suite 150 Oakland, CA 94618 Subject: Comments on the Pentair Warehouse Expansion Project (SCH No. 2022070289) Dear Ms. Yundt, We have reviewed the July 2022 Initial Study / Mitigated Negative Declaration (“IS/MND”) for the Pentair Warehouse Expansion Project (“Project”) located in the City of Moorpark (“City”). The Project proposes to construct 87,566-square-feet (“SF”) of warehouse space, 3,000-SF of office space, and 185 parking spaces on the 5.65-acre site. Our review concludes that the IS/MND 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 are underestimated and inadequately addressed. An 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 Failure to Adequately Mitigate Construction-Related Criteria Air Pollutant Emissions Regarding the criteria air pollutant emissions associated with Project construction, the IS/MND states: “As detailed in the VCAPCD Guidelines, the VCAPCD has not established quantitative thresholds for particulate matter (PM10 and PM2.5); and the 25-pound-per-day threshold for ROG and NOx does not apply to construction emissions since the emissions are temporary. However, the VCAPCD indicates that a project that may generate fugitive dust emissions in such quantities as to cause injury, detriment, nuisance, or annoyance to any considerable number of persons, or which may endanger the comfort, repose, health, or safety of any such person, or which may 68 2 cause or have a natural tendency to cause injury or damage to business or property would have a significant air quality impact. In order to reduce air quality impacts from construction activities, the VCAPCD requires that all projects minimize construction emissions through adherence to the VCAPCD Rule 55 fugitive dust control measures and minimize ROG through adherence to the VCAPCD Rule 74.2 architectural coating VOC content limits. Compliance with VCAPCD Rules 55 and 74.2 would ensure that construction emissions would not be generated in such quantities as to cause injury, detriment, nuisance, or annoyance to any considerable number of persons or that may endanger the comfort, repose, health or safety of any such person or the public. Therefore, a less than significant air quality impact would occur from construction of the Proposed Project” (IS/MND, pp. 24). As demonstrated above, the IS/MND claims that the Ventura County Air Pollution Control District (“VCAPCD”) significant thresholds do not apply to construction emissions, and that the VCAPCD only requires adherence to Rules 55 and 74.2. However, this is incorrect. According to VCAPCD Air Quality Assessment Guidelines: “Construction-related emissions (including portable engines and portable engine-driven equipment subject to the ARB’s Statewide Portable Equipment Registration Program, and used for construction operations or repair and maintenance activities) of ROC and NOx are not counted towards the two significance thresholds, since these emissions are temporary. However, construction-related emissions should be mitigated if estimates of ROC and NOx emissions from the heavy-duty construction equipment anticipated to be used for a particular project exceed the 5 pounds per day threshold in the Ojai Planning Area, or the 25 pounds per day threshold in the remainder of the county. Mitigation measures to reduce such emissions are listed in Section 7.4.3, “ROC and NOx Construction Mitigation Measures” and in the mitigation module of URBEMIS” (emphasis added).1 Here, the IS/MND estimates that the VOC and NOx emissions associated with Project construction are greater than 25 pounds per day (“lbs/day”) (see excerpt below) (p. 18, Table 4). 1 “Ventura County Air Quality Assessment Guidelines.” October 2003, available at: http://www.vcapcd.org/pubs/Planning/VCAQGuidelines.pdf, p. 5-3 – 5-4. 69 3 As demonstrated above, the Project’s construction-related VOC and NOx emissions exceed the applicable VCAPCD threshold. As such, the IS/MND is required to incorporate the following measures pursuant to VCAPCD Guidelines Section 7.4.3: “As discussed in Chapter 5, Estimating Ozone Precursor Emissions, ozone precursor emissions from construction vehicles can be substantial. However, there are very few feasible measures available to reduce these emissions. APCD recommends the following measures to mitigate ozone precursor emissions from construction motor vehicles: 1. Minimize equipment idling time. 2. Maintain equipment engines in good condition and in proper tune as per manufacturers’ specifications. 3. Lengthen the construction period during smog season (May through October), to minimize the number of vehicles and equipment operating at the same time. 4. Use alternatively fueled construction equipment, such as compressed natural gas (CNG), liquefied natural gas (LNG), or electric, if feasible.”2 Thus, until the IS/MND incorporates the above-mentioned mitigation, the IS/MND’s air quality analysis, and subsequent less-than-significant impact conclusion, should not be relied upon. Diesel Particulate Matter Emissions Inadequately Evaluated The IS/MND concludes that the Project would have a less-than-significant health risk impact without conducting a quantified construction or operational health risk analysis (“HRA”). Regarding the health risk impacts associated with the Project construction, the IS/MND states: “Construction of the Proposed Project would generate TAC emissions from the onsite operation of diesel-powered equipment in the form of diesel particulate matter (DPM). Given the relatively limited number of heavy-duty construction equipment, the varying distances to the nearby sensitive receptors that construction equipment would operate, and the short-term construction schedule, the Proposed Project would not result in a long-term (i.e., 70 years) substantial source of toxic air contaminant emissions and corresponding individual cancer risk. In addition, CCR Title 13, Article 4.8, Chapter 9, Section 2449 regulates emissions from off-road diesel equipment in California. This regulation limits idling of equipment to no more than five minutes and requires equipment operators to label each piece of equipment and provide annual reports to CARB of their fleet’s usage and emissions. This regulation also requires systematic upgrading of the emission Tier level of each fleet; currently, no commercial operator is allowed to purchase Tier 0 or Tier 1 equipment; and by January 2023 no commercial operator is allowed to purchase Tier 2 equipment. In addition to the purchase restrictions, equipment operators need to meet fleet average emissions targets that become more stringent each year between 2 “Ventura County Air Quality Assessment Guidelines.” October 2003, available at: http://www.vcapcd.org/pubs/Planning/VCAQGuidelines.pdf, p. 7-8. 70 4 years 2014 and 2023. Therefore, less-than-significant short-term toxic air contaminant impacts would occur during construction of the Proposed Project” (p. 20). As demonstrated above, the IS/MND concludes that the Project would result in a less-than-significant construction-related health risk impact because the short-term construction duration, limited amount of heavy-duty equipment, distance from sensitive receptors, and compliance with applicable regulations would not result in substantial toxic air contaminant (“TAC”) emissions. Regarding the health risk impacts associated with the Project operation, the IS/MND states: “Particulate matter (PM) from diesel exhaust is the predominant TAC in most areas; and, according to The California Almanac of Emissions and Air Quality 2013 Edition prepared by CARB, about 80 percent of the outdoor TAC cancer risk is from diesel exhaust. Some chemicals in diesel exhaust, such as benzene and formaldehyde, have been listed as carcinogens by State Proposition 65 and the Federal Hazardous Air Pollutants program. According to the Project Description (Section 1.3.2 Operations), the Proposed Project would generate 12 truck deliveries between 7:00 a.m. and 7:00 p.m. and 6 truck deliveries between 7:00 p.m. and 7:00 a.m., or approximately 18 truck deliveries per day. According to the Health Risk Assessments for Proposed Land Use Projects prepared by CAPCOA, July 2009, a truck distribution facility that accommodates 100 or more truck deliveries per day has the potential to create significant health risks from TAC emissions. Since the Proposed Project would generate less than a fifth of the truck deliveries that CAPCOA found would have the potential to create significant health risks, a less than significant TAC impact would occur during the on-going operations of the Proposed Project; and no mitigation would be required” (p. 21). As demonstrated above, the IS/MND concludes that the Project would result in a less-than-significant operational health risk impact because the proposed Project would not generate more than 100 truck trips per day. However, the IS/MND’s evaluation of the Project’s potential health risk impacts, as well as the subsequent less-than-significant impact conclusion, is incorrect for four reasons. First, the IS/MND indicates that the Project is exempt from the preparation of an HRA according to CAPCOA, as the proposed warehouse building would not generate more than 100 truck deliveries per day. This is incorrect, as the above-referenced CAPCOA guidance is in reference to the recommended preparation of an HRA for the development of a new receptor, not for a new source. Specifically, CAPCOA states: “Avoid siting new sensitive land uses within 1,000 feet of a distribution center (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).”3 As demonstrated above, the correct use of this guidance would be to avoid locating new residential developments within 1,000-feet of an existing distribution center. As such, the IS/MND’s conclusion that 3“Health Risk Assessments for Proposed Land Use Projects.” CAPCOA, July 2009, available at: http://www.capcoa.org/wp-content/uploads/2012/03/CAPCOA_HRA_LU_Guidelines_8-6-09.pdf, p. 9, Table 2. 71 5 the Project is exempt from the preparation of an HRA is based on an incorrect interpretation of CAPCOA guidance and should not be relied upon. Second, by failing to prepare a quantified construction and operational HRA, the Project is inconsistent with CEQA’s requirement to make “a reasonable effort to substantively connect a project’s air quality impacts to likely health consequences.”4 This poses a problem, as according to the IS/MND, construction of the Project would produce DPM emissions through the exhaust stacks of construction equipment over a duration of approximately 12 months (p. 6). Furthermore, according to the Traffic and Circulation Study, provided as Appendix K to the IS/MND, operation of the Project is expected to generate 216 daily vehicle trips, which would produce additional exhaust emissions and continue to expose nearby, existing sensitive receptors to DPM emissions (p. 9, Table 3). However, the IS/MND and associated documents fail to evaluate the TAC emissions associated with Project construction and operation or indicate the concentrations at which such pollutants would trigger adverse health effects. Thus, without making a reasonable effort to connect the Project’s TAC emissions to the potential health risks posed to nearby receptors, the IS/MND is inconsistent with CEQA’s requirement to correlate Project-generated emissions with potential adverse impacts on human health. Third, the State of California Department of Justice recommends that warehouse projects prepare a quantitative HRA pursuant to the Office of Environmental Health Hazard Assessment (“OEHHA”), the organization responsible for providing guidance on conducting HRAs in California, as well as local air district guidelines.5 In February 2015, OEHHA released its most recent Risk Assessment Guidelines: Guidance Manual for Preparation of Health Risk Assessments. This guidance document describes the types of projects that warrant the preparation of an HRA. Specifically, OEHHA recommends that all short-term projects lasting at least 2 months assess cancer risks.6 Furthermore, according to OEHHA: “Exposure from projects lasting more than 6 months should be evaluated for the duration of the project. In all cases, for assessing risk to residential receptors, the exposure should be assumed to start in the third trimester to allow for the use of the ASFs (OEHHA, 2009).”7 Thus, as the Project’s anticipated construction duration exceeds the 2-month and 6-month requirements set forth by OEHHA, construction of the Project meets the threshold warranting a quantified HRA under OEHHA guidance and should be evaluated for the entire 12-month construction period. Furthermore, OEHHA recommends that an exposure duration of 30 years should be used to 4 “Sierra Club v. County of Fresno.” Supreme Court of California, December 2018, available at: https://ceqaportal.org/decisions/1907/Sierra%20Club%20v.%20County%20of%20Fresno.pdf. 5 “Warehouse Projects: Best Practices and Mitigation Measures to Comply with the California Environmental Quality Act.” State of California Department of Justice, available at: https://oag.ca.gov/sites/all/files/agweb/pdfs/environment/warehouse-best-practices.pdf, p. 6. 6 “Risk Assessment Guidelines: Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February 2015, available at: https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf, p. 8-18. 7 “Risk Assessment Guidelines: Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February 2015, available at: https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf, p. 8-18. 72 6 estimate the individual cancer risk at the maximally exposed individual resident (“MEIR”).8 While the IS/MND fails to provide the expected lifetime of the proposed Project, we can reasonably assume that the Project would operate for at least 30 years, if not more. Therefore, operation of the Project also exceeds the 2-month and 6-month requirements set forth by OEHHA and should be evaluated for the entire 30-year residential exposure duration, as indicated by OEHHA guidance. These recommendations reflect the most recent state health risk policies, and as such, an EIR should be prepared to include an analysis of health risk impacts posed to nearby sensitive receptors from Project-generated DPM emissions. Fourth, by claiming a less-than-significant impact without conducting a quantified construction or operational HRA for nearby, existing sensitive receptors, the IS/MND fails to compare the Project’s excess cancer risk to the VCAPCD specific numeric threshold of 10 in one million.9 Thus, in accordance with the most relevant guidance, an assessment of the health risk posed to nearby, existing receptors as a result of Project construction and operation should be conducted. Screening-Level Analysis Demonstrates Potentially Significant Health Risk Impact In order to conduct our screening-level risk assessment we relied upon AERSCREEN, which is a screening level air quality dispersion model.10 The model replaced SCREEN3, and AERSCREEN is included in the OEHHA and the California Air Pollution Control Officers Associated (“CAPCOA”) guidance as the appropriate air dispersion model for Level 2 health risk screening assessments (“HRSAs”).11, 12 A Level 2 HRSA utilizes a limited amount of site-specific information to generate maximum reasonable downwind concentrations of air contaminants to which nearby sensitive receptors may be exposed. If an unacceptable air quality hazard is determined to be possible using AERSCREEN, a more refined modeling approach is required prior to approval of the Project. We prepared a preliminary HRA of the Project’s construction and operational health risk impact to residential sensitive receptors using the annual PM10 exhaust estimates from the IS/MND’s CalEEMod output files. Consistent with recommendations set forth by OEHHA, we assumed residential exposure begins during the third trimester stage of life.13 The IS/MND’s CalEEMod model indicates that construction activities will generate approximately 202 pounds of DPM over the 362-day construction period.14 The AERSCREEN model relies on a continuous average emission rate to simulate maximum 8 “Risk Assessment Guidelines: Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February 2015, available at: https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf, p. 2-4. 9 “Ventura County Air Quality Assessment Guidelines.” Ventura County Air Pollution Control District (VCAPCD), October 2003, available at: http://www.vcapcd.org/pubs/Planning/VCAQGuidelines.pdf, p. 3-5. 10 “AERSCREEN Released as the EPA Recommended Screening Model,” U.S. EPA, April 2011, available at: http://www.epa.gov/ttn/scram/guidance/clarification/20110411_AERSCREEN_Release_Memo.pdf 11 “Risk Assessment Guidelines: Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February 2015, available at: https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf. 12 “Health Risk Assessments for Proposed Land Use Projects.” CAPCOA, July 2009, available at: http://www.capcoa.org/wp-content/uploads/2012/03/CAPCOA_HRA_LU_Guidelines_8-6-09.pdf. 13 “Risk Assessment Guidelines: Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February 2015, available at: https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf, p. 8-18. 14 See Attachment A for health risk calculations. 73 7 downward concentrations from point, area, and volume emission sources. To account for the variability in equipment usage and truck trips over Project construction, we calculated an average DPM emission rate by the following equation: 𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸 𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅 �𝑔𝑔𝑔𝑔𝑅𝑅𝐸𝐸𝐸𝐸𝐸𝐸𝑅𝑅𝑠𝑠𝐸𝐸𝐸𝐸𝑠𝑠�= 201.9 𝑙𝑙𝑙𝑙𝐸𝐸362 𝑠𝑠𝑅𝑅𝑑𝑑𝐸𝐸 × 453.6 𝑔𝑔𝑔𝑔𝑅𝑅𝐸𝐸𝐸𝐸𝑙𝑙𝑙𝑙𝐸𝐸 × 1 𝑠𝑠𝑅𝑅𝑑𝑑24 ℎ𝐸𝐸𝑜𝑜𝑔𝑔𝐸𝐸 × 1 ℎ𝐸𝐸𝑜𝑜𝑔𝑔3,600 𝐸𝐸𝑅𝑅𝑠𝑠𝐸𝐸𝐸𝐸𝑠𝑠𝐸𝐸 =𝟎𝟎.𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎 𝒈𝒈/𝒔𝒔 Using this equation, we estimated a construction emission rate of 0.00293 grams per second (“g/s”). Subtracting the 362-day construction period from the total residential duration of 30 years, we assumed that after Project construction, the sensitive receptor would be exposed to the Project’s operational DPM for an additional 29.01 years. The IS/MND’s operational CalEEMod emissions indicate that operational activities will generate approximately 6 pounds of DPM per year throughout operation. Applying the same equation used to estimate the construction DPM rate, we estimated the following emission rate for Project operation: 𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸 𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅 �𝑔𝑔𝑔𝑔𝑅𝑅𝐸𝐸𝐸𝐸𝐸𝐸𝑅𝑅𝑠𝑠𝐸𝐸𝐸𝐸𝑠𝑠�= 5.9 𝑙𝑙𝑙𝑙𝐸𝐸 365 𝑠𝑠𝑅𝑅𝑑𝑑𝐸𝐸 × 453.6 𝑔𝑔𝑔𝑔𝑅𝑅𝐸𝐸𝐸𝐸𝑙𝑙𝑙𝑙𝐸𝐸 × 1 𝑠𝑠𝑅𝑅𝑑𝑑24 ℎ𝐸𝐸𝑜𝑜𝑔𝑔𝐸𝐸 × 1 ℎ𝐸𝐸𝑜𝑜𝑔𝑔3,600 𝐸𝐸𝑅𝑅𝑠𝑠𝐸𝐸𝐸𝐸𝑠𝑠𝐸𝐸=𝟎𝟎.𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎 𝒈𝒈/𝒔𝒔 Using this equation, we estimated an operational emission rate of 0.0000849 g/s. Construction and operation were simulated as a 5.65-acre rectangular area source in AERSCREEN, with approximate dimensions of 214- by 107-meters. A release height of three meters was selected to represent the height of stacks of operational equipment and other heavy-duty vehicles, and an initial vertical dimension of one and a half meters was used to simulate instantaneous plume dispersion upon release. An urban meteorological setting was selected with model-default inputs for wind speed and direction distribution. The population of Moorpark was obtained from U.S. 2020 Census data.15 The AERSCREEN model generates maximum reasonable estimates of single-hour DPM concentrations from the Project Site. The United States Environmental Protection Agency (“U.S. EPA”) suggests that the annualized average concentration of an air pollutant be estimated by multiplying the single-hour concentration by 10% in screening procedures.16 According to the IS/MND the nearest sensitive receptors are single-family homes located adjacent to the Project site (p. 19). However, review of the AERSCREEN output files demonstrates that the MEIR is located approximately 100 meters from the Project site. Thus, the single-hour concentration estimated by AERSCREEN for Project construction is approximately 4.632 µg/m3 DPM at approximately 100 meters downwind. Multiplying this single-hour concentration by 10%, we get an annualized average concentration of 0.4632 µg/m3 for Project construction at the MEIR. For Project operation, the single-hour concentration estimated by AERSCREEN is 0.1342 µg/m3 DPM at approximately 100 meters downwind. Multiplying this single-hour concentration by 10%, we get an annualized average concentration of 0.01342 µg/m3 for Project operation at the MEIR. 15 “Moorpark.” U.S. Census Bureau, 2020, available at: https://datacommons.org/place/geoId/0649138. 16 “Screening Procedures for Estimating the Air Quality Impact of Stationary Sources Revised.” U.S. EPA, October 1992, available at: http://www.epa.gov/ttn/scram/guidance/guide/EPA-454R-92-019_OCR.pdf. 74 8 We calculated the excess cancer risk to the MEIR using applicable HRA methodologies prescribed by OEHHA, as recommended by VCAPCD.17 Specifically, guidance from OEHHA and the California Air Resources Board (“CARB”) recommends the use of a standard point estimate approach, including high- point estimate (i.e. 95th percentile) breathing rates and age sensitivity factors (“ASF”) in order to account for the increased sensitivity to carcinogens during early-in-life exposure and accurately assess risk for susceptible subpopulations such as children. The residential exposure parameters, such as the daily breathing rates (“BR/BW”), exposure duration (“ED”), age sensitivity factors (“ASF”), fraction of time at home (“FAH”), and exposure frequency (“EF”) utilized for the various age groups in our screening-level HRA are as follows: Exposure Assumptions for Residential Individual Cancer Risk Age Group Breathing Rate (L/kg-day)18 Age Sensitivity Factor 19 Exposure Duration (years) Fraction of Time at Home 20 Exposure Frequency (days/year)21 Exposure Time (hours/day) 3rd Trimester 361 10 0.25 0.85 350 24 Infant (0 - 2) 1090 10 2 0.85 350 24 Child (2 - 16) 572 3 14 0.72 350 24 Adult (16 - 30) 261 1 14 0.73 350 24 For the inhalation pathway, the procedure requires the incorporation of several discrete variates to effectively quantify dose for each age group. Once determined, contaminant dose is multiplied by the cancer potency factor (“CPF”) in units of inverse dose expressed in milligrams per kilogram per day (mg/kg/day-1) to derive the cancer risk estimate. Therefore, to assess exposures, we utilized the following dose algorithm: 𝐷𝐷𝐸𝐸𝐸𝐸𝑅𝑅𝐴𝐴𝐴𝐴𝐴𝐴,𝑝𝑝𝑝𝑝𝑝𝑝 𝑎𝑎𝑎𝑎𝑝𝑝 𝑎𝑎𝑝𝑝𝑔𝑔𝑔𝑔𝑝𝑝= 𝐶𝐶𝑎𝑎𝑎𝑎𝑝𝑝× 𝐸𝐸𝐸𝐸 × �𝐵𝐵𝑅𝑅𝐵𝐵𝐵𝐵� × 𝐴𝐴 × 𝐶𝐶𝐸𝐸 where: DoseAIR = dose by inhalation (mg/kg/day), per age group 17 “Ventura County Air Quality Assessment Guidelines.” Ventura County Air Pollution Control District, October 2003, available at: http://www.vcapcd.org/pubs/Planning/VCAQGuidelines.pdf, p. 6-6 – 6-8. 18 “Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February 2015, available at: https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf. 19 “Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February 2015, available at: https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf, p. 8-5 Table 8.3. 20 “Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February 2015, available at: https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf, p. 8-5, Table 8.4. 21 “Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February 2015, available at: https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf, p. 5-24. 75 9 Cair = concentration of contaminant in air (μg/m3) EF = exposure frequency (number of days/365 days) BR/BW = daily breathing rate normalized to body weight (L/kg/day) A = inhalation absorption factor (default = 1) CF = conversion factor (1x10-6, μg to mg, L to m3) To calculate the overall cancer risk, we used the following equation for each appropriate age group: 𝐶𝐶𝑅𝑅𝐸𝐸𝑠𝑠𝑅𝑅𝑔𝑔 𝑅𝑅𝐸𝐸𝐸𝐸𝑅𝑅𝐴𝐴𝐴𝐴𝐴𝐴= 𝐷𝐷𝐸𝐸𝐸𝐸𝑅𝑅𝐴𝐴𝐴𝐴𝐴𝐴 × 𝐶𝐶𝐶𝐶𝐸𝐸 × 𝐴𝐴𝐴𝐴𝐸𝐸 × 𝐸𝐸𝐴𝐴𝐹𝐹 × 𝐸𝐸𝐷𝐷𝐴𝐴𝐴𝐴 where: DoseAIR = dose by inhalation (mg/kg/day), per age group CPF = cancer potency factor, chemical-specific (mg/kg/day)-1 ASF = age sensitivity factor, per age group FAH = fraction of time at home, per age group (for residential receptors only) ED = exposure duration (years) AT = averaging time period over which exposure duration is averaged (always 70 years) Consistent with the 362-day construction schedule, the annualized average concentration for construction was used for the entire third trimester of pregnancy (0.25 years), and the first 0.74 years of the infantile stage of life (0 – 2 years). The annualized average concentration for operation was used for the remainder of the 30-year exposure period, which makes up the latter 1.26 years of the infantile stage of life, as well as the entire child (2 – 16) and adult (16 – 30 years) stages of life. The results of our calculations are shown in the table below. The Maximally Exposed Individual at an Existing Residential Receptor Age Group Emissions Source Duration (years) Concentration (ug/m3) Cancer Risk 3rd Trimester Construction 0.25 0.4632 5.35E-06 Construction 0.74 0.4632 4.80E-05 Operation 1.26 0.0134 2.36E-06 Infant (0 - 2) Total 2 5.03E-05 Child (2 - 16) Operation 14 0.0134 3.50E-06 Adult (16 - 30) Operation 14 0.0134 5.39E-07 Lifetime 30 5.97E-05 76 10 As demonstrated in the table above, the excess cancer risks for the 3rd trimester of pregnancy, infants, children, and adults at the MEIR located approximately 100 meters away, over the course of Project construction and operation, are approximately 5.35, 50.3, 3.5, and 0.539 in one million, respectively. The excess cancer risk over the course of a residential lifetime (30 years) is approximately 59.7 in one million. The infant and lifetime cancer risks exceed the VCAPCD threshold of 10 in one million, thus resulting in a potentially significant impact not previously addressed or identified by the IS/MND. Our analysis represents a screening-level HRA, which is known to be conservative and tends to err on the side of health protection. The purpose of the screening-level HRA is to demonstrate the potential link between Project-generated emissions and adverse health risk impacts. According to the U.S. EPA: “EPA’s Exposure Assessment Guidelines recommend completing exposure assessments iteratively using a tiered approach to ‘strike a balance between the costs of adding detail and refinement to an assessment and the benefits associated with that additional refinement’ (U.S. EPA, 1992). In other words, an assessment using basic tools (e.g., simple exposure calculations, default values, rules of thumb, conservative assumptions) can be conducted as the first phase (or tier) of the overall assessment (i.e., a screening-level assessment). The exposure assessor or risk manager can then determine whether the results of the screening- level assessment warrant further evaluation through refinements of the input data and exposure assumptions or by using more advanced models.” As demonstrated above, screening-level analyses warrant further evaluation in a refined modeling approach. Thus, as our screening-level HRA demonstrates that construction and operation of the Project could result in a potentially significant health risk impact, an EIR should be prepared to include a refined health risk analysis which adequately and accurately evaluates health risk impacts associated with both Project construction and operation. Mitigation Feasible Mitigation Measures Available to Reduce Emissions The IS/MND’s analysis demonstrates that the Project would result in potentially significant air quality and health risk impacts that should be mitigated further. In an effort to reduce the Project’s emissions, we identified several mitigation measures that are applicable to the proposed Project. Feasible mitigation measures can be found in the Department of Justice Warehouse Project Best Practices document.22 Therefore, to reduce the Project’s emissions, consideration of the following measures should be made: • Prohibiting off-road diesel-powered equipment from being in the “on” position for more than 10 hours per day. 22 “Warehouse Projects: Best Practices and Mitigation Measures to Comply with the California Environmental Quality Act.” State of California Department of Justice. 77 11 • Requiring on-road heavy-duty haul trucks to be model year 2010 or newer if diesel-fueled. • Providing electrical hook ups to the power grid, rather than use of diesel-fueled generators, for electric construction tools, such as saws, drills and compressors, and using electric tools whenever feasible. • Limiting the amount of daily grading disturbance area. • Prohibiting grading on days with an Air Quality Index forecast of greater than 100 for particulates or ozone for the project area. • Forbidding idling of heavy equipment for more than two minutes. • Keeping onsite and furnishing to the lead agency or other regulators upon request, all equipment maintenance records and data sheets, including design specifications and emission control tier classifications. • Conducting an on-site inspection to verify compliance with construction mitigation and to identify other opportunities to further reduce construction impacts. • Using paints, architectural coatings, and industrial maintenance coatings that have volatile organic compound levels of less than 10 g/L. • Providing information on transit and ridesharing programs and services to construction employees. • Providing meal options onsite or shuttles between the facility and nearby meal destinations for construction employees. • Requiring that all facility-owned and operated fleet equipment with a gross vehicle weight rating greater than 14,000 pounds accessing the site meet or exceed 2010 model-year emissions equivalent engine standards as currently defined in California Code of Regulations Title 13, Division 3, Chapter 1, Article 4.5, Section 2025. Facility operators shall maintain records on-site demonstrating compliance with this requirement and shall make records available for inspection by the local jurisdiction, air district, and state upon request. • Requiring all heavy-duty vehicles entering or operated on the project site to be zero-emission beginning in 2030. • Requiring on-site equipment, such as forklifts and yard trucks, to be electric with the necessary electrical charging stations provided. • Requiring tenants to use zero-emission light- and medium-duty vehicles as part of business operations. • Forbidding trucks from idling for more than two minutes and requiring operators to turn off engines when not in use. • Posting both interior- and exterior-facing signs, including signs directed at all dock and delivery areas, identifying idling restrictions and contact information to report violations to CARB, the air district, and the building manager. • Installing and maintaining, at the manufacturer’s recommended maintenance intervals, air filtration systems at sensitive receptors within a certain radius of facility for the life of the project. • Installing and maintaining, at the manufacturer’s recommended maintenance intervals, an air monitoring station proximate to sensitive receptors and the facility for the life of the project, 78 12 and making the resulting data publicly available in real time. While air monitoring does not mitigate the air quality or greenhouse gas impacts of a facility, it nonetheless benefits the affected community by providing information that can be used to improve air quality or avoid exposure to unhealthy air. • Constructing electric truck charging stations proportional to the number of dock doors at the project. • Constructing electric plugs for electric transport refrigeration units at every dock door, if the warehouse use could include refrigeration. • Constructing electric light-duty vehicle charging stations proportional to the number of parking spaces at the project. • Installing solar photovoltaic systems on the project site of a specified electrical generation capacity, such as equal to the building’s projected energy needs. • Requiring all stand-by emergency generators to be powered by a non-diesel fuel. • Requiring facility operators to train managers and employees on efficient scheduling and load management to eliminate unnecessary queuing and idling of trucks. • Requiring operators to establish and promote a rideshare program that discourages single- occupancy vehicle trips and provides financial incentives for alternate modes of transportation, including carpooling, public transit, and biking. • Meeting CalGreen Tier 2 green building standards, including all provisions related to designated parking for clean air vehicles, electric vehicle charging, and bicycle parking. • Achieving certification of compliance with LEED green building standards. • Providing meal options onsite or shuttles between the facility and nearby meal destinations. • Posting signs at every truck exit driveway providing directional information to the truck route. • Improving and maintaining vegetation and tree canopy for residents in and around the project area. • Requiring that every tenant train its staff in charge of keeping vehicle records in diesel technologies and compliance with CARB regulations, by attending CARB-approved courses. Also require facility operators to maintain records on-site demonstrating compliance and make records available for inspection by the local jurisdiction, air district, and state upon request. • Requiring tenants to enroll in the United States Environmental Protection Agency’s SmartWay program, and requiring tenants to use carriers that are SmartWay carriers. • Providing tenants with information on incentive programs, such as the Carl Moyer Program and Voucher Incentive Program, to upgrade their fleets. These measures offer a cost-effective, feasible way to incorporate lower-emitting design features into the proposed Project, which subsequently, reduce emissions released during Project construction and operation. A EIR should be prepared to include all feasible mitigation measures, as well as include updated air quality and health risk analyses to ensure that the necessary mitigation measures are implemented to reduce emissions to below thresholds. The analysis should also demonstrate a commitment to the implementation of these measures prior to Project approval, to ensure that the Project’s significant emissions are reduced to the maximum extent possible. 79 13 Disclaimer SWAPE has received limited discovery regarding this project. Additional information may become available in the future; thus, we retain the right to revise or amend this report when additional information becomes available. Our professional services have been performed using that degree of care and skill ordinarily exercised, under similar circumstances, by reputable environmental consultants practicing in this or similar localities at the time of service. No other warranty, expressed or implied, is made as to the scope of work, work methodologies and protocols, site conditions, analytical testing results, and findings presented. This report reflects efforts which were limited to information that was reasonably accessible at the time of the work, and may contain informational gaps, inconsistencies, or otherwise be incomplete due to the unavailability or uncertainty of information obtained or provided by third parties. Sincerely, Matt Hagemann, P.G., C.Hg. Paul E. Rosenfeld, Ph.D. Attachment A: Health Risk Calculations Attachment B: AERSCREEN Output Files Attachment C: Matt Hagemann CV Attachment D: Paul E. Rosenfeld CV 80 Annual Emissions (tons/year)0.1018 Total DPM (lbs)201.9265753 Annual Emissions (tons/year)0.00295 Daily Emissions (lbs/day)0.557808219 Total DPM (g)91593.89458 Daily Emissions (lbs/day)0.016164384 Construction Duration (days)362 Emission Rate (g/s)0.002928493 Total DPM (lbs)5.9 Total DPM (lbs)201.9265753 Release Height (meters)3 Emission Rate (g/s)8.4863E-05 Total DPM (g)91593.89458 Total Acreage 5.65 Release Height (meters)3 Start Date 1/1/2023 Max Horizontal (meters)213.84 Total Acreage 5.65 End Date 12/29/2023 Min Horizontal (meters)106.92 Max Horizontal (meters)213.84 Construction Days 362 Initial Vertical Dimension (meters)1.5 Min Horizontal (meters)106.92 Setting Urban Initial Vertical Dimension (meters)1.5 Population 35,975 Setting Urban Start Date 1/1/2023 Population 35,975 End Date 12/29/2023 Total Construction Days 362 Total Years of Construction 0.99 Total Years of Operation 29.01 Construction Operation 2023 Total Emission Rate Attachment A 81 Start date and time 08/11/22 12:09:04 AERSCREEN 21112 Pentair Warehouse Expansion, Construction Pentair Warehouse Expansion, Construction ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ DATA ENTRY VALIDATION ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ METRIC ENGLISH ** AREADATA ** ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ Emission Rate: 0.293E‐02 g/s 0.232E‐01 lb/hr Area Height:3.00 meters 9.84 feet Area Source Length: 213.84 meters 701.57 feet Area Source Width: 106.92 meters 350.79 feet Vertical Dimension: 1.50 meters 4.92 feet Model Mode:URBAN Population:35975 Dist to Ambient Air:1.0 meters 3. feet ** BUILDING DATA ** Attachment B 82 No Building Downwash Parameters ** TERRAIN DATA ** No Terrain Elevations Source Base Elevation: 0.0 meters 0.0 feet Probe distance: 5000. meters 16404. feet No flagpole receptors No discrete receptors used ** FUMIGATION DATA ** No fumigation requested ** METEOROLOGY DATA ** Min/Max Temperature: 250.0 / 310.0 K ‐9.7 / 98.3 Deg F Minimum Wind Speed: 0.5 m/s 83 Anemometer Height: 10.000 meters Dominant Surface Profile: Urban Dominant Climate Type: Average Moisture Surface friction velocity (u*): not adjusted DEBUG OPTION ON AERSCREEN output file: 2022.08.11_AERSCREEN_PentairWarehouseExpansion_Construction.out *** AERSCREEN Run is Ready to Begin No terrain used, AERMAP will not be run ************************************************** SURFACE CHARACTERISTICS & MAKEMET Obtaining surface characteristics... 84 Using AERMET seasonal surface characteristics for Urban with Average Moisture Season Albedo Bo zo Winter 0.35 1.50 1.000 Spring 0.14 1.00 1.000 Summer 0.16 2.00 1.000 Autumn 0.18 2.00 1.000 Creating met files aerscreen_01_01.sfc & aerscreen_01_01.pfl Creating met files aerscreen_02_01.sfc & aerscreen_02_01.pfl Creating met files aerscreen_03_01.sfc & aerscreen_03_01.pfl Creating met files aerscreen_04_01.sfc & aerscreen_04_01.pfl Buildings and/or terrain present or rectangular area source, skipping probe FLOWSECTOR started 08/11/22 12:13:25 ******************************************** Running AERMOD Processing Winter Processing surface roughness sector 1 85 ***************************************************** Processing wind flow sector 1 AERMOD Finishes Successfully for FLOWSECTOR stage 2 Winter sector 0 ******** WARNING MESSAGES ******** *** NONE *** ***************************************************** Processing wind flow sector 2 AERMOD Finishes Successfully for FLOWSECTOR stage 2 Winter sector 5 ******** WARNING MESSAGES ******** *** NONE *** ***************************************************** Processing wind flow sector 3 AERMOD Finishes Successfully for FLOWSECTOR stage 2 Winter sector 10 ******** WARNING MESSAGES ******** *** NONE *** 86 ***************************************************** Processing wind flow sector 4 AERMOD Finishes Successfully for FLOWSECTOR stage 2 Winter sector 15 ******** WARNING MESSAGES ******** *** NONE *** ***************************************************** Processing wind flow sector 5 AERMOD Finishes Successfully for FLOWSECTOR stage 2 Winter sector 20 ******** WARNING MESSAGES ******** *** NONE *** ***************************************************** Processing wind flow sector 6 AERMOD Finishes Successfully for FLOWSECTOR stage 2 Winter sector 25 ******** WARNING MESSAGES ******** *** NONE *** ***************************************************** 87 Processing wind flow sector 7 AERMOD Finishes Successfully for FLOWSECTOR stage 2 Winter sector 30 ******** WARNING MESSAGES ******** *** NONE *** ******************************************** Running AERMOD Processing Spring Processing surface roughness sector 1 ***************************************************** Processing wind flow sector 1 AERMOD Finishes Successfully for FLOWSECTOR stage 2 Spring sector 0 ******** WARNING MESSAGES ******** *** NONE *** ***************************************************** Processing wind flow sector 2 AERMOD Finishes Successfully for FLOWSECTOR stage 2 Spring sector 5 88 ******** WARNING MESSAGES ******** *** NONE *** ***************************************************** Processing wind flow sector 3 AERMOD Finishes Successfully for FLOWSECTOR stage 2 Spring sector 10 ******** WARNING MESSAGES ******** *** NONE *** ***************************************************** Processing wind flow sector 4 AERMOD Finishes Successfully for FLOWSECTOR stage 2 Spring sector 15 ******** WARNING MESSAGES ******** *** NONE *** ***************************************************** Processing wind flow sector 5 AERMOD Finishes Successfully for FLOWSECTOR stage 2 Spring sector 20 89 ******** WARNING MESSAGES ******** *** NONE *** ***************************************************** Processing wind flow sector 6 AERMOD Finishes Successfully for FLOWSECTOR stage 2 Spring sector 25 ******** WARNING MESSAGES ******** *** NONE *** ***************************************************** Processing wind flow sector 7 AERMOD Finishes Successfully for FLOWSECTOR stage 2 Spring sector 30 ******** WARNING MESSAGES ******** *** NONE *** ******************************************** Running AERMOD Processing Summer Processing surface roughness sector 1 90 ***************************************************** Processing wind flow sector 1 AERMOD Finishes Successfully for FLOWSECTOR stage 2 Summer sector 0 ******** WARNING MESSAGES ******** *** NONE *** ***************************************************** Processing wind flow sector 2 AERMOD Finishes Successfully for FLOWSECTOR stage 2 Summer sector 5 ******** WARNING MESSAGES ******** *** NONE *** ***************************************************** Processing wind flow sector 3 AERMOD Finishes Successfully for FLOWSECTOR stage 2 Summer sector 10 ******** WARNING MESSAGES ******** *** NONE *** ***************************************************** 91 Processing wind flow sector 4 AERMOD Finishes Successfully for FLOWSECTOR stage 2 Summer sector 15 ******** WARNING MESSAGES ******** *** NONE *** ***************************************************** Processing wind flow sector 5 AERMOD Finishes Successfully for FLOWSECTOR stage 2 Summer sector 20 ******** WARNING MESSAGES ******** *** NONE *** ***************************************************** Processing wind flow sector 6 AERMOD Finishes Successfully for FLOWSECTOR stage 2 Summer sector 25 ******** WARNING MESSAGES ******** *** NONE *** ***************************************************** Processing wind flow sector 7 92 AERMOD Finishes Successfully for FLOWSECTOR stage 2 Summer sector 30 ******** WARNING MESSAGES ******** *** NONE *** ******************************************** Running AERMOD Processing Autumn Processing surface roughness sector 1 ***************************************************** Processing wind flow sector 1 AERMOD Finishes Successfully for FLOWSECTOR stage 2 Autumn sector 0 ******** WARNING MESSAGES ******** *** NONE *** ***************************************************** Processing wind flow sector 2 AERMOD Finishes Successfully for FLOWSECTOR stage 2 Autumn sector 5 93 ******** WARNING MESSAGES ******** *** NONE *** ***************************************************** Processing wind flow sector 3 AERMOD Finishes Successfully for FLOWSECTOR stage 2 Autumn sector 10 ******** WARNING MESSAGES ******** *** NONE *** ***************************************************** Processing wind flow sector 4 AERMOD Finishes Successfully for FLOWSECTOR stage 2 Autumn sector 15 ******** WARNING MESSAGES ******** *** NONE *** ***************************************************** Processing wind flow sector 5 AERMOD Finishes Successfully for FLOWSECTOR stage 2 Autumn sector 20 ******** WARNING MESSAGES ******** 94 *** NONE *** ***************************************************** Processing wind flow sector 6 AERMOD Finishes Successfully for FLOWSECTOR stage 2 Autumn sector 25 ******** WARNING MESSAGES ******** *** NONE *** ***************************************************** Processing wind flow sector 7 AERMOD Finishes Successfully for FLOWSECTOR stage 2 Autumn sector 30 ******** WARNING MESSAGES ******** *** NONE *** FLOWSECTOR ended 08/11/22 12:13:36 REFINE started 08/11/22 12:13:36 AERMOD Finishes Successfully for REFINE stage 3 Winter sector 0 ******** WARNING MESSAGES ******** 95 *** NONE *** REFINE ended 08/11/22 12:13:37 ********************************************** AERSCREEN Finished Successfully With no errors or warnings Check log file for details *********************************************** Ending date and time 08/11/22 12:13:39 96 file:///C/Users/stuar/Downloads/2022.08.11_AERSCREEN_PentairWarehouseExpansion_Construction_max_conc_distance.txt[8/16/2022 1:46:22 PM] Concentration Distance Elevation Diag Season/Month Zo sector Date H0 U* W* DT/DZ ZICNV ZIMCH M-O LEN Z0 BOWEN ALBEDO REF WS HT REF TA HT 0.35387E+01 1.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.38781E+01 25.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.41721E+01 50.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.44205E+01 75.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.46322E+01 100.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 * 0.46908E+01 108.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.41937E+01 125.00 0.00 25.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.29347E+01 150.00 0.00 20.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.23714E+01 175.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.20210E+01 200.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.17504E+01 225.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.15359E+01 250.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.13632E+01 275.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.12208E+01 300.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.11026E+01 325.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.10028E+01 350.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.91689E+00 375.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.84368E+00 400.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.77964E+00 425.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.72351E+00 450.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.67412E+00 475.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.63004E+00 500.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.59104E+00 525.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.55628E+00 550.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.52425E+00 575.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.49541E+00 600.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 97 file:///C/Users/stuar/Downloads/2022.08.11_AERSCREEN_PentairWarehouseExpansion_Construction_max_conc_distance.txt[8/16/2022 1:46:22 PM] 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.46933E+00 625.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.44565E+00 650.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.42401E+00 675.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.40391E+00 700.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.38547E+00 725.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.36836E+00 750.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.35255E+00 775.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.33791E+00 800.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.32433E+00 825.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.31170E+00 850.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.29978E+00 875.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.28864E+00 900.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.27822E+00 925.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.26844E+00 950.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.25927E+00 975.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.25063E+00 1000.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.24250E+00 1025.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.23476E+00 1050.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.22744E+00 1075.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.22052E+00 1100.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.21396E+00 1125.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.20774E+00 1150.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.20176E+00 1175.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.19608E+00 1200.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.19067E+00 1225.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.18552E+00 1250.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.18061E+00 1275.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 98 file:///C/Users/stuar/Downloads/2022.08.11_AERSCREEN_PentairWarehouseExpansion_Construction_max_conc_distance.txt[8/16/2022 1:46:22 PM] 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.17595E+00 1300.00 0.00 5.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.17147E+00 1325.00 0.00 5.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.16719E+00 1350.00 0.00 5.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.16308E+00 1375.00 0.00 5.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.15916E+00 1400.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.15540E+00 1425.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.15179E+00 1450.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.14833E+00 1475.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.14501E+00 1500.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.14182E+00 1525.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.13874E+00 1550.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.13579E+00 1575.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.13292E+00 1600.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.13016E+00 1625.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.12750E+00 1650.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.12493E+00 1675.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.12246E+00 1700.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.12005E+00 1725.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.11772E+00 1750.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.11547E+00 1775.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.11329E+00 1800.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.11118E+00 1825.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.10914E+00 1850.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.10717E+00 1875.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.10526E+00 1900.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.10341E+00 1924.99 0.00 5.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.10161E+00 1950.00 0.00 5.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 99 file:///C/Users/stuar/Downloads/2022.08.11_AERSCREEN_PentairWarehouseExpansion_Construction_max_conc_distance.txt[8/16/2022 1:46:22 PM] 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.99869E-01 1975.00 0.00 5.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.99237E-01 2000.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.97563E-01 2025.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.95937E-01 2050.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.94357E-01 2075.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.92822E-01 2100.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.91330E-01 2125.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.89878E-01 2150.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.88466E-01 2175.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.87092E-01 2200.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.85755E-01 2225.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.84453E-01 2250.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.83185E-01 2275.00 0.00 5.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.81949E-01 2300.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.80745E-01 2325.00 0.00 5.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.79571E-01 2350.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.78427E-01 2375.00 0.00 5.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.77310E-01 2400.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.76221E-01 2425.00 0.00 5.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.75158E-01 2450.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.74120E-01 2475.00 0.00 5.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.73108E-01 2500.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.72118E-01 2525.00 0.00 5.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.71152E-01 2550.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.70208E-01 2575.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.69286E-01 2600.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.68384E-01 2625.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 100 file:///C/Users/stuar/Downloads/2022.08.11_AERSCREEN_PentairWarehouseExpansion_Construction_max_conc_distance.txt[8/16/2022 1:46:22 PM] 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.67502E-01 2650.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.66640E-01 2675.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.65797E-01 2700.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.64972E-01 2725.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.64165E-01 2750.00 0.00 10.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.63375E-01 2775.00 0.00 10.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.62602E-01 2800.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.61845E-01 2825.00 0.00 10.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.61104E-01 2850.00 0.00 10.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.60377E-01 2875.00 0.00 10.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.59666E-01 2900.00 0.00 5.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.58969E-01 2925.00 0.00 10.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.58286E-01 2950.00 0.00 5.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.57617E-01 2975.00 0.00 10.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.56961E-01 3000.00 0.00 5.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.56318E-01 3025.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.55687E-01 3050.00 0.00 5.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.55068E-01 3075.00 0.00 10.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.54462E-01 3100.00 0.00 5.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.53866E-01 3125.00 0.00 10.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.53282E-01 3150.00 0.00 10.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.52709E-01 3174.99 0.00 10.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.52146E-01 3199.99 0.00 10.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.51594E-01 3225.00 0.00 10.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.51051E-01 3250.00 0.00 5.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.50519E-01 3275.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.49996E-01 3300.00 0.00 5.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 101 file:///C/Users/stuar/Downloads/2022.08.11_AERSCREEN_PentairWarehouseExpansion_Construction_max_conc_distance.txt[8/16/2022 1:46:22 PM] 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.49482E-01 3325.00 0.00 15.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.48978E-01 3350.00 0.00 5.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.48482E-01 3375.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.47995E-01 3400.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.47516E-01 3425.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.47045E-01 3450.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.46583E-01 3475.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.46128E-01 3500.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.45681E-01 3525.00 0.00 25.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.45242E-01 3550.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.44810E-01 3575.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.44384E-01 3600.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.43966E-01 3625.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.43555E-01 3650.00 0.00 25.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.43150E-01 3675.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.42751E-01 3700.00 0.00 20.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.42359E-01 3724.99 0.00 20.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.41974E-01 3750.00 0.00 25.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.41594E-01 3775.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.41220E-01 3800.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.40852E-01 3825.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.40489E-01 3849.99 0.00 15.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.40132E-01 3875.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.39781E-01 3900.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.39435E-01 3925.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.39093E-01 3950.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.38757E-01 3975.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 102 file:///C/Users/stuar/Downloads/2022.08.11_AERSCREEN_PentairWarehouseExpansion_Construction_max_conc_distance.txt[8/16/2022 1:46:22 PM] 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.38426E-01 4000.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.38100E-01 4025.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.37779E-01 4050.00 0.00 30.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.37462E-01 4075.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.37150E-01 4100.00 0.00 10.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.36843E-01 4125.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.36539E-01 4150.00 0.00 10.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.36240E-01 4175.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.35946E-01 4200.00 0.00 10.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.35655E-01 4225.00 0.00 5.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.35368E-01 4250.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.35086E-01 4275.00 0.00 5.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.34807E-01 4300.00 0.00 10.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.34532E-01 4325.00 0.00 10.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.34261E-01 4350.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.33994E-01 4375.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.33730E-01 4400.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.33469E-01 4425.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.33212E-01 4450.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.32959E-01 4475.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.32709E-01 4500.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.32462E-01 4525.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.32218E-01 4550.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.31978E-01 4575.00 0.00 20.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.31740E-01 4600.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.31506E-01 4625.00 0.00 25.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.31274E-01 4650.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 103 file:///C/Users/stuar/Downloads/2022.08.11_AERSCREEN_PentairWarehouseExpansion_Construction_max_conc_distance.txt[8/16/2022 1:46:22 PM] 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.31046E-01 4675.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.30820E-01 4700.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.30597E-01 4725.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.30377E-01 4750.00 0.00 5.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.30160E-01 4775.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.29945E-01 4800.00 0.00 5.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.29733E-01 4825.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.29524E-01 4850.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.29317E-01 4875.00 0.00 20.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.29113E-01 4900.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.28911E-01 4925.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.28711E-01 4950.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.28514E-01 4975.00 0.00 15.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.28319E-01 5000.00 0.00 5.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 104 Start date and time 08/11/22 12:14:16 AERSCREEN 21112 Pentair Warehouse Expansion, Operation Pentair Warehouse Expansion, Operation ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ DATA ENTRY VALIDATION ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ METRIC ENGLISH ** AREADATA ** ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ Emission Rate: 0.849E‐04 g/s 0.674E‐03 lb/hr Area Height: 3.00 meters 9.84 feet Area Source Length: 213.84 meters 701.57 feet Area Source Width: 106.92 meters 350.79 feet Vertical Dimension: 1.50 meters 4.92 feet Model Mode: URBAN Population: 35975 Dist to Ambient Air: 1.0 meters 3. feet ** BUILDING DATA ** 105 No Building Downwash Parameters ** TERRAIN DATA ** No Terrain Elevations Source Base Elevation: 0.0 meters 0.0 feet Probe distance: 5000. meters 16404. feet No flagpole receptors No discrete receptors used ** FUMIGATION DATA ** No fumigation requested ** METEOROLOGY DATA ** Min/Max Temperature: 250.0 / 310.0 K ‐9.7 / 98.3 Deg F Minimum Wind Speed: 0.5 m/s 106 Anemometer Height: 10.000 meters Dominant Surface Profile: Urban Dominant Climate Type: Average Moisture Surface friction velocity (u*): not adjusted DEBUG OPTION ON AERSCREEN output file: 2022.08.11_AERSCREEN_PentairWarehouseExpansion_Operation.out *** AERSCREEN Run is Ready to Begin No terrain used, AERMAP will not be run ************************************************** SURFACE CHARACTERISTICS & MAKEMET Obtaining surface characteristics... 107 Using AERMET seasonal surface characteristics for Urban with Average Moisture Season Albedo Bo zo Winter 0.35 1.50 1.000 Spring 0.14 1.00 1.000 Summer 0.16 2.00 1.000 Autumn 0.18 2.00 1.000 Creating met files aerscreen_01_01.sfc & aerscreen_01_01.pfl Creating met files aerscreen_02_01.sfc & aerscreen_02_01.pfl Creating met files aerscreen_03_01.sfc & aerscreen_03_01.pfl Creating met files aerscreen_04_01.sfc & aerscreen_04_01.pfl Buildings and/or terrain present or rectangular area source, skipping probe FLOWSECTOR started 08/11/22 12:19:27 ******************************************** Running AERMOD Processing Winter Processing surface roughness sector 1 108 ***************************************************** Processing wind flow sector 1 AERMOD Finishes Successfully for FLOWSECTOR stage 2 Winter sector 0 ******** WARNING MESSAGES ******** *** NONE *** ***************************************************** Processing wind flow sector 2 AERMOD Finishes Successfully for FLOWSECTOR stage 2 Winter sector 5 ******** WARNING MESSAGES ******** *** NONE *** ***************************************************** Processing wind flow sector 3 AERMOD Finishes Successfully for FLOWSECTOR stage 2 Winter sector 10 ******** WARNING MESSAGES ******** *** NONE *** 109 ***************************************************** Processing wind flow sector 4 AERMOD Finishes Successfully for FLOWSECTOR stage 2 Winter sector 15 ******** WARNING MESSAGES ******** *** NONE *** ***************************************************** Processing wind flow sector 5 AERMOD Finishes Successfully for FLOWSECTOR stage 2 Winter sector 20 ******** WARNING MESSAGES ******** *** NONE *** ***************************************************** Processing wind flow sector 6 AERMOD Finishes Successfully for FLOWSECTOR stage 2 Winter sector 25 ******** WARNING MESSAGES ******** *** NONE *** ***************************************************** 110 Processing wind flow sector 7 AERMOD Finishes Successfully for FLOWSECTOR stage 2 Winter sector 30 ******** WARNING MESSAGES ******** *** NONE *** ******************************************** Running AERMOD Processing Spring Processing surface roughness sector 1 ***************************************************** Processing wind flow sector 1 AERMOD Finishes Successfully for FLOWSECTOR stage 2 Spring sector 0 ******** WARNING MESSAGES ******** *** NONE *** ***************************************************** Processing wind flow sector 2 AERMOD Finishes Successfully for FLOWSECTOR stage 2 Spring sector 5 111 ******** WARNING MESSAGES ******** *** NONE *** ***************************************************** Processing wind flow sector 3 AERMOD Finishes Successfully for FLOWSECTOR stage 2 Spring sector 10 ******** WARNING MESSAGES ******** *** NONE *** ***************************************************** Processing wind flow sector 4 AERMOD Finishes Successfully for FLOWSECTOR stage 2 Spring sector 15 ******** WARNING MESSAGES ******** *** NONE *** ***************************************************** Processing wind flow sector 5 AERMOD Finishes Successfully for FLOWSECTOR stage 2 Spring sector 20 112 ******** WARNING MESSAGES ******** *** NONE *** ***************************************************** Processing wind flow sector 6 AERMOD Finishes Successfully for FLOWSECTOR stage 2 Spring sector 25 ******** WARNING MESSAGES ******** *** NONE *** ***************************************************** Processing wind flow sector 7 AERMOD Finishes Successfully for FLOWSECTOR stage 2 Spring sector 30 ******** WARNING MESSAGES ******** *** NONE *** ******************************************** Running AERMOD Processing Summer Processing surface roughness sector 1 113 ***************************************************** Processing wind flow sector 1 AERMOD Finishes Successfully for FLOWSECTOR stage 2 Summer sector 0 ******** WARNING MESSAGES ******** *** NONE *** ***************************************************** Processing wind flow sector 2 AERMOD Finishes Successfully for FLOWSECTOR stage 2 Summer sector 5 ******** WARNING MESSAGES ******** *** NONE *** ***************************************************** Processing wind flow sector 3 AERMOD Finishes Successfully for FLOWSECTOR stage 2 Summer sector 10 ******** WARNING MESSAGES ******** *** NONE *** ***************************************************** 114 Processing wind flow sector 4 AERMOD Finishes Successfully for FLOWSECTOR stage 2 Summer sector 15 ******** WARNING MESSAGES ******** *** NONE *** ***************************************************** Processing wind flow sector 5 AERMOD Finishes Successfully for FLOWSECTOR stage 2 Summer sector 20 ******** WARNING MESSAGES ******** *** NONE *** ***************************************************** Processing wind flow sector 6 AERMOD Finishes Successfully for FLOWSECTOR stage 2 Summer sector 25 ******** WARNING MESSAGES ******** *** NONE *** ***************************************************** Processing wind flow sector 7 115 AERMOD Finishes Successfully for FLOWSECTOR stage 2 Summer sector 30 ******** WARNING MESSAGES ******** *** NONE *** ******************************************** Running AERMOD Processing Autumn Processing surface roughness sector 1 ***************************************************** Processing wind flow sector 1 AERMOD Finishes Successfully for FLOWSECTOR stage 2 Autumn sector 0 ******** WARNING MESSAGES ******** *** NONE *** ***************************************************** Processing wind flow sector 2 AERMOD Finishes Successfully for FLOWSECTOR stage 2 Autumn sector 5 116 ******** WARNING MESSAGES ******** *** NONE *** ***************************************************** Processing wind flow sector 3 AERMOD Finishes Successfully for FLOWSECTOR stage 2 Autumn sector 10 ******** WARNING MESSAGES ******** *** NONE *** ***************************************************** Processing wind flow sector 4 AERMOD Finishes Successfully for FLOWSECTOR stage 2 Autumn sector 15 ******** WARNING MESSAGES ******** *** NONE *** ***************************************************** Processing wind flow sector 5 AERMOD Finishes Successfully for FLOWSECTOR stage 2 Autumn sector 20 ******** WARNING MESSAGES ******** 117 *** NONE *** ***************************************************** Processing wind flow sector 6 AERMOD Finishes Successfully for FLOWSECTOR stage 2 Autumn sector 25 ******** WARNING MESSAGES ******** *** NONE *** ***************************************************** Processing wind flow sector 7 AERMOD Finishes Successfully for FLOWSECTOR stage 2 Autumn sector 30 ******** WARNING MESSAGES ******** *** NONE *** FLOWSECTOR ended 08/11/22 12:19:38 REFINE started 08/11/22 12:19:38 AERMOD Finishes Successfully for REFINE stage 3 Winter sector 0 ******** WARNING MESSAGES ******** 118 *** NONE *** REFINE ended 08/11/22 12:19:39 ********************************************** AERSCREEN Finished Successfully With no errors or warnings Check log file for details *********************************************** Ending date and time 08/11/22 12:19:40 119 file:///C/Users/stuar/Downloads/2022.08.11_AERSCREEN_PentairWarehouseExpansion_Operation_max_conc_distance.txt[8/16/2022 1:46:22 PM] Concentration Distance Elevation Diag Season/Month Zo sector Date H0 U* W* DT/DZ ZICNV ZIMCH M-O LEN Z0 BOWEN ALBEDO REF WS HT REF TA HT 0.10254E+00 1.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.11238E+00 25.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.12090E+00 50.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.12809E+00 75.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.13423E+00 100.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 * 0.13593E+00 108.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.12152E+00 125.00 0.00 25.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.85039E-01 150.00 0.00 20.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.68718E-01 175.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.58562E-01 200.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.50721E-01 225.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.44506E-01 250.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.39502E-01 275.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.35377E-01 300.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.31951E-01 325.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.29058E-01 350.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.26569E-01 375.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.24448E-01 400.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.22592E-01 425.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.20965E-01 450.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.19534E-01 475.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.18257E-01 500.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.17127E-01 525.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.16120E-01 550.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.15191E-01 575.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.14356E-01 600.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 120 file:///C/Users/stuar/Downloads/2022.08.11_AERSCREEN_PentairWarehouseExpansion_Operation_max_conc_distance.txt[8/16/2022 1:46:22 PM] 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.13600E-01 625.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.12914E-01 650.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.12287E-01 675.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.11704E-01 700.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.11170E-01 725.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.10674E-01 750.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.10216E-01 775.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.97917E-02 800.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.93982E-02 825.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.90322E-02 850.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.86870E-02 875.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.83641E-02 900.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.80620E-02 925.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.77787E-02 950.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.75128E-02 975.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.72627E-02 1000.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.70270E-02 1025.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.68027E-02 1050.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.65906E-02 1075.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.63900E-02 1100.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.62000E-02 1125.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.60197E-02 1150.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.58465E-02 1175.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.56819E-02 1200.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.55252E-02 1225.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.53760E-02 1250.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.52337E-02 1275.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 121 file:///C/Users/stuar/Downloads/2022.08.11_AERSCREEN_PentairWarehouseExpansion_Operation_max_conc_distance.txt[8/16/2022 1:46:22 PM] 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.50986E-02 1300.00 0.00 5.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.49688E-02 1325.00 0.00 5.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.48447E-02 1350.00 0.00 5.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.47257E-02 1375.00 0.00 5.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.46120E-02 1400.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.45031E-02 1425.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.43986E-02 1450.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.42983E-02 1475.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.42020E-02 1500.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.41095E-02 1525.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.40204E-02 1550.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.39347E-02 1575.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.38518E-02 1600.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.37718E-02 1625.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.36947E-02 1650.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.36202E-02 1675.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.35484E-02 1700.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.34786E-02 1725.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.34111E-02 1750.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.33459E-02 1775.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.32828E-02 1800.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.32218E-02 1825.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.31627E-02 1850.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.31055E-02 1875.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.30500E-02 1900.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.29965E-02 1924.99 0.00 5.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.29445E-02 1950.00 0.00 5.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 122 file:///C/Users/stuar/Downloads/2022.08.11_AERSCREEN_PentairWarehouseExpansion_Operation_max_conc_distance.txt[8/16/2022 1:46:22 PM] 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.28939E-02 1975.00 0.00 5.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.28756E-02 2000.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.28271E-02 2025.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.27800E-02 2050.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.27342E-02 2075.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.26897E-02 2100.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.26465E-02 2125.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.26044E-02 2150.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.25635E-02 2175.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.25237E-02 2200.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.24850E-02 2225.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.24472E-02 2250.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.24105E-02 2275.00 0.00 5.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.23747E-02 2300.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.23398E-02 2325.00 0.00 5.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.23058E-02 2350.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.22726E-02 2375.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.22402E-02 2400.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.22087E-02 2425.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.21779E-02 2450.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.21478E-02 2475.00 0.00 5.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.21185E-02 2500.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.20898E-02 2525.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.20618E-02 2550.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.20344E-02 2575.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.20077E-02 2600.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.19816E-02 2625.00 0.00 5.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 123 file:///C/Users/stuar/Downloads/2022.08.11_AERSCREEN_PentairWarehouseExpansion_Operation_max_conc_distance.txt[8/16/2022 1:46:22 PM] 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.19560E-02 2650.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.19311E-02 2675.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.19066E-02 2700.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.18827E-02 2725.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.18593E-02 2750.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.18364E-02 2775.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.18140E-02 2800.00 0.00 10.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.17921E-02 2825.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.17706E-02 2850.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.17496E-02 2875.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.17290E-02 2900.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.17088E-02 2925.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.16890E-02 2950.00 0.00 5.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.16696E-02 2975.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.16506E-02 3000.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.16319E-02 3025.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.16137E-02 3050.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.15957E-02 3074.99 0.00 20.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.15781E-02 3100.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.15609E-02 3125.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.15440E-02 3150.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.15274E-02 3174.99 0.00 10.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.15111E-02 3200.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.14951E-02 3225.00 0.00 10.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.14793E-02 3250.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.14639E-02 3275.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.14488E-02 3300.00 0.00 5.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 124 file:///C/Users/stuar/Downloads/2022.08.11_AERSCREEN_PentairWarehouseExpansion_Operation_max_conc_distance.txt[8/16/2022 1:46:22 PM] 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.14339E-02 3325.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.14192E-02 3350.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.14049E-02 3375.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.13908E-02 3400.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.13769E-02 3425.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.13633E-02 3450.00 0.00 15.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.13498E-02 3475.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.13367E-02 3500.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.13237E-02 3525.00 0.00 25.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.13110E-02 3550.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.12985E-02 3575.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.12861E-02 3600.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.12740E-02 3625.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.12621E-02 3650.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.12504E-02 3675.00 0.00 25.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.12388E-02 3700.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.12275E-02 3725.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.12163E-02 3750.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.12053E-02 3775.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.11944E-02 3800.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.11838E-02 3825.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.11733E-02 3850.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.11629E-02 3875.00 0.00 5.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.11527E-02 3900.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.11427E-02 3925.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.11328E-02 3950.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.11231E-02 3975.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 125 file:///C/Users/stuar/Downloads/2022.08.11_AERSCREEN_PentairWarehouseExpansion_Operation_max_conc_distance.txt[8/16/2022 1:46:22 PM] 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.11135E-02 4000.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.11040E-02 4025.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.10947E-02 4050.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.10856E-02 4075.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.10765E-02 4100.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.10676E-02 4125.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.10588E-02 4149.99 0.00 20.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.10502E-02 4175.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.10416E-02 4200.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.10332E-02 4225.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.10249E-02 4250.00 0.00 10.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.10167E-02 4275.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.10086E-02 4300.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.10006E-02 4325.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.99280E-03 4350.00 0.00 10.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.98504E-03 4375.00 0.00 10.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.97740E-03 4400.00 0.00 10.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.96985E-03 4425.00 0.00 10.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.96241E-03 4450.00 0.00 10.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.95506E-03 4475.00 0.00 10.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.94781E-03 4500.00 0.00 10.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.94066E-03 4525.00 0.00 10.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.93360E-03 4550.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.92662E-03 4575.00 0.00 20.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.91974E-03 4600.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.91295E-03 4625.00 0.00 5.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.90625E-03 4650.00 0.00 20.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 126 file:///C/Users/stuar/Downloads/2022.08.11_AERSCREEN_PentairWarehouseExpansion_Operation_max_conc_distance.txt[8/16/2022 1:46:22 PM] 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.89962E-03 4675.00 0.00 20.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.89308E-03 4700.00 0.00 15.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.88663E-03 4725.00 0.00 25.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.88025E-03 4750.00 0.00 5.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.87396E-03 4775.00 0.00 20.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.86774E-03 4800.00 0.00 5.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.86159E-03 4825.00 0.00 15.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.85553E-03 4850.00 0.00 5.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.84953E-03 4875.00 0.00 30.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.84361E-03 4900.00 0.00 5.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.83776E-03 4924.99 0.00 15.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.83198E-03 4950.00 0.00 5.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.82627E-03 4975.00 0.00 0.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 0.82062E-03 5000.00 0.00 5.0 Winter 0-360 10011001 -1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0 310.0 2.0 127 2656 29th Street, Suite 201 Santa Monica, CA 90405 Matt Hagemann, P.G, C.Hg. (949) 887-9013 mhagemann@swape.com Matthew F. Hagemann, P.G., C.Hg., QSD, QSP Geologic and Hydrogeologic Characterization Investigation and Remediation Strategies Litigation Support and Testifying Expert Industrial Stormwater Compliance CEQA Review 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 Certifications: California Professional Geologist California Certified Hydrogeologist Qualified SWPPP Developer and Practitioner Professional Experience: Matt has 30 years of experience in environmental policy, contaminant assessment and remediation, stormwater compliance, and CEQA review. He spent nine years with the U.S. EPA in the RCRA and Superfund programs and served as EPA’s Senior Science Policy Advisor in the Western Regional Office where he identified emerging threats to groundwater from perchlorate and MTBE. While with EPA, Matt also served as a Senior Hydrogeologist in the oversight of the assessment of seven major military facilities undergoing base closure. He led numerous enforcement actions under provisions of the Resource Conservation and Recovery Act (RCRA) and directed efforts to improve hydrogeologic characterization and water quality monitoring. For the past 15 years, as a founding partner with SWAPE, Matt has developed extensive client relationships and has managed complex projects that include consultation as an expert witness and a regulatory specialist, and a manager of projects ranging from industrial stormwater compliance to CEQA review of impacts from hazardous waste, air quality and greenhouse gas emissions. Positions Matt has held include: •Founding Partner, Soil/Water/Air Protection Enterprise (SWAPE) (2003 – present); •Geology Instructor, Golden West College, 2010 – 2104, 2017; •Senior Environmental Analyst, Komex H2O Science, Inc. (2000 ‐‐ 2003); Attachment C 128 2 •Executive Director, Orange Coast Watch (2001 – 2004); •Senior Science Policy Advisor and Hydrogeologist, U.S. Environmental Protection Agency (1989– 1998); •Hydrogeologist, National Park Service, Water Resources Division (1998 – 2000); •Adjunct Faculty Member, San Francisco State University, Department of Geosciences (1993 – 1998); •Instructor, College of Marin, Department of Science (1990 – 1995); •Geologist, U.S. Forest Service (1986 – 1998); and •Geologist, Dames & Moore (1984 – 1986). Senior Regulatory and Litigation Support Analyst: With SWAPE, Matt’s responsibilities have included: •Lead analyst and testifying expert in the review of over 300 environmental impact reports and negative declarations since 2003 under CEQA that identify significant issues with regard to hazardous waste, water resources, water quality, air quality, greenhouse gas emissions, and geologic hazards. Make recommendations for additional mitigation measures to lead agencies at the local and county level to include additional characterization of health risks and implementation of protective measures to reduce worker exposure to hazards from toxins and Valley Fever. •Stormwater analysis, sampling and best management practice evaluation at more than 100 industrial facilities. •Expert witness on numerous cases including, for example, perfluorooctanoic acid (PFOA) contamination of groundwater, MTBE litigation, air toxins at hazards at a school, CERCLA compliance in assessment and remediation, and industrial stormwater contamination. •Technical assistance and litigation support for vapor intrusion concerns. •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., Matt’s duties included the following: •Senior author of a report on the extent of perchlorate contamination that was used in testimony by the former U.S. EPA Administrator and General Counsel. •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 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. 129 3 • Expert witness testimony in a case of oil production‐related contamination in Mississippi. • Lead author for a multi‐volume remedial investigation report for an operating school in Los Angeles that met strict regulatory requirements and rigorous deadlines. • Development of strategic approaches for cleanup of contaminated sites in consultation with clients and regulators. Executive Director: As Executive Director with Orange Coast Watch, Matt led efforts to restore water quality at Orange County beaches from multiple sources of contamination including urban runoff and the discharge of wastewater. In reporting to a Board of Directors that included representatives from leading Orange County universities and businesses, Matt prepared issue papers in the areas of treatment and disinfection of wastewater and control of the discharge of grease to sewer systems. Matt actively participated in the development of countywide water quality permits for the control of urban runoff and permits for the discharge of wastewater. Matt worked with other nonprofits to protect and restore water quality, including Surfrider, Natural Resources Defense Council and Orange County CoastKeeper as well as with business institutions including the Orange County Business Council. Hydrogeology: As a Senior Hydrogeologist with the U.S. Environmental Protection Agency, Matt led investigations to characterize and cleanup closing military bases, including Mare Island Naval Shipyard, Hunters Point Naval Shipyard, Treasure Island Naval Station, Alameda Naval Station, Moffett Field, Mather Army Airfield, and Sacramento Army Depot. Specific activities were as follows: • Led efforts to model groundwater flow and contaminant transport, ensured adequacy of monitoring networks, and assessed cleanup alternatives for contaminated sediment, soil, and groundwater. • Initiated a regional program for evaluation of groundwater sampling practices and laboratory analysis at military bases. • Identified emerging issues, wrote technical guidance, and assisted in policy and regulation development through work on four national U.S. EPA workgroups, including the Superfund Groundwater Technical Forum and the Federal Facilities Forum. At the request of the State of Hawaii, Matt developed a methodology to determine the vulnerability of groundwater to contamination on the islands of Maui and Oahu. He used analytical models and a GIS to show zones of vulnerability, and the results were adopted and published by the State of Hawaii and County of Maui. As a hydrogeologist with the EPA Groundwater Protection Section, Matt worked with provisions of the Safe Drinking Water Act and NEPA to prevent drinking water contamination. Specific activities included the following: • Received an EPA Bronze Medal for his contribution to the development of national guidance for the protection of drinking water. • Managed the Sole Source Aquifer Program and protected the drinking water of two communities through designation under the Safe Drinking Water Act. He prepared geologic reports, conducted 130 4 public hearings, and responded to public comments from residents who were very concerned about the impact of designation. •Reviewed a number of Environmental Impact Statements for planned major developments, including large hazardous and solid waste disposal facilities, mine reclamation, and water transfer. Matt served as a hydrogeologist with the RCRA Hazardous Waste program. Duties were as follows: •Supervised the hydrogeologic investigation of hazardous waste sites to determine compliance with Subtitle C requirements. •Reviewed and wrote ʺpart Bʺ permits for the disposal of hazardous waste. •Conducted RCRA Corrective Action investigations of waste sites and led inspections that formed the basis for significant enforcement actions that were developed in close coordination with U.S. EPA legal counsel. •Wrote contract specifications and supervised contractor’s investigations of waste sites. With the National Park Service, Matt directed service‐wide investigations of contaminant sources to prevent degradation of water quality, including the following tasks: •Applied pertinent laws and regulations including CERCLA, RCRA, NEPA, NRDA, and the Clean Water Act to control military, mining, and landfill contaminants. •Conducted watershed‐scale investigations of contaminants at parks, including Yellowstone and Olympic National Park. •Identified high‐levels of perchlorate in soil adjacent to a national park in New Mexico and advised park superintendent on appropriate response actions under CERCLA. •Served as a Park Service representative on the Interagency Perchlorate Steering Committee, a national workgroup. •Developed a program to conduct environmental compliance audits of all National Parks while serving on a national workgroup. •Co‐authored two papers on the potential for water contamination from the operation of personal watercraft and snowmobiles, these papers serving as the basis for the development of nation‐ wide policy on the use of these vehicles in National Parks. •Contributed to the Federal Multi‐Agency Source Water Agreement under the Clean Water Action Plan. Policy: Served senior management as the Senior Science Policy Advisor with the U.S. Environmental Protection Agency, Region 9. Activities included the following: •Advised the Regional Administrator and senior management on emerging issues such as the potential for the gasoline additive MTBE and ammonium perchlorate to contaminate drinking water supplies. •Shaped EPA’s national response to these threats by serving on workgroups and by contributing to guidance, including the Office of Research and Development publication, Oxygenates in Water: Critical Information and Research Needs. •Improved the technical training of EPAʹs scientific and engineering staff. •Earned an EPA Bronze Medal for representing the region’s 300 scientists and engineers in negotiations with the Administrator and senior management to better integrate scientific 131 5 principles into the policy‐making process. •Established national protocol for the peer review of scientific documents. Geology: With the U.S. Forest Service, Matt led investigations to determine hillslope stability of areas proposed for timber harvest in the central Oregon Coast Range. Specific activities were as follows: •Mapped geology in the field, and used aerial photographic interpretation and mathematical models to determine slope stability. •Coordinated his research with community members who were concerned with natural resource protection. •Characterized the geology of an aquifer that serves as the sole source of drinking water for the city of Medford, Oregon. As a consultant with Dames and Moore, Matt led geologic investigations of two contaminated sites (later listed on the Superfund NPL) in the Portland, Oregon, area and a large hazardous waste site in eastern Oregon. Duties included the following: •Supervised year‐long effort for soil and groundwater sampling. •Conducted aquifer tests. •Investigated active faults beneath sites proposed for hazardous waste disposal. Teaching: From 1990 to 1998, Matt taught at least one course per semester at the community college and university levels: •At San Francisco State University, held an adjunct faculty position and taught courses in environmental geology, oceanography (lab and lecture), hydrogeology, and groundwater contamination. •Served as a committee member for graduate and undergraduate students. •Taught courses in environmental geology and oceanography at the College of Marin. Matt is currently a part time geology instructor at Golden West College in Huntington Beach, California where he taught from 2010 to 2014 and in 2017. Invited Testimony, Reports, Papers and Presentations: Hagemann, M.F., 2008. Disclosure of Hazardous Waste Issues under CEQA. Presentation to the Public Environmental Law Conference, Eugene, Oregon. Hagemann, M.F., 2008. Disclosure of Hazardous Waste Issues under CEQA. Invited presentation to U.S. EPA Region 9, San Francisco, California. Hagemann, M.F., 2005. Use of Electronic Databases in Environmental Regulation, Policy Making and Public Participation. Brownfields 2005, Denver, Coloradao. Hagemann, M.F., 2004. Perchlorate Contamination of the Colorado River and Impacts to Drinking Water in Nevada and the Southwestern U.S. Presentation to a meeting of the American Groundwater Trust, Las Vegas, NV (served on conference organizing committee). 132 6 Hagemann, M.F., 2004. Invited testimony to a California Senate committee hearing on air toxins at schools in Southern California, Los Angeles. Brown, A., Farrow, J., Gray, A. and Hagemann, M., 2004. An Estimate of Costs to Address MTBE Releases from Underground Storage Tanks and the Resulting Impact to Drinking Water Wells. Presentation to the Ground Water and Environmental Law Conference, National Groundwater Association. Hagemann, M.F., 2004. Perchlorate Contamination of the Colorado River and Impacts to Drinking Water in Arizona and the Southwestern U.S. Presentation to a meeting of the American Groundwater Trust, Phoenix, AZ (served on conference organizing committee). Hagemann, M.F., 2003. Perchlorate Contamination of the Colorado River and Impacts to Drinking Water in the Southwestern U.S. Invited presentation to a special committee meeting of the National Academy of Sciences, Irvine, CA. Hagemann, M.F., 2003. Perchlorate Contamination of the Colorado River. Invited presentation to a tribal EPA meeting, Pechanga, CA. Hagemann, M.F., 2003. Perchlorate Contamination of the Colorado River. Invited presentation to a meeting of tribal repesentatives, Parker, AZ. Hagemann, M.F., 2003. Impact of Perchlorate on the Colorado River and Associated Drinking Water Supplies. Invited presentation to the Inter‐Tribal Meeting, Torres Martinez Tribe. Hagemann, M.F., 2003. The Emergence of Perchlorate as a Widespread Drinking Water Contaminant. Invited presentation to the U.S. EPA Region 9. Hagemann, M.F., 2003. A Deductive Approach to the Assessment of Perchlorate Contamination. Invited presentation to the California Assembly Natural Resources Committee. Hagemann, M.F., 2003. Perchlorate: A Cold War Legacy in Drinking Water. Presentation to a meeting of the National Groundwater Association. Hagemann, M.F., 2002. From Tank to Tap: A Chronology of MTBE in Groundwater. Presentation to a meeting of the National Groundwater Association. Hagemann, M.F., 2002. A Chronology of MTBE in Groundwater and an Estimate of Costs to Address Impacts to Groundwater. Presentation to the annual meeting of the Society of Environmental Journalists. Hagemann, M.F., 2002. An Estimate of the Cost to Address MTBE Contamination in Groundwater (and Who Will Pay). Presentation to a meeting of the National Groundwater Association. Hagemann, M.F., 2002. An Estimate of Costs to Address MTBE Releases from Underground Storage Tanks and the Resulting Impact to Drinking Water Wells. Presentation to a meeting of the U.S. EPA and State Underground Storage Tank Program managers. 133 7 Hagemann, M.F., 2001. From Tank to Tap: A Chronology of MTBE in Groundwater. Unpublished report. Hagemann, M.F., 2001. Estimated Cleanup Cost for MTBE in Groundwater Used as Drinking Water. Unpublished report. Hagemann, M.F., 2001. Estimated Costs to Address MTBE Releases from Leaking Underground Storage Tanks. Unpublished report. Hagemann, M.F., and VanMouwerik, M., 1999. Potential W a t e r Quality Concerns Related to Snowmobile Usage. Water Resources Division, National Park Service, Technical Report. VanMouwerik, M. and Hagemann, M.F. 1999, Water Quality Concerns Related to Personal Watercraft Usage. Water Resources Division, National Park Service, Technical Report. Hagemann, M.F., 1999, Is Dilution the Solution to Pollution in National Parks? The George Wright Society Biannual Meeting, Asheville, North Carolina. Hagemann, M.F., 1997, The Potential for MTBE to Contaminate Groundwater. U.S. EPA Superfund Groundwater Technical Forum Annual Meeting, Las Vegas, Nevada. Hagemann, M.F., and Gill, M., 1996, Impediments to Intrinsic Remediation, Moffett Field Naval Air Station, Conference on Intrinsic Remediation of Chlorinated Hydrocarbons, Salt Lake City. Hagemann, M.F., Fukunaga, G.L., 1996, The Vulnerability of Groundwater to Anthropogenic Contaminants on the Island of Maui, Hawaii. Hawaii Water Works Association Annual Meeting, Maui, October 1996. Hagemann, M. F., Fukanaga, G. L., 1996, Ranking Groundwater Vulnerability in Central Oahu, Hawaii. Proceedings, Geographic Information Systems in Environmental Resources Management, Air and Waste Management Association Publication VIP‐61. Hagemann, M.F., 1994. Groundwater Ch ar ac te r i z a t i o n and Cl ean up a t Closing Military Bases in California. Proceedings, California Groundwater Resources Association Meeting. Hagemann, M.F. and Sabol, M.A., 1993. Role of the U.S. EPA in the High Plains States Groundwater Recharge Demonstration Program. Proceedings, Sixth Biennial Symposium on the Artificial Recharge of Groundwater. Hagemann, M.F., 1993. U.S. EPA Policy on the Technical Impracticability of the Cleanup of DNAPL‐ contaminated Groundwater. California Groundwater Resources Association Meeting. 134 8 Hagemann, M.F., 1992. Dense Nonaqueous Phase Liquid Contamination of Groundwater: An Ounce of Prevention... Proceedings, Association of Engineering Geologists Annual Meeting, v. 35. Other Experience: Selected as subject matter expert for the California Professional Geologist licensing examinations, 2009‐2011. 135 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 10 October 2021 Paul Rosenfeld, Ph.D.Chemical Fate and Transport & Air Dispersion Modeling Principal Environmental Chemist Risk Assessment & Remediation Specialist Education Ph.D. Soil Chemistry, University of Washington, 1999. Dissertation on volatile organic compound filtration. M.S. Environmental Science, U.C. Berkeley, 1995. Thesis on organic waste economics. B.A. Environmental Studies, U.C. Santa Barbara, 1991. Thesis on wastewater treatment. Professional Experience Dr. Rosenfeld has over 25 years’ experience conducting environmental investigations and risk assessments for evaluating impacts to human health, property, and ecological receptors. His expertise focuses on the fate and transport of environmental contaminants, human health risk, exposure assessment, and ecological restoration. Dr. Rosenfeld has evaluated and modeled emissions from oil spills, landfills, boilers and incinerators, process stacks, storage tanks, confined animal feeding operations, industrial, military and agricultural sources, unconventional oil drilling operations, and locomotive and construction engines. His project experience ranges from monitoring and modeling of pollution sources to evaluating impacts of pollution on workers at industrial facilities and residents in surrounding communities. Dr. Rosenfeld has also successfully modeled exposure to contaminants distributed by water systems and via vapor intrusion. Dr. Rosenfeld has investigated and designed remediation programs and risk assessments for contaminated sites containing lead, heavy metals, mold, bacteria, particulate matter, petroleum hydrocarbons, chlorinated solvents, pesticides, radioactive waste, dioxins and furans, semi- and volatile organic compounds, PCBs, PAHs, creosote, perchlorate, asbestos, per- and poly-fluoroalkyl substances (PFOA/PFOS), unusual polymers, fuel oxygenates (MTBE), among other pollutants. Dr. Rosenfeld also has experience evaluating greenhouse gas emissions from various projects and is an expert on the assessment of odors from industrial and agricultural sites, as well as the evaluation of odor nuisance impacts and technologies for abatement of odorous emissions. As a principal scientist at SWAPE, Dr. Rosenfeld directs air dispersion modeling and exposure assessments. He has served as an expert witness and testified about pollution sources causing nuisance and/or personal injury at sites and has testified as an expert witness on numerous cases involving exposure to soil, water and air contaminants from industrial, railroad, agricultural, and military sources. Attachment D 136 Paul E. Rosenfeld, Ph.D. Page 2 of 10 October 2021 Professional History: Soil Water Air Protection Enterprise (SWAPE); 2003 to present; Principal and Founding Partner UCLA School of Public Health; 2007 to 2011; Lecturer (Assistant Researcher) UCLA School of Public Health; 2003 to 2006; Adjunct Professor UCLA Environmental Science and Engineering Program; 2002-2004; Doctoral Intern Coordinator UCLA Institute of the Environment, 2001-2002; Research Associate Komex H2O Science, 2001 to 2003; Senior Remediation Scientist National Groundwater Association, 2002-2004; Lecturer San Diego State University, 1999-2001; Adjunct Professor Anteon Corp., San Diego, 2000-2001; Remediation Project Manager Ogden (now Amec), San Diego, 2000-2000; Remediation Project Manager Bechtel, San Diego, California, 1999 – 2000; Risk Assessor King County, Seattle, 1996 – 1999; Scientist James River Corp., Washington, 1995-96; Scientist Big Creek Lumber, Davenport, California, 1995; Scientist Plumas Corp., California and USFS, Tahoe 1993-1995; Scientist Peace Corps and World Wildlife Fund, St. Kitts, West Indies, 1991-1993; Scientist Publications: Remy, L.L., Clay T., Byers, V., Rosenfeld P. E. (2019) Hospital, Health, and Community Burden After Oil Refinery Fires, Richmond, California 2007 and 2012. Environmental Health. 18:48 Simons, R.A., Seo, Y. Rosenfeld, P., (2015) Modeling the Effect of Refinery Emission On Residential Property Value. Journal of Real Estate Research. 27(3):321-342 Chen, J. A, Zapata A. R., Sutherland A. J., Molmen, D.R., Chow, B. S., Wu, L. E., Rosenfeld, P. E., Hesse, R. C., (2012) Sulfur Dioxide and Volatile Organic Compound Exposure To A Community In Texas City Texas Evaluated Using Aermod and Empirical Data. American Journal of Environmental Science, 8(6), 622-632. Rosenfeld, P.E. & Feng, L. (2011). The Risks of Hazardous Waste. Amsterdam: Elsevier Publishing. Cheremisinoff, N.P., & Rosenfeld, P.E. (2011). Handbook of Pollution Prevention and Cleaner Production: Best Practices in the Agrochemical Industry, Amsterdam: Elsevier Publishing. Gonzalez, J., Feng, L., Sutherland, A., Waller, C., Sok, H., Hesse, R., Rosenfeld, P. (2010). PCBs and Dioxins/Furans in Attic Dust Collected Near Former PCB Production and Secondary Copper Facilities in Sauget, IL. Procedia Environmental Sciences. 113–125. Feng, L., Wu, C., Tam, L., Sutherland, A.J., Clark, J.J., Rosenfeld, P.E. (2010). Dioxin and Furan Blood Lipid and Attic Dust Concentrations in Populations Living Near Four Wood Treatment Facilities in the United States. Journal of Environmental Health. 73(6), 34-46. Cheremisinoff, N.P., & Rosenfeld, P.E. (2010). Handbook of Pollution Prevention and Cleaner Production: Best Practices in the Wood and Paper Industries. Amsterdam: Elsevier Publishing. Cheremisinoff, N.P., & Rosenfeld, P.E. (2009). Handbook of Pollution Prevention and Cleaner Production: Best Practices in the Petroleum Industry. Amsterdam: Elsevier Publishing. Wu, C., Tam, L., Clark, J., Rosenfeld, P. (2009). Dioxin and furan blood lipid concentrations in populations living near four wood treatment facilities in the United States. WIT Transactions on Ecology and the Environment, Air Pollution, 123 (17), 319-327. 137 Paul E. Rosenfeld, Ph.D. Page 3 of 10 October 2021 Tam L. K.., Wu C. D., Clark J. J. and Rosenfeld, P.E. (2008). A Statistical Analysis Of Attic Dust And Blood Lipid Concentrations Of Tetrachloro-p-Dibenzodioxin (TCDD) Toxicity Equivalency Quotients (TEQ) In Two Populations Near Wood Treatment Facilities. Organohalogen Compounds, 70, 002252-002255. Tam L. K.., Wu C. D., Clark J. J. and Rosenfeld, P.E. (2008). Methods For Collect Samples For Assessing Dioxins And Other Environmental Contaminants In Attic Dust: A Review. Organohalogen Compounds, 70, 000527- 000530. Hensley, A.R. A. Scott, J. J. J. Clark, Rosenfeld, P.E. (2007). Attic Dust and Human Blood Samples Collected near a Former Wood Treatment Facility. Environmental Research. 105, 194-197. Rosenfeld, P.E., J. J. J. Clark, A. R. Hensley, M. Suffet. (2007). The Use of an Odor Wheel Classification for Evaluation of Human Health Risk Criteria for Compost Facilities. Water Science & Technology 55(5), 345-357. Rosenfeld, P. E., M. Suffet. (2007). The Anatomy Of Odour Wheels For Odours Of Drinking Water, Wastewater, Compost And The Urban Environment. Water Science & Technology 55(5), 335-344. Sullivan, P. J. Clark, J.J.J., Agardy, F. J., Rosenfeld, P.E. (2007). Toxic Legacy, Synthetic Toxins in the Food, Water, and Air in American Cities. Boston Massachusetts: Elsevier Publishing Rosenfeld, P.E., and Suffet I.H. (2004). Control of Compost Odor Using High Carbon Wood Ash. Water Science and Technology. 49(9),171-178. Rosenfeld P. E., J.J. Clark, I.H. (Mel) Suffet (2004). The Value of An Odor-Quality-Wheel Classification Scheme For The Urban Environment. Water Environment Federation’s Technical Exhibition and Conference (WEFTEC) 2004. New Orleans, October 2-6, 2004. Rosenfeld, P.E., and Suffet, I.H. (2004). Understanding Odorants Associated With Compost, Biomass Facilities, and the Land Application of Biosolids. Water Science and Technology. 49(9), 193-199. Rosenfeld, P.E., and Suffet I.H. (2004). Control of Compost Odor Using High Carbon Wood Ash, Water Science and Technology, 49( 9), 171-178. Rosenfeld, P. E., Grey, M. A., Sellew, P. (2004). Measurement of Biosolids Odor and Odorant Emissions from Windrows, Static Pile and Biofilter. Water Environment Research. 76(4), 310-315. Rosenfeld, P.E., Grey, M and Suffet, M. (2002). Compost Demonstration Project, Sacramento California Using High-Carbon Wood Ash to Control Odor at a Green Materials Composting Facility. Integrated Waste Management Board Public Affairs Office, Publications Clearinghouse (MS–6), Sacramento, CA Publication #442-02-008. Rosenfeld, P.E., and C.L. Henry. (2001). Characterization of odor emissions from three different biosolids. Water Soil and Air Pollution. 127(1-4), 173-191. Rosenfeld, P.E., and Henry C. L., (2000). Wood ash control of odor emissions from biosolids application. Journal of Environmental Quality. 29, 1662-1668. Rosenfeld, P.E., C.L. Henry and D. Bennett. (2001). Wastewater dewatering polymer affect on biosolids odor emissions and microbial activity. Water Environment Research. 73(4), 363-367. Rosenfeld, P.E., and C.L. Henry. (2001). Activated Carbon and Wood Ash Sorption of Wastewater, Compost, and Biosolids Odorants. Water Environment Research, 73, 388-393. Rosenfeld, P.E., and Henry C. L., (2001). High carbon wood ash effect on biosolids microbial activity and odor. Water Environment Research. 131(1-4), 247-262. 138 Paul E. Rosenfeld, Ph.D. Page 4 of 10 October 2021 Chollack, T. and P. Rosenfeld. (1998). Compost Amendment Handbook For Landscaping. Prepared for and distributed by the City of Redmond, Washington State. Rosenfeld, P. E. (1992). The Mount Liamuiga Crater Trail. Heritage Magazine of St. Kitts, 3(2). Rosenfeld, P. E. (1993). High School Biogas Project to Prevent Deforestation On St. Kitts. Biomass Users Network, 7(1). Rosenfeld, P. E. (1998). Characterization, Quantification, and Control of Odor Emissions From Biosolids Application To Forest Soil. Doctoral Thesis. University of Washington College of Forest Resources. Rosenfeld, P. E. (1994). Potential Utilization of Small Diameter Trees on Sierra County Public Land. Masters thesis reprinted by the Sierra County Economic Council. Sierra County, California. Rosenfeld, P. E. (1991). How to Build a Small Rural Anaerobic Digester & Uses Of Biogas In The First And Third World. Bachelors Thesis. University of California. Presentations: Rosenfeld, P.E., "The science for Perfluorinated Chemicals (PFAS): What makes remediation so hard?" Law Seminars International, (May 9-10, 2018) 800 Fifth Avenue, Suite 101 Seattle, WA. Rosenfeld, P.E., Sutherland, A; Hesse, R.; Zapata, A. (October 3-6, 2013). Air dispersion modeling of volatile organic emissions from multiple natural gas wells in Decatur, TX. 44th Western Regional Meeting, American Chemical Society. Lecture conducted from Santa Clara, CA. Sok, H.L.; Waller, C.C.; Feng, L.; Gonzalez, J.; Sutherland, A.J.; Wisdom-Stack, T.; Sahai, R.K.; Hesse, R.C.; Rosenfeld, P.E. (June 20-23, 2010). Atrazine: A Persistent Pesticide in Urban Drinking Water. Urban Environmental Pollution. Lecture conducted from Boston, MA. Feng, L.; Gonzalez, J.; Sok, H.L.; Sutherland, A.J.; Waller, C.C.; Wisdom-Stack, T.; Sahai, R.K.; La, M.; Hesse, R.C.; Rosenfeld, P.E. (June 20-23, 2010). Bringing Environmental Justice to East St. Louis, Illinois. Urban Environmental Pollution. Lecture conducted from Boston, MA. Rosenfeld, P.E. (April 19-23, 2009). Perfluoroctanoic Acid (PFOA) and Perfluoroactane Sulfonate (PFOS) Contamination in Drinking Water From the Use of Aqueous Film Forming Foams (AFFF) at Airports in the United States. 2009 Ground Water Summit and 2009 Ground Water Protection Council Spring Meeting , Lecture conducted from Tuscon, AZ. Rosenfeld, P.E. (April 19-23, 2009). Cost to Filter Atrazine Contamination from Drinking Water in the United States” Contamination in Drinking Water From the Use of Aqueous Film Forming Foams (AFFF) at Airports in the United States. 2009 Ground Water Summit and 2009 Ground Water Protection Council Spring Meeting . Lecture conducted from Tuscon, AZ. Wu, C., Tam, L., Clark, J., Rosenfeld, P. (20-22 July, 2009). Dioxin and furan blood lipid concentrations in populations living near four wood treatment facilities in the United States. Brebbia, C.A. and Popov, V., eds., Air Pollution XVII: Proceedings of the Seventeenth International Conference on Modeling, Monitoring and Management of Air Pollution. Lecture conducted from Tallinn, Estonia. Rosenfeld, P. E. (October 15-18, 2007). Moss Point Community Exposure To Contaminants From A Releasing Facility. The 23rd Annual International Conferences on Soils Sediment and Water. Platform lecture conducted from University of Massachusetts, Amherst MA. Rosenfeld, P. E. (October 15-18, 2007). The Repeated Trespass of Tritium-Contaminated Water Into A Surrounding Community Form Repeated Waste Spills From A Nuclear Power Plant. The 23rd Annual International 139 Paul E. Rosenfeld, Ph.D. Page 5 of 10 October 2021 Conferences on Soils Sediment and Water. Platform lecture conducted from University of Massachusetts, Amherst MA. Rosenfeld, P. E. (October 15-18, 2007). Somerville Community Exposure To Contaminants From Wood Treatment Facility Emissions. The 23rd Annual International Conferences on Soils Sediment and Water. Lecture conducted from University of Massachusetts, Amherst MA. Rosenfeld P. E. (March 2007). Production, Chemical Properties, Toxicology, & Treatment Case Studies of 1,2,3- Trichloropropane (TCP). The Association for Environmental Health and Sciences (AEHS) Annual Meeting. Lecture conducted from San Diego, CA. Rosenfeld P. E. (March 2007). Blood and Attic Sampling for Dioxin/Furan, PAH, and Metal Exposure in Florala, Alabama. The AEHS Annual Meeting. Lecture conducted from San Diego, CA. Hensley A.R., Scott, A., Rosenfeld P.E., Clark, J.J.J. (August 21 – 25, 2006). Dioxin Containing Attic Dust And Human Blood Samples Collected Near A Former Wood Treatment Facility. The 26th International Symposium on Halogenated Persistent Organic Pollutants – DIOXIN2006. Lecture conducted from Radisson SAS Scandinavia Hotel in Oslo Norway. Hensley A.R., Scott, A., Rosenfeld P.E., Clark, J.J.J. (November 4-8, 2006). Dioxin Containing Attic Dust And Human Blood Samples Collected Near A Former Wood Treatment Facility. APHA 134 Annual Meeting & Exposition. Lecture conducted from Boston Massachusetts. Paul Rosenfeld Ph.D. (October 24-25, 2005). Fate, Transport and Persistence of PFOA and Related Chemicals. Mealey’s C8/PFOA. Science, Risk & Litigation Conference. Lecture conducted from The Rittenhouse Hotel, Philadelphia, PA. Paul Rosenfeld Ph.D. (September 19, 2005). Brominated Flame Retardants in Groundwater: Pathways to Human Ingestion, Toxicology and Remediation PEMA Emerging Contaminant Conference. Lecture conducted from Hilton Hotel, Irvine California. Paul Rosenfeld Ph.D. (September 19, 2005). Fate, Transport, Toxicity, And Persistence of 1,2,3-TCP. PEMA Emerging Contaminant Conference. Lecture conducted from Hilton Hotel in Irvine, California. Paul Rosenfeld Ph.D. (September 26-27, 2005). Fate, Transport and Persistence of PDBEs. Mealey’s Groundwater Conference. Lecture conducted from Ritz Carlton Hotel, Marina Del Ray, California. Paul Rosenfeld Ph.D. (June 7-8, 2005). Fate, Transport and Persistence of PFOA and Related Chemicals. International Society of Environmental Forensics: Focus On Emerging Contaminants. Lecture conducted from Sheraton Oceanfront Hotel, Virginia Beach, Virginia. Paul Rosenfeld Ph.D. (July 21-22, 2005). Fate Transport, Persistence and Toxicology of PFOA and Related Perfluorochemicals. 2005 National Groundwater Association Ground Water And Environmental Law Conference. Lecture conducted from Wyndham Baltimore Inner Harbor, Baltimore Maryland. Paul Rosenfeld Ph.D. (July 21-22, 2005). Brominated Flame Retardants in Groundwater: Pathways to Human Ingestion, Toxicology and Remediation. 2005 National Groundwater Association Ground Water and Environmental Law Conference. Lecture conducted from Wyndham Baltimore Inner Harbor, Baltimore Maryland. Paul Rosenfeld, Ph.D. and James Clark Ph.D. and Rob Hesse R.G. (May 5-6, 2004). Tert-butyl Alcohol Liability and Toxicology, A National Problem and Unquantified Liability. National Groundwater Association. Environmental Law Conference. Lecture conducted from Congress Plaza Hotel, Chicago Illinois. Paul Rosenfeld, Ph.D. (March 2004). Perchlorate Toxicology. Meeting of the American Groundwater Trust. Lecture conducted from Phoenix Arizona. 140 Paul E. Rosenfeld, Ph.D. Page 6 of 10 October 2021 Hagemann, M.F., Paul Rosenfeld, Ph.D. and Rob Hesse (2004). Perchlorate Contamination of the Colorado River. Meeting of tribal representatives. Lecture conducted from Parker, AZ. Paul Rosenfeld, Ph.D. (April 7, 2004). A National Damage Assessment Model For PCE and Dry Cleaners. Drycleaner Symposium. California Ground Water Association. Lecture conducted from Radison Hotel, Sacramento, California. Rosenfeld, P. E., Grey, M., (June 2003) Two stage biofilter for biosolids composting odor control. Seventh International In Situ And On Site Bioremediation Symposium Battelle Conference Orlando, FL. Paul Rosenfeld, Ph.D. and James Clark Ph.D. (February 20-21, 2003) Understanding Historical Use, Chemical Properties, Toxicity and Regulatory Guidance of 1,4 Dioxane. National Groundwater Association. Southwest Focus Conference. Water Supply and Emerging Contaminants.. Lecture conducted from Hyatt Regency Phoenix Arizona. Paul Rosenfeld, Ph.D. (February 6-7, 2003). Underground Storage Tank Litigation and Remediation. California CUPA Forum. Lecture conducted from Marriott Hotel, Anaheim California. Paul Rosenfeld, Ph.D. (October 23, 2002) Underground Storage Tank Litigation and Remediation. EPA Underground Storage Tank Roundtable. Lecture conducted from Sacramento California. Rosenfeld, P.E. and Suffet, M. (October 7- 10, 2002). Understanding Odor from Compost, Wastewater and Industrial Processes. Sixth Annual Symposium On Off Flavors in the Aquatic Environment. International Water Association. Lecture conducted from Barcelona Spain. Rosenfeld, P.E. and Suffet, M. (October 7- 10, 2002). Using High Carbon Wood Ash to Control Compost Odor. Sixth Annual Symposium On Off Flavors in the Aquatic Environment. International Water Association . Lecture conducted from Barcelona Spain. Rosenfeld, P.E. and Grey, M. A. (September 22-24, 2002). Biocycle Composting For Coastal Sage Restoration. Northwest Biosolids Management Association. Lecture conducted from Vancouver Washington.. Rosenfeld, P.E. and Grey, M. A. (November 11-14, 2002). Using High-Carbon Wood Ash to Control Odor at a Green Materials Composting Facility. Soil Science Society Annual Conference. Lecture conducted from Indianapolis, Maryland. Rosenfeld. P.E. (September 16, 2000). Two stage biofilter for biosolids composting odor control. Water Environment Federation. Lecture conducted from Anaheim California. Rosenfeld. P.E. (October 16, 2000). Wood ash and biofilter control of compost odor. Biofest. Lecture conducted from Ocean Shores, California. Rosenfeld, P.E. (2000). Bioremediation Using Organic Soil Amendments. California Resource Recovery Association. Lecture conducted from Sacramento California. Rosenfeld, P.E., C.L. Henry, R. Harrison. (1998). Oat and Grass Seed Germination and Nitrogen and Sulfur Emissions Following Biosolids Incorporation With High-Carbon Wood-Ash. Water Environment Federation 12th Annual Residuals and Biosolids Management Conference Proceedings. Lecture conducted from Bellevue Washington. Rosenfeld, P.E., and C.L. Henry. (1999). An evaluation of ash incorporation with biosolids for odor reduction. Soil Science Society of America. Lecture conducted from Salt Lake City Utah. Rosenfeld, P.E., C.L. Henry, R. Harrison. (1998). Comparison of Microbial Activity and Odor Emissions from Three Different Biosolids Applied to Forest Soil. Brown and Caldwell. Lecture conducted from Seattle Washington. 141 Paul E. Rosenfeld, Ph.D. Page 7 of 10 October 2021 Rosenfeld, P.E., C.L. Henry. (1998). Characterization, Quantification, and Control of Odor Emissions from Biosolids Application To Forest Soil. Biofest. Lecture conducted from Lake Chelan, Washington. Rosenfeld, P.E, C.L. Henry, R. Harrison. (1998). Oat and Grass Seed Germination and Nitrogen and Sulfur Emissions Following Biosolids Incorporation With High-Carbon Wood-Ash. Water Environment Federation 12th Annual Residuals and Biosolids Management Conference Proceedings. Lecture conducted from Bellevue Washington. Rosenfeld, P.E., C.L. Henry, R. B. Harrison, and R. Dills. (1997). Comparison of Odor Emissions From Three Different Biosolids Applied to Forest Soil. Soil Science Society of America. Lecture conducted from Anaheim California. Teaching Experience: UCLA Department of Environmental Health (Summer 2003 through 20010) Taught Environmental Health Science 100 to students, including undergrad, medical doctors, public health professionals and nurses. Course focused on the health effects of environmental contaminants. National Ground Water Association, Successful Remediation Technologies. Custom Course in Sante Fe, New Mexico. May 21, 2002. Focused on fate and transport of fuel contaminants associated with underground storage tanks. National Ground Water Association; Successful Remediation Technologies Course in Chicago Illinois. April 1, 2002. Focused on fate and transport of contaminants associated with Superfund and RCRA sites. California Integrated Waste Management Board, April and May, 2001. Alternative Landfill Caps Seminar in San Diego, Ventura, and San Francisco. Focused on both prescriptive and innovative landfill cover design. UCLA Department of Environmental Engineering, February 5, 2002. Seminar on Successful Remediation Technologies focusing on Groundwater Remediation. University Of Washington, Soil Science Program, Teaching Assistant for several courses including: Soil Chemistry, Organic Soil Amendments, and Soil Stability. U.C. Berkeley, Environmental Science Program Teaching Assistant for Environmental Science 10. Academic Grants Awarded: California Integrated Waste Management Board. $41,000 grant awarded to UCLA Institute of the Environment. Goal: To investigate effect of high carbon wood ash on volatile organic emissions from compost. 2001. Synagro Technologies, Corona California: $10,000 grant awarded to San Diego State University. Goal: investigate effect of biosolids for restoration and remediation of degraded coastal sage soils. 2000. King County, Department of Research and Technology, Washington State. $100,000 grant awarded to University of Washington: Goal: To investigate odor emissions from biosolids application and the effect of polymers and ash on VOC emissions. 1998. Northwest Biosolids Management Association, Washington State. $20,000 grant awarded to investigate effect of polymers and ash on VOC emissions from biosolids. 1997. James River Corporation, Oregon: $10,000 grant was awarded to investigate the success of genetically engineered Poplar trees with resistance to round-up. 1996. 142 Paul E. Rosenfeld, Ph.D. Page 8 of 10 October 2021 United State Forest Service, Tahoe National Forest: $15,000 grant was awarded to investigating fire ecology of the Tahoe National Forest. 1995. Kellogg Foundation, Washington D.C. $500 grant was awarded to construct a large anaerobic digester on St. Kitts in West Indies. 1993 Deposition and/or Trial Testimony: In the Circuit Court Of The Twentieth Judicial Circuit, St Clair County, Illinois Martha Custer et al., Plaintiff vs. Cerro Flow Products, Inc., Defendants Case No.: No. 0i9-L-2295 Rosenfeld Deposition, 5-14-2021 Trial, October 8-4-2021 In the Circuit Court of Cook County Illinois Joseph Rafferty, Plaintiff vs. Consolidated Rail Corporation and National Railroad Passenger Corporation d/b/a AMTRAK, Case No.: No. 18-L-6845 Rosenfeld Deposition, 6-28-2021 In the United States District Court For the Northern District of Illinois Theresa Romcoe, Plaintiff vs. Northeast Illinois Regional Commuter Railroad Corporation d/b/a METRA Rail, Defendants Case No.: No. 17-cv-8517 Rosenfeld Deposition, 5-25-2021 In the Superior Court of the State of Arizona In and For the Cunty of Maricopa Mary Tryon et al., Plaintiff vs. The City of Pheonix v. Cox Cactus Farm, L.L.C., Utah Shelter Systems, Inc. Case Number CV20127-094749 Rosenfeld Deposition: 5-7-2021 In the United States District Court for the Eastern District of Texas Beaumont Division Robinson, Jeremy et al Plaintiffs, vs. CNA Insurance Company et al. Case Number 1:17-cv-000508 Rosenfeld Deposition: 3-25-2021 In the Superior Court of the State of California, County of San Bernardino Gary Garner, Personal Representative for the Estate of Melvin Garner vs. BNSF Railway Company. Case No. 1720288 Rosenfeld Deposition 2-23-2021 In the Superior Court of the State of California, County of Los Angeles, Spring Street Courthouse Benny M Rodriguez vs. Union Pacific Railroad, A Corporation, et al. Case No. 18STCV01162 Rosenfeld Deposition 12-23-2020 In the Circuit Court of Jackson County, Missouri Karen Cornwell, Plaintiff, vs. Marathon Petroleum, LP, Defendant. Case No.: 1716-CV10006 Rosenfeld Deposition. 8-30-2019 In the United States District Court For The District of New Jersey Duarte et al, Plaintiffs, vs. United States Metals Refining Company et. al. Defendant. Case No.: 2:17-cv-01624-ES-SCM Rosenfeld Deposition. 6-7-2019 143 Paul E. Rosenfeld, Ph.D. Page 9 of 10 October 2021 In the United States District Court of Southern District of Texas Galveston Division M/T Carla Maersk, Plaintiffs, vs. Conti 168., Schiffahrts-GMBH & Co. Bulker KG MS “Conti Perdido” Defendant. Case No.: 3:15-CV-00106 consolidated with 3:15-CV-00237 Rosenfeld Deposition. 5-9-2019 In The Superior Court of the State of California In And For The County Of Los Angeles – Santa Monica Carole-Taddeo-Bates et al., vs. Ifran Khan et al., Defendants Case No.: No. BC615636 Rosenfeld Deposition, 1-26-2019 In The Superior Court of the State of California In And For The County Of Los Angeles – Santa Monica The San Gabriel Valley Council of Governments et al. vs El Adobe Apts. Inc. et al., Defendants Case No.: No. BC646857 Rosenfeld Deposition, 10-6-2018; Trial 3-7-19 In United States District Court For The District of Colorado Bells et al. Plaintiff vs. The 3M Company et al., Defendants Case No.: 1:16-cv-02531-RBJ Rosenfeld Deposition, 3-15-2018 and 4-3-2018 In The District Court Of Regan County, Texas, 112th Judicial District Phillip Bales et al., Plaintiff vs. Dow Agrosciences, LLC, et al., Defendants Cause No.: 1923 Rosenfeld Deposition, 11-17-2017 In The Superior Court of the State of California In And For The County Of Contra Costa Simons et al., Plaintiffs vs. Chevron Corporation, et al., Defendants Cause No C12-01481 Rosenfeld Deposition, 11-20-2017 In The Circuit Court Of The Twentieth Judicial Circuit, St Clair County, Illinois Martha Custer et al., Plaintiff vs. Cerro Flow Products, Inc., Defendants Case No.: No. 0i9-L-2295 Rosenfeld Deposition, 8-23-2017 In United States District Court For The Southern District of Mississippi Guy Manuel vs. The BP Exploration et al., Defendants Case: No 1:19-cv-00315-RHW Rosenfeld Deposition, 4-22-2020 In The Superior Court of the State of California, For The County of Los Angeles Warrn Gilbert and Penny Gilber, Plaintiff vs. BMW of North America LLC Case No.: LC102019 (c/w BC582154) Rosenfeld Deposition, 8-16-2017, Trail 8-28-2018 In the Northern District Court of Mississippi, Greenville Division Brenda J. Cooper, et al., Plaintiffs, vs. Meritor Inc., et al., Defendants Case Number: 4:16-cv-52-DMB-JVM Rosenfeld Deposition: July 2017 144 Paul E. Rosenfeld, Ph.D. Page 10 of 10 October 2021 In The Superior Court of the State of Washington, County of Snohomish Michael Davis and Julie Davis et al., Plaintiff vs. Cedar Grove Composting Inc., Defendants Case No.: No. 13-2-03987-5 Rosenfeld Deposition, February 2017 Trial, March 2017 In The Superior Court of the State of California, County of Alameda Charles Spain., Plaintiff vs. Thermo Fisher Scientific, et al., Defendants Case No.: RG14711115 Rosenfeld Deposition, September 2015 In The Iowa District Court In And For Poweshiek County Russell D. Winburn, et al., Plaintiffs vs. Doug Hoksbergen, et al., Defendants Case No.: LALA002187 Rosenfeld Deposition, August 2015 In The Circuit Court of Ohio County, West Virginia Robert Andrews, et al. v. Antero, et al. Civil Action N0. 14-C-30000 Rosenfeld Deposition, June 2015 In The Iowa District Court For Muscatine County Laurie Freeman et. al. Plaintiffs vs. Grain Processing Corporation, Defendant Case No 4980 Rosenfeld Deposition: May 2015 In the Circuit Court of the 17th Judicial Circuit, in and For Broward County, Florida Walter Hinton, et. al. Plaintiff, vs. City of Fort Lauderdale, Florida, a Municipality, Defendant. Case Number CACE07030358 (26) Rosenfeld Deposition: December 2014 In the County Court of Dallas County Texas Lisa Parr et al, Plaintiff, vs. Aruba et al, Defendant. Case Number cc-11-01650-E Rosenfeld Deposition: March and September 2013 Rosenfeld Trial: April 2014 In the Court of Common Pleas of Tuscarawas County Ohio John Michael Abicht, et al., Plaintiffs, vs. Republic Services, Inc., et al., Defendants Case Number: 2008 CT 10 0741 (Cons. w/ 2009 CV 10 0987) Rosenfeld Deposition: October 2012 In the United States District Court for the Middle District of Alabama, Northern Division James K. Benefield, et al., Plaintiffs, vs. International Paper Company, Defendant. Civil Action Number 2:09-cv-232-WHA-TFM Rosenfeld Deposition: July 2010, June 2011 In the Circuit Court of Jefferson County Alabama Jaeanette Moss Anthony, et al., Plaintiffs, vs. Drummond Company Inc., et al., Defendants Civil Action No. CV 2008-2076 Rosenfeld Deposition: September 2010 In the United States District Court, Western District Lafayette Division Ackle et al., Plaintiffs, vs. Citgo Petroleum Corporation, et al., Defendants. Case Number 2:07CV1052 Rosenfeld Deposition: July 2009 145 ATTACHMENT 3 146 TRUCKS ONLY AUTOS ONLY AUTOS/TRUCKS CIRCULATION LEGEND 147 DAB-A1.0E Developer Project: Consultants: SITE (10951 Los Angeles Ave.)Tabulation Aerial Map 148 149 150 151 152 For illustrative purposes.Final design subject to final approved plans during permitting process.153 For illustrative purposes.Final design subject to final approved plans during permitting process.154 155 156 ACCENTS GROUNDCOVER Greybox Coast Rosemary Westringia 'Greybox' QTYSIZE REMARKSSYMBOL SHRUBS BOTANICAL/COMMON NAME WUCOLS QTYSIZE REMARKSSYMBOLBOTANICAL/COMMON NAME WUCOLS SPACINGSIZE REMARKSSYMBOLBOTANICAL/COMMON NAME WUCOLS Hesperaloe parviflora Red Yucca Carex pansa California Meadow Sedge 12" O.C.4" Pots M Texas Privet Ligustrum j. Texanum Deer Grass Muhlenbergia Rigens Lonicera j. 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All rights reserved. Lithonia RSX2 Area LED Rev. 06/14/21 Page 1 of 9 COMMERCIAL OUTDOOR Catalog Number Notes Type Introduction The new RSX LED Area family delivers maximum value by providing significant energy savings, long life and outstanding photometric performance at an affordable price. The RSX2 delivers 11,000 to 31,000 lumens allowing it to replace 250W to 1000W HID luminaires. The RSX features an integral universal mounting mechanism that allows the luminaire to be mounted on most existing drill hole patterns. This “no-drill” solution provides significant labor savings. An easy-access door on the bottom of mounting arm allows for wiring without opening the electrical compartment. A mast arm adaptor, adjustable integral slipfitter and other mounting configurations are available. Hit the Tab key or mouse over the page to see all interactive elements. Options Finish Shipped Installed HS House-side shield 7 PE Photocontrol, button style 8,9 PEX Photocontrol external threaded, adjustable 9,10 PER7 Seven-wire twist-lock receptacle only (no controls)9,11,12,13 CE34 Conduit entry 3/4” NPT (Qty 2) SF Single fuse (120, 277, 347) 5 DF Double fuse (208, 240, 480) 5 SPD20KV 20KV Surge pack (10KV standard) FAO Field adjustable output 9,13 DMG 0-10V dimming extend out back of housing for external control (control ordered separate) 9,13 DS Dual switching 9,14 Shipped Installed *Standalone and Networked Sensors/Controls (factory default settings, see table page 9) NLTAIR2 nLight AIR generation 2 13,15,16 PIRHN Networked, Bi-Level motion/ambient sensor (for use with NLTAIR2) 13,16,17 BAA Buy America(n) Act Compliant *Note: PIRHN with nLight Air can be used as a standalone dimming sensor with out-of-box settings or as a wireless networked solution. See factory default settings table. Sensor coverage pattern is affected when luminaire is tilted. Shipped Separately (requires some field assembly) EGS External glare shield 6 EGFV External glare full visor (360° around light aperture) 7 BS Bird spikes 18 DDBXD Dark Bronze DBLXD Black DNAXD Natural Aluminum DWHXD White DDBTXD Textured Dark Bronze DBLBXD Textured Black DNATXD Textured Natural Aluminum DWHGXD Textured White WW Ordering Information EXAMPLE: RSX2 LED P6 40K R3 MVOLT SPA DDBXD RSX2 LED Series Performance Package Color Temperature Distribution Voltage Mounting RSX2 LED P1 P2 P3 P4 P5 P6 30K 3000K 40K 4000K 50K 5000K R2 Type 2 Wide R3 Type 3 Wide R3S Type 3 Short R4 Type 4 Wide R4S Type 4 Short R5 Type 5 Wide 1 R5S Type 5 Short 1 AFR Automotive Front Row AFRR90 Automotive Front Row Right Rotated AFRL90 Automotive Front Row Left Rotated MVOLT (120V-277V) 2 HVOLT (347V-480V) 3 XVOLT (277V-480V) 4 (use specific voltage for options as noted) 120 3 277 5 208 3 347 5 240 3 480 5 SPA Square pole mounting (3.0" min. SQ pole for 1 at 90°, 3.5" min. SQ pole for 2, 3, 4 at 90°) RPA Round pole mounting (3.2" min. dia. RND pole for 2, 3, 4 at 90°, 3.0" min. dia. RND pole for 1 at 90°, 2 at 180°, 3 at 120°) MA Mast arm adaptor (fits 2-3/8" OD horizontal tenon) IS Adjustable slipfitter (fits 2-3/8" OD tenon) 6 WBA Wall bracket 1 WBASC Wall bracket with surface conduit box AASP Adjustable tilt arm square pole mounting 6 AARP Adjustable tilt arm round pole mounting 6 AAWB Adjustable tilt arm with wall bracket 6 AAWSC Adjustable tilt arm wall bracket and surface conduit box 6 Buy American RSX2 LED Area Luminaire Specifications EPA (ft2@0°):0.69 ft2 (0.06 m2 ) Length:29.3” (74.4 cm) (SPA mount) Width:13.4” (34.0 cm) Height:3.0" (7.6 cm) Main Body 7.2” (18.3 cm) Arm Weight: (SPA mount)30.0 lbs (13.6 kg) L W H 167 One Lithonia Way • Conyers, Georgia 30012 • Phone: 1-800-705-SERV (7378) • www.acuitybrands.com © 2011-2021 Acuity Brands Lighting, Inc. All rights reserved. Lithonia RSX2 Area LED Rev. 06/14/21 Page 2 of 9 COMMERCIAL OUTDOOR Ordering Information NOTES 1 Any Type 5 distribution, is not available with WBA. 2 MVOLT driver operates on any line voltage from 120-277V (50/60 Hz). 3 HVOLT driver operates on any line voltage from 347-480V (50/60 Hz). 4 XVOLT driver not available with P1. XVOLT driver operates on any line voltage from 277V-480V (50/60 Hz). XVOLT not available with fusing (SF or DF) and not available with PE or PEX. 5 Single fuse (SF) requires 120V, 277V or 347V. Double fuse (DF) requires 208V, 240V or 480V. 6 Maximum tilt is 90° above horizontal. 7 It may be ordered as an accessory. 8 Requires MVOLT or 347V. 9 Not available in combination with other light sensing control options (following options cannot be combined: PE, PEX, PER7, FAO, DMG, DS, PIRHN). 10 Requires 120V, 208V, 240V, or 277V. 11 Twistlock photocell ordered and shipped as a separate line item from Acuity Brands Controls. See accessories. Shorting Cap included. Dimming leads capped for future use. 12 For units with option PER7, the mounting must be restricted to +/- 45° from horizontal aim per ANSI C136.10-2010. 13 Two or more of the following options cannot be combined including DMG, DS, PER7, FAO and PIRHN. 14 DS only available on performance package P5 and P6. 15 Must be ordered with PIRHN. 16 Requires MVOLT or HVOLT. 17 Must be ordered with NLTAIR2. For additional information on PIRHN visit here. 18 Must be ordered with fixture for factory pre-drilling. 19 Requires luminaire to be specified with PER7 option. Ordered and shipped as a separate line item from Acuity Brands Controls. Accessories Ordered and shipped separately. RSX2HS RSX2 House side shield (includes 2 shields) RSX2EGS (FINISH) U External glare shield (specify finish) RSX2HSAFRR (FINISH) U RSX2 House side shields for AFR rotated optics (includes 2 shields) RSX2EGFV (FINISH) U External glare full visor (specify finish) RSXRPA (FINISH) U RSX Universal round pole adaptor plate (specify finish) RSXWBA (FINISH) U RSX WBA wall bracket (specify finish) 1 RSXSCB (FINISH) U RSX Surface conduit box (specify finish, for use with WBA, WBA not included) DLL127F 1.5 JU Photocell -SSL twist-lock (120-277V) 19 DLL347F 1.5 CUL JU Photocell -SSL twist-lock (347V) 19 DLL480F 1.5 CUL JU Photocell -SSL twist-lock (480V) 19 DSHORT SBK U Shorting cap 19 House Side Shield External Glare Shield External 360 Full Visor External Shields Pole/Mounting Informatiion HANDHOLE ORIENTATION A Handhole B C D Accessories including bullhorns, cross arms and other adpaters are available under the accessories tab at Lithonia's Outdoor Poles and Arms product page. Click here to visit Accessories. RSX2 - Luminaire EPA Fixture Quantity & Mounting Configuration Single 2 @ 90 2 @ 180 3 @ 90 3 @ 120 4 @ 90 2 Side by Side 3 Side by Side 4 Side by Side Mounting Type Tilt SPA - Square Pole Adaptor 0 ° 0.69 1.22 1.27 1.8 1.61 2.39 1.37 2.06 2.74 RPA - Round Pole Adaptor 0.74 1.27 1.37 1.9 1.71 2.49 1.42 2.16 2.84 MA - Mast Arm Adaptor 0.61 1.14 1.11 1.64 1.45 2.23 1.29 1.9 2.58 IS - Integral Slipfitter AASP/AARP - Adjustable Arm Square/Round Pole 0 ° 0.69 1.22 1.27 1.8 1.61 2.39 1.37 2.06 2.74 10° 0.53 1.06 1.05 1.58 1.37 2.08 1.06 1.59 2.12 20° 0.52 1.02 1.03 1.52 1.33 2.02 1.03 1.55 2.07 30° 0.64 1.11 1.18 1.63 1.45 2.21 1.27 1.91 2.54 40° 0.81 1.21 1.35 1.74 1.65 2.39 1.62 2.43 3.23 45° 0.91 1.25 1.5 1.81 1.75 2.48 1.82 2.73 3.64 50° 1.34 1.83 2.17 2.61 2.56 3.62 2.68 4.02 5.36 60° 2.2 2.97 3.57 4.24 4.17 5.89 4.41 6.61 8.82 70° 2.86 4.13 4.7 5.89 5.71 8.21 5.71 8.57 11.42 80° 3.4 5.13 5.67 7.34 7.09 10.21 6.79 10.19 13.59 90° 3.85 5.96 6.55 8.58 8.31 11.88 7.70 11.56 15.41 *Includes luminaire and integral mounting arm. Other tenons, arms, brackets or other accessories are not included in this EPA data.Top of Pole 0.563” 2.650” 1.325”0.400” (2 PLCS) Template #8 RSX POLE DRILLING RSX STANDARD ARM & ADJUSTABLE ARM 5.25” 2.65” Drilling Template Mounting Option Single 2 @ 180 2 @ 90 3 @ 120 3 @ 90 4 @ 90 Head Location Side B Side B & D Side B & C Round Pole Only Side B, C & D Side A, B, C & D #8 Drill Nomenclature DM19AS DM28AS DM29AS DM32AS DM39AS DM49AS Tenon O.D.RSX Mounting Single 2 at 180°2 at 90°3 at 120°3 at 90°4 at 90° 2 - 3/8"RPA, AARP AS3-5 190 AS3-5 280 AS3-5 290 AS3-5 320 AS3-5 390 AS3-5 490 2 - 7/8"RPA, AARP AST25-190 AST25-280 AST25-290 AST25-320 AST25-390 AST25-490 4" RPA, AARP AST35-190 AST35-280 AST35-290 AST35-320 AST35-390 AST35-490 Round Tenon Mount - Pole Top Slipfitters Drill/Side Location by Configuration Type 168 One Lithonia Way • Conyers, Georgia 30012 • Phone: 1-800-705-SERV (7378) • www.acuitybrands.com © 2011-2021 Acuity Brands Lighting, Inc. All rights reserved. Lithonia RSX2 Area LED Rev. 06/14/21 Page 3 of 9 COMMERCIAL OUTDOOR Performance Data Lumen Ambient Temperature (LAT) Multipliers Use these factors to determine relative lumen output for average ambient temperatures from 0-50°C (32-122°F). Ambient Ambient Lumen Multiplier 0°C 32°F 1.05 5°C 41°F 1.04 10°C 50°F 1.03 15°C 59°F 1.02 20°C 68°F 1.01 25°C 77°F 1.00 30°C 86°F 0.99 35°C 95°F 0.98 40°C 104°F 0.97 45°C 113°F 0.96 50°C 122°F 0.95 Current (A) Performance Package System Watts (W) 120V 208V 240V 277V 347V 480V P1 71W 0.59 0.34 0.30 0.26 0.20 0.15 P2 111W 0.93 0.53 0.46 0.40 0.32 0.23 P3 147W 1.23 0.70 0.61 0.53 0.42 0.31 P4 187W 1.55 0.90 0.78 0.68 0.53 0.38 P5 210W 1.75 1.01 0.87 0.76 0.60 0.44 P6 244W 2.03 1.17 1.01 0.88 0.70 0.51 Electrical Load Values calculated according to IESNA TM-21-11 methodology and valid up to 40°C. Operating Hours 50,000 75,000 100,000 Lumen Maintenance Factor >0.97 >0.95 >0.92 Projected LED Lumen Maintenance To see complete photometric reports or download .ies files for this product, visit Lithonia Lighting’s RSX Area homepage. Photometric Diagrams Isofootcandle plots for the RSX2 LED P6 40K. Distances are in units of mounting height (30’). 4 3 2 1 0 -4 -3 -2 -1 43210 4321 4 3 2 1 0 -4 -3 -2 -1 43210 4321 4 3 2 1 0 -4 -3 -2 -1 43210 4321 4 3 2 1 0 -4 -3 -2 -1 43210 4321 R3R3 R4R4 R5R5R2R2 LEGEND 0.1 fc 0.5 fc 1.0 fc 4 3 2 1 0 -4 -3 -2 -1 43210 4321 AFRAFR 4 3 2 1 0 -4 -3 -2 -1 43210 4321 AFRL90AFRL90 4 3 2 1 0 -4 -3 -2 -1 43210 4321 AFRR90AFRR90 169 One Lithonia Way • Conyers, Georgia 30012 • Phone: 1-800-705-SERV (7378) • www.acuitybrands.com © 2011-2021 Acuity Brands Lighting, Inc. All rights reserved. Lithonia RSX2 Area LED Rev. 06/14/21 Page 4 of 9 COMMERCIAL OUTDOOR Performance Data Performance Package System Watts Distribution. Type 30K (3000K, 70 CRI) 40K (4000K, 70 CRI) 50K (5000K, 70 CRI) Lumens B U G LPW Lumens B U G LPW Lumens B U G LPW P1 71W R2 10,040 2 0 1 139 11,031 2 0 1 153 11,031 2 0 1 153 R3 10,005 2 0 2 141 10,992 2 0 2 155 10,992 2 0 2 155 R3S 10,271 2 0 2 143 11,285 2 0 2 157 11,285 2 0 2 157 R4 10,136 2 0 2 143 11,136 2 0 2 157 11,136 2 0 2 157 R4S 9,779 2 0 2 138 10,744 2 0 2 151 10,744 2 0 2 151 R5 10,271 4 0 2 145 11,285 4 0 2 159 11,285 4 0 2 159 R5S 10,544 3 0 1 149 11,585 3 0 2 163 11,585 3 0 2 163 AFR 10,026 2 0 1 141 11,016 2 0 1 155 11,016 2 0 1 155 AFRR90 10,122 3 0 2 140 11,121 3 0 2 154 11,121 3 0 2 154 AFRL90 10,164 3 0 2 141 11,167 3 0 2 155 11,167 3 0 2 155 P2 111W R2 15,712 2 0 2 138 17,263 2 0 2 151 17,263 2 0 2 151 R3 15,657 2 0 3 141 17,202 3 0 3 155 17,202 3 0 3 155 R3S 16,075 2 0 2 141 17,661 2 0 2 155 17,661 2 0 2 155 R4 15,862 2 0 3 143 17,427 2 0 3 157 17,427 2 0 3 157 R4S 15,304 2 0 2 138 16,815 2 0 2 151 16,815 2 0 2 151 R5 16,075 4 0 2 145 17,661 5 0 3 159 17,661 5 0 3 159 R5S 16,502 4 0 2 149 18,130 4 0 2 163 18,130 4 0 2 163 AFR 15,691 2 0 2 141 17,240 2 0 2 155 17,240 2 0 2 155 AFRR90 15,841 3 0 3 139 17,404 4 0 3 153 17,404 4 0 3 153 AFRL90 15,907 3 0 3 139 17,477 4 0 3 153 17,477 4 0 3 153 P3 147W R2 19,855 3 0 2 132 21,814 3 0 2 145 21,814 3 0 2 145 R3 19,785 3 0 3 135 21,737 3 0 4 148 21,737 3 0 4 148 R3S 20,312 3 0 3 135 22,317 3 0 3 149 22,317 3 0 3 149 R4 20,044 3 0 3 136 22,022 3 0 4 150 22,022 3 0 4 150 R4S 19,339 3 0 3 132 21,247 3 0 3 145 21,247 3 0 3 145 R5 20,313 5 0 3 138 22,317 5 0 3 152 22,317 5 0 3 152 R5S 20,852 4 0 2 142 22,910 4 0 2 156 22,910 4 0 2 156 AFR 19,828 3 0 2 135 21,785 3 0 2 148 21,785 3 0 2 148 AFRR90 20,017 4 0 3 133 21,992 4 0 3 147 21,992 4 0 3 147 AFRL90 20,101 4 0 3 134 22,084 4 0 3 147 22,084 4 0 3 147 P4 187W R2 22,836 3 0 2 120 25,090 3 0 2 132 25,090 3 0 2 132 R3 22,756 3 0 4 122 25,002 3 0 4 134 25,002 3 0 4 134 R3S 23,363 3 0 3 123 25,668 3 0 3 135 25,668 3 0 3 135 R4 23,054 3 0 4 123 25,329 3 0 4 135 25,329 3 0 4 135 R4S 22,243 3 0 3 119 25,059 3 0 3 134 25,059 3 0 3 134 R5 23,363 5 0 3 125 25,669 5 0 4 137 25,669 5 0 4 137 R5S 23,983 4 0 2 128 26,350 4 0 2 141 26,350 4 0 2 141 AFR 22,806 3 0 2 122 25,056 3 0 2 134 25,056 3 0 2 134 AFRR90 23,023 4 0 3 121 25,295 4 0 3 133 25,295 4 0 3 133 AFRL90 23,120 4 0 3 122 25,401 4 0 3 134 25,401 4 0 3 134 P5 210W R2 26,141 3 0 2 122 28,721 3 0 2 135 28,721 3 0 2 135 R3 26,049 3 0 4 124 28,620 3 0 4 136 28,620 3 0 4 136 R3S 26,744 3 0 3 125 29,383 3 0 4 138 29,383 3 0 4 138 R4 26,390 3 0 4 126 28,994 3 0 4 138 28,994 3 0 4 138 R4S 25,462 3 0 3 121 27,974 3 0 3 133 27,974 3 0 3 133 R5 26,744 5 0 4 127 29,383 5 0 4 140 29,383 5 0 4 140 R5S 27,454 4 0 2 131 30,163 4 0 2 144 30,163 4 0 2 144 AFR 26,106 3 0 2 124 28,682 3 0 2 137 28,682 3 0 2 137 AFRR90 26,354 4 0 3 123 28,955 5 0 3 136 28,955 5 0 3 136 AFRL90 26,465 4 0 3 124 29,077 5 0 3 136 29,077 5 0 3 136 P6 244W R2 27,646 3 0 2 112 30,374 3 0 2 123 30,374 3 0 2 123 R3 27,549 3 0 4 113 30,267 3 0 4 124 30,267 3 0 4 124 R3S 28,283 3 0 3 115 31,075 3 0 4 126 31,075 3 0 4 126 R4 27,909 3 0 4 114 30,663 3 0 4 126 30,663 3 0 4 126 R4S 26,928 3 0 3 110 29,585 3 0 3 121 29,585 3 0 3 121 R5 28,284 5 0 4 116 31,075 5 0 4 127 31,075 5 0 4 127 R5S 29,035 4 0 2 119 31,900 5 0 3 131 31,900 5 0 3 131 AFR 27,608 3 0 2 112 30,332 3 0 2 123 30,332 3 0 2 123 AFRR90 27,872 4 0 3 113 30,622 5 0 3 124 30,622 5 0 3 124 AFRL90 27,989 4 0 3 113 30,751 5 0 3 125 30,751 5 0 3 125 Lumen Output Lumen values are from photometric tests performed in accordance with IESNA LM-79-08. Data is considered to be representative of the configurations shown, within the tolerances allowed by Lighting Facts. Contact factory for performance data on any configurations not shown here. 170 One Lithonia Way • Conyers, Georgia 30012 • Phone: 1-800-705-SERV (7378) • www.acuitybrands.com © 2011-2021 Acuity Brands Lighting, Inc. All rights reserved. Lithonia RSX2 Area LED Rev. 06/14/21 Page 5 of 9 COMMERCIAL OUTDOOR L W H Length: 30.3” (77.0 cm) Width: 13.4” (34.0 cm) Height: 3.0” (7.6 cm) Main Body 7.2” (18.3 cm) Arm RSX2 with Round Pole Adapter (RPA) Length: 28.3” (71.9 cm) Width: 13.4” (34.0 cm) Height: 3.0” (7.6 cm) Main Body 7.6” (19.3 cm) Arm RSX2 with Adjustable Slipfitter (IS) L W H L W H Length: 30.6” (77.7 cm) Width: 13.4” (34.0 cm) Height: 3.0” (7.6 cm) Main Body 3.5” (8.9 cm) Arm RSX2 with Mast Arm Adapter (MA) Dimensions & Weights Note: RPA — Round Pole mount can also be used to mount on square poles by omitting the round pole adapter plate shown here. 7/16" locking thru bolt/nut provided 7/8" KO - fits 1/2" NPT water- tight fitting Luminaire Weight by Mounting Type Mounting Configuration Total Luminaire Weight SPA 30 lbs RPA 32 lbs MA 30 lbs WBA 33 lbs WBASC 36 lbs IS 33 lbs AASP 33 lbs AARP 35 lbs AAWB 36 lbs AAWSC 39 lbs 171 One Lithonia Way • Conyers, Georgia 30012 • Phone: 1-800-705-SERV (7378) • www.acuitybrands.com © 2011-2021 Acuity Brands Lighting, Inc. All rights reserved. Lithonia RSX2 Area LED Rev. 06/14/21 Page 6 of 9 COMMERCIAL OUTDOOR Dimensions L W H Length: 31.2" (79.2 cm) Width: 13.4” (41.7 cm) Height: 3.0” (7.6 cm) Main Body 8.9” (22.6 cm) Arm RSX2 with Wall Bracket (WBA) Wall Bracket (WBA) Mounting Detail 4.5 7.0 L W H Length: 32.8” (83.3 cm) Width: 13.4” (41.7 cm) Height: 3.0” (7.6 cm) Main Body 9.2” (23.4 cm) Arm RSX2 with Wall Bracket with Surface Conduit Box (WBASC) 3/4" NPT taps with plugs - Qty (4) provided Surface Conduit Box (SCB) Mounting Detail 4.4 7.0 172 One Lithonia Way • Conyers, Georgia 30012 • Phone: 1-800-705-SERV (7378) • www.acuitybrands.com © 2011-2021 Acuity Brands Lighting, Inc. All rights reserved. Lithonia RSX2 Area LED Rev. 06/14/21 Page 7 of 9 COMMERCIAL OUTDOOR Dimensions L W H Length: 32.8” (83.3 cm) AASP 33.8” (85.9 cm) AARP Width: 13.4” (34.0 cm) Height: 3.0” (7.6 cm) Main Body 7.2” (18.2 cm) Arm RSX2 with Adjustable Tilt Arm - Square or Round Pole (AASP or AARP) NOTE: RPA - Round Pole mount can also be used to mount on square poles by omitting the round pole adapter plate shown here. 7/8" KO - fits 1/2" NPT water- tight fitting Notes AASP: Requires 3.0" min. square pole for 1 at 90°. Requires 3.5" min. square pole for mounting 2, 3, 4 at 90°. AARP: Requires 3.2" min. dia. round pole for 2, 3, 4 at 90°. Requires 3.0" min. dia. round pole for mounting 1 at 90°, 2 at 180°, 3 at 120°. L W H Length: 34.7” (88.0 cm) Width: 13.4” (34.0 cm) Height: 3.0” (7.6 cm) Main Body 8.9” (22.6 cm) Arm RSX2 with Adjustable Tilt Arm with Wall Bracket (AAWB) Wall Bracket (WBA) Mounting Detail 4.5 7.0 7/8" KO - fits 1/2" NPT water- tight fitting 173 One Lithonia Way • Conyers, Georgia 30012 • Phone: 1-800-705-SERV (7378) • www.acuitybrands.com © 2011-2021 Acuity Brands Lighting, Inc. All rights reserved. Lithonia RSX2 Area LED Rev. 06/14/21 Page 8 of 9 COMMERCIAL OUTDOOR Dimensions L W H Length: 36.2” (91.9 cm) Width: 13.4” (40.0 cm) Height: 3.0” (7.6 cm) Main Body 9.2” (23.4 cm) Arm RSX2 with Adjustable Tilt Arm with Wall Bracket and Surface Conduit Box (AAWSC) Additional Reference Drawings Surface Conduit Box (SCB) Mounting Detail 4.4 7.0 3/4" NPT taps with plugs - Qty (4) provided 7/8" KO - fits 1/2" NPT water- tight fitting Option CE34 Reference Dimensions Automotive Front Row - Rotated Optics (AFRL90/R90) (Example: 2@180 - arrows indicate direction of light exiting the luminaire) AFRR90 AFRL90 174 One Lithonia Way • Conyers, Georgia 30012 • Phone: 1-800-705-SERV (7378) • www.acuitybrands.com © 2011-2021 Acuity Brands Lighting, Inc. All rights reserved. Lithonia RSX2 Area LED Rev. 06/14/21 Page 9 of 9 COMMERCIAL OUTDOOR FEATURES & SPECIFICATIONS INTENDED USE The RSX LED area family is designed to provide a long-lasting, energy-efficient solution for the one-for- one replacement of existing metal halide or high pressure sodium lighting. The RSX2 delivers 11,000 to 31,000 lumens and is ideal for replacing 250W to 1000W HID pole-mounted luminaires in parking lots and other area lighting applications. CONSTRUCTION AND DESIGN The RSX LED area luminaire features a rugged die-cast aluminum main body that uses heat- dissipating fins and flow-through venting to provide optimal thermal management that both enhances LED performance and extends component life. Integral “no drill” mounting arm allows the luminaire to be mounted on existing pole drillings, greatly reducing installation labor. The light engines and housing are sealed against moisture and environmental contaminants to IP66. The low-profile design results in a low EPA, allowing pole optimization. Vibration rated per ANSI C136.31: 3G Mountings: Include SPA, RPA, MA, IS, AASP, AARP rated for 3G vibration. 1.5G Mountings: Include WBA, WBASC, AAWB and AAWSC rated for 1.5G vibration. FINISH Exterior parts are protected by a zinc-infused Super Durable TGIC thermoset powder coat finish that provides superior resistance to corrosion and weathering. A tightly controlled multi-stage process ensures superior adhesion as well as a minimum finish thickness of 3 mils. The result is a high-quality finish that is warrantied not to crack or peel. OPTICS Precision acrylic refractive lenses are engineered for superior application efficiency, distributing the light to where it is needed most. Available in short and wide pattern distributions including Type 2, Type 3, Type 3S, Type 4, Type 4S, Type 5, Type 5S, AFR (Automotive Front Row) and AFR rotated AFRR90 and ARFL90. ELECTRICAL Light engine(s) configurations consist of high-efficacy LEDs mounted on metal-core circuit boards and aluminum heat sinks to maximize heat dissipation. Light engines are IP66 rated. LED lumen maintenance is >L92/100,000 hours. CCT’s of 3000K, 4000K and 5000K (minimum 70 CRI) are available. Class 1 electronic drivers ensure system power factor >90% and THD <20%. Easily serviceable 10kV surge protection device meets a minimum Category C Low operation (per ANSI/ IEEE C62.41.2). STANDARD CONTROLS The RSX LED area luminaire has a wide assortment of control options. Dusk to dawn controls include MVOLT and 347V button-type photocells and NEMA twist-lock photocell receptacles. nLIGHT AIR CONTROLS The RSX LED area luminaire is also available with nLight® AIR for the ultimate in wireless control. This powerful controls platform provides out-of-the-box basic motion sensing with photocontrol functionality and is suitable for mounting heights up to 40 feet. No commissioning is required when using factory default settings that provide basic stand-alone motion occupancy dimming that is switched on and off with a built-in photocell. See chart above for motion sensor default out- of-box settings. For more advanced wireless functionality, such as group dimming, nLight AIR can be commissioned using a smartphone and the easy-to-use CLAIRITY app. nLight AIR equipped luminaries can be grouped, resulting in motion sensor and photocell group response without the need for additional equipment. Scheduled dimming with motion sensor over-ride can be achieved when used with the nLight Eclypse. Additional information about nLight Air can be found here. INSTALLATION Integral “no-drill” mounting arm allows for fast, easy mounting using existing pole drillings. Select the “SPA” option for square poles and the “RPA” option to mount to round poles. Note, the RPA mount can also be used for mounting to square poles by omitting the RPA adapter plate. Select the “MA” option to attach the luminaire to a 2 3/8” horizontal mast arm or the “IS” option for an adjustable slipfitter that mounts on a 2 3/8” OD tenon. The adjustable slipfitter has an integral junction box and offers easy installation. Can be tilted up to 90° above horizontal. Additional mountings are available including a wall bracket, adjustable tilt arm for direct-to-pole and wall and a surface conduit box for wall mount applications. LISTINGS CSA Certified to meet U.S. and Canadian standards. Suitable for wet locations. Rated for -40°C minimum ambient. DesignLights Consortium® (DLC) Premium qualified product and DLC qualified product. Not all versions of this product may be DLC Premium qualified or DLC qualified. Please check the DLC Qualified Products List at www.designlights.org/QPL to confirm which versions are qualified. International Dark-Sky Association (IDA) Fixture Seal of Approval (FSA) is available for all products on this page utilizing 3000K color temperature only. BUY AMERICAN Product with the BAA option is assembled in the USA and meets the Buy America(n) government procurement requirements under FAR, DFARS and DOT. Please refer to www.acuitybrands.com/buy-american for additional information. WARRANTY 5-year limited warranty. Complete warranty terms located at: www.acuitybrands.com/support/customer-support/terms-and-conditions Note: Actual performance may differ as a result of end-user environment and application. All values are design or typical values, measured under laboratory conditions at 25 °C. Specifications subject to change without notice. nLight Control - Sensor Coverage and Settings NLTAIR2 PIRHN nLight Sensor Coverage Pattern nLight PIRHN Top Side Motion Sensor Default Settings - Option PIRHN Option Dimmed State (unoccupied) High Level (when occupied) Photocell Operation Dwell Time (occupancy time delay) Ramp-up Time (from unoccupied to occupied) Ramp-down Time (from occupied to unoccupied) NLTAIR2 PIRHN Approx. 30% Output 100% Output Enabled @ 1.5FC 7.5 minutes 3 seconds 5 minutes *Note: NLTAIR2 PIRHN default settings including photocell set-point, high/low dim rates, and occupancy sensor time delay are all configurable using the Clairity Pro App. Sensor coverage pattern shown with luminaire at 0°. Sensor coverage pattern is affected when luminaire is titled. 175 One Lithonia Way • Conyers, Georgia 30012 • Phone: 1-800-705-SERV (7378) • www.acuitybrands.com © 2018-2021 Acuity Brands Lighting, Inc. All rights reserved. Lithonia RSX1 Area LED Rev. 05/04/21 Page 1 of 9 COMMERCIAL OUTDOOR RSX1 LED Area Luminaire Specifications Catalog Number Notes Type Introduction The new RSX LED Area family delivers maximum value by providing significant energy savings, long life and outstanding photometric performance at an affordable price. The RSX1 delivers 7,000 to 17,000 lumens allowing it to replace 70W to 400W HID luminaires. The RSX features an integral universal mounting mechanism that allows the luminaire to be mounted on most existing drill hole patterns. This “no-drill” solution provides significant labor savings. An easy-access door on the bottom of mounting arm allows for wiring without opening the electrical compartment. A mast arm adaptor, adjustable integral slipfitter and other mounting configurations are available. EPA (ft2@0°):0.57 ft2 (0.05 m2) Length:21.8” (55.4 cm) (SPA mount) Width:13.3” (33.8 cm) Height:3.0" (7.6 cm) Main Body 7.2” (18.4 cm) Arm Weight: (SPA mount):22.0 lbs (10.0 kg) Hit the Tab key or mouse over the page to see all interactive elements. L W H Options Finish Shipped Installed HS House-side shield 7 PE Photocontrol, button style 8,9 PEX Photocontrol external threaded, adjustable 9,10 PER7 Seven-wire twist-lock receptacle only (no controls) 9,11,12,13 CE34 Conduit entry 3/4” NPT (Qty 2) SF Single fuse (120, 277, 347) 5 DF Double fuse (208, 240, 480) 5 SPD20KV 20KV Surge pack (10KV standard) FAO Field adjustable output 9,13 DMG 0-10V dimming extend out back of housing for external control (control ordered separate) 9,13 Shipped Installed *Standalone and Networked Sensors/Controls (factory default settings, see table page 9) NLTAIR2 nLight AIR generation 2 13,14,15 PIRHN Networked, Bi-Level motion/ambient sensor (for use with NLTAIR2) 13,15,16 BAA Buy America(n) Act Compliant *Note: PIRHN with nLight Air can be used as a standalone or networked solution. Sensor coverage pattern is affected when luminaire is tilted. Shipped Separately (requires some field assembly) EGS External glare shield 7 EGFV External glare full visor (360° around light aperture) 7 BS Bird spikes 17 DDBXD Dark Bronze DBLXD Black DNAXD Natural Aluminum DWHXD White DDBTXD Textured Dark Bronze DBLBXD Textured Black DNATXD Textured Natural Aluminum DWHGXD Textured White WW Ordering Information EXAMPLE: RSX1 LED P4 40K R3 MVOLT SPA DDBXD RSX1 LED Series Performance Package Color Temperature Distribution Voltage Mounting RSX1 LED P1 P2 P3 P4 30K 3000K 40K 4000K 50K 5000K R2 Type 2 Wide R3 Type 3 Wide R3S Type 3 Short R4 Type 4 Wide R4S Type 4 Short R5 Type 5 Wide 1 R5S Type 5 Short 1 AFR Automotive Front Row AFRR90 Automotive Front Row Right Rotated AFRL90 Automotive Front Row Left Rotated MVOLT (120V-277V) 2 HVOLT (347V-480V) 3 XVOLT (277V-480V) 4 (use specific voltage for options as noted) 120 3 277 5 208 3 347 5 240 3 480 5 SPA Square pole mounting (3.0" min. SQ pole for 1 at 90°, 3.5" min. SQ pole for 2, 3, 4 at 90°) RPA Round pole mounting (3.2" min. dia. RND pole for 2, 3, 4 at 90°, 3.0" min. dia. RND pole for 1 at 90°, 2 at 180°, 3 at 120°) MA Mast arm adaptor (fits 2-3/8" OD horizontal tenon) IS Adjustable slipfitter (fits 2-3/8" OD tenon) 6 WBA Wall bracket 1 WBASC Wall bracket with surface conduit box AASP Adjustable tilt arm square pole mounting 6 AARP Adjustable tilt arm round pole mounting 6 AAWB Adjustable tilt arm with wall bracket 6 AAWSC Adjustable tilt arm wall bracket and surface conduit box 6 Buy American 176 One Lithonia Way • Conyers, Georgia 30012 • Phone: 1-800-705-SERV (7378) • www.acuitybrands.com © 2018-2021 Acuity Brands Lighting, Inc. All rights reserved. Lithonia RSX1 Area LED Rev. 05/04/21 Page 2 of 9 COMMERCIAL OUTDOOR Ordering Information NOTES 1 Any Type 5 distribution, is not available with WBA. 2 MVOLT driver operates on any line voltage from 120-277V (50/60 Hz). 3 HVOLT driver operates on any line voltage from 347-480V (50/60 Hz). 4 XVOLT driver not available with P1 or P2. XVOLT driver operates on any line voltage from 277V-480V (50/60 Hz). XVOLT not available with fusing (SF or DF) and not available with PE or PEX. 5 Single fuse (SF) requires 120V, 277V or 347V. Double fuse (DF) requires 208V, 240V or 480V. 6 Maximum tilt is 90° above horizontal. 7 It may be ordered as an accessory. 8 Requires MVOLT or 347V. 9 Not available in combination with other light sensing control options (following options cannot be combined: PE, PEX, PER7, FAO, DMG, PIRHN). 10 Requires 120V, 208V, 240V or 277V. 11 Twistlock photocell ordered and shipped as a separate line item from Acuity Brands Controls. See accessories. Shorting Cap included. Dimming leads capped for future use. 12 For units with option PER7, the mounting must be restricted to +/- 45° from horizontal aim per ANSI C136.10-2010. 13 Two or more of the following options cannot be combined including DMG, PER7, FAO and PIRHN. 14 Must be ordered with PIRHN. 15 Requires MVOLT or HVOLT. 16 Must be ordered with NLTAIR2. For additional information on PIRHN visit here. 17 Must be ordered with fixture for factory pre-drilling. 18 Requires luminaire to be specified with PER7 option. Ordered and shipped as a separate line item from Acuity Brands Controls. Accessories Ordered and shipped separately. House Side Shield External Glare Shield External 360 Full Visor RSX1HS RSX1 House side shield (includes 1 shield) RSX1HSAFRR U RSX1 House side shield for AFR rotated optics (includes 1 shield) RSX1EGS (FINISH) U External glares hield (specify finish) RSX1EGFV (FINISH) U External glare full visor (specify finish) RSXRPA (FINISH) U RSX Universal round pole adaptor plate (specify finish) RSXWBA (FINISH) U RSX WBA wall bracket (specify finish) 1 RSXSCB (FINISH) U RSX Surface conduit box (specify finish, for use with WBA, WBA not included) DLL127F 1.5 JU Photocell -SSL twist-lock (120-277V) 18 DLL347F 1.5 CUL JU Photocell -SSL twist-lock (347V) 18 DLL480F 1.5 CUL JU Photocell -SSL twist-lock (480V) 18 DSHORT SBK U Shorting cap 18 External Shields Pole/Mounting Informatiion HANDHOLE ORIENTATION A Handhole B C D Accessories including bullhorns, cross arms and other adpaters are available under the accessories tab at Lithonia's Outdoor Poles and Arms product page. Click here to visit Accessories. RSX1 - Luminaire EPA Fixture Quantity & Mounting Configuration Single 2 @ 90 2 @ 180 3 @ 90 3 @ 120 4 @ 90 2 Side by Side 3 Side by Side 4 Side by Side Mounting Type Tilt SPA - Square Pole Adaptor 0 ° 0.57 1.03 1.05 1.52 1.36 2.03 1.31 1.7 2.26 RPA - Round Pole Adaptor 0.62 1.08 1.15 1.62 1.46 2.13 1.36 1.8 2.36 MA - Mast Arm Adaptor 0.49 0.95 0.89 1.36 1.2 1.87 1.23 1.54 2.1 IS - Integral Slipfitter AASP/AARP - Adjustable Arm Square/Round Pole 0 ° 0.57 1.03 1.05 1.52 1.36 2.03 1.31 1.7 2.26 10° 0.68 1.34 1.33 2 1.74 2.64 1.35 2.03 2.71 20° 0.87 1.71 1.73 2.56 2.26 3.42 1.75 2.62 3.49 30° 1.24 2.19 2.3 3.21 2.87 4.36 2.49 3.73 4.97 40° 1.81 2.68 2.98 3.85 3.68 5.30 3.62 5.43 7.24 45° 2.11 2.92 3.44 4.2 4.08 5.77 4.22 6.33 8.44 50° 2.31 3.17 3.72 4.52 4.44 6.26 4.62 6.94 9.25 60° 2.71 3.66 4.38 5.21 5.15 7.24 5.43 8.14 10.86 70° 2.78 3.98 4.54 5.67 5.47 7.91 5.52 8.27 11.03 80° 2.76 4.18 4.62 5.97 5.76 8.31 5.51 8.27 11.03 90° 2.73 4.25 4.64 6.11 5.91 8.47 5.45 8.18 10.97 *Includes luminaire and integral mounting arm. Other tenons, arms, brackets or other accessories are not included in this EPA data.Top of Pole 0.563” 2.650” 1.325”0.400” (2 PLCS) Template #8 RSX POLE DRILLING RSX STANDARD ARM & ADJUSTABLE ARM 5.25” 2.65” Drilling Template Mounting Option Single 2 @ 180 2 @ 90 3 @ 120 3 @ 90 4 @ 90 Head Location Side B Side B & D Side B & C Round Pole Only Side B, C & D Side A, B, C & D #8 Drill Nomenclature DM19AS DM28AS DM29AS DM32AS DM39AS DM49AS Tenon O.D.RSX Mounting Single 2 at 180°2 at 90°3 at 120°3 at 90°4 at 90° 2 - 3/8"RPA, AARP AS3-5 190 AS3-5 280 AS3-5 290 AS3-5 320 AS3-5 390 AS3-5 490 2 - 7/8"RPA, AARP AST25-190 AST25-280 AST25-290 AST25-320 AST25-390 AST25-490 4" RPA, AARP AST35-190 AST35-280 AST35-290 AST35-320 AST35-390 AST35-490 Round Tenon Mount - Pole Top Slipfitters Drill/Side Location by Configuration Type 177 One Lithonia Way • Conyers, Georgia 30012 • Phone: 1-800-705-SERV (7378) • www.acuitybrands.com © 2018-2021 Acuity Brands Lighting, Inc. All rights reserved. Lithonia RSX1 Area LED Rev. 05/04/21 Page 3 of 9 COMMERCIAL OUTDOOR Performance Data Lumen Ambient Temperature (LAT) Multipliers Use these factors to determine relative lumen output for average ambient temperatures from 0-50°C (32-122°F). Ambient Ambient Lumen Multiplier 0°C 32°F 1.05 5°C 41°F 1.04 10°C 50°F 1.03 15°C 59°F 1.02 20°C 68°F 1.01 25°C 77°F 1.00 30°C 86°F 0.99 35°C 95°F 0.98 40°C 104°F 0.97 45°C 113°F 0.96 50°C 122°F 0.95 Current (A) Performance Package System Watts (W) 120V 208V 240V 277V 347V 480V P1 51W 0.42 0.25 0.21 0.19 0.14 0.11 P2 72W 0.60 0.35 0.30 0.26 0.21 0.15 P3 109W 0.91 0.52 0.45 0.39 0.31 0.23 P4 133W 1.11 0.64 0.55 0.48 0.38 0.27 Electrical Load Values calculated according to IESNA TM-21-11 methodology and valid up to 40°C. Operating Hours 50,000 75,000 100,000 Lumen Maintenance Factor >0.97 >0.95 >0.92 Projected LED Lumen Maintenance To see complete photometric reports or download .ies files for this product, visit Lithonia Lighting’s RSX Area homepage. Photometric Diagrams Isofootcandle plots for the RSX1 LED P4 40K. Distances are in units of mounting height (20’). 4 3 2 1 0 -4 -3 -2 -1 43210 4321 4 3 2 1 0 -4 -3 -2 -1 43210 4321 4 3 2 1 0 -4 -3 -2 -1 43210 4321 4 3 2 1 0 -4 -3 -2 -1 43210 4321 R3R3 R4R4 R5R5R2R2 LEGEND 0.1 fc 0.5 fc 1.0 fc 4 3 2 1 0 -4 -3 -2 -1 43210 4321 AFRAFR 4 3 2 1 0 -4 -3 -2 -1 43210 4321 AFRL90AFRL90 4 3 2 1 0 -4 -3 -2 -1 43210 4321 AFRR90AFRR90 178 One Lithonia Way • Conyers, Georgia 30012 • Phone: 1-800-705-SERV (7378) • www.acuitybrands.com © 2018-2021 Acuity Brands Lighting, Inc. All rights reserved. Lithonia RSX1 Area LED Rev. 05/04/21 Page 4 of 9 COMMERCIAL OUTDOOR Performance Data Performance Package System Watts Distribution. Type 30K (3000K, 70 CRI) 40K (4000K, 70 CRI) 50K (5000K, 70 CRI) Lumens B U G LPW Lumens B U G LPW Lumens B U G LPW P1 51W R2 6,482 1 0 1 126 7,121 1 0 1 139 7,121 1 0 1 139 R3 6,459 1 0 2 127 7,096 1 0 2 139 7,096 1 0 2 139 R3S 6,631 1 0 1 129 7,286 1 0 2 142 7,286 1 0 2 142 R4 6,543 1 0 2 128 7,189 1 0 2 141 7,189 1 0 2 141 R4S 6,313 1 0 1 124 6,936 1 0 1 136 6,936 1 0 1 136 R5 6,631 3 0 2 130 7,286 3 0 2 143 7,286 3 0 2 143 R5S 6,807 3 0 1 133 7,479 3 0 1 147 7,479 3 0 1 147 AFR 6,473 1 0 1 127 7,112 1 0 1 139 7,112 1 0 1 139 AFRR90 6,535 2 0 2 127 7,179 2 0 2 140 7,179 2 0 2 140 AFRL90 6,562 2 0 1 128 7,210 2 0 2 140 7,210 2 0 2 140 P2 72W R2 8,991 2 0 1 123 9,878 2 0 1 135 9,878 2 0 1 135 R3 8,959 2 0 2 124 9,843 2 0 2 137 9,843 2 0 2 137 R3S 9,198 2 0 2 126 10,106 2 0 2 139 10,106 2 0 2 139 R4 9,077 2 0 2 126 9,972 2 0 2 139 9,972 2 0 2 139 R4S 8,757 1 0 2 122 9,622 2 0 2 134 9,622 2 0 2 134 R5 9,198 4 0 2 128 10,106 4 0 2 140 10,106 4 0 2 140 R5S 9,443 3 0 1 131 10,374 3 0 1 144 10,374 3 0 1 144 AFR 8,979 2 0 1 125 9,865 2 0 1 137 9,865 2 0 1 137 AFRR90 9,064 3 0 2 124 9,959 3 0 2 137 9,959 3 0 2 137 AFRL90 9,102 3 0 2 125 10,001 3 0 2 137 10,001 3 0 2 137 P3 109W R2 12,808 2 0 1 117 14,072 2 0 2 129 14,072 2 0 2 129 R3 12,763 2 0 2 117 14,023 2 0 2 129 14,023 2 0 2 129 R3S 13,104 2 0 2 120 14,397 2 0 2 132 14,397 2 0 2 132 R4 12,930 2 0 2 119 14,206 2 0 2 130 14,206 2 0 2 130 R4S 12,475 2 0 2 114 13,707 2 0 2 126 13,707 2 0 2 126 R5 13,104 4 0 2 120 14,397 4 0 2 132 14,397 4 0 2 132 R5S 13,452 3 0 2 123 14,779 3 0 2 136 14,779 3 0 2 136 AFR 12,791 2 0 1 117 14,053 2 0 2 129 14,053 2 0 2 129 AFRR90 12,913 3 0 3 118 14,187 3 0 3 130 14,187 3 0 3 130 AFRL90 12,967 3 0 2 118 14,247 3 0 3 130 14,247 3 0 3 130 P4 133W R2 14,943 2 0 2 112 16,417 2 0 2 123 16,417 2 0 2 123 R3 14,890 2 0 3 112 16,360 2 0 3 123 16,360 2 0 3 123 R3S 15,287 2 0 2 115 16,796 2 0 2 126 16,796 2 0 2 126 R4 15,085 2 0 3 113 16,574 2 0 3 125 16,574 2 0 3 125 R4S 14,554 2 0 2 109 15,991 2 0 2 120 15,991 2 0 2 120 R5 15,287 4 0 2 115 16,796 4 0 2 126 16,796 4 0 2 126 R5S 15,693 4 0 2 118 17,242 4 0 2 130 17,242 4 0 2 130 AFR 14,923 2 0 2 112 16,395 2 0 2 123 16,395 2 0 2 123 AFRR90 15,065 3 0 3 113 16,551 3 0 3 124 16,551 3 0 3 124 AFRL90 15,128 3 0 3 114 16,621 3 0 3 125 16,621 3 0 3 125 Lumen Output Lumen values are from photometric tests performed in accordance with IESNA LM-79-08. Data is considered to be representative of the configurations shown, within the tolerances allowed by Lighting Facts. Contact factory for performance data on any configurations not shown here. 179 One Lithonia Way • Conyers, Georgia 30012 • Phone: 1-800-705-SERV (7378) • www.acuitybrands.com © 2018-2021 Acuity Brands Lighting, Inc. All rights reserved. Lithonia RSX1 Area LED Rev. 05/04/21 Page 5 of 9 COMMERCIAL OUTDOOR Dimensions & Weights L W H Length: 22.8” (57.9 cm) Width: 13.3” (33.8 cm) Height: 3.0” (7.6 cm) Main Body 7.2” (18.4 cm) Arm RSX1 with Round Pole Adapter (RPA) Note: RPA — Round Pole mount can also be used to mount on square poles by omitting the round pole adapter plate shown here. L W H Length: 23.2” (59.1 cm) Width: 13.3” (33.8 cm) Height: 3.0” (7.6 cm) Main Body 3.5” (8.9 cm) Arm RSX1 with Mast Arm Adapter (MA) 7/16" locking thru bolt/nut provided L W H Length: 20.7” (52.7 cm) Width: 13.3” (33.8 cm) Height: 3.0” (7.6 cm) Main Body 7.6” (19.3 cm) Arm RSX1 with Adjustable Slipfitter (IS) 7/8" KO - fits 1/2" NPT water- tight fitting Luminaire Weight by Mounting Type Mounting Configuration Total Luminaire Weight SPA 22 lbs RPA 24 lbs MA 22 lbs WBA 25 lbs WBASC 28 lbs IS 25 lbs AASP 25 lbs AARP 27 lbs AAWB 28 lbs AAWSC 31 lbs 180 One Lithonia Way • Conyers, Georgia 30012 • Phone: 1-800-705-SERV (7378) • www.acuitybrands.com © 2018-2021 Acuity Brands Lighting, Inc. All rights reserved. Lithonia RSX1 Area LED Rev. 05/04/21 Page 6 of 9 COMMERCIAL OUTDOOR Dimensions L W H Length: 23.6" (59.9 cm) Width: 13.3” (33.8 cm) Height: 3.0” (7.6 cm) Main Body 8.9” (22.6 cm) Arm RSX1 with Wall Bracket (WBA) Wall Bracket (WBA) Mounting Detail 4.5 7.0 L W H Length: 25.3” (64.3 cm) Width: 13.3” (33.8 cm) Height: 3.0” (7.6 cm) Main Body 9.2” (23.4 cm) Arm RSX1 with Wall Bracket with Surface Conduit Box (WBASC) 3/4" NPT taps with plugs - Qty (4) provided Surface Conduit Box (SCB) Mounting Detail 4.4 7.0 181 One Lithonia Way • Conyers, Georgia 30012 • Phone: 1-800-705-SERV (7378) • www.acuitybrands.com © 2018-2021 Acuity Brands Lighting, Inc. All rights reserved. Lithonia RSX1 Area LED Rev. 05/04/21 Page 7 of 9 COMMERCIAL OUTDOOR Dimensions L W H Length: 25.3” (65.3 cm) AASP 26.3” (66.8 cm) AARP Width: 13.3” (33.8 cm) Height: 3.0” (7.6 cm) Main Body 7.2” (18.2 cm) Arm RSX1 with Adjustable Tilt Arm - Square or Round Pole (AASP or AARP) NOTE: RPA - Round Pole mount can also be used to mount on square poles by omitting the round pole adapter plate shown here. 7/8" KO - fits 1/2" NPT water- tight fitting Notes AASP: Requires 3.0" min. square pole for 1 at 90°. Requires 3.5" min. square pole for mounting 2, 3, 4 at 90°. AARP: Requires 3.2" min. dia. round pole for 2, 3, 4 at 90°. Requires 3.0" min. dia. round pole for mounting 1 at 90°, 2 at 180°, 3 at 120°. L W H Length: 27.1” (68.8 cm) Width: 13.3” (33.8 cm) Height: 3.0” (7.6 cm) Main Body 8.9” (22.6 cm) Arm RSX1 with Adjustable Tilt Arm with Wall Bracket (AAWB) Wall Bracket (WBA) Mounting Detail 4.5 7.0 7/8" KO - fits 1/2" NPT water- tight fitting 182 One Lithonia Way • Conyers, Georgia 30012 • Phone: 1-800-705-SERV (7378) • www.acuitybrands.com © 2018-2021 Acuity Brands Lighting, Inc. All rights reserved. Lithonia RSX1 Area LED Rev. 05/04/21 Page 8 of 9 COMMERCIAL OUTDOOR Dimensions L W H Length: 28.8” (73.2 cm) Width: 13.3” (33.8 cm) Height: 3.0” (7.6 cm) Main Body 9.2” (23.4 cm) Arm RSX1 with Adjustable Tilt Arm with Wall Bracket and Surface Conduit Box (AAWSC) Additional Reference Drawings Surface Conduit Box (SCB) Mounting Detail 4.4 7.0 3/4" NPT taps with plugs - Qty (4) provided 7/8" KO - fits 1/2" NPT water- tight fitting Option CE34 Reference Dimensions Automotive Front Row - Rotated Optics (AFRL90/R90) AFRR90 AFRL90 (Example: 2@180 - arrows indicate direction of light exiting the luminaire) 183 One Lithonia Way • Conyers, Georgia 30012 • Phone: 1-800-705-SERV (7378) • www.acuitybrands.com © 2018-2021 Acuity Brands Lighting, Inc. All rights reserved. Lithonia RSX1 Area LED Rev. 05/04/21 Page 9 of 9 COMMERCIAL OUTDOOR FEATURES & SPECIFICATIONS INTENDED USE The RSX LED area family is designed to provide a long-lasting, energy-efficient solution for the one- for-one replacement of existing metal halide or high pressure sodium lighting. The RSX1 delivers 7,000 to 17,000 lumens and is ideal for replacing 70W to 400W HID pole-mounted luminaires in parking lots and other area lighting applications. CONSTRUCTION The RSX LED area luminaire features a rugged die-cast aluminum main body that uses heat- dissipating fins and flow-through venting to provide optimal thermal management that both enhances LED performance and extends component life. Integral “no drill” mounting arm allows the luminaire to be mounted on existing pole drillings, greatly reducing installation labor. The light engines and housing are sealed against moisture and environmental contaminants to IP66. The low-profile design results in a low EPA, allowing pole optimization. All mountings are rated for minimum 1.5 G vibration load per ANSI C136.31. 3G Mountings: Include SPA, RPA, MA, IS, AASP, and AARP rated for 3G vibration. 1.5G Mountings: Include WBA, WBASC, AAWB and AAWSC rated for 1.5G vibration. FINISH Exterior parts are protected by a zinc-infused Super Durable TGIC thermoset powder coat finish that provides superior resistance to corrosion and weathering. A tightly controlled multi-stage process ensures superior adhesion as well as a minimum finish thickness of 3 mils. The result is a high-quality finish that is warrantied not to crack or peel. OPTICS Precision acrylic refractive lenses are engineered for superior application efficiency, distributing the light to where it is needed most. Available in short and wide pattern distributions including Type 2, Type 3, Type 3S, Type 4, Type 4S, Type 5, Type 5S, AFR (Automotive Front Row), and AFR rotated AFRR90 and ARFL90. ELECTRICAL Light engine(s) configurations consist of high-efficacy LEDs mounted on metal-core circuit boards and aluminum heat sinks to maximize heat dissipation. Light engines are IP66 rated. LED lumen maintenance is >L92/100,000 hours. CCT’s of 3000K, 4000K and 5000K (minimum 70 CRI) are available. Class 1 electronic drivers ensure system power factor >90% and THD <20%. Easily serviceable 10kV surge protection device meets a minimum Category C Low operation (per ANSI/ IEEE C62.41.2). STANDARD CONTROLS The RSX LED area luminaire has a wide assortment of control options. Dusk to dawn controls include MVOLT and 347V button-type photocells and NEMA twist-lock photocell receptacles. nLIGHT AIR CONTROLS The RSX LED area luminaire is also available with nLight® AIR for the ultimate in wireless control. This powerful controls platform provides out-of-the-box basic motion sensing with photocontrol functionality and is suitable for mounting heights up to 40 feet. No commissioning is required when using factory default settings that provide basic stand-alone motion occupancy dimming that is switched on and off with a built-in photocell. See chart above for motion sensor default out-of-box settings. For more advanced wireless functionality, such as group dimming, nLight AIR can be commissioned using a smartphone and the easy-to- use CLAIRITY app. nLight AIR equipped luminaries can be grouped, resulting in motion sensor and photocell group response without the need for additional equipment. Scheduled dimming with motion sensor over-ride can be achieved when used with the nLight Eclypse. Additional information about nLight Air can be found here. INSTALLATION Integral “no-drill” mounting arm allows for fast, easy mounting using existing pole drillings. Select the “SPA” option for square poles and the “RPA” option to mount to round poles. Note, the RPA mount can also be used for mounting to square poles by omitting the RPA adapter plate. Select the “MA” option to attach the luminaire to a 2 3/8” horizontal mast arm or the “IS” option for an adjustable slipfitter that mounts on a 2 3/8” OD tenon. The adjustable slipfitter has an integral junction box and offers easy installation. Can be tilted up to 90° above horizontal. Additional mountings are available including a wall bracket, adjustable tilt arm for direct-to-pole and wall and a surface conduit box for wall mount applications. LISTINGS CSA Certified to meet U.S. and Canadian standards. Suitable for wet locations. Rated for -40°C minimum ambient. DesignLights Consortium® (DLC) Premium qualified product and DLC qualified product. Not all versions of this product may be DLC Premium qualified or DLC qualified. Please check the DLC Qualified Products List at www.designlights.org/QPL to confirm which versions are qualified. International Dark-Sky Association (IDA) Fixture Seal of Approval (FSA) is available for all products on this page utilizing 3000K color temperature only. BUY AMERICAN Product with the BAA option is assembled in the USA and meets the Buy America(n) government procurement requirements under FAR, DFARS and DOT. Please refer to www.acuitybrands.com/buy-american for additional information. WARRANTY 5-year limited warranty. Complete warranty terms located at: www.acuitybrands.com/support/customer-support/terms-and-conditions Note: Actual performance may differ as a result of end-user environment and application. All values are design or typical values, measured under laboratory conditions at 25 °C. Specifications subject to change without notice. nLight Control - Sensor Coverage and Settings Motion Sensor Default Settings - Option PIRHN Option Dimmed State (unoccupied) High Level (when occupied) Photocell Operation Dwell Time (occupancy time delay) Ramp-up Time (from unoccupied to occupied) Ramp-down Time (from occupied to unoccupied) NLTAIR2 PIRHN Approx. 30% Output 100% Output Enabled @ 1.5FC 7.5 minutes 3 seconds 5 minutes nLight Sensor Coverage Pattern NLTAIR2 PIRHN Top Side *Note: NLTAIR2 PIRHN default settings including photocell set-point, high/low dim rates, and occupancy sensor time delay are all configurable using the Clairity Pro App. Sensor coverage pattern shown with luminaire at 0°. Sensor coverage pattern is affected when luminaire is titled. 184 ATTACHMENT 4 185 186 187 188 Mitigated Negative Declaration (incorporated by reference) http://www.moorparkca.gov/DocumentCenter/View/14180/Pentair-Final-MND- Large-File?bidId= ATTACHMENT 5 189 ATTACHMENT 6 RESOLUTION NO. 2022-____ A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF MOORPARK, CALIFORNIA, APPROVING INDUSTRIAL PLANNED DEVELOPMENT NO. 2022-01 AND CONDITIONAL USE PERMIT NO. 2022-01 FOR THE DEVELOPMENT OF A 90,566 SQUARE-FOOT INDUSTRIAL WAREHOUSE BUILDING AND ASSOCIATED SITE WORK ON 5.65 ACRES OF PROPERTY, LOCATED AT 10941 LOS ANGELES AVENUE, AND ADOPTION OF A MITIGATED NEGATIVE DECLARATION AND A MITIGATION MONITORING AND REPORTING PROGRAM PURSUANT TO THE CALIFORNIA ENVIRONMENTAL QUALITY ACT IN CONNECTION THEREWITH, ON THE APPLICATION OF AMIR DEVELOPMENT ON BEHALF OF MOORPARK LOT A, LP WHEREAS, on January 22, 2022, Keenan Wolens of Amir Development (Applicant) for Moorpark Lot A, LP (Owner) submitted an application for an Industrial Planned Development (IPD) to develop an industrial warehouse and office building, totaling 90,566 square feet and a Conditional Use Permit (CUP) to allow the maximum building height of 44 feet which exceeds the maximum height of 30 feet, thereby requiring a CUP (Proposed Project). The Project Site includes 5.65 acres, located on an undeveloped and relatively flat lot, located at 10941 Los Angeles Avenue (Assessor Parcel No. 511-0-200-265) (Project Site, Site); and WHEREAS, pursuant to Section 15074 of the State Guidelines for the California Environmental Quality Act (“CEQA”), (the “State CEQA Guidelines”), an Initial Study and Draft Mitigated Negative Declaration (“MND”), dated September 2022 have been prepared by Chambers Group, Inc., and based on the type and intensity of Project and information contained therein, the Initial Study and Draft Mitigated Negative Declaration conclude that the Project, with the proposed mitigation measures, would not have a significant adverse effect on the environment; and WHEREAS, the MND identified that the Project will have no or less than significant effects on agriculture and forestry, mineral resources, population and housing, public services, recreation, aesthetics, air quality, energy, geology and soils, greenhouse gas emissions, hazards and hazardous materials, hydrology and water quality noise, tribal cultural resources, utilities and service systems and wildfire. In addition, the MND identified that the Project’s impacts on biological resources, cultural resources, land use and planning and transportation are potentially significant but that all such impacts can be reduced to levels of insignificance by implementation of the mitigation measures identified in the MND; and WHEREAS, on July 18, 2022, the City of Moorpark Community Development Department, as lead agency for the Project, published pursuant to the California Environmental Quality Act (CEQA) a Notice of Intent to Adopt an MND for the Pentair Warehouse Expansion Project (State Clearinghouse Number 2022070289) analyzing the Project’s potential impacts on the environment and provided copies of it for a 30-day comment period between July 18, 2022, and August 17, 2022. The MND was posted on 190 Resolution No. 2022-____ Page 2 the City website, at City Hall and City Library and at the Ventura County Clerk’s Office; and WHEREAS, the City received seven comments on the Draft MND during the public review period and thereafter the City prepared written responses to all comments received on the Draft MND, as set forth in Attachment 5 to the staff report for this item, and those responses to comments are incorporated into the MND. A link to the copy of the MND is set forth in Attachment 5 to the staff report for this item and is incorporated herein by this reference (www.moorparkca.gov/1070/Pentair-Expansion); and WHEREAS, in connection with the approval of a project involving the preparation of an MND that identifies one or more potentially significant environmental effects, CEQA requires the decision-making body of the lead agency to incorporate feasible mitigation measures that would reduce those potentially significant effects to a less-than-significant level; and WHEREAS, pursuant to State CEQA Guidelines Section 15074, whenever a lead agency approves a project requiring the implementation of measures to mitigate or avoid potentially significant effects on the environment, CEQA also requires a lead agency to adopt a mitigation monitoring and reporting program to ensure compliance with the mitigation measures during project implementation. A copy of the Mitigation Monitoring and Reporting Program (“MMRP”) for the Project, which defines the measures which would be imposed on the Project to mitigation or avoid potentially significant environmental impacts, is attached hereto as Exhibit B, and incorporated herein by this reference; and WHEREAS, at a duly noticed public hearing on September 27, 2022, the Planning Commission considered the Final MND and proposed Project, including the agenda report and any supplements thereto and written public comments; opened the public hearing and took and considered public testimony both for and against the Project applications; and reached a decision on this matter, adopting Resolution No. PC-2022- 680 recommending that the City Council adopt the Final MND and approve the Project, with Conditions as amended; and WHEREAS, at a duly noticed public hearing on November 2, 2022, the City Council considered the Final MND and proposed Project, including public testimony both for and against the proposal; opened the public hearing and took and considered public testimony both for and against the proposal and reached a decision on this matter. NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF MOORPARK DOES HEREBY RESOLVE AS FOLLOWS: SECTION 1. The findings made in this Resolution are based upon the information and evidence set forth in the Final MND (attached by reference in the staff report as Attachment 5) and upon other substantial evidence that has been presented at the hearings and in the record of the proceedings. The Final MND, agenda reports, technical studies, appendices, plans, specifications, and other documents and materials that 191 Resolution No. 2022-____ Page 3 constitute the record of proceedings on which this Resolution is based are on file for public examination during normal business hours at the City of Moorpark Community Development Department, 799 Moorpark Avenue, Moorpark, CA 93021. Each of these documents is incorporated herein by reference. SECTION 2. The City Council finds that agencies and interested members of the public have been afforded ample notice and opportunity to comment on the Final MND and Project. SECTION 3. Prior to taking action, the City Council has heard, been presented with, reviewed and considered the information and data in the record, including oral and written testimony presented for and during public hearings. The City’s independent environmental consultants, City staff, and the Project Applicant’s environmental consultants reviewed and analyzed the comments received on the Project’s environmental review. SECTION 4. The City Council, pursuant to CEQA Guidelines Section 15074, finds in connection with the adoption of the Final MND: 1) that the MND reflects the City Council’s independent judgment and analysis; 2) the IS/MND was presented to, and reviewed and considered by, the City Council together with all comments received during the public review process; 3) the MND has been completed in compliance with CEQA and the State CEQA Guidelines; 4) the MND contains a complete and accurate reporting of the environmental impacts associated with the Project; 5) the Project will not result in a significant effect on the environment because the mitigation measures described in the MMRP have been added to the Project as conditions of approval; and 6) based on its review of the whole record before it, there is no substantial evidence in the record supporting a fair argument that the Project will have a significant effect on the environment. SECTION 5. No comments or any additional information submitted to the City have produced any substantial new information requiring additional environmental review or re-circulation of the MND pursuant to CEQA because no new significant environmental impacts were identified, nor was any substantial increase in the severity of any previously disclosed environmental impacts identified. SECTION 6. Pursuant to Public Resources Code Section 21081.6, the City Council adopts the MND, attached as Attachment 5 to the Staff Report for this item, and the Mitigation Monitoring and Reporting Program, attached hereto as Exhibit B to this Resolution, and incorporated herein by reference, and adopts each mitigation measure set forth therein, and imposes each mitigation measure as a Condition of the Project’s Approval. SECTION 7. INDUSTRIAL PLANNED DEVELOPMENT FINDINGS: Based upon the information set forth in the staff report(s), accompanying studies, and oral and written public testimony, the City Council makes the following findings in accordance with City of Moorpark, Municipal Code Section 17.44.040: 192 Resolution No. 2022-____ Page 4 1. The site design, including structure location, size, height, setbacks, parking, massing, scale, architectural style and colors, and landscaping, is consistent with the provisions of the general plan, zoning ordinance, and any other applicable regulations. The General Plan land use designation for the Project Site is Medium Industrial (I-2). The I-2 designation allows for a variety of uses including light manufacturing, processing, fabrication, and other non-hazardous industrial uses. The proposed warehouse use is consistent with the I-2 designation. The proposed deviations from developments standards, allowed pursuant to Moorpark Municipal Code (MMC) 17.44.040.C, have been found compatible with nearby industrial developments. 2. The site design would not create negative impacts on or impair the utility of properties, structures, or uses in the surrounding area. As proposed and conditioned, the Project Site provides required parking, access improvements, site lighting, utility upgrades, storm water detention, and landscape improvements necessary to serve the proposed use and prevent impacts to adjacent properties. The proposed height of 44 feet, as addressed by the Conditional Use Permit, would be compatible with the existing height of the neighboring industrial building to the west and other similar industrial buildings throughout Moorpark. The proposed Conditions of Approval would ensure the proposed office use would not negatively impact the surrounding area. 3. The proposed industrial warehouse use and site improvements are compatible with the existing and permitted uses in the surrounding area. The Project is compatible to similar nearby uses including adjacent existing and entitled industrial development to the west, agricultural uses to the north and south, and undeveloped industrial zoned land to the east. The proposed Project includes architectural elements, colors and materials similar to the nearby industrial uses and well-developed landscape plan which will help screen the warehouse development from the nearby travel routes. In addition, as required by the MMRP, a new traffic signal will be installed at Montair Drive and Los Angeles Avenue to mitigate for traffic impacts generated by the traffic at the intersection. SECTION 8. CONDITIONAL USE PERMIT FINDINGS: Based upon the information set forth in the staff report(s), accompanying studies, and oral and written public testimony, the Planning Commission makes the following findings in accordance with City of Moorpark, Municipal Code Section 17.44.040: 1. The proposed use is consistent with the provisions of the General Plan, zoning ordinance, and all applicable regulations in that the industrial warehouse is a permitted use when associated with a manufacturing and assembly use within the M-1 zoning district. The CUP is required to authorize an increase to the height of a structure pursuant to MMC Section 17.24.035, table 17.24.031, whereby a height of 30 feet is allowed and a maximum height of up to 60 feet may be permitted with a CUP. The proposed warehouse is 44 feet and is similar in height to the neighboring industrial building and other industrial and commercial buildings throughout Moorpark. 193 Resolution No. 2022-____ Page 5 2. The proposed height of 44 feet, which requires a CUP, is compatible with both existing and permitted structures in the surrounding area in that the warehouse is located near an existing industrial manufacturing and assembly use building to the west, which is approximately 45 feet tall. The proposed height is also compatible with several other industrial and commercial buildings throughout Moorpark. 3. The proposed building height of 44 feet is compatible with the scale, visual character, and design of surrounding properties, in that the proposed building height is appropriate for the architecture of the building and consistent with the adjacent industrial buildings. 4. The proposed use, as conditioned and with the mitigation measures included in the MMMRP, would not be obnoxious or harmful, or impair the utility of neighboring property or uses. The project is located near vacant and agricultural uses to the north, west and south and the adjacent Pentair industrial use to the west. The inclusion of specific transportation demand management strategies would be used to reduce the vehicle miles traveled and promote a lesser number of employees using personal transportation. The Project also includes the installation of a new traffic signal at the intersection of Montair Drive and State Route 118 to reduce traffic impacts to the associated intersection consistent with General Plan Circulation Element Policy 2.1. 5. The proposed building height of 44 feet would not be detrimental to the public health, safety, convenience, or welfare in that the project would be located along a well-traveled state route, near existing industrial and agricultural uses, and would be required to comply with all applicable codes and regulations. SECTION 9. CITY COUNCIL - Based on all the findings contained in this Resolution and based on all the evidence in the public hearing for this matter, the City Council does hereby resolve as follows: A. The City Council adopts the Mitigated Negative Declaration (attached by reference to staff report as Attachment 5 and the MMRP contained in Exhibit B); B. Approves Industrial Planned Development No. 2022-01, subject to conditions of approval contained in Exhibit A; and C. Approves Conditional Use Permit No. 2022-01, subject to the Conditions of Approval contained in Exhibit A. 194 Resolution No. 2022-____ Page 6 SECTION 10. CERTIFICATION OF ADOPTION: The City Clerk shall certify to the adoption of this resolution and shall cause a certified resolution to be filed in the book of original resolutions. PASSED AND ADOPTED this 2nd day of November, 2022. __________________________________ Janice S. Parvin, Mayor ATTEST: ___________________________________ Ky Spangler, City Clerk Attachments: Exhibit A: Conditions of Approval Exhibit B: Mitigation Monitoring and Reporting Program 195 Resolution No. 2022-____ Page 7 EXHIBIT A CITY OF MOORPARK CONDITIONS OF APPROVAL Project Approval Date: ________, 2022 Expiration Date: ____________, 2023 Location: 10941 Los Angeles Avenue (Assessor Parcel No. 511-0-200-265) Entitlements: Industrial Planned Development Permit No. 2022-01 and Conditional Use Permit No. 2022-02 Project Description: Development of a warehouse building totaling 90,566 square feet and 44 feet in maximum height. The applicant/permittee is responsible for the fulfillment of all conditions and standard development requirements, unless specifically stated otherwise. General Conditions In addition to complying with all applicable City, County, State and Federal Statutes, Codes, Ordinances, Resolutions and Regulations, Development Agreements, Permittee expressly accepts and agrees to comply with the following Conditions of Approval and Standard Development Requirements of this Permit: 1) Within thirty (30) calendar days of approval of this entitlement, the applicant shall sign and return to the Planning Division an Affidavit of Agreement and Notice of Entitlement Permit Conditions of Approval, indicating that the applicant has read and agrees to meet all Conditions of Approval of this entitlement. The Affidavit of Agreement/Notice shall include a legal description of the subject property and have the appropriate notary acknowledgement suitable for recordation. [CDD] 2) This Industrial Planned Development and Conditional Use Permit expires one (1) year from the date of its approval unless the use has been inaugurated by issuance of a building permit for construction. The Community Development Director may, at his/her discretion, grant up to two (2) additional one-year extensions for use inauguration of the development permit if there have been no changes in the adjacent areas and if the applicant can document that he/she has diligently worked towards use inauguration during the initial period of time. The request for extension of this planned development permit must be made in writing, at least thirty (30) days prior to the expiration date of the permit and must be accompanied by applicable entitlement processing deposits. [CDD] 196 Resolution No. 2022-____ Page 8 3) The Conditions of Approval of this entitlement, the City of Moorpark Municipal Code and adopted City policies at the time of the entitlement approval, supersede all conflicting notations, specifications, dimensions, typical sections and the like which may be shown on said plans or on the entitlement application. This language shall be added as a notation to the final plans for the planned development. [CDD] 4) Should continued compliance with these Conditions of Approval not be met, the Community Development Director may modify the conditions in accordance with Municipal Code Section 17.44.100 and sections amendatory or supplementary thereto, declare the project to be out of compliance, or the Director may declare, for some other just cause, the project to be a public nuisance. The applicant shall be liable to the City for any and all costs and expenses to the City involved in thereafter abating the nuisance and in obtaining compliance with the Conditions of Approval or applicable codes. If the applicant fails to pay all City costs related to this action, the City may enact special assessment proceedings against the parcel of land upon which the nuisance existed (Municipal Code Section 1.12.170). [CDD] 5) The applicant shall defend, indemnify and hold harmless the City and its agents, officers and employees from any claim, action or proceeding against the City or its agents, officers or employees to attack, set aside, void, or annul any approval by the City or any of its agencies, departments, commissions, agents, officers, or employees concerning this entitlement approval, which claim, action or proceeding is brought within the time period provided therefore in Government Code Section 66499.37 or other sections of state law as applicable and any provision amendatory or supplementary thereto. The City will promptly notify the applicant of any such claim, action or proceeding, and, if the City should fail to do so or should fail to cooperate fully in the defense, the applicant shall not thereafter be responsible to defend, indemnify and hold harmless the City or its agents, officers and employees pursuant to this condition. a. The City may, within its unlimited discretion, participate in the defense of any such claim, action or proceeding if both of the following occur: i. The City bears its own attorney fees and costs; ii. The City defends the claim, action or proceeding in good faith. b. The applicant shall not be required to pay or perform any settlement of such claim, action or proceeding unless the settlement is approved by the applicant. The applicant's obligations under this condition shall apply regardless of whether a Final Map is ultimately recorded with respect to the subdivision or a building permit is issued pursuant to the planned development permit. [CDD] 6) If any of the conditions or limitations of this approval are held to be invalid, that holding does not invalidate any of the remaining conditions or limitations set forth. [CDD] 197 Resolution No. 2022-____ Page 9 7) All facilities and uses, other than those specifically requested in the application and approval and those accessory uses allowed by the Municipal Code, are prohibited unless otherwise permitted through application for Modification consistent with the requirements of the zone and any other adopted ordinances, specific plans, landscape guidelines, or design guidelines. [CDD] 8) Entitlement Processing: Prior to the approval of any Zoning Clearance for this entitlement, the applicant shall submit to the Community Development Department all outstanding entitlement case processing fees, including all applicable City legal service fees. This payment must be made within sixty (60) calendar days after the approval of this entitlement. [CDD] 9) Condition Compliance: Prior to the issuance of any Zoning Clearance, building permit, grading permit, or advanced grading permit, the applicant shall submit to the Community Development Department the Condition Compliance review deposit. [CDD] 10) Any expansion, alteration or change in architectural elements requires prior approval of the Community Development Director. Those changes in architectural elements that the Director determines would be visible from abutting street(s) may only be allowed, if, in the judgment of the Community Development Director such change is compatible with the surrounding area. Any approval granted by the Director must be consistent with the approved Design Guidelines (if any) for the planned development and applicable Zoning Code requirements. A Permit Modification application may be required as determined by the Community Development Director. [CDD] 11) The applicant agrees not to protest the formation of an underground Utility Assessment District. [CDD & PW] 12) The continued maintenance of the subject site and facilities is subject to periodic inspection by the City. The Applicant and his/her successors, heirs, and assigns are required to remedy any defects in ground or building maintenance, as indicated by the City within five (5) working days from written notification. [CDD] 13) The applicant and his/her successors, heirs, and assigns must remove any graffiti within five (five) days from written notification by the City of Moorpark. All such graffiti removal must be accomplished to the satisfaction of the Community Development Director. [CDD] 14) If any hazardous waste or material is encountered during the construction of this project, all work must be immediately stopped and the Ventura County Environmental Health Department, the Ventura County Fire Protection District, the Moorpark Police Department, and the Moorpark City Engineer and Public Works 198 Resolution No. 2022-____ Page 10 Director must be notified immediately. Work may not proceed until clearance has been issued by all of these agencies. [CDD, VCFPD, MPD, VCEHD & PW] 15) Prior to the issuance of a Grading Permit, the Permittee is encouraged to install fiber‐optic conduit from the proposed building to the right‐of‐way during grading to maximize the utility and futureproofing of the building. [ED] 16) The Project shall use electric or propane/compressed natural gas forklifts during construction and operations of the facility. Use of gasoline or diesel fueled forklifts on the Project Site is prohibited. [CDD] Development Fees 17) Capital Improvements and Facilities, and Processing Fees: Prior to the issuance of any Zoning Clearance, the applicant shall submit to the Community Development Department, capital improvement, development, and processing fees at the current rate then in effect. Said fees include, but are not limited to, building and public improvement plan checks and permits. Unless specifically exempted by City Council, the applicant is subject to all fees imposed by the City as of the issuance of the first permit for construction. Fees typically adjust annually. 18) Intentionally omitted. 19) Prior to installation of any signage on the site, the applicant shall submit a Master Sign Program or a Sign Permit to the Community Development Director for review and approval. [CDD] 20) The use of highly reflective glass or highly reflective film applied to glass is not allowed on any structures. Highly reflective glass is defined as glass having a visible light reflectance (VLR) rating of twenty (20) percent or greater. The use of darkly tinted glass is only allowed in industrial zones. Darkly-tinted glass is defined as glass with a visible light transmittance (VLT) rating of fifty (50) percent or less. The use of low-emissivity (Low-E) glass is encouraged, but it must meet reflectance and transmittance requirements as noted above. The applicant shall provide a sample of the glass to be used, along with information on the VLR and VLT for review and approval by the Community Development Director prior to the issuance of building permits. [CDD] 21) Site shall provide a minimum of 185 parking spaces, as required by Moorpark Municipal Code Chapter 17.32. Parking areas must be developed and maintained in accordance with the requirements of the Moorpark Municipal Code. All parking space and loading bay striping must be maintained so that it remains clearly visible during the life of the development. [CDD] 199 Resolution No. 2022-____ Page 11 22) All parking areas must be surfaced with asphalt, concrete, or other surface acceptable to the Community Development Director, City Engineer and Public Works Director, and must include adequate provisions for drainage, National Pollution Discharge Elimination System (NPDES) compliance, striping and appropriate wheel blocks, curbs, or posts in parking areas adjacent to landscaped areas. All parking, loading and common areas must be maintained at all times to ensure safe access and use by employees, public agencies and service vehicles. [CDD & PW] 23) Potential Waters of the U.S./State. Prior to issuance of a Grading Permit or commencement of other site work within 25 feet of / or in the Gabbert Channel, the developer shall determine if the California Department of Fish and Wildlife (CDFW), Regional Water Quality Control Board (RWQCB), or U.S. Army Corps of Engineers (USACE) have determined that the Gabbert Channel is considered waters of the state/U.S., the Applicant or its contractor shall obtain, and shall comply with all mitigation and conditions associated with, one or more of the following permits, as applicable: a CDFW Lake and Streambed Alteration Agreement; RWQCB Section 401 Water Quality Certification; or Section 404 USACE permit. Permit compliance shall be met through the purchase of in-lieu credits for non-vegetated streams at an approved mitigation bank, implementation of in-kind or out-of-kind restoration, or a combination of these actions. The mitigation replacement ratio shall be determined by the regulatory agencies during the permitting process. Evidence of compliance with agency requirements shall be provided to CSLC staff prior to Proposed Project activities. Evidence of such determination shall be submitted to the City of Moorpark Community Development and Public Works Departments. [CDD & PW] 24) The Building Plans must be in substantial conformance to the plans approved under this entitlement and must specifically include the following: a) Transformers, backflow prevention devices, fire department apparatus, and cross connection water control devices (subject to approval by Ventura County Waterworks District No. 1), screened from street view with a masonry wall and/or landscaping as determined by the Community Development Director. b) Bicycle racks or storage facilities, in quantities as required by the Community Development Director and in accordance with the Municipal Code. c) Required loading areas with 45-foot turning radii for loading zones consistent with the AASHO WB-50 design vehicle and as required by the Community Development Director, City Engineer and Public Works Director. If drains from the loading area are connected to the sewer system, they are subject to the approval of Ventura County Waterworks District No. 1. 200 Resolution No. 2022-____ Page 12 d) Final exterior building materials and paint colors consistent with the approved plans under this permit. Any changes to the building materials and paint colors are subject to the review and approval of the Community Development Director. e) Identification of coating or rust-inhibitive paint for all exterior metal building surfaces to prevent corrosion and release of metal contaminants into the storm drain system. [CDD] Permit Specific Conditions – Conditional Use Permit 25) The maximum height of the warehouse building associated with this entitlement shall not exceed 44-feet in height. [CDD] 26) Exterior downspouts are not permitted unless designed as an integral part of the overall architecture and approved by the City as part of the planned development permit. [CDD] 27) Mechanical equipment for the operation of the building must be ground-mounted and screened to the satisfaction of the Community Development Director. The Community Development Director may approve roof-mounted equipment, in which case, all parts of the roof mounted equipment (such as vents, stacks, blowers, air conditioning equipment, etc.) must be below the lowest parapet on the roof; and must be painted the same color as the roofing material. No piping, roof ladders, vents, exterior drains and scuppers or any other exposed equipment may be visible from adjacent public rights-of-way. [CDD] 28) Any outdoor ground level equipment, facilities or storage areas including, but not limited to loading docks, trash enclosures, cooling towers, generators, must be architecturally screened from view with masonry wall and/or landscaping as determined by the Community Development Director. [CDD] Ground Disturbance 29) Due to the potential that archaeological resources may be present on the Project Site, the City of Moorpark shall require a note on any plans that require ground- disturbing excavation that there is a potential for exposing buried cultural resources, including prehistoric Native American artifacts. Construction personnel associated with earth-moving equipment, drilling, grading, and excavating, shall be provided with basic training conducted by a qualified archaeologist, to be retained and compensated by the development team, with the approval of the City of Moorpark. Issues that shall be included in the basic training will be geared toward training the applicable construction crews in the identification of archaeological deposits, further described below. Training will include written notification of the restrictions regarding disturbance and/or removal of any portion of archaeological deposits and the procedures to follow should a resource be identified. The construction contractor, or its designee, shall be responsible for implementation of this measure. A Native American monitor shall be provided an 201 Resolution No. 2022-____ Page 13 opportunity to attend the pre-construction briefing, upon request. A Native American monitor from a consulting Tribe under AB 52 monitor (Fernandeño Tataviam Band of Mission Indians) and a qualified archaeologist, to be compensated by the development team, shall be available on an “on-call” basis during ground-disturbing construction in native soil to review, identify, and evaluate cultural resources that may be inadvertently exposed during construction. If archaeological remains or tribal cultural resources are uncovered, all construction activities within a 100-foot radius shall be halted immediately until a qualified archaeologist, in consultation with the Native American monitor, shall evaluate whether the resource requires further study. The City shall require that the applicant include a standard inadvertent discovery clause in every construction contract to inform contractors of this requirement. If any previously undiscovered resources are found during construction, the City of Moorpark Community Development Department shall be contacted; and the resource shall be evaluated for significance in terms of CEQA criteria by a qualified archaeologist. Prehistoric archaeological site indicators include but are not limited to: obsidian and chert flakes and chipped stone tools; grinding and mashing implements (e.g., slabs and handstones, and mortars and pestles); bedrock outcrops and boulders with mortar cups; and locally darkened midden soils. Midden soils may contain a combination of any of the previously listed items, with the possible addition of bone and shell remains, and fire-affected stones. Historic-period site indicators generally include but are not limited to: fragments of glass, ceramic, and metal objects; milled and split lumber; and structure and feature remains such as building foundations and discrete trash deposits (e.g., wells, privy pits, dumps). If the City and the qualified archaeologist determine the resource to be significant under CEQA, they shall determine whether preservation in place is feasible. Such preservation in place is the preferred mitigation. Contingency funding and a time allotment sufficient for recovering an archaeological sample or to employ an avoidance measure may be required. If such preservation is infeasible, the qualified archaeologist shall prepare and implement a formal Archaeological Monitoring Plan (AMP) which will include a research design and archaeological data recovery plan for the resource. Development and implementation of the AMP will be determined by the City of Moorpark, and treatment of any significant cultural resources shall be undertaken with the approval of the Project Applicant and the City. The archaeologist shall also conduct appropriate technical analyses, prepare a comprehensive written report and file it with the appropriate information center (California Historical Resources Information System [CHRIS]), and provide for the permanent curation of the recovered materials. The City of Moorpark and/or development team shall, in good faith, consult with the Fernandeño Tataviam Band of Mission Indians and consulting Tribes on the disposition and treatment of any recovered materials. A Monitoring Closure Report shall be filed with the City of Moorpark at the conclusion of ground-disturbing construction if archaeological resources were encountered and/or recovered. After the find has been appropriately mitigated (as defined by State CEQA Guidelines Section 15126.4(b)), work in the area may resume. 202 Resolution No. 2022-____ Page 14 30) If human remains or funerary objects are unearthed during any activities associated with the Project, State Health and Safety Code Section 7050.5 requires that no further disturbance shall occur within a 100-foot buffer of the find until the County Coroner has made the necessary findings as to origin and disposition pursuant to Public Resources Code Section 5097.98. If the remains are determined to be of Native American descent, the Coroner has 24 hours to notify the Native American Heritage Commission (NAHC), the Fernandeño Tataviam Band of Mission Indians, and consulting Tribes. The NAHC will then contact the deceased Native American’s most likely descendant, who will then serve as consultant on how to proceed with the remains (i.e., avoid, rebury). 31) Inadvertent Discovery of Human Remains. The inadvertent discovery of human remains is always a possibility during ground disturbances; State of California Health and Safety Code Section 7050.5 addresses these findings. This code section states that in the event human remains are uncovered, no further disturbance shall occur until the County Coroner has determined the origin and disposition of the remains pursuant to California Public Resources Code Section 5097.98. The Coroner must be notified of the find immediately, together with the City and the property owner. If the human remains are determined to be prehistoric, the Coroner will notify the Native American Heritage Commission (NAHC), which will determine and notify a Most Likely Descendant (MLD). The MLD shall complete the inspection of the site within 48 hours of notification and may recommend scientific removal and nondestructive analysis of human remains and items associated with Native American burials and an appropriate reinternment site. [CDD] 32) Paleontological Plan: If paleontological remains are discovered, a paleontological mitigation plan outlining procedures for paleontological data recovery must be prepared and submitted to the Community Development Director for review and approval. The development and implementation of this Plan must include consultations with the Applicant's engineering geologist as well as a requirement that the curation of all specimens recovered under any scenario will be through the Los Angeles County Museum of Natural History (LACMNH). All specimens become the property of the City of Moorpark unless the City chooses otherwise. If the City accepts ownership, the curation location may be revised. The monitoring and data recovery shall include periodic inspections of excavations to recover exposed fossil materials. The cost of this data recovery is limited to the discovery of a reasonable sample of available material. The interpretation of reasonableness rests with the Community Development Director. [CDD] Operational Requirements 33) Restrictive hours for loading and unloading may be imposed by the Community Development Director if there are noise and other issues that make the loading and unloading incompatible with the adjacent residential uses. There shall be no idling of trucks while loading or unloading. [CDD] 203 Resolution No. 2022-____ Page 15 34) All uses and activities must be conducted inside the building(s) unless otherwise authorized in writing by the Community Development Director consistent with applicable Zoning Code provisions. [CDD] 35) Prior to the issuance of a Zoning Clearance for any use which requires handling of hazardous or potentially hazardous materials, the applicant shall provide proof that he/she has obtained the necessary permits from Ventura County Environmental Health Division. Should the Community Development Director determine that a compatibility study is required; the applicant shall apply for a Permit Modification to the entitlement. [CDD & VCEHD] 36) Prior to the issuance of a Zoning Clearance for tenant occupancy, the prospective tenant shall obtain a Business Registration Permit from the City of Moorpark. Future tenants or uses may require additional discretionary permits, as identified in the Moorpark Municipal Code. All contractors doing work in Moorpark shall have or obtain a current Business Registration Permit. [CDD] 37) Prior to or concurrently with the issuance of a Zoning Clearance for occupancy of any of the buildings, the applicant shall request that the City Council approve a resolution to enforce California Vehicle Codes (CVC) on the subject property as permitted by the CVC. [CDD] 38) Prior to or concurrently with the issuance of a Zoning Clearance for a grading permit, the applicant shall submit the construction phasing plan for approval by the Community Development Director and City Engineer and Public Works Director. Phasing shall avoid, to the extent possible, construction traffic impacts to existing adjacent residential, commercial, industrial areas, schools, parks and other city facilities, if any. [CDD & PW] 39) No overnight parking, repair operations or maintenance of trucks may occur on site. The property owner may enter into an agreement with the City to allow the City to enter the property when the property owner has properly posted signs restricting the overnight parking, repair or maintenance of truck, to enforce the onsite restrictions and assume the costs of towing the violating vehicles. [CDD] 40) Prior to issuance of Zoning Clearance for occupancy, the applicant shall provide proof of taking an on-site waste management education program to the satisfaction of the City's Solid Waste Management staff. [CDD & EMSW] 204 Resolution No. 2022-____ Page 16 California Environmental Quality Act (CEQA) – Mitigated Negative Declaration 41) All mitigation measures required as part of an approved Mitigation Monitoring Report and Program (MMRP) for this entitlement are hereby adopted and included as requirements of this entitlement. Where conflict or duplication between the MMRP and the Conditions of Approval occurs the Community Development Director shall determine compliance so long as it does not conflict with the California Environmental Quality Act and the more restrictive measure or condition shall apply. [CDD] 42) Biological Resources MITIGATION MONITORING AND REPORTING PROGRAM Mitigation Measure Implementation Phase Monitoring Phase Enforcement Agency MM BIO-1: A nesting bird pre-construction survey will be conducted by a Qualified Biologist and submitted to the City three days prior to demolition and/or vegetation removal activities during nesting bird season (February 1 through September 15). Should nesting birds be found, an exclusionary buffer will be established by a Qualified Biologist. The buffer may be up to 500 feet in diameter depending on the species of nesting bird found. This buffer will be clearly marked in the field by construction personnel under guidance of the Qualified Biologist, and construction or clearing will not be conducted within this zone until the Qualified Biologist determines that the young have fledged or the nest is no longer active. Nesting bird habitat within the Project site will be resurveyed during bird breeding season if a lapse in construction activities lasts longer than seven days. Prior to construction Prior to and during construction City of Moorpark MM BIO-2: To avoid direct mortality, a qualified biological monitor should be on site prior to and during ground and habitat disturbing activities to move out of harm’s way special status species or other wildlife of low mobility that would be injured or killed by grubbing or Project-related construction activities. Salvaged wildlife of low mobility should be removed and placed onto adjacent and suitable (i.e., species appropriate) habitat out of harm’s way. It should be noted that the temporary relocation of on-site wildlife does not constitute effective mitigation for the purposes of offsetting program impacts associated with habitat loss. Prior to and during construction Prior to and during construction City of Moorpark 205 Resolution No. 2022-____ Page 17 MM BIO-3: Grubbing shall be done to avoid islands of habitat where wildlife may take refuge and later be killed by heavy equipment. Grubbing shall be done from the center of the Project site, working outward towards adjacent habitat off site where wildlife may safety escape. If grading is scheduled to occur in phases, another round of grubbing would be required prior to the start of ground disturbance to allow wildlife that may be present in the center of the Project site to safely escape. During construction During construction City of Moorpark 43) Cultural Resources MITIGATION MONITORING AND REPORTING PROGRAM Mitigation Measure Implementation Phase Monitoring Phase Enforcement Agency MM CUL-1: Prior to issuance of grading permits, the Applicant shall be required to obtain the services of a qualified project archaeologist to remain on call for the duration of the proposed ground-disturbing construction activity. The archaeologist selected must be approved in writing by the Community Development Director. Prior to construction commencing, all construction personnel associated with earth-moving equipment, drilling, grading, or excavating shall be provided with basic training. The training shall be completed by the Applicant-retained project archaeologist and shall include written notification of the restrictions regarding disturbance and/or removal of any portion of archaeological deposits and the procedures to follow should a potential resource be identified during construction activity. The construction contractor, or its designee, shall be responsible for implementation of this measure. A tribal monitor shall be provided an opportunity to attend the pre-construction briefing, if requested. The project archaeologist shall be on call and available to contact in the event of any unanticipated discovery of archaeological or historical resources during the proposed construction activity. If any archeological or historical resources are uncovered during grading or excavation operations, all grading or excavation shall immediately cease in the immediate area, a 50-foot buffer area around the discovery shall be cordoned off, and the discovery must be left untouched. The Applicant, in consultation with the project archaeologist, shall assure the preservation of the resource and immediately contact the Community Development Director by phone, in writing by email, or hand-delivered correspondence informing the Director of the find. Prior to construction Prior to and during construction City of Moorpark 206 Resolution No. 2022-____ Page 18 In the absence of the Director, the Applicant shall so inform the City Manager. Additionally, all consulting Native American Tribal groups that requested notification of any unanticipated discovery of archaeological resources on the Project shall be notified appropriately. The Applicant-retained project archaeologist shall provide an assessment regarding the sensitivity of the discovery and, if avoidance is not feasible, recommend the appropriate treatment and/or recovery procedures for discovery. The Applicant shall pay for all costs associated with the investigation and, if required, the treatment and/or recovery of the discovery. MM CUL-2: At the completion of all ground- disturbing activities, the project archaeologist shall prepare an Archaeological Resources Monitoring Report summarizing all monitoring efforts and observations, as performed, and any and all prehistoric or historic archaeological finds as well as providing follow-up reports of any finds to the South-Central Coastal Information Center (SCCIC), as required. After construction After construction City of Moorpark 44) Land Use and Planning MITIGATION MONITORING AND REPORTING PROGRAM Mitigation Measure Implementation Phase Monitoring Phase Enforcement Agency MM LU-1: Install a signal at the intersection of Los Angeles Avenue and Montair Drive. Prior to issuance of Certificate of Occupancy for the building N/A City of Moorpark MM LU-2: Restrict the proposed driveway on Los Angeles Avenue between the existing facility and proposed facility to emergency vehicles only and design to accommodate emergency vehicle turning requirements. During operation N/A City of Moorpark 45) Transportation MITIGATION MONITORING AND REPORTING PROGRAM Mitigation Measure Implementation Phase Monitoring Phase Enforcement Agency MM TRA-1: Restrict the proposed driveway on Los Angeles Avenue between the existing facility and proposed facility to emergency vehicles only and design to accommodate emergency vehicle turning requirements. During operation For the first 5 years of operation City of Moorpark 207 Resolution No. 2022-____ Page 19 The Project will provide an employer-sponsored vanpool (CAPCOA T-11). At a minimum 12 percent of employees will need to participate in the vanpool program. The Project will implement the program, and costs for the employer could include the vehicles, labor costs of the driver, and other incentives for employee participation. The Project could select to implement this measure or other equivalent commuter trips reduction measure(s) that would achieve a similar VMT reduction, potential including but not limited to: • rideshare incentive programs, • ride matching services, • discounted transit expense program, • end of trip facilities, or • telecommuting/alternative work schedules. The Project will provide the City, on an annual basis, a report indicating the implementation measures used and the number and percentage of employees that participate in each of the programs to achieve the 12 percent participation rate. AGENCY AND DEPARTMENT CONDITIONS Landscaping, Lighting And Maintenance Requirements 46) Prior to or concurrently with the issuance of a Zoning Clearance, applicant shall provide affirmative votes to establish a Community Facilities District (CFD) for the continued maintenance of the landscaping along the Hwy 118 frontage area. Upon written request of City, applicant will advance amounts necessary to pay all costs and expenses of City to evaluate and structure any CFD or other financing mechanism, to the end that City will not be obligated to pay any costs related to the formation or implementation of any CFD or other financing mechanism. City staff shall meet with the applicant to establish a preliminary budget for such costs and will confer with applicant from time to time as to any necessary modifications to that budget. Any CFD may provide for the reimbursement to applicant of any advances by applicant for any costs incurred as provided immediately above, and any other costs incurred by applicant that are related to the District, such as the costs of legal counsel, special tax consultants, engineers, etc. Once the CFD has been established, the CFD area will be reviewed by the City to determine if the formation of additional easements will be required along the frontage. Any landscaping outside of the right-of-way must be within the CFD or an easement. [PRCS & CDD] 208 Resolution No. 2022-____ Page 20 City of Moorpark Public Works Department Conditions Engineering Division General Conditions 47) The applicant agrees not to protest the formation of an underground Utility Assessment District. [CDD & PW] 48) If any hazardous waste or material is encountered during the construction of this project, all work must be immediately stopped and the Ventura County Environmental Health Department, the Ventura County Fire Protection District, the Moorpark Police Department, and the Moorpark City Engineer and Public Works Director must be notified immediately. Work may not proceed until clearance has been issued by all of these agencies. [CDD, VCFPD, MPD, VCEHD & PW] Permit Specific Conditions 49) Prior to issuance of a grading permit, the applicant shall provide an Irrevocable Offer of Dedication to the City of an easement for the purpose of providing ingress/egress access, drainage and parking to the adjacent commercial/industrial properties. The City of Moorpark shall not assume any responsibility for the offered property or any improvements to the property until this action has been accepted by the City Council. If accepted by the City of Moorpark, this easement may be fully assignable to the adjacent property owners, as an easement appurtenant for parking, ingress/egress access purposes and all uses appurtenant thereto. The form of the Irrevocable Offer of Dedication and other required pertinent documents required to satisfy the above requirements must be to the satisfaction of the Community Development Director, City Engineer and Public Works Director and the City Attorney. [CDD, PW & CA] 50) All parking areas must be surfaced with asphalt, concrete, or other surface acceptable to the Community Development Director, City Engineer and Public Works Director, and must include adequate provisions for drainage, National Pollution Discharge Elimination System (NPDES) compliance, striping and appropriate wheel blocks, curbs, or posts in parking areas adjacent to landscaped areas. All parking, loading and common areas must be maintained at all times to ensure safe access and use by employees, public agencies and service vehicles. [CDD & PW] OPERATIONAL REQUIREMENTS (Commercial and Industrial) 51) Prior to or concurrently with the issuance of a Zoning Clearance for a Grading Permit, the applicant shall submit the construction phasing plan for approval by the Community Development Director and City Engineer and Public Works Director. Phasing shall avoid, to the extent possible, construction traffic impacts to existing 209 Resolution No. 2022-____ Page 21 adjacent residential, commercial, industrial areas, schools, parks and other city facilities, if any. [CDD & PW] LANDSCAPING, LIGHTING AND MAINTENANCE REQUIREMENTS 52) All landscaping must be maintained in a healthy and thriving condition, free of weeds, litter and debris. All paved surfaces: including, but not limited to, the parking area and aisles, drive-through lanes, on-site walkways must be maintained free of litter, debris and dirt. Walkways, parking areas and aisles and drive-through lanes must be swept, washed, or vacuumed regularly. When swept or washed, litter, debris and dirt must be trapped and collected to prevent entry to the storm drain system in accordance with NPDES requirements. [CDD & PW] ENGINEERING DIVISION 53) Prior to construction, applicant shall submit a construction traffic control plan for the review and approval of the City Engineer and Public Works Director. Traffic control plan shall include construction advisory speed limits, speed limit posting locations, and enforcement measures if needed. [PW] 54) The applicant and/or property owner shall provide verification to the City Engineer and Public Works Director that all on-site storm drains have been cleaned at least twice a year, once immediately prior to October 1st (the rainy season) and once in January. Additional cleaning may be required by the City Engineer and Public Works Director depending upon site and weather conditions. [PW] 55) Prior to any work being conducted within any State, County, or City right-of- way, the applicant shall obtain all necessary encroachment permits from the appropriate agencies and provide copies of these approved permits and the plans associated with the permits to the City Engineer and Public Works Director. [PW] 56) Reactive organic compounds, nitrogen oxides (ozone/smog precursor), and particulate matter (aerosols/dust) generated during construction operations must be minimized in accordance with the City of Moorpark standards and the standards of the Ventura County Air Pollution Control District (APCD). When an air pollution Health Advisory has been issued, construction equipment operations (including but not limited to grading, excavating, earthmoving, trenching, material hauling, and roadway construction) and related activities must cease in order to minimize associated air pollutant emissions. [PW & VCAPCD] 57) The applicant shall utilize all prudent and reasonable measures (including installation of a 6-foot-high chain link fence around the construction site(s) and/or provision of a full time licensed security guard) to prevent unauthorized persons from entering the work site at any time and to protect the public from accidents and injury. [PW] 210 Resolution No. 2022-____ Page 22 58) Prior to construction, the applicant shall post, in a conspicuous location, the construction hour limitations and make each construction trade aware of the construction hour limitations to the satisfaction of the City. [CDD & PW] 59) Prior to the issuance of a Grading Permit, the applicant shall post sufficient surety with the City, in a form acceptable to the City Engineer and Public Works Director, guaranteeing completion of all onsite and offsite improvements required by these Conditions of Approval and/or the Municipal Code including, but not limited to grading, street improvements, storm drain improvements, temporary and permanent Best Management Practice (BMP) for the control of non-point water discharges, landscaping, fencing, and bridges. Grading and improvements must be designed, bonded, and constructed as a single project. [PW] 60) Prior to the issuance of a Grading Permit, the applicant shall provide written proof to the City Engineer and Public Works Director that any and all wells that may exist or have existed within the project have been properly sealed, destroyed or abandoned per Ventura County Ordinance No. 2372 or Ordinance No. 3991 and per California Department of Conservation, Division of Oil, Gas, and Geothermal Resources requirements. [PW] 61) Written weekly progress reports and a grading completion report must be submitted to the City Engineer and Public Works Director by the project geotechnical engineers. These reports must include the results and locations of all compaction tests, as-built plans of all landslide repairs and fill removal, including geologic mapping of the exposed geology of all excavations showing cut cross- sections and sub-drain depths and locations. The lists of excavations approved by the engineering geologist must also be submitted. Building permits will not be issued without documentation that the grading and other pertinent work has been performed in accordance with the geotechnical report criteria and applicable Grading Ordinance provisions. [PW] 62) Temporary irrigation, hydroseeding and erosion control measures, approved by the Community Development Director, City Engineer and Public Works Director, must be implemented on all temporary grading. Temporary grading is defined to be any grading partially completed and any disturbance of existing natural conditions due to construction activity. These measures will apply to a temporary or permanent grading activity that remains or is anticipated to remain unfinished or undisturbed in its altered condition for a period of time greater than thirty (30) calendar days except that during the rainy season (October 1 to April 15), these measures will be implemented immediately. [CDD & PW] 63) Grading may occur during the rainy season from October 1 to April 15, subject to timely installation of erosion control facilities when approved in writing by the City Engineer, Public Works Director and the Community Development Director and when erosion control measures are in place. In order to start or continue grading 211 Resolution No. 2022-____ Page 23 operations between October 1 and April 15, project-specific erosion control plans that provide detailed Best Management Practices for erosion control during the rainy season must be submitted to the City Engineer and Public Works Director no later than September 1 of each year that grading is in progress. During site preparation and construction, the contractor shall minimize disturbance of natural groundcover on the project site until such activity is required for grading and construction purposes. During the rainy season, October 1 through April 15, all graded slopes must be covered with a woven artificial covering immediately after completion of each graded slope. Grading operations must cease if the applicant fails to place effective best management measures on graded slopes immediately after construction. No slopes may be graded or otherwise created when the National Weather Service local three-day forecast for rain is twenty percent (20%), or greater, unless the applicant is prepared to cover the permanent and temporary slopes before the rain event. The artificial covering and planting will be to the satisfaction of the Community Development Director, City Engineer, and Public Works Director. [CDD & PW] 64) Prior to construction, the applicant shall comply with the City of Moorpark standard requirements for dust control, including, but not be limited to, minimization of ground disturbance, application of water/chemicals, temporary/permanent ground cover/seeding, street sweeping, and covering loads of dirt for the review and approval of the City Engineer and Public Works Director. All clearing, grading, earth moving, excavation, soil import and/or soil export operations must cease during periods of high winds (greater than 15 mph averaged over one hour). [PW] 65) At least one (1) week prior to commencement of grading or construction, the applicant shall prepare a notice that grading or construction work will commence. This notice shall be posted at the site and mailed to all owners and occupants of property within five-hundred feet (500') of the exterior boundary of the project site, as shown on the latest equalized assessment roll. The notice must include current contact information for the applicant, including all persons with authority to indicate and implement corrective action in their area of responsibility, including the name of the contact responsible for maintaining the list. The names of individuals responsible for noise and litter control, tree protection, construction traffic and vehicles, erosion control, and the twenty-four (24) hour emergency number, must be expressly identified in the notice. The notice must be re-issued with each phase of major grading and construction activity. A copy of all notices must be concurrently transmitted to the Community Development Department. The notice record for the City must be accompanied by a list of the names and addresses of the property owners notified and a map identifying the notification area. [CDD & PW] 66) Applicant has full right to exercise the service of a new engineer in charge at any time during a project. When there is a change in engineer, the applicant/owner shall notify the City Engineer and Public Works Director in writing within 48 hours 212 Resolution No. 2022-____ Page 24 of such change. Said letter shall specify successor California Registered Civil Engineer and shall be stamped and signed and dated by said engineer in responsible charge and shall accept responsibility of project. The letter will be kept on file at the City. [PW] 67) Prior to construction, applicant shall obtain an Encroachment Permit from Caltrans District 7 Office of Permits for all construction related activities on Los Angeles Avenue (State Highway 118). This includes, but is not limited to, construction traffic control plan and phasing, detours, temporary construction improvements such as stabilized entrances, and placement of stormwater BMPs. [PW] 68) Prior to issuance of a Grading Permit: a) Applicant shall coordinate with Caltrans District 7 Office of Permits for any State requirements for construction related activities, such as, but not limited to, site improvements, grading operations, storm water pollution prevention BMPs, traffic control, etc., that may impact Los Angeles Avenue (State Highway 118). If Caltrans Office of Permit has determined that an Encroachment Permit is required for construction related activities, applicant shall obtain a Caltrans Encroachment Permit prior to issuance of a Grading Permit. b) All offsite street improvements, including but not be limited to, utility improvements, drainage infrastructure improvements, sanitary sewer and domestic water improvements, and signage and striping improvements, within State right-of-way (Los Angeles Avenue) will require review and approval by Caltrans District 7 Office of Permits. A separate Caltrans Encroachment Permit may be required for all improvements within State right-of-way. [PW] 69) Prior to Grading Permit issuance, all domestic water and sanitary sewer improvements shall be reviewed and approved by Ventura County Waterworks District No. 1. [PW] 70) Prior to Grading Permit issuance, site access and fire hydrant locations shall be reviewed and approved by the Ventura County Fire Department. [PW] 71) Prior to Building Permit issuance, any existing sub-surface septic systems shall be removed. [PW] 72) All other requirements, notes and regulations arising from plan review as determined necessary by the City and their reviewers shall be incorporated into the design as the need arises during plan review. [PW] 73) Prior to construction, existing utility points of connection shall be potholed to verify location and elevation. [PW] 213 Resolution No. 2022-____ Page 25 74) The applicant shall be responsible for identifying all easements and related encumbrances on the project plans and related documents and ensuring that all such easements and encumbrances are not impeded, burdened, and are adequately maintained in accordance with the terms and language of the original easement. Determination of such compliance shall be subject to the City of Moorpark Public Works approval. [PW] 75) Permanent construction within easement extents shall require approval from easement owners. Proof of approval from easement owners shall be provided prior to grading plan approval. [PW] 76) Grading operations involving the hauling of dirt shall be controlled and reasonable efforts to avoid the spillage of dirt onto Public Streets shall be enforced. The grading contractor shall maintain on site at all times a means of preventing blowing dust within the project site and onto adjacent sites. [PW] 77) Any deviations from the approved grading plan must be reviewed and approved in advance by the Public Works Department. The City Engineer may issue a Stop Work Order Notice if field conditions deviate from the approved plans without obtaining prior approval from all the appropriate City Departments. [PW] 78) The project’s primary access is from Montair Drive through the private property that is adjoining to the west. A new access easement and agreement will be required from the adjoining property to the west for continuous access from Los Angeles Avenue and Montair Drive. The proposed, new access easement and agreement shall be reviewed by the City Engineer. GRADING AND GEOTECHNICAL 79) The applicant shall submit Precise Grading Plans, prepared by a California Registered Civil Engineer, detailing the design of finished surfaces including parking lot pavement, curbs, curb and gutter, local depressions, sidewalks disabled access parking, ramps, connections to public right of way and disabled access circulation within the site. The plans should include design grades for proposed buildings, including pad and finished floor elevations, required over- excavations cut/fill slopes, keyways, subdrains, limits and details of any required remedial grading. Required retaining walls shall be detailed with top of wall/top of footing callouts every 25 to 50 feet, related finished grades at the top of walls, and details of provisions for subdrains and connections to approved points of disposal. Precise Grading Plans shall be submitted to the City of Moorpark Public Works Department for review and approval prior to the issuance of a Grading Permit. [PW] 80) The applicant shall submit a design level Geotechnical Report prepared by a Geotechnical Engineer and Engineering Geologist. The Geotechnical Report shall 214 Resolution No. 2022-____ Page 26 provide specific recommendations for cut/fill slopes, foundations, retaining walls, temporary excavations, utility trenches, by the proposed development. The report shall present detailed geotechnical recommendations for design and construction of the proposed project and improvements, as well as mitigation of known geologic hazards. The Geotechnical Report shall be prepared in accordance with the County of Ventura standards and shall be submitted to the City of Moorpark Public Works Department for review and approval prior to the issuance of a Grading Permit. [PW] 81) All pavement structural sections shall be designed by the project Geotechnical Engineer and Engineering Geologist and submitted in conjunction with the final geotechnical report for review and approval by the City of Moorpark Public Works Department prior to the issuance of a Grading Permit. [PW] 82) All slopes shall be 2:1 (horizontal to vertical) or less in accordance with the approved geotechnical studies. [PW] 83) The applicant shall provide for the mitigation of the potential for liquefaction and lateral spreading based on the recommendations in the project Geotechnical Report. Liquefaction mitigation measures shall be submitted to the City of Moorpark Public Works Department for review and approval prior to the issuance of a Grading Permit. [PW] 84) The applicant shall eliminate or remediate all geologic hazards associated with this proposed development to the satisfaction of the City of Moorpark Public Works Department. [PW] 85) During grading, the project geotechnical engineer shall observe and approve all keyway excavations, removal of fill and landslide materials down to stable bedrock or in-place material, and installation of all sub-drains including their connections. All fill slope construction must be observed and tested by the project geotechnical engineer, and the density test results and reports submitted to the City Engineer and Public Works Director to be kept on file. Cuts and slopes must be observed and mapped by the project geotechnical and civil engineers who will provide any required slope modification recommendations based on the actual geologic conditions encountered during grading. Written approval from the City Engineer and Public Works Director must be obtained prior to any modification. [PW] 86) The applicant agrees to address and mitigate any and all engineering and geotechnical design and construction issues not contained within these conditions, associated with the proposed development that may arise during final design. [PW] 87) The applicant shall provide a current copy of the preliminary title report (dated within the last ninety (90) days), for the subject property. [PW] 215 Resolution No. 2022-____ Page 27 88) The applicant’s engineer shall plot all referenced easements on the site plans and grading plans. All existing and proposed easements shall be reflected on the project plans. [PW] 89) Prior to any Grading Permit issuance, offsite construction agreements shall be obtained from adjacent property where construction for access is proposed. [PW] 90) Prior to any Grading Permit issuance, reciprocal access easement agreement from both properties shall be obtained for proposed access drive aisle between both properties. [PW] 91) Prior to grading permit issuance, proof that existing access easement aligns with proposed entrance from adjacent property shall be provided. If access easement does not align with proposed entrance, access easement shall be modified to address the proposed access alignment. [PW] 92) All grading and excavation shall be observed and documented by the project Geotechnical Engineer, who shall verify that the excavation, grading, subdrainage, backfill, compaction, and related operations are executed by the site construction personnel in conformance with the provisions of the approved Geotechnical Report. Any deficiencies noted shall be brought to the attention of the grading contractor and the City. Such observations, verifications, related tests, and other pertinent documentation shall be submitted to the City of Moorpark Public Works and Community Development Departments for review and approval prior to the issuance of a Building Permit. [PW] 93) Rough Grade Report. At the completion of rough grading, the project Geotechnical Engineer shall submit a comprehensive rough grade report summarizing the required observations, verifications, related tests, and other pertinent documentation to the City of Moorpark Public Works and Community Development Departments for review and approval prior to the issuance of a Building Permit. [PW] 94) Rough Grade and Building Pad Certifications. Upon completion of rough grading, the applicant shall submit Rough Grade and Building Pad Certifications on the City’s forms. The certifications shall be signed by the project Geotechnical Engineer and project Civil Engineer, as well as the Grading Contractor. The certification shall be accompanied by as-built survey where deemed necessary by the City Engineer to verify compliance with the limits and elevations required by the approved grading and drainage plans. The Rough Grade and Building Pad Certifications shall be reviewed in conjunction with the Rough Grade Report by the City of Moorpark Public Works Department for approval prior to the issuance of a Building Permit. [PW] 95) Approval of Rough Grading. The project Rough Grade Report and Rough Grade and Building Pad Certifications shall be reviewed and approved by the City 216 Resolution No. 2022-____ Page 28 Engineer. Evidence of such approval shall be provided to the Community Development Department, Building and Safety Division, prior to the issuance of a Building Permit. No Building Permit shall be issued for the project without these approvals. [PW] 96) Final Grade Certification. Prior to the issuance of a Certificate of Occupancy (C of O), the applicant shall submit a Final Grade Certification on the City’s form. The Final Grade Certification shall be reviewed and approved by the City Engineer prior to the issuance of a C of O for the project. [PW] PUBLIC AND PRIVATE STREETS AND RELATED IMPROVEMENTS 97) Prior to construction of any public improvement, the applicant shall submit to the City Engineer and Public Works Director, for review and approval, street improvement plans prepared by a California Registered Civil Engineer, and enter into an agreement with the City of Moorpark to complete public improvements, with sufficient surety posted to guarantee the complete construction of all improvements, except as specifically noted in these Standard Conditions or Special Conditions of Approval. [PW] 98) Intentionally omitted. 99) Prior to final inspection of improvements, the project Registered Civil Engineer shall submit certified original "record drawing" plans with three (3) sets of paper prints and the appropriate plan revision review fees to the City Engineer and Public Works Director along with electronic files in a format satisfactory to the City Engineer and Public Works Director. These "record drawing" plans must incorporate all plan revisions and all construction deviations from the approved plans and revisions thereto. The plans must be "record drawings" on 24" X 36" Mylar® sheets (made with proper overlaps) with a City title block on each sheet. In addition, the applicant shall provide an electronic file update of the City's Master Base Map electronic file, incorporating all streets, sidewalks, streetlights, traffic control facilities, street striping, signage and delineation, storm drainage facilities, water and sewer mains, lines and appurtenances and any other utility facility installed for this project. [PW] 100) Prior to reduction of improvement bonds, the applicant must submit reproducible centerline tie sheets on 3-mil polyester film to the City Engineer and Public Works Director. [PW] 101) Prior to Grading Permit Issuance, all street dedications and vacations shall be reviewed for technical correctness and acceptance by the City. [PW] 102) The applicant shall submit Street Improvement Plans, prepared by a California Registered Civil Engineer, detailing the design of frontage improvements including curb, gutter, sidewalk, roadway pavement, drainage, signage, striping, utilities and 217 Resolution No. 2022-____ Page 29 other improvements. Plans shall include designs and details of existing and proposed sidewalk and driveway transitions compliant with the Americans with Disabilities Act (ADA) as well as disabled access provisions as contained in the latest edition of the California Building Code (CBC), as amended by the County of Ventura and the City of Moorpark. Sidewalk and driveway transitions occurring within Caltrans right of way shall comply with the requirements of DIB 82-06 or latest edition per Caltrans District 7 Office of Permits. Driveways and related transitions and connections to Los Angeles Avenue (State Highway 118) shall be designed in accordance with requirements of the project traffic study and Caltrans geometric requirements and standards to accommodate design vehicles, associated turning movements, and required turn lanes. Any existing frontage improvements (sidewalk, driveway(s), clearances around above-ground utility poles, utility boxes, etc.) shall be reviewed and upgraded as necessary to comply with disabled accessibility standards. Street Improvement Plans shall be submitted to the City Engineer and Public Works Director for review and approval prior to the issuance of a Grading Permit. [PW] 103) Applicant shall provide street improvements for Montair Drive. Street improvements shall include, at minimum, full width street pavement, curb and gutter, curb ramps, and drainage facilities. Street improvements shall comply with Ventura County Road Standards. [PW] 104) The applicant shall provide plans detailing the design of the horizontal and vertical alignment for the project’s access driveways and vehicle circulation to the satisfaction of the County of Ventura Fire Department and City of Moorpark Public Works Department. Such design shall utilize standards for vertical curve, sight distance and turning movement design consistent with County of Ventura, AASHTO and City of Moorpark design requirements. Design plans shall be submitted to the City of Moorpark Public Works Department for review and approval prior to the issuance of a Grading Permit. [PW] 105) Proposed driveway(s) in Caltrans right of way shall be in compliance with Standard Plans and Specifications for Public Works Construction and Caltrans Design Information Bulletin (DIB) 82-06 or latest edition as required by Caltrans District 7 Office of Permits. [PW] 106) Prior to any Grading Permit issuance, the applicant shall obtain approval and/or permit, if applicable, from Ventura County Watershed Protection District (VCWPD) for proposed driveway to Los Angeles Avenue and related modifications to Gabbert Canyon Channel. [PW] 107) Prior to Grading Permit issuance, applicant shall submit structural plans and calculations for proposed vehicular access over Gabbert Canyon Channel. Driveway access and associated Gabbert Canyon Channel improvements shall be designed to accommodate HS-20 loading, as well as any hydrodynamic forces associated with the analysis of Gabbert Canyon Channel culvert modifications. 218 Resolution No. 2022-____ Page 30 Structural and hydraulic analysis shall be reviewed and approved by VCWPD and the City of Moorpark Public Works Department. [PW] 108) Prior to grading permit issuance, applicant shall obtain approval from Caltrans District 7 Office of Permits for new driveway access and public improvements on Los Angeles Avenue (State Highway 118). Los Angeles Avenue (Highway 118) has been designated as an Expressway. Existing and new vehicular access connections and related improvements to Los Angeles Avenue shall conform to Caltrans’ Office of Permits requirements and standards. [PW] 109) Applicant shall construct curb and gutter along the property frontage on Los Angeles Avenue. Curb and gutter alignment shall be aligned and coordinated with adjacent property, unless otherwise required by Caltrans District 7 Office of Permits. a) Drainage report shall include analysis of flow patterns along Los Angeles Ave project frontage. Drainage improvements shall be provided, as necessary, to mitigate excessive pavement ponding and maintain any required dry lane width from added curb and gutter in Los Angeles Avenue travel lanes. 110) Applicant shall construct barrier to Gabbert Canyon Channel to the satisfaction of the City Engineer and Public Works Director. Improvements shall be coordinated with the adjacent property. a) Prior to Grading Permit issuance, approval from VCWPD shall be obtained for improvements to Gabbert Canyon Channel and within VCWPD easement. [PW] 111) Applicant shall construct 2” pipe at culvert for future irrigation along the frontage of Los Angeles Avenue to the satisfaction of the City Engineer and Public Works Director. [PW] 112) Proposed traffic signal at Montair Drive/Los Angeles Avenue shall be reviewed and approved by Caltrans District 7. Associated intersection improvements for the proposed traffic signal, including but not limited to signing and striping improvements, curb and gutter, roadway widening, and drainage improvements, shall be reviewed by Caltrans and City of Moorpark. DRAINAGE AND HYDROLOGY 113) Prior to approval of a grading plan, the applicant shall submit a drainage plan with calculations that analyze conditions before and after development, as well as potential development proposed, approved, or shown in the General Plan for the review and approval of the City Engineer and Public Works Director. Quantities of water, water flow rates, major watercourses, drainage areas and patterns, 219 Resolution No. 2022-____ Page 31 diversions, collection systems, flood hazard areas, sumps, sump locations, detention and NPDES facilities and drainage courses must be addressed. [PW] 114) Hydrology calculations must be per current VCWPD Agency Standards and to the satisfaction of the City Engineer and Public Works Director. [PW] 115) All storm water detention, retention, and impoundment facilities shall provide access for maintenance purposes. This includes, but is not limited to, maintenance access roads, vehicle and/or man gates, and adequate space to maneuver equipment. [PW] 116) Provide a complete Hydrology and Hydraulic Report for the entire development. This includes all technical analysis for storm water impoundment and conveyance facilities, peak flow mitigation analysis, storm water runoff calculations, and facility sizing design requirements. If the improvements are to be phased, any interim drainage condition shall be considered as part of the proposed improvements. [PW] 117) If drainage is conveyed to adjacent properties, additional easements and/or approvals may be required. [PW] 118) The applicant’s engineer shall provide for the interception of tributary areas of offsite drainage to maintain existing drainage patterns for adjacent properties. Onsite storm drain systems shall be designed to accommodate the interception and associated conveyance of such tributary offsite drainage to the satisfaction of the City Engineer and Public Works Director. [PW] 119) The applicant shall submit a Project Drainage Report, prepared by a California Registered Civil Engineer, to address existing and proposed hydrology, including offsite flow patterns which currently influence the project site. Report shall address developed hydrology associated with the site development, based on the provisions of the Ventura County Hydrology Manual and associated methodology, addressing both 10-year and 100-year existing and proposed drainage conditions, including provisions for the interception and conveyance of the 10-year design storm and flood hazards associated with the 100-year storm. Calculations for the mitigation of increased stormwater runoff shall be provided to support on-site detention facility sizing. Calculations shall address the detailing and sizing of area drains, catch basins and storm drain laterals on site, and shall be coordinated with the project Storm Drain Plans. The Project Drainage Report shall be submitted to the City of Moorpark Public Works Department for review and approval prior to the issuance of a Grading Permit. 120) The applicant’s engineer shall provide for detention of on-site storm drainage, based on either offsite storm drain capacity limitations or a ‘no net increase’ approach, whichever yields the greater volume or required detention. In either case 220 Resolution No. 2022-____ Page 32 the required volume shall be calculated by unit hydrograph or other approved means. Such calculations shall be included in the Project Drainage Report. 121) Unless specifically approved by the City of Moorpark, the on-site storm drain system shall be privately owned and maintained. Storm drain plans shall clarify that the on-site storm drain system is not to be maintained by either the City of Moorpark or the VCWPD. 122) Prior to any Grading Permit issuance, the applicant shall obtain approval and/or permit, if applicable, from VCWPD for any storm water connection(s) and discharges into the Gabbert Canyon Channel. Any requirements for storm drain connection, including pipe size, type, allowable flow and associated detention shall be coordinated with the project plans and incorporated in the project drainage report. [PW] 123) Prior to Grading Permit issuance, applicant shall provide hydraulic analysis of Gabbert Canyon Channel relative to proposed culvert at driveway access. Culvert shall be sized to provide sufficient freeboard as required by VCWPD, as well as associated improvements deemed appropriate by the District to address hydraulic transitions, channel stability and design of culvert inlet and outlet structures. [PW] NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) 124) Prior to the start of grading or any ground disturbance, the applicant shall identify a responsible person experienced in NPDES compliance who is acceptable to the City Engineer and Public Works Director. The designated NPDES person (superintendent) shall be present, on the project site Monday through Friday and on all other days when the probability of rain is forty percent (40%) or greater and prior to the start of and during all grading or clearing operations until the release of grading bonds. The superintendent shall have full authority to rent equipment and purchase materials to the extent needed to effectuate Best Management Practices. The superintendent shall be required to assume NPDES compliance during the construction of streets, storm drainage systems, all utilities, buildings, and final landscaping of the site. [PW] 125) Development shall conform to the current requirements for the County’s MS4 permit for new developments. [PW] 126) All storm water facilities shall conform to the most current Ventura County Technical Guidance Manual for Storm Water Quality Control Measures. This includes all HOA and Facilities District maintained storm water quality facilities. [PW] 127) In-tract improvements shall incorporate Low Impact Development standards. [PW] 221 Resolution No. 2022-____ Page 33 128) A State Storm Water Pollution Prevention Plan is required for all ground disturbing activities that are greater than one acre. Prior to Grading Permit issuance, a Notice of Intent (NOI) and the SWPPP shall be filed with the State Water Resources Control Board, and a Waste Discharger Identification (WDID) number and Construction General Permit must be obtained. [PW] 129) Development shall conform to the current requirements for the County’s MS4 permit for new developments. The applicant’s engineer shall design required water quality mitigation features and related storm water mitigation volumes (Qpm) in accordance with the Ventura County Technical Guidance Manual for Stormwater Quality Control Measures, NPDES and City requirements. Calculations shall be submitted with the Project Drainage Report. All covenants shall be submitted to the City of Moorpark Public Works Department for review and approval and be recorded prior to Grading Permit issuance. [PW] 130) The applicant’s engineer shall provide for the mitigation of the project’s storm water quality impacts. The applicant’s engineer shall provide calculations for the sizing and location of devices intended to mitigate such impacts and coordinate the locations of required water quality treatment devices on the Storm Drain Plans. The details of the required devices shall be included in the Project Drainage Report and detailed on the project plans. [PW] 131) Prior to the issuance of any construction/Grading Permit and/or the commencement of any qualifying, grading or excavation, the applicant for projects with facilities identified as subject to the State Board General Industrial and Commercial permits shall prepare and submit a Stormwater Pollution Prevention Plan (SWPPP). The SWPPP must address post-construction compliance with stormwater quality management regulations for the project. The SWPPP, improvement plans and grading plans must note that the contractor shall comply with the latest edition of the California Best Management Practices New Development and Redevelopment Handbook, published by the California Stormwater Quality Association. The SWPPP must comply with the Ventura Countywide Stormwater Quality Management Program Land Development Guidelines, Technical Guidance Manual for Stormwater Quality Control Measures, and the Stormwater Management Program (SMP) to develop, achieve, and implement a timely, comprehensive, cost effective stormwater pollution control program to reduce pollutants to the maximum extent practicable. The SWPPP must be prepared in compliance with the form and format established in the Ventura Countywide Stormwater Quality Management Program, and submitted, with appropriate review deposits, for the review and approval of the City Engineer/Public Works Director. The proposed plan must also address all relevant NPDES requirements, maintenance measures, estimated life spans of Best Management Practices facilities, operational recommendations and recommendations for specific Best Management Practices technology, including all related costs. The use of permanent dense ground cover planting approved by the City Engineer/Public Works Director and Community Development Director is 222 Resolution No. 2022-____ Page 34 required for all graded slopes. Methods of protecting the planted slopes from damage must be identified. Proposed management efforts during the lifetime of the project must include best available technology. “Passive” and “natural” BMP drainage facilities are to be provided such that surface flows are intercepted and treated on the surface over biofilters (grassy swales), infiltration areas and other similar solutions. The use of filters, separators, clarifiers, absorbents, adsorbents or similar “active” devices is not acceptable and may not be used without specific prior approval of the City Council. The use of biological filtering, bio-remediation, infiltration of pre-filtered stormwater and similar measures that operate without annual maintenance intervention, that are failsafe, that, when maintenance is needed, will present the need for maintenance in an obvious fashion and which will be maintainable in a cost effective and non-disruptive fashion is required. As deemed appropriate for each project, the SWPPP must establish a continuing program of monitoring, operating and maintenance to: a) Provide discharge quality monitoring. b) Assess impacts to receiving water quality resulting from discharged waters. c) Identify site pollutant sources. d) Educate management, maintenance personnel and users, to obtain user awareness and compliance with NPDES goals. e) Measure management program effectiveness. f) Investigate and implement improved BMP strategies. g) Maintain, replace and upgrade BMP facilities (establish BMP facility inspection standards and clear guidelines for maintenance and replacement). h) Secure the funding, in perpetuity, to achieve items “a” through “g” above. [PW] Solid Waste 132) Prior to issuance of a construction permit, the applicant shall provide a Recycling Bin Plan for the review and approval of the City's Solid Waste Management staff. Bins must be labeled with "Recycling Only" and bins containing mixed material must be sent to a State-approved recycling center or transfer station where the material is to be sorted for proper recycling. Applicant will also be required to divert 65% of all non-hazardous construction materials from landfill. [SWM] 133) Space must be provided in the trash enclosure for the storage of containers for recycling, green waste and at least one additional 95-gallon food waste bins to satisfaction of the City's Solid Waste Management staff. Alternatively, a separate enclosure must be provided depending on the anticipated volumes of recyclable and green or organic waste material. [SWM] 134) Prior to issuance of a building permit, the applicant shall submit a Construction and Demolition Materials Management Plan Estimate for the review and approval of the City's Solid Waste Management staff and Building and Safety Division for recycling of waste materials consistent with the aforementioned requirement. The 223 Resolution No. 2022-____ Page 35 Plan must include estimated quantities for each type of material to be diverted or landfilled. [SWM] 135) Prior to final inspection, the applicant must submit a Final Report Construction and Demolition Waste Letter of Documentation (including premium gate tickets) to the Building and Safety Division, demonstrating compliance with the Construction and Demolition Materials Management Plan Estimate and indicate the total amount of construction and demolition waste diverted. [SWM] 136) Prior to issuance of a zoning clearance for a building permit, the applicant shall provide a trash enclosure plan for the review and approval of the City's Solid Waste Management staff and Community Development Director. Trash enclosure must include a solid-screen gate with a solid roof design to match building and be of sufficient size to accommodate appropriate trash bins. [SWM] Moorpark Police Department 137) Prior to issuance of a zoning clearance for building permit, a security plan shall be reviewed and approved by the Moorpark Police Department. Security plan shall include exterior access doors that have viewport windows. [MPD] 138) Prior to issuance of a certificate of occupancy, the applicant shall provide a video surveillance camera plan for common areas and will be subject to the review and approval of the Moorpark Police Department. Cameras shall also be registered with the Ventura County Sheriff’s Office Video Surveillance Camera Registration Program. [MPD] 139) Trash enclosures shall be secured with a durable latch system. [MPD] Ventura County Waterworks District No. 1 Conditions 140) Prior to the issuance of a Signed Agreement to Install Water and Sewer Improvements the Applicant shall provide Ventura County Waterworks District with the following: a) Water and sewer improvement plans prepared in accordance with District standards. i) No structures or trees shall be constructed within the District’s existing easements. ii) Proposed sewer main shall extend along the entire length of parcel for future development. b) Hydraulic analysis by a registered Civil Engineer to determine the adequacy of the proposed and existing water and sewer lines to determine the extent of capital improvements to the existing water and sewer facilities to serve the subject properties. 224 Resolution No. 2022-____ Page 36 c) Digital copies of the grading, street, and storm drain plans. d) A plan denoting the location of fire hydrants and copy of approvals by the Ventura County Fire Protection District for fire hydrant locations. e) Cost estimates for water and sewer improvements. f) Plan check deposit, construction inspection deposit, capital improvement charge, g) sewer connection fee, and meter charges per phase of the project as calculate by the District. h) Recorded easements dedicated to the District for water and sewer facility improvements as shown on the recorded tract map. Dedicated easements shall be over and across all streets and parking lots for access to maintain and repair of the District’s substructures and facilities. [VCWD1] 141) The District will provide “Will Serve Letters” upon completed review and acceptance of the water and sewer improvement plans and payment of applicable fees. [VCWD1] 142) Following the acceptance of the above items, Applicant is to provide Ventura County Waterworks District with 3 sets of the signed Agreement to Install improvements and Surety Bonds. Blank copies of the Agreement to Install and Surety Bond are available upon request. [VCWD1] Ventura County Air Pollution Control District 143) Prior to issuance of a grading permit, and to ensure that fugitive dust and particulate matter that may result from site preparation, construction and/or grading activities are reduced, the applicant shall comply with the provisions of applicable VCAPCD Rules and Regulations, which include, but are not limited to, Rule 50 (Opacity), Rule 51 (Nuisance), and Rule 55 (Fugitive Dust), and the Air Quality Assessment Guidelines. [VCAPCD] 144) Prior to issuance of a grading permit, and to ensure that ozone precursor and particulate emissions from diesel-powered mobile construction equipment are reduced to the greatest amount feasible, the applicant shall comply with the provisions of all applicable California State Laws and APCD Rules and Regulations, and the Air Quality Assessment Guidelines regarding portable construction equipment and construction vehicles. [VCAPCD] Ventura County Watershed Protection District 145) Prior to obtaining a grading permit, the applicant shall obtain a watercourse/encroachment permit issued by the Ventura County Watershed Protection District. [VCWPD] 146) Prior to issuance of a Zoning Clearance, the applicant shall sign a VCPWA-WP instrument to not oppose membership of a future special assessment district which 225 Resolution No. 2022-____ Page 37 will collect fees to pay for the reconstruction, replacement, repair, or rehabilitation of the Gabbert/Walnut Canyon drainage system which serves the property and has known deficiencies. [VCWPD] 147) Prior to zoning clearance, the applicant shall record a VCPWA-WP legal instrument (document, deed, covenant, or other) on the property title which will hold VCPWA-WP harmless for any flood damage that may occur, effective until the Project’s channel connections are completed and accepted by VCPWA-WP. [VCWPD] 148) Prior to obtaining a grading permit, the applicant shall provide a drainage study that shows adequate mitigation measures will be implemented to prevent negative impacts to Gabbert/Walnut Canyon channels due to increased site imperviousness and resultant stormwater runoff. [VCWPD] Ventura County Fire Department 149) Fire Department Clearance (Submit prior to Building & Safety approval) - Applicant shall obtain VCFD Form #610 "Fire Permit Application” and Form #625 “Fire Flow Verification” prior to obtaining a building permit for any new structures or additions to existing structures. [VCFPD] 150) Water System Plans (Submit prior to Building & Safety approval) - Plans for water systems supplying fire hydrants and / or fire sprinkler systems and not located within a water purveyor’s easement, shall be submitted to the Fire District for review and approval prior to issuance of grading and/or building permits or signing of Mylar plans, whichever is first. Plans shall reflect only dedicated private fire service lines and associated appurtenances. Plan shall be design and submitted with the appropriate fees in accordance with VCFPD Standard 14.7.2. [VCFPD] 151) Fire Lanes / Access Review (Submit prior to Building & Safety approval) - the applicant shall submit two (2) site plans to the Fire District for review and approval of Access and location of fire lanes. Prior to occupancy, all fire lanes shall be posted “NO PARKING-FIRE LANE-TOW AWAY” in accordance with California Vehicle Code, the International Fire Code and current VCFPD Fire Lane Standards. All signs and or Fire Lane markings shall be within recorded access easements. [VCFPD] 152) Access Covenant (Submit prior to Building & Safety approval) - A covenant and deed restriction upon parcels 511-0-200-175 & Flood Control Channel Easement shall be recorded at the time of map recordation and a copy of the record document shall be provided to the Fire District within (7) days of recordation. This covenant shall require upon the sale of any of these parcels, a reciprocal access easement be recorded on all parcels who share the access road / driveway / secondary access. This easement shall allow for an access road / driveway meeting all Ventura County Fire Protection District access standards and shall be approved by the Ventura County Fire Protection District prior to recordation. Access 226 Resolution No. 2022-____ Page 38 Covenant to include new proposed primary access across County Flood Control to Los Angeles Avenue, and secondary access through Montair Drive. [VCFPD] 153) State Fire Safe Regulations - The project is located within a Local Responsibility Area (LRA) Very High Fire Severity Zone (VHFHSZ) and shall comply with the minimum standards of the California Code of Regulations, Title 14, Division 1.5, Chapter 7, Article 6, Subchapter 2, “SRA/VHFHSZ Fire Safe Regulations” (CCR T-14 FSR), unless modified by more restrictive local ordinances and requirements. [VCFPD] 154) Access Road Width, Private Roads/Driveways - Private roads shall comply with Public Road Standards. 2.5-foot wide easements shall be provided on each side of any private access road/driveway to allow for curbs and fire lane signage. a) Access road width of 24 feet shall be required with no on-street parking permitted, or per Public Road Standards whichever is stricter. b) Aerial Ladder Fire Apparatus Access, Multi-Family, Commercial or Industrial Buildings or portions of buildings or facilities with perimeter eave lines exceeding 30 feet in height above the lowest level of fire department access shall require an approved aerial ladder fire apparatus access roads and driveways. Aerial fire apparatus access roads and driveways shall have a minimum clear width of 30 feet. Overhead utility and power lines shall not be located within the aerial ladder fire apparatus access roads and driveways. At least one of the required access routes meeting this condition shall be located a minimum of 15 feet and a maximum of 30 feet parallel to one side of the buildings, as approved by the Fire District. Buildings exceeding 50,000 SQFT shall have the required access route along a minimum of two sides. Parking shall be prohibited along the required width of the access roads and driveways. Landscaping and other improvements between the required access and the buildings shall not interfere with aerial ladder fire apparatus operations, as approved by the Fire District. [VCFPD] 155) Construction Access - Prior to combustible construction, a paved all-weather access road / driveway suitable for use by a 20-ton Fire District vehicle shall be installed at locations approved by the Fire District. [VCFPD] 156) Construction Access Utilities - Prior to combustible construction, all utilities located within the access road and the first lift of the access road pavement shall be installed. A minimum 20-foot clear width shall remain free of obstruction during any construction activities within the development once combustible construction starts. [VCFPD] 157) Site Access - Two (2) means of ingress/egress shall be provided to the development in accordance with Fire District access standards. [VCFPD] 227 Resolution No. 2022-____ Page 39 158) Access Road Gates - Any gates to control vehicle access are to be located to allow a vehicle waiting for entrance to be completely off the intersecting roadway. A minimum clear open width of 15 feet in each direction shall be provided for separate entry / exit gates and a minimum 20 for combined entry / exit gates. If gates are to be locked, a Knox system shall be installed. The method of gate control, including operation during power failure (battery back-up), shall be subject to review by the Fire Prevention Division. Gate plan details shall be submitted to the Fire District for approval prior to installation. A final acceptance inspection by the Fire District is required prior to placing any gate into service. [VCFPD] 159) Address Numbers (Commercial, Industrial, Multi-family buildings) - Building address numbers, a minimum of ten inches (10") high, shall be installed prior to occupancy, shall be of contrasting color to the background, and shall be readily visible at night. Brass or gold-plated numbers shall not be used. Where structures are set back more than 150 feet from the street, larger numbers will be required so that they are distinguishable from the street. In the event a structure(s) is not visible from the street, the address number(s) shall be posted adjacent to the driveway entrance on an elevated post. Individual unit numbers shall be a minimum of 4 inches in height and shall be posted at the front and rear entrance to each unit. Additional address directional signs may be required at common building entrances and stairways. [VCFPD] 160) Fire Hydrant Plan - Prior to construction, the applicant shall submit plans to the Fire District for placement of fire hydrants. On plans, show existing hydrants within 500 feet of the development. Indicate the type of hydrant, number, and size of outlets. [VCFPD] 161) Fire Hydrant(s) Required - Fire hydrant(s) shall be provided in accordance with current adopted edition of the International Fire Code, Appendix C and adopted amendments. On-site fire hydrants may be required as determined by the Fire District. [VCFPD] 162) Fire Hydrant Design (Commercial, Industrial, Multi-family buildings) - Fire hydrants shall be installed and in service prior to combustible construction and shall conform to the minimum standard of the City of Moorpark Water Works Manual and the following. a) Each hydrant shall be a 6-inch wet barrel design and shall have (1) 4 inch and (2) 2 ½ inch outlet(s). b) The required fire flow shall be achieved at no less than 20-psi residual pressure. c) Fire hydrants shall be spaced 300 feet on center and so located that no structure will be farther than 150 feet from any one hydrant. d) Fire hydrants shall be set back in from the curb face 24 inches on center. e) No obstructions, including walls, trees, light and signposts, meter, shall be placed within three (3) feet of any hydrant. 228 Resolution No. 2022-____ Page 40 f) A concrete pad shall be installed extending 18 inches out from the fire hydrant. g) Ground clearance to the lowest operating nut shall be between 18 to 24 inches. [VCFPD] 163) Fire Hydrant Installation - Prior to combustible construction on any parcel, a fire hydrant capable of providing the required fire flow and duration shall be installed and in service along the access road / driveway at a location approved by the Fire District, but no further than 250 feet from the building site. The owner of the combustible construction is responsible for the cost of this installation. [VCFPD] 164) Hydrant Location Markers - Prior to occupancy of any structure, blue reflective hydrant location markers shall be placed on the access roads in accordance with Fire District standards. If the final asphalt cap is not in place at time of occupancy, hydrant location markers shall still be installed and shall be replaced when the final asphalt cap in completed. [VCFPD] 165) Fire Flow (Commercial, Industrial, Multi-family buildings) - The minimum fire flow required shall be determined as specified by the current adopted edition of the International Fire Code Appendix B with adopted Amendments and the applicable Water Manual for the jurisdiction (with ever is more restrictive). The applicant shall verify that the water purveyor can provide the required volume and duration at the project prior to obtaining a building permit. [VCFPD] 166) Fire Sprinklers - All structures shall be provided with an automatic fire sprinkler system in accordance with current VCFPD Ordinance at time of building permit application. [VCFPD] 167) Fire Protection System Plans - Plans for all fire protection systems (sprinklers, dry chemical, hood systems, etc.) shall be submitted, with payment for plan check, to the Fire District for review and approval prior to installation. Note: Fire sprinkler systems with 20 or more heads shall be supervised by a fire alarm system in accordance with Fire District requirements. [VCFPD] 168) Fire Alarm System - A fire alarm system shall be installed in all buildings in accordance with California Building and Fire Code requirements. [VCFPD] 169) Fire Alarm/Sprinkler Monitoring Plans - Plans for any fire alarm system or sprinkler monitoring system shall be submitted, with payment for plan check, to the Fire District for review and approval prior to installation. [VCFPD] 170) Fire Extinguishers - Fire extinguishers shall be installed in accordance with the International Fire Code. The placement of extinguishers shall be subject to review by the Fire District. [VCFPD] 171) Trash Dumpster Locations - Commercial trash dumpsters and containers with an individual capacity of 1.5 cubic yards or greater shall not be stored or placed within 229 Resolution No. 2022-____ Page 41 5 feet of openings, combustible walls, or combustible roof eave lines unless protected by approved automatic fire sprinklers. [VCFPD] 172) Hazardous Fire Area - Portions of this development may be in a Hazardous Watershed Fire Area and those structures shall meet hazardous fire area building code requirements. Contact the Building Department for requirements. [VCFPD] 173) Fuel Modification Zone and Landscape Plans - The developer shall provide Fuel Modification Zone (FMZ) and or Landscape plans prepared by a licensed landscape architect to VCFD for review and approval as follows: a) Tracts and multiple lot projects: Plans shall be submitted for approval before the start of construction. This includes slopes, common areas, and individual lot landscaping install by the developer. b) Individual Parcels: Plans shall be submitted for approval prior to installation and or modification of any vegetation / landscape. This includes owner installed landscaping after original purchase of a parcel or building from the developer. [VCFPD] 174) Fire Code Permits - Applicant and / or tenant shall obtain all applicable International Fire Code (IFC) permits prior to occupancy or use of any system or item requiring an IFC permit. [VCFPD] 230 Resolution No. 2022-____ Page 42 MITIGATION MONITORING AND REPORTING PROGRAM PENTAIR WAREHOUSE EXPANSION PROJECT MOORPARK, CALIFORNIA Prepared for: CITY OF MOORPARK 799 Moorpark Avenue Moorpark, California 93021 Prepared by: CHAMBERS GROUP, INC. 600 West Broadway, Suite 250 Glendale, California 91204 July 2022 EXHIBIT B 231 Resolution No. 2022-____ Page 43 MITIGATION MONITORING AND REPORTING PROGRAM Public Resources Code, Section 21081.6 (Assembly Bill 3180) requires that mitigation measures identified in environmental review documents prepared in accordance with California Environmental Quality Act (CEQA) are implemented after a project is approved. Therefore, this Mitigation Monitoring and Reporting Program (MMRP) has been prepared to ensure compliance with the adopted mitigation measures during the construction and operation phase of the Pentair Warehouse Expansion Project. The City of Moorpark is the agency responsible for implementation of the mitigation measures identified in the MND. This MMRP provides the City of Moorpark with a convenient mechanism for quickly reviewing all the mitigation measures including the ability to focus on select information such as timing. The MMRP includes the following information for each mitigation measure: • The phase of the project during which the required mitigation measure must be implemented; • The phase of the project during which the required mitigation measure must be monitored; and • The enforcement agency. The MMRP includes a checklist to be used during the mitigation monitoring period. The checklist will verify the name of the monitor, the date of the monitoring activity, and any related remarks for each mitigation measure. 232 Resolution No. 2022-____ Page 44 MITIGATION MONITORING AND REPORTING PROGRAM Pentair Warehouse Expansion Project Mitigation Measure Implementation Phase Monitoring Phase Enforcement Agency Level of Significance After Mitigation Verification of Compliance Initial Date Remarks Biological Resources MM BIO-1: A nesting bird pre-construction survey will be conducted by a Qualified Biologist and submitted to the City three days prior to demolition and/or vegetation removal activities during nesting bird season (February 1 through September 15). Should nesting birds be found, an exclusionary buffer will be established by a Qualified Biologist. The buffer may be up to 500 feet in diameter depending on the species of nesting bird found. This buffer will be clearly marked in the field by construction personnel under guidance of the Qualified Biologist, and construction or clearing will not be conducted within this zone until the Qualified Biologist determines that the young have fledged or the nest is no longer active. Nesting bird habitat within the Project site will be resurveyed during bird breeding season if a lapse in construction activities lasts longer than seven days. Prior to construction Prior to and during construction City of Moorpark Less than Significant MM BIO-2: To avoid direct mortality, a qualified biological monitor shall be on site prior to and during ground and habitat disturbing activities to move out of harm’s way special status species or other wildlife of low mobility that would be injured or killed by grubbing or Project-related construction activities. Salvaged wildlife of low mobility shall be removed and placed onto adjacent and suitable (i.e., species appropriate) habitat out of harm’s way. It shall be noted that the temporary relocation of on-site wildlife does not constitute effective mitigation for the purposes of offsetting Program impacts associated with habitat loss. Prior to and during construction Prior to and during construction City of Moorpark Less than Significant MM BIO-3: Grubbing shall be done to avoid islands of habitat where wildlife may take refuge and later be killed by heavy equipment. Grubbing shall be done from the center of the Project site, working outward towards adjacent habitat off site where wildlife may safety escape. If grading is scheduled to occur in phases, another round of grubbing would be required prior to the start of ground disturbance to allow wildlife that may be present in the center of the Project site to safely escape. During construction During construction City of Moorpark Less than Significant 233 Resolution No. 2022-____ Page 45 MITIGATION MONITORING AND REPORTING PROGRAM Pentair Warehouse Expansion Project Mitigation Measure Implementation Phase Monitoring Phase Enforcement Agency Level of Significance After Mitigation Verification of Compliance Initial Date Remarks Cultural Resources MM CUL-1: Prior to issuance of grading permits, the Applicant shall be required to obtain the services of a qualified project archaeologist to remain on call for the duration of the proposed ground-disturbing construction activity. The archaeologist selected must be approved in writing by the Community Development Director. Prior to construction commencing, all construction personnel associated with earth-moving equipment, drilling, grading, or excavating shall be provided with basic training. The training shall be completed by the Applicant-retained project archaeologist and shall include written notification of the restrictions regarding disturbance and/or removal of any portion of archaeological deposits and the procedures to follow should a potential resource be identified during construction activity. The construction contractor, or its designee, shall be responsible for implementation of this measure. A tribal monitor shall be provided an opportunity to attend the pre-construction briefing, if requested. The project archaeologist shall be on call and available to contact in the event of any unanticipated discovery of archaeological or historical resources during the proposed construction activity. If any archeological or historical resources are uncovered during grading or excavation operations, all grading or excavation shall immediately cease in the immediate area, a 50-foot buffer area around the discovery shall be cordoned off, and the discovery must be left untouched. The Applicant, in consultation with the project archaeologist, shall assure the preservation of the resource and immediately contact the Community Development Director by phone, in writing by email, or hand- delivered correspondence informing the Director of the find. In the absence of the Director, the Applicant shall so inform the City Manager. Additionally, all consulting Native American Tribal groups that requested notification of any unanticipated discovery of archaeological resources on the Project shall be notified appropriately. The Applicant-retained project archaeologist shall provide an assessment regarding the sensitivity of the discovery and, if avoidance is not feasible, recommend the appropriate treatment and/or recovery procedures for discovery. The Applicant shall pay for all costs associated with the investigation and, if required, the treatment and/or recovery of the discovery. Prior to construction Prior to and during construction City of Moorpark Less than Significant MM CUL-2: At the completion of all ground-disturbing activities, the project archaeologist shall prepare an Archaeological Resources Monitoring Report summarizing all monitoring efforts and observations, as performed, and any and all prehistoric or historic archaeological finds as well as providing follow-up reports of any finds to the South-Central Coastal Information Center (SCCIC), as required. After construction After construction City of Moorpark Less than Significant Land Use MM LU-1: Install a signal at the intersection of Los Angeles Avenue and Montair Drive Prior to issuance of Certificate of Occupancy for the building N/A City of Moorpark Less than Significant MM LU-2: Restrict the proposed driveway on Los Angeles Avenue between the existing facility and proposed facility to emergency vehicles only and design to accommodate emergency vehicle turning requirements During operation N/A City of Moorpark Less than Significant 234 Resolution No. 2022-____ Page 46 MITIGATION MONITORING AND REPORTING PROGRAM Pentair Warehouse Expansion Project Mitigation Measure Implementation Phase Monitoring Phase Enforcement Agency Level of Significance After Mitigation Verification of Compliance Initial Date Remarks Transportation MM TRA-1: The Project will provide an employer-sponsored vanpool (CAPCOA T- 11). At a minimum 12 percent of employees will need to participate in the vanpool program. The Project will implement the program, and costs for the employer could include the vehicles, labor costs of the driver, and other incentives for employee participation. The Project could select to implement this measure or other equivalent commuter trips reduction measure(s) that would achieve a similar VMT reduction, potential including but not limited to: • rideshare incentive programs, • ride matching services, • discounted transit expense program, • end of trip facilities, or • telecommuting/alternative work schedules. The Project will provide the City, on an annual basis, a report indicating the implementation measures used and the number and percentage of employees that participate in each of the programs to achieve the 12 percent participation rate. During operation For the first 5 years of operation City of Moorpark Less than Significant 235